Draft Municipal Water Law Policy (2nd Comment Period)

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Comment From: Swinomish Indian Tribal Commun... (Laura Bartholet)

7/25/24 @ 4:05 PM

Mr. Melcher, Attached please find a letter from attorney Wyatt Golding containing the Swinomish Indian Tribal Community's comments on the second draft of the Municipal Water Law Policy Revision. Thank you, Laura Bartholet Paralegal/Legal Assistant Zi...↓

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Comment From: Port Gamble S'Klallam Tribe (Claire Newman)

7/08/24 @ 12:00 AM

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Comment From: Squaxin Island Tribe (Amalia Walton)

7/01/24 @ 12:00 AM

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Comment From: Eric Dobson

6/24/24 @ 2:05 AM

I would like to add a comment if possible. Many of these changes would help resolve speculation in water rights. I was stuck for nearly two years in a speculative situation between a water district and the eastern office. I have highlighted what I be...↓

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Comment From: Jefferson County PUD District ... (Kevin Streett)

6/24/24 @ 2:05 AM

Jefferson County Public Utility District No. 1 ("JPUD") appreciates the opportunity to review and comment on the Department of Ecology’s (Ecology) Second Public Review Draft of Policy 2030, “Municipal Water Law Interpretative and Policy Statement.” J...↓

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Comment From: Klickitat PUD (Jim Smith)

6/24/24 @ 12:00 AM

(Scanned copy uploaded)

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Comment From: Washington State Senate Republ...

6/24/24 @ 12:00 AM

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Comment From: Olympic View Water & Sewer Dis... (Bob Danson)

6/21/24 @ 7:22 PM

Please see comment attached.
Thanks,
Bob Danson
General Manager
Olympic View Water & Sewer District

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Comment From: Washington Association of Sewe... (Judi Gladstone)

6/21/24 @ 3:50 PM

The Washington Association of Sewer and Water Districts (WASWD) appreciates the opportunity to comment on the second version of the proposed Policy 2030 update. We recognize that Ecology is trying in various ways to manage available water supplies t...↓o meet environmental needs and respond to challenges by Tribes, environmental groups, and others. However, water is one of the most important and complex issues any of us face, and resolving such issues needs to be done in an open, transparent manner, not through roundabout means in a policy. That being said, we provide our comments on Policy 2030 in this letter to reflect ongoing concerns about its content.

WASWD represents more than 180 public water and sewer districts in the state that serve nearly 25% of our state's population, 97 of which are Association members. These districts provide cost-effective water and sewer services—ranging from the state's largest population centers, to the smallest rural communities. As stewards of water resources, our members, like all utilities, are careful to balance the needs of people with the needs of the environment. This has been borne out in the commitment to water conservation over the past twenty years that was embedded in the MWL.

In the Municipal Water Law (MWL) that was approved by the legislature in 2003, utilities committed to conservation requirements hand-in-hand with the certainty and flexibility for municipal water rights that the law intended to provide. As drinking water utilities across the state are expected to prepare for significant population and economic growth per the Growth Management Act both of these are essential. Unfortunately, the revisions to Policy 2030 in the second round does not improve the policy to better align with the intent of the law, and disregards the input we, other water utilities, and WWUC provided on the first version.

As we noted in our comment letter on the first draft update to Policy 2030, planning for expected growth in the face of significant climate change impacts and contamination issues such as PFAS is challenging enough. That challenge is compounded by the Policy 2030 update revisions that unjustifiably restrict municipal water rights, thwart the intent of the MWL, and threaten the ability of utilities to ensure an adequate quantity of high-quality drinking water at the lowest environmental and customer cost. In particular, the policy revision perpetuates the "active compliance" concept from the original Policy 2030 to demonstrate "good standing," both of which we continue to contend have no basis in law. The second draft of the policy furthers the problem with relying on new tests of "original intent," "reasonable diligence," and "public welfare" to determine whether a water right is in "good standing" for a changed water right. As we stated before, the application of these principles is directly opposite from the certainty and flexibility sought to be created when the legislature passed the MWL.

WASWD recognizes that water rights pose one of the most difficult challenges for the state as water availability becomes less certain for people and fish. To better navigate that challenge, please reconsider comments provided in the past by utilities, other utility associations, and WWUC as you finalize Policy 2030. At a time when water contaminants endanger existing drinking water sources and climate change threatens available drinking water supplies, utilities are even more in need of the certainty and flexibility intended in the Municipal Water Law.

Thank you again for the opportunity to comment on the second draft of Policy 2030.

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Comment From: Public Utility District No. 1 ... (Chris Heimgartner)

6/21/24 @ 3:40 PM

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Comment From: Snohomish River Regional Water... (Bruce Gardiner)

6/21/24 @ 2:58 PM

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Comment From: Lakewood Water District (Marshall Meyer)

6/21/24 @ 11:54 AM

Please see attached letter.

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Comment From: City of Redmond (Amanda Balzer)

6/21/24 @ 9:08 AM

Please see attached letter.

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Comment From: Public Utility District No. 1 ... (Alene Underwood)

6/20/24 @ 5:04 PM

Please find attached. Thank you.

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Comment From: Regional Water Cooperative of ... (Jeffrey Johnson)

6/20/24 @ 2:48 PM

(letter submitted by email to Austin Melcher)

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Comment From: JOEL FREUDENTHAL

6/20/24 @ 2:14 PM

While I understand that Ecology needs to update the policy in response to the Crown West proposed purchase of water rights out of Spokane and the need to firmly state that unperfected municipal rights are not subject to transfer or sale. But I stil...↓

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Comment From: Center for Environmental Law &... (Trish Rolfe)

6/20/24 @ 9:33 AM

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Comment From: Thurston PUD (John Weidenfeller)

6/20/24 @ 9:10 AM

(submitted by email to Austin Melcher)

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Comment From: Atul Deshmane

6/18/24 @ 4:08 PM

Ecology has received substantial comments that challenge the proposed rule from practically every political group in the state. The revised draft does very little to address the last set of comments. So, I wonder if Ecology needs assistance. Perhaps ...↓

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Comment From: Mason County Public Utility Di... (Kristin Masteller)

6/18/24 @ 2:58 PM

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Comment From: Everson Water Association (Dave Olson)

6/18/24 @ 11:30 AM

In WRIA 1, the EVERSON WATER ASSOCIATION is one of many associations serving more than 15 connections that also provides water to dairy operations since their inception. Everson Water Association is not a government entity. The Association was founde...↓

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Comment From: Skookum Chuck Water Associatio... (Laura Heystek)

6/18/24 @ 11:20 AM

In WRIA 1, the SKOOKUM CHUCK WATER ASSOCIATION is one of many associations serving more than 15 connections that also provides water to dairy operations since their inception. Skookum Chuck Water Association is not a government entity. The Associatio...↓

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Comment From: Meadowbrook Water Association (Dave Olson)

6/18/24 @ 11:18 AM

In WRIA 1, the MEADOWBROOK WATER ASSOCIATION is one of many associations serving more than 15 connections that also provides water to dairy operations since their inception. Meadowbrook Water Association is not a government entity. The Association wa...↓

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Comment From: Pole Road Water Association (Dave Olson)

6/18/24 @ 11:15 AM

In WRIA 1, the POLE ROAD WATER ASSOCIATION is one of many associations serving more than 15 connections that also provides water to dairy operations since their inception. Pole Road Water Association is not a government entity. The Association was ...↓

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Comment From: Seattle Public Utilities (Elizabeth Garcia)

6/18/24 @ 5:38 AM

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Comment From: WPUDA (Liz Anderson)

6/18/24 @ 4:32 AM

The Washington Public Utility Districts Association (WPUDA) appreciates the opportunity to comment on Ecology’s 2 nd Draft of Proposed Revisions to Policy 2030, related to the Municipal Water Law. Please find our comments attached.

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Comment From: Andy Dunn

6/17/24 @ 9:31 AM

Here are my track changes comments on the 2 nd draft policy. Let me know if you have any questions or would like to discuss.

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Comment From: WWUC Washington Water Utility ... (John Weidenfeller)

6/14/24 @ 1:23 PM

(submitted by email to Austin Melcher)

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Comment From: Neil Wilson

6/06/24 @ 10:09 AM

I believe that rights to clean drinking water are a basic human right. We die without water. Homeowners shouldn't have to pay ridiculous high charges for water and everything else the city wants to throw at us.

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Comment From: Bill Neve

5/07/24 @ 12:35 PM

I just wanted to make a general comment that when Ecology posts proposed changes to an existing document, it would be very helpful if Ecology would post the review draft with the proposed changes highlighted or otherwise identified in some fashion.

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