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
April 13, 2023 through April 17, 2023
Date Received From Subject
April 13, 2023 John Goldberg Objection to Rate Increases April 17, 2023 Dave Warner Where we Last Left Off
Peter Drekmeier Salmon Count Data Sources
From:
To: Commission
Cc: Paul C. Chignell
Subject: Objection to Rate Increase
Date: Thursday, April 13, 2023 3:44:01 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 the property owner and resident at 133 Starview Way, San Francisco. I object to the proposed rate increase to the SF water rates. The water rates in San Francisco are already the highest in the US. Moreover, the PUC has excess funds to pay for advertisements on FaceBook, encouraging people to rid themselves of natural gas appliances. These ads are purely political as they have nothing to do with the PUCs core mission as a public utility.
John Goldberg
April 17, 2023
Re: Where we last left off….
Dear Commissioners, General Manager Herrera and Assistant General Manager Ritchie,
We held our last workshop, workshop #7 regarding the design drought, on August 23rd, 2022. My understanding is that workshop concluded with then Commission President’s view that the design drought model was based upon experience, and return periods were not useful. In my opinion, such a position may deny the value of scientific analysis. My attached letter, dated September 12, 2022 explains my thinking further.
Does the full commission hold the view expressed by then President Moran? Perhaps it could be a topic for the next workshop.
As you know there have been seven content rich workshops over the last two and a half years. Let’s take advantage of all the effort that’s been invested and find consequential actions. The Tuolumne has seen no improvement and is still an ecological disaster.
Best regards,
Dave Warner
Enclosure
Cc: Nicole Sandkulla, BAWSCA CEO
September 12, 2022
Re: The Reasonable Person Standard and the Design Drought Discussion
Dear President Moran and Commissioners,
Thank you for your design drought discussion on August 23rd. Thank you also for expressing your perspectives—they are immensely helpful for learning and for understanding the basis for policy decisions. The conclusions I heard were i) that the design drought was a judgement based on experience and how we operate the system; and ii) that return periods are a false promise and don’t deliver on the ability to do better and can’t predict what’s going to happen next year.
The trouble is, the data does do better than a decision to add two years to the 1987-92 drought based on experience. Please consider the reasonable person standard. It’s a standard used by courts to determine negligence. Of 100 years of observed data, 1100 years of tree ring data, and 25,000 years of stochastic data, none of it found a drought using the design drought’s amount of storage at a demand level of 265 mgd. In 26,000 years of data there was never a drought that used 1,350 TAF of storage to supply the regional water system with 265 mgd of supply. If the Tuolumne salmon could be the plaintiffs in the case, it seems like there is an argument for negligence, a reasonable person would conclude that the SFPUC can do better than the design drought model in meeting the needs of all stakeholders.
It also appears that there was bias by at least part of the commission not to have an interest in finding a drought model/stress test better than the design drought. If there had been an interest in finding a better model, I would have expected more questions. One question that comes to mind: Can climate scientists and or climate models tell us if the probability of the next year being a drought declines as the number of sequential drought years increases? If the answer is yes, that would be exciting news for drought planning. Given that the 25,000 years of stochastic data didn’t find a drought as severe as the design drought, I would guess that there is such a relationship.
If part of the commission has a bias not to improve upon the design drought model, it would be incumbent on other commissioners to counteract that bias.
The design drought model is a consequential policy tool.
Best regards,
Dave Warner
cc: Dennis Herrera, Steve Ritchie
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
Marek Robinson, Secretary
Eric Heitz,
Chair Emeritus
Jose Borroel
Eddie Corwin
Eric Gonzalez
Camille King
Marty McDonnell
Homero Mejia
John Nimmons
Eric Riemer
Iris Stewart-Frey
Bart Westcott
Brad Wurtz
April 17, 2023
President Newsha Ajami and Commissioners
SFPUC
525 Golden Gate Ave.
San Francisco, CA 94102
Via Email
Re: Salmon Count Data Sources
Dear President Ajami and Commissioners:
The following salmon count graph was presented by staff to the Commission twice, first at a workshop on the scientific basis for the proposed Tuolumne River Voluntary Agreement on February 5, 2021, and later during an update on Tuolumne River fall-run Chinook salmon on November 8, 2022 TRT pointed out that the data sources used for the graph were changed in 2009, shifting from historic CDFW carcass surveys to FishBio weir counts. We informed the Commission that the weir counts were on average 2.5 times higher than the carcass surveys, so the graph did not compare apples to apples. Whether intentional or not, this made recent salmon counts appear higher than they should have been had a consistent source been used.
2 SFPUC staff never corrected the graph. However, upon request consultants for the Irrigation Districts, who had been using a similar graph, agreed to update their graph to show both CDFW carcass surveys and FishBio weir counts.
You will see that from 2009 to the present, weir counts (blue bar) averaged 2.5 times higher than carcass surveys (red bar).
Moving forward, please direct staff to use a consistent salmon count data source, which should be the CDFW carcass surveys upon which the State and Federal salmon doubling goal is based.
Thank you.
Sincerely,
Peter Drekmeier
Policy Director
Cc: BAWSCA Board of Directors
SFPUC Citizens Advisory Committee