"Water is even more essential than electricity," says Dan Smith, ACWA's director of regulatory affairs. "We do not believe there is justification to reject and ignore the need to assure that water agencies at all times are able to consistently provide adequate supplies of good quality water."

ACWA prepared comments in response to a draft decision issued back in March by the CPUC not to classify water utilities as "essential facilities" exempt from rotating power outages. ACWA is appealing to the full commission for blackout protection. (As of press time, the PUC had not made a final decision.)

"Undermining the reliability of water service is not only a risk for public health, safety and welfare, it also could threaten many economic activities and the basic economic stability of many communities and the state itself," Smith says.

While many water utilities maintain back-up power generators, those systems have been designed for use in emergencies such as floods, fires or earthquakes. They are not intended for use as alternative power sources. Sudden outages and power surges also can create mechanical problems for water utility equipment, resulting in extended down time beyond the period of the blackout.

If an agency's water treatment facilities are disrupted by a power outage, a two-hour blackout can result in a two-day interruption in providing safe drinking water as equipment is brought back on line and potentially contaminated water flushed from the system.

ACWA described the current blackout policy for water agencies as inadequate. At present, a water agency may request to be excluded from a blackout or to have electric service restored if necessary because of an emergency, such as firefighting.

The association warns that trying to communicate with a power company to restore power in the event of a fire emergency would be problematic at best. By the time power is restored, it could likely be too late.