ACWA Call to Action Packs State Water Board Workshop by Pamela Tobin Oct 20, 2023 Voices on Water ACWA member agencies have a proven track record of advancing water use efficiency in California. However, a regulatory approach proposed by the State Water Resources Control Board would require many urban water suppliers to reduce a significant amount of their water use on an unrealistic timeline. That was the primary sentiment ACWA staff and dozens of members conveyed at a State Water Board workshop on Oct. 4 in which the draft regulation for Making Conservation a California Way of Life was discussed. I was so proud to join more than 85 speakers from local water agencies, other associations and various interests up and down the state who provided valuable input, both in person and virtually, well into the late hours of the night as part of the workshop. Thank you to all who devoted their time in making a solid case to State Water Board members to reconsider the draft regulation’s approach. I would like to especially thank ACWA Regulatory Relations Manager Chelsea Haines and the members of ACWA’s multiple work groups on this topic whose heavy lifting and hard work pulled together a robust coalition to address flaws within the draft regulation. Chelsea herself spoke confidently and succinctly, identifying options to address the concerns of State Water Board members while providing the state with the opportunity to solve the regulation’s problems by working collaboratively with the regulated, local water management community. The State Water Board said in the past they wanted to hear directly from impacted water agencies, and they sure did. Across all ACWA departments, our staff’s coordination and outreach was directly responsible for the large number of speakers who attended the workshop. That’s pretty hard to ignore. As for the draft regulation itself, it is expected to be adopted in summer 2024 and go into effect a few months later. Compliance for urban retail water suppliers, including requirements to meet volumetric water budgets and implement extensive, prescribed actions for the commercial, industrial and institutional sector, would begin in 2025 – only a few months after the effective date of the new law. As currently drafted, many water suppliers would be out of compliance right after the new requirements take effect. Overall, the regulation as proposed would place a heavy cost burden on water suppliers and their customers. Moreover, its impractical deadlines for compliance make it virtually impossible for water agencies to inform their customers of the new requirements and elicit their support to effect change on the ground – an essential element of any effective water conservation program. Water suppliers need time to budget, staff, evaluate, design and implement cost-effective programs for their customers. This simply isn’t feasible with a 2025 timeline. It’s unrealistic to expect a dramatic change in public behavior without giving water suppliers the necessary time to build understanding and confidence in the underlying value of the changes themselves as well the care given to achieve meaningful results in a cost-effective, well-planned manner. I cannot stress enough the fact that ACWA members are committed to achieving greater water use efficiency in their service areas. However, the state must ensure that any standards aimed at achieving this goal be feasible and attainable. This is why ACWA worked closely with the California Department of Water Resources over the course of its three-year development of recommendations to the State Water Board to inform the draft regulation. DWR’s recommendations were based on studies and data and included a robust public process with diverse stakeholder participation. The State Water Board, however, deviated from DWR’s recommendations, as well as the authorizing legislation from 2018. They also failed to account for the practical realities of operating a public water system in California, something the membership of ACWA knows inside and out. To be clear, the local water management community stands ready to partner with the State Water Board on this important effort to set the stage for real progress toward a more water efficient future. We ask that you embrace this opportunity to collaborate with our members as the draft regulation is revised. Together, we can chart a feasible, cost-effective path forward in furtherance of our mutual commitment to Making Conservation a California Way of Life.
