for his thoughtful review, insight, and unfailing support, and to Miles Hogan, 2012-2013 Environmental Law Fellow at the California Environmental Law and Policy Center, UC Davis School of Law, for invaluable research and collaboration. I am also indebted to the wonderfully patient staff at the McGeorge Law Review. All errors, opinions, and passive voice violations are entirely my own. 2014 / Water Neutral Development in California 104 I. INTRODUCTION Urban water use efficiency is lauded as the best source of "new" water for drought-prone California. 1 Recurring droughts have energized the state's search for improved urban efficiency, starting with the severe drought of 1976-1977, which is credited with sparking a trend of legal, policy, and technical innovation that continues today. 2 As a result of these innovations, studies demonstrate that some cities are decreasing per capita consumption and using less water, despite growing populations. 3 Water use efficiency has been touted as one of the most promising, and least expensive, sources of water for California. 4 Programs that require "water neutral development," often referred to as "demand offset programs," 5 are one of the innovations inspired by drought.