First Name: | Bob |
---|---|
Last Name: | Hitchner |
Email Address: | bob@nexusewater.com |
Affiliation | Nexus eWater Inc. |
Subject | On achieving water-related GHG emissions reductions |
Comment |
I am writing to comment on the Discussion Draft for the 2030 Target Scoping Plan with respect to water-related use of energy for pumping, conveying, treating and heating water. Nexus eWater is a San Diego-based company that manufactures residential-scale solutions to recover and reuse valuable resources that are in the “grey water” discharge that leaves every home – the water itself, and the energy that is in the water. Ours is an emerging technology category that can play a positive role in the achievement of the goal of significant Greenhouse Gas Emissions reduction. However, it is critical that the Plan be able to adapt to challenges that are sometimes presented by new technologies. I would like to emphasize two points that are illustrated particularly in the water-related use of energy: 1. Conservation, efficiency and recycling are the shortest paths to cutting GHG emissions, not to mention directly engaging all Californians in the achievement of these goals. 2. The Plan must be open to switching between fuels, and to switching from one technology to another, if that results in system-wide reductions in energy and GHG emissions. In particular, I am referring to two technological paradigms: Electric vs. gas water heating; and distributed (on-site) vs. centralized water recycling. Water-related Greenhouse Gas Emissions – the Impact of Conservation and Onsite Water Reuse The Scoping Plan correctly identifies the water sector as a major user of energy, and thus a major source of greenhouse gas emissions. The Discussion Draft notes that 10% of the State’s energy use is associated with water-related end uses, and water and wastewater systems account for an additional 2% of energy use (page 76). The energy-intensity of water can be addressed at many different points in the long water supply, process and treatment chain. The most effective way to reduce the GHG impact of water use (page 77) -- bar none -- is to reduce water use. This, of course, is the well-worn concept of conservation or efficiency. The second most effective way to reduce the GHG impact of water is to switch our reliance from high-energy sources of water to locally-sourced water. The best example of this is the use of on-site sources of water such as grey water and rainwater as a replacement for potable water (for appropriate uses). Generally, this Is known as on-site water reuse. In order to achieve the GHG emissions goals of the scoping plan with respect to water, we need our policies to appropriately prioritize water conservation, water efficiency, and water reuse in our policy portfolio. Without an appropriate policy mix, we will instead be forced, over time, to move to more energy-intensive sources of water such as desalination or centralized wastewater treatment for potable reuse. Fortunately, in California we have already begun to move toward more on-site water reuse. Jurisdictions such as the City and County of San Francisco, the City of Los Angeles, and the service area of the Santa Clara Valley Water District have policies, or draft policies, which will encourage more and more residential and commercial buildings to make more effective reuse of grey water and rain water in the future. On-site sources of water can be used in California for landscape irrigation and toilet flushing, which are two of our largest residential uses of water. When homeowners are reusing their own water, they become more closely engaged with the process of producing and using water, rather than simply “consuming” water. A citizenry that is engaged in the process of conserving, using it efficiently, and recycling it for their own reuse is a citizenry that better understands and appreciates our climate policies and goals. Building-Level vs. System-wide Efficiency – Addressing Perverse Policy Incentives when Technologies Change Each scenario presented in the Discussion Draft reflects the State’s known commitment to double building-level energy efficiency by the year 2030, as required under AB 350 (see page 41). One means to do so is the replacement of inefficient space heating and water heating appliances with more efficient appliances, such as electric heat pumps. A number of participants in the review process have called for ending the use of fossil fuels in buildings on the pathway to achieving our GHG emissions reduction goals. On-site water reuse is an example of an emerging solution that can simultaneously contribute to the doubling of energy efficiency of the broader system, but not necessarily at the level of the individual building. It is obvious to see how it can contribute to this goal when the embedded energy in a home’s grey water is harvested and reused on site, which is already possible but not yet common. It is less obvious when on-site water treatment results in a new appliance power demand that currently is handled off-site at a centralized facility. Even if the net energy use is lower to treat and move water around at the building level than it is at a centralized treatment facility, it is not uncommon for policy-based calculators to create perverse incentives that may result in less efficient outcomes at the system level. This should not be allowed to happen. As was the case of rooftop solar, on-site water reuse solutions have the potential to transform a portion of water treatment from a centralized to a distributed solution. When this can happen, we need our policies to adapt to the technological change and not create perverse incentives that may perpetuate less efficient pre-existing technologies. The potential water and energy impact of on-site solutions for water is nothing short of transformational, and can have just a great an impact as the move from a centralized to the distributed power grid. Let us make certain that the Scoping Plan has the flexibility to anticipate, adapt to, and encourage such technological transformation that may be critical to our achievement of the goals of the plan – the 40% reduction in greenhouse gas emissions by the year 2030. |
Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2016-12-16 16:35:58 |
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