GPCD Compliance Option
(Approved by the Plenary June 11, 2009)
This GPCD target is 18% reduction by 2018 for the purpose of using the same timeframe as the CUWCC’s MOU. It is one of three compliance options, including the traditional BMP approach, and the Flex Track approach. The specific compliance method provided herein is not intended to be a one size fits all solution to the complex issue of GPCD reduction for a water agency. However, as one compliance method among others, it does provide an agency an opportunity, if appropriate, to use GPCD Compliance as a simplified reporting mechanism.
Potable Water GPCD shall equal (PWI – PWS) / Pop / 365; where
1. PWI = Potable Water Into the retail water agency’s service area distribution system.
2. PWS = Potable Water taken out of the retail water agency’s service area distribution system and:
• placed into storage and/or
• delivered to an agricultural customer through a dedicated agricultural meter, at discretion of the retail water agency.
3. Pop = residential population of the retail water agency’s service area (using Cal Dept of Finance statistic when those statistics are available and adjusted to include the population outside a retail agency’s normal service area when these are served by the retail agency)."
For retail water agency service areas not geographically continuous with census data: Pop = number of service area connections x most recent census data "average number of persons per household (PPH)."
The Baseline GPCD shall equal the average annual Potable Water GPCD for the years 1997 through 2006 (fiscal or calendar year, at the discretion of the retail water agency, so long as all calculations from an agency are consistent).
For purposes of compliance the 2018 GPCD Target for all signatories as of July 1, 2009 shall equal Baseline GPCD multiplied by 0.82 (an 18% reduction).
Biennial GPCD Targets
Using the Compliance Table below, for each “Year” in the table, a retail water agency’s Biennial GPCD Target shall equal its Baseline GPCD multiplied by that year’s Target (% Baseline). A retail water agency may choose a starting point as either its Baseline GPCD or its 2006 Potable Water GPCD.
First Biennial Report: For retail water agencies choosing the GPCD Option for compliance with the Programmatic BMPs, the retail water agency shall submit the following calculations along with supporting data as part of their first biennial report:
(1) Potable Water GPCD for each year in the baseline period;
(2) 2018 GPCD Target and four other Biennial GPCD Targets; and
All Biennial Reports: A retail water agency shall be considered to be in compliance with the Programmatic BMPs in any reporting period when it submits the following:
(1) Complete “Water Supply & Reuse” and “Accounts & Water Use” standard reports;
(2) Supporting data necessary to calculate that reporting period’s Potable Water GPCD; and
(3) Calculations showing the reporting period’s Potable Water GPCD is less than or equal to that period’s Biennial GPCD Target, or Highest Acceptable Bound after weather normalization.
(4) Calculation of and data (for example: ETo, rainfall, and solar radiation) necessary to make the weather normalization adjustment.
Compliance will be evaluated in relation to the Compliance Table below and relative progress toward the goal will be acknowledged in Council Compliance Reports. For retail water agencies signing the MOU after July 1, 2009, the compliance table will be read as five increments with reporting goals relative to their 1st through 5th Compliance reports.
Highest Acceptable Bound
1. An Appeals Committee shall be created to review appeals related to items listed below. The Appeals Committee will be comprised of two members of Group 1 and two members of Group 2, and will require a unanimous decision to grant an appeal. All denials shall be in writing to the signatory. A signatory may resubmit their appeal with additional information in response to the Appeal Committee’s decision for a follow-up review.
2. Retail water agencies that can substantiate exceptional impacts to GPCD such as exceptional use of potable water for wildfire suppression and significant changes to a signatory’s economic or customer demographics (i.e. unusually large unavoidable increase in CII demand) may file an appeal to adjust that year’s GPCD Compliance Target.
3. Retail water agencies that signed the MOU prior to 1997 (the beginning of the Baseline Period), and that can substantiate significant investments in conservation leading to declines in water consumption as measured by GPCD, may file an appeal to adjust the baseline period to reflect per capita water demands in the period prior to their signing the MOU and prior to their significant investments in conservation.
1. CUWCC staff may make non-substantive additions/ reporting requirements changes deemed necessary to implement this BMP compliance option, with approval of the Board of Directors.
2. Foundational BMP 1.1(3)(c), regarding Wholesale Agency Program Management and Assistance, applies to all retail agencies including those meeting GPCD compliance requirements. i
3. CUWCC GPCD subcommittee shall provide, no later than December 31, 2009, acceptable methods retail water agencies may use when weather normalizing data for compliance with this BMP. Additional methods or revisions to these methods may be approved by the Board of Directors from time-to-time.
4. Both weather-adjusted and non-adjusted GPCD shall be displayed in the CUWCC online report.
i This footnote is not to be included in the actual BMP, it is provided here as a convenience to CUWCC members. The following is the language referenced in Foundational BMP 1.1(3)(c):
1. Utility Operations Programs
1.1 Operations Practices, A. Implementation
3) Wholesale agency assistance programs
c) Program management
When mutually advantageous, wholesale and retail water agencies will join together to plan, design, implement, manage, and evaluate regional conservation programs.
When mutually agreeable and beneficial, the wholesale agency or another lead regional agency will operate all or part of the conservation program; if the wholesale agency or other lead regional agency operates all or part of a program, then it may, by mutual consent with the retail agency, assume responsibility for CUWCC reporting for funded BMPs; under this arrangement, a wholesale agency or other lead regional agency may aggregate all or portions of the reporting and coverage requirements of all retail agencies joining into the mutual consent.