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California AB2619 adds data‑center demand to urban water shortage planning

Requires urban water suppliers to quantify data center water use in annual supply‑and‑demand assessments and shortage plans, forcing planners and operators to confront data center water risk.

The Brief

AB2619 amends California Water Code Section 10632 to require urban water suppliers to include “data center demand” among the key data inputs when conducting annual water supply and demand assessments and when preparing water shortage contingency plans. The bill leaves intact existing plan elements—standardized shortage levels, response actions, communications, enforcement, and financial analysis—but explicitly adds data centers to the list of quantified demands suppliers must consider.

This change matters because data centers are concentrated, high‑intensity water users in parts of California and their growth can materially change local demand profiles. By forcing suppliers to quantify and plan around data center demand, the bill affects water suppliers' modeling, customer engagement, drought response tools, and potentially contracts with large commercial customers and regional planners.

At a Glance

What It Does

The bill inserts “data center demand” into the required key data inputs for the annual water supply and demand assessment and into the water shortage contingency plan framework, without creating a new regulatory authority or special exemptions. It preserves the statutory six shortage levels and the required set of shortage response actions and financial analyses.

Who It Affects

Urban water suppliers in jurisdictions with data centers, data center operators and their landlords, municipal water managers, and local governments that coordinate emergency proclamations will be directly affected. Regions with existing or planned large data center campuses — e.g., parts of the Bay Area, Sacramento region, and Inland areas — will see the most operational impact.

Why It Matters

Including data centers reveals and allocates a previously under‑tracked demand source, which changes risk assessments and could shift where and how shortage responses are designed and implemented. For planners and compliance officers, the bill creates a new information requirement and a potential point of negotiation with high‑use commercial customers.

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What This Bill Actually Does

California law already requires urban water suppliers to prepare water shortage contingency plans as part of their urban water management plans and to run annual supply‑and‑demand assessments that feed those plans. AB2619’s single, targeted amendment is to add “data center demand” to the enumerated key data inputs suppliers must use when assessing current‑year, one‑dry‑year (and optionally multi‑dry‑year) reliability.

That means suppliers must identify and quantify how much water data centers consume and explicitly fold those figures into shortage modeling and planning decisions.

Practically, the bill ties that data‑center figure into the existing mechanics: the annual decisionmaking process, the definition of shortage levels, the suite of supply augmentation and demand reduction actions, and the requirement to estimate how much each action will reduce the supply‑demand gap. The amendment does not specify a minimum threshold for what qualifies as a data center, how often operators must report usage, or confidentiality protections; those implementation details remain with suppliers and any implementing regulations or inter‑party agreements.Because the statute already demands communication protocols, enforcement procedures for retail suppliers, financial consequence descriptions, and plan availability to local governments and customers, the addition of data center demand creates a new driver for those existing sections.

Suppliers will need to obtain consumption data or estimates from data center customers (or develop reasonable proxies), document how that load affects revenues and emergency responses, and reflect it in public communications and potential customer compliance frameworks.On the operational side, water agencies will need to adapt modeling assumptions, develop methods to meter or estimate data center usage, and consider whether shortage response actions should treat data centers differently (for example, voluntary vs mandatory reductions, temporary curtailments, or contractual renegotiations). The bill leaves those policy choices to suppliers but makes data center demand a mandatory planning input.

The Five Things You Need to Know

1

AB2619 adds “data center demand” explicitly to the list of key data inputs in Section 10632(a)(2)(B) that urban water suppliers must use in annual supply and demand assessments.

2

The statute continues to require six standard shortage levels (up to 10%, 20%, 30%, 40%, 50%, and >50% shortages) but allows suppliers with existing categories to cross‑reference to those six.

3

For each shortage response action, suppliers must estimate how much that action will reduce the gap between supplies and demand (Section 10632(a)(4)(E)).

4

Urban retail water suppliers must maintain customer compliance, enforcement, appeal, and exemption procedures tied to triggered shortage actions (Section 10632(a)(6)).

5

Suppliers must make the adopted water shortage contingency plan available to customers and any city or county served no later than 30 days after adoption (Section 10632(c)).

Section-by-Section Breakdown

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Section 10632(a)(2)(B)(vi)

Add data center demand to required assessment inputs

This clause is the bill’s operative insertion: it requires suppliers to include a description and quantification of data center water demand among the inputs for the annual supply and demand assessment. Practically, agencies must decide how to measure demand (actual metering, bills, operator reports, or modeled estimates), whether to disaggregate different kinds of data‑center water use (e.g., evaporative cooling vs. domestic use), and how to handle commercial confidentiality when publishing plan documents.

Section 10632(a)(3)

Standardized shortage level framework retained

The statute preserves the six shortage levels and instructs suppliers to calibrate those bands to local conditions (percent reductions, groundwater declines, surface water changes, or catastrophic interruptions). This keeps a common planning vocabulary but requires suppliers to map local indicators — potentially including data‑center loads — to those standardized bands.

Section 10632(a)(4)

Shortage response actions and quantification requirement

Suppliers must list supply augmentation, demand reduction, operational changes, and additional prohibitions appropriate to each shortage level and, critically, estimate how much each action will reduce the supply‑demand gap. Including data center demand forces agencies to model the impact of actions that affect large commercial customers and demonstrate effect sizes in their contingency plans.

4 more sections
Section 10632(a)(5)–(6)

Communications, enforcement, and customer procedures

Existing obligations to notify customers, local governments, and state agencies about current or predicted shortages now apply with data‑center visibility. Retail suppliers must maintain enforcement, appeals, and exemption processes for triggered actions; incorporating data centers will compel agencies to decide whether operators fall under the same compliance mechanisms as residential users or require distinct contractual remedies.

Section 10632(a)(7)–(8)

Legal authority and financial impact disclosures

Suppliers must describe the authorities they will use to implement actions (statutes, ordinances, contracts) and outline revenue and expense impacts of activated shortage responses plus mitigation measures. Data centers’ large usage and commercial contracts mean agencies will need to analyze potential major revenue shifts, stranded costs, or mitigation funding tied to industry curtailment or incentives.

Section 10632(b)

Separate treatment of artificial water features

The bill preserves the requirement to analyze artificially supplied water features separately from pools and spas. That procedural rule matters because data centers sometimes use decorative or process water features on site; suppliers must distinguish those loads from the core data‑center process cooling demand when quantifying usage.

Section 10632(c)

Public availability of adopted plans

Suppliers must make their adopted shortage contingency plans available to customers and affected cities/counties within 30 days. That public disclosure requirement raises the confidentiality question: if plans must include quantified data center demand, suppliers will have to reconcile public transparency with any confidentiality promises made to commercial customers.

At scale

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Who Benefits and Who Bears the Cost

Every bill creates winners and losers. Here's who stands to gain and who bears the cost.

Who Benefits

  • Local water planners and regulators — gain visibility into a concentrated, growing commercial demand that materially affects reliability models and drought responses, enabling more targeted risk management and interagency coordination.
  • Communities in data‑center regions — benefit from better‑informed contingency plans that reduce the chance of unanticipated shortages and improve communication during droughts or emergencies.
  • Environmental and watershed managers — receive better data for protecting groundwater, surface water, and ecological flows because planners must account for high‑intensity industrial withdrawals and plan mitigation actions.

Who Bears the Cost

  • Data center operators and owners — face new expectations to disclose usage or accept agency estimates, possible inclusion in mandatory curtailments, renegotiated supply contracts, or new conservation requirements.
  • Urban water suppliers — absorb the administrative burden and modeling work to collect, validate, and publish data center demand estimates, and may face political pressure when proposing commercial curtailments or rate changes.
  • Local governments and emergency coordinators — may incur coordination costs and political friction when aligning proclamations and customer‑facing communications, and could be asked to negotiate or arbitrate exemptions or compliance disputes.

Key Issues

The Core Tension

The central dilemma is between public‑interest water planning — which requires full, transparent accounting of concentrated commercial demands to protect community supplies and ecosystems — and private commercial interests in confidentiality and economic continuity for data centers; the bill forces suppliers to choose how transparent and aggressive to be without providing a clear statutory rulebook.

The bill is narrowly targeted — it does not create a separate regulatory regime for data centers and leaves key implementation choices to urban water suppliers. That delegation creates variability: some suppliers will seek exact metered data; others will rely on rough estimates or aggregated billing data.

The absence of a statutory definition for “data center,” a reporting cadence, or confidentiality protocols means implementation could be uneven across jurisdictions and invite legal or commercial pushback.

There is also a practical tension between transparency and contractual confidentiality. Making adopted plans public within 30 days forces suppliers to balance disclosure obligations with nonpublic commercial information in existing contracts.

Suppliers may respond by anonymizing data, publishing ranges, or seeking non‑disclosure arrangements — each approach changes the utility of the data for downstream planners and regulators.

Finally, because the bill does not specify how data‑center demand should be treated in shortage responses, suppliers will confront policy choices with distributional effects: treat data centers as industrial users eligible for negotiated reductions and exemptions, or apply the same mandatory prohibitions used for residential customers. Those choices will shape revenue impacts, enforcement burdens, and regional competitiveness for data center siting.

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