Office of the Mayor
City of Santa Rosa
100 Santa Rosa Avenue, Room 10
Santa Rosa, CA 95404
March 29, 2022
The Honorable Robert Hertzberg
California State Senate
1021 O Street, Suite 8610
Sacramento, CA 95814
Re: SB 1157 (Hertzberg) – Indoor Residential Water Use – OPPOSE
Dear Senator Hertzberg,
On behalf of the City of Santa Rosa, I am writing to express our opposition to Senate Bill 1157.
SB 1157 would circumvent the long-term water conservation framework (framework) established in response to Governor Brown’s “Making Conservation a California Way of Life” Executive Order, by proposing to incrementally lower the standard for indoor residential water use to 42 gallons per capita per day (GPCD) starting on January 1, 2025.
The City of Santa Rosa is an urban retail water supplier serving approximately 175,000 residents in Sonoma County. Santa Rosa has a long-standing commitment to drought preparation and water use efficiency, recognizing the vital role that long-term drought preparation and continued improvement in water use efficiency provide in maintaining a resilient water supply.
Santa Rosa believes that effective research and collaboration between DWR, the State Water Board, and California water providers is necessary to maximize urban water use efficiency and conservation.
The long-term framework created by landmark legislation in 2018, included mandated studies, and technical and financial evaluations, which ultimately led to comprehensive water conservation regulations that build on the already successful implementation of statewide 20% urban water use reductions by 2020 sought in the “Water Conservation Act of 2009” legislation crafted in the Senate's Seventh Extraordinary Session under Senate Bill X7-7. The City of Santa Rosa was fully engaged in the coordinated effort between state agencies, water utilities, and other interested parties that shaped this framework through the passage of AB 1668, and its accompanying bill, SB 606, which called for the creation of new urban water use efficiency standards for indoor water use, outdoor use, commercial, industrial and institutional use, water loss, and variances for unique conditions.
The 2018 legislation set an indoor water use standard of 50 GPCD, which is not yet in effect.
The legislation also directed DWR, in collaboration with the State Water Board, to prepare a
Office of the Mayor
City of Santa Rosa
100 Santa Rosa Avenue, Room 10
Santa Rosa, CA 95404
study that addresses questions surrounding the effect of a decrease of the indoor residential water use standard from 55 GPCD to 50 GPCD. While a study was completed, the analysis of adverse impacts and other relevant information, including affordability and changing populations and patterns, was not quantitatively considered; nor were formal recommendations made in DWR’s Final Report. The Final Report indicates that, on average, current indoor residential water use is 48 gallons GPCD. Given this finding, the recommended standard for 2025-2030 of 47 GPCD, which is included in SB 1157, is very close to existing statewide average water use. Even so, many suppliers will still need to make significant investments to achieve the proposed 2025 standard. The reduction to 42 GPCD in 2030, however, is significantly lower than current water use, and there could be substantial negative impacts to water providers, sanitation agencies, and recycled water providers. Santa Rosa recommends that new indoor water use efficiency standards should only be implemented upon a stakeholder engagement process to ensure that it is feasible and appropriately reflects best practices, and actual possible results for indoor water use.
Furthermore, the proposed language in Senate Bill 1157 fails to provide for a stakeholder involvement process prior to employing a lower indoor water use standard, which becomes even more worrisome due to the impact the COVID-19 health emergency has had on residential water use. Santa Rosa and other utilities in the region are seeing trends where residential water use has increased, and commercial water use has decreased since the pandemic began. It is unclear whether this change in water use is permanent, however prior to setting a new standard this potential change of reality must be taken into consideration.
Additionally, lowering the indoor water use standard without proper analysis could inadvertently increase rates and pose significant financial challenges to disadvantaged communities and low-income households. The California Water Efficiency Partnership estimated during the regulatory process that the “the total anticipated cost range for reasonably complying with a 2030 standard in which all providers achieve a residential indoor per capita volume of 42 GPCD by 2030 is likely between $2.8 and $4.6 billion.” The unnecessary strain on the potable water system infrastructure from excessively low water use standards, can result in increased operation and maintenance costs to flush pipes more frequently to prevent infrastructure damage. These additional costs will ultimately be passed on to our ratepayers. Many water providers in California already have insufficient funding to bring their infrastructure into compliance. Additional operation and maintenance costs to counteract effects of a lower water flow could further exacerbate financial challenges and increase water rates throughout the state.
Office of the Mayor
City of Santa Rosa
100 Santa Rosa Avenue, Room 10
Santa Rosa, CA 95404
Santa Rosa supports a sensible and successful implementation of the water conservation framework, including the water use standards set in AB 1668 and SB 606, however, we firmly believe that a new standard should not be implemented without a stakeholder process and robust study of the technical feasibility.
SB 1157 fails to take a data-driven approach to water use standards and may adversely affect our infrastructure, ratepayers, and ability to efficiently manage our systems. For these reasons, the City of Santa Rosa opposes SB 1157 unless it is amended to provide for a stakeholder process and a feasibility study. We ask that the existing commitment and progress the state agencies and water utilities have already made in fulfillment of the long-term drought planning changes contained in the “Making Conservation a California Way of Life” framework adopted less than four years ago be allowed to continue.
Thank you for your attention to this matter. We look forward to working with the Legislature to secure a sustainable and resilient water future that includes sensible approaches to improving water use efficiency and enhancing drought planning and preparation.
If you have any questions please contact Peter Martin, Deputy Director of Water Resources at (707) 543-4294 or [email protected].
Sincerely,
Sincerely,
Chris Rogers, Mayor
CC: State Senator Mike McGuire
Assemblymember Jim Wood
Assemblymember Marc Levine
Members, Senate Committee of Natural Resources and Water