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Comment 22 for Water Comments for the GHG Scoping Plan (sp-water-ws) - 1st Workshop.
First Name: Lisa
Last Name: Novotny
Email Address: lnovotny@lakewoodcity.org
Affiliation: City of Lakewood, CA
Subject: City of Lakewood comments on Water section of draft scoping plan
Comment:
Here are the city of Lakewood's comments on the water section of the draft scoping plan: The state’s Climate Change Draft Scoping Plan contains an element related to water. The Plan calls for 6 initiatives to reduce greenhouse gas emissions: 1. Water Use Efficiency: a reduction in water use of 20 percent per capita by 2020. The plan expects that a 20 percent reduction will reduce water use by 1.75 million acre feet, which would result in a reduction of energy use to produce and deliver water to customers by 1.4 MMTCO2E (Million Metric Tons of CO2 Emitted). • The water portion of the plan only addresses the urban water use; agricultural reductions are not adequately addressed in the Agriculture section of the appendices. The agricultural community consumes 80% of the water used in California. The initial scoping plan does not require any required efficiencies related to the enormous amount of energy for crop irrigation, or irrigation pumping. This huge statewide drain on water and energy is given a pass. • Water conservation efforts carried southern California through the drought in the early 1990s. Many residents replaced water guzzling devices, planted drought tolerant landscape and changed water habits during this time. The push to reduce water use an additional 20 percent per capita, would require draconian measures and lead to unkempt landscape. A typical Lakewood family uses 12,000 gallons in a month. A 20 percent per capita reduction would require an individual to save 600 to 1,000 gallons a month. This type of conservation, in a non-drought situation, would impact the quality of life for our residents. • A 20 percent per capita reduction would force water utilities into the enforcement mode. Staff would be required to monitor water use, conduct mandatory water audits and serve as the water police. • The city of Lakewood is essentially built out. Changes in landscape, and water using devices, with or without a subsidy, will cost the typical homeowner thousands of dollars. To retrofit these homes with solar water heaters, water efficient washing machines and expensive irrigation timers would save water, but the costs would outweigh the benefits. • Some of the water efficiency elements are targeted toward water runoff and wastewater reuse. These elements need to be separate from those that are related to water supply/demand. 2. Water Recycling: increase in use of recycled water from 10 to 23 percent by 2030. • Lakewood’s recycled water system was initiated in 1989. It saves enough potable water savings to serve approximately 880 Lakewood families. This initiative does not give credit for the efforts already accomplished by water agencies that have already spend millions of dollars to implement a recycled water system. • Approximately 70% percent of the potential recycled water uses have been connected to the existing system. Expanding the recycled water system to reach the small number of potential schools, parks and parkways is currently not cost effective without grant money or rebates for recycled water use. Expansion of the city’s recycled water system would cost an estimated $2.5-3.5 million, and would result in an additional 60 to 100 acre feet of recycled water used annually. • The recycled water customer base is limited by regulation to supply to non-residential landscape and other commercial uses. Expansion of use of the existing distribution system would require regulation changes by the California Department of Public Health and the LA County Health Department, such as expansion of the use of dual piping in commercial buildings and irrigation use in residential areas beyond irrigation of professionally managed common areas. The increase in the ratio of recycled water used for groundwater recharge would also require a philosophical change by the state’s Department of Public Health. • The state has not placed a dollar value on this initiative, which makes it difficult to make constructive comments. Are we to assume unlimited funding? 3. Water System Energy Efficiency: The proposed scoping plan set a target of a 20 percent reduction in energy use from the 2006 level for water related production, including water waste treatment. The state expects utilities to increase pumping efficiency by evaluating the energy use to determine feasibility of efficiency programs and better manage the energy demand associated with operating the water system. • Water utilities are experts at monitoring and altering pump efficiency as a method to save money. This is an on going function of the department in an effort to keep water rates low and water reliability high. The market should be the driver for utilities to implement energy efficiencies in the water system. The city of Lakewood water utility routinely performs wire-to-water efficiency tests of its water production facilities. Production facilities not meeting the required level of efficiency are either replaced or rehabilitated. The water utility staff works with Southern California Edison to operate the most energy efficient facilities during peak energy periods and the remaining at off peak hours. Lakewood is always looking for energy alternatives to reduce dependence on the electrical grid. The water utility is installing a solar array to operate a water storage facility during daylight hours. 4. Reuse Urban Runoff: the capture and distribution of stormwater runoff. In addition or vegetated channels to allow for the infiltration of stormwater into the groundwater table, the scoping plan calls for the development of regional and neighborhood infiltration facilities. • The quality of urban runoff is not adequate for groundwater recharge or immediate reuse. This would require the construction of water treatment facilities at an unknown cost to the community. • The 0.2 MMTCO2E saved by this initiative does not have a cost associated with it, which makes it difficult to provide constructive comments. 5. Increase Renewable Energy Production from Water: This initiative requires the capture and use of gases from wastewater treatment to be used to for energy generation. • The city is not in the wastewater business, and will not comment on this initiative. 6. Public Goods Charge for Water: Water utilities would collect a flat fee, between $10-50 annually, from water customers to be used to pay for programs to reduce water-related GHG emissions. The flat fee would not be charged to low-income residents, defined as customers on lifeline billing. The utility would collect the fee, but the plan seems to indicate that the revenue would be forwarded to the state for local, regional and statewide programs. • If the state wants to tax the citizenry to pay for the implementation of water efficiency measures then the state should be the collectors of these funds. This initiative places the burden of collection on an organization that might not obtain any benefit from the fee. If low-income residents are not going to be required to pay the fee the “more effluent” ratepayers will bear the entire cost. • The utilities must respond to the ratepayers’ negative response to the increase in water rates. Utilities are already struggling with the balance between the cost of operation and infrastructure needs related to aging systems and capital requirements to meet new water quality regulations. Collecting an additional fee will appear like the utility is gaining revenue, but those funds will not be available to the utility for direct benefit to its customers. • The initiative calls for non-payment of the public goods charge on water for those individuals that are “lifeline” customers. Most water utilities don’t have lifeline customers. In fact most municipal water utilities no longer have a “free” quantity of water associated with the basic charge for service fee, which allows every residential customer a water allowance without payment of a quantity charge.
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Date and Time Comment Was Submitted: 2008-08-07 17:07:54
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