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Proposed BMP 3 - Problem #3
When Have You Spent Enough?
In Problem #1 we discussed how the leak detection “trigger” would change for the worse. In Problem #2 we discussed the lunacy of a water agency spending more money to conserve an acre-foot of “paper” water than of real water. Now we highlight the impossibility of complying with the “cost-effectiveness” standard of the proposed BMP 3.
First, an important aside: under the proposed BMP 3, your agency will have four years to gather very accurate data to put into your ILI calculation (see Problem #1). If your ILI is 3.0 or greater, you have six more years to bring it below 3 or prove that you have taken every action possible that costs less than the water that would be saved, or as long as the actions are cost-effective. In order to reduce an ILI to below 3 within six years, some agencies may have to rapidly expand their water main and valve replacement programs beyond the current revenue stream’s ability to support the potentially massive debt that would have to be issued.
But the main point is this: if your agency already repairs leaks it knows about, then the builk of the “real losses” that must be eliminated are from unknown leaks. But if you don’t know where leaks are, or how much water is being lost from each, then you can’t perform the cost-benefit analysis that’s required for compliance.
Proponent of the proposal, including consultants (consultants stand to make gobs of money from retail agencies if this proposal gets adopted) have said: a water agency must spend money looking for unknown leaks, then after it has spent some undefined amount, it can decide whether it is cost-effective to continue looking.
The problem for a water agency interested in complying with the BMPs is this: what constitutes “enough” for compliance? After you have spent looking for leaks: $1,000? $10,000? $50,000? $100,000? $1,000,000?
If your general manager is okay with a third party having discretion over whether his or her agency has spent enough looking for unknown leaks, then you should be okay with this proposal.
Matt Lyons,
Long Beach Water Department
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June 16th, 2008 at 4:38 pm (Reply)
I attended the AWWA National Conference in Atlanta. Leak detection and prevention was a significant topic of discussion at the conference. It is my understanding that the M36 manual could take as long as another year to be finalized due to the number of comments that were received. I attended the leak detection session on Thursday morning. This was a packed session on the last day of the conference. While water agencies recognize a need for standardizing leak detection and audit procedures, there is still significant discussion on the national level on how to use the manual to set standards for how much leakage should be acceptable.
In light of the status at the national level of AWWA, what may be more appropriate at this time is to get agencies to start standardizing their audit procedures. Appropriate leak standards could be set at a later date when more information is available and the industry has had a chance to adapt to some of the new approaches.
Toby Roy
June 17th, 2008 at 2:50 pm (Reply)
I think problem number four would be the absolute paucity of meaningful, technical information about how to value the duration of unknown leaks. When you find one, by accident of course, are you suppose to multiply the leak rate by one day, four days, three hundred and sixty-five days, seven hundred and thirty days? The duration of undiscovered leaks, as Matt points out, is so elementally integral to a good science approach to BMP 3 that we can’t move on without it. Until conventions are developed,as suggested by Toby above, for such core factors as valuing unknown leaks, BMP 3 is pointless.
Rick Hydrick