Staff Report - Onsite Water Reuse and Dual Plumbing Study - Findings and Preliminary Recommendations — Law and Legislation Committee, July 19, 2022 (part 1 of 2)

City of Sacramento
Law and Legislation Committee Report
915 I Street, 1st Floor
Sacramento, CA 95814
www.cityofsacramento.org
File ID: 2022-01264 7/19/2022 Discussion Item 04.

Title: Onsite Water Reuse and Dual Plumbing Study - Findings and Preliminary Recommendations
File ID: 2022-01264
Location: Citywide
Recommendation: Review and comment on the Onsite Water Reuse and Dual Plumbing Study findings and preliminary recommendations and timeline for a potential ordinance that would facilitate sustainable and resilient water management through dual plumbing and onsite non-potable water reuse for new buildings.

Contact: Yvette Rincon, Chief of Staff to the Director of Utilities, 916-808-1806, [email protected] Department of Utilities, Laura Tuller, Associate Planner, (916) 808- 3546, [email protected] Matt Hertel, Principal Planner, (916) 808-7158, [email protected], Community Development Department Presenter: Yvette Rincon, Chief of Staff to the Director of Utilities, 916-808-1806, [email protected] Department of Utilities
Attachments:
1-Description/Analysis
2-Onsite Water Reuse and Dual Plumbing - Preliminary Recommendations 3-Onsite Water Reuse and Dual Plumbing Study
Description/Analysis
Issue Detail: California is in a historic drought period, with the beginning of 2022 marking the driest January-March stretch in over 100 years. While the state has experienced drought historically, the impacts of climate change are projected to increase the intensity and frequency of droughts through 2050, even if global greenhouse gas emissions are drastically reduced and eliminated in the coming decades.

On February 2, 2021, City Council approved $4.4 million one-time allocation for the 2021 Climate City of Sacramento Page 1 of 7
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Implementation Work Plan projects in the Fiscal Year 2020/2021 Midyear Budget (Resolution No. 2021-0029), which supports additional work for water conservation and workforce tasks. On June 1, 2021, City Council adopted a Resolution No. 2021-0166 directing staff to the evaluate water conservation policies that could conserve water while promoting green job opportunities.

A study to assess the feasibility of requiring dual plumbing in certain types of large commercial, non- residential buildings was initiated in January 2022. The completed study can be found as Attachment

3. Dual plumbing is a system of plumbing installation used to supply both potable and non-potable water to a building for indoor and/or outdoor end uses. Dual plumbing systems can be used for reuse of rainwater, greywater, and/or blackwater that is captured and treated onsite, or they can be designed to connect to municipal sources of recycled water. According to the United States Environmental Protection Agency, up to 95% of water demand in commercial buildings can be met with non-potable water. Common end uses for non-potable water are toilet/urinal flushing and irrigation. Dual plumbing for reuse of greywater and rainwater is currently permitted under the California Plumbing Code (CPC). Onsite reuse of blackwater is not currently permitted under the CPC. However, forthcoming state regulations through SB 966 will provide water quality standards for all non-potable source water types to be treated and reused onsite if a local program is implemented.

SB 966, which was signed into law in 2018, requires the State Water Board to adopt regulations on or before December 1, 2022, for risk-based water quality standards for the onsite treatment and reuse of non-potable water for non-potable end uses in multi-unit residential, commercial, and mixed-use buildings. In addition, on or before December 1, 2023, the California Department of Housing and Community Development, in consultation with the State Water Board, is required to develop and propose for adoption any necessary corresponding building standards to support the risk-based water quality standards established by the State Water Board. Existing onsite treated non-potable water systems in operation before the effective date of the regulations will be required to comply with the regulations within two years of the effective date.

This staff report provides the key findings from the study, additional considerations, next steps, and a preliminary framework for ordinance development. City staff seeks direction from the Law and Legislation Committee on the preliminary ordinance framework and timeline (attachment 2).

Policy Considerations: The 2035 General Plan includes the following key policies related to water conservation:

ER 6.1.7 Greenhouse Gas Reduction in New Development. The City shall reduce greenhouse gas emissions from new development by discouraging auto dependent sprawl and dependence on the private automobile; promoting water conservation and recycling; promoting development that is compact, mixed use, pedestrian friendly, and transit oriented; promoting energy-efficient building design and site planning; improving the jobs/housing ratio in each community; and other methods of City of Sacramento Page 2 of 7
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reducing emissions.

On November 12, 2019, Council adopted the Vision and Guiding Principles for the 2040 General Plan and Climate Action and Adaptation Plan Update. This document includes the commitment to take bold action to achieve carbon neutrality by 2045 and become a leading voice in the effort to reduce greenhouse gas emissions (GHGs) and adapt to climate change. Principles of sustainable and responsible growth include:

6. Make Sacramento a model of sustainable living by promoting environmentally conscious and health promoting design of buildings, parks and infrastructure, as well as by promoting the adaptive reuse of existing buildings and the careful conservation of energy, water, open spaces, trees, and other natural resources.

Economic Impacts: The economic impacts of passing a dual plumbing ordinance would be increased construction costs for commercial non-residential development and increased demand for plumbing and onsite water treatment equipment. Some of this cost would be offset by cost savings from all electric construction, as demonstrated by California Energy Codes and Standards Cost Effectiveness Studies.

Environmental Considerations: City Council rules of procedure generally require that all proposals for ordinances must be reviewed by the Law and Legislation Committee prior to Council review and adoption. The review by the Law and Legislation Committee is not itself a project under the California Environmental Quality Act (CEQA) because it is a request for input and recommendation as an administrative activity that will not result in any direct or indirect physical change in the environment. (CEQA guidelines section 15378(b)(5).) Environmental review pursuant to CEQA will be conducted prior to any adoption of the proposed ordinance.

Sustainability: It is anticipated that a dual plumbing ordinance requiring onsite reuse of non-potable water will have a net positive environmental impact, because it will conserve valuable potable water supply by matching alternate water sources with the appropriate non-potable end use.

Commission/Committee Action: None.

Rationale for Recommendation: Staff are recommending a two-phased approach for a Dual Plumbing Ordinance (attachment 2) for new buildings for the reasons outlined below.

Sustainable and Resilient Water Management
: Onsite water reuse systems allow building owners to
match alternate water sources with the appropriate non-potable end use, such as landscape irrigation and toilet and urinal flushing, conserving valuable potable water supplies and creating a more resilient and sustainable water management system.

Just Job Transition: On January 1st, 2023, the New Building Electrification Ordinance will take effect City of Sacramento Page 3 of 7
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requiring all electric new construction for buildings three stories or less and all electric new construction for all buildings beginning on January 1, 2026. While building decarbonization will create many new jobs in multiple sectors, for plumbers and gas pipefitters, there are projected job losses.

Thus, it is important for the City and other regional policymakers take action to create opportunities to ensure there is a just transition away from fossil fuels across the Sacramento region. Dual Plumbing and Onsite Water Reuse is a potential avenue to mitigate job losses that may be caused by electrification while increasing resilience and improving adaptation to our changing climate.

Alignment with current and future regulations: Dual plumbing and onsite reuse of greywater and rainwater is currently allowed under California Plumbing Code (CPC). State regulations governing the onsite treatment of non-potable water are expected to go into effect December 1, 2022. Thus, staff recommends a two phased approach, outlined in attachment 2 of the staff report. The first phase would be a dual plumbing ordinance for greywater only, which would mitigate some initial negative job impacts of building electrification while allowing time to implement state regulations for onsite blackwater reuse (second phase).

Financial Considerations: The initial phase of the preliminary recommendations for a potential Dual Plumbing Ordinance is not anticipated to have a significant cost impact for the City. The Department of Utilities and Community Development Department could implement the initial phase with existing resources. The second phase of the preliminary recommendations for a potential Dual Plumbing Ordinance is anticipated to require additional staff resources to implement onsite treatment of non- potable resources. The financial resources that may be required to implement the second phase will not be fully known until State regulations governing onsite treatment of non-potable water go into effect on December 1, 2022. See attachment 2 for the recommended two-phased approach for a Dual Plumbing Ordinance for new buildings.

Local Business Enterprise (LBE): Not applicable.

Background
The Onsite Water Reuse and Dual Plumbing Study consists of two phases:
• Phase One: Dual Plumbing Feasibility Study (attachment 3) • Phase Two: Onsite Water Treatment Feasibility Study (to be initiated in 2024) Phase one of the study is complete, and covers regulatory, technical, and economic considerations for implementing a potential dual plumbing ordinance. The full text of the study is included as Attachment 3 of the staff report. Three case studies were developed (San Francisco, Santa Monica, City of Sacramento Page 4 of 7
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Honolulu) to better understand the technical and administrative requirements of developing and implementing a program, and preliminary cost modeling has been developed to identify the anticipated costs of installing dual plumbing and onsite non potable water treatment systems.

Phase two of the study, tentatively scheduled for 2024, will review the compliance with state mandated SB 966 requirements and related operational needs of establishing an onsite water reuse program in the City of Sacramento.

Key Findings of the Dual Plumbing Feasibility Study
· Dual plumbing installation costs: The study cost model shows that the cost of adding dual plumbing varies according to building size and type, as well as the number of plumbing fixtures per square-foot (fixture density). The cost model found that the average cost to install dual plumbing is $2.88 per sq ft (in April 2022 dollars), resulting in an average of

0.34% increase in building cost compared to buildings that are not required to install dual plumbing. This cost represents capital costs of installation only, as the cost model does not account for the maintenance or replacement costs of the dual plumbing systems or potential cost savings from reduction in potable water use. Additionally, the cost model does not account for the anticipated cost savings by not installing gas infrastructure in accordance with the City’s New Building Electrification Ordinance. Further information about the costs associated with installation of dual plumbing are included in section 4.1 of the study (attachment 3).
· Treatment and operation
: Treatment costs are highly variable depending on source water, end use (determines treatment requirements), demand (determines system size), and technology. Treatment may not be required for some irrigation end uses of greywater and rainwater, but these water sources must be treated and disinfected for indoor uses such as toilet and urinal flushing. There are increased treatment and disinfection requirements for blackwater reuse. Detailed explanations of treatment requirements for various water sources and end uses are included in section 2.4.1 of the study (attachment 3). · Testing and Inspection
: Implementation of dual plumbing and onsite water reuse will need to meet strict public health and safety requirements to prevent contamination of the potable water supply. These requirements include cross-connection testing, public notification of non-potable water sources/end uses, and system inspection. Details about testing, signage, and inspection requirements are outlined in section 2.5 of the study (attachment 3).
· Program Administration: While existing staff resources could be used to implement a basic Dual Plumbing Ordinance with greywater reuse (initial phase of preliminary recommendations), it is anticipated that additional staff resources will be required for the City of Sacramento Page 5 of 7
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Department of Utilities to implement an onsite water reuse program that includes blackwater (second phase of preliminary recommendations), with ongoing support from the Community Development Department and the Department of Public Works to review dual plumbing plans, conduct inspections, approve installations, and issue permits.

Coordination with the County of Sacramento or other water quality regulators will be required to issue and enforce treatment and testing requirements if the City requires reuse of blackwater. Details about potential program administration requirements are outlined in section 4.4 of the study (attachment 3).

Additional Considerations
In addition to assessing the basic feasibility of adopting a dual plumbing ordinance and onsite water reuse systems, staff are evaluating the potential benefits and challenges of implementing an onsite non-potable water reuse program as a means of sustainable and resilient water management and a just job transition for plumbers and gas pipefitters. Additional considerations not included in depth in the study (attachment 3) are outlined below.
· Fixture Density/Building Use Types
: The study focused on commercial, non-residential
buildings 100,000 gross square feet (gsf) or greater. This size threshold was chosen to mimic the recently reduced threshold from 250,000 gsf to 100,000 gsf for the City of San Francisco’s Onsite Non-Potable Water Systems (ONWS) program. San Francisco is widely regarded as a leader in the field of ONWS and state regulations are expected to follow the requirements of San Francisco’s program. However, in addition to size, density of plumbing fixtures is an important criterion. Because some commercial nonresidential building types (such as warehouses) have very low fixture density, the viability of onsite water reuse systems is greatly reduced. Thus, staff recommend consideration of fixture density as a potential criterion for inclusion in a dual plumbing ordinance. Detailed explanation of these fixture density criteria is included in attachment 2.
· Market Assessment and Building Size: The study revealed that since 2010, 13 commercial non-residential buildings 100,000 gsf or larger have been constructed in the City of Sacramento. 14 commercial non-residential buildings 100,000 gsf or larger have received their planning entitlements but have not yet been issued building permits. Though it fell outside the focus of the study, staff also collected data on the number of commercial non-residential buildings constructed above the 50,000 square foot threshold. Since 2010, 31 commercial non -residential buildings have been constructed that are 50,000 square feet or larger. In addition, there are 21 commercial non-residential buildings larger than 50,000 square feet which have received their planning entitlements but have not yet been issued building permits. · County Role
: Onsite reuse of rainwater and greywater does not require ongoing risk-based water quality testing if systems meet certain criteria. However, if the City of Sacramento were City of Sacramento Page 6 of 7
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to decide to adopt an ordinance and implement a local program either based on current (CPC) or upcoming (SB 966) regulations to allow or mandate the onsite reuse systems, Sacramento County may play an important role in ongoing local regulatory compliance. However, the county role is still being developed and is not clearly defined. · Potential Collaboration with Regional Sanitation: The use of municipal treated recycled water is subject to master reclamation permit governance, limited to the geographical service area, and non-potable end uses must be approved by the recycled water supplier. Currently, the recycled water that flows through Regional Sanitation’s purple recycled water pipe is used for irrigation in the Elk Grove/Laguna area, primarily for irrigation of parks. For Sacramento’s dual plumbed buildings to use the recycled water from the purple pipe for non-potable end uses, Regional Sanitation would need to allow and build capacity for these end uses as part of their recycled water program. Further collaboration would be required to study the feasibility of connection to municipal recycled water for non-potable end uses in large commercial buildings in Sacramento.

The Dual Plumbing Feasibility Study is included in Attachment 3 of the staff report.

Summary of Outreach Conducted to Date
· City and County of San Francisco: City of Sacramento staff met several times with staff from San Francisco’s Onsite Non-Potable Water Reuse program, including site visits to learn more about program implementation, potential challenges, and best practices. · City of Sacramento Staff participates in the National Blue Ribbon Commission, a group consisting of local agencies initiating on-site reuse programs and policies throughout the USA. · Sacramento County: City of Sacramento staff met with members of the Sustainability and Environmental Management teams at Sacramento County to discuss potential county roles for ongoing inspection and testing requirements if the city were to implement onsite non-potable water reuse requirements.
· Labor stakeholders: Staff have met with members of Local 447 and Sacramento-Sierra’s Building and Construction Trades Council to discuss preliminary results of the study and get feedback. Based on this outreach, staff performed additional data collection to determine the potential workforce impact of a range of size thresholds and use type criteria for buildings. · Commercial developers: Staff convened a meeting with developers who have received planning entitlements for commercial nonresidential projects but have not yet applied for building permits to gain insights into the benefits and challenges of dual plumbing systems.

City of Sacramento Page 7 of 7
1 Attachment 2-Onsite Water Reuse and Dual Plumbing – Preliminary Recommendations
Staff recommends a two-phased approach for implementation of a dual plumbing ordinance and onsite water reuse treatment requirements. The first phase contemplates requiring dual plumbing in new buildings to reuse greywater as currently permitted under the California Plumbing Code. The dual plumbing requirement would apply to commercial non-residential buildings of a certain size threshold and certain building types meeting minimum fixture densities. The second phase contemplates onsite water reuse treatment requirements. The proposed considerations and timing for both phases are detailed below. These recommendations are informed by the Key Findings of the Dual Plumbing Feasibility Study and Additional Considerations sections of this staff report.

Preliminary Recommendations Phase 1 – Dual Plumbing Ordinance Dual Plumbing Requirements
Amend Title 15 (Buildings and Construction) of the Sacramento Code to require dual plumbing in new buildings to reuse greywater as currently permitted under the California Plumbing Code. The dual plumbing requirement would apply to commercial non-residential buildings of a certain size threshold and certain building types meeting minimum fixture densities. Staff is not recommending a requirement to reuse rainwater due to the lack of consistent rainfall and the additional cost of installing and maintain rain catchment systems.
 Permitted sources of greywater:
o clothes washing machines, hand washing sinks (non-kitchen sinks), showers and bathtubs  Permitted end uses of greywater:
o toilet flushing, urinal flushing, landscaping/irrigation  Options for required treatment and equipment:
o Passive System for landscaping/irrigation: gravity-fed system for landscaping (if building is located above end use)
 Anticipated equipment: two pipes and diverter valve
o Collection System for toilet and urinal flushing and above grade landscaping/irrigation  Anticipated equipment: storage tank, sump pump, two pipes, diverter valve  Minimal treatment of greywater used for toilet and urinal flushing may be required under SB 966 to prevent odors
Requirements would apply to new commercial nonresidential buildings of 100,000 sq. ft. or greater that fall into certain occupancy groups listed below, as defined by the California Plumbing Code (Table 421.1 & Table A). These occupancy groups are recommended due to the number of fixtures required and the anticipated water conservation benefit. The size threshold of 100,000 sq. ft. or greater is recommended to maximize the water conservation benefit, limit the percentage of cost of dual plumbing compared to total construction costs, and align with the threshold used by the City and County of San Francisco.  Note: City Code Title 15 (Buildings and Construction) only applies to building types under the City’s purview and does not generally include State or Federal buildings, hospitals, or public schools. 2  Group A:
o A-1: Assembly occupancy (fixed or permanent seating) - theaters, concert hall, and auditoriums
o A-2: Assembly occupancy – restaurants, pubs, lounges, nightclubs, and banquet halls o A-3: Assembly occupancy (typical without fixed or permanent seating) – arcades, places of worship, museums, libraries, lecture halls, gymnasiums (without spectator seating), indoor pools (without spectator seating)
o A-4: Assembly occupancy (indoor activities or sporting events with spectator seating) – swimming pools, skating rinks, arenas, and gymnasiums
o A-5: Assembly occupancy (outdoor activities or sporting events) – amusement parks, grandstands and stadiums
 Group B: Business occupancy (office, professional or service type transactions) – banks, vet clinics, car wash, beauty salons, laundries and dry cleaning, or training facilities not located within school, and printing shops
 Group E: Education occupancy – private schools
 Group F1, F2: Factory or Industrial occupancy – fabricating or assembly work  Group M: Mercantile occupancy (the sale of merchandise and accessible to the public)  The following occupancy groups are recommended for exclusion from dual plumbing requirements based:
o Group B: Business occupancy: hospitals, ambulatory health care facilities, education institutions (above high school), post offices (not generally subject to City Code Title 15 (Buildings & Construction)
o Group E: Education occupancy –public schools (not generally subject to City Code Title 15 (Buildings & Construction)
o Group I: Institutional occupancy (residential or uses not generally subject to City Code Title 15 (Buildings & Construction)
o Group R (residential uses)
o Group S-1, S-2: Storage occupancy – storage of goods, warehouse, aircraft hangar, food products, appliances (very low fixture density)
Effective Date
Staff recommends bringing forward an ordinance requiring dual plumbing for new buildings as described above, within six months of the effective date SB 966 (anticipated for December 1, 2022) to provide staff with adequate time to ensure that a dual plumbing ordinance contemplated by the City is consistent the requirements SB 966 and 2022 California Plumbing Code (effective January 1, 2023). See the staff report for a description of the anticipated SB 966 requirements. Although this recommended effective date would not perfectly align with the initial effective date of New Building Electrification Ordinance of January 1, 2023, for new construction of 1-3 stories, it would ensure compliance with State requirements.

Preliminary Recommendations Phase 2 – Onsite Water Reuse Treatment for Grey & Blackwater
After the state adopts water quality standards for onsite treatment of non-potable water (including blackwater), per SB 966 (effective December 1, 2022), and the permitting agency establishes their 3 program, the City could then incorporate these standards for buildings to collect, treat, and re-use greywater, rainwater, and blackwater onsite. The Department of Utilities will be initiating an Onsite Water Treatment Feasibility Study in 2023 to determine the operational needs of establishing an onsite water reuse program in the City of Sacramento. Staff recommends onsite water reuse treatment requirements for the building types described above go into effect on January 1, 2026, to align with the 2025 California Plumbing Code and the New Building Electrification Ordinance effective date for new building of 4 or more stories.

2882 Prospect Park Drive, Suite 240
Rancho Cordova, California 95670
(916) 858-2700

Dual Plumbing and
Onsite Non-Potable
Water Systems Study
29 June 2022

Prepared for

City of Sacramento
Department of Utilities
1395 35th Avenue
Sacramento, California 95822

KJ Project No. 2270001.00

Acknowledgements
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx The Dual Plumbing and Onsite Non-Potable Water Systems Study was prepared for the City of Sacramento by Kennedy/Jenks Consultants, Inc. with major contributions by Roth Ecological Design International, LLC and O’Connor Construction Management, Inc.

Front Matter Page i
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Table of Contents
Glossary ........................................................................................................................................ v List of Acronyms .......................................................................................................................... vi Executive Summary ....................................................................................................................... I Regulatory Considerations .................................................................................. I Technical Considerations .................................................................................. III Testing, Inspection, and Public Notification Considerations ............................. III ONWS Program Development through One Water Vision ................................ V Economic Considerations ............................................................................... VIII Dual Plumbing Ordinance Development Options .......................................... XIV Section 1: Introduction and Background ................................................... 1-1

1.1 Study Background ............................................................................... 1-1

1.2 Project Stakeholders ........................................................................... 1-2

1.3 Study Organization .............................................................................. 1-2 Section 2: Implementation Considerations for Onsite Water Reuse Dual Plumbing ............................................................................ 2-1

2.1 Dual Plumbing Systems ...................................................................... 2-1

2.2 Onsite Non-Potable Water Systems ................................................... 2-2

2.3 Regulatory Considerations .................................................................. 2-3

2.3.1 Recycled Water Regulations .................................................... 2-3

2.3.1.1 CCR – Title 17 ....................................................... 2-3

2.3.1.2 CCR – Title 22 ....................................................... 2-4

2.3.1.3 State Recycled Water Policy ................................. 2-5

2.3.1.4 Statewide General Order ....................................... 2-5

2.3.2 California Plumbing Code ........................................................ 2-5

2.3.3 ONWS Regulations .................................................................. 2-6

2.4 Technical Considerations .................................................................... 2-7

2.4.1 Recycled Water Treatment Standards ..................................... 2-7

2.4.1.1 Recycled Water Treatment for Non-Potable
Uses ....................................................................... 2-7

2.4.1.2 Addi tional Considerations for Indoor Use of
Recycled Water ..................................................... 2-8

2.4.2 Proposed Treatment Standards for ONWS ............................. 2-9

2.4.2.1 Treatment Processes for Alternate Water
Sources ................................................................ 2-11

2.4.3 Treatment Systems for Alternate Water Sources .................. 2-12

2.4.3.1 Rainwater ............................................................. 2-12

2.4.3.2 Stormwater .......................................................... 2-13

2.4.3.3 Graywater ............................................................ 2-13

2.4.3.4 Blackwater Treatment .......................................... 2-14 Table of Contents (cont’d)
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2.4.3.5 Other Alternate Water Sources ............................ 2-14

2.5 Testing and Inspection Requirements ............................................... 2-14

2.5.1 Cross-Connection Testing ..................................................... 2-14

2.5.2 Signage and other System Requirements ............................. 2-16

2.5.2.1 Recycled Water Systems Identification ............... 2-16

2.5.2.2 ONWS Identification ............................................ 2-17

2.5.2.3 Other Public Health Protections ........................... 2-17

2.6 Developing an ONWS Program ........................................................ 2-17

2.7 Development of an ONWS Ordinance .............................................. 2-19 Section 3: One Water Program Development through One Water Vision ......................................................................................... 3-1

3.1 Case Studies for One Water and Dual Plumbing ................................ 3-1

3.1.1 San Francisco Case Study ...................................................... 3-2

3.1.2 Santa Monica Case Study ....................................................... 3-7

3.1.3 Honolulu Case Study ............................................................. 3-11

3.2 ONWS One Water Vision .................................................................. 3-16

3.2.1 Sacramento One Water Vision .............................................. 3-17

3.2.2 Role of Onsite Water Reuse in the Sacramento One
Water Vision .......................................................................... 3-18

3.2.3 Implementation of a Dual Plumbing Ordinance ..................... 3-18 Section 4: Economic Considerations ......................................................... 4-1

4.1 Dual Plumbing Construction Cost Comparison ................................... 4-1

4.2 ONWS Treatment and Operations Costs ............................................ 4-3

4.3 Onsite Non-Potable Water System Market Assessment
Comparison ......................................................................................... 4-8

4.3.1 Market Assessment Mapping ................................................... 4-8

4.3.2 Market Assessment for a Typical Commercial Property ........ 4-11

4.4 ONWS Program Administration Resources ...................................... 4-13

4.5 Cost Summary and Funding Options ................................................ 4-14 Section 5: Dual Plumbing Ordinance and ONWS Program Feasibility and Next Steps .......................................................................... 5-1

5.1 C
ase Studies to Demonstrate the Viability of Implementing Dual Plumbing and ONWS when Supported by the Right Ordinance ......... 5-1

5.2 Dual Plumbing Ordinance Considerations .......................................... 5-2

5.2.1 Regulatory Considerations ....................................................... 5-2

5.2.2 Technical Considerations ......................................................... 5-2

5.2.3 Administrative Considerations ................................................. 5-2

5.2.4 Economic Considerations ........................................................ 5-3

5.3 ONWS Considerations ........................................................................ 5-4 Table of Contents (cont’d)
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5.3.1 Regulatory Considerations ....................................................... 5-4

5.3.2 Technical Considerations ......................................................... 5-4

5.3.3 Administrative Considerations ................................................. 5-5

5.3.4 Economic Feasibility ................................................................ 5-7

5.4 ONWS Program Implementation Considerations ................................ 5-7

5.4.1 Pilot Test .................................................................................. 5-7

5.4.2 Program Size Considerations .................................................. 5-8

5.4.3 ONWS Alternate Sources Considerations ............................... 5-8

5.4.4 ONWS Program Implementation and Cost .............................. 5-9

5.5 Recommended Next Steps ............................................................... 5-10

List of Tables
Table ES-1: City of Sacramento Onsite Non-Potable Water Reuse One Water Vision Framework – Key Elements ................................................................................ VII Table 2-1: Log Reduction Targets for 10-4 per person per year for ONWS ....................... 2-10 Table 2-2: Treatment Process Log Reduction Credits....................................................... 2-10 Table 2-3: ONWS Treatment Processes for Different End Uses ....................................... 2-11 Table 2-4: Rainwater Treatment Systems Water Quality .................................................. 2-13 Table 3-1: San Francisco Onsite Water Reuse Program Core Agencies (Adapted from SFPUC, 2021) ............................................................................................ 3-4 Table 3-2: Core Agencies for City of Santa Monica Recycled Water Ordinance ............... 3-10 Table 3-3: Summary of Core Working Agencies for Honolulu ........................................... 3-12 Table 4-1: Dual Plumbing Cost Model Results for the City of Sacramento ......................... 4-1 Table 4-2: ONWS Treatment Costs (based on San Francisco Onsite Water Reuse Program Projects) .............................................................................................. 4-7 Table 5-1: Initial ONWS Program Coordination Matrix ........................................................ 5-6

List of Figures
Figure ES-1: ONWS Alternative Water Sources......................................................................... II Figure ES-2: Cost Per Area ($/sq ft) to Add Dual Plumbing to Commercial Buildings ............ VIII Figure ES-3: Percent Increase to Total Project Cost to Add Dual Plumbing to Commercial Buildings .......................................................................................... VII Figure ES-4: ONWS Installation Costs, $/sq ft ........................................................................... X Figure ES-5: Annual ONWS O&M Costs, $/gallons ................................................................... X Figure ES-6: ONWS Opportunity Areas .................................................................................. XII Figure 2-1: Non-Potable Demands in Commercial Buildings ................................................ 2-1 Figure 2-2: ONWS Alternative Water Sources...................................................................... 2-2 Figure 2-3: Multi-Barrier Approach to Reuse ........................................................................ 2-4 Figure 2-4: Types of Non-Potable Reuse and Associated Treatment Processes ................. 2-8 Table of Contents (cont'd)
Front Matter Page iv
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Figure 2-5: Example Recycled Water Advisory Sign .......................................................... 2-16 Figure 3-1: Kapālama Water Demands and Potential Supplies (District Scale) ................. 3-13 Figure 3-2: Annual Water Portfolio and Annual Non-Potable Water Demands .................. 3-15 Figure 3-3: Blueprint for a One Water Approach ................................................................ 3-16 Figure 4-1: Cost Per Area ($/SF) to Add Dual Plumbing to Commercial Buildings .............. 4-2 Figure 4-2: Percent Increase to Total Project Cost to Add Dual Plumbing to Commercial Buildings ......................................................................................... 4-2 Figure 4-3: Summary of Projects Implemented Under the San Francisco Onsite Water Reuse Program by Source Water ....................................................................... 4-4 Figure 4-4: Summary of Projects Implemented Under the San Francisco Onsite Water Reuse Program by End Uses ............................................................................. 4-5 Figure 4-5: ONWS Opportunity Areas ................................................................................ 4-10 Figure 4-6: Pre and Post Development of 8340 Delta Shores Circle .................................. 4-11 Figure 4-7: Estimated Non-Potable Water Supplies and Demands for 8340 Delta Shores Circle .................................................................................................... 4-12 Figure 4-8: Estimated Capture and ONWS Capital Cost for 8340 Delta Shores Circle by ONWS Type ................................................................................................ 4-13

List of Appendices
A Case Study Summary Sheets
B Case Study Ordinances
C Onsite Water Reuse Strategy and One Water Vision Draft Framework D Dual Plumbing Cost Model
E San Francisco Onsite Reuse Program Projects Summary

Front Matter Page v
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Glossary

Air Gap: A physical break between a supply pipe and a receiving vessel as set forth in the local or state plumbing code.

Blackwater: Wastewater originating from toilets, urinals, and/or kitchen counters (i.e., kitchen sinks and dishwashers).

Condensate: Water vapor collected from air conditioning systems

Cross-Connection: Any physical connection or arrangement between potable water and any source of contamination

Disinfection: A physical or chemical process, including, but not limited to, ultraviolet radiation, ozonation, and chlorination that is used for removal, deactivation or killing of pathogenic microorganisms.

First Flush Diverter: A device or mechanism that diverts a quantity of rainwater collected from a surface following the onset of a rain event.

Foundation Drainage: Nuisance groundwater that is extracted to maintain a building’s or facility’s structural integrity and would otherwise be discharged to the sanitary or combined sewer system. It does not include groundwater extracted for beneficial use that is subject to the groundwater well regulations

Graywater: Wastewater collected from non-blackwater sources, such as bathroom sinks, showers, bathtubs, clothes washers, and laundry sink

Non-Potable Water: Non-potable water collected from alternate water sources, treated, and intended to be used on the project applicant’s site or district-scale project and is suitable for direct beneficial use.

Onsite Non-Potable Water System (ONWS): A system in which water from local sources is collected, treated, and used for non-potable uses at the building to district/ neighborhood-scale, generally at a location near the point of generation.

Rainwater Catchment: Rain that is collected from a building roof or other manmade above ground collection surfaces.

Stormwater: Precipitation runoff from rain or snowmelt events that flows over land and/or impervious surfaces (e.g., streets and parking lots). Stormwater also includes runoff from roofs with frequent public access.

Front Matter Page vi
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx List of Acronyms

Acronym Definition
AFY Acre-feet per Year
BOD Biochemical Oxygen Demand
CCR California Code of Regulations
CPC California Plumbing Code
COD Chemical Oxygen Demand
CCH City and County of Honolulu
CDD Community Development Department
DPH Department of Public Health
DOU Department of Utilities
DDW Division of Drinking Water
gpd Gallons per Day
gal/yr Gallons per Year
GSI Green Stormwater Infrastructure
LEED Leader in Energy and Environmental Design
LID Low Impact Development
LRT Log Reduction Target
MWD Metropolitan Water District
MF Microfiltration
MG Million Gallons
MGD Million Gallons per Day
MG/yr Million Gallons per Year
NPDES National Pollutant Discharge Elimination System
NSF National Sanitation Foundation
ONWS Onsite Non-potable Water Systems
O&M Operation and Maintenance
Central Valley Regional Board Central Valley Regional Water Quality Control Board RW Recycled Water
ROI Return of Investment
RO Reverse Osmosis
ROM Rough Order of Magnitude
SMUD Sacramento Municipal Utility District
Regional San Sacramento Regional County Sanitation District SFDPH-EH San Francisco Department of Public Health – Environmental Health SFPW San Francisco Public Works
SFPUC San Francisco Public Utilities Commission
SSO Sanitary Sewer Overflow
SMURRF Santa Monica Urban Runoff Recycling Facility
SB Senate Bill

Front Matter Page vii
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Acronym Definition
sq ft Square Feet
State Water Board State Water Resources Control Board
SWIP Sustainable Water Infrastructure Project
SWMP Sustainable Water Master Plan
TDS Total Dissolved Solids
TSS Total Suspended Solids
UF Ultrafiltration
US EPA United State Environmental Protection Agency
UV Ultraviolet
WERF Water Environment Research Foundation
WRF Water Research Foundation

Executive Summary Page I
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Executive Summary
In June 2021, Sacramento City Council directed the Community Development Department and the Department of Utilities to evaluate opportunities for expansion of water conservation standards for buildings. The City of Sacramento is considering new approaches to water supply, driven by drastic changes in the water landscape due to drought, climate change, regulations, population growth and economics. The City’s Climate Action and Adaption Plan and New Building Electrification Ordinance are initiatives that lay out key elements of the City’s sustainability strategies. As a result of these initiatives, the City is considering the development of an ordinance for new non-residential buildings of a certain size threshold to install dual plumbing as part of a non-potable water reuse strategy.

This Dual Plumbing and Onsite Non-Potable Water Systems (ONWS) Study has been prepared to summarize the feasibility of implementing dual plumbing systems in Sacramento.

This Study assesses the feasibility, benefits and implications of implementing an ordinance to pre-plumb new commercial (non-residential) developments with dual plumbing for future non- potable supply with either municipal recycled water or ONWS. This Study will also be used to support stakeholder outreach and solicit feedback from parties that may be impacted by a dual plumbing ordinance. The dual plumbing ordinance is intended to be the first phase in the development of the City’s non-potable water reuse strategy. The next phase, which is anticipated to happen by or after 2024, will address water treatment requirements in further detail, including compliance with state mandated requirements for ONWS, operational responsibilities, system protection needs, additional partnerships and engagement, and the cost and funding impacts.

The Department of Utilities and Community Development Department conducted this work in coordination with the Department of Public Works, and the City Manager’s Office of Climate Action and Sustainability. Sacramento Regional County Sanitation District and Sacramento County Environmental Health Division were also consulted.

Regulatory Considerations
Throughout California, the use of treated municipal wastewater for non-potable demands (commonly referred to as municipal recycled water) has been growing in popularity during the last century. The production and use of municipal recycled water must adhere to strict regulations stipulating the levels of treatment, allowable types of reuse, and water quality requirements. Regulations related to municipal recycled water production and use have been in place since the 1970s and are contained within Title 17 and 22 of the California Code of Regulations (CCR).

Driven by severe droughts experienced in the state, California continues to develop regulations to support the expansion of municipal recycled water use, as well as the reuse of other alternative (non-potable) water sources, as shown in Figure ES - 1, to offset potable water demands. One method gaining momentum is the collection, treatment, and reuse of alternative water sources for non-potable needs within a building, which relies on dual plumbing and an ONWS. The requirements for dual plumbing systems that use alternative water sources such as those shown in Figure ES - 1 are regulated by the California Plumbing Code (CPC) Chapter 15,

Executive Summary Page II
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx 16 and the State Water Resources Control Board - Division of Drinking Water (DDW) for backflow protection. Currently CPC Chapter 15 and 16 specifies minimum water quality requirements for rainwater capture systems to meet indoor and outdoor demands. The CPC also allows for the reuse of graywater to meet indoor and outdoor demands but does not require treatment to minimum levels; instead, CPC specifies that graywater treatment equipment and components meet the material and manufacturing standards of NSF/American Standards Institute (ANSI) Standard 350 (NSF/ANSI Standard 350).

Figure ES - 1: ONWS Alternative Water Sources

Source: Onsite Non-Potable Water Reuse Practice Guide, William J Worthen Foundation, 2018 Unlike municipal recycled water and rainwater capture, there are currently no regulations in California regarding treatment standards or water quality limits for non-potable supplies treated by ONWS for reuse. Draft regulations are being developed by DDW for risk-based water quality standards for onsite treatment and reuse of non-potable water for non-potable end uses in multi- unit residential, commercial, and mixed-use buildings. These regulations are expected to be finalized and adopted by December 1, 2022. Any ONWS that are in operation before the effective date of the regulations will be required to comply with the regulations within two years of the effective date.

The City of Sacramento could adopt a dual plumbing ordinance consistent with the CPC, but additional processes would need to be established for ONWS treatment and water quality standards for alternative sources other than rainwater and graywater. Regulating ONWS will

Executive Summary Page III
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx also require the City to coordinate with Sacramento County and others to establish agency jurisdiction and powers of enforcement and regulation.

If the City of Sacramento adopts an ordinance to require dual plumbing supplied by municipal recycled water for indoor use, the local Water Reclamation Permit with the Central Valley Regional Water Quality Control Board (Regional Board) will need to be amended. The current permit, which is held by Sacramento Regional County Sanitation District, does not allow for indoor uses and the City would need to work with Sacramento Regional County Sanitation District to amend the Water Reclamation Permit if indoor use of municipal recycled water is desired within the City of Sacramento.

Technical Considerations
The implementation and use of dual plumbing and ONWS is dependent on the source and end- use of non-potable water. Dual plumbing systems allow for the supply and use of potable and alternate (non-potable) water sources to supply different fixtures and systems within a building or development. Alternative sources that can be used to supply non-potable demands include:

1. Municipal Treated Recycled Water: Tertiary treated and disinfected municipal wastewater, or advanced treated recycled water, are suitable for non-potable purpose applications such as landscape irrigation, toilet flushing, industrial non-potable uses like equipment cleaning or cooling systems, and agriculture or for environmental benefits. These treatment systems are typically centrally located with an extensive transmission and distribution system.

Non-potable demands in a commercial building include water used for toilet flushing, cooling tower make up water, irrigation systems, drain trap priming and other miscellaneous uses. The requirements for reuse vary based on (1) the source water, (2) the degree of treatment required and (3) the intended use. Generally, when more treatment is provided, the final use of the water is less restricted.

Testing, Inspection, and Public Notification Considerations Implementation of dual plumbing or ONWS in Sacramento will need to meet strict public health and safety requirements. These include on-going cross-connection testing and inspections to prevent contamination of the potable water supply with non-potable water, as well as notification requirements to make the public, and those working around non-potable water sources, aware of the different water supply systems and restrictions for these systems.

Cross-Connection Testing
Cross-connection refers to any physical connection or arrangement between potable water and any source of contamination. It is critical that no cross-connection exists between a potable and a non-potable water system to protect the quality of drinking water. Cross-connection testing is

Executive Summary Page IV
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx required for any dual plumbed system, which uses municipal recycled water or non-potable water from an ONWS, to verify that there is no potential cross-connection between the potable and non-potable water supplies. Cross-connection testing must be overseen by a Certified Cross-Connection Control Specialist.

For dual-plumbed systems, cross-connection inspections must be conducted annually, with testing of the recycled water (municipal and blackwater) systems every four (4) years, per CCR Title 17 and 22. In addition, cross-connection inspections for other alternate water sources (graywater and other onsite water supplies) are required whenever there is a major plumbing alteration.

Signage and Other System Requirements
Signage must be provided for any dual plumbed system that is either using municipal recycled water or non-potable water from an ONWS. Signage must properly indicate if the system is using recycled water or other type of non-potable water and comply with the state regulations (CPC and CCR Title 22).

Signage is required at entrances or locations where recycled water is used, like landscape areas or bathrooms where recycled water is used for toilet flushing. Signs must be located such that they are visible to users. Signs must also be included in the equipment rooms visible to workers and identifying the fixtures and equipment using recycled water or non-potable water.

In addition to signage, there are other specific requirements for irrigation systems using recycled water. This includes providing locking features for valves (except control valves), not allowing hose bibbs on recycled water piping systems, and only using quick coupler valves, which must differ from quick coupler valves used with potable water supply in areas subject to public access. CCR Title 22 also requires that any use of recycled water be confined so that its application does not pose a public health threat with restrictions on places of use and application methods.

Example Recycled Water
Advisory Sign

Executive Summary Page V
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx ONWS Program Development through One Water Vision
The One Water concept involves a collaborative and comprehensive long-term approach to community-based water management that recognizes all urban water supplies as resources (e.g., surface water, groundwater, stormwater/rainwater, wastewater, graywater, etc.). One Water policies are implemented through integrated planning to meet community and ecosystem needs. The implementation of a dual plumbing ordinance and ONWS projects in the City can be supported through this type of long-term water resource planning. A One Water Vision for the City’s Onsite Water Reuse Strategy can guide the development and implementation of an ONWS Program in the context of the City’s potable and non-potable water resources. Integral to implementation is the identification of roles and responsibilities to meet regulatory, technical and other program needs.

Onsite Non-Potable Water Reuse One Water Vision Framework Long-term implementation of a dual plumbing ordinance can be supported by the creation of a One Water Vision for the City of Sacramento, which would consist of the scope, vision, and objectives for the City’s ONWS program. As part of this Study, a preliminary One Water Vision for the City was developed to support the City’s Onsite Water Reuse Strategy. Application to other City programs and activities have not yet been evaluated.

These programs were selected based on their similarity to the City of Sacramento criteria for applicable building types, water sources, and uses, as well as the mechanism by which a dual plumbing ordinance is (to be) implemented. While none of these case studies can be directly duplicated to meet the City of Sacramento’s goals for implementing dual plumbing or ONWS, the lessons learned can be used to inform the development of the Sacramento dual plumbing ordinance and/or ONWS program.

The One Water approach takes a holistic view of a
community’s or a facility’s multiple water resources

Executive Summary Page VI
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx

Case Study 1: The San Francisco Onsite Water Reuse Program started in 2012 as a voluntary program before requiring all new buildings over 250,000 sq ft to install dual plumbing and onsite treatment in 2015. The City’s first project was the San Francisco Public Utilities Commission (SFPUC) building. Since then, the ordinance has evolved to require all new buildings over 100,000 sq ft to install dual plumbing and ONWS.

Photo: SFPUC Headquarters
Source: SFPUC, San Francisco’s Onsite Water Reuse System Projects, September 2021.

Lessons Learned:
• The Onsite Water Reuse Program evolved since its start in 2012, when implementation of ONWS was voluntary. Information gathered from these voluntary projects, including the SFPUC building, informed the update of the program and requirements, which were changed in 2015 to require the implementation of ONWS by new buildings 250,000 sq ft and larger. The current program requires new buildings 100,000 sq ft and larger to implement ONWS.
• In 2013 the program was amended to include district-scale systems. A district-scale project is when two or more buildings within a development share a system. • The program is administered by one full-time equivalent, funded through the SFPUC operating budget. The program is also supported directly by the San Francisco Department of Public Health, San Francisco Department of Building Inspections, and San Francisco Public Works, which are funded through permitting fees.

Lessons Learned:
• The Recycled Water Ordinance is part of a larger effort by the City of Santa Monica to reduce its dependence on imported water and become water self-sufficient by 2023. • The City of Santa Monica administers and enforces the requirements of the Recycled Water Ordinance; this effort will be covered through administration fees to be paid by developers at the time of building permit issuance.
• Los Angeles County Department of Public Health is delegated by the State to approve recycled water use and coordinates between applicants and DDW. • Los Angeles County Department of Public Health administers the Cross-Connection and Water Pollution Control Program and provides cross-connection control and signage regulations. For new applications for recycled water use within the City of Santa Monica, reviews, inspections and conditional use approvals are incorporated into the County’s existing processes.

Case Study 2: The City of Santa Monica Recycled Water Ordinance, adopted March 2022, requires the use of recycled water by: (1) all new developments of 7,500 square-feet or greater, and (2) existing potable water surface irrigation applications within the existing local recycled water service area. The recycled water ordinance is one element of Santa Monica’s Sustainable Water Master Plan, first adopted in 2014 and updated in 2018.

Executive Summary Page VII
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx

Lessons Learned:
• The One Water Ordinance outlines principles and procedures for how city departments and agencies work together, including establishing regular interagency meetings and collaboration. Mechanisms to support interested developers are also described; for example, creating easier permitting pathways for projects that are investing in climate resilience infrastructure.
• Pilot studies are being conducted to analyze the potential benefits of different ONWS systems, including stormwater capture and potable water conservation.

An Onsite Non-Potable Water Reuse One Water Vision Framework was developed through a multi-day workshop with City staff representing the Department of Utilities, Community Development Department, the Department of Public Works and City Manager’s Office of Climate Action and Sustainability. The outcome was a draft One Water Vision Framework (Appendix C) to guide the formation of the City’s dual plumbing ordinance in the context of a long-term water reuse strategy. Key elements of the draft framework are summarized in Table ES -1.

Case Study 3: The City and County of Honolulu (CCH) passed a One Water Ordinance in 2020 as a result of the Hawaii Freshwater Initiative to pro-actively address and resolve water supply issues. The ordinance codifies how the city agencies will collaborate on water infrastructure initiatives to build climate resiliency and water security. The Hawaii Freshwater Initiative Council, established in 2016, has conducted studies and pilot projects to inform the development of water quality rules and monitoring requirements for onsite wastewater treatment for indoor recycled water reuse and updates to the plumbing code to provide allowances for non-potable (rainwater and reclaimed water) for both outdoor and indoor reuse.

Executive Summary Page VIII
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Table ES - 1: City of Sacramento Onsite Non-Potable Water Reuse One Water Vision Framework – Key Elements
VISION

STATEMENT
The City of Sacramento’s Onsite Non-Potable Water Reuse Program seeks to optimize the use of local water resources and provide reliable and resilient water systems for the future.

PROGRAM
GOALS
• Optimize the use of local water resources
• Provide reliable/resilient water systems for the future • Balance community needs (e.g., water conservation, economic feasibility of new development, job creation)

PROGRAM

OBJECTIVES
• Increase resiliency and adaptability of water and wastewater infrastructure • Establish and sustain communication with community stakeholders • Integrate onsite reuse strategies with land use and other planning efforts (sewer, wastewater treatment, reuse, drainage, etc.)
• Provide a favorable economic environment for private investment

Economic Considerations
The potential costs of dual-plumbed systems and ONWS were evaluated as part of this Study to help inform the economic feasibility and financial implications of implementing a dual plumbing ordinance. The estimated cost to install dual plumbing and implement ONWS is intended to inform recommendations for the building sizes and types that would be subject to the dual plumbing ordinance.

Dual Plumbing Construction Cost Comparison
A cost model was developed to compare the costs to install dual plumbing, to conventional single plumbing systems. The cost model reviewed 17 new commercial buildings constructed in California within the last five years and estimated the cost to add dual plumbing to those same buildings based on the number of fixtures that would use non-potable water, additional piping and valves to supply non-potable water to fixtures, backflow preventers and pressure regulators, buffer tanks, pumps, and additional piping and valves to supply the building with non-potable water. The outcomes were used to anticipate the costs and financial impacts to development due to implementation of a dual plumbing ordinance.

Figure ES - 2 and Figure ES - 3 summarize the findings of the cost model for the City of Sacramento.

Executive Summary Page IX
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Figure ES - 2: Cost Per Area ($/sq ft) to Add Dual Plumbing to Commercial Buildings

Figure ES - 3: Percent Increase to Total Project Cost to Add Dual Plumbing to Commercial Buildings

$4.03
$1.20
$2.76
$1.35
$0.57
$4.23
$2.02
$3.55
$1.87
$1.20
$1.75
$0.48
$1.32
$3.49
$4.64
$3.32
$2.14
$-
$0.50
$1.00
$1.50
$2.00
$2.50
$3.00
$3.50
$4.00
$4.50
$5.00
Educational/Office
- Lake Tahoe, CA
Retail, Event Spaces
- San Bernardino, CA
Medical
- Santa Clara, CA
Educational
- Fremont, CA
Educational
- Cloverdale, CA
Recreation
- Salinas, CA
Recreation
- Cloverdale, CA
Educational
- Vallejo, CA
Educational
- Fullerton, CA
Maintenance/Operations
- Fullerton, CA
Educational
- Fullerton, CA
Educational
- Costa Mesa, CA
Educational
- Walnut, CA
Office
- Walnut, CA
Educational
- Morena Valley, CA
Educational
- Mountain View, CA
Educational
- Los Altos, CA
$/SF

0.50%

0.18%

0.39%

0.17%

0.10%

0.73%

0.34%

0.23%

0.41%

0.22%

0.31%

0.06%

0.23%

0.49% 0.52% 0.52%

0.33%

0.00%

0.10%

0.20%

0.30%

0.40%

0.50%

0.60%

0.70%

0.80%
Educational/Office
- Lake Tahoe, CA
Retail, Event Spaces
- San Bernardino, CA
Medical
- Santa Clara, CA
Educational
- Fremont, CA
Educational
- Cloverdale, CA
Recreation
- Salinas, CA
Recreation
- Cloverdale, CA
Educational
- Vallejo, CA
Educational
- Fullerton, CA
Maintenance/Operations
- Fullerton, CA
Educational
- Fullerton, CA
Educational
- Costa Mesa, CA
Educational
- Walnut, CA
Office
- Walnut, CA
Educational
- Morena Valley, CA
Educational
- Mountain View, CA
Educational
- Los Altos, CA
Average = 0.34%
Average = $2.88/sq ft

Executive Summary Page X
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Based on the cost model, it was observed that the cost of adding dual plumbing varied according to building size and type, as well as the number of plumbing fixtures per square-foot (sq ft). The cost model found that the average cost to install dual plumbing is $2.88 per sq ft (in April 2022 dollars), per Figure ES - 2, resulting in an average of 0.34% increase in building cost (Figure ES - 3) compared to buildings that are not required to install dual plumbing. This cost represents capital costs only, as the cost model does not account for the maintenance or replacement costs of the dual plumbing systems. Additional details on the dual plumbing cost model, including a description of the types of building, cost assumptions, and construction assumptions, can be found in Appendix D.

ONWS Treatment and Operations Costs
If a dual plumbed building receives recycled water from a municipal agency, then an ONWS treatment facility would not be required. For all other alternative non-potable water sources collected onsite, treatment facility and operations and maintenance (O&M) costs would be incurred. The cost of treatment installation and O&M for an ONWS is highly variable depending on the (1) source and end use (which impacts treatment level), (2) amount of demand (which impacts storage volume), and (3) technology (which also impacts operations and maintenance costs). Available data from projects implemented under the San Francisco Onsite Water Reuse Program was reviewed to estimate the potential cost impacts to developers and building owners. Evaluation of ONWS treatment and O&M costs included a review of 20 new commercial buildings constructed under the San Francisco Onsite Water Reuse Program.

Based on the 20 buildings evaluated, rainwater systems have the highest unit cost per area, at around 6 dollars per square feet ($/sq ft) to install, blackwater systems fall in the middle at around $3/sq ft and graywater/stormwater systems are the least expensive, under $1/sq ft, as shown in Figure ES - 4. Though blackwater is more expensive to treat, the cost for rainwater systems is higher because it requires significant storage to accumulate sufficient rainwater during the winter season to meet the non-potable demands year-round. The availability of blackwater on a consistent basis does not require additional storage, thus the treatment system can be sized to meet daily demands.

The effects of storage on the cost to install rainwater ONWS is further illustrated in a review of the three (3) projects installed in San Francisco with rainwater as the only reuse supply, where construction costs ranged from about $4/sq ft to $11/sq ft. However, as shown in Figure ES - 5, rainwater systems are the lowest cost to operate and the addition of graywater, concentrate and stormwater can result in an order of magnitude increase in annual O&M costs.

Executive Summary Page XI
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Figure ES - 4: ONWS Installation Costs, $/sq ft

Note: Values based on available data through the San Francisco Onsite Water Reuse Program for 9 projects (non-residential buildings)
Figure ES - 5: Annual ONWS O&M Costs, $/gallons

Note: Values based on available data through the San Francisco Onsite Water Reuse Program for 4 projects

Executive Summary Page XII
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Potential Cost Offsets due to Building Electrification
On June 1, 2021, City Council adopted the New Building Electrification Ordinance. The Ordinance phases in the requirement for all new construction of 1-3 stories to be fully electric by January 1, 2023, and buildings of 4+ stories to be all electric by January 1, 2026, with several limited exemptions. Because it is intended that a dual plumbing ordinance, if adopted, become effective concurrent with the New Building Electrification Ordinance, the City is interested in potential cost trade-offs between dual plumbing (and/or ONWS) and building electrification. A study on the net cost of fully electrifying new non-residential buildings that also install dual plumbing and ONWS was not conducted as part of this Study; however, cost effectiveness studies prepared by California Energy Codes and Standards indicate cost savings for all-electric commercial nonresidential buildings.

ONWS Market Assessment
To understand the scale of future commercial developments that could be candidates to install dual plumbing systems, a review of recently constructed and planned commercial and industrial developments of 100,000 sq ft or greater was conducted. Figure ES-6 shows the locations of 14 non-residential developments that have submitted building permit applications for buildings over 100,000 sq ft. This figure also shows the location of the Sacramento Regional County Sanitation District current recycled water pipeline and proposed expansion phases.

Based on the City’s past rate of development and anticipated future developments, it can be assumed that there will be limited commercial developments located near enough to take advantage of the existing or future Sacramento Regional County Sanitation District recycled water distribution system (municipal recycled water). Thus, the majority of future developments with dual plumbing would need to be supplied through an ONWS.

ONWS Program Administration Resources
In addition to the cost impacts to developers and commercial building owners, the implementation of an onsite water reuse program will also require City resources to administer the program. A review of the agency coordination and staffing requirements for the San Francisco Onsite Water Reuse Program case study provides an indication of the potential City of Sacramento resources needed to implement an onsite water reuse program:
• Additional staff resources to start up the ONWS program (advertise, develop guidance and outreach materials, meet with developers and other stakeholders), with these resource commitments reducing to administer the ONWS Program • Support from the Community Development Department (Building and Planning Divisions) and Public Works to provide reviews of dual plumbing plans, conduct inspections, approve installations, and issue construction and other permits • Coordination with County of Sacramento or other water quality regulator to issue and enforce treatment requirements
Based on the City’s Building Data,
since 2010 there have been:
• 8 new commercial or industrial
developments with habitable
areas greater than 100,000 SF
• 5 new commercial or industrial
developments with habitable
areas greater than 250,000 SF
Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c) OpenStreetMap contributors, and the GIS User Community
³
City of Sacramento
OnSite Non-Potable Water Reuse Strategy
ONWS Opportunity Areas
K/J Project Number
2270001*00
Figure ES-6
Kennedy/Jenks Consultants
C:\Users\EvelynChoudhary\OneDrive - Kennedy Jenks Consultants\Desktop\Projects\Sac-Onsite\SacOnsite_Acella_filtered.mxd Date: 6/9/2022 Printed by: EvelynChoudhary Legend
Proposed Recycled Water Pipelines
Phase 1
Phase 2
Phase 3
Phase 4
Phase 5
Proposed Recycled Water Area
City Limits
Planned Commercial Properties for Development

Executive Summary Page XIV
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Although the City of Sacramento is not anticipated to
see as large or as many commercial developments as
the City of San Francisco, the City of Sacramento will
need to commit resources to the administration of an
ONWS program and enforcement of the dual plumbing
ordinance, if the ordinance were to be implemented.

Responsibilities related to the enforcement of the dual plumbing ordinance will need to be defined within the
City, as well as other roles and authorities for
enforcement between the County of Sacramento or
other local Jurisdiction with Authority. Similarly, the added costs to carry out these responsibilities will need to be evaluated for their impact to existing programs
and City budgets.

Dual Plumbing Ordinance Development Options
As stated previously, the goal of this Study is to evaluate the potential for the adoption of a dual plumbing ordinance with phase 2 to include installation of water reuse systems onsite.

Regulatory, technical, and economic considerations, as well as the broader One Water Vision, contributed to the development of ordinance options.

At this stage of the City’s efforts, there are multiple options available to the City to guide the adoption, enforcement and modification of the dual plumbing ordinance:

1. Do not adopt a dual plumbing ordinance at this time.

Continue to develop the City’s One Water Vision and Onsite Water Reuse Strategy with the intent of adopting a dual plumbing ordinance in the future.

2. Adopt a local dual plumbing ordinance which allows new buildings to voluntarily install dual plumbing with or without a non-potable water source.

3. Adopt a local dual plumbing ordinance requiring new buildings within the vicinity of existing and planned Sacramento Regional County Sanitation District pipelines and meeting other eligibility criteria to install dual plumbing and connect to municipal recycled water when it becomes available. At this time, Sacramento Regional County Sanitation District has no plans on expanding recycled water service within the City of Sacramento, but this may change in the future.

4. Adopt a local dual plumbing ordinance requiring all new buildings meeting the eligibility criteria (e.g., commercial, non-residential of 100,000 sq ft or greater) to install dual plumbing.

After the state adopts water quality standards for ONWS, the City can then incorporate these standards for buildings to collect, treat, and reuse water onsite.

5. Adopt a local dual plumbing ordinance requiring all new buildings meeting the eligibility criteria (e.g., commercial, non-residential of 100,000 sq ft or greater) to also install ONWS.

Pilot projects are one way the City of
Sacramento can investigate the potential
costs and resources needed to administer
and enforce a dual plumbing ordinance
with or without ONWS. For projects that
will be owned by a public entity, grants
may be available to fund the construction
of pilot projects. The US Bureau of
Reclamation’s CALFED Water Use
Efficiency Grant Program funds water use
efficiency activities such as small, publicly
owned recycled water and reuse projects.

Historically, grant application solicitations
are released annually.

Executive Summary Page XV
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx After the state adopts water quality standards for ONWS, the City can update the ordinance as needed.

Consideration of each of the above options should include weighing the regulatory, technical, and economic needs to implement a dual plumbing ordinance and should also reflect the priorities of the One Water Vision for the City’s Onsite Water Reuse Strategy.

To aid the City in determining the next actions needed to develop a dual plumbing ordinance (with or without an ONWS program), the recommended next steps include:

Engage stakeholders in a review and comment process for the draft dual plumbing ordinance to get buy-in early on and include considerations for building types and sizes based on stakeholder recommendations.

Identify public and private partners and work with them to develop and implement pilot ONWS projects to trace out the City’s process for reviewing permits, applications, and plans, as well as to understand better the needs of developers and building owners.

Define the One Water Vision for the City’s Onsite Water Reuse Strategy to guide the development and implementation of an ONWS Program and identify roles and responsibilities, program needs, and next steps.

As part of Phase 2 of the City’s Onsite Non-Potable Water Reuse Strategy, the City should:

Establish a small group to champion and facilitate the development of the City’s ONWS Program. The core group should consider including representatives from the public health department, planning and building officials, and water/wastewater utilities.

Using existing guidelines and examples from other locations, draft the ONWS Program to define the alternate water sources to be used, the allowable non- potable end uses, the type and scale of developments required to install dual plumbing systems, the applicable rules and regulations, sampling requirements, fees, and incentives.

Track the implementation and adoption of the water quality standards for ONWS expected to be released by the State Water Resources Board in 2022 and review the draft risk-based regulations once released.

1.1 Study Background Page 1-1
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The Dual Plumbing and Onsite Non-Potable Water Systems Study (Study) was prepared to summarize the feasibility of implementing dual plumbing systems as part of a non-potable water reuse strategy. This Study will inform the preparation of a potential ordinance to pre-plumb new commercial (non-residential) developments with dual plumbing for future supply with either municipal recycled water or Onsite Non-Potable Water Systems (ONWS).

1.1 Study Background
This Study was initiated against a backdrop of two City Council actions:
• On June 1, 2021, City Council adopted the New Building Electrification Ordinance, requiring new construction of 1-3 stories to be fully electric by January 1, 2023, and buildings of 4+ stories to be all electric by January 1, 2026. • City Council adopted a resolution on June 1, 2021, directing staff to evaluate opportunities for the expansion of water conservation standards for buildings in advance of the New Building Electrification Ordinance effective dates.

Sacramento’s City Council has accelerated City efforts to mitigate the local contribution to climate change and prepare for its effects. Building on recommendations of the Mayors’ Commission on Climate Change, the City Council prioritized several urgent climate initiatives for implementation in Fall of 2020. The City’s 2021 Climate Implementation Work Plan identified water reuse as part of the City’s near-term and long-term strategy to meet water conservation objectives, while also supporting implementation of the New Building Electrification Ordinance and the “Just Transition” from local gas pipefitting work to green infrastructure.

There are few active ONWS programs in the United States, with San Francisco as one of the oldest and robust. According to the National Blue Ribbon Commission 1, only a handful of states
are advancing regulations supporting ONWS; these include California, Minnesota, Colorado, Washington, Oregon, and Hawaii. Washington and Oregon are basing their regulations on California’s Senate Bill (SB) 966 which directs the state to develop risk-based water quality standards for ONWS. There are city-level ONWS programs in various stages of development in Honolulu, Hawaii, New York City, and Austin, Texas, and there are single building ONWS installations scattered throughout the country. If an ONWS program is implemented, the City of Sacramento would be joining the ranks of a small but growing number of agencies to utilize this water conservation tool.

This Study is intended to evaluate the feasibility and cost effectiveness of dual plumbed systems to inform City efforts for developing a dual plumbing ordinance to pre-plumb certain types of new commercial (non-residential) construction with dual plumbing systems that allow for future installation of onsite non-potable water systems or supply with locally produced municipal recycled water. The dual plumbing ordinance is intended to be the first phase of the

1 “Highlights and Accomplishments, March 2016-April 2019.” National Blue Ribbon Commission for Onsite Non-potable Water Systems.

1.1 Study Background Page 1-2
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx development of the City’s non-potable water reuse strategy. The next phase, which is anticipated to happen by or after 2024, will address water treatment requirements in further detail, including compliance with state mandated requirements for ONWS, operational responsibilities, system protection needs, additional partnerships and engagement, and the cost and funding impacts.

This Study was spearheaded by the City’s Department of Utilities (DOU) and Community Development Department (CDD). DOU is responsible for providing and maintaining drinking water, sewage collection, storm drainage and flood control services for over 500,000 residents and businesses within the City’s service area. CDD led the New Building Electrification Ordinance and will use the results of this Study to develop the anticipated dual plumbing ordinance.

1.2 Project Stakeholders
The DOU and CDD conducted this work in coordination with multiple City Departments (Department of Public Works, City Manager’s Office, and the Mayor’s Office), Sacramento Regional County Sanitation District (Regional San), and Sacramento County. Virtual meetings were held to present issues and considerations related to the implementation of a dual plumbing ordinance. These meetings were also used to facilitate discussion of concerns and solicit feedback from these coordinating groups.

During this Study, the City also maintained regular communication and outreach to other community members with interests in the dual plumbing ordinance, including local trade groups, local land developers, and California State Water Resources Control Board staff. In addition, a page
2 was added to the City’s website to allow the general public to access resources and subscribe for updates on the Study.

1.3 Study Organization
This Study provides considerations for feasibility and cost effectiveness of installing dual plumbing systems in new commercial developments for future supply with ONWS or municipal recycled water. The Study summarizes findings from national literature, examples of dual pluming and ONWS programs in California, availability of alternative water sources locally, impacts and costs for developers to install dual plumbed systems, stakeholder considerations, and implementation requirements. This Study is organized into the following sections:
• Section 1: Introduction and Background – briefly describes the Study purpose, as well as provides the context and setting for the City’s dual plumbing ordinance and ONWS feasibility evaluation.
• Section 2: Implementation Considerations for Onsite Water Reuse Dual Plumbing – summarizes the regulatory, technical, monitoring and testing requirements that the City

2 https://www.cityofsacramento.org/Community-Development/Planning/Major-Projects/General- Plan/About-The-Project/Climate_Change/Onsite-Water-Reuse-Study

1.3 Study Organization Page 1-3
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• Section 3: One Water Vision for the City’s Onsite Water Reuse Strategy – presents the scope, vision, and objectives for implementing the City’s Onsite Water Reuse Strategy and identifies partners and needs, opportunities, and next steps. This section will also summarize three case studies relevant to the development of an onsite water reuse program.
• Section 4: Economic Considerations – summarizes a dual-plumbing cost model that compares the added cost to dual-plumb a commercial building versus using potable water system in the same building. This section also summarizes potential operations and maintenance costs based on information available from existing systems, as well as reviews the potential scale of application to future development in the City of Sacramento.
• Section 5: Dual Plumbing Ordinance and ONWS Program Feasibility and Next Steps - describes an appropriately sized program for the City that implements dual-plumbing, considering the scale of the project (building size, type of building, location(s)), available water sources, and cost estimates. This section will identify the critical path and next steps to advance the City’s Onsite Water Reuse Strategy.

2.1 Dual Plumbing Systems Page 2-1
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The following section describes dual plumbing and ONWS and summarizes the regulatory and technical considerations for these systems, as well as presents testing and inspection requirements.

2.1 Dual Plumbing Systems
Dual plumbing systems allow for the supply and use of potable and non-potable water sources to supply different fixtures and systems within a building or development. Traditionally fixtures in a building are all supplied with potable water from a connection to the municipal potable water system. However, according to the United States Environmental Protection Agency (US EPA), about 95% of the water demands in commercial buildings do not require potable water (see Figure 2-1). Non-potable demands in a commercial building include water used for toilet flushing, cooling tower make up water, irrigation systems, drain trap priming, and other miscellaneous uses.

Figure 2-1: Non-Potable Demands in Commercial Buildings

Source: Onsite Non-Potable Water Reuse Practice Guide, William J Worthen Foundation, 2018

By installing a dual plumbed system, the potable water demand by new developments can be significantly reduced, preserving potable water supplies for human consumption, and supplying non-potable needs with alternative water sources. Alternative sources that can be used to supply non-potable demands include:

1. Disinfected Tertiary Recycled Water: Non-potable reuse of recycled water refers to the use of tertiary treated municipal wastewater for a specific purpose other than drinking such as landscape irrigation, industrial uses, and agriculture or for Drain Trap Priming

2.2 Onsite Non-Potable Water Systems Page 2-2
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Recycled water systems have strict regulations for not entering the waterways, including over spray such that it can enter storm drains. In California, non-potable reuse has been ongoing throughout the state for the last century and regulations for non-potable reuse have been in place since the 1970s.

2. Onsite Treated Non-Potable Water: Alternative non-potable water sources collected and treated onsite to be reused at a building or district scale to supply non-potable needs such as irrigation, toilet flushing and cooling systems. Alternative water sources can include rainwater collected from buildings roofs, stormwater collected from runoff in landscape areas, foundation drainage, condensate from cooling systems, graywater from washing machines, and blackwater from toilets (see Figure 2-2). These systems that collect and treat alternative sources onsite are considered ONWS.

Figure 2-2: ONWS Alternative Water Sources

Source: Onsite Non-Potable Water Reuse Practice Guide, William J Worthen Foundation, 2018

2.2 Onsite Non-Potable Water Systems
Traditional developments collect rainwater, stormwater, and municipal wastewater and convey it to the municipal sewer and/or storm drain system as applicable, and all water demands are met through a potable water or municipal recycled water source. ONWS would instead collect and

2.3 Regulatory Considerations Page 2-3
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ONWS are one tool available to address long-term water supply reliability strategy. Benefits of an ONWS include reducing potable water use for non-potable needs, maximizing resiliency of water and wastewater infrastructure, reducing costs of expanding water and sewage infrastructure for new developments, diversifying water supply portfolios, and supporting projects aiming to achieve green building certifications or net-zero energy and water use. In case the onsite treatment system is not operating properly or is not sized to supply all non- potable demands in a development, potable water should be available to use as a backup source or to complement other demands. However, dual plumbing systems need to ensure that potable and non-potable sources are not cross-connected to prevent contamination of potable supplies, as described in more detail in Section 2.5.

2.3 Regulatory Considerations
One of the most important aspects of a water reuse system is the adherence to the regulations set forth by local, state, and federal guidelines aimed to protect public health. Throughout California, non-potable reuse of municipal recycled water has been ongoing for the last century, and regulations have been in place since the 1970s. The regulations for water reuse are different for using disinfected tertiary (municipal) recycled water or onsite treated non-potable water.

2.3.1 Recycled Water Regulations
There are no federal regulations governing water reuse in the United States, thus regulations (or guidelines) for water reuse are developed and implemented at the state government level. In the State of California, municipal recycled water requirements are administered by the Division of Drinking Water (DDW) from the State Water Resources Control Board (State Water Board), formerly under California Department of Public Health, and individual Regional Water Quality Control Boards. The regulatory requirements for municipal recycled water projects in California are contained in California Code of Regulation (CCR) Title 22 and Title 17.

2.3.1.1 CCR – Title 17
Title 17 of the CCR focuses on the protection of drinking (potable) water supplies through control of cross-connections with potential contaminants, including non-potable water supplies such as municipal recycled water. Title 17 specifies the minimum backflow protection requirements to prevent any potential for cross contamination of the potable water supply with other non-potable sources.

2.3 Regulatory Considerations Page 2-4
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2.3.1.2 CCR – Title 22
Title 22 of the CCR stipulates the treatment and water quality requirements for drinking water as well as municipal recycled water and the allowed uses for municipal recycled water. Municipal recycled water begins as wastewater and undergoes a series of treatment steps, using a multi- barrier approach, to remove organic matter and pollutants. The production and use of municipal recycled water must adhere to strict regulations stipulating the levels of treatment, allowable types of reuse and water quality requirements. The multi-barrier approach to reuse highlights the increasing level of treatment necessary to produce the right quality of water for the right use as shown in Figure 2-3. Title 22 also provides the requirements for sampling and monitoring of municipal recycled water.

Figure 2-3: Multi-Barrier Approach to Reuse

2.3 Regulatory Considerations Page 2-5
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2.3.1.3 State Recycled Water Policy
The State Water Board adopted a Recycled Water Policy (RW Policy) in 2009 (amended in 2013), to establish more uniform requirements for water recycling throughout the State and to streamline the permit application process in most instances. The RW Policy includes a mandate that the State increase the use of recycled water over 2002 levels by at least 200,000 acre-feet per year (AFY) by 2030. Also included are goals for stormwater reuse, conservation, and potable water offsets by recycled water. The onus for achieving these mandates and goals is placed both on recycled water purveyors and potential users.

2.3.1.4 Statewide General Order
On June 7, 2016, the State Water Board adopted Water Reclamation Requirements for Recycled Water Use
3 (General Order). Similar to the RW Policy, the intent of the General Order is to streamline the permitting of municipal recycled water use statewide and encourage the use of municipal recycled water as a valuable resource. The General Order is used to permit non- potable municipal recycled water distribution and use. The production of municipal recycled water at a wastewater treatment facility would require separate coverage under a Regional Water Quality Control Board permit. As of May 2022, the Central Valley Regional Board, which issues water reclamation permits for the region that includes the City of Sacramento, does not allow the use of non-potable water for indoor uses.

2.3.2 California Plumbing Code
The California Plumbing Code assigns authority to the Authority Having Jurisdiction, and it is up to the City to define who the Authority Having Jurisdiction is. The Authority Having Jurisdiction is to review the proposed and completed work and to decide whether a plumbing system conforms to the code requirements. As a public servant, the Authority Having Jurisdiction enforces the code in an unbiased, proper manner.

Chapter 15 of the CPC provides the requirements for construction, alteration, discharge, use and repair of alternative water source systems for non-potable applications. Chapter 15 outlines the permitted uses (where approved by the Authority Having Jurisdiction) for recycled water and graywater. This chapter also lists requirements for testing, inspection, and maintenance of alternate water source systems, including requirements for signage and cross-connection testing.

Chapter 16 of the CPC outlines the requirements for installation, construction, alteration, and repair of non-potable rainwater catchment systems, including inspection and testing requirements. This chapter outlines the minimum water quality standards for using rainwater for different applications such as car washing, irrigation (surface, subsurface, drip, spray), toilet

3 http://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/2016/wqo2016_0068_ ddw.pdf

2.3 Regulatory Considerations Page 2-6
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2.3.3 ONWS Regulations
Current state regulations in California regarding treatment standards or water quality limits for non-potable supplies treated by ONWS for reuse are limited to rainwater capture systems and graywater equipment and components. Draft regulations are being developed by the State Water Board for risk-based water quality standards for onsite treatment and reuse of non- potable water for non-potable end uses in multifamily residential, commercial, and mixed-use buildings. These regulations are expected to be finalized and adopted by December 1, 2022.

The risk-based water quality standards will not address untreated graywater systems for subsurface irrigation or untreated rainwater systems used exclusively for surface, subsurface, or drip irrigation. Any ONWS that are in operation before the effective date of the state regulations will be required to comply with the state regulations within two years of the effective date.

ONWS in operation prior to the implementation of the state regulations will have to comply with all local regulations.

To develop an ONWS program requires understanding, in addition to the applicable regulations, of other site-specific considerations that can include:

1. Discharge restrictions related to water quality, storm and sewer tie-ins, sewer overflow mitigation, existing discharge permit compliance, and stormwater runoff requirements.

2. Sensitive areas susceptible to flooding or wildlife corridors.

3. Authorities Having Jurisdiction including local, regional, or state public health agencies, building departments, State Water Board and Regional Boards and local sewer and utility agencies.

4. Employees completing certification for managing ONWS.

In general, building codes dictate how non-potable ONWS are built and used. Rainwater and graywater reuse is regulated by CPC Chapter 15 and 16 as described in the following section.

In the absence of state or national standards some cities are developing their own standards and guidelines to promote onsite reuse while assuring public and environmental health protection. Some jurisdictions also use standards set by the National Sanitation Foundation (NSF), which certifies graywater and wastewater reuse treatment systems. The NSF standards are performance based. NSF developed their own standards for toilet flushing (NSF-350) and subsurface irrigation (NSF-350-1) based on survey of national and international water reuse standards.

2.4 Technical Considerations Page 2-7
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2.4 Technical Considerations
Water quality requirements vary for each source of alternate water and its end use. This section summarizes the requirements and recommendations for treatment for different alternate water sources.

2.4.1 Recycled Water Treatment Standards
The forms of non-potable recycled water use that are permitted in California vary based on (1) the degree of treatment required and (2) the intended use of the recycled water. Generally, when more treatment is provided, the final use of the water is less restricted. The levels of treatment, from the lowest level (with the highest restrictions) to the highest level (with the lowest restrictions), per the regulatory classifications (CCR Title 22) are:
 Undisinfected secondary recycled water
 Disinfected secondary – 23 recycled water
 Disinfected secondary – 2.2 recycled water
 Disinfected tertiary recycled water

Disinfected secondary – 23 recycled water and disinfected secondary – 2.2 recycled water differ in the degree of disinfection required to achieve different total coliform bacteria concentrations after disinfection.

2.4.1.1 Recycled Water Treatment for Non-Potable Uses
Wastewater from a sanitary sewer undergoes primary and secondary treatment. Primary treatment removes large solids, scum and debris, and heavier sludge that settle out in primary holding tanks. Secondary treatment utilizes micro-organisms and oxygen to break down and consume organic matter. Together these processes produce secondary effluent to meet land discharge or National Pollutant Discharge Elimination System (NPDES) requirements for discharge to a waterway, bay, or the ocean.

Additional treatment is typically required to produce recycled water for non-potable reuse.

Tertiary treatment provides filtration to remove suspended solids and other pollutants using sand or media filtration or membrane filters. Disinfection serves to destroy bacteria or viruses through the addition of chemicals (such as chlorine) or ultraviolet (UV) light. Disinfection may follow secondary or tertiary treatment, depending on the intended reuse type.

Figure 2-4 provides a summary of the non-potable recycled water irrigation options with the associated treatment required.

2.4 Technical Considerations Page 2-8
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Figure 2-4: Types of Non-Potable Reuse and Associated Treatment Processes

2.4.1.2 Additional Considerations for Indoor Use of Recycled Water Non-irrigation uses, such as toilet and urinal flushing and cooling towers that are dual plumbed with an internal purple pipe system to separate potable water from municipal recycled water (non-potable) may have water quality objectives beyond meeting CCR Title 22 objectives. For aesthetic reasons, it is preferable that recycled water used for toilet and urinal flushing is odorless and colorless. This is generally recommended by professionals in the water reuse industry. Organic and inorganic compounds in recycled water can cause discoloration and odor.

Oxidizing agents such as chlorine, ozone, and hydrogen peroxide can be used for removal of color and odor, and UV light may also contribute to the removal of color. Hydrogen peroxide (H
2O2) is an oxidant commonly used in water treatment and wastewater reclamation for eliminating color and odor; it is less effective than ozone but easier to implement. Chlorine is less effective for odor and color removal compared to ozone and hydrogen peroxide and therefore is not specifically used for this purpose.

2.4 Technical Considerations Page 2-9
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Variable water quality can be a challenge as it impacts the number of cycles and chemical requirements; additionally, ammonia concentration is of greatest concern due to the potential for corrosion. Removal of salinity and ammonia may be desirable to meet cooling tower water quality objectives. It is not uncommon for cooling towers to have small package Reverse Osmosis (RO) plants to manage water quality from potable water sources. Thus, if cooling towers are selected as use for the non-potable recycled water it would be important to work closely with their operators to understand the elements of the specific cooling system and their current practices and needs.

2.4.2 Proposed Treatment Standards for ONWS
Since there are limited regulations for treatment for ONWS, the National Blue Ribbon Commission was founded to advance management practice to support the use of privately owned and maintained ONWS for buildings or at a local scale. One of the Commission’s goals is to provide policy guidance for the management of ONWS including water quality criteria, monitoring and reporting requirements, and operational and permitting strategies. The Commission developed the Guidebook for Developing and Implementing Regulations for On- site Non-potable Water Systems to guide local jurisdictions in developing and implementing the regulations and oversight programs for ONWS that are protective of public health. The guidebook refers to the recommendations from the Water Research Foundation (WRF) study Risk Based Framework for the Development of Public Health Guidance for Decentralized Non-potable Water Systems (Sharvelle et al., 2017) which establishes a risk-based approach for pathogen removal and/or inactivation targets defined as “log reduction targets” (LRTs). The LRTs indicate the targets for inactivation or removal of viruses, protozoa and to reduce the annual risk of infection to less than 10
-4 per person per year, which was determined as a
stringent risk goal to protect public health. Using log removal as treatment criteria is the accepted practice for both drinking water and non-potable reuse.

ONWS should treat alternate water sources to meet or exceed the LRTs as summarized in Table 2-1. This will require employing onsite licensed/certified operators to ensure compliance.

For stormwater, two levels of dilution are assumed for potential fecal contamination in stormwater from urban environments. Some contamination is likely from sewer leaks or sewer overflows into stormwater.

2.4 Technical Considerations Page 2-10
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Enteric
Viruses
Parasitic
Protozoa
Enteric
Bacteria
Domestic Wastewater or Blackwater
Unrestricted Irrigation 8.0 7.0 6.0
Indoor Use 8.5 7.0 6.0
Graywater
Unrestricted Irrigation 5.5 4.5 3.5
Indoor use 6.0 4.5 3.5
Rainwater/Roof Runoff
Unrestricted Irrigation N/A 1 No Data 1 3.5
Indoor use N/A 1 No Data 1 3.5
Stormwater (10-1 dilution)
Unrestricted Irrigation 5.0 4.5 4.0
Indoor use 5.5 5.5 5.0
Stormwater (10-3 dilution)
Unrestricted Irrigation 3.0 2.5 2.0
Indoor use 3.5 3.5 3.0

1. Not Applicable

Other wastewater treatment parameters like Biochemical Oxygen Demand (BOD), Chemical Oxygen Demand (COD), Total Dissolved Solids (TDS), and nutrients (nitrogen and phosphorus) may be important to monitor and treat for depending on the alternative water source and the end use.

Treatment systems for alternate water sources would need to be designed to meet the LRTs.

Typical treatment systems include microfiltration (MF), ultrafiltration (UF), membrane biological reactors (MBR) ultraviolet light (UV) disinfection, ozone disinfection, and chlorination. There are accepted pathogen crediting frameworks for validation, field verification, and monitoring of treatment performance. Table 2-2 provides pathogen credits for common treatment processes.

Table 2-2: Treatment Process Log Reduction Credits
Treatment Process
Log10 Reduction Credits
Virus/Protozoa/Bacteria
Microfiltration (MF) or Ultrafiltration (UF) 0/4/0
Membrane Biological Reactor (MBR) 1.5/2/4
Reverse Osmosis 2/2/2
UV Disinfection 6/6/6
Chlorine Disinfection 5/0/5 (CT dependent1)
Ozone Disinfection 4/3/0 (CT dependent1)

1. CT = Concentration x Contact Time

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2.4.2.1 Treatment Processes for Alternate Water Sources Successful non-potable water reuse systems include three basic steps: primary, secondary, and tertiary, as referenced in Section 2.4.1.1. For ONWS the primary treatment step is required for all alternate water sources to remove coarse biological material and large solids. Most alternate sources require secondary treatment to remove organic material which involves biological treatment and chemical oxidation to degrade organic matter. Tertiary treatment is usually required based on the use and water source and it includes additional filtration and disinfection.

The filtration step for tertiary treatment can be an MF, UF, and can also include RO system for removal of dissolved solids. The disinfection step can be UV disinfection, chlorination, or ozone.

The combinations of primary, secondary and tertiary treatment systems for different alternate water sources based on the end use are summarized in Table 2-3.

Table 2-3: ONWS Treatment Processes for Different End Uses Water
Source Type
Treatment
End Uses
Primary Secondary Tertiary
Screen
Flow
Equalization
Bio
Treatment
or Chemical
Oxidation
Filtration
(MF, UF) RO
Disinfection
(Chlorine,
UV, Ozone)
Condensate
• Subsurface
Irrigation
Rainwater ● ●
Stormwater ● ●
Foundation
Drainage ○ ○
Graywater ● ● ○ ○
Blackwater ● ● ● ● ○
Condensate ● ○
• Toilet
Flushing
• Decorative
Fountains
• Car
Washing
• Surface
Irrigation
Rainwater ● ● ● ○
Stormwater ● ● ● ●
Foundation
Drainage ○ ○ ● ●
Graywater ● ● ○ ● ●
Blackwater ● ● ● ● ○ ●

2.4 Technical Considerations Page 2-12
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Source Type
Treatment
End Uses
Primary Secondary Tertiary
Screen
Flow
Equalization
Bio
Treatment
or Chemical
Oxidation
Filtration
(MF, UF) RO
Disinfection
(Chlorine,
UV, Ozone)
Condensate ● ●
• Cooling
Towers
• Boilers
Rainwater ● ● ● ●
Stormwater ● ● ● ●
Foundation
Drainage ○ ○ ● ●
Graywater ● ● ○ ● ○ ●
Blackwater ● ● ● ● ● ●
● Typically Required
○ Project Specific

The following sections provide examples of treatment approaches for different alternate water sources that have been successfully implemented ONWS in cities like San Francisco, New York, and other international locations. Specific examples of case studies in other locations are presented in Section 3.1.

2.4.3 Treatment Systems for Alternate Water Sources

2.4.3.1 Rainwater
Rainwater refers to rainfall that is collected from a building roof or other manmade above ground collection surface before it reaches the ground. Rainwater collection systems start with a screening or filter to remove debris such as leaves or branches. Then, a first flush diverter is used to discharge the first flow of rainfall following the onset of a rain event, which is assumed to have potential for fecal matter from birds and other animals. After the first flush, the rainwater collected is stored in a tank. The size for the storage tank is based on local rainfall patterns, the intended uses for the rainwater, structural design, and space available at the site. If rainwater is used for toilet flushing or surface irrigation, then a disinfection step is added after the storage tank prior to pumping the treated rainwater into the non-potable distribution system or irrigation system.

The limitations of ONWS that only include collection of rainwater (or even stormwater) is that the water source is limited to weather conditions, in areas like Sacramento, rainfall capture is limited to a few storm events in the winter season requiring large storage tanks to accumulate enough rainwater and store it long term for use either in the irrigation season (holding the water until summertime) or to meet indoor demands until the next rain event. Rainwater systems require a potable water supplied to the storage tank as a backup supply as well as an overflow system.

Potable water is supplied to the storage tank using an air gap, which is a physical break

2.4 Technical Considerations Page 2-13
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Other considerations for designing a rainwater treatment system include treatment for color or odors that can be caused if the system has a green roof, and the influent water may be collecting organic material. In these cases, filtration with media and/or activated charcoal can be added, in addition to chlorine for disinfection. In addition, blending rainwater into ONWS systems would prevent its ability to be permitted to enter storm drain systems. Sacramento currently has a combined storm and sewer system, which would need to be taken into consideration when designing a rainwater treatment system.

Per the CPC Chapter 16, the minimum water quality requirements for rainwater treatment systems are summarized in Table 2-4.

Table 2-4: Rainwater Treatment Systems Water Quality
Application Minimum Treatment Minimum Water Quality
Car Washing Debris screening (100 micron
for drip irrigation)
N/A
Surface, Subsurface and Drip
Irrigation
Debris screening (100 micron
for drip irrigation)
N/A
Spray Irrigation
(Storage < 360 gallons)
Debris screening and
disinfection
N/A
Spray Irrigation
(Storage > 360 gallons)
Debris screening • E. Coli < 100 CFU/100 ml
• Turbidity < 10 NTU
Toilet Flushing, Clothes
Washing, Trap Priming
Debris screening (100 micron
for drip irrigation)
• E. Coli < 100 CFU/100 ml
• Turbidity < 10 NTU
Decorative Fountains Debris screening • E. Coli < 100 CFU/100 ml • Turbidity < 10 NTU
Cooling Tower Make-up Water Debris screening (100 micron for drip irrigation)
• E. Coli < 100 CFU/100 ml
• Turbidity < 10 NTU
N/A: Not Applicable
CFU: Colony Forming Units
ml: milliliters
NTU: Nephelometric Turbidity unit

2.4.3.2 Stormwater
Stormwater refers to precipitation runoff from rain or snowmelt events that flows over land and/or impervious surfaces (i.e., streets and parking lots). Stormwater usually requires higher level of treatment than rainwater due to the potential for additional contamination from urban environments from sediment, oils, debris in parking lots, trash, organic or fecal contamination in soil or from sewer leaks or sewer overflows into stormwater drain systems. Currently, there are no water quality requirements for stormwater defined in the CPC.

2.4.3.3 Graywater
Graywater is wastewater that is collected from non-blackwater sources, such as bathroom sinks, showers, bathtubs, clothes washers, and laundry sinks. Graywater typically requires

2.5 Testing and Inspection Requirements Page 2-14
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2.4.3.4 Blackwater Treatment
Blackwater is wastewater that originates from toilets, urinals, and/or kitchen counters (i.e., kitchen sinks and dishwashers). Blackwater requires the highest level of treatment, tertiary treatment and disinfection, equivalent to the level of treatment provided for recycled water production to protect public health. Water quality requirements for blackwater are the standards provided in the CCR Title 22 for recycled water, as summarized in Section 2.4.1; however, there are currently no water quality requirements for blackwater defined in the CPC.

2.4.3.5 O ther Alternate Water Sources
Other potential alternate water sources include condensate water which is vapor collected from air conditioning systems, and foundation drainage, which is nuisance groundwater that is extracted discharged to the sanitary or combined sewer system. It does not include groundwater extracted for beneficial use that is subject to the groundwater well regulations. Currently, there are no water quality requirements for other alternate sources defined in the CPC.

2.5 Testing and Inspection Requirements
Testing and inspection requirements are outlined in different guidelines. California Code of Regulations and California Plumbing Code detail certain requirements for ONWS.

2.5.1 Cross-Connection Testing
Cross-connection refers to any physical connection or arrangement between potable water and any source of contamination. It is critical that no cross-connection exists between a potable and a non-potable water system to protect the quality of drinking water. Cross-connection testing is required for any dual plumbed system that is either using municipal recycled water or non- potable water from an ONWS, to provide evidence that there is no potential cross-connection between the potable and non-potable water supplies. Cross-connection testing must be overseen by a Certified Cross-Connection Control Specialist.

For dual-plumbed systems, cross-connection inspections must be conducted annually, with testing of the recycled water (municipal and blackwater) systems every four (4) years, per CCR Title 22. In addition, other alternate water sources (graywater and other onsite water supplies) cross-connection inspections are required whenever there is a major plumbing alteration.

Typically cross-connection testing will involve a two-way shut down, which will consist of turning off the potable water supply and verifying that any potable water connection, such as fixtures within buildings and bathrooms, water fountains, or irrigation areas that will remain on potable water, do not have running water; then, the water system will be restarted and the non-potable water supply will be shut down to verify that none of the irrigation or non-potable fixtures connected to the municipal recycled water or ONWS have running water. Additionally, there is a manual test of the backflow equipment to ensure the valves are seating correctly.

2.5 Testing and Inspection Requirements Page 2-15
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 Meter locations of the alternate water source and potable water lines shall be checked to verify that no modifications were made and that no cross-connections are visible.  Pumps and equipment, equipment room signs and exposed piping in equipment room shall be checked.
 Valves shall be checked to ensure that the valve lock seals are still in place and intact.

Valve control door signs shall be checked to verify that no signs have been removed.

The current steps for testing are outlined in the CPC and are subject to change over time. The steps required from the CPC in 2022 for a cross-connection test are:
• The potable water system shall be activated and pressurized. The alternate water source system shall be shut down, depressurized, and drained.

 The potable water system shall remain pressurized for a minimum period specified by the Authority Having Jurisdiction while the alternate water source system is empty. The minimum period the alternate water source system is to remain depressurized shall be determined on a case-by-case basis, considering the size and complexity of the potable and the alternate water source distribution systems, but in no case shall that period be less than 1 hour.
 The drain on the alternate water source system shall be checked for flow during the test and fixtures, potable, and alternate water source, shall be tested and inspected for flow.

Flow from an alternate water source system outlet indicates a cross-connection. No flow from a potable water outlet shall indicate that it is connected to the alternate water source system.
 The potable water system shall then be depressurized and drained.  The alternate water source system shall then be activated and pressurized. When an alternate water source is not available for the initial cross-connection test, a temporary connection to a potable water supply shall be required. At the conclusion of the initial cross-connection test, the temporary connection to the potable water supply shall be disconnected.
 The alternate water source system shall remain pressurized for a minimum period specified by the Authority Having Jurisdiction while the potable water system is empty.

The minimum period the potable water system is to remain depressurized shall be determined on a case-by-case basis, but in no case shall that period be less than 1 hour.  Fixtures, potable, and alternate water source shall be tested and inspected for flow. Flow from a potable water system outlet indicates a cross-connection. No flow from an alternate water source outlet will indicate that it is connected to the potable water system.

2.5 Testing and Inspection Requirements Page 2-16
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 Where there is no flow detected in the fixtures which would indicate a cross-connection, the potable water system shall be repressurized.

2.5.2 Signage and other System Requirements
Signage must be provided for any dual plumbed system that is either using municipal recycled water or non-potable water from an ONWS. Signage must properly indicate if the system is using recycled water, which is reserved for municipal supplies and not ONWS, or other type of non-potable water and comply with the state regulations (CPC and CCR Title 22).

2.5.2.1 Recycled Water Systems Identification
Recycled water signs and fixtures using recycled water must be purple and visibly marked with back lettering stating “CAUTION: RECYCLED WATER, DO NOT DRINK” on a purple background, according to CPC Chapter 15 (see Figure 2-5). Signage is required at entrances or locations where recycled water is used like landscape areas or bathrooms where recycled water is used for toilet flushing. Signs must be located such that they are visible to users.

In addition to signage, there are other specific requirements for irrigation systems using recycled water such as providing locking features for valves, except control valves, hose bibbs are not allowed on recycled water piping systems and only quick coupler valves can be used and must differ from quick coupler valves used with potable water supply in areas subject to public access.

Figure 2-5: Example Recycled Water Advisory Sign

2.6 Developing an ONWS Program Page 2-17
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2.5.2.2 ONWS Identification
According to CPC Chapter 15, signs for ONWS should include text indicating the intended use to inform the public such as: “TO CONSERVE WATER, THIS BUILDING USES ONSITE TREATED NON-POTABLE WATER TO FLUSH TOILETS AND URINALS” Signs must also be included in the equipment rooms visible to workers and identifying the fixtures and equipment using recycled water or non-potable water. Signs should include notification to workers such as: “CAUTION: ONSITE TREATED NON-POTABLE WATER, DO NOT DRINK. DO NOT CONNECT TO DRINKING WATER SYSTEM. NOTICE: CONTACT BUILDING MANAGEMENT BEFORE PERFORMING ANY WORK ON THIS WATER SYSTEM.

Signage and proper ONWS identification must be inspected prior to finalizing a permit to operate an ONWS project.

2.5.2.3 Other Public Health Protections
CCR Title 22 also requires that any use of recycled water be confined so that its application does not pose a public health threat with restrictions on places of use and application methods.

These restrictions include:
• Conditions that must be met for the use of recycled water for irrigation within 50 feet of a domestic water supply well.
• No impoundment of recycled water within 100 feet of a domestic water supply well. • No use of disinfected secondary – 23 recycled water or disinfected secondary – 2.2 recycled water within 100 feet of a domestic water supply well. • No irrigation or impoundment of undisinfected secondary recycled water within 150 feet
of a domestic water supply well.

• No unauthorized recycled water irrigation runoff outside the recycled water use area. • No spray, mist, or runoff of recycled water can enter dwellings, designated outdoor eating areas, or food handling facilities or come into contact with drinking water fountains.
• Only disinfected tertiary recycled water can be used for spray irrigation within 100 feet of a residence, park, playground, schoolyard, or other place of similar use.

2.6 Developing an ONWS Program
The San Francisco Public Utilities Commission (SFPUC), in partnership with WRF and the Water Environment Research Foundation (WERF) partnered to develop a Blueprint for Onsite

2.6 Developing an ONWS Program Page 2-18
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1. Create a small group to facilitate the development of the local program.

2. Select the alternate water sources that will be permitted within the program.

3. Identify the specific end uses for the non-potable water in the program.

4. Establish water quality standards for each alternate water source and/or end use.

5. Integrate the program into local building practices through construction requirements and building permit processes.

6. Establish monitoring and reporting requirements for water quality.

7. Create the permit process for initial and ongoing operations. a. Define which agency is responsible for: administering operating permits, reviewing monitoring data, reviewing and approving engineering and design reports, and having the authority to shut down systems that do not comply with permit requirements.
b. Permit phases that should be considered: pilot systems, startup permit, temporary use permit, final permit, and continuing operation permit.

8. Publicize the program and provide direction for the project sponsors and developers. a. Define the design, construction, and operation processes for project sponsors and developers. Educational materials, such as brochures or guidebooks, that highlight the objectives and requirements of the program should be developed. Identify champions of the program and how they can support. Support can be a general resolution, a specific ordinance, or a planning policy.

Steps 1 through 8 help guide the development of an ONWS program and Steps 9 and 10 are concerned with growing the ONWS program.

9. Evaluate the program and advance the best practices for ONWS. Evaluation criteria can include: effectiveness, accomplishments, adjustments that may be necessary, updates to the program based on treatment technologies and/or regulations, and data collection.

10. Promote the growth of the program by finding opportunities to expand onsite water systems. Growth can include: increasing water sources, allowing other non-potable uses, adjusting the scale, and increasing financial incentives.

Section 3.1.1 reviews the San Francisco Onsite Water Reuse Program, which serves as a model for the 10 steps above. The City of Sacramento can use this guide to develop its own ONWS Program, with this Study presenting the topics and identifying the decisions and

2.7 Development of an ONWS Ordinance Page 2-19
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2.7 Development of an ONWS Ordinance
The National Blue Ribbon Commission for Onsite Non-potable Water Systems included in their Guidebook for Developing and Implementing Regulations for Onsite Non-potable Water Systems, a template to develop a local ordinance to implement an ONWS program

There are multiple pathways to implementation of an ONWS ordinance including: development of regulations by state and implementation by local authority, development and implementation of regulations by state, and development and implementation of regulations by local authority.

This specific template focuses on the scenario where the state develops the regulations, and the local authority implements them.

The template is broken down into 12 sections recommended to be included for an ordinance.

For a local jurisdiction to develop an ordinance several parameters would need to be defined for the program as referenced in Section 2.6, such parameters include:

1. Defining the alternate water sources that may be used to supply an ONWS (excluding groundwater wells).

2. Selecting the allowable non-potable end uses to be supplied by an ONWS.

3. Specifying the type and scale of developments that would be required to or recommended to implement an ONWS.

4. Determining the applicable rules and regulations for ONWS, including:
a. Treatment and water quality standards, based off existing regulations or proposed risk-based standards as summarized in Section 2.4.2.
b. Operation, monitoring, and reporting standards
c. Application process to obtain a permit to install an ONWS d. Review process to approve a permit for an ONWS (plan check and construction) e. Inspection and certification requirements to approve an ONWS for operation, including site supervisor certification requirements
f. Permit issuance, renewals, revocation, enforcement or transfers due to Change of Ownership

5. Establishing fees, penalties, and incentives

6. Developing guidelines, manuals, and references.

3.1 Case Studies for One Water and Dual Plumbing Page 3-1 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Section 3: One Water Program Development through One
Water Vision
The One Water concept involves a collaborative and comprehensive long-term approach to community-based water management that recognizes all urban water supplies as resources (e.g., surface water, groundwater, stormwater, wastewater, graywater, etc.). One Water policies are implemented through integrated planning to meet community and ecosystem needs. One Water planning and implementation requires a coordinated effort to identify integrated water management practices and priorities to support building water security and resiliency. The implementation of a dual plumbing ordinance and ONWS projects in the City can be supported through this type of long-term water resource planning. A One Water Vision for the City’s Onsite Water Reuse Strategy can guide the development and implementation of an ONWS Program in the context of the City’s potable and non-potable water resources.

3.1 Case Studies for One Water and Dual Plumbing
Three relevant case studies were evaluated to understand how dual plumbing implementation is being achieved in other communities and how ONWS fit into the broader One Water framework.

Case Study 1. San Francisco Onsite Water Reuse Program: This case study provides an example of a city that is a leader in the State of California as an adopter of ONWS and development of a program for planning, monitoring, and installation. The case study demonstrates the use of pilot studies to develop organizational knowledge and technical capacity. It demonstrates the resources and coordination needed to administer this program and enforce the requirements. The case study also introduces the concept of district scale projects and the opportunities and drawbacks of these types of projects.

Case Study 2. City of Santa Monica Recycled Water Ordinance: This case study provides an example of a smaller scale project, when compared to the San Francisco case study. The ordinance took 1 year to draft and applies to buildings 7,500 square feet or larger. It demonstrates the integration of the ordinance with existing water infrastructure, current County regulations and processes, and future water conservation initiatives.

Case Study 3. One Water Ordinance (Honolulu, Hawaii): This case study provides an example of a process to develop the principles and procedures for how city departments and agencies work together, including establishing regular interagency meetings and collaboration. This ordinance describes mechanisms to support developers. This case

3.1 Case Studies for One Water and Dual Plumbing Page 3-2 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx study also demonstrates the value of pilot studies in analyzing the potential benefits of different ONWS systems, including stormwater capture and potable water conservation.

Appendix A provides case study summary sheets with key information about each of the programs. Appendix B provides the ordinances for each city. The City’s One Water Vision and Onsite Water Reuse Strategy builds off the lessons learned from these case studies.

3.1.1 San Francisco Case Study
The City of San Francisco was the first city in the United States to mandate newly constructed buildings to install ONWS. As of 2022, the Non-potable Water Ordinance requires that new development projects of 100,000 square-feet or greater must use ONWS. For commercial buildings, the project must meet its toilet and urinal flushing and drain trap priming demands through the collection, treatment, and use of available blackwater and condensate. For residential and mixed-use buildings, the building must meet its toilet and urinal flushing, irrigation, clothes washing, and drain trap priming demands through the collection, treatment, and use of available graywater and condensate. In addition to the requirements for buildings 100,000 square-feet (sq ft) or greater, buildings 40,000 square-feet or larger must submit water budget calculations and assess the supply available from alternative water sources and the demand from required non-potable uses.

ONWS Timeline
The San Francisco Onsite Water Reuse Program was first established in 2012 as a voluntary program. In 2012 the SFPUC created a voluntary program for water reclamation. SFPUC led the onsite initiative by installing an ONWS with a 5,000 gallons per day capacity in the lobby of its administrative building, treating the building’s wastewater, and reducing the building’s demand by more than 70 percent.

In 2013 the program was amended to include district-scale systems. A district-scale project is when two or more buildings within a development share a system. In 2015, the program became mandated, requiring onsite systems. Between 2012 and the mandate of ONWS, many of the systems were driven by achieving credits towards Leadership in Energy and Environmental Design (LEED) certifications, complying with the City’s stormwater management ordinance, and individual project sustainability goals. The stormwater management ordinance was in place before the ONWS ordinance and required the retention of stormwater onsite through development of bioswales, green roofs, or rainwater harvesting systems. In buildings that opted for rainwater harvesting systems, the ONWS permit process was required. In 2016, buildings 250,000 square feet or larger required ONWS. In 2021, regulations for ONWS were further tightened to require new developments as of January 1, 2022 with 100,000 square feet or greater to require ONWS.

Ordinance Exemptions
Exemptions to the Non-potable Water Ordinance include:
• Rehabilitation of buildings constructed prior to August 1, 2015

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• Production, distribution, and repair use buildings
• A building that will receive water service from the San Francisco Public Utilities Commission through no larger than a 5/8” domestic water meter or a 5/8” recycled water domestic meter
Implemented ONWS Systems
SFPUC led by example and in 2012 installed an ONWS in the lobby of its administration building with a capacity of 5,000 gallons per day. The building contains two onsite water systems, a Living Machine® and a rainwater harvesting system. In 2021, SFPUC published a report that details the developments in San Francisco that are currently operating or are in the process of installing a non-potable water system. This report included 17 sites, which were using rainwater, blackwater, bay water, graywater, foundation drainage, steam condensate, stormwater for onsite non potable reuse. 14 of the 17 projects used rainwater or rainwater and another water source, and 14 of the 17 projects used non potable reuse water for toilet and urinal flushing. On average the building size was 650,600 square feet (375,800 sq ft for 50 th
percentile) and the volume treated at each building on average was 5.91 million gallons per year (0.91 MG/yr for 50
th percentile).

Project Funding
SFPUC incentivized project developers to go ‘above and beyond’ the required treatment volumes through a grant program. The Onsite Water Reuse Grant Program provides grants for voluntary or ‘above-and-beyond’ projects, with the level of funding based on estimated water offset (gal/yr for 10-years). The maximum funding available to offset the upfront construction costs for each project is $1 million for offsetting 3 million gallons per year or more of water.

Based on the available case study information, this grant has provided funding to five of the case study projects, ranging in 14%-20% of the ONWS installation cost

4. Agency Coordination and Staffing Requirements
SFPUC manages the program administration where they review the onsite non-potable water budgets, track the projects and annual potable offset achieved, and provide technical support and outreach to developers. SFPUC also manages the cross-connection control program.

SFPUC is also supported directly by the SF Department of Public Health, SF Department of Building Inspections, and SF Public Works. The SF Department of Public Health, Environmental Health issues the water quality and monitoring requirements. They also review the engineering

4 ONWS installation costs were available for four of the five projects that have received funding through the SFPUC Onsite Water Reuse Grant Program.

3.1 Case Studies for One Water and Dual Plumbing Page 3-4 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx reports that are submitted by the developers. They are responsible for issuing the permit to operate the system and once the systems are in operation, they are responsible for reviewing the water quality reporting from the systems.

The SF Department of Building Inspections conducts plumbing plan checks and issue plumbing permits. They are also responsible for inspecting and approving system installations. SF Public Works Department is responsible for right of way mapping, issuing encroachment permits as needed. These roles and responsibilities are summarized in Table 3-1.

Table 3-1: San Francisco Onsite Water Reuse Program Core Agencies (Adapted from SFPUC, 2021)
San Francisco Public
Utilities Commission
SF Department of
Public Health-
Environmental Health
SF Department of
Building Inspections SF Public Works
Program
Administration &
Cross-Connection
Control
Environmental Health Construction Right of Way &
Mapping
Review onsite non-
potable water supplies &
demands
Issue water quality &
monitoring requirements
Conduct Plumbing Plan
check and issue
Plumbing Permit
Issue encroachment
permits as needed for
infrastructure in the
Right-of-Way (if needed)
Administer citywide
project tracking & annual
Review & approve non-
potable engineering
report
Inspect and approve
system installations
Includes condition on a
subdivision map or a
parcel map requiring
compliance with the Non-
Potable Ordinance prior
to approval and issuance
of said map (if
applicable)
Provide technical support
& outreach to developers
Issue permit to operate
onsite systems
Managers Cross-
Connection Control
Program1
Review water quality
reporting to evaluate
compliance with
standards while system
is operating
Table Adapted from SFPUC

1. Cross-connection control program requires inspection and testing prior to operation of the system. For blackwater systems the system must be tested every four years. For graywater, rainwater, groundwater, etc. subsequent cross-connection testing is not required.

SFPUC currently has one full-time employee who operates the program administration. During project startup, there was one full-time employee and one part time employee dedicated to the program. These employees are funded through the operating budget of SFPUC. Other departments have not seen increased staffing and activities are funded through permitting fees.

The City is not involved in the operation and maintenance of any of the installed ONWS.

System Implementation Steps

3.1 Case Studies for One Water and Dual Plumbing Page 3-5 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx SFPUC has a ten-step process for developers implementing ONWS. These steps are as follows:

1. A water budget must be submitted that demonstrates the available water supplies and non-potable demands. SFPUC has a Non-Potable Water Use Calculator available to support developers at this step.

2. Submit non-potable implementation plan (District Scale Projects only) that provides details on the design, operation, and phasing schedule. SFPUC has a checklist to aid developers at this step. This includes schematic layouts of onsite water reuse system components, details on the district scale system, estimated potable and non-potable demands, analysis of anticipated sewer system impacts, proposed ownership model, as well as a phasing plan for implementation of the project.

3. Submit an application for permit to operate to San Francisco Department of Public Health – Environmental Health (SFDPH-EH). This provides the department of health information on the proposed system. An engineering report is prepared and submitted to SFDPH-EH that provides details on the treatment system design and technical information for the onsite non-potable water systems. SFPUC has developed a database of ONWS vendors and technologies to assist developers at this stage.

4. Obtain an encroachment permit if the project includes installing infrastructure in the public right-of-way. This is reviewed by San Francisco Public Works (SFPW) to identify any potential utility conflicts.

5. Obtain plan check approval and complete system construction. This includes a plumbing plan check to verify that the ONWS meets State of California and San Francisco Plumbing Code requirements. Once the system is constructed, a Construction Certification Letter must be submitted to verify that the system was installed in accordance with the engineering report. System modifications from the engineering report must be submitted.

6. Once the system is constructed, before it can be used a cross-connection test and complete post-construction inspection must be completed. The City has a list of certified cross-connection control specialists who are qualified to conduct the tests.

Cross-connection testing is required for all systems before startup and after any major plumbing alterations. Blackwater systems require cross-connection testing every four years.

7. Submit documentation for a permit to operate after passing the cross-connection test.

This permit step includes submitting an operation and maintenance manual, proof of a contract with a laboratory for water quality testing, information demonstrating that all parties legally agree with their responsibilities, as well as a treatment system manager affidavit. Graywater systems require a Grade 2 water treatment plant or distribution system operator or Grade 2 Wastewater Treatment Plant operator. Blackwater systems require a Grade 2 wastewater treatment plant operator. At this stage the project is also added to the City’s tax collector website.

3.1 Case Studies for One Water and Dual Plumbing Page 3-6 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx

8. Obtain a permit to operate from SFDPH-EH. This permit allows the start of the system in a conditional mode.

9. Once the permit is issued, the system can be operated in conditional startup mode. A 90-day period of conditional startup is followed. During this phase the system is verified that it meets log reduction targets, BOD, total suspended solids (TSS), and turbidity requirements. During this time the treated water is diverted to the sewer and the end uses are supplied with potable water. Rainwater, stormwater, foundation drainage, and blackwater have varying conditional startup water quality sampling requirements.

10. Once the conditional startup mode proves the system is operating and meeting water quality requirements the system can operate in final mode with approval. Treatment system managers must continue to report monitoring results to SFDPH-EH, with blackwater systems reporting quarterly and other systems reporting annually. Systems must also be regularly inspected and tested to verify it is operating correctly. This is demonstrated through water quality monitoring. Once the systems are operating in final use mode, blackwater systems must submit reports on a quarterly basis and other water source systems must submit reports on an annual basis to SFDPH-EH. Backflow prevention assemblies and cross-connection tests must be conducted in accordance with local and state regulations.

Implementation of District-Scale Projects
A district-scale project is defined as a system serving two or more buildings, whether under the jurisdiction of one entity or several entities. District-scale projects were added to the program in 2013. These projects can provide for greater efficiencies for onsite water reuse, however, are subject to additional requirements given the complexity of design, phasing, and implementation.

District-scale projects were incorporated due to the found benefits of balance of supply/demand, reduced operation and maintenance (O&M) complexity/cost, building footprint, payback period, and stormwater compliance. Challenges to district-scale projects have included higher initial program cost, ownership and maintenance agreements, schedule and phasing challenges, permitting requirements, as well as encroachment permits and private infrastructure challenges.

Examples of district scale projects include the following:
• Chase Center arena which includes two towers adjacent to the arena and a 3.2 acres public plaza. It is owned by a single entity and ongoing service and maintenance is contracted.
• Moscone Center Expansion Project includes a 1.5 million square feet project using rainwater, foundation drainage and steam condensate to treat approximately 15 million gallons per year. The project was conducted with the City and County of San Francisco’s Convention Facilities Department, San Francisco Public Works, and the San Francisco Tourism Improvement District Management Corporation. A motivation of the project was for LEED Certification and compliance with the San Francisco Mayoral Executive Directive 14-01.
• Mission Rock will be a new mixed-use 28-acre neighborhood that includes parks, open space, residential, commercial, and retail. As of 2021, the project is still in design, but

3.1 Case Studies for One Water and Dual Plumbing Page 3-7 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx will treat blackwater to produce 43,000 gallons per day. The project will establish its own utility organization (Mission Rock Utilities, Inc.) to oversee the system and the daily activities of the utility will be managed by Ever Green Energy through a management services agreement.

Summary of San Francisco Case Study
SFPUC pioneered the implementation of ONWS in the United States. SFPUC led by example through the implementation of the first system in their buildings. The program started as an optional, sustainability driven and LEED certification program with a strong nexus between the stormwater requirements. Funding opportunities for developers aided the growth of the program and encouraged programs to achieve water reuse above recommendations or requirements.

Over time, as technologies developed, and implementation and monitoring systems were established by various City departments the program became mandated. Ongoing activity required to support the project from SFPUC as well as support from the public health, public works, and building inspection departments. District-scale projects emerged because of the findings of the initial projects and provide potential cost-savings to developers.

While the San Francisco Onsite Water Reuse Program has shown that an ONWS program is feasible in California, it has taken a decade to become the robust and stable program that it is.

The City of Sacramento will need to go through much of the same discovery path to establish an ONWS of its own that matches the City’s local climate, economy, and building potentials. The development of the City of Sacramento’s ONWS can benefit, however, from the lessons learned by the San Francisco Onsite Water Reuse Program to establish its own ONWS in a shorter amount of time. Unlike San Francisco, which is both the City and County, the City of Sacramento will need to obtain buy-in from other agencies with jurisdictions within the City boundaries.

3.1.2 Santa Monica Case Study
The City of Santa Monica aims to reduce its dependence on imported water using municipal recycled water and become water self-sufficient by 2023. A recycled water ordinance to increase the use of municipal recycled water is one way in which Santa Monica aims to reduce its dependence on imported water. In 2014, the City established the recycled water service area through their Sustainable Water Master Plan in 2014. Since 2014, the City of Santa Monica has increased their recycled water production through the Sustainable Water Infrastructure Project, which has included upgrading their Urban Runoff Recycling Facility. The City is currently evaluating additional potential opportunities to expand their recycled water service (purple pipe) network.

The City Council passed the dual plumbing ordinance on March 22, 2022, which sets guidelines for dual-plumbed buildings and landscape irrigation within the City’s service area. The City of Santa Monica began drafting a Recycled Water Ordinance and Recycled Water User Guidelines in 2021. The ordinance requires the use of recycled water by: (1) all new developments of 7,500 square-feet or greater, and (2) existing potable water surface irrigation applications within the existing local recycled water service area. For indoor use, dual plumbing systems are to be utilized in new buildings that are commercial, industrial, or multi-facility residential developments, with applications including: flushing toilets/urinals, industrial process or boiler

3.1 Case Studies for One Water and Dual Plumbing Page 3-8 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx feeds, commercial laundries or carwashes, industrial or commercial cooling towers or evaporative condensers. Outdoor uses will include surface irrigation for highway and median landscaping, city parks, cemeteries, commercial building landscaping, and public-school grounds.

Ordinance Exemptions
Exemptions to the Recycled Water Ordinance will include:
• Any exemptions recognized by the Los Angeles County Department of Public Health. • Fire protection systems in any development
• Uses where recycled water quality has been deemed non-suitable for a particular fixture or equipment as reasonably determined by the Manager
• Uses when installing a recycled water system for surface irrigation and/or dual-plumbing system uses is commercially infeasible as reasonably determined by the Manager. In this case a Recycled Water In-Lieu Fee shall be required.

Influent Water Sources
Currently the City of Santa Monica’s recycled water production comes from the Santa Monica Urban Runoff Recycling Facility (SMURRF) and is used for beneficial non-potable reuse.

Influent sources include dry weather runoff (water from excessive irrigation spills, construction sites, pool draining, car washing, washing down of pavement) and occasional wet weather runoff.

The City of Santa Monica is currently in the process of expanding recycled water sources through the City’s Sustainable Water Infrastructure Project (SWIP). The SWIP will deliver advanced treated recycled water to the City for both groundwater replenishment and non- potable use for applications including irrigation and toilet flushing. As part of the SWIP, the City of Santa Monica is constructing an advanced water treatment plant to treat 1 MGD of municipal wastewater for non-potable and indirect potable reuse. The current recycled water demand is lower than the planned increase in production of recycled water, so the implementation of the ordinance will expand recycled water use opportunities in the City. The installation of dual plumbing will not only increase demand, it will also facilitate expansion of the existing recycled water infrastructure to ultimately reduce dependency on imported water and increase water self-sufficiency.

Agency Coordination and Staffing Requirements
Several agencies were involved in the drafting process of the Recycled Water Ordinance, and they continue to be involved based on the requirements of the ordinance. These agencies include the City Building and Safety Department, City Water Resources Division, Los Angeles County Department of Public Health, Los Angeles County Sanitation District, the Los Angeles Regional Water Quality Control Board, and the State Water Resources Control Board.

3.1 Case Studies for One Water and Dual Plumbing Page 3-9 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx The City of Santa Monica Water Resources Division led the development of the Recycled Water Ordinance. They are the entity that will review the recycled water use applications and oversee the implementation and inspection of the systems. They are supported by the City Building and Safety Department who review the building permit applications, issue building permits, and collect the associated fees. The costs to the City of Santa Monica for administering and implementing the requirements of the Recycled Water Ordinance will be covered by administrative fees. Building permit applicants that are candidates for recycled water use under the City of Santa Monica’s ordinance will be required to pay the administrative fee at the time of issuance of the building permit.

Los Angeles County Department of Public Health administers the Cross-Connection and Water Pollution Control Program and provides cross-connection control and signage regulations. Los Angeles County Department of Public Health is delegated by the State to approve recycled water use and coordinates between applicants and the State Water Resources Control Board Division of Drinking Water. For new applications for recycled water use within the City of Santa Monica, reviews, inspections and conditional use approvals are incorporated into the County’s existing processes. Additionally, water quality and system requirements are regulated by the Los Angeles Regional Water Quality Control Board and the State Water Resources Control Board. The Los Angeles County Sanitation Districts is a local organization that provides recycled water user site supervisor training. These agencies and their roles are summarized in Table 3-2.

3.1 Case Studies for One Water and Dual Plumbing Page 3-10 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Table 3-2: Core Agencies for City of Santa Monica Recycled Water Ordinance City
Building &
Safety
City Water
Resources
Division
Los
Angeles
County
Department
of Public
Health
Los
Angeles
County
Sanitation
District
Los Angeles
Regional
Water
Quality
Control
Board
State Water
Resources
Control Board,
Division of
Drinking Water
Construction Program
Administration
Cross-
Connection
Control
Training Permitting
Program
Administration
and Review
Review
building
permit
applications
Led
development of
Recycled
Water
Ordinance
Sets
regulations for
cross-
connection
safety and
testing
Oversees
recycled
water users
site
supervisor
training
program
Sets SWIP
waste
discharge
requirements
Reviews project
plans and
specifications for
dual-plumbing
systems

Issue
Building
permits and
collect
associated
fees
Review
recycled water
use
applications
Approves
recycled water
signage

Set Water
Reclamation
Requirements
requiring the
City to
implement
ordinances
governing the
use of RW
Oversees
implementation
and inspection
of systems

Project Funding
As part of the City’s Sustainable Water Master Plan (SWMP) three major projects were identified to achieve water self-sufficiency for the City: expanding the City’s WTP capacity and efficiency; increase groundwater production; and construct a new advanced water treatment facility and pipeline. To help offset the capital expenditures, the City plans to pursue funding programs. These opportunities include: Metropolitan Water District’s Local Water Resources Program, California Department of Water Resources Water Quality, Supply. And Infrastructure Improvement Act of 2014 (Proposition 1) Grants, United States Bureau of Reclamation programs; and County of Los Angeles Measure W funding. For the funding to draft the Recycled Water Ordinance and Recycled Water User Guidelines, the City has budget allocated and did not choose to pursue any funding opportunities.

Summary of Santa Monica Case Study
The recycled water ordinance sets forth a path for the City’s future use of recycled water that aligns with their objective of water self-sufficiency and integrates into their planned construction of the SWIP. The development of the ordinance took almost one year to draft and applies to buildings 7,500 square feet or larger.

3.1 Case Studies for One Water and Dual Plumbing Page 3-11 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx The City of Santa Monica is similar to the City of Sacramento in that it requires to support of another agency to enforce water quality requirements. However; in this case this authority was assigned to Los Angeles County Department of Public Health well before the City’s efforts to expand its recycled water program. Even still, the City of Santa Monica’s recycled water ordinance can be used as a model for a program that is in its initial stages, which has not yet fully defined the requirements to comply with the program or the fees or resources needs to administer it.

3.1.3 Honolulu Case Study
Background

In 2016 the Hawaii Community Foundation convened the Freshwater Initiative Council. It consisted of a group of water department leads, regulators, large landowners, and other stakeholders to arrive at quantitative goals for the state to collectively achieve to meet water security goals by the year 2030. The primary factors that contributed to establishing water security measures included: decreasing overall rainfall, increasing drought conditions, land use changes and increasing evapotranspiration. These were drivers to establish the Freshwater Initiative Council and water security goals, outlined in the publication “The Blueprint for Action:

Water Security for an Uncertain Future.” The following are the goals outlined in the report for Hawaii to meet the water security target by 2030:

• Conservation: Increase Water Efficiency (40 million gallons per day, by increasing efficiency by 8%)
• Reuse: Double the volume of reuse (50 million gallons per day) • Recharge: Direct stormwater back into the ground (30 million gallons per day)

The Freshwater Initiative (FWI) goals were the driver for local water departments and regulators to work together to achieve these goals.

City and County of Honolulu One Water Ordinance

In 2020, Bill 65 was introduced to the City and County of Honolulu (CCH) Council to codify how water security and climate adaptation goals would be met, as well as encouraged partnerships and interagency coordination for water-related infrastructure. The bill was brought forward by the City and County of Honolulu Office of Climate Change, Sustainability and Resiliency and supported by the Honolulu Board of Water Supply (potable water supplier), City and County of Environmental Services (wastewater), City and County of Honolulu Facilities and Maintenance (stormwater) and the City and County of Honolulu Department of Transportation (roads).

The One Water Ordinance outlines both principles and procedures that will guide the coordinating departments and agencies. The procedures methodize how the agencies will work together on sea level rise, water and climate related issues and includes establishing regular interagency meetings and collaboration as well as pilot projects. In addition, the ordinance recognizes the need for partnerships with developers interested in supporting one water goals.

Mechanisms to support these projects are also described; for example, creating easier permitting pathways for projects that are investing in climate resilience infrastructure. Table 3-3

3.1 Case Studies for One Water and Dual Plumbing Page 3-12 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx summarizes the roles and responsibilities of the agencies implementing the One Water Ordinance.

Table 3-3: Summary of Core Working Agencies for Honolulu State of Hawaii
Department of
Health -
Wastewater
Branch
CCH
Environmental
Services
Honolulu Board
of Water Supply
CCH
Department of
Facility
Maintenance
CCH Planning
and Permitting
Environmental
Health
Sanitary Sewer &
Municipal WWTPs
Potable and
Municipal
Recycled Water
Distribution
MS4 Stormwater
Systems
Building
Permits/Plumbing
Code
Oversees Hawaii
Administrative
Rules 11-62
relating to
wastewater and
recycled water
Reviews
development's
sewer plans and
provide municipal
sewer hookups
Reviews
development's
potable water
demands. Provides
water meter.

Administrates
rules relating to
stormwater quality
and quantity.

Review
Stormwater
Quality Reports
and inspects LIDs.

Reviews and
inspects
development
projects for
building code and
plumbing code.

Provides water
quality rules
(except for
rainwater and
stormwater),
reviews
engineering
reports,
inspection, water
quality monitoring
Currently would
require a variance
with approval from
CCH ENV (and
DOH) for onsite
wastewater
treatment
Distributes recycled
water from
municipal
wastewater
treatment plant
Oversees LID/GSI
projects in the
right-of-way.
*Ultimate building
permit requires the
sign off approval of
the project from
the other CCH
department noted
in this table.

Note: City and County of Honolulu are one agency
Onsite Reuse for New and Redevelopment

In 2019 the Honolulu Board of Water Supply led an initiative to identify where onsite reuse along the new transit-oriented development corridor may have the most benefits for multiple agencies and developers. The One Water planning effort combined city and state data available that showed:

• Areas of low sustainable (ground) water yield
• Areas of flooding, sea level rise and lower sewer capacity • Soil capacity for groundwater recharge
• Optimum zones for rainwater harvesting

The study also identified four larger transit-oriented redevelopment projects to investigate the potential water and cost savings for onsite reuse at the district and building scale.

3.1 Case Studies for One Water and Dual Plumbing Page 3-13 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx

Kapālama Redevelopment Onsite Reuse Analysis

Of the four major redevelopment projects identified in the One Water planning effort, the Kapālama Redevelopment project was selected for a deeper analysis for the potential benefits for onsite reuse. It was selected because of the project location in an area where there is potential to achieve multiple benefits across multiple agencies. The site characteristics showed that the redevelopment project was in an area of lower sewer capacity area and nuisance flooding and was projected to be impacted by future sea level rise. Without any intervention to include onsite reuse, the development had the following baseline conditions:

• Total area: 88 acres
• Number of projected residential units: 4,400
• Assumed daily water demand: 880K gallons per day (gal/day) (200 gpd per unit) • Ave rage number of residents in PUC = 2.4 people/residential unit • Projected annual water & sewer bill: >$2.8M
• Estimate annual stormwater runoff: ~64 million gallons (MG) • Projected annual stormwater utility fee: ~$188K ($4.82/1000 sq ft IA)

The onsite reuse analysis investigated onsite reuse both at the district scale and single building level. Annual onsite water supplies were compared to various annual non-potable water end use demands to determine optimum strategies.

Figure 3-1: Kapālama Water Demands and Potential Supplies (District Scale)

As shown in Figure 3-1, wastewater and graywater supplies exceeded the non-potable reuse demands and that stormwater (as rainwater collected from rooftops or land area runoff) could meet cooling tower makeup water throughout the year, while only supplying toilets for about 6-7 months during an average year of rainfall. The trend was also the same at a disaggregated scale for the individual parcels that comprise the overall project.

3.1 Case Studies for One Water and Dual Plumbing Page 3-14 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Individual Parcel

An average size parcel was identified within the redevelopment to undergo an onsite reuse assessment to evaluate the cost-benefit for a typical building in this development. The parcel included the following baseline conditions should no action be taken:

• Average parcel size: 1.6 acres
• Number of projected residential units: 81 (4400 total/54 parcels) • Assumed water demand: 200 gallons per unit
• Average number of residents = 2.4 people/residential unit • Total estimated annual water demand: 4.67 MG
• Projected annual water & sewer bill: $53,400
• Estimated annual stormwater runoff: 1.1 MG
• Projected stormwater utility fee: $3,400/yr

A water balance was conducted for the parcel based on the expected number of building occupants, estimated building footprint and rainfall. The analysis yielded estimates for non-potable water demands and potential onsite supplies (blackwater, graywater, condensate, and rainwater from the building roof). As shown in Figure 3-2, it is estimated that 4.4 MG of wastewater would be generated, 7% of which is condensate recovery, 50% graywater, and 25% stormwater capture from the roof (rainwater). Although the remaining 18% of wastewater would not be recoverable, the amount of wastewater that can be reused is still more than enough to meet the non-potable demands of toilet flushing, cooling and heating, and irrigation totaling 2.87 MG.

Figure 3-2 also shows that the reuse of wastewater would also result in a savings in energy due to the avoided pumping, treatment, and distribution of potable water by the local water utility.

Reuse would also result in annual savings to residents from avoided potable water and sewer fees both on the supply side (potable water) and the demand side (sewer or storm drain discharge). Although costs for specific ONWS were not evaluated, this analysis shows how much cost savings from the reuse of wastewater can be used to offset installation and operations costs of onsite treatment.

Alternative Source Water Selection
The results of the District Scale and Individual Parcel analyses both indicate there was more than adequate blackwater and graywater supplies to meet the non-potable end uses for toilet flushing, cooling tower makeup water and irrigation. However, after discussions with the various city water agencies and due to the site conditions, rainwater harvesting/stormwater capture from roofs was determined to have the most benefit across multiple agencies and would meet capital and operational costs considerations for the developer. Identified benefits for the agencies included:

• Supporting the reduction of current flooding and future sea level rise • Storing stormwater (minimizes impacts of sanitary sewer overflows (SSOs) during rain events)
• Conserving potable water

3.1 Case Studies for One Water and Dual Plumbing Page 3-15 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Figure 3-2: Annual Water Portfolio and Annual Non-Potable Water Demands Annual Water Portfolio (with Occupant Cost-Savings)

Annual Non-Potable Water Demands

1. Energy Assumption based on average energy intensity of 3.2 kWh/1000 gal for Oahu (DLNR, 2016 Hawaii Water Energy Nexus Report)

2. Occupant savings are based on assumption of replacing potable water with non-potable water (estimated from avoided potable water and sewer costs)

3. Total wastewater includes graywater and blackwater

4. 12 gal/1000sq ft per day (Novak 2014)

5. Assumes stormwater capture from building roofs only

Regulating Onsite Reuse

The City and County of Honolulu is currently using the 2018 Uniform Plumbing Code which includes code for non-potable reuse for indoor fixtures. Currently, the State of Hawaii Department of Heath Wastewater Branch is collaborating with developers to conduct initial pilots for onsite reuse to identify overlaps in responsibilities. It will likely be adopting a similar regulatory framework for onsite reuse as outlined by the Blue-Ribbon Commission.

Summary of Honolulu Case Study
Although the City and County of Honolulu is a single entity, they adopted the One Water Ordinance to serve as a roadmap for the different agencies to work together to meet the Freshwater Initiative water security goals. In addition to outlining the principles and procedures for how city departments and agencies work together, the One Water Ordinance establishes a commitment to lead, plan, and implement the development of comprehensive planning, regulations, design, and construction of city infrastructure that incorporates climate change adaptation solutions. Demonstration projects will inform the development of climate change adaptation solutions such as ONWS as well as provide an opportunity for CCH to partner with developers and find ways to streamline permitting pathways for projects that are investing in climate resilience infrastructure.

3.2 ONWS One Water Vision Page 3-16
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Although rainwater was identified as the optimal alternative water source for Honolulu, this resource may not be preferred in the City of Sacramento, which experiences less precipitation annually. The method to analyze the Kapālama Redevelopment can be used to estimate the potential water and cost savings, as well as ONWS that would work best for Sacramento.

Similar to the City and County of San Francisco, the City and County of Honolulu is a single entity. Even still, CCH adopted the One Water Ordinance to define how the departments would work together to develop the plans and programs, regulations, and design updates to meet the Freshwater Initiative water security goals. This approach could be used by the City of Sacramento to develop its ONWS program, as well as further define how it fits into a One Water Vision and the City’s Climate Implementation Framework.

3.2 ONWS One Water Vision
Long-term implementation of a dual plumbing ordinance can be supported by the creation of the City’s One Water Vision, which would consist of the scope, vision, and objectives for the City’s ONWS program. The Water Research Foundation drafted the “Blueprint for One Water” with a suggested process for developing a One Water Framework. The City of Sacramento is currently in the process of Setting the Foundation, Establishing the Direction, and Engaging Stakeholders.

Figure 3-3: Blueprint for a One Water Approach

Adapted from “Blueprint for One Water” (The Water Research Foundation)

3.2 ONWS One Water Vision Page 3-17
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx A series of workshops were held to identify the top priorities and direction for the City’s Onsite Water Reuse Strategy and One Water Vision. One Water is the idea that water, similar to mass, is neither created nor destroyed, it is merely transformed. The quality of this water is largely dependent on human behavior. Therefore, it is important to be proactive about protecting it. The San Francisco, Santa Monica, and Honolulu case studies were used as examples of how One Water and Onsite Water Reuse Strategies were developed and implemented to demonstrate the specific actions and decisions needed to create and implement a dual plumbing and ONWS ordinance and program. At this stage of development, the City’s One Water Vision will apply to the City’s One Water Reuse Strategy only, as its application to other City programs and activities have not yet been evaluated.

The goals of the One Water Vision Workshops were to:

1. Identify key components of a Sacramento One Water Vision for the Onsite Water Reuse Program;

2. Define high level goals for a Sacramento Onsite Water Reuse System Program in the context of the Sacramento One Water Vision; and,

3. Establish objectives of Sacramento Dual Plumbing Ordinance to meet the goals for onsite reuse and the Sacramento One Water Vision.

During the One Water Vision Workshops, City staff representing DOU, CDD, the Department of Public Works and City Manager’s Office of Climate Action and Sustainability were asked a series of questions related to 1) the City’s One Water Vision, 2) the role of onsite water reuse in the One Water Vision, and 3) implementation of a dual plumbing ordinance. The following sections summarize the outcomes of the workshops. A draft framework for the City’s Onsite Water Reuse Strategy and One Water Vision for use in development of the dual plumbing ordinance is provided as Appendix C.

3.2.1 Sacramento One Water Vision
Based on workshop discussion, the Sacramento One Water Vision as applied to the City’s Onsite Water Reuse Strategy should lead to:
• R eliable and resilient water systems for the future
• Optimized use of local water resources
• Use of right resources to the right use
In order to implement the Sacramento One Water Vision, the effort will need to be driven by:
• Bold leaders from senior positions at both political and executive levels • Legislators and local and regional representatives from regulatory agencies • Engaged stakeholders, including community representatives The Sacramento One Water Vision should also consider:

3.2 ONWS One Water Vision Page 3-18
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx • Water in the Sacramento region is of good quality, and affordable, especially when compared to the cost and availability of recycled water from Regional San or from ONWS.
• On-going engagement with the regulatory agencies (State Water Resources Control Board and Sacramento County) will be needed to help drive the development and implement the One Water Vision.

3.2.2 Role of Onsite Water Reuse in the Sacramento One Water Vision
Workshop participants identified the top drivers and goals for the City’s Onsite Water Reuse Strategy:
• Balancing the needs of the community, including developers, trades and labor unions, and other stakeholders
• Reliable and resilient water systems for the future
• Optimized use of local water resources
Aligning energy use and reducing carbon emissions, matching the right resource to the right use, and avoiding costs for the collection of drainage were also identified as important goals and drivers. In addition, as this Study was initiated in response to the New Building Electrification Ordinance and the City’s Climate Implementation Workplan, the Onsite Water Reuse Strategy is an opportunity to think about long-term sustainability of water and its relationship to climate change.

The greatest challenges to achieving the One Water Sacramento Vision through the Onsite Water Reuse Program are:
• Establishing water quality standards and monitoring and reporting requirements for alternate water sources and/or end uses
• Establishing a permit process for initial and ongoing operations for ONWS • Publicizing the program to developers, promoting best practices, and expanding and encouraging ONWS
Other challenges identified include integrating the Onsite Water Reuse Program into local construction requirements and building permit processes and selecting the allowable types of alternate water sources. In addition, there are currently no state regulations in place that define water quality requirements for ONWS except for water quality parameters for rainwater systems defined in the CPC; therefore, the program that the City implements may need to be updated as these regulations are developed.

3.2.3 Implementation of a Dual Plumbing Ordinance
Workshop participants agreed that the objectives of Dual Plumbing Ordinance are to:

3.2 ONWS One Water Vision Page 3-19
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx • Increase resiliency and adaptability of our water and wastewater infrastructure • Establish and sustain communication with community stakeholders • Integrate onsite reuse strategies with land use and other planning efforts (sewer, wastewater treatment, reuse, and drainage, etc.)
• Provide a favorable economic environment for private investment Achievement of these objectives will be a process; therefore, Workshop participants identified the following elements that should be included in the initial Dual Plumbing Ordinance:
• Roles and responsibilities, including assigning agencies for overseeing water quality criteria, monitoring, and permitting requirements
• Updates to existing City policies, rules, regulations, and design guidelines, as well as procedures/guidelines for City departments
• Defining the parameters and boundaries to require dual plumbing, including options for developers to opt out of installing dual plumbing. The Dual Plumbing Ordinance should also allow the City flexibility in how they enforce the requirement.

Additional activities that can be considered for the initial Dual Plumbing Ordinance include establishing fees and incentives for installing dual plumbing and protections for the City against taking over abandoned ONWS (for example as the result of building ownership changes).

Once the City’s Dual Plumbing Ordinance is adopted, the City should turn its focus to the following activities to continue working towards achieving the objectives of the Dual Plumbing Ordinance:
• Evaluating, refining, and updating roles and responsibilities as needed • Continue to update procedures/guidelines for City departments • Expand incentives for installing dual plumbing and update fees as needed • Participate in partnerships and support pilot projects to showcase the Dual Plumbing Ordinance
In addition to adopting the anticipated State treatment standards and requirements, additional actions the City take include continuing the development and modification of rules and regulations, including options for developers to opt out; updating existing City policies, rules, regulations, and design guidelines; and establishing a collaboration framework for addressing and implementing the City’s One Water Vision.

4.1 Dual Plumbing Construction Cost Comparison Page 4-1 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Section 4: Economic Considerations
This Section presents an economic assessment of dual-plumbing and onsite treatment installation and operations costs and potential fees and funding opportunities to offset those costs. Understanding the potential costs to dual-plumb and treat onsite water supplies will aid the City in defining the size of commercial buildings that could be required to construct dual plumbing.

4.1 Dual Plumbing Construction Cost Comparison
A model of costs to install dual plumbing, compared to conventional single plumbing systems, was developed to aid the City in communicating with developers the financial consideration of a dual plumbing ordinance. A dual plumbing cost model was developed to compare the added construction cost to dual-plumb a commercial building in comparison to using the potable water system in the same building.

The cost model reviewed 17 new commercial buildings ranging in constructed area of 8,000 square feet to 271,000 sq ft constructed in California within the last five years.

Construction costs for these buildings were adjusted for Sacramento using location indices and escalated to 2022 dollars. Table 4-1, Figure 4-1, and Figure 4-2 summarizes the findings of the dual plumbing costs model for the City of Sacramento. Based on the cost model, it was observed that the cost of adding dual plumbing varied according to building size and type as well as the number of plumbing fixtures per sq ft.

Table 4-1: Dual Plumbing Cost Model Results for the City of Sacramento

Capital Cost to Add Dual
Plumbing
Average Unit Cost $2.88/sq ft
For a 100,000 sq ft Building $288,000
For a 250,000 sq ft Building $720,000
% of Total Plumbing Cost 9.0
% of Total Construction Cost 0.34
Based on 2022 dollars

4.1 Dual Plumbing Construction Cost Comparison Page 4-2 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Figure 4-1: Cost Per Area ($/SF) to Add Dual Plumbing to Commercial Buildings

Figure 4-2: Percent Increase to Total Project Cost to Add Dual Plumbing to Commercial Buildings

0.50%

0.18%

0.39%

0.17%

0.10%

0.73%

0.34%

0.23%

0.41%

0.22%

0.31%

0.06%

0.23%

0.49% 0.52% 0.52%

0.33%

0.00%

0.10%

0.20%

0.30%

0.40%

0.50%

0.60%

0.70%

4.2 ONWS Treatment and Operations Costs Page 4-3
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx The cost model is a high-level assessment of the potential construction cost implications on new commercial developments using available data and information. Limitations on this model include:
• Building uses and types were limited to public and institutional buildings such as schools, medical facilities, and military housing. These uses and types of buildings are assumed to have similar water uses, fixtures, and density of fixtures as offices, gyms and other recreational buildings, and hotels.
• Data for industrial use buildings was not available for this model; however, estimating dual-plumbing costs based on previously constructed industrial-use buildings is difficult as the fixtures and water demands are highly variable. For example, a brewery would have significantly different fixtures and demand than a cold-storage facility or a bulk distribution warehouse.
• Plumbing and construction costs are variable and depend on many factors including but not limited to the size of the development, the use of the building, and the density of fixtures.
• Construction and cost data was available for public buildings only; data from private developers was not provided. Historically the construction costs of public buildings were expected to be lower than private developments, as the public bid process required for public projects is intended to create competition for the work. However, current supply chain issues, inflation, labor shortages and labor union agreements, and other market forces have contributed to recent increases in building and construction costs in the double-digits
5, regardless of if a project was required to use competitive bidding or not.

Therefore, the costs presented should be viewed as a snapshot in time and may not reflect future building and construction costs.
• No evaluation has been made on the impacts of the cost to install dual plumbing on future building ownership costs or leasing potential.
• This model compares construction costs only and does not estimate maintenance or operation costs, nor does it include costs related to the replacement of dual plumbing systems.

Additional details on the dual plumbing cost model, including a description of the types of building, cost assumptions, and construction assumptions, can be found in Appendix D.

4.2 ONWS Treatment and Operations Costs
The cost of treatment and operations using ONWS is highly variable depending on the source and end use (which impacts treatment level), amount of demand (which impacts storage volume), and technology (which also impacts operations and maintenance costs). These costs can include on-going energy use for treatment and distribution, chemical additions, replacement

5 “ENR Cost Indexes in San Francisco (1978-2022).” Engineering News-Record. Accessed 16 May 2022. <https://www.enr.com/economics/historical_indices/SanFrancisco>

4.2 ONWS Treatment and Operations Costs Page 4-4
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx parts or repairs, and operator time. Specific cost information for treatment and operation of ONWS was not available, but the projects implemented under the San Francisco Onsite Water Reuse Program were reviewed to understand the overall potential cost impacts to developers and building owners. Appendix E summarizes the available information reviewed for each of the projects implemented under the San Francisco Onsite Water Reuse Program.

Evaluation of ONWS treatment and operations costs included a review of 20 new commercial and industrial use buildings ranging in constructed area of 69,000 sq ft to 2,700,000 sq ft constructed under the San Francisco Onsite Water Reuse Program. Based on the data available, as shown in Figure 4-3, most projects used multiple sources, with rainwater capture systems being the most common ONWS, followed by graywater systems, and then foundation drainage. Blackwater, steam condensate, and stormwater ONWS were least common.

Treatment volumes for all projects ranged from 30,000 gallons per year to 39 million gallons per year. As shown in Figure 4-4, the most common uses of non-potable reuse water were toilet and urinal flushing, followed by irrigation, and then heating and cooling systems.

Figure 4-3: Summary of Projects Implemented Under the San Francisco Onsite Water Reuse Program by Source Water

*Based on a total of 20 projects. Some projects use multiple alternative water sources.

15 5
4 3
2 1 1 1
# of Projects by Source Water
Rainwater (15)
Graywater (5)
Blackwater (4)
Foundation drainage (3)
Steam condensate (2)
Stormwater (1)
Bay water (1)
Brewery Process Water (1)

4.2 ONWS Treatment and Operations Costs Page 4-5
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Figure 4-4: Summary of Projects Implemented Under the San Francisco Onsite Water Reuse Program by End Uses

*Based on a total of 20 projects. Some projects supply multiple end uses.

Table 4-2 summarizes the average ONWS treatment costs (construction and operations and maintenance [O&M]) based on available data through the San Francisco Onsite Water Reuse Program. The information summarized in Table 4-2 and Appendix E is based on data voluntarily provided to the San Francisco Onsite Water Reuse Program by building developers and owners and has the following limitations:
• The year of building construction or ONWS installation or startup was not always provided, therefore these costs were not normalized to 2022. Similarly, not enough information was provided to normalize O&M costs to 2022. • Treatment and storage capacities were not provided. When not specified, it was assumed that the treatment volumes provided are average values (e.g., gallons per day or gallons per year).
• Reported treatment volumes did not split out volumes per ONWS source for those systems that treated multiple alternative sources. Similarly demand volumes were provided for the development as a whole and did not provide demands for each non- potable use.
• Annual O&M costs were mostly provided as an aggregated value; costs for specific O&M items, such as energy, chemicals, and operator time, were not available for all projects.
14 12
5 2
1 3
# of Projects by End Uses
Toilet and urinal flushing (14)
Irrigation (12)
Heating and cooling systems (5)
Street sweeping (2)
Industrial uses (1)
Other (3)

4.2 ONWS Treatment and Operations Costs Page 4-6
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx • Total development construction cost was not always provided; therefore, analysis of ONWS installation impacts on the total construction cost was not conducted. • Separate costs for the construction of dual plumbing was not provided.

Based on the above data limitations, a summary of the installation and O&M costs should be used only to understand the relative scale and ranges of costs and should not be used to estimate potential costs for developments in Sacramento. Furthermore, installation and O&M costs may be impacted by related City standards, future state or other regulations, or offsets from other programs.

Based on the data available through the San Francisco Onsite Water Reuse Program, installation of ONWS made up less than 1 percent of the overall project cost. As can be seen in Table 4-2, on a per gallon per year (gal/yr) and per sq ft basis, rainwater systems are the costliest to install, followed by blackwater systems. Blackwater treatment is typically more costly to purchase and install, but the cost for rainwater is brought up due to the costs of storage, which is sized to meet demand annual. The effects of storage on the cost to install rainwater ONWS is further illustrated in a review of the three (3) projects installed with rainwater as the only reuse supply, where construction costs ranged from about $3/gal/yr to about $11/gal/yr or about $4/sq ft to about $11/sq ft. However, rainwater systems are the lowest cost to operate with a consistent range of annual costs based on the San Francisco Onsite Water Reuse Program. The addition of graywater, concentrate and stormwater can result in an order of magnitude increase in annual O&M costs.

4.2 ONWS Treatment and Operations Costs, Page 4-7
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Table 4-2: ONWS Treatment Costs (based on San Francisco Onsite Water Reuse Program Projects) Water Source
Average
Development Size
(sq ft)
Average
Treatment
Volume
(gal/yr)
Average
Construction
Cost Annual O&M Cost
($/sq ft) ($) ($/gal)
Blackwater only1

2,700,000 39,000,000 3.11 NA2 NA2
Blackwater + additional
water sources1
280,000 913,000 3.60 NA2 NA2
Graywater + additional
water sources
803,000

10,600,000 0.82 50,000 to
18,300,000

0.03 to 0.94
Condensate + additional
water sources
1,500,000 19,000,000 1.07 18,300,000 0.94
Foundation Drainage only

NA2 17,600,000 NA2 NA2 NA2
Foundation Drainage +
additional water sources1
1,500,000 15,000,000 1.67 NA2 NA2
Rainwater only

89,000 204,000 6.09 2,500 to 38,000 0.07 to 0.10
Rainwater + additional
water sources
840,000 10,600,000 1.55 50,000 to
18,300,000

0.03 to 0.94
Stormwater + additional
water sources2
1,500,000 19,000,000 0.47 18,300,000 0.94
Brewery Process Water1

NA2 3,700,000 NA2 NA2 NA2
Notes:

1. Data available through the San Francisco Onsite Water Reuse Program for one (1) project only.

2. No data available through the San Francisco Onsite Water Reuse Program

4.3 Onsite Non-Potable Water System Market Assessment Comparison Page 4-8 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx

4.3 Onsite Non-Potable Water System Market Assessment
Comparison
Understanding the market for ONWS is typically the first step towards creating a successful reuse program. An initial market assessment investigation was conducted to identify developments that are anticipated to be developed in the upcoming years and identify their location and scale that could implement ONWS. The approach includes evaluating opportunity areas in Sacramento to refine the scale where ONWS may provide the most benefit and meet economic needs. Potential to use recycled water produced by Regional San was also considered.

The following information was reviewed for commercial buildings, as the City is not anticipated to apply the ordinance to residential buildings:

• Approved commercial non-residential building developments larger than 100,000 sq ft since 2010 (via the City’s Accela Building Permit database, Building Data) • Approved entitlements that do not yet have a building permit (via the City’s Accela Building Permit database, Planning Data)
• Opportunity area mapping information that was developed for the City’s Water Master Plan
• Regional San future recycled water pipeline phasing for the City of Sacramento

4.3.1 Market Assessment Mapping
The market assessment mapping approach considered future non-potable demands for new developments that could be served by (1) onsite treatment systems and (2) municipal recycled water from Regional San. In order to understand the number of developments that may be impacted by Sacramento’s dual plumbing ordinance, based on the San Francisco Onsite Water Reuse Program case study information, this market assessment also considered developments with habitable areas over 250,000 sq ft and between 100,000 sq ft and 250,000 sq ft.

Developments with habitable areas between 50,000 sq ft and 100,000 sq ft were also considered.

To understand the scale of future commercial developments that may need to comply with the dual plumbing ordinance, a review of approved and completed commercial developments in the City of Sacramento since 2010 (Building Data) was conducted and found that in the past 12 years there were:
• 8 total new commercial developments with habitable areas between 100,000 sq ft and 250,000 sq ft. Building uses include amusement (1), industrial (5), and retail store (2). • 5 total new commercial developments with habitable areas greater than 250,000 sq ft.

Building uses include amusement (1), industrial (2), and office (2).

4.3 Onsite Non-Potable Water System Market Assessment Comparison Page 4-9 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx However, past developments alone cannot predict future growth, so a review of the planned commercial developments from the City’s Planning Data was conducted and found that there are 14 building permit applications for non-residential developments over 100,000 sq ft. Building uses include commercial/retail (6), hotel/motel (2), industrial (3), office (1), and warehouse (2).

The locations of these future developments are shown on Figure 4-5.

While the City’s dual plumbing ordinance is considering the applicability of onsite treatment, a dual-plumbed building could similarly be designed to receive municipal recycled water if there is an available source of supply. Discussions with Regional San representatives during April 2022 found that the supply of municipal recycled water is not anticipated to be significantly impacted by the reduction in flows through the use of ONWS or dual plumbing, as the resulting flow reduction is expected to be only a small amount when compared to Regional San’s average daily treatment volume of 124 million gallons per day. Despite this, current and planned contracts use up the currently available supply of municipal recycled water. If the use of municipal recycled water were to be expanded within the City of Sacramento, future additional recycled water supply would rely on the wastewater generation from future new developments within the Regional San and Sacramento Area Sewer District service areas. Therefore, while municipal recycled water supply is not readily accessible to users within the City of Sacramento today, it may be an option available in the future.

Regional San already has recycled water pipelines that extend into the City of Sacramento and the potential synergy between these two programs were evaluated as part of the market assessment mapping exercise. Figure 4-5 shows the existing portion of the Regional San recycled water pipeline within the City of Sacramento, as well as potential future expansions.

Based on Figure 4-5, a majority of the future developments are not within the proposed Regional San recycled water pipeline expansion area (shown in purple) and are therefore candidates for an ONWS.

Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c) OpenStreetMap contributors, and the GIS User Community
³
City of Sacramento
OnSite Non-Potable Water Reuse Strategy
ONWS Opportunity Areas
K/J Project Number
2270001*00
Figure 4-5
Kennedy/Jenks Consultants
C:\Users\EvelynChoudhary\OneDrive - Kennedy Jenks Consultants\Desktop\Projects\Sac-Onsite\SacOnsite_Acella_filtered.mxd Date: 6/9/2022 Printed by: EvelynChoudhary Legend
Proposed Recycled Water Pipelines
Phase 1
Phase 2
Phase 3
Phase 4
Phase 5
Proposed Recycled Water Area
City Limits
Planned Commercial Properties for Development

4.3 Onsite Non-Potable Water System Market Assessment Comparison Page 4-11 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx

4.3.2 Market Assessment for a Typical Commercial Property To estimate the potential construction cost for an ONWS with various source waters, a recent commercial development was selected from the City’s Accela Building Permit database to represent a ‘typical’ commercial property. 8340 Delta Shores Circle was selected as a recent ‘typical’ commercial development. This building was developed between 2016 and 2018, as shown in Figure 4-6, with the pre-development (2016) on the left and the post-development (2018) on the right. Google Earth, US EPA data, and other available information was used to estimate the parameters of the building based on various water sources. Building stats include the following:
• building interior area = ~173,300 square feet.
• building footprint (based on Google Earth) = ~102,400 square feet. • 2021 total metered water usage = 1.25 MG.
• Average daily water demand = 3,440 gallons.
• Average daily blackwater volume
6 = About 2,680 gallons, or 78% of the water demand
based on US EPA water demands for commercial (office) buildings.

Figure 4-6: Pre and Post Development of 8340 Delta Shores Circle

Based on the proposed site parameters the total infrastructure required for each of the types of water were identified and the cost savings were estimated. These accounted for the seasonal variation in supplies and demand throughout the year. For example, rainwater capture is varied based on available precipitation. Historical trends indicate the capture will be highest in December, January, and February, while the capture will be lowest in June, July, and August.

Figure 4-7 identifies the anticipated supplies (potential rainwater capture, estimated condensate, graywater from handwashing, and total average monthly blackwater [including graywater]) and demands (irrigation, toilet flushing, and cooling and heating). The largest potential supplies are potential rainwater capture, followed by total blackwater.

6 Water use percentages: EPA and American Water Works Association (AWWA); plumbing estimate does not include showers; 20 secondhand wash, 0.5 gallons per minute, 1.28 gallons per flush.

4.3 Onsite Non-Potable Water System Market Assessment Comparison Page 4-12 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Figure 4-7: Estimated Non-Potable Water Supplies and Demands for 8340 Delta Shores Circle

Notes:

1. Rainfall Data Source: California State Univ at Sacramento (CSU), California Data Exchange Center.

2. Condensate: 12 gal/1000 sq ft per day (Novak, Allen, et al. Designing Rainwater Harvesting Systems:

Integrating Rainwater into Building Systems); air-conditioned space is equal to building area; AC running April through September.

A comparison of treatment size and rough order of magnitude (ROM) capital costs is shown in Figure 4-8. This demonstrates that condensate is the lowest cost option in terms of capital cost, however, it also produces the smallest amount of water. The higher capital cost options such as rainwater and blackwater provide significant water volumes in comparison.

0 50
100
150
200
250
300
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
1,000 Gallons
Potential Rainwater
Capture
Estimated Condensate
Greywater
(Handwashing)
Blackwater
Irrigation

4.4 ONWS Program Administration Resources Page 4-13
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Figure 4-8: Estimated Capture and ONWS Capital Cost for 8340 Delta Shores Circle by ONWS Type

Construction costs, potable water savings, O&M costs, and ONWS Program fees are all critical to identifying return on investment, which will be completed in the next phase of developing the City’s ONWS Program.

4.4 ONWS Program Administration Resources
In addition to the cost impacts to developers and commercial building owners, the implementation of an onsite water reuse program will also require City resources to administer the program. As presented as Step 7 of Blueprint for Onsite Water Systems A Step-by-Step Guide for Developing a Local Program to Manage Onsite Water Systems in Section 2.6 of this Study, one or more agencies will need to be responsible for administering permits; reviewing data, and engineering and design reports; and shutting down non-compliant systems. Step 8 involves publicizing the program, developing resources, and providing clear direction to project sponsors and developers on how to comply with program requirements. These additional responsibilities will fall to the City and potentially to other local agencies to fulfill.

A review of the agency coordination and staffing requirements for San Francisco Onsite Water Reuse Program case study presented in Section 3.1 provides an estimate of the potential resources to implement an onsite water reuse program:
• T he San Francisco Onsite Water Reuse Program is administered by one full-time equivalent, but startup of the program involved one additional part-time equivalent.

These employees are funded through the operating budget of the SFPUC. • Support from the SF Department of Public Health, SF Department of Building Inspections, and SF Public Works to provide reviews of dual plumbing documents and $600,000
$4,000 $9,000
$405,000
0 200,000
400,000
600,000
800,000
1,000,000
1,200,000
Rainwater (building roof) Condensate Greywater Blackwater ONWS Treated Volume (gallons/year)
Treated Volume (gal/yr) ONWS Capital Cost ($)

4.5 Cost Summary and Funding Options Page 4-14
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Although the City of Sacramento is not anticipated to see as large or as many commercial developments as the City of San Francisco, the City of Sacramento will need to commit resources to the administration of an ONWS program and enforcement of the dual plumbing ordinance. If the City of Sacramento chooses to adopt a dual plumbing ordinance without an ONWS program, enforcement responsibilities can likely be folded into existing roles and responsibilities and use the existing fee-for-service structure to recover the cost of review and inspection times. Furthermore, to support administration of a dual plumbing and/or ONWS program, the City of Sacramento can adopt the use of an administration fee to be submitted by developers at the time of application, similar to the City of Santa Monica’s recycled water program.

4.5 Cost Summary and Funding Options
Sections 4.1, 4.2, and 4.3, present the estimated impacts to developers and project sponsors the implementation of a dual plumbing ordinance with ONWS requirements:
• Based on the dual plumbing cost model, adding dual plumbing to a building adds less than 1% to the total construction cost of the building. • ONWS system costs vary based on treatment capacity, filtration and disinfection technology, and property use. Review of projects implemented under the San Francisco Onsite Water Reuse Program reveal that rainwater treatment systems and blackwater treatment systems are the most expensive ONWS to install, averaging about $6/sq ft and about $3 sq ft, respectively.
• Review of four projects implemented under the San Francisco Onsite Water Reuse Program with O&M cost information found that rainwater systems can be the lowest cost to operate, ranging from $2,500/yr to $38,000/yr or $0.07/gal/yr to $0.10/gal/yr.

Combining rainwater systems with other ONWS can increase O&M costs at least one order of magnitude. This could be different for Sacramento, however, since it does not see the same amount of rainfall as San Francisco.

The City may consider options to defray the added costs of potential compliance with a dual plumbing ordinance:
• Capacity charge adjustments – while every building will still be required to install potable water connections capable of meeting all building demands, the City could choose to reduce this charge based on the expected savings due to the installation of ONWS or use of municipal recycled water. This charge reduction will need to be supported by demonstration of actual reduction in City water use. This option will require Proposition 218 authorization for implementation.
• Wastewater adjustments – the city could consider adjusting wastewater charges to the extent there is a reduction in service needs. This option will require Proposition 218 authorization for implementation.

4.5 Cost Summary and Funding Options Page 4-15
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx • Water savings rebate program – The City of Sacramento offers water conservation rebates to water customers based on the installation of water saving devices or low water use landscapes. A similar program could be implemented for commercial/industrial properties that implement OWNS.
• Permit fee waivers – the City can choose to waive building permit fees for projects that install dual plumbing and ONWS, however this strategy should be evaluated against the cost to the City to support reviews, inspections, and administration. • Federal and State grants – for publicly owned buildings, the City may support the application of a grant application for the cost of construction in compliance with the dual plumbing ordinance and ONWS program.

In addition to added costs to developers and project sponsors, the City and other agencies responsible for the implementation and enforcement of the dual plumbing ordinance and ONWS program will need to devote additional resources. For the City of San Francisco’s Onsite Water Reuse Program, one full-time employee, whose funding comes from the SFPUC operating budget, administers the program with support from other existing departments, who are funded through permit/plan review and inspection fees.

The National Blue Ribbon Commission’s “Local Ordinance Framework” presented in Section 2.7 provides recommended approaches to cost recovery and program funding based on existing programs that have been implemented in the United States. Based on the “Local Ordinance Framework” and a review of the case studies presented in Section 3, the following funding options are available:
• Initial Permit Application Fee for costs related to investigating and processing an ONWS application and issuing a permit. This amount of this fee would be based on source (e.g., rainfall capture, stormwater, graywater, blackwater). • Annual License Fee, the amount of which would be based on source. • A Plan Review/Onsite Inspection Hourly Rate would also be assessed for permit/ownership transfers, review of district-scale projects, and additional reviews, or onsite inspection.

For the San Francisco Onsite Water Reuse Program, depending on source, the initial application fee for an ONWS ranges from $2,014 to $11,783 and the annual license fee ranges from $560 to $2,186. The hourly review/inspection rate for ONWS is $249. For a Sacramento commercial building valued at $100 million, the initial application fee would be about 1% of the Building and Plan review fees.

In addition to the above fee-for-service mechanisms, San Francisco charges for excess use for potable makeup water, to be assessed at two-times the metered rate for potable water plus two- time the calculated wastewater discharge rate. This charge would be assessed when the amount of potable water used by the project is greater than the amount indicated on the water budget that was submitted with the initial building permit.

4.5 Cost Summary and Funding Options Page 4-16
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Other funding mechanisms available for the implementation of an onsite water reuse program include:
• Developer cost-sharing: during the initial year(s) of the Onsite Water Reuse Program, the City may solicit partners to implement pilot projects that will inform the growth of the Program. The City may offer incentives through capacity rate reductions for water services.
• Grants for construction costs of pilot projects: the US Bureau of Reclamation’s CALFED Water Use Efficiency Grant Program funds water use efficiency activities such as small recycled water and reuse projects. Current grant policies require that the pilot project be publicly owned. Historically solicitations for new project applications have opened annually.
• City General Funds: while the City’s Onsite Non-Potable Water Reuse Program is in development, the Program could draw on General Funds to develop program materials and conduct stakeholder outreach.

Because it is intended that a dual plumbing ordinance, if adopted, become effective concurrent with the New Building Electrification Ordinance, the City is interested in potential cost trade-offs between dual plumbing (and/or ONWS) and building electrification. A study on the net cost of fully electrifying new non-residential buildings that also install dual plumbing and ONWS was not conducted as part of this Study; however, cost effectiveness studies prepared by California Energy Codes and Standards indicate cost savings for all-electric commercial nonresidential buildings.

5.1 Case Studies to Demonstrate the Viability of Implementing Dual Plumbing Page 5-1 and ONWS when Supported by the Right Ordinance
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx Section 5: Dual Plumbing Ordinance and ONWS Program
Feasibility and Next Steps
This section summarizes the Study findings, citing relevant case studies and considerations that would influence the viability of dual-plumbing and ONWS for the City of Sacramento.

Recommendations to consider when implementing a dual plumbing ordinance and developing an ONWS program are provided, including some key next steps.

5.1 Case Studies to Demonstrate the Viability of
Implementing Dual Plumbing and ONWS when Supported
by the Right Ordinance
The three case studies introduced in Section 3.1 are summarized herein to demonstrate that dual-plumbing and ONWS can be a viable component of a water supply portfolio in urban areas when supported by an appropriate ordinance. These case study programs include elements that are similar to those that the City of Sacramento is interested in implementing, such as the criteria for applicable building types, water sources, and uses, as well as the adoption of an ordinance.

In 2012 the City and County of San Francisco adopted their Onsite Water Reuse ordinance for commercial, multi-family, and mixed-use developments. The ordinance was implemented in a phased approach, starting with optional incentives for developers to implement ONWS and after proving the program, feasibility of onsite reuse, and new technologies for onsite treatment the requirements became mandatory for new developments of a certain size. The ordinance started requiring developments 250,000 sq ft and larger to install and operate ONWS, and based on the findings from implementation, it now requires developments 100,000 sq ft and larger to install and operate an ONWS. The ordinance also considers the implementation of district scale projects which are often technically and administratively more complex but provide larger benefits in terms of water production and cost savings due to the economy of scale. For commercial buildings, the ONWS are required to supply the toilet and urinal flushing and drain trap priming demands through the collection, treatment, and use of available blackwater and condensate. In San Francisco there are 17 sites that either have an operating ONWS or are in the process of installing one, as recorded by the City’s program documentation.

The City of Santa Monica approved a dual plumbing ordinance in 2022 requiring all new developments of 7,500 square-feet or greater within the recycled water service area to use recycled water. Dual plumbing systems are only required for new commercial, industrial or muti- family residential for flushing toilets, industrial process or boiler feeds, commercial laundries or carwashes, industrial or commercial cooling towers or evaporative condensers. The benefit and outcomes of the ordinance is not known at this time.

The City and County of Honolulu introduced a One Water Ordinance in 2020 to guide the city departments and agencies to work together and in partnership with developers interested in supporting one water goals. In 2019 the Honolulu Board of Water Supply led an initiative to identify where onsite reuse could be feasible and selected a redevelopment project for detailed

5.2 Dual Plumbing Ordinance Considerations Page 5-2
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Overall, these 3 case studies provide examples of where a dual plumbing ordinance and ONWS programs have been introduced and are at varying stages of implementation. A key part of each of these programs required defining the roles and responsibilities within their existing organizations to support the development, implementation, and management of the program.

The pathway for such an ordinance or program, timeline, and considerations, are unique to the needs of each City and region and should be considered in detail when defining the criteria for an ordinance or ONWS program.

5.2 Dual Plumbing Ordinance Considerations

5.2.1 Regulatory Considerations
The existing regulations in California, the CPC Chapter 15, 16 and CCR Title 17, provide the requirements for installing dual plumbing systems that allow for use of alternate water sources (rainwater, graywater and recycled water) for non-potable applications and provide considerations for protection of the public water system and public health. Following the standards of these codes, the regulations allow for the Authority Having Jurisdiction to approve permits for dual plumbed systems that have been designed and constructed following these standards. For the City of Sacramento, the agencies involved in ordinance development would need to establish agency jurisdiction to regulate these systems and responsibilities for enforcing state requirements for non-potable water use. The City of Sacramento (and other Authorities Having Jurisdiction) will also need to review and update the standards and codes that are impacted by allowing the use of municipal recycled water or alternative water supply, such as Regional San’s Water Reclamation Permit to allow indoor uses, the City’s drinking water standard details, and potentially sewer/storm drainage standard details.

5.2.2 Technical Considerations
It is technically feasible for new commercial developments to include dual-plumbed systems to convey alternative water supplies for non-potable needs. Multiple developments in California already include dual plumbed systems to supply outdoor irrigation and indoor non-potable needs with alternate water sources collected and treated onsite or municipal recycled water.

5.2.3 Administrative Considerations
Administrative considerations related to the development of Dual-Plumbing Ordinance, include:
• Defining the roles and responsibilities for the agencies that will oversee the implementation of the ordinance;
• Updating existing City standards and regulations as needed to allow for dual-plumbing systems;

5.2 Dual Plumbing Ordinance Considerations Page 5-3
City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx • Defining the parameters and boundaries for requiring dual-plumbing systems, including options for developers to opt-out of installing dual plumbing systems if proven it is not feasible for that development (i.e., non-compatible building use or insufficient water savings). The Dual Plumbing Ordinance should also allow the City flexibility in how they enforce the requirements.

Without an available supply of municipal recycled water, the City would need to develop an ONWS program to complement a dual plumbing ordinance, which would have additional administrative requirements as discussed in Section 5.3

5.2.4 Economic Considerations
Understanding the potential costs of dual-plumbed systems will help inform the economic feasibility and financial implications of implementing a dual plumbing ordinance. The Dual- Plumbing Cost Model discussed in Section 4.1 estimated that the cost of installing dual plumbing to a building to serve toilet/urinal flushing and washing machines would add about

0.34% to the total building construction cost, or approximately $2.88/sq ft, to the total building construction cost for an average 100,000 sq ft building in Sacramento, constructed in 2022. The cost model reviewed 18 new commercial buildings ranging in constructed areas of 8,000 sq ft to 271,000 sq ft constructed in California within the last five years.

For the City of Sacramento, the possibility of supplying new developments with municipal recycled water for non-potable uses was evaluated in Section 4.3. The initial market assessment investigation looked at the potential to use municipal recycled water produced by Regional San to supply the concentrated areas where new developments are currently planned for the City. However, from Figure 4-5, planned areas for new commercial developments do not overlap significantly with areas where Regional San is planning to expand the municipal recycled water service. Based on discussions with Regional San personnel, the planned municipal recycled water production for Regional San has already been allocated, further reducing the viability of using municipal recycled water to supply dual plumbed systems in new developments in the City.

The City of Sacramento could consider incentives for developers and/or building owners to install dual plumbing systems. For example, the City and County of San Francisco offers capacity charge adjustments for new buildings installing ONWS and provides funding opportunities to incentivize developers, offering up to $1 million for offsetting 3 million gallons per year or more of water demand. This option will require Proposition 218 authorization for implementation. The City of Santa Monica waives building permit fees for projects and properties that include reuse systems, although this strategy should be evaluated in combination with the opportunities of using building permit fees to support the program inspection and/or administrative costs. A rebate program similar to the City’s existing water conservation rebate program could also be created for buildings that install dual plumbing and/or ONWS.

Additionally, the green building market continues to grow. LEED, Living Building Challenge, or other green certified buildings with lower operating costs and better indoor environmental quality are more attractive to corporate, public and individual buyers and have higher demand for leasing. Owners of green buildings reported that their return of investment (ROI) improved by

5.3 ONWS Consideration Page 5-4
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A dual plumbing ordinance should include provisions for developers to provide a water balance budget with potential offsets for potable water demands, and a cost estimate for the required dual plumbing and/or ONWS. Exceptions or incentives could be included in the ordinance for developments that do not seem to be cost effective due to a high cost of implementation or minor potential for offsetting potable demands.

5.3 ONWS Considerations

5.3.1 Regulatory Considerations
Although there are no regulations currently for ONWS, regulations for risk-based water quality standards for ONWS are expected to be finalized and adopted by December 1, 2022. Due to the timing of the regulations, it should be feasible to develop an ONWS program following the recommended risk-based water quality standards once approved by the State Water Board.

The City and County of San Francisco developed their requirements for ONWS based on the Guidebook for Developing and Implementing Regulations for Onsite Non-potable Water Systems by the Blue Ribbon Commission. The guidebook refers to the recommendations from the WRF study that establishes a risk-based approach for pathogen removal and/or inactivation targets (Sharvelle et al., 2017). The City and County of Honolulu will likely be adopting a similar regulatory framework for onsite reuse as outlined by the Blue-Ribbon Commission. The regulations for risk-based water quality standards for ONWS are expected to follow the similar recommendations from the Blue Ribbon Commission and WRF Study.

Following the guidelines from the Blue Ribbon Commission and studies for risk-based approach for ONWS, SFPUC proved there is a regulatory pathway for developing an ONWS program.

The Blueprint for On-site Water Systems developed by SFPUC, provides a potentially useful guide for other agencies to develop their own ONWS programs (see Section 2.6).

5.3.2 Technical Considerations
As summarized in Section 2.4, it is technically feasible to provide treatment systems for alternate water sources that meet the pathogen removal and/or inactivation targets defined as the water quality standards for the protection of public health, similar to the treatment systems used for both drinking water and potable reuse.

Treatment systems such as MF, UF, MBR, UV disinfection, ozone or chlorine disinfection have been used for ONWS in California and have proven the capacity of the technology to treat alternate water sources and provide clean and safe non-potable supplies for dual plumbed systems. There are accepted pathogen crediting frameworks for validation, field verification, and monitoring of treatment performance. Certified operators will be required for operation and maintenance of these systems.

5.3 ONWS Consideration Page 5-5
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5.3.3 Administrative Considerations
One of the first steps for the City of Sacramento to develop an ONWS program would be to define the roles and responsibilities for the agencies that will oversee the implementation and administration of the program, including defining the ONWS water quality criteria, monitoring, and permitting requirements and identify updates to existing permits, ordinances, and City standards that would need to be implemented in order to support an ONWS program. Typically, agencies that would need to be involved with such program include: the local building department, utilities division, public health department, sanitation district, and regulatory regional and state water boards.

The greatest challenges identified in Section 3.2 for an ONWS Program included:

1. Selecting the allowable types of alternate water sources and establishing water quality standards and monitoring and reporting requirements for alternate water sources and/or end uses,

2. Establishing a permit process for initial and ongoing operations for ONWS,

3. Publicizing the program to developers, promoting best practices, and expanding and encouraging ONWS, and

4. I ntegrating the ONWS Program into local construction requirements and building permit processes.

Potential solutions to these challenges that the City could consider include:

1. Wait for the state to establish water quality standards.

2. Establishing water quality standards based on the recommended risk-based standards by the National Blue Ribbon Commission, and updating the ONWS program to incorporate any changes required once the risk-based water quality standards are adopted by the State Water Board,

3. Establish rules and regulations for operations of ONWS based on regulations implemented by other agencies such as the SF DPH Rules and Regulations Regarding the Operation of Alternate Water Source Systems,

4. Engaging with Stakeholders early on the process of developing the program to get buy in and continue the engagement beyond the development phase to promote and expand the program. Evaluate opportunities to partner with developers in pilot projects to test the program considerations and adjust as needed for successful implementation,

5. Involving the building department in the development of the program to establish the best pathway to update local requirements, and

5.3 ONWS Consideration Page 5-6
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6. Include in the ordinance considerations to update permit processing fees to cover the costs of developing and implementing an ONWS program.

Overall, it is feasible to develop an ONWS program, but it will require collaboration, clear roles and responsibilities for the different city agencies to set the foundation for the successful implementation of the program.

Table 5-1 presents an initial list of roles and responsibilities based on the case study examples as well as the City’s existing roles and responsibilities.

Table 5-1: Initial ONWS Program Coordination Matrix
City of
Sacramento –
Department of
Utilities
Sacramento
County
Environmental
Management
Department/Other
Regulator*
City of
Sacramento –
Community
Development
Department
City of
Sacramento –
Public Works Developer
Program
Administration
Environmental
Health Construction
Right-of-Way and
Mapping
Comply with
Ordinance
Review onsite non-
potable water
supplies & demands
(coordinate with
CDD)
Administer city-wide
project tracking &
annual potable
offset achieved
Provide technical
support as needed
Manages Cross-
Connection Control
Program: Once
building permit
closed, ensure
system remains as
approved (Cross-
Connection
Inspections, Annual
CC Survey)
Coordination
w/County
EMD/other
Regulator
Issue water quality
& monitoring
requirements
Review and approve
non-potable
engineering report
Issue permit to
operate onsite
system
Review water quality
reporting
Provide technical
support as needed
Conduct Plumbing
Plan check and
issue Plumbing
Permit (Building)
Inspect and approve
system installations.

Issue certification of
occupancy
(Building)
Outreach to
developers
(Planning)
Provide technical
support as needed.

Provide first point of
contact, direct
questions to
appropriate
departments
(Current Planning)
*Include advisory
note on planning
applications for
applicable projects
Issue Encroachment
Permits as needed
for infrastructure in
the Right-of-Way
(if needed).

Provide technical
support as needed

* Sacramento County EMD provides municipal recycled water compliance assistance and has established and enforces the rules and regulations for municipal recycled water use and distribution in the County. No entity has committed to this role for the City of Sacramento Onsite Non-Potable Water Reuse Program as of May 2022.

5.4 ONWS Program Implementation Considerations Page 5-7 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx

5.3.4 Economic Feasibility
The cost of ONWS treatment can range from $0.50/sq ft to over $6/sq ft (see Table 4-2). ONWS treatment and operation costs are highly variable depending on the source and end use (which impacts treatment level), amount of demand (which impacts storage volume), and the selected technology to be used (which also impacts operations and maintenance costs). The evaluation of ONWS treatment and operations costs of 20 new commercial buildings in San Francisco, ranging in constructed area of 69,000 sq ft to 2,700,000 sq ft, reflected the variability of these treatment and operation costs as summarized in Section 4.2.

Similarly, the economic feasibility of ONWS should be evaluated for specific cases, as each commercial or industrial development will have varying non-potable water needs and opportunities for onsite supply. ONWS requirements should include provisions for developers to evaluate the cost effectiveness of ONWS. An ONWS program should include considerations for district-scale ONWS that could make a project economically feasible due to economy of scale.

Startup of the Sacramento ONWS Program could find support through private-public partnerships to implement pilot projects that will inform the growth and development of the Program. Grants through the federal and state government, such as US Bureau of Reclamation’s CALFED Water Use Efficiency Grants, may also be available to fund the construction of publicly owned ONWS. The City may also offer incentives through capacity rate reductions for water services and LEED or other green building certifications.

5.4 ONWS Program Implementation Considerations

5.4.1 Pilot Test
In order to further explore and define the ONWS Program, the City can establish a pilot program, to trace out the City’s process for reviewing permits, applications, and plans, as well as to understand better the needs of developers and building owners. There are multiple avenues to implement a pilot ONWS Program:
• City-Owned ONWS: Following the example of the San Francisco Onsite Water Reuse Program, the City can install a ONWS in a city-owned facility as a retrofit or as new construction. The City can partner with an ONWS vendor interested in showcasing their product, and the vendor would be responsible for designing the ONWS and operate the system for the duration of the pilot test. If the installation is permanent, the City would take over operation of the ONWS following the end of the pilot test. Design and construction costs for the ONWS can be paid for through state or federal grants. • Other Publicly Owned ONWS: The City can also partner with another local public entity to install and operate an ONWS in a public building. Similar to the City-Owned ONWS pilot above, this project would also partner with a vendor to design and operate the ONWS for the pilot test period. At the end of the test, the local public entity would be responsible for the operations and maintenance of the ONWS. Potential public partners include Sacramento County, Sacramento Municipal Utility District (SMUD), and California State University Sacramento. Design and construction costs for the ONWS can be paid for through state or federal grants.

5.4 ONWS Program Implementation Considerations Page 5-8 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx • Developer Partnership: The City can solicit opportunities to partner with developers to implement ONWS in their developments, offering breaks on permitting fees and/or capacity charges. The additional benefits to a developer include direct input on the development of the ONWS program as well as an opportunity to showcase the development. At this time, no state or federal funding opportunities for privately-owned ONWS have been identified to offset the costs of planning, design, construction, or operation of this ONWS.

The duration of the pilot portion of the ONWS Program can be as little as three years, during which the City can evaluate the permitting, review, and inspection process; monitor the performance of installed ONWS; conduct additional stakeholder outreach; coordinate with state and local regulators; and develop and update City policies, rules, regulations, and design guidelines. Information and experience garnered from these pilot projects can inform funding/cost-recovery options, expansion or modification of the City’s dual plumbing ordinance, or additional resources needed to achieve program goals and objectives. A pilot program would also allow the City to wait until the release of anticipated state regulations related to ONWS before finalizing the City’s requirements.

5.4.2 Program Size Considerations
Dual plumbing ordinances and ONWS programs are typically defined based on a specific development footprint, however for commercial and industrial buildings the non-potable water demands can vary considerably regardless of the footprint of the development, based on the uses intended for the building. It is recommended that the City of Sacramento considers a water balance budget as a parameter in defining the program size in addition to the development footprint.

Based on review of permitted and completed commercial developments in the City of Sacramento since 2010, the quantities of new developments based on footprint for the past 12 years include:
• 18 developments over 50,000 sq ft, the majority being hotels, offices and retail stores, • 8 developments over 100,000 sq ft, mostly for industrial purposes, • 5 developments over 250,000 sq ft, mostly industrial and office space.

Assuming that future commercial developments in the City follow a similar parameter of growth as seen for the past decade, the City could consider initiating a program for developments larger than 100,000 sq ft as long as the water budget and economic study do not deem the project not economically feasible. The City could revise the program in the future to adjust the footprint criteria based on changes in the development market or other local and state regulations.

5.4.3 ONWS Alternate Sources Considerations
The City’s ONWS could consider requiring specific alternate water sources to supply ONWS or allow for the developer to provide the combination of sources that best help meet the project non-potable demands. As an example, commercial buildings in San Francisco are required to supply the toilet and urinal flushing and drain trap priming demands using available blackwater

5.4 ONWS Program Implementation Considerations Page 5-9 City of Sacramento Dual Plumbing and Onsite Non-Potable Water Systems Study j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 3\dualplumbingstudy_draft3_29jun2022_clean.docx and condensate, which are typically the largest and most reliable alternate water sources in commercial buildings.

For industrial developments, non-potable industrial process water could provide an opportunity for onsite reuse and be a cost-effective project. Industrial developments can have large non- potable demands for cleaning of equipment or process areas, and for heating and cooling systems, and can have a significant process wastewater generation that results in considerable water bills and sewer discharge fees. This combination of factors allows for the potential of reuse of industrial effluent for ONWS. Industrial onsite reuse systems are unique to the type of process and should be evaluated on a case-by-case basis. There are examples in California of breweries, wineries, and other industrial manufacturing that use ONWS for treatment of industrial effluent for supply of non-potable demands. Brewing companies like Anchor in San Francisco, Lagunitas in Petaluma, Seismic in Santa Rosa are examples of industrial ONWS that have been driven by strong environmental values and economic cost effectiveness of these systems.

Unlike the Honolulu case study (see Section 3.1.3) that found that onsite rainwater harvesting was the most beneficial alternative water source for reuse, the City of Sacramento does not have a consistent precipitation pattern that would allow for reliable harvesting and use of rainwater to supply ONWS. With climate change, precipitation patterns are becoming more variable and unreliable. Therefore, it is recommended that the City of Sacramento ONWS program considers alternate water sources in addition to rainwater. The program should include considerations to prohibit or limit ONWS that are supplied only with rainwater as this would increase capital and operational costs driven by large storage needs and require constant backup potable supply during periods of low precipitation.

5.4.4 ONWS Program Implementation and Cost
The City’s ONWS Program can zipper into the City’s existing building permitting, review and inspections process, which also coordinates with Sacramento County. Additional time and materials can be expected for ONWS-specific reviews and inspections, and based on the San Francisco Onsite Water Reuse Program, this can require as much as one additional full-time position to coordinate between departments and Sacramento, provide ONWS-related technical support, and develop and facilitate a stakeholder outreach program. Furthermore, start-up of the San Francisco Onsite Water Reuse Program relied on an additional one and a half full-time positions, which were later tapered back as the program stabilized.

Similar to the existing building permit and review program, on-going administration of the City of Sacramento’s ONWS program can be funded through fee-for-service mechanisms to review ONWS-related engineering documents, plans, and permits. These fees include an initial application fee, annual license fee, and an hourly review/inspection rate similar to what is already charged by the City for building permitting and inspections. Development of Program stakeholder outreach materials and documents may be funded through the City’s General Funds.

5.5 Recommended Next Steps Page 5-10
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5.5 Recommended Next Steps
As stated in Section 1.1, the goal of this Study is to evaluate the potential for the adoption of a dual plumbing ordinance with consideration for the future installation of water reuse systems onsite. At this stage of the City’s efforts, there are multiple options available to the City in how the dual plumbing ordinance is adopted, enforced, and modified, including:

1. Do not adopt a dual plumbing ordinance at this time. Continue to develop the City’s One Water Vision and Onsite Water Reuse Strategy with the intent of adopting a dual plumbing ordinance in the future.

2. Adopt a local dual plumbing ordinance which allows new buildings to voluntarily install dual plumbing with or without a non-potable water source.

3. Adopt a dual plumbing ordinance requiring new buildings within the vicinity of existing and planned Sacramento Regional County Sanitation District pipelines and meeting the eligibility criteria (e.g., commercial, non-residential of 100,000 sq ft or greater) to install dual plumbing and connect to municipal recycled water when it becomes available. At this time, Regional San has no plans on expanding recycled water service within the City of Sacramento, but this may change in the future.

4. Adopt a dual plumbing ordinance requiring all new buildings meeting the eligibility criteria (e.g., commercial, non-residential of 100,000 sq ft or greater) to install dual plumbing. After the state adopts water quality standards the City can then incorporate these standards for buildings to collect, treat, and reuse water onsite.

5. Adopt a dual plumbing ordinance requiring all new buildings meeting the eligibility criteria (e.g., commercial, non-residential of 100,000 sq ft or greater) to also install ONWS. After the state adopts water quality standards for ONWS, the City can update the ordinance as needed.

A dual plumbing ordinance may be implemented in combination or separate from an ONWS program. If a dual plumbing ordinance is implemented without an ONWS program in consideration, it could lead to dual plumbing systems that are stranded. or never supplied with alternative water supplies, unless they can connect to a municipal recycled water source produced off-site. However, a dual plumbing ordinance could be the first step implemented to allow for the development of an ONWS program while new developments are designed to have dual plumbing systems to be supplied in the near future from ONWS.

To aid the City in determining the next actions needed to develop a dual plumbing ordinance (with or without an ONWS program), the recommended next steps include:

1. Identify public and private partners and work with them to develop and implement pilot ONWS projects.

2. Define the One Water Vision for the City’s Onsite Water Reuse Strategy to guide the development and implementation of an ONWS Program and identify roles and responsibilities, program needs, and next steps.

5.5 Recommended Next Steps Page 5-11
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3. Engage stakeholders in a review and comment process for the draft dual plumbing ordinance to get buy in early on and include considerations based on stakeholder recommendations.

As part of Phase 2 of the City’s Onsite Non-Potable Water Reuse Strategy, the City should:

1. Establish a small group to champion and facilitate the development of the dual plumbing ordinance. The core group should consider including representatives from the public health department, planning and building officials, and water/wastewater utilities.

2. Using existing guidelines and examples from other locations, draft the dual plumbing ordinance that defines the alternate water sources to be used, the allowable non-potable end uses, the type and scale of developments required to install dual plumbing systems, the applicable rules and regulations, fees, and incentives.

3. Track the implementation and adoption of the water quality standards for ONWS expected to be released by the State Water Board in 2022 and review the draft risk- based regulations once released.

2882 Prospect Park Drive, Suite 240
Rancho Cordova, California 95670
(916) 858-2700

Dual Plumbing and
Onsite Non-Potable
Water Systems Study
16 June 2022

Prepared for

City of Sacramento
Department of Utilities
1395 35th Avenue
Sacramento, California 95822

KJ Project No. 2270001.00

Dual Plumbing and Onsite Non-Potable Water Systems Study, i City of Sacramento - Onsite Non-Potable Water Reuse Strategy j:\2022\2270001.00_cityofsac_onws_nprstrategy\09-reports\9.09-reports\task 5 - dual plumbing study\draft 2\dualplumbingstudy_draft2_15jun2022_clean.docx Table of Contents
Glossary ........................................................................................................................................ v List of Acronyms .......................................................................................................................... vi Executive Summary ....................................................................................................................... I Regulatory Considerations .................................................................................. I Technical Considerations .................................................................................. III Testing, Inspection, and Public Notification Considerations ............................. III ONWS Program Development through One Water Vision ............................... IV Economic Considerations ................................................................................ VII Dual Plumbing Ordinance Development Options ........................................... XIII Section 1: Introduction and Background ................................................... 1-1

1.1 Study Background ............................................................................... 1-1

1.2 Project Stakeholders ........................................................................... 1-2

2.1 Dual Plumbing Systems ...................................................................... 2-1

2.2 Onsite Non-Potable Water Systems ................................................... 2-2

2.3 Regulatory Considerations .................................................................. 2-3

2.3.1 Recycled Water Regulations .................................................... 2-3

2.3.1.1 CCR – Title 17 ....................................................... 2-3

2.3.1.2 CCR – Title 22 ....................................................... 2-3

2.3.1.3 State Recycled Water Policy ................................. 2-5

2.3.1.4 Statewide General Order ....................................... 2-5

2.3.2 ONWS Regulations .................................................................. 2-5

2.3.3 California Plumbing Code ........................................................ 2-6

2.4 Technical Considerations .................................................................... 2-6

2.4.1 Recycled Water Treatment Standards ..................................... 2-6

2.4.1.1 Recycled Water Treatment for Non-Potable
Uses ....................................................................... 2-7

2.4.1.2 Additi
onal Considerations for Indoor Use of
Recycled Water ..................................................... 2-8

2.4.2 Proposed Treatment Standards for ONWS ............................. 2-9

2.4.2.1 Treatment Processes for Alternate Water
Sources ................................................................ 2-11

2.4.3 Treatment Systems for Alternate Water Sources .................. 2-12

2.4.3.1 Rainwater ............................................................. 2-12

2.4.3.2 Stormwater .......................................................... 2-13

2.4.3.3 Graywater ............................................................ 2-13

2.4.3.4 Blackwater Treatment .......................................... 2-14 Table of Contents (cont’d)
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2.4.3.5 Other Alternate Water Sources ............................ 2-14

2.5 Testing and Inspection Requirements ............................................... 2-14

2.5.1 Cross Connection Testing ...................................................... 2-14