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The WAS will review quantitative and qualitative features of the NC Local Water Supply Plans.

Contents 1 Research questions for WAS 2 Sampling possibilities 3 Other evaluations to gather 4 Analysis and Reporting 4.1 Background 4.2 Methodology 4.3 Quantitative Analysis 4.4 Qualitative Analysis 4.5 References

Research questions for WAS

1. How accurate have demand projections been? (Data will be obtained from plans)
   
2. How has the quality of the plans in general changed over time?
   
3. How have the numbers of interconnections and the reliance on interbasin transfers changed over time?
4. How consistent and useful is the supply estimation in the plans?
5. How useful are the water shortage response plans as a means of drought response?
6. How is water efficiency and conservation being used as a method of meeting projected water needs?
7. Do the plans address how increased volumes of wastewater will be handled if projections of increased water demand actually occur?
8. What indication is there that the planning process has engaged local leaders in thinking about their water system needs?
9. In general, how could the planning process be improved?
10. In particular, how could the planning process be tied more closely to the newly evolving river basin models?
11. How different are the demand projections from the numbers projected for the Water 2030 study?

Notes from initial meeting with Don Rayno 6/17/08:

Background. (info for Q. #2) The water supply planning initiative originally developed out of response to the drought in the late 80's. We should be able to pull some data from the oldest plans which were developed in 1989. Over the years, every drought has generated new responses and new initiatives to piggy-back on the program first implemented nearly 20 years ago. Water supply plans (WSPs) were required for all water systems beginning in 1992; they are updated every five years. Each submittal cycle, the WSP questionnaires have grown in sophistication.  For this study we will have access to plans for 1992; 1997 and 2002. The WSPs for 2007 are still under review; due to the record drought of 2007, the Division of Water Resources (DWR) has had little time to devote to reviewing and approving the latest submissions. We may be able to get some plans from the Neuse and Roanoke plans submitted in 2006 for the purposes of this study (DWR is in the process of transitioning the submittal process to match with river basin planning, and to spread their plan reviews over 5 years instead of all being submitted at once).  Portions of WSP data from '97 and '02 can be found online at the DWR website; no data prior to '97 is available online. Once it is available, the online data for 07 will be in its entirety. Each WSP cycle has grown in its sophistication of information requested via online submittal; while originally submittals were hardcopy, now systems can submit their entire plans online. Note: need to look specifically at framework vs. content for each cycle.

3. How have the numbers of interconnections and the reliance on interbasin transfers changed over time? need to be aware of the definition of an interbasin transfer (IBT), and IBT certificate thresholds.Review 1993 IBT law: systems were grandfathered that were enacting transfers in place or under construction prior to 7/1/93.

4. How consistent and useful is the supply estimation in the plans?This will relate to the quality of the plans. Some plans consider available water supple to equal th current water treatment plant's capacity. Some systems have studied how much they can withdraw; others have capacity constraints. Lots of groundwater system estimates have changed over time.

5. How useful are the water shortage response plans as a means of drought response?most WSRPs need a lot of work; often there is a gap in planning for what happens after restrictions limiting outdoor water uses have been enacted. For some, the next step is considered to be providing bottled water to customers, whereas in reality many other options exist in the range between these two management options. "If you could get only 20% of your supply, who would get it and how would you ensure that?" Note: get information on the drought tabletop exercise developed DWR and the Division of Emergency Management as a basis for a drought measures toolbox. 

6. How is water efficiency and conservation being used as a method of meeting projected water needs? Rarely - water efficiency as a "source" of water is used by a handful of utilities in the state, and to various degrees. Systems with designated water conservation staff include Charlotte, Cary, Durham, Greensboro, OWASA, and Raleigh.

7. Do the plans address how increased volumes of wastewater will be handled if projections of increased water demand actually occur?Not in the context of the local water supply plans. In the river basin plans (for which the LWSP serves as a foundation), discharge = current year WW. (consider opportunity to track WW and then resulting land area needed for disposal).

8. What indication is there that the planning process has engaged local leaders in thinking about their water system needs?The LWSP statute requires local governing boards to approve the LWSP. Note: when reviewing plans, look for proof that the plan was indeed approved.

9. In general, how could the planning process be improved? look at enforcement; these plans are currently voluntary. (Although SRFs will ask if "all statutory obligations have been met); 5-yr. cycle surprises some systems if institutional memory does not exist; annual reporting requirements began with 3/07 drought rules will help further keep systems on target. look at SB 1879 for latest proposed rules. Also look at definition of "essential water use".

10. In particular, how could the planning process be tied more closely to the newly evolving river basin models? develop a more formal feedback loop from modeling results (talk to Dan McLaurin prev. with DEHNR now w/ city of Raleigh); look for way to link LWSPs and SWSP (state water supply plans). Talk to participants in Cape Fear River Basin plan model and Catawba.

11. How different are the demand projections from the numbers projected for the Water 2030 study? Note: lots of the 2030 study used data from the 2002 WSPs

Sampling possibilities

• Look at the set of plans that has developed for the longest time period
• Look at the largest systems
• Draw a random sample
• Identify unusual cases
• For some data that are summarized quantitatively, describe the entire universe of plans (e.g. measures of central tendency and variation for demand and service area population projections)

Notes: Confirm lists of longest developed plans (1989 forward) and largest systems. It would be fairly straightforward to look at large systems (need to define, but would include at least Raleigh/Charlotte/Fayetteville/Asheville). MANY of NC's systems serve less than 200 people. To further plan for the sampling I will confirm numbers of systems by size category and water source (surface vs. groundwater). Unusual cases. Might want to consider looking at systems within the Capacity Use Area (CUA) as a subset. Also would be interesting to look at systems rated during the 2002 drought as Tier 1 (< 100 days of water left) and those systems that repeated the "Tier 1" ranking in the 2007 drought.

Other study notes/considerations/food for thought: if possible, we need to look not only how the plans are written, but provide some feedback on how the systems are managed. North Carolina has about 2,000 public water supply systems (confirm number); one of the highest numbers in the U.S. Would be useful to compare to plans developed in northeastern states as a point of comparison/contrast because of the high number of systems in that region as well. Need for long-term planning: 50-100 years. Access to water for non-riparian communities and associated issues. reasonable use of groundwater based on land use above it. How much water should be left for habitat? Impacts of water reuse on streamflows in the context of reuse water being used to expand supply: in which case the end result is that less water flows back to the stream (particularly if reuse water is for non-potable consumptive use).

Other evaluations to gather

• Steve Cavanaugh and others have assessed the water accounting methods used in some of the plans in connection with their study of the possibilities raised by the IWA/AWWA water audit procedures.

Analysis and Reporting

Background

North Carolina’s water supply planning initiative originally developed as a response to a severe drought that occurred in 1988. The first Local Water Supply Plans (LWSPs) were submitted to the State’s Division of Water Resources (DWR) in 1989 and primarily included data regarding municipal water demand. Every subsequent drought has generated new questions and new initiatives to piggy-back on the program first implemented nearly 20 years ago.

Beginning in 1992, North Carolina General Statute G.S. 143-355(l) requires local water supply plans for all municipal water systems and all community water systems serving more than 3,000 people or 1,000 connections; the statute also requires that plans be updated every five years, which to date has included 1992, 1997, 2002 and 2006/2007. 

North Carolina’s State Water Supply Plan, dated January 2001, is based on Local Water Supply Plans developed during 1998 and 1999, which reflect the water system data reported by over 500 local government water systems for 1997. This plan serves as a reference point for statewide water supply needs, water use, and supply issues across the state. The Division of Water Resources has recently adopted a new river-basin oriented planning strategy to correspond with the Division of Water Quality’s river basin planning and to further foster long-term sustainable water resources management.

Overview of Local Water Supply Plan submittal, review and tracking process.

The Division of Water Resources begins each round of LWSP submittals by working with the Public Water Supply Section (of Division of Water Quality) to verify current list of systems meeting the submission criteria. In coordination with the NC Rural Water Association, DWR notifies systems early in the year about their required submittal the following July and provides a series of workshops around the state for technical support in developing municipal plans. The workshops provide a comprehensive overview of the planning process and provide a step-by-step guide to developing the information needed to submit the plans online. In addition, DWR's software allows staff to provide virtual online assistance in real time - both the person filling out the survey and the staff member can review the screen at the same time.

Each submittal cycle, the LWSP questionnaires have grown in sophistication. The 1989 data is skeletal and summary statistics provide only system consumption parameters. DWR is in the process of transitioning the submittal process to correspond with river basin modeling and to spread their plan reviews over 5 years (instead of requiring all plan submittals the same year). For the purpose of this study, researchers had access to plans for 1989 (demand only), 1992, 1997 and 2002. The LWSPs for 2006/2007 are still under review and have not been completed. Portions of WSP data from '97 and '02 can be found online at the DWR website; no data prior to '97 is available online. Each WSP cycle has grown in the sophistication of information requested via online submittal. While originally submittals were hardcopy, now systems can submit their entire plans and supporting documents online.

After the plans are submitted for a particular round, DWR staff begin the review process. The surveys are designed with checks and balances throughout the questions, to ensure accuracy of information wherever possible. Where answers do not match or are not complete, DWR staff provide a follow-up list of questions to the water system. This review process can take two or three iterations in some cases. When the process is complete, DWR sends a notification that the system has received approval for its plan. At that time, the local government formally adopts the plan and it is considered final until the next cycle. Some systems never complete the process. Summary statistics are provided in the quantitative section regarding percentage of plans that are deemed approved, completed or incomplete.

LWSP reporting requirements in 2008 legislative action9

Methodology

'Because the scope of the LWSP surveys changes with each cycle, few consistent parameters exist among the plans submitted in 1989, 1992, 1997 and 2002. The data that was requested during each survey cycle includes municipal demand; however, even this data changed parameters from 1989 to 1992 when the surveys began to distinguish between average daily demand (ADD) and service area demand (SAD). ADD is the entire average daily water produced by a water treatment facility or utility system, including water distributed (usually for a fee) to other systems. The service area demand is that portion of the ADD that is used by the utility's own service area - including (but not limited to) the customers that receive water from a system or facility. 

The research questions for the purpose of this study are:

1. Do Local Water Supply Plans get more accurate over time?
2. Do larger systems do a better job of providing responses to Local Water Supply Plans than other systems?
3. What differences, if any, are noted among surface water systems, ground water systems, and purchased water systems?

To evaluate these questions, two approaches (one qualitative, one quantitative) will be used to analyze North Carolina’s Local Water Supply Plans.

'

Quantitative Analysis

'Sampling Bins and Data Sources. With input from Don Rayno of DWR and Shadi Eskaf of the UNC School of Government’s Environmental Finance Center, two primary parameters were determined to be useful for describing the sampling bins: system size (service population), and system source (surface, ground, or purchased water). Service population was requested beginning with the 1992 LWSPs. Systems that submitted LWSPs in 1997 and 2002 were asked to provide information on their supply sources (surface, ground, and purchased). All systems from the 1997 and 2002 LWSP data were evaluated to determine the predominant source (> 50%) of supply: surface water, ground water, and purchased water. The systems were subsequently allocated by population served for three sizes: small (0-3,000), medium (3,001 – 10,000), and large (> 10,000). It is worth noting that the State deems systems serving greater than 3,000 people to be “large” and thus subject to various reporting requirements.

1. Describe the entire universe of plans, providing measures of central tendency and variation
2. How accurate have demand projections been? How is demand changing over time?
3. How consistent and useful is the supply estimation in the plans?

 Here is a file with the descriptive statistics for the LWSP study.

LWSP Review Process. As noted earlier in the "Background" section above, DWR spends an extensive amount of time reviewing the Local Water Supply Plans. Staff responsible for plan review often have conflicting priorities and are not able to complete plans in a timely manner. In recent years the legislation has changed several times - each time the rules change regarding plan requirements DWR (assisted by divisions such as Public Water Supply and the NC Rural Water Association) must embark on a public notification campaign. In some instances DWR finished the notification process only to have another set of rules effected. The tables below summarize the review process for 1997 and 2002 both by system size and by water source. In 1997, 43% of plans were never adopted by their municipal government; over half of these systems (28% of the total systems) were "small" systems. In 2002, 93% of LWSPs were never formally adopted by their government. Over half of the plans (55%) were deemed incomplete, either because they were not submitted or had unresolved questions. Small systems (47% of the total) again showed lack of ability to take plans through to the "adoption" stage. The 2002 and 2003 extreme droughts likely contributed to the lack of plans adopted. In addition, in 2003 the rules changed (again) to require all municipalities to submit Water Shortage Response Plans in concert with their Local Water Supply Plans.

GW = Groundwater; PW = Purchased Water; SW = Surface Water

Small systems: < 3,000 service population; Medium systems: 3,001 - 10,00; Large systems: > 10,000

Qualitative Analysis

For the qualitative analysis, a paper review of randomly-sampled LWSPs was performed to provide additional insight regarding changes in plan quality over time; consistency of supply estimation; content of water shortage response plans; suggested improvements; and synchronization with the river basin models. To consider changes over time within systems, the author reviewed all available plan years for each system.

2002 LWSP Category Number reviewed
Small Systems 1 SW; 6 GW; 4 PW
Medium Systems 2 SW; 3 GW; 2 PW
Large Systems 2 SW; 1 GW; 1 PW
Capacity Use Area Systems (12 included above)
Total 22 (4% of total LWSPs)

Evolution of Water Supply Plans (changes in quality over time)
DWR distributed paper surveys in1989 and 1992, returned by municipalities along with supporting materials. Beginning with the 1997 plans, DWR began offering a partial online submittal process; in 2007 the online submittal process was streamlined such that both the survey and all supporting materials can be submitted electronically. In addition, DWR staff can now provide real-time technical support while the survey is being filled out – with both parties reviewing their computer screens simultaneously.

As discussed earlier, the original plans in 1989 requested very little data. Each subsequent year the plans have increased in sophistication. The 1992 plan had sections requesting (). The 1997 plans asked additional questions in the arena of (). Surveys for 2002 were the most comprehensive to date, expanding the universe of questions to also request data regarding inter-basin transfers and ().

A general difference in quality for small systems versus medium and large systems was observed during review of paper plans, especially those submitted in the first two rounds (1992 and 1997). This is quite understandable given the general lack of resources within small systems. Often the paperwork is filled out by the mayor’s assistant, who is expected to handle all leftover tasks not assigned to other employees. Systems could often only provide general system demand and could not provide specific consumption by customer type (residential, commercial, industrial, etc.). DWR provides extensive technical support to small systems in particular which has ranged from a few minutes to more than eight hours per municipality. With each round of plan submittals, it is apparent that respondents are getting better at providing the requested data.

Submittal and review. Because the LWSP process was brand new and both municipalities and DWR staff were on a learning curve, plans submitted often had to go through several iterations before receiving final approval. Because there are no enforcement mechanisms, plans might be submitted late, if they were even submitted at all. (Note: a financial incentive does exist in the form of requirements for state and federal funding to meet “all statutory obligations” which would include submission of the LWSP.)

In tandem with the basin modeling process, DWR has recently initiated a phased submittal process, whereby approximately 20% of municipalities will submit their LWSPs each year. In 2007, 100 municipalities were scheduled to submit their 2006 plans. At the end of August 2008, 90% of the 2007 plans due had been submitted.

Often the 5-year plan cycle would catch utility staff by surprise because they had not been involved in the previous cycle. They, like their successors, often had to come up to speed on their system’s parameters, programs, and capabilities. However, with the new requirements of 15A NCAC 02E .0604 ANNUAL REPORTING OF WATER USE DATA implemented in March 2007, all LWSP systems must report on an annual basis the system’s annual and monthly ADD, number of connections and consumption by category (residential, industrial, commercial and institutional, and other demand statistics. DWR staff anticipate that the annual reporting requirement to make the 5-year survey much easier to fill out.

Usefulness of Supply Estimation in the Plans. For each planning cycle from 1992 onward, systems were asked to provide details on both current and long-term projected water supplies. The ability of municipalities to accurately answer this question directly relates to the quality of the data and extent of planning considerations used. Some respondents considered available water supply to equal the system’s current water treatment plant's capacity. Some systems studied the limitations of their well withdrawals; and others estimated supply based on current purchase contract agreements. The quality of answers is improving over time, as the LWSP survey now provides a definition of “available supply” for consultation during the survey process. Many groundwater system estimates have changed over time. The benefit of this question is that it compels utilities to begin considering long-term system needs, especially when the calculations provided in the survey show that demand is approaching supply capacity over the coming years.

Water Shortage Response Plans as Means of Drought Response
A Water Shortage Response Plan (WSRP) establishes authority for municipalities or other water provider to declare a water shortage. The WSRP defines different phases of water shortage severity, and outlines appropriate responses for each phase.

After the severity of the 2002 drought, the North Carolina General Assembly required local government and large community water systems to include a section in their 2003 LWSPs to describe how the water system would “respond to drought and other water emergencies and continue to meet essential public water supply needs during the emergency”. The sudden requirement to include the Water Shortage Response Plans in their 2003 plans substantially delayed submission by many municipalities of their LWSPs due July 1, 2003. To further clarify content needed in the WSRPs, the Environmental Management Commission adopted rules in March 2007 providing detailed requirements. (15A NCAC 02E .0612 - .0614).

Most WSRPs need a lot of work; often there is a gap in planning for what happens after enacting restrictions to limit outdoor water uses. For some municipalities, the next step is considered to be providing bottled water to customers, whereas in reality numerous options exist in the range between restricting outdoor water use and providing bottled water. The Division of Water Resources evaluates the WSRPs against a defined checklist with criteria that includes enforceability, triggers to move in and out of response levels, public notification processes, authority to enact, severity of stages, and opportunity for public comment.

While reviewing the sample of 2002 plans, the reviewer noted that all of the small system plans included copies of water shortage response ordinances but did not provide documentation of approval; i.e. the ordinance provided did not have a code assigned and did not show the date of adoption. Ordinances reviewed for medium and large systems provided substantiation of adoption.

While research was underway for the 2008 Water Allocation Study, Session Law 2008-143 was approved which requires local water shortage response plans to have formal DENR approval and set the following criteria for an approved plan:

1. The plan must have tiered levels of water conservation measures or other response actions based on the severity of water shortage conditions.
2. The tiers must result in progressively more stringent water conservationmeasures that correspond to increased severity of water shortage or drought conditions.Note: A plan that lacks specific triggers for water conservation measures or makes implementation of measures optional at each step (or dependent on a decision by a public official or governing body) will not meet this requirement.
3. The plan must meet all other requirements set out in the EMC’s rules (15A NCAC 02E .0612 - .0614).
4. Water shortage response plans cannot regulate or require the metering of private drinking water wells (defined as wells that serve fourteen or fewer service connections or twenty-four or fewer individuals).

Under the newly adopted rules, a WSRP submitted to DENR is presumed approved until DENR notifies the system of disapproval. If the system’s existing water shortage response plan meets the new criteria, the water system can continue to operate under that plan. Otherwise, an updated water shortage response plan must be submitted to the Department by July 1, 2009.

As of September 5, 2008, 398 of the required 544 water systems (73%) had submitted Local Water Shortage Response Plans. As noted earlier, these WSRPs are considered approved until they are formally disapproved. The Division of Water Resources, in concert with the North Carolina League of Municipalities, is currently in the process of developing formal criteria for approval. Some systems have elected to utilize the default rules which may not provide the desired flexibility and customization to their particular system’s needs in the case of a water shortage.

Discuss definition of essential water use

Water Shortage Response Plans provide the opportunity for municipalities to enact a powerful planning tool. Particularly with the latest round of rule changes the plans continue to increase in sophistication by requiring both tiers of response actions and specific triggers based on the severity of the situation. During droughts it is really hard to predict the future; utility actions are partially judgment calls made on the basis of probabilities that a current drought will continue for a certain time into the future. WSRPs provide a sound foundation for crisis stages because they are (usually) developed during non-crisis times.

Improvements in Planning Process
(pending)

References

Steve Cavanaugh, President, Cavanaugh & Associates, P.A.

Shadhi Eskaf, Environmental Economist, UNC-Chapel Hill School of Government

Leila Goodwin, Water Resources Planner, Town of Cary, North Carolina

Brian McCrodden, Vice President, HydroLogics, Inc.

Linwood Peele, Water Supply Planning Section Chief, North Carolina Division of Water Resources

Don Rayno, Water Supply Planner, North Carolina Division of Water Resources

http://www.gdrc.org/uem/water/iwrm/1pager-01.html

http://www.ncwater.org/Water_Supply_Planning/