Comment Log Display

please see attached file- text reproduced below for convenience:

Dear Chair Nichols and Board Members:

Thank you for the opportunity to comment on the 2017 Climate Change
Scoping Plan Update (“2017 Update”).  Los Angeles Waterkeeper (LAW)
submits these comments primarily to point out the large existing
GHG emissions associated with California’s outdated system of water
supply.  Our water supply relies primarily on pumping water over
vast distances, using it once, treating it, and then dumping it as
“wastewater,” often into California’s rivers and bays where it
becomes a source of water pollution.  The inefficiency and
wastefulness of the current system is also an opportunity—the
increased commitment to conserve water and to develop local sources
of sustainable water supplies, rather than relying on imported
water pumped over great distances, could prove to be the single
greatest steps California can take to reduce its GHG emissions. 
Such a commitment would also effectuate improvements in water
quality.  Now is the time to seize this win-win opportunity for our
air and our water, as the world looks increasingly to California
for environmental and political leadership on climate change
issues.  

LAW  is a nonprofit environmental organization with over 3,000
members dedicated to protecting and restoring all surface and
ground waters in Los Angeles County and ensuring an environmentally
and socially sustainable water supply. LAW advocates the "4R"
approach to Integrated Water Management: Reduce use of water
through conservation with a goal of 50/gallons/person/day; Reuse
greywater and capture stormwater; Recycle through wastewater
reclamation; and Restore watershed health both in source areas of
water supply and in the increasingly important aquifer underlying
large sections of the San Fernando Valley.

The GHG emissions associated with California’s current wasteful
water supply choices are unsustainable, especially given the
ambitious and now legally binding goal to reduce California GHG
emissions to 40% below 1990 baseline levels by the year 2030.  But
the very GHG inefficiency of the water supply system presents an
enormous opportunity to realize large additional reductions in GHG
emissions through a mix of water conservation and increased
reliance on multi-benefit stormwater capture projects and increased
water recycling.   For example, U.C. Davis researchers found that
between June 2015 and February 2016, when mandatory water
conservation measures were in place due to an historic drought,
California’s water conservation rate of 23.9 percent over 2013
levels resulted in energy savings that translated into a reduction
in greenhouse gas emissions of 219,653 metric tons.   LAW also
recently filed an administrative appeal with the State Water
Resources Control Board, seeking to quantify the benefits-
including the GHG benefits- of ending ocean discharge of treated
“wastewater” from the Hyperion Water Treatment Plant in Los
Angeles.  LAW believes these discharges constitute an
unconstitutional waste and unreasonable use of a California water
resource.   While the GHG analysis is currently lacking
(necessitating in part the appeal), LAW has no doubt that the GHG
reductions from ending open ocean discharge of municipal wastewater
are substantial.  LAW requests that CARB consider carefully and
fully the GHG benefits of a more efficient water supply as it plans
for meeting the 40% GHG reduction target.  The efficiency
improvements should come from increased emphasis on conservation,
increased and aggressive use of water recycling, and increased use
of stormwater capture and infiltration for multi-benefit projects
including water supply.

LAW thanks you for the opportunity to comment on the 2017 Update.