On October 17, 2023 CalWEP submitted written comments to the State Water Resources Control Board on their draft regulation to "Make Water Conservation a California Way of Life." CalWEP's recommendations are as follows:
- CalWEP recommends that the State Water Board and the California Department of Water Resources work together to secure funding for agencies to successfully comply with the proposed regulation.
- The State Water Board should recognize and promote programs offered by regional water wholesalers, energy utilities, and non-profits like CalWEP as a means for suppliers to comply with the regulations, this includes Best Management Practices listed under the CII Performance Measure and under a revised Alternative Compliance Pathway
- CII Performance Measures should apply to the top 20% of water users amongst all CII accounts rather than the top 2.5% of water users, and the requirement to target the top 20% of water users by sector should be eliminated from the Regulation. Additionally, suppliers with less than 10% CII potable water usage should be exempt from CII Performance Measures, based on a five-year average that is re-evaluated every five years.
- Extend the compliance start-date for CII BMP implementation to 2030 to allow ample time for CII classification, landscape area measurement, and targeted BMP development.
- The Board should consider an Alternative Compliance Pathway that is less onerous and more streamlined than what is currently required under the proposed regulation a