LAO Evaluates Water Use Efficiency Requirements by ACWA Staff Jan 9, 2024 Water News SACRAMENTO — The Legislative Analyst’s Office on Jan. 4 released a report to the Legislature “Assessing Early Implementation of Urban Water Use Efficiency Requirements” that evaluates the state’s current implementation of the Making Water Conservation a Way of Life framework and specifically the State Water Resource Control Board’s draft regulation. The report finds that the State Water Board’s proposed regulations go beyond what Legislation requires or the Department of Water Resources recommends. It also finds the proposed regulations will “create challenges for water suppliers in several key ways, in many cases without compelling justifications” and makes recommendations to the Legislature that it says would “ease suppliers’ administrative burden and potentially reduce costs.” Many of the report’s findings and recommendations are similar to the issues and solutions that have been raised by ACWA and member agencies to the State Water Board in a coalition comment letter and public workshop last October, as well as ongoing discussions with State Water Board staff and environmental and environmental justice organizations to identify solutions with consensus to address key concerns. The specific findings listed are: Impacts to individual water suppliers will vary significantly. Proposed regulations are overly complicated and lack clarity. Achieving the water use objective is likely to be challenging and costly. Framework could create disproportional impacts on lower-income Californians. Water savings due to the conservation framework are likely to be modest. It’s unclear how any water savings would be used. It’s unclear if the framework’s benefits will outweigh the costs. An analysis by the Public Policy Institute of California last November reached similar conclusions about the proposed regulations. In 2018, the Legislature enacted two key policy bills — SB 606 (Hertzberg) and AB 1668 (Friedman) — to implement a new framework for long-term water conservation and drought planning for water suppliers. The two bills provide new and expanded authorities and requirements that affect water conservation and drought planning for water suppliers, agricultural water suppliers, and small water suppliers and rural communities. SB 606 also requires the Legislative Analyst’s Office to assess implementation of urban water use efficiency standards and urban water supplier reporting, and submit a report by Jan. 10, 2024 to the Legislature and the public. The full report is available on the Legislative Analyst’s Office’s website. More information on the draft regulation is available in ACWA’s two-page fact sheet at acwa.com/resources.
