CalWEP's comment letter to the State Water Board regarding the second round of updates to the proposed framework regulation was submitted March 27, 2024.
CalWEP prides itself on continuing our collaborative efforts with suppliers, industry partners, and fellow non-profits, against the backdrop of climate change, to seek out and support new and innovative approaches to reduce urban water usage further.
In summary, CalWEP supports:
- The State Water Board’s initiative to simplify and streamline an alternative compliance pathway for all suppliers who will have to achieve significant savings to meet their objective.
- The inclusion of an option to target the top 20% of overall CII water users.
- Limiting BMP implementation requirements for suppliers whose overall CII water use totals 10% or less of all deliveries.
- The elimination of the originally proposed tiered CII BMP implementation approach as well as the newly proposed timeline extension for CII BMP implementation.
CalWEP suggests modifications:
- CalWEP does not support the elimination of 20% INI from the outdoor residential water budget calculation once updated landscape area measurements are provided by DWR due to technological limitations coupled with equity concerns.
- CalWEP recommends that the proposed regulation include the language “and/or statewide” following the term “regional entities” for both paragraphs (g)(3) and (h)(2) of section 974.
CalWEP is committed to partnering with the State Water Board to get this proposed regulation over the finish line. We look forward to moving into the implementation phase with our members to ensure that conservation continues to be way a life in California.
Read the full comment letter here: CalWEP March 2024 Comment Letter.