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Meeting Packet - 3/18/2013
WATER RESOURCES ADVISORY BOARD MEETING SPECIAL MEETING DATE: Monday, 18 March 2013 7:00 p.m. 1777 West Conference Room 1777 Broadway Agenda Highlights: 1. Call to order. (7:00 p.m.) II. Approval of minutes from the 25 February meeting (7:01 p.m.) III. *Public Comment Period. (7:05 p.m.) IV. Continuation - Public hearing and consideration of a recommendation for thresholds for a recreational boating Program on Barker Reservoir (7:10 p.m.) V. * Public hearing and consideration of recommendation to City Council regarding the adoption of a Critical Facilities Ordinance (7:50 p.m.) VI. Information Item - Update on Commercial, Industrial, and Institutional Water Budgets (8:00 p.m.) VII. Matters • From the Board (9:00 p.m.) • From Staff (9:10 p.m.) VIII. Discussion about Future Schedule (9:20 p.m.) 1X. Adjournment. (9:30 p.m.) * Public Comment Item Information: Contact the WRA 3 Secretary, Laurel Olsen-Horen at (303) 441-3203 or olsenl@bouldercolorado.gov . Packets are available in the reference section of the Main Library and on-line at http://www.bouldercolorado.go , Departments, Public Works, c~ Utilities, Water Resources Advisory Board. Agenda item times are approximate. w rn CITY OF BOULDER, COLORADO BOARDS AND COMMISSIONS MEETING MINUTES Name of Board / Commission: Water Resources Advisory Board Date of Meeting: 25 February 2013 Contact Information of Person Preparing Minutes: Laurel Olsen-Iloren; 303-441-3203 Board Members Present: Susan Iott, Chuck Howe (departed 10:25 p.m.), Dan Johnson, Vicki Scharnhorst Board Members Absent: Staff Present: Jeff Arthur, Director of Public Works for Utilities Bob Harberg, Engineering Project Management Coordinator Bret Linenfelser, Water Quality and Environmental Services Coordinator Joe Taddeucci, Water Resources Coordinator Jody Jacobson, Communication Manager. Lesli Ellis, Comprehensive Planning Manager Craig Skeie, Water Resources Facilities Manager Russ Sands, Water Conservation Manager Michelle Wind, Drinking Water Program Supervisor Kaaren Davis, Board Secretary MeetingType: Regular Agenda Item I - Call to Order 17:04 p.m.] This meeting was called to order at 7:04 p.m. Agenda Item 2 - Approval of the 28 January 2013 Meeting Minutes: 17:02 p.m.] Motion to approve the 28 December minutes as presented by: Howe; Seconded by: Johnson Motion Passes; 3:0:1 (Scharnhorst abstains) Agenda Item 3 - Public Participation and Comment [7:03 p.m.] Public Comment: None Agenda Item 4 - Public Hearing and Consideration of a Recommendation on Thresholds for a Recreational Boating Program on Barker Reservoir [7:04p.m.] Jeff Arthur presented item to the board. Lesli Ellis facilitated the discussion on the item. Executive Summary from Packet Materials: On September 18, 2012, the Town of Nederland Board of Trustees (Trustees) adopted resolution 2012-27, "A Resolution Declaring Town Support for a Boating Program on Barker Meadow Reservoir" (Attachment 1). Specifically, the resolution states that, "The Nederland Board of Trustees urges the Boulder City Council to direct City staff to negotiate in good faith with Town representatives to draft a mutually acceptable program." Because the Trustees' request was specifically directed to City Council and requested allocation of city resources, council consideration was scheduled prior to requesting a recommendation from WRAB. At its January 22, 2013 meeting, City Council considered the request from the Trustees. The staff memorandum and recommendation for the associated agenda item is included as Attachment 2. Council did not make a specific motion regarding the item but Council members did express varying perspectives and reached general agreement on the concept of WRAB discussing "thresholds" for a potential boating program. Cost/sustainability, program management, safety, water quality and liability were general areas identified as important considerations. Council feedback indicated that development of a boating program was not a City of Boulder work program priority and that minimal staff resources should be committed to related efforts. Staff recommends that WRAB members view the video recording of the meeting to gain an understanding of the Council's discussion and direction. The recording is available on the city's website at the following link: http://www.bouldereolorado.gov/index.phht)?option=com content&view=article&id=16407&itemid=875 At the January 28, 2013 WRAB meeting, the board discussed scope and timing of an agenda item to respond to City Council's request. The WRAB did not vote or otherwise take an official position on the concept of boating or associated details. WRAB Minutes 25 February 2013 Page No. 1 The board supported scheduling the requested "threshold" discussion for the February 25, 2013 meeting. There was also agreement that the discussion would not involve a review or evaluation of a draft boating proposal. While the volunteer group leading the boating effort has indicated that a draft proposal has been prepared, it has not been formally submitted for review at this time. The focus of the current agenda item is to identify key "thresholds" to guide next steps in the preparation and consideration of a proposal. Public Comment: (7:39) • Randy Lee: Town of Nederland Trustee- Executive Director Ned Rec: Non-profit volunteer based organization can function as well as a professional company with regards to oversight and enforcement. Goal would be for their group to manage oversight for a couple of years and then hand over to a Parks District. Rescue boat on sight, improves safety for everyone. Reservoir is Nederland's defacto dog park- This plan is the best way to get that under control with active management, oversight, and enforcement. ANS component in proposal, mature zebra mussel tests done twice yearly for larvae, once per year for mature muscles. State of CO does not recognize any threat from carry on craft; we recognize that any inspection program will be state certified. Recent Master Plan update included survey information on boating. 64% of respondents were in favor. • Allen Nelson: Has a professional background in research statistics. Trail Boating study was done in 1999. This recreation opportunity would serve both Boulder and Nederland. One major advantage is environmental benefit and sustainability in that there would be less driving to farther boating facilities. Could save 80,000 lbs of C02. Study showed that most lakes in the area do not have any supervision or resources. Nederland has facilities nearby and a willingness to enforce. 2003 WRAB voted against boating, but the materials did not say why. FERC approved the boating in 1999. Please allow Ned citizens to actively participate in the discussion. • Randy Varga: Very supportive of folks taking a close look at the issues including cost effective management of facility, risk, etc. Feels the same as Mr. Nelson about a closer facility. Would be in support of using the money saved in driving costs as a user fee that would help support the cost of the facility and its oversight. WRAB Preliminary Discussion Included: [7:53 p.m.] • Howe: Made a statement prior to the presentation- Howe elects not to recuse himself from the discussion on Barker Reservoir as he feels he can be objective and can provide input on the issue which is valuable to both sides. Council asked for WRAB input, Howe has background useful for guidelines for the proposal which will be developed to send to Council. • WRAB discussed questions from the staff memorandum including whether the board generally supports the concept of non-motorized boating on Barker Reservoir, thresholds for a boating proposal, and city role in developing and managing a program. • WRAB discussed specific thresholds related to safety, water quality, program development and management, liability, cost/sustainability, and regulatory requirements. • WRAB requested that staff summarize and format the notes from the discussion for consideration as a motion at the March 18, 2013 meeting. Motion by Johnson, seconded by Howe: Motion to continue this item until the March meeting. Vote: 4:0 WRAB Minutes 25 February 2013 Page No. 2 Agenda Item 5 - Information Item - discussion of Flood Safety Education and Outreach Plan [10:05 p.m.] Jody Jacobson presented item to the board. Executive Summary from Packet Materials: On May 29, 2012, City Council held a study session on floodplain management. The discussion included feedback on a variety of areas including associated flood education and outreach. Staff has worked to incorporate that feedback into the overall flood education and outreach efforts. The purpose of this item is to inform the WRAB of the 2013 flood safety education and outreach plan and to get feedback from the board on tactics, priorities, key messages and audiences. WRAB Discussion Included: A set of questions for the board to discuss presented by staff. 1) What questions does WRAB have about the current flood safety education and outreach plan? 2) Does the WRAB have feedback about tactics, audiences or key message priorities? a) Are there any education and outreach approaches that appear to be ineffective that could be modified or eliminated? b) Are there any additional education and outreach approaches that are not being utilized that should be considered? 3) Would WRAB like any additional information on this topic'? WRAB Comments: Suggestions from the WRAB included.. • Better education on what people should actually do during a flood. • Focus on a few, good, effective methods. Quality over quantity. • Repeat the Fort Collins water slide (high hazard) test. Repeat blue dots. • Education that the Dam does not always protect us. • Connect to historical flood event. Images of historical floods (Big Thompson). Markers for flood levels. • Fresh approaches. Same thing every year means people become inured to risks and their education. • Early childhood education. Howe departs at 10:25 p.m. Motion: No formal action requested of the Board. Agenda Item 6 - Matters f10:34 p.m.] From Staff: • Staff- Update on Civic Areal Planning Process:. Starting to develop alternatives and evaluation criteria for them. Public meeting on April 17''. Can come back to WRAB in May when staff has some directions to pursue. • New UV: has passed its 30 days • Boulder Reservoir ANS • CDOT/US 36 Improvements/Flood model: From the Board: • Protocols: ✓ Discussion of specific protocols regarding interactions between board members and members of the public within the context of taking positions on items coming before the board. ✓ Recusais/conflict of interest ✓ Issuing reminders of protocols periodically to Board members when need is perceived • Which current WRAB member should replace Kate on the GAC. Scharnhorst will serve. Motion by lott, Seconded by Johnson: Motion to appoint Scharnhorst as the official WRAB representative to the GAC. Vote: 3:0 Agenda Item 7 - Discussion on Future Schedule [11:00 p.m.] • CII WRAB Minutes 25 February 2013 Page No. 3 • Water Conservation ( could be consent or IP) • Barker Continuation • Critical Facilities as a consent item Agenda Item 8 - Adjournment [11:10 p.m.] There being no further business to come before the Board at this time, by motion regularly adopted, the meeting was adjourned at 11:10 p.m. Motion to adjourn by: Scharnhorst; Seconded by: Johnson Motion Passes 3:0 Date, Time, and Location of Next Meeting: The next WRAB meeting will be March 18, 2013 at 7:00 p.m., in the 1777 West Conference Room of the city Municipal Building located at 1777 Broadway, unless otherwise decided b staff and the Board. APPROVED BY: ATTESTED BY: Board Chair Board Secretary Date Date An audio recording of the full meeting for which these minutes are a summary, is available on the Water Resources Advisory Board web page. WIZAH Minutes 25 February 201 3 Page No. 4 CITYOFBOULDER WATER RESOURCES ADVISORY BOARD AGENDA ITEM MEETING DATE: March 18, 2013 AGENDA TITLE: Public Hearing and Consideration of a Recommendation to City Council Regarding the Adoption of a Critical Facilities Ordinance PRESENTERS: Jeff Arthur, Director of Public Works for Utilities Bob Harberg, Utilities Engineering Project Management Coordinator Annie Noble, Greenways Coordinator Christie Coleman, Engineering Project Manager EXECUTIVE SUMMARY: The City of Boulder is proposing an ordinance to increase flood protection for facilities that offer lodging, and for critical facilities that provide essential services, serve at-risk populations, or contain hazardous materials. This ordinance requires lodging facilities to develop an emergency management plan and critical facilities to both develop an emergency management plan and implement flood protection measures. The proposed requirements would help reduce the risk to life and safety, ensure continuous service, minimize infrastructure damage and reduce environmental contamination following a major flood event. In 2011, WRAB and Planning Board recommended approval of a draft critical facilities flood ordinance. City Council subsequently raised concerns about the ordinance's potential impact on the business community. At a May 29, 2012 flood study session, City Council expressed support for continuing development of the ordinance and provided the following feedback: • Minimize impacts to nonprofits and small businesses • Avoid conflicts between height restrictions and elevation requirements Structure ordinance to clearly reflect the impacted uses At the June 2012 WRAB meeting, staff gave an update on the outcome of the flood study session, and in September 2012, staff presented a summary of City Council's feedback and staffs anticipated next steps. On December 17, 2012, staff presented an update on the ordinance and asked WRAB to assess proposed modifications to address City Council's feedback. No significant concerns were identified and WRAB was generally supportive of scheduling an agenda item to make a formal recommendation to City Council. AGENDA ITEM # 5 PAGE 1 Staff has continued to refine the ordinance to improve its organization and incorporate public feedback. Portions of the ordinance have been relocated from the (loodplain management section of the Boulder Revised Code, 1981, to a section focused on development standards. Another change, based on feedback from a facility manager, provides a two year time frame for completing levee modifications. Outside of these changes, the substance of the regulations remains substantially the same as discussed in December. STAFF RECOMMENDATION: Staff recommends that the Water Resources Advisory Board approve a motion recommending adoption of the proposed ordinance, in Attachment A, to City Council. The ordinance's wording and organization may continue to be refined through the Planning Board and City Council processes. Staff is recommending that the WRAB motion include "substantially the same form" language to clarify that the board's recommendation is on the substantive content of the ordinance and not the exact wording. Suggested Motion Language Staff requests the Water Resources Advisory Board's consideration of this matter and action in the form of the following motion: • Motion to recommend adoption of an ordinance amending Chapter 9-3, "Overlay Districts," Chapter 9-9 "Development Standards," and Section 9-16-1 "Definitions," B.R.C 1981, in substantially the same form as Attachment A. BACKGROUND: The following facility types are included in the proposed ordinance: • Essential Service Facilities: Examples include police stations, fire stations, hospitals and utility plants • At-risk Population Facilities: Examples include nursing homes, schools and daycares • Hazardous Material Facilities: Facilities with large amounts of chemicals • Lodging Facilities: Examples include hotels, motels, and bed and breakfasts The ordinance proposes the following requirements: Flood Protection Requirements in the 500-year Floodplain Facility Type Protection Method Triggers • Essential Service Floodprool'or Elevate New Buildings, Additions, Substantial Improvements or • At-risk Population Modifications • Hazardous Material Floodproof or Elevate or Development Requiring a Contain Chemicals Floodplain Permit or Compliance within 10 Years AGENDA ITEM H 5 PAGE 2 Emergency Management Plan Requirements in the 500- and 100-year Floodplains Facility Type Strategy Triggers • Essential Service Shelter in Place or Evacuation Development Requiring a • At-risk Population Plan Floodplain Permit or Compliance within 10 Years • Hazardous Material • Lodging In the 100-year floodplain, facilities still need to comply with existing flood protection requirements. There are no current requirements for emergency management plans in the 500- or 100-year floodplains. Under the proposed ordinance, approximately 80 facilities would be required to implement emergency management plans. Of those 80 facilities, approximately 40 critical facilities would be required to implement flood protection measures. The number of facilities has not changed from what was presented in December. A list of impacted facilities is included as Attachment B. Additional background information, from the December 17, 2012 critical facilities memo, is included in Attachment C. ANALYSIS: Since WRAB's December meeting, the format of the ordinance has been refined. The wording and organization of some sections has been updated to improve clarity or address public feedback. One significant change is that most critical facilities related requirements have been moved to the "Development Standards" section of the Boulder Revised Code, 1981. The intent of this change is to further reinforce that the ordinance is narrowly focused on specific critical uses and is not a broad set of 500-year floodplain regulations. An additional modification to the proposed ordinance was made at the request of a facility manager. The proposed ordinance was amended to allow critical facilities protected by a 500- year levee and impacted by flood mapping changes, to expand or be modified during a two year compliance time frame in which levee improvements were planned and constructed. Without this provision, flood protection measures would be required at the time of a building permit application for any expansion or modification. This modification is considered appropriate because of the substantial time involved in design, permitting, and construction of levee improvements. Outside of these two modifications, the requirements and scope of the ordinance remain substantially the same as discussed in the December 17, 2012 critical facilities memo. The proposed ordinance is presented in Attachment A. There was no public feedback at the December WRAB meeting. Impacted facility managers have been notified of the proposed revisions, and the draft ordinance has been posted to the AGENDA ITEM # 5 PAGE 3 project webpage. Staff is also continuing to reach out to the Chamber of Commerce and Boulder Hotel Association. NEXT STEPS: Pending WRAB's recommendation, the ordinance is scheduled to be presented to the Planning Board in April and City Council in June. ATTACHMENTS: Attachment A: Critical Facilities and Lodging Facilities Ordinance Attachment B: List of Existing Critical Facilities and Lodging Facilities Attachment C: December 17, 2012 Critical Facilities Memo (URL: http://www.bouldercolorado.gov/files/Utilities/WRAB/2012/2012-12/Agenda_6_CF memo.pdo AGENDA ITEM # 5 PAGE 4 ATTACHMENT A Draft.for WRAB 3-08-2013 1 ORDINANCE NO. 2 AN ORDINANCE AMENDING FLOODPLAIN REGULATIONS 3 AND DEVELOPMENT STANDARDS IN ORDER TO PROTECT CRITICAL FACILITIES AND LODGING FACILITIES IN THE 4 FIVE HUNDRED-YEAR FLOODPLAIN INCLUDING CHAPTER 9-3, "OVERLAY DISTRICTS," CHAPTER 9-9, 5 "DEVELOPMENT STANDARDS," AND SECTION 9-16-1 6 "DEFINITIONS," B.R.C. 1981; AND SETTING FORTH RELATED DETAILS. 7 8 BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF BOULDER, 9 COLORADO: 10 Section 1. Section 9-3-2, B.R.C. 1981 is amended to read: 11 9-3-2 Floodplains. 12 (a) Legislative Intent: The purpose of this section is to regulate certain areas of the city 13 subject to flooding in order to protect the public health, safety, and welfare by: 14 (1) Restricting or prohibiting certain uses that are hazardous to life or property in time of flood; 15 (2) Restricting the location of structures intended for human occupancy and 16 regulating the manner in which such structures may be built in order to minimize danger to human life within and around such structures; 17 (3) Requiring that those structures allowed in the floodplain be expanded or enlarged, 18 and equipment and fixtures be installed or replaced, in a manner designed to prevent their being washed away and to assure their protection from severe 19 damage; 20 (4) Regulating the method of construction and replacement of water supply and sanitation systems in order to prevent disease, contamination, and unsanitary 21 conditions; 22 (5) Maintaining for public inspection available maps delineating areas subject to such provisions in order to protect individuals from purchasing or using lands for 23 purposes that are not suitable-; ; 24 (6) Protecting and preserving the water-carrying and water-retention characteristics 25 and capacities of watercourses used for conveying and retaining floodwaters; and (7) Obtaining and maintaining the benefits to the community of participating in the 26 National Flood Insurance Program. 27 .I I7, s ~naiirtain -ed by tl~~_rrt5'_~11+r11 also dclhie_ate_th4_ (ivy I1L111_d0esi-ycaF 000cis?lairr COr tat1rp0se• SeK1i4n t2-t}- 28 3.r13 ItLa1!L)j&_rg_%~gni ral Facilities ,ind Lodging Facil,itics,"-13 R,C;._ 101. I ATTACHMENT A Draft for WRAB 3-08-2013 1 2 (b) Flooding May Occur: The degree of flood protection provided by the terms of this section has been determined to be reasonable for regulatory purposes. Floods of greater 3 magnitude will occur, and flood heights may be increased as a result of natural or human- 4 made causes. The provisions of this section do not imply that areas outside of the floodplain or land uses permitted within the floodplain are free from flooding, flood 5 hazard, or flood damages. A grant or approval by the city under the requirements of this section does not constitute a representation, guarantee, or warranty of any kind or nature 6 by the city or any city official or employee of the practicability or safety of any structure 7 or proposed use, and it creates no liability to or cause of action against the city or any city official or employee for any damages from flood or otherwise that may result from such 8 structure or use. 9 (c) Scope and Application: (1) The requirements of this section supplement those imposed on the same lands by 10 any underlying zoning provisions of this code or other ordinance of the city. The 11 city has also adopted development standards for critical facilities and lodin facilities located within the live huncirccl-yzar oodplain pursuarit•to section 9-9- 12 23. "Regulations Governing, Critical Facilities and Lodging Facilities." B.R.C 1981. If there is a conflict between such requirements, the more restrictive 13 controls. 14 (2) If a lot or parcel of land lies partly within the high hazard zone or the conveyance zones er- the or the one hundred-year floodplain, the part(s) of 15 such lot or parcel lying within such area or areas shall meet all the standards and 16 requirements of such respective area as prescribed by this section. For the purposes of new construction, if any portion of a structure lies partly within the 17 high hazard zone,-@+-the conveyance zone, or the one hundred-year floodnlainer the good fizinge area, all the standards and requirements of this section shall apply 18 to the entire structure. 19 (3) If lands located outside the city limits are included within the one hundred-year floodplainood fiin , the the conveyance zone or the high hazard zone, the 20 requirements of this section shall apply to such lands upon annexation. 21 (d) Administration: The city manager shall administer the requirements of this section and shall: 22 (1) Determine that the requirements of this section have been met before issuing any 23 permit for development in the floodplain; 24 (2) Obtain and maintain for public inspection any certificates of floodproofmg required by this section, and any information on the elevation (in relation to mean 25 sea level) of the level of the lowest floor (including basement) of all new or 26 substantially improved structures, and information specifying whether or not such structures contain a basement, and if the structure has been floodproofed, the 27 elevation (in relation to mean sea level) to which the structure was floodproofed; 28 ATTACHMENT A Draft for WRAB 3-08-2013 1 (3) Notify Boulder County and the Colorado Water Conservation Board before permitting any change in a watercourse and submit evidence of such notice to 2 FEMA; 3 (4) Adopt rules interpreting and implementing the requirements of this section 4 including, without limitation, application procedures for floodplain development permits and specifications for the floodproofing of structures, substantial 5 improvements, and utilities; 6 (5) Assure that the Boulder Valley Comprehensive Plan is consistent with the floodplain management objectives of this section and the regulations of FEMA; 7 (6) Make necessary interpretations of the exact location of the boundaries of the floodplain, the f4ee r ntxe, the conveyance zone and the high hazard zone; 8 (7) Amend the boundaries of the high hazard zone and the conveyance zone pursuant 9 to subsection (f) of this section; 10 (8) Determine that all necessary permits have been obtained from state, federal, or 11 local agencies the approval of which is required before issuing any permit for development in the floodplain; 12 (9) Require that persons changing a watercourse maintain the watercourse so that its 13 flood carrying capacity is not diminished; (10) Require that new and replacement water supply systems in the floodplain be 14 designed to minimize or eliminate infiltration of floodwaters into the systems; 15 (11) Require that new and replacement sanitary sewage systems within the floodplain be designed to minimize or eliminate infiltration of floodwaters into the systems 16 and discharges from the systems into floodwaters; 17 (12) Require that on-site waste disposal systems be located to avoid impairment to 18 them or contamination from them during flooding; and (13) Obtain, review, and reasonably utilize any base-flood elevation and floodway data 19 available from federal, state, and other sources, including data developed pursuant 20 to chapter 9-12, "Subdivision," B.R.C. 1981, as criteria for requiring that all new development meet the requirements of this section. 21 (e) Appeals: Any person contesting the city manager's interpretation of a boundary location 22 under paragraph (d)(6) of this section, or any person aggrieved by the granting or denial of a floodplain development permit, may appeal such determination to the planning board 23 through the process described in section 9-4-4, "Appeals, Call-Ups And Public Hearings," B.R.C. 1981. The request shall set forth the reason and basis for the appeal 24 and such other information as the manager may prescribe by rule. 25 (f) Map Amendments: As watercourse or flood channel improvements or mapping corrections are made, the city manager may amend the flood regulatory area maps to 26 recognize the changed conditions produced by such improvements or corrections 27 provided that no such amendments or corrections may change a FEMA "area of special flood hazard" or "regulatory floodway" unless the city is in receipt of a letter of map 28 amendment or a letter of map revision issued by FEMA. 3 ATTACHMENT A Draft for WRAB 3-08-2013 1 (g) Flood Regulatory Areas: 2 (1) The provisions of this section apply to the area shown as floodplain on the most recent maps adopted by the city council, as amended from time to time by the city 3 manager pursuant to subsections (d), (e), and (f) of this section. The regulatory 4 floodplain encompasses the one hundred-year floodplain, the-fleed ffinge-1 the conveyance zone, and the high hazard zone. The following regulations governing 5 each portion of the floodplain are cumulative and not exclusive. 6 (2) In addition to the regulatory areas identified in paragraph (g)(1) of this section, the city has adopted the areas of special flood hazard identified in the Flood 7 Insurance Study for Boulder County, effective December 18, 2012, and delineated on the Flood Insurance Rate Map for Boulder County and the City of Boulder as 8 adopted by the city in compliance with 44 C.F.R. chapter 1. In no event will the 9 regulations contained in this section be interpreted to permit any action not permitted under those regulations promulgated by FEMA for the regulation of 10 areas of special flood hazard and regulatory floodways. 11 ) The city has also ado t 1 development standards for critical facilities and lodrri g facilitig-s -located within the five hundred-year floodplain pursuant to section 9-9- 12 23, "Regulations Governing, Critical Facilities and Lodging Facilities." B.R.C. 19$1. Thc_re ;ulations goverili, i sdiical facilities and lodging, aeilities ar_e 13 supnlernental to the Iollm -ing requirements in the_ttrod reiMultor areas_ 14 15 Section 2. Section 9-3-3, B.R.C. 1981 is amended to read: 16 9-3-3 Regulations Governing the Floodplain. 17 (a) General Provisions: in the entire one hundred-year floodplain, the following standards 18 apply: 19 (1) Floodplain Development Permit: Except as specified in section 9-3-6(a). "Activities Exempt From A Floodplain Development Permit." B.R.C. 1981. 20 par-affaph (A)3-=no development in the floodplain may occur prior to the issuance of a floodplain development permit pursuant to section 9-3-6, 21 "Floodplain Development Permits," B.R.C. 1981. 22 aet; :t: "11 oil :thin the fleed r-egulatefy fid de not r 23 floodplain development 24 (i) "Mainlenanee" as defined in ehapter- 9 16 "Defiiii6ens" that do no „4:441to " ubst""tia "t an do not af'forot thy, 25 26 (ii) Sidewallc6, eericfete, aSphal4 6_11-4ta-M-3 " that does not na-4111t 28 :l T nde nd utilities that `l o edi f . existing gr-ade, 4 ATTACHMENT A Draftfor WRAB 3-08-2013 1 (iv) Poles, iiiies, cables, sty landseaping and ai4 ,-L that do e 2 haFafd ze33e, 3 (y) TemperaFy faciliIies, that are of p "+l, .,t+.,< hed to the 4 ' .;<do<d that +l, they Will REA affeet the efF;..-.. eity of th 5 ee ff .eya ffee . " I*ig h f o, of tke will FefAai+i in pplaee 6 (2) Anchoring: 7 (A) All new construction and substantial improvements or substantial 8 modifications shall be anchored to prevent flotation, collapse, or lateral movement of the structure and be capable of resisting the hydrostatic and 9 hydrodynamic loads. 10 (B) All manufactured homes must be elevated and anchored to resist flotation, collapse, or lateral movement and capable of resisting the hydrostatic and 11 hydrodynamic loads. Methods of anchoring may include, but are not limited to, use of over-the-top or frame ties connecting to permanent 12 ground anchors, in addition to any anchoring requirements for resisting 13 wind forces and any tie-down requirements of chapter 10-12, "Mobile Homes," B.R.C. 1981. Requirements shall include, without limitation, the 14 following: 15 (i) Over-the-top ties shall be provided at each of the four corners of the manufactured homes. For manufactured homes fifty feet or 16 longer, two additional ties per side are required at intermediate locations. For manufactured homes less than fifty feet long, one 1 additional tie per side is required; 18 (ii) Frame ties shall be provided at each of the four corners of the 19 manufactured homes. For manufactured homes fifty feet or longer, five additional ties per side are required at intenmediate points. For 20 manufactured homes less than fifty feet long, four additional ties per side are required; 21 (iii) All components of the anchoring system shall be capable of 22 carrying a force of four thousand eight hundred pounds; and 23 (iv) Any additions to manufactured homes shall be similarly anchored. 24 (3) Construction Materials and Methods: (A) All new construction, substantial improvements, and substantial 25 modifications shall be constructed with materials and utility equipment 26 resistant to flood damage as outlined in the most current FEMA Technical Document on 2 93. Flood-Resistant Materials Requirements. 27 (B) All new construction, substantial improvements, and substantial 28 modifications shall be constructed using methods and practices that minimize flood damage. 5 ATTACHMENT A Draft for WRAB 3-08-2013 1 (C) All new construction, substantial improvements and substantial modifications shall be constructed with electrical, heating, ventilation, 2 plumbing, and air conditioning equipment and other service facilities that 3 are designed and located (by elevating or floodproofing the components) so as to prevent water from entering or accumulating within the 4 components during flooding conditions. 5 (4) Utilities: 6 (A) All new and replacement water supply systems shall be designed to minimize or eliminate infiltration of floodwaters into the systems. 7 (B) All new and replacement sanitary sewage systems shall be designed to 8 minimize or eliminate infiltration of floodwaters into the systems and discharge from the systems into floodwaters. 9 (C) On-site waste disposal systems shall be located to avoid impairment or 10 contamination during flooding. 11 (5) Subdivision Proposals: (A) All subdivision proposals shall demonstrate efforts to minimize flood 12 damage. 13 (B) All subdivision proposals shall have public utilities and facilities such as sewer, gas, electrical, and water systems located and constructed to 14 minimize flood damage. 15 (C:) All subdivision proposals shall have adequate drainage provided to reduce 16 exposure to flood damage. (D) Base flood elevation data shall be provided for subdivision proposals and 17 other proposed development. 18 (E) No subdivision proposal shall create a lot which is unbuildable pursuant to this section. 19 (6) Pleedprne€iag: „ building st`• tetufe to b 20 flaedp`-ee f ,d the Fell",, ing star dafds shall be et. 21 22 floodpreefing promulgated by the eity manager pursuant to ehapter- 1 4, rB7 ~ CkiEh beil~ 7CIZT~CCfCr+tfueatur-e shall 0 1,4 .dprvvLfed CCa fl 7 e„tion ele""tie 2 L ~ TZlT1T- f7 SIDocL-s to ~CLIG tke rLV^v^crFrrvt~vvrtvn-vrcvuCrva 25 26 humaa 27 28 6 ATTACHMENT A Druft for WRAB 3-08-2013 1 2 B.R.G. 3 1-9g i . (_67) Hazardous Materials: No person shall store a hazardous substance at or below the 4 flood protection elevation for the area of the floodplain in which it is located, 5 except for the storage of fuelgfts&4ne in existing and replacement underground tanks in existing gaseliFi-efuelinu service stations and service garages, which tanks 6 are designed to prevent infiltration and discharge into floodwaters and which are adequately anchored and shielded against rupture. For purposes of this paragraph, 7 "existing" means in place and in use on January 1, 1989. 8 (1-) Automobile Parking: Notwithstanding other provisions of this title, no person shall establish an area for automobile parking in any portion of the floodplain 9 where flood depths exceed eighteen inches. 10 (W) Flood Warning System: No owner of a hotel, a motel, a dormitory, a rooming house, a hostel, a school, a bed and breakfast, a daycare center, a group home, or a I 1 residential or congregate care facility located in the Boulder Creek floodplain 12 shall fail to provide a flood warning system approved by the city manager that is connected to a point of central communication in the building with twenty--four- 13 hour monitoring. No such person shall fail to maintain such a flood warning 14 system. (94-0) Rental Property: No owner of property that is located in athe floodplain and 15 subject to a city rental license under chapter 10-3, "Rental Licenses," B.R.C. 1981, shall fail to post on the exterior of the premises at the entrance a sign 16 approved by the city manager stating that the property is subject to flood hazard 17 and containing such further information and posted at such other locations inside the building as the city manager may require. 18 (104-) Manufactured Housing: All manufactured homes placed in the city after July 1, 19 1989, and all manufactured homes which are substantially unproved or substantially modified shall be elevated on a permanent foundation so that the 20 lowest floor of the manufactured home is at or above the flood protection elevation and is securely anchored to an adequately anchored foundation system, 21 and shall meet the anchorage and tie-down requirements of paragraph (a)(2) of 22 this section. (11-2) Recreational Vehicles: in order to reduce debris and hazard potential, recreational 23 vehicles shall either: a) be in the floodplain for fewer than one hundred eighty 24 consecutive days, b) be fully licensed and ready for highway use, or c) meet the permit requirements and elevation and anchoring requirements for manufactured 25 homes. 26 (12-3) Structure Orientation: In order to minimize the obstruction to flow caused by buildings, to the extent consistent with other city policies regarding solar access, 27 new structures shall be placed with their longitudinal axes parallel to the predicted direction of flow of floodwaters or be placed so that their longitudinal axes are on 28 lines parallel to those of adjoining structures. 7 ATTACHMENT A Draft for WRAB 3-08-2013 1 (134) Existing Uses: The use of any land or structure that was lawful before the application of this section or any amendment thereto but that does not conform to 2 the requirements of this section may be continued subject to the requirements of 3 this section. If such a use not conforming to the requirements of this section is discontinued for twelve consecutive months, no person shall use the land or 4 structure thereafter unless such use conforms to the requirements of this section. 5 (14-5) New Uses: All uses allowed by the underlying zoning district may be established, subject to the requirements of this section, except for the outdoor or uncontained 6 storage of moveable objects below the flood protection elevation. 7 (156) Existing Structures: Any structure in existence before the enactment of this section or any amendment thereto that does not conform to the requirements of 8 this section may remain or may undergo rehabilitation subject to the requirements 9 of this section. Further, any such structure may be otherwise improved as follows: (A) Any person making an expansion or an enlargement to an existing 10 residential structure shall elevate the lowest floor, including the basement, of the expanded or enlarged portion to or above the flood protection 11 elevation. 12 (B) Any person making an expansion or an enlargement to an existing nonresidential structure shall floodproof or elevate the lowest floor, 1' including the basement, of the expanded or enlarged portion to or above 14 the flood protection elevation. 15 (C) Any person making a substantial modification or a substantial improvement to any existing nonresidential structure shall floodproof or 16 elevate the lowest floor, including the basement, of the substantially modified or improved portion to or above the flood protection elevation 17 and shall floodproof the remainder of the existing structure. 18 (D) Any person making a substantial modification or a substantial improvement to any existing residential structure shall elevate the lowest 19 floor, including the basement, of the entire residential structure to or above 20 the flood protection elevation. (1 Cry) New Structures: Construction of new structures shall meet the following 21 requirements: 22 (A) Any person constructing a new residential structure shall elevate the lowest floor, including the basement, to or above the flood protection 23 elevation; 24 (B) Any person constructing a new nonresidential structure shall floodproof in a manner requiring no human intervention or elevate the lowest floor, 25 including the basement, to or above the flood protection elevation with the 26 following exceptions: 27 (i) Open air carwashes; (ii) Unheated pavilions; 28 (iii) Unfinished or flood resistant building entryways or access areas; 8 ATTACHMENT A Draft for WRAB 3-08-2013 1 (iv) Garden storage sheds; 2 (v) Sidewalks, paving, or asphalt, concrete, or stone flatwork; 3 (vi) Fences; and (vii) Poles, lines, cables, or other transmission or distribution facilities 4 of public utilities. 5 (C) Any person constructing a new structure on a property removed from the one hundred-year floodplain through a FEMA Letter of Map Revision 6 Based on Fill (LOMR-F) shall protect the lowest floor, including the 7 basement, to or above the flood protection elevation that existed before placement of fill, as follows: 8 9 (i) Residential structures: by elevating the structure; or 10 11 (ii) Non-residential structures: by elevating or floodproofing the structure. 12 13 Solely for the purposes of this subparagraph (a)(1 7)(C), previously designated floodplain areas that have been removed from the one hundred- 14 year floodplain through a LOMR-F shall be considered to be within the 15 floodplain. No person shall construct a new structure subject to this subparagraph (a)(1 7)(C) prior to the issuance of a floodplain development 16 permit pursuant to section 9-3-6, "Floodplain Development Permits," B.R.C. 1981. 17 (17-9) Enclosures: Enclosures below the lowest floor that are unfinished or flood 18 resistant, usable solely for parking of vehicles, crawl spaces, building access or storage, in an area that is not a basement, and that are not floodproofed as set forth 19 in this section shall meet the following requirements: 20 (A) Compliance with the provisions of paragraphs (a)(2), (a)(3), and (a)(4) of this section; and 21 (B) Design and construction that automatically equalizes hydrostatic flood 22 forces on exterior walls by allowing for the entry and exit of floodwaters. 23 (i) Designs for meeting this requirement shall meet or exceed the following minimum criteria: a minimum of two openings having a 24 total net area of not less than one square inch for every square foot 25 of enclosed area subject to flooding shall be provided. The bottom of all openings shall be no higher than one foot above grade. 26 Openings may be equipped with screens, louvers, valves, or other coverings or devices provided that they pen-nit the automatic entry 27 and exit of floodwaters. 28 9 ATTACHMENT A Draft for WRAB 3-08-2013 1 (ii) Any designs not in conformance with subparagraph (a)(18)(B)(i) of this section, shall be sealed and certified by a registered 2 professional engineer or licensed architect and shall conform with 3 the most currentFEMA Technical Bulletin on4-9-3; Openings In Foundation Walls. 4 (C) Fully enclosed areas below the lowest floor subject to this provision, 5 include the following: 6 (i) Residential garages placed at or above grade; (ii) Enclosures or vestibules that are attached to structures and that are 7 utilized for storage or entryways; (iii) Crawl spaces; and 8 (iii) Outdoor pavilions and patio enclosures with removable walls not 9 located in the high hazard zone. 10 (189) Below Grade Crawl Space Construction: New construction, expansion or enlargement, substantial improvement and substantial modification of any below 11 grade crawl space shall meet the following requirements: 12 (A) Interior grade elevation that is below the base flood elevation shall be no lower than two feet below the lowest adjacent grade; 13 (B) The height of the below grade crawl space measured from the interior 14 grade of the crawl space to the top of the foundation wall shall not exceed 15 four feet at any point; (C) Adequate drainage systems shall allow floodwaters to drain from the 16 interior area of the crawl space following a flood; and 17 (D) The provisions of paragraphs (a)(2), (a)(3), (a)(4) and (a)(197) of this section shall be complied with. 18 Section 3. Section 9-3-4, B.R.C. 1981 is amended to read: 19 20 9-3-4 Regulations Governing the Conveyance Zone. 21 In the conveyance zone, the following standards apply: 22 (a) The provisions of section 9-3-3, "Regulations Governing the Floodplain," B.R.C. 1981. 23 (b) The provisions of section 9-3-5, "Regulations Governing the High Hazard Zone," B.R.C. 1981, if the land is also located in the high hazard zone. 24 (c) All uses allowed under the provisions of section 9-3-3, "Regulations Governing the 25 Floodplain," B.R.C. 1981, if they are not prohibited by the underlying zoning district or any ordinance of this city, may be established except that no person shall establish or 26 change any use that results in a rise in the elevation of the one hundred-year flood. 27 (d) All structures allowed under section 9-3-3, "Regulations Governing the Floodplain," B.R.C. 1981, may be established except that no person shall: 28 10 ATTACHMENT A Draft for WJUB 3-08-2013 1 (1) Place any structure in the conveyance zone that will result in any rise in the 2 elevation of the one hundred-year flood; or (2) Place any obstruction in the conveyance zone, except a device reasonably 3 necessary for flood management if the device is designed and constructed to 4 minimize the potential hazards to life and property. (e) No person shall carry out any other development that results in a rise in the elevation of 5 the one hundred-year flood. 6 (f) Localized rises within flood channels or on a specific parcel that is being developed are permissible, if there is no adverse impact on nearby properties and there is no increase in 7 the average water surface elevations along the cross sections of the floodplain. 8 (g) Localized rises on land owned or controlled by a government, or governmental subdivision or agency or within public drainage or flood control easements are 9 permissible, if the following requirements have been satisfied: 10 (1) The applicant has necessary property interests or permission to use land to allow 11 the increase in any water surface elevation or there is no adverse impact to such land; 12 (2) There are no insurable structures under the FEMA National Flood Insurance 13 Program affected by the localized rise; (3) The applicant minimizes the amount of the localized rise in a flood elevation; and 14 (4) The applicant complies with all necessary FEMA requirements, including without 15 limitation, obtaining a Conditional Letter of Map Revision (CLOMR) prior to development and a Letter of Map Revision (LOMR) upon completion of a project 16 causing a localized rise in a flood elevation. 17 Section 4. Section 9-3-5, B.R.C. 1981 is amended to read: 18 9-3-5 Regulations Governing the High Hazard Zone. 19 In the high hazard zone of the floodplain, the following standards apply: 20 21 (a) The provisions of section 9-3-3, "Regulations Governing The Floodplain," B.R.C. 1981. (b) The provisions of section 9-3-4, "Regulations Governing The Conveyance Zone," B.R.C. 22 1981, if the land is also located in the conveyance zone. 23 (c) All uses allowed under the provisions of section 9-3-3, "Regulations Governing The Floodplain," S.R.C. 1981, 'if they are not prohibited by the underlying zoning district or 24 any other ordinance of the city, may be established, except that no person shall: 25 (1) Change the use of an existing structure intended for human occupancy from a nonresidential use to a residential use or use as a school, daycare center, group 26 home, residential care facility, or congregate care facility. 27 (2) Establish any new parking lot for motor vehicles. 28 (3) Establish any campground. 11 ATTACHMENT A Draft.for WRAB 3-08-2013 1 (d) All structures allowed under the provisions of section 9-3-3, "Regulations Governing The 2 Floodplain," B.R.C. 1981, may be established, except that no person shall: (1) Construct or place any new structure intended for human occupancy. 3 (2) Expand, enlarge, or make a substantial modification or substantial improvement 4 to any existing structure intended for human occupancy. Notwithstanding this provision, a person may reconstruct a non-flood-damaged structure or portion 5 thereof, which otherwise does constitute a substantial improvement, under the 6 provisions of subparagraphs 9-3-3(a)(165)(C) and (a)(1650), B.R.C. 1981. (c) Unconditioned, unenclosed building elements such as balconies, awnings, and roof 7 overhangs may extend up to four feet into the high hazard zone if completely located 8 above the flood protection elevation and the remainder of the structure complies with this chapter. 9 10 Section 5. Section 9-3-6, B.R.C. 1981 is amended to read: 11 9-3-6 Floodplain Development Permits. 12 (a) Activities Exempt from a Floodplain Development Permit' The following activities are 13 allowed within the flood regulatory areas and O-Q of regUire a floodplain develornnent 14 et~nit: 15 (1) "Maintenance" as defined in chapter 9-16. "Definitions." B.R.C. 1981 that do not constitute a substantial i nravenient or a modifcation to an existing hazardous 16 material facility that exceeds 25_t}ercent market value of the existing structure 17 before the start of construction, and tl-at do not affect the efficiency or capacity of the conveyance zone or high hazard zone. 18 (2) Sidewalks concrete asphalt or stone flaLwork that does not result in the 19 establishment or exnansion of narking areas and does_ im modiry existing grade 20 by more than six inches. 21 (3) Underground utilities that do not modify existing grade. 22 (4) Poles. lines, cables, sign hosts, landscaping and artwork that do not affect the efficiencopity of the conveyance zone or hig23 h hzard zone. 24 5 Tcm 3or r f •li • s that are not 1ernlane attached to the round such as tents traffic control devices and lawn furniture provided that they will not affect the 25 efficiency or capacity of the conveyance zone or hig11 hazard xane or the Na ill 26 remain in place for no more than 30 days. 27 An applicant for a floodplain development permit shall pay the fee prescribed by section 28 4-20-44, "Floodplain Development Permits And Flood Control Variance Fees," B.R.C. 12 ATTACHMENT A Draft fbr WRAB 3-08-2013 1 1981, and shall complete an application form provided by the city manager that shall 2 include, without limitation, the following: (1) The written consent of the owners of all property subject to the development 3 request; 4 (2) A written statement addressing the criteria for approval; 5 (3) ground; A sur-faee view plan showing elevations and eonteufs of the pertinent st++ietufes, fill, and stafage elevations; sizes, loeations, and spatial aFrangements 6 of & 8pesed, antieipated, and existing std etures en the site; 1 ate and elevations of stFeets, water supplies and sanitafy faeilities5 and soil typew,--and 7 n a licant for a critical facility Pursuant to section 9-9-23, "Regulatio 1 8 Governin Critical Facilities and Lod ,ina Facilities," B.R.C. 1981 _shall indicate whether the facility will contain hazardous material. If the facility will contain 9 hazardous material, the application must include information on the location of 10 the hazardous material and how the hazardous material will be secured to prevent its release during a five hundred-year flood event. 11 L Piling, 12 ehanne! impr-ovementS -A.4- ehffifl.ges, storage of materials, water > sanitafy ies. An applicant for a critical facility or lodging facility in the live 13 hundr -year floodplain pursuant to section 9-9-23. "Regulations GoveMin~* 14 Critical Facilities and Lodging Facilities." B.R.C. 1981, shall provide a ccppy o (lie emergency management plan for the_f_a_cility meeting the requirements of 15 ection 9-9-23ld1. 16 (Qb) The manager may require the applicant to furnish additional information and details deemed necessary to evaluate the effects of the proposed construction upon the 17 floodplain, including, without limitation: 18 (1) A surface view p!-an showing, elevation, and contours of the groucld: pertinent structures, 1.111, and storage elevations; sizes, locations, and spatial arrangements 19 of all proposed. anticipated, and existing structures on the site: location and elevations of streets water supplies and sanitar facilities; and soil t pesi and 20 121 Specifications for proposed building construction and materials. filling,. dredgii 21 +rading, channel improvements and changes storage of materials %Naler supply, 22 and sanitary facilities. L3 (4) Valley cross sections showing the floodplain surrounding the watercourse, cross 23 sections of the area to be occupied by the proposed development, and one hundred-year flood maximum water surface elevation inforn-lation; and for critical 24 facilities and lod+unng facilities. the live hundred-year maximum water surface 25 elevation _infonnation_pursuant to section 9-9-23, "R~ul~~ic?n_s_Gcrvern n~Critic~_rl Facilities and Lodging Facilities," B.R.C. 1981; 26 (42) A profile showing the slope of the bottom of the channel or thalweg of the 27 watercourse; 28 L3) A floodplain analysis by a Colorado registered professional engineer of the flood profile, elevation, and velocity, using methodology acceptable to FEMA, 13 ATTACHMENT A Draft for WRAB 3-08-2013 1 including existing and anticipated uses and making a determination that the proposed construction or development will not cause a rise in the elevation of the 2 water surface of a one hundred-year flood; 3 (-64) A structural analysis by a Colorado registered professional engineer showing that 4 any proposed structures will be adequately designed and constructed to prevent flotation, collapse, or lateral movement of the structure resulting from 5 hydrodynamic and hydrostatic loads, including the effects of buoyancy and scouring. 6 (de) When reviewing an application fora permit the city manager shall determine which - 7 portion or portions of the floodplain are affected by the particular development request and shall then apply the provisions of sections 9-3-2, "Floodnlains." 9-3-3, "Regulations 8 Governing The Floodplain," 9-3-4, "Regulations Governing the Conveyance Zone," and 9 9-3-5, "Regulations Governing the High Hazard Zone," and 9-9-23. "Regulations Governing Critical Facilities and Lodging Facilities." B.R.C. 1981, as applicable. The 10 manager also shall detennine whether the application ineets the intent of this chapter prescribed by subsection 9-3-2(a', B ~784-, and the intent of section 9-9-23 as ll prescribed _by subsection 9-9-23(a), B.R.C. 1981, after considering the following factors: 12 (1) The effects upon the efficiency or capacity of the conveyance zone and high hazard zone; 13 (2) The effects upon lands upstream, downstream, and in the immediate vicinity; 14 (3) The effects upon the one hundred-year flood profile; 15 (4) The effects upon any tributaries to the main stream, drainage ditches, and any 16 other drainage facilities or systems; (5) Whether additional public expenditures for flood protection or prevention will be 17 required; 18 (6) Whether the proposed use is for human occupancy; 19 (7) The potential danger to persons upstream, downstream, and in the immediate vicinity; 20 (8) Whether any proposed changes in a watercourse will have an adverse 21 environmental effect on the watercourse, including, without limitation, stream banks and streamside trees and vegetation; 22 (9) Whether any proposed water supply and sanitation systems and other utility 23 systems can prevent disease, contamination, and unsanitary or hazardous conditions during a flood; 24 (10) Whether any proposed facility and its contents will be susceptible to flood 25 damage and the effect of such damage; 26 (11) The relationship of the proposed development to the Boulder Valley Comprehensive Plan and any applicable floodplain management programs; 27 (12) Whether sai'e access is available to the property in times of flood for ordinary and 28 emergency vehicles; 14 ATTACHMENT A Draft for WR4B 3-08-2013 1 (13) Whether the applicant will provide flood warning systems to notify floodplain 2 occupants of impending floods; (14) Whether the cumulative effect of the proposed development with other existing 3 and anticipated uses will increase flood heights; and 4 (15) Whether the expected heights, velocities, duration, rate of rise, and sediment transport of the floodwaters expected at the site will adversely affect the 5 development or surrounding property. 6 (9d) If the city manager determines that the applicant meets the purposes and requirements of this chapter, the manager shall issue the permit and may attach such conditions as 7 deemed necessary to further the purposes of this chapter. 8 (fe) A permit issued on or after April 7, 1985, expires three years after its date of issuance, if the peimittee has not commenced construction under the permit. The term "commenced 9 construction" shall mean the first placement of permanent construction of a structure on a 10 site, such as the pouring of slabs or footings, the installation of piles, the construction of columns, or any work beyond the stage of excavation; or the placement of a 11 manufactured home on a foundation; but does not include land preparation, grading and 12 filling, or installation of streets or sidewalks. (g#) No person who has obtained a permit shall fail to construct in accordance with their 13 approved application and design. 14 (hg) Floodplain development permits that allow for development in the conveyance zone or the high hazard zone, or which will involve a change of watercourse, shall be decided by 15 the city manager. The decision of the city manager shall be subject to call-up by the 16 planning board, or appeal by any aggrieved party to the planning board, subject to the call-up and appeal procedure of section 9-4-4, "Appeals, Call-Ups And Public Hearings," 17 B.R.C. 1981. 18 (i#) A floodplain development permit for any of the following items is effective upon the date of its issuance: 19 (1) Sidewalks, parking lots, or other concrete, asphalt, or stone flatwork that do not 20 modify existing grade; (2) Uninhabited overhead structural projections, no portion of which extends below 21 the flood protection elevation; or 22 (3) Rehabilitation of an existing structure in accordance with the definitions in 23 chapter 9-16, "Definitions," B.R.C. 1981. In addition, for properties in the high hazard zone, the rehabilitation shall not result in a prohibited change in use as set 24 forth in subsection 9-3-5(c), B.R.C. 1981. 25 (j}) No person shall initiate any use after obtaining a permit under this section without first submitting to the city manager a sealed certification by a Colorado registered professional 26 engineer that the development has been completed in compliance with the approved permit application and that all conditions have been fulfilled. 27 28 15 ATTACHMENT A Draft for WRAB 3-08-2013 1 (k) Flooclplain L?eveloni~t4rlt Permit Restu_ i ctnents for Critical Facilities Protected by Levee Svstems. 2 111 An al2plicant for a floodnlain development permit for a critical facility pr tecte 3 b . a levee system shall vay the fee prescribed b , s tion 4-20-44, "Floodnl 4 Development Permits and Flood Control Variance Fees."_B.R.C. 1981, and shall C In- Cte ',111_3126i cattorl form provided by thSL.Ctty f11EUlaaer that shall include- 5 without limitation, the following: 6 A written statement clcmonstrating cornpliance with subsection 9-9-23(x, scaled and certif ed by a Coloradg-re stored professional engineer; and 7 Ai, additional information and details deemed necessary_f~y_t-he city 8 manager to evaluate the permit application, 9 Q The city nlarla er shall evaluate a fl odpl_ain develoninent nemait ap_p icati itt for a 10 critical facility _ra ected by a Iwee s stem_ ui suant tom- the re uir meats in this subs, (k) and subsection 9-9-23(f), "Critical Facilities Protected by Levee 11 Systems," B.R.C. 1981. 12 C3) A fl adplain development tzernlit for a critical facility rotectell by a levee system 13 hall e iss c~nl u~c~n a f rdin by the city manager that, based on~1 Coic}rado registered professionpi engincer's sealed c.crtilicati-on, the levee system is in 14 con 4iiance with the requirements of subsection 9-9- "Critical Facilities Protected by Levee Systems" B.R.C. 1981. 15 16 141 A flood-ain development permit issue for a critical facilitytrrotected y a levee system is not subiect to the call-up and appeal pm;rdui•es set forth in subsection 17 9-3-6 h 185 least once ever three years. 1 wiier or operator p lie critical facil't 19 nrotec:ted by a levee systcili shall tiler with the city manager a determination Pram the annropria -e federal or- Stale agency, pr a sealed and certified drier ninia 20 from a Colorado registered I3t'ufessional err;;ineer. that the levee system nice is the minimum freeboard eritcria as set forth in subsection 9-9-2,3 and appe - - n 21 visual inspection, to be structurally sound and deQUately rllaintainCCl The city 22 manager may require the owner or operator to-submit _such_cer-tification more frectuently than once every three years if wazm'anted by recent flood conditions or 23 ircumstances that may lead to changes in the levee svstem at the critical facility 24 The permit shall lapse if the required determination is not filed - - 25 (-1-~(~ C?nce a floc}clnlain dcvelQ~i~ent_perrllit has been issued felt a critical facility protec ipd I.~y a levee system, fitture development on the land protected by the 26 cvice sstenl shall not require a floodplain gv Ql fitment permit so long as the reguirenicnts of this subsection (k) and subsection 9-9-23(f) are satisfied. 27 28 16 ATTACHMENT A Draft for WRAB 3-08-2013 1 Section 6. Section 9-3-6, B.R.C. 1981 is amended to add a new section 9-3-6.5, B.R.C. 1981 to read: 2 3 9-3-6.5 Floodaroofing Standards. 4 (a)_= _Eloa~ iv~ofin Wl~cncvcr this_cliat~tGr or_ se,ction_9-9-23. "Rogulations G_o}T -1riny Critical Facilities and Luduiiw Facilities.- B.R_C l9 j- , Muire loodpi, tins a building of 5 structure, the following standards shall apply: 6 I11 F•loodnroofing shall comply with any rules prescribed by the city manager 1'611 fIo_Q ldpro(>fin_ and current FNMA National Flood Insurance Pro ram (NFII'). 7 Technical Bulletins: 8 0 The manner of lloodpr ofint; shall, without requiring any human intervention, make the building or structure watertight to the flood protection elevation. with 9 walls substantially impermeable to the passage of water, 10 ( The building or structurashall have _structural cczr?in vents c le of resisting projected hydrostatic and hydrodynamic loads and the effects ofbuoyancy; and 11 (4J The applicant Shall provide a sealed ccrtificatigit in a foun acce)a lc t ~ the cit 12 manager from a Colorado rc~isteiw(L -ofessional engineer or licensed architect ertif ing that the floodprooiing measures comply witith this chanter or section 9- 13 9-23, as applicable. 14 15 Section 7. Section 9-3-7, B.R.C. 1981 is amended to read: 16 9-3-7 Variances. (a) A person wishing to develop, in a manne -ex-pa a enlarge ^ existing stmel r-e that does 17 not conform to the requirements of this chapter and cannot be made to conform without 18 unreasonable expense or unreasonable impact on the existing structure may apply to the city manager for a variance from the requirements of subparagraphs 9-3-3(a)(156)(C) and 19 (a)(15b)(D), B.R.C. 1981, except that no variance shall be granted for expansion or 20 enlargement of any structure constructed after July 12, 1978, unless such expansion or enlargement conforms to the flood protection elevation requirement in effect at the time 21 of the original construction. 22 (b) The city manager shall not grant a variance under this section unless the manager determines that: 23 (1) Considering the flood hazard, the variance is the minimum necessary to afford 24 relief; 25 (2) To do so would not result in additional threats to public safety, extraordinary public expense, nuisance, fraud, victimization of the public, or for variances in the 26 conveyance zone a rise in the elevation of the water surface of a one hundred-year flood, or be in conflict with existing provisions of this code or any ordinance of 27 the city; and 28 (3) Failure to grant the variance would result in exceptional hardship to the applicant. 17 ATTACHMENT A Draft for- WRAB 3-08-2013 1 (c) The manager shall examine the following factors in determining whether or not to grant a variance under this section: 2 (1) The danger to life and property due to flooding or erosion damage; 3 (2) The likelihood that the proposed development, in conjunction with existing and 4 anticipated development, may increase flood hazards; 5 (3) The relationship of the proposed development to the Boulder Valley Comprehensive Plan and any applicable floodplain management programs; and 6 (4) The cost of providing essential services such as maintaining and protecting public 7 utility systems, roads, and bridges during and after floods. 8 (d) The city manager shall not grant a cumulative total of variances that increases a structure's floor area by more than ten percent of the structure throughout the life of the 9 structure. 10 (e) An applicant for a variance shall apply on forms provided by the city manager and pay the fee prescribed by section 4-20-44, "Floodplain Development Permits And Flood 11 Control Variance Fees," B.R.C. 1981, unless a floodplain development permit is required as well, in which case no fee is required for the variance. 12 (f) Any decision by the city manager to approve a variance is subject to call-up by the 13 planning board or appeal by any aggrieved party to the planning board as described by 14 section 9-4-4, "Appeals, Call-Ups And Public Hearings," B.R.C. 1981. (g) When granting any variance that allows for construction below FEMA's one hundred- 15 year flood protection elevation, the city manager shall provide to the recipient of the variance written notice that the proposed construction does not conform with FEMA 16 guidelines and that the proposed construction and the original structure may be subject to 17 increased flood insurance premiums. 18 19 Section 8. Chapter 9-9, B.R.C. 1981 is hereby amended to add a new section 9-9-23 to read: 20 21 9-9-23 Regulations Governing Critical Facilities and Lodging Facilitie 22 (a) Purpose- The purpose of thissection is to regulate the dcvelop1 a of critical facilities the five hundred-year Host)lain in order to minimize the I rds to public health and 23 safety and the interruption of essential services and o pet rati )ns for the cC111l.munity at any time before. dur_in after a flood; and to require the development of emer~,y 24 rnana-,YgI t plans for Al critical facilities and lodgin facilities in order to pronuMe all 25 effective an lrg pia Alo- co 1 -opsim- , 26 Scope and Ap lica i n: (1) he following development standards apply to cri&al f i jAJ . nd Iods?in~ 27 facilities located within the five hundred-year flood It~as shown on the most 28 recent maps ad t I by the city council, as amended from time to time by the city manager pursuant to subsections (d). (e) and (fl of section 9-3-2. "Floodplains." 18 ATTACHMENT A Draft for WRAB 3-08-2013 1 B.R.C. 1981 if any portion of a structure lies partly within the five hundred-year jl L(L d 11a .rl, all the requirements of this section shall apply to the entire strac 2 tui - (2) The standards gg ernii)u the deveig ment of critical facilities aaidb_cl,iU 3 facilities in this section are in addition to the floodnlain regulations of sections 9- 4 3-3_, "Regulations Governing tllc_FlocLd -loin," 9-3-4, ' Regulati€s Qi vernin t_lic Conveyance Zone." and 9-3-55. "ReYulations Governing the High Hazard Zone." 5 B.R.C. 1981 _ fthe critical facility or lodging facility is also located in the one hundred-year tlc~odplain. the high hazard zone or the canvevaig e '/.one 6 (3) The city manager shall administer the requirements of this section and may adopt 7 rules interpreting and imp nenting the requirements of this section, and shall make necessary interpretations of the exact location of the boundaries of the five 8 hundred-year floodnlain. 9 (4) Where the water surface elevation of the five hundred-year flood has notbeen established or is determined 4iy the city maiia Ter 1 e ins;onsistent with other 10 available-topographic or hydraulic data, the city manager nay establish a flood 11 rot 'ti n e1gyation baud on data- sources desciibed in suhsec 9- -2 (5) Existing Uses: The use of any land or stiucture that was lawful before the 12 application of this section or any amendment thereto but that does not conform Io 13 the rcctuirements o( this section may be continued_sul~teet to tlle_requrements of this section. If such a Use not conforming to the requirements of this section is 14 discontinued for 12 consecutive months, no person shall use the land or structure 15 thereafter unless such use conforms to the requirements of this section. (c).~Flc~odpla n_Dev_elopmcnt Permit Required. Except as specified in subsection 9-3-6 a" 16 "Activities Exempt From a Floodplain Development Permit," B.R.C. 1981, tlo 17 development of a critical facility orlociging facility_in_the five hu n. "d_ye-(vr Q("d lain may occLn• prior to the issuance of a floodnlain development permit pursuant to section 9- 18 3-6, "Floodplain Development Permits." B.R.C,191. 19 (d) Ei ergency Management Flan Required. Owners or operators of a critical facitity or lode facil_i_t rwitlricthe_fivc_l?unclrcd-ycaz flocuclpla_i_n shall develop an_eniuraenc 20 management plan meeting the requirements of this section by January 1, 2023. 21 fD Emer_€ nc mane ement plans shall include either an evacuatio~lati-ar a shelter - in place plan. 22 (A) Evacuation plans shall be sealed and certified by a Colorado registered 23 professional engineer or 1 ieensed architect. and shall provide a means for safely cvacuat n_ occui-t,ts to a location ~ i icic f_tlae f _c bundre d-ye 24 fl lain. 25 Shietter in pl~ac&plans _shall be sealed attd cer ifiecl_t~y_a_Caloracio registered professional engineer and shall demonstrate that the structure 26 will be safe to occupy during a five hundred-year flood event. 27 Emergency management plans shall be oste can thtinside of eaclt~l c 1 ax l e a d i n g , to a Separate unit in a lodging facility and displayed in a comment 28 19 ATTACHMENT A Draft for WRAB 3-08-2013 1 location or a location desi_;tle ci tQ-v_icie information to_persons within the 2 critical facility that is approved by the city manager.- Q Emergency mariai~cn-cnt_plans shall be completed nric~r to issuance of a 3 floodylain development Dermit. 4 Dee Construction Rectuirements for Critical Facilities in the Five Hundred-Year Floodplain. The followinh requirements al21Zy to critical facilities Ioeatc wi h In the five hunched- 5 ear- flaml. Main. The flood roofi a standard- a j )licable to this subsecti n e rc set 6 folrth in section 9-3-6.5, "Flo )dprooling Standards " B.R C 1981 W No owner or operator of a critical facility shall construct or modify, or cause to be 7 COIISt1•tletgd or nlodnccd, a critical facility within the five hundred-year goodnlain 8 except in compliance with the requirements of this section- Any person making, an expansion or an enlargement to an cxistinu at-risk 9 lionulation facility or essential service facility shall floodnroofor elevate the 10 lowest floor, including the basement of the expanded or enlarged portion to or above the flood protection elevation: 11 Any pet:scan making a substantial mozlificatr_Qn or a_substant zI inrprovelrrent to 12 any existing at-risk population Facility or essential service facility sllall floodpl'tlOf or-Ocvate the lowest floor- including tile- basement of the strbstantially modified 13 or irnproved portion to or above the flood protection elevation and shall floodproof or elevate the remainder of the existing, structure to or above the GQW 14 protection elevation; 15 (41 Any person constructing, a new at-risk population facility or essential service 16 facility shall floodnroofor elevate the lowest floor, including the basement to or above the flood protection elevation, 17 Iti7I'S©17 COI1Str'UCltttg,_a new hazardous material Facility shall secure all 18 hazardous materials firm flooding, and Isom being, r'elcased during, a five hundred- year flood event or shall 11 od roof the facility. An person making, a 19 deyelori ent to an existing hazardous material facility that requires a flop Inlain develppincntparillit_sh<ill secure all hazardous materials from flog lin , and from 20 bbein{~ released during _a fiv h r die -year flood event in the structure or• portion 21 of the faculty being modified or sha_II flQodproof the structure ot_p~rtiQn ft he facility being, modified, 22 "A The owner or ctt~ctatol of.tlic_.hazardous material.-facility shall demonstrate 23 compliance with this standard by-j•oviding, a scaled certification •o Colorado royistcrodj roFe~l engineer d~curnenting, that due tc~_the 24 flood threat and hazardous mat rial storag,e conditions. hazardous material will not be released at or from the facility during a five hundred-year flood 25 event. 26 No person owning o Grating, or otherwise us_ine, a ha-z_ar ous material l-a-'Jility shall fail to brine tlic entir cility into compliance with Iis 27 subsection (5) by Januai 1, 2023. 28 20 r ATTACHMENT A Draft for WR B 3-08-2013 1 (L ri ij~a]-Facilities Protected ly Levee Systems. Critical facilities protected by Icvcc_ stems within the fin hundred-year flo.~~dt)lain are exer.ll~t f-i~?1]-I the rcgiLlaw nts f 2 subsections (d),-ancl-(e) of this section 9-9-23_p -ovided_that the following i'ecttI rements 3 are satisfied: 4 Elnnd.l~laitt_De~~clc~pinent_Permit Rg- jrei J~9o..~ n shall constrLICI or use a new or existing critical facility !)rotected by a levee system under this subsection 5 9-9 23(,O- prior tg thc, issuance of_a_floodL iin develot'melt G~ei mit_pursuant to section 9-3-6(k) "Flc~o(IIIlain__eve~»z ent Permit Rectuiren-lents ft~r Crideal_ 6 Facilities Protected by Levee Systems," B.R.C. 1981. 7 (22) The owner or operator of a new or existing critical facility located landward of a levee svsteillyQuts de the one hundred-ycar_il-ooid -lain but within the f ive 8 hundred-year floodplain, shall demonstrate that the levee system provides 9 t)rc►tecti9ntin_st,_a_vc hundred-yeti _ food event by meeting the foli_owin requirements: 10 A Deshui criteria consistent with 44 CFR § 65. 10. except that the minimum I l riverine levee freeboard criterion shall be one foot above the water surface elevation of a five hundred-year flood, rather than three: and 12 " C_)neration and maintenance standards (including Gul operating wid 13 ni inlenance manual and periodic fn - a4t-d_and_visual inspections that ensure continuing proper function of the levee system, consistent wi 1 plains 14 Rule 10 of the Colorado Rules and Regulations for Regulatory Fl=ood in Colorado. (2 CCR 408-1:10, Criteria for Determining Effects _or Levees 15 on Regulatory Floodplains). 16 S31 The owner or operator of a new or existing critical facility located landward of an accredited levee or ajmiyisittnally , Lgciited levee within areas manned Zone X 17 sl)adedl shall den)onsit' to that the Ieve s stem meets the design criteria of 44 18 CFR §5._1.0 and Rule 1.0 of the Col_orado_Rules and Regulations for_Rcgulatc~ry Floodplains in Colorado (2 CCR 408-1:10, Criteria for Determining. Effects d 19 Levees on Regulatory Floodplainsl. 20 44 The owner or operator of a critical facility must secure an agreement, meeting the requLrnetrts of_suhpaiaral)hs_9-9-23(f)(2) atul(3) _as altplicahle, with the levee 21 owner and/or operator for continued operation and maintenance of the levee 22 system in order to lie recogni-r_ecl as protecLed by a levee system. If l -v s st a c t' U a i cr` ` facilit ails t meet the freeboard 23 criterion of subparagraph _(fj(2)-(A) of this section because FEMA revises a FIRM, 24 construction and use of that critical facility may occur for two vears after the revisio11 but cgnl"%jii_I-e the hQytg, _o-yvner r tor actively and diligently purstu;s levec improvements to comply with this subsection (1). The requirements of section 9-3-3 will apply in the one hundred-year floodplain. 26 27 28 21 ATTACHMENT A Draft for WRAB 3-08-2013 1 Section 3. Section 9-16-1, B.R.C. 1981 is amended to read: 2 3 9-16-1 General Definitions. 4 (a) The definitions contained in chapter 1-2, "Definitions," B.R.C. 1981, apply to this title unless a tern is defined differently in this chapter. 5 (b) Terms identified with the references shown below after the definition are limited to those 6 specific sections or chapters of this title: 7 (1) Airport influence zone (AIZ). 8 (2) Fooodplain regulations (Fooodplain). g (3) Historic preservation (Historic). 10 (4) Inclusionary housing (Inclusionary Housing). 11 (5) Residential growth management system (RGMS). 12 (6) Solar access (Solar). 13 (7) Wetlands Protection (Wetlands). 14 (8) Signs (Signs). 15 9) Critical Facilities and Lodging Facilities (Critical Facilities). 16 (c) The following terms as used in this title have the following meanings unless the context 17 clearly indicates otherwise: 18 19 "Accredited ]-levee orprovisionaIly accredited levee" means a S l%_~m ofartificial 20 embankment(s) or flood control structure s) used for nroncrty protection, flood eQntrol and flood 21 hazard miti-gation accredited or nrovisianally accredited and mapped Zone X (shaded) by tile Fe til Emergency Mana ement Agency (FEMAI under the National Flood Insurance Proaran 22 (NFIP). (Floodplain and Critical Facilities) 23 24 "Area of special flood hazard" means the land in the floodplain subject to a one percent or greater chance of flooding in any given year, Such areas may be designated as Zones A, AO, 25 AH, AE and Al-30 on the FIRM for the City of Boulder. (Floodplain) 26 "At-risk tiot?ttladu facility" means a pre-school, 12ublic or private nri ry or Secondary school. 27 use and after school care center with twelve or more su - ;daycare center with twelve or more children group me or assisted 'esid ntial or con re ate care fac' ' v with twelve 28 22 ATTACHMENT A Draft far WRAB 3-08-2013 1 or more residents. At-risk population facility is also included in the definition of "critical 2 facility." (Floodplain and Critical Facilities) 3 4 "Base flood elevation" is the cott~nuted elevac~nLto which floodwater isAnti(ii7{ed to ri., during the one hundred-year flood. (Floodplain) 5 "Basement" means any enclosed area of a building having its lowest floor a minimum of two feet 6 below grade level on all sides. (Floodplain and Critical Facilities) 7 8 "Change in a watercourse" means any change in an existing thalweg, bed, or bank of a 9 watercourse. (Floodplain) 10 11 "Conveyance zone" means those portions of the floodplain required for the passage or 12 conveyance of the one hundred-year flood. The conveyance zone is delineated based on an equal encroachment methodology (measured in volume of water), which is applied to the floodplain 13 from the edges of the flood channel to a point where the one hundred-year flood profile will be 14 raised no more than six inches, after considering a reasonable expectation of blockage at bridges and other obstructions by flood borne debris. The city may, in its discretion, delineate the 15 conveyance zone on city owned land or right of way based on unequal encroachment to 16 minimize delineation on other properties. The conveyance zone is equivalent to a floodway delineation based on a six inch rise. (Floodplain and Critical Facilities};tCrl 17 18 19 20 "Crawl space" means the enclosed area contained inside the foundation walls and below the habitable floor of a structure. Crawl spaces having the lowest floor a minimum of two feet below 21 grade level on all sides shall be considered a basement, and not a crawl space. (Floodplain) 22 "Critical facility" means any structure or related -infrastructure the loss of which may result in 23 severe hazards to public health and safcty or may interrupt essential services and g orations for the community at any time before, during, and after a flood. Critical facilities are classified as 24 follows: (1) eFssential s9ervices (Facility, (2) hazardous mMaterial f€acility. and (3) a 4t-risk 25 pRopulations -Facility. (Floodplain and Critical Facilities) 26 27 "Development" means any change to improved or unimproved real estate, including, without limitation, constructing, relocating, rehabilitating, reconstructing or expanding or enlarging (but 28 not maintaining) a building or other structure or portion thereof, or establishing or changing a 23 ATTACHMENT A Dra t.for W1Z,4B 3-08-2013 1 use, or mining, dredging, filling, grading, paving, or excavation. (Floodplain and Critical 2 Facilities) 3 "Essential services facilit~[JL'211 ntcurls any facilityLiunidinr{g essentiat services that, if flooded. 4 may result in severe hazards to public health and safety or interrupt essential services anc 5 ot~erations for the community at any tune before during or after a flood iha; iiie de 444 4 6._ 7 e er t+ s. Examples of essential services faciliti s includQwithout limitation the following: 8 1 Public safety facilities such as police stations, fire and rescue stations, and 9 emergency operation centers 10 (2) Emergency response facilities,such as emergency vehicle and eauinrnent storage. 11 and essential governmental work centers for continuity of uovern,rr nt operations, (3) Emergency medical facilities, such as hospitals, cmergency care, urgent care, and 12 ambulance services but eXclUding clinics. doctors offices, and non-urgent care 13 medical facilities, 14 4 Shelters designated by the city manager that will be used during_ar after a flood 15 for displaced personas- (5) Communication facilities. such as main hubs for telephone, main broadcasting 16 a uinment for television systems, radio and other emergency warning systems. 17 but excluding towers, poles, lines, cables, and conduits: 18 (6) Public utility plant facilities and essential equipment for treatment. generation. oraue, Humping. and di tribution such as hubs for water, wastewater, power, and 19 gas but excluding hydro electric faci " ics, towers, poles, power lines, buried 20 pipelinej transmission lines, distribution lines, and service lines; 21 (7} Essential pgycr ningntal facil_it•e, including, without limitation, facilities where permanent records, as defined by an agency's data 22 intention policy,publie eee -ds am - ored. courts, jails, building permijtin[,nd 23 rpm 'goon services. ea' emt:nGTn-ifnni:njati-j6a r agement dcpar'tment4 that mana-gc utilities and lranspor'tatron systems, information technoloe~ 24 departments, finance departments, health departments, the county commissioner's 25 oflice, the city manager's office, and maintenance and ~uipment centers3; and 26 (8) Air transportation lifelines, such as an airport or helinorrtaild_structures serving emergency functions, and associated infrastructure such as Eaviation control 27 towers, air traffic control centers, and emergency equipment aircraft hangars) 28 24 ATTACHMENT A Draft for WRAB 3-08-2013 1 Essentialservice-facility is also included to the definition of "critical facility." (Flood plain and 2 Critical Facilities) 3 4 "Exceptional hardship" means a substantially disproportionate burden in relationship to the 5 benefit to be derived from conformance with the requirements of this title. (Floodplain) 6 7 "Existing manufactured home park or subdivision" means a manufactured home park for which the construction of facilities for servicing the lots on which the manufactured homes are to be 8 affixed (including, at a minimum, the installation of utilities, the construction of streets, and 9 either final site grading or the pouring of concrete pads) was completed prior to July 12, 1978. (Floodplain) 10 I1 "Expansion or enlargement" of a structure'-' _means any addition of an exterior wall to the 12 structure or any addition to the floor area of the structure, whether under, at, or above grade, and 13 whether or not the external dimensions of the structure are changed, or the reconstruction of a flood-damaged portion of a structure, so long as such expansion, enlargement or reconstruction 14 does not constitute a "substantial modification" or a "substantial improvement." (Floodplain and 15 Critical Facilities) 16 "Expansion to existing manufactured home park or subdivision" means the preparation of additional sites by the construction of facilities for servicing the lots on which the manufactured 17 homes are to be affixed (including, without limitation, the installation of utilities, the 18 construction of streets, final site grading, or the pouring of concrete pads). (Floodplain) 19 20 "FEMA" means the Federal Emergency Management Agency. (Floodplain and Critical 21 Facilities 22 23 "EiYdi Ulired-year flood" means a flood having a ().2 percent chance of occurrin-, in any year. 24 (Floodnlain and Critical Facilities) 25 "Flood" or "flooding" means a general or temporary condition of partial or complete inundation of normally dry land areas from a watercourse that temporarily overflows the boundaries within 26 which it is ordinarily confined or from the rapid accumulation of runoff of surface water caused 27 by rain, snow melt, flow blockage, or any other source. (Floodplain and Critical Facilities) 28 "Flood channel" means a natural or artificial watercourse with a definite bed and banks which periodically or continuously conducts flowing water and is shown on the Flood Channel 25 ATTACHMENT A Draft for WRAB 3-08-2013 1 Inventory Map prepared by the city's Utility Division of the Public Works Department. 2 (Floodplain) 3 the high hazafd zone. (Fleedplain) 4 "Flood Insurance Rate Map (FIRM)" means the official map on which FEMA has delineated 5 both the areas of special flood hazard and the risk premium zones applicable to the cormnunity. 6 (Floodplain and Critical Facilities) 7 "Flood insurance study (FIS)" means the official report provided by the Federal Emergency Management Agency that included flood profiles, the Flood Boundary- F I oodway Map, and the 8 water surface elevations of the base flood. (Floodplain) 9 "Flood profile" means a graph showing the elevations of the floodwater surface and the 10 elevations of the underlying land as a function of distance along a path of flow. (Floodplain) 11 "Flood protection elevation" means the following an elevaiien -of: 12 1) In the one hundred-year floodplain, an elevation of: 13 4A) Ttwo feet above the elevation of the water surface of a one hundred-year 14 flood as determined pursuant to sections 9-3-2 through 9-3-8, B.R.C. 1981, or, if no such elevation is determined, two feet above the highest grade adjacent to a structure}; or 15 X13 Ttwo feet above the base flood elevation in AE zones or two feet above the 16 flood depth number indicated for AO zones on the FIRM for the City of Boulder, 17 whichever is higher. 18 21 In the five hundred-year floodplain, the lower of the following elevations: 19 A) -Gone foot above the water surface of a five hundred-year flood under these 20 standards in section 9-3-2 through 9-3-8.-5- and section 9-9-23 BKC., 1981:: or 21 B)--Tthe one hundred-year flood protection elevation (Floodplain and Critical Facilities 22 "Floodplain" means the area that is susceptible to being inundated by a flood. Unless the 23 context clearly indicates otherwise, "floodplain" refers to the one hundred-year Floodplain. 24 (Floodplain), 25 "Floodplain development permit" means any permit granted under the terms and conditions of 26 sections 9-3-2 through 9-3-8, and section 979-23, B.R.C. 1981, for development on land in a floodplain. (Floodplain and Critical Facilities) 27 "Floodplain five hundred-year" means the area inundated by a flood having a 0.2 percent or 28 greater chance of occur ing in any given near. (Floodplain and Oil ~i Q1 Eacilities) 26 ATTACHMENT A Draft for WRAB 3-08-2013 1 "Floodplain, one hundred-year" means the area inundated by a flood having a one percent or 2 greater chance of occurring in any given year. (Floodplain) 3 "Floodproofing" means any combination of structural and nonstructural changes, modifications, or adjustments to structures or real property which reduce or eliminate flood damage to improved 4 or unimproved real property, water and sanitary facilities, structures and their contents. 5 (Floodplain and Critical Facilities} 6 "Floodway, FEMA regulatory" means the channels of watercourses and the adjacent land areas that must be reserved in order to discharge the base flood without cumulatively increasing the 7 water surface elevation more than one foot. (Floodplain) 8 9 "Hazardous material" means any material used, generates, or stored at a facility of a type and in to i-q _ l at would classify the facility as a hazardous materials facility. (Floodplain and Critical Facilities II 12 13 "Hazardous material facility" means a structure crn• group of structures that is: 14 t l) subject to Section 303 of the Emergency Planning and Con~~tiuzuty 15 Right-to-Knew Act, .42 U C U1 l 003,..becausc it has on--s-i-w-an "Extremely Hazardous Substance" on site in quantities that meet or exceed the "Threshold 16 Planning ~uanltics" established by the United Stag s Environmental Protection 17 Agency and 1c_tit_ed at 40CFR Poi t_35 ,_4tap_e_it~lix A and_A}~pgn(hx Bo- 18 [2 a td - - covered sub nail ( l) above, storm,zardogs n~~~teriat a-s defined by Department of Transportation regulations at 49 CFR Parts 171- 180 but 19 only to the extent that the facility is storing the hazardous material in the "Bulk Packaging" container in which it was delivered as that term is defined at 49 CFR 20 171.8.- - 21 (3-)--sue storing a hazardous substance of the type and quantity listed by §29- 22-107.C.R.S; or- 22 (4) A-lhci;;j~-regulated as a transfer facility tinder Colorado hazardous waste 23 reg„uliltions at 6 CU I-QO7-3, Tart 263. 24 Hazardous material facility is also included in the definition of `'critical facilit rte. 25 odplain and Critical Facilities) 26 "Hazardous substance" means any substance, as determined from time to time by the city manager pursuant to the rule making authority granted by subsection 9-3-2(c), B.R.C. 1981, that 27 is flammable, radioactive, toxic, or explosive, and that in times of flooding could be released in 28 sufficient quantities to be harmful to humans, animals, or plant life. (Floodplain) 27 ATTACHMENT A Drafi for WRAB 3-08-2013 1 2 "High hazard zone" means those portions of the floodplain where an unacceptably high hazard to human safety exists defined as those areas where the product number of' flow velocity (measured 3 in ft./sec.) times flow depth (measured in feet) equals or exceeds four, or where flow depths 4 equal or exceed four feet. (Floodplain and Critical Facilities) 5 6 "Intended for human occupancy" means, as applied to structures, capable of and likely to be used for residential habitation, or for commercial, industrial or governmental occupation by persons on a regular basis. Examples of structures normally not intended for human occupancy include, 8 without limitation, garages useable solely for the parking of vehicles or storage, open air carwashes, unheated pavilions, porches or patio covers, crawl spaces, flood resistant enclosures 9 useable solely for building access, barns and other agricultural buildings, garden storage sheds, 10 ATMs, and mausoleums. (Floodplain) 11 12 L.od-ine facility' means a hotel, motel, dormitory. bed and breakfast. or hostel. as defined in the 13 ouldcr Revised Code_ -(Floodplain and Critical Facilities) 14 15 "Lowest floor" means the lowest floor of the lowest enclosed area (including basement or crawl space). An unfinished or flood resistant enclosure, usable solely for parking of vehicles, building 16 access or storage, in an area other than a basement area, is not considered a building's lowest 17 floor, provided that such enclosure is not built so as to render the structure in violation of the applicable design requirements of sections 9-3-2 through 9-3-8, and section 9-9-23 B.R.C. 1981. 18 (Floodplain and Critical Facilities) 19 20 "Maintenance" means any activity undertaken to repair or prevent the deterioration, impainnent 21 or failure of any stream, previously constructed improvement or structure including, without 22 limitation: the removal of sediment and debris, installation of erosion and sediment control devices and the replacement of structural components. Maintenance does not include substantial 23 modifications, substantial improvements, total replacement of existing facilities or total 24 reconstruction of a facility. (Floodplain and Critical Facilities) 25 " 26 "Manufactured home" means a structure, transportable in one or more sections, which is built on a permanent chassis and is designed for use with or without a permanent foundation when 27 connected to the required utilities. The term "manufactured home" does not include a 28 "recreational vehicle." (Floodplain) 28 ATTACHMENT A Draft for WRAB 3-08-2013 1 "Manufactured home park or manufactured home subdivision" means any lot or tract of land 2 designed, used, or intended to provide a location or accominodation for one or more manufactured homes and upon which any manufactured home or homes are parked or located, 3 whether or not the lot or tract or any part thereof is held or operated for profit, on which 4 construction was completed on or after July 12, 1978. (Floodplain) 5 6 "Moveable object" means an item or material not anchored to the ground that is subject to being transported by water, including, without limitation, a manufactured home not anchored to a 7 permanent foundation, a tank, a trash dumpster, lumber, and other materials, but not a motor 8 vehicle. (Floodplain) 9 10 "New construction" means structures for which the "start of construction" commenced on or after July 12, 1978, and includes any subsequent improvements to such structures. (Floodplain 11 and Critical Facilities) 12 New manufactured home park or subdivision" means a manufactured home park or subdivision 13 for which the construction of facilities for servicing the lots on which the manufactured homes 14 are to be affixed (including, at a minimum, the installation of utilities, the construction of streets, final site grading, or pouring of concrete pads) is completed on or after July 12, 1978. 15 (Floodplain) 16 "Nonresidential structure" means any structure or any portion of a structure used exclusively for, 17 or designed as and capable of being used for, office, commercial, industrial, or governmental occupation. (Floodplain) 18 19 "Obstruction" means any item or material not constituting a moveable object in, along, across, or 20 projecting into the floodplain that might impede, retard, or change the direction of a flow of 21 water, either by itself or by catching or collecting debris carried by such water, in a way that the city manager determines would increase the flood hazard to adjacent properties. (Floodplain) 22 23 24 One hundred-year flood" means a flood having a one percent chance of occurring in any year. (Floodplain and Critical Facilities) 25 26 "Reconstruction" means exact replacement of an existing structure or portion thereof or exact 27 structural repair of a damaged structure. (Floodplain and Critical Facilities) 28 29 ATTACHMENT A Draft for WRAB 3-08-2013 1 "Recreational vehicle" means a vehicle which is: 1) built on a single chassis; 2) four hundred 2 square feet or less when measured at the largest horizontal projections; 3) designed to be self- propelled or permanently towable by a light duty truck; and 4) designed primarily not for use as 3 a permanent dwelling but as temporary living quarters for recreational, camping, travel, or 4 seasonal use. (Floodplain) 5 " 6 "Rehabilitation" means any improvement, maintenance, or remodeling made to the interior or exterior of any existing structure or the reconstruction of a deteriorated or non-flood-damaged 7 portion of an existing structure so long as such improvement or reconstruction does not 8 constitute an "expansion or enlargement of a structure," "substantial modification," or a "substantial improvement." (Floodplain) 9 10 "Residential structure" means any structure or any portion of a structure that is used for, or 11 designed as and capable of being used for, the temporary or permanent domicile of persons, 12 including, without limitation, a dwelling, a boarding house, a hotel, a motel, and similarly used 13 structures. (Floodplain) 14 15 "Start of construction" means the date the building permit was issued, provided the actual start of construction, repair, reconstruction, rehabilitation, addition, placement, or other improvement 16 was within one hundred eighty days of the permit date. The actual start means either the first 17 placement of permanent construction of a structure on a site such as the pouring of slab or footings, the installation of piles, the construction of columns, or any work beyond the stage of 18 excavation; or the placement of a manufactured home on a foundation. (Floodplain and Critical 19 Facilities 20 21 "Structure" means a building or other roofed construction, a basement, a wall, a fence, a manufactured home, or a storage tank. (Floodplain and Critical Facilities 22 23 24 "Substantial damage" means damage of any origin sustained by a structure whereby the cost of restoring the structure to its before-damaged condition would equal or exceed fifty percent of the 25 market value ofthe structure before the damage occurred. (Floodplain) 26 "Substantial improvement" means any repair, reconstruction, rehabilitation, addition, or 27 improvement of a structure, the cost of which equals or exceeds fifty percent of the market value of the structure before the "start of construction" of the improvement. This terin includes 28 structures which have incurred "substantial damage," regardless of the actual repair work 30 ATTACHMENT A Draft for WRAB 3-08-2013 1 performed. For the purposes of this definition, "substantial improvement" is considered to occur 2 when the first alteration of any wall, ceiling, floor, or other structural part of the building commences, whether or not that alteration affects the external dimensions of the structure. The 3 term does not, however, include either: 1) any project for improvement of a structure to comply 4 with existing state or local health, sanitary, or safety code specifications which are solely necessary to assure safe living conditions or 2) any alteration of a structure listed on the National 5 Register of Historic Places or the Colorado Inventory of Historic Places or designated as an individual landmark under section 9-11-2, "City Council May Designate Or Amend Landmarks 6 And Historic Districts," B.R.C. 1981. (Floodplain and Critical Facilities) 7 8 "Substantial modification" means any expansion or enlargement of a structure which equals or 9 exceeds fifty percent of the floor area of the structure intended for human occupancy, considered 10 cumulatively, commencing July 12, 1978. (Floodplain and Critical. Facilities) 11 . 12 Section 4. This ordinance shall become effective on the laterbf , 2013~JLP31, 13 or 30 days after its final passage by the City Council. This ordinance shall apply to all permits 14 and development applications submitted to the city after the effective date of its passage. 15 Section 4. This ordinance is necessary to protect the public health, safety, and welfare of 16 17 the residents of the city, and covers matters of local concern. 18 Section 5. The City Council deems it appropriate that this ordinance be published by title 19 only and orders that copies of this ordinance be made available in the office of the city clerk for 20 public inspection and acquisition. 21 22 23 24 25 26 27 28 31 ATTACHMENT A Draft for WRAB 3-08-2013 1 INTRODUCED, READ ON FIRST READING, AND ORDERED PUBLISHED BY 2 TITLE ONLY this day of , 2013. 3 4 5 Mayor 6 Attest: 7 8 City Clerk on behalf of the 9 Director of Finance and Record 10 READ ON SECOND READING, PASSED, ADOPTED, AND ORDERED 11 12 PUBLISHED BY TITLE ONLY this day of , 20_. 13 14 Mayor IS Attest: 16 17 18 City Clerk on behalf of the Director of Finance and Record 19 20 21 22 23 24 25 26 27 28 32 ATTACHMENT B Attachment B List of Existing Critical Facilities and Lodging Facilities 500-year Flood lain Name Address Facility Tv e Creek Boulder County Justice Center 1777 6th St Essential Service Boulder Boulder Fire Station 7 1380 55th St Essential Service South Boulder Police Annex 1500 Pearl St Essential Service Boulder US West Communications 1545 Walnut St Essential Service Boulder American Medical Response 3800 Pearl St Essential Service Goose Boulder Community Foothills Hospital 4747 Arapahoe Ave Essential Service Boulder Boulder Countv Clerk and Recorder 1750 33rd St Essential Service Boulder Boulder Fire Station 5 4365 19th St Essential Service Fourmile Canyon Boulder Sheriff 5600 Flatiron Parkway Essential Service Boulder Public Safety Building 1805 33rd St Essential Service Boulder Regional Transportation District 1707 Exposition Dr Essential Service Boulder Municipal Service Center 5050 Pearl St Essential Service Goose Xecl Boulder Terminal 2500 28th St Essential Service Goose Eisenhower Elementary School 1220 Eisenhower Dr At-risk Population South Boulder First Presbyterian Church 1820 15th St At-risk Population Boulder September School 1902 Walnut St At-risk Population Boulder September School (auditorium) 1833 19th St At-risk Population Boulder Alterra Villas at the Atrium 3350 30th St At-risk Population Wonderland Boulder County Head Start 2675 Mapleton Ave At-risk Population Goose Boulder County Head Start (Martin Park) 3650 Martin Dr At-risk Population Bear Canon Canyon Pointe Housing 700 Walnut St At-risk Population Boulder Columbine Elements School 3130 Rep lier St At-risk Population Twomile Canyon Homestar Child Development Center 3280 Dartmouth Ave At-risk Population Bear Canyon McGregor's Garden Preschool 3535 Eastman Ave At-risk Population Bear Canyon Montessori Education Center of the Rockies 4745 Walnut St At-risk Po ulation Boulder Mountain Morning Preschool 1286 Sumac Ave At-risk Population Wonderland New Horizons Cooperative Preschool 1825 Upland Ave At-risk Population Fournile Canvon Rall s ort Health Club Day Care 2727 29th St At-risk Population Ehlers Twomile Shining Mountain Waldorf School 1179 Union Ave At-risk Population Founnile Canvon Sunflower Preschool 3340 Dartmouth At-risk Population Bear Canyon Tinv Minders Dav Care 3685 Martin Dr At-risk Population Bear Canyon Comcast 3250 Walnut St hazardous Material Boulder Corden Pharma 2075 55th St hazardous Material South Boulder The Bradley Boulder Inn 2040 16th St Lodging Boulder Boulder Best Western 770 28th St Lodging Skunk Golden Buff Motel 1725 28th St Lodging Boulder Residence Inn 3030 Center Green Dr. Lodging Wonderland The Village Marriott 2660 Canvon Blvd Lodging Boulder Notes: 1. New flood protection measures arc required for listed essential service, at-risk population, and hazardous material facilities in the 500-year floodplain. 2. Emergency management plans are required for all listed facilities in the 500-year floodplain. 3. Blue fill denotes government facilities. ATTACHMENT B 100-year Flood lain Name Address Facility Ty e Creek Regional Transportation District 4920 Table Mesa Dr Essential Service South Boulder Regional Transportation District Terminal 1800 14th St Essential Service Boulder Atrium Building 1300 Canyon Blvd Essential Service Boulder Boulder Building Maintenance 1720 13th St Essential Service Boulder Boulder Community Hospital 1100 Balsam Ave Essential Service Goose Boulder Fire Station 3 1585 30th St Essential Service Boulder Boulder Medical Center 2750 Broadwav Essential Service Goose Boulder Municipal Building 1777 Broadwav Essential Service Boulder CU Research Center 3300 Marine St Essential Service Boulder FBI 1050 Walnut #219 Essential Service Boulder New Britain Building 1101 Arapahoe Ave Essential Service Boulder Park Central Building 1739 Broadway Essential Service Boulder Countrvside Montessori Preschool 5524 Baseline Rd At-risk Population South Boulder r Friend's School 5465 Pennsylvania Ave At-risk Population South Boulder Take a Break at Frasier Meadows 4950 Thunderbird Dr At-risk Population South Boulder Boulder Good Samaritan Center 2525 Taft Dr At-risk Population Boulder Boulder High School 1604 Arapahoe Ave At-risk Population Boulder Boulder Presbvtcrian Manor 1050 Arapahoe Ave At-risk Population Gregory Canyon Boulder Waldorf Kindergarten 4072 N 19th At-risk Population Wonderland City Assisted Housing on Arapahoe 951-53 Arapahoe Ave At-risk Population Gregory Canyon Cottage School 805 30th St At-risk Population Skunk Cottage School North 1301 North St At-risk Population Goose Crest View Elementary School 1897 Sumac Ave At-risk Population Fourmile, Canyon CU Children's Center 2202 Arapahoe Ave At-risk Population Boulder Dream Makers Preschool 1345 28th St At-risk Population Boulder Flatirons Elementary School 1150 7th St At-risk Population Gregory Canyon Foothills Elementa School 1001 Hawthorn Ave At-risk Population Twomile Canyon Livin,; School 1852 Arapahoe Ave At-risk Population Boulder Patience Montessori 3600 Hazelwood Ct At-risk Population Wonderland Shining Mountain Waldorf School 999 Violet Ave At-risk POP - ulation Founnile Canyon The Elm Tree 1330 Alpine Ave At-risk Population Goose Wvnwood at Ridge Point 3375 34th St At-risk Population Wonderland Ball Aerospace 1600 Commerce St Hazardous Material Boulder Athens Court Family Housing 2010 Athens St Lodging Boulder Boulder University Inn 1632 Broadwav St Lodging Boulder Briar Rose Bed & Breakfast 2151 Arapahoe Ave Lodcinz Boulder Homewood Suites 4950 Baseline Rd Lodging South Boulder Marine Court Family Housing 1350 20th St Lodging Boulder Millennium Harvest house 1345 28th St Lodging Boulder Newton Court Family Housin 1475 Folsom St Lodging Boulder Quality Inn & Suites Boulder Creek 2020 Arapahoe Ave Lodging Boulder St. Julien hotel 900 Walnut St Lodging Boulder Notes: 1. Emergency management plans are required for all listed facilities in the 100-year floodplain. 2. Blue fill denotes government facilities. CITY OF BOULDER WATER RESOURCES ADVISORY BOARD INFORMATION ITEM MEETING DATE: March 18, 2013 AGENDA TITLE: Commercial, Industrial and Institutional (CII) Water Budget Update PRESENTERS: Jeff Arthur, Director of Public Works for Utilities Bret Linenfelser, Water Quality and Environmental Services Coordinator Russ Sands, Water Conservation Program Manager EXECUTIVE SUMMARY: When water budgets were implemented in 2007 they were intended to equitably link monthly water allotments with water efficiency. While single family, multifamily and outdoor water budgets were set using informed efficiency levels, the Commercial, Industrial and Institutional (CII) sector was less straightforward. Given the complexities of the CII sector, historic water use was used to determine CII water budgets regardless of whether the historic use had been efficient or inefficient. Upon implementation of water budgets in 2007, and amidst subsequent CII budget changes in 2008, City Council directed staff to continue evaluating if an efficiency-based, equitable CII water budget could be developed. With WRAB guidance, staff initiated a CII water budget pilot study in 2009 to identify what, if any, water efficiency-based alternatives could be developed and implemented. In 2011, staff developed a CII water budget approach that combined statistical benchmarks and water audits into a single "Combined Approach." With WRAB's support, staff has moved forward with a deeper analysis of how and if this methodology could be used to establish new CII water budgets. Through 2012 staff continued to analyze the Combined Approach, focusing most heavily on the benchmarking methodology- the more data intensive component. Now, with sub-sector benchmarks identified, initial revenue impacts analyzed and water audits ready to test, staff is providing WRAB with an update on progress to date. Staff plans to continue testing and refining the Combined Approach through 2013 in order to bring a final recommendation back to WRAB in early 2014. STAFF RECOMMENDATION Staff recommends that WRAB consider the following questions when reviewing this Information Item. • Does WRAB have any questions or concerns with the benchmarking analysis? • Does WRAB have any questions, concerns or specific direction for water audits? • Is there specific financial analysis WRAB would like to see in future presentations? • Is WRAB supportive of having staff continue exploring the Combined Approach? BACKGROUND: Residential Water Budgets Water budgets were first approved by City Council in 2004 but were not officially implemented until 2007. The goal of water budgets was to link an expected level of water-efficiency to the block rate structure such that more efficient water users would pay less for water than those who wasted water. For residential customers, the average winter consumption (AWC) was used as the basis for setting indoor water budgets, with some additional water allotted for winter watering. CII Water Budgets Due to the variability in CII customers and their water use, applying AWC as an indoor water budget was not practical. Even if broken into sub-sectors (hotels, carwashes), varying seasonal water usage made AWC a poor choice. In lieu of a better way to calculate C11 water budgets, historic use became the default. Based on 2005 data, Average Monthly Use (AMU) was used to determine CII water budgets starting in 2007. In 2008, CII customer water budgets were expanded beyond AMU to include four additional water budget options as detailed in Attachment A. City Council directed staff to continue looking for options that would allow a more tailored approach to CII water budgets while still honoring city water conservation and sustainability goals. In 2009, under direction from WRAB, staff began exploring options including the use of benclunarking. Benchmarks and Normalizing Factors Commercial, Industrial and Institutional water consumption benchmarks typically analyze water use across key CII sub-sectors (e.g. hotels, offices), identifying the highest and lowest water users then setting a target efficiency benchmark somewhere in between (typically the 25t' percentile). Because analysis solely based on water use would unfairly skew the data, making larger properties appear less efficient than smaller ones, CII studies utilize one or more normalizing factors (e.g. gallons per hotel room) to show the relative efficiency across properties. Initial Benchmarking Concerns While WRAB encouraged the use of benchmarks, staff had some specific concerns, as follows: • Normalizing Factors- Studies often use multiple normalizing factors which are often difficult, if not unrealistic, to accurately capture and maintain (e.g. gallons per plate sold in a restaurant). Using factors like employee count or occupied room, which is easily subject to change, combined with the inherent difficulties in managing one or more of these factors in the utility billing database, was seen as cost prohibitive and unmanageable by staff. • Stringent Benchmarks- Studies like the 2000 Water Research Foundation, Commercial and Institutional End Uses of Water Study suggested the use of stringent benchmarks which set the efficiency level at the 25`h percentile; indicating that 75 percent of CII users would need to reduce their water use down to the level used by 25 percent of C11 customers. Since studies also cited that easily achievable water savings typically fell in the 5 percent to 10 percent reduction range, staff felt that having 75 percent of the CII sector decrease water use would create an economic burden and was likely unachievable for most CII customers. • Guidance, Not Billing- None of the CII benchmarking studies reviewed suggested that benchmarks should be used to set water budgets or to otherwise bill customers. Rather, the benchmarks were suggested as a tool to help water conservation programs. • Difficulties in Categorization- None of the studies fully categorized or analyzed all CII sub-sectors. Instead they focused on 5 to 10 of the highest water using CII sub-sectors. Given these issues, staff were initially concerned that there was not a realistic pathway to implement CII water budgets based on benchmarks. However, one commonality staff did see across benchmarking studies was a water audit component. A water audit approach that would allow for onsite analysis of CII water use seemed more readily implementable to staff. Water Audits and Benchmarks Reconsidered Staff pursued trial water audits in 2010 after a recommendation from WRAB, although WRAB noted that the water audit approach would be resource and time intensive. The benefits of water audits were clear, as there was seemingly an inherent equity in evaluating CII customers based on their real (not estimated) efficiency. The WRAB also suggested that benclunarks could be modified to allow for greater equity by setting the benchmark at the 75t' percentile or even as high as the 95'h percentile. Staff Developed Combined Approach Taking WRAB's comments under advisement, staff needed to plan for unique customers that couldn't be benchmarked, to allow options for customers who might challenge their benchmark- based water budget and to develop an approach that could work within the confines of the existing utility billing database. Staff developed an approach that seemingly addressed all concerns through a combined benchmarking and water audit methodology that would use a modified version of the existing Efficiency Standard water budget. At the November, 2011 WRAB meeting, WRAB approved staff s recommendation to explore the Combined Approach, which is shown in Attachment B. Monterey, California Implements Similar Methodology In moving forward with the Combined Approach, staff discovered that the Monterey Peninsula Water Management District (MPWMD) of California had actually implemented something similar. After contacting MPWMD and California American Water (Monterey's water utility), it was clear that many of staff's initial concerns were born out in Monterey such that they were abandoning their methodology altogether. Details are explained in Attachment C. Monterey's experience offers critical lessons that can inform the city's Combined Approach as shown in the following table. Potential Benchmarking and Water Audit Issues and Mitigation Strategies Issue Monterey's Approach Boulder's Proposed Mitigation Benchmarks Used the 50th Percentile; customers paid Set the benchmark between the 75th Can't Be 'l'oo higher bills because they couldn't always and 95th percentile. Stringent meet the efficiency benchmark Multiple Used 10 different normalizing factors Normalizing causing confusion for customers and staff. Use only gallons per square foot. Factors Don't Difficult for staff to manage. Work No exceptions to the benchmark. Water Allow increases based on water Businesses audits only for unique use. Ex: Hotels audits. Allow a trial year for Require receive budget based on gallons per customers to see if their budget Flexibility occupied room regardless of if they used would be negatively affected, water for laundry or contracted that work. Provide water audits as needed/requested. Contract lower-cost, quicker audits Water Audits Monterey paid over $2,000 per water audit. through Boulder County. Audits to for Total Audits were lengthy and detailed the total evaluate opportunities to reduce Water Use are water waste. Use higher cost, more Costly wafer a customer would use. detailed audits for unique customers or as needed. Budgets Must Monterey's "True Up" meant the city could Monthly water budgets are more Consider not accurately estimate revenue; customers effective. Any budget changes must Revenue who weren't over their annual water consider all rate and revenue Impacts budget would receive a check at the end of impacts. the year. ANALYSIS: Staff progress on developing both the benchmarking and water audit components of the Combined Approach is shown in the following sections. Benchmarking Analysis From the time WRAB approved further exploration of the Combined Approach, the bulk of staff time has been dedicated to benchmarking analysis. Staff contracted with the Brendle Group to provide analysis and their efforts to date is detailed in Attachment C. Key findings and decisions are summarized below: • Base Consumption on 2011 Water Use- As part of the update to the Water Conservation Future's Study, contractor AMEC Environmental has done preliminary research which suggests that 2011 would be a representative year to use as a baseline year for new CII water budgets water use. • Categorize Sub-sectors by NAICS Code- The North American Industrial Classification System (NAICS) codes use a six-digit identification number to group businesses types. Use of NAICS codes was suggested by WRAB and was supported by studies. By using NAICS codes, the 2,038 CII customer accounts were divided into 29 sub-sectors. This is the minimum number of sub-sectors staff feels can be equitably set. The 29 sub-sectors are shown in Attachment C. • Normalize Use by Square Footage- As with other CII studies, normalizing factors like "gallons-per-employee" were considered. While no single factor was found to work best for all CII sub-sectors, "gallons-per-square-foot" was more compelling than any other normalizing factor due to the consistency, reliability and public availability of a commercial properties size (in square feet). Because any increase in square footage would require a city-issued permit, staff feels there is a feedback-loop that could be used to accommodate increased water budgets for customers who expand their business. Additional detail on the selection of square footage as a normalizing factor is shown in Attachment C. • Use Annual Water Use, Not AWC for Most Customers- Due to the variability of when CII customers use the most water or when CII customers are busiest, AWC may be a poor indicator of total water use. Annual water consumption is a better indicator of CII water needs. • Differentiate Seasonal Indoor Water Use from Irrigation- It is generally assumed that C11 customers have separate meters for irrigation. However, staff has long suspected that some amount of unreported irrigation is done through C11 domestic water meters resulting in CII customers having smaller water budgets than the additional 159/sgft they would otherwise be allotted for any pervious area. Because seasonal increases often coincide with summer months, irrigation can be masked by increased indoor water use. By comparing increases in water use for CII accounts with known irrigation meters, it appears that increases during the irrigation season, which are greater than 1.5 times a customers' AWC, strongly suggest irrigation is occurring. To remove outdoor water use from the city's indoor CII analysis, accounts suspected of irrigating (about 20 percent of CII customers) had their water consumption was based on AWC. Future analysis will evaluate whether subtracting 15gal/sqft from the permeable area may better favor CII customers. In either case, both water audits and any trial period to test new water budgets would serve to identify if irrigation is occurring. If confirmed, customers would be given an equivalent outdoor allotment. • Set a Single Benchmark Across Sub-Sectors- Setting a single benchmark (e.g. 85th percentile) across all sub-sectors is equitable between sub-sectors and easier to manage. • Benchmarks Should Consider Rate Impacts- Staff was initially concerned about the number of customers who would be caught above the benchmark, requiring a reduction in water use to be within budget, or paying more for water. However, it is the number of accounts below the benchmark which stands to most negatively impact revenue such that water rates would need to increase. It was WRAB's feeling that new CII water budgets should be implemented as they were for residential customers. This means CII customers below the benchmark would see an increase in their water budget up to the benchmark. Using the single family water budget example, if customer A used 3,000 a month and customer B used 15,000 a month, both were still allotted 7,000 a month when water budgets went into effect in 2007. This illustrates how water can essentially become cheaper for those below the benchmark and more expensive for those above it. In the case of CII, benchmark based water budgets, while calculated differently, would have a similar impact on those below and above the benchmark. Using the 95th percentile one would expect that 94 percent of customers would see their water budget increase while only 5 percent would see a decrease (1 percent would stay the same). The numbers presented in Attachment C are slightly different due the way "overbudget" is defined (three consecutive months, not annual net). In either case, revenue impact analysis should be used to guide the benchmark selection such that the impacts to revenue are minimalized, deferring the need to raise water rates. Rate and Revenue Impacts Associated with Benchmarks: As WRAB advised staff to evaluate scenarios using a benchmark set between the 75th and 95th percentiles, staff performed preliminary revenue impact analysis on the 75t'', 85", 90th and 95th percentile of CII water consumption using 2011 as the baseline year. Two variations of this analysis are detailed in Attachment D. Although more thorough revenue analysis is needed, initial summary findings provide some insight as to where a benchmark might be set: 1. Base Revenue Impact Analysis- In all cases, the initial revenue impact analysis revealed no negative impacts to revenue; the utility would see additional revenue in each case. This is achieved because the increased bills on the top users (as normalized) would be so significant that it would offset the decreased revenue brought in by those receiving increased water budgets below the benchmark. For the purposes of this analysis, customers receiving a larger water budget were not assumed to use more water simply because their budget was increased. 2. Alternate Revenue Impact Analysis- As the goal of this project is not to create an undue burden on business, a second round of analysis was done to evaluate revenue impacts which discounted outliers, extreme customer bill increase and known issues (e.g. looped accounts). Staff feels this may give a more realistic snarhot of the revenue impacts of a practically applied benchmark. In this case the 85' percentile seems to more closely represent a revenue neutral option. Overbudget Customers Under Existing And Proposed Benchmarks As noted in Attachment C, a benchmark set at the 85`h percentile places about 13percent (260) of the total 2,038 CII customers overbudget (in block 4 for at least three consecutive months). Comparatively, in 2011, under the current water budgets, 14 percent (279) customers were overbudget. However, not all of the overbudget accounts are comprised of the same customers. Under the proposed methodology, customers would be overbudget if they exceed the efficiency benchmark. The existing water budget process allows a customer to increase their water budget even if water is being used inefficiently. Through a simple adjustment request, CII customers can recalculate their AMU water budget using their highest water use year or their three highest consecutive months of water use (since 2005). Thus, a customer who is under their water budget due to an adjustment under the existing water budget structure, if inefficient, will likely result in the same customer being overbudget using a benchmark-based approach. Conversely, many CII customers have never adjusted their original 2005-based AMU and some are currently overbudget, paying higher block rates. A customer like this who is using water efficiently, although they may be currently overbudget, could be given a larger water budget using a benchmark-based approach. Considering the 85`h percentile, 112 of the 260 currently overbudget CII accounts are the same customer accounts that were overbudget in 2011. The other 148 CII accounts that are currently under their budget would be overbudget using efficiency-based benchmarks. In other words, 7% (148) of the total CII accounts would be "newly overbudget" at the 85"' percentile. Staff expects this group would request a water audit as allowed for under the Combined Approach. Water Audit Analysis: Because so much of the water audit process hinges on the development of the benchmarks (e.g. determining who will be overbudget), staff has not fully developed the water audit process. The interaction between benchmarking and water audits is detailed in Attachment C. A flowchart explaining water audit triggers has also been extrapolated in Attachment E. Staff realized that starting water audits now would better inform future efforts. Staff contracted with Boulder County to perform standard CII water audits across most of the 29 identified sub- sectors. This allows staff to test the forms, criteria and cost associated with future water assessments but it also serves as outreach to high use CII customers. Staff has made $20,000 available to help with CII rebate assistance for customers who would like to make changes suggested in the water audit. Unique CII customers may receive a more detailed audit from a professional engineer. These audits could be by completed by the Brendle Group using their existing contract. In planning for upcoming audits, staff identified the following key issues and core program component goals as follows: • Define Criteria That Triggers a Water Audit- Staff have identified several key reasons a customer could get a water audit. These include 1) Unique Water Use; 2) Customer Complaints; 3) Change in Use (triggered by a permit); 4) Instigated by Staff/Outreach; 5) Customer Request. • Clarify Water Audit Process- In order to accommodate a larger number of water audits and more effectively use funds, the standard water audit will evaluate water waste and opportunities for efficiency. The standard audit will cost the Utility approximately $700 per water audit as compared with the cost of a more detailed water audit done by a professional engineer (about $2000 per audit). • Define Water Budgets Increases- In some cases customers will legitimately need a budget increase. Water budgets could be based on the current AMU increase allowance (using the highest 3 consecutive months of water use) minus the amount of water waste found during an audit. Alternately, a flat percent increase above the efficiency benchmark for that sub-sector could similarly be applied after subtracting any water wasted found during an audit. These concepts need to be evaluated and vetted for equity and ease of implementation. • Identify Water Audit Passing Criteria- Staff will need to detail what comprises a passing score on a water audit. One thought is to tie this to a reasonable Return on Investment (ROI), where a 1-2 year payback period might serve as threshold for what can be reasonably achieved. Boulder County standard CII audits performed in 2013 will seek to quantify the ROI associated with the efficiency opportunities they arc finding. • Revise Audit Form- Because the Brendle Group has already developed a CII Too] for performing CII audits, which is widely used across Colorado municipalities, staff have asked Brendle Group to make improvements to the tool and will be using that tool for 2013 audits. • Identify Alternate Audit Methodology and Form- For some unique customers, the standard water audit will not be sufficient. When water use is so specialized and technical that it requires evaluation of things such as mechanical rooms, pumps and process water, water audits will likely need to be performed by a professional engineer. Currently, there is no standardized form that professional engineers can use. To ensure equity across audits, staff will ensure the CII tool will also work well for professional engineers. • Quantify Maximum Water Audits per Year- Staff need to quantify a maximum number of water audits which could reasonably be performed each year in order to prepare for water audit demand in the implementation or pre-implementation or trial year for benchmark based water budgets. Additional Information on 2013 Water Audits Staff plan to initiate audits, to be performed by Boulder County, after April 1, 2013. Boulder County water auditors will focus on targeting the highest users in each sub-sector. This process will serve to ground-truth the benchmarking analysis by confirming that there are/are not water conservation opportunities where the customers could be conserving more water than they currently use. By quantifying these opportunities staff will be able to identify a reasonable amount of savings to help inform the benchmark selected for the CII sector. If audits suggest that customers could easily reduce water use by 30 percent, a lower benchmark (75t` percentile) may be supported. If they could only save 5 percent then the 95"' may need to be considered. Staff will also work with Brendle Group to perform approximately two audits for unique facilities, requiring a professional engineer, to better understand needs and achievable savings for those customers. TIMELINE: Water budgets were originally approved by City Council in 2004, were seen on customer's water bills (but not billed) during the 2006 trial year, and were fully implemented in 2007. Staff proposes following a similar approximate timeline for CII water budgets, as follows: • 2013- Develop CII water budget methodology for benchmarks and water audits refined. • 2014- New budgets approved and programmed into the city's Utility Billing database. • 2015- Trial year where CII customers see what their new budget but are billed normally. • 2016- Fully implement new CII water budgets. NEXT STEPS: As staff continues to evaluate the Combined Approach to developing CII sector water budgets there are several components that need to be refined. This year staff will work to: • Identify and categorize the remaining 200 CII customers currently labeled as "other." • Perform water audits, collect data and use results to inform audit improvements. • Quantify the maximum number (and cost) of audits that can be completed each year. • Analyze revenue rate impacts in more detail. • Work with the business community to help explain possible water budget changes. • Discuss possible impacts to the Plant Investment Fess with the city Planning Department. • Provide City Council with an initial overview of CIi water budget progress to date. • Return to WRAB in early 2014 with findings. ATTACHMENTS: Attachment A- Existing CII Water Budgets Attachment B- Combined Approach Flowchart Attachment C- Brendle Group City of Boulder CII Analysis Attachment D- Revenue Impact Analysis Attachment E- Water Audit Flowchart ATTACHMENT A CII WATER BUDGETS: There are currently five types of Commercial, sv~. nk1f :a Industrial and Institutional Water Budgets which all relate to the tiered block rate structure shown here. e+s«4 a - ia~. Each of these five water budgets are explained in 131.4 10T °(WA" the section below. 7/'i-0f Fi'arrr AMU (Average Monthly Use) -started 2007 1. The AMU is the original water budget and is currently the default water budget. This is based on a 12 month average using a default of Jan- Dec 2005 numbers- "AMU budget is calculated using [100% of] the historical average of 12 consecutive months of water use for that account, so that every month's water budget is the same." Because the Water budget is the same for each month a graph might look the same each month and the customer may even be able to stay in budget each month if they have consistent indoor usage (as shown below): AMU (default Jan-Dec 2005) block 5 block 4 block 3 JAN DEC 2. The AMU can be adjusted. This has been the case since the AMU water budgets began in 2007. Customers cans: a. Change AMU to use different months (at least 3 consecutive months; could be more) b. Change AMU using a different year c. Change AMU to a different year and use different months i. Changes are done upon completion of a form ii. Changes are only done once a year for CII customers Because the customer selects the AMU they can use it to their advantage. By picking their highest year and three highest months their use is able to reach historical peaks without going over budget. The following graph attempts to illustrate this with the light blue representing the AMU and the actual use shown in dark blue. AMU (adjusted) block 5 block 4 block 3 JAN DEC ATTACHMENT A H M U (Historic Monthly Use) -started 2008 The HMU budget is calculated using a rolling (3 year) average for each individual month. For example, the average of the past three January's use would be next year's January budget. This allows the HMU water budgets can trend up or down overtime. In this case, increased business or wasteful use could both lead to an increased water budget where increasingly efficient use or less business would decrease the water budget over time. HMU is best for customers who have a bump in (indoor water) use that is not necessarily in the summer and because it takes a rolling average it accounts for growth. HMU may not be acceptable to some groups whose business is not predictable in a given month in which case and adjusted AMU may be preferred. For example, an adjusted AMU is better for a car wash than using HMU because the car wash is busier during the snowiest months which may not be the same from year to year. A graph of an HMU water budget might look like this: HMU (rolling average by month for last 3 years) block 5 block 4 block 5 block 3 block 4 block 5 _i block 3 block 4 block 3 x`T JAN DEC 1/0 (Indoor/Outdoor) -started June 2008 The Indoor/Outdoor budget is given to CII customers who are watering their landscape using a single (domestic) meter. These customers may appear to be over budget on an AMU water budget. When irrigation is discovered and the customer requests a change, the customer is converted to an 1/0 water budget which gives them a larger budget. In this case, indoor use is based on AWC (average winter consumption) and the newly added outdoor use is based on irrigable area (15 gallons per square foot of permeable area). Single Family and Multifamily accounts do not have an I/O budget but their use is figured similarly (the indoor allotment being the main difference.) An 1/0 water budget will have the traditional peak in the summer month as follows: 1/0 (Indoor uses AWC / Outdoor based on irrigable area) block 5 block 5 block 4 block 5 block 4 block 3 block 5 block 4 block -3 block 4 block 3 block 3 JAN DEC ATTACHMENT A ES- (Efficiency Standard) started June 2008 The Efficiency Standard option allows for a specific customized water budget. The customer must hire a professional engineer (PE) to evaluate and recommend a personalized indoor budget, which then must be reviewed and approved by the city. The customer is currently charged a fee for the city review. Because the ES is customizable, it can be set as the customer would like. No graph is displayed for this water budget as the ES water budget can be graphed to mirror any of the preceding usage patterns. If the Efficiency Standard water audit from the PE shows an increase in water use needed, that could result in the customer being switched to a PIF water budget (see below) PIF - (Plant Investment Fee) as of April 2, 2009 Currently the city uses a buy in approach where new customers connecting to the city's utility system are asked to pay a one-time capital charge to compensate current customers for their past investment. PIFs are also charged to existing customers who increase their projected usage of water and wastewater infrastructure or to existing customers who increase the amount of impervious area (stormwater /flood management PIF). When customers pay a PiF it's based on whether they purchase 25%, 50% or 85% of their meter based on the max capacity for that meter size. Max capacity is currently calculated by using the customer class average for each specific meter size. Once a customer is on a PIF water budget, Utility Billing can no longer make adjustments without approval from the Planning Department who manage the PIF system. If an efficiency audit uncovered that the customer needed a larger budget and the customer really used 45% of their meter but had only paid for 25%, the customer might have to "buy" the extra use on their meter or continue to pay the higher penalty block fees. If customers don't know this then it could even be a benefit to the customer to find this out as it could be cheaper to pay PIF than to continue paying in penalty blocks. For more information on PIF's please go to: http://www.bouldercolorado.gov/index.php?option=com content&task=view&id=7863&Item id=1189 ATTACHMENT B Set benchmarks For CII sub-sector water use (done outside of the UTB database) STANDARD CII WATER USE UNIQUE CII WATER USE Convert benchmark use (amount) into an ES water budget; ES amount based on sub-sector benchmark (At or below the benchmark) (Above the benchmark) (NO known benchmark) Customer should not have Offer audits to the customer Audit the customer to issues with their new water to determine the customer's Customer Customer determine budget their new budget; ES can be flat or needs efficiencies, employee refuses the refuses the ES water budget adjusted as needed count, etc. water audit water audit (AMU-waste=budget) NO VARIANCE VARIANCE Customer is Customer is Budget determined Budget determined given the same given a reduced to be adequate or NOT to be adequate; benchmark ES budget; a generous; customer has based ES water budget which is budget as the less than their investment in invested in best efficiencies are available efficient rest of their current use needed technologies sub-sector I - . . _F_ , T ANY REQUEST FOR A BUDGET INCREASE WILL REQUIRE AN INDOOR WATER AUDIT Requirements of the audit audit form, and metrics to be used to be determined by Staff & WRAB. Only 1 budget change is allowed in any given year. ATTACHMENT C r:~_+-.1 f~cr-z^a rw,.~ .•-.wr-rrr-:r rcr-~ T e{ ~ s.s ,~c W c1`-~rP ,(~`-tip' ;,grA ' yV.~1~m _ city of &X"-i brendle PREPARED FOR UTILITIES DIVISION, CITY OF BOULDER, COLORADO BY BRENDLE GROUP ATTACHMENT C 0 Brendle The contents of this report are offered for informational purposes only. The Brendle Group, Inc. and all sources referenced in this guide do not (a) make any warranty or representation, expressed or implied, with respect to the accuracy, completeness, or usefulness of the information contained in this report, or that the use of any information, apparatus, method or process disclosed in this guide may not infringe on privately owned rights; (b) assume any liabilities with respect to the use of, or for damages resulting from the use of, any information, apparatus, method or process disclosed in this guide. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by The Brendle Group, Inc. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 2 r ATTACHMENT C bren&e Contents Executive Summary .......................................................................................................................................4 1. Background 6 1.1. Objectives: City Council Direction 6 1.2. Current CII Water Budgets 6 1.3. Motivations for Improving CII Budget Approach 7 1.4. Normalized Water Use and Benchmark-Based Budgeting 7 2. Benchmark-Based Budgeting In Practice: other community experiences ..........................................10 2.1. MPWMD's Experience ................................................................................................................10 2.2. Lessons Learned From Monterey . 11 3. Methodology for Benchmarking in boulder .......................................................................................16 3.1. Water Consumption 16 3.2. Normalization., 17 3.3. Categorization .............................................................................................................................19 3.4. Review and Quality Control 21 4. Benchmarking Results 23 4.1. Demand Distributions and Benchmarks by Sub-Sector for Boulder CII Customers ....................24 5. Developing Budgets 26 5.1. Budgets for Analysis 26 5.2. Next Budget Development Steps 28 6. Implementing the Budget/Audit Hybrid Approach 29 Appendix A. Demand Distributions by Sub-Sector 32 Appendix B. Over Budget Customers By Sub-Sector ..................................................................................47 CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 3 ATTACHMENT C Brendle EXECUTIVE SUMMARY When the City of Boulder (City) first implemented water budgets in 2007, City Council directed staff to re-evaluate how commercial, industrial, and institutional (CII) customer water budgets could be better linked to water use efficiency. The City's Water Resources Advisory Board (WRAB) recommended staff begin analysis in 2009 and after testing several concepts, in November 2011 WRAB asked that staff conduct a more in-depth review of benchmark and audit-based methodologies for establishing C11 water budgets. While City staff members continue to work on the project, this report conveys the results of the review and analysis effort as of February 2012. Using benchmarks to establish water budgets for Cil customers has the potential to satisfy both criteria considered priorities by WRAB, that water use budgets be linked to the efficient use of water and that establishing the efficient use of water be done in a fair and equitable way. First, these budgets use a comparison of normalized water use between peer customers which, assuming that peer water use represents a full spectrum from efficient to inefficient use - theoretically links the budget to the efficiency of water use. A particular customer would have to be more efficient than a selected percentage of their peers in order to be at or under budget. Second, this approach to establishing the budget can be fair and equitable because it uses the range of existing water use practices among peer customers to establish the definition of efficient. By looking to the "market" to set budgets, the resulting budgets should be attainable. For those customers with unique uses or circumstances, an audit-based alternative path would be used to establish a fair water use budget. This study resolved 29 sub-sectors, or peer groups, and prepared distributions of normalized water consumption for each one (see Table 2-1 and Appendix A). These sub-sectors include offices, retail, gas stations, supermarkets, and many of the other common Cll customers one would expect. Hypothetical water budgets were developed for the City's CII customers using 2011 water use data at the 75th, 85tH 90th, and 95th percentiles, as directed by WRAB, of their sub-sector distributions. These budget options will be used to refine the process of budget development and analyze the implications of setting the budget benchmark at different percentiles. From the experience of conducting this study and literature review, it is clear that the benchmark-based budgeting approach has potential benefits and shortcomings (see section 2). Of the shortcomings, many of these can be mitigated, however, through the design of the budget approach such as selecting a higher percentile use to define over budget (e.g. 75th or higher as suggested by WRAB). One persistent challenge is the categorization of CII customers into sub-sectors. With the available data in Boulder, the categorization completed for this study is very preliminary, Should the City pursue the benchmark- based approach, it is recommended that the City provide customers a "budget preview" period during which the customers can self-report their sub-sector. Complementing the benchmark-based budget approach is alternative water audit path for establishing an efficient and fair water use budget. Through this hybrid approach, the City will have a flexible alternative for establishing water use budgets for customers with unique uses or circumstances unlike their peers. In parallel to this study the City is preparing a water auditing process and associated tools and auditing resources to support CII customers. In 2013, the City will pilot 30 basic CII audits and 10 more involved audits, including process water uses, in order to prepare the audit path. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP I 4 brendle ATTACHMENT C As further analysis and consideration of the hybrid benchmark and audit-based budgeting approach is completed there are many design considerations that will have to be resolved if the City chooses to pursue this approach. First, selecting a percentile at which to establish what use is under and over budget will determine how many customers are impacted and the revenue impacts to the Utility. Consequently, if revenue impacts to the Utility are negative, it might be possible to modify how such budgets are implemented. For example, the new budgets could be implemented only for those customers that are over the selected benchmark percentile while maintaining the historically-based budget for customers under the benchmark. This could preserve the revenue stability for the Utility and budgeting expectations of most customers while still providing a pricing signal and opportunity for those customers that appear to be the least efficient. Pursuing a hybrid benchmarking and water audit approach to CII water use budgeting has the potential, if designed to mitigate the potential problems identified in the study, to result in a water use budgeting approach that meets the City's goals of tying water budgets to efficiency and establishing an equitable approach to defining efficient use. Even if a benchmark-based budget approach is not pursued, the benchmarks generated by this study can still be a useful tool for the City's Water Conservation Department to target outreach efforts and resources. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 5 ATTACHMENT C brendte t BACKGROUND 1.1. OBJECTIVES; CITY COUNCIL DIRECTION When the City of Boulder (City) first implemented water budgets in 2007, City Council directed staff to re-evaluate how commercial, industrial, and institutional (CII) customer water budgets could be better linked to water use efficiency. The City's Water Resources Advisory Board (WRAB) recommended staff begin analysis in 2009 and after testing several concepts, in November 2011 WRAB asked that staff: "...continue the Cl/ study utilizing a revised approach that incorporates both benchmark and audit-based methodologies and with a purpose statement that the overarching goal of the project is to improve the process for developing Cl/ water budgets such that they fairly and equitably establish an efficient level of water use. "1 This recommendation established the directive for staff to conduct a more in-depth review of benchmark and audit-based methodologies for establishing CII water budgets. While City staff members continue to work on the project, this report conveys the results of the review and analysis effort as of February 2012. 1.2. CURRENT CII WATER BUDGETS The City's CII customers can currently choose from one of the following five water budget options:' • Average Monthly Use (AMU) - This is the default option. The AMU budget is calculated using the historical average of 12 consecutive months of water use for that Budget? What is a Water account, so that every month's water budget is the same. A water budget is the basis Customers can now apply to change the timeframe used for a water rate structure for the 12-month average. (The default timeframe is that establishes the amount January through December 2005.) of water a customer is • Historical Monthly Use (HMU) - The HMU budget is expected to need for a calculated using a rolling three-month average for each specific month. The water individual month. For example, the average of use for the budget only applies to past three Januarys would be next year's January budget. water-use charges. • Indoor/Outdoor- The Indoor/Outdoor budget is comprised of both an indoor and outdoor water allocation. The indoor allocation is based on the most recent Average Winter Consumption (AWC), which is the average water use for that account for December through March. The outdoor allocation is calculated based on irrigable area, including right of way, and seasonal watering needs. • Efficiency-Standard - This option allows for a specific customized water budget. The customer must hire a professional engineer to evaluate and recommend a personalized indoor water use budget, which then must be reviewed and approved by the city. The customer will be charged a fee for the City review. • Plant Investment Fee (PIF) Water Budget- Customers with a new or redeveloped use that increases water use and places increased demand on the City's water system will be placed on the CII PIF custom annual budget, which is 25, 50, or 85 percent of the AWC for a specified meter size.3 CITY OF BOULDER, COLORADO I 2Ci3 CA CCNSJ"aPTION SEi~CHMARKS ANJ DLDGETING I BRENDLE GROJP 6 ATTACHMENT C 0 Brendle The current CII water budget approach was approved in 2004, designed in 2005, trialed in 2006, and fully implemented in 2007 with ongoing improvements such as the introduction of the HMU budget type in 2008. 1.3. MOTIVATIONS FOR IMPROVING CII BUDGET APPROACH There are two primary limitations with the City's current approach to C11 water budgets that a new budgeting approach may be able to address. The first limitation is that the City's current CII water budgets do not have any relationship to the efficiency of water use by the customer. Most of the budget types are based on historical water use for the customer, which could include poor operational practices, inefficient water-using equipment and fixtures, leaks, and/or water waste. Customers can also apply to change the timeframe for AMU budgets and receive larger budgets by selecting the periods with the highest use. The structure of these budgets does not highlight opportunities for more efficient use of water, nor does it encourage CII customers, through pricing signals, to act on those opportunities, Even though the current budgeting approach does not link budgets with efficient use, indoor water use in Boulder's C111 sector has declined over the last 12 years.4 In fact, the CII sector has shown the sharpest decline in use when compared with single-family and multi-family customers. As a result of the efficiency gains made in the CII sector, the Water Conservation Futures Study Update Preliminary Analysis (AMEC, December 18, 2012) proposes to maintain the City's CII goal at the current use of 50 gallons per capita per day (gpcd). If this goal is adopted, there is no immediate imperative to drive water use efficiency by linking budgets with efficient use. Instead, putting this link in place would prepare for the City to use budgets as a conservation tool in the CII sector should more stringent goals emerge in the future. The second limitation of the current CII water budgets is that they do not facilitate establishing the efficient use of water in a fair and equitable way. For example, assume that the City wanted to encourage greater water use efficiency using the current water budgeting approach. The City could, hypothetically, reduce all water budgets uniformly (e.g., by 2%) to achieve a desired conservation impact. For customers with some inefficiency to address this approach may work fine. Customers already using water efficiently, however, would be unduly penalized if they are not able to operate within the newly established budget. Establishing a link between budgets and efficient use of water and defining efficient use in fair and equitable terms are the two primary criteria considered by the WRAB in recommending additional review of a combined benchmarking and auditing approach to CII water budgeting. 1.4. NORMALIZED WATER USE AND BENCHMARK-BASED BUDGETING Normalized water use defines the quantity of water consumed in terms of a normalizing factor such as number of consumers, square feet in a building, or seats in a restaurant. The previously mentioned gpcd is one example of a normalized expression of water use. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 7 brendle ATTACHMENT C Quantity of Water Consumed (Total use, AWC, or other) City of Boulder and Water Use Benchmarking Some Normalizing Factor by Sector (Square footage, seats in restaurant, etc.a The City participated in a Figure 1-1. A Water Use Benchmark Northern Colorado benchmarking study of four Normalized water use can be a useful tool for comparing Cil sectors in 2007..and is water use efficiency between entities that are generally currently a ' similar but have some key differences that influence how benchmarking study with they use water - such as size. For example, consider the Hazen and Sawyer' ana the American Water Works hypothetical comparison of water use in Office A and Office Association (AWWA). B. Office A uses twice as much water as Office B. Without any additional information, this comparison does not convey much about the water use efficiency in either office. Office A could be twice as big as Office B, have twice as many occupants, and/or have inefficient water fixtures. Assuming, as one scenario, that Office A is twice as big as Office B, their normalized use - water use divided by square footage - would be the same. Comparing normalized provides some indication that water use efficiency between the buildings may be similar. There are certainly other factors that influence water use that are not directly represented when normalizing by just one factor, such as the number of occupants and hours of operation in this example case. These other factors that impact consumption can be partially addressed by categorizing water users such that their differences are minimized. In doing so, more refined comparisons can be made from offices to offices, restaurants to restaurants, and so on. By considering the distribution of normalized water use for a particular subset of customers, water use benchmarks can be established. The 50`h percentile of the distribution, or median, might be representative of the "typical" customer in that subset, the 25`h percentile representative of an efficient customer, and the 75`h percentile representative of a customer with an opportunity to reduce use to be more aligned with the peers in their subset. With a benchmark established by selecting a desired threshold in the distribution of existing normalized use (more discussion of the process for selecting that threshold follows in Section 6) customer budgets can be established by multiplying their particular normalizing factor by the selected benchmark. For example, if Office A is 10,000 square feet and the budgeting benchmark for offices is 0.015 thousand gallons per square foot per year, Office A would have an annual water budget of 150 thousand gallons (kgal), which is equivalent to a monthly budget of 12.5 kgal. The City's existing block rate structure would then be applied to the customer's actual use relative to this budget as is done today.5 Using benchmarks to establish water budgets for CII customers has the potential to satisfy the criteria established by the WRAB and the larger concerns of Council while being equitable to CII customers. First, these budgets use a comparison of normalized water use between peer customers which, assuming that peer water use represents a full spectrum from efficient to inefficient use - theoretically links the budget to the efficiency of water use. A particular customer would have to be more efficient CITY OF BOULDER, COLORADO 1 2013 C11 CONSUMPTION BENCHMARKS AND BUDGETING I ARF'JDLE GRDUP 1 8 ATTACHMENT C 0 brend[e than a selected percentage of their peers in order to be at or under budget. Second, this approach to establishing the budget can be fair and equitable because it uses the range of existing water use practices among peer customers to establish the definition of efficient. By looking to the "market" to set budgets, the resulting budgets should be attainable. Over budget customers in this budgeting approach also stand to gain efficiencies that will make them more competitive with their peers and less sensitive to drought restrictions. Some other potential benefits of a benchmark-based budgeting approach include: • The City already has some experience in benchmarking CII customerslo; • The resulting water use benchmarks can be useful planning tools for Utilities; • The approach is consistent with how budgets are set for residential customers; • This approach can be implemented in the existing utility billing database (UTB); and • This single approach could be implemented in lieu of maintaining multiple CII water budget types. CITY OF BOULDER, COLORADO 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 9 ATTACHMENT C Brendle 2. BENCHMARK-BASED BUDGETING IN PRACTICE: OTHER COMMUNITY EXPERIENCES There are a number of communities nationwide, like the City, which currently have or have previously had CII water budgets based on historical customer use. These communities include but are not limited to the City of Corona, California; Moulton Niguel Water District, California; Laguna Beach County Water District, California; the Town of Cary, North Carolina; and Aurora, Colorado. Of all the communities budgeting CII water use, only the Monterey Peninsula Water Management District (MPWMD) was identified as having implemented a benchmark-based budgeting approach for a broad range of CII sub-sectors. In order to establish a potential approach for the City, the first consideration was what has and has not worked for other communities. The MPWMD case study offers a lot of lessons for the potential implementation of a hybrid benchmark and audit-based approach in the City. The following two sections explore in more detail the outcomes of MPWMD's application of benchmark-based budgeting and potential mitigation approaches the City could use to address the issues that MPWMD faced. 2.1. MPWMD'S EXPERIENCE The MPWMD is a water provider in southern California that serves a population of over 100,000 people and over 1,700 CII accounts in coastal communities near to and including Monterey. The MPWMD is mandated to reduce its customers' water consumption by California law. Benchmark-based water budgets were implemented for 54 CII sub-sectors in 2000 as a water conservation tool. The budgeting benchmark is the 50th percentile, which is very aggressive, such that any customer above the median will be over budget with over budget rate blocks rising to nearly $30/kgal. In 2011, MPWMD commissioned a study by A&N Technical Services, Inc. to review the practices for defining the benchmarks - which are called water-use factors by MPWMD - and to develop updated benchmarks. The results of this study convey some lessons that should inform the City's consideration of benchmark-based budgeting and its eventual implementation should the City pursue this approach.' The study concludes that, "it is difficult to see how a non-residential rate structure can be implemented on the existing definitions of Non-residential Water Use Factors." The primary reasons the study identifies that a benchmark-based budget can be impractical include: 1) The normalization factor, or measurement unit, like square footage, was missing for 38 percent of active CII accounts. The MPWMD used over 10 different normalization factors depending on the customer's sub-sector including square footage, acreage, number of seats, number of rooms, etc. 2) The reliability of normalization factors is unknown. The MPWMD's normalization factors were collected, at least in part, from customer surveys. 3) The use of a single factor to normalize doesn't account for all the factors that influence customer water use and leads to an inaccurate definition of efficient water use. There was a wide variation in CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 10 brendle ATTACHMENT C normalized water use in individual sub-sectors with just a single factor considered. The MPWMD sets the benchmark for budgeting at the 501h percentile, so it is particularly important that the benchmark accurately describes the water use efficiency of the customer because any customer that uses more than the median will be over budget. 4) Steep escalation in rate blocks can make uncertainties unacceptable. The MPWMD's highest rate block is nearly $30/kgal, which makes the penalty for being over budget severe. This severity is exacerbated by the number of customers potentially affected by setting the benchmark at the 50`h percentile. A follow-up interview with the study's author from A&N Technical Services, Tom Chestnutt, confirmed the above issues, and he elaborated on another issue.' There were insufficient numbers of customers by sub-sector in MPWMD's territory to develop robust distributions and benchmarks for smaller sub- sectors. In other words, statistically it was impractical to establish a benchmark in sub-sectors that had only a few customers. In addition to the technical concerns raised by the study, MPWMD also convened stakeholder input sessions as part of the study process. Some of the stakeholder concerns included: • Budgeting based on historical usage data punishes successful businesses; • Businesses vary significantly within sub-sectors and standardizing is not fair; • The baseline year for water consumption had adverse economic conditions that lowered water consumption (e.g. lower occupancy in hotels) which set an unfairly low standard; • The potential for customers to be mis-categorized; and • The availability and content of existing non-residential water auditing services is insufficient to help over budget customers improve. As a result of these issues and challenges in implementing the benchmark-based budgets, MPWMD is now seeking approval for a new approach of establishing CII water budgets that is based on a prescriptive list of best management practices that Of customers must implement.8 Despite the challenges faced by MPWMD in implementing this particular approach to benchmark-based water use budgets, the potential benefits of a benchmark-based budgeting approach remain appealing. As a tool for measuring the efficient use of water, establishing equitable water use budgets, and targeting water conservation resources; benchmarks continue to be a sought after standard as evidenced by the benchmarking work underway by the AWWA - a study in which the City is a participant. The next section explores opportunities for the City to mitigate the challenges faced by MPWMD to effectively implement a hybrid benchmark and audit-based approach. 2.2. LESSONS LEARNED FROM MONTEREY While the issues identified in MPWMD's study of their benchmark-based budgeting are not wholly encouraging for other communities considering this approach to water budgeting, it is important to remember that the circumstances are different between MPWMD and the City. The City has more freedom in designing a benchmark-based budget than MPWMD did. Table 2-1 summarizes the key issues and mitigation approaches. Table 2-1, Summary of Potential Benchmark-Based Budgeting Issues and Mitigation Strategies Issue Mitigation Strategy Missing normalizing factor data (e.g. square Apply Boulder County Assessor square footage data, footage) which is available for almost all customers CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 11 ATTACHMENT C brendle Issue Mitigation Strategy Reliability of normalizing factor Assessor data is reliable Single factor doesn't account for water use Use higher benchmark for budgeting (e.g. 75th percentile and offer an audit path Steep escalation in rate blocks Use higher benchmark for budgeting (e.g. 75'h percentile); rate block escalation not as steep in Boulder Too few customers per sub-sector Use fewer sub-sectors so there are more customers in each one Budgets based on historical use punishes success Benchmark may help to alleviate this if the space also grows in proportion to water use; offer an audit option Use higher benchmark for budgeting (e.g. 75th Variation in customers within sub-sector percentile); offer an audit path Baseline year for water consumption had adverse Use higher benchmark for budgeting (e.g. 75th economic conditions that lowered water percentile); offer an audit path consumption "Budget preview" year provides customers chance to Mis-categorization of customers change category; establish process for updating custome categories Availability and content of existing non-residential Audit resources are being prepared to support audit pat water auditing services With strong regulatory drivers, MPWMD was mandated to reduce customer water consumption and sought to implement C1I water budgets as an aggressive conservation tool. As such, the benchmark for over budget use was set at the SOth percentile such that a significant portion of the customer base might be over budget. Furthermore, the rate blocks escalated significantly to nearly $30/kgal. Audits were offered, but more as an exception than as part of a hybrid approach intended to equitably establish water use budgets. MPWMD also only offered one water use profile to customers. This profile allowed the same amount of water use per month throughout the year like the City's AMU. At the end of the year MPWMD would "true-up" the difference between the customer's annual budget and annual use and credit the customer if they were under budget for the year. This approach inconvenienced customers and created significant administrative challenges and revenue uncertainty for MPWMD. As previously indicated, the City does not have an imperative conservation goal for the CII sector and can therefore use a less aggressive budgeting benchmark (e.g. the 75th percentile or above as WRAB recommended for consideration), which means fewer customers will be over budget and the approach will be fairer considering the uncertainties of categorizing CII customers into sub-sectors. The City's block rate structure is also less aggressive compared with MPWMD, with Block 5 topping out at $15.45/kgal.5 A hybrid approach to budgeting has been proposed that uses audits more broadly to ensure that CII customers have reasonable and equitable water use budgets. The City would also maintain the current budget profile options (e.g. AMU, HMU, 1/0) in order to accommodate the seasonal variations in customer use and eliminate the need for the annual "true-up". The implications of each of the other technical issues identified by the MPWMD have been considered and possible mitigation options for the City of Boulder are discussed as follow: 1) Availability of normalization factor: For the purpose of this study, the City has elected to use only square footage as a normalizing factor for all sub-sectors. Since square footage data is readily CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 12 ATTACHMENT C 0 Brendle available for almost all CII accounts, this largely resolves this issue. Square footage may not be the best descriptive factor for all sub-sectors - restaurant water use, for example, may be better correlated with number of seats9 - but may be sufficient considering the previous point about the probable application of these budgets with a higher budgeting benchmark percentile. 2) Reliability of normalization factor: The City may avoid some of the uncertainty associated with customer surveys by using square footage data from the Boulder County Assessor. There is uncertainty, however, in applying this information source in matching the appropriate square footage with water use in the space. This issue is described further in the Methodology Section. 3) Use of a single normalizing factor: A single factor will not fully account for the water use of a customer and using the same factor for all sub-sectors will likely exacerbate this issue. However, a single factor may be sufficient to identify those customers that have the biggest opportunity for decreasing water consumption. Applying a higher percentile for the budget and offering water use audits as a complementary path to establish a budget will also mitigate this issue. The City can also expand the number of sub-sectors where disparities are identified and can be linked with a specific characteristic. For example, separating full-service from limited-service restaurants. 4) Escalation of rate blocks: The City's rate blocks do not escalate as significantly as MPWMD's so the economic penalties for over budget customers are not as extreme. It is important, however, that the City apply any budget with caution such that customers are not unduly impacted. 5) [Number of customers per sub-sector: With a similar number of Cil customers to MPWMD, it is to be expected that the City will have similar issues with some sub-sectors having too few customers to establish a robust benchmark. Therefore, this study's methodology categorizes the customers into 29 sub-sectors instead of the 54 used by MPWMD. The tradeoff is that this increases the range of variability within a sub-sector and reduces the resulting quality of the distribution from which the benchmark is determined. As previously stated, quality of the benchmark is less imperative if higher percentiles (e.g. 75th or above) are used to establish the budgeting benchmark. In addition to the technical issues examined above, the stakeholder input received by MPWMD also deserves consideration by the City for potential lessons learned: Budgeting based on historical usage data punishes successful customers: This is true of the City's current CII water budgets as well. If a customer grows and their water use increases, they will exceed their budget based on their own historical use until they contact the City to modify their budget. In a benchmark-based budgeting approach, a customer may have some room to grow depending on where they start in the spectrum of normalized water use of their sub-sector peers. In addition, because the benchmarks are based on water use normalized by square footage, customer growth with proportional growth in space would maintain a customer's normalized water use at similar levels. This is one of the potential benefits of benchmark-based budget. For customers that grow without proportional increases in space, such as adding another shift in the same space, a water audit option can be offered to determine if the customer is using water efficiently and establish a custom water budget accordingly. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 13 ATTACHMENT C % brend~e • Customers vary significantly within sub-sectors and standardizing is not fair: This is a legitimate concern and the problem may be exacerbated by this study's approach of using fewer sub-sectors such that small sub-sectors will have more customers for statistical robustness. This issue may be mitigated by setting the budgeting benchmark at a higher percentile - such that only the highest intensity water users are impacted and not those marginally higher than the median. It can also be mitigated by adding additional sub-sectors for specific differentiating characteristics may be identified. • The baseline year for water consumption had adverse economic conditions that lowered water consumption which sets an unfairly low standard: This study proposes to use 2011 as a baseline year - and for indoor use only - because it was the most representative and complete year of CII water use available when the consultant team and City staff began the study. A review of CII consumption in the City has shown that CII water use is declining over time, so it is important to select a recent baseline year that accounts for the savings being achieved by the ongoing replacement of older fixtures with newer fixtures that useless water.4 The years 2008, 2010, and 2011 were found to be similar in normalized use per capita. Potential for customers to be mis-categorized: This study attempts to categorize customers into sub-sectors based on a variety of data sources. There are many challenges in this process, however, that are discussed under the Methodology section. This issue is significant but can be mitigated during the "budget preview" year, prior to budgets taking effect, by providing customers the opportunity to change their sub-sector categorization. Audits, beginning now and continuing in subsequent years, can also be used to inform categorization. • Availability and content of existing CII water auditing services not sufficient: City staff and the consultant team have proposed to combine a benchmark-based budgeting approach with an alternative audit-based path that would help customers that are over budget or seeking a change in budget. The City has already begun development of this audit-based path and plans to offer audits in advance of any new budget implementation. The Implementing Budgets section discusses audit delivery in more detail. In short, a benchmark-based budgeting approach has potential shortcomings. Some of these were a result of the aggressiveness with which MPWMD implemented their approach and many can be mitigated through the design of budgets by the City. In particular, it is recommended that the City strongly emphasize the following elements should they pursue this hybrid benchmark and audit-based budgeting approach: 1) Provide a "budget preview" when customers can seethe new budget and its implications on their bill before they are actually billed on the new budget. This trial period could be initiated with outreach that explains the new budget and offers clear guidance and mechanisms for changing categorization and normalizing square footage. This will be important for addressing the uncertainties in customer categorization that are discussed in the Methodology section. If the City chooses to do so, it is recommended that the trial period be long enough to provide customers ample opportunity to adjust their category. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING BRENDLE GROUP 14 brenck'` ATTACHMENT C 2) The City would greatly benefit from having a well-established audit process and available auditors that provide an alternative method of establishing budgets for customers that are requesting larger budgets or are over budget when the new approach is implemented. CITY OF BOULDER, COLORADO 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 15 ATTACHMENT C brendle 3. METHODOLOGY FOR BENCHMARKING IN BOULDER Before benchmark-based budgets can be developed, water use benchmarks by sub-sector must be determined. Benchmarks are available in water use literature, but these are somewhat limited and not necessarily representative of CII water use in Boulder. The City's previous participation in CII benchmarking in 2007 provided a foundation for the preliminary consideration of budgeting approaches - prior to this study - but was too limited in scope (only four sub-sectors) and dated (2005 consumption data) to be relevant to this consideration.'() Therefore, the first step of this project was to establish CII sub-sector benchmarks for the city. There is no single data source available in Boulder that combines water use, square footage, and sub- sector categorization for CII customers. Therefore, the process of creating benchmarks is one of integrating a number of data sources into a single set that contains this information. This benchmarking effort can be considered in four phases as shown in the figure below and described in the following sections. tiv ,1 n i ~~1 sK~ ~~F _ 'I 3.1. WATER CONSUMPTION Developing benchmarks began by determining the numerator of the normalized water use - water consumption -for each CII customer. Quantity of Water Consumed (Total use, AWC, or other) Some Normalizing Factor by Sector (Square footage, seats in restaurant, etc.) As previously mentioned, water consumption data for calendar year 2011 was selected as the baseline from which benchmarks were determined. The year 2011 was the most recent complete calendar year in terms of data on water consumption at the time this study was undertaken. Preliminary data from the draft Water Conservation Futures Study Update (WCFS Update), which is currently underway, indicates that 2011 had similar water consumption to 2008 and 2010 and will be reasonably representative of trends toward increasingly efficient end-use of water.4 This indicates that 2011 is probably a reasonably achievable level of water use, particularly if the budgeting benchmark is established at a higher percentile. Another important reason for selecting a very recent year of consumption for developing benchmarks is that it will limit the customer categorization required to apply the benchmarks as budgets. The older the consumption data used in the benchmarking, the more effort that will be required to categorize all of the customers that have moved or been added as new customers since the baseline year. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 16 ATTACHMENT C 0 Brendle A dataset containing water consumption information and relevant account information (e.g. address, irrigable area, AWC, etc.) for Boulder customers in 2011 was prepared by Daniel Fairchild, City of Boulder IT, and provided to Brendle Group in May 2012. This dataset served as the foundation for the benchmark development. To prepare this dataset, all account types not considered part of CI1 were first removed. This included all the account types that led with an "F", "M", "R", or "U", which represent multi-family, metered irrigation, residential, and municipal accounts. Next, any accounts that were labeled "municipal", "sewer only", or "bulk water" in the "Street APT" field, which is used for notes, were removed at the direction of Russ Sands, City Water Conservation Program Manager. This resulted in 2,038 CII accounts. The benchmarks are intended to represent indoor use in each sub-sector. Outdoor use is typically metered separately or addressed with the 1/0 budget. That said, there are still some accounts that irrigate on the same meter as indoor use and do not have an 1/0 budget. It is desirable to exclude as much outdoor use as possible from the benchmarks so that they are not skewed upwards, but without excluding other seasonal variations in water use (e.g. a restaurant with more summer traffic). Two approaches were used to identify and exclude outdoor uses. First, approximately 4.5 percent of CII accounts were on indoor/Outdoor (1/0) budgets in 2011, indicating the presence of an irrigation component in their total water use. Some customers, however, are not on the 1/0 budget and have not reported irrigable area to the City. Second, Brendle Group attempted to identify those accounts practicing significant irrigation but that have not had their budget adjusted to the 1/0 format. For the CII accounts that have sub-metered irrigation, the median ratio of outdoor to indoor consumption was 1.38 and the average ratio was 12.3. Based on this examination of existing sub-metered irrigation, it is possible that meters with increases in summer consumption of a similar magnitude are irrigating. The CII accounts with a ratio of summer consumption to total consumption based on AWC' for the year of greater than 1.5 were assumed to be irrigating. For all accounts that appear to be irrigating, annual consumption based on AWC is used in benchmarking to exclude likely outdoor use. This applied to about 21 percent of CII accounts. For all other accounts, total annual consumption was used to develop the benchmark. 3.2. NORMALIZATION The next step to developing benchmarks was to determine the denominator of the normalized water use - in this case square footage -for each CII customer. Total consumption in April through September minus average winter consumption (AWC) - average consumption in December through March when there should be little or no irrigation -for those 6 months. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 17 ATTACHMENT C brendk Quantity of Wafter Consumed (Total use, AWC, or other) Some Normalizing Factor by Sector (Square footage, seats in restaurant, etc) The City elected to use square footage as a normalizing factor for all sub-sectors because it is widely available for CII accounts, it is relatively reliable data, and it can be readily sourced from the Boulder County Assessor. Furthermore, by using only one factor from a single source, future updates to the benchmarks will be easier to carry out than if multiple factors had been used. It was known at the outset, based on additional analysis of the data from the 2007 Northern Colorado benchmarking effort in which the City participated, that factors besides square footage are better indicators of water use in some sectors. 11 Seats in a restaurant and employees in a school are examples. The City felt, however, that the benefits of a single and reliable normalizing factor would be more effective than multiple, less reliable data sources. Square footage offered a common and consistent data source for which any changes were already captured by the City through the permitting process. Thus, the benefits of using a single normalizing factor appear to outweigh the benefits of using multiple factors - particularly when coupled with a relatively high benchmark. This approach also would reduce the costs and the complexity of any potential programming into the utility billing system. Two parcel databases were provided in May 2012 by Sean Metrick, the City's Senior GIS Specialist. The first database included Boulder County Assessor data that included square footage by parcel number. Parcel number is not an available field in the UTB. The second database provided was a personal property database that included parcel number and property address. This database was used to link the square footage in the Assessor's data with the customers in the UTB. Though addresses can be complicated by different formats, spacing, or added information (e.g. street direction), the two datasets matched relatively well. Brendle Group made minor modifications to about 120 addresses in the consumption dataset to remove extra spaces and hyphens, or to clarify intersection addresses such that they would match with the parcel databases. After this process, about 44 percent of the customer accounts had not matched a square footage either because there was no matching address in the personal property database or there was a mismatch in the addresses between the databases. A list of these accounts was provided to Sean Metrick, who was able to provide geo-located matches for them using the City's GIS system. The parcel databases included square footage for building features and improvements that would not have any impact on indoor water use (e.g. parking garages and decks). It was therefore necessary to determine areas that would or would not have an impact on indoor water use and be relevant for inclusion in the benchmark. Each address had one or more square footage records that described the multiple building styles or types at the address. Generally, building styles seem to relate more to building use (e.g. bank, daycare, etc.) while the building type relates more to the type of structure/improvement (e.g. duplex/triplex improvements, lodging improvements, etc.). Since the building styles field was more clearly related to use, this field was used to identify building uses that related to water use. For example, square footage for a "bank" building style was included, but square footage for a "deck area" or "patio" was not since it would not impact indoor water use. This is similar CITY OF BOULDER, COLORADO 1 2013 CII CONSUVIPTlCN BENCHMARKS AND BUDGETING I BRENDLE GROUP 18 brenale ATTACHMENT C to the approach applied in a benchmarking effort in Florida that used heated square footage as a normalization factor.12 Many of the building style or building type records also provide some indication of intended use for which the building was originally built (e.g. car wash). This information was retained so that it could also contribute to the categorization of the customer. 3.3. CATEGORIZATION To compare the customers' normalized use, each customer must be categorized into a sub-sector representative of their use. There was no single data source identified that covered the entire CII customer set and provided clear categorization. Numerous datasets, summarized in Table 3-1, were considered in determining the sub-sector for each customer. Table 3-1. Data Sources Used in Categorization % Last Update of Customers F. Source Category Data Type • Categorization Approach North American Industry 2008 Six-digit code Address (separated 51% Classification System representing industry from single string) (NAICS) Original property Building styles and u Parcel data record building types sometime Address 98/0 imply use Landlink Permit Database- Date of permit Restaurants Address 6% Restaurants Landlink Permit Date of permit Hotels Address 2% Database - Hotels Utilities Backflow Last inspection Observations from last Service key and payer 9% Prevention Databas inspection account numbers Each of the datasets has positive and negative attributes with respect to categorization. The NAICS dataset has the advantage of being the most recent data, providing decent a . coverage of the CII accounts, and offering a fairly high detail - up to six digits where each adds another layer of distinction - defining the industries at an address. The disadvantage of the NAICS dataset is that it can be a better description of industry ' than of water using activity for the customer. For example, a 3-digit NAICS code of "Heavy and Civif Engineering ° Construction" could refer to an office space where these . P f types of projects are designed, or it could refer to an . 0 . 0 equipment maintenance building for construction equipment • e . used in the field on these types of projects. These buildings . , , . . are both in the same industry but their indoor water uses . ° . might be very different. The parcel data matches an even larger portion of the CII customer set. However, the CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 19 ATTACHMENT C Brendle categorization implied by some of the building styles and types are often vague with respect to how a space might use water (e.g. industrial office). These descriptions are also potentially dated and the building use could be very different than what was permitted at construction. Due to these attributes, some of the datasets are more useful than others for categorization. Also, the datasets were frequently in conflict with each other. These conflicts can probably be attributed to many factors, including their temporal differences (e.g. parcel data category assigned at time of construction, NAICS assigned in 2008), differences in categorization approach (e.g. parcel data by building use and NAICS by industry), and interpretation. As such, it was necessary to establish a hierarchy for which categorization sources would take precedent. The sources were considered in the following sequence: 1. NAICS (newest, highest resolution); 2. Parcel data (most complete, sometimes provided clarity where an industry's water use was unclear in NAICS); and 3. Landlink Permit databases and Utilities backflow prevention database (where neither NAICS nor parcel data provided any clear indication of water use). The NAICS dataset offered a range of resolutions for categorization because each additional digit after the first two represents increasingly specific industry categories. For example, 2-digits represent a broad industry like "Agriculture, Forestry, Fishing and Hunting" and 6-digits represent a very specific sub-category like "Potato Farming". As the following table demonstrates, the number of digits used in categorization has a significant impact on the number of categories represented by the City's customers. As the number of NAICS digits used is increased, the specificity increases, the number of categories present increases and the number of customers in each category decrease. Table 3-2 presents the total number of categories from NAICS as well as the other data sources that were applied when there was no match in the NAICS dataset. Table 2-2. Number of Categories in Analysis with Depending on NAICS Resolution Resulting # of # of Categories NAICS Level Categories • Categories withi (digits) Cll Customers Customers 1 C111 Customer 2 122 73 55 3 170 100 65 4 251 166 95 5 319 238 148 6 342 263 167 To determine the level of NAICS resolution that was appropriate for establishing benchmarking sub- sectors, the categorization schemes from a number of other benchmarking studies were considered. It was known from MPWMD, a district with a similar number of CII customers, that it was difficult to establish robust benchmarks with 54 sub-sectors because there were too few accounts in some sub- sectors.6 A number of other studies were also reviewed for methodologies to establish distinct categories. 1314 With the intent of further consolidating categories where appropriate, three digits of the NAICS code were selected as a starting point. Starting with these 170 categories, Brendle Group conducted a manual consolidation process to combine categories that were similar between the various data sources and categories likely to have CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING BRENDLE GROUP 1 20 Brendle ATTACHMENT C similar water uses. For example, the category "church" from one data source was combined with the category "Worship" from another. There were also many categories that seemed reasonable to further abstract based on how they would likely use water. For example, "Clothing and Clothing Accessories Stores" and "Furniture and Home Furnishings Stores" were combined in the retail sub-sector. This process resulted in about 25 sub-sectors with just two sectors having less than five customers. A few additional steps were used to refine categories before moving on to the review and quality control phase. First, authors of studies documenting previous benchmarking experience and MPWMD's study identified significant water use variation among restaurants.s 10 In response, four digits of the NAICS code were applied in the restaurant sector to allow differentiation of limited-service and full-service eateries. Second, a study of water use by industrial customers in California was used to differentiate some light and heavy manufacturing from a water use perspective.ls This study found, for example, that beverage and textiles manufacturing were highly water intensive. Based on these findings, some of the manufacturing customers in the City were re-classified. Finally, there were many customers (32 percent) for which What sub-sectors were found? numerous NAICS codes were matched by address. These are most likely to be cases where a master water meter serves resolved This study 29 sub- multiple tenant spaces. Each of these cases was examined sectors which are individually. In some cases the NAICS codes represented summarized in Table 2-1. clearly similar uses (e.g. all different codes but clearly offices, These sub-sectors include retail, or medical offices). In this case, the customer was offices, retail, gas stations, classified as the dominant use. In other cases - about 9 supermarkets, and many of percent of all customers - the uses were too diverse to place the other common C11 the customer in a single category. These cases are mostly customers one would shopping centers or strip malls with a mix of retail, expect. There are a number restaurants, and potentially other sub-sectors represented. of sub-sectors that are still being investigated for These customers were left in a "Mixed" category and the City further specification is working on approaches for better characterizing sub- Including those related to sectors at each site. 3.4. REVIEW AND QUALITY CONTROL Once all the CII customers had been identified with a sub-sector the consultant team again reviewed results for quality control. This process included, for all customers, a comparison of the customer name (Payer name in the UTB) to the names associated with other datasets (NAICS, parcel database) to identify apparent incongruities in the sub-sector assigned to a customer. The distribution of benchmarks in each sub-sector was then considered with attention paid to any customer that was an outlier, either well above or below what was typical for the sub-sector. It was determined that there was a significant incongruity between the UTB customer name and associated fields in other datasets. This issue was traced back to a sorting error in the original UTB dataset provided by Utilities to the Brendle Group that had associated almost all the customer names with the wrong records. Once this issue was corrected, it revealed a second issue that this problem had masked. A large number of records that had appeared to be sub-meters because there were multiple CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 21 ATTACHMENT C / bre ndie customer names at the same address were found to be records representing newly opened or closed customer accounts. These records were appropriately merged with the rest of the data to accurately represent annual consumption for each customer. Once these issues were resolved, the service key and payer account numbers were used to map the completed sub-sector categorization to the newly revised UTB dataset and the normalized water use was recalculated for all customers. With this issue addressed, the review and quality control process resumed. Customers that were outliers were examined to ensure appropriate categorization and accurate summation of square footage. This process revealed, for example, a distribution in gas stations with two peaks, where the higher intensity water users had a car wash attached. The NAICS code, even with more than three digits applied, did not differentiate gas stations with car washes. As a result, Google Street View was used to confirm the presence of a car wash. Street View and web searches were used to further investigate the categorization of other outlying accounts as well. At the end of this process the number of outliers and the variation within most of the sub-sectors had been significantly reduced. The challenges of the categorization process and results of the subsequent review emphasize the importance of conducting a "budget preview" period (e.g. 1 year), prior to fully implementing any benchmark-based budgeting approach, during which customers can request re-classification to a different sub-sector. The issues inherent with merging so many datasets, with their own uncertainties such as dated information, are compounding. Furthermore, the consolidation process used to achieve a manageable number of categories introduces further uncertainty. Even the shift in customers and uses by address since the NAICS dataset was prepared in 2008 could be significant. As such, this preliminary categorization should be considered an informed estimate, which could be validated by a "budget preview" year that seeks customer self-reporting and applies the findings of water audits for customers with unique uses. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRFNDLF GROUP 1 22 ATTACHMENT C brenale 4. BENCHMARKING RESULTS Brendle Group generated a demand distribution for each of the 29 sub-sectors in the study, as exemplified in Figure 4-1. This figure shows the relative frequency for each bin of normalized water use as well as the cumulative frequency of occurrence. By selecting a percentile on the cumulative frequency (y-axis), one can find the intersection with the cumulative frequency line (red) and then determine the associated normalized use for that percentile. For example, in the case of offices, the 75th percentile is 14.3 gal/square foot. Demand Distribution for Office 3} - 100% r 90% 30% i`fJ 80% f7 ^ 25% 70% 3 N 60% rr W 20% C7 (D Cr L fD LL 40% .V a I~ 10% 30% 20% 5% - - J II 10%. 090 l I t ` 11 ■ 1 ■ ■ _s L a - OJo 0 12 24 36 47 59 71 83 95 IN 119 Gallons per Square Foot MRela(ivePreq -CumulativeFreq Figure 4.1. Example Demand Distribution Table 4-1 provides similar data in tabular form. Table 3-1. Example Benchmarks for Offices at Illustrative Percentiles (gal/scl.ft./yr) goth 95th 75th 85 14.3 25.3 34.5 53.2 CITY OF BOULDER, COLORADO 1 2013 Cli CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP I 23 ATTACHMENT C brend[e 4.1. DEMAND DISTRIBUTIONS AND BENCHMARKS BY SUB-SECTOR FOR BOULDER CII CUSTOMERS Demand distribution figures for each of the identified 29 sub-sectors selected by City staff are provided in Appendix A. Table 4-2 presents the number of customers and the benchmarks at the 75tH 85tH 90tH and 95th percentiles for each of the sub-sectors. Table 4-2. Benchmarks by Sub-Sector (gal/sq. ft./yr) Number . Sub-Sector Customers 751h Percentile 851h Percentile 990t' Percentile 95th Percentile, Auto dealer 25 15.3 16.8 18.8 19.6 Bar and beverage 10 131.2 142.7 224.7 383.1 Car wash 5 321.4 333.1 339.0 344.9 Daycare 14 64.6 74.6 89.6 117.3 Equipment repair 51 21.4 23.7 28.4 41.2 Gas and car wash 11 413.3 473.8 476.7 503.4 Gas station 20 79.5 108.7 119.4 164.3 Health club 8 49.8 53.1 73.4 96.8 Heavy manufacturing 48 354.2 613.1 710.5 1021.1 Homeowners Association (common 57 166.8 208.1 230.6 397.6 areas) Hospital 3 84.4 97.5 104.1 110.6 Industrial office 36 10.0 18.0 20.9 26.4 Laundry 2 820.8 928.1 981.7 1035.4 Light manufacturing 102 15.7 25.0 27.8 38.1 Lodging 68 77.0 102.2 118.6 143.4 Medical office 91 42.8 60.4 67,5 90.1 Mixed (many sub- 176 55.1 85.5 130.3 227.4 sectors on one meter) Nursing and residential 8 109.3 134.3 136.9 139.5 care Office 569 14.3 25.3 34.5 53.2 Other 26 33.8 37.6 44.2 133.7 Public events 14 5.7 9.7 13.4 38.2 Restaurant full-service 82 175.3 225.1 267.2 341.9 Restaurant limited- 48 133.9 169.8 207.1 248.0 service Retail 289 15.1 29.1 43.6 68.9 Salon and personal 14 32.1 74.6 86.8 98.3 services School 89 27.5 41.2 46.1 52.6 Supermarket 14 95.8 168.8 183.4 254.2 Warehouse 113 15.7 21.4 28.8 49.9 Worship 45 16.1 20.5 23.4 26.6 CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING BRENDLE GROUP 24 brendle ATTACHMENT C The resulting benchmarks from this effort were also compared to other benchmarks found during the literature review for this study, as shown in Table 4-3. It should be noted that sub-sectors seem similar between studies but the definitions used and the approach to categorization are likely different. Regional differences also play a role in the differing water use. Table 4-3. Boulder Sub-Sector Benchmarks Compared to Benchmarks from Other Sources (median gal/sq. ft./yr) Commercial and ENERGY City of Instimlo"All, STAR Boulder End Uses of . Porffollo Northern i' Manager"* SCVWD" Auto dealer 9.4 Bar and beverage 44.7 Car wash 212.1 Daycare 28.3 Equipment repair 13.6 6.5 Gas and car wash 340.7 Gas station 47.0 Health club 27.1 6.7 Heavv manufacturing 15.6 Homeowners Association (common 73.0 areas) Hospital 51.8 50.0 79.6 Industrial office 4,7 Laundry 552.5 Light manufacturing 7,8 Lodging 52.5 72.6 55.0 63.9 76.0 Medical office 16.2 8.1 20.0 120.1 Mixed (many sub- 17.5 sectors on one meter) Nursing and residential 82.8 60.0 203.3 63.0 care Office 7.0 14.2 6.6 15.0 19.3 Other 12.9 Public events 2.4 16.5 Restaurant full-service 75.2 306.1 159.0 Restaurant limited 50.6 service Retail 4.5 6.0 6.0 Salon and personal 12.4 services School 12.6 24.4 13.0 16.4 11.0 Supermarket 42.7 33.3 29.4 25.0 36.9 Warehouse 6.3 3.0 3.0 Worship 7.0 10.9 8.0 *Vafues are visual estimates from a chart. **This value is for high schools specifically. Note that sub-sector definitions between sources are not necessarily equivalent. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING BRENDLE GROUP 25 ATTACHMENT C Brendle 5. DEVELOPING BUDGETS With respect to water budgets, this study will conclude with the development of water budgets, the merits of which will be considered by staff, WRAB, and City Council. This process will highlight key aspects of budget development and provide information for decision making, but additional steps would be required to prepare budgets for implementation. The following diagram outlines the steps that would be required, including developing preliminary budgets in the UTB, conducting a "Budget Preview" period for customers, incorporating changes from the Budget Preview period into the budgets, and then rolling out and actually billing customers based on the new budgets. 1.1 j' ~ j ~ caWl1 ' ~3 I~ ~.r I i 5.1. BUDGETS FOR ANALYSIS In this study Brendle Group developed hypothetical water budgets for the City's CII customers using 2011 water use data at the 75tH 851n 90tH and 951n percentiles, as directed by WRAB, of their sub-sector distributions. These budget options will be used to refine the process of budget development and analyze the implications of setting the budget benchmark at different percentiles. While an average monthly allocation that is constant throughout the year will work for some CII customers, like in the current AMU budget type, there will be CII customers that experience more seasonal variability in their water consumption due to changes in occupancy, production levels, etc. To avoid having these customers over budget during the months of higher use, even though they may be on budget in the net for the year, the budgets for analysis include budget types that are effectively similar to those CII customers had in 2011. In other words, a customer on AMU in 2011 will still be on an AMU-like profile, but the budget amount is adjusted to align with the selected benchmark. Similarly, HMU budget types will still get the same HMU-like profile that reflects their seasonal variability, but that profile will be adjusted proportionally to reflect an annual amount in line with the benchmark-based budget allotment. By maintaining these flexible budget types, the City can continue to accommodate the unique water use profiles of CII customers. The customers with multiple users on a single meter, mixed meters, present another challenge for establishing budgets. In the budgets used for analysis, the mixed meters that appear to have homogenous sub-sectors on the meter (e.g. mostly offices) are included in their respective sub-sectors and assigned budgets accordingly. Those customers with heterogeneous uses on a meter (e.g. a restaurant, retail, and supermarket) are currently included the "Mixed" sub-sector. It is hoped that the Budget Preview period and water audits can better reveal the end-uses for each of these mixed customers. Depending on the outcomes of that process the City may choose to maintain a Mixed sub- sector or to allocate budget to these mixed customers based on be size of each of their sub-sector end users (e.g, 5,000 sq. ft. of restaurant at the restaurant benchmar plus 3,000 sq. ft. of retail at the retail benchmark, etc.). The culmination of the benchmark-based budget analysis will be selecting a benchmark percentile to use for budgeting. There are many considerations in this selection: CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 26 ATTACHMENT C brenclle • Magnitude of benchmark percentile: Lessons learned from the MPWMD case study indicate that setting a higher percentile benchmark (e.g. 75"' 85th 90th 95th etc.) will make the budgeting approach more fair considering the uncertainties of categorizing CII customers into a finite set of sub-sectors. A higher percentile is also compatible with the City's immediate intent, which is not aiming to drive down CII consumption but to link budgets to efficiency and motivate improvements by those with the biggest opportunities. Furthermore, there is precedent in the City for more lenient approaches in regulatory programs, like water budgets, such as the Performance Path requirements of the SmartRegs program.19 • One benchmark percentile for all sub-sectors or different benchmark percentiles for each sub- sector: Selecting a single benchmark percentile for all sub-sectors would be equitable between sub- sectors and simpler to implement. • Revenue impacts: The percentile(s) selected will also impact revenue generation for the City Utility. The budgets for analysis will be evaluated for their potential impacts on the Utility's revenue. • Number of customers over budget: In 2011, about 279 CII customers were over budget, where over budget is defined as three consecutive months in Block 4 or above. It may be desirable to maintain a similar number of over budget customers with the benchmark-based approach so that it is clear that the intent of the new approach is not to have more customers over budget. As indicated in the following table, by setting a uniform percentiles across all sub-sectors at the 85th percentile, roughly the same number of customers would be over budget as were in 2011, assuming similar consumption. The 85th percentile is also where the benchmark is set for the residential water budgets. Table 5-1. Estimated Number of Customers Over Budget Based on 2011 Consumption Benchmark-based Budget at SWAM 2011 Percentile Nurnber of Customers Budgets 7P 85th ge 951, At or under budget 1,759 1,643 11778 1,832 1,905 Over budget* 279 395 260 206 133 Still over budget (were in 2011 also) 148 112 96 75 Newly over budget 247 148 110 58 (were not in 2011) No longer over budget (were in 2011 but no longer) 131 167 183 204 Net negatively affected 116 -19 -73 -146 (newly over budget -no longer over budget) I _j 'Over budget is defined as three consecutive months in Block 4 or above. Total CII customers in the analysis is 2,038 (e.g. 1,759+279). It should be noted that the customs that were over budget in 2011 are not necessarily the same customers that would be over budget in a benchmark-based approach. For example, a customer that was over budget in 2011 may have grown their operation relative to their historic use but not requested an increase in their budget. That same customer may be using water efficiently relative to their peers and be under the budget in a benchmark-based approach. The previous table also indicates how a benchmark-based approach would affect customers including the number of customers that are still over budget (were also over budget in 2011), newly over budget (were not in 2011 but now are with the CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING BRENDLF GROUP 1 27 ATTACHMENT C 0 Brendle benchmark-based approach), and are no longer over budget (were in 2011 but are no longer with a benchmark-based approach). 5,2. NEXT BUDGET DEVELOPMENT STEPS Should the City choose to pursue a hybrid benchmark and audit-based budgeting beyond this analysis phase, there are a number of additional steps to prepare these budgets for full implementation. Brendle Group recommends the revenue analysis results be considered and the customers with the most significant revenue impacts be re-evaluated to ensure that the best classification of sub-sector has been made given available data. The analysis budgets can then be input into the UTB as preliminary budgets in preparation for the "Budget Preview" process. During this process, perhaps over the course of a year, customers will be given the opportunity to correct any problems with their sub-sector classification or square footage. If the customer corrections result in significant changes to the benchmark distributions, it will be necessary to re-establish the benchmarks at the end of this "Budget Preview" year and recalculate the budgets accordingly. At this point the City could roll-out the final budgets and begin billing according to them. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 28 ATTACHMENT C Brendle 6. IMPLEMENTING THE BUDGET/AUDIT HYBRID APPROACH A tentative schedule for implementing the benchmark-based budgeting approach, should the City decide to pursue this approach, is presented in the following figure. It is anticipated that the new budgets could be launched in 2016. 2013 2015 -Decision to -"Budget Proceed/Not Preview" Proceed -Customer Continued Response on Design Categorization 2014 2016 Finish Design -Full Launch Preliminary Implementation in UTB Figure 6-1 Proposed Implementation Schedule After 2016, this approach to budgeting will continue to require some maintenance. Brendle Group recommends that a process be established to update the budgets based on changes in customer use. There are a number of mechanisms under consideration for triggering these updates including the issuance of a building permit, the annual backflow inspection process, and customer inquiries for new accounts. An update is currently being considered for the Landlink permitting system that may include better linkages to the UTB. The City could motivate additional conservation in future years by ratcheting down the percentile at which the budgeting benchmark is set. At some point, however, the City may wish to re-establish the status of the "market" by updating the benchmarks to reflect the new normal. This exercise should be less time intensive in the future since the categorization of the CII customer accounts should already be established. In parallel with the development of this benchmarking and budgeting approach, the City is also preparing a water auditing path to complement benchmark-based budgets when there are unique customers that do not fit well in any sub-sector and to address any customer complaints about budgets. Acknowledging the challenges of categorizing CII customers, the audit process can be used to establish CITY OF BOULDER, Col ORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGEI ING I BRENDLE GROUP 1 29 i Brendle ATTACHMENT C fair and equitable budgets. Figure 6-2 represents an illustrative process flow for how the audit process could proceed. Characteristic Update Processes Means by which Backflow by Customer Inquiry changes in Permit Request Survey or Tester (e,g. budget building use or (online) increase) size will be identified Entry Points Means by which an account may be Unique Use Complaint Change in Outreach in Trial Year referred to the Category Characteristic Preceding Years Adjustments budget adjustment or audit process. Standard Checks < IF Adjust budget se and sq. I'll, p Need t based on these correct? IlQ candidale9 purchase standard checks, more? Above checks lead to adjustment. Budget Yes Done. issue resolved? No PE or advanced PACE or basic audit audit Lbased et Set budget at maKimum of d current budget or s. ES budget based n improvemen,l Figure 6-2. Illustrative Process for Triggering a Water Audit In addition to designing the process for how the audit would interact with the benchmark-based budgeting, the City is also beginning work on a process for the audit itself. Two types of audits are being considered for inclusion: a more basic audit targeted for customers with standard water uses (e.g. end- use fixtures, common appliances, etc.) and a more advanced audit for customers with more involved CITY OF BOULDER, COLORADO I 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 30 Brendle ATTACHMENT C processes (e.g. manufacturing or cooling towers). In 2013 the City is planning to provide up to 30 of the basic audits and up to 10 more involved audits with the intent of building tools, defining how efficiency will be measured at the customer site (e.g. a prescriptive list of best management practices by water use), determining how measures will be communicated to the customer and relate to the budget, and the level of support the City will provide. The City has contracted with the County to perform the base audits, a service the County already offers for water and energy. CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 31 ATTACHMENT C brendle"' APPENDIX A. DEMAND DISTRIBUTIONS BY SUB-SECTOR Demand Distribution for Auto Dealer le% f IUM 1G9: / - 90'.6 f1 C o par 3 C 60~ 3 I f)t: fi $y~ L d! C 7 4V.- M 41 7 64 - - - - O~C 30% o 49:: - - - - - - za: 27e - - - - - - - - - 109•; 0►« 0% 0 3 5 8 10 13 16 18 21 24 26 29 31 34 37 39 Gallons per Square Foot A.R+IRwFi l.7 ~~.~'^+411If Iw~ Demand Distribution for Bar and beverage 3~sf 100% 90ri 30% I 80% C) R Z5% 1 c ? c cDr. cj 2 r; ~ m L. son m LL a a t ~`c V a✓ dOY. N N DC 1]5t 3DK ao 2D7+ S9~ SOk J`! D:h 0 SS 111 166 221 277 332 387 443 498 553 Gallons per Square Foot CITY OF WULDER. COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENOLE GROUP I 32 e ATTACHMENT C brendl Demand Distribution for Car wash 2 t 10054 9064 2.75£ ON, G t04E C } C 1?5: b05F el 7 ro y 506c ~ LL d y i~st 4U% 3 N CJ SY 205: k 0'r. A 054 Oy 0 45 90 135 180 225 270 315 350 405 450 Gallons per Square Foot Demand Distribution for Daycare ~ss4 ~ i0a?c B0 us4 ~ zo 3 3 U m m ss; Sar. 6L 1° ai c a 40`. ~p 'u S44 ~ rO ~ 414. 20Y zx t0ar 0 16 32 48 63 79 95 111 127 143 158 Gallons per Square Foot CITY OF BOULDER. COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP ( 33 ATTACHMENT C brenai Demand Distribution for Equipment Repair 1351 100): l 90]s I 14V ~ so;. 1z+: i ~ c a+ 7 r4 Cr 3 5a}: 1i m c ~ 40i: SD m 3or. o tor. 254 I I I I iPY. p7E 0'.'. 0 4 8 12 16 20 24 28 32 36 40 44 48 52 56 60 Gallons per Square Foot ra ANa ~r~rc~ -dtnLL:cr.e mQ Demand Distribution for Gas and car wash 23ri 100% 1854 90?: lo`~ 8DX n C 11~< 7Ar: 3 ? C C 1 Y% 60 . (U 7 fti SY: SO'. t v6 _ fD ~ N c ~ 9~4 / 40:. fD Y J 3 K 49 5% 30': u 454 20% 254 101t 0: 0 45 91 136 181 227 272 317 363 408 454 Gallons per Square Foot taArl~l y'r:~ (...A:t.e 7-1 CITY OF BOULDER COLORADO 1 2013 CII CONSMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 34 j! Brendle ATTACHMENT C Demand Distribution for Gas station k 3'.f 1f10Ai 19~ ~~JOYa dY 90% ~_1 n 70u C } U 7 M 50i, r or N W HY, J3 42 C 7 4U% N a• 7 m 5: n Qj ~ sor: a° U 2[ri•. 1X 1@f. 0X 0 37 74 110 147 184 221 258 295 331 368 Gallons per Square Foot DemandDistrIbutlon for Health club IDC% CO% 12"4 803s n l? 7rn 3 C ~ 6Uk DI .a Gy 3°: { d Sao. 'T+ ti (D 40?: rD a~ 7 tb ~ t$ SK 30~` 2s4 10?t. i 0 12 24 36 48 60 72 84 96 106 120 Gallons per Square Foot IWiNNle v. focy {urric!Nt -rtti] CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING J BRENDLE GROUP ~ 35 brend((e ATTACHMENT C Demand Distribution for Heavy manufacturing TY 17754 anE srr 873E f f"1 50%, 7):f C I~ C 57%< as 43 4)„ 7 N 47 ci 5 ax Z U. ci ; C y s>:; rfl m f CC 2J:s 3J7F 21K t~ 0+4 ~ 1 1 1~ 1 1 1 1 0 307 614 921 1227 1534 1841 2148 Gallons per Square Foot ~R&Ihrrrm -Cu,mffilrertac DemandDlstrihutlon for HOA aJ~a 1. too±: 351 80W 3 J'.: / n 7" ~ ~ c u L>` ID C 6ax 4r C• 7 n7 Cr 7" u tJ. > / no . r~o t~v: ~ f0 34=: CC 1 D`.4 554 0 91 182 273 363 454 545 636 727 818 908 Gallons per Square Foot mgeat,,403 cw ktke'roq CITY OF BOULDER. COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP I 36 ATTACHMENT C brendle"'_`r Demand Distribution for hospital 701, a r1 ao~:• n e c ? c u 2JN 7 to c 505. -n Z ao . m 7 to ra n a { 20% 544 10% 0 15 30 45 60 75 90 105 120 135 150 Gallons per Square Foot Demand Distrlbutinn for Industrlal nfflce 10PWY. 3SK /r 903: ~~4 ~ SOY 35°Y 70: 3 c x3sG 603. .mi rJ C' ' to caw L ~ ru C > 20411 t0?, tD Y ro { tsv, 303: e 20% 5 10% fir{ ~ I I ~ 0;ti 0 12 23 35 47 59 70 82 94 106 117 Gallons per Square Foot s 6dow.-u 7 - Wrei.m"'u'l CITY Of BOULDER. COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP I 37 ATTACHMENT C brende Dcmand Distribution for Laundry ,]:•i 100!6 9064 SO'•= _ n 7]s7 ? c a c 6tr:a n ap 3 rb -Ti lu W tD .B G c } M 2]Y 20% 10'n 10Yr J is W.. 0 148 296 444 592 740 888 1036 Gallons per Square Foot i ~ReUt~rF~e7 -CuRJatwr~m~ Demand ai5trlbutlon for Light manufacturing SQS4 1063: r 90X jJ 505E I $OY, I 7034 C ~ ]'F C > = G05 d ~ C 7 rp t 37.' S~6 T 6i a c > nog .Y 3 .2 d. I Sob. o 2W% l3~ lop: 0 21 42 63 84 105 126 148 169 190 211 Gallons per Square Foot rgR.J .i~l -Ciarl:1HP -1vq CITY OF BOULDER, COLORADO 1 20 ?3 CII CONSUIMP?IGs SEND HMARKS AND BUDGETING I BRENOLE GROUP I 18 ATTACHMENT C brend[e Demand Distribution for Lodging 214 1W$ f' 9031 15`4 r~ 8il7. J/ f1 14H 70'i+ C ~ C r 12% 60% R a C 7 ro ccr j 1 J`:. 50h rt) U. .Q a c S sH 46% m r$ rv ~ Sl 305, c el 4W 263. t1~ ~ I I iab JY c1,. 0 41 83 124 166 207 249 290 331 373 414 Gallons per Square Foot -F,fjto;%ra -WrJAP"'M Demand D lstributlon for Medical office 3,0r% 1063: i~ i 25X /f 863; U C s63. .°1. N C 7 [0 c lip 50 a C S 1a~, fD 30Jv w 13` + 2Qy: 5Y, to 0 20 39 59 79 98 118 137 157 177 196 Gallons per Square Foot ilAvlol.v F.oy -_tvrJ; t.rm+..; CITY OF BOULDER. COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP I 39 ATTACHMENT C brendI[e Demand Distribution for Mixed 9?`: _ - SOD;, f 70 , 90%a 80 •t +rni c 3 c V S~ y C GCTY; ~ 3 a0'x 50,; n 66 ro .s m c > 40% r0 ID n 3035 20Y+ 2D% 10'ii 0 138 277 415 553 592 330 958 Gallons per Square Foot ®RHm.a^He~ -Cunt; rr+e °rrq Demand DIstributlon for NursirC and res1dentim1 care 3?s~ ' 170% 9?}a ] 5°f g34. _ n 7036 C ~ z J2, 3 > c V d C 6~iG a) C 7 n I 1 ~ °4 a3i ~ C t 1 3 lap( CX 3,~ Q 0% 0 18 36 54 72 90 108 126 144 162 180 Gallons per Square Foot r•P.d_Iha crrq -Crnvl.xr.e fray CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING BRINDLE GROUP 40 brendle ATTACHMENT C Demand Distribution for Office 41% 90A r f 3~4i r $aYa f'S -e 3551 7" T = C 37v r 603s fir G G ~ m y 25 1 54Y K 61. m >a m c > zjrc ao3: m m ~ Q 15i 3ai 10 20% 5't 1Xi 0 18 36 54 72 90 108 126 144 162 180 Gallons per Square Foot ~RPlal ~7Nea -cur Wttke °req Demand Disirlbution for other 57 4 10D% f 90Y. SOY4 f/ f•1 7P3i C 9?5S C Gds C Q0 r~ ro $03 T LL CJ C ~ n03s m tv za z I 3a~., 20?'. 0 30 61 91 122 152 183 213 243 274 304 Gallons per Square Foot CITY OF BOULDER COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP ( 41 ATTACHMENT C b ren dle Demand Distribution for Public events 100% { 90h flQac ~ n 7035 r cox. 3 ru 3 ru ut rb a a rD > aor: ro 3 ~ II 3a7~ 2D% 1 I I I ,O t lr o~. 0 5 9 14 19 23 28 33 37 42 46 51 56 60 65 70 Gallons per Square Foot Demand Dlstributlon for Restaurant full. service 3aSG 1~J~4 9JK 3074 9?t ti 25u 7Jh 3 / C d=r 21W 7 Cr T i 5:N W. Q f4 ~ ~ 17>[ 37ri 2oa. i Yc II I! IIB II 1 IA A I~x aY N Sac 0 67 135 202 270 337 405 472 540 607 675 Gallons per Square Foot CITY OF BOULDER. COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 42 Brendle ATTACHMENT C Demand Distribution for Restaurant limited service 9~4E 3$w 63X 37f4 / P1 ot° r 734 y Z''~ d C 6?➢; r, 4r C ~ m Cr Z3 53S 6i / U C > A X96 rJ ',r. 1 iY 3 M ~ 3 Jae law 2w aYe I o~ III I I 0 80 160 240 320 400 480 561 641 721 801 Gallons per Square Foot ms[roNe-feu -cu'"Neflev Demand Distribution for Retail ]Yrf r- 10M 90'K X35 SQ): )Dk ~ JOB: C 60k. n ~ ' rCD Cr 50r T ii ro a~;r a d r - ^o~: ro Z 41 Cam! 3 J: n o[ 30~ NZ e 20% 10% 16?. 0 59 118 176 235 294 353 411 470 529 588 Gallons per Square Foot CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 43 j brend(e ATTACHMENT C. Demand Oistribution for Salon and Personal Services 3~% ; lOJ'~4 ~ 3.rn 3 Jsc / 3 a 2) < t 7 ra rr T a SJk LL y / am M 2 CLJ ~o~t 3ar~ ~ 2 Jyi s% 1 J7i O% Q>i 0 11 23 34 45 56 68 79 90 102 113 Gallons per Square Foot WrndaUreirrv -•wm+,11'e11eo Demand Distribution for School 4X4 1W3'. 35H 9lNL i 80y 3•r~ ~ n 7M. c ~j 25% y C 6(». ci G 7 nl Cr 2J4: so,; 9 LL > dQ3: tp V t7`'. 3 f9 2 a aoroc oc to 20% ss~ lox ~ I 1 1 ~ 0 27 55 82 110 137 164 192 219 246 274 Gallons per Square Foot CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I 8RENDLE GROUP 44 ATTACHMENT C Brendle Demand Distribution for supermarket 3J~t / 1009. / 90}5 25ir 8031 C 2Jri C } 60>. ti W < 7 fD c l ii' 543. LL 0 403. M 3 e9 1 J ~ tY' 103. 794 0r 0 38 76 114 152 190 228 266 305 343 381 Gallons per Square Foot ~Ael~l ve+~C] -euru:tbe °teq Demand 01sitrlbutron for Warehouse ID ~ - 10(13: r i 699£ I 1t0% Y1 "rJY C 70?: } C C 603r A qJ -3']:R C 7 ID 50.. W ~ M d 2C1"G 30% o 20'rr 10% 10% 0 34 67 101 134 168 201 235 269 302 336 Gallons per Square Foot ■a fl1IJt vG, ea ~i.rif:lm-t 47 CITY OF BOULDER, COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 45 1;.~ 11 N ATTACHMENT C bren Demand Distribution for Worship ? ±n! 10Dh 90h 2 )s~ 80>. n ~ c c T c 15% G0`, C1 K :3 m c 50i. W ~ Z 13% ao}. m 30% 5% tor. 1 0% 0 6 11 17 23 28 34 39 45 51 56 62 68 73 79 84 Gallons per Square Foot MR011"?f1c.7 -tw A.tke'rM CITY OF BOULDER. COLORADO 1 2013 CII CONSUMPTION BENCHMARKS AND BUDGETING I BPENDLE GROUP 46 brendle ATTACHMENT C APPENDIX B. OVER BUDGET CUSTOMERS BY SUB-SECTOR Table B-1. Summary of Over Budget Customers by Sub-Sector The values presented in each cell represent the number of customers over budget at each percentile and those still over budget that were also over budget in 2011 (over budget/still over budget), Number Over Number of Budget in 7V 85th 9P 9P Sub-Sector Customers 2011 Percentile Percentile Percentile Percentile Auto dealer 25 3 6/2 4/2 4/2 4/2 Bar and beverage 10 2 1/0 1/0 1/0 0/0 Car wash 5 1 0/0 0/0 0/0 0/0 Daycare 14 1 1/0 1/0 0/0 0/0 Equipment repair 51 5 7/2 7/2 6/2 2/1 Gas and car wash 11 2 2/1 2/1 2/1 1/0 Gas station 20 5 5/2 3/1 3/1 2/1 Health club 8 1 1/0 1/0 1/0 0/0 Heavy manufacturing 48 12 8/5 4/4 4/4 3/3 Homeowners Association (common 57 6 areas) 7/2 5/0 4/0 3/0 Hospital 3 1 1/0 0/0 0/0 0/0 Industrial office 36 6 7/3 5/2 4/1 3/0 Laundry 2 0 1/0 0/0 0/0 0/0 Light manufacturing 102 21 17/8 11/6 8/5 4/3 Lodging 68 5 9/1 5/0 3/0 2/0 Medical office 91 9 19/6 11/3 8/2 3/2 Mixed (many sub- sectors on one meter) 176 27 29/26 31/24 31/24 31/24 Nursing and residential care 8 0 0/0 0/0 0/0 0/0 Office 569 79 142/44 89133 65/24 31/16 Other 26 2 4/2 3/2 3/2 1/1 Public events 14 1 2/1 2/1 2/1 2/1 Restaurant full-service 82 6 11/1 5/1 4/1 4/1 Restaurant limited- service 48 8 5/2 4/2 3/2 2/1 Retail 289 28 55/14 34/10 20/6 11/4 Salon and personal services 14 0 3/0 1/0 0/0 0/0 School 89 18 18/11 12/9 11/8 10/7 Supermarket 14 4 3/1 1/0 1/0 1/0 Warehouse 113 17 18/8 10/4 10/5 5/3 Worship 45 9 13/6 8/5 8/5 8/5 Based on 2011 consumption. CITY OF BOULDER, COLORADO 1 2013 011 CONSUMPTION BENCHMARKS AND BUDGETING I BRENDLE GROUP 1 47 i ATTACHMENT C 0 Brendle Endnotes 1 City of Boulder. (1121, 2011). Water Resources Advisory Board Agenda Item. 2 City of Boulder. (10 4, 2012). Water Budget Changes, Fact Sheet -June 2008. Retrieved 2 18, 2013, from Site: http://www.bouldercolorado.gov/index.php?option=com content&task=view&id=9369&Itemid=5520 3 City of Boulder. (8 1, 2009). Water Budget Rules -August 1, 2009. Retrieved 2 18, 2013, from Site: http://www.bouldercolorado.gov/files/Utilities/Water/20Budgets/waterbudgetrules 080109.odf 4 AMEC. (12 18, 2012). Water Conservation Futures Study Update. Presentation provided by Russ Sands. 5 City of Boulder. (12 27, 2012). The Basics of Your Water Budget. Retrieved 2 18, 2013, from Site: http://www.bouldercolorado.gov/index.php?option=com content&task=view&id=6243&Item id=5520 6 Chestnutt, T. (A&N Technical Services, Inc.). (9 22, 2011). Analysis of Non-Residential Water Use Factors. 7 Chestnutt, T. (9 7, 2012). (S. Jansen, interviewer) s MPWMD. (n.d.) MPWMD Water Efficiency Requirements for Change of Ownership, Change of Use, and Expansion of Use: Non-Residential. 9 Jansen, S. (Brendle Group). (10 5, 2011). Water Benchmarking for Select ICI Sectors in Boulder (Scope request #1, TM #2) 10 Brendle Group. (6, 2007). Benchmarking Task Force Collaboration for Industrial, Commercial & Institutional (10) Water Conservation. 11 Jansen, S. (Brendle Group). (3 15, 2011). Water Benchmarking for Select ICI Sectors in Boulder. 12. Morales, M., Martin J., and Heaney J. (University of Florida). (Fall 2009). Methods for Estimating Commercial, industrial and Institutional Water Use. 13 Gleick, P., et. al. (Pacific Institute) (11, 2003). Waste Not Want Not. The Potential for Urban Water Conservation in California. 14 Denver Water GIS System. (n.d.). Premise Types and Examples. 15 DeOreo, W. (n.d.). Characterization of Industrial Entities in the State of California. 16 AWWA Research Foundation. (2000). Commercial and Institutional End Uses of Water. 37 ENERGY STAR Portfolio Manager. (10, 2012). Data Trends: Water Use Tracking. 18 Santa Clara Valley Water District. (2, 2008). Cll Water Use & Conservation Baseline Study. 19 City of Boulder. (2 14, 2013). SmartRegs Compliance Pathways. Retrieved 2 21, 2013, from Site: http://www.bouldercolorado.gov/index.php?option=com content&view=article&id=13996&Item id-5263 CITY OF BOULDER, COLORADO I 2013 CII CONSUMPTION B=NCHMARKS AND BUDGETING I BRENDLE GROUP 1 48 ATTACHMENT D Attachment D: Revenue Impact Analysis 1) Base Revenue Impact Analysis CII 2011 Use with 95th Percentile Budgets Consumption (expressed in 1,000 gallons) Block 1 Block 2 Block 3 Block 4 Block 5 916,144 195,995 98,105 33,561 102,507 Revenue Service Additional Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,997,194 $568,386 $569,009 $291,981 $1,486,352 $754,634 $5,667,555 $643,831 CII 2011 Use with 90th Percentile Budgets Consumption (expressed in 1,000 gallons) Block 1 Block 2 Block 3 Block 4 Block 5 849,938 218,300 110,032 38,510 129,532 Revenue Service Additional Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,852,865 $633,070 $638,186 $335,037 $1,878,214 $754,634 $6,092,006 $1,068,282 CII 2011 Use with 85th Percentile Budgets Consumption Block 1 Block 2 Block 3 Block 4 Block 5 807,368 228,118 118,659 42,298 149,869 Revenue Service Additional Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,760,062 $661,542 $688,222 $367,993 $2,173,101 $754,634 $6,405,554 $1,381,830 CII 2011 Use with 75th Percentile Budgets Consumption (expressed in 1,000 gallons) Block 1 Block 2 Block 3 Block 4 Block 5 754,854 224,266 114,809 55,363 206,258 Revenue Service Additional Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,645,582 $650,371 $665,892 $481,658 $2,990,741 $754,634 $7,188,879 $2,165,155 CII 2011 Use with 2011 Budgets Consumption (expressed in 1,000 gallons) Block 1 Block 2 Block 3 Block 4 Block 5 872,949 301,635 101,548 32,779 42,563 Revenue Service Additional Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,903,029 $874,742 $588,978 $285,177 $617,164 $754,634 $5,023,724 N/A ATTACHMENT D 2) Alternate Revenue Impact Analysis* CII 2011 Use with 95th Percentile Budgets* Consumption (expressed in 1,000 gallons) Block 1 Block 2 Block 3 Block 4 Block 5 740,854 112,909 49,624 16,452 20,455 Revenue Service Reduced Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,615,062 $327,436 $287,819 $143,132 $296,598 $696,855 $3,366,902 -$523,574 CII 2011 Use with 90th Percentile Budgets* Consumption (expressed in 1,000 gallons) Block 1 Block 2 Block 3 Block 4 Block 5 689,176 134,033 60,794 23,648 32,643 Revenue Service Reduced Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,502,404 $388,696 $352,605 $205,738 $473,324 $696,855 $3,619,621 -$270,855 CII 2011 Use with 85th Percentile Budgets* Consumption (expressed in 1,000 gallons) Block 1 Block 2 Block 3 Block 4 Block 5 652,291 145,255 69,383 27,539 45,826 Revenue Service Reduced Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,421,994 $421,240 $402,421 $239,589 $664,477 $696,855 $3,846,577 -$43,899 CII 2011 Use with 75th Percentile Budgets* Consumption (expressed in 1,000 gallons) Block 1 Block 2 Block 3 Block 4 Block 5 577,760 159,377 95,775 41,330 75,290 Revenue Service Additional Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,259,517 $462,193 $555,495 $359,571 $1,091,705 $696,855 $4,425,336 $534,861 CII 2011 Use with 2011 Budgets* Consumption (expressed in 1,000 gallons) Block 1 Block 2 Block 3 Block 4 Block 5 604,330 190,401 79,583 29,159 41,983 Revenue Service Additional Block 1 Block 2 Block 3 Block 4 Block 5 Charge Total Revenue $1,317,439 $552,163 $461,581 $253,683 $608,754 $696,855 $3,890,476 N/A *Does not include 8 looped accounts and/or large water user accounts. 1 ATTACHMENT E Characteristic Update Processes Means by which Backflow by Customer Inquiry changes in Permit Request Survey or Tester (e.g. budget building use or (online) increase) size will be identified. Entry Points Means by which an account may be Unique Use Complaint Change in Outreach in Trial Year referred to the Category Characteristic Preceding Years Adjustments budget adjustment or audit process. Standard Checks *Purchase Need t Adjust budget <se and sq. h. 110 candidate? based on these c orrect? standard checks. -Above checks lead tom, adjustment. Budget Yes- Dane. issue resolved? No PE or advanced PACE or basic audit audit dget at based an mum of Set ES budget 7improveent recommended (ES budget or Improvements. et trased m. Consider options f or defining appropriate use and required level of efficiency: prescriptive list, defined payback for opportunities, period in which improvements are required, and level of funding support from City. Commercial, Industrial and Institutional (CII) Study Update March 18, 2013 f~ ! 0 r 9 0 \ ~r \ ~ 1 i .i i ~ ® O ! i8 • r _ v'. ~f+1 Y a t Types of CI I Water Budgets Mon • AMU Jan Dec Jan Dec !an Dec • HMU hwid • 1(O • ES- Can mimic any of these; P.E. hired to determine water use. * PI F- Customer pays a plant investment fee and receives a comparable water budget * 25%, 509 or 85% of the Customer Class Average for that meter size. C1 I Studies * More than 14 Studies referenced including: 2000 Commercial and Industrial End Uses -zooo 2003 UK Watermark 2003 Pacific Institute "Waste Not, Want Not" zoos Exergy CII Study 2007 CWW Benchmarking Taskforce/Brendle Group 2008 Santa Clara Valley Water District CII Baseline Study 2011 CUWCC CI I Task Force Report to the Legislature * (ongoing) Applying NAICS Codes A North American Industrial Classification System (NAILS Codes) * Pronounced "hakes" Codes Start with 2 digit level for zo broad categories Replaced the Standard Industrial System (SIC Codes) in 1997 Reviewed every 5 years (2012 was most recent). 4~a NAIC'S Codes Fxplained 2 Digits: 72 Accommodation and Food Services 72: Accommodation and Food Services 721 Accommodation 7211 Traveler Accommodation 72111 Hotels (except Casino Hotels) and Motels 721110 Hotels (except Casino Hotels) and Motels 72112 Casino Hotels 721120 Casino Hotels 3 Digits: 72119 Other Traveler Accommodation 721191 Bed-and-Breakfast Inns * 721- Accommodation 721199 All Other Traveler Accommodation 7212 RV (Recreational Vehicle) Parks and Recreational Camps 72121 RV (Recreational Vehicle) Parks and Recreational Camps * 722- Food Services and Drinking Places 721211 RV (Recreational Vehicle) Parks and Campgrounds 721214 Recreational and Vacation Camps (except Campgrounds) 7213 Rooming and Boarding Houses 72131 Rooming and Boarding Houses 721310 Rooming and Boarding Houses ~C /I Digits: 722 Food Services and Drinking Places 7221 Full-Service Restaurants 72211 Full-Service Restaurants * EX: 7222 Limited Service Eating Place 722110 Full-Service Restaurants 7222 Limited-Service Eating Places 72221 Limited-Service Eating Places 722211 Limited-Service Restaurants Digits 722212 Cafeterias, Grill Buffets, and Buffets ~c [ 722213 Snack and Nonalcoholic Beverage Bars J 7223 Special Food Services 72231 Food Service Contractors 'k EX: 72221 (Same Title As Previous) 722310 Food Service Contractors 72232 Caterers 722320 Caterers 72233 Mobile Food Services 722330 Mobile Food Services 6 Digits 7224 Drinking Places (Alcoholic Beverages) 72241 Drinking Places (Alcoholic Beverages) 722410 Drinking Places (Alcoholic Beverages) * EX: 722211 Limited Service Restaurant * EX: 722212 Cafeteria/Buffet "NAICS Based Codes" NAICS Codes don't always give the detail needed Hotels with: * pools? * laundry? * restaurants? * All of the above? Reclassify as needed? * Gas Station with a Car Wash * Should it be with Car Washes or Gas Stations? Applying Normalizing Factors Equitable customer comparison Studies often use gallons per: * Employee * Student * Pupil * Hotel Room * Occupied Hotel Room * Square Foot * Plate * Table CI I Bench arks 25th Percentile has been used as the efficiency benchmark... For guidance NOT billin 75th 50th 25th Staff Concerns Studies: * Use the 25th Percentile Guidance Not Billing * Use many Normalizing Factor(s) * Don't classify all C1 i subsectors Other Concerns: * UTB Database * Allowances for Complaints Allowances for Unique Customers 2011 WRAB Guidance I y * Doesn't have to be 25th percentile * It could be between the 75th and 95th * water Audits alone will take too long * Benchmarks should be used * Should mitigate issues/ be equitable 'a. i v i w i o4 i'_ u o-1 it r ri U Set benchmarks For CII sub-sector water use (done outside of the UT8 database) STANDARD CII WATER USE UNIQUE CII WATER USE Convert benchmark use (amount) into an ES water budget; ES amount based on sub-sector benchmark (ref pr belativ the benchmark) {AbPVc the benchmark) fN knosyn benchmark) Customer should not have Offer audits to the customer Audit the customer to issues with their new water to determine the customer's wtom~ Custcrrer determine budget heir new budget, ES can be flat or needs efficiencies, employee refuses the refuses the ES water budget adjusted as needed count, etc water and it water audit (AMU-waste=budget) i NC VARIANCE VARIANCE Customer is Customer is S,Aget determined Budget determined given the same given a reduced to be adequate or NOT to be adequate, benchmark ES budget: a generous; customer has based ES water budget which is ,nvestment in invested in best budget as the less than their efficiencies are available efficient rest of their current use needed techna'o~es sub-sector ANY REQUEST FOR A BUDGET INCREASE WILL REQUIRE AN MDOOR WATER AUDrr Requirements of the audit, audit form, and metrics to be used to be determined by Staff & WR48. Only 1 budget change is allowed in any given year. E Wit' 9 i • l 'o OMEN s~ U dk, fr' v~ r~{~Ir iy 'h . at, Initial Discussion with Monterey 1 ~ i Did Monterey Do What We Proposed? Not really. Similar intent, different choices: * Sot" percentile benchmark * 54 subsectors * lo+ Normalizing Factors * $z,ooo+ Water Audits (not available to all) * Couldn't calculate revenue until the end of the year Monterey had different regulatory requirements * Put the city, Utility and Customers in an impossible situation More Discussion with Monterey * Discussion with Tom Chestnutt, A&N Technical Services * Attempted to update benchmarks in 2011 * 54 sub-sectors * 38% missing normalizing data * Aligning data sources * Single factor insufficient to predict usage * Wide variations in within sub-sectors ' * Multiple uses on a single meter * Steep escalation in over budget rate blocks r * Annual "true-up" created uncertainties for utility and customer * Recommend that benchmarks are NOT used for rate making * Currently developing a new approach with BM Ps - , W to t, e - ~ ' a ® a - ~ - Potential Benchmarking and Water Audit Issues and Mitigation Strategies Issue Monterey's Approach Boulder's Proposers Mitigation Benchmarks Used the 50th Percentile; customers paid Set the benchmark between the 75th Can't Be Too higher bills because they couldn't always r,. and 95thpcrcentile. High Benchmark 5trin~;cnt meet the efficiency benchmark 4. Multiple Normalizing Used 10 different normalizing factors Factors Don't causing confusion for customers and staff. Use only gallons per square faot_ Work Difficult for staff to manage. L Normalizing Factor l No exceptions to the benchmark. Water Allow increases based on water audits. Allow a trial year for Businesses audits only for unique use. Ex: Hotels Require receive budget based on gallons per customers to see if their budget Flexibility occupied room regardless of if they used would be negatively affected. water for laundry or contracted that work. Provide water audits as needed/rcgnesled. Make Audits Available Contract lower-cost, quicker ata its Water Audits Monterey paid over $2,000 per water audit. through Boulder County. Audits to for Total Audits evaluate opportunities to reduce Water Use are were lengthy and detailed the total water waste. Use higher cast, more Costly water a customer would use, detailed audits for unique customers or as needed. Monterey's "True Up„ meant the city could Make Audits Affordable Budgets Must Monthly water budgets are more Consider not accurately estimate revenue; customers effective. Any budget changes must Revenue who weren't over their annual water consider all rate and revenue budget would receive a check at the end of Impacts the year. impacts. Consider Revenue Y -r 7r - 01 7 s Y 1,,'I I I r • I i • i i }}y~am s "q 14, Process Water Consumption Data Normalization Data Categorization of Cil customers Benchmarks by sub-sector Water Consu ption 1u . Calendaryearzo11 - * Similar to 20o8 and 2010 * Trend toward efficiency Indoor consumption (including seasonal) * Irrigation known or suspected used AWC (Dec-Mar) * 1/O budgets * High ratio of summer consumption to total consumption * All others used annual consumption Nor ■ Factor Square footage used for all sub-sectors Widely available Relatively reliable Simplifies futures updates Matched by address or in City's GIS system o - - ~ e q e i Last Update of % Customers Data Source Category Data • • Categorization Approach Matched North American Industry Classification 2008 Six-digit code representing Address (separated from 51% System (NAICS) industry single string Original property Building styles and building Parcel data record types sometimes imply use Address 98% Landlink Permit Date of permit Restaurants Address 6% Database - Restaurants Landlink Permit Date of permit Hotels Address 2% Database - Hotels Utilities Backflow Observations from last Service key and payer Prevention Database Last inspection inspection account numbers 9% Categorizing Using NAICS Codes * How many NAILS digits to use? * Balance resolution against number of customers per sub-sector * Consolidated from170 to about 30 sub-sectors NAICS Level # of Resulting Categories with # of Categories with <5 C11 # of Categories with I C11 (digits) Customers Customers Customer 2 122 73 55 3 170 100 65 4 251 166 95 5 319 238 148 6 342 263 167 9P L Auto riealer 14.6 Bar and beverage 10 131.2 142.7 224.7 383.1 Car wash 5 321.4 333.1 339.0 344.9 Daycare 14 64.6 74.6 89.6 117.3 Equipment repair 51 21.4 23.7 28.4 41.2 Gas and car wash 11 4133 473.8 475.7 503.4 Gas station 20 79.5 108.7 119.4 164.3 z 9 s U b-s e et o rs Health club 8 49.8 53.1 73.4 96.8 Heavy manufacturing 48 354.2 613.1 710.5 1021.1 See Table 4-2i n report Homeowners Association (common 57 166.8 208.1 230.6 397.6 r areas) I Demand Distribution for Office Hospital 3 84.4 97.5 104.1 110.6 II 35% _ 100% Industrial office 36 10.0 18.0 20.9 26.4 Laundry 2 820.8 928.1 981.7 1035.4 90% Light manufacturing 102 1S-7 25.0 27.8 38.1 30% 80% Lodging 68 77.0 102.2 118.6 143.4 A Medical office 91 42.8 60.4 67.5 90.1 0 254 70% 3 Mixed (many sub r 176 55.1 85.5 130.3 227.4 s. sectors on one meter) bo% ! Nursing and a =e ' c 8 109.3 134.3 136.9 139.5 3 m residential care Li sow M Office 569 14.3 25.3 34.5 53.2 5? - j 40y Other 26 33.8 37.6 44.2 133.7 Public events 14 5.7 93 13.4 38.2 10^a 30% Restaurant full-service 82 175.3 2251 267.2 341.9 eE Restaurant limited 1t>% 48 133.9 169.8 207.1 748.0 service 594 10% Retail 289 15.1 29.1 43.6 689 Salon and personal 14 32.1 74.6 86.8 98.3 I I ®f e e Q_ _ L services 0% C.a 0 12 24 36 47 59 71 83 95 107 119 School 89 27.5 41.2 461 52.6 Gallons per Square Foot Supermarket 14 95.8 168.8 183.4 254.2 lAe4e6rve FreV -Cumulatl- Fred warehouse 113 15.7 21.4 28.8 49.9 Worship 45 16.1 20.5 23.4 26.6 Commad A and 0i ENERGY CRY of A End STAA~. WA10. _ Y • i 1 7.UrJ :..'a~PI 1 i - Bar and beverage 44.7 Car wash 212.1 Daycare 28.3 Equipment repair 13.6 6.5 Gas and car wash 340.7 Gas stat ion 47.0 Health club 27.1 6.7 Heavv manufacturing 15.6 Homeowners Association (common 73.0 areas) Compared to benchmarks in H ospital 51.8 50.0 79.6 Industrial office 4,7 literature Laundry 552.5 Light manufacturing 7.8 Lodging 52.5 72.6 55.0 63.9 76,0 Medical office 16.2 8.1 20.0 120.1 M 17.5 Categorization and regional sectors on on one meter) differences Nursing and residential 82.8 60.0 203.3 63.0 care Office 70 14.2 6-6 15.0 19.3 Other 12.9 Public events 2.4 16.5 Restaurant full service 75.2 306.1 159.0 See Table 4-3 in report Restaurant limited- 50.6 service Retail 4.5 U0 6.0 Salon and personal 12.4 services School 12.6 24.4" 13.0 16.4 11.0 Supermarket 42.7 33.3 29.4 25.0 36.9 Warehouse 6,3 3.0 3.0 Worship 7.0 10.9 8.0 y Implications of "overbudget" different Customer under or over budget in current system may be opposite in benchmark-based system Case Current • Benchmark-based Budgets At or under budget Customer using less than they have Customer using less relative to peers historically or have requested adjustment Over budget Customer using more than they have Customer using more relative to peers historically 1 t - _ Benchmark-based Budget at Shown Percentile 2011 Number 1 Budgets 85th 90th q5th At or under budget 1,759 1,643 11778 11832 11905 Over budget* 279 395 260 206 133 Still over budget 148 112 96 75 (were in 2011 also) Newly over budget 247 148 110 58 (were not in 2011) No longer over budget 131 167 183 204 (were in 2011 but no longer) Net negatively affected 116 -19 -73 -146 (newly over budget - no longer over budget) *Over budget is defined as three consecutive months in Block 4 or above. Total CII customers in the analysis is 2,038 (e.g. 1,759+279). Revenue I pact Analysis Analysis #i * All scenarios increase revenue. Analysis #i Scenarios increase/decrease revenue. 85th percentile is closer to revenue neutral. V a. 1 . Types of Water Audits 1 Standard Benchmark Customer Water Audits evaluate opportunities to conserve r - ~Water Audit by County a terSerjse Z Unique Users ;It Work Water Audits evaluate total water needed + Opportunities to conserve t11- !1 a Water Audit by P.E.= ' 9ackflow by Customer !ncu -y Permit Revues- Survey or-este- :u_get icz- net n:ieasc: Unique Use Cha-ae.n C-.,tra•.h jr, - ria' Year Co npla r .,ategcry vhara-ens'is '-e.edm•_ Yea . ,^-.dust^ren-g Multiple ways to 'seandsq F:hase axrec,~ I,O cand,~ale? purc r^c-e receive an audit. • Unique AEclechecks lead to • Complaint adisssue msoly udgel Yes- Done • Change in Use No • Outreach PEx acvanced PACEe-basic • Trial Year Concern audit audit Set "cS budget SES budge: a- bases on r+axin^un of recomnenc~d curreet budge: or zrtprtivetrents c5 budget based ircprovement Consider optiuns far defining appropriate use and required level of efficiency- prescroWe list defined payback for opportunities. period in which inprrwemefAs are required, and level of findng support from City. Water Audit Questions TBD * Enhance Water Audit Form s * Identify Water Audit Passing Criteria * Identify Unique User Form/ Will same form work? * How many audits can we do each year? * Define Water Budgets Increases o.-r;. ~ - ~ ! YJr ~s_ 1f1 ~ y _ r t ~ I ~r I~i s i 8 y}~s~i.'''?~'~' ~ ~ m i - ~ - s ~ i6 ~ ~ ~ v a r r ~ ~ a ~ 1 ~ q w ~ y ~ ~ ~ 1 ~ • ~ 4 ~ 1 ~ • ~ 1 1 09 ~ ~ tq i ~ ~ ~ s O ! s ~ ~ ~ ~ ~ i a 1 ~ iF • Y 1 ~ ~1 ~ l ~ q ~ ~ i d1~b~ ' t~,wu V~~: II. ~T}w _ ~ =.R _ ,,a _ r-- ~ ' - WE spa TIMELINE 010* 201 Develop Cli WB methodology for benchmarks and water audits. 001* 2014 New budgets approved/ program new WB into UTB database. 100* 2015 Trial year- customers see their new budget but are billed normally. 010* 2016 Fully implement new CII water budgets. a 1 A. f ,I9i i t i ■ ft Ilk `I~ti II f. ~ u II ■ 9 u. t 0 / 1 L ' A R E Y 0 U` r g t: ,rN 8ouWer Water Conservation Fair - May] 3 WAT ~h R Celebrate the efficient use of water! Bring the family yT ; r to East Boulder Community y Park on May 18 for this - free event. Kids will enjoy free canoe rides and - t entertainment while garden enthusiasts pick-up W I S-E discounted xeriscape plants, attend irrigation Pick one of three low-water, professionally • classes, and get free mulch and compost. designed xeriscape gardens with 15-28 plants each. These gardens cost 574 to $110. SAVE WATER AROUND YOUR 0/1F'~ : N, 'sl- IS YEr:R: Forests to Faucets Bus Tour r Take a guided bus tour that follows Boulder's J When it's hot and dry, it's even more water supply from source to stream. Tour stops Boulder water customers can get a 50 percent important to use water efficiently. will highlight reservoirs, ditches and more. The discount on drip irrigation kits and garden The City of Boulder and the tour costs $10, which includes lunch at hose timers! This basic, versatile kit comes Center for Re$ource Conservation (CRC) Northern Water Conservancy District. with everything you need to connect to your Call CRC to reserve your seat! SMART offer several programs and resources to IRRIGATION outdoor hose bibt and get started! help customers conserve. - Ca11303-999 -3820 ext, 217 for details or visit www.conservationccnter.org. i Participate in one or both of these free sessions I ` taught by local landscape professionals. Class Sign help up you and a save twater!rained iAuditsrrigation audidentifyitor will information can be found below or, for more sprinkler f systems'effrciency, review watering schedules details on these and other classes, visit: t i 4r. www.conservationcenter.org, and more- Free repairs and sprinkler upgrades will be made where applicable. Audits are DRIP IRRIGAT'ON 'i' scheduled for June 11 through August 24. Tuesday, April 16, 2013 fmi-.1 t:6;)p.:n. to n.CCr~. 63D9 Spurce Street, Boulder, CO 80302 rl',. 3 a~ E: i7€ 4~ ( fl Cr ,fir A.11~ a 1, VA When* comes toyourjawn,.WaW-Tm less-often ReSource~ Saturday, May 18, 2013`from 9:00a.m. to 10:30a.m. r.OH5fRVAT144 VVater'Sense 1 03 - 56605iou~Drive, Boulder, CO 80303 it 4 is ° ~.ortTruek wm ! i h y + Call CRC Today! 303-999-3820 ext. 217 54 " 'teaM 1 r 1 >l~ ~tr~-i~. ! ( siSt..ryaA~ufr,.rlrr - 7A': SPECIAL EVENTS ARE YOU WATER Celebrate the efficient use of water! Bring the family a y to East Boulder Community Park on May 18 for this - free event. Kids will enjoy free canoe rides and W I S E 7 entertainment while garden enthusiasts pick-up i discounted xeriscape plants, attend irrigation Pick one of three low-water, professionally • classes, and get free mulch and compost. designed xeriscape gardens with 15-28 plants each. These gardens cost $74 to $110. ~AV~ WATER AROUND YOUR eacu-ca~ YARD AND GARDEN THIS Y17,RR! Take a guided bus tour that follows Boulder's When it's hot and dry, it's even more water supply from source to stream. Tour stops Boulder water customers can get a 50 percent important to use water efficiently, will highlight reservoirs, ditches and more. The discount on drip irrigation kits and garden The City of Boulder and the tour costs $10, which includes lunch at hose timers! This basic, versatile kit comes Northern Water Conservancy District. ,u Center for Resource Conservation {CRC) with everything you need to connect to your Call CRC to reserve your seat! 7-4 SMART offer several programs and resources to ~IRRIGA+- outdoor hose Bibb and get started. w help customers conserve. i - = WATER WISE SEMINARS SLOW-THE-FLOW AUDITS Call 303-999-3820 ext. 217 for details or visit www.conservationcenter.org. Participate in one or both of these free sessions taught by local landscape professionals. Class Sign up and a trained irrigation auditor will information can be found below or, for more help you save water! Audits identify sprinkler ' , r details on these and other classes, visit: systems efficiency, review watering schedules ' and more. Free repairs and sprinkler upgrades ~j www.conservationcenter.org. ~ will be made where applicable. Audits are scheduled for June 11 through August 24. DRIP IRRIGATION 141 Tuesday, April 16, 2013 from 6:00p.m, to 8:00p.m. 2639 Spurce Street, Boulder, CO 80302 When it comes to • • • Less • Il TT l! Resource can make • _ Saturday, May 18, 2013 from 9:00a.m. to 10:30a_m. CONSERVkTIOt; o, 1/VaterSense 5660 Sioux Drive, Boulder, CO 80303 s Call CRC Today! 303-999-3820 ext. 217 All programs are made possible by the city's Water Conservation Program in r partnership with the {enter for Resource Conservation, To learn about other j► + ~10 pr i t ' . 1►,t~ ! e * ) Water con5ervaticn efforts or tips, visit: www.boutdersaveswater.net. i i'ruat dnn In0'. p.,;a riocunter;rcytErB (~efirntpap'' t.] f~ f s f EVENTDS ESPECIAIES A r e n d a a 'I'll XP C u *1 d a r e ' iCelebre el use eficiente del a ua! Trai a a su fam ilia al' t 4 ' ' • Parque comunitario del este de Boulder el 18 de mayo a este evento gratuito. Los Winos disfrutaran paseos gratuitos en a g u a canoa y diversion mientras los entusiastas de la jardineria obtienen plantas de xerojardineria, asisten a clases sobre Qbtenga una de tres variedades de rajas de xerojar' fneria irrigaci6n y reciben gratis abonos y compostas. disenadas profesionalmente, que contienen de 15 a 28 plantas cada una. Las rajas cuestan de $74 a $110. Visita "De los bosques a ios grifos en autobus KITS DE IRRIGACION POR Haga una visita guiada en autobus desde la fuente hasta la r,- Cuando hate calor y esta seco es aun mas corriente de suministro de agua de Boulder. En las paradas importante usar el agua de manera eficiente. veremos los embalses, las acequias y mas. La visita cuesta Los clientes de agua de Bouider putden obzener uh La Ciudad de Boulder y el Centro de $10 e incluye el almuerzo en el Distrito Norteno de descuento del 50% en kits de irrigation por goteo y en Conservation de Recursos (CRC por sus siglas Conservation de Agua. Llame a CRC para reservar temporizadores de riego. Este kit basico y versatil viene con su lugar. en ingles) ofrecen varios programas y recursos SMART todo to que usted necesita para conectarlo a su sistema de IRRIGATION MONT- riego. para ayudar a los chentes a la conservation. MCINT ~H- Llame al 303-999-3820 ext.217 SEMI NARIOS PARA CUID>AR EL AGUA para mas detalles o visite: www.conservationcenter.org Participe en uno o en los dos seminaries gratuitos dictados por profesionales locales dejardineria. Registrese para que un auditor de irrigaci6n capacitado La information sobre las clases esta abajo o para le ayude a ahorrar agua. Las auditorias identifican la mas detalles sobre estas y otras clases, visite: eficiencia de los sistemas de riego, revisan la L, www.conservationcenter.org programacidin del riego y mas. Se haran reparaciones y actualizaciones de sistemas de riego gratuitas cuando i ~ ! T }Tr ~y ry n- aplique. Las auditorias estan programadas de111 de junio IRRIGAC16N POP, ;(0 I I~ I al 24 de agosto. l 1 r Martes 16 de abril de 2013, 6:00p.m. - B:OOp.m. 2639 Spruce Street, Boulder, CO 80302 que se XENJARDINIERfA: Lo bAsi(o ,r r 5s ir, ReSource` . - _ _ Sabado 18 de mayo de 2013, 9:30a.m. -10:00a.m.2 CONSERVATION V1i~tterSense cm dv 5660 Sioux Drive, Boulder, CO 80303 to is 13 ' `I r< _ f~ 303-999-3820 ext 217 01 ~ ~ I ~ w - ~ ~ 1O~r R7d510;17i51i)il, ?JRiCIaSd d~5(k4,1~lUrGl.il~~)filPi.LICOn r,~7Pil]i' f t ? • m6s en www.bouldersaveswater.net iquadela dudadcon Memo pm conservaclande recursos #araconocermasarenade esitierm de COtIS (V2LIU d a 4i I ara COr S4i0S Vlt1;?. 14 4'1'.".I7( fld^CS 1'E'S1'Y3I f rt"_(. t Impreso en peel que mnoene materwes love utiivxlos y recidados. n o. y r 0, a .1~1$I i►. I 1 t~ f r *Aprenda a t 9 Ta r4-4 toe, - 18demayo C u d a r le iCelebre?I use eficiente del agua!Traiga a su familia al Li4 f_ L Parque comunitario del este de Boulder el 18 de mayo a este ' evento gi atuito. Los ninon disfrutaran paseos gratuitos en a g u a canoa y diversion mientras los entusiastas de la jardineria ® obtienen plantas de xerojardineria, asisten a clases sobre Obtenga una de tres vafiedades de rajas de xerojardineria in igab6n y reciben gratis abonos y cornpostas. disenad?s profeslonalmente, que contienen de 15 a 28 plantas cada una, Las cajas cuestan de 5774 a S 110. Ahorre aqua en su cespczz do daja codto y jardin esf e atie. Viisita "De los hosques a los grifos"en autobtjs ;::';Ea.:: KITS Dl= IRRiGACIUN POR Haga una visita guiada en autobus desde la fuente hasta la Cuando hate calor y esta seco es a6rl mis corriente de sum;nistro de aqua de Boulder. En las paradas i mportante usar el aqua de manera eficiCente, veremos los embalses, las acequias y mas- La visita cuesta Los clientes dig agues de E4u'der ; i; Gi r C:)?_ nrr un La Ciudad de Boulder y el Centro de $10 e incluye el ahnuer.o en e) Distrito Norteno de descue--;o dF-' 50", en k;t; ce f;oii, on ci,,teo yen Conservaci6n de Recursos (CRC l)or sus siglas Const rvacidn de Agues Llame a CRC: para reservar temporizadort•;s de riego. Esie kit bosico y versatil viene con su Lugar. JULY- en ingles) ofrecen varios programas y recursos SMAAR~f todo to que usted necesita para conectarloa su sistema de para ayuciar a los clientes a la conservation, _t4n'ANni- riego. Home al 303-999-3820 ext-21 I AUPITOPI n "S~ OAVJ Pl=_r1 n1AF" para mas detalles o visite: f ' - Jvd n se rvationcenter.org Participe en uno o en ios dos seminarios gratuitn,, dictados por profesionales locales de jardineria Pegistrese pare que un auditor de irrioaci6n capacitado La information sobre las clases esta abajo o p.tr,, le ayude a ahorrar aqua. Las auditorias identtfican la mas detalles sobre estas y otr .s cases, v s : eficiencia de los siste•nas de riego, revisan la v, arw.conservationcenter.org programab6n del riego y mas. Se haran reparations y i 1 ac alizaciones de sistemas de riego gratuitas cuando ON aplique. Las auditor(asestan pragramades del I 1 de junio Nlartes 16 de abnl de 2013, 6:00p.m. - 8:00p.ru. al 24 deagast4. 2639 Spruce Street, Boulder, CO 80302 • • s ~a • . o v Resource V664 14 m cis to le ra 1latectufa. Sahado 18 de Mayo de 2013, 9 30a.m. 10:00a.m. C045f.RYa1104 L a n I rSet1Se 566QSioux D ' e, Boulder, CO 80303 Allame 4 t e3 m r .y ~r • ' r. 1 r ' i 0 0 01 _ ' ~u .c»u ~I~ l1~s) ~G., m rn;r7rrcuruattr:tnn.rr.uand.: w VAN,; t). - , . - , , t • w ;~f ~ : 6 r 14~,. • f n ' y~xd?tanalldronfiCxntre~ar~(onr~er~autmtlr r~ur a~.PaneonuCrrmJsacerradz h,~.+ ? ~ „~~w ~ 4; ,,~6a-:,,,dr~onten~nbndra~ua6(Iw.~ronirios,rt5tle:www.hnuldrests~..,,:,ir,cn:;. , ,