California Regulatory Updates

May 1st 2018

When it comes to water loss control, California is moving fast. Only a few years ago, water loss control best practices were voluntary and often an afterthought. Now, water loss control best practices are mandated and evolving as California utilities reckon with leakage, meter performance, and water loss data, many for the first time.

Water loss reporting in California began with voluntary submissions coordinated by the California Urban Water Conservation Council (CUWCC). Signatories to CUWCC best management practices committed to publishing annual American Water Works Association water audits and completing a component analysis of real loss every four years. Some of California’s most progressive agencies signed on and upheld their annual reporting commitments, thereby exemplifying water loss management for peers, but the CUWCC dataset often contained inconsistent or implausible water audits and didn’t completely cover California. As a result, drawing conclusions about distribution efficiency from CUWCC data proved impossible.

Recognizing the importance of complete and frequent data in water loss management, the California State Senate passed Senate Bill 1420 in 2014 to require water audit submissions with urban water management plans submitted every five years. But Senate Bill 1420 didn’t address the quality of water audit data observed in previous voluntary submissions, so one year later the State Senate passed Senate Bill 555. Senate Bill 555 mandates annual level 1 validated water audit submissions. But Senate Bill 555 doesn’t stop at reporting – it also lays the groundwork for water loss performance standards.

To enact Senate Bill 555, the State Water Resources Control Board will have to publish water loss standards sometime between January 2019 and July 2020. The structure of those standards is not yet clear, but they will be informed by level 1 validated water audit submissions from 2017, 2018, and 2019. At the time of this post’s publication, the Board has indicated that neither data validity grades nor the infrastructure leakage index will be included in standards. Instead, water loss standards will be volumetric, and meaningful steps towards improving water audit data accuracy will be promoted. We’re involved in the water loss standards conversation and will offer technical support and the stories we’ve accumulated from our work throughout California, particularly in the Water Loss Technical Assistance Program.

But wait, there’s more! Leakage is also being debated as a component of retail water supplier budgets outlined in the implementation plan for Executive Order B-37-16. Executive Order B-37-16, “Making Water Conservation a California Way of Life,” aims to replace the 20 by 2020 conservation framework with a more customized, pervasive, and meaningful water efficiency plan. Whatever leakage component ends up in Executive Order B-37-16 implementation will have to dovetail with Senate Bill 555 standards, so we’re anticipating plenty of lively conversation on the subject as 2020 nears.

Lastly, and most recently, Assembly Bill 3206 was introduced into the California State Assembly. Assembly Bill 3206 would mandate specific customer meter accuracy and direct the State Water Resources Control Board to adopt requirements for regular and thorough customer meter testing, to be performed by utilities as a component of their water loss management program. Though we typically endorse customer meter testing, the devil is in the details (and in the surprisingly complicated statistics!), so we look forward to joining the conversation on Assembly Bill 3206’s merits and shortcomings.

With all this movement in the world of California water loss control, it’s easy to feel overwhelmed. We’re mostly excited but a little overwhelmed ourselves! We’ll keep you posted here on our blog and in our quarterly newsletter. If you’d like to stay abreast of water loss regulatory development, keep an eye out for our newsletter.

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