California Water Compliance for LA Apartments: 2027 Guide

Planet Optima is a Los Angeles utility rebate implementation partner. It replaces toilets in multifamily buildings (5+ units) at no cost to the owner through LADWP’s commercial rebate, and has installed more than 500,000 rebate toilets across Southern California in 15+ years. The regulatory summaries below are for planning, not legal advice. Check the linked source for anything that affects a decision.

The rules that already carry fines in Los Angeles (the LADWP conservation ordinance, EBEWE reporting, unreasonable water use budgets) are the tools LADWP will lean on to hit its number. This guide separates what applies to suppliers from what applies to you, lists every current requirement with its penalty, and shows the one indoor fix LADWP pays for.

What January 1, 2027 Actually Requires

Short version: the state is regulating LADWP, and LADWP is going to regulate you.

On July 3, 2024, the State Water Resources Control Board adopted Making Conservation a Way of Life, the permanent water efficiency framework that came out of AB 1668 and SB 606. It took effect January 1, 2025. It is not a drought measure. It does not turn off when it rains.

The regulation gives every urban retail water supplier an annual water use objective. That objective is built from four parts:

Here is the timeline:

That last row matters. Several vendor and law-firm pages describe January 1, 2027 as a building deadline. It is not. The regulation’s own fact sheet names urban retail water suppliers as the regulated party.

So why does it matter to a 60-unit building in Koreatown?

It matters because LADWP has to hit a number, and multifamily indoor use is a major lever it controls on the customer side. The regulation’s own list of supplier tools reads like a preview of what is coming: rate structures, leak detection, direct-install programs, rebates, enforcement of local ordinances. LADWP already runs all of these. The 2027 date gives it a reason to run them harder.

The indoor standard is the number to remember: 47 gallons per person per day. An apartment with two people, two 1.6 GPF toilets, and one slow flapper leak can burn through that before anyone showers.

Rules That Apply to Your Building Today

These are the requirements that carry penalties for Los Angeles apartment buildings right now. Every one predates the 2027 date, and every one gets more enforcement attention as it approaches.

LADWP Water Conservation Ordinance

LADWP’s Emergency Water Conservation Ordinance has been in force continuously since 2023. The city moves between phases based on supply; the phase in effect is listed on LADWP’s ordinance page, and it was Phase 2 as of September 2026. Core rules apply in every phase:

• Outdoor watering is allowed only on assigned days (odd and even street numbers get different days).
• Outdoor watering is not allowed between 9 a.m. and 4 p.m.
• Sprinkler run times are capped per station (8 minutes standard, 15 minutes for water-conserving nozzles).
• Hardscape must not be watered, and water must not run off to the street.
• Leaks must be repaired promptly.

Watering-day rules by street number are covered in LADWP’s conservation rules for apartment buildings.

Penalties for meters two inches and larger (most apartment buildings):

Fines post to the water bill. Under the ordinance, an owner may pass up to half of a conservation penalty through to tenants as a temporary surcharge. In practice that creates a tenant-relations problem to go with the fine.

Unreasonable Water Use Amendment

This is the part of the ordinance most owners have never heard of.

LADWP’s Board approved enforcement rules for the unreasonable water use amendment, which targets the city’s highest-tier users. A property flagged for unreasonable use gets an on-site water use analysis from the Water Conservation Response Unit, a property-specific water budget, and a Customer Conservation Plan listing required actions.

Miss the plan, and penalties start:

The $40,000 figure gets quoted a lot. It applies only in Phase 5. But the $1,000 to $4,000 per month range is live in Phase 2, which is the phase LADWP listed for the city in September 2026. Source: LADWP News.

A 100-unit building with 1980s fixtures is exactly the kind of high-volume account this program is built to find.

EBEWE: Annual Water Benchmarking

The Existing Buildings Energy and Water Efficiency ordinance (LAMC 91.9701, 2017) applies to privately owned buildings over 20,000 square feet in the City of Los Angeles. That covers most apartment buildings of roughly 25 units and up.

EBEWE carries two obligations:

1. Annual benchmarking: Report 12 months of whole-building energy and water data through ENERGY STAR Portfolio Manager. It is due June 1 every year.
2. Audit or retro-commissioning every five years: It is due December 1 of your cohort year, set by the last digit of the LADBS Building ID. Building IDs ending in 0 or 1 are due December 1, 2026; IDs ending in 2 or 3 are due December 1, 2027. Check your cohort at LADBS before relying on any third-party chart.

Water is scored alongside energy. Buildings that show poor water performance can face required audits and improvement plans. Fixture replacement is one of the few line items that moves the water score in a single reporting year.

AB 1572: Nonfunctional Turf Ban

Signed in October 2023, AB 1572 bans using potable water to irrigate nonfunctional turf (decorative grass nobody walks on) on a phased schedule:

Apartment properties fall in based on how the parcel is classified and where the turf sits. If your common areas have ornamental lawn, plan the conversion now. Penalties can reach $1,000 per day. This is the one rule in this guide that toilet replacement does nothing for. It is outdoor, and it needs a landscape plan.

SB 407: The Fixture Rule Most Buildings Already Passed

SB 407 (Civil Code 1101.1 to 1101.8) required all multifamily and commercial properties to replace noncompliant plumbing fixtures by January 1, 2019. “Noncompliant” means a toilet that uses more than 1.6 gallons per flush, a urinal over 1.0 gallon, or a showerhead over 2.5 gallons per minute. Sellers also disclose fixture compliance at sale.

Most LA buildings cleared this years ago by installing 1.6 GPF toilets. That is the trap. Legal is not the same as efficient, and the 1.6 GPF section below explains why.

LA’s Retrofit-on-Sale Rule and the 1.28 GPF Standard

Selling a building in Los Angeles adds a city step before escrow closes. Under Ordinance 172075 (LA Municipal Code Chapter XII, Article II), the seller must bring every toilet up to at least an ultra-low-flush model and every showerhead up to a low-flow model before the close of escrow, and a Certificate of Compliance is filed with LADWP. For apartment buildings with more than 10 units, a licensed contractor or a certified retrofitter does the inspection. LADWP can add water surcharges for continued noncompliance. Source: LADWP Water Conservation Ordinance

The sale rule is not where the 1.28 number comes from. A separate city law, Ordinance 180822 (2009), says every toilet installed in Los Angeles, in a new building or as a replacement in an existing one, must use no more than 1.28 gallons per flush. So a building with 1.6 GPF toilets can pass the sale check, but any toilet you replace before a sale, or at any other time, has to be 1.28 GPF or less. Planet Optima installs 0.9 GPF models, which clear both rules. Source: LA Ordinance 180822

Compliance Calendar for LA Apartment Owners

Two things stand out in that table. Only two rows carry a hard date for owners through the end of 2027, and both are EBEWE. Everything else is either already live or lands on LADWP first. The cost rows, though, hit every account on a fixed schedule with no appeal. The sewer rate guide walks through those numbers building size by building size.

Why 1.6 GPF Toilets Pass the Law and Still Cost You

Here is the gap between compliance and efficiency, in one row of numbers.

A 1.6 GPF toilet uses about 78 percent more water per flush than the 0.9 GPF WaterSense fixtures Planet Optima installs through the LADWP program. And that is the rated number on a new unit. Measured data from Planet Optima projects shows real 1.6 GPF toilets in 20- to 40-year-old buildings use more than their rating after years of worn flappers, mineral buildup, and slow leaks that never show up as a puddle.

Three projects have a full year of billing on each side of the replacement:

Source: Planet Optima 2024 case study data, LADWP billing before and after. The average is roughly 10,000 gallons saved per toilet per year.

That is the connection to every rule above. A third less water has three effects:

• The building has a third less exposure to a high-tier flag under the unreasonable use program.
• The water score improves in the next EBEWE benchmarking report (due each June 1), without waiting five years.
• A third less volume is billed at a sewer rate that is on its way to $11.96 per HCF.

The regulation gives LADWP a target. Your fixtures decide how much of LADWP’s problem is your building.

The LADWP-Funded Fix

LADWP’s commercial rebate is $300 per toilet for multifamily buildings with five or more units. LADWP’s program requires replacing a toilet rated 1.6 GPF or higher with one rated 1.1 GPF or less. Planet Optima installs 0.9 GPF WaterSense fixtures, which use less water than the program requires. LADWP funding covers the fixture, licensed installation, and haul-away of the old unit. The owner pays nothing. Planet Optima handles the program end to end: eligibility check, pre-inspection, LADWP paperwork, scheduling, installation, post-inspection, and rebate processing.

Here is what it looks like on a 100-unit building:

The savings estimate uses about 10 HCF saved per toilet per year (below the measured average) and roughly 1.25 toilets per unit, at July to December 2026 rates: $10.885 per HCF for Schedule B Tier 1 water and $10.13 per HCF for sewer, billed on 93% of water use. That works out to 1,250 HCF × ($10.885 + 0.93 × $10.13), or about $25,400 a year, the same inputs the sewer rates guide uses. The method comes from the Planet Optima data registry, validated in April 2026 against 2020 to 2024 case study billing data. Your building’s number depends on fixture count, occupancy, and current fixture condition, which is why the assessment comes first. The full process, fixture specs, and FAQ are in the complete guide to LADWP’s toilet replacement program.

One honest limit: this fixes the indoor side. If your exposure is a decorative lawn under AB 1572 or a sprinkler schedule that ignores the ordinance, you need a landscape contractor, not a plumber. Most LA apartment buildings have both problems. The indoor one is the only one somebody else pays for.

What to Do This Month

1. Confirm your EBEWE status: Look up your Building ID cohort and put June 1 on the calendar if you are over 20,000 square feet.
2. Walk the property for outdoor violations: Check watering days, run times, runoff, and turf. These are the fines that arrive first.
3. Count the toilets: If they are 1.6 GPF or older and the building has five or more units, LADWP will pay to replace them.

Sewer rates step up again in July 2027. LADWP’s compliance clock starts January 1, 2027. The fixture program is funded as of September 2026.