The California Water Association (CWA) is pleased the final recycled water decision reflects many of CWA’s concerns and issues. Among the revisions made in the final decision that responded favorably to CWA’s comments were:

  • The California Public Utilities Commission (CPUC) will continue to use the more streamlined “Tier 2” advice letter process for recycled water project proposals that have no impact on a utility’s revenue requirement.
  • Estimates for greenhouse gas reductions in a recycled water project proposal are optional and subject to the availability of data and tools.
  • A recycled water project’s cost-benefit analysis can go beyond the immediate impacts within a specific service area, and it can consider regional and statewide benefits.
  • Language was added narrowing the provision of information regarding rates and rate design only to new projects, while language requiring an “explanation and justification” for a proposed rate design was eliminated.
  • Regarding project cost-effectiveness, a comparison against securing the “next least cost alternative source of potable water supply” was modified to a more appropriate phrasing of “next available alternative source of potable water supply.”

Additionally, as Commissioner Florio noted from the dais when he presented his decision to the full CPUC on August 29, CWA is concerned that the final decision’s comprehensive list of minimum criteria requirements for a proposed project may be an inhibiting factor for promoting new projects because the participating public partner may perceive them as unduly burdensome and be dissuaded from moving forward as a result. CWA member companies will work with Commissioner Florio and the rest of the CPUC staff to ensure that public agency partners in recycled water projects are not dissuaded from participating under the CPUC’s new policy.


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