On December 22, 2017, the California Water Association (CWA) submitted a comment letter to the State Water Resources Control Board (SWRCB) on the proposed regulation of wasteful water-use practices.

CWA generally supports the proposed restrictions, considering them reasonable and necessary for continued progress in maximizing water-use efficiency; however, in its letter, CWA asked the SWRCB to provide sufficient flexibility to water providers and their communities. This would include allowing local government agencies to tailor restrictions to local circumstances and work with their public water systems on those restrictions. Local circumstances might include supply portfolios, recycled water investments, conservation rate structures, municipal separate storm sewer systems permit conditions, financial incentives and disincentives, etc.

In addition to minor revisions to the listed wasteful water-use practices requested in the comment letter, CWA included the following recommendations:

  • Modify Sec. 963(b)(1)(E)’s proposed restriction on irrigating turf and ornamental landscapes within 48 hours of measurable rainfall of at least one-tenth of an inch of rain to orient the prohibition to local community implementation.
  • Exclude the prohibition to “serve drinking water other than upon request” in eating or drinking establishments.
  • Revise and simplify the health and safety exemptions.

CWA will continue to work with the State Water Resources Control Board and its counterpart water utility associations as the rulemaking on wasteful water use prohibitions moves forward.

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