Commercial, Industrial, Institutional Standard and Performance Measures

Published: July 23, 2021

The Basics

  • The commercial, industrial, and institutional (CII) landscape standard applies to Commercial, Industrial, and Institutional dedicated irrigation metered accounts only. 
  • Similar to the outdoor residential standard, the CII landscape standard uses concepts like evapotranspiration, irrigation efficiency and landscape area to calculate a water use budget for a supplier’s total CII dedicated irrigation accounts.
  • Unlike the outdoor residential standard, it is the responsibility of the water suppliers to map the landscape area of their dedicated irrigation accounts.  The total landscape area will then be incorporated into a landscape water use equation/standard (provided by DWR) to produce a supplier level CII landscape budget in gallons.
  • The state will not enforce CII landscape budgets for individual parcels/customers.
  • Other CII water use is not subject to volumetric standards (like breweries, salons, and laundries) and will be addressed through  performance standards.

Updates

October 2022

Below is a summary of DWR’s recent Long Term Framework recommendations to the State Water Board as submitted on Thursday, September 29, 2022.

Note that these recommendations are subject to change per the final rulemaking process that allows for additional evaluation and public comment.  The State Water Board is expected to initiate final rulemaking in early 2023, as announced at CalWEP’s fall Plenary on September 8, 2022.

CII Outdoor Standard for DIMs:

  1. Existing landscapes: Established an ETF of 0.80 and will decrease to an ETF of 0.63 by 2030 with no further recommendations to reduce. Note modifications are allowed for SLAs.
  2. New landscapes (after Jan. 1, 2020): Established an ETF of 0.45 with potential to decrease based on future MWELO amendments. Note modifications are allowed for SLAs.
  3. Within 5 years of rule adoption, identify and measure landscape area.
  4. Areas that qualify as SLAs include: Bioengineered slopes, public swimming pools and supplemental water for ponds or lakes including those that sustain wildlife, recreation or other public benefit.
  5. Exempt landscapes: those exempt within Government Code 65598 and 2015 MWELO

CII Performance Measures:

  1. Within 5 years following rule adoption, reclassify CII accounts based on 19 water-centric categories. Where DWR will provide technical assistance and guidance for mapping CII water used into the classification categories.
  2. Established a 1-acre threshold for converting CII MUMs to DIMs, DIM equivalent technologies, or in-lieu technologies. Installation must be completed within 5 years of rule adoption.
  3. The following technologies shall qualify as in-lieu technologies for CII landscapes with MUMs that exceed the 1-acre threshold:
    • Water budget-based rate structures
    • Water budget-based management without a rate structure
    • Hardware improvements with enhanced performance
    • Remote sensing combined with other data and hardware improvements
    • Landscape plant palette transformation programs
    • Others (as approved by the State Water Board)

If a supplier opts to install an in-lieu technology rather than a DIM (or equivalent), they must also implement BMPS for communication, irrigation system maintenance and irrigation scheduling. Date for compliance with within 5 years of rule adoption.

  1. Develop a CII BMP implementation program specific to a supplier’s service area and target to CII accounts that exceed the following thresholds:
    • Top 20% of water-use sector
    • Top 5% of individual CII accounts (excluding process water use)

BMP implementation must address each of the following categories: Outreach, technical assistance, and education; incentives; landscape; collaboration and coordination; and operational. Suppliers must also document increased water use efficiency after implementation. BMPs must be implemented within 3 years of rule adoption. Note that alternative pathways could be considered for suppliers who have long-term CII programs where additional savings may not be achievable.

January 2022

At the January 25, 2022 DWR meeting regarding CII Performance Measure Recommendations, the following information was provided:

CII-DIM Size Threshold

“DWR recommends the conversion for a CII-DIM or in-lieu technology when the aggregate irrigated landscape area within a parcel is greater than one acre.”

  • The threshold for converting mixed-use-meters (MUMs) to Dedicated Irrigation Meters (DIM) on commercial accounts was recommended for irrigated landscape areas > 1 acre.
  • In-lieu technology could be used instead of a DIM even for irrigated landscapes > 1acre, but must follow the “In-lieu technologies performance measures”.
  • The following technologies can qualify as in-lieu:
    • Water budget-based rate structure
    • Water budget-based management (no rate structure)
    • Hardware improvements
    • Remote sensing combined with other available information
    • Other technologies meeting the burden of proof
  • Use of in-lieu technologies will require complementary BMPs implemented along with the technology. The required BMPs include:
    • Communications
    • Irrigation system inspections, repair and maintenance
    • Proper irrigation scheduling

CII Water Use BMPs

  • CII process water is categorially excluded from the CII Performance Measures
  • CII BMPs Performance Measure does NOT require quantification of changes in CII water use associated with implementation
  • BMP implementation individual customer threshold is set at CII water users in the top 2.5% of all CII Water users
  • BMP implementation sector (classification) threshold is set at CII water users in the top 20% of all CII Water users
  • CII customers are excluded if process water comprises 80% or more of their total water use
  • The five categories of BMP implementation include:
    • Outreach and Education
    • Incentive Programs
    • Landscape
    • Collaboration and Coordination
    • Operational
  • An implementation plan and schedule for all CII-BMPs must be developed
  • Suppliers must document associated WUE improvements and expected successes
  • Suppliers must identify metrics or key performance indicators that will determine success

Example Timeline of CII PM Implementation:

 

Comments on the draft CII Performance Measure recommendation are due to DWR by COB February 8, 2022. Email to: [email protected]

October 2021

At the October 25, 2021 DWR meeting the proposed equation for calculating the outdoor urban water use objective (UWUO) for CII-DIMs and a suggested threshold for splitting mixed-use-meters (MUMs) at CII parcels was presented.

CII-DIM Urban Water Use Objective

The following equation was recommended for calculating the UWUO for CII-DIMs for the period spanning 2023 to 2029:

  • CII-DIM UWUO = (0.62) x {[(CII-DIM Regular Landscape Area) x (0.8) x (ETo-Peff)] + [(New Landscape Area) x (0.45) x (ETo)] + [(Special Landscape Area) x (ETo)]} + Exempt Water Volume

Threshold for DIM Conversion

DWR staff indicated they were considering a DIM threshold based on an area of 20,000 square feet or greater and were no longer exploring a volumetric threshold. All considerations as they relate to a threshold for MUM conversion and as presented on the 25th include:

  1. Threshold for conversion is based on landscape area size
  2. Conversion to a DIM or DIM-equivalent technology is subject to the CII-DIM Standard
  3. Conversion to in-lieu technology is subject to performance measure reporting.

Check out the slides here.

August 2021

The Urban Water Use Objective shall include the aggregate estimated efficient outdoor irrigation of landscape areas with dedicated irrigation meters or equivalent technology in connection with CII water use.

Dedicated Irrigation Meters

DWR is requesting information to inform a threshold to determine which dedicated irrigation meters should be included in the regulation and not - could be based on size, volume, etc.

Option 1: Acreage Option 2: Volume Option 3: Behavior

A DIM or equivalent technology is required for existing landscape areas that are of:

  • 10,000 square feet or greater if DIM is used
  • 5,000 square feet or greater if an equivalent technology is used

A DIM or equivalent technology is required for existing landscape areas with the equivalent Maximum Allowed Water Allowance (MAWA) water budget for potable water irrigation under local climate conditions and consistent with MWELO exceeding the volume for:

  • Irrigating 10,000 square feet of turf if a DIM is used
  • Irrigating 10,000 square feet of turf if an equivalent technology is used

A DIM is required for existing landscape areas that meet the threshold in Options 2 that consistently uses more than 140% of the applicable MAWA water budget.

(Note Option 1 is less compatible due to the focus on acreage but not volume)

 

CII Classification

DWR must provide “Recommendation for a CII water use classification system for CA that address significant uses of water.” (CWC Section 10609.10 (b) (1)

DWR has proposed a classification system for CII accounts for a standardized method statewide and is looking for feedback. ACWA has submitted a recommended classification system to DWR. A summary of these options is presented in the table below:

Option 1: Water-Centric/Water Use-Focused Option 2: Building on Existing System Option 3: Ramping up Implementation

Category Total: 17 + 1 (dedicated irrigation meter)

  • Based on Task Force and WRF Kiefter, and other considerations (e.g. Mitchell Whitepaper)

Category: 18 + 1 (dedicated irrigation meter)

  • Based on EPA's EnergyStary Property Classification System (not including voluntary, public facing benchmarking tool in the Portfolio Manager)

Category: 3 + 1 (dedicated irrigation meter)

  • Based on ACWA June recommendations

 

Timeline of events

  • Jan. 25, 2022 – Present draft recommendation on CII performance measures including the size threshold for splitting meters and to solicit add’l feedback from stakeholders regarding these recommendations.
  • Nov. 17 - Present the final draft recommendations for CII Water Use Classification System and Guidance and Methodologies (Register)
  • Nov. 16 - Present the final draft recommendations for CII outdoor landscape area with dedicated irrigation (Register)
  • May 17 – DWR White Paper on BMPs
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