Recommendations: The Residential Retrofit Program

It appears from data supplied in the WSSMPs that the Residential Retrofit Program has been poorly implemented and managed throughout the state. Some water suppliers do it; some don't. Some have their customers come to the office to pick retrofit kits up; other water suppliers mail the kits to all residential customers. However, virtually no one keeps track of the impact that the RRP has upon water use within their district. Recommendations to make the RRP more efficient follow.

Legislation

  • Require that rates be calculated to include money to conduct a comprehensive RRP, including an impact study.

RIGL Chapter 46.15.3-21(b)(8) specifies that the preparation, maintenance and implementation of water supply system management programs should be considered when setting rates. Yet, rates are subject to the approval of various entities (including the PUC, town councils, voters, water supply boards) depending on the water supplier. Therefore, a water supplier can request a rate increase to implement such programs, but the approving body can deny their request. In fact, Pawtucket's WSSMP states that they applied to the PUC for a rate increase to implement a RRP and were denied (23).

The language in the legislation says that the implementation of programs such as the RRP shall be "considered" when setting rates. Instead, the implementation of demand reduction programs should be a required element to all rate applications. A comprehensive RRP can not be conducted if there is no money to do so. Therefore, legislation should be amended to require that all rate changes include recovery of funds spent on demand reduction programs such as the RRP.

  • Continue to amend building code standards as more efficient technologies become available.

    The last amendments to the Plumbing Standards in the RI Building Codes occurred in 1990. Since 1990, according to data supplied in the WSSMPs, water use has decreased. During these last 12 years RRPs have been required as well. It is important to continue to amend building codes because they are the only means by which the state can force consumers to reduce their water use through technological improvements in their homes. These building codes should be amended at least every 10 years. Evidence that this can have a significant impact on water use is shown by Jamestown's low daily per capita demand. They are the only water supply system to require the installation of water saving devices through town legislation.

Regulation

  • Restructure the RRP, defined in the Rules and Procedures for Water Supply System Management (4) to meet the following requirements:
    • Include outdoor watering equipment in the Residential Retrofit Program.

    Currently the equipment required in the Residential Retrofit Kits (RRKs) by Section 8.05(a)(2) includes a minimum of "2 low-flow faucet aerators, one low-flow showerhead, one toilet displacement device, one package of leak detection tablets, installation instructions, leak detection pamphlet, reorder card for obtaining additional equipment, and a survey form to evaluate the potential for long term water conservation" (4). Yet, it has been shown that although most residential water is consumed the bathroom of the home, outdoor water use has a significant impact on the amount of water consumed, as well. This is illustrated by examining the seasonal trends in water use. As a result, it is logical that including outdoor retrofit equipment in retrofit kits will have an impact on water use.

    • Deliver the retrofit kits to the consumers' doors free of charge.

    Currently, Section 8.05(a)(2) specifies that retrofit kits shall be made available "at cost or at no direct cost to all residential users (4)." Furthermore, Section 8.05(a)(4) of the document defines "mailing or direct delivery of retrofit kit request cards to each residential class user; direct distribution of kits to residential dwelling units (door-to-door delivery or direct mailing of kits); and messages included on customer bills providing a toll free phone number to call to order retrofit kits" as acceptable kit distribution methods (4). The only acceptable method should be the direct distribution of the kits either door-to-door or via mail.

    Since the majority of Rhode Islanders have been targeted by the water supplier for the RRP but have not received a retrofit kit, it can be assumed that either 1. Rhode Islanders do not want a retrofit kit, or 2. they do not want to pay for one. Because people like a hard shower or a strong flush, there may be an aversion to installing a kit. However, when coupled with amended legislation that requires kit components to be installed, a very efficient way to enable a user to install the required technology is to deliver it to their door, free of charge.

    • Maintain records of kit distribution quantity and location.

    The main reason that no one knows how much water is saved due to the RRP is that those water suppliers who haven't done a mass mailing/delivery of retrofit kits have not kept track of who came to pick up them up. To begin a comprehensive evaluation of the RRP, a water supplier must begin with this information.

    • Conduct a follow up survey to determine how many kits have been installed.

    A card is provided with the kits that the consumer receives. Those that don't send the card back should receive a telephone call that reminds them of the importance of installing the retrofit kit and asks them if they have done so. This will give the water supplier a fairly accurate understanding of how many consumers are participating in the program.

    The new stipulation in Section 8.05(a)(4)(iii) should read:

      "Within 30-60 days of distribution of retrofit kits, customers shall be contacted by the Water Supplier in order to determine if the contents of the kits have been utilized. If not, the customer will be reminded of the importance of water conservation and asked to install the water saving plumbing devices.

    • Record water use before and after the distribution of the kits in order to evaluate the success of the program.

    This recommendation speaks for itself. To date there have been no requirements for evaluating this program. However, Newport Water Works conducted a pilot study to determine that very fact. Newport's study is a good example of a conscientious water supplier evaluating where its money is going and if the RRP is a sound investment in the name of water conservation. If water suppliers find, as Newport did, that implementing a RRP does not reduce long term water consumption, perhaps the state should go about reducing demand in another way. However, this decision can not be made until sufficient data have been collected.