Comment Log Display

The Department of Water Resources (DWR) has broad responsibilities
for water management and planning for California, as well as for
the operation of the State Water Project (SWP).  DWR is a member of
the Governor’s Climate Action Team, has achieved Climate Action
Leader status from The Climate Registry, and is actively assisting
the California Air Resources Board in implementing the AB 32
Scoping Plan.  The Department respectfully submits these comments
on the Supplement to the Functional Equivalent Document for the AB
32 Scoping Plan, related to the California Water Plan Update and
the SWP.

First, the subject document includes unclear statements and
mischaracterizations about the California Water Plan Update, the
state’s strategic plan for water resources.  Specifically, the
Supplement states that the Water Plan presents three potential
scenarios for conditions in 2050, and that all three scenarios
indicate a growing demand for water.  In fact, one of the three
plausible scenarios, called “Slow and Strategic Growth,” indicates
less overall demand for water.  More importantly, though, these
scenarios are intended to be the basis for measuring the resiliency
of future water policies and actions, rather than to simply
underscore how much water demand is expected to grow (or not).  The
document also states, without reference, that water shortages in
California may get worse at a “rate of approximately two to three
percent per year.”  Without citation, it is unclear the basis for
this prediction, one that is not included in the Water Plan. 

Second, DWR remains concerned regarding the allocation of
allowances under the Cap & Trade element of the Scoping Plan, as
proposed in the current draft regulation. The concern specifically
relates to:  1) the equity of declining to provide DWR with
allowances reflecting its energy consumption, and instead giving
away those allowances to public and private utilities; and 2) the
lack of analysis of the potential environmental and economic
impacts of Cap & Trade on the SWP and the agencies and consumers
that receive SWP water.