A coalition of 63 water districts, utilities, municipalities, and related entities, including the California Water Association and three of its members, submitted a comment letter to the State Water Resources Control Board (SWRCB) on May 30, 2018. Expressing concerns about new content and data-collection requirements for the 2017 electronic Annual Report (eAR), the letter pointed out that the “new content was developed without an open and transparent stakeholder process and requested without the appropriate advanced notice required to collect accurate information.”

The letter went on to provide reasons why the “eAR is not currently the best vehicle to gather relevant and informative data about water rates, affordable drinking water, water loss from distribution systems, and climate change adaptation strategies and resiliency for water utilities.” Additionally, since the water suppliers did not know the type of data to collect until April 2018, many agencies did not have systems or staff in place to collect it, which will render inaccurate results for 2017 and the beginning of 2018. In the future, the coalition encouraged the SWRCB to communicate proposed changes in data requests well in advance to ensure availability and improve accuracy.

The coalition also recommended implementing a stakeholder process to help improve the acquisition of relevant and accurate data and to prevent potential duplication of efforts. Currently, water suppliers are addressing water loss, affordable drinking water issues, and climate change adaptation through other stakeholder processes. By partnering in advance with water suppliers, the SWRCB could develop stakeholder-driven processes that would improve the quality and quantity of data collected and economize staff time invested in collecting the data.

While the recommendations stated in the coalition letter were not able to be implemented in time for the initial early June filing of the 2017 eAR, CWA, which is a member of the SWRCB’s Division of Drinking Water Advisory Group (DDWAG), intends to continue pushing for these reforms at the DDWAG’s next meeting on September 7, 2018.

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