Comments on Extension of Emergency Conservation Regulation May 13, 2016 Comment Letters Agency: State Water Resources Control Board Subject: “May 18, 2016 BOARD MEETING (Conservation Extended Emergency Regulation)” Letter excerpt: ACWA recommends that the staff proposal by modified to make the following four changes: 1) Provide an additional week for compliance with the self-certification requirements by amending Sec. 864.5(a)(2) and Sec. 864.5 (a)(3) to June 22, and Sec. 864.5 (e) to June 15. This allows wholesale and retail agencies some additional time to ensure that their calculations are quality-assured. This is particularly necessary where multiple levels of wholesale suppliers need to coordinate based on complex water supply relationships, as is the case in some parts of the state. 2) Allow urban water suppliers that are unable to meet the June 22 deadline to comply with the self-certification requirements beginning in July, while still complying with their existing applicable conservation standard through June 2016, as provided for in Sec. 865. This alternative could be permitted on a case-by-case basis in consultation with staff, based on a showing of good cause. 3) Amend Sec. 864.5(a)(4)(b) to calculate the conservation standard based on the first year, rather than the third year to reflect immediate emergency conditions rather than more speculative and highly conservative “worst case” conditions associated with the third year hydrology. 4) Amend Sec. 864.5(b)(2) to calculate potable water demand based on an average of three years including 2015, which is expected to better reflect likely water user demand in the face of continued drought conditions, as currently communicated by water suppliers, the State and the media. Download ACWA’s comment letter
