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SR-11-24-2015-4B City Council Report City Council Regular Meeting: November 24, 2015 Agenda Item: 4.B 1 of 18 To: Mayor and City Council From: Dean Kubani, Sustainability Manager, Office of Sustainability and the Environment Subject: Proposal for Water Neutrality Ordinance Recommended Action Staff recommends that the City Council review and comment on options f or creation of a water neutrality ordinance for new development, tenant improvement projects and major remodels, and provide staff with direction on how to proceed. Executive Summary At a time when frequent drought conditions are widely predicted to be "the new normal," City Council has directed staff to look at replacing our current Water Demand Mitigation (WDM) fee with a policy to require new development to completely offset the added water demand above the baseline of previous water use on the site. Staff believes that this can be achieved through implementation of a water neutrality ordinance requiring developers to achieve this goal by installing water efficiency retrofits elsewhere in the community; through a modification of the WDM fee; or a combination of both. While many other cities are moving in this direction, there are no "off the shelf" models that fully ensure that water efficiency measures eliminate the need for additional water generated by new development. Santa Monica would be breakin g new ground; there are practical advantages as well as disadvantages to the various options, including paying for start-up costs for implementation, ranging from $25,000 to $340,000; potential reductions between $235,000 and $300,000 in future Water Fund revenues from WDM fees under the direct offset approach; and possible annual reductions in Capital Facility Fee revenues of between $375,000 and $475,000 . Background On October 28, 2014 during City Council’s discussion of the Water Shortage Response Plan and the Sustainable Water Master Plan, Council directed staff to look into the feasibility of developing requirements to offset or eliminate new water demand related to new development in Santa Monica and report back on what forms those requirements might take. Council also asked staff to look into options for modifying the City’s existing Water Demand Mitigation (WDM) Fee to further incentivize water conservation. 2 of 18 Water Demand Mitigation Fee On February 26, 1991, Council approved an ordinance authorizing the WDM Fee (Ordinance Number 1571 (CCS), codified in SMMC Section 7.16.050). On March 19, 1991 Council adopted Resolution No. 8196 (CCS) setting the fee amount and specifying that it would be used to retrofit water inefficient plumbing fixtures in the City. The intent of the fee was to mitigate the increase in water use of new and substantial remodels in single-family, multi-family and commercial projects during a water shortage. It is a one - time fee charged to new development intended to mitigate the total daily water consumption rate projected for the development. The total daily water demand for the project is calculated using standard water demand factors which were developed by City staff. The fee is set at $3.00 for each gallon of daily wat er demand which must be mitigated. The fee amount and formula for calculating it has not been updated since the fee was adopted. Payment of the fee is triggered by the following:  Single-Family Residence -- for construction of a new residence or wheneve r adding 50% or greater to the square footage.  Multi-Family -- for construction of a new building or whenever new units are added.  Non-Residential -- for construction of a new building or whenever there is a change of use, changing or adding plumbing fixtu res, or adding restaurant seats or square footage. The WDM fee generates approximately $300,000 in revenue annually which is used to fund a variety of water efficiency upgrades to public infrastructure throughout the city, including installations of water-efficient plumbing, landscaping, rainwater and stormwater capture and reuse equipment, and indoor plumbing fixtures. 3 of 18 Similar Actions by Other Cities A number of cities and utility districts, primarily in the most drought impacted areas of California, have adopted policies designed to offset water use related to new development. These include the cities of Lompoc, Morro Bay, Napa, and St. Helena; San Luis Obispo County; and water districts in Cambria, Monterey and Soquel Creek. In general these policies either require a developer to directly offset the new water demand of their development project through the installation of water efficiency retrofits elsewhere in the community, or pay an in -lieu fee (similar to Santa Monica’s WDM fee) which is used by the city, county or water agency to fund water efficiency offsets. Discussion Staff from the Office of Sustainability and the Environment (OSE) have reviewed similar ordinances and regulations adopted by other cities, interviewed staff in the cities of Napa, CA and Morro Bay, CA about implementation and effectiveness of their ordinances, and worked with staff from Planning and Community Development, the City Attorney’s Office, Public Works, and the City Manager’s Office to develop the options presented in this report. The City’s Task Force on the Environment and Water Advisory Committee have also provided input on the proposals. The Task Force on the Environment adopted the following motion at their October 19, 2015 meeting regarding water neutrality: The Task Force on the Environment recommends that City Council develop and approve a W ater Neutrality Ordinance that requires all new projects and major remodel projects must offset any water demand that exceeds the current water use on the project property. (Note: this motion replaces a similar motion adopted by the Task Force on February 23, 2015 regarding water neutrality) Options for Achieving Water Neutrality 4 of 18 As noted above, the two primary mechanisms currently in use to promote water neutrality for new development are either 1) requirements for developers to directly offset the calculated new water demand prior to construction of the new development through the replacement of inefficient water fixtures or irrigation systems on existing properties in other parts of the jurisdiction with more water efficient fixtures or systems, or 2) requirements that in-lieu fees be paid to a jurisdiction to complete water offsets. Both of these approaches have positives and negatives and require costs to effectively administer in order to achieve water neutrality. These are discussed below. Direct Offset Approach Following review of similar water neutrality regulations and discussion with staff in other jurisdictions it was clear that the most effective way to ensu re that all water demand related to new development is completely offset is to institute the direct offset requirement. Below is a description of how this approach could be implemented in Santa Monica.  Applicability: For all projects that require development review permits, development agreements and all projects over a certain size (e.g. 7500 square feet) that require a change-of-use permit (such as tenant improvement projects), any increase in water demand on the project site would have to be offset. I n other words, credit would be given for the existing water use baseline on the site, but any additional water demand would need to be offset on a 1:1 basis. This ratio could also be adjusted to require a greater than 1:1 offset in order to generate overall water demand reductions in the event that prolonged drought conditions necessitate a higher offset. Projects in the Paso Robles and Los Osos Water Basins in San Luis Obispo County and within the Soquel Creek Water District are currently required to achieve a 2:1 offset ratio. It is important to note that these areas are currently impacted by either restricted water sources, salt water intrusion, or intensive agricultural uses that are not experienced to the same extent in Santa Monica. 5 of 18  Calculate Net New Water Demand: The amount of water demand to be offset would be determined during the plan check process either by requiring a developer to submit information regarding the type and number of water fixtures (toilets, sinks, showers, cooling towers, irrigation systems, etc.) in the new development, or by applying a standardized water use calculation based upon the size and use of the building. In both cases, City staff would be required to review the plan submittals and calculate the projected usage from the development. The projected water demand minus the existing water use at the site (determined by taking the average of water use at the site over the previous three years), or, alternatively, an imputed reasonable allocation based upon the existing zoning allowed for development permitted by right, is the amount that the developer would be required to offset. The developer would have an incentive to design the project to be as water efficient as possible in order to reduce the offset requirement.  Offsets: Eligible offsets would need to be identified in other locations in Santa Monica where water use could permanently be reduced, and then developers would be responsible for implementing those offsets and demonstrating to the City that they have been completed prior to receiving a Certificate of Occupancy. Offsets could include retrofitting toilets in existing buildings, replacing lawns and other high water use landscaping, or upgrading irrigation systems or other infrastructure. Because Santa Monica has a significant amount of older multi- family apartment buildings it is believed that replacing 1.6 gallon per flush toilets with more efficient toilets (1.28 gpf or less), along with efficient faucet fixtures and showerheads, in existing buildings could provide offset opportunities for several years based on the anticipated near term levels of new development and remodels. An offset program could be managed and administered by City staff, by an outside vendor contracted by the City or, as is the case in Morro Bay, CA, a developer could be directly required to identify the offset opportunities, complete the retrofits, and demonstrate to the City that the offsets have been completed. Each of these alternatives, and their associated costs and trade -offs are discussed in more detail below. 6 of 18 Estimated Volume of Projects There are presently 32 projects (26 development agreements and 6 development review permits) that are pending review that could be subject to a water neutrality ordinance requiring direct offsets as described above. Table 1 presents the estimated potential water demand of the pending projects, as analyzed in the 2010 LUCE Final EIR. The total estimated water demand of pending projects equals 695,463 gallons per day, which equates to annual water use of 780 acre-feet per year. The current citywide water demand is approximately 14,000 acre -feet per year so the projected new demand would equate to an increase of about 5.5% beyond current demand. It should be noted that this projected demand does not take into account recently adopted water efficiency standards which would likely result in a smaller increase in water demand than was projected in the LUCE EIR. It should also be noted that for development agreement projects, negotiations have typically included performance standards for water efficient fixtures and a minimum percentage below CalGreen baseline for interior and exterior water use, resulting in projects that would likely have lower demand than presented below. Table 1: Pending Projects Estimated Water Demand Use Residential Retail Office Hotel Cultural Hospital Amount 1,802 units 402,988 sf 106,800 sf 921 rooms 13,700 sf 799,000 sf Estimated Water Demand Factors* 124 gpd/unit 0.15 gpd/sf 0.10 gpd/sf 130 gpd/room 0.11 gpd/sf 0.35 gpd/sf Estimated Water Demand (gpd) 223,448 60,448 10,680 119,730 1,507 279,650 *From 2010 LUCE Final EIR Sample Offset Calculation and Cost for Compliance In order to determine a rough estimate of the potential cost to developers to fully offset their water demand, staff evaluated a small sample of newly built mixed-use and multi- family properties to determine their actual water usage. These water use figures were compared to the previous water use at each site to determine the amount that would be required to be offset in order to achieve water neutrality for that property. The cost of 7 of 18 the offset was determined by calculating the average water savings for the replacement of an existing toilet with a more water efficient model and then dividing the amount of water to be offset by the amount of savings per toilet to determine the number of toilets that would need to be replaced in order to meet the offset requirement. Toilet replacement was used for this estimate because it is the most cost effective way to reduce water usage and would likely be the method chosen by most developers to offset new water demand. The buildings evaluated for this estimate had between 36 and 122 individual residential units. The annual water use in the buildings sampled averaged about t wo million gallons per year with the per unit water usage averaging about 32,500 gallons per year. Based on a current contract with a plumbing company to install high -efficiency toilets, the cost to replace an existing residential type toilet is approxim ately $350. There would also be a cost for administration which would be determined based on the projected number of new projects, plan review, verification, certification, and database management. The administration cost could add approximately 25% to 30% to the total cost of the retrofit project. The full costs for retrofitting and administering this type of program would need to be determined through a fee study. For the example below staff chose an existing office building which was replaced with a Tier 2 mixed-use property with 40 residential units. This represents a typical project constructed in the downtown area in the past several years. It is important to note that the potential water offset requirement for any project is highly variable depen ding on the previous water usage on the property. Sample Offset Calculation and Cost - Mixed Use Building with 40 Residential Units Previous Water Use at Site (Gallons Per Proposed Water Use of New Development Water Use in Gallons to be Offset Per Year Number of Toilets to be Retrofitted Cost to Retrofit Toilet (doesn’t 8 of 18 Year) (Gallons Per Year) include admin fee) 34,229 1,300,000 1,265,771 1,084 $379,400 Proposed New Development: 40 residential units Average Water Use per Unit: 32,500 gallons/year Proposed Annual Water Use (entire project): 32,500 x 40 units = 1,300,000 gallons/year New Water Demand to be Offset: 1,300,000 (new development demand) - 34,229 (existing water use at site) = 1,265,771 gallons/year Average Water Savings for each 1.6 gallon per flush (gpf) toilet replaced with a 1.28 gpf toilet: 3.2 gallons per day x 365 days = 1,168 gallons Number of Toilet Replacements Required: 1,265,771/1,168 = 1,084 Toilets Estimated Cost: 1,084 toilets x $350 (cost to retrofit a residential style tank toilet) = $379,400 to offset 1,265,771 gallons per year Based on the above example (and other estimates calculated but not shown here) and factoring in estimated administrative fees, it is anticipated that the cost to a developer to offset 1000 gallons per year of new water demand would be approximately $350 - $500 if the retrofit were accomplished through the replacement of toilets. As noted above, there are many variables that have been used to arrive at this rough estimate and it is only provided to help with discussion. 9 of 18 Implementation and Costs for Direct Offset Options 1. City Administered Program – This option would be entirely administered by the City of Santa Monica’s Office of Sustainability and the Environment . Staff would identify existing properties throughout the city whose owners are interested and willing to have their plumbing fixtures upgraded with more efficient fixtures to offset the additional estimated water use of applicable new development or improvement commercial projects; approve applicable project offset requirements; hire and assign plumbers to install the devices; and track the installations and water offsets. The developer/applicant would pay the City directly for all expenses related to the offset process. This option wou ld require the hiring of one full time staff person. Ongoing annual costs (including staff salary costs) would be approximately $150,000. In addition, first year program start-up costs would be approximately $115,000 for a new staff work station and office equipment, computer software upgrades, and miscellaneous expenses. Alternately, if this option were completed using existing staff , the start-up and ongoing staffing costs would be avoided, however, OSE’s ability to provide water consultations to residents and businesses and effective enforcement of water efficiency regulations would be reduced. This would negatively impact OSE’s drought response efforts and would make it more difficult to achieve the City’s water conservation goals. A City administered program would allow for accurate tracking and verification of achievement of water neutrality goals but is also the most staff intensive and costly. 2. Applicant Administered Program – For this program, the City’s involvement would be minimal. The developer/applicant would be required to identify offset options in the community, negotiate with the property owner where the offsets would be obtained, complete installation of the offset equipment using their own installer, and pay all costs. OSE staff would oversee the verification process with costs for verification able to be recovered through the collection of a permitting and processing fee paid by the developer/applicant. This option would not likely require the hiring of additional staff however if the volume of offset applications is 10 of 18 significant this would impact the ability of existing staff to complete other job responsibilities, including water consultations to residents and businesses and effective enforcement of water efficiency regulations, in a timely manner. One- time costs would likely be approximately $25,000 for computer software upgrades and ongoing costs for computer maintenance would be approximately $5000 per year. This option would shift the burden for compliance to the developer, and could become onerous for small development projects to complete. 3. Vendor Administered Program – this option would be similar to option 1 except that the City would hire a vendor to administer all aspects of the program. Staff estimates that the annual cost to complete this scope of work would be approximately $150,000 for an outside vendor, with an additional $25,000 for first year start-up costs. Options 1 and 3 above would provide the best quality control and tracking of water offsets but would require significant start-up costs to administer. It is anticipated that costs could be recovered through permitting and processing fees, however funds would need to be identified in order to initiate the program. In addition, all options would likely result in a net loss to the City due to a decrease in Water Fund revenues. Implementation of a water neutrality requirement for new development could also result in the reduction in development-related revenues that currently accrue to the Water Fund. New developments are currently required to pay connection fees and capital facility fees to the City in order to connect to the City’s water system. Accrual of these fees based on anticipated future development in Santa Monica was factored into the calculation of the City’s current water rates. Capital facility fees generate approximately $375,000 to $475,000 per year in revenue depending upon the level of development from year to year. The capital facility fees are charged to help offset increased capacity requirements to the water infrastructure that the project will create. If a developer offsets the water demand from a new project, it would be difficult to calculate and charge a capital facility fee for that project. However, while the total water demand in the City would be unaffected, the new development would still be increasing the water 11 of 18 demand within its localized area, with a concurrent decrease in the area where the offsets were installed. This localized increase in demand could require localized infrastructure upgrades which would require a new source of funding. An alternative fee mechanism to account for these anticipated costs would need to be developed in order to adequately fund future infrastructure and capacity upgrades. Timeline for Direct Offset Program Development and Launch Staff estimates that a City- or vendor-administered direct offset program could be established and ready for implementation within 11 months. The following steps would be involved in the program development process: • Select water-saving devices • Establish water use savings for selected devices • Establish ConserveTrack software update specifications • Amend contract with ConserveTrack to perform software update and provide on- going maintenance • Create applicant checklist • Research top water users • Invite top water users to apply for the program • Open up the program to the public • Select plumbers through a competitive bid process and award contracts • Develop checklist for plan submittal • Complete fee analysis to allow for recovery of administrative costs • Possibly modify the existing connection and capacity fee structure • Establish plan check process • Establish installation verification process If Council directs staff to proceed with development of a Water Neutral ity Ordinance requiring direct offsets, staff anticipates that a draft ordinance could be brought back to Council for first reading by February 2016. In-Lieu Fee Approach 12 of 18 As noted above, the City’s current WDM fee is intended to offset water demand from new development. It is a one -time fee charged to new development to mitigate the total daily water consumption rate projected for the development, and applies to new development and major remodels of single family, multi -family and non-residential projects. The fee generates approximately $300,000 per year and is used to fund City water efficiency infrastructure upgrades, including replacement of irrigation systems in parks and public landscapes, rainwater catchment and reuse systems, and installation of water efficient fixtures in public facilities. The fee amount was developed in 1991 and is based on the estimated cost to offset a gallon of water demand at that time. For single family and multi-family residential projects, the fee is based on estimated water use for a typical project of each type. For non -residential projects the projected water use is estimated based on the project square footage and building type. Staff was not able to identify any jurisdiction that is effectively using an in -lieu fee option to offset 100% of projected water demand from new development projects. The primary reason for this is that these fees are often times generated by many small projects in small amounts and, because jurisdictions typically use the fees to fund inf rastructure projects which are often large and expensive, these improvements may happen months or years after a development is completed. Staff was unable to find a jurisdiction that carefully tracks water savings from projects funded by water demand miti gation or in- lieu fees and links them back to the projects that generated the funds. This is not to suggest that in-lieu fees are not effective at producing water savings, but rather that it is difficult to directly track those water savings back to a specific development to demonstrate that the new demand from that development was completely offset. The WDM fee could be used on its own or in conjunction with a Direct Offset program to address water neutrality in new developments and major redevelopments. If used on its own the WDM fee would continue to apply to all development projects. If a Direct Offset option is preferred by Council, for smaller projects that would not require development review or change of use permits, such as single family residen tial and very small commercial and multi-family projects, Council could require that those projects pay the WDM fee to ensure that new water demand is indirectly offset for those projects as well. 13 of 18 Alternately, Council could exempt these small projects from paying the fee. Because of their small size these projects generate relatively little new water demand. Collectively they currently generate approximately 22% of the WDM fee revenues however they represent 76% of the projects that are subject to the fe e. If Council directs staff to pursue either of these options, staff recommends that the WDM Fee be reevaluated and updated to reflect current costs to offset water use and more accurately reflect projected water demand from new projects. This process would require a new nexus study, further fee analysis and Council action if the amount of the fee were increased. A tracking procedure could also be established to provide better correlation between the water savings achieved by the projects funded by the fee and the increased water demand generated by the projects that paid the fee. The estimated costs and trade-offs for these various approaches are discussed below. Implementation and Costs for In-Lieu/WDM Fee Options If Council wishes to continue using the WDM Fee, either as the sole means to address and offset new water demand, or in conjunction with a Direct Offset program, staff recommends that a fee analysis and nexus study be completed. This would cost approximately $75,000 and take approximately six months to complete. In conjunction with the adoption of a new fee, staff could develop a tracking system in-house at a minimal cost. This would however increase staff workload to continually monitor and regularly report on the offsets. If the WDM Fee were used in conjunction with a Direct Offset program and restricted to single family residential and small multi-family and commercial projects, the annual revenues from WDM Fees would be reduced from approximately $300,000 to $65,000. If Council decides to eliminate the WDM Fee moving forward this would result in a $300,000 reduction in revenues to the Water Fund , eliminating this source of funding for water efficiency upgrades to the City’s infrastructure. 14 of 18 Summary of Water Neutrality Options 1. Continue with Water Demand Mitigation Fee Only For All Projects Advantages:  The fee and the process to collect it is already established.  Fee currently generates approximately $300,000 per year which funds water efficient City infrastructure upgrades. Challenges:  No tracking system has been established to directly link water offsets to particular development projects and ensure that 100% of new water demand has been offset. Tracking system would need to be developed if Council wanted to demonstrate that new water demand was completely offset by upgrades funded by the WDM Fee.  New water demand would not likely be offset in advance of occupation of new developments due to the way the WDM funds are expended.  Fee methodology and amount was developed in 1991 and requires updating.  New nexus study and fee analysis should be completed if the fee is continued to be used. Council action needed to adopt a new fee. Estimated costs:  Approximately $75,000 to complete a Fee analysis/ Nexus study  Minimal costs to develop tracking system 2. Create Direct Offset Program and continue using WDM Fee for small projects Advantages:  Direct offset program can ensure that new water demand is completely offset prior to occupation of a new development.  Developers could complete Direct Offsets through the retrofit of older, private multi-family housing, which would permanently reduce water use and costs to those properties and their owners and occupants.  Retaining the WDM Fee option for single family homes and smaller 15 of 18 developments and tenant improvement projects could help to ensure that new water demand from smaller projects continues to be offset while simplifying the offset requirement process for these smaller projects. Challenges:  Establishment and Implementation of a Direct Offset Program would take approximately 11 months and require upgrades to existing computer programs, development of a submittal and verification process, and modification to the City’s existing plan check process.  Staff would need to develop an alternate fee calculation to ensure that new developments contribute to the cost of upgrading and maintaining local water infrastructure.  A tracking system would need to be developed if Council wanted to demonstrate that new water demand from smaller developments not subject to the Direct Offset requirement was completely offset by upgrades funded by the WDM Fee.  New water demand from the smaller developments not subject to the Direct Offset requirement would not likely be offset in advance of occupation of new developments due to the way the WDM funds are expended.  WDM Fee methodology and amount was developed in 1991 and requires updating.  New nexus study and fee analysis should be completed if the fee is continued to be used. Estimated Costs:  Start-up costs would range from $25,000 to $115,000 and ongoing annual costs for program implementation would range from $5,000 to $150,000 depending upon the type of Direct Offset Program (City Administered, Vendor Administered, or Developer Administered) the Council prefers. 16 of 18  Annual revenues from WDM Fees would be reduced from approximately $300,000 to $65,000 with the shift to the Direct Offset requirement for larger development projects. This funding reduction would directly impact efficiency upgrades to the City’s water infrastructure.  Annual loss of $375,000 to $475,000 in Capital Facility Fee revenues  Approximately $75,000 to complete a Fee analysis/ Nexus study  Minimal costs to develop tracking system 3. Create Direct Offset Program and Eliminate WDM Fee Advantages:  Direct offset program can ensure that new water demand is completely offset prior to occupation of a new development.  Developers could complete Direct Offsets through the retrofit of older, private multi-family housing, which would permanently reduce water use and costs to those properties and their owners and occupants.  Elimination of WDM Fee would eliminate the need for updating the fee methodology and completing a new nexus study. It would also somewhat reduce the current staff workload involved in collecting and tracking the WDM Fees on individual projects. Challenges:  Establishment and Implementation of a Direct Offset Program would take approximately 11 months and require upgrades to existing computer programs, development of a submittal and verification process, and modification to the City’s existing plan check process.  Staff would need to develop an alternate fee calculation to ensure that new developments contribute to the cost of upgrading and maintaining local water infrastructure  New water demand from smaller developments and single family projects would not be offset if Council restricted the requirement to developments above a certain size threshold. 17 of 18  Smaller development projects and single family homeowners could find compliance with this process to be onerous if the developer were required to directly complete all of the program requirements (as opposed to participating in a City or Vendor administered program) Estimated Costs:  Start-up costs would range from $25,000 to $115,000 and ongoing costs for program implementation would range from $5,000 to $150,000 depending upon the type of Direct Offset Program (City Administered, Vendor Administered, or Developer Administered) the Council prefers.  Annual revenues from WDM Fees of $300,000 would be eliminated by pursuing this option. This funding reduction would directly impact efficiency upgrades to the City’s water infrastructure.  Annual loss of $375,000 to $475,000 in Capital Facility Fee revenues Environmental Analysis A Water Neutrality Ordinance as discussed above would be exempt from the provisions of the California Environmental Quality Act (CEQ A) pursuant to CEQA Guidelines, Section 15307 (Class 7). Section 15307 provides exemption for a class of projects (Class 7) consisting of actions taken by regulatory agencies to assure the maintenance, restoration, or enhancement of the natural resource where the regulatory process involves procedures for the protection of the environment. A proposed ordinance would provide for the maintenance and enhancement of the City’s water resources. Therefore, the ordinance qualifies as a Class 7 exemption. Financial Impacts & Budget Actions There is no immediate financial impact or budget action necessary as a r esult of the recommended action, however, depending upon on Council recommendations, costs for development, implementation and enforcement of a proposed Water Neutrality Ordinance could range from $25,000 to $340,000, with ongoing costs ranging from $5,000 to $150,000 annually. Revenue to the Water Fund could be decreased by 18 of 18 $235,000 to $300,000 if the WDM Fee were modified or eliminated and by $375,000 to $475,000 if the water neutrality efforts resulted in the Capital Facility Fee being eliminated. It is anticipated that administrative costs could be recovered through permitting and processing fees, however funds would need to be identified in order to initiate the program. In addition, all options would likely result in a net loss to the City due to a decrease in Water Fund revenues. Budget requests and changes would be included in a future report based on Council direction. Prepared By: Jennifer Simmons, Approved Forwarded to Council