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<br />On page 6, the Memo defines "passive" and "active'" conservation as follows: <br /> <br />') <br /> <br />{Passive water consenJation savings are] water savings that result from the impacts of <br />plumbing codes, ordinances, and standards that improve efficiency of water use. These <br />conservation savings are called "passiven because water utilities do rwt actively fund <br />and implement programs that produce these savings~ In contrast7 water conservation <br />savings resulting from utility-sponsored water conservation programs are referred to as <br />':~activel1 saving$~ <br /> <br />The explanation of passive conservation that follows these definitions focuses solely on indoor <br />appliances and fixtures that are installed in response to local, state, and/or federal building <br />standards (e.g. the 1992 EPAct).. This conversion to water-efficient appliances and fixtures will <br />result from natural replacement of appliances in existing structures over time and initial <br />installation of appliances in new/future structures. <br /> <br />This approach overlooks other significant "passive" savings potential~ including the examples <br />below: <br /> <br />y <br /> <br />· Consistent with the SWSI definition of "passive," other municipal ordinances and <br />standards should be factored into the future savings estimates and demand forecasting. <br />Some examples include changes in municipal zoning ordinances, land use densities and <br />development standards, and urban landscaping ordinances. These are all policies and <br />regulations enacted by the municipality" not the utility district or department. In recent <br />years, municipalities allover the region have begun to understand the important role that <br />land use planning plays in water demand reduction.. As we proceed farther into the 21 st <br />Century~ more and more cities throughout our region will adopt ordinances and standards <br />for future and ex~sting urban and suburban developments that maximize Xeriscaping, <br />minimize inefficient high-water-use plants, minimize landscaping coverage area, and/or <br />minimize lot sizes. Each year, more and more examples of such policy changes occur. A <br />the state-wide level, the enactment of House Bill 03-1001 last year, which prohibits <br />future "bluegrass only" covenants, will contribute to future downward trends in per capita <br />use. Similarly, decreasing lot size for new development, a trend that is occurring <br />throughout the state and region, has a direct correlation with decreasing per capita <br />demand. See, e.g., Smart Water pp. 98-99 (analyzing four-decade residential lot size <br />trends in Las Vegas, NV). <br /> <br />· Although it fits the SWSI definition of "passive" conservation, current and future <br />technological advancements in urban irrigation controllers are not addressed in the <br />Memo's explanation of passive conservation. Failing to consider outdoor water savings <br />from technological gains leaves out another significant potential for passive water <br />savings in future years. Just in the past few years, several new irrigation controller <br />designs have surfaced on the market~ ranging from ET -based irrigation controllers to soil <br />moisture sensors, all resulting in decreased outdoor water use" SWSI demand projections <br />should assume similar advancements that improve the efficiency of urban landscape <br />irrigation will arise in the future and fit inside the definition of "passiven conservation. <br /> <br />" <br />.I <br />