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.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
