Comments on Validated Water Loss Reporting Regulations

  • Apr 17, 2017
  • Comment Letters

Agency: California Department of Water Resources

Subject: Validated Water Loss Reporting Regulations

Letter excerpt:

 

2.) Amend Section 700.5 (B) 2 To Ensure That Annual Validated Water Audits Are The Basis For Actions Taken To Increase Water Audit Data Validity And Reduce The Volume Of Losses

ACWA recommends the following change to section 700.5 (b) 2 “Beginning in 2018, information identifying steps taken by the water supplier in the preceding year to increase the validity of data entered into the final audit, reduce the volume of apparent losses, and reduce the volume of real losses as informed by the annual validated water audit.”

3.) Extend State Funding for WL TAP Program to Provide for Qualified Validators

ACWA supports the requirement that water loss audits validation be performed by trained and qualified validators. ACWA is concerned that there will be a gap between the funded WL TAP program for 2017 reporting and full transition by 2019 to the AWWA CA-NV Water Audit Validator (WAV) certificate program. Therefore, we recommend that funding for the Water Loss Technical Assistance Program (WL TAP) be extended to cover the 2018 reporting period.

4.) Ensure that Proposed Statewide Water Loss Performance Indicators are Supported by 2017 Audit Results

ACWA supports criteria established to evaluate and accept validated water audits as proposed in the regulations, but we are concerned that inconsistent application of audit data grading scores and misunderstanding of source data which support the audits could lead to improper and indefensible statewide water loss performance indicators. We recommend that that DWR work closely with the State Water Resources Control Board, in continued collaboration with water industry experts to inform this process in 2018.

Download ACWA’s comment letter

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