Water Community Submits Comments on Draft Long-Term Conservation Framework

ACWA today submitted comments signed by 114 urban water suppliers regarding a draft framework aimed at redefining water conservation for both the urban and agricultural sectors.

The letter reflects input from hundreds of urban water agencies and builds on a previously submitted Oct. 18 letter with detailed recommendations for the framework, which was released Nov. 30 by the California Department of Water Resources, the State Water Resources Control Board, the Public Utilities Commission, California Department of Food and Agriculture and the California Energy Commission.

In the joint comment letter prepared by ACWA, the water community states its commitment to long-term water-use efficiency. It voices concern, however, with giving state agencies broad authority to determine future water-use budgets or performance measures without stakeholder input.

“We believe all new water-use target setting efforts must include a formal stakeholder involvement process, allowing for input on technical considerations and the potential for unintended consequences,” the letter states.

“The conservation framework must take into account the One Water policy perspective, seeking a balanced and integrated approach to sustainable water management. Water sustainability and drought resilience must be measured in terms of BOTH water-use efficiency and the development of new supplies and storage.”

Specific recommendations from the water community include creating an alternative target-setting approach that can be customized to unique local conditions, removing recycled water for indoor or CII uses from water production / use calculations for determining compliance with 2025 targets, and adding a provision for local variances to accommodate unique uses, such as providing water for large animals, swamp coolers and food production, and adding language clearly stating the state’s intent to preserve existing water rights.

The comment letter is available on ACWA’s website here. ACWA also submitted a separate comment letter to convey the association’s input on the agricultural supplier elements of the draft framework document.


The draft framework report, “Making Conservation a California Way of Life” November 2016 Public Review Draft, outlines a process for developing new permanent urban water use targets beyond the current “20x2020” requirements and includes new requirements for water shortage contingency plans and enhanced leak detection and repair.

On the agricultural side, water districts serving 10,000 acres or more will be required to prepare updated Agricultural Water Management Plans that quantify water use efficiency and include plans for water supply shortages.

Some of the actions described in the draft plan will require legislation to provide new or expanded state authority. Others can be implemented under existing authorities. The recommendations are intended to achieve the main objectives of Gov. Jerry Brown’s Executive Order B-37-16, which was issued May 9.

State agencies are scheduled to release a final framework document by Jan. 20.