SR-09-08-2015-8A
City Council
Report
City Council Regular Meeting: September 8, 2015
Agenda Item: 8.A
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To: Mayor and City Council
From: Dean Kubani, Sustainability Manager, Office of Sustainability and the
Environment
Subject: Update to the Water Shortage Response Plan
Recommended Action
Staff recommends that the City Council adopt by resolution the Water Shortage
Response Plan.
Executive Summary
On January 13, 2015, in response to the fourth year of unprecedented drought, Council
adopted the Water Shortage Response Plan (WSRP) and re-declared a Stage 2 Water
Supply Shortage requiring a 20% reduction in water use from 2013 through the
implementation of Water Use Allowances (WUA) and penalties. This report presents
recommended changes to the WRSP regarding penalties to be incurred for water use
beyond a customer’s Allowance. The proposed changes reflect public input, new
information, and most effectively utilizes limited City resources in order to achieve the
water savings mandate.
Staff recommends the following:
1. Water Use Allowance formula for residential water customers:
The average daily baseline use per billing period x the % of water available or
the residential threshold; whichever is higher
2. The Water Use Allowance formula for commercial and landscape water
customers:
The average daily baseline use per billing period x the % of water available
3. Penalties set at:
first violation penalty: $250
second violation penalty (within twelve months of the first violation): $500
third violation penalty (within twelve months of the first violation): $1,000
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4. Customers that exceeded their Water Use Allowance and received a penalty
would have the first violation penalty waived by demonstrating attendance at a
City offered water school.
5. Change the Santa Monica Malibu Unified School District’s landscape water use
Allowance to a total percent reduction in water use by combining all the
landscape water accounts.
Background
Since 2007, with the exception of 2011-12, California has been in a drought. The
current drought has seen some of the lowest rainfall and snowpack since 1896.
On May 27, 2008 Council adopted amendments to SMMC 7.16 Water Conservation,
which gave Council authority to determine and declare a water supply shortage and
adopt a Water Shortage Response Plan (WSRP). The current WSRP was developed in
2009 to comply with the State’s Urban Water Mana gement Plan requirements. The
WSRP was based on the California Department of Water Resources 2007 Urban
Drought Guidebook.
On June 9, 2009 Council adopted the WSRP and declared a Water Shortage Advisory
calling for a voluntary 10% reduction in water use in response to the drought. The
WSRP was included in the City’s 2010 Urban Water Management Plan which was
subsequently approved by the State. This Advisory remained in place as part of the
effort to reduce the need to import water from MWD and reach the City’s goal for water
self-sufficiency by 2020.
On January 17, 2014, the Governor declared a Drought Emergency and asked all
Californians to voluntarily reduce water use by 20% in support of the Governor’s efforts.
On January 29, 2014, the City increased its voluntary conservation target from 10% to
20%. On March 1, 2014, the Governor signed Senate Bill 104, state legislation which
implements numerous drought relief measures. On July 15, 2014, the State Water
Resources Control Board adopted an Emergency Regulation for Statewide Urban Water
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Conservation which requires urban retail water agencies, like Santa Monica, to
implement all requirements and actions of their water shortage response plans that
impose mandatory outdoor irrigation restrictions and prohibit certain activities in
promotion of water conservation.
On August 12, 2014 Council adopted a resolution declaring a Stage 2 Water Supply
Shortage which changed the drought response from a voluntary 20% reduction in water
use to a mandatory 20% reduction and directed staff to return with a detailed Stage 2
Water Supply Shortage implementation plan including proposed amendments to
Section 7.16 of the Municipal Code and the WSRP, a financial impact analysis to
address revenue reductions and additional staffing and program implementation costs,
and an implementation timeline.
On October 28, 2014 staff returned to Council and presented proposed updates to the
WSRP as well as information about proposed changes to the Municipal Code and
implementation of drought response measures. Council provided feedback and
directed staff to: return with proposed changes to the WSRP that included input from the
public; develop a Water Conservation Unit within the Office of Sustainability and the
Environment to implement the Stage 2 Water Supply Shortage; and return with
proposed changes to the Municipal Code related to water conservation.
On January 13, 2015 Council adopted the proposed WSRP and re-declared a Stage 2
Water Supply Shortage.
On April 1, 2015 Governor Brown issued an Executive Order to direct the State Water
Resources Control Board (SWRCB) to implement restrictions for a statewide cutback in
potable urban water use of 25% through 2016. The SWRCB was directed to establish a
framework of reduction levels for individual water supplies.
On April 14, 2015 the Metropolitan Water District of Southern California (MWD)
approved a 15% reduction in water supplied to its member agencies from July 1, 2015
through June 30, 2016. Recognizing Santa Monica’s water conservation efforts, the
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MWD modified the City’s allocation reduction to 14%.
On May 5, 2015 the SWRCB set the City’s mandatory water reduction level at 20%
through February 2016. The City is required to provide SWRCB monthly reports to track
progress. In July 2015, city-wide water use was reduced 24%.
On June 8, 2015 Water Use Allowances went into effect for water customers, excluding
recycled water customers.
Discussion
This report presents recommended changes to the existing WSRP. The proposed
changes reflect input from the public and new information regarding penalties. Staff is
proposing an approach that mirrors existing penalty structures and most effectively
utilizes limited City resources in order to achieve the water savings mandate.
Water Use Allowances
The existing WSRP sets Water Use Allowances (WUA) for Stages 1, 2, 3 and 4 as a
means to deter water waste and achieve specific water reduction targets. Staff
recommends including the WUA formulas listed below in the WSRP.
Residential Water Customer Formula:
The average daily baseline use per billing period x the % of water available or
the residential threshold; whichever is higher
Commercial and Landscape Water Customer Formula:
The average daily baseline use per billing period x the % of water available
Water Use Allowance for all Water Customers*
Stage 1 Stage 2 Stage 3 Stage 4
85% Water
Available Per
80% Water
Available Per
70% Water
Available Per
50% Water
Available Per
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Customer Customer Customer Customer
Single-Family average daily
baseline use x
0.85
or
22 HCF;
whichever is
higher
average daily
baseline use x
0.8
or
22 HCF per
billing period;
whichever is
higher
average daily
baseline use x
0.7
or
16 HCF;
whichever is
higher
average daily
baseline use x
0.5
or
16 HCF;
whichever is
higher
Multi-Family average daily
baseline use x
0.85
or
11 HCF per unit;
whichever is
higher
average daily
baseline use x
0.8
or
11 HCF per
unit; whichever
is higher
average daily
baseline use x
0.7
or
8 HCF per unit;
whichever is
higher
average daily
baseline use x
0.5
or
8 HCF per unit;
whichever is
higher
Commercial average daily
baseline use x
0.85
average daily
baseline use x
0.8
average daily
baseline use x
0.7
average daily
baseline use x
0.5
Landscape average daily
baseline use x
0.85
average daily
baseline use x
0.8
average daily
baseline use x
0.7
average daily
baseline use x
0.5
*HCF is hundred cubic feet
WUAs are established for each customer per billing period. A billing cycle is typically 60
days; however, the days between meter reads can range from 54 to 65 days. Because
the number of days fluctuate each billing period, staff can only provide an estimated
WUA. In Stage 2 customers need to reduce water use 20% during each bi-monthly
billing period compared to their 2013 bi-monthly billing usage. Where the City’s water
billing records show the water customer used no water in 2013 or that a property was
vacant, the baseline is calculated using the average water usage in 2013 for customers
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in the same customer class with the same meter size. Water customers using Santa
Monica Urban Runoff Recycling Facility (SMURRF) non-potable water are exempted
from the water use Allowance requirements. SMURRF customers include the City,
RAND, and the Water Garden office complex.
The WSRP includes water conservation thresholds for single-family and multi-family
water customers whereby customers using less than or equal to the threshold would not
be required to further reduce their water use and would not be subject to penalties. The
residential water conservation thresholds are intended to recognize the successful
water-efficiency efforts of many residential water customers. The lowest Stage 2 WUA
for single-family customers is 22 HCF per bill and 11 HCF per unit per bill for multi-
family water customers. There are no water conservation thresholds for commercial
water customers due to the large variation in size, business type and corresponding
water use.
Water Use Allowance Penalties
Existing policy states customers that exceed their WUA may be issued an
administrative citation. The adopted penalty structure, as detailed in the existing WSRP,
is calculated by multiplying the HCF of excess water above the WUA times $10 up to
the total water charges for that billing period or $1,000, whichever is less. For example a
single-family customer that used 32 HCF and which exceeds their WUA by 3 HCF
would be charged a $30 penalty. This dollar amount would be assessed through an
administrative citation issued separately from the customer’s utility bill.
Over the past few months staff researched penalty structures for water waste and
reviewed recent case law regarding water penalties. Staff recommends revising the
penalty policy to be consistent with other administrative citations issued by the City.
Currently City administrative citations start at $75 for the first violation and cannot
exceed $1,000 per State law. For example, the administrative citation penalty for
violating the City’s Water Conservation Ordinance (SMMC 7.16) for irrigation runoff
starts at $250. This sends a strong signal to excess water users.
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Penalties often escalate and typically a maximum of three administrative citations are
issued before additional remedies are imposed. Staff recommends the following
changes to penalty amounts:
$250 for the first violation penalty
$500 for the second violation penalty (within twelve months of the first violation)
$1,000 for the third violation penalty (within twelve months of the second violation)
As with all administrative citations, the citations issued are based on the City resources
available to enforce them. While modifications will be made to the City’s billing system
to automate some aspects of the citation process, the entire process cannot be fully
automated. Administrative citations for excess water use will require staff review and
processing. Staff proposes directing the limited resources available to focus first on the
most significant water wasters.
The WSRP provides for additional enforcement mechanisms. Customers that exceed
their WUA three times in a one-year period may be required to have a water audit
performed by a licensed engineering firm with water audit experience to be paid by the
water customer. The audit must be performed and a full report submitted to the City o f
Santa Monica within 30-days of notice. The audit report must include how the audit was
administered and list all interior and exterior uses of domestic and non-domestic water.
Results of the audit, recommendations, and return on investment calculations must also
be included. The City may require the implementation of the audit recommendations as
a precondition to granting any request for a WUA adjustment.
Customers that exceed their WUA seven or more times may have a flow restrictor
installed in the meter which restricts the flow of water going into the building and/or be
subject to civil penalties or criminal prosecution.
There are no proposed changes to the implementation timeline. Penalties will begin to
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accrue October 2015 and administrative citations may be issued to those exceeding
their WUA starting December 2015.
Waiver of Excessive Water Use Penalties
Customers that receive a WUA penalty may appeal that penalty pursuant to SMMC
1.09. If an appeal is granted, the customer would be refunded the penalty. As an
option, staff recommends a change to the WSRP to include waiving the first violation
penalty if the customer attends a live or web-based water school.
The class would explain the need for regulations and restrictions on water use and
provide tools and strategies to stay within their Allowance and include information about
Santa Monica’s water supplies, water self-sufficiency, impacts of the drought, WUAs,
specific ways for customers to save water, examples of ways other customers are
staying within their Allowance. Attendees that fail to attend the school, leave early or
exit the web-based school without finishing the materials, will not have the penalty
waived.
The City of Santa Cruz implemented both WUAs and water school and is meeting its
mandatory water reduction target of 20%. This option helped Santa Cruz lessen the
number of appeals which are staff and resource intensive to review and process.
Landscape Water Use Allowances
After discussions with the Santa Monica Malibu School District (SMMUSD), staff
recommends changing the WSRP to offer SMMUSD the same method of compliance as
City and Caltrans landscapes by aggregating their landscape water use. The SMMUSD
has five dedicated landscape meters. This change would require meeting a reduction
(for Stage 2 that is 20%) in the total water use of all five meters instead of for each
individual meter. This allows for better management to keep the recreational landscape
areas, such as ball fields, functional and safe while significantly reducing water use in
other landscape areas.
Summary of the Proposed Changes to the Water Shortage Response Plan
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1. Water Use Allowance formula for residential water customers:
The average daily baseline use per billing period x the % of water available or
the residential threshold; whichever is higher
2. The Water Use Allowance formula for commercial and landscape water
customers:
The average daily baseline use per billing period x the % of water available
3. Penalties set at:
first violation penalty: $250
second violation penalty (within twelve months of the first violation): $500
third violation penalty (within twelve months of the first violation): $1,000
4. Customers that exceeded their Water Use Allowance and received a penalty
would have the first violation penalty waived by demonstrating attendance at a
City offered water school.
5. Change the Santa Monica Malibu Unified School District’s landscape water use
Allowance to a total percent reduction in water use by combining all the
landscape water accounts.
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Financial Impacts & Budget Actions
The amount of penalties imposed for exceeding the applicable WUA is difficult to
project. Citation fines for exceedances of WUAs will be deposited in account
01226.408740. Funds generated by penalties will be used to offset costs in the Water
Conservation Unit.
Prepared By: Kimberly O'Cain, Sustainability Analyst
Approved
Forwarded to Council
Attachments:
A. May 27, 2008 Staff Report (web link)
B. June 9, 2009 Staff Report (web link)
C. June 29, 2014 Information Item (web link)
D. August 12, 2014 Staff Report (web link)
E. October 28, 2014 Staff Report (web link)
F. January 13, 2015 Staff Report (web link)
G. Water Shortage Response Plan Resolution draft
H. Water Shortage Response Plan
Attachment BA
CITY OF SANTA MONICA
WATER SHORTAGE
RESPONSE PLAN
Department of Public Works
Water Resources Division
1212 5th St., Third Floor
Santa Monica, CA 90401
(310) 458-8975
www.smgov.net/water
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
Page 2 of 12
Table of Contents
Section 1: Introduction………………………………………………………………………. page 3
Section 2: Objectives and Priorities of Water Use……………………………………… page 3
Section 3: Triggers for Implementation…………………………………………………… page 3
Section 4: Stages of Water Shortage Supply……………………………………………. page 4
Table 1: Water Shortage Reduction Targets…………………………………………. page 4
Section 5: Water Use Restrictions for All Stages………………………………………. page 4
Section 6: City of Santa Monica Staff Responsibilities………………………………… page 4
Section 7: Water Allowances for Stages 1, 2, 3, 4……………………………………… page 5
Table 2: Water Use Allowances ………………………………………………………… page 5
Section 8: Penalty…………………………………………………………………………….. page 67
Section 9: Waiver of Penalty………………………………………………………………… page 7
Section 10:Water Use Allowance Adjustment……………………………………………. page 67
Section 1011: Definitions……………………………………………………………………….. page
8
Exhibit 1 – Residential Water Conservation Threshold Calculations…………… page 10
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
Page 3 of 12
Section 1: Introduction
The City of Santa Monica City Council adopts this Water Shortage Response Plan
(WSRP) pursuant to Santa Monica Municipal Code (“SMMC”) section 7.16.030. The
WSRP is intended both as an action plan and as the implementing regulations for water
conservation as authorized by Section 7.16.030. It is designed to reduce water demand
during water shortages. The WSRP is based in part on the State of California
Department of Water Resources 2007 Urban Drought Guidebook. The Urban Water
Management Planning Act (Section 10632 of the Calif ornia Water Code) requires water
shortage contingency planning as a component of the Urban Water Management Plan,
which is updated every five years.
The WSRP establishes five stages of water shortage severity based on predicted or
actual water supply reductions. Each stage establishes water use reductions through
voluntary or mandatory measures. Triggers for implementing the WSRP may include
such events as a state or local emergency; natural disaster; a localized event that
critically impacts the water supply; drought or the City’s wholesale water agency
imposing water allocation restrictions.
Section 2: Objectives and Priorities of Water Use
A. The objectives of the WSRP are to:
(1) Prioritize essential uses of available water;
(2) Avoid irretrievable loss of natural resources;
(3) Manage current water supplies to meet ongoing and future needs;
(4) Maximize local municipal water supplies;
(5) Eliminate water waste city-wide;
(6) Create equitable demand reduction targets; and
(7) Minimize adverse financial effects.
B. The following priorities for use of available water are listed in order from highest to
lowest priority:
(1) Health and Safety including: consumption and sanitation for all water
users; fire suppression; hospitals, emergency care, nursing and other
convalescent homes and other similar health care facilities; shelters and
water treatment;
(2) Institutions, including government facilities and schools such as public
safety facilities, essential government operations, public pools and
recreation areas;
(3) All non-essential commercial, institutional, and residential water uses;
(4) New water demand.
Section 3: Triggers for Implementation
The City Council may declare by resolution that an Advisory or S tage 1, 2, 3 or 4 Water
Supply Shortage exists and that the actions outlined in this WSRP are necessary. Upon
Council adoption by resolution, any Advisory or Stage may be rescinded. The type of
event which may prompt the City Council to declare an Advisory or Stage1, 2, 3, 4
Water Supply Shortage may include, among other factors:
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
Page 4 of 12
Drought;
State or local emergency;
A natural disaster that critically impacts the water treatment or water distribution
system;
A localized event that critically impacts the water supply, water quality, water
treatment or water distribution system;
The City’s wholesale water agency requests extraordinary water conservation
efforts in order to avoid mandatory water allocations;
The City’s wholesale water agency implements a water allocation.
Section 4: Stages of Water Shortage Supply
The WSRP establishes five stages of severity based on predicted or actual water supply
reductions. Each stage establishes water use reductions either through voluntary or
mandatory measures. Mandatory water restrictions include water use allowance for
each water customer category. Table 1 below outlines the stages and water use
reduction goals.
Table 1: Water Shortage Reduction Targets
Section 5: Water Use Restrictions for All Stages
The water conservation requirements in SMMC Section 7.16d are permanently
enforced.
Section 6: City of Santa Monica Staff Responsibilities
(A) City staff will be informed of the water supply shortage. Each staff member will
be expected to use water efficiently.
(B) The City’s landscaped areas will be efficiently irrigated based on the Irrigation
Association’s Best Management Practices.
(C) Each staff member will be expected to notify the appropriate City department
immediately of any leaks seen on City property or private property.
Section 7: Water Allowances for Stages 1, 2, 3, 4
A Water Use Allowance (WUA) is established for each water customer.
The WUA shall not apply to:
Water
Shortage
Stage
Water Use
Restrictions
City-wide
Use
Reduction
Goal
Advisory Voluntary 10%
Stage 1 Mandatory 15%
Stage 2 Mandatory 20%
Stage 3 Mandatory 30%
Stage 4 Mandatory 50%
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
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(A) Any water customer of the City of Santa Monica during an Advisory water
supply shortage stage;
(B) Any water customer account designated for municipal non-potable water.
Summary of Allowances
A WUA is the maximum allowable amount of water that could be used by a water
customer and it is calculated as a percent reduction in the amount of water available for
each water customer in the City of Santa Monica for the duration of a declared water
shortage.
The WUA is calculated as a percentage of the baseline year’s water usage. The
baseline is calendar year 2013. Each water customer will receive a WUA for each billing
period. A billing period is approximately 60-days.
Public agency, including but not limited to the City of Santa Monica, Caltrans, Santa
Monica-Malibu Unified School District, individual landscape only accounts will be
combined and receive one WUA. Water Use Allowances for new water accounts, new
water customers, properties vacant in 2013, and water accounts with zero usage in
2013 will be based on the average usage of water customers in the same water
customer class (single-family, multi-family, mixed-use, commercial, industrial,
landscape, etc.) with the same meter size.
For example a single-family water customer whose home was vacant due to a remodel
in 2013 and as a result of the remodel their meter size increased from ¾ inch to two
inch because the house size increased significantly, shall get a WUA that is the average
of other single-family homes with a two inch meter.
Water Use Allowances
The Water Use Allowance formula for residential water customers is:
The average daily baseline use per billing period x the % of water available or the
residential threshold; whichever is higher
The Water Use Allowance formula for commercial and landscape water
customers is:
The average daily baseline use per billing period x the % of water available
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
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Table 2: Water Use Allowance for all Water Customers*
Stage 1 Stage 2 Stage 3 Stage 4
% Water
Available per
Customer
85%
80%
70% or
50%
Stage 1 Stage 2 Stage 3 Stage 4
85% Water
Available Per
Customer
80% Water
Available Per
Customer
70% Water
Available Per
Customer
50% Water
Available Per
Customer
Single-Family average daily
baseline use x
0.85
or
22 HCF;
whichever is
higher
average daily
baseline use x
0.8
or
22 HCF per
billing period;
whichever is
higher
average daily
baseline use x
0.7
or
16 HCF;
whichever is
higher
average daily
baseline use x
0.5
or
16 HCF;
whichever is
higher
Multi-Family average daily
baseline use x
0.85
or
11 HCF per unit;
whichever is
higher
average daily
baseline use x
0.8
or
11 HCF per
unit; whichever
is higher
average daily
baseline use x
0.7
or
8 HCF per unit;
whichever is
higher
average daily
baseline use x
0.5
or
8 HCF per unit;
whichever is
higher
Commercial average daily
baseline use x
0.85
average daily
baseline use x
0.8
average daily
baseline use x
0.7
average daily
baseline use x
0.5
Landscape average daily
baseline use x
0.85
average daily
baseline use x
0.8
average daily
baseline use x
0.7
average daily
baseline use x
0.5
*HCF is hundred cubic feet
Residential Water Conservation Thresholds – see Exhibit 1 for calculations
Water Shortage Supply Stage 1 & 2
Penalties will not be imposed for single family customers using less than 22 HCF per bi-
monthly billing period and each multi-family unit per building using less than 11 HCF per
bi-monthly billing period.
Water Shortage Supply Stage 3 & 4
Penalties will not be imposed for single family customers using less than 16 HCF per bi-
monthly billing period and each multi-family unit per building using less than 8 HCF per
bi-monthly billing period.
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
Page 7 of 12
Section 8: Penalties
When a Responsible Party exceeds the applicable WUA during a billing period, a
Penalty may be imposed through the issuance of. The notice of the penalty may be
issued to the responsible party in the same mailing as the utility bill an administrative
citation. The citation fine amount and will be calculated as set forth below.
$10 per HCF used in excess of the Water Use Allowance up to the total bi-monthly
water charges or $1,000, whichever is less.
first violation penalty: $250
second violation penalty (within twelve months of the first violation): $500
third violation penalty (within twelve months of the second violation): $1,000
Any Responsible party that exceed the WUA three times may be required to have a
water audit performed by a licensed engineering firm having water audit experience and
all related expenses paid by the Responsible Party. The audit must be performed and a
full report submitted to the City of Santa Monica within 30 -days of notice. The audit
report must include how the audit was administered, list all interior and exterior uses of
domestic and non-domestic water uses, results of the audit, recommendations, and
return on investment calculations. The City may require the implementation of the audit
recommendations as a precondition to granting any request for a WUA Adjustment.
Any Responsible Party that exceed the WUA seven or more times may have a flow
restrictor installed in the meter which restricts the flow of water going into the building,
be charged with a Civil Penalty, and/or be charged with a criminal penalty.
Section 9: Waiver of Penalty
Any Responsible Party that receives a first violation WUA exceedance penalty may
choose to attend a City offered water school. Upon successful completion of the water
school, the penalties associated with the first violation shall be waived. The City
Manager or his or her designee is authorized to develop regulations to implement the
water school program consistent with the policies, objectives and priorities of this Plan.
Section 910: Water Use Allowance Adjustment
Application for Water Use Allowance Adjustment
Comply with requirements listed under Required Finding for an Adjustment.
Fill out a Water Use Allowance Adjustment Application available at
www.smgov.net/water and 1717 4th St., Suite 150, Santa Monica, CA 90401.
Submit completed application and required supporting documentation (such as
photographs, itemized receipts, maps, drawings, engineering reports, water audit
reports, utility bill showing participation in any low income assistance program, or
other pertinent information) by mail or in-person at 1717 4th St., Suite 150, Santa
Monica, CA 90401.
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
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Approval Authority
The Adjustment Administrator will exercise approval authority and act upon any
completed Water Use Allowance Adjustment Application after submittal and may
approve, conditionally approve, or deny the adjustment request. The applicant
requesting the adjustment will be notified in writing of any action taken.
The decision of the Adjustment Administrator shall be issued within sixty days after the
conclusion of the hearing or the submission of all written materials if no hearing is
conducted. The applicant may appeal any such decision pursuant to Chapter 6.16 of
this Code. Unless specified otherwise at the time the adjustment is approved, the
adjustment applies to the subject property during the term of the applicable stage of the
WSRP.
Factors to be considered by the Approval Authority in Reviewing a Water Use
Allowance Adjustment Application:
Whether denial of the application would create an undue hardship which could
create an emergency condition relating to health or safety; or
Whether an undue financial hardship to a water customer would result; or
A new water account is requested by a new user; or
The property was vacant (or otherwise devoid of water use) during 2013 but is
now being inhabited; or
There has been an increase in household size or change in tenancy
Required Findings for an Adjustment
An application for an adjustment will be denied unless the approving authority finds,
based on the information provided in the application, supporting documentation, and/or
such additional information as may be requested, and on water use information for the
property as shown by the records of the City of Santa Monica, all the following:
1. The subject property has implemented all practical water saving measures at
minimum, unless unique circumstances that makes meeting these requirements
impossible:
a. High-efficiency toilets (uses1.28 gallons per flush or less)
b. High-efficiency urinals (uses 0.5 gallons or less per flush or is waterless)
c. High-efficiency showerheads (uses 2.0 gallons per minute or less)
d. High-efficiency faucets (uses 1.5 gallons per minute or less for residential
or guest rooms; uses 0.5 gallons per minute or less for commercial)
e. No leaks anywhere on the property
f. No irrigation runoff and overspray
2. That the adjustment does not constitute a grant of special privilege inconsistent
with the limitations placed upon other City of Santa Monica water customers.
3. That because of special circumstances applicable to the property or its use, the
requirements of the Water Shortage Response Plan would have a
disproportionate impact on the property or use that exceeds the impacts to
customers generally.
4. That the adjustment will not materially affect the ability of the City of Santa
Monica to effectuate the purpose of the Water Shortage Response Plan and will
not be detrimental to the public interest.
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
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Section 101: Definitions
Billing Period. The billing period is approximately 60 days between water meter
readings;
Commercial Water Customer. Any water customer whose property is not designated
as single family, multi-family or landscape only. This may include mixed-use properties,
schools, businesses;
HCF. The billing measurement for water in hundred cubic feet. One HCF
is equal to 748 gallons;
Irrigation. Any system for distribution of pressurized water in the
landscape, including but not limited to any system in which any portion is
installed below grade or affixed to any structure;
Landscape. Modification of the ground surface with live planting
materials such as trees, shrubs, turf, groundcover or other horticultural
materials; as well as non-living materials such as mulch, synthetic turf,
hardscape, or stone;
Landscape Only Account. Any water meter installed to measure the flow of water for
irrigation and landscape purposes only;
Master Meter Account. A meter that serves multiple tenants in a building and may
include but is not limited to water used for common areas such as toilets, urinals,
laundry, irrigation equipment and pools;
Multi-Family. A residential property with two or more units on the premises. This may
include master metered or individually metered units;
Multi-Family Individual Meter Account. A meter that serves only one unit and does
not include outdoor or landscape water use;
New Water Account. A new water service connection where one was not previously
installed;
Responsible Person or Party. Also referred to as the water customer or any other
party responsible for the violation.
Potable Water. Water suitable or intended for human consumption;
Single-Family. A residential property with one unit;
Shortage. The actual or projected demand for water placed upon the water supply
system by water customers which exceeds the actual supply, where the actual supply of
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
Page 10 of 12
water is the amount of water available for delivery from the municipal water supply
system for subsequent delivery to water customers;
Water: All potable water supplied from the municipal water supply system to any water
customer. Non-potable water that is metered separately is excluded;
Water Customer. The person designated on the water account records maintained by
the City as the person responsible for payment of charges incurred for the use of the
water supply system.
Water Demand. The amount of water used by water customers;
Water Use Allowance. The amount of water assigned to water customers based on a
percentage of the baseline water usage.
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
Page 11 of 12
Exhibit 1 – Residential Water Conservation Threshold
Calculations
The water use allowance is a percentage of 2013 water usage. Each water customer
will receive a WUA for each billing period. Residential water customers that are at or
below the residential water conservation threshold outlined in Section 7 will not need to
reduce water use.
The residential water conservation thresholds are calculated based on the following:
Assumptions for Calculating the Water Conservation Thresholds:
1. Number of Single Family Residents per Home = 4 (based on 2010 Census data)
2. Number of Multi-Family Residents per Unit = 2 (based on 2010 Census data)
Table 5: Water Use Gallons Per Capita Day Calculation Stage 1 & 2 based on
AWWA Residential End Uses Report and pre-2013 plumbing code standards
Allocated water use is 68 gallons per capita per day (gpcd)
Toilets 5 flushes x 1.6 gallons per flush 8.0
Shower/bath 5 min x 2.5 gallons per minute 12.5
Clothes Washer 1/3 load 6.0
Kitchen/Dishwasher 4 gpcd 4.0
Bathroom Sinks 4 gpcd 4.0
Inside Total (gpcd) 34.5
Cleaning/outdoor Use 33.5
TOTAL 68.0 gpcd
Table 6: Water Use Gallons Per Capita Day Calculation Stage 3 & 4 based on
AWWA Residential End Uses Report and 2013 plumbing code standards
Allocated water use is 50 gallons per capita per day (gpcd)
Toilets 5 flushes x 1.6 gallons per flush 8.0
Shower/bath 5 min x 2.5 gallons per minute 12.5
Clothes Washer 1/3 load 6.0
Kitchen/Dishwasher 4 gpcd 4.0
Bathroom Sinks 4 gpcd 4.0
Inside Total (gpcd) 34.5
Cleaning/outdoor Use 15.5
TOTAL 50.0 gpcd
Single-family Water Customer Threshold Calculation:
68 gallons gpcd x 4 people x 60 days (bi-monthly billing period) x 748 gallons (HCF) =
22 HCF
City of Santa Monica Water Shortage Response Plan January 13, 2015-September 8, 2015
Page 12 of 12
Multi-family Water Customer Threshold Calculation:
68 gallons gpcd x 2 people/unit x 60 days (bi-monthly billing period) x 748 gallons (HCF)
= 11 HCF/unit
Table 7: Threshold Water Use Billing Unit (HCF) Calculations
Stage 1 & 2 Stage 3 & 4
Single Family Water Account 22 HCF/bi-monthly
billing period
16 HCF/ bi-monthly billing
period
Multi-Family Master Meter
Water Account
11 HCF//unit/ bi-monthly
billing period
8HCF/ unit/bi-monthly
billing period