Comments on Proposed Extension of Emergency Conservation Regulation Jan 28, 2016 Comment Letters Agency: State Water Resources Control Board Subject: “Comments on Proposed Extended Emergency Water Conservation Regulation” Letter excerpt: The required key changes are: Remove the caps of 4% for the climate adjustment, and 8% on drought-resilient supplies, and the overall cap of 8% to fully address the current equity issues and the disincentive for further investment in drought-resilient supplies. Remove the 2013 project start-date as qualifying criteria for drought-resilient supplies as it cuts off significant pre-drought investments and does not recognize the funding and planning cycle that has positioned California to meet the challenge of this drought. Expand the definition of “drought-resilient supplies” to clearly include brackish groundwater desalination, surface and groundwater storage and conjunctive use projects, and direct non-potable recycled water supply projects. Needed refinements: Modify the climate adjustment method as more fair and effective in recognizing the variation in water demand associated with climate difference across the state. Modify the growth adjustment method so that it is easier to calculate and is more effective. Preserve the Commercial Agricultural Exemption without adding the unnecessary additional administrative burden of imposing and verifying the proposed $1000 agricultural sales threshold. Additional considerations: Add a Regional Compliance Option, develop measurable objective to assess if the Emergency Regulation should be subject to further adjustments or should be rescinded in May. Download ACWA’s comment letter Download “Real World Examples” document
