Comments on Draft Regulation to Prohibit Wasteful Water Use Practices

  • Dec 21, 2017
  • Comment Letters

Agency:  State Water Resources Control Board

Subject: Comment Letter – Prohibiting Wasteful Water Use Practices


Although many of the proposed prohibitions make sense in principle and are already locally well-implemented and generally supported by Californians, urban water suppliers have concerns about some of the more prescriptive details of the staff proposal. We recommend that some of the proposed prohibitions be amended and others dropped, as described below and in other water agency comment letters being submitted separately.

In addition, and as explained further below, ACWA shares a more general concern with many urban water agencies 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. Instead, we support reframing the State Water Board’s action as requiring water users to eliminate inefficient water use practices and maximize the beneficial use of water through increased water conservation.

Download ACWA’s comment letter 

Suggested Resources

Comments on Amending and Re-Adopting Emergency Regulations

Submitted to the State Water Resources Control Board on Feb. 3, 2017.

Comments on Urban Water Conservation Workshop

Submitted to the State Water Resources Control Board on Jan. 12, 2017.

Comments on Long-Term Conservation Framework (Agricultural Elements)

Submitted to the State Water Resources Control Board on Dec. 19, 2016