ACWA Submits Comments on DWR’s “Water Available for Replenishment” Report

ACWA on March 10 submitted formal comments and recommendations for improving the California Department of Water Resources’ draft “Water Available for Replenishment” (WAFR) report, which analyzes water supply and demand in ten separate regions of the state and concludes that with the exception of high precipitation years, available replenishment water will be limited in many regions.

The WAFR report, required under the Sustainable Groundwater Management Act of 2014, will be used by leaders of groundwater sustainability agencies (GSAs) as they craft groundwater sustainability plans (GSPs) that are due in 2020 for critically overdrafted basins and two years later for remaining high- and medium-priority basins.

In its March 10 comment letter, ACWA requests that DWR provide more detail on various aspects of the report to ensure that GSAs can appropriately use the information.

Specifically, ACWA notes the need to more thoroughly discuss issues related to the “regulatory reallocation of surface water previously available for replenishment,” how reallocation of water during non-drought years has exacerbated drought impacts, and opportunities to make more water available.

ACWA also has requested that the report clarify a number of items affecting DWR’s “best estimate” of water available for replenishment.

Specifically, ACWA notes the need to clarify that the Central Valley Project and State Water Project were designed to serve as “in-lieu” water supply to reduce dependence on groundwater, clearly identify that the report’s findings are based on very conservative assumptions and methodology, and provide a thorough analysis of how implementation of Gov. Jerry Brown’s California Water Action Plan could increase water available for replenishment in the future.

ACWA’s comment letter is available here.