Preparing Water Conservation Plans for Florida’s Public Water Supply Utilities: Water Management District Guidance

Water conservation contributes to the sustainability of water supply resources. The Florida Legislature recognized in Section 373.227, Florida Statutes (F.S.) “...that the proper conservation of water is an important means of achieving the economical and efficient utilization of water necessary, in part, to constitute a reasonable, beneficial use. The overall water conservation goal of the state is to prevent and reduce wasteful, uneconomical, impractical, or unreasonable use of water resources.”

Water conservation should be a critical element in all water supply strategies. Conservation and efficiency measures should be maximized to the extent that is economically, environmentally, and technically feasible, regardless of the water source, before more-costly water supply development options are implemented. Water conservation can reduce and defer the need to develop new water supply sources to meet current or future demands. Moreover, conservation and demand management have been shown to reduce costs to utilities and rate payers over the long term (Chesnutt et al., 2018; Feinglas et al., 2013). Florida public water supply utilities are required to have a permit for the consumptive use of water. Florida is divided into five regulatory regions, each governed by a water management district (WMD), which issue consumptive use, or water use, permits, i.e., consumptive use permits (CUPs) or water use permits (WUPs). All five WMDs have a specific Water Use Permit Applicant’s Handbook (handbook) that needs to be followed to obtain a permit. Per these handbooks, a water conservation plan (WCP) is required when applying to obtain, modify, or renew a CUP for a public supply utility. The specific criteria for permit issuance vary among WMDs; however, the WCP requirements are nearly identical among them. After application submittal, the WMDs may need to request additional information related to the WCP due to outdated information, lack of critical elements, or lack of a schedule and frequency for implementation of the proposed measures and programs.

Josh Madden is a senior environmental project manager, and Cassidy Hampton is an environmental project manager, with Southwest Florida Water Management District in Brooksville. Deirdre Irwin is a water conservation coordinator, and Gretchen Smith is a water conservation coordinator, with St. Johns River Water Management District in Palatka. James Harmon, P.G., is a principal scientist, and Rosines Colon is a senior water conservation analyst, with South Florida Water Management District in West Palm Beach.

In this article, utilities will find recommendations on WCP structure and content that will make the plan more effective and readily acceptable to the WMDs.

The WMD staff members consider several factors when reviewing a WCP to determine if it’s effective, including utility size; volume of withdrawals; the historical, current, and projected per capita trend; if adverse impacts to the water resource are present or expected; and compliance status, among others. For example, a utility with a high per capita rate, or one that has an increasing per capita trend, is also located near an impacted water resource, and is requesting a large increase in quantities, would need a very robust WCP to quickly provide assurances that the water resources are being efficiently utilized and that the permit will be in compliance.

Another factor for consideration is that larger utilities and local governments have more resources available to implement morecomplex and costly initiatives and programs. Local governments and utilities are encouraged to take advantage of WMD cooperative funding (that covers up to 50 percent of

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In the WCP, utilities are encouraged to mention if WMD funding was received for conservation measures, along with quantified water savings rates. It’s also beneficial to partner with other entities that provide similar services, such as the University of Florida (UF) Institute of Food and Agricultural Sciences (IFAS) Extension.

A utility has the option to submit either a standard WCP or a goal-based WCP. A standard WCP includes five prescribed elements, while a goal-based WCP can include fewer or additional customized elements.

The standard WCP is the most common option currently used by utilities. The standard WCP must contain the five elements listed in the handbook:

1. Water Conservation Public Education Program

2. Outdoor Water Use Conservation Program

3. Rate Structure (that promotes water conservation)

4. Water Loss Reduction Program (if water loss is over 10 percent)

5. Indoor Water Conservation Program

The plan should be structured so that each of the five elements has a clear section header in the document to avoid confusion. According to the handbook, the proposed WCP shall allow no reduction in (i.e., maintain) and increase (where environmentally, technically, and economically feasible) overall utility-specific water conservation effectiveness. The WCP should be a forward-looking document and outline the conservation measures, programs, and actions the utility plans to implement in the future.

Presenting past programs and measures can serve as historical documentation for items, such as local water conservation-related ordinances that have been adopted in the past or as references or examples of similar activities that the utility plans to repeat into the future. Calculating the estimated savings for initiatives and programs can help demonstrate the effectiveness of a program; however, past programs or actions should not make up the bulk of a WCP unless they are current programs that are expected to continue. The requirement is for a water conservation plan, not a report of past action.

For each element, utilities should explain how the proposed measures and program will effectively promote water conservation. Activities should include frequency and duration, and an implementation schedule. Sometimes a measure (activity) might be difficult to classify because it can fit into more than one element from the handbook, especially if it’s a multifaceted program; however, utilities should avoid repeating information under multiple elements.

Public education and outreach programs can be powerful tools to help develop a conservation ethic within a community. Public education program benefits are not readily quantifiable, but are essential to building public awareness and support for water conservation programs.

Providing examples of the educational materials used by the utility is highly encouraged. State the schedule and frequency of the measures to be implemented. Public education examples include, but are not limited to:

S Outreach events and exhibits with water conservation speakers at schools and community organizations

S Website information

S Direct outreach and mailers to high-volume water users

S Sharing comparative and granular usage data with customers

S Bill stuffers

An effective outdoor water conservation program primarily addresses water use for irrigation. For some residential customers, more than 50 percent of their utility-supplied water is used for irrigation. Given that most new homes built in the last decade have inground irrigation systems resulting in more outdoor water use, reducing irrigation use should be the priority—now and in the future. It’s highly recommended that utilities focus their efforts on high-volume water users as they represent the greatest potential for water savings, and these measures tend to be more cost-effective. Ordinances implementing yearround irrigation restrictions (day per week limitations) and their subsequent enforcement are critical components of outdoor conservation. Utilities should coordinate with local code enforcement entities to maximize effectiveness of the restrictions.

Adoption of landscape and irrigation design ordinances/requirements for new construction, such as Florida Water StarSM, can also significantly curb future water demand and should be strongly considered for any utility or local government expecting significant growth. Additionally, utilities should consider landscape irrigation evaluations, irrigation timer resets, Florida-Friendly Landscaping® (FFL) demonstration gardens, and rebates for WaterSense-labeled irrigation controllers and/ or high-efficiency spray nozzles.

Water conservation refers to increasing the efficiency of use of any water source. While the WMDs encourage and fund alternative water supply projects (including reclaimed water), changing water sources is not considered a conservation measure. Inclusion of alternative water supply projects in a WCP is not appropriate.

The primary goal of a utility’s water rate structure is to generate the revenue needed to continue providing water supply services, but also encourage water conservation. Rate structures that encourage water conservation should send a price signal to high-volume water users to encourage them to reduce their water use. Pursuant to section 373.227(3), F.S., the WMDs shall afford the utility wide latitude in adopting a rate structure; however, some rate structures are more effective than others at promoting water conservation. The most common and effective water conserving rate structure is an increasing block rate (i.e., inclining tiered rate) structure.

In increasing block rate structures, the price per unit of water rises as consumption increases; in other words, the more water a customer uses, the higher the cost per unit of water. These rate structures are most effective at promoting water conservation if the cost difference between tiers is substantial and the volumes between tiers are close enough to send the desired signals to the average water user. Furthermore, if a large percentage of the total bill is comprised of the base charge, the volumetric conservation charge is less impactful.

When setting water rates, utilities are encouraged to consider setting pricing, tiers, and base charges in such a way that it sends an effective conservation signal, while still recovering adequate operational revenue. If a utility hires a consultant to develop its water rates, the utility should specify that sending an effective conservation signal is one of its water rate goals.

Table 1 presents hypothetical increasing block rates that have different levels of effectiveness in promoting water conservation. Even though the rate for Utility No.1 is an increasing block rate, once the base fees are factored in, customers that use 12,000 gal per month are paying less per 1,000 gal (Kgal) of water (i.e., $3.54 per Kgal) than customers using only 4,000 gal of water per month ($8.50 per Kgal). Furthermore, the total difference between the bill for 4,000 gal and the bill for 12,000 gal is only $8.50, even though one customer uses three times more water than the other. The high base charges, combined with larger tiers and small price increases, cause the average cost per unit (Kgal) to be less for the higher users, making the rate for Utility No. 1 less effective in promoting water conservation.

In contrast, the rate for Utility No.2 uses a lower base charge, smaller tiers, and moresignificant price increases to affect the amount paid by high users. In this case, customers using 4,000 gal of water are only paying $2.44 per Kgal, and customers using 12,000 gal are paying $3.10 per Kgal. The customers that use 12,000 gal pays almost four times more in their total bill ($37.20) than the customers using 4,000 gal ($9.75).

Tiers should be visible on the bill so that customers can easily recognize that water gets more expensive per unit as more water is used. A copy of an example water bill should be included as an appendix to the utility’s WCP.

Utilities with water losses greater than 10 percent are required to present a water loss reduction program as part of their standard WCP. Water losses should be calculated in accordance with the handbook guidance. It’s recommended to develop a water loss reduction program, even if loss is less than 10 percent, because keeping water loss low has financial benefits for a utility when considering underreading customer meters and chemical costs.

The steps of an effective water loss reduction program are shown in Figure 1.

Documenting this process with a schedule that works for the utility is important. If possible, include activities such as completing a water audit by April 2023 and each subsequent year thereafter, implementing a meter testing program, replacing 10 percent of customer meters per year, repairing 95 percent of leaks within one week of notification, installing meters on all water line flushing locations by 2024, and optimizing water line flushing quantity each quarter.

Indoor water use efficiency has increased steadily over the last 20 plus years in the United States, from 69.3 gal per capita per day (gpcd) in 1999 to 58.6 gpcd in 2016 (DeOreo, Mayer, Dziegielewski, & Kiefer, 2016). Even as old and inefficient plumbing fixtures, like 3.5-galper-flush (gpf) toilets, are becoming scarce, opportunity still exists to save water indoors thanks to innovation with more-efficient fixtures (e.g., replacing 1.6-gpf toilets with 0.8-gpf toilets). The indoor element of a WCP should consider leak alerts to customers using advanced metering infrastructure systems, conservation kit giveaways, and in-home evaluations.

Applicants should not include adhering to federal manufacturing standards or state building code standards as part of their WCP, as these standards do not reflect the utility’s active conservation program.

Examples of how water conservation activities should be shown in the plan are in Table 2.

While the majority of utilities prepare standard plans, goal-based WCPs are encouraged to establish a measurable goal and document the measures to be implemented, along with associated savings. Some examples where goal-based plans are highly encouraged are:

S If a utility’s current or projected demands are or will impact water resources or existing users.

S If there is a regulatory requirement to reduce per capita water use below a specific amount.

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S If the utility’s water use is nearing its permitted allocation and new infrastructure will need to be constructed to meet future needs.

S If customer demands periodically exceed the water system’s peak supply capacity, resulting in low system pressure.

When compared to developing new alternative water supply sources or constructing new facilities, conservation is typically less expensive, and therefore, more economically sound. Setting a measurable goal tied to implementation of identified active measures and programs helps to ensure success. The goal may be a reduction in per capita use, a percent reduction of overall demands, a reduction in frequency and magnitude of production peaks, or some other metric.

Utilities may choose to submit a goalbased WCP as part of their application. A utility should select plan elements that are appropriate to its service area, even if they are different from, and/or inclusive of, those in the standard water conservation plan described.

The plan should contain the following:

S A description of water conservation measures and programs selected and an implementation schedule for each.

S An explanation of why alternative elements included in the goal-based WCP are more appropriate to achieve effective water conservation in the utility’s service area if any of the five elements in the standard WCP are not selected.

According to Section 373.227(4), F.S., progress toward the goal must be measurable. Recommended methods to measure progress include calculating the reduction in residential per capita, gross per capita, or per service connection water use; number of participants in the program; households included in the initiatives, etc. For example, an applicant might include a goal to decrease its gal per capita demand by 5 percent by the end of the permit duration. This goal will be accomplished by implementing several water conservation initiatives and measures that will target indoor and outdoor water use. In this case, the applicant should provide measurable progress toward the goal by tracking a reduction in use annually and explain any variables that delayed progress (such as droughts).

A goal-based WCP allows the utility to tailor its conservation measures to meet its objectives. Meeting water conservation goals can result in lowering operating costs, delaying the development and expansion of water sources, reducing nonrevenue water, etc. Utilities can target specific areas and users where water can be used more efficiently. For example, a utility with the appropriate infrastructure and software might collect data that suggest if industrial users with cooling towers engage in better practices, they could reduce cooling tower water use by 30 percent. The utility could include a goal to save a specific amount of water by reaching out to these specific water users and implementing measures to reduce their water use with retrofits, rebates, and evaluations.

A goal-based WCP requires detailed planning, but also allows more flexibility. It also showcases a utility’s commitment to water conservation by providing measurable milestones and goals.

According to Dr. Nicholas Taylor, manager of the UF IFAS H2OSAV Program (Taylor, 2023), a water conservation program’s success can be attributed to four key factors:

S Effectiveness – has measurable water savings

S Significance – size and scale of program is impactful to service area

S Reliability – savings are consistent and reliable every time they are implemented

S Persistence – long-term program, water savings continue over time

A water conservation plan should be scaled to the size and needs of a utility, forwardlooking, include an implementation schedule, and maintain or improve water efficiency among customers. The plan should include standard elements outlined in the applicant handbooks or appropriate alternatives in a goal-based plan.

As Florida approaches the limits of traditional water supplies, a goal-based WCP is preferred and, as mentioned, can delay costs associated with alternative sources of water. Finally, WMD conservation staff members are available anytime to advise and guide utilities with water conservation matters, including WCP development, and during permit preapplication meetings.

Additional water conservation information is available on all of the WMD websites.

Measure/Activity

Public Education

Bill stuffers containing water conservation information and tips are sent to customers with each monthly bill. Examples are included in appendix A.

Outdoor

Ongoing activity Irrigation evaluations with zoneby-zone recommendations, timer reset, and rain sensor provided by a licensed irrigation contractor Focused on high water users and includes education with homeowner on FFL and controller operation.

Water loss

Install meters on all water line flushing locations. Complete by 2024

Indoor

Ongoing activity – Toilet rebate (up to $100) to replace older, pre-1994 toilets with new 0.8 gpf units. Program is currently WMD-cofunded. It’s promoted with bill stuffers, digital ads, and the county’s social media account.

2030

• DeOreo, W., Mayer, P., Dziegielewski, B., & Kiefer, J. (2016). Residential End Uses of Water, Version 2. Water Research Foundation.

• Taylor, N. (2023, February 2). Trends in Water Use [meeting presentation]. Quarterly Water Conservation Forum, Kissimmee, Fla., United Sates.

• Chesnutt, T.W., D. Pekelney, and J.M. Spacht. 2018. Lower Water Bills: The City of Los Angeles Shows How Water Conservation and Efficient Water Rates Produce Affordable and Sustainable Use. California Water Efficiency Partnership, Sacramento, Calif., and Alliance for Water Efficiency, Chicago, Ill.

• Feinglas, S., C. Gray, and P. Mayer. 2013. Conservation Limits Rate Increases for a Colorado Utility. Alliance for Water Efficiency, Chicago, Ill. S