Comments on the Water Board’s draft urban conservation regulations

Tree in wet and dry landscape

On Wednesday, October 4, 2023, the State Water Resources Control Board held a hearing on proposed regulations to implement 2018 legislation to make conservation a way of life in California. According to the Board’s fact sheet:

Making Conservation a California Way of Life is a new regulatory framework proposed by State Water Board staff that establishes individualized efficiency goals for each
Urban Retail Water Supplier. These goals are based on the unique characteristics of the supplier’s service area and give suppliers the flexibility to implement locally appropriate solutions. Once implemented, these goals are expected to reduce urban water use by more than 400-thousand-acre feet by 2030, helping California adapt to the water supply impacts brought on by climate change.

Although Water Board staff had worked with water agencies for years in drafting the regulations, at the hearing, many water agency staff and board members called for further delay in implementing the regulations.

We made these comments in support of implementation.

Good evening, Chair and Board members. Thank you for your stamina tonight. Deirdre Des Jardins. My organization, California Water Research, has advocated for the use of best available science in climate adaptation in the California water sector for over a decade.

The California Water Board has been a national leader in climate adaptation in the water sector, and I wanted to thank the Water Board staff for the effort they have put into drafting the Making Conservation as a Way of Life regulations, and to say that we support it.

I am saddened by proposals today for delay. We can’t be sugar-coating the risk of more extreme droughts, and we can’t be waiting. California has already seen increased atmospheric thirst and drying of watersheds in the hotter droughts of the 2010s.

This year, we have seen a staggering increase in global temperatures. About September temperature data which has just come in, climate scientist Zeke Hausfather said:

This month was, in my professional opinion as a climate scientist – absolutely gobsmackingly bananas. JRA-55 beat the prior monthly record by over 0.5C, and was around 1.8C warmer than preindustrial levels.

We’ve already seen a dramatic worldwide increase in heat extremes in the 2010s, with 3 standard deviation heat waves increasing 90-fold, and a 1000-fold increase of 4 standard deviation events. It was over 115 degrees in Sacramento and other inland locations this summer. This will continue. It is maladaptive to continue to try to have large decorative lawns with these kinds of extreme temperatures.

The Water Board needs to set clear, numeric conservation standards. Atmospheric thirst is like another water user in the watershed, and in  2020s droughts, it will take an even greater share than it did in drought years in the 2010s.

Proposals to mitigate increasingly hot droughts by constructing more storage are a “field of dreams” strategy. Water agency folks hope that if we build more dams, the water to fill them will come. But the most recent climate research is pointing to increasing uncertainty about whether the average frequency of atmospheric rivers on the west coast will increase or decrease. So far, in the 21st century, there has been a decrease, on average, and recent climate model experiments suggest this could continue.

Conservation is the low-hanging fruit for climate adaptation in the water sector. I believe the proposed regulations will be much less costly than delay and denial. The time to act is now.

We appreciate the concerns the water agencies have expressed about implementation, but also ask that environmental and climate NGOs be at the table as the regulations are revised. It is critically important to achieve the goals of the 2018 legislation.

Further reading

Avanzi F, Rungee J, Maurer T, Bales R, Ma Q, Glaser S, Conklin M. 2020. Climate elasticity of evapotranspiration shifts the water balance of Mediterranean climates during multi-year droughts. Hydrology and Earth System Sciences. 24(9):4317–4337.

Albano CM, Abatzoglou JT, McEvoy DJ, Huntington JL, Morton CG, Dettinger MD, Ott TJ. 2022. A Multidataset Assessment of Climatic Drivers and Uncertainties of Recent Trends in Evaporative Demand across the Continental United States. Journal of Hydrometeorology. 23(4):505–519.

Carrington, D. 2023. ‘Gobsmackingly bananas’: scientists stunned by planet’s record September heat. The Guardian. Oct 4, 2023.

Desert Research Institute. 2022. New study shows robust increases in atmospheric thirst across much of US during past 40 years. April 6, 2022.

Gershunov A, Shulgina T, Clemesha RES, Guirguis K, Pierce DW, Dettinger MD, Lavers DA, Cayan DR, Polade SD, Kalansky J, et al. 2019. Precipitation regime change in Western North America: The role of Atmospheric Rivers: Supplementary Materials. Sci Rep. 9(1):9944.

Lee, S., L’Heureux, M., Wittenberg, A.T. et al. On the future zonal contrasts of equatorial Pacific climate: Perspectives from Observations, Simulations, and Theoriesnpj Clim Atmos Sci 5, 82 (2022).

Lee S, Karnauskas K, Heede U, L’Heureux M. 2023. How the pattern of trends across the tropical Pacific Ocean is critical for understanding the future climate. ENSO blog. Jan 26, 2023.

Riquelmy, A. 2023. California water board urged to ditch reporting aspect of conservation plan. Courthouse News Service. October 4, 2023.

Robinson, A., Lehmann, J., Barriopedro, D. et al. Increasing heat and rainfall extremes now far outside the historical climatenpj Clim Atmos Sci 4, 45 (2021).

State Water Resources Control Board. 2023. Making Conservation a Way of Life Fact Sheet.

State Water Resources Control Board. 2023. Notice of Proposed Regulatory Action: TITLE 23. Waters DIVISION 3. State Water Resources Control Board and Regional Water Quality Control Boards CHAPTER 3.5 – Urban Water Use Efficiency and Conservation ARTICLE 1 SUBJECT: MAKING CONSERVATION A CALIFORNIA WAY OF LIFE. August 18, 2023.


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