In response to the State Water Resources Control Board’s (SWRCB) outreach to the drinking water community for a reaction to its proposed Conceptual Plan for a needs analysis of the state of drinking water in California, the California Water Association (CWA) filed a comment letter on June 6. The letter emphasized a parallel effort for troubled systems that may be in compliance with current drinking water standards, but for whom the long-term outlook for sustainability is grim.

CWA noted that a water provider’s operations may be at risk of failure even where the system is meeting water quality standards. It is critical to adopt a systematic approach to identifying and periodically monitoring the operations of these “systems of need,” which often are neglected until a problem arises, before the failure of the provider’s technical, managerial, and/or financial capabilities impairs the delivery of safe, reliable, and high-quality water to its customers. Accordingly, CWA supported the SWRCB’s work to perform the needs analysis described in the Conceptual Plan but recommended that “at-risk” water systems be listed as a standalone category for assessment rather than showing them combined with water systems presently violating water quality standards.

Additionally, CWA recommended that the elements be listed in a priority order, one that places significant – if not primary – emphasis on at-risk systems. In CWA’s view, making these structural changes to the Conceptual Plan and any associated documents or forthcoming contractual scope of work would help convey the appropriate direction to the SWRCB’s consultant in performing the needs analysis.

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