In response to the Drinking Water Fee Regulations proposed by the State Water Resources Control Board (SWRCB) on April 29, 2016, the California Water Association (CWA) submitted a comment letter on behalf of the 108 investor-owned water utilities regulated by the California Public Utilities Commission.
While agreeing with the need to establish fees that fully fund the Drinking Water Program (DWP), CWA urged the SWRCB to minimize the disproportionality in the fee schedule, specifically on large public water systems, and institutionalize practices from the traditional fee-for-service model. CWA also encouraged the inclusion of additional mechanisms to ensure accountability of the DWP to the water systems and their customers, including:
- Tracking and reporting DWP staff time attributed to specific water systems.
- Establishing performance standards with metrics tracking and reporting on turnaround time for processing variances/waivers and inspections and permitting of infrastructure and including language on the number of planned sanitary surveys for water systems.
- Requiring annual reporting to inform water systems and the public about the DWP’s performance and achievements.
- Setting criteria for future fee increases tied to compensation rates and benefits cost increases and losses in grants and other funding sources.
CWA will continue to monitor and weigh in on the proposed regulations as they are further developed by the SWRCB.