What California's new data inventory law means for water managers
Senator Hertzberg's SB 272, signed into law by Governor Brown on October 11th, amends the California Public Records Act to require local governments in California to inventory their enterprise data management systems and catalog the following information on their website:
(1) Current system vendor.
(2) Current system product.
(3) A brief statement of the system’s purpose.
(4) A general description of categories or types of data.
(5) The department that serves as the system’s primary custodian.
(6) How frequently system data is collected.
(7) How frequently system data is updated.
The law categorically exempts school districts and provides several exemptions, including an infrastructure clause pertinent to water utilities:
"Infrastructure and mechanical control systems, including those that control or manage street lights, electrical, natural gas, or water or sewer functions."
Yet data on conservation programs like turf rebates (which have already been disclosed to newspapers under the California Public Records Act) would not be exempted from the law. Further, although disclosing actual customer's water usage publicly is prohibited per a 1997 amendment to the California Public Records Act, nothing in this new law exempts disclosing the above enterprise data management catalog information on what billing system a water utility uses or how the utility tracks water production. (Utility's already report aggregated water usage metrics publicly to the SWRCB and DWR.)
Yet another mandate or an opportunity to get smarter about how we manage water?
The law requires these catalogs to be posted on agencies websites by July 1, 2016 and updated annually thereafter. Combined with the ongoing DWR Urban Water Management Planning, SWRCB conservation reporting, IRWMP development and other requirements, this new law could easily feel like a "yet another mandate" coming out of the blue from the state.
Properly implemented, however, this cataloging of data management systems provides a big opportunity for water managers with a couple key benefits:
- The state will likely have some form of future water efficiency regulations beyond the current 25% mandatory reductions and inventorying available water usage data provides an opportunity to get smarter about what metrics are used long term.
- Sharing information on what billing system and other data management vendors utility's use provides an opportunity to more rapidly surface best practices and avoid billing horror stories like LADWP. Data management vendors regularly track market penetration and sharing this information across utility's will help the water community get smarter about procuring data management technology.
- Currently, the SWRCB is working to implement the Governor’s executive order #8, which requires agencies to adopt conservation based pricing. Such rate structures like water budgets require robust historical usage data along with household size, evapotranspiration and irrigable area. Improving how we manage data can thus help support utilities that elect to shift to such rate structures.
The bill was just passed two weeks ago and I haven't seen any other water specific analysis of its implications. So consider this blog post preliminary. Yet rather than wait for potential legal actions working to force compliance post July 2016, water utilities have an opportunity here to proactively work together to improve our community's data systems so that we can improve how we measure and thus manage water in California.