NRDC submitted comments this week on California’s draft plan for implementing Governor Brown’s executive order to make “water conservation a California way of life.” The plan aims to push our cities and farms to more efficiently use our state’s precious and limited water resources. We joined a coalition with 10 other NGO partners to submit comments on the agricultural components of the plan. You can read more about our recommendations for the urban water conservation framework in this blog post by my colleague Tracy Quinn.
When the plan was released several weeks ago, I noted that the plan’s approach for increasing agricultural water savings misses critical opportunities to streamline the state’s agricultural water planning process, encourage the adoption of water-saving practices, and improve enforcement of existing rules in favor of a convoluted approach that is quite simply a different way of counting the vast amount of water that agriculture already uses.
To help state agencies fully achieve the governor’s vision, we recommend that state agencies consider the following when finalizing the plan:
- Calculating water budgets and water use efficiency fractions don’t improve efficiency: Without also requiring water suppliers to identify water savings opportunities, counting water that flows in and out of an area (by completing water budgets and water use efficiency fractions) will not result in increased water efficiency. Water budgets and water use fractions also ignore the many benefits of water conservation and efficiency, such as improved drought resilience, better water quality, and healthier ecosystems for fish and wildlife.
- Insufficient data prevents agricultural water suppliers from completing an accurate water budget: Water suppliers are not currently collecting all of the data needed to complete an accurate water budget (and many don’t have the resources to do so). A water budget will only be as reliable as the underlying data so if you have bad or no data, you’ll end up with a wrong water budget.
- Annual water delivery reports should not be replaced by more complicated annual water budget reports: The annual water delivery reports currently required by law are relatively simple for water suppliers to complete and they yield useful information on customer water deliveries. Yet less than half of agricultural water suppliers have consistently submitted this annual report. Replacing the existing delivery report with a new, complex water budget report would lead to even worse compliance with little benefit (as the inclusion of private groundwater pumping data is not required).
- Agricultural water planning and efficiency practices should apply to medium-sized suppliers (those serving between 10,000 and 25,000 irrigated acres): Merely developing an agricultural water management plan does not achieve any water savings. Water suppliers must actually implement water-conserving practices to save water and reduce waste.
- The existing agricultural water planning process should be improved before large-scale changes are made: Relatively simple fixes to the existing planning process, such as standardizing reporting and requiring electronic filing, would make it much easier for the public and state agencies to review the plans that suppliers are submitting.
- Tools and resources are critical for suppliers to effectively implement planning requirements: Smaller water suppliers especially may need help developing agricultural water management plans and evaluating and implementing water-saving practices. State agencies should provide resources, such as detailed guidance for suppliers on how to evaluate water-saving practices, and can help facilitate information sharing among suppliers.
- Suppliers should be asked to modernize water delivery systems and consider how they can incentivize the adoption of on-farm practices that improve soil health: Flexible water delivery systems would drastically reduce water waste by allowing farmers to precisely time irrigation to meet crop needs. These systems also enable farmers to use more efficient irrigation methods, such as drip and regulated deficit irrigation. Practices that improve soil health, such as conservation tillage, compost application, and cover cropping, can reduce the need for irrigation by increasing the water infiltration and storage capabilities of soil. Suppliers can help fund the adoption of on-farm practices that build soil health, which provide water-saving and other benefits for suppliers and farmers.
- Enforcing existing rules would save more water: Although water management plans have been required for several years, roughly half of suppliers fail to turn these plans in. Similarly, many suppliers have failed to implement basic water conservation practices, such as measuring water deliveries and charging customers based on water usage, even though they’re required by law. The Department of Water Resources has been lax in getting suppliers to comply. It’s time for the State Water Board to step in and make sure that suppliers are following the rules.
In the months and years ahead, we’ll be carefully paying attention as state agencies begin to implement the plan. This is a pivotal moment for state agencies and Gov. Brown to leave a lasting legacy and really make water conservation a permanent way of life for all Californians. We stand ready to help.