CalMutuals provided comments to the State Water Resources Control Board on its Draft Policy for Developing the Fund Expenditure Plan for the Safe and Affordable Drinking Water Fund. Our recommendations included a continued focus on addressing the needs of small water systems statewide, a focus on action instead of further needs analysis and consideration of funding approaches beyond traditional grants.
Our comments centered on two key points:
- Use previously completed assessments instead of creating a new one: Spending another year or more on developing a needs analysis “from scratch” doesn’t make sense when similar analysis has already been completed by the County Drought Advisory Group. Guided by these needs assessments, CalMutuals recommends using an Assessment to Action framework that targets water systems already found to need help and/or intervention. Then, District Engineers at the Division of Drinking Water could concentrate on evaluation of the specific needs of those water suppliers and yield concrete options, plans and budget estimates.
- Think beyond the grant: CalMutuals further encouraged the SWRCB to think creatively about alternative approaches to funding common needs for small water systems. Traditional grant application processes are beyond the reach of struggling small systems because of very technical and costly application and grant reporting requirements. Mutual water companies face another key obstacle in receiving grants because California tax code does not recognize their 501 (c) (12) not-for-profit status. CalMutuals believes it is possible to identify common managerial, technical and non-construction infrastructure needs that could be addressed with more accessible approaches. CallMutuals called on the State Board to identify tools for small systems to address such things as budgeting and financial management and support, and purchase and installation of water meters, point of use devices and SCADA Systems. As an alternative to a traditional grant these resources could be made available at no cost or on a sliding scale based on ability to pay through a simple application process.
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