Joint Comments on State Water Board Electronic Annual Reporting

  • May 31, 2018
  • Comment Letters

Agency:  State Water Resources Control Board

Subject: 2017 Electronic Annual Reporting

Letter excerpt:

We believe there is great opportunity for the State Water Resources Control Board (State Board) and  water suppliers to work together to jointly improve water supply reliability, affordability, sustainability and water quality. Included in the effort, should be partnering together to collect and analyze relevant and reasonable data to inform and assist with sound water management decisions. On March 19, 2018, State Board staff held a webinar introducing new content to be added to the 2017 electronic Annual Report (2017 eAR). This new content was developed without an open and transparent stakeholder process, and requested without the appropriate advanced notice required to collect accurate information. This abrupt and one‐sided approach to data collection limits the value of the data collected and is counterproductive to stakeholder processes currently in place. Below, we have compiled comments and concerns about the vehicle used to collect information, the timing of data requests, and the process used to determine the content of data request. Comments on specific concerns about the revised eAR content are also included in our 2017 report submittals. We respectfully ask you to consider our comments and take steps necessary to improved data collection efforts so that the State Board and water suppliers can partner together effectively to achieve mutually shared objectives.

Download joint comment letter