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Below is the HillCo client report from the January 15 Texas Water Development Board stakeholder meeting on prospective rulemaking for HB 3605 (83R) regarding water loss metrics and financial assistance.

Robert Mace, Deputy Executive Administrator, Water Science & Conservation TWDB

  • TWDB is looking for feedback and wants to hear thoughts on the following three questions
    • Which measure of water loss should be used
      • A percentage of total water supply or total loss per connection per day
    • What should the threshold be
      • The original idea was to affect the top 20% of utilities losing water
      • If the threshold is too low it creates a disincentive to use TWDB for financing
    • What will utilities need to do to address loss

 
Joe Reynolds, Staff Attorney, Legal Services, TWDB

  • Applications submitted before September 1, 2013 will be grandfathered and not subject to new water loss rules

 
John Sutton, Municipal Water Conservation, TWDB

  • There is unavoidable water loss per mile of utilities that will be taken into account
  • Thresholds will be used within multiple categories
    • Utilities with less than 32 connections per mile will be categorized separately from utilities with 32 or more connections per mile
    • Within those categories, utilities will be split up by number of connections
  • Water loss can be addressed in many ways including laying new lines to reduce leakage or even installing new meters that calculate more accurately
  • The current idea is to use data from reporting year 2010 which was the last statewide water audit
  • TWDB must adopt rules for use of financial assistance to mitigate water loss
  • TWDB is aware that flexibility needs to be considered in cases where the utility is already addressing water loss, in emergency situations, or in cases where the data is too old and no longer accurate

 
Public Comment
 
Sierra Club

  • Agrees that total loss per connection is the best way to measure loss
  • Concerned that the rules might not significantly affect water loss if only the top 20% threshold is used
    • Sutton replied that TWDB is using the 2010 data to create the threshold but going forward, yearly data may be used as it becomes available; the 20% threshold was only used to submit data to the Board preliminarily and can be changed

 
Austin Water Utility

  • Concerned about the accuracy of data being used; some systems show negative water loss or small enough numbers that there is no way it could be accurate
  • There is currently no penalty for filing inaccurate data
  • There needs to be a third party audit done on submitted reports
  • The top 20% threshold may need to be addressed as Austin shows up in that group while being very aggressive on water loss

 
City of Houston

  • Curious about the accuracy of the formulas used to calculate water loss as well as the accuracy of data being submitted

 
San Antonio Water System

  • Surprised that 2010 data is being used when most utilities will be submitting data every year
  • TWDB should use the scoring system for validity that American Water Works Association uses; it is more refined than the state model
  • Would like for utilities to pay an application fee to fund a third party audit of reports
  • Will loan funds be able to be used for non-capital projects such as planning and consulting
    • Reynolds replied that funding is already given out for planning and consulting and he doesn’t expect that to change

 
Webb & Webb Attorneys

  • Rulemaking may provide an avenue to address the appropriateness of the water loss survey and the validity of data

 
Texas Water Infrastructure Network

  • There is a lot of water loss due to breaking pipes through excavation which creates a headache for water utilities
  • Emphasizing water loss may be a good way to get municipalities to sign on with a one-call center so that when individuals call before they dig they are informed of water lines in the area as well as gas lines and electricity lines