Pressure Reduction Water pressure in distribution systems should be monitored and reduced where possible. Pressure reduction decreases water loss through leaks, and reduces water use when volume is not essential. One study revealed that excess pressure in three Massachusetts city systems could be reduced by 30-40 pounds per square inch (psi) and result in a 3 percent to 6 percent water savings. In another Massachusetts study, pressure reduction on an 8-inch water main to a community of 316 singlefamily homes and 1097 multiple-family dwellings led to an 8 percent water savings. Leak Detection and Repair Water systems should incorporate ongoing leak detection and repair programs. One such program in Arlington, Massachusetts reduced water loss by 25 percent. The City of Oakland, California was able to save 4 million gallons per day in its first two years of a" leak detection and repair program. California's Department of Water Resources has saved more than 7 million gallons per day in 57 communities, while also saving $2.80 for each $1.00 spent on the program. Wastewater Treatment System Standards The standards we recommend for water conservation and efficient use of facilities by wastewater treatment systems are similar to those suggested for water supply systems. For those systems proposing new or expanded facilities, we recommend: universal metering of all customers recovery of all costs through user charges monthly billing elimination of promotional rates programs to reduce infiltration and inflow from leaks where wastewater treatment is provided by a municipality, promulgation of efficiency standards for newly installed plumbing fixtures and fittings where water supply is provided by the same entity, compliance with the water supply conservation standards above. These standards should be met by all wastewater treatment systems seeking new permits under section 402 for discharges from new or expanded wastewater treatment plants or seeking financing for such activities from revolving loan funds. ●Metering As with water supply, metering is essential to provide accurate information for use-based sewage treatment charges. All billing for wastewater treatment should include a charge for volume based upon metered use. Water supply meters are commonly used for wastewater metering. Total consumption may be adjusted by a factor to account for non-return flow use, such as lawn watering. As already discussed, water metering is a common and accepted practice. Thus, the requirement of metering for wastewater treatment systems need not be viewed as burdensome. Monthly Billing Monthly billing is again essential for wastewater treatment systems to provide timely feedback on the cost of discharging wastes. Customers will be more likely to adjust their practices if they associate large waste flows with higher costs. Monthly billing for wastewater treatment is a well established practice; in 1990, 64 percent of 118 cities surveyed used monthly billing for wastewater treatment. ●Eliminating Promotional Rates Promotional rates, such as flat monthly fees not based on use, or declining-block rate schedules that charge lower prices as discharge increases, should be eliminated. These rates encourage waste of water and are a further disincentive to conservation. Where water and sewer charges are billed together, promotional rates for sewer charges dilute the price signals from usage-based water supply charges. Rates should be based on actual use. Again, the volume of discharge into wastewater treatment systems could be reduced even further through conservation pricing measures such as inclining block rate structures. The use of inclining block rates in wastewater systems grew from less than 2 percent in 1986 to almost 7 percent in 1990. •Cost Recovery through User Charges As with water supply systems, property taxes and sales taxes should not be used to fund capital or operating costs of wastewater treatment system expansion. A 1982 EPA study indicated that 10 percent of wastewater utilities received general tax fund financing to cover costs. More recently, EPA has found that 91 percent of wastewater system revenues come from user charges and hook-up fees. The residual funding from sources other than system users encourages use and expansion of wastewater treatment systems by diverting the pergallon cost from users to the tax base in general. • Reducing Infiltration Wastewater treatment systems should implement programs to reduce infiltration from leaky collection systems. Infiltration results in higher treatment costs and reduces available treatment capacity. Infiltration can also exacerbate sewer overflow events in which raw sewage is released into streams and other receiving waters. Broadened Purposes for the Revolving Loan Funds In addition, as suggested in Senator Fowler's proposed legislation, the revolving loan funds should be made available to invest in conservation and reuse, in order to encourage greater efficiency, as well as capacity. Senator Fowler's Municipal and Industrial Water Conservation bill from last Congress included a new provision to fund water conservation activities that will reduce operating and capital costs for wastewater treatment facilities. Current law allowing use of loan funds to finance water reclamation systems should also be expanded to include areclaimed water distribution systems as well as treatment plants. Recipients of loans should also be required to demonstrate that they have considered techniques for reclaiming and recycling wastewater. Agricultural Water Conservation Standards In many areas, agricultural water use far exceeds municipal water use, and the effects on water quality from agricultural water withdrawals and polluted return flows are substantial. Agricultural water districts also receive permits under section 404 for various structures for water supply. In the future, permits for new water supply development should be conditioned upon the institution of agricultural water efficiency practices, and should take into account the water use reductions achievable with such practices. Before receiving 404 permits for new water supply development, we recommend that agricultural water districts meet the following water efficiency standards: universal metering water pricing based on measured water use conversion of fixed-schedule irrigation to demand-based supply development of water conservation goals and practices to meet those goals lining supply canals and regulatory storage reservoirs, unless unlined facilities are part of a groundwater recharge program. ⚫ Metering As with municipal use, permittees should meter each customer or be committed to full metering by a date certain. This data is essential to the effort to tie water prices to actual use, providing customers with the economic incentive to conserve water. In addition, metering allows more efficient application of irrigation water and can help farmers avoid overwatering. Eliminating Promotional Pricing Permittees should base water pricing on measured water use, and eliminate promotional water rates. Many irrigation districts provide water at a flat rate, deterring farmers from conservation efforts. Use-based charges, and increasing block rates, can significantly reduce water use. The Broadview Water District in California found a 10 percent reduction in water use in certain crops when it instituted an increasing block rate schedule in 1989. Converting to Demand-Based Irrigation Permittees should convert fixed schedule irrigation systems to flexible demand systems that can deliver water when required by soil moisture and crop conditions. On a fixed delivery system, water is delivered regardless of weather conditions or crop requirements. Excess deliveries contribute to waterlogging or polluted runoff from farmlands. Converting to demand-based irrigation can save water and save money for farmers. Implementing Water Conservation Goals Permittees should identify water conservation goals and formulate an implementation schedule for "best management practices" to meet those goals for irrigation application and irrigation runoff. The adoption of best management plans has been recognized as a means of reducing pollution from agricultural runoff, but it can also serve to reduce water use, keeping more water in streams and saving money for farmers. Lining Water Storage and Delivery Facilities In many areas, substantial water is lost into the ground from unlined canals and delivery facilities. Permittees should commit to lining supply canals and regulatory storage reservoirs, except where part of an approved plan for groundwater recharge and conjunctive use, by a date certain. Lining of the Bureau of Reclamation's All American Canal, for example, is expected to yield water savings of approximately 100,000 acre-feet (over 32 billion gallons) of water per year. Least-cost Planning Water supply and wastewater treatment systems might also be required to perform least-cost planning under the CWA. In order to assure that water supply and wastewater treatment utilities consider cost-effective alternatives to facility expansion, a least-cost planning requirement could be incorporated with any of the CWA programs discussed previously. For example, a wastewater treatment system seeking new capital for facility expansion from a revolving loan fund could be required to demonstrate that it has performed a least-cost planning analysis to identify and evaluate the least costly alternatives, or mix of alternatives, for managing the volume of wastewater. Such a requirement might also be set out for utilities seeking new permits under section 402 for new or expanded wastewater treatment capacity, or new section 404 permits for water supply expansion. The EPA would provide guidelines and technical advice on the preparation of this least-cost planning analysis. Applicants should compare the construction and operating costs of planned expansion, including costs of associated environmental damage, with the cost, feasibility, and environmental effects of potential water efficiency investments that could be implemented in incremental units. Water efficiency alternatives would include measures such as: (1) retrofitting low water use plumbing fixtures and appliances; (2) providing incentives for low water use landscaping; (3) investing in increased industrial and commercial water conservation; and (4) instituting more frequent leak detection and repair programs. The least-cost planning analysis should also consider savings in energy costs due to increased water efficiency. The successful experience of electric utilities with least-cost planning indicates that such analysis may hold great promise to increase the efficiency of water utilities. In some communities, evaluation of least-cost plans has already led water supply planners to abandon expensive and environmentally harmful projects in favor of less expensive alternatives. A U.S. Army Corps of Engineers study led to the abandonment of plans for an expensive series of water supply reservoirs in the Potomac River Basin in favor of relatively inexpensive changes in reservoir management and the construction of a single management reservoir to meet the Washington area's peak water demand. An economic analysis led Phoenix, Arizona to begin a major water conservation program in 1986 that has become a cornerstone of the city's water management policies. San Jose, California initiated a plumbing retrofit program as an alternative to costly expansion of its sewage treatment plant. New York City's ongoing water conservation program provides a several hundred million dollar alternative to an anticipated several billion dollar outlay for water supply and treatment expansions. These examples demonstrate how demand management and water conservation alternatives can lead to significantly reduced costs. Wastewater treatment and water supply entities should be encouraged to work together in analyzing savings from water conservation. Water conservation investments reduce the costs of both supply and wastewater treatment. Conservation has often been undervalued because water supply and wastewater treatment entities working independently have seldom assessed the full range of benefits. Once these entities have jointly prepared a least-cost plan, they will be able to make informed decisions about costeffective investment in water supply and wastewater treatment. WATER EFFICIENCY SHOULD BE FURTHER ENCOURAGED BY NEW INITIATIVES IN THE CLEAN WATER ACT These recommendations for water efficiency improvements in existing Clean Water Act programs will represent important first steps toward incorporating water efficiency practices into the planning and operations of water supply and wastewater treatment utilities. In addition to these measures, we believe the Act should set new goals and provide new support for national water conservation efforts. Based on proposals previously introduced by Senator Fowler, plus a water regulatory policy initiative similar to the Public Utility Regulatory Policies Act, these new measures might form a new Title to the Clean Water Act. Office of Water Conservation The provisions of S. 1422 from the 101st Congress, the Municipal and Industrial Water Conservation Act, which establishes a National Clearinghouse on Water Conservation and an Office of Water Conservation within EPA, should be incorporated into the Clean Water Act. This legislation would require EPA to coordinate technical assistance and public information on water conservation. It would support leastcost planning for water supply, and studies of the most effective water conservation measures. This legislation could be expanded to require EPA to evaluate water conservation potential at Federal facilities as a model for efficient water use. Plumbing Standards The provisions of S. 583 from the 101st Congress, the National Plumbing Products Efficiency Act, should also be incorporated into the Clean Water Act. This bill would set national performance standards for newly manufactured plumbing products and waterusing appliances sold in the United States. Many States and communities have already found that standards for new plumbing products can produce significant reductions in water use. These efforts should be supported by national standards and labeling requirements for water-using products. If a 25 percent reduction in indoor water use in new construction (the anticipated effect of these plumbing fixture standards) would yield a 10 percent savings in wastewater treatment capital costs associated with growth, the standards would save at least $1.5 billion in capital outlays for wastewater treatment, based on EPA's 1988 figures. The subcommittee may wish to review a study prepared for EPA by the California Department of Water Resources dated August 1980, entitled "Effects of Water Conservation Induced Wastewater Flow Reduction: A Perspective." The study concluded that water conservation measures applied to new growth served by new wastewater treatment facilities would yield capital cost savings averaging 7 percent for wastewater collection systems and savings of up to 8 percent for wastewater treatment plants. The study also found, however, that where new growth would be served by additions to or expansions of existing wastewater facilities, the capital cost savings attributable to conservation were much larger: 15 percent for collection systems and 22 percent for treatment plants. This suggests that a significantly larger fraction of the $15.6 billion expected to be needed to accommodate new growth over the next 20 years might be saved through water conservation. Water Utilities Regulatory Policy EPA has found that 37 percent of the communities it surveyed are collecting revenues that are insufficient to cover their total wastewater treatment costs.2 States should review and where necessary reform water and sewer rates to reduce the effects of droughts, damage from untreated wastewater, and economic and environmental costs of new water supply systems. In order to achieve water conservation and assure the availability of financial resources necessary to meet discharge requirements, the Clean Water Act should incorporate requirements for water supply and wastewater treatment rate review similar to the energy rate review required under the Public Utilities Regulatory Policy Act of 1978. Each State should designate an official or public body with the responsibility to perform a minimal review of rates for public water supply and wastewater treatment systems serving over 2,000 customers, within three years of date of enactment. Such review should: ⚫evaluate and confirm the total revenue requirements, including a reasonable rate of return, for publicly owned and investor-owned systems; ●require sufficient rates to generate total revenue requirements, without other payments to support the system from property or sales taxes; evaluate and approve rate schedules that preclude promotional rates and include seasonal and drought surcharges where appropriate. CONCLUSION The Clean Water Act has in the past placed little emphasis on water efficiency measures as a tool for improving water quality. With increasing population density in urban and coastal areas, more and more pressure is being placed on limited sources of water both to provide potable water and to assimilate treated wastewater. This bill would also provide for revolving loan funds to be made available for water conservation activities that will reduce wastewater treatment costs, an issue discussed above. 2 U.S. EPA, Office of Water, National Wastewater User Fee Study (DRAFT) June 1990. Water conservation can help to protect and restore our nation's waterways by reducing this pressure and ensuring cost-effective use of existing water supply and wastewater treatment facilities. We urge the subcommittee to incorporate these water conservation measures into the Clean Water Act. PREPARED STATEMENT OF BEVIN BEAUDET Good morning, Mr. Chairman, members of the subcommittee. My name is Bevin Beaudet. I am Director of Palm Beach County Water Utilities Department. I am here representing the American Water Works Association (AWWA) to testify on behalf of Clean Water. I want to thank you and the members of the subcommittee for providing us the opportunity to present our views on this vital element of the water supplied to the American people. The American Water Works Association is a 110-year-old scientific and educational association and the largest association in the world representing drinking water supply professionals. Our 53,000 plus members are comprised of administrators, utility operators, professional engineers, contractors, manufacturers, scientists, professors and health regulators. Our membership includes over 3,500 utilities which supply over 75 percent of the nation's drinking water. Our purpose is to promote public health, safety and welfare through the provision of safe, high quality drinking water. A growing number of AWWA's member water utilities are facing significant source water problems in both quality and quantity. Many have active water conservation programs, and most of the water conservation strategies developed, funded, implemented, and evaluated to date, have been pioneered by AWWA members. Palm Beach County and other municipalities in the State of Florida have adopted several water conservation measures which I will explain in further detail later in my testimony. The proposed Clean Water bill S. 1081 continues eligibility of State Revolving Loan Funds for construction of treatment works, nonpoint source management programs, and estuary management programs. S. 1081 also expands this eligibility to include combined sewers overflows remediation and mitigation programs. As part of the combined sewers program, domestic water conservation is specified as a method to reduce sewage influent. The AWWA supports the eligibility criteria for combined sewers overflows and water conservation in order to conserve drinking water resources and improve water quality in streams and rivers. These improvements to the Clean Water Act will help prevent pollution and protect aquatic ecosystems, however, we caution that planning must be realistic with full consideration given to the cost implications. Water conservation and watershed management plans must be doable at the local level. The AWWA believes that commitment to efficient use of existing water supplies is becoming increasingly important. Increasing demands on limited high quality water sources and persistent or recurring drought conditions in many regions of the United States demands that water supplies be used wisely and efficiently. Conservation has both short-term and long-term impacts to the AWWA member utilities. The AWWA supports Congressional action to promote wise and efficient use of water by the nation's municipalities, industries, and agriculture. The proposed legislation should initiate water conservation programs with the goal of reducing the per capita consumption of water. This reduction in water consumption translates into a reduction in sewage influent. By way of example, I would like to explain in detail the impact of the water conservation measures adopted by Palm Beach County and other municipalities. The entire State of Florida, including Palm Beach County, suffered through a severe drought during the summer of 1989. Due to the summer drought, water restrictions were adopted by Palm Beach County in December of 1989. These restrictions reduced the per capita water consumption, and in some cases, were converted into permanent water conservation measures. The three mandatory restrictions adopted by Palm Beach County were the use of low-flow plumbing fixtures, restrictions on lawn watering, and the use of Xeriscape plantings. The use of low-flow plumbing fixtures in all new construction and renovation was passed by the Florida legislature in 1990. Many of the municipalities have incorporated these requirements into their local plumbing codes. AWWA continues to support the use of low-flow plumbing fixtures. The decrease in sewage influent from the use of low-flow plumbing fixtures can be substantial. Current water use for toilets ranges from 3.5-7.0 gallons per flush. The proposed maximum water use for toilets in the proposed National Plumbing Products Efficiency Act would be 1.6 gallons per flush. Showerheads flow rates would be reduced for 3.0-8.0 gallon per |