The Region Description in the plan describes the watersheds and water systems in the region, the internal boundaries of the region, the water supply and demand for the 20-year planning horizon, the current and expected water quality, the social and cultural makeup of the region, major water related objectives and conflicts, an explanation of how the IRWMP regional boundary was determined to be appropriate for the area, and the working relationship with neighboring IRWMP efforts. The intent of the Region Description is to identify the region by the water systems being managed and the common water issues of concern. By identifying the water systems and issues of concern to people, those working on the IRWMP can try to include a sufficient variety of interested parties in the planning process.

If you have relevant information to contribute to the regional description, you can include that in your comments. It is also helpful to provide references to your information sources.

3) Objectives

The objectives of the IRWMP identify the regional conflicts and water management issues the IRWMP will address. The IRWMP must explain the process used to select the objectives. The objectives should be measurable, so that success in meeting the objectives can be monitored and reported. At a minimum, all IRWMPs must address: water supply reliability, water quality, threats from groundwater overdrafting; stewardship of aquatic, riparian, and watershed resources; groundwater contamination, and the water related needs of disadvantaged communities.

If the IRWMP you are reviewing did not address one of these objectives of concern to you, you can suggest its addition to the plan in your comments.

4) Resource Management Strategies

The 2009 California Water Plan Update provides a list of Regional Management Strategies to encourage diversification of water management approaches. Each IRWMP must consider each of these Regional Management Strategies. To reduce water demand, the state encourages both urban and agricultural water use efficiency. To improve operational efficiency, the state encourages new conveyances, system reoperation and water transfers. To increase water supply the state encourages surface storage, groundwater storage, and recycled municipal water. To improve water quality, the state encourages drinking water treatment, groundwater remediation, pollution prevention, and urban runoff management. To improve resource stewardship, the state encourages economic incentives, ecosystem restoration, forest management, recharge area protection, water –dependent recreation, watershed management, and agricultural land stewardship.

When reviewing an IRWMP, see if any Regional Management Strategies applicable to the region have been left out of the plan. If any have, suggest in your comments that they be added to the plan.

5) Integration

While most IRWMPs will not have a separate section entitled “Integration”, the integration concept must be apparent in other sections of the plan. The intent is that, through development of the IRWMP, separate pieces of the regional water management puzzle are combined into an efficiently functioning unified effort. For example, the governance section may reflect a balanced process that enabled a diverse group of stakeholders to collaborate in developing the IRWMP. For another example, water projects in the IRWMP may reflect an effort both to improve the natural ecosystem and to enhance water supply. For another example, separate local water supply efforts may be combined to form more efficient regional projects.

When reviewing a plan, look for examples of integration. Also, if your review of the plan suggests integration opportunities that were not seized in the plan, suggest them for consideration.

6) Project Review Process

An IRWMP must include the process used to submit and to select the water projects included in the IRWMP. Project review must consider how the project contributes to achieving the plan objectives, and to implementing the regional management strategies. Also, project review must consider the project’s cost, financing, and economic feasibility. In addition, the project review process must identify the status of the project, and its technical feasibility. Furthermore, the project review must consider environmental justice considerations and the specific benefits of the project to disadvantaged communities. Next, project review must evaluate the project’s contribution to climate change adaptation, and greenhouse gas emission reduction. Finally, the project review must consider a project’s strategic role in IRWMP implementation. The IRWMP includes a list of the selected projects that systematically compares the aforementioned factors. This information should be used in prioritizing projects.

When reviewing the project list, see if it includes your top priority projects from your water purveyor’s, or your wastewater treater’s, long-range capital improvement plan. If not, you may want to suggest that your favorite project get included in the IRWMP.

On the other hand, if the project list includes projects that you object to, note that in your comments.

When reviewing this comparative project evaluation, consider if there are particular planning objectives or strategies that are not being implemented as vigorously as others. If so, consider proposing a project that could restore balance to the plan, and improve its chances of success. Such projects could be considered in an interim plan amendment or future plan update.

7) Impacts and Benefits

This section contains a screening-level review of project impacts and benefits, including those directly affecting environmental justice, disadvantaged communities, and Native American tribes. This review should be used in the future when plan performance is monitored, to see if some project benefits did not result, or if additional impacts did result. Any such changes must be noted when the plan is updated.

When reviewing this section, see if any of the project impacts or benefits have been left out of the plan. If so, note them in your comments and ask that they be included in the plan. Also, check to see if the treatment of project impacts and benefits is balanced, objective, and equal in detail. If not, make suggestions to help improve the analysis.

8) Plan Performance and Monitoring

The IRWMP must include performance measures and monitoring to be used in evaluating whether the projects are being implemented, and whether the plan is achieving its objectives. The IRWMP must explain who is responsible for evaluating plan implementation, how frequently they will do so, and who will maintain the monitoring data collected. Also, the IRWMP must identify who is responsible for project-specific monitoring, and when project-specific monitoring plans will be prepared. Such subsequent project-specific monitoring plans will include: a table of what is being monitored for each project, remedies if problems are discovered from monitoring; the monitoring location, frequency, and protocol; the methods of data collection, storage, and sharing; and procedures to fund and keep monitoring on schedule. Finally, the IRWMP must identify the adaptive management procedures for using the plan implementation monitoring data to amend and improve the IRWMP.

Good data are essential for adaptive management. If the data collection efforts seem inconsequential, or the mechanism for converting monitoring results into plan improvements is weak, note this in your comments.

9) Data Management

The IRMP must include a process for data collection, storage, and dissemination to IRWMP participants, stakeholders, the public and the State of California. This information includes project designs, feasibility studies, and information collected in every phase of project development from planning through construction, operation, and monitoring.

The IRWMP should explain the data to be collected, the data collection techniques, how stakeholders contribute data, who will maintain the data, quality control measures for data, data sharing procedures with interested parties and government agencies, and efforts to generate and share data compatible with State databases.

The public availability of this data is essential to ensure the accountability of local and state agencies. This data will help to determine if projects delivered the promised benefits, if their benefit and cost analyses in the IRWMP were accurate, and if the State chose to spend money wisely. This data management procedure will help stakeholders in an ongoing effort to provide information useful to the next IRWMP update.

If the IRWMP avoids collecting useful data, excludes stakeholders from contributing data, ignores quality problems with the data, does not intend to provide public access to the data or the programs to use it, does not help to interpret the data for the public, or does not seek to effectively provide the data to the State in a useful format, then mention it in your comments.

10) Finance

This Finance section can be one of the most interesting and provocative sections of the IRWMP. In most cases, State funding provides only a very small supplement to the local funds necessary to implement water and wastewater treatment projects. Most of the project costs will be borne by local entities. The Finance section should explain how the many funding pieces fit together for each project. This IRWMP information is often of great interest to ratepayers.

The Finance section of the IRWMP includes a description of funding for ongoing IRWMP implementation, and of funding sources for specific projects and programs. Project information should include sources of funding for project construction, operation and maintenance. The percentage of funding from each source should be identified. The IRWMP should identify the certainty and longevity of each funding source. The intent of this section is not to demonstrate that all project funding has already been secured, but to demonstrate that the project proponent has thought through how the entire project will be financed.

When evaluating this section, see if the required information is present. Then consider the implications of the financial information. What is the total capital cost of all the projects proposed by your water purveyor or wastewater treater? Can the ratepayers bear their share of those costs? Compare the cost of each project to the number of ratepayers who will benefit. Is this a reasonable cost per-ratepayer for the benefit conferred by the project? Is the proportion of costs borne by current ratepayers and future ratepayers equitably proportioned? Does the purveyor have an effective public participation and outreach procedure for addressing and resolving such public concerns? If the answers to these questions raise concerns for you, make those concerns known in your comments.

11) Technical Analysis

The IRWMP must reference the documents and the data analyses that support the plan. The intent of this standard is to ensure that the IRWMP is based upon sound information. The IRWMP must explain the techniques used to forecast water management needs throughout a plan’s 20-year horizon.

The IRWMP must explain why the information used is adequate, and provide references to its sources. For each data source, the IRWMP explains what the study did, what outcomes resulted, what level of uncertainty applies to the data, and how the data was used in the IRWMP. Any data referenced should be made available to the public upon request.

If upon review of the IRWMP, you take issue with the data used, mention this in your comments. If there are additional data gaps that need to be filled, mention this in your comments. If you are interested in reviewing the data, you may request to review the data in your comments.

12) Relation to Local Water Planning

For regional water planning to be effective, it must objectively and fairly incorporate local planning information. The intent of the standard is to ensure that an IRWMP is congruent with local plans, and includes information from current local water plans. Thus, an IRWMP will consider local plans for groundwater management, urban water management, water supply assessments, agricultural water management, flood protection, watershed management, stormwater management, low impact development, and disaster response.

In describing the use of these plans, the IRWMP includes the jurisdiction of the local plan, when it is updated, how it may be influenced by the IRWMP, inconsistencies between the local plans and the IRWMP, and how those inconsistencies might be resolved. An IRWMP must include coordination between local and IRWMP content, information from local plans that is both current and accurate, information from local plans regarding water management and climate change issues, and water management tools or criteria from local plans.

If your review of an IRWMP indicates a disconnect between the IRWMP and local water plans, mention that in your comments, and suggest how that could be resolved.

13) Relation to Land Use Planning

The IRWMP should include processes that foster communications between regional water managers and land use planners.

The IRWMP should explain the current relationship between regional water planning and local land use planning, and future efforts to improve collaboration. It should answer questions like: How do water managers and planning agencies interact? Do they provide input on each other’s projects? Are local land planners included in the IRWMP governance structure or project selection committee? Do the answers to these questions suggest that improvement is needed in future communications and collaboration? If so, the IRWMP should identify these future efforts. For example, it could suggest new forums needed for these professionals to interact.

To facilitate more effective IRWMP implementation, water agencies can seek useful input from land use agencies on issues such as flood management, groundwater recharge, conveyance facilities, stormwater management, water conservation, and watershed management. In turn, land use agencies can get useful advice from water agencies on landscaping programs, recreation, long-term planning, development review, public safety, and habitat management.

The intent of the standard is to require an exchange of knowledge and expertise among these resource professionals. The goal is for these managers to make informed, collaborative, and proactive decisions. The old model of reactive decisionmaking must be changed.

If your review of the IRWMP suggests that there are ways to improve the collaboration between land use and water managers, please include these suggestions in your comments.

14) Stakeholder Involvement

The intent of the standard is to ensure that all stakeholders have an opportunity to actively participate in the IRWMP decisionmaking process on an on-going basis.

Stakeholders are needed to gather regional information and to make regional decisions. The IRWMP processes should support stakeholder involvement. As noted above in the governance section, the IRWMP explains the efforts made to identify, to inform, to invite, and to involve in the planning process water purveyors, wastewater agencies, flood control agencies, city and county governments, special district, electrical utilities, Native American tribes, self-supplied water users, environmental stewardship organizations, community organizations, tax-payer groups, recreational interests, industry organizations, state and federal agencies, and disadvantaged communities. The IRWMP must explain how the collaborative process engaged a balance of the interest groups.

If your review of the plan indicates that necessary stakeholders have been left out of the planning process, make suggestions in your comments on ways to better include them. These suggestions could include, for example, different meeting times, different opportunities for participation (like single-subject committees), or particular people who should be contacted to represent a missing stakeholder group.

15) Coordination

There are three levels of required coordination.

First, the IRWMP must establish a process to coordinate stakeholder activities to avoid conflicts. This could include bringing local water agencies and stakeholders together in a setting where projects and activities can be discussed.

Second, the IRWMP must identify ways to collaborate with neighboring regions to avoid conflict, to avoid redundant projects, or to reveal opportunities for cooperative projects. It must identify common water management issues among neighboring regions, describe existing coordination efforts, and discuss joint project opportunities.

Third, the IRWMP must identify ways that the State and Federal governments can work with local agencies to promote effective plan and project implementation.

The intent of the standard is to reduce conflict among stakeholders and among neighboring regions; and to build effective working relationships with State and Federal agencies.

If your review of the IRWMP indicates that these coordination mechanisms are lacking, suggest ways to improve them.

16) Climate Change

An IRWMP must discuss both mitigation of greenhouse gas emissions, and adaptation to the effects of climate change.

As part of this effort, an IRWMP explains how GHG emissions are disclosed and considered when choosing among project alternatives. In many cases, this is currently done late in the planning process through quantitative project-level analyses in accordance with the California Environmental Quality Act (CEQA). However, the Project Review section of the IRWMP must include a less detailed analysis of a project’s contribution to reducing GHG emissions and adapting to climate change.

The IRWMP also discloses the potential impacts of climate change on the region including the water-related impacts on public safety and ecosystems, as well as on water supply reliability. The IRWMP should address the changes in water runoff and in groundwater recharge. The IRWMP Region Description section describes these impacts.

At this time, when considering adaptations to climate change, regions are encouraged to adopt “no regret” adaptations. These are policies, projects and programs that both make sense in light of current water concerns, and also help in terms of climate change adaptation. These include ongoing practices such as increasing water use efficiency, sustaining ecosystems, and integrating flood management. The Plan Objectives and Resource Management Strategies sections of the IRWMP should include the region’s approach to these “no regret” adaptations.

The IRWMP should contain provisions explaining how adaptive management will be used to respond to climate change challenges as new information becomes available. These provisions should appear in the Plan Performance and Monitoring section of the IRWMP.

In the future, as the analytical tools become available, IRWMPs will have to provide a more detailed evaluation of the adaptability of the region’s water management systems to climate change.

Today, climate change considerations are a driving force in water management decisions in California. In some cases, it may be driving good decisions, and in other cases it may be driving bad decisions. If your review of an IRWMP indicates that it has not considered Climate Change as required by the standards, and in a fair and objective fashion, then note that in your comments. Also, suggest improvements to the plan.

Conclusion

From a fiscal, environmental, population growth, economic development, and public works standpoint, there is a lot riding on the adequacy of an IRWMP. Thus, it is important for public comments to identify weaknesses in an IRWMP, and to suggest ways to strengthen the final plan. Since an IRWMP is periodically updated, it is also important for public comments to recommend improvements in the plan and the planning process that can be implemented when the plan is next updated.