Comments on Proposed Emergency Conservation Framework Jan 6, 2016 Comment Letters Agency: State Water Resources Control Board Subject: “Comments on Proposed Regulatory Framework” Letter excerpt: ACWA believes that the State Water Board should not adopt an Extended Regulation without addressing three fundamental concerns raised by the staff Proposed Framework. First, ACWA strongly opposes the total cap of 4 percentage points for all credits and adjustments as proposed by staff. We also oppose the individual caps of 4 percentage points for climate adjustment and drought resilient sources of supply. These caps severely undermine the purpose of these needed adjustments. Second, the credit for drought resilient sources of supply must be modified to remove the “coastal” restrictions and explicitly include a much broader range of drought resilient supplies, such as the desalination of brackish groundwater, groundwater banks and conjunctive use projects, surface storage, and non-potable recycled water supplies which contribute to local water supply reliability, even if developed prior to 2013. Third, the State Water Board should incorporate within the Extended Regulation a provision to re-evaluate and reduce or suspend the mandatory conservation standards based on precipitation, snowpack and reservoir storage in April 2016. If above-normal rainfall alleviates drought conditions as expected, the Emergency Conservation Regulation needs to include a “reopener” mechanism to adjust accordingly, thereby preserving public support for the regulation. These fundamental concerns and suggestions for refinements, are explained below. Download ACWA’s comment letter
