The 2013 Baseline Water Use puts cities such as Piedmont at a disadvantage, according to a San Diego County Water Authority Board protest of the State Water Resources Control Board regulations.

Piedmont and some other residential communities have cut water use for a decade or more, while other areas had unlimited, unmetered water and no incentive to conserve. A protest has been submitted by the San Diego County Water Authority Board to the State Water Resources Control Board on their latest regulations governing water restrictions. The protest explains the use of 2013 as the baseline for new water use reductions creates negative incentives to water conservation.  The protest points are:

1.      The proposed water-reduction target punishes those who have conserved and rewards those who have not.  The state’s proposal to use 2013 as the baseline year against which to measure conservation seriously disadvantages communities that already achieved major, sustained water conservation prior to 2013.  For example, water use in San Diego declined 20 percent from 2007 to 2013. By failing to account for this conservation, the proposed regulations punish those who have conserved and rewards communities that did not make such early and sustained commitments to conservation.

Thus, some Californians are encouraged to minimally meet water use reductions  and are being rewarded for avoiding past conservation measures.

An additional complaint points out the negative consequences for water districts, such as East Bay Municipal Utility District (EBMUD), that have invested in conservation and supply reliability.

2.   The proposed framework punishes those who have invested in new supplies while rewarding those who have not. The state’s current approach does not give any credit to agencies or regions that have made substantial investments in water supply reliability, thus eliminating the incentive to increase regional self-reliance as called for in the Governor’s California’s Water Action Plan. For more than two decades, the San Diego region has diversified its water supplies at a substantial cost through a historic water conservation-and-transfer agreement with Imperial Valley for independent Colorado River supplies and construction of the Carlsbad Desalination Project. The desalination plant is more than 80 percent complete and on track to begin commercial production this fall, producing up to 56,000 acre-feet of drought-proof supplies annually. Under the State Board’s proposed regulations, the ratepayers in San Diego County who are funding this $1 billion project would experience no benefit from water produced by the plant.

Piedmont’s water supplier, EBMUD, has invested in aquifers, banking its excess supply in wet years to be withdrawn in dry years in order to maintain water supply availability.

Residential water users in urban and suburban communities, including Piedmont are asked to provide the conservation of water. Bay Area agriculture is also disadvantaged as the protest explains below.

San Diego also protested the State Water Board’s differential treatment of agriculture, including vineyards in coastal California, compared with Central Valley agriculture.

3.   The proposed framework threatens industrial and commercial production, and local agriculture.  State board regulations have shifted from focusing on achieving savings in discretionary outdoor water use to targeting commercial and industrial water uses that are critical to maintaining the livelihood of businesses and the regional economy. The proposed regulatory framework will hamper economic recovery in San Diego and statewide because it treats economic uses of water the same way as ornamental landscapes. Unlike agriculture in other areas of the state such as the Central Valley, agriculture in San Diego County is treated just like residential landscapes under the proposed regulations. This approach ignores the fact that agriculture is a major economic driver for our region. In 2013, the value of agriculture in San Diego County totaled $1.9 billion. If left unchanged, the proposed regulations would devastate local agriculture.