State Implements New Urban Water Conservation Regulations Starting January 1, 2025

In a significant move to address the growing water challenges posed by climate change, the California State Water Resources Control Board (SWRCB) has approved a groundbreaking regulation aimed at promoting efficient water use by large urban water suppliers across California. As a result of this regulation, the state’s comprehensive Water Supply Strategy is expected to save 500,000 acre-feet of water annually by 2040, which is enough to supply over 1.4 million households for a year.

Addressing Climate Change with Water Conservation

As California faces a projected 10% water supply shortfall by 2040 due to increasingly hotter and drier weather conditions, water conservation has become a crucial component of the state’s strategy to enhance water resilience. The new regulation specifically targets the state’s largest water utilities, which serve 95% of California’s population, requiring them to implement measures to ensure more efficient water use.

One of the key initiatives includes creating storage capacity for up to four million acre-feet of groundwater and water in new and expanded reservoirs. To support this, some “less than satisfactory” dams that currently hold water at reduced levels will be repaired, enabling them to hold back increased volumes.

Additionally, by 2030, the state aims to recycle and re-use at least 800,000 acre-feet of water annually. The SWRCB has already invested $1.8 billion over the past five years on recycling projects that are expected to provide 124,000 acre-feet of new water supply.

Meanwhile, additional conservation measures are projected to free up 500,000 acre-feet of water through the enactment of new laws and education efforts. Urban stormwater capture and treatment are expected to add more than 250,000 acre-feet by 2030, while desalination of brackish groundwater will contribute another 28,000 acre-feet annually by the same year.

These combined efforts form a comprehensive approach to bolstering California’s water resilience in the face of growing climate challenges.

Key Components of the Regulation

The regulation mandates that urban retail water suppliers develop water budgets based on various parameters, including residential indoor and outdoor water use, commercial and industrial landscapes with dedicated irrigation meters, and the maximum allowable volume of water loss from leakage. These standards are set to reach their most efficient levels by 2040, forming what is known as the “water use objective.” Suppliers must comply with this objective starting in 2027.

To meet their water use objectives, suppliers can employ a range of conservation strategies tailored to their local conditions. These include education and outreach, leak detection, rebates, and direct installation of water-efficient appliances or landscapes.

Flexibility and Local Adaptation

The regulation provides flexibility for water suppliers to adapt their conservation actions to unique local circumstances. This flexibility is critical in ensuring that conservation measures are both effective and practical across diverse communities. Suppliers can also request variances for special water uses, such as those associated with livestock, wildlife ponds, evaporative coolers, and irrigation of existing trees.

Historical Context and Future Impact

This regulation builds on lessons learned from past droughts, during which Californians demonstrated significant water-saving behaviors. By formalizing water conservation as a way of life, the regulation aims to reduce the need for emergency water use reduction targets in future droughts. It also gives water suppliers time to develop and expand conservation programs, ensuring long-term sustainability.

Implementation and Future Goals

Set to take effect on January 1, 2025, this regulation marks a historic step in California’s ongoing efforts to manage its water resources sustainably. For more information on the state’s water conservation initiatives and long-term goals, visit the SWRCB’s Water Conservation Portal at www.waterboards.ca.gov/conservation/.

Conclusion

The SWRCB’s new water conservation regulations mark a significant step towards sustainable water management in California. For manufacturing facilities, these regulations present both challenges and opportunities. While compliance may require substantial investments and operational changes, the long-term benefits of water conservation, cost savings, and enhanced environmental stewardship can outweigh the initial efforts. As industries adapt to these new standards, they will play a crucial role in ensuring the sustainable use of California’s precious water resources, setting a precedent for other states and sectors to follow.

ALL4 is well-equipped to help manufacturers navigate the complexities of California’s new urban water conservation regulations. With extensive expertise in environmental compliance and sustainability, ALL4 can assist in ensuring regulatory compliance. By staying ahead of these changes, manufacturers can achieve long-term water resilience while contributing to the state’s broader conservation goals. For any inquiries, please contact Bruce Armbruster at barmbruster@all4inc.com or 909.477.7103, or reach out to Victor Chen at vchen@all4inc.com or 909.477.7128.

Energy Efficiency, a First Step Toward Decarbonization

Three weeks ago, I had the pleasure of representing ALL4 at the Association of Energy Engineers (AEE) World Energy Conference, in Nashville, Tennessee. It was great to spend time with other Certified Energy Managers and energy industry professionals, talking about the rapidly changing field of energy management as we transition toward a carbon-free economy. It was exciting to hear about some of the new technologies and creative solutions that are being developed to decarbonize industry. It was reassuring to hear that we don’t have to wait for new technologies to reduce energy demand and greenhouse gas (GHG) emissions.

It reminded me of a quote that I recently heard in a TED Talk by Johnathan Foley, Executive Director of Project Drawdown, when he said that “now is better than new, and time is more important than tech.” What he meant was that taking any actions we can to reduce GHG emissions and mitigate the impacts of climate change now are better than waiting for that ‘shiny’ new technology to finally be developed and commercialized so that we can all use it. But what actions can we take now, and how do we get started?

The answer to those questions is energy efficiency. According to the U.S. Department of Energy (U.S. DOE) energy efficiency is a foundational, cross-cutting strategy for near-term decarbonization and should be the first action taken because it is the most cost-effective and can lead to significant energy savings and GHG reductions. So how do we start addressing energy efficiency?

Energy Efficiency Audits

One of the best ways to start improving energy efficiency is to conduct an energy efficiency audit. Energy efficiency audits can be used in a broad range of settings to identify opportunities to improve energy efficiency. Heavy manufacturing industrial facilities, warehouses, office buildings, university campuses, retail shops, and even apartments and single-family homes can all benefit from an energy efficiency audit. However, the level of effort involved, and the level of energy management expertise required, will obviously vary widely across this range. A certified energy manager (C.E.M.) or energy engineer is recommended, and may be required to perform these audits, especially at the higher levels. In general, the field of energy management recognizes four basic levels of energy efficiency audits: Benchmarking, Level 1, Level 2, and Level 3 audits. Each of these levels have specific characteristics that are discussed below.

Benchmarking Audit or “Preliminary Energy Audit”

A benchmark audit may also be known as a “Preliminary Energy Audit.” The characteristics of a benchmark audit include:

• May not require a site visit.
• Utilizes existing actual energy use records from utility bills or other sources.
• Calculates benchmark values such as Energy Use Index (EUI) and Energy Cost Index (ECI).
• Compares actual energy use to normative values, such as DOE’s Energy Star Portfolio Manager.
• Quickly identifies performance compared to averages for the type of facility or process.

Level 1 – “Walk-Through Audit”

A Level 1 audit may also be known as a “Walk-Through Audit.” As the name implies, this audit is conducted fairly quickly and can identify the simple or easy-to-implement opportunities or energy conservation measures (ECMs). This walk-through may also identify opportunities where further data gathering or engineering may be required to realize greater potential energy savings and GHG reductions. The characteristics of a Level 1 audit include:

• Requires an on-site visual inspection and review of prior audits or actions. Typical audits require 1-3 days, depending on facility complexity and size.
• Reviews operation and maintenance practices and identifies issues and opportunities for improvement.
• Identifies “No-Cost” or “Low-Cost” opportunities for improvement.
• Includes rough estimates of potential costs for implementation and potential savings.

Level 2 – “Energy Survey and Analysis”

A Level 2 audit requires greater data collection and provides a higher level of detail and engineering analysis than a Level 1 audit. A Level 2 audit can potentially identify ECMs that may cost more to implement, but can result in greater savings and decarbonization potential. The characteristics of a Level 2 audit include:

• Multiple on-site and remote components, over a short term (weeks to months).
• Measurements and data collection, potentially using temporary meters or data logging equipment.
• An energy use breakdown at the facility/building by use category and energy type.
• A review of operation and maintenance procedures in detail, including:
  • Qualitative assessment of maintenance practices
  • Review of set points, operating schedules, start-up, shutdown, and idling practices, etc.
• Provides detailed savings and cost analyses of potential projects, including estimated energy use according to equipment size, loads, rated efficiency, hours, etc., and provides recommendations.
• Lists capital-intensive ECMs or improvements that may require further analysis.

Level 3 – Detailed Analysis of Capital-Intensive Projects

The Level 3 audit demands the most effort because it requires the most data collection and provides a higher level of detail and engineering analysis than a Level 2 audit. Typically, a Level 3 audit is restricted to the evaluation of capital-intensive projects that will require capital funding and will have relatively long implementation times. The characteristics of a Level 3 audit include:

• A focus on selected capital-intensive opportunities.
• Data collection that will likely include detailed field data, quotes from equipment vendors, and may include computer modeling of the options. This data collection may require months to complete.
• Project life-cycle cost analysis and risk assessment of options.
• A detailed project cost and savings information with a level of confidence to make major capital investment decisions and include in capital investment requests, either from banks or other capital sources.

Benefits of Energy Efficiency Audits

As previously stated, energy efficiency is the best first step toward decarbonization and energy savings. Energy efficiency audits are an excellent way to reduce GHG emissions and save money on energy expenditures. When performed sequentially to address opportunities of increasing complexity and increasing improvement potential, these audits are a cost-effective means to improve performance. Conducting these audits can also improve production performance, employee comfort, and reduce indirect costs.

If you would like to discuss how ALL4 can assist your company with energy efficiency improvements or performing energy efficiency audits, please contact me, Daryl Whitt, Technical Director, Climate Change & Sustainability, P.E., C.E.M. at dwhitt@all4inc.com or your project manager. Together, we can improve your energy efficiency and begin to decarbonize your operations and meet GHG reduction goals.

CISWI Federal Plan Finalized

On September 16, 2024, the U.S. Environmental Protection Agency (U.S. EPA) signed a final rule containing the Federal Plan requirements at 40 CFR Part 62, Subpart IIIa to implement the emissions guidelines for existing facilities under the commercial and industrial solid waste incinerator (CISWI) standards at 40 CFR Part 60, Subpart DDDD. The Federal Plan covers subject facilities in states that either did not submit a state-specific plan for the source category or that submitted a state-specific plan that was not approved by U.S. EPA. It applies to existing CISWI units that commenced construction on or before June 4, 2010 and have not been modified or reconstructed since August 7, 2013. Units modified or reconstructed after August 7, 2013 are subject to the CISWI standards at 40 CFR Part 60, Subpart CCCC.

U.S. EPA originally published major revisions to the CISWI emissions guidelines in 2011 and has subsequently made additional revisions, as recently as April 2019, that have been incorporated into the final Federal Plan. The Federal Plan will apply 30 days after the date of publication in the Federal Register.

A CISWI unit is defined in the emissions guidelines as an operating unit of any commercial or industrial facility that combusts solid waste (as defined in 40 CFR Part 241). U.S. EPA has included four subcategories for existing CISWI in the Federal Plan:

• Incinerators
  • Units designed to burn discarded waste materials for the purpose of disposal
• Energy recovery units (ERUs)
  • Units that would be boilers or process heaters if they did not combust solid waste (further subcategorized into three subcategories)
• Waste burning kilns
  • Units that would be cement kilns if they did not combust solid waste (further subcategorized into two subcategories)
• Small remote incinerators
  • Units that combust three tons per day or less of solid waste and more than 25 miles driving distance to nearest municipal solid waste landfill

Emissions guidelines are intended to provide a regulatory framework to implement a state or federal plan. Each state is given an option to submit for approval by U.S. EPA a state-specific plan that is at least as stringent as the emissions guidelines. As you might expect, state responses vary, but the current status looks like this:

For state plans that are under review, the Federal Plan will apply in those states until the corresponding state plan is approved by U.S. EPA.

U.S. EPA asserts that existing CISWI units should already be in compliance with the requirements that are established by the Federal Plan because sources have been aware of the CISWI requirements for many years.  However, the final compliance date for the final Federal Plan is 30 days after the date of publication in the Federal Register. U.S. EPA also asserts that there is no authority under Clean Air Act Section 129 to provide compliance extensions.

Now that the final rule is out, ALL4 can support your facility’s environmental compliance, permitting, and applicability. ALL4 is also tracking the upcoming proposed updates to the New Source Performance Standards (NSPS) and emissions guidelines for Large Municipal Waste Combustors and the proposed technology review for Hazardous Waste Combustors. If you have any specific questions regarding incinerator compliance, please don’t hesitate to reach out to me at scunningham@all4inc.com.

Will U.S. EPA require changes to Florida Water Quality Standards?

The White House Office of Management and Budget (OMB) is reviewing the United States Environmental Protection Agency (U.S. EPA) proposed final rule that will update calculations used to develop human health criteria (HHC) in the state of Florida. At play here is the assumption of local fish consumption rates (FCR). U.S. EPA is pushing Florida to use the national default value of 22 grams per day (g/day) consumption of fish and shellfish. Currently Florida uses a FCR of 6.5 g/day to calculate HHC for regulated compounds such as pesticides, polycyclic aromatic hydrocarbons (PAHs), Per- and polyfluoroalkyl substances (PFAS), heavy metals, dioxins and furans, and polychlorinated biphenyls (PCBs).

Background

The FCR is one of the key factors in determining HHC and is derived from multiple studies and sources. U.S. EPA default fish consumption rate for the general population is 22 grams per day. This rate is based on the 90^th percentile of fish and shellfish consumption for adults 21 and older as provided in Appendix A of the Estimated Fish Consumption Rates for the U.S. Population and Selected Subpopulations (NHANES [National Health and Nutrition Examination Survey] 2023-2010). However, populations in each region (state) consume fish and shellfish at varying quantities, and some state agencies establish their own FCR’s using state specific data rather than using U.S. EPA’s value. To develop a FCR, a state would consider fish and shellfish that are found in fresh and estuarine waters, including harvest in or near coastal waters. This state specific FCR would include local, commercial, aquaculture, interstate, and international waters, but it would not include marine species. The NHANES survey provides marine species considered including but not limited to such fish as snapper, tuna, swordfish, some shrimp species, most sea bass species, certain clam species, and most flounder species. As Florida is a coastal state, Floridians enjoy fresh fish from both freshwater and saltwater and the State of Florida has determined that the FCR (excluding marine species) is 6.5 g/day. Florida’s stance is that while its citizens consume fish and shellfish, freshwater and estuarian species are consumed at a lower rate than the national average due to higher consumption of marine species. Environmental groups are pushing U.S. EPA to look at other Florida studies that suggest the FCR should be closer to 46 g/day.

Florida is also home to the Seminole and Miccosukee Tribes who have reserved rights to subsistence fish. U.S. EPA established the FCR for subsistence fishing at 142 g/day. If this FCR is applied to the HHC calculations, the HHC would be even lower.

Also at issue is the FCR calculation methodology. Florida developed its criteria based on a probabilistic risk assessment methodology which they believe is more scientifically sound than the deterministic risk assessment methodology currently used by U.S. EPA. Deterministic risk considers the impact of a single risk scenario, whereas probabilistic risk considers all possible scenarios, their likelihood and associated impacts.

What do facilities in Florida need to know?

Changes to the HHC and ultimately updated Water Quality Standards (WQS) would require Florida to reassess its ambient water quality against more stringent standards, possibly resulting in additional waterbodies being listed as impaired. Florida would then develop total maximum daily loads (TMDL). From the TMDL, Florida would apply a loading value to each NPDES permit holder in that watershed.

What are the next steps?

ALL4 will continue to provide updates as they become available. It is likely that we will see court cases being filed when the rule is finalized. U.S. EPA and states are seeing more comments and scrutiny of the “sound scientific” development of water quality criteria across the United States.

If you have questions concerning your state’s WQC or WQS, or have questions concerning your NPDES permit, please reach out to Karen Thompson at kthompson@all4.com or one of our project managers in your area.

The Ultimate Reporting Tool that You Already Have: Excel Power Query

From annual emissions reporting to periodic environmental reports to emissions projections and baseline/actual emissions comparisons needed for permitting, calculation and reporting tasks can be tedious and repetitive. Although there are many tools to streamline the calculation process, the most affordable and accessible is Excel Power Query, available with any Microsoft Excel license, and which creates dynamic tables with live data and the option of a seamless integration with Power BI.

Power Query is a tool native to Microsoft Excel that functions in the background of any .xlsx file. It is Excel’s way of making sense of any imported data, and once it is set up, a Power Query can be used over and over again to run the same calculations with new data. You can use a Power Query to streamline data processing for many kinds of environmental reports and calculations.

Set up a Power Query once, have near-instant emissions calculations for years to come.

How does this tool work?

Power Query is simple to learn, especially if you are already accustomed to doing moderate-to-complicated tasks in Microsoft Excel. The Power Query editor is set up similar to a spreadsheet but with a list of every change that has been applied to the data. That same list of changes can then be applied to fresh data by either refreshing the data pull or changing the data source. Using Power Query, you can run calculations, summarize data, filter and clean data, and create custom formulas to apply to data every month, quarter, year, etc.

Excel Power Query is highly effective at importing mass amounts of data into Excel and formatting it consistently. You can import entire folders of data at a time, which comes in handy when consolidating daily or monthly equipment data across many files. The Power Query then informs Excel how to interact with this data. Within the Power Query you can clean your tables, filter the data, and add calculations and transform your data. Power Query also connects seamlessly with other Microsoft tools like Excel Power Pivot and Power BI, which makes it that much easier to summarize data and create live reports.

What kind of data file types can Excel Power Query use?

A wide variety of file types are acceptable, including .xlsx, .xlsm, .csv, .txt, .pbix, common database files, and most notably .pdf. If your PDF files are readable in Adobe Acrobat or any similar digital PDF editor, then they can likely import successfully into Excel Power Query.

How do I know if this would work for my reporting tasks?

Consistent data formatting is key to successfully implementing a Power Query. For instance, if your data is coming directly from a CMS or an internal server such as PI SMT, you can be confident that the data formatting will be consistently similar from one year to the next and thus that an Excel Power Query will work well with this data.

How many Power Queries will I need to set up?

You only need one Power Query for each calculation type. For example, if you have three power boilers and two lime kilns, you only need two Power Queries because the first Power Query can be used for all power boilers and the second Power Query for both lime kilns, as long as the throughputs are measured the same way across each equipment type (e.g., heat input of boiler fuel and kiln throughput).

How long does it take to set up a Power Query? 

Depending on your reporting needs, a simple Power Query can be set up in just a few hours. That can add up to dozens or hundreds of saved hours over the lifetime of the Power Query.

Can I use a Power Query that someone else set up? 

Yes, even without a tutorial from the person who created it. Using Power Query’s list of all applied steps, you can easily familiarize yourself with a given Power Query by clicking through the steps to watch the data processing unfold.

Does this fully automate the calculations I need for all my reporting?

Unfortunately, no – Excel Power Query is best at automating individual calculation steps and is no replacement for a more comprehensive digital solution. If you are interested in exploring a fully-automated or partially-automated reporting system, our Digital Solutions Practice can connect you with the best product for your needs. Reach out to Stephanie Taylor (staylor@all4inc.com) for more information.

How do I get started?

You can learn how to set up a Power Query yourself using any of the countless online resources. Alternatively, we at ALL4 would be happy to help you implement a Power Query to use for years to come. If you would like to start the process of automating the calculation steps of your environmental reports, I encourage you to reach out to your ALL4 project manager or you can connect with me at opearson@all4inc.com.