RULES AND REGULATIONS REVIEW COMMITTEE

 

 

2.

DEVELOP RECOMMENDATION TO THE BOARD REGARDING FIRST READING OF AN ORDINANCE REGARDING INSTALLATION OF DUAL PLUMBING SYSTEMS

 

Meeting Date:

June 18, 2009

Budgeted: 

N/A

 

From:

Darby Fuerst,

Program/

N/A

 

General Manager

Line Item No.:

 

 

 

Prepared By:

Stephanie Pintar

Cost Estimate:

N/A

 

General Counsel Approval:  Approved by Counsel

Committee Recommendation:  N/A

CEQA Compliance:  Pending

 

SUMMARY:  On September 22, 2008, the Board referred development of a dual plumbing ordinance to the Rules and Regulations Committee.  Staff has prepared a draft ordinance to allow dual plumbing (i.e., separate plumbing for each water supply source) within a single structure for consideration by the committee.  The draft ordinance is attached as Exhibit 2-A.

 

Requests to use two water systems in the same building to provide water for a home or business have become more frequent during times of limited water supply.  For many years, with rare exceptions such as the Monterey Bay Aquarium, the District’s administrative practice has been to deny requests to allow two water sources within one structure, such as, California American Water (CAW) and a non-CAW source such as a private well.  Multiple supply sources have been allowed in separate structures on a site, such as CAW water for the main residence and non-CAW water for a separate, detached garage/office or guest house.  Multiple sources have also been allowed for non-potable uses, such as CAW service to the home and well water for landscape irrigation. 

 

Given increasing requests for water permits to plumb for both CAW and non-CAW water sources, an ordinance addressing this process is timely.  It should be noted that staff continues to have concerns that were raised at the September 22, 2008 Board meeting.  Specifically:

 

·        There is the potential contamination of the CAW system due to accidental or intentional connection to an untreated, unregulated source (especially single-family residential well or other situations without professional operators and financial resources to maintain the system).  A backflow prevention device is required for any CAW connection that also uses an alternative supply, which minimizes this risk.  Backflow devices must be certified annually at a cost to the property owner;

 

·        Potential to unlawfully use CAW water without a benefit of an MPWMD Water Permit for the portion of the building that should be served by non-CAW water (undetected source change is possible with minimal plumbing work).  This activity would be virtually impossible to enforce and could potentially impact the CAW water use in the District.

·        Difficulty accurately accounting for CAW or non-CAW use in a drought/rationing scenario.  Given that water users would be given a per-capita ration for each system, a dual-plumbed system would afford this type of user with an inequitable ration.

 

·        This ordinance is not intended to address greywater systems.  Greywater systems require specific permitting by the County and are not usable as potable sources of water.

 

RECOMMENDATION:  Staff will provide feedback on this ordinance from the Monterey County Department of Environmental Health at the meeting.  The Rules and Regulations Review Committee should then discuss the draft ordinance and formulate a recommendation to the Board. 

 

BACKGROUND:  It has been the District’s administrative practice to allow different water sources to supply water for separate structures (i.e., caretaker, auxiliary unit) on a property.  This practice allows both well water and potable water from another distribution system to provide supply.  Usually, this occurs on properties that have water supplied by California American Water (CAW) and where a single-connection water distribution system (i.e., private well) is also available on site.  The District’s administrative practice is to issue a water permit when a new structure is physically separate from the structure(s) served by CAW.  This practice usually occurs when there are inadequate CAW water credits available on the site or when the jurisdiction has inadequate water in its allocation to supply the proposed project.  A separate and distinct Board-approved policy allows the use of water from non-CAW sources to fill swimming pools. 

 

IMPACTS ON STAFF/RESOURCES:  The addition of dual plumbing in one building will cause a need for District staff to inspect a property during construction to verify plumbing and identification of non-CAW water lines.  Dual plumbing may also impact CAW staff who have to verify backflow protection and Health Department staff who must authorize the water system as a secondary supply.

 

EXHIBIT

2-A      Draft Dual Plumbing Ordinance

 

 

 

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