Community Water Systems Frequently Asked Questions
1. How do I know if my water system is a Community Water System?
A Community Water System serves at least 15 connections used by year-round residents of the area served, or regularly serves at least 25 year-round residents. The Arizona Department of Environmental Quality makes this determination.
2. What is an Annual Water Use Report?
The Annual Water Use Report includes such information as water pumped or diverted, water received from other suppliers, water delivered to customers, and effluent used or received.
3. What is a System Water Plan?
The System Water Plan consists of three components:
‣ Water Supply Plan – describes the service area, transmission facilities, monthly system production data, historic demand for the past five years, and projected demands for the next five, 10 and 20 years.
‣ Drought Preparedness Plan – includes drought and emergency response strategies, a plan of action to respond to water shortage conditions, and provisions to educate and inform the public.
‣ Water Conservation Plan – addresses measures to control lost and unaccounted for water, considers water rate structures that encourage efficient use of water, and plans for public information and education programs on water conservation.
4. What are the due dates for the Annual Water Use Reports and System Water Plans?
‣ System Water Plan Updates are due every five years after the initial System Water Plan is submitted. The next set of updates are as follows:
Large Systems - due January 1, 2022 and addresses 2016-2020
Small Systems - due January 1, 2023 and addresses 2017-2021
‣ Annual Water Use Reports are due every year by June 1st. Each report will include the previous year’s data.
5. Is there a guidance document available to assist me in reporting my annual water use information?
No, all the necessary information and instructions are included in the Annual Water Use Report forms.
6. Is there a form I can use to report my annual water use, or can I enter the data on the internet?
7. Are there any existing System Water Plans that I can use as a resource for developing my own plan?
Many larger cities and towns in Arizona do have some type of drought management plan in place. You may want to check city websites or contact towns in your area for ideas for your own plan. ADWR encourages information and idea sharing, especially among systems in the same area. A regional approach to drought planning and management may allow systems to pool resources and coordinate not only planning activities but drought mitigation and response actions as well.
There are many valuable resources to aid in plan development available on the Community Water System Program website: a guidance document for the System Water Plan form which gives information and ideas to preapre a Drought Preparedness Plan and a Conservation Plan, population projection and water estimation tools, and numerous drought and conservation links and documents.
8. Why are Community Water Systems required to submit Annual Water Use Reports and System Water Plans?
These requirements were established by Arizona House Bill 2277 passed by the Arizona Legislature in 2005 and then established in Arizona Revised Statutes Title 45, Chapter 1, Article 14. The requirements were part of a larger set of recommendations made by the Governor's Drought Task Force. The reports and plans are intended to reduce Community Water Systems’ vulnerability to drought and ensure that water providers are prepared to respond to drought or water shortage conditions. The information submitted by the water systems will also allow the State to provide regional assistance for drought planning, mitigation and response.
9. Are these new requirements intended to regulate or restrict my water use?
No, these requirements are intended to serve as an information-gathering tool for the State. As drought conditions have worsened over the past several years, the State has been asked to provide drought planning assistance. However, the State had no means of gathering information to begin the planning process. Thus, the information submitted under these new requirements will enable the State to provide regional assistance for drought planning, mitigation and response.
10. My water system is very small. Do I have to meet the same requirements as large systems?
The basic requirements for large and small systems are the same. ADWR has developed a form that can be filled out and submitted as the system water plan. See the Community Water System home page for the form and other helpful materials.
11. What happens if I do not submit the Annual Water Use Report or System Water Plan?
‣ Annual Water Use Report – If you do not file the report by June 1st of each year, ADWR will send you a noncompliance letter notifying you that you have 60 days to file the report. If the report is not filed after 60 days, ADWR must provide notice of noncompliance to the governing bodies of the cities, towns, and counties located in your service area.
‣ System Water Plan – If you do not submit your plan by the due date, ADWR will send you a noncompliance letter notifying you that you have 120 days to submit the plan. If the plan is not received by the end of this period, ADWR must provide notice of noncompliance to the governing bodies of the cities, towns, and counties located in your service area.
12. Will I hear back from ADWR about whether or not my submittals were adequate?
‣ Annual Water Use Report – ADWR will contact you if the report is not received (see #11 above).
‣ System Water Plan – ADWR will review the plans and notify you whether or not your plan meets the requirements. If the plan complies, ADWR will provide a written notice of compliance.
If the plan does not comply, ADWR will send you a noncompliance letter notifying you that you have 120 days to submit a revised plan.
If a revised plan is not received by the end of this period, or still does not meet the requirements, ADWR must provide notice of non-compliance to the governing bodies in your service area.
13. Why should I encourage my customers to conserve water when it may cause my business to lose money?
ADWR recognizes that some water providers rely on water use to sustain their business and cover costs. However, conservation does not necessarily lead to lost revenue. For example, one way to reduce drought vulnerability and encourage customers to conserve is to implement rate structures that are higher for excessive water use or are higher during certain seasons. Also, bear in mind the long-term costs that may result as water supply dwindles. Providers may have to deepen wells, construct new storage facilities, or drill new wells. Water conservation is an excellent way to reduce drought vulnerability and guard against these large expenditures on new infrastructure. In short, reducing vulnerability to drought now can be less expensive than dealing with water shortages later.
14. How can I encourage my customers to conserve water, given that conservation is a voluntary practice?
It is true that water conservation is a voluntary practice in most cases. It is up to each water system to be creative and consider what might work for its customers. The most successful conservation programs are those that are tailored to the needs and lifestyles of the customers who are being asked to conserve. You might want to consider surveying your customers to help you design a conservation program. Do not rely simply on penalizing bad practices (i.e. excessive use rates); remember also to encourage or reward good conservation practices (e.g. offering conservation materials, workshops or rebate programs). Although you may not reach 100% of your customers with your efforts, every little bit will help.
15. I already submit an annual report to the Arizona Corporation Commission (ACC). Do I need to submit a separate report to ADWR?
Yes. Because there is minimal overlap between the reports, you will need to submit a separate report to both agencies.
16. I already submit an annual water use report to ADWR because I am within an Active Management Area. Do I need to submit a separate report to the Community Water System program?
No, systems in an Active Management Area already submitting an annual report to ADWR are exempted in the statute from submitting the Annual Water Use Report to the Community Water System program (note: you are still required to submit the System Water Plan).
17. I already submit an annual report to ADWR because I have an Adequate Water Supply designation. Do I need to submit a separate report to the Community Water System Program?
Yes, systems with an Adequate Water Supply designation must still submit an Annual Water Use Report to the Community Water System Program. The report you are currently submitting does not include sufficient information to meet the new reporting requirements.
18. I already submit an annual report to ADWR because I have an Assured Water Supply designation. Do I need to submit a separate report to the Community Water System program?
No, you are exempt from the Annual Water Use Report to the Community Water System program (note: you are still required to submit the System Water Plan).
19. I have an Adequate Water Supply Designation. Do I need to submit a System Water Plan?
Systems with an Adequate Water Supply Designation are not automatically exempt from the Water Supply Plan section of the System Water Plan. However, the statute does allow systems to request exemptions if they believe they have already submitted all the required information to ADWR. In most cases, it is probably best to go ahead and submit the plan. The System Water Plan form should simplify the process for you.
20. I have already submitted maps of my system and service area to ADWR. Do I need to submit another copy as part of the WATER SUPPLY Plan SECTION?
If you are within an Active Management Area (AMA), the statute provides an exemption from the map requirement if the maps have already been provided to ADWR.
21. I am already required to have an Emergency Operations Plan (EOP) by the Arizona Department of Environmental Quality (ADEQ), and it includes planning for water shortages. Will this meet the Drought Preparedness Plan requirements of the System Water Plan?
In most cases, an EOP will probably not meet the requirements of the Drought Preparedness Plan, Part 2 of the System Water Plan. Remember that the purpose of the Drought Preparedness Plan is to plan for drought and reduce the vulnerability of the system, not just respond to an emergency. You are required to develop drought response stages and management measures for each of these stages, with the goal of preventing an emergency situation. You may be able to incorporate parts of your EOP into this portion of the Drought Preparedness Plan, or vice versa.
22. I have a curtailment tariff on file with the Arizona Corporation Commission (ACC). Can I use this as part of my Drought Preparedness Plan?
Yes, a curtailment tariff is sufficient to meet one of the requirements of the Drought Preparedness Plan: 45-342(I) (3) (c) (management measures for each stage of drought). You may include it in your plan or refer to it as an attachment at the end.
23. I have already implemented conservation measures because I am a large municipal provider in an Active Management Area (AMA). Do I still have to submit the Water Conservation Plan?
No, large municipal providers in an AMA are exempt from the Water Conservation Plan portion of the System Water Plan.