BILL ANALYSIS
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| SENATE COMMITTEE ON NATURAL RESOURCES AND WATER |
| Senator Fran Pavley, Chair |
| 2009-2010 Regular Session |
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BILL NO: AB 49 HEARING DATE: July 6, 2009
AUTHOR: Feuer URGENCY: No
VERSION: June 29, 2009 CONSULTANT: Dennis O'Connor
DUAL REFERRAL: No FISCAL: Yes
SUBJECT: Water conservation: agricultural water management
planning.
BACKGROUND AND EXISTING LAW
1.Under existing law, the California Water Plan is accepted as
the master plan that guides the orderly and coordinated
control, protection, conservation, development, management and
efficient utilization of the water resources of the state.
The Department of Water Resources (DWR) is required to update
the Water Plan on or before December 31, 2003, and every five
years thereafter. The plan shall include a discussion of
various strategies that may be pursued in order to meet the
future water needs of the state.
2.The Urban Water Management Planning Act requires urban water
suppliers to prepare and submit Urban Water Management Plans
(UWMPs) to DWR every five years on or before December 31, in
years ending in five and zero. Among other things, the plans
are required to:
Describe the reliability of the water supply by water
year type (average, single dry year, etc.)
Quantify, to the extent records are available, past,
current, and projected water use, identifying the uses
among water use sectors (residential, commercial, etc.).
Describe each water demand management measure currently
being implemented, or scheduled for implementation.
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1.The Agricultural Water Management Planning Act required
agricultural water suppliers that supply more than 50,000
acre-feet of water annually to develop agricultural water
management plans by 1992. Among other things, and to the
extent information was available, the reports were to address
the following:
Current water conservation and reclamation practices
being used.
Plans for changing current water conservation plans.
Conservation educational services being used.
Whether the supplier, through improved irrigation water
management, has a significant opportunity to do one or both
of the following:
Save water by means of reduced evapotranspiration,
evaporation, or reduction of flows to unusable water
bodies that fail to serve further beneficial uses.
Reduce the quantity of highly saline or toxic
drainage water.
1.Existing law makes the terms of, and eligibility for, a water
management grant or loan made to an urban water supplier and
awarded or administered by the department, state board, or
California Bay-Delta Authority or its successor agency
conditioned on the implementation of the water demand
management measures identified in the Urban Water Management
Planning Act.
2.Under Federal law (Section 210 Public Law 97-293 of 1982) all
CVP contractors are required to develop water conservation
plans. In 1993, the Central Valley Project Improvement Act
(CVPIA) Section 3405(e) required the Bureau of Reclamation to
develop criteria to determine the adequacy of the water
conservation plans required by Section 210. The Bureau
adopted the criteria in 1993 and the most recent update was
done in 2005.
3.On February 28, 2008 Governor Schwarzenegger sent a letter to
Senators Perata, Steinberg, and Machado in response to their
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concerns that his administration was unilaterally beginning
work on a "peripheral canal." In that letter, the Governor
identified administrative actions he was considering as part
of a comprehensive solution in the Delta. Included in that
letter was the following "key element":
"1. A plan to achieve a 20 percent reduction in per capita
water use statewide by 2020. Conservation is one of the
key ways to provide water for Californians and protect and
improve the Delta ecosystem. A number of efforts are
already underway to expand conservation programs, but I
plan to direct state agencies to develop this more
aggressive plan and implement it to the extent permitted by
current law. I would welcome legislation to incorporate
this goal into statute."
PROPOSED LAW
1.This bill would require the state to achieve a 20% reduction
in urban per capita water use in California by December 31,
2020. The state would be required to make incremental progress
towards this goal by reducing per capita water use by at least
10% on or before December 31, 2015.
2.The bill would define several terms, including:
"Agricultural water supplier" - a water supplier that
provides water to an unspecified number of acres of
agricultural land, excluding recycled water.
"Base daily per capita water use"
The urban retail water supplier's estimate of its
average gross daily water use per capita, measured in
gallons per capita per day (gpcd) and calculated over a
continuous 10-year period ending in 2004 or later.
For an urban retail water supplier that meets at
least 10 percent of its 2008 metered retail water demand
through recycled water, the urban retail water supplier
may extend the calculation of base daily per capita water
use up to an additional five years, to a maximum of a
continuous 15-year period ending in 2004 or later.
For an urban water supplier that was a member of the
California Urban Water Conservation Council (CUWCC)
before 1994, and whose base daily per capita water use is
at or below a specific state hydrologic region target,
the urban retail water supplier's estimate of its average
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gross daily water use per capita, reported in gpcd and
calculated over a continuous five-year period ending in
2007 or later.
"Baseline commercial, industrial, and institutional
water use" - an urban retail water supplier's base daily
per capita water use for commercial, industrial, and
institutional (CII) users.
1.The bill would require each urban retail water supplier to:
Develop an urban water use target and interim urban
water use targets by December 31, 2010. Urban water use
target and interim urban water use targets would be defined
as follows:
Urban water use target would be one of the
following:
(a) 80% of the baseline daily per capita water
use.
(b) Calculated as follows:
For indoor residential water use, 55 gpcd.
For landscape irrigated through dedicated
or residential meters, water efficiency equivalent
to the standards of the Model Water Efficient
Landscape Ordinance.
For CII uses, a 10-percent reduction in
water use from the baseline CII use by 2015. Upon
completion of a CII task force report, targeted
savings for 2020 shall be based on the CII
efficiency standards by the task force. If the task
force report is not completed by April 1, 2012, the
10-percent targeted reduction in water use shall be
extended from 2015 to 2020.
(c) For an urban water supplier that was a member
of the CUWCC before 1994, and whose base daily per
capita water use is at or below a specific state
hydrologic region target, 95 percent of base daily per
capita water use.
Interim urban water use targets
(a) The midpoint between the urban retail water
supplier's base daily per capita water use and the
urban retail water supplier's urban water use target
for 2020.
(b) For urban water suppliers using the system
described in (b) above, the sum of the following:
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For indoor residential and landscape uses,
the midpoint between the urban retail water
supplier's base daily per capita water use and the
indoor residential and landscape targets for 2020.
For CII uses, a 10-percent reduction from
the baseline CII water use.
Report their urban water use target and interim urban
water use target in their 2010 urban water plan and report
on their progress in meeting their urban water use targets
in subsequent updates of their urban water management
plans.
1.The bill would require agricultural water suppliers to:
Implement all of the following critical efficient
management practices:
Measure the volume of water delivered to customers
and to implement volumetric pricing.
Adopt a pricing structure for water customers based
at least in part on quantity delivered.
Designate a water conservation coordinator who will
develop and implement the water management plan and
prepare progress reports.
Provide for the availability of specific water
management services to water users.
Evaluate the policies of agencies that provide the
supplier with water to identify the potential for
institutional changes to allow more flexible water
deliveries and storage.
Evaluate and improve the efficiencies of the
supplier's pumps.
Implement all of the following additional efficient
management practices if the measures are locally
cost-effective and technically feasible:
Facilitate alternative land use for lands with
exceptionally high water duties or whose irrigation
contributes to significant problems, including drainage.
Facilitate use of available recycled water that
otherwise would not be used beneficially, that meets all
health and safety criteria, and does not harm crops or
soils.
Facilitate the financing of capital improvements for
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on-farm irrigation systems.
Implement an incentive pricing structure that
promotes specified goals:
Line or pipe distribution systems and construct
regulatory reservoirs to increase distribution system
flexibility and capacity, decrease maintenance, and
reduce seepage.
Increase flexibility in water ordering by, and
delivery to, water customers within operational limits.
Construct and operate supplier spill and tailwater
recovery systems.
Increase planned conjunctive use of surface and
groundwater within the supplier service area.
Automate canal control structures.
Facilitate or promote customer pump testing and
evaluation.
Report to DWR on which efficient water management
practices have been implemented and are planned to be
implemented, an estimate of the water savings that have
occurred since the last report, and an estimate of the
water savings estimated to occur five and 10 years in the
future. If an agricultural water supplier determines that a
particular efficient water management practice is not
locally cost-effective or technically feasible, the
supplier would be required to submit information
documenting that determination.
The reports would be due by December 31, 2012, and
thereafter in years ending in zero and years ending in
five.
The reporting requirements could be met through the
submitting to DWR an agricultural water management plan,
or a plan developed for the United States Bureau of
Reclamation that is consistent with this part.
1.The bill would require DWR to:
Develop, in consultation with the board, the California
Bay-Delta Authority, the State Department of Public Health,
and the Public Utilities Commission, a single standardized
water use reporting form to meet the water use information
needs of each agency.
Convene, in conjunction with the CUWCC, by April 1,
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2010, a task force consisting of experts to develop
alternative best management practices for CII users and an
assessment of the potential statewide reduction in water
use in the CII sector that would result from implementation
of these best management practices. The task force would be
required to submit a report to the Legislature by April 1,
2012, that, among other things, would establish water use
efficiency standards for CII users among various sectors of
water use.
Develop, in consultation with the Agricultural Water
Management Council, academic experts, and other
stakeholders, a methodology for quantifying the efficiency
of agricultural water use. Alternatives to be assessed
would be required to include determining efficiency levels
based on crop type or irrigation system distribution
uniformity. DWR would be required to report to the
Legislature by December 31, 2011 on a proposed methodology
and a plan for implementation. The plan would be required
to include the estimated implementation costs and the types
of data needed to support the methodology.
Review the 2015 urban water management plans and report
to the Legislature by December 31, 2016, on progress
towards achieving a 20-percent reduction in urban water use
by 2020. The report could include recommendations on
changes to water efficiency standards or urban water use
targets in order to achieve the 20-percent reduction and to
reflect updated efficiency information and technology
changes.
Submit to the Legislature a series of reports by
December 31, 2013, December 31, 2016, and December 31,
2021, on the agricultural efficient water management
practices that have been implemented and are planned to be
implemented and an assessment of how the implementation of
those efficient water management practices have or will
affect agricultural operations, including estimated water
savings, if any.
Submit to the Legislature a series of reports by
December 31, 2013, and thereafter in the years ending in
six and years ending in one, a report summarizing the
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status of the Agricultural Water Management Plans required
by this bill.
The report would be required to identify the
outstanding elements of any plan adopted pursuant to this
part. The report would be required to include an
evaluation of the effectiveness of the Agricultural Water
Management Planning Act in promoting efficient
agricultural water management practices and
recommendations relating to proposed changes to this
part, as appropriate.
DWR would be authorized to update the best
management practices established in this bill, in
consultation with the Agricultural Water Management
Council, the United States Bureau of Reclamation, and
SWRCB. The best management practices for agricultural
water use would be adopted or revised by DWR only after
public hearings to allow participation of the diverse
geographical areas and interests of the state.
1.This bill would substantially revise existing law relating to
agricultural water management planning to require agricultural
water suppliers to prepare and adopt agricultural water
management plans with specified components by December 31,
2012, and updated on or before December 31, 2015, and on or
before December 31 every 5 years thereafter.
An agricultural water supplier that becomes an
agricultural water supplier after December 31, 2012, would
be required to prepare and adopt an agricultural water
management plan within one year after becoming an
agricultural water supplier.
The agricultural water supplier would be required to
notify each city or county within which the supplier
provides water supplies with regard to the preparation or
review of the plan. The bill would require the agricultural
water supplier to submit copies of the plan to the
department and other specified entities.
The bill would provide that an agricultural water
supplier is ineligible to receive specified state funds if
the supplier does not prepare, adopt, and submit the plan
in accordance with the requirements established by the
bill.
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1.The bill, with certain exceptions, would condition eligibility
for certain water management grants or loans to urban water
suppliers, beginning July 1, 2016, and agricultural water
suppliers, beginning July 1, 2013, on the implementation of
water conservation requirements established by the bill.
2.The bill would repeal on July 1, 2016, an existing requirement
that conditions eligibility for certain water management
grants or loan to an urban water supplier on the
implementation of certain water demand management measures.
ARGUMENTS IN SUPPORT
According to the Sponsors, "There is growing imperative to
accelerate water use efficiency in California. The impacts of
climate change, the fragility of Delta ecosystems and levees,
recent court decisions limiting Delta water exports, and reduced
reliability of other traditional sources demonstrate a need for
prompt action to conserve precious water resources. Efficient
use is the foundation of local water supply reliability, and the
State must act to promote this and other critical water
management strategies."
"Using water more efficiently also saves tremendous amounts of
energy. The California Energy Commission estimates that 19% of
the state's electricity and over 30% of the non-power plant
natural gas use is associated with water use. Achieving these
water savings is critical both to meet the state's water supply
needs and to help meet the state's AB32 targets for reducing
greenhouse gas emissions."
Many supporters point out AB 49 would:
Meet the Governor's goal by requiring a 10% reduction in
statewide urban per capita water use by 2015, and a 20%
reduction in statewide urban per capita water use by 2020.
Provide flexibility to water suppliers by allowing them to
comply on an individual or regional basis, and by allowing
them to allocate savings across customer classes in the manner
they deem appropriate to their service area.
Require agricultural water suppliers to implement specified
Best Management Practices, and to report on savings from those
practices.
Require agricultural water suppliers every 5 years to prepare
water management plans and submit those plans to the
Department of Water Resources.
ARGUMENTS IN OPPOSITION
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Opponents tend to focus on one of two sets of issues, either CII
water use efficiencies or requirements of agricultural water
suppliers.
A coalition of manufacturing interests asserts that the bill
suffers from thee critical flaws:
"First, it measures efficiency of water use in the CII setting
by the arbitrary measure of gallons per day per capita among
residences in the supplier's service area. This is a
meaningless measurement in the CII setting."
"Second, the bill combines residential and CII water use into
one target, which results in arbitrary water use reductions in
both sectors. The only alternative is an absolute reduction
in CII water use by 10% in the next five years."
"Third, it fails to recognize or provide credit for existing
use of recycled water and other major conservation efforts
that have already taken place in the CII sector."
A coalition of agricultural interests make two main points:
"Agricultural interests believe the threshold [to be subject
to the provisions of AB 49] should be 35,000 acres, because
small irrigation districts to not have the personnel,
resources or financial capacity to prepare, and adopt and
implement efficient water management plans for their
customers. The 35,000 acre threshold would cover
approximately 75 percent of all agriculturally-applied water
in the state."
"AB 49 is fashioned after a controversial congressional
mandate for federal water contractors. The United States
Bureau o f Reclamation provides technical assistance and
funding to assist smaller suppliers in complying with the
requirements, however, AB 49 provides no such assistance."
Most opponents also either directly or indirectly question the
appropriateness of DWR taking the lead on developing,
overseeing, and reporting on progress in meeting various
efficiency measures.
COMMENTS
Will It Achieve 20% By 2020? Probably not, but it depends in
part on how you interpret the Governor's call for "A plan to
achieve a 20 percent reduction in per capita water use statewide
by 2020." This bill contends that the 20 percent statewide
reduction should reasonably apply to all water supplied by urban
water suppliers, with certain significant exceptions. One could
just as reasonably assert that it should apply to all water
uses, regardless of sector (urban, agriculture, environment) or
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water supplier (urban water supplier, agricultural water
supplier, or self-supplied).
Another question is that of the base year. That is, a 20
percent reduction compared to when? The Governor first went on
record calling for the 20 percent reduction in February 2008.
So, one could reasonably argue that 2008 should be the basis for
comparison. Others argue that since urban water management
plans were last updated in 2005, and urban water management
plans include an officially adopted detailed analysis of local
urban water use, that 2005 should be the base year. This bill
suggest that an average of the 10 year period ending in 2004 or
later should be the base, as averaging evens out annual
fluctuations due to climate and other variables.
One key reason this bill will probably not achieve the 20%
reduction is its "credit" features for earlier conservation
efforts. This credit comes in two forms.
Base year adjustment - this bill would set the base year as an
average of the 10 year period ending in 2004 or later.
However, urban retail water suppliers that meet at least 10
percent of its 2008 demand through recycled water may extend
the base year calculation up to an additional five years to a
maximum of a continuous 15-year period ending in 2004 or
later.
Each year, Californians automatically improve their water use
efficiency by some amount by things such as replacing out of
date water fixtures, upgrading irrigation systems, etc.
Consequently, the further back in time the base year is
calculated, the less efficient the water use in the base year,
and the easier it is to meet the target. It also means that a
20 percent reduction in water use by an agency using the
15-year basis does not mean the same thing.
Pre 1994 CWCC members - this bill would allow urban water
suppliers that were members of the CWCC prior to 1994, and
whose base daily per capita water use is at or below a
specified state hydrologic region target, to only reduce
baseline per capita water use by 5 percent by 2020. It would
also provide that the base year be calculated on a 5-year
average ending in 2007 or later. This is a tremendous
discount. Depending on the number of people served by water
agencies that meet this criteria, other water agencies would
need to reduce their gpcd water use by significantly more than
20 percent in order for the state as a whole to meet the
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statewide target.
The bill does provide that by December 31, 2016, DWR is to
report to the Legislature on progress towards achieving a
20-percent reduction in urban water use by 2020. And, the
report may include recommendations on changes to water
efficiency standards or urban water use targets in order to
achieve the 20-percent reduction and "to reflect updated
efficiency information and technology changes." However,
without some sort of future action by the Legislature, or
statutory direction to DWR to develop regulations to implement
the recommendations, any recommendations would not become the
new standards or targets. Also, because the recommendation
would be limited to reflect updated efficiency information and
technology changes, the recommendations could not be focused on
resolving issues associated with the crediting provisions.
Interim Target. The bill defines the 2015 interim target as the
mid point between the base water use and the 2020 target. While
requiring water agencies to demonstrate meaningful progress half
way into implementing this new program makes sense, it is not
clear why a strict mid-point calculation would be appropriate in
every case. Agency A may be about to implement some program
that would provide significant reductions in the near future -
Agency B may be developing plans that will have a big pay-off by
2020, but not much sooner. In both cases, comparing actual 2015
water use with a mid point target would provide misleading
information. Agency A's actual 2015 water use would likely be
significantly below its interim target, suggesting that it may
exceed its target, Agency B's actual 2015 water use would show
just the opposite. It might be more appropriate to require
water agencies to develop their plans to achieve their 2020
targets, and then report on their estimated reduction for 2015
based on their individual plans.
CII & GPCD. Population is at best tangentially related to
determining CII water use. Economic output, gross receipts,
enrollment, etc. are much more appropriate factors to consider
in evaluating how efficiently water is being used by CII water
users. When the economy is growing well, a manufacture may see
an increase in water use, even while adopting highly water
efficient production methods, due solely to higher output.
While it is true that the Governor's call was for a 20 percent
reduction in gpcd water use, it is also true that gpcd is a
flawed metric for measuring CII efficiency. It might make sense
to require the CII taskforce established through this bill to
recommend how to best reconcile its recommended metrics for CII
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efficiency in context of the requirements of this bill.
Task Force Setting Regulatory Standards. Typically, task forces
recommend regulatory standards, state agencies adopt regulatory
standards through the administrative law process. This bill
states that the report of the CII Task Force "shall establish ?"
and that for those agencies that chose to use the disaggregated
approach for reaching their targets, the CII targeted savings
for 2020 "shall be based on the [CII] standards ? established by
the task force ? " While the bill does include language stating
that the bill would not limit the application of the
administrative law process, it might make sense to make more
explicit that upon completion of the CII Task Force, DWR would
initiate a regulatory process to adopt the water use efficiency
standards recommended by the CII Task Force.
Agricultural Water Suppliers. As noted in the Background and
Existing Law, the existing, though dormant, provisions of the
Agricultural Water Management Planning Act required agricultural
water suppliers to fully describe their service area, quantity
and quality of water resources, water management practices, etc.
Agricultural water suppliers were defined as a supplier
providing more than 50,000 acre-feet of water annually for
agricultural purposes. However, this bill has a blank for the
definition of agricultural water suppler. The question is; what
is the appropriate definition of an agricultural water supplier?
There are a number of approaches one might take to answer this
question. One might be able to determine, based on an analysis
of water agency operations, financial and technical capacity,
etc., the minimum size of an agency that would not only be
technically able to conduct the analysis but where the results
of the analysis would be commensurate with the costs of the
analysis. This is probably neither a simple nor uncontroversial
approach. Another approach would be to focus on establishing
parity with urban water management plans. Such an analysis
would consider the percent of agricultural water that would be
covered by agricultural water plans as compared to the percent
of urban water covered by urban water management plans. While
probably easier computationally, it may result in picking only
the low hanging fruit.
Urban/Ag Equity. There are a number of instances in this bill
where agricultural water suppliers are treated significantly
different from urban water suppliers. For example:
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Compliance Dates. The bill would condition eligibility for
grants or loans on complying with the requirements of the
bill. Urban water suppliers must demonstrate compliance in
grant or loan applications beginning July 1, 2016,
agricultural water suppliers demonstrate compliance beginning
July 1, 2013. Those dates coincide with the first required
submissions of information to DWR under this bill.
However, water agencies do have to act earlier than 2016 -
they must develop their targets by the end of 2010. It is
just that the bill is silent as to what they have to do with
those targets beyond including them in their urban water
management plans. As urban water agencies are already
required under current law to submit those plans to DWR, it
might make sense from both an accountability and an
equitability perspective to condition loans and grants to
urban water suppliers on including their targets in the urban
water management plans that are due 12/31/10.
Causes of Action - Under this bill, any action or proceeding
to attack, review, set aside, etc. the acts or decisions of an
agricultural water supplier on the grounds of noncompliance
the provisions of the Agricultural Water Management Planning
Act, would be required to be brought pursuant to Section 1085
of the Code of Civil Procedure (regarding writs of mandate).
Moreover, the court's review of compliance or noncompliance
would extend only to whether the plan, or portion thereof, or
revision thereto, substantially complies with the requirements
of that Act. No such language exists for urban water
management plans.
The author should be encouraged to resolve any inappropriate
differences in treatment of the two water using sectors.
Related Bills: SB 261 (Dutton & Ducheny) requires urban water
supplier to develop and implement a water use efficiency and
efficient water resources management plan to reduce per capita
residential water use by 20 percent, creates a task force to
develop best management practices for CII water uses, and
revises and updates requirements under the Agricultural Water
Management Planning Act.
While AB 49 and SB 261 both attempt to implement the Governor's
call for a 20 percent reduction in per capita water use by 2020,
they take significantly different approaches. Most
fundamentally, AB 49 is focused on achieving the goal by greater
water use efficiency - squeezing more out of each drop. SB 261,
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which includes water use efficiency options, is focused more on
improvements in water resources management - freeing up more
drops.
Work In Progress. This bill has been heavily negotiated and
heavily amended. In addition to the issues raised above, this
bill has a number of confusing or otherwise incomplete
provisions, such as how "compliance daily per capita water use"
relates to "base daily per capita use" and "urban water use
target." There are conflicting provisions whether "the state
shall achieve" a 20-percent reduction or whether "it is the
intent of the Legislature that" these provisions result in a
20-percent reduction. There are other areas requiring
additional attention as well.
Should the committee decide to move this bill forward, the
committee may wish to seek a commitment from the author to
continue to work closely with committee staff to resolve the
various issues raised by this analysis.
SUGGESTED AMENDMENTS: None
SUPPORT
Metropolitan Water District of Southern California (Sponsor)
Natural Resources Defense Council (Sponsor)
Aerospace Cancer Museum of Education
Amigo de los Rios
CA ReLeaf
California League of Conservation Voters
California Sportfishing Protection Alliance
California State Grange
California Striped Bass Association West Delta Chapter
California Urban Forests Council
Central Basin Municipal Water District
City of Los Angeles
Clean Up Rocketdyne
Clean Water Action
Contra Costa Water District
Defenders of Wildlife
Diablo Valley Fly Fishermen
Environmental Defense Fund
Environmental Entrepreneurs
Food and Water Watch
Friends of the River
Green Plumbers USA
Heal the Bay
Inland Empire Utilities Agency
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Irvine Ranch Water District
Mountains Recreation and Conservation Authority
National Parks Conservation Association
Northern California/Nevada Council Federation of Fly Fishers
Pacific Coast Federation of Fishermen's Associations
Pacific Institute
Sierra Club California
Sierra Nevada Alliance
Sonoma County Water Agency
The Bay Institute
Three Valleys Municipal Water District
TreePeople
Upper San Gabriel Valley Municipal Water District
Water 4 Fish
West Basin Municipal Water District
1 Individual
OPPOSITION
Agricultural Council of California
Association of California Water Agencies
California Association of Nurseries and Garden Centers
California Association of Wheat Growers
California Association of Winegrape Growers
California Bean Shippers
California Cattlemen's Association
California Chamber of Commerce
California Citrus Mutual
California Cotton Growers and Ginners Associations
California Farm Bureau Federation
California Grain and Feed
California League of Food Processors
California Manufacturers and Technology Association
California Nevada Soft Drink Association
California Pear Growers
California Retailers Association
California Rice Commission
California State Floral Association
California Warehouse Association
Chemical Industry Council of California
City of Lakewood
Family Winemakers of California
Friant Water Authority
Grocery Manufacturers Association
Imperial Irrigation District
Industrial Environmental Association
Irrigation Association
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Kern County Water Agency
Modesto Irrigation District
Nisei Farmers League
Northern California Water Association
Pacific Egg and Poultry Association
Regional Council of Rural Counties
Santa Barbara Technology and Industry Association
Solano County Water Agency
Tule River Association
Valley Ag Water Coalition
Western Growers
Western States Petroleum Association
Wine Institute
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