Is Your Water Shortage Contingency Plan Robust Enough to Support You Through This Drought?

As the news headlines have been highlighting, 2012 and 2013 have been some of the driest years in recorded history for California. With no significant precipitation on the horizon, we start 2014 with water storage reservoirs low, fire danger high, and drought on everyone’s mind.

In light of this, some of the agencies that EKI works with are dusting off their existing Water Shortage Contingency Plans (WSCPs) and asking hard questions about their preparedness for a drought.  EKI is working with our clients to answer the following questions with respect to the adequacy of their WSCPs:

  • Does my existing WSCP reflect the significant strides my customers have made in increasing their water use efficiency (i.e., demand hardening)?
  • Was it developed through a public process such that it reflects the local public policy interests in how water shortage allocations are determined?
  • Does it clearly specify the mechanisms by which the necessary cutbacks can be realized and assess the impacts of the projected cutbacks on revenues and staffing and the local economy?
  • Does it include a detailed implementation plan and estimates of the lead time required to implement specific actions during a water shortage (e.g., adding additional meter readers in order to move from bi-monthly to monthly billing)?
  • Is it coupled with a drought rate schedule that has been vetted through a Proposition 218 process such that it can go into effect immediately upon declaration of a drought?

Applicable Regulations

California Water Code Section 10632(a) requires urban water suppliers to develop a water shortage contingency plan which indicates the actions the supplier will take in response to supply shortages of up to 50 percent.  California Water Code Section 10632(a)(5) allows water suppliers to use any type of consumption reduction methods in its water shortage contingency analysis that would reduce water use, are appropriate for its area, and have the ability to achieve a water use reduction consistent with up to a 50 percent reduction in water supply.

There is also a new requirement for WSCPs. Pursuant to 10632(a)(9): …the urban water supplier shall analyze and define water features that are artificially supplied with water, including ponds, lakes, waterfalls, and fountains, separately from swimming pools and spas, as defined in subdivision (a) of Section 115921 of the Health and Safety Code.

Potential Approach to Updating Your Water Shortage Contingency Plan

In its work with existing clients to update their WSCPs, EKI has recommended that, as part of their prudent water supply planning efforts, they pursue a transparent and technically-sound approach to developing the policies and procedures that they will employ during the next drought.  The following are sample tasks that EKI is implementing for its clients as part of WSCP development:

  • Prepare a Work Plan to develop a WSCP that reflects the interests of the Agency, its Governing Body, the Customers, and the available budget, data and schedule;
  • Engage the public in the WSCP planning and development  process through development of a Task Force, regular public meetings, or other mechanisms;
  • Identify the laws, goals and principles that will govern the development of the WSCP and that reflect the interests of the Agency, its Governing Body, and the Customers;
  • Determine water supply availability and the triggers for the declaration of a water shortage emergency, potentially including the establishment of a Level of Service goal;
  • Define the Stages of Action (i.e., the classification a shortage event into one of five levels, up to a reduction of 50 percent);
  • Develop a water allocation methodology using an analytical tool (GIS- or excel-based) that will allow testing of different water allocation methodologies and assess, for each Stage of Action, what the impact would be on water use and revenue on both a system-wide scale, and disaggregated based on customer type and geographic areas;
  • Analyze consumption reduction methods (i.e., the demand reduction measures, communications actions, and operating actions that the Agency and/or Customers must take to achieve the stated water reduction goals for each Stage of Action);
  • Summarize enforcement and appeals procedures that the Agency would follow with respect to its Customers in the event of a water shortage;
  • Develop a WSCP Implementation Plan that includes specific Agency and/or Customer actions and includes the approximate lead time needed to activate the different elements of a demand reduction program (e.g., the application of drought rates, and more frequent billing which requires additional personnel and billing system flexibility); and
  • Prepare a WSCP and Template Water Shortage Ordinance.

To find out more about how EKI can assist your Agency to better prepare for the next drought by updating its WSCP, please contact Anona Dutton at or (650)292-9100.

Please also see the presentation that Anona Dutton gave to the Bay Area Water Conservation Coordinators at their quarterly meeting on December 4, 2013.