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Outdoor Water Use Regulations: Frequently Asked Questions (FAQs)

1: How may a district “bank” existing MWELO compliant irrigated landscape areas not previously submitted to DSA?

A: The same procedure applies to “bank” previously completed work if the work complied with technical requirements of either the 2009 MWELO or the 2015 MWELO. DSA accepts compliance with the 2009 MEWLO because the evapotranspiration factor was only incrementally changed from 0.70 to 0.65 in the 2015 MWELO.

If the project has been completed, please file the following:

  • Form DSA 1 for a “Landscape Only” scope of work
  • Form DSA 1-L
  • Site Landscape Area Location Plan
  • Form DSA 1-LC
  • $500 application fee

Ideally this would be done by the design professional in general responsible charge of the landscape irrigation design and documentation and/or the landscape irrigation installation oversight.

If the original design professional is not available to submit the documentation, another design professional may complete the documentation with the same level of information that is required of the original design professional.

If the documentation is in order, DSA will accept it as appropriate credit to the irrigated landscaped area to the District Landscape Account; however, the district should understand that a past project submitted as compliant with the past or recently upgraded MWELO regulations may be a likely candidate for a compliance audit, which would require submission of both the landscape design documentation package and the landscape installation Certificate of Completion documentation package.



2: What would trigger a DSA MWELO Audit?

A: DSA’s code provisions require compliance with both the design and completion documentation provisions of the MWELO. While DSA is relying on a trust-based self-certification of compliance by licensed design professionals, it also has a responsibility for accountability to the Department of Water Resources that the regulations are being followed.

DSA audits of landscape irrigation projects will be based on several criteria:

  • Randomly selected from projects with significant landscape irrigation work.
  • Observations of DSA inspectors and field engineers.
  • Citizen or district complaints of noncompliance.
  • Pattern or practice of systematic noncompliance on previous audits.


3: Do these Outdoor Water Use Regulations apply to relocatable buildings?

A: Yes, for projects involving replacement of a relocatable building, with a total of 1,600 square feet or greater, the outdoor water use regulations (Section 5.304.6) apply per scoping Section 301.4.1.



4: Will a landscape-only project be reviewed as an “over-the-counter” project (OTC)?

A: No, an over-the-counter (OTC) appointment is not necessary for landscape only projects. Submittal of the required documents and fee payment may be coordinated with the Intake Specialist.



5: If an existing relocatable building on a site is being moved to a different location on the same site, is it exempt from the landscape regulations?

A: If you are moving a DSA-certified relocatable building to a different location on the same site, or to a different site, then the Minimum Rehabilitated Landscape Area requirement (per CALGreen Section 301.4) would not be triggered. If there is landscape area in the scope of work with a square footage exceeding the thresholds outlined in the CALGreen Section 5.304.6, then the project needs to comply with the Outdoor Water Use regulations.



6: For projects that have greater than 1600 sq. ft. of conditioned space, it is required to have the form DSA 1-L filled out and the $500 fee paid before final approval of the project. Is the 8-1/2x11 hard copy of the Site Landscape Area Location Plan required before DSA approval, too?

A: Yes.



7: Is a campus exempt from the Minimum Rehabilitated Landscape Area (MRLA) requirement (per CALGreen Section 301.4.1) if there are no irrigated landscape areas on the entire campus?

A: Yes, projects on a campus that have no irrigated landscape areas or are fully compliant with either the 2009 or 2015 MWELO would not trigger the MRLA requirement, even if the district has other campuses that are not fully compliant. If there is less area on the site to rehabilitate than the MRLA requirement, then completing the site to be fully compliant is acceptable.



8: Is a shade structure exempt from the Minimum Rehabilitated Landscape Area (MRLA) requirement (per CALGreen Section 301.4.1) and the Outdoor Water Use regulations per CALGreen Section 5.304.5?

A: Shade structures are exempt from the MRLA requirement; however, if there are irrigated landscape areas in the scope of work, then the Outdoor Water Use regulations apply if it is a new irrigated landscape area of 500 square feet or a rehabilitated landscape area of 1,200 square feet.



9: When is the DSA 1-L form and plan review fee of $500 required?

A: There are two CALGreen Sections where form DSA 1-L is required:

  1. CALGreen Section 304.4.1 for the Minimum Rehabilitated Landscape Area (MRLA) requirement. This is triggered by newly constructed building(s) on an existing site, or by a building addition on an existing site when the total area of new building and/or additions exceeds 1,600 square feet of total floor area.

  2. CALGreen Section 5.304.6 for new irrigated landscape areas or rehabilitated existing irrigated landscape areas to meet the 2015 Model Water Efficient Landscape Ordinance (MWELO). Compliance is triggered for projects submitted with newly irrigated landscape areas equal to or greater than 500 square feet and/or rehabilitated landscape areas equal to or greater than of 1,200 square feet irrigated landscape areas in the scope of work, including work required by the MRLA requirement.


10: Can both new and rehabilitated landscape occur on an existing site?

A: Yes, “new landscape” is an area that never has had landscape irrigation installed, whereas “rehabilitated landscape” is an area that previously had landscape irrigation installed.



11: What Outdoor water use codes apply to charter schools on district leased property?

A: If a charter school is on a leased site owned by a public school district or community college, then the site work needs to comply with the DSA CALGreen Code for Sections 301.4 and 5.304.6, as follows: 1) If the site has no irrigated landscape or is fully compliant with either the 2009 or 2015 the Model Water Efficient Landscape Ordinance (MWELO), it would not trigger the Minimum Rehabilitated Landscape Area (MRLA) requirement of Section 301.4, even if the district has other campuses that are not fully compliant; 2) If a project on the site either triggers the MRLA requirement or has irrigated landscape in the scope of work over the thresholds in Section 5.304.6, it needs to comply with the Outdoor Water Use regulations.



12: Are landscape maintenance projects (Irrigation upgrade, reseeding/resodding of athletic fields) required to be submitted to DSA with the implementation of procedure PR 15-03?

A: “Maintenance” work does not require a DSA submittal as long as the existing irrigation systems are not being changed or upgraded. However, if the work involves improving or upgrading the irrigation system, it would be considered “rehabilitation” work. Per the CALGreen Code, Section 5.304.6, landscape irrigation rehabilitation work over 1,200 square feet in area is required to be submitted to DSA. If the area is under the threshold, then the district would have the option to submit and add the area to the District Landscape Account (see DSA PR 15-03.2), but they would not be obligated to do so.



13: If an area of rehabilitated landscape is over 1,200 square feet but is a Special Landscape Area (SLA), does the project need to be submitted to DSA for review?

A: Yes. The code requirement is based on the square footage threshold, not the type of landscape to be rehabilitated. The same requirement applies to new landscape areas over 500 square feet. While Special Landscape Areas have an increased water allowance, they must be designed and installed with an evapotranspiration adjustment factor equal to or less than 1.00.



14: Can the Minimum Rehabilitated Landscape Area (MRLA) requirement (75 percent SF of the building footprint) be reached by using a combination of rehabilitated landscape areas and removing of existing landscape areas from service?

A: Yes, the options outlined in the DSA procedure PR 15-03 can be combined. Show the location and the square footages on the Site Landscape Area Location Plan with a description of the type of rehabilitation or removal, and show the entire area of the previously irrigated landscaped area.



15: If an existing irrigated landscape area is taken out of service by new paving, hardscape or a building, what is the procedure for the remainder of irrigated landscape area?

A: To receive credit toward the District Landscape Account (DLA) or the Minimum Rehabilitated Landscape Area (MRLA) for a specific project, the area being removed must be a previously landscaped area with an irrigation system. Any portions of the remaining existing landscape irrigation system that are modified to accommodate the project must also comply with the current version of the Model Water Efficient Landscape Ordinance (MWELO), per the CALGreen Outdoor Water Use regulations.



16: How do I determine the District Landscape Account (DLA) balance?

A: The DLA spreadsheet is started after the district’s first submitted landscape project. If this spreadsheet has not been started, the balance is zero. If there is a spreadsheet, the DSA Intake Specialist at the DSA Regional Office in which the District is located can assist with finding the balance on the DSA Landscape box, which is accessible to the district and all design professionals working on the project.



17: When is Part 3 of form DSA 1-L filled out?

A: Part 3 of form DSA 1-L refers to the District Account Balance (DLA). This Part 3 is filled out when there is an excess of rehabilitated landscape area which the district wishes to record on the DLA spreadsheet.



18: If the district wants to replace natural turf which has an existing irrigation system with synthetic turf which will only require water for cooling/cleaning (using a permanent watering system composed of quick couplers and/or hose bibs), will the existing area be considered “out-of-service” and earn credits for their District Landscape Account (DLA) spreadsheet?

A: The intent of the Outdoor Water Use regulations is to save water and rehabilitate existing nonefficient irrigation systems. While the 2015 Model Water Efficient Landscape Ordinance (MWELO) does not specifically address synthetic (artificial) turf, the Department of Water Resources (DWR) considers it a nonliving area, like hardscapes. Since artificial turf needs to be cooled and washed, the water utilized by a permanent watering system or hose bibs needs to be included in the district’s water budget. The area is not necessarily “out-of-service”; however, it would be considered “rehabilitated” since it is basically more water efficient. Therefore, this area can be credited to the District Landscape Account (DLA) and/or be applied to meet current or future Minimum Required Landscape Area (MRLA) requirements.



19: When is the Minimum Rehabilitated Landscape Area (MRLA) per CALGreen Code Section 301.4.1 required for relocatable buildings when installed on a new or existing site?

A: The following table lists the various options and whether the Minimum Rehabilitated Landscape Area (MRLA) is required:

Type of Relocatable moved to another site Is the Minimum Rehabilitated Landscape Area (MRLA) Required?
New (N) Relocatable(s) to (N) site No, since a new site must be fully compliant with CALGreen Code (Title 24, Part 11), Section 5.304.6, Outdoor Water Use Regulations.
Existing (E) Relocatable(s) to (N) site
Stockpile Relocatable(s) to (N) site
(N) Relocatable(s) to (E) site Yes, if the total floor area is 1,600 square feet or greater (per CALGreen Code, Section 301.4.1, Exception 1).
Stockpile Relocatable(s) to (E) site
(E) Relocatable(s) acquired from outside of the district and installed on (E) site
(E) Relocatable(s) to (N) location on the same site No, since the relocatable(s) will be moved within the district and does not represent additional building area.
(E) Relocatable(s) to (E) site within the same district


20: Does “rehabilitated landscape area” mean that the existing landscape area is irrigated? Are there any situations where the existing landscape is not irrigated, but can be considered rehabilitated?

A: No, having a current irrigation system of some sort is the key to what “rehabilitated landscape area” means; an existing landscape area has to have an irrigation system to be considered as a landscape area that can be rehabilitated.



21: We are working on certifying existing sites within a district for compliance with the 2009 MWELO to receive DLA credits. What parts of the form DSA 1-L need to be filled out?

A: All sections of form DSA 1-L will need to be filled out except Part 2.6, 2.8 and 2.9. Additionally, Part 4 will not require a signature since the certification is for the installation.



22: If a school district utilizes reclaimed water at all their sites, are they required to file form DSA 1-L?

A: When they are submitting a project to DSA that has an irrigated landscape project in the scope of work, the school district is required to file forms DSA 1-L and DSA 1-LC per DSA procedure PR 15-03 because they still need to have an architect, landscape architect or civil engineer certify that the irrigation system is in compliance with the Model Water Efficient Landscape Ordinance (MWELO) requirements per the CALGreen Code Section 5.304.6. Even if a site is in full compliance, modifications to the existing irrigation systems still need to be submitted to DSA if they are over the various thresholds. Refer to DSA publications IR A-10 and IR A-22 for information on these thresholds.



23: For incremental projects with increment specific irrigated landscape in the scope of work, will each increment be required to submit form DSA 1-L and pay the $500 plan review fee?

A: No, since there is only one DSA application number for incremental projects, there will be only one DSA Landscape number. The initial submittal will require a one-time fee of $500 and one form DSA 1-L with a Site Landscape Area Location Plan which shows all the irrigation landscape scope for all the increments. If there is a change of scope after the initial submittal, a revised form DSA 1-L needs to be submitted and an hourly fee will be charged, as needed.



24: For a site that has less landscape area needing rehabilitation than required by the Minimum Rehabilitated Landscape Area (MRLA), will the district be required to find another site to rehabilitate the outstanding MRLA?

A: The MRLA is specific to the existing site that generates the requirement. If the existing irrigated landscape area available on the site that generated the MRLA is less that the MRLA required square footage, show on the Site Landscape Area Location Plan (attachment to the form DSA 1-L) the areas to be rehabilitated and add a note that there are no additional irrigated landscape areas on the existing site to be rehabilitated. Note, too, any irrigated landscape areas that were rehabilitated in a previous DSA application(s) or which already complied with the 2009 MWELO or the 2015 MWELO per CALGreen Section 5.304.6 (per Box 4b on form DSA 1-L).



25: Can the Minimum Rehabilitated Landscape Area (MRLA) be met when a new building is placed where relocatable buildings were removed? Can any credit for the District Account Balance (DLA) be earned if the new building is less than the previous built area?

A: No, if the new building or addition is constructed on a previously built area (i.e., permanent structure demolished or relocatable removed), the area cannot be utilized to meet the MRLA, nor can DLA credits be earned. The newly built area must be constructed on a previously irrigated landscaped area to earn DLA credits or meet the MRLA.



26: What is the time frame for submitting an existing MWELO compliant landscape area (not previously submitted to DSA for DLA credits) if it will be utilized on a current project site submitted to DSA?

A: It is preferable to have the District Account Balance (DLA) credits established on an existing MWELO compliant landscaping prior to or at the time the form DSA 1-L is submitted for the current application. However, the next option is to have the form DSA 1-L submitted at the back-check appointment.



27: Is the Minimum Rehabilitated Landscape Area (MRLA) required for buildings that are being replaced due to fire, water, or other related damage? If not, is a form DSA 1-L required?

A: If the building has approximately the same square footage as the original building (measured at the footprint), then it would be a considered a “replacement-in-kind” rather than a new building or building addition; therefore, compliance with CALGreen Code, Section 301.4.1 is not required.

Form DSA 1-L may be required to be submitted to certify compliance with the 2015 Model Water Efficient Landscape Ordinance (MWELO) requirements per CALGreen Code, Section 5.304.6 depending on whether the project’s scope of work includes irrigated landscape work that exceeds the square footage thresholds (CALGreen Code, Sections 5.304.6.1 and 5.304.6.2).



28: We are working with a school district that is planning to replace an existing 1,920 sf modular building with a new 2,800 sf modular building. Since we are only adding 880 sf of building area, and therefore below the 1,600 sf threshold, are we exempt from the Minimum Rehabilitated Landscape Area (MRLA)?

A: In this scenario, the 2,800 sf modular building is considered a “new building” and the existing 1,920 sf modular building being removed is not given any credit towards the building size that would exempt the project from the MRLA requirement per Section 301.4.1 of the CALGreen Code. Credit is given when a new building is replacing an existing irrigated landscape area as stated in DSA procedure PR 15-03.



29: When is form DSA 1-LC required?

A: If there is a form DSA 1-L filed and a DSA Landscape (L) Application number assigned, then a form DSA 1-LC is required. The signed DSA 1-LC form certifies that the irrigation system on the project site was installed in accordance with the requirements of Title 24, Part 11, Section 5.304.6.

The exception is: If the project’s scope of work did not include the installation of an irrigation system, then an email (to the intake architect) explaining the conditions of the landscape work (removal, no irrigation, farm land, or other) will suffice in place of the DSA 1-LC form. Include the project’s DSA L Application No. in the email’s subject line. This email statement will be filed in the DSA Landscape Box and the District Account Balance (DLA) for that DSA L Application number will be finalized.



30: Does the client need to pay another $500 fee to be able to use surplus credits that they already submitted in order to attain District Account Balance (DLA) credits?

A: Yes, the client needs to pay the $500 fee even if the DLA credits cover 100 percent for the Minimum Required Landscape Area (MRLA). Similar to any DSA submittal, a plan review is required to verify that the area on the plans aligns with the DSA Form 1-L.



31: Are stand-alone irrigated landscape installations per PR 15-03, Section 2.3 allowed to earn District Landscape Account (DLA) credits on new sites?

A: As indicated on line 4c of the DSA 1-L form, existing campuses are allowed to earn DLA credits for the sites for stand-alone irrigated landscape installations. New school campus are not allowed to earn DLA credits; however, an existing site used by the district for other than educational purposes can be considered a stand-alone irrigated landscape installation and earn DLA credits. The area would be filled out at Line 5a of the DSA 1-L form.



32: Is the DSA 1-L form required to be submitted for school or community college district facilities that have an Access Only requirement for review by DSA?

A: No. “Access Only” project submittals do not require a DSA 1-L form to be submitted to DSA. Compliance with the CALGreen Code outdoor water regulations is required.



33: Do you need to file and pay the fee for the DSA form L-1 if the scope of work includes reconfiguration of the ballfields on an existing irrigated sports area? There will also be new backstops and infields, walkways, bleachers, bullpens, batting cages, storage yards, scoreboards, fencing and gates, etc.

A: Landscape projects where the scope of work includes rehabilitated irrigation systems are required to meet the CALGreen Code, Section 3.504.6 which cites the MWELO. The DSA Form L-1 is utilized as a self-certification process and is still required for projects at existing schools modifying existing irrigation systems.