More than 200 letters leveling criticisms at a plan to force Californians to slash urban water use by 25% make it clear just how difficult it will be for regulators to enforce Gov. Jerry Brown's unprecedented mandate.
In the week since the State Water Resources Control Board announced its proposal to cut water use statewide, tiny rural towns, huge urban water agencies and suburban districts submitted a raft of comments calling the board's conservation targets unfair and, in some cases, unattainable.
Citing factors ranging from previous water-saving efforts to wildfire risk and the need of water for coffee shops, they argue the proposed cuts are too much.
Their grievances are aimed at a framework the state water board unveiled last week to comply with Brown's historic April 1 order requiring a 25% cut in overall urban water use across California over the next year. The proposal assigns individual targets to more than 400 local water agencies, which have been told they will have to chop water use by anywhere from 10% to 35% or face fines of up to $10,000 a day.
Brown issued his order in the fourth year of severe drought that has depleted reservoirs and caused a surge in well pumping that has driven groundwater levels to historic lows in parts of the Central Valley.
Under the state board proposal, the steepest cuts would fall on cities with the highest rates of per-capita water consumption during September of last year. They include small rural communities, along with such affluent enclaves as Newport Beach and Beverly Hills.
Cities with the lowest per-capita use that month, including Santa Cruz and Seal Beach, would have to cut the least.
One of the most consistent themes from Southern California agencies that commented on the framework is that the region has for years been a leader in water conservation, whereas some parts of the state are only now getting serious about it.
"Yet the [board] now considers a proposal that treats agencies with a history of saving water the same as others that are only now beginning to meter water used by their consumers," wrote Jeffrey Kightlinger, general manager of the Metropolitan Water District of Southern California.
The proposed cutbacks "punish those who have conserved and reward communities that did not make such early and sustained commitment to conservation," wrote Kimberly Thorner, general manager of the Olivenhain Municipal Water District in northern San Diego County.
Southern California farmers who get supplies from urban water districts said their businesses would be "devastated." "We cannot just turn off water at 20-35% and expect the trees and bushes to thrive," wrote Neil Nagata of Nagata Brothers Farms in San Luis Rey near Oceanside. "If I do not produce a crop, I will not have any income to continue farming at all."
Desert Water Agency General Manager David K. Luker wrote that a 35% water-use reduction would mean a $10.1-million loss in revenue for the water supplier, which serves Coachella Valley resort communities such as Palm Springs.
"A customer came to our office this week and asked us who he should file suit against when his property value decreases because the landscaping that he has invested tens of thousands of dollars in has died," Luker wrote.
That will not be a problem in Compton, where Deputy Director of Public Works Chad Blais wrote that the community's water use was already low because many residents can't afford basic services.
"If you drive through the City of Compton most of the front yards are brown," Blais wrote. "Therefore, the prospect of achieving an additional 20% reduction from this community is not feasible."
Another voice of discontent came from largely poor, rural Central Valley communities that are surrounded by cropland.
A 25% reduction in local residential usage would make a tiny dent in the area's overall consumption, because most of the water is sucked up by "farms, duck hunting clubs and newly planted pistachio orchards," complained John E. Burchard, general manager of the Alpaugh Community Services District in Tulare County.
The public works director of Kerman, a town of about 13,500 residents in Fresno County, wrote: "Our community is completely surrounded by agriculture and how is it equitable for the city to drastically reduce its use of water while the adjacent farmers are allowed to pump for 24 hours per day?"
The California Chamber of Commerce expressed concern that deep cuts would hurt some water-dependent businesses, including coffee shops.
"Beverage manufacturers, bottlers, coffee shops, industries like micro chip processors and food processors for example would be put in jeopardy if 25 percent of their water usage were cut or if they had to pay significantly more for their water," wrote policy advocate Valerie Nera.
In an email, state water board spokesman George Kostyrko said the draft regulations, scheduled for release Friday, will "reflect the thoughtful comments we receive to the framework."
The board is expected to adopt the regulations next month. Implementation of the regulations is expected to begin sometime before June 1.