HomeMy WebLinkAboutSWRCB_ProposedWaterUseRegulations_LtrToTownsend_20171213Public Utilities
879 Marro Street, San Luis Obispo, CA 93401-2710
805.781.7215
slocity org
December 13, 2017
Ms. Jeanine Townsend, Clerk to the Board
State Water Resources Control Board
10011 Street, 24th Floor
Sacramento, CA 95814
SUBMITTED VIA EMAIL
Subject: Comments on the Proposed Prohibited Water Uses Regulatory Action
Dear Ms. Townsend:
The City of San Luis Obispo (City) appreciates the opportunity to provide the State Water Resources
Control Board (State Water Board) with comments related to the proposed regulatory actions
regarding prohibited water uses. The opportunity to comment helps identify ambiguities in the
regulation and provides valuable insight into issues that may deter the ability to comply with the
regulation. More importantly, improvements to the regulation will lead to better conservation of our
water resources.
While the City supports the permanent prohibition on wasteful water use, the proposed regulation
is unclear regarding as to if how it relates to the use of recycled water. After listening to the
November 21, 2017 State Water Board meeting, it became clear that the State Water Board intends
for these prohibitions apply to recycled water though the regulation is unclear in this regard. Added
clarity regarding the State Water Board's intent to treat recycled water and potable water equally
would help clear up this ambiguity.
While the City supports the conservation of all water resources, flexibility in the use of recycled water
is one of the major driving factors for growth of recycled water use across the state and within the
City. Unlike surface water reservoirs and groundwater, without an active groundwater recharge
program, recycled water cannot be stored in any significant quantity beyond on-site storage tanks.
The inability for many agencies to store this resource may lessen the need for such strict conservation
regulations. Given the current underutilization of recycled water resources across the state, the City
recommends removal of recycled water from the proposed prohibitions. Instead of a one -size fits all
approach, the City recommends allowing local jurisdictions more control of how recycled water
resources are utilized. Flexibility will ultimately lead to an increased use of this resource and will
result in a decrease in the demand for potable water. Local regulation of this resource will also ensure
that a jurisdiction's specific scenarios and operational constraints are considered when regulating
the use of this resource.
In addition, the City requests further clarification on the following prohibition:
(G) The irrigation of turf on public street medians or publicly owned or maintained landscaped
areas between the street and sidewalk, except where the turf serves a community or neighborhood
function;
The term "community or neighborhood function" is not defined in the regulation and this language
will likely be subject to a wide degree of interpretation from jurisdiction to jurisdiction. Clarification
of what may be considered a "community or neighborhood function" would aid in compliance with
the proposed prohibition. An example of a definition for a community or neighborhood function may
be "An existing function utilized by the community and providing value to the community, such as a
dog walking area, pocket park, or community gathering location.
Additionally, the removal of turf and the installation of new irrigation systems and landscaping on
publicly owned street medians is an action that would require significant time and financial
resources. In order to plan accordingly for these changes, if left as part of the code, the City requests
that an adoption period be added to the regulation for this specific prohibition to allow for adequate
financial planning and remediation efforts. Since this specific prohibition was not part of required
emergency regulations during the drought, most Cities have not had adequate time to plan for the
required remediation efforts and financial investments.
The City applauds the work the State Board has conducted to ensure adequate water resources for
existing and future Californians and fully supports the permanent prohibitions on wasteful water use
with the above changes integrated. Thank you for your consideration.
Sincerely,
Carrie Mattingly, Utilities
C: San Luis Obispo City Council
State Senator Bill Monning, fax: (916) 651-4917
State Assembly Member Jordan Cunningham, fax: (916) 319-2135