Comments on Amending and Re-Adopting Emergency Regulations

  • Feb 3, 2017
  • Comment Letters

Agency: State Water Resources Control Board

Subject: 2/7-2/8 Board Meeting/Hearing/Workshop – Item #9 Consideration of Proposed Resolution Amending and Readopting Drought-Related Emergency Regulations for Urban Water Conservation to Implement Executive Order B-29-15, B-36- 15 and B-37-16

Letter excerpt:

ACWA has previously provided comments and continues to stand by the position conveyed in our comment letter dated January 12, 2017 that it is now time to let the Emergency Regulation expire. The demonstrations of water supply security and future drought contingency planning as represented in the so-called “stress tests” in the Emergency Regulation are now fully addressed in current water agency practices and are a part of the long term water use efficiency conservation policy of “Making Water Conservation a California Way of Life”, which is expected to become the focus of implementation in coming months and years. B-37-16 directs the State Board to replace the elements of the Emergency Regulation with permanent regulations that will require on-going reporting and water use data collection, and extend the water waste prohibitions. Since these efforts are now well underway, the Emergency Regulation is no longer necessary. Even though the proposed resolution amending and readopting drought-related emergency regulations implies that a sudden end to the winter precipitation or snowfall could threaten water supplies this summer, this is demonstrability not the case. Although it is clear that on-going groundwater recharge and sustainable management efforts will take many years in some areas, and California needs continued investment in new and integrated storage and conveyance capabilities, as described in the Governor’s California Water Action Plan, none of these policy initiatives are materially advanced by the Emergency Regulation.

Download ACWA’s comment letter

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