Legal Alerts Sep 08, 2020

DWR Releases Draft Guidebook for 2020 Urban Water Management Plans

Stakeholders Have Until Sept. 21 to Review and Comment

DWR Releases Draft Guidebook for 2020 Urban Water Management Plans

The California Department of Water Resources released its long-awaited draft Guidebook for 2020 Urban Water Management Plans last week. The Guidebook is designed to assist urban water suppliers with preparing UWMPs that are due to DWR on July 1. DWR also released its draft 2020 Agricultural Water Management Plan Guidebook related to long-term water supply and demand strategies for agricultural water planning. The 2018 water conservation legislation (Senate Bill 606 and Assembly Bill 1668) created new requirements for both plans.
The Urban Water Management Planning Act requires all wholesale and retail urban water suppliers (those that directly or indirectly serve more than 3,000 customers or 3,000 acre-feet annually) to prepare an UWMP every 5 years. Among other information and analyses, UWMPs evaluate current and projected water supplies and demands within an urban water supplier’s service area during normal and drought year periods over the next 20- to 25-year planning horizon. There are numerous new requirements for 2020 UWMPs including:

  • 5-year drought water reliability assessment,
  • Drought risk assessment,
  • Addressing seismic risk,
  • Water shortage contingency plan with new prescriptive elements,
  • Coordination with Groundwater Sustainability Plans and
  • A lay description of the UWMP’s conclusions regarding water service reliability, challenges ahead and strategies for managing reliability risks.

UWMPs continue to be critically important and increasingly complex documents. They are used as supporting documents for land use decision-making, environmental review, integrated regional water supply planning and groundwater management. Importantly, failure to adequately and timely prepare an UWMP in accordance with the UWMP Act can expose the supplier to a direct legal challenge. It could also jeopardize the legal sufficiency of future water supply planning and environmental documents that rely on UWMPs, such as Water Supply Assessments (SB 610), Written Verifications (SB 221) and other water supply analyses under the California Environmental Quality Act, leading to litigation from project opponents.

DWR’s Draft 2020 Urban Water Management Plan Guidebook
DWR helps urban water suppliers with UWMP preparation by providing the UWMP Guidebook, conducting workshops, developing tools and providing program staff assistance. DWR also reviews the submitted plans to ensure they have addressed the requirements identified in the Water Code and submits a report to the Legislature summarizing the status of the plans for each 5-year cycle.

DWR’s draft 2020 Guidebook addresses core elements that are required for legally sufficient UWMPs. In particular, the 2020 Guidebook provides guidance related to the following: plan preparation, water system descriptions, water use and supply characterizations, drought risk assessments, water shortage contingency plans, demand management measures and plan adoption, submittal and implementation. The 2020 Guidebook also includes reference material and resources, including applicable California laws and recent changes, an annual water supply and demand assessment, water loss auditing information, recycled water use information, reporting requirements, UWMP tables and an SB X7-7 Verification Form.
Stakeholders have until Sept. 21 to review and comment on the draft. Urban water suppliers should review the draft Guidebook and submit any questions or comments before this deadline. They should also begin preparing their 2020 UWMPs, if they haven’t already. Additional important upcoming dates include the following:

  • Sept. 16: UWMP 2020 Guidebook Public Workshop to solicit feedback and comments.
  • Fall: Release of final Guidebook planned.
  • July 1: Due date for urban water suppliers to submit their UWMPs to DWR.

BB&K has a team of attorneys providing advice to clients throughout the State to ensure that their 2020 UWMPs are both legally sufficient and will serve stakeholder needs as a useful source document for long-term water supply planning. We are available to assist and discuss any questions you may have.

Disclaimer: BB&K Legal Alerts are not intended as legal advice. Additional facts, facts specific to your situation or future developments may affect subjects contained herein. Seek the advice of an attorney before acting or relying upon any information herein.

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