2.1 Conservation Coordinator (last amended December 2017[LTT1])
Applicability
This BMP is required by HB 1648[1], effective September 1, 2017, intended forof all retail public water utilities with 3,300 service connection or more. It is also recommended for all other Municipal Water User Groups (“utility”). A common element in successful conservation programs1[TL2] is a conservation coordinator who is responsible for coordinating utility staff support, data from various departments, and other resources as necessary for the purpose of implementing and maintaining the utility’s water-use conservation plan.program[TL3][LTT4].
Description
A Conservation Coordinator is an individual designated to oversee and coordinate conservation efforts within a utility and throughout the utility’s service area. A regional supplier may have a coordinator that works with all of its wholesale customers. Under this BMP, the utility designates a Conservation Coordinator to be responsible for preparation and implementation of the utility’s water conservation and drought contingency plans, preparation and submittal of annual conservation status reports to utility management, and implementation of the utility’s conservation program. Other duties should include preparation of the annual conservation budget, promotion of water conservation programs, developing marketing strategies for conservation programs, coordination with other utility staff and promoting the value of conservation programs within the utility, participation in regional water planning conservation and drought period initiatives and management of conservation staff, consultants and contractors when appropriate.
The Conservation Coordinator may have other duties and job titles within the utility. Small utilities may share costs with other small utilities by jointly hiring a Conservation Coordinator. Wholesale suppliers may hire a Conservation Coordinator to serve the retail utilities that receive water from them. Retail public utilities that provide potable water service to 3,300 or more connections must designate a Conservation Coordinator per HB 1648 requirements[LTT5].
Implementation
Implementation should consist of identifying a Conservation Coordinator and support staff (when needed), whose duties can include the following:
1) Manage and oversee conservation programs and implementation; 2) Document water conservation program implementation status as this relates to state requirements and BMPs adopted; 3) Communicate and promote water conservation to utility management; 4) Coordinate utility conservation programs with operations and planning staff; 5) Prepare annual conservation budget 6) Manage consultants and contractors assisting in implementing the water conservation program; 7) Develop public outreach and marketing strategies for water conservation; and 8) Participate in regional water conservation planning and drought planning initiatives[TL6]
For water utilities with 3,300 service connections or more, the name of the Conservation Coordinator shall be reported, in writing, to the Executive Administrator of the Texas Water Development Board to maintain compliance with HB 1648.
2.0 Conservation Analysis and Planning TWDB Report 362 (2004[LTT7])
2.1 conservation Coordinator |
Often, the Conservation Coordinator is the spokesperson for the utility on conservation issues. For small utilities, the Conservation Coordinator may have other responsibilities. Utilities that jointly operate regional conservation programs are not expected to staff duplicative and redundant Conservation Coordinator positions if they individually provide potable water service to less than 3,300 connections.
Schedule
Utilities pursuing this BMP should begin implementing this BMP within six (6) months of adoption of the official resolution to initiate the program. Implementation should be completed in a timely manner[TL8].
Scope
A utility should staff and maintain the position of Conservation Coordinator and provide support staff as necessary. This includes providing the Conservation Coordinator with the necessary resources to prepare and implement the water conservation program. Depending upon the size of the utility or opportunity to collaborate with neighboring utilities or wholesale agencies within its region, this BMPs objective may be achieved by sharing resources and implementation efforts with other utilities[TL9].
Documentation
To track this BMP and compliance with HB1648, the utility should gather the following documentation:
1) Description of the Conservation Coordinator position. 2) The date the Conservation Coordinator was appointed or hired. 3) Annual or more frequent reports on progress of water conservation program implementation, costs and water savings[LTT10].
Determination of Water Savings
Water savings are not quantified for this BMP. The Coordinator assists in the implementation of other BMPs and this additional effort can be considered as essential to the savings accrued by the implementation of the whole range of conservation program(s) which are offered by the utility[TL11][LTT12].
Cost-Effectiveness Considerations
Without specific water savings, it may be difficult to do a true cost-effectiveness analysis for this BMP. However, this BMP is essential to the successful implementation of other BMPs the utility chooses to undertake. There will be non-financial benefits as a result of implementing this BMP such as enhanced public image through increased outreach and visibility in emphasizing conservation programs. The salary and associated overhead expenses for the Coordinator would be the primary costs that would be incurred in implementing this BMP[TL13]. Depending on size and scope of the water conservation programs, the Coordinator position could be full-time, part-time, shared with others, or contracted out.
References for Additional Information[LTT14]
2.0 Conservation Analysis and Planning TWDB Report 362 (2004)
Alliance for Water Efficiency, Water Conservation Tracking Tool - The tool can help the Conservation Coordinator plan for implementing the most appropriate conservation programs for their utility. More information and access to the tool can be found here:
Handbook of Water Use and Conservation by Amy Vickers, 2001. Amherst, MA: WaterPlow Press. ISBN 1-931579-07-5[LTT15]
2.1 conservation Coordinator[LTT16] |
1) Texas utilities and regional suppliers with conservation coordinators include (but are not limited to) Austin, Corpus Christi, Dallas, El Paso, Lower Colorado River Authority, San Antonio,San Marcos, Post Wood Municipal Utility District, and Harris Galveston Coastal Subsidence District[TL17].
2) Memorandum of Understanding, California Urban Water Conservation Council, 1999[TL18].
3) Groundwater Conservation Plan, Edwards Aquifer Authority, 2000.
Text of legislation –
By:Price(Senate Sponsor - Seliger) / H.B.No.1648(In the Senate - Received from the House May1,2017;
May3,2017, read first time and referred to Committee on
Agriculture, Water & Rural Affairs; May10,2017, reported
favorably by the following vote:Yeas6, Nays1; May10,2017,
sent to printer.)
Click here to see the committee vote
A BILL TO BE ENTITLED
AN ACT
relating to the designation of a water conservation coordinator by
a retail public water utility to implement a water conservation
plan.
BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS:
SECTION1.Section 13.146, Water Code, is amended to read as
follows:
Sec.13.146.WATER CONSERVATION PLAN. The commission shall
require a retail public utility that provides potable water service
to 3,300 or more connections to:
(1)submit to the executive administrator of the board
a water conservation plan based on specific targets and goals
developed by the retail public utility and using appropriate best
management practices, as defined by Section 11.002, or other water
conservation strategies;
(2)designate a person as the water conservation
coordinator responsible for implementing the water conservation
plan; and
(3)identify, in writing, the water conservation
coordinator to the executive administrator of the board.
SECTION2.This Act takes effect September 1, 2017.
[1] 85th Regular Session of the Texas Legislature, 2017
[LTT1]As these individual bmps are updated, I suggest that we indicate the last amended date.
[TL2]Footnote #1 has been made moot by the legislation.
[TL3]While the CC may be responsible for implementation and program maintenance, it will be helpful to point out that this individual also has to coordinate various departments and people in order to enable program implementation and maintenance. Thus, emphasis on a term in the position title seems warranted here even if it is discussed in the description section below.
[LTT4]How do we wish to acknowledge that TCEQ is currently conducting rulemaking to implement HB 1648? We’ll likely want to issue the updated BMP before rulemaking is settled and we can come back and do another minor update as necessary once rules are finalized. A formal public
rule hearing and comment period
is planned for March2018
.
[LTT5]This addition is redundant, but seems necessary if you wish to keep the original two sentences in place. The related matter of reporting the CC’s name to TWDB is mentioned below.
[TL6]We might want to add a couple of duties beginning with determination of conservation actions that are most appropriate given the local context and/or actions that are prioritized as an outcome of using a tool (e.g., A4WE conservation tracking tool). Additionally, it seems appropriate to add program evaluation to the list as at some point, this step should be undertaken. Since six duties are currently enumerated, why not give more explicit guidance rather than assume that evaluation on both the front and back ends are either optional or not needing to be called out.
[LTT7]Do we want to reference the TWDB’s Water Conservation Plans webpage? The CC will likely be responsible for completing the every-5-year plan and annual progress reports. In any event, adding a reference to this material should offer a nice complement to Report 362
[TL8]Rewrite (or delete) to reflect current legislation. The final rules might indicate a last date for appointing a CC and a timeframe within which the CC should be identified with TWDB. Given the new legislation, it might make sense for us to combine the “schedule” and “scope” sections.
[TL9]Will have to be revised since the legislation indicates that water service providers of a certain size need to designate a CC.
[LTT10]Does notification of the named CC to the Exec. Admin. / TWDB need to be documented here too?
[TL11]If program identification up front and evaluation post-hoc are part of the duties, then who best to assign the task of water savings determination to? In any case, the current language is not clear as to whether it should be done or who is to determine water savings. Increasingly, I suspect the CC will be called upon to document savings and program efficacy.
[LTT12]
[TL13]What about program costs? If someone currently employed by the utility is newly assigned this role, does the task of fulfilling the CC role assume all salary and associated expenses? Also, at this point in the read, I’m reminded that the CC is now a statutory requirement that is a qualifier of sorts to being a best management practice.
[LTT14]It might be more intuitive to had “references for additional information” at the bottom of the section where they pertain. That will get us away from duplicating section numbers here that seem a tad confusing.
[LTT15]This will be updated in 2018 according to Amy V.
[LTT16]Do we want to insert the language of HB 1648 here or have we adequately covered those details with edits elsewhere? I’ve pasted the legislative language at the bottom of this document.
[TL17]As noted where this footnote appears, this can be deleted.
[TL18]Perhaps this can be updated with something posted on the A4WE website. I’m not sure it remains relevant given the new legislative requirement. Also, the CUWCC has evolved, has a different name, and is in the process of merging with the A4WE (in some fashion.)