Water Loss Standard
- The water loss standard is derived from separate but related legislation, Senate Bill 55 (2015), which also requires urban water retail suppliers to submit annual validated water audit.
- The water standard focuses on real losses expressed in gallons per connection per day or gallons per mile (of pipe) per day depending on supplier size. The vast majority of suppliers will have a standard in gallons per connection per day.
- Supplier specific 2028 water loss targets (maximum loss) are calculated from a State Water Resource Control Board created economic model (link to the create model version below) that incorporates both water loss and economic metrics.
- The majority of the economic model’s inputs can be customized by supplier if documentation is submitted. However not all inputs are weighted equally in the model. Additional information on model inputs can be found below:
- Formal rulemaking started Dec. 24th and comments are due to the SWRCB by Feb. 11th
- If there are major changes an additional 15-day comment period will be added
- Regulation is expected to be adopted in Q2
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
- April 15 – Revised draft economic model and performance standards
- Ongoing discussions:
- CMUA Compliance Path – >30% reduction
- Changes to economic model
- Supplier option to customize economic model inputs
- Recent addition of apparent loss target (only real loss target originally)
- October 13, 2021 – Release of the Standardized Regulatory Impact Assessment (SRIA)Report -Required economic analysis of regulation implementation
- No formal comment period, CA NV AWWA to submit informal comments on November 19, 2021
- Mid December 2021– Public posting of formal rulemaking materials (including proposed water loss regulation text)
- December 24, 2021 – Start of formal rulemaking process, initial 45-day comment period (can extend up to 365 days)
- January 3rd-7th, 2022 –State Water Board to host public workshop to discuss additions and change to the proposed water loss regulation
- January 5, 2022 – ACWA/CMUA Workgroup meeting to discuss proposed water loss regulation
- Contact Chelsea Haines, ACWA, for more information
- Late January/Early February 2022 – State Water Board to host public hearing for stakeholder comments on proposed water loss regulation
- Comments can be submitted to the State Water Board via email anytime during the 45-day comment period
- April/May 2022 – Anticipated Regulation approval
- July 1, 2022 - Effective date of approved Regulation