Audit, Compliance and Risk Blog

Environmental Compliance: Are You Using Water Efficiently?

Posted by Jon Elliott on Wed, Mar 11, 2015 day-to-day environmental regulations tend to focus on water quality, water quantity is also an issue … and can be a critical one. Here in California, we’re experiencing the third year of a drought of historic proportions; our Sierra Nevada snowpack is at 18% of average as winter ends. As the drought continues, state and local agencies are taking stronger and stronger measures to limit water use. The State Water Resources Control Board SWRCB) has just proposed to expand emergency regulations adopted in July 2014.

If you’re in California, you should already be following the 2014 requirements and preparing for the additions. Even if you’re not in California, you should consider voluntary implementation of at least some of these provisions. They will save your organization money on its water bills, and help “green” your activities.

What Restrictions Apply Directly To End Users?

SWRCB regulations include restrictions directly applicable to end users, and the pending proposal will expand those restrictions to include all of the following:

  • Application of potable water to outdoor landscapes, producing water flow “onto adjacent property, non-irrigated areas, private and public walkways, roadways, parking lots, or structures.”

  • Use of a hose dispensing potable water to wash a motor vehicle, except where the hose is fitted with a shut-off nozzle or device that causes it to cease dispensing water immediately when not in use.

  • Application of potable water to driveways and sidewalks.

  • Use of potable water in a fountain or other decorative water feature, except in a recirculating system.

  • Application of potable water to outdoor landscapes during and up to 48 hours after measurable rainfall (new requirement).

These restrictions can apply in industrial, commercial, and residential locations. In addition, the latest proposal adds the following requirements for hotels and eating and drinking establishments:

  • Serving drinking water other than upon request.

  • Hotels and motels must allow guests to choose not to have towels and linens laundered daily. The hotel or motel must prominently display notice of this option in each bathroom using clear and easily understood language.

Self-Evaluation Checklist

Organizations begin to evaluate the efficiency of their water usage by considering the provisions in SWRCB’s existing and proposed regulations, whether or not the organization is active in California.

Does the organization water or irrigate its grounds?

  • Are driveways and sidewalks cleaned by flushing them with water (e.g., from hoses)?

  • Is watering managed to minimize runoff to storm drains or offsite?

  • Are hoses or other equipment used for watering equipped with shut-off nozzles to prevent water flow when not actively in use?

Does the organization have ornamental fountains or ponds?

  • If so, does water recirculate?

Do operating procedures defer outside watering after rainfall events?

  • If so, what factors determine how long watering is deferred?

Does the organization dispense food or beverages (in a restaurant or bar, company commissary or lunchrooms, etc.)?

  • If patrons/employees are provided drinking water, is it provided automatically or only on request?

Does the organization provide services to overnight guests (e.g., hotel or motel)?

  • If so, are linens and/or towels provided, and if so can residents defer receiving clean linens/towels for more than one day?

Where Can I Go For More Information?

Specialty Technical Publishers (STP) provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements. These include:

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About the Author Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 25 years. He was involved in developing 12 existing products, including Environmental Compliance: A Simplified National Guide and The Complete Guide to Environmental Law.

Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).

Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).

You may contact Mr. Elliott directly at:

photo credit: 20130821-OC-RBN-2786 via photopin (license)

Tags: Corporate Governance, California Legislation, Environmental risks, Environmental, EHS, EPA