Comment Log Display

LACSD offers the following comments on the discussion concerning
Water Strategies in the Draft Scoping Plan:

1.	Page C-81: We believe it is necessary for CARB to review the
actions taken by other state agencies under the umbrella of
climate change to make sure that they are consistent with the
goals of the Scoping Plan. We truly wonder if the WATER section
accomplishes the goal stated in the Overview (to develop
additional [water] supply reliability), and would like to see more
discussion of this in the Scoping Plan.

2.	Page C-82: The wastewater treatment renewable energy resources
estimate of 2,100 GWh/yr. is very optimistic given that continuous
duty reciprocating engine drivers, the primary choice of wastewater
treatment plant operators, are very difficult to install under
today’s AQMPs and distributed generation regulations.

3.	Page C-83: Section W-2 of the Draft Scoping Plan contains
recommendations for reduction of GHG emissions from increased
usage of recycled water.  We fully agree that increased
implementation of recycled water is an important strategy for
reducing GHG emissions, due to the much lower energy demand to
supply recycled water versus imported water in many parts of the
state.

However, the Scoping Plan proposes that increased usage of
recycled water should be accomplished by amending National
Pollution Discharge Elimination System (NPDES) permits to require
preparation and implementation of water recycling plans at
wastewater treatment plants. Communities that rely on imported
water and where water recycling would otherwise require less
energy than current supplies would be targeted. We disagree with
this proposal because it is overly focused on forcing change
through regulation of recycled water producers.  It is overly
simplistic to impose mandates on wastewater treatment plants and
expect these mandates to lead to increased water recycling.  Use
of such a strategy presumes that the major reason that greater
water recycling is not occurring in these areas is because the
wastewater agencies have failed to plan for it or are somehow
recalcitrant.  We submit that this is generally not the case.  For
the majority of agencies, preparation of a water recycling plan
would not serve as a useful tool to increase recycled water usage.
 The only case where it might do so is when agencies face
significant obstacles to expansion of recycled water usage that
are of a political nature, and that is rarely the case.

There are many factors that influence the ability to reuse water,
including the level of treatment of the water, proximity to
customers and use areas, and permitting requirements imposed by
the Regional Water Quality Control Boards and the California
Department of Public Health. Wastewater agencies alone cannot
determine how and where their recycled water is used.  There are a
number of statutory provisions that limit a wastewater agency’s
ability to unilaterally maximize recycled water (e.g., Public
Utilities Code Section 1501 and Water Code Sections 13579-13583). 
Water recycling involves a number of agencies to make a successful
project.  A wastewater agency produces the recycled water, a water
wholesaler transports it, a water retailer sells it, and an end
user buys and uses it.  Local, state, and federal entities
participate in funding.  Regulators permit the use of the recycled
water and assure the protection of public health and water quality.
 If any one of these partners does not participate fully, it is
unlikely that a recycled water project will be successful. 
Finally, it is important to recognize that the cost of obtaining
and serving recycled water in relation to the costs of
alternatives, including local groundwater, conservation, and other
supplies, is one of the most important drivers that determines how
much water recycling occurs.

In lieu of proposing to increase recycled water usage by putting
the entire burden on wastewater agencies, we believe that the
approach to increasing recycled water usage should align with the
approach to increasing water use efficiency proposed in Appendix C
Section W-1.  That is, the DWR should coordinate with the
appropriate parties, such as the water boards, the California
Department of Public Health, and affected stakeholders, to develop
a Recycled Water Action Plan.  This Plan should utilize a range of
tools, including funding and other incentives, technical
assistance, public education and outreach, permitting flexibility,
and regulatory approaches to increase recycled water usage.  For
wastewater treatment plants located in areas using energy
intensive water supplies, development of a water recycling plan
could be required when significant institutional obstacles to
otherwise feasible recycled projects or expanded recycling
projects are identified.

4.	Pages C-83, C-84: As water quality regulations overall become
increasingly stringent and with increased pressures for water
recycling, treatment plants are driven towards more advanced
treatment standards, often beyond the tertiary treatment
considered "advanced" not too many years ago.  The extra effort
required to reach these water quality targets greatly increases
plant energy usage with subsequent increases in GHG emissions. 
When assessing the advantages of local use of reclaimed water vs.
imported water, the actual greenhouse gas reductions may fall
short of initial expectations unless the extra energy needed for
advanced treatment is taken into consideration.  The ARB and
WET-CAT should not neglect the extra energy requirement needed for
advanced treatment in their estimates of the greenhouse gas
benefits of reclaimed water over imported water.

5.	Page C-84: Should the Scoping Plan ultimately approach water
system energy efficiency using an energy intensity basis much like
the LCFS, the options to comply with water cycle energy intensity
targets should be no less creative than what exists for the LCFS
including averaging of supplies and use of credits in addition to
the tools (shifting loads offpeak, intermittent renewable
generation, etc.) mentioned on this page.

6.	Page C-86: Section W-5 of the Scoping Plan addresses increased
renewable energy production from water.  We fully agree that
production of available renewable energy from the water sector
should be maximized.  In particular, gases generated during
treatment of solids at wastewater treatment plants should be used
for energy production to the maximum extent possible.  However,
state and local air quality rules governing distributed generation
of energy hamper efforts to maximum this renewable source of
energy.  In particular, these rules limit usage of reciprocating
engines to harness the energy due to stringent emission standards
on this equipment.  The Scoping Plan should include an effort to
review such rules and determine whether they can be amended to
better encourage usage of this energy source.  Further, for
clarity, references in the Scoping Plan to “gases emitted from
decomposing organic wastes” should be changed to “gases emitted
during treatment of solids at wastewater treatment plants.” The
term “gases emitted from decomposing organic wastes” is overly
broad and could be interpreted to include, say, gases produced at
landfills during waste composition.

7.	Page C-86: Section W-5: The text mentions the CEC's PIER
program estimates statewide generation potential from undeveloped
in-conduit hydroelectric and wastewater treatment renewable energy
resources at a total of 2,100 GWh per year.  The water/wastewater
renewable potential components should be kept separate to better
focus the strategies being considered.

8.	Page C-86: Energy recovery from decomposing organic wastes in
wastewater systems typically face a lot of community opposition. 
CARB’s inserting themselves into the permitting and public review
process as a resource to the project proponent would assure a
higher percentage of renewable resource projects actually get
built.

9.	Page C-87: Section W-6 proposes a public goods charge for water
to raise funds for reducing GHG emissions resulting from capturing,
storing, conveying, treating, and disposing of water. We would like
to note that the proposed funding of such a charge would provide
$100 million to $500 million per year and is only a very small
fraction of the funds that would be necessary to accomplish the
actions proposed for reducing the water sector’s GHG emissions. 
If agencies are to be encouraged to generate more tertiary treated
effluent as part of the Scoping Plan, some of the monies should go
to support those efforts.