Preparing for the Storm or Relying on the Calm?
The Rhode Island Water Supply System Management Plan

Megan Terebus
Master's of Arts in Environmental Studies

The purpose of the study is to evaluate the current and potential use of Water Supply System Management Plans as planning tools for present and future water supply management in the State of Rhode Island. This study was initiated during drought conditions and was completed with the understanding that as climate change continues, both dry and wet years will become more frequent and more severe. With this in mind, the state should consider minimum precipitation conditions when developing policies for development and water allocation.

Background

Most people do not associate the eastern United States, or New England, with drought. Therefore, major water conservation efforts have not been a significant priority in many Eastern states. Yet, as this part of the country continues to develop and as climate change continues, water shortages are an increasing concern. As of July 2002, Rhode Island has been in an eight-month precipitation deficit and is currently in the Watch Phase of drought, defined by the Rhode Island Drought Management Plan. The total impact of the current drought has yet to be seen in Rhode Island, however, one thing is for sure -- this won't be the last drought Rhode Island faces.

Ninety percent of the Rhode Island's population is served by large public water suppliers (1, 2). Traditionally, southern Rhode Island has relied on groundwater for its primary source of drinking water while most of the remainder of the public water supply system is supplied by surface water reservoirs (2). Due to characteristics of the 22 aquifers that exist under Rhode Island, the state's groundwater is more sensitive to variations in rainfall than are most of the reservoirs (1). As a result, it is not rare for water districts in southern Rhode Island to face summer shortages.

Water is a common resource, shared by all. As a result, the state has taken on the responsibility of making sure that water supplies are managed properly. The state has four State Guide Plan (SGP) Elements (721-724) that address the management of the water supply. The guide plans focus very broadly on demand management, supply management and system management under both normal and emergency conditions. These are the main policies that plan for the sustenance and maintenance of the state's water supply.

The only potential indicators of water supply quantity and management are the Water Supply System Management Plans (WSSMPs). The Rules and Procedures for Water Supply System Management Planning (4) require water suppliers to file a WSSMP with the Rhode Island Water Resources Board (WRB) every five years. Within the WSSMP, water suppliers are required to report on the supply, demand, and system management within their own water supply district. They are also required to project future demands upon their system and current and future strategies for decreasing those demands in order to enable continual growth and conservation of the water supply (4). These documents serve as both reports on current system characteristics and as well as planning documents for the future of water supply management. The State has set goals within the SGP Elements for managing the water supply. The WSSMPs are approved based on their consistency with these goals and the Rules and Procedures for Water Supply System Management Planning.

Methods and Analysis

There are 30 major water suppliers who file WSSMPs with the Water Resources Board (WRB). There is no existing summary of these documents. As of June 2002, only 22 of the second round of WSSMPs had been submitted to the WRB. In order to determine the reality of and potential for WSSMPs as sufficient planning documents, each of the 22 latest WSSMPs was individually examined and data regarding the uses of water in the residential, commercial, industrial, governmental sectors were compiled. The water use of major users and the individual water supply systems (measured as non-account water) were also collected. No data was taken from the initial set of WSSMPs submitted in the mid-nineties. The data were then analyzed in order to answer the following questions:

1. Which sector is consuming the most water in RI (major users, commercial, residential, government, industrial, etc.)?
   
2. Who are the major water users and what impact do they have on the overall water supply systems?
   
3. What is the status of demand reduction programs (Residential Retrofit and Major Users Technical Assistance Program) in Rhode Island?
   
4. How much water is accounted for once it leaves the supply reserves?
   
5. To what extent do water rates impact water use in Rhode Island?
   
6. To what extent do water suppliers utilize water restrictions, seasonally and in times of drought, as demand reduction tools?
   
7. Is the WSSMP process a reliable tool for water resources planning under both normal and drought conditions?

Water Supply System Management Plan Results

The preparation of a Rhode Island Water Supply System Management Plan (WSSMP) is required of all large public water suppliers in the state (4). Each document is required to contain information regarding present efforts and future plans for demand reduction. Data were collected to determine the status of demand reduction activities within the public water supply systems of Rhode Island. The strategies examined in this section include those aimed at improving water use equipment technology (demand reduction programs) and those targeted towards changing water use behavior (rates and water restrictions). Conclusions will be made from these results as to the overall adequacy of the WSSMP as a planning tool for drought.

Results are presented in five categories: Residential Retrofit Program, Major Users Technical Assistance Program, Non-Account Water, Rates and Restrictions. The first three categories deal with technology. By persuading consumers to participate in the RRP and the MUTAP, the water supplier is encouraging them to adopt/install more efficient, water-saving technology in their homes and businesses. Similarly, water suppliers are also complying with efficiency standards by replacing infrastructure and reducing non-account water to achieve compliance with statewide goals.

Rates and restrictions, on the other hand, are tools that policy makers can use to help people change their behavior. Rates can be used to encourage the efficient use of water. They hit the spot that tend to hurt people the most -- their pockets. With the appropriate rate, water conservation becomes a way of life. Seasonal water restrictions, on the other hand, serve as reminders to conserve water in times when water conservation is needed the most. During the summer, water demand increases by 156% in some water supply districts. Without sufficient water restrictions, some systems run the risk of not being able to meet demand or having to import water just to meet the needs of customers.

Technology Based Conservation Tools

Residential Retrofit Program (RRP):

• According to the latest round of WSSMPs, 15 of the 22 reporting water suppliers had implemented a RRP; six had not, but three of those six had a RRP scheduled to begin in 2002. The Residential Retrofit Program was not applicable to one water supplier.
  
• Of the 15 water suppliers with implemented RRPs, eight distributed the retrofit kits upon demand, i.e. if a customer wants a kit, she picks it up at the office of the water supplier. Four water suppliers mailed retrofit kits to their customers and two water suppliers used a combined method of mailing, hand delivering and on-demand distribution. Only one water supplier implemented the components of the RRP by passing a town ordinance requiring the installation of retrofit devices.
  
• Six water suppliers indicated that they offer retrofit kits to their customers free of charge. Two charge their customers a fee for the kits; and, it was unclear if the remaining eight water suppliers charge any sort of fee.
  
• Twelve of the 15 water suppliers target 100% of their service population each year. They do this by including flyers with bills informing the customer of the availability of the retrofit kits. The flyers also include educational information and instructions about how one can obtain a kit. Two water suppliers approach notification from the required 10% targeted per year goal set by the state in the Rules and Procedures for Water Supply System Management document. Finally, one water supplier targets 25% of its population every year.
  
• Only eight of the 15 water suppliers that had implemented a RRP had a record of how many retrofit kits had been distributed. Information regarding location of kits and installation is not required to be indicated in the plans.
  
• The water supplier passed a town ordinance to require the installation of retrofit devices in homes maintains the lowest per capita water use and water use per residential service connection in the state.
  
• Of the two water suppliers that have completed their RRPs, one has a below average and the other has an above average water use per residential service connection.

Major User Technical Assistance Program (MUTAP):

• Three water suppliers did not offer the MUTAP at the time of their WSSMPs' preparation. Two of these water suppliers were to begin a MUTAP in 2002. One water supplier stated that it would not implement any type of MUTAP because it had been denied funding for such a program from the PUC. One water supplier failed to mention any type of MUTAP in its plan. Therefore, it is unknown if this program exists within that water supply district.
  
• All 21 water suppliers audit sanitary equipment. None mention the existence of an auditing program for industrial/manufacturing processes. Two water suppliers offer MUTAPs as extensions of their Residential Retrofit Programs (RRP).
  
• Of the 15 other water suppliers that offer a MUTAP, only one takes the initiative to schedule visits to the sites of its major users; the others conduct audits only upon request.
  
• One water supplier has entered into a partnership to conduct water audits with the Narragansett Bay Commission. (The details of the audits or the partnership were not provided in the plans.)
  
• Eleven percent of Rhode Island's major users are located in a water supply district that relies on groundwater as a primary supply source. The other 89% are located in surface water supply districts. Major users in groundwater supplied districts consume 12% of all of the water consumed by major users in Rhode Island.
  
• The majority of the major users in the state are in the industrial category.

Non-Account Water:

• Of the 22 Water Districts that filed WSSMPs in time to be considered in this thesis, two did not report on their non-account water.
  
• Seventeen of the 22 reported that their systems are 100% metered. It was not clear to what extent the other five systems are metered.
  
• Leak Detection Surveys (LDS) are reportedly conducted by 14 of the 22 water suppliers. Four water suppliers do not conduct leak detection surveys and it was unclear if the remaining four water suppliers have performed LDSs in the past.
  
• Of the water suppliers that have conducted LDSs, five are supplied by ground water (seven total reporting water suppliers are supplied by groundwater) and nine are supplied by surface water (15 total water suppliers are reliant on surface water).
  
• Of the water suppliers who reportedly do not conduct LDSs, two are supplied by ground water and two are supplied by surface water.
  
• All reported LDSs were performed in the 1990s or 2000.
  
• Over nine years (1990-1999), average annual non-account water for water suppliers supplied by groundwater was 18%. For water suppliers supplied by surface water, over the same time period, average non-account water was calculated to be approximately 10%. The state's average annual non-account water over this time period was approximately 11%.

Behavior-Targeted Conservation Tools

Rates:

• At the writing of their WSSMPs, two water suppliers report a declining block rate structure, 12 had a uniform rate, and seven water suppliers operated with an inclining block rate.
  
• Both water suppliers with the declining rate structure rely on surface water for their primary source of water, as do 11 of the 12 water suppliers with a uniform rate and one water supplier with an inclining rate.
  
• Conversely, among the ground water supplied water suppliers, none maintain a declining block rate, one maintains a uniform rate, and six operate with an inclining block rate.
  
• Of the five PUC regulated water suppliers that filed WSSMPs in time for analysis in this thesis, two maintained a declining block rate structure and three maintained uniform rates.
  
• The 17 remaining water suppliers seek rate approval from either a water supply board, town council, or local voters.

Restrictions:

• Of the 22 water suppliers that filed WSSMPs in time to be analyzed in this thesis, three ground water supplied systems indicated that they enforce mandatory seasonal outdoor water use restrictions within their supply system.
  
• No surface water supplied water suppliers indicated that they operate with any kinds of water use restrictions during a normal year.
  
• Within their drought emergency plans, all water suppliers define drought. Only 13 have drought-specific responses. The remaining eight have actions based on general water quantity emergencies.
  
• Of the three systems that annually enforce seasonal water use restrictions, one has below average per capita water use, one has above average and the other did not provide sufficient data in order to calculate per capita water use within its system.
  
• Finally, of the two systems with annual seasonal water use restrictions, in 1999 one witnessed a 136% increase in demand from spring to summer. The other experienced an increase in demand of only 25% in 1998.

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

RRP

Restructure the RRP to meet the following requirements:

1. Include outdoor watering equipment in the Residential Retrofit Program.
   
2. Deliver the RRKs to the consumers' doors free of charge.
   
3. Maintain records of kit distribution quantity and location.
   
4. Conduct a follow up survey to determine how many kits have been installed.
   
5. Record water use by month before and after the distribution of the kits to evaluate the success of the program.

MUTAP

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.

Non-Account Water

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

Rates

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.

Restrictions

Require a separate section in the WSSMPs that addresses drought, meeting the following requirements:

1. All local drought plans should use terminology that is consistent with SGP 724: The Rhode Island Drought Management Plan.
   
2. Water suppliers should be responsible for determining drought levels by measuring the percent capacity of each supply source.
   
3. All water suppliers should outline a schedule for restrictions on all outdoor water use triggered by percent capacity or supply.