The California Water Association (CWA) submitted a comment letter to the California Natural Resources Agency on March 15, 2018, on the Governor’s Office of Planning and Research’s proposed updates to regulations implementing the California Environmental Quality Act (CEQA).

CWA’s comments centered on the following proposed updates:

  • Amendment to Section 15155, Water Supply Analysis; City or County Consultation with Water Agencies, proposing to codify the holding in Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova (2007).
  • New Section 15064.3, Determining the Significance of Transportation Impacts, which implements Senate Bill 743 and represents a paradigm shift in the evaluation of projects’ transportation impacts.
  • New Section 15126.2(b), Consideration and Discussion of Significant Environmental Impacts, Energy Impacts, intended to underscore the requirement to perform an energy impacts analysis for all project phases and components, include a determination of whether a project’s energy use is “wasteful, inefficient, and unnecessary,” and identify alternatives and/or mitigation measures to reduce energy use determined to be wasteful, inefficient, and unnecessary.
  • Amendments to Section 15064.4, Determining the Significance of Impacts from Greenhouse Gas Emissions, which largely codify the case law and good CEQA practice.

CWA’s letter expressed appreciation for the necessity to update CEQA guidelines from time to time to reflect recent legislative changes to CEQA, as well as clarify and update portions of the guidelines to be consistent with recent court decisions. However, CWA also expressed hope that the final amendments would reflect the concerns outlined in the letter, emphasizing that “CWA’s members must always be aware of the administrative burdens and increased costs resulting from regulatory updates, as they must be approved by the California Public Utilities Commission and ultimately passed onto water service customers.”

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