Telemetry Requirements of the Water Measurement and Reporting Regulation

The telemetry requirements of the Water Measurement and Reporting Regulation (Regulation, often referred to as SB-88) require applicable diverters to measure their diversions and post their data to a public website. The Regulation is found in California Code of Regulations, title 23, sections 931 through 938, with telemetry requirements described in section 933(b)(4). For more information regarding the general requirements of the Regulation and how to comply, please refer to the Water Measurement and Reporting Regulation website.

Diverters who do not comply with the Regulation, including telemetry requirements, are subject to fines of up to $500 per day and other consequences. If you need assistance complying with the Regulation, please contact Division of Water Rights (Division) staff at DWR-Measurement@Waterboards.ca.gov.

Announcements

The State Water Board is proposing changes to the Water Measurement and Reporting Regulation. Please visit the Water Measurement and Reporting Regulation Rulemaking webpage for more information.

New and updated guidance documents and compliance assistance resources are available on the Water Measurement and Reporting Regulation website.

What Are Telemetry Requirements?

The telemetry requirements, described in section 933(b)(4) of the Regulation, require applicable diverters to publish their diversion data to a public website. This requirement only applies to the largest diverters in the state. These diverters must comply with the telemetry requirements regardless of whether diversion data is collected via a Measuring Device, Measurement Method, or Alternative Compliance Plan.

Why Do Telemetry Requirements Exist?

The telemetry requirements of the Water Measurement and Reporting Regulation aim to address California's need for more timely and accurate data on how much water is being diverted at specific locations. Although telemetry requirements only apply to the largest diverters in the State, this group accounts for more than 90 percent of the surface water diverted in California. Since large diversions are more likely to impact stream conditions and the availability of water resources, having more timely data for these diversions helps the State Water Resources Control Board (State Water Board) better understand the availability of water in near-real-time. With this data, the State Water Board can more effectively:

  • Administer the water rights priority system
  • Protect public trust resources
  • Understand and plan for limited water supplies
  • Assure compliance with limitations on the quantity and diversion seasons of existing water rights
  • Protect the senior rights of diverters in accordance with their relative priorities
  • Improve water planning and near-term forecasting of water demand

Am I Subject to Telemetry Requirements?

Diverters who meet any of the following criteria must adhere to telemetry requirements:

  • Have an authorized diversion of more than 10,000 acre-feet per year
  • Own or operate a storage facility with a storage capacity of 10,000 acre-feet or more
  • Directly divert more than 30 cubic feet per second at any time during the period from June 1 through September 30
  • Divert during the period from June 1 through September 30, have water right(s) or claim(s) to more than 20% of historical calculated mean monthly streamflow as measured by a stream gage with publicly available records maintained by the U.S. Geological Survey, the California Department of Water Resources, the U.S. Army Corps of Engineers, or the State Water Board, and meet any of any of the following conditions:
    • Threatened, endangered, or fully protected fish species are or have historically been present in the stream from which water is diverted
    • The diversion is made from a stream that is part of the State Water Board's North Coast Instream Flow Policy area
    • The diversion is made from the Deer Creek, Mill Creek, or Antelope Creek subwatersheds in the Sacramento River watershed
    • The diversion is made from the Mark West Creek, Green Valley Creek, Mill Creek, or Dutch Bill Creek subwatersheds in the Russian River watershed
  • The combined authorized diversion volumes or rates for multiple water rights/claims that share a point of diversion or place of use meet any of the above criteria.

How Do I Comply with Telemetry Requirements?

Diverters who are subject to telemetry requirements must comply with all of the following requirements:

  1. Measure diversions at the frequency and accuracy specified by the Regulation, as described on the Water Measurement and Reporting Regulation website.
  2. Post daily diversion data to a publicly accessible webpage which is updated weekly. The webpage should include data for the water year to-date but can be reset at the beginning of each new water year. The water year is defined as the 12-month period beginning October 1 of the previous year and extending through September 30 (e.g., water year 2024 extends from October 1, 2023, through September 30, 2024). See additional website guidance below.
  3. When completing Annual Reports through the Report Management System (RMS), submit all of the following to the State Water Board:
    1. A datafile containing diversion data, as required by the Water Measurement and Reporting Regulation, uploaded as an attachment to the Annual Report (datafile templates are available on the Water Measurement and Reporting Regulation website)
    2. Conversion methodology and formulas used to calculate volume of water diverted, uploaded as an attachment to the Report of Measurement Device within the Annual Report (this form only needs to be completed once for each Measuring Device)
    3. The URL for the public webpage where telemetry data is posted, entered in the "Telemetry Information" section of the Report of Measurement Device form within the Annual Report (this form only needs to be completed once for each Measuring Device)

Note: Telemetry data must be displayed at a daily timestep at a minimum. For authorized diversions of more than 10,00 acre-feet, however, datafiles submitted with Annual Reports are required to contain measurement data collected at a higher frequency (see the Water Measurement and Reporting Regulation website). Annual Reports are due to the State Water Board by February 1 of the following water year (e.g., Annual Reports for water year 2024 will contain data from October 1, 2023, through September 30, 2024, and must be submitted by February 1, 2025).

Webpage Requirements

Telemetry data must be posted at least weekly to a webpage that is accessible to the public, without requiring login credentials. The webpage can be owned and maintained by the diverter or by a third-party provider. The webpage URL must be included in the diverter's Annual Report(s) in the "Telemetry Information" section of the Report of Measurement Device form within the Annual Report. This URL must link directly to a webpage that displays data for a single water right or claim. See additional webpage best practice guidance below.

The Deputy Director of the Division of Water Rights may request that a diverter provide telemetry data in a format that is retrievable and viewable by either Microsoft Excel, Microsoft Access, or another authorized software program. Generally .csv, .xls, .xlsx, .txt, and .dat files would meet this requirement.

Telemetry Webpage Best Practices

The State Water Board suggests but does not require that telemetry webpages include the following components at a minimum:

  • Webpage headings indicating the Water Right ID and Measuring Device ID
  • Data for only a single water right or claim (i.e., data for each water right/claim should be provided on separate webpages)
  • Date and time associated with each measurement for the current water year to-date
  • Measurement data, including all of the following:
    • Descriptive column headings in the first row
    • Measured value (the raw/unaltered data measured by the Measuring Device or Measurement Method)
    • A separate column of QA/QC'd values correcting for known or suspected errors, to be used in subsequent calculations
    • Data flags identifying known or suspected errors (if applicable)
    • The rate (volume per unit time) and volume of water diverted pursuant to the relevant water right/claim in each timestep, presented as discrete (not cumulative) values

Units of measured values written out in their entirety without abbreviation (for example, "acre-feet" should be used instead of "AF" or "acft")

Frequently Asked Questions (FAQ)

The Water Measurement and Reporting Regulation FAQ contains general information about both the regulation and telemetry requirements. If you have any additional questions, please refer to the Water Measurement and Reporting Regulation website or contact DWR-Measurement@Waterboards.ca.gov.

  1. How often do I need to post telemetry data?

    Telemetry data must be posted at least once per week to a public website. The data must include at least daily diversion measurements.

  2. Is there a specific website where I should post my telemetry data?

    No, any webpage that is publicly accessible without login credentials is acceptable for posting telemetry data. Such a webpage can be owned and maintained directly by the diverter or by a third-party provider and should follow best practices. As part of a water rights data modernization effort, the State Water Board is developing a new water accounting, tracking, and reporting platform that is anticipated to make the direct posting of telemetry data easier.

    When completing Annual Reports, diverters must provide an active link to their telemetry webpage.

  3. If I comply with the Regulation through a Measurement Method or Alternative Compliance Plan, do I still need to adhere to telemetry requirements?

    Yes, all diverters who are subject to telemetry requirements must post their data to a public webpage. Some Alternative Compliance Plans may specify other means of data submittal; please contact the Division of Water Rights to discuss how to post data in a manner that is compliant with the Regulation.

  4. I did not divert any water this year. Do I still need to post telemetry data?

    Yes, the applicability of telemetry requirements is based on authorized diversion amounts (for permits, licenses, and registrations), capacity of storage facilities (for registrations), and maximum past diversions or future intended diversions (for statements of diversion and use). Even if you do not divert any water within the 12-month reporting period, you are still required to post telemetry data to a public website, even if all entries are "0" (the lack of a telemetry webpage is not the same as a webpage containing all zeros). The Division is currently evaluating alternative ways of complying with the regulation and reporting zero diversions.

  5. Do I need to measure and post telemetry data for the entire year, or just during my diversion season?

    Diverters who are subject to telemetry requirements are required to measure and post their data throughout the entire year. For periods when no diversion occurs, posted measurement data should reflect zero diversion. The Division is currently evaluating alternative ways of complying with the regulation and reporting zero diversions.

  6. If I am subject to telemetry requirements, do I still need to submit a datafile with my Annual Report?

    Yes, all diverters who are subject to the Regulation must submit datafiles with their Annual Reports. Datafiles submitted with Annual Reports should contain data collected at the applicable frequency specified by the Regulation. This frequency may be higher than is required by the telemetry requirements (which require daily data). Datafile templates are available on the Water Measurement and Reporting Regulation website.

  7. What if there was a period during my diversion season when I was unable to measure my diversion (e.g., due to inaccessibility, weather, malfunctioning device, etc.)?

    Diverters should flag any missing measurements or raw data known to be incorrect rather than estimate missing values. If possible, diverters should use a corrected or QA/QC'd value in any subsequent calculations (e.g., to determine the volume of water diverted). If device repairs or replacement are required to fix erroneous data, these must be done by a Qualified Individual.

  8. Should I post raw data from my Measuring Device(s), or should I post QA/QC'd data or data containing calculations?

    Telemetry data should contain the raw, unaltered data recorded by a Measuring Device or collected through a Measurement Method. It may also include a separate column containing QA/QC'd values correcting for known or suspected errors. Please flag any missing measurements or data known to be incorrect. Use the corrected or QA/QC'd value in any subsequent calculations (e.g., to determine the total volume of water diverted). It is recommended that QA/QC be done as early as possible after the measurement data is collected and no later than the submittal of the Annual Report.

  9. My diversion occurs at a remote location without reliable internet or cellular signal. How can I comply with telemetry requirements?

    Telemetry data does not need to be automatically transmitted and uploaded through traditional "telemetry" technologies (e.g., Application Programming Interfaces [APIs] or radio transmission). Diverters have the option to manually record and post daily measurement data to their telemetry webpage as long as it is updated at least weekly. Diverters may also submit an Alternative Compliance Plan if they can provide substantiative documentation that they meet the criteria for being unable to strictly comply with the telemetry requirements (outlined in section 935 of the Regulation) and how they intend to alternatively comply.

  10. How long am I required to keep records of my data?

    Diverters must keep records of their measurement data for no less than 10 years. Telemetry data only needs to remain posted on the associated webpage for the current water year (October 1 of the previous calendar year through September 30 of the current calendar year).

  11. I recently bought a property with a Statement of Diversion and Use/Riparian Claim. Am I subject to telemetry requirements based on the previous owner's water usage?

    For riparian claims on recently acquired properties, the applicability threshold is based on the maximum future intended use. A previous owner's historical water use will not affect the applicability of the Regulation for current or future riparian claim owners. However, new owners may find it helpful to review previously reported or measured diversions to estimate future uses and determine their diversion measurement obligations.

    For pre-1914 claims, new owners are subject to the regulation based on the water use reported in the initial Statement of Diversion and Use. New owners should review information submitted by previous owners to ensure it accurately reflects the amount of water used under the new ownership.

    For assistance obtaining previous Statements of Diversion and Use, please see the Division's Electronic Water Rights Information System (eWRIMS) database or contact DWR@waterboards.ca.gov or (916) 341-5300.

  12. How do I report telemetry data if I divert through a point of diversion that is shared between multiple water rights/claims and/or other diverters?

    Multiple water rights and/or claims sharing a point of diversion should report and upload a Measurement Method with their Annual Reports, describing how to disaggregate the shared diversion data among multiple rights. Telemetry data should specify the volume of water diverted under each water right/claim. For optimal machine readability, each water right/claim should have its own webpage.

  13. What will happen if I fail to comply with telemetry requirements?

    Diverters who are subject to telemetry requirements but do not post daily diversion data to a public website on a weekly or more frequent basis are subject to civil liability of up to $500 per day and enforcement actions. Please contact the State Water Board as soon as possible and staff will work with you to reach compliance.