This week, a critical milestone that can eventually save a significant amount of water was passed when the California Water Commission gave its unanimous approval to a rule proposed by the Department of Water Resources (DWR) that requires large irrigation districts to measure the water delivered to each of their customers. California’s landmark Water Conservation Act of 2009 requires large agricultural water suppliers to measure how much water they deliver to individual farmers, both to serve as the basis for volumetric billing of customer water use and to provide more accurate data on the amount of water actually passing through each irrigator’s farm gate.
In the agricultural sector, measuring water deliveries and
charging based on how much water is used is a critical water efficiency
tool that can help improve water use efficiency and farm productivity.
Nearly all urban water suppliers across the country measure their water
deliveries and bill customers based on how much water is used, and
these tools have been shown to improve efficiency by 20%. Until now,
however, most agricultural water suppliers in California were not
required to measure how much water they were delivering nor to bill
individual irrigators according to their measured water use.
Thus, although many irrigation water suppliers already measure
agricultural water deliveries at the farm gate, a surprising number do
not, especially in the rice growing region of the Sacramento Valley,
where application rates are enormous. To place this issue in
perspective, California is the #2 rice producing state in the nation,
and in 2010, over 550,000 acres of rice were harvested, more harvested
acreage than any other crop in the state except hay. By applying about 5
feet of water to rice fields each year in California’s semi-arid
climate, rice production draws nearly 3 million acre-feet of water per
year, a staggering amount of water roughly equal to the customer demand of five cities the size of Los Angeles.
So a requirement for water measurement and volumetric billing in rice
country could bring new attention to rice production and management
practices that might eventually save a significant amount of water – but
only if regulations effectively implement the law.
As recently as January, the California Water Commission approved a
muddled rule that was designed to broadly exempt rice-growing districts
and many additional districts receiving water from the federal Central
Valley Project. In a highly unusual move, the state’s Office of
Administrative Law, which must approve state agency rules for both
substance and process, agreed with NRDC and rejected the draft
regulation, finding it was not consistent with the 2009 Act. http://switchboard.nrdc.org/blogs/dobegi/california_to_strengthen_measu.html.
By the Department’s estimate, fully half the acreage in the Sacramento
Valley covered by the Act was not expected to implement farm gate
measurement under their initial rule.
The Department reconsidered its approach following the rejection by
the Office of Administrative Law in February and at the continued urging
of NRDC attorney Doug Obegi and his colleagues at the Sierra Club and
the Pacific Institute. (Urban water suppliers, who know the value of
water measurement, were conspicuously absent from this debate.) The
just-approved rule removes the broad exemptions sought by
rice-producing districts, and instead establishes performance standards
that all water suppliers must meet and lets water suppliers determine
the most cost-effective way of meeting them. The regulation
lays out numeric requirements for the accuracy of water measurement
devices, and requires that an engineer validate their accuracy. While
the accuracy testing and certification requirements are less rigorous
than we would have preferred, the new rule is nevertheless a giant step
forward for water conservation in agriculture, an industry that uses 80 %
of the state’s developed water supply.
Making more efficient use of irrigation water will be crucial for
maintaining the agricultural economy of the Golden State and the health
of its rivers and fisheries in the years ahead. This rule, by providing
more accurate water use information and enabling the introduction of
volumetric pricing, begins to align the financial interest of individual
farm operators with the broader community interest in making more
efficient use of irrigation water. Innovative district managers are
already setting out to find economical ways to measure their
deliveries. And as rice prices, while off of their highs of 2008 and
2009, remain historically strong, there’s no better time than now to
upgrade the water delivery systems upon which this crop depends. And
the good news for water managers and consumers throughout the state is
that the Water Conservation Act will be enforced even-handedly so that
its water-saving purpose will actually be achieved.
As noted above, the Office of Administrative Law must sign off on this rule before it can take effect. A decision from OAL is expected within the next three to six weeks. Stay tuned and follow us at @NRDCWater for the latest.
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