Update provided by Amy Talbot, Chair of CA-NV AWWA Water Loss Committee
The State Water Board staff will present the SB 555/SB 606/AB 1668 Water Loss Regulation for Board approval at their October 19th Board meeting (starting at noon). Please see the agenda (page 3, item #9), item details, and draft resolution for approval for more information.
SWB staff will be posting an updated version of the regulation text soon, however, staff stated via email “there will be no substantive changes between the reg text that was posted on September 2nd and the one that will be published.” In the meantime, the September 2nd regulation text (tab 3) and the September 9th supplier targets/standards (under water loss model, standards and questionnaires heading, which also includes the economic model) can be reviewed. I will send the updated regulation text as soon as it is available. It is unclear if the supplier targets will also be updated. We do not anticipate any additional changes to the economic model.
Stakeholders are welcome to attend the October 19th Board meeting online or in person to provide comments. More information on how to provide comments here.
The 2nd formal rulemaking for the water loss regulation started on Friday, September 2nd and will run through Monday, September 19th at noon PST.
NOTE #1: Please check your supplier standards as they may have changed, especially those systems that had an initial benefit cost ratio <1 as your standard has reverted back to current loss.
Note #2: It looks like at least some of the small systems between 200 and 3,000 connections are not listed in the updated standards spreadsheet. An inquiry has been sent to State Water Board staff to figure out why they were left out.
Main changes in regulation text and model between the August 8th version and the September 2nd version include:
The water loss coalition (ACWA, CMUA, CA NV AWWA and CWA) are working on a draft comment letter based on the various meetings we’ve had over the last month or so. More information on the draft letter to come soon!
If you are interested in submitting a comment letter by the September 19th at noon PST deadline:
Letter – Proposed Water Loss Performance Standards” in the subject line to facilitate timely identification and review of the comment
For more updates about major changes and next steps, please review these slides prepared by Amy Talbot at RWA for CA-NV AWWA Water Loss Committee on January 13, 2022.
The Standardized Regulatory Impact Assessment (SRIA) Report was publicly posted on October 13, 2021. The SRIA is a required economic analysis of the costs and benefits of implementing the water loss regulation. The SRIA is developed by the State Water Board and submitted to the California Department of Finance. There is no formal comment period on the document. However, suppliers can submit informal comments to State Water Board staff. This is the first step to initiate the formal rulemaking process, which is expected to start on December 24, 2021. See timeline below for more information about the formal rulemaking process.
The updated economic model was released in April 2021. The SWRCB is encouraging water suppliers to customize the inputs and submit to SWRCB staff for approval an updated 2028 target. Formal rulemaking is expected to start in Fall 2021.
Economic model found here.
Timeline of Events