CII sector water conservation measures under development

By Michael Shaw

Capitol Update, Oct. 28, 2016 Share this on FacebookTweet thisEmail this to a friend

On the heels of declining monthly water conservation numbers, the State Water Resources Control Board (SWRCB) in conjunction with the Department of Water Resources (DWR) are developing a report for release by January 10, 2017 that provides recommendations and specific regulatory proposals for drought conservation activities and new water efficiency measures. The approach, as discussed at a recent Urban Advisory Group (UAG), is based on the Governor’s most recent Executive Order (EO) that focuses on strengthening local drought resilience, eliminating water waste and using water more efficiently. Bottom line, the proposed approach being contemplated would institute additional permanent wasteful use prohibitions, institute water budgets for each water supplier, set performance measures for the Commercial, Industrial and Institutional (CII) sectors and set indoor and outdoor residential use standards.

These recommendations and regulatory proposals would be a part of revised emergency water conservation regulations in early 2017. Specific to the CII proposed approach, it would establish performance measures and an overall water budget for the CII sector containing the following components:

  • Dedicated irrigation systems must be on a water budget using specified outdoor standards with implementation of a threshold for all CII landscape water use;
  • Require sector classification by NAICS by 2021 (exact classification basis open for discussion/alternative approaches);
  • Upon classification, development of benchmarks within the sector classes to develop water budgets; and
  • Audits and water management plans for reporting efficiency in CII water use based on volume, percentage or classification number.

Under such a framework, if a CII entity is going to use above a certain threshold set for that classification they will be subject to an audit to justify that the usage is an efficient, necessary use of water. The plan is to establish some sort of technical advisory group to help determine the classification scheme and establish the benchmarks by 2018.

The CII and other components would all be subject to mandatory reporting and progress reports by 2019 to describe efforts to meet 2025 requirements, particularly for suppliers. Enforcement actions are contemplated for suppliers, CII entities, and more for non-compliance. In terms of timing, the proposal is on an aggressive schedule as follows:

Draft released for public comment        November 14th
Workshop                                              November 18th
Public comments due                            November 23rd @ Midnight
Final                                                      January 10, 2017 

For more information, please see

CMTA’s Water Advisory Group will discuss this issue on a future conference call. If you are interested in participating in that group, please contact Michael Shaw at


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