Joint Comments on Water Audits / Water Loss Control Reporting Regulations

  • Jul 3, 2017
  • Comment Letters

Agency: California Department of Water Resources

Subject: Comments on June 16, 2017 – Second Revised Draft of “Water Audits and Water Loss Control Reporting Regulations”

Letter excerpt:

We consider the second revised draft regulations to be a satisfactory vehicle for audit validation purposes, and they should serve both the industry’s and the regulatory agencies’ needs until the next step in the regulatory process when the water use efficiency regulations and associated water use targets are promulgated, following the 2017 legislative session. Accordingly, the undersigned urge that the second revised draft regulations be adopted now so that affected water agencies and utilities will have sufficient time to prepare and submit the required water audits by the October 1, 2017 deadline.

Application to Potable Water Systems

Although we support efficient use of all water, including recycled water, it is important to note that the AWWA water audit was designed for use on potable water distribution systems, and must be conducted on an individual, discrete system. To the extent recycled water systems are separated hydraulically and operationally from potable systems, it is inappropriate to combine recycled and potable water into a single audit. The M36 manual addresses the water balance in the context of potable water and contains only three mentions of recycled water (p. 160, 356, 382), and all of them are in the context of distinguishing recycled water from potable water for the purpose of excluding recycled water from the potable water balance.

Download joint comment letter

Suggested Resources

Coalition Statement on 21st Century Approach to Water Management for the Bay-Delta

Submitted to the State Water Resources Control Board on Nov. 13, 2017.

Comments on California Water Plan Update 2018

Submitted to the California Department of Water Resources on Oct. 13, 2017.

Coalition Comments on State Wetland Definition and Procedures for Discharges

Submitted to the State Water Resources Control Board on Sept. 18, 2017.