Comments on Changes to Proposed Regulation Prohibiting Wasteful Water Use Practices Feb 14, 2018 Comment Letters Agency: State Water Resources Control Board Subject: Comment Letter – Changes Changes to Proposed Regulation Prohibiting Wasteful Water Use Practices Letter excerpt: ACWA appreciates many of the proposed changes to refine and better target the proposed prohibitions. However, we continue to have several concerns about some of the proposed prohibitions, which were identified in our previous letter and to which the proposed changes are not fully responsive. Additionally, ACWA continues to share a fundamental concern with urban water agencies and water rights holders statewide about the State Water Board’s intention to use its general authority to prevent “waste and unreasonable use” as a means to categorically prohibit certain water use practices without consideration of specific water use circumstances as required by law. ACWA has joined a coalition letter dated February 14, 2018, prepared by water rights attorneys and submitted separately on behalf of a significant number of water agencies, which conveys the basis of this concern and advocates a more defensible legal framework for the proposed conservation regulation. Download ACWA’s comment letter
