CUPcon

COMPLIANCE MONITORING

CUPcon

Issues Identified by Stakeholders

• Inconsistent reporting requirements among Districts

• Level of monitoring inconsistent with potential for impacts

• Perception that monitoring data is not being used by Districts

CUPcon

Goals

• Determine the optimal amount of monitoring and compliance submittals needed to ensure permitting criteria and conditions for issuance are being met

• Develop standardized compliance forms and submittal frequencies to be used by all Districts

CUPcon

Compliance Monitoring Categories

• Water Use Monitoring• Water Quality Monitoring• Alternative Water Supply Development• Reclaimed Water Feasibility Reporting• Conservation Plan Implementation Reports• Wetland/Water Level Monitoring

CUPcon

Evaluation of Compliance Submittals

1. Purpose and use statement

2. Applicability

3. Frequency of submittal

4. Standardized form

CUPcon

1. Purpose and Use

• What is the purpose of the data collection/monitoring?

• How will the data be used?• Based on defined statement, group

was able to propose appropriate applicability and submittal frequency.

Evaluation of Compliance Submittals

CUPcon

2. Applicability

• Coordination with other CUPcon groups as needed for permitting/compliance consistency• Ex. Public Supply Report

• Applicability to be provided by Water Conservation group

• Development of decision trees for consistent application of monitoring requirements• Ex. Wetland/water quality monitoring

Evaluation of Compliance Submittals

CUPcon

3. Frequency

No reportin

g required

Annual reportin

g

Semi-annual

reporting

Quarterly

reporting

Monthly reportin

g

Ex. Current Pumpage Submittal Requirement

Evaluation of Compliance Submittals

CUPcon

3. Frequency

Semi-annual reporting*- For all individual permits

- Monthly totals by well/pump/station

*Limited areas of special concern or certain circumstances may require more frequent submittal of

data.

Proposed Pumpage Submittal Requirement

Evaluation of Compliance Submittals

CUPcon

4. Standardized Compliance Submittal Forms

Form Type Draft Complete

Work in Progress

Water Use/Pumpage Form

Flow Meter Accuracy Form

Alternative Method Flow Verification Form

Crop Summary Form

Crop Protection Form

Public Supply Report

Water Level Template

Water Quality Template

Evaluation of Compliance Submittals

CUPcon

Accomplishments in Consistency

Submittal Type Applicability

Submittal Frequency

Comments

Pumpage Form Individual permits

Semi-annual

Monthly totals by well/pump/station

Flow Meter Accuracy Form

Individual permits with flow meters

7 years 95% accuracy requirement

Alternative Method Flow Validation Form

Individual permits using alternative method

7 years Alternative method to be approved by District (90% accuracy requirement)

Water Use Reporting

CUPcon

Accomplishments in Consistency

Submittal Type Applicability

Submittal Frequency

Comments

Crop Protection Form

Case-by-case (specific resource concerns only)

Consistent with pumpage reporting

Provided by permittees on request in response to dry-well complaints

Crop Summary Form

Case-by-case for variable crop allocations/ rotational fields (specific resource concerns only)

Annual Not used to limit allocation flexibility

Water Use Reporting

CUPcon

Accomplishments in Consistency

Submittal Type Applicability

Submittal Frequency

Comments

AWS Report Case-by-case (permits with specific AWS goals indentified during permit review)

Custom Districts to analyze broad scale AWS applicability/feasibility in planning process or at permit review

Alternative Water Supply

CUPcon

Accomplishments in Consistency

Submittal Type Applicability

Submittal Frequency

Comments

Reclaimed Water Feasibility Report (End-User)

Case-by-case (permits with specific reclaimed water goals indentified during permit review)

5 years Not for projects already maximizing, or with concrete plans to maximize, use of reclaimed water

Reclaimed Water End-User Feasibility

CUPcon

Next Steps• Obtain public feedback on draft forms• Integrate recommendations from other

CUPcon groups• Finalize evaluation and

recommendations for remaining compliance monitoring categories• Water Quality• Wetland/Water Level• Water Conservation Plan Implementation• Public Supply Report

• Complete remaining standardized compliance forms/templates

CUPcon

Benefits of Consistency in Compliance/Monitoring

• Uniform statewide monitoring requirements (format, frequency, applicability)

• Eliminate unnecessary or excessive monitoring

• Improved level of certainty for permittees regarding their compliance/monitoring responsibilities

• Improved ability for Districts to share compliance and monitoring data