Comments on Long-Term Conservation Framework (Urban Advisory Group)

  • Dec 19, 2016
  • Comment Letters

Agency: State Water Resources Control Board

Subject: Comments on “Making Conservation a California Way of Life” November 2016 Public Review Draft

Other signatories: 114 ACWA member agencies also designated as members of the state’s Urban Advisory Group

Letter excerpt:

While we are largely supportive of the initial recommendations in the Draft Report, we cannot support any policy that allows the State Agencies carte blanche in determining future water-use budgets, prohibitions or performance measures. We believe all new water-use target setting efforts must include a formal stakeholder involvement process, allowing for input on technical considerations and the potential for unintended consequences.

The conservation framework must take into account the One Water policy perspective, seeking a balanced and integrated approach to sustainable water management. Water sustainability and drought resilience must be measured in terms of BOTH water-use efficiency and the development of new supplies and storage.

To that end, we are concerned that the uncertainty associated with unknown future conservation regulations will serve as a significant disincentive for the development of new sustainable supply sources and storage by local agencies, and we strongly believe that this would be an unwise direction for California to take. As such, several of our comments are aimed at improving incentives for new supply development while maintaining water-use efficiency principles.

Download ACWA’s comment letter

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