MCWRA Letters to the State Water Board – Curtailments Conservation Framework
MCWRA Response to Revised Water Conservation Framework
In an April 29, 2015, letter to the State Board, MCWRA continues to be concerned, because the draft framework is still of a singular focus on per capita water use, even though the State’s own Drinking Water Information Clearinghouse website (“DRINC Portal”) states:
It is not appropriate to use R-GPCD water use data for comparisons across water suppliers unless all relevant factors are accounted for. Factors that can affect per capita water usage include:
- Rainfall, temperature and evaporation rates – Precipitation and temperature varies widely across the state. Areas with high temperature and low rainfall need to use more water to maintain outdoor landscaping. Even within the same hydrological region or the same water supply district, these factors can vary considerably having a significant effect on the amount of water needed to maintain landscapes.
- Population growth – As communities grow, new residential dwellings are constructed with more efficient plumbing fixtures, which cause interior water use to decline per person as compared to water use in older communities. Population growth also increases overall demand.
- Population density – highly urbanized areas with high population densities use less water per person than do more rural or suburban areas since high density dwellings tend to have shared outdoor spaces and there is less landscaped area per person that needs to be irrigated.
- Socio-economic measures such as lot size and income – Areas with higher incomes generally use more water than areas with lower incomes. Larger landscaped residential lots that require more water are often associated with more affluent communities. Additionally, higher income households may be less sensitive to the cost of water, since it represents a smaller portion of household income.
- Water prices – Water prices can influence demand by providing a monetary incentive for customers to conserve water. Rate structures have been established in many districts for water conservation, but the effectiveness of these rate structures to deter excessive use and customer sensitivity to water prices vary.
https://drinc.ca.gov/dnn/Applications/UrbanWaterR-GPCD.aspx.
Read more: 042915 – SWRCB Emergency Conservation Regulation Letter
MCWRA Letter to the State Water Board – Pre-1914 Water Rights
In response to a April 23, 2015,State Water Board notice to water right holders within the San Joaquin River watershed that pre-1914 are likely to be curtailed this summer, MCWRA sent a second letter to the State Board again emphasizing that regulatory action should not be imposed on the long-standing legal rights of pre-1914 senior diverters.
“As previously expressed, Mountain Counties is concerned with the SWRCB’s notices of potential future curtailments, which suggest an intention to take the unprecedented actions of curtailing vested pre-1914 appropriative rights and requiring reductions of riparian water rights. We are fully aware that the severity of the drought requires appropriate regulatory action and we support the SWRCB’s adherence to the water right priority system in curtailing post-1914 water rights for the protection of senior water rights, including previously stored water. However, no regulatory action should be imposed with respect to the long-standing legal rights of pre-1914 senior diverters”, said John Kingsbury, Executive Director, MCWRA
Read more: 042915 – SWRCB Letter – Tom Howard – Curtailments
