Assessing Effectiveness of Water Use Efficiency Regulations

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When Washington created municipal water use efficiency requirements 20 years ago, many in our famously rainy state may have been skeptical of the need to conserve water. Today, however, our population is growing rapidly, and our water supplies are more constrained.

Rapid population growth and changing climate are putting growing pressure on the availability of Washington’s fresh water supply. Most Washingtonians have experienced drought conditions in recent years. As a result, managing the state’s water resources is becoming an increasingly vital responsibility of the state.

This audit assessed the effectiveness of Washington’s water use efficiency regulations as administered by DOH. It also explored opportunities to improve the results.

Read a two-page summary of the report.

Report Number 1033620 Report Credits

Key results

One of the two main goals of the water efficiency program is to reduce the loss of drinkable water as it travels through municipal systems. The audit found better collection and use of data could help reduce the loss of drinkable water. We found the data maintained by the Department of Health (DOH) was incomplete and often unreliable. This was due in part because the agency does not collect all the information required by law. 

DOH can also focus more of its efforts on helping small water systems understand and comply with its regulations. These systems make up 90 percent of all municipal systems in the state. When we surveyed water suppliers, they singled out two issues as barriers to compliance with efficiency requirements. First, insufficient funds, and second, the difficulty of finding leaks. Most of the respondents that cited these barriers were small-system operators.

Conservation is the second of the main goals of state water use efficiency requirements. Our survey showed that water suppliers were overwhelmingly concerned about the importance of conservation. We found those efforts may be better housed within the state Department of Ecology, which already has expertise in natural resource conservation. In addition, the Legislature recently directed Ecology to update the state’s response to climate change.

Background

In 2003, the Legislature passed the Municipal Water Law, which included statutory requirements designed to address municipal water use efficiency. The law assigned implementation of the requirements to the Department of Health (DOH). The statute (RCW 70A.125.170) was designed to advance water use efficiency through two methods:

  • First, decreasing customer use of water by expanding water systems’ conservation efforts
  • Second, ensuring the efficient supply of water by minimizing water loss as it travels through the distribution system

DOH received some funding through 2007 to create and begin implementation of a water use efficiency program to implement the law.

Drinking water is the state’s second-largest use of water. About 2,065 municipal water systems supply customers with water. Most of these systems serve at least 15 residential connections. Seattle Public Utilities is the largest, serving 177,000 connections overall. Municipal water systems account for only 12 percent of all water systems. Nonetheless, they supply 98 percent of Washington’s water system customers with drinking water. Two-thirds of municipal systems are privately owned. The remainder are publicly owned, for example by cities or counties.

Managing supplier data

Most municipal water suppliers reported water use efficiency data to DOH, as required by agency rules. However, we found that DOH’s inventory of municipal water systems was inaccurate. Furthermore, DOH has not maintained current contact information for some municipal water suppliers. We discussed this with DOH staff during the audit. They said the agency has already begun to improve the accuracy and completeness of its inventory.

The water use efficiency data DOH maintains is incomplete and often unreliable for two main reasons. First, DOH does not collect all supplier data required by its rules, and the agency does not use some data it does collect. Second, DOH did not identify which water systems were exempt from metering requirements. Because its data is unreliable, DOH cannot accurately determine compliance with its water use efficiency regulations.

Applying leading practices

DOH does not use or require industry leading practices that could help improve the reliability of water loss calculations. For example, water audits and data validation could help suppliers better understand and manage water loss.

Changing the standard for water loss from percentage lost to an alternative benchmark could improve water system evaluations. As part of a pilot project in 2017-2018, DOH offered training on leading practices. Most participants valued the training, and thought water audit methodology preferable to the state’s required calculations. However, the agency has not implemented the project’s final recommendations.

Reassigning agency responsibility

DOH created rules around improving water conservation, but has focused few resources on implementing them. Water suppliers themselves recognized the importance of conservation in their survey responses.

In response to increasingly limited state water resources, the Legislature could reassign responsibility for water conservation from DOH to the Department of Ecology. Ecology is well suited to provide water conservation oversight and assistance.

Better coordination on conservation issues could help ensure consistent policies and rules in the future. This is the case no matter which agency ultimately holds responsibility for water conservation.

Recommendations

We made a series of recommendations to help DOH address issues we found in its regulation of municipal water loss. We recommended the agency:

  • Collect all information from suppliers required by its rules
  • Ensure calculations used to determine water system compliance use only reliable data
  • Improve assistance to suppliers, for example by improving the website and developing a supplier forum
  • Pursue results from its water use efficiency pilot project

Additionally, we recommended the Legislature grant DOH the authority to exempt small municipal water systems from water loss regulations. This change would help ease the regulatory burden on these systems.

Finally, we recommended the Legislature revise the water use efficiency portion of the Municipal Water Law to grant the Department of Ecology oversight of conservation planning and implementation.