Comment Letter: ACWA Comments on Urban Water Conservation Reporting Jan 28, 2020 Comment Letters Agency: State Water Resources Control Board Subject: Proposed Urban Water Conservation Reporting Regulations Description: ACWA provided public comment on the proposed urban water conservation reporting that would require permanent monthly water production reporting by urban water suppliers. A major concern is the residential gallons per capita per day (R-GPCD) metric. Other suggestions include to sunset the Rule with SB 606/AB 1668 implementation and concerns on data integrity. Download the full comment letter.