Comment Log Display

Dear Chair Nichols:
The San Diego County Water Authority (Water Authority) participated
in the November 7, 2016 Public Workshop on the 2030 Target Scoping
Plan Update: GHG Policy Scenarios, Natural & Working Lands, and
Public Health Analysis, and appreciates the opportunity to provide
comments. The Water Authority is a regional wholesale water agency
serving 24 member retail agencies in San Diego County. We sustain
the region’s $222 billion economy and the quality of life for 3.3
million residents through a multi-decade water supply
diversification plan, major infrastructure investments and
forward-thinking policies that promote fiscal and environmental
responsibility.  The Water Authority supports the California Air
Resources Board’s (ARB) efforts to address climate change by
reducing GHG emissions in California. In addition, the Water
Authority voluntarily developed and adopted its first Climate
Action Plan in March 2014, with a goal of minimizing greenhouse gas
emissions (GHGs) in fulfilling its primary responsibility to
provide a reliable, high-quality, and safe water supply to the San
Diego region.

At the Public Workshop, ARB sought input on a carbon tax structure
in-lieu of a post-2020 cap-and-trade. As ARB explores the concept
of a carbon tax and potentially including other sectors that may
contribute indirect emissions from electricity consumption, the
Water Authority requests that you exempt critical water supply 
infrastructure  from a carbon tax.  These include facilities that
provide a local, drought-resilient supply for our region and
already have GHG mitigation measures as part of their operational
plans. If critical water supply infrastructure was subject to a
carbon tax it would lead to higher water rates, which in turn to
would impact water customers including disadvantaged or underserved
communities. 

At the Public Workshop, ARB also sought comments on where to return
carbon tax revenues.  The Water Authority strongly believes that
carbon taxes generated locally should be reinvested locally. We
support the Natural and Working Lands Update draft goal for
wetlands that promote healthy wetland and riparian ecosystems along
streams, rivers, deltas, bays, and coastal zones to provide
long-term carbon sequestration benefits.   For example, local
reinvestment could contribute to wetland creation regionally.
Wetlands creation or restoration have the ability to improve water
quality thus benefiting our regional water supplies.  Wetlands also
provide carbon sequestration benefits, habitat, and recreational
opportunities.  


The Water Authority appreciates the opportunity to comment and
thanks ARB for its review and consideration of the comments. Please
contact me with any questions at (858) 522-6743.

Sincerely,


Toby Roy, Water Resources Manager
Water Resources Department

1 NIPP, 2006, Glossary of Key Terms, is the source for the
definitions of critical infrastructure and key resources. These
definitions are derived from the provisions of the Homeland
Security Act of 2002 and HSPD-7.

2 Healthy Landscapes 2030: California’s Climate Change Vision and
Goals for Natural and Working Lands, Page 5

(Letter attached)