April 13, 2015
Chairperson, State Water Resources Control Board
Attn: Jessica Bean
1001 I Street, 24th Floor
Sacramento CA 95814
Subject: YLWD Comments on the Mandatory Conservation Proposed Regulatory Framework
Dear Chairperson Marcus,
The purpose of this letter is to provide information concerning the impact of this regulation relative to our District, identify policy calculations that disproportionally affect our District’s customers, and finally offer recommendations that achieve the desired results in a fair manner.
YLWD has a 106 year history of serving the region (primarily with groundwater), which has transformed from agriculture to a bedroom community. This change has resulted in large parcels and open spaces, in what is considered arid and rugged terrain that is highly desirable for its scenic beauty. Water use is down significantly from our agricultural days, but is still higher than more densely populated urban areas. We understand everyone’s sense of fairness differs, but comparing residential gallons per capita day (R-GPCD) data without weighing it based upon considerations including land use, precipitation, temperature, and population growth, fails any definition of fairness. On one hand a sliding scale is used to determine YLWD’s Conservation Standard at 35%, but a sliding scale is not used in the calculation of our R-GPCD. Consequently, we feel the draft Standard for YLWD is unreasonable.