In regard to my previous blog post, Water rationing upon us.
California Public Utilities Commission
Water Utilities Division, Room 3106
505 Van Ness Avenue, 3rd Floor
San Francisco, CA 94102
Attention: Seaneen Wilson
Re: GSWC Advice Letter No 1329-W
11 June 2009
I'm writing in regard to Notice received from Golden State Water Company (GSWC) in regard to Advice Letter 1329-W - staged mandatory rationing plan.
While I am not opposed to a rationing plan in general, the proposed Plan has some deficits. The first and most glaring deficit is that no threshold of acceptable use has been set for any of the rationing stages. The impact of this oversight is that someone who has a history of conservation and low water use will be asked to make the same percentage cut as someone who has never conserved. This is intrinsically unfair to the conserving user, since water savings will be more difficult for the conserving user to achieve.
I suggest that each rationing stage have a threshold below which there is no requirement to save additional water. Since you have previously established 18 hcf as the revenue neutral usage point, I suggest that the Stage 1 minimum usage threshold be set at 18 hcf.
The second oversight in your letter is that no commitment been made to provide broadcast TV or computer video, or computer audio transcripts of the June 15th public meeting. Is it too much to ask that GSWC tape the meeting and put it on YouTube?
The third deficit of the Notice is that the contact requirements seem designed to prevent all but the most perseverant correspondent: While responses may be made either electronically or by US Postal Service to GSWC, the CPUC requires duplicate delivery of the response on the same date by USPS only! In our modern times, it seems ridiculous to levy this requirement on the public. Adding to the potential level of public confusion is a requirement to refer to GSWC Advice letter 1329-W in all correspondence, but placing this requirement in a section apart from the section where contact information is provided.
The fourth deficit is in the Special Conditions section of the Notice. Of several poorly specified rules, the most glaring is the absence of exceptions for low-flow drip-type irrigation systems. Typical drip systems run for much more than 15 minutes (item m) and might be a viable exception for item h as well.
cc (by email):
Golden State Water Company
630 East Foothill Blvd
San Dimas, CA 91773
Attention Ronald Moore
regulatoryaffairs at gswater dot com