July 3, 2008
The Honorable Arnold Schwartzenegger
Governor
State Capitol
Sacramento, CA 95814
RE: AB 2270
Dear Governor Schwarzenegger:
California leads all states in its dedication to protecting its natural environment for the benefit of its citizens. In virtually every medium – air, land and water – California’s leadership has helped identify policy solutions that recognize that our citizens’ quality of life must be considered in the context of its long-term environmental consequences.
In partisan votes, the Legislature is moving AB 2270 towards passage, ignoring rising concerns about its unintended consequences, which are, ironically, environmental in their impact. It could reach your desk within 60 days. We urge you to veto AB 2270 to protect both California consumers and the environment.
The majority in the Legislature argues that AB 2270 further extends environmental protection against the adverse impacts of dissolved solids in wastewater effluent, particularly chlorides discharged in the operation of ion-exchange water softeners. Certainly, re-use of water with high concentrations of TDS (total dissolved solids) and chloride may be inadvisable for certain crops and industries. Nine years ago, the Legislature considered this same problem and devised a solution that created a process to identify and balance the social and environmental benefits and costs of measures to address this serious problem. In 1999, SB 1006 resolved the competing demands by enacting a framework to balance consumer choice and environmental issues.
Every solution involves trade-offs, and 1999-SB1006 created an orderly means to identify options that can achieve our environmental goals. AB 2270 is designed to replace that careful process with one that invites new problems. Not only will it strip away consumers’ ability to protect their homes and businesses, but AB 2270 would impose new environmental costs that represent a shifting of burden from TDS/chloride-rich surface waters to put new stresses on air pollution abatement programs and our efforts to stretch scarce solid waste landfill capacity.
There is no doubt that ion-exchange water softeners contribute to the problem of adding TDS and chlorides to the wastewater stream. Likewise, we should accept that use of water softeners used to condition “hard” water, protect hot water-using appliances like water heaters, dishwashers and washing machines – and the very pipes of each home’s plumbing infrastructure. Without water softeners, not only are consumers facing the aesthetic sacrifice of “white whites” from their laundry, but the physics and chemistry involved means they’ll require considerably more detergent. Unsoftened, hard water reaching home hot water appliances – and industrial boilers – results in mineral scaling that significantly shortens each appliance’s useful life and imposes a mounting energy penalty as the scaling makes the appliance progressively less energy-efficient. So water-using businesses and millions of homes will find they need more frequent replacement of their dishwashers, washing machines and, especially, hot water heaters with the attendant energy costs for manufacturing units prematurely landfilled to say nothing of the increased volume of such scrap materials seeking to fill landfill capacity. Add to that the fact that clothing itself wears out a third faster when laundered in hard water and it is reasonable to add the costs of replacing that clothing – including the energy costs in manufacturing and shipping tons and tons of apparel – to the environmental costs of banning water softeners.
Success in balancing these environmental impacts would be imperiled if AB 2270 becomes law. 1999 SB1006 was crafted taking these trade-offs into consideration. It makes no sense to merely push environmental stressors from one medium to another; what we need is a framework to identify the best net-benefit for the environment rather than lurch emotionally from one crisis to the next, responding to the “urgent” without full consideration of the “important.”
Softener technology has made great strides in recent years, providing consumers with the social and environmental benefits of water softeners while reducing their environmental impact. Further progress can be expected. As California learned when it pioneered more stringent automobile air emission controls, the greatest benefit comes from removing from service the worst offenders. Removal of time-clock regenerating units and requiring all operating units to be on-demand regenerating would be an obvious positive step. There are surely others that reasonable people could agree on.
But AB 2270 short-circuits that careful policy consideration. We urge you to reject AB 2270 and direct local governments and water utilities to utilize the SB 1006 process.
In sum, this bill is about a lot more than whiter whites and brighter brights; more than healthy-looking hair. It’s not about mindless consumerism. Consumers choosing water softeners are investing to preserve the value of their homes, including their home appliances. Conserving their pipes, water heaters and other hot water appliances makes good environmental sense. Your veto of AB 2270 should be more than affirmation that quality of life in California not only includes consumer choice, but an affirmation that the carefully-drawn process in current law will prevent any rush to judgment that could actually have a net-negative environmental impact.
The Salt Institute appreciates this opportunity to provide its comments. We represent those who sell salt for water softeners and are anxious to be part of the solution in improving the environment and quality of life for all Californians.
Sincerely,
Richard L. Hanneman
President
 |
| [About Salt Institute] [About salt] [About the salt industry] [News] [SI Member Business (password required] [E-Mail Salt Institute] |