At a Conservation Pricing Workshop on July 8th, CWC's Jenny Rempel offered the following comments to the State Water Resources Control Board:
Conservation measures are clearly necessary during the drought and beyond as we adapt to a changing water supply framework in California. Rethinking our water pricing structures presents a great opportunity to address the dual goals of promoting conservation and achieving the Human Right to Water.
Water affordability is a central element to the Human Right to Water. But despite the obvious importance of access to safe water, there is not state policy that protects vulnerable individuals and communities from unaffordable rates. If implemented poorly, conservation pricing structures could further exacerbate existing affordability challenges facing CA communities. Thus, in developing conservation pricing programs and policies, we strongly encourage the State Water Board to develop conservation policies that do not place affordable water further out of reach, but rather increase access to safe, reliable and affordable water.
We suggest several ways of leveraging conservation pricing to further the Human Right to Water, including incorporating a public goods charge, developing a conservation signal in conjunction with an affordability program, promoting conservation for all water users - industrial, commercial, and agricultural as well as domestic users, and creating a fund to support operations and maintenance costs where appropriate to ensure that water is reliable and affordable.
First, we propose incorporating a public goods charge or water fee designed to ensure affordable drinking water for low-income customers. The fund created could then be used to support rate subsidies to customers, or regional projects like consolidations that would lower the cost of water delivery for the long term. Second, we suggest water utilities consider policies that encourage water use efficiency and conservation when designing affordability programs. This could be done by waiving or applying discounts to the fixed portion of the water bill rather than the variable portion of the water bill that reflects customer usage. It could also be done by offering a percentage discount on the total water bill based on reducing average water use for a particular household size. Third, we encourage the State Water Board to consider conservation pricing policies that address water use equitably and fairly by adopting policies that promote conservation not just with domestic water users, but with industrial, commercial, and agricultural users as well. And fourth, we recommend creating a fund to support operations and maintenance costs where appropriate to ensure that water is safe and affordable, and to make conservation pricing an option in some disadvantaged (DACs) where it is not currently an option due to the unaffordability of installing meters. This fund could be derived from a fertilizer fee at the rate of state sales tax to address nitrate contamination. Another potential funding source would be fees or enforcement actions to require parties responsible for contamination to contribute an appropriate share of the cost of providing safe drinking water.
In conclusion, this is an opportunity to simultaneously incentivize conservation and promote drinking water solutions that advance our state’s work toward securing the Human Right to Water for all Californians. We strongly urge you to find solutions that address the joint goals of water affordability and conservation.
Our full comments letter is here.