OWASA Proposed Conservation Standards

The Board of OWASA is proposing Conservation Standards to replace the current Ordinance.

It may be necessary to have regulations to allocate the water supply available in time of shortage, but I would suggest to you that any directive that is enacted to restrict water use should meet these criteria:

1. The regulations should bear equally, so far as possible, on all customers.

2. The right of customers to determine for themselves how best to meet the limitations placed on them should be recognized.

3. The primary obligation of OWASA is to make as much water available as their customers desire to use and for which they are prepared to pay and, consequently, restrictions on use should be imposed only when needed.

First, the proposed Standards have specific limits that focus to a large extent on irrigation, not only during water shortages, but also at all times. The effect of this is that the proposed Standards, like the current Ordinance, do not deal in an even-handed manner with all of OWASA's customers. Let me explain this statement.

OWASA's customers may be divided into five categories:

% of consumption

Single-family residences 28.0

Multi-family residences 26.1

Commercial 14.6

University/UNC Hospitals 30.0

Irrigation-only 1.3

Many, perhaps most, single-family residences irrigate their gardens. Multi-family residences and commercial users generally have little or no irrigation needs. The University/UNC Hospitals do show significant seasonality, which might be assumed to be for irrigation needs but analysis of the data shows that the variations are primarily in the student housing, office/administration, and utility areas, which suggests that other uses, such as cooling, are important. For example, student housing, the sector with the greatest seasonal variation, peaks in October, after any increase likely due to irrigation. Also, about one-half of the University irrigation needs are met from wells, not from OWASA supplied water.

I believe that focusing on limiting irrigation to control demand in effect places the burden disproportionately on single-family residences.

Second, while OWASA needs to be able to tell customers that they need to reduce consumption, and by how much, it seems to me to be inappropriate to target irrigation, when other uses, no more necessary, are not restricted. This seems to be particularly the case with sprinkler systems where the discussion in more than one forum seems to have acquired an almost moral dimension. I do not have a sprinkler system, which I consider wasteful and unnecessary, but that does not mean that those who wish to spend money in this way should be restricted from doing so, so long as there is no cogent reason to believe that their consumption is affecting the supply to others. Their high use levels should mean that they should be considered to be good customers who help to keep the water bills of other customers down, not reprehensible characters.

I would suggest that a fundamentally different approach to limiting consumption needs to be developed, based on the principle that if, for example, a 5% reduction in demand is necessary, customers should be so advised, together with a specific, individually calculated monthly target volume figure. The development of such a system undoubtedly has some complexities to overcome, but OWASA has a comprehensive customer consumption database, which should allow this to be done.

I believe that fairness requires that restrictions that bear largely on one group of customers, single family residences, who represent less than one-third of the total consumption should not be the way to control demand. A major attraction of the irrigation limiting approach may be the high visibility of offenders, but I do not think that regulation should be based on ease of detection.

In spite of my preceding comments, I would reluctantly suggest to Council that, as a temporary measure, they should endorse the proposed Standards, because they do mitigate some of the worst effects of the present Ordinance. But, and this is an important but, Council should establish a date certain on which the Standards will lapse. I would suggest December 31, 2003. Council should ask the Board of OWASA to return, before that date, with revised Standards that will impose similar restrictions on all customers, are less intrusive and only come into effect when there is concrete evidence of need. Each customer can then decide for himself or herself how best to use the volume available to them.

Respectfully submitted,

Michael A. (Mac) Clarke