Drought Contingency Plans: Are You Prepared? By Allison Kaminsky, Deputy Executive Director, Texas Rural Water Association
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very year, regions of Texas deal with drought to some degree. Though most concerning in summer months when irrigation and water use is at its peak, a drought can happen any time of year. According to the U.S. Drought Monitor, the longest duration of drought in Texas lasted 271 weeks beginning in May 2010 and ending in July 2015. When a system is in a time of drought, water emergency or high usage that requires conservation, having a Drought Contingency Plan in place will help curtail water use. Whether you have one in place or are working on developing one, it is important to know the essentials of a Drought Contingency Plan. A Drought Contingency Plan should be comprehensive and should include all possible variables that will secure enough capacity to meet a drought event. If you need to start from scratch, do you know what you need to be looking for and what to include? If you already have one in place, have you audited it to ensure you’re not missing something important? Hopefully, this article will help you in either scenario. First, let’s look at rules governing Drought Contingency Plans and how they apply to your system. The mandate requiring these plans for certain entities is found in Texas Water Code Section 11.1272. What needs to be contained within these plans, as well as filing requirements, are set forth in Title 30 Texas Administrative Code Chapter 288. The following entities must develop, implement, and submit a Drought Contingency Plan every five years: • • •
Retail public water suppliers with more than 3,300 connections* Irrigation water providers (Irrigation Districts) Wholesale public water suppliers
*It is important to note that retail public water suppliers with less than 3,300 connections still must prepare and adopt an updated Drought Contingency Plan and make the plan available for inspection by TCEQ, but they are not required to submit plans to TCEQ every 5 years. 16
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According to these rules, the minimum requirements for these plans include the following: • • • •
• • •
• • •
A plan to actively inform the public and provide opportunity for public input A plan for continued public education and information Documentation of coordination with the regional water planning groups for the area A description of information to be monitored by the water supplier, and specific criteria for the initiation and termination of drought response stages, as well as explanation and rationale for the triggering criteria Drought or emergency response stages Targets for water use reductions Water supply or water demand management measures to be implemented at each stage of the plan, including limitations on non-essential water use and utilization of alternative water sources Initiation and termination procedures for each stage of drought response, including plans for notifying the public Procedures for granting variances to the plan Procedures for enforcement of mandatory water use restrictions, including specific penalties
As you can see from the requirements, a Drought Contingency Plan is not just an outline of stages you need to implement that you can copy and paste every five years to meet the reporting requirements. Instead, this plan is a detailed, complex document that helps systems prepare for and manage a drought event while attempting to minimize the economic, social and environmental impacts of a drought. Public involvement and education are an essential first step in developing your plan, so be sure to get your community involved. Your instinct may be to want to leave the public out of the planning process, saying “nobody comes to the meetings” or “all they want is water,” but engaging with community stakeholders who are invested in
