Comment Log Display

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.