MCWRA Comments on Proposed Water Loss Regulations
October 25, 2019
In a letter to Joaquin Esquivel, Chair, State Water Resources Control Board (SWRCB), the Mountain Counties Water Resources Association (MCWRA) sent a “Comment Letter” to raise concerns regarding the proposed framework, relevant to the development of water loss performance standards. There are concerns that the information and assumptions included in the economic model, as presented, could lead to inequitable targets that require costly, ineffective actions to avoid enforcement for the members in the mountain counties.
Specifically, MCWRA raised the following concerns regarding the proposed framework:
- Default assumptions in model do not provide appropriate agency-specific standards
- Model needs to be peer-reviewed and tested
- Model does not account for margin of error to ensure water loss standards are economical
- Model inappropriately uses customer retail unit cost
- Model assumptions regarding increased cost of water are unreasonable
- Model’s use of default leakage profiles is problematic
- Model’s assumption regarding leak surveys is unrealistic
- Model uses inappropriate default values for estimating cost-effective and feasible pressure reduction.
- Pipe replacement should not be regulated as part of the water loss standard
- Inappropriate water loss standards undermine water supplier’s mission of providing reliable and affordable water service
Click link for further description and details in the letter: Water Loss Regulation
