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San Francisco Public Utilities Commission
Correspondence Log
March 3, 2022, through March 14, 2022
Date Received From Subject
March 3, 2022 Judy Irving Design Drought
Martin Gothberg Design Drought Deliberations
Stephen Rosenbum Long Term Vulnerability Assessment
and the Design Drought
March 4, 2022 Brian Browne A Clarification Question
Peter Drekmeier Need to Prioritize Action on the Design Drought and Water Demand Projections
March 5, 2022 Virginia VanKuran Please Support Adequate Water for the Tuolumne River. It's Possible!
March 6, 2022 Denis Louie Message of hope
March 7, 2022 Brian Browne Alternative Water Supply Quarterly Report
Peter Drekmeier Alternative Water Supply Planning
Quarterly Update
March 8, 2022 Ed Hillard Urgent Need to Change the Design Drought
Carol Steinfeld Comment for Alternative Water Supply
Planning Quarterly Report
March 9, 2022 Kent Iverson Tell San Francisco to do its part to save salmon and heal the environment
Judy Schriebman Request for Changes in Design Drought
Fleur Uptegraft
San Francisco can avoid a water crisis.
Why isn’t SFPUC on board?
John Cote Sacramento Bee Op-Ed: As PG&E
wobbles, we can’t let the utility stop the
growth of public power in California
March 10 2022 Dave Warner Fish Passage Chart
Eileen Boken All-women engineering team from
Philippines win UNESCO hackathon
with their clean water solution
Thailand makes green push with
floating hydro-solar power project
Lori Tyler Resolution 210577: Support
March 11, 2022 Cindy Charles Request to expedite decision on the Design Drought Plan
March 14,2022 Steve Ritchie Governors' press release re State Drought Emergency
Weekly Media Clips
• February 26 through March 4
From: Judy Irving
To: Commission
Subject: Design Drought
Date: Thursday, March 3, 2022 1:59:35 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear Commissioners,
I'm a filmmaker ("Secrets of the Bay," "San Pablo Baylands") and Bay swimmer. I have intimate, on-the-ground and in-the-water knowledge of the Bay-Delta over nearly fifty years, making environmental films such as those listed above (as well as “The Wild Parrots of Telegraph Hill” and “Pelican Dreams.”) My in-progress feature documentary, entitled “Cold Refuge,” is about the healing aspects of swimming in San Francisco Bay.
The entire Bay-Delta ecosystem is on the brink of collapse. I urge you to expedite your deliberations on the Design Drought. There is no time to waste. Fish and other aquatic species need protection, and so do we humans who value and depend upon a healthy bay.
Thank you,
Judy Irving
Producer/Director
From: Martin Gothberg
To: Commission
Subject: Design Drought Deliberations
Date: Thursday, March 3, 2022 2:56:28 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Commissioners,
I am a long time supporter of the TRT with my time and money. Having listened in on four of the six workshops and attending several SFPUC hearings with presentations by staff, after reading through the LTVA, it is clear to me that the 'design drought' introduced as an idea years ago is extremely unlikely to occur. Please expedite your review of this understandably conservative idea that will more
likely cause the extinction of salmon than
address possible water constraints in the Bay Area.
Thank you,
Martin Gothberg
Santa Clara, CA
From: [email protected]
To: Commission
Subject: Long Term Vulnerability Assessment and the Design Drought Date: Thursday, March 3, 2022 5:10:23 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear Commissioners,
I am an end user of SFPUC water in Palo Alto and avid outdoors person and fisher person. During all our droughts my family has scrupulously saved water and have installed all manner of water saving technology-low flow shower heads and toilets, rain sensitive irrigation timers, and native plant landscaping to replace lawns. We have done this in the expectation that thee efforts would lead to better protection of the natural environment, especially salmon Unfortunately this his not turned out to be the case as the SFPUC has sued the State Water Board over minimum flows on the Tuolumne rather than providing sufficient flows for fish reproduction. At the science workshops sponsored by the SFPUC, academic experts repeatedly said that the voluntary agreements were helpful but that there was no substitute for adequate flows to promote fish reproduction.
The eight year Design Drought and unrealistic assumption of 265 MGD of consumption in the future has resulted in the SFPUC proposing to continue to destroy fish habitat.
Problems caused by low flows extend up into river ecosystems. Low flows (1) make it hard for
anadromous fish—such as salmon—to migrate from freshwater where they are born to the ocean, and then back again to spawn; (2) allow our
Sierra streams to get too warm for native fish to be
healthy; (3) don’t allow floodplains (critical habitat for baby fish) to get inundated; and (4) fail to dilute pollutants, such as agricultural pesticides and fertilizers.
I urge the SFPUC to reconsider the assumption of an 8 year Design Drought and extremely high consumption estimates which will continue to promote the destruction of the riverine environment.
Thank you.
Dr. Stephen Rosenblum
Palo Alto
From: Brian Browne
To: Hood, Donna
Cc: Elsbernd, Sean (MYR); Peter Drekmeier
Subject: A clarification question -
Date: Friday, March 4, 2022 9:43:11 AM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear Donna,
Please forward to GM Herrera and Honorable SFPUC Commissioners. I am trying to understand the below mentioned document. I hope i have not confused the language? Cheers,
Brian Browne
Dear General Manager Herrera and Honorable Commissioners, I have read part of your presentation THE SAN FRANCISCO PUBLIC UTILITIES COMMISSION (SFPUC) Management's Discussion and Analysis (Unaudited) June 30, 2021, and 2020. You note "that capital assets (less?)
accumulated depreciation and amortization
increased by $141,887 or 2.6% to $5,530,545." Is this number equivalent to what your Rate base would be (plus working cash) if the SFPUC was still using the Utility Method for calculating debt service? If so, what would be your weighted average cost of capital to compute debt-service eligible for P218 rate inclusion? What is your Cash Method computed debt service for the identical period?
I do find the utility method more concise for tracking the mandate of 1996 Proposition 218 that only current costs are allowed in current rates.
Truly and thank you for reading,
Brian Browne
March 4, 2022
President Anson Moran and Commissioners
SFPUC
525 Golden Gate Avenue
San Francisco, CA 94102
Via email
Re: Need to Prioritize Action on the Design Drought and Water Demand Projections.
Dear President Moran and Commissioners:
On November 30, 2020, the SFPUC embarked on the first of six very productive workshops focusing on the Tuolumne River and water supply. 11 months later, on October 29, 2021, the workshops culminated with a presentation and discussion on the Long-Term Vulnerability Assessment. Four months have passed since then, and the SFPUC has yet to take the next step of acting upon the wealth of information received over the past 15 months.
At your most recent meeting, President Moran asked staff to prepare a schedule to address the unfinished business related to items identified at the workshops. This is a step in the right direction, but we are concerned we will experience a series of delays, as we have in the past. It is important that you, the Commissioners, take the lead on driving next steps to ensure the momentum generated by the workshops is not lost.
Following the October LTVA workshop, we encouraged you to request additional information from staff to help make your process for making changes to the Design Drought a little clearer.
We submitted letters on November 5, 2021 and January 19, 2022, and commented at a number of SFPUC meetings, but didn’t receive responses.
On February 4, 2022, we followed up with our own analysis of the LTVA, but again were met with silence. If you were provided with the additional information we requested, which we believe exists, it should not be a difficult decision to reduce the length of the Design Drought.
Staff has a long history of withholding information from the public and dismissing NGO recommendations. They also have failed to respond to requests from Commissioners. Putting former Commissioner Vietor’s numerous unmet requests aside, we present the following three recent examples of staff’s failure to address your requests.
2 1) At the July 16, 2021 water demand and demand management workshop, Commissioner Moran requested information about the difference between CA. Dept. of Finance and Plan Bay Area population projections. Seven months have passed, yet there has been no response.
2) On November 9, 2021, former Commissioner Harrington requested regular updates on environmental metrics focusing on the health of the Tuolumne, specifically salmon returns to the river. Four months have passed, yet there has been no response. In the meantime, Dave Warner, a member of public, provided bi-monthly salmon count graphs throughout the spawning season.
3) On January 7, 2022, Commissioner Ajami requested a graph comparing historic water demand projections from the Water Enterprise and the SFPUC’s financial division. Two months have passed, yet there has been no response.
Meanwhile, the Tuolumne salmon run dropped to less than 600 fish last fall, as compared to more than 6,000 salmon returning to the Stanislaus River. The clear difference between the two rivers is the magnitude of instream flow.
The SFPUC has known for decades that major action is needed to restore the Tuolumne River ecosystem and prevent the extirpation of salmon, yet little action has been taken.
In 1996, a settlement agreement during a FERC proceeding for the Tuolumne River was signed by the SFPUC, MID and TID, government agencies and NGOs. Much like the proposed Tuolumne River Voluntary Agreement (TRVA), the 1996 settlement was based primarily on non-flow measures. The agreement failed to restore fish populations. In fact, the number of spawning fish in the Tuolumne has declined precipitously since 1996. Of the 10 priority habitat restoration projects identified in the 1996 agreement, only four were completed.
The signature project of the 1996 settlement involved filling in an old in-river mining pit that harbored non-native bass. It was a sound idea partially, but it failed because it was not accompanied by the flows that might have made it effective. The post-project monitoring report was very clear that high flows are an essential element of controlling predator habitat.
The report states:
During extremely wet years, high flows can flush largemouth bass out of a stream, but typically a sufficient number of adults can find shelter in flooded areas to repopulate the stream during lower flow conditions (Moyle 2002)…During the years following the flood, largemouth bass abundance was controlled by spring and summer flow conditions that were unfavorable for reproduction. Largemouth bass require low water velocities and warm water temperatures to reproduce. (Moyle 2002, Swingle and Smith 1950, Harlan and Speaker 1956, Mraz 1964, Clugston 1966, Allan and Romero 1975, all as cited in Stuber et al 1982) (p 130).
1 1 Special Run Pool 9 and 7/11 Reach: Post-project Monitoring Report, McBain & Trush and Stillwater Sciences, June 30, 2006, p. 130.
3 Though the science shows that low river flows are the primary cause of salmon mortality, the SFPUC and Irrigation Districts have for many years pursued the TRVA, which focuses almost exclusively on non-flow measures.
Notwithstanding messaging and policy statements about environmental stewardship, the SFPUC and Irrigation Districts have failed the Tuolumne River ecosystem. During the five-year period from 2012 through 2016, the total volume of flow in the Tuolumne River averaged just 12% of unimpaired flow. Over the past two years, it averaged 14% of unimpaired flow. As a result, the salmon population has plummeted.
Graphs produced by Dave Warner.
Recommendations
The conservation and fishing organizations on this letter recommend that the Commission:
1) Direct staff to produce specific information you need to make well-informed decisions regarding the length of the Design Drought and realistic water demand projections. We encourage you to revisit our letters for suggestions. Specifically, you should direct staff to: 1) produce graphs similar to those identified in the January 19, 2022 NGO letter that use current demand and incorporate the Bay Delta Plan instream flow requirements; 2) determine the occurrence interval (likelihood) of the Design Drought and the Design Drought minus its final year; and 3) respond to the NGO analysis of how earlier runoff might affect the SFPUC’s water entitlements.
2) Schedule a final workshop to go over the LTVA and new information provided by staff, as well as information provided by the NGOs. This workshop should take place within the next six weeks.
3) Schedule a discussion at your next meeting following the workshop to address the outcomes of the workshop and revisit policy decisions regarding the Design Drought and water demand projections.
We are convinced the SFPUC can meet the Bay Delta Plan instream flow requirements without compromising water supply security. The workshops and LTVA have helped make this clear. The Tuolumne River and Bay-Delta ecosystems are on the brink of collapse and cannot wait any longer. The time for action is now.
4 Thank you for considering our comments and recommendations.
Sincerely.
Peter Drekmeier
Tuolumne River Trust
Chris Shutes
California Sportfishing Protection Alliance
John McManus
Golden State Salmon Association
Bill Martin
Sierra Club Bay Chapter
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BOARD MEMBERS
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Harrison “Hap” Dunning,
Vice Chair
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Chair Emeritus
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Marty McDonnell
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Bart Westcott
November 5, 2021
President Anson Moran and Commissioners
SFPUC
525 Golden Gate Ave.
San Francisco, CA 94102
Via Email
Dear President Moran and Commissioners:
We’d like to thank you again for hosting last week’s workshop on the SFPUC’s Long- Term Reliability Assessment, and for including us. Some important information was shared.
We understand the purpose of the study was to assess the Regional Water System’s (RWS) vulnerability to climate change and other factors. However, the study also provides useful information that can help you assess the reasonableness of the Design Drought.
There are two issues we believe would benefit from additional analysis. First is an assessment of the expected occurrence interval for the Design Drought and for the Design Drought minus one year. Second is the potential impact of earlier runoff on the SFPUC’s water rights.
Occurrence Interval for the Design Drought
The following table was included on slide 43 of the staff/consultant presentation. We request that the Commission direct staff to add two new rows to this table, one for the Design Drought and a second for the Design Drought minus one year.
It could be that the occurrence interval for the Design Drought is as simple as multiplying the recurrence intervals of 1976/77 and 1987-92. If this is the case, the current odds of experiencing the Design Drought would be 1-in-42,000. With a 10%
2 decrease in precipitation (if it weren’t made up for in some other way) would be 1-in-5,400, and a 20% decrease in precipitation would be 1-in-1,125.
Below is a graph produced by Paul Collacchi, a former Mayor of Menlo Park and a member of the Mayor’s Water Supply Stakeholder Group. He plotted every eight-year sequence over the past 600 years using the historical record and tree ring data. Each bar represents eight consecutive years. The red line represents the Design Drought. You’ll see that the Tuolumne River did not experience anything even close in severity to the Design Drought during that time period.
Impact of Earlier Runoff on Water Rights
There was some disagreement at the workshop as to how earlier runoff might affect the SFPUC’s water rights. It turns out everyone was correct. On average, the SFPUC’s water rights remain about the same, because in normal and wet years the SFPUC tends to lose some of its entitlement to the Irrigation Districts. However, in dry years, when it really matters, the SFPUC gains entitlements.
Working with Greg Reis from The Bay Institute, we looked at how a three-week shift in runoff might affect the SFPUC’s water rights during the Design Drought. The data we used came from the Tuolumne Daily Model version 3.1 developed by the Irrigation Districts for use in the FERC licensing process. The unimpaired flow data were an input dataset developed by Dan Steiner in 2013.
3 The following scatter plot demonstrates that in drier years (on the left side of the horizontal axis) water entitlements shift from the Irrigation Districts to the SFPUC, showing up on the vertical axis as above zero (the break-even point). In wetter years, moving to the right on the horizontal axis, water rights shift from the SFPUC to the Irrigation Districts. The loss of entitlements in wet years is much less of a concern to the SFPUC than the benefit of picking up water rights in dry years when water is needed most.
According to our calculations, the shift in water rights for the eight years that constitute the Design Drought is as follows (figures are in thousand acre-feet).
1976 = +20
1977 = 0
1987 = +51
1988 = +8
1989 = +33
1990 = +54
1991 = +9
1992 = +62
The total amount of water the SFPUC would gain during the Design Drought if runoff were to occur three weeks earlier is 237 thousand acre-feet (TAF). Total SFPUC entitlements during the Design Drought years were 858 TAF, so 237 TAF represents a 28% increase.
RWS demand in FY 2019/20 was 198 mgd, or 222 thousand acre-feet. Therefore, the change in water rights during the Design Drought with runoff occurring three weeks earlier would amount to more
4 than one year’s-worth of water shifting to the SFPUC. We believe this should further justify removing one year from the Design Drought.
Conclusion
In summary, we request that the Commission direct staff to:
1) Determine the occurrence interval for the full Design Drought and the Design Drought minus one year.
2) Assess the potential impact of earlier runoff on the SFPUC’s water entitlements under the Design Drought scenario.
Thank you for the opportunity to share our thoughts and requests.
Sincerely,
Peter Drekmeier Dave Warner
Policy Director TRT Volunteer
Alameda Creek Alliance • California Sportfishing Protection Alliance Friends of the River • Golden State Salmon Association
Golden West Women Flyfishers • Institute for Fisheries Resources Northern California Council Federation of Flyfishers • Pacific Coast Federation of Fishermen’s Associations • San Francisco Baykeeper
San Francisco League of Conservation Voters • Tuolumne River Trust
January 19, 2022
Dr. Casey Brown and Mr. Alexis Dufour
[email protected]
[email protected]
Dear Dr. Brown and Mr. Dufour:
Thank you for the effort you’ve put into the SFPUC’s Long-Term Vulnerability Assessment (LTVA). It’s an impressive study that will play an important role in helping the SFPUC plan for future water supply security in the era of climate change.
The report describes future vulnerability under long-term conditions of extreme stress. Its modeling setup could also be re-used, quite easily, to help the SFPUC better understand current and near-future conditions and stressors to answer timely questions, such as:
1) How likely is the SFPUC’s design drought to occur? Could it be modified or operational rule changes made to provide more flexibility for water supply planning (i.e. less unnecessary rationing) without compromising water supply security? 2) How might climate change, along with the instream flow requirements adopted by the State Water Board through the Bay Delta Water Quality Control Plan, affect the SFPUC’s water supply and entitlements under expected future conditions? 3) Under which future climate change projections, with the Bay Delta Plan implemented, would the SFPUC need to develop alternative water supplies, and if so, how much?
The undersigned organizations and individuals request that you consider additional water supply scenarios to help answer the questions above. These scenarios are:
Re-analyze scenarios using actual current demand.
The LTVA analyzes a number of scenarios, but none considers the possibility that water demand in the SFPUC’s Regional Water System (RWS) service area might remain flat or decline. The figures used are anywhere from 16% to 71% above current demand. The report should include a demand scenario of 200 mgd, if not also one of even lower demand. SFPUC water deliveries have been below 200 mgd for the past seven years.
2 Add more scenarios that consider potential impacts from the Bay Delta Plan.
Only a few of the scenarios analyze the impact of the Bay Delta Plan’s flow requirements on the SFPUC’s water supply. Including the Bay Delta Plan flow requirements in more scenarios would help the SFPUC determine the potential impacts on water supply of leaving more water in the Tuolumne River for environmental purposes.
Following are three recommendations we have for inclusion in your webinar presentation scheduled for January 27, 2022.
1) Produce scenarios that include demand of 200 mgd and the Bay Delta Plan flow requirements for the following figures: 3-26, 3-29, 5-19 and 5-26. 2) Calculate the return period (or occurrence interval) for the design drought and the design drought minus its final year for Tables 3-19 and 5-1. Please do the same using a 224 TAF threshold (200 mgd demand).
3) Calculate the shift in Water Available to the City (WAC) for the design drought years (1987-92 plus 1976/77), but with runoff occurring 10 days and 20 days earlier, as projected in the summary on pages 147 and 148.
Again, this additional information would be extremely useful in near-term deliberations. Please include these additional analyses in your presentation on January 27.
Thank you for your attention.
Sincerely,
Peter Drekmeier
Policy Director
Tuolumne River Trust
Chris Shutes
FERC Projects Director
CA Sportfishing Protection Alliance
Ashley Overhouse
Resilient Rivers Director
Friends of the River
John McManus
President
Golden State Salmon Association
Ian Wren
Staff Scientist
San Francisco Baykeeper
Cindy Charles
Conservation Chairperson
Golden West Women Flyfishers
3 Mark Rockwell
President
Northern California Council Federation of
Flyfishers
Mike Conroy
Executive Director
Pacific Coast Federation of Fishermen’s
Associations
Institute for Fisheries Resources
Kristina Pappas
President
San Francisco League of Conservation
Voters
Jeff Miller
Dave Warner
Member
SF Mayor’s Water Supply Stakeholder
Group
Bill Martin
Bill Martin
Member
SF Mayor’s Water Supply Stakeholder
Group
Paul Collacchi
Member
SF Mayor’s Water Supply Stakeholder
Group
Iris Stewart-Frey
Professor
Santa Clara University
Executive Director
Alameda Creek Alliance
Cc: SFPUC Commissioners
Dennis Herrera, SFPUC
Steve Ritchie, SFPUC
California Sportfishing Protection Alliance • Coalition for San Francisco Neighborhoods • Friends of the River • Golden West Women Flyfishers Institute for Fisheries Resources • Northern California Council, Fly Fishers International • Pacific Coast Federation of Fishermen’s Associations San Francisco League of Conservation Voters • Save California Salmon • Sierra Club California • Sierra Club San Francisco Bay Chapter Tuolumne River Trust • Wholly H2O
February 4, 2022
President Anson Moran and Commissioners
San Francisco Public Utilities Commission
525 Golden Gate Avenue
San Francisco, CA 94102
Via email
Re: The Long-Term Vulnerability Assessment Offers Promising Results.
Dear President Moran and Commissioners:
While the SFPUC’s Long-Term Vulnerability Assessment (LTVA) is an impressive document that includes a lot of useful information, it falls short on providing clear answers to questions you may have regarding the practicality of the Design Drought. However, information can be extrapolated from the Study that clearly demonstrates the SFPUC could manage the Bay Delta Water Quality Control Plan instream flow requirements without risking running out of water.
Following are some of our findings.
Even with Inflated Water Demand Figures, the SFPUC’s Water Supply Is Not in Jeopardy
The LTVA states, “In summary, water delivery reliability is more sensitive to demand change than to change in temperature and precipitation.”
1 Yet the LTVA used a baseline demand of 227
mgd, which is 16% higher than the actual current demand of 195 mgd. Given the importance of demand in water supply planning, we find it surprising and disappointing the LTVA didn’t include any scenarios using current demand.
In fact, the six figures used to represent water demand in the LTVA are between 16% and 71% higher than current demand. Our requests to include current demand went unanswered.
1 SFPUC Long-Term Vulnerability Assessment, p. 172.
2 At your January 7, 2022 budget workshop, there once again was discussion about the large disparity in demand projections between the SFPUC’s financial and water supply divisions. We appreciated Commissioner Ajami’s request that staff produce a graph showing both sets of projections together, and compared to actual demand.
You have yet to receive this graph, but we’ve done our own analysis based on Urban Water Management Plan (UWMP) projections and the five most recent 10-Year Financial Plan projections (we’re still waiting to receive the earlier plans). We found that the financial projections were extremely close to the actuals, whereas projections for 2020 demand in the 2000 through 2015 UWMPs ranged from 19% to 47% greater than actual demand.
The most recent 10-Year Financial Plan forecasts water sales will remain flat over the coming decade. But even with the inflated demand figures used in the LTVA, the chance of the SFPUC running out of water as a result of the Bay Delta Plan instream flow requirements is very small, as explained below.
Annual Mean Precipitation is Unlikely to Change
The LTVA offers a much better understanding of how climate change will likely affect precipitation. It found that annual mean precipitation is unlikely to change, and is slightly more likely to increase than decrease. The Study states:
According to climate projections and expert elicitations, there is a central tendency of warming of +2°C and +4°C by 2040 and 2070 (Representative Concentration Pathway [RCP]
3 8.5), respectively, with no clear direction of change in mean annual precipitation over the planning horizon.2
And:
The Upcountry region and East Bay and Peninsula regions are in the positive precipitation domain for the winter season in 2070, and thus are somewhat more likely to see positive than negative precipitation in the near future.
3 The Bay Delta Plan Will Not Cause the SFPUC to Run Out of Water
Despite our repeated requests, the LTVA does not include scenarios incorporating the Bay Delta Plan instream flow requirements (IFR) to allow for an easy comparison with the current flow regime. However, it does provide information that can be used to deduce the Bay Delta Plan’s potential impact on water supply. For example, the Study states:
The RWS [Regional Water System] is particularly vulnerable to the state-adopted new IFR below Don Pedro Dam (State WQCP), which represents a significant reduction in water available. At a demand of 227 mgd, the effect of state-amended WQCP under current conditions is equivalent to a reduction in mean annual precipitation of about 15% in terms of the water delivery reliability (reliability around 85%, rationing in 1 out of 6.5 years on average).
4 The following graph demonstrates that even with a 20% reduction in precipitation, and at 227 mgd demand, the SFPUC remains in the safe zone (green) when it comes to water supply reliability. A 20% decrease in precipitation is greater than the 15% decrease that would be comparable to the Bay Delta Plan IFR. Using actual current demand (195 mgd), the impact of the IFR would move closer to the vertical line above 0% decrease in precipitation.
2 Ibid, p. xxii.
3 Ibid, p. 26.
4 Ibid, p. xxii.
4 Source: LTVA webinar, 1/27/22
The graph below5 illustrates the potential impact of precipitation change on water supply, using the 227 mgd baseline and a 20% decrease in precipitation. Substituting the Bay Delta Plan IFR (the equivalent of 15% precipitation loss), it demonstrates that the SFPUC is unlikely to run out of water. Using actual current demand would further improve the calculus.
The Design Drought is Extremely Unlikely to Occur
The following table
6 predicts how likely the severity of past droughts is to reoccur under two scenarios – demand of 240 mgd (Threshold: 269 TAF) and demand of 326 mgd (Threshold: 365 TAF). In other words, at 240 mgd demand, a two-year drought with an impact on water supply
5 Ibid, p. 176.
6 Ibid, p. 81.
5 as severe as the 1976/77 drought would be expected to occur once in 98 years. A drought as severe as 1987-92 would be expected to occur once in 772 years.
Despite our repeated requests, the SFPUC has failed to produce similar return periods for the Design Drought and the Design Drought minus one year. When flipping a coin, the odds of getting heads is 50%. The odds of getting heads twice in a row is 50% times 50%, or 25%. If this same methodology applies to droughts, the chances of the Design Drought occurring are miniscule.
Earlier Runoff Will Benefit the SFPUC’s Water Entitlements in Dry Years
The Study found that runoff is expected to come earlier in the season as a result of a diminished snowpack and more precipitation arriving as rain instead of snow. It states:
Therefore, an increase in temperature would result in less snowpack accumulation during winter season, as more precipitation will fall as rain rather than snow, leading to 1) a reduced spring runoff volume and magnitude and 2) an increase in winter flows. The spring runoff is also expected to occur earlier in the season (Figure 5-2). 7 And:
A +2°C warming leads to a spring runoff arrival 10 days prior to the baseline temperature conditions. Median of projections estimate warming around +2°C by 2040 with most projections and elicitations between +1°C and +4°C. At +4°C, the shift in timing would be closer to 20 days prior to baseline conditions. By 2070 RCP8.5, warming could reach around +4°C with most projections and elicitations between +3°C and +6°C. 8 Our analysis of historic data suggests that if the Design Drought were to repeat, but runoff came three weeks earlier, the SFPUC would pick up an additional 237 thousand acre-feet (211 mgd) of water – enough to add more than a year’s-worth of water to SFPUC storage. This is because the Modesto and Turlock Irrigation Districts are entitled to the first 2,400 cubic feet
7 Ibid, p. 147
8 Ibid, p. 147
6 per second (cfs) of runoff for most of the year. But between mid-April and mid-June (time of peak runoff), the Irrigation Districts are entitled to the first 4,000 cfs of runoff. Runoff between 2,400 and 4,000 cfs that shifts from mid-April-to-mid-June into the earlier season is water the SFPUC picks up. Runoff between 2,400 and 4,000 cfs that shifts from post-mid-June into the mid-April-to-mid-June period is water the Irrigation Districts pick up.
According to our calculations, the shift in water entitlements for the eight years that constitute the Design Drought would produce the following additions to SFPUC water supply (figures in thousand acre-feet).
Conclusion
If the SFPUC were to use reasonable demand projections, remove one year from the Design Drought, and consider the increase in “Water Available to the City” as a result of earlier runoff, it would significantly change the risk analysis. The following table is based on 200 mgd demand, includes the Bay Delta Plan instream flow requirements, and incorporates the additional water available to the SFPUC as a result of earlier runoff.
7 Source: Tuolumne River Trust
The results shown in the above table are extremely encouraging. Within the planning exercise that the Design Drought actually is, the SFPUC could manage a 7.5-year Design Drought and still retain positive storage, without developing any new alternative water supplies. The SFPUC could maintain positive storage over an eight-year Design Drought by developing 4,000 acre feet (3.8 mgd) of alternative annual water supplies.
Thank you for the opportunity to share our analysis of the LTVA. We look forward to working with you to implement decisions that will benefit the Tuolumne River ecosystem while also protecting the SFPUC’s water supply. We encourage you to schedule a discussion on the Design Drought as soon as possible.
Sincerely,
Peter Drekmeier
Policy Director
Tuolumne River Trust
Chris Shutes
FERC Projects Director
CA Sportfishing Protection Alliance
8 Ashley Overhouse
Resilient Rivers Director
Friends of the River
Cindy Charles
Conservation Chairperson
Golden West Women Flyfishers
Mark Rockwell
President
Northern California Council, Fly Fishers
International
Mike Conroy
Executive Director
Pacific Coast Federation of Fishermen’s
Associations
Institute for Fisheries Resources
Regina Chichizola
Co-Director
Save California Salmon
Eileen Boken
Eileen Boken
State and Federal Legislative Liaison
Coalition for San Francisco Neighborhoods
Molly Culton
Conservation Organizer
Sierra Club California
Chance Cutrano
Chapter Chair
Sierra Club San Francisco Bay Chapter
Kristina Pappas
President
San Francisco League of Conservation
Voters
Dave Warner
Member
SF Mayor’s Water Supply Stakeholder
Group
Bill Martin
Member
SF Mayor’s Water Supply Stakeholder
Group
Paul Collacchi
Member
SF Mayor’s Water Supply Stakeholder
Group
9 Elizabeth Dougherty
Elizabeth Dougherty
Executive Director
Wholly H20
Iris Stewart-Frey
Professor
Santa Clara University
From: Virginia VanKuran
To: Commission
Subject: Please Support Adequate Water for the Tuolumne River. It"s Possible! Date: Saturday, March 5, 2022 7:44:06 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear San Francisco Public Utilities Commission,
Thank you for this opportunity to express my opinion. I’ve lived in the Bay Area for most of my 73 years and watched it prosper. I think we all have realized over the past years that we need to take care of our natural environment for true prosperity. I’ve donated and belong to several organizations that are focused on a clean, healthy environment for the Bay Area.
As a long time member of Tuolumne River Trust I admire their thoughtful approach to advocating for a balanced approach to how we use the precious water from the Tuolumne River to benefit the environment we depend upon, the water we drink (I live in Palo Alto) and the food we eat (I’m a vegetarian and benefit from all the local organic farms).
In order to maintain a healthy Tuolumne River there needs to be adequate flow for the health of the river's environment.
The Tuolumne River Trust has shown in many different ways that we can ensure adequate flow for the river and have sufficient water for those of us who drink Tuolumne River water.
I support their suggestions and hope that you will also.
Regards,
Virginia Van Kuran
Palo Alto
From: Denise Louie
To: Commission
Subject: Message of hope
Date: Sunday, March 6, 2022 11:24:08 AM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Hi President Anson Moran and Commissioners,
The time has come for you to decide the fate of numerous species and the health of ecosystems. It's an awesome responsibility. It's also a great opportunity to show that you care about the 7 threatened fish species in the San Francisco Bay-Delta.
These
include smelt, salmon, sturgeon and more. Smelt are an indicator species, indicating the health of the Bay-Delta ecosystem. And there are barely enough smelt to count, where once they were in great abundance. Salmon are a keystone species. Once gone, entire ecosystems will fail.
California is one of only 36 internationally recognized biodiversity hotspots. We are blessed with an abundance of species, many of which we humans have brought to the brink of extinction--especially during our lifetimes.
We may have enjoyed nature's
bounty, but now it's time to protect that bounty from human activities and climate disruption.
I hope you will adopt water use projections based on Tuolumne River Trust analyses.
I hope you will withdraw the SFPUC's two law suits against the State Water Board with all due speed.
Thank you.
Denise Louie
Member, Center for Biological Diversity
SFPUC customer
SF native
From: Brian Browne
To: Hood, Donna
Cc: Peter Drekmeier; Douglas L Comstock
Subject: Re: Updated: March 8, 2022 SFPUC Regular Meeting Agenda Date: Monday, March 7, 2022 9:25:39 AM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear Donna - Please forward the following to D. Herrera and Commissioners. I remain perplexed at some of their statements. Truly and thanks - Brian Browne
***************************************************************************************** March 7, 2022
Dear GM Herrera and Honorable Commissioners:
I have reviewed Item 8(a) Alternative Water Supply Quarterly Update by S. Ritchie and M Kathari dated 3/8/2022.
The number 265 MGD is mentioned in many different contexts. Mr. Richie has proclaimed it as an average demand and now on page 55 of 64, the above-mentioned report is a contractual amount.
If it is an average demand – how was that determined?
Is there a statistical distribution around your assumed average demand of 265 MGD? Statistical analysis of the Hetch Hetchy demand series shows 265 MGD is a statistical outlier. A number that is expected infrequently and not an average (50% less/50% greater) demand or a number to benchmark ad infinitum contractual allocations.
I find no prolonged demand series validating BAWSCA’s ad Infinitum rights to receive 184 MGD.
Please show your calculations used in making the 184 MGD allocations (contractual amounts) enshrined in the 2009 Water Sales Agreement?
The SFPUC must show the equations (with explanatory and understandable prose) that drive your demand forecasts and allocation criteria.
I look forward to your immediate response and hopefully engaging in a dialog.
Truly,
Brian Browne
SF 94111
**************************************************************************************** On 3/6/2022 9:18 AM, Hood, Donna wrote:
Good Morning,
The SFPUC Regular Meeting agenda for March 8 has been updated to include revision for item 8a, Alternative Water Supply Planning Report and can be accessed via the following updated
LINK.
Thank you and apologies for any inconvenience.
Donna Hood
Commission Secretary
From: Hood, Donna <[email protected]>
Sent: Thursday, March 3, 2022 12:31 PM
Subject: March 8, 2022 SFPUC Regular Meeting Agenda
Good Afternoon,
The SFPUC Regular Meeting Agenda has been posted and can be found via the following LINK.
Thank you,
Donna Hood
Commission Secretary
OFFICES
San Francisco
Modesto
Sonora
Mailing Address
P.O. Box 3727
Sonora, CA 95370
Phone
(415) 882-7252
Website
www.tuolumne.org
BOARD MEMBERS
John Kreiter, Chair
Harrison “Hap” Dunning,
Vice Chair
Cindy Charles, Treasurer
Kerstyn Crumb, Secretary
Eric Heitz,
Chair Emeritus
Jose Borroel
Eddie Corwin
Bob Hackamack
Camille King
Marty McDonnell
Homero Mejia
John Nimmons
Eric Riemer
Marek Robinson
Bart Westcott
March 7, 2022
President Anson Moran and Commissioners
SFPUC
525 Golden Gate Ave.
San Francisco, CA 94102
Re: Item 8a: Alternative Water Supply Planning Quarterly Update.
Dear President Moran and Commissioners:
Item 8a on your March 8 agenda provides an excellent example of why you should revisit the Design Drought as soon as possible. The Design Drought as it is currently configured, would lead to overinvestment in alternative water supplies and stranded assets. With the Alternative Water Supply Plan due for completion by July 1, 2023, time is of the essence.
Slide 3 in the staff presentation indicates that 84 mgd of additional supplies would be needed to meet 2045 demand. Slide 4 identifies 35 mgd of “Projects Underway.”
Scenario VII presented at the March 26, 2021 SFPUC workshop shows that if the Design Drought were shortened by one year, 35 mgd would be sufficient to meet 236 mgd demand in 2045, even with the Bay Delta Plan instream flow requirements in place.
2 Water demand in 2045 is likely to be much lower than 236 mgd (the figure used in the 2020 UWMP and reflected in Scenario VII). At the July 16, 2021 SFPUC workshop, Steve Ritchie stated:
“I want to make sure it’s clear that the Urban Water Management Plan is not intended to be an actual projection of demands, because plan developments may or may not occur or may be delayed for a variety of reasons…and the projections presented in the 2020 Urban Water Management Plan are closer to an outside envelope of what the demands may be in 2045 rather than actual demands.”
The 2045 population growth projection for San Francisco in the 2020 Urban Water Management Plan (UWMP) is four times greater than the CA Department of Finance’s (DoF) projection. Using the DoF projection would reduce demand in San Francisco alone by 10 mgd.
Similarly, BAWSCA’s population projection for 2045 is more than twice that of DoF.
The additional 49 mgd (above the 35 mgd included in “Projects Underway”) cited in the staff presentation would be a terrible investment. It also is unlikely the 35 mgd of “Projects Underway” will be needed. Paying for this unneeded water would increase rates dramatically, sending a stronger price signal to consumers to reduce water consumption. As a result of the decrease in demand, rates would need to be increased even more to cover fixed costs.
Before investing more time in the Alternative Water Supply Plan, it would be prudent for the Commission to make a determination on the length of the Design Drought and realistic demand projections. Doing so would enable you to make a better informed decision on how much to invest in expensive alternative water supplies.
Thank you for considering our comments.
Sincerely,
Peter Drekmeier
Policy Director
Tuolumne River Trust
Dave Warner
Volunteer
Tuolumne River Trust
From: Ed Hillard
To: Commission
Subject: Urgent Need to Change the Design Drought
Date: Tuesday, March 8, 2022 2:06:07 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
March 7, 2022
To: SFPUC Commissioners
Re: Change the Design Drought
Honorable SFPUC Commissioners:
I am a seventy six year old nearly sixty year resident of the Bay Area.
I have lived here long enough vividly to
remember the impact that Sylvia McLaughlin and her colleagues made in changing the view of the Bay from a garbage dump to a natural resource, one worth treasuring and preserving. It is in the name of those women and the members of the Tuolomne River Trust that I am writing you to request your rational recognition of the risks entailed to the Bay and its tributaries by the Commission’s current Design Drought evaluations and failure to use realistic demand projections of water use in its Long-Term Vulnerability Assessment (LTVA).
Sylvia McLaughlin, Kay Kerr and Esther Gulick, had the insight some sixty years ago that saving the Bay meant improving the lives of everyone who lived near the Bay.
The Tuolomne River Trust (TRT) likewise has the insight of which they have been trying to persuade the SFPUC that saving the tributaries of the Bay helps save the Bay.
They have pointed out the consequences of not doing so, a dead San Joaquin River, a dead Tuolomne River, and so forth.
The TRT are asking the SFPUC to go about their evaluation honestly and the TRT are pointing out that if an honest evaluation is done it will show that the SFPUC can be confident that they will have assured water resources into at least the late 21st century and they will not have to ask their client customers to forego water usage beyond what these clients have already shown they can do and are willing to do.
Yet the SFPUC it seems in every evaluation to keep putting their finger on the scale.
Most recently this occurred
in the figure chosen for baseline demand in the LTVA, where they chose a figure of 227 mgd when even recent demand had not exceeded 195 mgd. Citizens of the Bay Area have shown they can reduce their demand. The SFPUC doesn’t seem treat to these citizens’ past behavior as valid or indicative of future behavior. The SFPUC hasn’t treated as valid this tendency to conserve for the public good for a long time now.
Before I retired I worked for Hewlett-Packard in that company’s computer business. One of the things we at HP always found ourselves up against as we tried to persuade businesses of the viability of our technology was the rule of thumb, You’ll never get fired for choosing IBM. Buying managers in the businesses that were our potential customers had this engrained in their thinking. They would not consider something that was demonstrably a better choice for them because of this engrained thought pattern. I suggest that the members of the SFPUC have the same kind of engrained thinking in their approach to the amount of water they want to keep in Hetch Hetchy versus the amount of water that is needed to keep the San Joaquin, the Tuolomne, and the greater San Francisco Bay as healthy natural waterways.
In the meantime, as Rome burns, these rivers and even the Bay suffer with every year of declining water supply, despite the SFPUC’s having in its own research the information that, were they to behave differently, more responsibly, they could with confidence still deliver well into the later decades of the 21st century the water their clients and customers needed while keeping the waterways healthy and alive, to act in the legacy of Save the Bay.
From: Carol Steinfeld
To: Commission
Subject: Comment for Alternative Water Supply Planning Quarterly Report Date: Tuesday, March 8, 2022 2:46:40 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
[The moderator heard my call as muted; I am not sure why.] This is Carol Steinfeld, co-chair of the water committee of the Sierra Club's Loma Prieta chapter. Our chapter covers most of the wholesale buyer area.
We very much support reuse, but this challenge of creating supply security requires analysis of usage before looking at expensive big water-reuse solutions.
When you start there, we think you'll see the uninterruptible-supply wholesale customers are the most targetable to reduce demand (and perhaps address leaks).
Given the state's charge to SFPUC to provide water—any water—it is absolutely in SFPUC's financial interest to offer consulting on demand management and small-flows reuse to San Mateo County wholesale buyers. (However, I would not say that San Francisco leads the country in small-scale reuse.)
SFPUC could drop its litigation against the state and use the savings to offer resources to the wholesale buyers. This is about truly managing the supply.
Reuse has challenges. The city of San Mateo's potential contribution to Crystal Springs is too salty now and would require pumping water up a very steep hill at great power costs.
That is
just an example of the many, many factors.
Please form ways to work with the wholesaler buyers. That is not against your public charge.
This should be a program mandate to staff.
Thank you.
Carol Steinfeld
From: Kent Iverson
To: Commission
Subject: Tell San Francisco to do its part to save salmon and heal the environment Date: Wednesday, March 9, 2022 6:44:43 AM
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Dear San Francisco Water,
Dear President Maxwell,
I am writing to urge the SFPUC to embrace science-based environmental protections for the Tuolumne, the San Francisco Bay-Delta, and our declining salmon runs. This is urgent because the SFPUC staff is fighting efforts to heal the river and the Bay and Delta it flows into. Because of the SFPUC’s lack of leadership, salmon have fared more poorly on the Tuolumne River than on any other river in the Bay-Delta watershed. This is causing great damage to Bay-Delta ecosystem and San Francisco’s salmon fishing industry. The SFPUC’s position must change to reflect San Franciscans’ strong commitment to protecting the environment.
I oppose the two lawsuits brought by the City seeking to block protections by the State Water Resources Control Board for the Tuolumne and the Bay-Delta. (NOTE – I DO NOT BELIEVE THE FIRST LAWSUIT CHALLENGED THEIR AUTHORITY. IT JUST CHALLENGED THE FLOW OBJECTIVES.)
The SFPUC is also refusing to accept the scientific evidence presented to them by a peer review commissioned by the National Marine Fisheries Service. This peer review found that the SFPUC’s opposition to improving river flows is not supported by science. Yet the SFPUC is still promoting your baseless proposal, including power washing the gravel in the Tuolumne’s salmon spawning beds.
San Francisco is a great city and the SFPUC should be leading the way in supporting strong protections for the Tuolumne River and the Bay. The SFPUC should also be leading the state by investing in water recycling and stormwater capture, which can help climate-proof our water supplies. Instead, the SFPUC is lagging far behind communities like Los Angeles, Orange County, and San Diego. The SFPUC should work with local groups that care about the environment instead of teaming up with anti-environmental San Joaquin Valley agribusinesses that insist on siphoning over 90 percent of the river.
I urge the SFPUC to listen to the science and drop your baseless and damaging proposal for the Tuolumne River. The best solution is to support environmentally responsible, science- based protections adopted by the State Water Resources Control Board.
Sincerely,
Kent Iverson
Sonoma, CA 95476
From: Judy Schriebman
To: Commission
Subject: Request for Changes in Design Drought
Date: Wednesday, March 9, 2022 1:08:28 PM
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Dear SFPUC Commissioners:
I have had several wonderful camping trips to Yosemite and one awesome hiking day in Hetch Hetchy. I believe this incredible valley should be and can be restored while still having enough water for SF urbanites. I am very encouraged by the usage of recycled water rather than aquifer/potable for Golden Gate Park as one step in a resilient OneWater approach to future drought scenarios. Ditto the onsite recycling of water at the SFPUC building in SF, showing the way forward for better urban water cycle usage. These and other steps being undertaken by the city would mean the Bay Delta Plan would not cause the SFPUC to run out of water.
I do care passionately about our natural world. I am on the Marin Group Executive Committee of the Sierra Club, the Watershed Alliance of Marin, the Gallinas Watershed Council and am elected to the Las Gallinas Valley Sanitary District. This groups are all based on environmental health protection and WATER: healthy, clean and safe for wildlife and the public. Salmon and restored wild rivers are essential for us for many reasons, which is why I care so much about the work you are doing in order to create a more resilient water supply for the city.
I encourage you to expedite your work on the Design Drought changes to make it more reality based. And I am hopeful that Hetch Hetchy may someday look like it was before it was dammed. And that the river through it can run again, wild and free and supporting a more diverse population of wildlife, plants, and visitors.
Judy
From: [email protected] on behalf of Fleur via San Francisco Baykeeper To: Commission
Subject: San Francisco can avoid a water crisis. Why isn’t SFPUC on board? Date: Wednesday, March 9, 2022 10:44:14 PM
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Dear Mayor Breed,
I urge you to withdraw the City’s litigation against the State Water Resources Control Board and direct SFPUC to start investing aggressively in water recycling today.
I am writing to you in the early days of yet another punishing drought. While San Franciscans are doing their part to save water at the household level, SFPUC is mismanaging San Francisco’s main water source, the Tuolumne River, and it isn’t doing nearly enough to prepare for drought this year—or in the decades to come.
Other cities have learned the lessons of California’s unpredictable climate and are quickly adopting water recycling to reduce their burden on rivers, while increasing the reliability of their supply. Orange County gets more than 75 percent of its water through its water reuse program. Las Vegas recycles nearly all of its water used indoors. And Los Angeles is on the path to reusing 100 percent of its wastewater by 2035.
But, as SFPUC’s draft Urban Water Management Plan recently revealed, San Francisco currently has no plans to make recycled water widely available in the next 25 years. Instead, the city is pursuing multiple expensive and misguided lawsuits so that it can continue to rely, almost exclusively, on the Tuolumne River—one of the state’s most overtapped rivers—for the next several decades. San Francisco and large agribusiness water districts divert four out of every five gallons of water that flow in the Tuolumne River during a typical year.
This overuse has caused the river’s once mighty Chinook Salmon populations to crash. Meanwhile, low river flows from the Tuolumne contribute to deteriorating water quality—including toxic algae blooms— downstream, in the Delta and San Francisco Bay.
It’s unacceptable for the city with the nation’s greenest reputation to shirk its responsibilities to preserve California’s precious and unpredictable water supply. We support increasing river flows to uphold San Francisco Bay’s fisheries, water quality, and recreation. San Franciscans want the city to do its part to protect the Bay and its rivers—water recycling is a common-sense way to limit the city’s water use, increase the reliability of its supply, and protect the Bay from harmful wastewater treatment plant effluent.
Thank you,
Fleur Uptegraft
Redwood City, CA
From: Dave Warner
To: Hood, Donna
Cc: Ritchie, Steve
Subject: Fish passage letter
Date: Thursday, March 10, 2022 4:18:27 PM
Attachments: Fish passage chart - Dave Warner letter to commissioners 2022-03-10.pdf CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Hi Donna,
Thank you for taking time with all our correspondence. Would you forward the attached letter to Mr. Herrera, President Moran and the commissioners? I have copied Steve Ritchie here.
Best regards,
Dave
March 10, 2022
General Manager Dennis Herrera, President Anson Moran and Commissioners San Francisco Public Utilities Commission
525 Golden Gate Avenue
San Francisco, CA 94102
Via email
Re: CDFW Fish Passage Chart
Dear General Manager Herrera, President Moran and Commissioners, Thank you for listening to my public comment regarding fish passage at your March 8th meeting. Thank you
also for the discussion you all had regarding addressing public comments—your discussion was good to hear. In that context I am not requesting a response to this letter.
Here is the fish passage chart I referenced:
This chart was produced by the California Department of Fish and Wildlife (CDFW) and presented at their March 2nd salmon informational meeting.
Two
takeaways are:
1) The Tuolumne salmon are in bad shape.
2) Average unimpaired flows may be a reason for the differences between the Merced, Stanislaus and Tuolumne. The chart below plots the average unimpaired flow for the Stanislaus, Merced and Tuolumne (40%, 26% and 21% respectively) to the 2021 adult salmon counts. Correlation is not causal but there appears to be a strong relationship. As you know the TRVA does not substantially increase flows, which to me means it is a risky approach to solving the problem.
One other note. The fish counts on the CDFW charts are lower than the Fishbio counts that I used for the earlier charts. However, the relative differences between the Stanislaus and the Tuolumne still hold.
I chose the Fishbio data for the earlier charts because they provided daily reporting. Fishbio uses a weir to count incoming salmon while CDFW does carcass surveys to determine successful spawners. I am not qualified to say if one data set is better than the other. Unfortunately, either set of data indicates that the Tuolumne salmon are in trouble.
Kind regards,
Dave Warner
CC: Steve Ritchie, Assistant General Manager, Water Enterprise -
500
1,000
1,500
2,000
2,500
0% 20% 40% 60% 80% 100%
2021 Adult Salmon Count
Average Percent Unimpaired Flow
2021 Adult Salmon Counts and Average
Uni
mpaired Flow
Stanislaus
Merced
Tuolumne
From: Lori Tyler
To: Commission
Subject: Resolution 210577: Support
Date: Thursday, March 10, 2022 4:31:41 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear San Francisco Water,
Dear Supervisors:
I’m writing to urge you to pass Resolution 210577, introduced by Supervisor Peskin, which calls on the San Francisco Public Utilities Commission to pause litigation against the State Water Resources Control Board.
This resolution is needed because the SFPUC staff and the City Attorney, without informing the Board of Supervisors, or even seeking the approval of the SFPUC Commissioners, challenged state-required protections for the Tuolumne River, San Francisco’s drinking water source. The lawsuit relies on a highly flawed interpretation of the Clean Water Act forced on the nation by the Trump administration.
The SFPUC and City Attorney Dennis Herrera claim that allowing the state to protect the Tuolumne River would threaten the City’s drinking water supplies. Together, San Francisco and the two big agricultural water districts on the Tuolumne River divert more than 90 percent of the river’s water in some years. That unsustainable water pumping has had a devastating effect on the river and its salmon runs which the state rightly says needs addressing. San Francisco should be supporting stronger protections for the Tuolumne River and salmon – not fighting them.
San Francisco has a vast network of large reservoirs that store enough water to weather years of drought. In fact, we use less water today than a decade ago and are likely to use even less in future, thanks to technology and population trends. San Francisco could use even less of the Tuolumne River’s water if it followed the example of communities like Los Angeles and Orange County, which are far ahead in water recycling and reuse technologies.
The City’s lawsuit stands in stark contrast to actions taken by former State Attorney General Xavier Becerra who sued the Trump administration over its attempts to weaken the Clean Water Act. The Attorney General’s actions were based on the belief that California should have the ability to keep its rivers and lakes clean and healthy. The SFPUC and City Attorney Dennis Herrera disagree and argues that Trump was right when it comes to stripping protections for the environment.
No doubt the SFPUC and City Attorney’s office will present you with arguments about how the sky will fall if the City is forced to withdraw its anti-environmental lawsuit. Some of the biggest air polluters in the state would have presented similar arguments when AG Becerra fought off Trump administration efforts to weaken California’s air pollution laws. Fortunately, Becerra won that fight. If he were still here, he’d probably win this fight too.
Sincerely,
Lori Tyler
Fremont, CA 94536
From: Cindy Charles
To: Commission
Subject: Request to expedite decision on the Design Drought Plan Date: Friday, March 11, 2022 9:20:58 AM
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To the Commissioners,
I am Cindy Charles, a native San Franciscan and someone who has fly fished the Tuolumne River for decades top to bottom. I have seen the dramatic decline of the fishery on the lower Tuolumne to the point where I don’t fish there anymore. Not only is it not worth fishing, but the few remaining trout are too valuable to be impacted by even catch and release angling.
I participated in numerous SFPUC workshops focusing on the Tuolumne River. These workshops were a great opportunity to collaborate with stakeholders and to communicate and share information to work towards some meaningful solutions.
An important goal of the workshops was to take a look at your projected Design Drought Plan. The Design Drought combined the worst two droughts from the last century (1987-1992 and 1976/77) to create a manufactured and unprecedented eight-year mega-drought.
This Plan is unrealistic and is
in need of serious reassessment based on actual demand and realistic demand projections.
I am asking you to please modify and expedite a decision on the Design Drought Plan. The Tuolumne River is continuing to suffer and is facing total ecological collapse. With only 576 salmon returning last fall/winter and 1 lonesome steelhead returning, this is a heartbreaking situation. The native fish are about to disappear on the Tuolumne River having been impacted by the long entrenched SFPUC water policies that are outdated.
You cannot delay decisions on keeping more water in the Tuolumne for the fish and the environment.
Your actions can make a huge impact.
SFPUC needs to have a realistic and responsible water policy in place for the lower Tuolumne.
Thank you,
Cindy Charles
Board Member, Tuolumne River Trust
Board Member, California Sportfishing Protection Alliance Conservation Chairperson, Golden West Women Flyfishers
Policy Advisor, Trout Unlimited, Golden Gate Chapter
San Francisco, CA 94107
From: Ritchie, Steve
To: Hood, Donna
Cc: Herrera, Dennis J
Subject: Governors" press release for sharing with the Commission re State Drought Emergency Date: Monday, March 14, 2022 1:30:53 PM
Attachments: Newsom Press-release-3.14.2022.pdf
Newsom Administration Boosts State Funding for Drought Emergency | California Governor
Also, copy attached.
Steve.
Steven R. Ritchie
Assistant General Manager, Water
San Francisco Public Utilities Commission
Phone: (415) 934-5736
E-mail: [email protected]
www.sfwater.org
Please conserve water today!
FOR IMMEDIATE RELEASE:
Sunday, March 13, 2022
Governor's Press Office: (916) 445-4571
Newsom Administration Boosts State
Funding for Drought Emergency
SACRAMENTO -- After California recorded its driest January and February in more than 100 years of records in the Sierra Nevada, Governor Gavin Newsom’s administration is spending an additional $22.5 million to respond to the immediate drought emergency.
The additional $22.5 million allocation includes more funding for the Department of Water Resources, State Water Resources Control Board and the California Department of Food and Agriculture.
More than a third of the money – $8.25 million – will be used to increase outreach efforts to educate Californians on water conservation measures and practices.
“These investments continue to provide crucial drought support to communities impacted around the state,” wrote Chief Deputy Finance Director Erika Li in a letter to Legislative budget and appropriations leaders.
The funds requested are part of a comprehensive effort by the Newsom Administration to increase water conservation. Earlier this month, the state launched new video ads to encourage Californians to reduce outdoor watering.
On March 1, the survey of the state’s snowpack showed levels were dropping sharply after robust storms in December. Current snowpack readings are about one-third below average. The Department of Water Resources is analyzing the latest snowpack data and has indicated it may revise its current forecast for State Water Project deliveries in 2022.
With the infusion of additional state budget funds, the Save Our Water campaign is gearing up to reach Californians with water-saving tips via social media and other digital advertising, geo-targeting counties with high water use.
The campaign also is securing partnerships with retailers and other organizations to urge Californians to reduce water use in the immediate term and also make permanent changes to landscaping to build resilience in the long-term.
###
OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.
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San Francisco, CA 94102
T 415.554.3155
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TTY 415.554.3488
San Francisco Public Utilities Commission
Earned Media Clips
February 26, 2022 – March 4, 2022
This is a weekly roundup of local, regional and national media stories either focused on the SFPUC or the result of proactive and reactive efforts by the Communications Division
Date Outlet Story
2/27/22 SF Chronicle Satellite images show just how quickly Sierra’s snowpack is retreating
(sfchronicle.com)
3/2/22 Civil Eats A New California Law Will Create a Lot More Compost—but Will it Make it to
Farmland? | Civil Eats
3/3/22 NBC Bay Area SF Granted Nearly $11M to Credit
Customers on Utility Bills – NBC Bay
Area
3/3/22 SF Gate City Granted Nearly $11 Million To Credit Customers for Utility Bills (sfgate.com)
3/3/22 CBS San Francisco Secures Almost $11
Million To Help Residents With Utility Bills
– CBS San Francisco (cbslocal.com)
3/3/22 Patch Apply Now For Discounts on Water Bill +
Hetch Hetchy Power Bill | San Francisco,
CA Patch
From: Judy Irving
To: Commission
Subject: Design Drought
Date: Thursday, March 3, 2022 1:59:35 PM
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Dear Commissioners,
I'm a filmmaker ("Secrets of the Bay," "San Pablo Baylands") and Bay swimmer. I have intimate, on-the-ground and in-the-water knowledge of the Bay-Delta over nearly fifty years, making environmental films such as those listed above (as well as “The Wild Parrots of Telegraph Hill” and “Pelican Dreams.”) My in-progress feature documentary, entitled “Cold Refuge,” is about the healing aspects of swimming in San Francisco Bay.
The entire Bay-Delta ecosystem is on the brink of collapse. I urge you to expedite your deliberations on the Design Drought. There is no time to waste. Fish and other aquatic species need protection, and so do we humans who value and depend upon a healthy bay.
Thank you,
Judy Irving
Producer/Director
From: Martin Gothberg
To: Commission
Subject: Design Drought Deliberations
Date: Thursday, March 3, 2022 2:56:28 PM
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Commissioners,
I am a long time supporter of the TRT with my time and money. Having listened in on four of the six workshops and attending several SFPUC hearings with presentations by staff, after reading through the LTVA, it is clear to me that the 'design drought' introduced as an idea years ago is extremely unlikely to occur. Please expedite your review of this understandably conservative idea that will more
likely cause the extinction of salmon than
address possible water constraints in the Bay Area.
Thank you,
Martin Gothberg
Santa Clara, CA
From:
To: Commission
Subject: Long Term Vulnerability Assessment and the Design Drought Date: Thursday, March 3, 2022 5:10:23 PM
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Dear Commissioners,
I am an end user of SFPUC water in Palo Alto and avid outdoors person and fisher person. During all our droughts my family has scrupulously saved water and have installed all manner of water saving technology-low flow shower heads and toilets, rain sensitive irrigation timers, and native plant landscaping to replace lawns. We have done this in the expectation that thee efforts would lead to better protection of the natural environment, especially salmon Unfortunately this his not turned out to be the case as the SFPUC has sued the State Water Board over minimum flows on the Tuolumne rather than providing sufficient flows for fish reproduction. At the science workshops sponsored by the SFPUC, academic experts repeatedly said that the voluntary agreements were helpful but that there was no substitute for adequate flows to promote fish reproduction.
The eight year Design Drought and unrealistic assumption of 265 MGD of consumption in the future has resulted in the SFPUC proposing to continue to destroy fish habitat.
Problems caused by low flows extend up into river ecosystems. Low flows (1) make it hard for
anadromous fish—such as salmon—to migrate from freshwater where they are born to the ocean, and then back again to spawn; (2) allow our
Sierra streams to get too warm for native fish to be
healthy; (3) don’t allow floodplains (critical habitat for baby fish) to get inundated; and (4) fail to dilute pollutants, such as agricultural pesticides and fertilizers.
I urge the SFPUC to reconsider the assumption of an 8 year Design Drought and extremely high consumption estimates which will continue to promote the destruction of the riverine environment.
Thank you.
Dr. Stephen Rosenblum
Palo Alto
From: Brian Browne
To: Hood, Donna
Cc: Elsbernd, Sean (MYR); Peter Drekmeier
Subject: A clarification question -
Date: Friday, March 4, 2022 9:43:11 AM
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Dear Donna,
Please forward to GM Herrera and Honorable SFPUC Commissioners. I am trying to understand the below mentioned document. I hope i have not confused the language? Cheers,
Brian Browne
Dear General Manager Herrera and Honorable Commissioners, I have read part of your presentation THE SAN FRANCISCO PUBLIC UTILITIES COMMISSION (SFPUC) Management's Discussion and Analysis (Unaudited) June 30, 2021, and 2020. You note "that capital assets (less?)
accumulated depreciation and amortization
increased by $141,887 or 2.6% to $5,530,545." Is this number equivalent to what your Rate base would be (plus working cash) if the SFPUC was still using the Utility Method for calculating debt service? If so, what would be your weighted average cost of capital to compute debt-service eligible for P218 rate inclusion? What is your Cash Method computed debt service for the identical period?
I do find the utility method more concise for tracking the mandate of 1996 Proposition 218 that only current costs are allowed in current rates.
Truly and thank you for reading,
Brian Browne
March 4, 2022
President Anson Moran and Commissioners
SFPUC
525 Golden Gate Avenue
San Francisco, CA 94102
Via email
Re: Need to Prioritize Action on the Design Drought and Water Demand Projections.
Dear President Moran and Commissioners:
On November 30, 2020, the SFPUC embarked on the first of six very productive workshops focusing on the Tuolumne River and water supply. 11 months later, on October 29, 2021, the workshops culminated with a presentation and discussion on the Long-Term Vulnerability Assessment. Four months have passed since then, and the SFPUC has yet to take the next step of acting upon the wealth of information received over the past 15 months.
At your most recent meeting, President Moran asked staff to prepare a schedule to address the unfinished business related to items identified at the workshops. This is a step in the right direction, but we are concerned we will experience a series of delays, as we have in the past. It is important that you, the Commissioners, take the lead on driving next steps to ensure the momentum generated by the workshops is not lost.
Following the October LTVA workshop, we encouraged you to request additional information from staff to help make your process for making changes to the Design Drought a little clearer.
We submitted letters on November 5, 2021 and January 19, 2022, and commented at a number of SFPUC meetings, but didn’t receive responses.
On February 4, 2022, we followed up with our own analysis of the LTVA, but again were met with silence. If you were provided with the additional information we requested, which we believe exists, it should not be a difficult decision to reduce the length of the Design Drought.
Staff has a long history of withholding information from the public and dismissing NGO recommendations. They also have failed to respond to requests from Commissioners. Putting former Commissioner Vietor’s numerous unmet requests aside, we present the following three recent examples of staff’s failure to address your requests.
2 1) At the July 16, 2021 water demand and demand management workshop, Commissioner Moran requested information about the difference between CA. Dept. of Finance and Plan Bay Area population projections. Seven months have passed, yet there has been no response.
2) On November 9, 2021, former Commissioner Harrington requested regular updates on environmental metrics focusing on the health of the Tuolumne, specifically salmon returns to the river. Four months have passed, yet there has been no response. In the meantime, Dave Warner, a member of public, provided bi-monthly salmon count graphs throughout the spawning season.
3) On January 7, 2022, Commissioner Ajami requested a graph comparing historic water demand projections from the Water Enterprise and the SFPUC’s financial division. Two months have passed, yet there has been no response.
Meanwhile, the Tuolumne salmon run dropped to less than 600 fish last fall, as compared to more than 6,000 salmon returning to the Stanislaus River. The clear difference between the two rivers is the magnitude of instream flow.
The SFPUC has known for decades that major action is needed to restore the Tuolumne River ecosystem and prevent the extirpation of salmon, yet little action has been taken.
In 1996, a settlement agreement during a FERC proceeding for the Tuolumne River was signed by the SFPUC, MID and TID, government agencies and NGOs. Much like the proposed Tuolumne River Voluntary Agreement (TRVA), the 1996 settlement was based primarily on non-flow measures. The agreement failed to restore fish populations. In fact, the number of spawning fish in the Tuolumne has declined precipitously since 1996. Of the 10 priority habitat restoration projects identified in the 1996 agreement, only four were completed.
The signature project of the 1996 settlement involved filling in an old in-river mining pit that harbored non-native bass. It was a sound idea partially, but it failed because it was not accompanied by the flows that might have made it effective. The post-project monitoring report was very clear that high flows are an essential element of controlling predator habitat.
The report states:
During extremely wet years, high flows can flush largemouth bass out of a stream, but typically a sufficient number of adults can find shelter in flooded areas to repopulate the stream during lower flow conditions (Moyle 2002)…During the years following the flood, largemouth bass abundance was controlled by spring and summer flow conditions that were unfavorable for reproduction. Largemouth bass require low water velocities and warm water temperatures to reproduce. (Moyle 2002, Swingle and Smith 1950, Harlan and Speaker 1956, Mraz 1964, Clugston 1966, Allan and Romero 1975, all as cited in Stuber et al 1982) (p 130).
1 1 Special Run Pool 9 and 7/11 Reach: Post-project Monitoring Report, McBain & Trush and Stillwater Sciences, June 30, 2006, p. 130.
3 Though the science shows that low river flows are the primary cause of salmon mortality, the SFPUC and Irrigation Districts have for many years pursued the TRVA, which focuses almost exclusively on non-flow measures.
Notwithstanding messaging and policy statements about environmental stewardship, the SFPUC and Irrigation Districts have failed the Tuolumne River ecosystem. During the five-year period from 2012 through 2016, the total volume of flow in the Tuolumne River averaged just 12% of unimpaired flow. Over the past two years, it averaged 14% of unimpaired flow. As a result, the salmon population has plummeted.
Graphs produced by Dave Warner.
Recommendations
The conservation and fishing organizations on this letter recommend that the Commission:
1) Direct staff to produce specific information you need to make well-informed decisions regarding the length of the Design Drought and realistic water demand projections. We encourage you to revisit our letters for suggestions. Specifically, you should direct staff to: 1) produce graphs similar to those identified in the January 19, 2022 NGO letter that use current demand and incorporate the Bay Delta Plan instream flow requirements; 2) determine the occurrence interval (likelihood) of the Design Drought and the Design Drought minus its final year; and 3) respond to the NGO analysis of how earlier runoff might affect the SFPUC’s water entitlements.
2) Schedule a final workshop to go over the LTVA and new information provided by staff, as well as information provided by the NGOs. This workshop should take place within the next six weeks.
3) Schedule a discussion at your next meeting following the workshop to address the outcomes of the workshop and revisit policy decisions regarding the Design Drought and water demand projections.
We are convinced the SFPUC can meet the Bay Delta Plan instream flow requirements without compromising water supply security. The workshops and LTVA have helped make this clear. The Tuolumne River and Bay-Delta ecosystems are on the brink of collapse and cannot wait any longer. The time for action is now.
4 Thank you for considering our comments and recommendations.
Sincerely.
Peter Drekmeier
Tuolumne River Trust
Chris Shutes
California Sportfishing Protection Alliance
John McManus
Golden State Salmon Association
Bill Martin
Sierra Club Bay Chapter
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Bart Westcott
November 5, 2021
President Anson Moran and Commissioners
SFPUC
525 Golden Gate Ave.
San Francisco, CA 94102
Via Email
Dear President Moran and Commissioners:
We’d like to thank you again for hosting last week’s workshop on the SFPUC’s Long- Term Reliability Assessment, and for including us. Some important information was shared.
We understand the purpose of the study was to assess the Regional Water System’s (RWS) vulnerability to climate change and other factors. However, the study also provides useful information that can help you assess the reasonableness of the Design Drought.
There are two issues we believe would benefit from additional analysis. First is an assessment of the expected occurrence interval for the Design Drought and for the Design Drought minus one year. Second is the potential impact of earlier runoff on the SFPUC’s water rights.
Occurrence Interval for the Design Drought
The following table was included on slide 43 of the staff/consultant presentation. We request that the Commission direct staff to add two new rows to this table, one for the Design Drought and a second for the Design Drought minus one year.
It could be that the occurrence interval for the Design Drought is as simple as multiplying the recurrence intervals of 1976/77 and 1987-92. If this is the case, the current odds of experiencing the Design Drought would be 1-in-42,000. With a 10%
2 decrease in precipitation (if it weren’t made up for in some other way) would be 1-in-5,400, and a 20% decrease in precipitation would be 1-in-1,125.
Below is a graph produced by Paul Collacchi, a former Mayor of Menlo Park and a member of the Mayor’s Water Supply Stakeholder Group. He plotted every eight-year sequence over the past 600 years using the historical record and tree ring data. Each bar represents eight consecutive years. The red line represents the Design Drought. You’ll see that the Tuolumne River did not experience anything even close in severity to the Design Drought during that time period.
Impact of Earlier Runoff on Water Rights
There was some disagreement at the workshop as to how earlier runoff might affect the SFPUC’s water rights. It turns out everyone was correct. On average, the SFPUC’s water rights remain about the same, because in normal and wet years the SFPUC tends to lose some of its entitlement to the Irrigation Districts. However, in dry years, when it really matters, the SFPUC gains entitlements.
Working with Greg Reis from The Bay Institute, we looked at how a three-week shift in runoff might affect the SFPUC’s water rights during the Design Drought. The data we used came from the Tuolumne Daily Model version 3.1 developed by the Irrigation Districts for use in the FERC licensing process. The unimpaired flow data were an input dataset developed by Dan Steiner in 2013.
3 The following scatter plot demonstrates that in drier years (on the left side of the horizontal axis) water entitlements shift from the Irrigation Districts to the SFPUC, showing up on the vertical axis as above zero (the break-even point). In wetter years, moving to the right on the horizontal axis, water rights shift from the SFPUC to the Irrigation Districts. The loss of entitlements in wet years is much less of a concern to the SFPUC than the benefit of picking up water rights in dry years when water is needed most.
According to our calculations, the shift in water rights for the eight years that constitute the Design Drought is as follows (figures are in thousand acre-feet).
1976 = +20
1977 = 0
1987 = +51
1988 = +8
1989 = +33
1990 = +54
1991 = +9
1992 = +62
The total amount of water the SFPUC would gain during the Design Drought if runoff were to occur three weeks earlier is 237 thousand acre-feet (TAF). Total SFPUC entitlements during the Design Drought years were 858 TAF, so 237 TAF represents a 28% increase.
RWS demand in FY 2019/20 was 198 mgd, or 222 thousand acre-feet. Therefore, the change in water rights during the Design Drought with runoff occurring three weeks earlier would amount to more
4 than one year’s-worth of water shifting to the SFPUC. We believe this should further justify removing one year from the Design Drought.
Conclusion
In summary, we request that the Commission direct staff to:
1) Determine the occurrence interval for the full Design Drought and the Design Drought minus one year.
2) Assess the potential impact of earlier runoff on the SFPUC’s water entitlements under the Design Drought scenario.
Thank you for the opportunity to share our thoughts and requests.
Sincerely,
Peter Drekmeier Dave Warner
Policy Director TRT Volunteer
Alameda Creek Alliance • California Sportfishing Protection Alliance Friends of the River • Golden State Salmon Association
Golden West Women Flyfishers • Institute for Fisheries Resources Northern California Council Federation of Flyfishers • Pacific Coast Federation of Fishermen’s Associations • San Francisco Baykeeper
San Francisco League of Conservation Voters • Tuolumne River Trust
January 19, 2022
Dr. Casey Brown and Mr. Alexis Dufour
[email protected]
[email protected]
Dear Dr. Brown and Mr. Dufour:
Thank you for the effort you’ve put into the SFPUC’s Long-Term Vulnerability Assessment (LTVA). It’s an impressive study that will play an important role in helping the SFPUC plan for future water supply security in the era of climate change.
The report describes future vulnerability under long-term conditions of extreme stress. Its modeling setup could also be re-used, quite easily, to help the SFPUC better understand current and near-future conditions and stressors to answer timely questions, such as:
1) How likely is the SFPUC’s design drought to occur? Could it be modified or operational rule changes made to provide more flexibility for water supply planning (i.e. less unnecessary rationing) without compromising water supply security? 2) How might climate change, along with the instream flow requirements adopted by the State Water Board through the Bay Delta Water Quality Control Plan, affect the SFPUC’s water supply and entitlements under expected future conditions? 3) Under which future climate change projections, with the Bay Delta Plan implemented, would the SFPUC need to develop alternative water supplies, and if so, how much?
The undersigned organizations and individuals request that you consider additional water supply scenarios to help answer the questions above. These scenarios are:
Re-analyze scenarios using actual current demand.
The LTVA analyzes a number of scenarios, but none considers the possibility that water demand in the SFPUC’s Regional Water System (RWS) service area might remain flat or decline. The figures used are anywhere from 16% to 71% above current demand. The report should include a demand scenario of 200 mgd, if not also one of even lower demand. SFPUC water deliveries have been below 200 mgd for the past seven years.
3 Mark Rockwell
President
Northern California Council Federation of
Flyfishers
Mike Conroy
Executive Director
Pacific Coast Federation of Fishermen’s
Associations
Institute for Fisheries Resources
Kristina Pappas
President
San Francisco League of Conservation
Voters
Jeff Miller
Dave Warner
Member
SF Mayor’s Water Supply Stakeholder
Group
Bill Martin
Bill Martin
Member
SF Mayor’s Water Supply Stakeholder
Group
Paul Collacchi
Member
SF Mayor’s Water Supply Stakeholder
Group
Iris Stewart-Frey
Professor
Santa Clara University
Executive Director
Alameda Creek Alliance
Cc: SFPUC Commissioners
Dennis Herrera, SFPUC
Steve Ritchie, SFPUC
California Sportfishing Protection Alliance • Coalition for San Francisco Neighborhoods • Friends of the River • Golden West Women Flyfishers Institute for Fisheries Resources • Northern California Council, Fly Fishers International • Pacific Coast Federation of Fishermen’s Associations San Francisco League of Conservation Voters • Save California Salmon • Sierra Club California • Sierra Club San Francisco Bay Chapter Tuolumne River Trust • Wholly H2O
February 4, 2022
President Anson Moran and Commissioners
San Francisco Public Utilities Commission
525 Golden Gate Avenue
San Francisco, CA 94102
Via email
Re: The Long-Term Vulnerability Assessment Offers Promising Results.
Dear President Moran and Commissioners:
While the SFPUC’s Long-Term Vulnerability Assessment (LTVA) is an impressive document that includes a lot of useful information, it falls short on providing clear answers to questions you may have regarding the practicality of the Design Drought. However, information can be extrapolated from the Study that clearly demonstrates the SFPUC could manage the Bay Delta Water Quality Control Plan instream flow requirements without risking running out of water.
Following are some of our findings.
Even with Inflated Water Demand Figures, the SFPUC’s Water Supply Is Not in Jeopardy
The LTVA states, “In summary, water delivery reliability is more sensitive to demand change than to change in temperature and precipitation.”
1 Yet the LTVA used a baseline demand of 227
mgd, which is 16% higher than the actual current demand of 195 mgd. Given the importance of demand in water supply planning, we find it surprising and disappointing the LTVA didn’t include any scenarios using current demand.
In fact, the six figures used to represent water demand in the LTVA are between 16% and 71% higher than current demand. Our requests to include current demand went unanswered.
1 SFPUC Long-Term Vulnerability Assessment, p. 172.
2 At your January 7, 2022 budget workshop, there once again was discussion about the large disparity in demand projections between the SFPUC’s financial and water supply divisions. We appreciated Commissioner Ajami’s request that staff produce a graph showing both sets of projections together, and compared to actual demand.
You have yet to receive this graph, but we’ve done our own analysis based on Urban Water Management Plan (UWMP) projections and the five most recent 10-Year Financial Plan projections (we’re still waiting to receive the earlier plans). We found that the financial projections were extremely close to the actuals, whereas projections for 2020 demand in the 2000 through 2015 UWMPs ranged from 19% to 47% greater than actual demand.
The most recent 10-Year Financial Plan forecasts water sales will remain flat over the coming decade. But even with the inflated demand figures used in the LTVA, the chance of the SFPUC running out of water as a result of the Bay Delta Plan instream flow requirements is very small, as explained below.
Annual Mean Precipitation is Unlikely to Change
The LTVA offers a much better understanding of how climate change will likely affect precipitation. It found that annual mean precipitation is unlikely to change, and is slightly more likely to increase than decrease. The Study states:
According to climate projections and expert elicitations, there is a central tendency of warming of +2°C and +4°C by 2040 and 2070 (Representative Concentration Pathway [RCP]
3 8.5), respectively, with no clear direction of change in mean annual precipitation over the planning horizon.2
And:
The Upcountry region and East Bay and Peninsula regions are in the positive precipitation domain for the winter season in 2070, and thus are somewhat more likely to see positive than negative precipitation in the near future.
3 The Bay Delta Plan Will Not Cause the SFPUC to Run Out of Water
Despite our repeated requests, the LTVA does not include scenarios incorporating the Bay Delta Plan instream flow requirements (IFR) to allow for an easy comparison with the current flow regime. However, it does provide information that can be used to deduce the Bay Delta Plan’s potential impact on water supply. For example, the Study states:
The RWS [Regional Water System] is particularly vulnerable to the state-adopted new IFR below Don Pedro Dam (State WQCP), which represents a significant reduction in water available. At a demand of 227 mgd, the effect of state-amended WQCP under current conditions is equivalent to a reduction in mean annual precipitation of about 15% in terms of the water delivery reliability (reliability around 85%, rationing in 1 out of 6.5 years on average).
4 The following graph demonstrates that even with a 20% reduction in precipitation, and at 227 mgd demand, the SFPUC remains in the safe zone (green) when it comes to water supply reliability. A 20% decrease in precipitation is greater than the 15% decrease that would be comparable to the Bay Delta Plan IFR. Using actual current demand (195 mgd), the impact of the IFR would move closer to the vertical line above 0% decrease in precipitation.
2 Ibid, p. xxii.
3 Ibid, p. 26.
4 Ibid, p. xxii.
4 Source: LTVA webinar, 1/27/22
The graph below5 illustrates the potential impact of precipitation change on water supply, using the 227 mgd baseline and a 20% decrease in precipitation. Substituting the Bay Delta Plan IFR (the equivalent of 15% precipitation loss), it demonstrates that the SFPUC is unlikely to run out of water. Using actual current demand would further improve the calculus.
The Design Drought is Extremely Unlikely to Occur
The following table
6 predicts how likely the severity of past droughts is to reoccur under two scenarios – demand of 240 mgd (Threshold: 269 TAF) and demand of 326 mgd (Threshold: 365 TAF). In other words, at 240 mgd demand, a two-year drought with an impact on water supply
5 Ibid, p. 176.
6 Ibid, p. 81.
5 as severe as the 1976/77 drought would be expected to occur once in 98 years. A drought as severe as 1987-92 would be expected to occur once in 772 years.
Despite our repeated requests, the SFPUC has failed to produce similar return periods for the Design Drought and the Design Drought minus one year. When flipping a coin, the odds of getting heads is 50%. The odds of getting heads twice in a row is 50% times 50%, or 25%. If this same methodology applies to droughts, the chances of the Design Drought occurring are miniscule.
Earlier Runoff Will Benefit the SFPUC’s Water Entitlements in Dry Years
The Study found that runoff is expected to come earlier in the season as a result of a diminished snowpack and more precipitation arriving as rain instead of snow. It states:
Therefore, an increase in temperature would result in less snowpack accumulation during winter season, as more precipitation will fall as rain rather than snow, leading to 1) a reduced spring runoff volume and magnitude and 2) an increase in winter flows. The spring runoff is also expected to occur earlier in the season (Figure 5-2). 7 And:
A +2°C warming leads to a spring runoff arrival 10 days prior to the baseline temperature conditions. Median of projections estimate warming around +2°C by 2040 with most projections and elicitations between +1°C and +4°C. At +4°C, the shift in timing would be closer to 20 days prior to baseline conditions. By 2070 RCP8.5, warming could reach around +4°C with most projections and elicitations between +3°C and +6°C. 8 Our analysis of historic data suggests that if the Design Drought were to repeat, but runoff came three weeks earlier, the SFPUC would pick up an additional 237 thousand acre-feet (211 mgd) of water – enough to add more than a year’s-worth of water to SFPUC storage. This is because the Modesto and Turlock Irrigation Districts are entitled to the first 2,400 cubic feet
7 Ibid, p. 147
8 Ibid, p. 147
6 per second (cfs) of runoff for most of the year. But between mid-April and mid-June (time of peak runoff), the Irrigation Districts are entitled to the first 4,000 cfs of runoff. Runoff between 2,400 and 4,000 cfs that shifts from mid-April-to-mid-June into the earlier season is water the SFPUC picks up. Runoff between 2,400 and 4,000 cfs that shifts from post-mid-June into the mid-April-to-mid-June period is water the Irrigation Districts pick up.
According to our calculations, the shift in water entitlements for the eight years that constitute the Design Drought would produce the following additions to SFPUC water supply (figures in thousand acre-feet).
Conclusion
If the SFPUC were to use reasonable demand projections, remove one year from the Design Drought, and consider the increase in “Water Available to the City” as a result of earlier runoff, it would significantly change the risk analysis. The following table is based on 200 mgd demand, includes the Bay Delta Plan instream flow requirements, and incorporates the additional water available to the SFPUC as a result of earlier runoff.
7 Source: Tuolumne River Trust
The results shown in the above table are extremely encouraging. Within the planning exercise that the Design Drought actually is, the SFPUC could manage a 7.5-year Design Drought and still retain positive storage, without developing any new alternative water supplies. The SFPUC could maintain positive storage over an eight-year Design Drought by developing 4,000 acre feet (3.8 mgd) of alternative annual water supplies.
Thank you for the opportunity to share our analysis of the LTVA. We look forward to working with you to implement decisions that will benefit the Tuolumne River ecosystem while also protecting the SFPUC’s water supply. We encourage you to schedule a discussion on the Design Drought as soon as possible.
Sincerely,
Peter Drekmeier
Policy Director
Tuolumne River Trust
Chris Shutes
FERC Projects Director
CA Sportfishing Protection Alliance
9 Elizabeth Dougherty
Elizabeth Dougherty
Executive Director
Wholly H20
Iris Stewart-Frey
Professor
Santa Clara University
From: Virginia VanKuran
To: Commission
Subject: Please Support Adequate Water for the Tuolumne River. It"s Possible! Date: Saturday, March 5, 2022 7:44:06 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear San Francisco Public Utilities Commission,
Thank you for this opportunity to express my opinion. I’ve lived in the Bay Area for most of my 73 years and watched it prosper. I think we all have realized over the past years that we need to take care of our natural environment for true prosperity. I’ve donated and belong to several organizations that are focused on a clean, healthy environment for the Bay Area.
As a long time member of Tuolumne River Trust I admire their thoughtful approach to advocating for a balanced approach to how we use the precious water from the Tuolumne River to benefit the environment we depend upon, the water we drink (I live in Palo Alto) and the food we eat (I’m a vegetarian and benefit from all the local organic farms).
In order to maintain a healthy Tuolumne River there needs to be adequate flow for the health of the river's environment.
The Tuolumne River Trust has shown in many different ways that we can ensure adequate flow for the river and have sufficient water for those of us who drink Tuolumne River water.
I support their suggestions and hope that you will also.
Regards,
Virginia Van Kuran
Palo Alto
From: Denise Louie
To: Commission
Subject: Message of hope
Date: Sunday, March 6, 2022 11:24:08 AM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Hi President Anson Moran and Commissioners,
The time has come for you to decide the fate of numerous species and the health of ecosystems. It's an awesome responsibility. It's also a great opportunity to show that you care about the 7 threatened fish species in the San Francisco Bay-Delta.
These
include smelt, salmon, sturgeon and more. Smelt are an indicator species, indicating the health of the Bay-Delta ecosystem. And there are barely enough smelt to count, where once they were in great abundance. Salmon are a keystone species. Once gone, entire ecosystems will fail.
California is one of only 36 internationally recognized biodiversity hotspots. We are blessed with an abundance of species, many of which we humans have brought to the brink of extinction--especially during our lifetimes.
We may have enjoyed nature's
bounty, but now it's time to protect that bounty from human activities and climate disruption.
I hope you will adopt water use projections based on Tuolumne River Trust analyses.
I hope you will withdraw the SFPUC's two law suits against the State Water Board with all due speed.
Thank you.
Denise Louie
Member, Center for Biological Diversity
SFPUC customer
SF native
From: Brian Browne
To: Hood, Donna
Cc: Peter Drekmeier; Douglas L Comstock
Subject: Re: Updated: March 8, 2022 SFPUC Regular Meeting Agenda Date: Monday, March 7, 2022 9:25:39 AM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear Donna - Please forward the following to D. Herrera and Commissioners. I remain perplexed at some of their statements. Truly and thanks - Brian Browne
***************************************************************************************** March 7, 2022
Dear GM Herrera and Honorable Commissioners:
I have reviewed Item 8(a) Alternative Water Supply Quarterly Update by S. Ritchie and M Kathari dated 3/8/2022.
The number 265 MGD is mentioned in many different contexts. Mr. Richie has proclaimed it as an average demand and now on page 55 of 64, the above-mentioned report is a contractual amount.
If it is an average demand – how was that determined?
Is there a statistical distribution around your assumed average demand of 265 MGD? Statistical analysis of the Hetch Hetchy demand series shows 265 MGD is a statistical outlier. A number that is expected infrequently and not an average (50% less/50% greater) demand or a number to benchmark ad infinitum contractual allocations.
I find no prolonged demand series validating BAWSCA’s ad Infinitum rights to receive 184 MGD.
Please show your calculations used in making the 184 MGD allocations (contractual amounts) enshrined in the 2009 Water Sales Agreement?
The SFPUC must show the equations (with explanatory and understandable prose) that drive your demand forecasts and allocation criteria.
I look forward to your immediate response and hopefully engaging in a dialog.
Truly,
Brian Browne
SF 94111
**************************************************************************************** On 3/6/2022 9:18 AM, Hood, Donna wrote:
Good Morning,
The SFPUC Regular Meeting agenda for March 8 has been updated to include revision for item 8a, Alternative Water Supply Planning Report and can be accessed via the following updated
LINK.
Thank you and apologies for any inconvenience.
Donna Hood
Commission Secretary
From: Hood, Donna <[email protected]>
Sent: Thursday, March 3, 2022 12:31 PM
Subject: March 8, 2022 SFPUC Regular Meeting Agenda
Good Afternoon,
The SFPUC Regular Meeting Agenda has been posted and can be found via the following LINK.
Thank you,
Donna Hood
Commission Secretary
OFFICES
San Francisco
Modesto
Sonora
Mailing Address
P O Box 3727
Sonora, CA 95370
Phone
(415) 882-7252
Website
www tuolumne org
BOARD MEMBERS
John Kreiter, Chair
Harrison “Hap” Dunning,
Vice Chair
Cindy Charles, Treasurer
Kerstyn Crumb, Secretary
Eric Heitz,
Chair Emeritus
Jose Borroel
Eddie Corwin
Bob Hackamack
Camille King
Marty McDonnell
Homero Mejia
John Nimmons
Eric Riemer
Marek Robinson
Bart Westcott
March 7, 2022
President Anson Moran and Commissioners
SFPUC
525 Golden Gate Ave.
San Francisco, CA 94102
Re: Item 8a: Alternative Water Supply Planning Quarterly Update.
Dear President Moran and Commissioners:
Item 8a on your March 8 agenda provides an excellent example of why you should revisit the Design Drought as soon as possible. The Design Drought as it is currently configured, would lead to overinvestment in alternative water supplies and stranded assets. With the Alternative Water Supply Plan due for completion by July 1, 2023, time is of the essence.
Slide 3 in the staff presentation indicates that 84 mgd of additional supplies would be needed to meet 2045 demand. Slide 4 identifies 35 mgd of “Projects Underway.”
Scenario VII presented at the March 26, 2021 SFPUC workshop shows that if the Design Drought were shortened by one year, 35 mgd would be sufficient to meet 236 mgd demand in 2045, even with the Bay Delta Plan instream flow requirements in place.
2 Water demand in 2045 is likely to be much lower than 236 mgd (the figure used in the 2020 UWMP and reflected in Scenario VII). At the July 16, 2021 SFPUC workshop, Steve Ritchie stated:
“I want to make sure it’s clear that the Urban Water Management Plan is not intended to be an actual projection of demands, because plan developments may or may not occur or may be delayed for a variety of reasons…and the projections presented in the 2020 Urban Water Management Plan are closer to an outside envelope of what the demands may be in 2045 rather than actual demands.”
The 2045 population growth projection for San Francisco in the 2020 Urban Water Management Plan (UWMP) is four times greater than the CA Department of Finance’s (DoF) projection. Using the DoF projection would reduce demand in San Francisco alone by 10 mgd.
Similarly, BAWSCA’s population projection for 2045 is more than twice that of DoF.
The additional 49 mgd (above the 35 mgd included in “Projects Underway”) cited in the staff presentation would be a terrible investment. It also is unlikely the 35 mgd of “Projects Underway” will be needed. Paying for this unneeded water would increase rates dramatically, sending a stronger price signal to consumers to reduce water consumption. As a result of the decrease in demand, rates would need to be increased even more to cover fixed costs.
Before investing more time in the Alternative Water Supply Plan, it would be prudent for the Commission to make a determination on the length of the Design Drought and realistic demand projections. Doing so would enable you to make a better informed decision on how much to invest in expensive alternative water supplies.
Thank you for considering our comments.
Sincerely,
Peter Drekmeier
Policy Director
Tuolumne River Trust
Dave Warner
Volunteer
Tuolumne River Trust
From: Ed Hillard
To: Commission
Subject: Urgent Need to Change the Design Drought
Date: Tuesday, March 8, 2022 2:06:07 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
March 7, 2022
To: SFPUC Commissioners
Re: Change the Design Drought
Honorable SFPUC Commissioners:
I am a seventy six year old nearly sixty year resident of the Bay Area.
I have lived here long enough vividly to
remember the impact that Sylvia McLaughlin and her colleagues made in changing the view of the Bay from a garbage dump to a natural resource, one worth treasuring and preserving. It is in the name of those women and the members of the Tuolomne River Trust that I am writing you to request your rational recognition of the risks entailed to the Bay and its tributaries by the Commission’s current Design Drought evaluations and failure to use realistic demand projections of water use in its Long-Term Vulnerability Assessment (LTVA).
Sylvia McLaughlin, Kay Kerr and Esther Gulick, had the insight some sixty years ago that saving the Bay meant improving the lives of everyone who lived near the Bay.
The Tuolomne River Trust (TRT) likewise has the insight of which they have been trying to persuade the SFPUC that saving the tributaries of the Bay helps save the Bay.
They have pointed out the consequences of not doing so, a dead San Joaquin River, a dead Tuolomne River, and so forth.
The TRT are asking the SFPUC to go about their evaluation honestly and the TRT are pointing out that if an honest evaluation is done it will show that the SFPUC can be confident that they will have assured water resources into at least the late 21st century and they will not have to ask their client customers to forego water usage beyond what these clients have already shown they can do and are willing to do.
Yet the SFPUC it seems in every evaluation to keep putting their finger on the scale.
Most recently this occurred
in the figure chosen for baseline demand in the LTVA, where they chose a figure of 227 mgd when even recent demand had not exceeded 195 mgd. Citizens of the Bay Area have shown they can reduce their demand. The SFPUC doesn’t seem treat to these citizens’ past behavior as valid or indicative of future behavior. The SFPUC hasn’t treated as valid this tendency to conserve for the public good for a long time now.
Before I retired I worked for Hewlett-Packard in that company’s computer business. One of the things we at HP always found ourselves up against as we tried to persuade businesses of the viability of our technology was the rule of thumb, You’ll never get fired for choosing IBM. Buying managers in the businesses that were our potential customers had this engrained in their thinking. They would not consider something that was demonstrably a better choice for them because of this engrained thought pattern. I suggest that the members of the SFPUC have the same kind of engrained thinking in their approach to the amount of water they want to keep in Hetch Hetchy versus the amount of water that is needed to keep the San Joaquin, the Tuolomne, and the greater San Francisco Bay as healthy natural waterways.
In the meantime, as Rome burns, these rivers and even the Bay suffer with every year of declining water supply, despite the SFPUC’s having in its own research the information that, were they to behave differently, more responsibly, they could with confidence still deliver well into the later decades of the 21st century the water their clients and customers needed while keeping the waterways healthy and alive, to act in the legacy of Save the Bay.
From: Carol Steinfeld
To: Commission
Subject: Comment for Alternative Water Supply Planning Quarterly Report Date: Tuesday, March 8, 2022 2:46:40 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
[The moderator heard my call as muted; I am not sure why.] This is Carol Steinfeld, co-chair of the water committee of the Sierra Club's Loma Prieta chapter. Our chapter covers most of the wholesale buyer area.
We very much support reuse, but this challenge of creating supply security requires analysis of usage before looking at expensive big water-reuse solutions.
When you start there, we think you'll see the uninterruptible-supply wholesale customers are the most targetable to reduce demand (and perhaps address leaks).
Given the state's charge to SFPUC to provide water—any water—it is absolutely in SFPUC's financial interest to offer consulting on demand management and small-flows reuse to San Mateo County wholesale buyers. (However, I would not say that San Francisco leads the country in small-scale reuse.)
SFPUC could drop its litigation against the state and use the savings to offer resources to the wholesale buyers. This is about truly managing the supply.
Reuse has challenges. The city of San Mateo's potential contribution to Crystal Springs is too salty now and would require pumping water up a very steep hill at great power costs.
That is
just an example of the many, many factors.
Please form ways to work with the wholesaler buyers. That is not against your public charge.
This should be a program mandate to staff.
Thank you.
Carol Steinfeld
From: Kent Iverson
To: Commission
Subject: Tell San Francisco to do its part to save salmon and heal the environment Date: Wednesday, March 9, 2022 6:44:43 AM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear San Francisco Water,
Dear President Maxwell,
I am writing to urge the SFPUC to embrace science-based environmental protections for the Tuolumne, the San Francisco Bay-Delta, and our declining salmon runs. This is urgent because the SFPUC staff is fighting efforts to heal the river and the Bay and Delta it flows into. Because of the SFPUC’s lack of leadership, salmon have fared more poorly on the Tuolumne River than on any other river in the Bay-Delta watershed. This is causing great damage to Bay-Delta ecosystem and San Francisco’s salmon fishing industry. The SFPUC’s position must change to reflect San Franciscans’ strong commitment to protecting the environment.
I oppose the two lawsuits brought by the City seeking to block protections by the State Water Resources Control Board for the Tuolumne and the Bay-Delta. (NOTE – I DO NOT BELIEVE THE FIRST LAWSUIT CHALLENGED THEIR AUTHORITY. IT JUST CHALLENGED THE FLOW OBJECTIVES.)
The SFPUC is also refusing to accept the scientific evidence presented to them by a peer review commissioned by the National Marine Fisheries Service. This peer review found that the SFPUC’s opposition to improving river flows is not supported by science. Yet the SFPUC is still promoting your baseless proposal, including power washing the gravel in the Tuolumne’s salmon spawning beds.
San Francisco is a great city and the SFPUC should be leading the way in supporting strong protections for the Tuolumne River and the Bay. The SFPUC should also be leading the state by investing in water recycling and stormwater capture, which can help climate-proof our water supplies. Instead, the SFPUC is lagging far behind communities like Los Angeles, Orange County, and San Diego. The SFPUC should work with local groups that care about the environment instead of teaming up with anti-environmental San Joaquin Valley agribusinesses that insist on siphoning over 90 percent of the river.
I urge the SFPUC to listen to the science and drop your baseless and damaging proposal for the Tuolumne River. The best solution is to support environmentally responsible, science- based protections adopted by the State Water Resources Control Board.
Sincerely,
Kent Iverson
Sonoma, CA 95476
From: Judy Schriebman
To: Commission
Subject: Request for Changes in Design Drought
Date: Wednesday, March 9, 2022 1:08:28 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear SFPUC Commissioners:
I have had several wonderful camping trips to Yosemite and one awesome hiking day in Hetch Hetchy. I believe this incredible valley should be and can be restored while still having enough water for SF urbanites. I am very encouraged by the usage of recycled water rather than aquifer/potable for Golden Gate Park as one step in a resilient OneWater approach to future drought scenarios. Ditto the onsite recycling of water at the SFPUC building in SF, showing the way forward for better urban water cycle usage. These and other steps being undertaken by the city would mean the Bay Delta Plan would not cause the SFPUC to run out of water.
I do care passionately about our natural world. I am on the Marin Group Executive Committee of the Sierra Club, the Watershed Alliance of Marin, the Gallinas Watershed Council and am elected to the Las Gallinas Valley Sanitary District. This groups are all based on environmental health protection and WATER: healthy, clean and safe for wildlife and the public. Salmon and restored wild rivers are essential for us for many reasons, which is why I care so much about the work you are doing in order to create a more resilient water supply for the city.
I encourage you to expedite your work on the Design Drought changes to make it more reality based. And I am hopeful that Hetch Hetchy may someday look like it was before it was dammed. And that the river through it can run again, wild and free and supporting a more diverse population of wildlife, plants, and visitors.
Judy
From: [email protected] on behalf of Fleur via San Francisco Baykeeper To: Commission
Subject: San Francisco can avoid a water crisis. Why isn’t SFPUC on board? Date: Wednesday, March 9, 2022 10:44:14 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear Mayor Breed,
I urge you to withdraw the City’s litigation against the State Water Resources Control Board and direct SFPUC to start investing aggressively in water recycling today.
I am writing to you in the early days of yet another punishing drought. While San Franciscans are doing their part to save water at the household level, SFPUC is mismanaging San Francisco’s main water source, the Tuolumne River, and it isn’t doing nearly enough to prepare for drought this year—or in the decades to come.
Other cities have learned the lessons of California’s unpredictable climate and are quickly adopting water recycling to reduce their burden on rivers, while increasing the reliability of their supply. Orange County gets more than 75 percent of its water through its water reuse program. Las Vegas recycles nearly all of its water used indoors. And Los Angeles is on the path to reusing 100 percent of its wastewater by 2035.
But, as SFPUC’s draft Urban Water Management Plan recently revealed, San Francisco currently has no plans to make recycled water widely available in the next 25 years. Instead, the city is pursuing multiple expensive and misguided lawsuits so that it can continue to rely, almost exclusively, on the Tuolumne River—one of the state’s most overtapped rivers—for the next several decades. San Francisco and large agribusiness water districts divert four out of every five gallons of water that flow in the Tuolumne River during a typical year.
This overuse has caused the river’s once mighty Chinook Salmon populations to crash. Meanwhile, low river flows from the Tuolumne contribute to deteriorating water quality—including toxic algae blooms— downstream, in the Delta and San Francisco Bay.
It’s unacceptable for the city with the nation’s greenest reputation to shirk its responsibilities to preserve California’s precious and unpredictable water supply. We support increasing river flows to uphold San Francisco Bay’s fisheries, water quality, and recreation. San Franciscans want the city to do its part to protect the Bay and its rivers—water recycling is a common-sense way to limit the city’s water use, increase the reliability of its supply, and protect the Bay from harmful wastewater treatment plant effluent.
Thank you,
Fleur Uptegraft
Redwood City, CA
From: Dave Warner
To: Hood, Donna
Cc: Ritchie, Steve
Subject: Fish passage letter
Date: Thursday, March 10, 2022 4:18:27 PM
Attachments: Fish passage chart - Dave Warner letter to commissioners 2022-03-10.pdf CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Hi Donna,
Thank you for taking time with all our correspondence. Would you forward the attached letter to Mr. Herrera, President Moran and the commissioners? I have copied Steve Ritchie here.
Best regards,
Dave
March 10, 2022
General Manager Dennis Herrera, President Anson Moran and Commissioners San Francisco Public Utilities Commission
525 Golden Gate Avenue
San Francisco, CA 94102
Via email
Re: CDFW Fish Passage Chart
Dear General Manager Herrera, President Moran and Commissioners, Thank you for listening to my public comment regarding fish passage at your March 8th meeting. Thank you also
for the discussion you all had regarding addressing public comments—your discussion was good to hear. In that context I am not requesting a response to this letter.
Here is the fish passage chart I referenced:
From: Lori Tyler
To: Commission
Subject: Resolution 210577: Support
Date: Thursday, March 10, 2022 4:31:41 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear San Francisco Water,
Dear Supervisors:
I’m writing to urge you to pass Resolution 210577, introduced by Supervisor Peskin, which calls on the San Francisco Public Utilities Commission to pause litigation against the State Water Resources Control Board.
This resolution is needed because the SFPUC staff and the City Attorney, without informing the Board of Supervisors, or even seeking the approval of the SFPUC Commissioners, challenged state-required protections for the Tuolumne River, San Francisco’s drinking water source. The lawsuit relies on a highly flawed interpretation of the Clean Water Act forced on the nation by the Trump administration.
The SFPUC and City Attorney Dennis Herrera claim that allowing the state to protect the Tuolumne River would threaten the City’s drinking water supplies. Together, San Francisco and the two big agricultural water districts on the Tuolumne River divert more than 90 percent of the river’s water in some years. That unsustainable water pumping has had a devastating effect on the river and its salmon runs which the state rightly says needs addressing. San Francisco should be supporting stronger protections for the Tuolumne River and salmon – not fighting them.
San Francisco has a vast network of large reservoirs that store enough water to weather years of drought. In fact, we use less water today than a decade ago and are likely to use even less in future, thanks to technology and population trends. San Francisco could use even less of the Tuolumne River’s water if it followed the example of communities like Los Angeles and Orange County, which are far ahead in water recycling and reuse technologies.
The City’s lawsuit stands in stark contrast to actions taken by former State Attorney General Xavier Becerra who sued the Trump administration over its attempts to weaken the Clean Water Act. The Attorney General’s actions were based on the belief that California should have the ability to keep its rivers and lakes clean and healthy. The SFPUC and City Attorney Dennis Herrera disagree and argues that Trump was right when it comes to stripping protections for the environment.
No doubt the SFPUC and City Attorney’s office will present you with arguments about how the sky will fall if the City is forced to withdraw its anti-environmental lawsuit. Some of the biggest air polluters in the state would have presented similar arguments when AG Becerra fought off Trump administration efforts to weaken California’s air pollution laws. Fortunately, Becerra won that fight. If he were still here, he’d probably win this fight too.
Sincerely,
Lori Tyler
Fremont, CA 94536
From: Cindy Charles
To: Commission
Subject: Request to expedite decision on the Design Drought Plan Date: Friday, March 11, 2022 9:20:58 AM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
To the Commissioners,
I am Cindy Charles, a native San Franciscan and someone who has fly fished the Tuolumne River for decades top to bottom. I have seen the dramatic decline of the fishery on the lower Tuolumne to the point where I don’t fish there anymore. Not only is it not worth fishing, but the few remaining trout are too valuable to be impacted by even catch and release angling.
I participated in numerous SFPUC workshops focusing on the Tuolumne River. These workshops were a great opportunity to collaborate with stakeholders and to communicate and share information to work towards some meaningful solutions.
An important goal of the workshops was to take a look at your projected Design Drought Plan. The Design Drought combined the worst two droughts from the last century (1987-1992 and 1976/77) to create a manufactured and unprecedented eight-year mega-drought.
This Plan is unrealistic and is
in need of serious reassessment based on actual demand and realistic demand projections.
I am asking you to please modify and expedite a decision on the Design Drought Plan. The Tuolumne River is continuing to suffer and is facing total ecological collapse. With only 576 salmon returning last fall/winter and 1 lonesome steelhead returning, this is a heartbreaking situation. The native fish are about to disappear on the Tuolumne River having been impacted by the long entrenched SFPUC water policies that are outdated.
You cannot delay decisions on keeping more water in the Tuolumne for the fish and the environment.
Your actions can make a huge impact.
SFPUC needs to have a realistic and responsible water policy in place for the lower Tuolumne.
Thank you,
Cindy Charles
Board Member, Tuolumne River Trust
Board Member, California Sportfishing Protection Alliance Conservation Chairperson, Golden West Women Flyfishers
Policy Advisor, Trout Unlimited, Golden Gate Chapter
San Francisco, CA 94107
From: Ritchie, Steve
To: Hood, Donna
Cc: Herrera, Dennis J
Subject: Governors" press release for sharing with the Commission re State Drought Emergency Date: Monday, March 14, 2022 1:30:53 PM
Attachments: Newsom Press-release-3.14.2022.pdf
Newsom Administration Boosts State Funding for Drought Emergency | California Governor
Also, copy attached.
Steve.
Steven R. Ritchie
Assistant General Manager, Water
San Francisco Public Utilities Commission
Phone: (415) 934-5736
E-mail: [email protected]
www.sfwater.org
Please conserve water today!
The funds requested are part of a comprehensive effort by the Newsom Administration to increase water conservation. Earlier this month, the state launched new video ads to encourage Californians to reduce outdoor watering.
On March 1, the survey of the state’s snowpack showed levels were dropping sharply after robust storms in December. Current snowpack readings are about one-third below average. The Department of Water Resources is analyzing the latest snowpack data and has indicated it may revise its current forecast for State Water Project deliveries in 2022.
With the infusion of additional state budget funds, the Save Our Water campaign is gearing up to reach Californians with water-saving tips via social media and other digital advertising, geo-targeting counties with high water use.
The campaign also is securing partnerships with retailers and other organizations to urge Californians to reduce water use in the immediate term and also make permanent changes to landscaping to build resilience in the long-term.
###
OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.
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San Francisco, CA 94102
T 415.554.3155
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San Francisco Public Utilities Commission
Earned Media Clips
February 26, 2022 – March 4, 2022
This is a weekly roundup of local, regional and national media stories either focused on the SFPUC or the result of proactive and reactive efforts by the Communications Division
Date Outlet Story
2/27/22 SF Chronicle Satellite images show just how quickly Sierra’s snowpack is retreating
(sfchronicle.com)
3/2/22 Civil Eats A New California Law Will Create a Lot More Compost—but Will it Make it to
Farmland? | Civil Eats
3/3/22 NBC Bay Area SF Granted Nearly $11M to Credit
Customers on Utility Bills – NBC Bay
Area
3/3/22 SF Gate City Granted Nearly $11 Million To Credit Customers for Utility Bills (sfgate.com)
3/3/22 CBS San Francisco Secures Almost $11
Million To Help Residents With Utility Bills
– CBS San Francisco (cbslocal.com)
3/3/22 Patch Apply Now For Discounts on Water Bill +
Hetch Hetchy Power Bill | San Francisco,
CA Patch