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Executive Summary Part 3: Recommendations
Recommendations for the WSSMP Process
- Rhode Island General Laws should be amended to assign enforcement
power to the Rhode Island Water Resources Board to insure WSSMP compliance
with regulations.
Currently, there is no enforcement power assigned to the WRB (RIGL Chapter 46-15.3-20), however, the Board is given primary approval responsibility for the WSSMPs (RIGL Chapter 46-15.3-15). The only leverage the WRB has over the water suppliers in holding them to compliance with the Rules and Procedures for WSSMPs is this approval and the authority to request that a hearing be conducted by the PUC to investigate charges of noncompliance (RIGL Chapter 39-4-3). It is not evident that the later part of these rules have never been used in regards to the WSSMPs and there are many components of the WSSMPs that are not in compliance with the guiding regulations. Lawmakers should consider this. There are no consequences for failing to implement the WSSMPs; and without consequences, the plans are merely reports. In order for the WSSMPs to be the planning tools described in the goals section of the Rules and Procedures for Water Supply System Management Planning, the WRB should be given and utilize the authority to oversee the implementation of the plans.
Recommendations for Technology Based Conservation Programs
- Restructure the RRP to meet the following requirements:
- Include outdoor watering equipment in the Residential Retrofit Program.
- Deliver the RRKs to the consumers' doors free of charge.
- Maintain records of kit distribution quantity and location.
- Conduct a follow up survey to determine how many kits have been installed.
- Record water use by month before and after the distribution of the kits to evaluate the success of the program.
- Assign technical assistance responsibilities to DEM's Office of Technical Assistance.
According to the WSSMPs, a full scale technical assistance program is not offered by any supplier because it would be too expensive for an individual water supplier to pay for the type of specialized technical assistance required. The Department of Environmental Management has an Office of Technical and Customer Assistance whose focus is providing audits. Until now, this office has only been responsible for water audits incidental to pollution prevention. Yet, this agency has acknowledged the need for and expressed interest in water auditing for conservation purposes.
- Require water suppliers to conduct leak detection surveys a minimum of once every 10 years.
Currently Section 8.07(b)(1) of the Rules and Procedures for Water Supply System Management states:
"Water supply management plans shall at a minimum set forth a comprehensive plan and schedule for the detection and repair of leaks so as to maintain non-account water at or below 15% of total metered supply. Comprehensive leak detection surveys shall be conducted on a periodic basis according to specific needs, however surveys shall be conducted immediately if non-account water exceeds 15%. Leaks should be repaired expeditiously (4)."
Yet, some water suppliers refuse to conduct an LDS, even if non-account water rises above 15%. While the state strives for the long term goal of 10% non-account water, water suppliers should be required to conduct an LDS more often than periodically. The 10-year requirement insures that all water suppliers are conducting LDSs, even if non-account water is below the current 15% goal. According to the regulations, all detected leaks shall be expeditiously repaired. With this recommendation and all water suppliers working to detect and repair leaks, non-account water should be significantly reduced within the next 10 years.
Recommendations for Behavior-Targeted Conservation Tools
- Determine individual water supply system triggers for conservation rates.
The Drought Management Plan defined four levels of drought based on precipitation, reservoir and groundwater levels, and streamflow. These 4 levels are linked to recommended actions that should take place, such as water bans or pressure reductions. At some point, these levels should be linked to percent capacity reductions, percent reduction goals and rates. There are two ways this can be done.
- Currently, rates in Rhode Island are set prospectively. Yet, when rates are set prospectively and water suppliers encourage their consumers to reduce consumption, they risk losing revenue and not covering their operating costs. With this first method, rates could continue to be set this way. Water suppliers could calculate what percent reduction should be associated with each trigger level of drought. (For example, a 70% capacity of supply might trigger a 10% water use reduction goal.) At the point that the percent capacity level of the supply is detected, a predetermined corresponding rate would be triggered to encourage water users to reduce consumption the desired amount, while enabling the water supplier to continue to cover its costs.
- A second method of rate setting could be done retroactively to insure that costs are covered. With this method, the water supplier informs consumers that the supply has been reduced by a certain percent of capacity (70%, according to the previous example) and that the state requires the water supplier to associate that level of capacity with a certain reduction goal (10%). At the point of notification, the water supplier does not know what the rate will be. At the end of the drought period, water use will be calculated and a rate determined.
It is important to note that in these examples rates will increase for everyone. In both cases, if the consumer reduces his water use by the target amount, his overall bill will be the same. If he does not, his bill amount will increase. Consequently, if demand is truly inelastic of price (2), then these rate setting methods will not work if the water supplier does not couple them with water use restrictions.
- Require a separate section in the WSSMPs that addresses drought, meeting the following requirements:
- All local drought plans should use terminology that is consistent with SGP 724: The Rhode Island Drought Management Plan.
- Water suppliers should be responsible for determining drought levels by measuring the percent capacity of each supply source.
- All water suppliers should outline a schedule for restrictions on all outdoor water use triggered by percent capacity or supply.
