Draft Plan Aims to Implement Gov’s Conservation Framework

This week, NRDC and our environmental partners submitted comments on California’s draft plan to make water conservation a way of life in our homes and business. 

Water powers California’s economy, sustains our communities, and nourishes our environment. And the exceptional drought we’re experiencing now—the worst California has seen in more than 1,200 years—has shown us that we can no longer take our water for granted.

So as we look ahead to a hotter, drier future with continued population and economic growth, we have two choices: make wise use of this precious resource or lurch from one drought emergency to the next.

Gov. Jerry Brown declared his intention to pursue the first option when he issued an Executive Order six months ago that laid out a framework for water suppliers to make conservation efforts permanent and also ensure that Californians continue to use this precious resource efficiently.

The framework Governor Brown lays out allows water suppliers to tailor conservation programs to fit their communities. Conservation targets will reflect local climate and land use, and account for conservation achievements to date. Local agencies can choose where to focus, prioritizing the most cost-effective measures for their region which could include indoor or outdoor water use or fixing leaks.

The implementation plan released by the state on November 30 is a good start at putting the Governor’s vision for our cities into practice. But there are some areas that need additional detail to realize the potential of this bold directive. 

My colleague Ben Chou wrote about the huge missed opportunities in the agricultural water efficiency piece of the plan and what’s needed for the plan to be meaningful and impactful. On the urban side, though, there is less to complain about…and that’s partly because some of the details have yet to be worked out. 

The urban conservation framework has the potential to transform the way we manage water in California in a manner that fosters sustainability, prioritizes affordability, and supports a thriving economy. But the state’s ability to accomplish these things will ultimately depend on the ability of agencies like the State Water Resources Control Board and Department of Water Resources to implement and enforce new standards in a timely manner. The draft plan does not yet adequately address three essential elements needed for the new framework to be effective and reassure water suppliers of the clear path ahead.

What We Need to See in the Final Report

Reasonable Implementation Timeline

Now is the time for a new approach to conservation. We have already laid the groundwork with huge advances in conservation and efficiency in the past five years. Timely implementation of the new water use standards and targets will ensure we can build on our conservation successes and help put California on firm ground to address the deepening challenges of long-term water supply reliability.

I recognize that some additional data collection is warranted before final standards can be adopted and that water suppliers will then need additional time to meet those targets. But the draft plan puts forth a timeline that is not only unclear, it also includes recommendations for processes that will unnecessarily delay implementation and enforcement of water use targets.  One example is deferring the identification of size thresholds for dedicated irrigation meters until December 2018 and not providing a timeframe for requiring installation. Dedicated landscape meters will be used to measure outdoor water use for commercial, institutional, and industrial (CII) customers[1] and will need to be installed in order to track progress on a water supplier’s compliance with the new water use target. DWR has already received public input on this during the rulemaking for the update of the 2015 Model Water Efficient Landscape and a size threshold for the installation of dedicated landscape meters has been established. The state should simply use the Model Water Efficiency Landscape Ordinance as a guide and require the installation of dedicated irrigation meters on landscapes equal to or greater than 1,000 square feet by January 1, 2020 so that these landscapes can be included in the reporting starting in 2021.

Clear and Transparent Enforcement Framework

Uniform enforcement will be essential to the ultimate success of the water use standards and targets. The credibility of the new framework depends on state agencies assuming the role of identifying and promptly addressing instances of non-compliance. Effective enforcement will help to ensure that the new proposed framework is recognized by all as a fair, level playing field. DWR and the Water Board should each play specific but differing roles in the enforcement process, and the final report should clearly describe agency enforcement roles, priorities, and protocols. Further, the Water Board should develop a clear and transparent enforcement framework by agreeing upon and communicating enforcement priorities at the outset of adopting the water use standards and targets.

Details on Available Technical and Financial Assistance

The draft plan refers throughout to “technical and financial” assistance that the state—specifically the Water Board, DWR and California Public Utilities Commission – will provide to utilities in connection with implementation of the EO framework. Such assistance is critical to ensuring successful implementation of the EO provisions, yet the report is surprisingly scarce on the details of the types of technical and financial assistance that will be available to water suppliers.


Some water suppliers are pushing back on these regulations and asking for an alternative compliance path. But we can’t afford to go down that road again. In order to make this new framework a success, we all need to support the budget-based approach. This will allow the state to make the best use of its resources in order to provide adequate technical and financial assistance to help all Californians make water conservation a way of life.

Simply put, business as usual is not an option this time: our climate won’t support it.

Conservation and efficiency are a lot cheaper than the alternative. Building new dams, canals, treatment plants, and pipes would cost far more, and will still not guarantee enough water in the long run…especially as we face the reality of hotter, drier summers and less snowpack. California is already a leader in climate action and energy efficiency, and we have made huge strides to save water in the past five years.

Now is the time to make conservation a way of life—to build resilience at the local level so every community can count on reliable and affordable water for years to come.

[1] Indoor CII water use is exempt from the new water use standards so a separate water meter will be required to separate indoor and outdoor water use for non-residential customers.


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