Comment on Sustainable Management Criteria Draft Best Management Practices Jan 8, 2018 Comment Letters Agency: California Department of Water Resources Subject: Sustainable Management Criteria Best Management Practice – Draft, November 2017 Letter excerpt: ACWA members appreciate DWR’s efforts to provide guidance to GSA’s regarding implementation considerations associated with SGMA’s “sustainable management criteria”, and generally finds the draft to be a useful and helpful document. The SMC Draft BMP outlines broad areas of measurable accountability that are generally needed in basin management. ACWA believes that the Department did a good job of laying out expectations. ACWA notes, and is generally appreciative of the fact, that the SMC Draft BMP defines and clarifies Sustainable Management Criteria terms without prescribing how a GSA must go about setting these criteria. It may be useful to state more clearly in an introductory section that this BMP clarifies and explains Sustainable Management Criteria, but is not intended to inform GSAs on how to set these criteria. It would be helpful to highlight that Sustainable Management Criteria are policy decisions, not the results of water budgets or other calculations. This will help frame the many considerations for GSAs, and emphasize that there is no formula for developing Sustainable Management Criteria. ACWA does have some suggestions for improving the document… Download ACWA’s comment letter
