March 24, 2026 | Melissa Matlock, CalWEP Deputy Director
The countdown to January 1, 2027 isn’t just about turf removal.
For water suppliers, it’s about something more foundational: having an adopted, defensible regulation, ordinance, or policy in place, and being able to show it.
By January 1, 2027, suppliers are required to revise their governing documents to include AB 1572 and communicate those requirements to customers.
That means the next 6–8 months are not about broad awareness. They’re about getting specific, aligned, and adopted.
A Quick Reset: What Suppliers Are Actually Required to Do
There’s a tendency to focus on customer compliance, but a tandem compliance milestone sits with suppliers.
At a minimum, agencies must:
- Adopt a regulation, ordinance, or policy prohibiting potable water use on non-functional turf for Commercial, Industrial, and Institutional (CII) customers
- Include required definitions and statutory language
- Communicate the requirements to customers
- Submit that adopted policy as part of UWUO reporting due January 1, 2027
This is not optional groundwork, it’s the prerequisite for everything that follows.
The Risk Most Agencies Are Underestimating
AB 1572 is not just rolling out a new program, it also needs to be a legal and governance exercise.
That creates a few immediate risks:
- Adopting language that conflicts with city or county code enforcement authority
- Passing an ordinance without a clear enforcement posture (or without coordinating with legal counsel on risks of different approaches)
- Misalignment between water supplier policy and local jurisdiction implementation
- Rushing adoption late in 2026 and creating avoidable legal or political friction
CalWEP’s internal agency guidebook is explicit about this: coordination with legal counsel isn’t a step—it’s a dependency.
The Next 6–8 Months: What Actually Needs to Happen
If you strip this down to what matters, most agencies should be focused on four parallel tracks.
1. Start with Legal
Before drafting anything, agencies should be working through a few core questions:
- What is the right adoption pathway—ordinance, resolution, or policy?
- Do we intend to enforce, and if so, how?
- What authority do we actually have vs. cities/counties?
- What happens if we adopt something we don’t enforce?
These discussions determine whether your policy holds up or creates exposure later.
2. Align with Cities and Counties Early
This is where most implementation efforts will break if ignored.
AB 1572 allows multiple entities to enforce—water suppliers, cities, and counties.
If you don’t align early, you risk:
- Conflicting enforcement approaches
- Duplicate or inconsistent compliance messaging
- Code enforcement unintentionally contradicting water policy
- Customers getting different answers depending on who they call
At a minimum, agencies should be sitting down with local jurisdictions now to clarify:
- Who will enforce (if anyone)?
- What enforcement model will be used?
- How complaints or violations will be handled
- How messaging will be coordinated
3. Build the Policy Using What Already Exists
You do not need to start from scratch.
CalWEP’s guidebook already lays out:
- Required statutory language
- Definitions that should be used verbatim
- Adoption pathways
- Enforcement considerations
The recommended (and fastest) path for most agencies will be updating an existing water waste ordinance, not creating something new.
This keeps things consistent with how water waste is already defined and enforced locally.
4. Plan for UWUO Reporting Now (Not Later)
This piece is getting overlooked.
Your adopted policy needs to be submitted as part of UWUO reporting due January 1, 2027.
That creates a hard backstop:
- Drafting needs to be done well before late 2026
- Legal review needs time
- Board adoption needs to be scheduled
- Documentation needs to be clean and defensible
If you wait until fall 2026, you’re already behind.
Communication Still Matters - But Timing Matters More
Communication is critical, but it needs to follow, not lead, policy clarity.
If you communicate too early without clear policy direction, you create confusion.
If you wait too long, customers don’t have time to respond.
The right approach is:
- Spring/Summer 2026: Internal alignment + policy drafting
- Mid–Late 2026: Adoption + initial communication with CII customers
- Late 2026: Reinforcement + compliance preparation for CII customers
And when you do communicate, don’t do it in isolation.
Tie it to existing resources and messaging, including CalWEP’s blog on what Public Agencies with a January 1, 2027 compliance deadline for AB 1572 should do and CalWEP materials, so customers are hearing a consistent story statewide.
A Practical Reality Check
There are a few uncomfortable truths worth calling out:
- Not every agency will enforce—and based on AB 1572 language, that’s okay, but it needs to be explicit
- Policy adoption without enforcement still carries risk
- CII Customers may not know who to look to first and need support
- One of the hard parts of AB 1572 is governance alignment
Ignoring those realities now just pushes the problem into 2027.
Final Thought: This Is the Quiet Work That Determines Everything
By the time January 1, 2027 arrives, the visible work—stopped watering NFT on Public Properties, turf removal, program participation, customer compliance—will get the attention.
But whether any of that works depends on what happens in the next 6–8 months:
- Clear policies
- Legal alignment
- Jurisdiction coordination
- Consistent messaging
The agencies that get this right won’t be scrambling in 2027 or in the future when the next drought hits.
They’ll already be operating.
As always, CalWEP is your implementation partner and is developing resources to help. Check it out at calwep.org/nft.
Melissa oversees CalWEP's programmatic vision and priorities. Prior to joining the team, Melissa worked with Western Municipal Water District in the Water Resources/Planning Department. She has also worked as a Development Coordinator at the renewable energy non-profit, GRID Alternatives. Melissa has a Master's in Climate and Society from Columbia University and a Ph.D. in Public Health from University of California, Irvine. Melissa obtained her AWWA Water Use Efficiency Grade 3, Water Loss Audit Validator, and Distribution Grade 1 certifications, is WaterSense Qualified Water Efficient Landscaper certified, and has her Project Management Professional (PMP) certification.