Brea City Council
May 19, 2026

4. Adoption of this Resolution is exempt from review under the California Environmental Quality Act (“CEQA”) pursuant to Water Code Section 10652. The City Manager shall cause a Notice of Exemption to be filed with the Orange County ClerkRecorder's Office.

Reso.No.2026-XXX
May19,2026
11222-0001\3242921v1.doc

5. The City Clerk shall:
a. Certify to the adoption of this Resolution;
b. File a certified copy of the attached WSCP with the DWR no later than July 1, 2026.
c. File a certified copy of the attached WSCP with the California State Library, and any city or county within which the City of Brea provides water supplies, no later than July 1, 2026.
d. Make the WSCP available for public review at the City’s offices during normal business hours and on the City website no later than 30 days after filing a copy of the UWMP with the DWR.

APPROVED AND ADOPTED this 19th day of May 2026.
_______________________________
Cecilia Hupp, Mayor
ATTEST: ____________________________
Victoria Popescu, City Clerk
Reso.No.2026-XXX
May19,2026
11222-0001\3242921v1.doc
I, Victoria Popescu, Clerk of the City of Brea, do hereby certify that the foregoing Resolution was adopted at a regular meeting of the City Council of the City of Brea, on the 19th day of May, 2026, by the following vote:

AYES:

NOES:

ABSENT:

COUNCIL MEMBERS: [include names]
COUNCIL MEMBERS: [include names]
COUNCIL MEMBERS: [include names]
ABSTAINED: COUNCIL MEMBERS : [include names]
Dated: __________________________
_______________________________
Victoria Popescu, City Clerk
Reso.No.2026-XXX
May19,2026
11222-0001\3242921v1.doc

EXHIBIT A
2025 Water Shortage Contingency Plan
(attached)
in collaboration with and
2025 Water Shortage
Contingency Plan
FINAL DRAFT / April 2026
2025 Water Shortage Contingency Plan
April 2026 / FINAL DRAFT
Prepared By: Prepared For:

Carollo Engineers, Inc. City of Brea
707 Wilshire Boulevard, Suite 3920 1 Civic Center Circle Los Angeles, California 90017 Brea, California 92821
Phone: 213.489.1587 Phone: 714.990.7600
https://www.carollo.com https://www.cityofbrea.gov/
In collaboration with:
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA i
pw://Carollo/CA/MWDOC/204447-000000/03 Reports and Studies/02 Deliverables/Grp5_Brea UWMP/Brea_2025 WSCP.docx Contents
SECTION 1 INTRODUCTION AND WSCP OVERVIEW 1

1.1 Water Shortage Contingency Plan Requirements and Organization 1

1.2 Integration With Other Planning Efforts 2
SECTION 2 BACKGROUND INFORMATION 3

2.1 City Service Area 3

2.2 Relationship to Wholesalers 4

2.3 Relationship with Wholesaler Water Shortage Planning 6

2.3.1 MET Water Surplus and Drought Management Plan 6

2.3.2 MET Water Supply Allocation Plan 8

2.3.3 MWDOC Water Supply Allocation Plan 9
SECTION 3 WATER SHORTAGE CONTINGENCY PREPAREDNESS AND
RESPONSE PLANNING 10

3.1 Water Supply Reliability Analysis 10

3.2 Annual Water Supply and Demand Assessment Procedures 11

3.2.1 Decision-Making Process 11

3.2.2 Data and Methodologies 13

3.3 Six Standard Water Shortage Levels 16

3.4 Shortage Response Actions 17

3.4.1 Supply Augmentation 17

3.4.2 Demand Reduction 18

3.4.3 Operational Changes 18

3.4.4 Additional Mandatory Restrictions 18

3.4.5 Emergency Response Plan (Hazard Mitigation Plan) 18

3.4.6 Seismic Risk Assessment and Mitigation Plan 20

3.4.7 Shortage Response Action Effectiveness 20

3.5 Communication Protocols 21

3.6 Compliance and Enforcement 22

3.7 Legal Authorities 22

3.8 Financial Consequences of WSCP 22

3.9 Monitoring and Reporting 23

3.10 WSCP Refinement Procedures 24

3.11 Special Water Feature Distinction 24

3.12 Plan Adoption, Submittal, and Availability 24
SECTION 4 REFERENCES 25
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA ii
Appendices

APPENDIX A DWR SUBMITTAL TABLES
APPENDIX B WATER SHORTAGE CONTINGENCY RESPONSE ORDINANCE 1221

APPENDIX C NOTICE OF PUBLIC HEARING (PENDING)

APPENDIX D ADOPTED WSCP RESOLUTION (PENDING)
Tables
Table 1 Cross-Reference for Standard vs Supplier Shortage Levels 17 Table 2 Communication Procedures 21
Table 3 Agency Contacts and Coordination Protocols 22
Figures
Figure 1 City Service Area 4
Figure 2 Regional Location of the City of Brea and Other MWDOC Member Agencies 6 Figure 3 Resource Stages, Anticipated Actions, and Supply Declarations 7 Figure 4 AWSDA Reporting Timeline 12
Figure 5 Water Shortage Contingency Plan AWSDA Framework 13 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA iii
Abbreviations
% Percent
AF Acre-Feet
AWSDA Annual Water Supply and Demand Assessment
CDWC California Domestic Water Company
City City of Brea
CRA Colorado River Aqueduct
DDW Division of Drinking Water
DRA Drought Risk Assessment
DVL Diamond Valley Lake
DWR California Department of Water Resources
EOC Emergency Operation Center
EOP Emergency Operations Plan
ERP Emergency Response Plan
IAWP Interim Agricultural Water Program
LHMP Local Hazard Mitigation Plan
M&I Municipal and Industrial
MCL Maximum Contaminant Level
MET Metropolitan Water District of Southern California
MWDOC Municipal Water District of Orange County
NIMS National Incident Management System
OSY Operating Safe Yield
PFAS Per- and Polyfluoroalkyl Substances
PFOA Perfluorooctanoic Acid
PFOS Perfluorooctane Sulfanate
PPT Parts Per Trillion
Producers Groundwater Producers
RL Response Level
SEMS Standardized Emergency Management System
Supplier Urban Water Supplier
SWP State Water Project
UWMP Urban Water Management Plan
Water Code California Water Code
WEROC Water Emergency Response Organization of Orange County WSAP Water Supply Allocation Plan
WSCP Water Shortage Contingency Plan
WSDM Water Surplus and Drought Management Plan
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 1
SECTION 1 INTRODUCTION AND WSCP OVERVIEW
The Water Shortage Contingency Plan (WSCP) is a strategic planning document designed to prepare for and respond to water shortages. This WSCP complies with California Water Code (Water Code) Section 10632, which requires that every Urban Water Supplier (Supplier) shall prepare and adopt a WSCP as part of its Urban Water Management Plan (UWMP). This level of detailed planning and preparation is intended to help maintain reliable supplies and reduce the impacts of supply interruptions.

The WSCP is the City of Brea (City)'s operating manual that is used to prevent catastrophic service disruptions through proactive, rather than reactive, management. A water shortage, when the water supply available is insufficient to meet the normally expected customer water use at a given point in time, may occur due to a number of reasons, such as drought, climate change, and catastrophic events. This plan provides a structured guide for the City to deal with water shortages, incorporating prescriptive information and standardized action levels, along with implementation actions in the event of a catastrophic supply interruption. This way, if and when shortage conditions arise, the City's governing body, its staff, and the public can easily identify and efficiently implement pre-determined steps to manage a water shortage. A well-structured WSCP allows real-time water supply availability assessment and structured steps designed to respond to actual conditions, enabling efficient management of any shortage with predictability and accountability.

The WSCP also describes the City's procedures for conducting an Annual Water Supply and Demand Assessment (AWSDA) that is required by Water Code Section 10632.1 and is to be submitted to the California Department of Water Resources (DWR) on or before July 1 of each year, or within 14 days of receiving final allocations from the State Water Project (SWP), whichever is later. The City's 2025 WSCP is included as an appendix to its 2025 UWMP which will be submitted to DWR by July 1, 2026. However, while developed in conjunction with the UWMP, this WSCP is a standalone document and can be amended, as needed, without amending the UWMP. Furthermore, the Water Code does not prohibit a Supplier from taking actions not specified in its WSCP, if needed, without having to formally amend its UWMP or WSCP.

1.1 Water Shortage Contingency Plan Requirements and
Organization
The WSCP provides the steps and water shortage response actions to be taken in times of water shortage conditions. The WSCP has prescriptive elements, such as an analysis of water supply reliability; the water shortage response actions for each of the six standard water shortage levels that correspond to water shortage percentages ranging from 10 percent to greater than 50 percent; an estimate of potential to close supply gap for each measure; protocols and procedures to communicate identified actions for any current or predicted water shortage conditions; procedures for an AWSDA; monitoring and reporting requirements to determine customer compliance; and reevaluation and improvement procedures for evaluating the WSCP.
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 2
This WSCP is organized into three main sections, with Section 3 aligned with the Water Code Section 16032 requirements.

Section 1 Introduction and WSCP Overview gives an overview of the WSCP fundamentals.

Section 2 Background Information provides a background on the City's water service area.

Section 3 Water Shortage Contingency Preparedness and Response Planning Section 3.1 Water Supply Reliability Analysis provides a summary of the water supply analysis and water reliability findings from the 2025 UWMP.

Section 3.2 Annual Water Supply and Demand Assessment Procedures provides a description of procedures to conduct and approve the AWSDA.

Section 3.3 Six Standard Water Shortage Stages explains the WSCP's six standard water shortage levels corresponding to progressive ranges of up to 10, 20, 30, 40, 50, and more than 50 percent shortages.

Section 3.4 Shortage Response Actions describes the WSCP's shortage response actions that align with the defined shortage levels.

Section 3.5 Communication Protocols addresses communication protocols and procedures to inform customers, the public, interested parties, and local, regional, and state governments, regarding any current or predicted shortages and any resulting shortage response actions.

Section 3.6 Compliance and Enforcement describes customer compliance, enforcement, appeal, and exemption procedures for triggered shortage response actions.

Section 3.7 Legal Authorities describes the legal authorities that enable the City to implement and enforce its shortage response actions.

Section 3.8 Financial Consequences of the WSCP provides a description of the financial consequences of and responses for drought conditions.

Section 3.9 Monitoring and Reporting describes monitoring and reporting requirements and procedures that ensure appropriate data is collected, tracked, and analyzed for purposes of monitoring customer compliance and to meet state reporting requirements.

Section 3.10 WSCP Refinement Procedures addresses reevaluation and improvement procedures for monitoring and evaluating the functionality of the WSCP.

Section 3.11 Special Water Feature Distinction is a required definition for inclusion in a WSCP per the Water Code.

Section 3.12 Plan Adoption, Submittal, and Availability describes the process the City followed to adopt its WSCP.

1.2 Integration With Other Planning Efforts
As a retail water supplier in Orange County, the City considered other key entities in the development of this WSCP, including the Municipal Water District of Orange County (MWDOC) (regional wholesale supplier), the Metropolitan Water District of Southern California (MET) (regional wholesaler for Southern California and the direct supplier of imported water to MWDOC), and the California Domestic Water 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 3
Company (CDWC) (mutual water company that provides imported groundwater from the Main San Gabriel Basin). As a MWDOC member agency, the City also developed this WSCP with input from several coordination efforts led by MWDOC.

Some of the key planning and reporting documents that were used to develop this WSCP are:
 MWDOC's 2025 UWMP provides the basis for the projections of the imported supply availability over the next 25 years for the City's service area.
 MWDOC's 2025 WSCP provides a water supply availability assessment and structured steps designed to respond to actual conditions that will help maintain reliable supplies and reduce the impacts of supply interruptions.
 MWDOC's 2023 Orange County Water Reliability Study is a planning document to help guide planning for future water supply reliability for water providers in Orange County and provide input on regional water supply issues for MET
 2025 Orange County Water Demand Projection Model Technical Memorandum is a collaborative effort amongst MWDOC and all retail water suppliers in Orange County that developed water demand projections to produce regionally consistent forecasts across all Orange County water agencies
 MET's 2025 UWMP uses assumptions that fall within the plausible futures contemplated in MET's Integrated Water Resources Plan to evaluate MET's future imported water supply reliability.  MET's 2025 WSCP provides a water supply availability assessment and guide for MET's intended actions during water shortage conditions.
 City of Brea's 2024 Local Hazard Mitigation Plan (LHMP) provides the basis for the seismic and other natural and natural disaster risk analysis of the water system facilities.  Brea Capital Improvement and Water Master Plans of the City's service area provide information on water infrastructure planning projects and plans to address any required water system improvements.

SECTION 2 BACKGROUND INFORMATION
The City was incorporated on February 23, 1917 and is governed by a five-member City Council, elected by residents to serve four-year terms. The City's Water Division is responsible for the City's potable water system, including backflow prevention and water quality issues. The Water Division goal is to achieve conservation and efficient use of urban water supplies to protect the people of the City and their water sources and ensure that sufficient water supplies will be available for further beneficial use.

2.1 City Service Area
The City is located in northern Orange County between the City of La Habra on the west, City of Fullerton on the southwest, the City of Yorba Linda on the southeast and the County of Los Angeles on the north.

The City Water Division serves all the City's area except the Vesuvius track at the eastern end which is served by Yorba Linda Water District. The City encompasses an area of approximately 12 square miles plus square footage of the Blackstone development.
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 4
The City offers easy access to Los Angeles, Riverside, and San Bernardino Counties, and to a number of beaches, resorts, and tourist attractions. Orange County Airport is 17 miles away; Ontario Airport is 25 miles away; and Los Angeles International Airport (LAX) is 48 miles away from the City. An Amtrak station and a municipal airport are located in the neighboring City of Fullerton, approximately 5 miles away. The City is 30 miles east of downtown Los Angeles. The Orange Freeway (SR-57) bisects the City from north to south and offers easy access to the Riverside Freeway (SR-91) to the south and the Pomona (SR-60) and San Bernardino (Interstate 10) Freeways to the north. A map of the City's water service area is shown as Figure 1.

Figure 1 City Service Area

2.2 Relationship to Wholesalers
The Metropolitan Water District of Southern California: MET is the largest water wholesaler for domestic and municipal uses in California, serving approximately 19 million customers. MET wholesales imported water supplies to 26 member cities and water districts in 6 Southern California counties. Its service area covers the Southern California coastal plain, extending approximately 200 miles along the Pacific Ocean from the City of Oxnard in the north to the international boundary with Mexico in the south.

This encompasses 5,200 square miles and includes portions of Los Angeles, Orange, Riverside, San Bernardino, San Diego, and Ventura counties. Approximately 85 percent of the population from the aforementioned counties reside within MET's boundaries.

MET is governed by a Board of Directors comprised of 38 appointed individuals with a minimum of one representative from each of MET's 26 member agencies. The allocation of directors and voting rights are 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 5
determined by each agency's assessed valuation. Each member of the Board shall be entitled to cast one vote for each ten million dollars ($10,000,000) of assessed valuation of property taxable for district purposes, in accordance with Section 55 of the Metropolitan Water District Act. Directors can be appointed through the chief executive officer of the member agency or by a majority vote of the governing board of the agency. Directors are not compensated by MET for their service.

MET is responsible for importing water into the region through its operation of the Colorado River Aqueduct (CRA) and its contract with the State of California for SWP supplies. Member agencies receive water from MET through various delivery points and pay for service through a rate structure made up of volumetric rates, capacity charges, and readiness to serve charges. Member agencies provide estimates of imported water demand to MET annually in April regarding the amount of water they anticipate they will need to meet their demands for the next five years.

The Municipal Water District of Orange County: In Orange County, MWDOC and the cities of Anaheim, Fullerton, and Santa Ana are MET member agencies that purchase imported water directly from MET.

Furthermore, MWDOC purchases both treated potable and untreated water from MET to supplement its retail agencies' local supplies. The City is one of MWDOC's 27 member agencies purchasing imported water from MWDOC. The City's location within MWDOC's service is shown on Figure 2.

The California Domestic Water Company: The CDWC is a specialized wholesaler water provider that the City of Brea purchases the majority of its water from. Water is supplied from the San Gabriel Basin via groundwater wells.
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 6
Figure 2 Regional Location of the City of Brea and Other MWDOC Member Agencies

2.3 Relationship with Wholesaler Water Shortage Planning The WSCP is designed to be consistent with MET's Water Surplus and Drought Management (WSDM) Plan, MWDOC's Water Supply Allocation Plan (WSAP), and other emergency planning efforts as described below. MWDOC's WSAP is integral to the WSCP's shortage response strategy in the event that MET or MWDOC determines that supply augmentation (including storage) and lesser demand reduction measures would not be sufficient to meet a projected shortage levels needed to meet demands.

2.3.1 MET Water Surplus and Drought Management Plan
MET evaluates the level of supplies available and existing levels of water in storage to determine the appropriate management stage annually. Each stage is associated with specific resource management actions to avoid extreme shortages to the extent possible and minimize adverse impacts to retail customers should an extreme shortage occur. The sequencing outlined in the WSDM Plan reflects anticipated responses towards MET's existing and expected resource mix.

Surplus stages occur when net annual deliveries can be made to water storage programs. Under the WSDM Plan, there are four surplus management stages that provides a framework for actions to take for surplus supplies. Deliveries in Diamond Valley Lake (DVL) and in SWP terminal reservoirs continue through 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 7
each surplus stage provided there is available storage capacity. Withdrawals from DVL for regulatory purposes or to meet seasonal demands may occur in any stage.

The WSDM Plan distinguishes between shortages, severe shortages, and extreme shortages. The differences between each term are listed below:
 Shortage: MET can meet full-service demands and partially meet or fully meet interruptible demands using stored water or water transfers as necessary (Stages 1-3).  Severe Shortage: MET can meet full-service demands only by making withdrawals from storage, calling on its water transfers, and possibly calling for extraordinary conservation and reducing deliveries under the Interim Agricultural Water Program (IAWP) (Stages 4-5).  Extreme Shortage: MET must allocate available imported supplies to full-service customers (Stage 6).

There are six shortage management stages to guide resource management activities. These stages are defined by shortfalls in imported supply and water balances in MET's storage programs. When MET must make net withdrawals from storage to meet demands, it is considered to be in a shortage condition.

Figure 3 gives a summary of actions under each surplus and shortage stages when an allocation plan is necessary to enforce mandatory cutbacks. The goal of the WSDM plan is to avoid Stage 6, an extreme shortage (MET, 2026b).

Source: MET, 2026.

Figure 3 Resource Stages, Anticipated Actions, and Supply Declarations MET's Board of Directors adopted a Water Supply Condition Framework in June 2008 to communicate the urgency of the region's water supply situation and the need for further water conservation practices. The 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 8
framework has four conditions, each calling increasing levels of conservation. Descriptions for each of the four conditions are listed below:
 Baseline Water Use Efficiency: Ongoing conservation, outreach, and recycling programs to achieve permanent reductions in water use and build storage reserves.  Condition 1 Water Supply Watch: Local agency voluntary dry-year conservation measures and use of regional storage reserves.
 Condition 2 Water Supply Alert: Regional call for cities, counties, member agencies, and retail water agencies to implement extraordinary conservation through drought ordinances and other measures to mitigate use of storage reserves.
 Condition 3 Water Supply Allocation: Implement MET's WSAP.

As noted in Condition 3, should supplies become limited to the point where imported water demands cannot be met, MET will allocate water through the WSAP (MET, 2026a).

2.3.2 MET Water Supply Allocation Plan
MET's imported supplies have been impacted by a number of water supply challenges as noted earlier. In case of extreme water shortage within the MET service area is the implementation of its WSAP.

MET's Board of Directors adopted the WSAP in February 2008 to fairly distribute a limited amount of water supply and applies it through a detailed methodology to reflect a range of local conditions and needs of the region's retail water consumers (MET, 2026a).

The WSAP includes the specific formula for calculating member agency supply allocations and the key implementation elements needed for administering an allocation. MET's WSAP is the foundation for the urban water shortage contingency analysis required under Water Code Section 10632 and is part of MET's 2025 UWMP.

MET's WSAP was developed in consideration of the principles and guidelines in MET's 1999 WSDM Plan with the core objective of creating an equitable "needs-based allocation." The WSAP's formula seeks to balance the impacts of a shortage at the retail level while maintaining equity on the wholesale level for shortages of MET supplies of greater than 50 percent cutback. The formula takes into account a number of factors, such as the impact on retail customers, growth in population, changes in supply conditions, investments in local resources, demand hardening aspects of water conservation savings, recycled water, extraordinary storage and transfer actions, and groundwater imported water needs.

The formula is calculated in three steps: (1) based period calculations; (2) allocation year calculations; and (3) supply allocation calculations. The first two steps involve standard computations, while the third step contains specific methodology developed for the WSAP.

Step 1: Base Period Calculations: The first step in calculating a member agency's water supply allocation is to estimate their water supply and demand using a historical based period with established water supply and delivery data. The base period for each of the different categories of supply and demand is calculated using data from the two most recent non-shortage years.

Step 2: Allocation Year Calculations: The next step in calculating the member agency's water supply allocation is estimating water needs in the allocation year. This is done by adjusting the base period estimates of retail demand for population growth and changes in local supplies. 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 9
Step 3: Supply Allocation Calculations: The final step is calculating the water supply allocation for each member agency based on the allocation year water needs identified in Step 2.

In order to implement the WSAP, MET's Board of Directors makes a determination on the level of the regional shortage, based on specific criteria, typically in April. The criteria used by MET includes current levels of storage, estimated water supplies conditions, and projected imported water demands. The allocations, if deemed necessary, go into effect in July of the same year and remain in effect for a 12-month period. The schedule is made at the discretion of the Board of Directors (MET, 2026b).

As demonstrated by the findings in MET's 2025 UWMP, both the Water Reliability Assessment and the Drought Risk Assessment (DRA) demonstrate that MET is projecting to be able to mitigate the challenges posed by hydrologic variability, potential climate change, and regulatory risk on its imported supply sources through the significant storage capabilities it has developed over the last two decades, both dry-year and emergency storage (MET, 2026b).

Although MET's 2025 UWMP forecasts that MET will be able to meet projected imported demands throughout the projected period from 2026 to 2050, uncertainty in supply conditions can result in MET needing to implement its WSAP to preserve dry-year storage and curtail demands (MET, 2026b).

2.3.3 MWDOC Water Supply Allocation Plan
To prepare for the potential allocation of imported water supplies from MET, MWDOC worked collaboratively with its 27 retail agencies to develop its own WSAP that was adopted in January 2009 and amended in 2016. The MWDOC WSAP outlines how MWDOC will determine and implement each of its retail agency's allocation during a time of shortage.

The MWDOC WSAP uses a similar method and approach, when reasonable, as that of the MET's WSAP.

However, MWDOC's plan remains flexible to use an alternative approach when MET's method produces a significant unintended result for the member agencies. The MWDOC WSAP model follows five basic steps to determine a retail agency's imported supply allocation.

Step 1: Determine Baseline Information: The first step in calculating a water supply allocation is to estimate water supply and demand using a historical based period with established water supply and delivery data. The base period for each of the different categories of demand and supply is calculated using data from the last two non-shortage years.

Step 2: Establish Allocation Year Information: In this step, the model adjusts for each retail agency's water need in the allocation year. This is done by adjusting the base period estimates for increased retail water demand based on population growth and changes in local supplies.

Step 3: Calculate Initial Minimum Allocation Based on MET's Declared Shortage Level: This step sets the initial water supply allocation for each retail agency. After a regional shortage level is established, MWDOC will calculate the initial allocation as a percentage of adjusted Base Period Imported water needs within the model for each retail agency.

Step 4: Apply Allocation Adjustments and Credits in the Areas of Retail Impacts and Conservation:

In this step, the model assigns additional water to address disparate impacts at the retail level caused by an across-the-board cut of imported supplies. It also applies a conservation credit given to those agencies that have achieved additional water savings at the retail level as a result of successful implementation of water conservation devices, programs, and rate structures. 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 10
Step 5: Sum Total Allocations and Determine Retail Reliability: This is the final step in calculating a retail agency's total allocation for imported supplies. The model sums an agency's total imported allocation with all of the adjustments and credits and then calculates each agency's retail reliability compared to its Allocation Year Retail Demand.

The MWDOC WSAP includes additional measures for plan implementation, including the following (MWDOC, 2016):
 Appeal Process: An appeals process to provide retail agencies the opportunity to request a change to their allocation based on new or corrected information. MWDOC anticipates that under most circumstances, a retail agency's appeal will be the basis for an appeal to MET by MWDOC.  Melded Allocation Surcharge Structure: At the end of the allocation year, MWDOC would only charge an allocation surcharge to each retail agency that exceeded their allocation if MWDOC exceeds its total allocation and is required to pay a surcharge to MET. MET enforces allocations to retail agencies through an allocation surcharge to a retail agency that exceeds its total annual allocation at the end of the 12-month allocation period. MWDOC's surcharge would be assessed according to the retail agency's prorated share (acre-feet [AF] over usage) of MWDOC amount with MET. Surcharge funds collected by MET will be invested in its Water Management Fund, which is used to in part to fund expenditures in dry-year conservation and local resource development.  Tracking and Reporting Water Usage: MWDOC will provide each retail agency with water use monthly reports that will compare each retail agency's current cumulative retail usage to their allocation baseline. MWDOC will also provide quarterly reports on its cumulative retail usage versus its allocation baseline.
 Timeline and Option to Revisit the Plan: The allocation period will cover 12 consecutive months and the Regional Shortage Level will be set for the entire allocation period. MWDOC only anticipates calling for allocation when MET declares a shortage; and no later than 30 days from MET's declaration will MWDOC announce allocation to its retail agencies.

SECTION 3 WATER SHORTAGE CONTINGENCY PREPAREDNESS AND

RESPONSE PLANNING
The City's WSCP is a detailed guide of how the City intends to act in the case of an actual water shortage condition. The WSCP anticipates a water supply shortage and provides pre-planned guidance for managing and mitigating a shortage. Regardless of the reason for the shortage, the WSCP is based on adequate details of demand reduction and supply augmentation measures that are structured to match varying degrees of shortage to ensure the relevant stakeholders understand what to expect during a water shortage situation.

3.1 Water Supply Reliability Analysis
Per Water Code Section 10632 (a)(1), the WSCP shall provide an analysis of water supply reliability conducted pursuant to Water Code Section 10635, and the key issues that may create a shortage condition when looking at the City's water asset portfolio. 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 11
Understanding water supply reliability, factors that could contribute to water supply constraints, availability of alternative supplies, and what effect these have on meeting customer demands provides the City with a solid basis on which to develop appropriate and feasible response actions in the event of a water shortage. For the 2025 UWMP, the City worked collaboratively with MWDOC, OCWD, and MWDOC's other retail water agencies to produce long-term projected water use over the next 25 years, in five-year increments, for each agency (MWDOC, 2025).

The City also conducted a DRA to evaluate a drought period that lasts five consecutive water years starting from the year following when the assessment is conducted (2026-2030). An analysis of both assessments determined that the City is capable of meeting all customers' demands from 2025 through 2050 for a normal year, a single dry year, and a drought lasting five consecutive years with significant imported water supplemental drought supplies from MWDOC/MET and ongoing conservation program efforts. The City receives the majority of its water supply from CDWC, as well as supplemental supplies from local groundwater from the La Habra Basin that adds reliability for non-potable water demand. As a result, there is no projected shortage condition due to drought that will trigger customer demand reduction actions until CDWC or MWDOC notifies the City of insufficient imported supplies. More information is available in the City's 2025 UWMP Sections 6 and 7 (City of Brea, 2026).

3.2 Annual Water Supply and Demand Assessment Procedures Per Water Code Section 10632.1, the City will conduct an AWSDA pursuant to subdivision (a) of Section 10632 and by July 1 of each year, beginning in 2022, submit an AWSDA with information for anticipated shortage, triggered shortage response actions, compliance and enforcement actions, and communication actions consistent with the Supplier's WSCP.

The City must include in its WSCP the procedures used for conducting an AWSDA. The AWSDA is a determination of the near-term outlook for supplies and demands and how a perceived shortage may relate to WSCP shortage stage response actions in the current calendar year. This determination is based on information available to the City at the time of the analysis. Starting in 2022, the AWSDA is due by July 1 of every year.

This section documents the decision-making process required for formal approval of the City's AWSDA determination of water supply reliability each year, the key data inputs and the methodologies used to evaluate the water system reliability for the coming year, while considering that the year to follow would be considered dry.

3.2.1 Decision-Making Process
The following decision-making process describes the functional steps that the City will take to formally approve the AWSDA determination of water supply reliability each year. 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 12

3.2.1.1 City Steps to Approve the AWSDA Determination
The AWSDA will be predicated on the CDWC Basin Operating Safe Yield (OSY) and on MWDOCs AWSDA outcomes. Figure 4 shows the AWSDA reporting timeline for the City of Brea.

Figure 4 AWSDA Reporting Timeline
The City obtains imported groundwater supply from CDWC, a mutual water company. CDWC provides groundwater from the Main San Gabriel Basin to each of its member agencies who owns and/or leases stock in the company. Each CDWC member agency receives a prescribed entitlement to water based upon the number of shares owned and the safe yield of the Main San Gabriel Basin. The member agency entitlement criterion per share varies year by year, based on CDWC's allotted percentage and the Basin OSY of the Main San Gabriel Basin. As so, there is not a permanent limit or cap on the amount of water CDWC can produce from the Basin; however, prescriptive pumping rights are adjusted based on the determination of the OSY annually. The OSY is determined annually by the Main San Gabriel Basin Watermaster, the agency created by the Main San Gabriel Judgment to manage the Main San Gabriel Basin. Agencies that use water beyond their share of entitlement must pay a surcharge levied by CDWC. A supply reduction that may result from the annual OSY projection will be included in the AWSDA.

While the City's primary source of water is CDWC groundwater, in the event of an emergency or shortage condition, the remaining source to meet retail demands comes from the purchase of imported water from MWDOC. MWDOC surveys its member agencies annually for anticipated water demands and supplies for the upcoming year. MWDOC utilizes this information to plan for the anticipated imported water supplies for the MWDOC service area. This information is then shared and coordinated with MET and is incorporated into their analysis of their service area's annual imported water needs. Based on the year's supply conditions and WSDM actions, MET will present a completed AWSDA for its member agencies' review from which they will then seek Board approval in April of each year. Additionally, MET expects that any triggers or specific shortage response actions that result from the AWSDA will be approved by their 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 13
Board at that time. Based upon MET's Assessment and taking into consideration information provided to MWDOC through the annual survey, MWDOC will provide an anticipated estimate of imported supplies for the City to incorporate into the AWSDA.

The AWSDA findings will determine the approval process. If a shortage is identified, the AWSDA will be taken to City Council for approval and formally submitted to DWR prior to the July 1 deadline. If no shortage is identified, the AWSDA will be approved by the Public Works Director, or designee, and formally submitted to DWR prior to the July 1 deadline.

3.2.2 Data and Methodologies
The following paragraphs document the key data inputs and methodologies that are used to evaluate the water system reliability for the coming year, while considering that the year to follow would be considered dry.

3.2.2.1 Assessment Methodology
The City will evaluate water supply reliability for the current year and one dry year for the purpose of the AWSDA. The AWSDA determination will be based on considerations of unconstrained water demand, local water supplies, MWDOC/MET imported water supplies, planned water use, and infrastructure considerations. The balance between projected local supplies coupled with MET imported supplies and anticipated unconstrained demand will be used to determine what, if any, shortage level is expected under the WSCP framework as presented in Figure 5. The WSCP's standard shortage levels are defined in terms of shortage percentages. Shortage percentages will be calculated by dividing the difference between water supplies and unconstrained demand by total unconstrained demand. This calculation will be performed separately for anticipated current year conditions and for assumed dry year conditions.

Figure 5 Water Shortage Contingency Plan AWSDA Framework 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 14

3.2.2.2 Locally Applicable Evaluation Criteria
Within the CDWC service area, there are no significant local applicable criteria that directly affect reliability. Through the years, the CDWC has made efforts to ensure supply reliability by adjusting prescriptive pumping rights based on the annual determination of the OSY. In the City's service area, most of the City's demands are met with imported groundwater from CDWC and imported water from MWDOC, augmented by local groundwater, where its limitation is based on the capacity of the City's system and well pumping capacity.

The City will also continue to monitor emerging supply and demand conditions related to supplemental imported water from MWDOC/MET and take appropriate actions consistent with the flexibility and adaptiveness inherent to the WSCP. The City's AWSDA was based on the City's service area, water sources, water supply reliability, and water use as described in Water Code Section 10631, including available data from state, regional, or local agency population, land use development, and climate change projections within the service area of the City. Some conditions that affect MWDOC's wholesale supply and demand, such as groundwater replenishment, surface water and local supply production, can differ significantly from earlier projections throughout the year.

If a major earthquake on the San Andreas Fault occurs, it has the potential to damage all three key regional water aqueducts and disrupt imported supplies for up to six months. The region would likely impose a water use reduction ranging from 25-35 percent until the system is repaired. However, MET has taken proactive steps to handle such disruption, such as constructing DVL, and prepositioning necessary reconstruction resources to quickly recover from such a seismic event, which mitigates potential impacts.

DVL, along with other local reservoirs, can store a six to twelve-month supply of emergency water (MET, 2026a).

3.2.2.3 Water Supply
The City relies on a combination of groundwater and imported water to meet its water needs. The City works with CDWC and MWDOC to ensure a safe and reliable water supply that will continue to serve the community in periods of average, dry and drought hydrologic conditions. In FY 2024-25, the City relied on approximately 93 percent from purchased groundwater from CDWC, 6 percent imported water from MWDOC, and 1 percent groundwater from La Habra Basin.

It is projected that by 2050, the City's water portfolio will remain to be similar as it is currently, as detailed in Chapter 6 of the City's 2025 UWMP. It should be noted that these representations of supply match the projected demand. However, the City can purchase more MET imported water through MWDOC, should the need arise (City of Brea, 2026).

3.2.2.4 Unconstrained Customer Demand
The WSCP and AWSDA define unconstrained demand as expected water use prior to any projected shortage response actions that may be taken under the WSCP. Unconstrained demand is distinguished from observed demand, which may be constrained by preceding, ongoing, or future actions, such as emergency supply allocations during a multi-year drought. WSCP shortage response actions to constrain demand are inherently extraordinary; routine activities such as ongoing conservation programs and regular operational adjustments are not considered as constraints on demands. 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 15
The City's DRA reveals that its supply capabilities are expected to balance anticipated total water use and supply, assuming a five-year consecutive drought from FY 2025-26 through FY 2029-30 (City of Brea, 2026). This is based on the water demand projection model, in a single dry year, demand is expected to increase by 7 percent above a normal year (MWDOC, 2025).

For the City, the five consecutive dry year demand scenario is based on the demand model's multiple dry year methodology. In accordance with the econometric demand model approach used to develop UWMP demand projections, a single hot/dry year was first identified based on weather conditions that produced the greatest demand response. Consecutive dry years were then represented by applying incremental scaling factors to this single hot/dry year demand to account for the compounding effects of persistent warm and dry conditions over time. These scaling factors show long‑term relationships between regional water use and multi‑year temperature and precipitation deficits and are applied sequentially to simulate second through fifth consecutive dry years. This approach is consistent with the demand modeling framework summarized in Chapter 7 of the City's UWMP.

3.2.2.5 Planned Water Use for Current Year Considering Dry Subsequent Year Water Code Section 10632(a)(2)(B)(ii) requires the AWSDA to determine "current year available supply, considering hydrological and regulatory conditions in the current year and one dry year." The AWSDA will include two separate estimates of City's annual water supply and unconstrained demand using: (1) current year conditions; and (2) assumed dry year conditions. Accordingly, the AWSDA's shortage analysis will present separate sets of findings for the current year and dry year scenarios. The Water Code does not specify the characteristics of a dry year, allowing discretion to the Supplier. The City will use its discretion to refine and update its assumptions for a dry year scenarios in each AWSDA as information becomes available and in accordance with best management practices.

Supply and demand analyses for the single-dry year case were based on conditions affecting the SWP as this supply availability fluctuates the most among MET's, and therefore MWDOC and the City's, sources of supply. Severe drought conditions in 2021-2022 affected must of the Western United States, including the Colorado River system, which caused its water supply decrease. As conditions worsened, Lake Mead and Lake Powell (the largest storage units in the system), had a combined total storage capacity of 25 percent in 2022, a significant decrease from 39 percent in 2021 (MWDOC, 2024).

The Orange County Water Demand Projection Model isolated the impacts that weather and future climate can have on water demand through the use of a statistical model. The impacts of hot/dry weather conditions are reflected as a percentage increase in water demands from the normal year condition. For a single dry year condition (FY 2013-14), the model projects a 3 percent increase in demand for the City's service area (MWDOC, 2025). Detailed information of the model is included in the City's 2025 UWMP.

The City has documented that it is 100 percent reliable for single dry year demands from 2025 through 2050 with a demand increase of 3 percent from normal demand with significant reserves held by MET, local groundwater supplies, and conservation (City of Brea, 2026).

3.2.2.6 Infrastructure Considerations
The AWSDA will include consideration of any infrastructure issues that may pertain to near-term water supply reliability, including repairs, construction, and environmental mitigation measures that may temporarily constrain capabilities, as well as any new projects that may add to system capacity. MWDOC 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 16
closely coordinates with MET and its member agencies, including the City, on any planned infrastructure work that may impact water supply availability. Throughout each year, MET regularly carries out preventive and corrective maintenance of its facilities within the MWDOC service area that may require shutdowns to inspect and repair pipelines and facilities and support capital improvement projects. These shutdowns involve a high level of planning and coordination between MWDOC, MWDOC's member agencies, and MET to ensure that major portions of the distribution system are not out of service at the same time. Operational flexibility within MET's system and the cooperation of member agencies allow shutdowns to be successfully completed while continuing to meet all system demands.

For the City, if any of the City's key water system elements, including pressure zones, distribution lines, service connections, reservoirs, pump stations, pressure reducing stations, and purchased water connections, are affected during a catastrophic event or emergency, the City's water supply would consequently be affected. Specifically for the City, as of March 2026 there are no foreseen near-term infrastructure issues that would impact supply.

3.2.2.7 Other Factors
For the AWSDA, any known issues related to water quality would be considered for their potential effects on water supply reliability.

Per- and polyfluoroalkyl substances (PFAS) are a group of thousands of manmade chemicals that includes perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). PFAS compounds were once commonly used in many products including, among many others, stain- and water-repellent fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning products, and fire-fighting foams.

MET has voluntarily monitored PFAS in its source and treated waters since 2017. Most samples have shown non detect (ND) for all tested PFAS, including PFOA and PFOS. A limited number of other PFAS— such as PFHxA, PFBA, PFPeA, PFDoA, PFTA, and PFBS, have been detected only at trace levels below their method detection limits. PFOA and PFOS have not been detected in MET's imported or treated water supplies. Some member agencies, however, have detected these compounds in local groundwater wells, which may require treatment or source management to comply with emerging Division of Drinking Water (DDW) regulations. As DDW and US Environmental Protection Agency (EPA) establish enforceable maximum contaminant levels (MCLs) for PFOA and PFOS, some agencies may supplement their local supplies with increased purchases of MET water (MET, 2025).

The EPA finalized the first national drinking water standards for six PFAS compounds in April 2024. These standards include enforceable MCLs for PFOA and PFOS set at 4 parts per trillion (ppt). In May 2025 the EPA announced that it would extend the compliance deadline for PFOA and PFOS from 2029 to 2031 to provide additional time for testing, planning, and installation of treatment technologies. While MET and its member agencies continue to monitor and test PFAS in imported and local sources, the delay in the federal compliance date allows additional time to evaluate treatment options, coordinate funding, and plan system upgrades necessary to meet forthcoming federal PFAS standards.

3.3 Six Standard Water Shortage Levels
Per Water Code Section 10632 (a)(3)(A), Suppliers must include the six standard water shortage levels that represent shortages from the normal reliability as determined in the AWSDA or cross-reference their shortage levels to the standard levels. The shortage levels have been standardized to provide a consistent 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 17
regional and statewide approach to conveying the relative severity of water supply shortage conditions.

This is an outgrowth of the severe statewide drought of 2012-2016, and the widely recognized public communication and state policy uncertainty associated with the many different local definitions of water shortage levels.

The six standard water shortage levels correspond to progressively increasing estimated shortage conditions (up to 10, 20, 30, 40, 50, and greater than 50 percent shortage compared to the normal reliability condition) and align with the response actions the Supplier would implement to meet the severity of the impending shortages (Table 1).

Table 1 Cross-Reference for Standard vs Supplier Shortage Levels Submittal Table 8-1: Cross-reference for Standard vs Supplier Shortage Levels Water Code Section 10632(a)(3)(B)
Check the box if the Supplier uses the Standard six levels of water shortage.

Proceed to the next table.

Standard
Shortage Levels
Percent
Shortage Range Suppliers Shortage Levels Percent Shortage Range 1 Up to 10%
2 Up to 20%
3 Up to 30%
4 Up to 40%
5 Up to 50%
6 >50%
NOTES:

3.4 Shortage Response Actions
Water Code Section 10632 (a)(4) requires the WSCP to specify shortage response actions that align with the defined shortage levels. The City has defined specific shortage response actions that align with the defined shortage levels in DWR Tables 8-2 and 8-3 (Appendix A). These shortage response actions were developed with consideration to the system infrastructure and operations changes, supply augmentation responses, customer-class or water use-specific demand reduction initiatives, and increasingly stringent water use prohibitions.

3.4.1 Supply Augmentation
The supply augmentation actions are described in DWR Table 8-2 (Appendix A). These augmentations represent short-term management objectives triggered by MET's WSDM Plan and do not overlap with the long-term new water supply development or supply reliability enhancement projects. Supply Augmentation is made available to the City through MWDOC/MET and CDWC. The City is able to lease additional shares of CDWC stock from member agencies that do not use their maximum allotted amount.

Additionally, as a MWDOC member agency, the City can further augment supply with imported water from MWDOC/MET. However, additional imported water purchases to meet the supply gap may have financial ramifications per MWDOC's WSAP.
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 18
MET's reliability portfolio of water supply programs includes existing water transfers, storage, and exchange agreements to supplement gaps in the City's supply/demand balance. MET has developed significant storage capacity (over 5 million AF) in reservoirs and groundwater banking programs both within and outside of the Southern California region. Additionally, MET can pursue additional water transfer and exchange programs with other water agencies to help mitigate supply/demand imbalances and provide additional dry-year supply sources.

3.4.2 Demand Reduction
The demand reduction measures that would be implemented to address shortage levels are described in DWR Table 8-3 (Appendix A). This table indicates which actions align with specific defined shortage levels and estimates the extent to which the actions will reduce the gap between supplies and demands to deliver the outcomes necessary to meet the requirements of a given shortage level. This table also identifies the enforcement action, if any, associated with each demand reduction measure.

Demand reduction actions designated by the City to reduce shortage gaps include a variety of statewide prohibitions, ongoing long-term conservation savings measures, repairing leaks within water systems, drought rates, and other prohibited uses, starting at the baseline in a normal year with no shortage. These actions include statewide prohibitions on decorative water features, washing hard surfaces or vehicles, irrigation, and new planting, fixing leaks within systems, limiting times for landscape irrigation, implementing, or modifying drought rates, swimming pool restrictions, and expanding public information campaigns, corresponding to reductions in the shortage gap of up to 70 percent (Appendix A).

3.4.3 Operational Changes
During shortage conditions, operations may be affected by supply augmentation or demand reduction responses. The City will consider their operational procedures when it completes its AWSDA or as needed to identify changes that can be implemented to address water shortage on a short-term basis, such as temporarily altering maintenance cycles, deferring planned system outages, and adjusting the flow and routing of water through its system to more effectively distribute available supply across the service area.

3.4.4 Additional Mandatory Restrictions
Water Code Section 10632(a)(4)(D) calls for "additional, mandatory prohibitions against specific water use practices that are in addition to state-mandated prohibitions and appropriate to the local conditions" to be included among the WSCP's shortage response actions. The City has identified additional mandatory restrictions in the Water Shortage Contingency Response Ordinance 1221 (Appendix B).

3.4.5 Emergency Response Plan (Hazard Mitigation Plan)
A catastrophic water shortage would be addressed according to the appropriate water shortage level and response actions. It is likely that a catastrophic shortage would immediately trigger Shortage Level 6 and response actions have been put in place to mitigate a catastrophic shortage. In addition, there are several Plans that address catastrophic failures and align with the WSCP, including MET's WSDM and WSAP, the City's Local Hazard Mitigation Plan (LHMP), and the Water Emergency Response Organization of Orange County (WEROC)'s Emergency Operations Plan (EOP).
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 19

3.4.5.1 MET's WSDM and WSAP
MET has comprehensive plans for stages of actions it would undertake to address a catastrophic interruption in water supplies through its WSDM and WSAP. MET also developed an Emergency Storage Requirement to mitigate against potential interruption in water supplies resulting from catastrophic occurrences within the southern California region, including seismic events along the San Andreas Fault. In addition, MET is working with the state to implement a comprehensive improvement plan to address catastrophic occurrences outside of the Southern California region, such as a maximum probable seismic event in the Sacramento-San Joaquin River Delta that would cause levee failure and disruption of SWP deliveries.

3.4.5.2 Water Emergency Response Organization of Orange County Emergency Operations Plan
In 1983, the Orange County water community identified a need to develop a plan on how agencies would respond effectively to disasters impacting the regional water distribution system. The collective efforts of these agencies resulted in the formation of WEROC to coordinate emergency response on behalf of all Orange County water and wastewater agencies, develop an emergency plan to respond to disasters, and conduct disaster training exercises for the Orange County water community. WEROC, administered by MWDOC, was established through the creation of an indemnification agreement among its member agencies to protect each other against civil liabilities and to facilitate the exchange of resources. WEROC is unique in its ability to provide a single point of contact for the representation of all water and wastewater utilities in Orange County during a disaster. This representation is to the county, state, and federal disaster coordination agencies. Within the Orange County Operational Area, WEROC is the recognized contact for emergency response for the water community, including the City.

As a member of WEROC, the City will follow WEROC's EOP in the event of an emergency and coordinate with WEROC to assess damage, initiate repairs, and request and coordinate mutual aid resources in the event that the City is unable to provide the level of emergency response support required by the situation.

The EOP defines the actions to be taken by WEROC Emergency Operations Center (EOC) staff to reduce the loss of water and wastewater infrastructure; to respond effectively to a disaster; and to coordinate recovery operations in the aftermath of any emergency involving extensive damage to Orange County water and wastewater utilities. The EOP includes activation notification protocol that will be used to contact partner agencies to inform them of the situation, activation status of the EOC, known damage or impacts, or resource needs. The EOP is a standalone document that is reviewed annually and approved by the MWDOC Board every three years.

WEROC is organized on the basis that each member agency is responsible for developing its own EOP in accordance with the California Standardized Emergency Management System (SEMS), National Incident Management System (NIMS), and Public Health Security and Bioterrorism Preparedness and Response Act of 2002 to meet specific emergency needs within its service area.

The WEROC EOC is responsible for assessing the overall condition and status of the Orange County regional water distribution and wastewater collection systems including MET facilities that serve Orange County. The EOC can be activated during an emergency situation resulting from both natural and man-made causes, and can be activated through automatic, manual, or standby for activation. 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 20
WEROC recognizes four primary phases of emergency management, which include:
 Preparedness: Planning, training, and exercises that are conducted prior to an emergency to support and enhance response to an emergency or disaster.
 Response: Activities and programs designed to address the immediate and short-term effects of the onset of an emergency or disaster that helps to reduce effects on water infrastructure and speed recovery. This includes alert and notification, EOC activation, direction and control, and mutual aid.  Recovery: This phase involved restoring systems to normal, in which short-term recovery actions are taken to assess the damage and return vital life-support systems to minimum operating standards, while long-term recovery actions have the potential to continue for many years.  Mitigation/Prevention: These actions prevent the occurrence of an emergency or reduce the area's vulnerability in ways that minimize the adverse impacts of a disaster or emergency.

The EOC Action Plans provide frameworks for EOC staff to respond to different situations with the objectives and steps required to complete them, which will in turn serve the WEROC member agencies. In the event of an emergency that results in a catastrophic water shortage, the City will declare a water shortage condition of up to Level 3 for the impacted area depending on the severity of the event, and coordination with WEROC is anticipated to begin at Level 4 or greater (WEROC, 2021).

3.4.5.3 City of Brea's Emergency Response Plan
The City will also refer to its current American Water Infrastructure Act Risk and Resilience Assessment and Emergency Response Plan in the event of a catastrophic supply interruption (City of Brea, 2026b).

3.4.6 Seismic Risk Assessment and Mitigation Plan
Per the Water Code Section 10632.5, Suppliers are required to assess seismic risk to water supplies as part of their WSCP. The plan also must include the mitigation plan for the seismic risk(s). Given the great distances that imported supplies travel to reach Orange County, the region is vulnerable to interruptions along hundreds of miles of aqueducts, pipelines and other facilities associated with delivering the supplies to the region. Additionally, the infrastructure in place to deliver supplies is susceptible to damage from earthquakes and other disasters.

In lieu of conducting a seismic risk assessment specific to the City's 2025 UWMP, the City has included their LHMP, as required under the federal Disaster Mitigation Act of 2000 (Public Law 106-390). The LHMP describes the City's approach to proactively decreasing threats before disaster occurs, including water supply specific mitigation actions such as improving security and alert systems, upgrading back-up power systems, and retrofitting existing flood control infrastructure (City of Brea, 2024).

3.4.7 Shortage Response Action Effectiveness
For each specific Shortage Response Action identified in the WSCP, the plan also estimates the extent to which that action will reduce the gap between supplies and demands identified in DWR Table 8-2 (Appendix A). To the extent feasible, the City has estimated percentage savings for the chosen suite of shortage response actions, which can be anticipated to deliver the expected outcomes necessary to meet the requirements of a given shortage level.
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 21

3.5 Communication Protocols
Timely and effective communication is a key element of the WSCP implementation. In the context of water shortage response, the purpose may be an emergency water shortage situation, such as may result from an earthquake, or a longer-term, non-emergency, shortage condition, such as may result from a drought.

In an emergency, the City will activate the communication protocol detailed in the Emergency Response Plan. In a non-emergency water shortage situation, the City will implement follow the communication protocols described below.

Per the Water Code Section 10632 (a)(5), the City has established communication protocols and procedures to inform customers, the public, interested parties, and local, regional, and state governments regarding any current or predicted shortages as determined by the AWSDA described pursuant to Section 10632.1; any shortage response actions triggered or anticipated to be triggered by the AWSDA described pursuant to Section 10632.1; and any other relevant communications.

Non-emergency water shortage communication protocols are focused on communicating the water shortage contingency planning actions that can be derived from the results of the AWSDA, and it would likely trigger based upon the decision-making process in Section 3.2. Prior to water shortage level declaration, the City will pursue outreach to inform customers of water shortage levels and definitions, targeted water savings for each drought stage, guidelines that customers are to follow during each level, and sources of current information on the City's supply and demand response status.

The type and degree of communication will vary with each shortage level in order to inform stakeholders of the current water shortage level status and associated shortage response actions, as defined in Section 3.4.1. Predefined communication objectives and tools will ensure the City's ability to message necessary events and information to ensure compliance with shortage response actions. These communication objectives and tools are summarized in Table 2.

Table 2 Communication Procedures
Shortage Level Communication Objectives Communication Tools 1 Compliance with response actions,
10% reduction in water use
 Webpage, social media,
 Water Bill communications
 Website information on the "City homepage"
 Social Media Outreach
 Adopt a City Council Resolution for the applicable Water Shortage Level
 Staff presence at local events
 Water Waste Patrols
2 Compliance with response actions,
20% reduction in water use
 Water Bill communications
 Website information on the "City homepage"
 Social Media Outreach
 Adopt a City Council Resolution for the applicable Water Shortage Level
 Staff presence at local events
3 Compliance with response actions,
30% reduction in water use
4 Compliance with response actions,
40% reduction in water use
5 Compliance with response actions,
50% reduction in water use
6 Compliance with response actions,
>50% reduction in water use
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 22
The City's Public Relations department will lead public information and outreach efforts in close coordination with other MWDOC and MET. The City will share information and provide guidance to its customers as well as monitor the customer response and attitude toward both voluntary and mandatory customer response guidelines. The City's customer outreach is required to successfully achieve targeted water savings during each shortage level.

3.6 Compliance and Enforcement
Per the Water Code Section 10632 (a)(6), the City has defined customer compliance, enforcement, appeal, and exemption procedures for triggered shortage response actions. Communication procedures to ensure customer compliance are described in Section 3.5 Communication Protocols and customer enforcement, appeal, and exemption procedures defined in the Water Shortage Contingency Response Ordinance 1221 (Appendix B).

3.7 Legal Authorities
Per Water Code Section 10632 (a)(7)(A), the City has provided a description of the legal authorities that empower the City to implement and enforce its shortage response in the City's Water Shortage Contingency Response Ordinance 1221 (Appendix B).

Per Water Code Section 10632 (a)(7) (B), the City shall declare a water shortage emergency condition to prevail within the area served by such wholesaler whenever it finds and determines that the ordinary demands and requirements of water consumers cannot be satisfied without depleting the water supply of the distributor to the extent that there would be insufficient water for human consumption, sanitation, and fire protection.

Per Water Code Section 10632 (a)(7)(C), the City shall coordinate with any agency or county within which it provides water supply services for the possible proclamation of a local emergency under California Government Code, California Emergency Services Act (Article 2, Section 8558). Table 3 identifies the contacts for all cities or counties for which the Supplier provides service in the WSCP, along with developed coordination protocols, can facilitate compliance with this section of the Water Code in the event of a local emergency as defined in subpart (c) of Government Code Section 8558.

Table 3 Agency Contacts and Coordination Protocols
Contact Agency Coordination Protocols
Water Distribution Superintendent, or designee City of Brea Phone person directly General Manager, or designee MWDOC Phone person directly Director of Water Operations, or designee CDWC Phone person directly Public Works Director, or designee County of Orange Phone person directly

3.8 Financial Consequences of WSCP
Per Water Code Section 10632(a)(8), Suppliers must include a description of the overall anticipated financial consequences to the Supplier of implementing the WSCP. This description must include potential reductions in revenue and increased expenses associated with implementation of the shortage response actions. This should be coupled with an identification of the anticipated mitigation actions needed to address these financial impacts.
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 23
During a catastrophic interruption of water supplies, prolonged drought, or water shortage of any kind, the City will experience a reduction in revenue due to reduced water sales. Throughout this period of time, expenditures may increase or decrease with varying circumstances. Expenditures may increase in the event of significant damage to the water system, resulting in emergency repairs. Expenditures may also decrease as less water is pumped through the system, resulting in lower power costs. Water shortage mitigation actions will also impact revenues and require additional costs for drought response activities such as increased staff costs for tracking, reporting, and communications.

The City receives water revenue from a service charge and a commodity charge based on consumption.

The service charge recovers costs associated with providing water to the serviced property. The service charge does not vary with consumption and the commodity charge is based on water usage. Rates have been designed to recover the full cost of water service in the charges. Therefore, the total cost of purchasing water would decrease as the usage or sale of water decreases. In the event of a drought emergency, the City will impose excessive water use penalties on its customers, which may include additional costs associated with reduced water revenue, staff time taken for penalty enforcement, and advertising the excessive use penalties. The excessive water use penalties are further described in the City's Water Shortage Contingency Response Ordinance 1221 (Appendix B).

However, there are significant fixed costs associated with maintaining a minimal level of service. The City will monitor projected revenues and expenditures should an extreme shortage and a large reduction in water sales occur for an extended period of time. To overcome these potential revenue losses and/or expenditure impacts, the City may use reserves. If necessary, the City may reduce expenditures by delaying implementation of its Capital Improvement Program and equipment purchases to reallocate funds to cover the cost of operations and critical maintenance, adjust the work force, implement a drought surcharge, and/or make adjustments to its water rate structure.

Based on current water rates, a volumetric cutback of 50 percent and above of water sales may lead to a range of reduction in revenues. The impacts to revenues will depend on a proportionate reduction in variable costs related to supply, pumping, and treatment for the specific shortage event. The City has set aside reserve funding as a Drought Reserve Fund to mitigate short-term water shortage situation.

3.9 Monitoring and Reporting
Per Water Code Section 10632(a)(9), the City is required to provide a description of the monitoring and reporting requirements and procedures that have been implemented to ensure appropriate data is collected, tracked, and analyzed for purposes of monitoring customer compliance and to meet state reporting requirements.

Monitoring and reporting key water use metrics is fundamental to water supply planning and management. Monitoring is also essential in times of water shortage to ensure that the response actions are achieving their intended water use reduction purposes, or if improvements or new actions need to be considered (see Section 3.10). Monitoring for customer compliance tracking is also useful in enforcement actions.

Under normal water supply conditions, potable water production figures are recorded daily. Weekly and monthly reports are prepared and monitored. This data will be used to measure the effectiveness of any water shortage contingency level that may be implemented. As levels of water shortage are declared by MET and MWDOC, the City will follow implementation of those levels as appropriate based on the City's 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 24
risk profile provided in UWMP Chapter 6 and continue to monitor water demand levels. When MET calls for extraordinary conservation, MET's Drought Program Officer will coordinate public information activities with MWDOC and monitor the effectiveness of ongoing conservation programs.

The City will participate in monthly member agency manager meetings with MWDOC to monitor and discuss monthly water allocation charts. This will enable the City to be aware of import and groundwater use on a timely basis as a result of specific actions taken responding to the City's WSCP.

3.10 WSCP Refinement Procedures
Per Water Code Section 10632 (a)(10), the City must provide reevaluation and improvement procedures for systematically monitoring and evaluating the functionality of the water shortage contingency plan in order to ensure shortage risk tolerance is adequate and appropriate water shortage mitigation strategies are implemented as needed.

The City's WSCP is prepared and implemented as an adaptive management plan. The City will use the monitoring and reporting process defined in Section 3.9 to refine the WSCP. In addition, if certain procedural refinements or new actions are identified by City staff, or suggested by customers or other interested parties, the City will evaluate their effectiveness, incorporate them into the WSCP, and implement them quickly at the appropriate water shortage level.

It is envisioned that the WSCP will be periodically re-evaluated to ensure that its shortage risk tolerance is adequate and the shortage response actions are effective and up to date based on lessons learned from implementing the WSCP. The WSCP will be revised and updated during the UWMP update cycle to incorporate updated and new information. For example, new supply augmentation actions will be added, and actions that are no longer applicable for reasons such as program expiration will be removed.

However, if revisions to the WSCP are warranted before the UWMP is updated, the WSCP will be updated outside of the UWMP update cycle. In the course of preparing the AWSDA each year, City staff will routinely consider the functionality the overall WSCP and make updates if changes are found to be needed.

3.11 Special Water Feature Distinction
Per Water Code Section 10632 (b), the City has defined water features in that are artificially supplied with water, including ponds, lakes, waterfalls, and fountains, separately from swimming pools and spas, as defined in subdivision (a) of Section 115921 of the Health and Safety Code, in the City's Water Shortage Contingency Response Ordinance 1221 (Appendix B).

3.12 Plan Adoption, Submittal, and Availability
Per Water Code Section 10632 (a)(c), the City provided notice of the availability of the draft 2025 UWMP and draft 2025 WSCP and notice of the public hearing to consider adoption of the WSCP. The public review drafts of the 2025 UWMP and the 2025 WSCP were posted prominently on the City website in advance of the public hearing on May 19, 2026. Copies of the draft WSCP were also made available for public inspection at the City Clerk's and Utilities Department offices and public hearing notifications were published in local newspapers. A copy of the published Notice of Public Hearing is included in Appendix C.
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA 25
The City held the public hearing for the draft 2025 UWMP and draft WSCP on May 19, 2026, at the City Council meeting. The City Council reviewed and approved the 2025 UWMP and the WSCP at its May 19, 2026 meeting after the public hearing. See Appendix D for the resolution approving the WSCP.

By July 1, 2021, the City's adopted 2025 UWMP and WSCP was filed with DWR, California State Library, and the County of Orange. The City will make the WSCP available for public review on its website no later than 30 days after filing with DWR.

Based on DWR's review of the WSCP, the City will make any amendments in its adopted WSCP, as required and directed by DWR.

If the City revises its WSCP after UWMP is approved by DWR, then an electronic copy of the revised WSCP will be submitted to DWR within 30 days of its adoption.

SECTION 4 REFERENCES
City of Brea. (2026a, July). 2025 Urban Water Management Plan.

City of Brea. (2026b, June). City of Brea Water System Risk and Resilience Assessment.

City of Brea. (2024). Local Hazard Mitigation Plan.

Metropolitan Water District of Southern California (MET). (2026a). 2025 Water Shortage Contingency Plan.

Metropolitan Water District of Southern California (MET). (2026b). 2025 Urban Water Management Plan.

Municipal Water District of Orange County. (2023, July). 2023 Orange County Water Reliability Study.

Municipal Water District of Orange County. (2024). Multi-Jurisdictional Hazard Mitigation Plan.

Municipal Water District of Orange County. (2025, December 30). Orange County Water Demand Projection Model Technical Memorandum.

Water Emergency Response Organization of Orange County (WEROC). (2025). WEROC 2025 Annual Report.
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO

CITY OF BREA

APPENDIX A DWR SUBMITTAL TABLES
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA A-1
Submittal Table 8-1: Cross Reference for Standard vs Supplier Shortage Level Submittal Table 8-1: Cross-reference for Standard vs Supplier Shortage Levels Water Code Section 10632(a)(3)(B)
Check the box if the Supplier uses the Standard six levels of water shortage.

Proceed to the next table.

Standard
Shortage Levels
Percent
Shortage Range
Suppliers
Shortage Levels
Percent
Shortage Range
1 Up to 10%
2 Up to 20%
3 Up to 30%
4 Up to 40%
5 Up to 50%
6 >50%
NOTES:

Submittal Table 8-2: Supply Augmentation and Other Actions Submittal Table 8-2 Retail: Supply Augmentation and Other Actions Water Code Section 10632(a)(4)(A),(C) and (E)
Yes Is the Supplier completing this table using the standard six levels? (yes/no) Shortage
Level
Supply Augmentation Methods and
Other Actions by Water Supplier
Drop down list
These are the only categories that
will be accepted by the WUEdata
online submittal tool
How much is this going to reduce
the shortage gap?
Additional Explanation or
Reference
(OPTIONAL)
Volume or
Percentage
Drop down
Shortage Gap
Reduction Value
(May be a
range)
(AF)
Add additional rows as needed
1 through 6 Other Purchases Percentage 0 - 100%
Additional imported water
purchases through
MWDOC
1 through 6 Other Purchases Percentage 0 - 100%
Additional imported water
purchases through
CDWC
4 through 6 Other Purchases Percentage 0 - 25% Intertie connections with neighboring cities
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.

NOTES: Additional Imported Water Purchases to meet the supply gap may have financial ramifications per the MWDOC Water Supply Allocation Plan.

AF - acre-feet; CCF - centum cubic feet; MG - million gallons 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA A-2
Submittal Table 8-3: Demand Reduction Actions
Submittal Table 8-3 Retail: Demand Reduction Actions
Water Code Section 10632(a)(4)(B) and (E)
Yes Is the Supplier completing this table using the standard six levels? (yes/no) Shortage
Level
Demand Reduction Actions
Drop down list
These are the only categories that
will be accepted by the WUEdata
online submittal tool. Select those
that apply.

How much is this going to reduce the shortage gap?
Additional Explanation or Reference
(OPTIONAL)
Penalty, Charge, or
Other Enforcement?
For Retail Suppliers
Only
Drop Down List
Volume or
Percentage
Drop down
Shortage Gap Reduction Value
(May be a range)
(AF)
Add additional rows as needed
0 Landscape - Prohibit certain types
of landscape irrigation
Statewide Prohibition is Required Watering or irrigation of nonfunctional turf (NFT) on State and local government properties, commercial, industrial, and institutional owned landscapes, homeowners' associations common area landscapes, and local government facilities in disadvantaged communities (DAC) is prohibited. See Note 1 below No
0 Landscape - Prohibit certain types
of landscape irrigation
Statewide Prohibition is Required Watering or irrigation of nonfunctional turf on publicly owned landscapes, commercial, industrial, and institutional owned landscapes, or homeowners' associations common area landscapes is prohibited.

Yes
0 Other water feature or swimming
pool restriction
Statewide Prohibition is Required All decorative water features must re-circulate water or users must secure a waiver from the City of Brea. Yes 0 Other Statewide Prohibition is Required Washing or hosing down vehicles is prohibited except by use of a handheld container, hose with an automatic shut off device, or at a commercial car wash.

Yes
0 Other - Prohibit use of potable
water for washing hard surfaces
Statewide Prohibition is Required Washing hard or paved surfaces is prohibited except to alleviate safety or sanitary hazards using a handheld container, hose with an automatic shut off device, or a low-volume high pressure cleaning machine that recycles used water.

Yes
0 Landscape - Restrict or prohibit
runoff from landscape irrigation
Statewide Prohibition is Required Watering vegetated areas in a manner that causes excessive water flow or runoff onto an adjoining sidewalk, driveway, street, alley, gutter, or ditch is prohibited.

Yes
0 Landscape - Other landscape
restriction or prohibition
Statewide Prohibition is Required Irrigating ornamental turf on public street medians is prohibited. Yes 0 Landscape - Other landscape
restriction or prohibition
Statewide Prohibition is Required No landscape watering shall occur within 48 hours after measurable precipitation. Yes 0 Landscape - Limit landscape
irrigation to specific times
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

Watering or irrigation with a device that is not continuously attended to is limited to ten (10) minutes per day per valve. Low flow drip type systems, water efficient stream rotor systems, and sensor/weather-controlled systems are exempt.

Yes
0 Landscape - Other landscape
restriction or prohibition
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

Any new planting should be performed with drought tolerant plants, as listed in Metropolitan's list of California friendly plants and the City of Brea's established Drought Tolerant Plant List.

Yes
0 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

Fix leaks or faulty sprinklers within 3 days. Yes
0 CII - Restaurants may only serve
water upon request
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

CII - Restaurants may only serve water upon request Yes 0 CII - Lodging establishment must
offer opt out of linen service
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

CII - Lodging establishment must offer opt out of linen service Yes 0 CII - Other CII restriction or
prohibition
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

No single pass cooling systems may be installed in new or remodeled buildings. Yes 0 Other - Prohibit vehicle washing
except at facilities using recycled or
recirculating water
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

All new commercial car wash and laundry facilities must re-circulate the wash water or obtain a waiver from the City of Brea. Yes 0 CII - Commercial kitchens required
to use pre-rinse spray valves
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

Food preparation establishments must use water efficient kitchen spray valves. Yes 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA A-3
Submittal Table 8-3 Retail: Demand Reduction Actions
Water Code Section 10632(a)(4)(B) and (E)
Yes Is the Supplier completing this table using the standard six levels? (yes/no) Shortage
Level
Demand Reduction Actions
Drop down list
These are the only categories that
will be accepted by the WUEdata
online submittal tool. Select those
that apply.

How much is this going to reduce the shortage gap?
Additional Explanation or Reference
(OPTIONAL)
Penalty, Charge, or
Other Enforcement?
For Retail Suppliers
Only
Drop Down List
Volume or
Percentage
Drop down
Shortage Gap Reduction Value
(May be a range)
(AF)
Add additional rows as needed
0 Landscape - Limit landscape
irrigation to specific times
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

Watering or irrigation of vegetated areas is prohibited between 10 am and 4 pm except by use of a handheld device, hose equipped with an automatic shutoff device, or for adjusting or repairing an irrigation system for short periods of time.

Yes
0 Other - Require automatic shut of
hoses
On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

Use a shutoff nozzle on hoses. Yes
0 Offer Water Use Surveys On-going Long-Term Conservation Savings Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

Offer Water Use Surveys Yes
0 Other On-going Long-Term Conservation Savings
Measure. Not applicable to Water Shortage
Contingency Plan quantifiable savings.

Unauthorized use of hydrants is prohibited. Authorization for use must be obtained from water supplier. Yes 1 Expand Public Information
Campaign
Percentage 0-1% Community Outreach and Messaging (Expand Public Information Campaign) Yes 1 Expand Public Information
Campaign
Percentage 0-1% Encourage customers to wash only full loads when washing dishes or clothes. Yes 1 Expand Public Information
Campaign
Percentage 0-1% Encourage customers to use pool covers to minimize evaporation. Yes 1 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
Percentage 0-1% Fix leaks or faulty sprinklers within 3 days. Yes 1 Landscape - Other landscape
restriction or prohibition
Percentage 0-5% New and existing residential automated irrigation systems must be equipped with rain sensors that shut off the system when it rains, or smart controllers or evapo-transpiration sensors that use weather-based data to set efficient watering schedules.

Yes
1 Landscape - Limit landscape
irrigation to specific days
Percentage 5-10% Irrigation shall be limited to 4 days per week and the watering days shall be Monday, Wednesday, Friday & Sunday from May to September and 2 days per week and the watering days shall be Monday & Friday from October to April for turf watering when using potable water. Plant containers, trees, shrubs, and vegetable gardens may be watered additional days using only drip irrigation or hand watering.

Yes
1 Landscape - Limit landscape
irrigation to specific times
Percentage 0-5% Watering or irrigation of vegetated areas is prohibited between 10 am and 4 pm except by use of a handheld device, hose equipped with an automatic shutoff device, or for adjusting or repairing an irrigation system for short periods of time.

Yes
1 CII - Other CII restriction or
prohibition
Percentage 0-1% Commercial, industrial, institutional equipment must be properly maintained and in full working order. Yes 1 Other Percentage 5-10% Other Prohibited Uses: The City of Brea may implement other prohibited water uses as determined by the City of Brea, after notice to customers.

Yes
1 Reduce System Water Loss Percentage 0-5% Real Loss Reduction - Pressure Management and More Aggressive Leak Detection and Repair Yes 1 Increase Water Waste Patrols Percentage 0-1% Increase Water Waste Patrols Yes 2 Provide Rebates for Landscape
Irrigation Efficiency
Percentage 0-1% Expanded/Enhanced Rebate Programs Yes
2 Provide Rebates on Plumbing
Fixtures and Devices
Percentage 0-1% Provide Rebates on Plumbing Fixtures and Devices Yes 2 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
Percentage 0-1% Fix leaks or faulty sprinklers within 2 days. Yes 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA A-4
Submittal Table 8-3 Retail: Demand Reduction Actions
Water Code Section 10632(a)(4)(B) and (E)
Yes Is the Supplier completing this table using the standard six levels? (yes/no) Shortage
Level
Demand Reduction Actions
Drop down list
These are the only categories that
will be accepted by the WUEdata
online submittal tool. Select those
that apply.

How much is this going to reduce the shortage gap?
Additional Explanation or Reference
(OPTIONAL)
Penalty, Charge, or
Other Enforcement?
For Retail Suppliers
Only
Drop Down List
Volume or
Percentage
Drop down
Shortage Gap Reduction Value
(May be a range)
(AF)
Add additional rows as needed
2 Improve Customer Billing Percentage 0-3% AMI Customer Leak Reports with Detection and Repair Assistance Yes 2 Landscape - Limit landscape
irrigation to specific days
Percentage 5-10% Irrigation shall be limited to 3 days per week and the watering days shall be Wednesday, Friday & Sunday from May to September and 1 day per week and the watering day shall be Wednesday from October to April for turf watering when using potable water. Plant containers, trees, shrubs, and vegetable gardens may be watered additional days using only drip irrigation or hand watering.

Yes
2 Improve Customer Billing Percentage 0-1% Improve customer billing reports to include more details on water use Yes 2 Other Percentage 5-10% Other Prohibited Uses: The City of Brea may implement other prohibited water uses as determined by the City of Brea, after notice to customers.

Yes
3 Pools and Spas - Require covers
for pools and spas
Percentage 0-1% Pools and Spas - Require covers for pools and spas Yes 3 Pools - Allow filling of swimming
pools only when an appropriate
cover is in place.

Percentage 0-1% Pools - Allow filling of swimming pools only when an appropriate cover is in place. Yes 3 Water Features - Restrict water use
for decorative water features, such
as fountains
Percentage 0-1% Filling or refilling ornamental lakes and ponds is prohibited. Ornamental lakes and ponds that sustain aquatic life of significant value and were actively managed prior to the storage declaration are exempt.

Yes
3 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
Percentage 0-1% Fix leaks or faulty sprinklers within 2 days. Yes 3 Implement or Modify Drought Rate
Structure or Surcharge
Percentage 0-5% Drought Rates and Surcharges Yes
3 Other water feature or swimming
pool restriction
Percentage 0-1% Decorative water features that use potable water must be drained and kept dry. Yes 3 Other - Prohibit vehicle washing
except at facilities using recycled or
recirculating water
Percentage 0-1% Car washing is only permitted using a commercial carwash that recirculates water or by high pressure/low volume wash systems.

Yes
3 Other - Prohibit use of potable
water for construction and dust
control
Percentage 0-1% Require a construction water use plan be submitted to the water supplier that addresses how impacts to existing water users will be mitigated (such as dust control).

Yes
3 Landscape - Other landscape
restriction or prohibition
Percentage 0-1% With the exception of landscapes watered with non-potable water, limit the installation of new landscaping to drought tolerant trees, shrubs, and groundcover. Prohibit installation of new turf or hydroseed. Customers may apply for a waiver to irrigate during an establishment period for the installation of new turf or hydroseed.

Yes
3 Landscape - Limit landscape
irrigation to specific days
Percentage 10-25% Irrigation shall be limited to 2 days per week and the watering days shall be Wednesday & Friday from May to September and 1 day per week and the watering day shall be Wednesday from October to April for turf watering when using potable water. Plant containers, trees, shrubs, and vegetable gardens may be watered additional days using only drip irrigation or hand watering.

Yes
3 Landscape - Prohibit certain types
of landscape irrigation
Percentage 0-1% Plant containers, trees, shrubs, and vegetable gardens shall be watered only by drip irrigation or hand watering. Yes 4 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
Percentage 0-1% Fix leaks or faulty sprinklers within 1 day. Yes 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO
CITY OF BREA A-5
Submittal Table 8-3 Retail: Demand Reduction Actions
Water Code Section 10632(a)(4)(B) and (E)
Yes Is the Supplier completing this table using the standard six levels? (yes/no) Shortage
Level
Demand Reduction Actions
Drop down list
These are the only categories that
will be accepted by the WUEdata
online submittal tool. Select those
that apply.

How much is this going to reduce the shortage gap?
Additional Explanation or Reference
(OPTIONAL)
Penalty, Charge, or
Other Enforcement?
For Retail Suppliers
Only
Drop Down List
Volume or
Percentage
Drop down
Shortage Gap Reduction Value
(May be a range)
(AF)
Add additional rows as needed
4 Other water feature or swimming
pool restriction
Percentage 0-1% Existing pools shall not be emptied and refilled using potable water unless required for public health and safety purposes. Yes 4 Other water feature or swimming
pool restriction
Percentage 0-1% No new permits for pools will be issued. Yes 4 Landscape - Other landscape
restriction or prohibition
Percentage 0-1% No new landscape installations or renovations will be permitted. Yes 4 Landscape - Prohibit all landscape
irrigation
Percentage 0-1% Previous waivers for watering during an establishment period will be revoked. Yes 4 Landscape - Limit landscape
irrigation to specific days
Percentage 5-20% Irrigation shall be limited to 1 day per week year-round and the watering day is Wednesday for turf watering when using potable water. Plant containers, trees, shrubs, and vegetable gardens may be watered additional days using only drip irrigation or hand watering.

Yes
4 Other Percentage 5-10% Other Prohibited Uses: The City of Brea may implement other prohibited water uses as determined by the City of Brea, after notice to customers.

Yes
4 Other Percentage 5-10% The City of Brea may reduce water allocations in all categories to meet the available water supply. Yes 5 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
Percentage 0-1% Fix leaks or faulty sprinklers within 1 day. Yes 5 Other Percentage 0-1% Water for agricultural or commercial nursery purposes, except for livestock watering, is prohibited. Yes 5 Landscape - Prohibit certain types
of landscape irrigation
Percentage 0-1% Watering of all golf course areas is prohibited Yes 5 Landscape - Prohibit certain types
of landscape irrigation
Percentage 0-1% Watering of parks, school grounds, and recreation fields is prohibited, except for rare plant or animal species Yes 5 Moratorium or Net Zero Demand
Increase on New Connections
Percentage 0-2% Moratorium or Net Zero Demand Increase on New Connections Yes 5 Other Percentage 0-50% Water use for public health and safety purposes only. Yes 6 Other Percentage 0-1% The City of Brea may discontinue service to consumers who willfully violate any water conservation provisions Yes 6 Other Percentage 0-1% Water for air conditioning is prohibited Yes 6 Landscape - Prohibit all landscape
irrigation
Percentage 0-5% The City of Brea may shut off all non-essential water services. All irrigation is prohibited. Yes 6 CII - Other CII restriction or
prohibition
Percentage 0-15% Water for commercial, manufacturing, or processing purposes shall be reduced in volume by up to 50% or exceeded if necessary for public health and safety purposes.

Yes
6 Other Percentage 0-70% Water use for public health and safety purposes only. Customer rationing may be implemented. Yes DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.

NOTES: Note 1: NFT irrigation requirements begin January 1, 2027 for State and local government properties, January 1, 2028 for commercial, industrial, and institutional owned landscapes, January 1, 2029 for homeowners' associations common area landscapes, and January 1, 2031 for local government properties in disadvantaged communities (DAC). 2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO

CITY OF BREA

APPENDIX B WATER SHORTAGE CONTINGENCY
RESPONSE ORDINANCE 1221
Below is the weblink to the City of Brea's Ordinance 1221 (last accessed on April 28, 2026):
https://www.cityofbrea.gov/DocumentCenter/View/12092.
.
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO

CITY OF BREA

APPENDIX C NOTICE OF PUBLIC HEARING (PENDING)
2025 WATER SHORTAGE CONTINGENCY PLAN
APRIL 2026 / FINAL DRAFT / CAROLLO

CITY OF BREA

APPENDIX D ADOPTED WSCP RESOLUTION (PENDING)
CITYofBREA
City Council Regular Meeting
Communication
May 19, 2026
Item No. 5A.

Continued Review of the Business License Modernization Effort

TO PREPARED BY
Honorable Mayor and City Council Members Faith Madrazo, Financial Services Manager, Revenue

DEPARTMENT HEAD APPROVAL CITY MANAGER APPROVAL
Monica Lo, Administrative Services Director Kristin Griffith, City Manager

RECOMMENDATION
Staff recommends that the City Council take the following actions:

1. Authorize the preparations necessary to include the business license modernization measure on the November 2026 ballot.

BACKGROUND/DISCUSSION
The City's business license program was established as a requirement for businesses operating within the City of Brea. This program was first established in 1961 through Ordinance No. 402, and its foundational structure has remained largely unchanged since 1976—nearly 50 years. At the time of its original adoption, voter approval was not required, as it predated Proposition 218. Subsequent amendments to the ordinance did not require voter approval either. However, following the adoption of Proposition 218, any adjustments to general revenue measures now require voter approval.

Currently, the City has approximately 6,500 registered businesses, generating approximately $1.1 million in annual business license revenue. This revenue fluctuates with local economic conditions and overall business activity. In Brea, business license rates vary by business type.

The City's business license structure has not undergone a comprehensive update in several decades. Among Orange County cities, Brea maintains one of the oldest structures that has not received the benefit of modernization efforts over time. Additionally, the City’s revenue per capita and revenue per business rank among the lowest in the region. The proposed ballot measure would modernize the City’s business license structure and better align the City's revenue model with those of comparable Orange County cities.

Table A (Business Comparisons with neighboring Orange County Cities) Since the ordinance has not been comprehensively updated since 1976, portions of the current structure are outdated and no longer reflect today’s business environment. The existing structure also includes maximum fee caps for certain business categories — Retail ($500), Wholesale ($750), and Manufacturing ($1,000) — which can create disparities among businesses, particularly for mid-sized operations. The proposed starting rates are intended to better align Brea with comparable cities while establishing a more consistent, equitable, and modern structure for businesses of all sizes.

A Business License Study was conducted by HdL, the City’s third-party Business License Administrator, to evaluate the existing business license structure and compare it against similar cities. Based on the study findings, staff is recommending updates to the Business License Ordinance, which may include:

Updating the minimum business license amount to $55 and establishing a maximum amount of $118.61 Removing the current maximum cap
Transitioning all businesses to a gross receipts-based structure Consolidating business categories from more than 30 categories to five (excluding exempt classifications) Updating terminology throughout the ordinance
Revising the appeals process
Updating the rental fee structure
Eliminating the one-unit rental exemption, consistent with the City’s Short-Term Rental Ordinance Revising the penalty structure, with no anticipated change to total penalty collections Since February 3 of this year, the City Council has been evaluating potential updates to the Business License Ordinance. The recommended rate model under consideration is a Variable Gross Receipts Structure.

Table B (Rate Model Options)
To help businesses gradually adjust over time, the recommendation includes a phased implementation approach.

Annual increases would be limited to no more than 3% per year, with maximum rates projected to be reached by 2053. This phased structure is intended to minimize immediate financial impacts and give businesses sufficient time to transition to the updated model. The recommended first phase is as follows:

Table C (First Phase Recommendation)

FISCAL IMPACT/SUMMARY
Revenue generated through business license collections is an ongoing general revenue source that supports services and the City’s long-term financial stability. These revenues are not restricted to specific programs and may be used to fund a variety of municipal services, infrastructure needs, and operational priorities.

If approved by voters, the proposed Business License Modernization measure is projected to generate approximately $565,000 in additional annual revenue during the first year of implementation. Over time, revenues are expected to fluctuate based on local economic conditions, business activity, and future growth within the City.

To place the Business License Modernization measure on the November 2026 ballot, the estimated election-related cost is between $8,500 and $17,000. Including the costs associated with three City Council seats appearing on the same ballot, the City’s total estimated election cost is projected to range from approximately $61,389 to $80,478.

Placing the measure on the November 2026 ballot would result in substantial cost savings compared to conducting a standalone election in a non-election year, when estimated election costs could range from roughly $521,000 to $590,000. Additionally, measures placed before voters during a non-election year require a unanimous City Council vote and declaration of a fiscal emergency pursuant to applicable election requirements.

Overall, the proposed modernization effort is intended to update and simplify the City’s outdated business license structure, improve equity and consistency across business classifications, and provide an additional ongoing revenue source to help maintain essential City services, including police, fire, infrastructure, and operational needs.