Comment Letter on the Proposed Framework for Performance Standards for Water Loss May 22, 2019 Comment Letters Agency: State Water Resources Control Board Subject: Proposed Framework for Performance Standards for Water Loss Letter excerpt: Dear Mr. Gomberg: Thank you for sharing the Proposed Framework for Performance Standards for Water Loss (Framework) at the fourth public stakeholder workshop earlier this year. We appreciate the State Water Resource Control Board (SWRCB)’s commitment in collaborating with Urban Retail Water Suppliers (URWS) to develop a cost-effective performance standard. The undersigned offer the following overarching comments on the Framework: For the Volume of Water Losses, Streamline the Performance Standard Setting Approach and Clarify the Process to Modify Allowable Water Losses. The Framework proposes the development of utility specific performance standards using an economic model that will consider data from submitted water loss audits, the Electronic Annual Report, and from literature. The Framework also acknowledged the need for improved data quality and additional time to collect and analyze data. Furthermore, it was recognized at the stakeholder workshop that poor data quality would lead to inherent issues with the development of performance standards. Download comment letter
