So you'd think that the water conservation element in the city's diversion application wouldn't raise too many questions in the yes of the regulatos who have to give initial approval to the diversion pitch.
But in the detailed letter sent the city's way by the Wisconsin Department of Natural Resources - - I have been breaking out sections all week on my blog to show what the DNR wants repaired in the application - - it is clear that what the DNR wants a mountain of detail, additional plans, projections and assurances from the city about water conservation
Take a look at what the DNR has told the city it expects to see in a full and complete Lake Michigan diversion application on just the issue of water conservation under the terms of the Great Lakes Compact and other standards.
And keep in mind: this is just a portion of the DNR's first cut. The seven other Great Lakes states and two Canadian Great Lakes provinces get their own crack at the application should the DNR decide to move it into the regional review.
And neighboring communities that would receive water service from Waukesha under the application have a review and approval role to play, too - - because the DNR says they do - - and, separately, a selling community like Milwaukee has its own requirements, needs and goals that Waukesha would have to meet as a water buyer.
Does Waukesha have the time and money to flesh out the application and get this complex environmental, political, financial, legal and capital project vetted, solved, approved and finished by a June, 2018 court-imposed deadline?
On the conservation issue, the DNR preliminarily wants to know:
Issues Related to Water Conservation & Efficiency:
The Water Conservation and Protection Plan (as approved by Waukesha Water Utility, March 2006) submitted with the diversion application, and pp. 2-7 through 2-12 of the May 2010 document “Application for Lake Michigan Water Supply” were reviewed for compliance with the Compact’s water conservation planning requirements as applied to diversion requests from communities within straddling counties. Although the department will complete a more detailed review of these documents, the department must—at a minimum—have the following items before beginning that more detailed review of the water conservation related provisions of the diversion application.
Standard: Persons applying for a new or increased diversion regulated under s. 281.346 (4) (c), (d), and (e), Stats. are categorized into Tier 3. [s. NR 852.02 (3), Wis. Admin. Code]. Note: NR 852 will be published on January 1, 2011; but a copy is available from the DNR’ s web page.
CE1. The City must demonstrate and document compliance with the Tier 3 water conservation and water use efficiency requirements contained in ch. NR 852. More specific comments are enumerated below.
Standard: All persons identified in Tier 1, Tier 2, or Tier 3 shall submit with the application for a new or increased withdrawal, diversion, or water loss approval all of the following: (1) A water conservation plan meeting the requirements of s. NR 852.07. (2) Written documentation showing that the person has implemented or completed the CEMs in Table 1 that do not require retrofitting, as applicable for each water use sector. [ss. NR 852.04 (1) and (2), Wis. Admin. Code]
CE2. Water conservation and efficiency measures (CEMs) contained in s. NR 852.04 (2) (Table 1) should be implemented and documentation provided with the diversion application.
CE3. A Water Conservation Plan that complies with s. NR 852.07 and describes conservation and efficiency measures that have been and will be implemented should be submitted to the department for review.
The Water Conservation Plan should address how conservation and efficiency measures will apply now and in the future for water users in the entire Water Supply Service Area, including those not currently receiving water from the Waukesha Water Utility. Water conservation and efficiency measures that need particular attention in this section are PWS-1, Water Audit (including results of the audit).
Standard: Persons identified in Tier 2 and Tier 3 shall complete the elements specified in s. NR 852.04 and the elements specified under either sub. (2) or (3). NR 852.05 (2) A person identified in Tier 2 or Tier 3 shall implement all CEMs identified in Table 2 for the applicable water use sector that do not require retrofitting, except those CEMs that are not cost-effective or environmentally sound and economically feasible, as determined by an analysis conducted by the applicant pursuant to s. NR 852.09 or s. NR 852.10, and approved by the department. (5) For persons applying for a new or increased diversion, the person shall implement the CEMs identified under sub. (1) prior to submitting an application. [s. NR 852.05 and s. NR 852.05 (2) and s. NR 852.05 (5), Wis. Admin. Code]
CE4. CEMs contained in s. NR 852.05 (2) (Table 2) should be implemented and documented in the Water Conservation Plan provided with the diversion application. Water conservation and efficiency measures that The following is a list of the additional information that is required for the review of the water conservation requirements for your application.
The list is organized by the statutory standards contained in s. 281.346, Wis. Stats., and specific regulatory requirements of Ch. NR 852, Wis. Admin. Code—set to be published on January 1, 2011 need particular attention in this section are: PWS-R1, Distribution System Pressure Management; PWS-R2, Residential Demand Management Program; PWS-R3, Commercial and Industrial Demand Management Program; and PWS-R4, Water Reuse (including the results of an analysis that was used to determine feasible options that were implemented).
Standard: In addition to the required elements specified in s. NR 852.04 and s. NR 852.05, persons identified in Tier 3 should conduct the appropriate analysis pursuant to s. NR 852.09 or s. NR 852.10 to identify additional CEMs that are cost effective or environmentally sound and economically feasible and implement the identified CEMs following the applicable timeframes under s. NR 852.05 (2) and (3). [s. NR 852.06 (1), Wis. Admin. Code]
CE5. The City should document its analysis to identify cost-effective or environmentally sound and economically feasible conservation and efficiency measures and provide that documentation to the department with the application. For example, the Alliance for Water Efficiency tool may be a good methodology to conduct this analysis, although other tools or methods of analysis may be used.
Documentation of the implementation of the conservation and efficiency measures identified through this analysis should also be delivered to the department.
Standard: Persons applying for a new or increased diversion shall also document the efficient use and conservation of existing water supplies by providing an analysis of community water use over the past 5 years, at a minimum.
The analysis shall quantitatively describe water use through time and how it has changed with the implementation of CEMs. The analysis shall include quantitative calculations of water use including but not limited to, the ratio of peak daily demand to average daily demand and per capita residential water use. [s. NR 852.06 (2), Wis. Admin. Code]
CE6. A quantitative description of water use by the Waukesha Water Utility and its customers for the past 5 years (at a minimum) should be provided. The analysis should show how implemented CEMs have affected water use.
The analysis should include quantitative calculations of water use, including but not limited to the ratio of peak daily demand to average daily demand and per capita residential water use. All residential water use should be included in this analysis, both single family and multifamily dwellings. The analysis should quantitatively account for the loss of industrial customers, weather variability, and economic considerations in addition to any other identified factors that may have affected withdrawal amounts.
Standard: Documentation of the implementation of the CEMs set forth in s. NR 852.04 (2) and a description of any other existing conservation, efficiency, and reuse measures, including when they were implemented. [s. NR 852.07 (2)(c), Wis. Admin. Code]
CE7. Documentation of prior implementation of Public Water Supply Sector CEMs in Table 1 and Table 2 will need to be included in the Water Conservation Plan. Additional cost effective measures identified by the cost effectiveness analysis, or the analysis of environmental soundness and economic feasibility of measures should be included in the plan along with an implementation timeline.
Standard: A person identified in Tier 3 shall implement CEMs selected from Table 2 in par. (a), the Optional CEM list in s. NR 852.08 (2), or other CEMs as proposed by the applicant and approved by the department, which can be shown to reduce water use or increase water reuse or efficiency by 10 percent, in accordance with ss. NR 852.05 (3) (a) and (b). [s. NR 852.05 (3), Wis. Admin. Code]
CE8. If a 10% reduction option is selected as allowed by this section, additional documentation and a defensible analysis of water use for the most recent complete year should be submitted. Water use and water use intensity should be adjusted to account for unique facility, economic, or weather variability. The water use or water use intensity from the most recent complete year of water use will be the basis of a 10% reduction calculation. The 10% reduction should be in addition to any reduction in water use or increase in water reuse or efficiency achieved through implementing the CEMs set forth in s. NR 852.04 (2) and should not be included in the calculated percent reduction.
The City must select conservation and efficiency measures that can show by way of documentation to reduce water use by 10%, and these measures should be implemented prior to submitting an application.
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