For those of you not up-to-speed on the upcoming BMP vote, here’s some background:

Signatory members to the CUWCC agree to implement BMPs under a Memorandum of Understanding to exercise water conservation measures throughout local service areas. As the initial ten year BMP implementation period is complete, several BMPs were reviewed for recommended revisions during 2008 to establish new performance expectations for the next ten years.

The Proposed Revisions that include Flex Track Menu Options are scheduled for adoption at the CUWCC Plenary Meeting scheduled to take place on Wednesday, December 10 at the Metropolitan Water District Headquarters, 700 North Alameda, Los Angeles. Water agencies will be voting to approve or delay the adoption of several revisions.

Greetings fellow water agencies,

Reminder: the deadline for submitting comments to the CUWCC on the proposed BMP revisions is Wed Oct 1st.

What the CUWCC will do with these comments is anyone’s guess; but because these proposed revisions are so significant, and final approval will require a simple majority of water agency support, we might find it helpful to share our views with each other before the Dec 2008 vote on this massive BMP revision.

(You may recall that with the BMP 11 vote, the CUWCC sent a letter to its members, written by supporters of the revision; it did NOT let any of us know some water agencies had strong objections and we did not find out until the morning of the vote — and on the morning of the vote the person chairing the meeting deferred discussion of the proposal until AFTER the vote.)

There is a new conceptual proposal for the water-loss control BMP on the table, put forward by, or acceptable in principle to Group 2 (Environmentalists), one that would require water agencies to complete the spreadsheet, “AWWA WLCC Water Audit Software” every year or two. This is really big news. The original proposal would have been a nightmare to implement.

To use the software, you enter information about the amount of water you supplied, the amount consumed by customers and the amount lost from your system, the number of connections and miles of water mains in your system, some financial data, and other information. The spreadsheet then calculates “Financial Indicators” (such as its estimate of the dollar value of the lost water) and “Operational Efficiency Indicators” (such as whether, in its estimate, your infrastructure is reasonably sound or not).

You can download a free copy of this software from AWWA’s website HERE.

However the software you download today will likely be revised soon, so that it will be able to rate the quality of the data your. For example, based on the precision of the data you entered, the spreadsheet may recommend that your agency focus on gathering more precise data rather than using the values generated by the spreadsheet (values such as the relative integrity of your water system) to improve your water-loss control program.

No one I know of has seen a drafted of this new BMP 3 proposal. Until we do, we cannot know with certainty what it will look like. And we may not see a draft until just before the CUWCC Plenary Meeting in September, when water agencies are suppose to give their tentative nod of approval. Hopefully this simple proposal will not be loaded up with additional requirements like needles on cactus.Some water agencies have suggested that we use this spreadsheet for the next few years:

* To better understand how the calculated results of the spreadsheet can and should be used in a regularotry way (i.e., judging BMP compliance),
* To give us time to collect more precise in-put values,
* To figure out how this approach (the spreadsheet and accompanying AWWA M36 Manual) can help California’s urban water agencies conserve water cost-effectively, and
* To give CUWCC time to work with AWWA to educate water agency field operations and management about AWWA’s new water loss control strategies.

Thanks to everyone who worked successfully to bring reason to this BMP 3 revision process.

- Matt Lyons

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

If your general manager prefers spending more money to conserve “paper” water than real water, they’ll love the CUWCC staff proposal (see it here).

BMP 3 Section A.3

Section A.3 of the proposal tells us that water agencies must value an acre-foot (AF) of “apparent losses” at their retail water rate ($700 to $1,000 an AF or more).

What are “apparent losses”? basically, this refers to water that was put to beneficial use but not recorded as such. The most common form of “apparent losses” are probably meters that under-read how much water went through them (i.e., they under-read how much water was actually consumed.) For example, if your customers consumed 10,000 AF of water in one year, but due to meter under-reading, you only recorded 9,500 AF consumed, then you had 500 AF of “apparent losses.” These apparent losses are also known as “paper losses” because its not like the water was really lost the way it would have been had the water leaked from a water main – this water was consumed and put to beneficial use by the customer. To put it another way, by reducing meter under-reading, little to no real water is conserved.

BMP 3 Section A.4

The proposed BMP 3 Section A.4 would require water agencies with an ILI (see Problem #1) of 3.0 or greater to use the CUWCC Avoided Cost spreadsheet to see if it would be cost-effective to reduce the paper losses, when those paper losses are valued at the retail rate.

If the CUWCC spreadsheet says that an aggressive meter replacement program would cost less than the paper losses it would eliminate, when those paper losses are valued at the retail rate, then your general manager must implement the more aggressive meter replacement program.

The upside-down nature of the CUWCC staff proposal would force retail water agencies to spend more money “conserving” an AF of paper water than an AF of real water. Go figure.

In summary: by requiring water agencies to place an artificially high value on “conserving” paper water as an input to the CUWCC’s Avoid Cost model, this proposal will likely force some retail water agencies to implement an overly aggressive meter replacement program that is not cost-effective in the real world.

-Matt Lyons, Long Beach Water Department

Here, Matt Lyons from the Long Beach Water Department offers the first in a series of postings that will address the core problems with the CUWCC’s proposed BMP 3. He begins by providing 3 things all retail water agencies should keep in mind over the course of the BMP review process:

3 Things Retail Water Agencies Should Keep in Mind:

• AB 1420 (state law potentially denying state funds to agencies not in compliance with the BMPs) mostly applied to retail water agencies because they have the most measurable, difficult BMPs to achieve.
• Some BMPs are already too difficult for more retail water agencies to comply with; for example, more than half of the retail water agencies are out of compliance with BMP 1 (water audits) and BMP 6 (HECW Rebates), yet the proposed BMP 3 is much more challenging than either of them.
• Proposals cannot become a BMP without a majority approval from Group 1 members (water agencies).

In last week’s BMP 3 conference call, I mentioned that AWWA stated that a water agency with about 10% water losses could be considered a well-run water agency. A proponent of BMP 3 said I was not telling the truth. Ouch! So I disengaged from the call, located the article (AWWA’s “Opflow” Magazine, August 2007 pg 16), got back on the call and quoted the publication. Subsequent to the meeting, I emailed the CUWCC a summary of key problems with the proposal to change BMP 3. The problems are the same as many of those raised over the last 3 years. The CUWCC sent the summary to members of the committee, and posted it on their website.This week, just before the conference call to discuss BMP 3, the CUWCC emailed committee members a link to an email posted on the CUWCC website. the email, from a consultant who has been a long-time support of the proposed revisions to BMP 3, begins with a statement that some of my comments “appear to be misleading or technically wrong.” Ouch! Check it out here.

Here is one of the issues I was accused of being misleading or technically wrong on: that an “infrastructure Leakage Index” (ILI) of 3.0 could unaccount for water loss of as little as 4%. I bring it up because the issue is VERY important for retail water agencies. Read more about it here.

The point is, retail water agencies MUST KNOW what this ILI of 3.0 or greater means for their agency. Before supporting the CUWCC staff proposal, retail agencies are advised to run this simple experiment: generate the ILI of your agency by plugging your numbers into the AWWA water loss spreadsheet, multiply this ILI by 3.0, then divide it by the % unaccounted for water estimate that you submitted to the CUWCC in past BMP 3 reports. Doing this will tell you what an ILI of 3.0 means to your agency in terms that we are familiar with: % unaccounted for water you must get down to in order to avoid the onerous work required by the proposed BMP. Get a copy of the free software from AWWA here.

The second issue Reinhard claimed I was misleading or technically wrong on, i.e. how much money agencies should spend to “conserve” paper water, will be addressed in a forthcoming blog. Until then…

Last week, the first CUWCC Caucus for Southern California water agencies was held at the Long Beach Water Department. If you missed it, here is a look at the key points discussed (click Here for the full meeting notes):

• Metropolitan Water District to Host Future Meetings

• DWR’s Model Landscape Ordinance

• AB 1420 Implementation (Read the letters sent to DWR by MWD, SDCWA and NRDC)

• Review of AB 2175 (Read the full summary)

• Possible Agenda Topics for the Next SoCal CUWCC Group 1 Caucus

• Requests to be made of the CUWCC

Questions? Comments? Please contact Matt Lyons at the Long Beach Water Department for more information.