Topic: State Water Resource Control Board’s Cost Estimates in Consideration of a Hexavalent Chromium Maximum Contaminant Level (MCL) White Paper.

 Thank you to all who helped CalMutuals take action with the State Water Resources Control Board to bring potential issues regarding the Hexavalent Chromium cost estimates to the forefront of discussion.

Summary: CalMutuals has the position that the State Water Resources Control Board’s current cost estimates may not reflect true economic feasibility and still retain problems that may prevent it from being legally acceptable.  The discussion of the allowance of alternative technologies such as POE/POU devices, modelling strategies for predictions, and universal treatment assumption concerns support CalMutuals’ position that more consideration must be given to all systems as well as their costs and abilities before moving forward.

Read CalMutuals Comment Letter

If you would like to follow the evolution of this issue you may read our previous comment letter to the State Water Resources Control Board regarding their economic feasibility analysis dating back to April 2020 that summarizes CalMutuals’ position that the White Paper does not adequately address the issues cited by the Courtin invalidating the previous standard for hexavalent chromium.

Read CalMutuals Comment Letter


Topic: CalMutuals Comment Letter about Governor Newsom Draft Resiliency Portfolio lacking Affordability 

 The Governor recently released his draft resiliency water portfolio which provides a comprehensive road map for progress on many fronts to achieve water supply reliability throughout the state but does not effectively define what it means to achieve “resiliency.” CalMutuals believes that vulnerability must be rated by the success of the smallest water system in terms of size and wealth. Please read our comment letter for our complete position.

Click to read CalMutuals Comment Letter


Topic: University of California Riverside Affordability Study

University of California, Riverside has recently completed a study and held a symposium in which they attempted to gauge the affordability of water throughout the state mainly using their Water Expenditure Ratio calculation and discussion the possible implications of those findings.

Here Are A Few Highlights:

  1. The study attempts to take into account the proportion of residents’ income that is spent on water and sewage to determine whether water is affordable, and whether a Low-Income Rate Assistance (LIRA) program should be implemented.
  2. UCR makes a distinction to use the median household incomes of a specific block or neighborhood in order to get a more accurate idea of the burden shouldered by certain communities.
  3. Research showed that at least within Eastern Municipal Service District there is an inverse trend between higher incomes and lower ratios of incomes spent on water.
  4. Panelist Adan Ortega urged the group to consider the building blocks of affordability as a whole in order to fully understand the situation and understand that our choices guide affordability. The building blocks include the age of infrastructure, sources of water supply, cultural drivers, community standards, and confidence in the safety of the water supply.
  5. While expenditure ratios partially explain the trends, Mr. Ortega contended that the burdens placed on disadvantaged communities without access to healthy water cause them to make more expensive choices.
    1. A distrust of the tap water can cause disadvantaged households to spend 600x more on bottled water.
  6. While a LIRA program may be helpful for many communities, Mr. Ortega urges the state to consider the deeper forces driving affordability issues.

Click to read CalMutuals Comment Letter


Bill of Interest: 

SB 974 (Hurtado) California Enviromental Quality Act: small community water System; exemption 

Sponsors: Self-Help Enterprises and Rural Community Assistance Corporation

Summary: SB 974 exempts from CEQA review drinking water projects benefiting public water systems serving small disadvantaged communities and schools in an attempt to uphold the State’s Commitment to the Human Rights to Water. Specifically this legislation creates a narrow statutory exemption for community water systems serving a DAC community with fewer than 10 thousand people and public water systems owned and operated by schools that serve a DAC community.





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