Comment Log Display

1) The document states on page 12 that the State of California is
establishing a target of reducing its greenhouse gas emissions by
a minimum of 30 % by 2020 below its estimated business-as-usual
emissions – approximately a 15% reduction from current levels.  At
the top of page 13, it notes that water projects will be among the
potential state areas targeted for GHG reductions. We assume that
the Department of Water Resources (DWR) has been tasked with
achieving GHG efficiencies with its operations of the State Water
Project (SWP).  If so, we request that the financial costs to SWP
water associated with this effort be revealed sooner rather than
later.  As water agencies prepare their 2010 Urban Water
Management Plans (UWMPs), it would be very helpful to be able to
incorporate the associated cost increases of imported water into
local decision-making.  Therefore, the information should be
released by early 2009 at the latest in order to factor into 2010
UWMPs.  This request also applies to the concept of carbon fees or
any other new energy fees that would be embedded in the cost of
transporting water.  Local water agencies need to understand the
cost implications of CARB’s proposals in order to make sound water
supply source decisions.
2) The Scoping Plan does not specifically address anticipated
decreases in the renewable power source of hydropower.  The DWR’s
Climate Change report identifies reduced hydropower as an
anticipated result of climate change.  Is (or should) the
decreased future availability of an existing renewable energy
source be calculated into the goals for additional renewable
energy sources?
3) Pumped storage of water in reservoirs has been an effective
tool in meeting peak energy demands.  While considered a “green”
energy source, the net GHG emissions produced is greater with
pumped storage than without.  It would be helpful for the CARB to
provide early guidance as to viability of pumped water storage in
the future.
4) We understand the attraction of a Public Goods Charge as
suggested on page 28.  However, we are concerned that such a
charge is premature and request that CARB collaborate with water
industry representatives such as they have done with the CWCCG in
the wastewater sector.  The City of San Diego recommends
collaboration with the California Urban Water Agencies (CUWA) to
more thoroughly scope out the design of such a charge if there is
to be one.  Of primary concern is that local funds will be
collected to benefit the efforts of unrelated outside entities. 
We need assurances that local funds will not be inappropriately
redirected.