CleanPowerSF Sfpuc Commission
February 28, 2023

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.

525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
T 415.554.3155
F 415.554.3161
TTY 415.554.3488

San Francisco Public Utilities Commission
Correspondence Log
February 9, 2023 through February 21, 2023

Date Received From Subject
February 9, 2023 Brian Browne Tuolumne River Flows
February 13, 2023 Dave Warner More Robust Alternative Water Supply Data Needed
Steve Ritchie SFPUC Response to BAWSCA’s
2/7/23 Comments on SFPUC’s
Proposed 10-Year Capital Plan for
FY2023-33, and Proposed FY 2023-
24 Capital Budget
February 14, 2023 Eileen Boken California's snowpack is melting faster than ever before, leaving less
available water
February 15, 2023 Eileen Boken Can San Francisco save the bay? February 21, 2023 Nicole Sandkulla Statement on Tuolumne River Voluntary Agreement Schedule

February 9, 2023
Brian Browne re: Tuolumne River Flows
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February 13, 2023

Re: More Robust Alternative Water Supply Data Needed

Dear Commissioners, General Manager Herrera and Assistant General Manager Ritchie, The January 30
th budget meeting highlighted the need for more robust alternative water supply planning data. Comments by staff included: Challenging capital budget; large amount of outstanding debt, 90% increase in rates over the next 10 years, and debt service will become 50% of our budget with the proposed capital plan. And the proposed capital plan includes no significant investment in alternative water supplies. In such context it is important to have more robust information regarding alternative water supplies (AWS). Here are examples of data that would inform AWS planning.

Please note that many assumptions and guesses were made in developing the data in this letter and it should not be relied upon. Instead, the SFPUC should develop its own analyses for these items.

AWS Capital Costs $4.7 - $6.1 billion with double the interest rate The December 2022 AWS quarterly report does not estimate possible AWS capital outlays although it specifies unmet obligations of 122 mgd and unmet demands of 94 mgd. Looking at the capital costs for both the soon to be completed San Francisco Westside Enhanced Water Recycling Project and the soon to break ground San Diego Pure Water Phase 1, the capital cost per mgd of AWS can range from $50 million to $108 million. Using the lower figure, $50 million of capital required per mgd, this translates to $4.7 billion in capital needed to produce 94 mgd of AWS and $6.1 billion to produce 122 mgd of AWS.

These are staggering figures when considering that the SFPUC is already looking at a possible $15.7 billion of debt before considering AWS.1

AWS Cost per Acre Foot Could Range from $3,100 to $6,000 Using capital costs as described above, a 5% interest rate mentioned in the January 30 th budget meeting and $550/acre foot operations and maintenance costs, the cost per acre foot of AWS could be 22% higher to as much as 138% higher than the currently projected water cost for 2032. Against today’s cost per acre foot, AWS costs could be 50% to 190% higher.

1 As of the January 30 th budget meeting the SFPUC had $9.4 billion in debt and the 10 year capital plan, without AWS investments, contemplated an additional $6.3 billion in debt, for a total of $15.7 billion.

Extrapolated AWS Project Costs
Project Cost Output
Project Cost
per MGD
Extrapolated
to 94 MGD
Extrapolated
to 122 MGD
(millions) (MGD) (millions) (billions) (billions)
San Francisco Westside Enhanced
Water Recycling Project
216 $ 2 108.0 $ 10.2 $ 13.2 $ San Diego Pure Water Phase 1 1,500 $ 30 50.0 $ 4.7 $ 6.1 $

Rates are more frightening if we invest and the water isn’t needed If we were to invest in AWS per the listed unmet demands of 94 mgd, our cost of water would increase to $2,725 per acre foot, up 32% from today’s rate. But the worst case would be to invest in AWS to the amount of listed unmet demands but the additional demand never materializes. Then our cost of water would increase 95% to over $4,000 per acre foot. The table below summarizes these points along with showing the impact of a scenario where only 20 mgd of AWS are added 2.

It is doubtful that we’d invest in 94 mgd of additional water supplies. But the point is that decision makers need more robust information in terms of both cost and demand than what is provided in the quarterly AWS reports. With better information the decision makers can start to formulate a strategy to address uncertain demand and manage costs.

Water Rates Already Amongst the Highest in California
When considering AWS and costs, it is important to know how SFPUC water rates compare to other urban agencies. A previous letter provided a chart showing that the SFPUC’s wholesale water rates were amongst the highest, if not the highest of any major water district in California (the comparison was not exhaustive). San Francisco’s retail water rates are also high. Comparing to Los Angeles, San Francisco’s water rates are 44% higher. We also know SFPUC’s water rates will continue to increase another 23% in the next 10 years. As you know, wastewater rates are increasing even more.

2 2032 baseline demand based upon department of Finance projections for 2032: 131.1 Wholesale demand, 58.6 retail demand and plus 6 mgd losses. AWS investments as shown in table Projected AWS Cost Per Acre Foot
Capital cost per MGD
(millions)
Percent
financed
Interest
rate
Amortization/
Loan Period
(years)
Amortized
Capital
cost/AF
Ops and
maint.
cost/AF
Total cost
/AF
Percent
increase
from 2032
cost
$108.0 75% 5% 30 $5,508 $550 $6,058 138%
$50.0 75% 5% 30 $2,550 $550 $3,100 22%
$ 2,545 Reference: Projected 2032 baseline cost/AF (before AWS investments):

Blending AWS Costs into Overall Rates

AWS Added
(MGD)
Cost/AF in
2032
(no AWS)
2032 Finance
Dept Demand
(MGD) 2
Cost/AF from
AWS
Blended cost
per AF
Percent
Increase from
cost today
Blended cost
per AF
Percent
Increase from
cost today
94 2,545 $ 196 3,100 $ 2,725 $ 32% 4,032 $ 95% 122 2,545 $ 196 3,100 $ 2,758 $ 33% 4,475 $ 116% 20 2,545 $ 196 3,100 $ 2,596 $ 25% 2,861 $ 38% Reference: Cost per acre foot today: 2,069 $
AWS FULLY Used (Demand
increases by amount of AWS)
AWS NOT Used (Demand
doesn't increase)

2023 Retail Water Rate Comparison
Service charge 3 2nd tier ccf rate 4 Total
Los Angeles $0 $8.99 $8.99
San Francisco $2.17 $10.76 $12.93 44% Higher

Breaking down 122 mgd of Obligations and 94 mgd of Demands While the December 2022 AWS Quarterly Report called out unmet obligations of 122 mgd and unmet demands of 94 mgd, it has been difficult to determine their makeup. The chart on the next page provides some clarity as to how these figures were calculated. The left two columns compare supplies to obligations while the right two columns compare supplies to projected 2045 demand. Note that the SFPUC uses the term, “Firm Yield” to reflect the combination of water system supplies/deliveries and the water saved from rationing.

Having the information presented in this way helps the reader better understand the figures against known benchmarks. For example, the 265 mgd of demand in column 2 is a well-known figure for obligated supplies at the time the Water System Improvement Program (WSIP) was approved. The 237 mgd of demand in column 4 is a less known figure
5, which in itself should be footnoted (as was done
here). Otherwise the reader doesn’t know exactly which data was incorporated. It is also valuable to see demand from the “interruptible customers”, San Jose and Santa Clara, broken out separately as whether or not to supply them is likely germane to AWS decisions. The 12mgd highlighted in red I am still working to understand its makeup 6.

3 San Francisco’s service charge is $15.17 per month. Assuming the average household uses 7 ccf of water per month, this translates to an average service charge of $2.17 per ccf. Los Angeles has no such charge. 4 San Francisco has two rate tiers, a lower rate for the first 3 ccf and then $10.76 for each ccf above that. Los Angeles has 4 tiers, tier 1 for the first 16 ccf and then varying amounts for tier 2, but at least 6 ccf on top of tier 1.

It seems like the fairest comparison is to use Los Angeles tier 2 rate of $8.99 per ccf. 5 Per email exchanges the 237 mgd incorporates the BAWSCA demand projections from its 2020-21 annual survey and is higher than what was projected in the 2020 Urban Water Management Plan (UWMP). 6 See email from Matt Moses to Peter Drekmeier dated October 26, 2022, which appears to state that the rationing policy impact, which was 30 mgd at 265 mgd demand, changes to 18 mgd because of reduced supply due to the Bay Delta Plan impact. However for the analysis demand remains at 265 mgd. It is a challenge to understand how the rationing policy impact is determined from supply rather than demand.

Other Demand Scenarios
Other demand scenarios that should be included in the Water Supply Needs section of the AWS are:
1) The SFPUC’s department of finance demand projections, which historically have been much closer to actual demand than other SFPUC projections (albeit still above). This would show demands could be 196 mgd rather than 237+9 mgd inclusive of Santa Clara’s and San Jose’s RWS demand, reflecting a potential reduction of 50 mgd from the 94 mgd demand shortfall.7 Needing 50 mgd less of AWS would save ~$2.5 billion of capital costs (assuming the lower $50 million per mgd capital cost rate).
2) The sensitivity analysis from BAWSCA’s recent demand study should be considered, suggesting that there are scenarios where their demand could be as little as 80% of current projections. This would reflect a potential reduction of 33 mgd from the 94 mgd demand shortfall.8 Needing 33 mgd less of AWS would save $1.65 billion in capital costs.

The chart on the next page depicts the potential savings from these two scenarios.

7 At this lower level of demand the impact of the rationing policy would reduce the savings by 9 mgd, which has not been reflected in the figures.
8 At this lower level of demand the impact of the rationing policy would reduce the savings by 6 mgd, which has not been reflected in the figures.
227 227
30 30
265
237
9 9
93 93
12 12
122
94 -
50 100
150
200
250
300
350
400
Firm Yield Obligations Firm Yield w/Lower Demand Demands MGD
Firm Yield Compared to Obligations and 2045 Demand
Based on December 2022 Quarterly AWS Report
System firm yield (Design Drought) Rationing policy Demand SJ & Santa Clara historical Bay Delta Plan Unclear amount Shortfall
Shortfall:

Obligations
to Firm Yield
Shortfall:

Demands
to Firm Yield
Obligations Shortfall Comparison
Demands Shortfall Comparison

Other Opportunities
Design drought, the billion dollar question: Using the SFPUC’s own Long Term Vulnerability Assessment (LTVA), the NGO’s have been making the case that the likelihood of the design drought is too rare and that it should be shortened. There was data in the LTVA showing that the design drought was potentially a once in a 70,000 year event. The NGO’s argue that by removing a year from the design drought model, the likelihood of a drought as severe as 7.5 years of a design drought is still very rare, once in 10,000 years.

The SFPUC’s Water Supply worksheet indicates that there is a savings of 23 mgd by reducing the design drought from 8.5 years to 7.5 years.
9 Applying an opportunity cost to 23 mgd comes to $1.15 billion of capital costs.

At the August 23rd, 2022 workshop then Commission President Anson Moran said that the LTVA wasn’t designed to answer the question of the adequacy or excessiveness of the design drought model. Given

9 The water supply worksheet shows that removing a year from the design drought increases supply by 31 mgd but because the year removed had small Bay Delta Plan flows, the average annual impact of Bay Delta Plan flows increases from 93 mgd to 101 mgd.
237
213
196
33 50
9 -
50 100
150
200
250
300
Assumed demand for 94 mgd
supply needs
Demand using low end of
BAWSCA's sensitivity analysis
Demand using finance depatment
projections
MGD
Other Demand Scenarios
Benefit of
lowerdemand

the question has a potential $1.15 billion dollar impact, it seems well worth investing the resources to answer this question.

The wonderful part about this item is that it’s a “stroke of the pen” issue. If the answer to the question is favorable, we’ve just saved a large amount of investment to the benefit of all.

Earlier Runoff: The NGO’s have suggested that due to climate change and the SFPUC’s unique water rights, the SFPUC will see increased entitlements as temperatures increase. According to the LTVA a 2°C increase in temperature will cause runoff to shift 10 days earlier. A 4°C increase in temperature will cause a 20 day shift.10 We found that during the design drought a shift in flows two weeks earlier had average favorable annual impact of 17 mgd. A three week shift in flows had an average favorable impact of 29 mgd. When asked about this, LTVA researchers said that on average they did not see a change in flows due to temperature increases. However NGO’s found that during dry years there was a favorable impact to water supply and during wet years there was a negative impact (and of course during wet years there’s not a concern about a negative impact as flows are very high).

A 17 mgd favorable impact to water rights is potentially worth $0.85 billion in reduced capital costs. It seems like it is worth investigating the impact of temperature change and flow shift on SFPUC’s water rights during dry years (perhaps the driest quintile).

Interruptible Customers: Santa Clara and San Jose are labeled interruptible customers and have historically used 9 mgd of water. When supply exceeds demand, Santa Clara and San Jose buying RWS water benefits all in the form of lower water costs. But if demand exceeds supply and the cost of additional supply is greater than projected prices, then adding supply to accommodate them becomes a burden to all other customers. The SFPUC, BAWSCA, San Jose and Santa Clara should all understand their options when faced with developing expensive water supplies. If saving 9 mgd of supply from Santa Clara and San Jose would reduce AWS needs by the same amount, capital cost savings would amount to $0.45 billion.

If the above three actions were taken, the water supply shortfall would be reduced by 49 mgd and the capital savings would be $2.45 billion of funds not spent. It seems well worth the investment to better understand these scenarios.

10 LTVA page 147, bullet starting at the bottom of the page. It should also be noted that with temperature increases drought frequency decreases. When asked, researchers did not have an answer for why this was the case (see table 5-2 on page 159).

Scenario
Water
savings
(MGD)
Capital Cost
Savings
(billions)

7.5 year design drought 23 1.15 $ Worth funding a study Earlier runoff 17 0.85 $ Worth funding a study Savings from Interruptible customers 9 0.45 $ Worth considering Total 49 2.45 $

Impact of Rationing Scenarios: The rationing scenario for the water supply shortfall calculations assumed 2 years, no rationing, 3 years 10% rationing and 3.5 years 20% rationing. This rationing scenario is conservative for the water supply needs presented in the last AWS quarterly report. Not only should the report be explicit on the rationing scenario used, but also other rationing scenarios should be explored, having the potential to reduce water supply needs by several mgd.

Summary
It is this kind of information that all parties should have available when considering alternative water supplies:
1) What are the potential capital costs of AWS at the level of needs contemplated? 2) What are the potential per acre foot costs of AWS?
3) What are the blended per acre foot costs incorporating AWS and assuming demand grows to match added AWS supplies?
4) What are blended per acre foot costs incorporating AWS but demand doesn’t grow, reflecting the downside/risk of investing in excess AWS?
5) How were the unmet obligations of 122 mgd and unmet needs of 94 mgd determined, including a breakdown of which demand projections were used?
6) What are the other relevant demand projections when considering AWS and how do they impact unmet needs?
7) How do our water rates compare to other agencies?
8) What other opportunities could mitigate water supply needs, such as shortening the design drought, earlier runoff, or not supplying interruptible customers and what is the financial impact of each?
While a decision of developing alternative water supplies may not occur this year, providing such information now in the quarterly alternative water supply reports will have everyone better prepared.

Please do not rely upon the data presented here but instead ask staff to provide its own analysis for these areas.

It seems financially worthwhile and timely to commission a study now to understand the adequacy or excessiveness of the design drought model. It also seems worthwhile to study the impact of earlier runoff in dry years due to climate change.

Kind regards,

Dave Warner

cc: BAWSCA Board of Directors
Nicole Sandkulla, BAWSCA CEO

Services of the San Francisco Public Utilities Commission

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.

525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
T 415.554.3155
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TTY 415.554.3488

February 13, 2023

Nicole Sandkulla
Chief Executive Officer/General Manager
Bay Area Water Supply and Conservation Agency
155 Bovet Road, Suite 650
San Mateo, CA 94402

Dear Nicole,

Thank you for your February 7th letter regarding BAWSCA’s comments on the SFPUC’s proposed 10-Year Capital Plan for FY 2024-33, and Proposed FY 2023-24 Capital Budget. We appreciate the focused engagement of BAWSCA in our capital planning process and we welcome the opportunity to respond to questions and comments. Please see our responses below.

Specific Comments:

The SFPUC must work to minimize unappropriation of funds – As with the prior 10-Year Capital Plan (FY 2023-2032), the approach to funding the first two years of the Capital Plan is to use the already appropriated funds to maintain progress and minimize new appropriation requests in those fiscal years. The need for this approach at this time has been explained to BAWSCA. However, this method should not be standard practice in the future as appropriating funds well over what can be reasonably expended gives a false sense of expected productivity and erodes confidence in the SFPUC’s capability to successfully implement its planned capital program.

SFPUC Response: We agree, and this has been a core focus of our capital planning approach this year, to plan to spend down existing appropriations before requesting new funding as well as align capital requests with deliverability to reduce future underspending.

The funding approach for select key Capital Plan projects could constrain future work – While BAWSCA mentioned this in our letter of January 27, 2023, it is important reemphasize that placeholder funding amounts for certain projects including Pilarcitos Dam, San Andreas Dam, and BDPL No. 4 PCCP Repair are likely significantly lower than what is actually needed. Additionally, SFPUC has reduced funding for some projects, such as O’Shaughnessy Dam Outlet Works and Early Intake Dam Long-Term Improvements, “to meet Capital Plan financial targets”. At the same time, the scope for these projects was not reduced, thus creating a further future funding shortfall. The SFPUC has stated that it is waiting until more facility assessments are completed before reflecting additional funding needs in the Capital Plan or until the financial outlook allows for more capital project funding. This approach may pose a constraint to doing future work in the expected timeframes as future Capital

Plans with greatly increased budgets for certain projects may require phasing work on other projects to balance cash flow needs.

SFPUC Response: Each budget cycle we prioritize projects over the next 10 to 20 years based on system needs and best available project information for scope, schedule and cost. Initial project probable cost and schedule information is high level and not accurate until planning work is completed to better determine scope, criticality, cost, and schedule. It is prudent to include some probable cost as a placeholder in the CIP; however, we do not agree that there is a risk of creating a funding shortfall since funding is limited, requiring consistent prioritization of projects each budget cycle to regularly adjust the CIP to assure we are addressing the highest system priorities within a limited budget. As projects proceed through planning; costs, project criticality, and asset risk and consequence of failure become better clarified. Thus project planning may result in raising or lowering the cost and priority of a project or potentially identifying lower cost solutions than originally envisioned.

We acknowledge that the long-term asset management needs for the water system may exceed the current 10-year CIP budgets that are limited by both deliverability and affordability. We are committed to continually improving our asset management and CIP delivery programs to build capacity to address future system needs as they arise. We also will continue to seek cost-effective solutions and sources of outside funding such as low-interest loans to optimize investments while properly managing assets.

SFPUC has enhanced the information provided on project data sheets – BAWSCA is appreciative of the added information that is provided on project data sheets provided as part of this midcycle change including: new summary information details a project’s prior approved budget, prior approved start, and prior approved finish; status indicators for budget changes, schedule changes, and scope changes relative to currently adopted Capital Plan; and narratives on “Reason for Changes”.

SFPUC Response: We appreciate the positive feedback and are committed to continuing to improve the quality of the project data sheets in the future.

Budgetary constraints in several large, in-progress projects were noted as the reason for budget reductions – The SFPUC continues to describe the proposed 10-Yr Capital Plan as robust. However, the Capital Plans for both the Water Enterprise (Regional) and Hetchy Enterprise (Water Infrastructure, Joint Infrastructure) are balanced but not robust in terms of being able to deliver the scope within the requested budget. Budgetary constraints for several large, in-progress projects were noted as the reason for budget reductions from the prior Capital Plan. With no corresponding reduction in scope, there is a high likelihood of needing additional budget to complete the planned work.

SFPUC Response: We disagree that the capital plan is not robust. Water and Hetchy Water have a combined capital plan total of $3.24 Billion, which represents a massive investment in the local and regional economy and the state of our Water system infrastructure. The plan has been developed

through a diligent prioritization process which has allowed us to maximize use of funds according to priorities.

Project data sheets developed for future Capital Plans could be improved by providing cash flow data – Each project data sheet should include a table showing anticipated cash flow for each year similar to the current table which shows budget appropriation. In this cash flow table, there should be a column for “prior years’ cash flow” ahead of the first year in the proposed 10-yr Capital Plan. This cash flow table would show timing and magnitude of project activity much more clearly than can be inferred from the appropriations and budget information that the data sheets currently present.

SFPUC Response: The proposed budget appropriations in the project data sheets reflect forecasted spending on each project and are generally paced with the anticipated spending needs of the project, including contract encumbrances. Actual project spending is reported in the CIP Quarterly Reports for the major projects and can be compared to the budget appropriations to assess project performance.

The deliverability of the Capital Plan is directly tied to the mitigation of key bottleneck issues, highlighting why those issues must be addressed – While BAWSCA made a similar comment in our letter of January 27, 2023, it warrants repeating. Covid-19 had significant impacts to project schedules in recent years, yet the underlying issues of very lengthy recruitment and contracting processes continue and are cited in several locations in the proposed Capital Plan as reasons for project delays. This issue is one that cannot be ignored by the Commission nor by the City and its elected leaders.

For example, as part of the WE Capital Plan, projects noting delay in project start date “due to lack of available resources from PUC Infrastructure Division” include the SVCF Chemical Storage Improvements ($1,687,500) and the SABPL Valve Redesign ($1,012,500). Also, the Calaveras Dam HOS ($2,071,242) project has extended its schedule by a year “due to resource challenges to continue planning and design”. These projects represent $4,771,242 of capital work explicitly impacted by staffing issues.

SFPUC Response: We agree that deliverability is a significant issue we need to work on, and we are working on it in earnest. Deliverability and capital planning process work is a long-term project that we know we cannot solve in one budget cycle. We have brought together a cross agency team to work on the “Capital Planning and Delivery Project”.

The long-term goals of this project are to:
 Build a unified approach for capital project planning, prioritization and decision making across SFPUC
 Improve our ability to assess deliverability for project planning and budgeting
 Develop solutions to key deliverability issues to increase our capacity to execute on projects
These objectives seek to improve, modernize, and unify the SFPUC’s Capital Planning approach - one of the most fundamental strategic activities of the SFPUC and its biggest cost driver. Given the broad scope, this program will likely span at least five years to include at least two full budget development

cycles which occur every other year. Also, given the existing workload of SFPUC staff, it will be important to identify what can be accomplished in time and in support of the next two-year budget cycle for FYs 24 and 25; and what can be accomplished in subsequent years.

It is important to mention however, that given the many internal and external factors that impact project execution, building the tools and capacity to measure deliverability consistently and effectively – and embed improved practices within our agency long-term – will require a dedicated, continuous, cross-functional effort. Long term, it will be important to balance deliverability reviews with an analysis of spending patterns and use both inputs to refine the CIP, while ensuring we invest in the capital improvement needs of our facilities.

The Capital Planning and Delivery project team anticipates providing an update to the Commission on progress later this year.

Questions and Requests: Water Enterprise (Regional) 10-Year Capital Plan

1. SVWTP Short Term Improvements – The “Reason for Change” in the budget and schedule narrative states that “the construction estimate for the Long-Term Improvements is $17.5M”. However, the data sheet provided for the SVWTP Long Term Improvements states “the construction estimate for the Long-Term Improvements is $22.1M”. Which is correct? SFPUC Response: The correct construction estimate is $22.1M. The correction will be made to the Short-Term Improvements Data Sheet.

2. Sunol Valley Chloramination Facility – The budget for this project is now shown as $10,586,387. That revised budget now is over the $5M threshold for a small capital projects and therefore, this project status should now be the other large capital projects beginning with the Q1 FY23-24 WE Capital Plan report. BAWSCA is not clear if this budget will cover all work in the project description or just the new carrier water system which is to be performed as the first phase. Please clarify.

SFPUC Response: After the increased budget for the Sunol Valley Chloramination Facility project is approved, the project will be reported in the Water Enterprise Capital Improvement Program Quarterly Reports beginning with the first quarter of FY23-24 as BAWSCA suggests. The proposed budget is forecasted to be sufficient to include all work as described in the project description.

3. SVWTP Long Term Improvements – No funding is being requested within the 10-year Capital Plan duration. The needed $28,457,154 is scheduled for after FY32-33. This essentially places the construction phase on hold, yet the RFP is ready to be issued. The “Reason for Change” narrative should be revised, making clear that the construction phase is ostensibly deferred for 10 or more years. In addition, the proposed project finish date, shown as 8/10/2029, is now incorrect. Please address these necessary edits to the project data sheet.

SFPUC Response: Funding for the SVWTP Long Term Improvements project is proposed to be postponed to “after FY24-33” in order to meet budget targets.

There are currently three other major active projects planned at the SVWTP in the next few years and delaying this project may be prudent to better

coordinate construction after the three projects are completed. The project currently has an approved appropriation of $1,130,000 of which less than $100,000 has been expended. The appropriated funding will be used to continue planning work to better refine the work scope, cost, and schedule.

Funding for design and construction may be accelerated in future budget cycles based on the project’s priority compared to other projects in the CIP.

The “Reason for Change” narrative and project finish date will be updated in the next budget cycle when project planning has further progressed.

4. HTWTP Underdrain Replacement – Per the Capital Plan, the underdrain work is on track for completion. However, there appears to be no plan to initiate work on the other twenty reliability improvements for the HTWTP in the proposed Capital Plan. Will this present reliability issues for the plant?
SFPUC Response: The other reliability improvements such as replacing the ammonia piping and supports at the tank farm, replacing diesel fuel polishing units, and adding double containment for diesel piping are being implemented as R&R projects.

5. Regional Groundwater Treatment Improvements – The project had its schedule “extended due to budgetary reasons.” This requires the bulk of the project expenditure ($31,079,862) to occur after FY 32-33. Thus, the proposed finish of 12/31/2033 is incorrect and will not occur. What is the updated expected completion date?
SFPUC Response: Design and construction funding for the Regional Groundwater Treatment Improvements project is proposed to be postponed to “after FY24-33” in order to meet budget targets. However, about $4.2M has been appropriated to the project to date, and another almost $2M is proposed to be appropriated in the next two years, allowing project planning to continue over the next few years. When the project needs are better defined (such as after Alternatives Analysis) full funding for the project may be requested to be restored, depending on other CIP priorities. The proposed completion date of 12/31/33 will be revisited as the planning work becomes better defined.

6. Corrosion Control – It appears that appropriations end in FY28-29 with the funding of Phase 3. Will work proceed beyond Phase 3? Is corrosion control work covered in an R&R program after Phase 3? Please respond to these two questions.

SFPUC Response: Work beyond Phase 3 is being scoped and will be covered in a future corrosion R&R program.

7. Calaveras Substation Upgrades project – The project “was removed from the capital plan during budget review and will be considered for reprioritization in the future.” The justification for the project notes that it is needed if the San Antonio Pump Station Upgrade work (conversion from diesel to electric pumps) proceeds. It appears that such upgrade work is funded in the Capital Plan and will proceed. Thus, there is a real possibility that the substation upgrade will be needed at least towards to end of the 10-year Capital Plan. Conceivably some planning funds would be expected to be needed in the latter years of the Capital Plan with the bulk of the funds shown after FY32-33. Should some planning funds have been

included, and if so is there an estimate as to the funding level needed?
SFPUC Response: The Calaveras Substation is a HHWP asset and is no longer included in the Water CIP. HHWP evaluated the project during its prioritization process and concluded that the project needs additional development before it can be included in the 10-year CIP as a standalone line item. Capital funds were identified to support the initial planning phase for the project. HHWP will use up to $325k from the R&R Power Transmission Life Extension Program to complete a Needs Assessment Report for the project, which will provide the information necessary to plan this project.

8. Palo Alto Pipeline project – The project is now budgeted through project completion. It is noted that the construction begins in the latter years of the 10-Year Capital Plan and that an additional $18,000,000 will need to be budgeted in the next capital planning cycle to fully fund the project to completion. Does the SFPUC agree that this was needed to balance the 10-yr Capital Plan budget, given the level of required funding and necessary timing?
SFPUC Response: The SFPUC does not agree. The Palo Alto Pipeline project is high enough priority to propose $71,000,000 of funding in this 10- Year CIP budget. The total project cost, while stated to be $90,000,000, is a high-level cost with a high degree of uncertainty. The project cost as well as criticality will be better refined as the project planning and scope become better defined.

9. Decommissioning of BDPL 1&2 – The Newark segment has been dropped from this Capital Plan. It identified $45,000,000 of work in the prior Capital Plan cycle, but is now not planned to be initiated until after FY31-

32. What is the status of this work?
SFPUC Response: The Conceptual Engineering Report was completed in September 2020. The report provided three potential Contractor’s methods to decommissioning BDPLs 1&2 in the East Bay with a range of potential costs between $35-50M, depending on the Contractor’s selected means for removal.

The work was not urgent to be performed due to the low risk for environmental and safety concerns to leave the pipeline in place, therefore the project is being deferred.

10. Decommissioning of BDPL 1&2 – The Ravenswood segment has been dropped from this Capital Plan. It identified $72,000,000 of work in the prior Capital Plan cycle, but is now not planned to be initiated until after FY31-

32. What is the status of this work?
SFPUC Response: See response above.

11. Purified Water & Other Supplies Category – All of the projects have the same budget as in the prior Capital Plan, however, the amount of expenditure in the 10-year period is $183,650,000 less than in the prior Capital Plan. This realignment gives the appearance that the proposed CIP Capital Plan is less focused on implementation of alternative water supplies. Is it correct to assume that more work would be performed in years beyond FY32-33, or is this due to the fact that cost estimates

are not yet available and once known, futures Capital Plans would be adjusted accordingly?
SFPUC Response: There is no lessening of priority for this work. As was stated to the Commission, these projects are the subject of an Alternative Water Supply Plan to be presented to the Commission by July 1, 2023. This work is fully funded for the next 3 fiscal years, and after the Commission’s consideration of the Plan, there will be a stronger basis for recommending funding in future fiscal years.

12. Sneath Lane Gate/San Andreas – No funding is being requested within the 10-year Capital Plan duration. The needed $10,956,484 is scheduled for after FY32-33. This essentially places the construction phase on hold (yet the project is in design). The “Reason for Change” narrative should be clear that the construction phase is ostensibly deferred for 10 or more years (and making the proposed finish date of 8/2/2027 incorrect). Please correct the project data sheet accordingly.

SFPUC Response: Design and construction funding for the Sneath Lane Gate/San Andreas project to build a new connecting trail in the Peninsula watershed is proposed to be postponed to “after FY24-33” in order to meet budget targets. However, about $1.4M has been appropriated to the project to date that will facilitate planning and environmental phases to continue. One reason for deferring the trail construction is to allow the Southern Skyline Blvd.

Ridge Trail to be constructed over the next several years and then implement “lessons learned” for construction of this connector trail. The proposed finish date will be updated in the next budget cycle when planning has further progressed.

Questions and Requests – Hetch Hetchy (Water infrastructure and Joint Infrastructure) 10-Yr Capital Plan

1. SJPL Valve and Safe Entry Improvement – The project budget was reduced by $2M with no change in schedule or scope. The stated reason was “to assist with meeting overall financial targets”. With the project over 4 years from completion and concepts for the surge tower still under study, it appears to be too early to feel all project costs fall within the current estimate. Does the SFPUC anticipate including a budget adjustment for this project in the next 10-year Capital Plan cycle?

SFPUC Response: At this time, we do not anticipate a budget adjustment for this project in the next 10-year Capital Plan. The project includes four formal construction contracts, two of which have already been awarded below the engineer’s estimate. Specifically, HH-1005 was awarded for $4.6M below the engineer’s estimate and HH-1006 was awarded for $2.2M below the engineer’s estimate. A modest budget reduction of ~$2M (a 1.4% reduction) is proposed for this budget cycle.

2. R&R Water Conveyance Life Extension – The project budget has been increased, which BAWSCA believes is appropriate considering the age of many of the water conveyance assets. However, the project start date has been deferred for 3 years. Why was it not possible to allocate a minimal amount of funds to get the R&R work started?

SFPUC Response: R&R work on HHWP water conveyance assets has started and progress is ongoing. Please note that the HHWP 10-year CIP includes three (3) line items for “R&R Water Conveyance” to align with the water, power, and joint authority levels; thus establishing a CIP line item and budget for all HHWP water conveyance assets. The “Joint” and “Power” R&R Water Conveyance line items currently have budget available, and work is ongoing.

The “Water” R&R Water Conveyance line item budget starts in year 3 of the CIP and is coordinated with our asset management needs. The assets covered by the “Water” line item are not anticipated to need R&R work during years 1 & 2, therefore no budget is provided. Note that R&R work on the SJPLs is funded under a separate line item and HHWP continues to make progress.

3. Early Intake Dam – Long Term – The project budget reduced by $6M with no change in scope. The stated reason was “to assist with meeting overall financial targets”. With the project’s Conceptual Engineering Report not completed, it appears to be too early to feel all project costs fall within the current estimate. Does the SFPUC feel confident that the budget reduction is justifiable based on likely future costs?

SFPUC Response: The proposed project cost is a high level cost with a high degree of uncertainty because the project is still very early in the Planning Phase. The $6M reduction is considered minor compared to the wide estimate range that is commensurate with the project’s current level of maturity. The current cost estimate is a level 5 per AACEI guidelines, which has a range of -50% to +100% (range of $44M to $177M). As noted in BAWSCA’s comment, the Conceptual Engineering Report (CER) has not been completed yet. Before the CER can be done, the SFPUC must first complete the Alternatives Analysis Report which includes a wide range of alternatives and associated cost estimates. Once an alternative is selected, the SFPUC will be able to produce an updated budget and schedule, with a higher degree of accuracy, which can be used in future CIP budget requests.

4. Cherry Dam Spillway – This project budget more than doubled to address deficiencies with the spillway as a short-term measure, noting that the spillway capacity is insufficient and must be addressed in a long-term project. Is there any planning for the long-term project in this Capital Plan? Will Division of Safety of Dams place an operating restriction on this dam at some point based on this spillway capacity issue? Please respond to the two questions.

SFPUC Response: The long-term project for Cherry Dam is currently being tracked as a candidate project; however, no funding is included in the current 10-year CIP.

The SFPUC has taken two significant actions in response to the spillway capacity: (1) advanced a short-term improvement project, which included an analysis of the potential impacts of spillway operations on overall dam safety, and (2) implemented a Forecast Informed Reservoir Operations strategy that ensures that forecasted storms can be safely routed through the system. As a

result, the SFPUC does not anticipate an operating restriction to be imposed by DSOD.

5. O’Shaughnessy Dam Outlet Works Phase 2 – The project budget was reduced by $14.2M with no change in scope. The stated reason was “to assist with meeting overall financial targets”. With the project not even initiated, it appears to be too early to feel all project costs fall within the current estimate. Does the SFPUC believe that the required work will not require that additional funding?

SFPUC Response: The future costs of this project are currently unknown because the project has yet to start the Planning Phase. However, the budget produced is reasonable based on the information that is currently available.

The $14.2M reduction is considered minor compared to the wide estimate range that is commensurate with the project’s current level of maturity. The current cost estimate is a level 5 per AACEI guidelines, which has a range of -50% to +100% (range of $49M to $196M). As noted in BAWSCA’s comment the project hasn’t started yet and the data available to support a cost estimate is minimal. When additional planning phase deliverables are completed, the SFPUC will be able to produce an updated budget and schedule, with a tighter accuracy range, which will be incorporated into future CIP budget requests.

6. Moccasin Old Powerhouse Hazard Mitigation – The scope does not describe work to create the materials storage area described in the scope for Moccasin Engineering and Records Building project. Is this scope element part of the existing project or planned for a future Capital Plan project?

SFPUC Response: The scope of the Moccasin Old Powerhouse Hazard Mitigation Project does not include a new material storage building. This project was developed to investigate alternatives to mitigate the hazards associated with the existing building, which is providing storage for some of HHWP’s materials and spare parts. If the project’s Alternative Analysis Report determines that the hazards can be reasonably mitigated, then the existing space will continue to be used. If the hazards cannot be mitigated, then a separate project will be developed to meet HHWP’s material storage needs.

Currently, a separate materials storage project is not included in the 10-year CIP.

7. R&R Wildfire Mitigation (Joint) – This is an R&R project with scope dramatically reduced from the prior Capital Plan to focus on creating fuel breaks. As this is an ongoing effort, is the budgeted amount sufficient for the full 10-year cycle? Is the fire risk reduced by some other means such that the creation of fuel breaks can be reduced substantially? Please respond to the two questions.

SFPUC Response: Yes, the budget amount for R&R Wildfire Mitigation (Joint) is sufficient for the scope of this project, which is focused on the creation of fuel breaks. This is an ongoing effort. Initial creation of fuel breaks will be funded by this capital project; while ongoing maintenance of the fuel breaks would be funded from Hetch Hetchy Water and Power’s Operating Budget.

Fire risk reduction is also included in the scope of another capital project, “R&R Power Distribution Line High Risk Fire Reduction (Joint)”, which will deliver electric distribution system capital improvements to reduce wildland fire risk on the HHWP Project. Projects will include reconductoring, increasing safe- clearance distances, undergrounding, and adding alternative power supplies at some locations to reduce HHWP’s overhead electrical line footprint.

We hope these responses address your questions. As always, please let us know if you have further questions we can address.

Sincerely,

Steven R. Ritchie
Assistant General Manager, Water

cc:

Newsha Ajami, President, San Francisco Public Utilities Commission Members of the Commission, SFPUC
Dennis Herrera, SFPUC, General Manager
Ron Flynn, SFPUC Deputy General Manager
Nancy L. Hom, SFPUC, Chief Financial Officer, Assistant General Manager, Business Services
Stephen Robinson, SFPUC, Assistant General Manager, Infrastructure Alison Kastama, SFPUC, BAWSCA Liaison
BAWSCA Board of Directors
BAWSCA Water Management Representatives
Allison Schutte, Hanson Bridgett, LLP, Legal Counsel

155 Bovet Road, Suite 650  San Mateo, CA 94402  ph 650 349 3000  fx 650 349 8395  www.bawsca.org

Statement from Nicole Sandkulla, Chief Executive Officer: The State Water Resources Control Board Has Announced an Aggressive Schedule for Consideration of a Voluntary Agreement for the Tuolumne River that will provide greater water flows and increased habitat to Protect Fish and a Reliable Water Supply for 1.8 million Residents, 40,000 Businesses, and Hundreds of Communities in Alameda, San Mateo, and Santa Clara Counties and for San Francisco's water users.

February 21, 2023

Last November, San Francisco, along with the Modesto and Turlock Irrigation Districts, signed onto a Memorandum of Understanding (MOU) for development of a larger voluntary agreement for the Sacramento-San Joaquin Delta that meets the State Water Resources Control Board's (State Board) objectives for the Bay-Delta.

The MOU includes a commitment by the Tuolumne River parties for new additional flows in the Tuolumne River to protect native fish species on top of the current requirements. The MOU also commits spending $64 million in habitat improvement projects over the eight-year term of the MOU to provide improved and increased habitat for native fish species. BAWSCA urges the Tuolumne River parties, including the SFPUC, to move forward now with early implementation of the MOU commitments for new additional flows in the Tuolumne River and implementation of identified habitat improvements.

At a workshop on January 19th, the State Board presented its schedule for a State Board workshop and consideration of a Tuolumne River Voluntary Agreement in Winter/Spring 2024.

The State Board also identified the release of a final draft environmental document and regulation for implementing the adopted Bay-Delta Plan in that same Winter/Spring 2024 period.

Now the parties to the MOU, including San Francisco, must finalize additional legal and implementation details of a voluntary agreement so that it can be submitted to the State Board for a successful evaluation as an alternative to part of the adopted Bay Delta Plan. The State Board has set an aggressive timeline that will require significant effort and engagement by all parties to achieve it, and those efforts are worthwhile given the downside risks of not securing a voluntary agreement for our water users and the water supply they rely on.

A voluntary agreement for the Tuolumne River will be a big step forward in providing necessary improvements for fish in the Tuolumne River and ensuring a continuing reliable supply of high- quality water at a fair price for the health, safety, and economic well-being of BAWSCA's water users in the three counties and for construction of thousands of new affordable housing units.

Fortunately, the State Board has invited voluntary agreements to resolve major California water- supply issues, such as this one, and BAWSCA looks forward to a voluntary agreement for the Tuolumne River being carefully analyzed, as an update to the Bay-Delta Plan, and implemented.

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