Comments on Urban Water Conservation Workshop Apr 14, 2016 Comment Letters Agency: State Water Resources Control Board Subject: Comment Letter – Urban Water Conservation Workshop Letter excerpt: ACWA does support a state call for voluntary water use reductions, and statewide continuation of the “End User Requirement in the Promotion of Water Conservation” in Section 864 through October, as a response to the possibility of a dry winter 2016-2017 and potential re-emergence of the drought crisis. If the State Water Board makes a determination that some form of mandated emergency water use restriction for individual water suppliers must be retained until this Emergency Regulation expires in October, we recommend that the regulation be restructured to implement the water supply reliability assessment self-certification alternative that is currently being proposed by several water agencies. However, if the State Water Board decides not to implement the water supply reliability assessment alternative method and yet continues to impose water supplier conservation mandates, the current Emergency Regulation needs to be significantly revised to add the credits and adjustments ACWA has previously advocated, including: Removing climate adjustment caps, and caps on drought-resilient supplies to fully address the remaining unresolved equity issues and continued disincentives for further investment in drought-resilient supplies. Removing the 2013 project start-date as qualifying criteria for drought-resilient supplies as it cuts off significant pre-drought investments and does not recognize the funding and planning cycle that has positioned California to meet the challenge of this drought. Expanding the definition of “drought-resilient supplies” to clearly include brackish groundwater desalination, surface and groundwater storage and conjunctive use projects, and direct non-potable recycled water supply projects. Download ACWA’s comment letter
