Comment Letter: Groundwater Trading Dec 6, 2021 Comment Letters Agency: California Water Commission Subject: A State Role in Guiding Groundwater Trading that Safeguards Communities, Ecosystems, and Small Farms Letter excerpt: ACWA represents more than 460 public water agencies that collectively deliver approximately 90 percent of the water used in California for domestic, agricultural, and industrial uses. Action 3.6 of the Water Resilience Portfolio calls on the State to create flexibility for groundwater sustainability agencies (GSAs) to trade water within basins by enabling and incentivizing transactional approaches, including groundwater markets, with rules that safeguard natural resources, small- and medium-size farms, and water supply and quality for disadvantaged communities. ACWA supports the Commission’s work to develop a whitepaper that guides the State’s continued work on Action 3.6. Download Comment Letter