Comments on Proposed Response to Climate Change

  • Mar 3, 2017
  • Comment Letters

Agency: State Water Resources Control Board

Subject: 3/7/17 BOARD MEETING – ITEM #7 “Consideration of a proposed Resolution adopting a comprehensive response to climate change”

Letter excerpt:

Although the Resolution does not explicitly propose State Water Board ranking or prioritization of types of water supply projects based on energy intensity (sometimes referred to as a “loading order”), we caution against trying to impose such a concept as part of project permitting or funding decisions as the Resolution is implemented by the State Water Board and Regional Water Quality Control Boards (collectively, the Water Boards). Public water agencies have made and are continuing to make significant investments in a variety of water supply sources in response to local water demands, balancing many important local policy, planning and cost considerations. Creating a topdown “preferred” state prioritization, or ranking, based on energy demand or source is infeasible as multiple water supply sources must be developed simultaneously in order to ensure resiliency in the water supply system and a diverse water supply portfolio. The need to develop a comprehensive and robust portfolio of water supply projects is articulated clearly in the Governor’s California Water Action Plan and The California Water Plan, and is the basis of most water agency integrated water resources planning, including Agricultural and Urban Water Management Plans.

ACWA supports the recognition in Whereas #11 of the contribution of multi-objective water management projects, including surface and groundwater storage and recharge, as being “integral to climate mitigation and adaptation.” Successfully adapting local, regional and state-wide water systems to anticipated future climate conditions will require continued and increasing investment in new multi-objective water management projects, especially significant new surface and groundwater storage and recharge projects, as essential elements of California’s climate adaptation strategy.

Download ACWA’s comment letter

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