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San Francisco Public Utilities Commission
Correspondence Log
August 31, 2023 through August 31, 2023
Date Received From Subject
August 31, 2023 Chance Cutrano NGO Comments on the SFPUC’s Draft Alternative Water Supply Plan
Tom Francis BAWSCA Comments on the SFPUC’s Draft
Alternative Water Supply Plan
Peter Drekmeier Tuolumne River Trust Comments on the
SFPUC’s Draft Alternative Water Supply Plan
David Happs SFPUC Alternative Water Supply Comments
1 August 31, 2023
President Newsha Ajami and Commissioners
San Francisco Public Utilities Commission
525 Golden Gate Ave.
San Francisco, CA 94102
Via Email
Re: Comments on the SFPUC’s Draft Alternative Water Supply Plan.
Dear President Ajami and Commissioners:
The Sierra Club, Tuolumne River Trust, Golden State Salmon Association, San Francisco League of Conservation Voters and California Sportfishing Protection Alliance appreciate the opportunity to comment on the SFPUC’s draft Alternative Water Supply Plan (AWS Plan). While we appreciate that the SFPUC is undertaking this exercise, we think the Plan has a lot of room for improvement. Of utmost concern is the lack of a robust assessment of how much alternative water supply the SFPUC might reasonably need to develop.
I. The Plan Must Include a Sensitivity Analysis, and Model Alternative Scenarios
The AWS Plan states, “Identifying future demand is critical to planning for long-term supply reliability of the RWS.” (p. 30) Yet it fails to include alternative scenarios that consider a more realistic drought planning horizon and reasonable demand projections.
It goes on to say:
Successful implementation of the AWS Program requires a balance between securing future reliability and maintaining affordability, both of which are critical SFPUC goals.
The AWS Program must focus on implementing water supply projects that will address long-term customer demands and obligations without over-building or overcommitting capital funding. (p. 57)
This comment emphasizes the importance of not overinvesting in AWS that will not be needed, but the Plan fails to accurately identify future water supply needs. The Plan acknowledges that changes in assumptions related to the Design Drought and projected water demand would have a profound impact on the SFPUC’s water supply deficit, yet there is no modeling of how such changes would affect “Demands.” It states:
2 The SFPUC relies on planning assumptions and modeling to project future water availability in dry-year conditions. The SFPUC design drought and adopted rationing policy…are assumptions that affect the estimates of water availability during dry-year conditions. Changes to the assumptions around the design drought or rationing would change total system yield estimates. For the purposes of this AWS Plan, these planning assumptions are being held constant as part of the SFPUC planning methodology for projecting future water supplies. This allows a direct comparison to the planning that was done for the WSIP program. (p. 39)
In BAWSCA’s 2022 “Regional Water Demand and Conservation Projections Update,”1 a sensitivity analysis was included that looked at slower population growth.2 The SFPUC should include a similar sensitivity analysis in the AWS Plan, especially considering that the California Department of Finance (CDOF) recently reduced its population growth projections, predicting population declines in both San Francisco and San Mateo Counties.3
Despite raising concerns about overinvesting in expensive alternative water supplies, the AWS Plan fails to consider alternative scenarios, such as reducing the length of the Design Drought or using CDOF population growth projections, both of which would reduce “Demands” significantly. The Commission should be informed on how these changes would impact the perceived water supply deficit.
Recommendations:
1) Direct staff to model “Demands” (water supply deficit) using a 7.5-year Design Drought. 2) Direct staff to model “Demands” using CDOF population growth projections, similar to BAWSCA’s sensitivity analysis (see Attachment A).
3) Direct staff to model “Demands” using a combination of a 7.5-year Design Drought and CDOF population growth projections.
4) Amend Figure 3-4 (Obligations and Demands) to include a third column titled “Lower Demands” that is based on a 7.5-year Design Drought and CDOF population growth projections. Rename the current “Demands” column “Upper Demands.”
II. Why It’s Important To Do This Right?
Alternative water supplies can be expensive, so investing wisely is important. According to the AWS Plan:
1 BAWSCA Regional Water Demand and Conservation Projects Update, December 5, 2022 – https://bawsca.org/uploads/userfiles/files/BAWSCA%202022%20Demand%20Study%20Update%20Final%20Repor t(1).pdf
2 Please see Attachment A.
3 San Francisco exodus: City may never recover population loss as other parts of the Bay Area grow, San Francisco Chronicle, August 9, 2023.
3 Based on preliminary estimates, the capital investment associated with the suite of regional AWS Projects could be on the order of $4 billion to $10 billion (escalated to the mid-point of construction) over the planning horizon, varying largely based on the size of the expansion of Calaveras Reservoir and the preferred conveyance facilities.4 (p. 124)
The amount of alternative water supplies the AWS Plan cites as needed – 92 million gallons per day (mgd) – is inflated and would be extremely expensive. On the low end, at $3,000 per acre foot, developing 92 mgd would cost $300 million per year, which would have to be passed on to ratepayers. As you know, ratepayers (especially low income) are already heavily stressed by water and wastewater rates.
Even without these AWS investments, water and wastewater rates are expected to increase substantially in coming years, as demonstrated by the following slide presented at the February 14, 2023 budget hearing.
The AWS Plan would increase rates further. The first phase alone (2% to 5% of the full implementation cost)5 would raise rates as follows:
AWS staff have worked with the Finance team to evaluate the rate impact of adding the AWS Project and Programmatic recommendations in this Plan, which would add
4 Note that the $4 billion to $10 billion range is for capital investments only, and does not include operations and maintenance. Table 5-1 should include at least a range of O&M costs to give a better sense of the full cost of the projects.
5 The first phase of the AWS Plan would cost $209 million. Full implementation would cost $4 billion to $10 billion.
4 approximately $209 million in capital and operating expenses between FY 2025 and 2034…The financial modeling showed that retail rates would need to increase by about
0.9% above the current projected rate plan by FY 2033 and wholesale rates would increase by 7.6% in the same time period…Rate impacts would also extend past the 10- year timeframe analyzed. (pp. 124 & 125)
Higher rates will continue to send a strong price signal to consumers, leading them to use water more efficiently in order to reduce their bills. At the July 16, 2021 SFPUC workshop, staff stated that in response to a 10% rate increase, single-family demand decreases 1.4%, multi-family demand decreases 2%, and commercial demand decreases between 1.4% and 3%.6
It should be of great concern to the Commission that if the AWS Plan is implemented, water rates will skyrocket, driving a dramatic increase in conservation. There would be more water infrastructure to pay for, but less demand to cover the costs. This would exacerbate the “death spiral” – rates increase to cover fixed costs, consumers use less water, rates increase again, and the economic situation continues to worsen.
III. Impacts on Water Supply
The AWS Plan erroneously states:
The most pronounced driver affecting water availability is the potential implementation of the 2018 Amendment to the State Water Resources Control Board’s San Francisco Bay/Sacramento-San Joaquin Delta Estuary Water Quality Control Plan. (p. XII)
According to the SFPUC’s $743,000 Long-Term Vulnerability Assessment (LTVA), this statement is incorrect. The LTVA states:
Climate change is not the single most important driver of vulnerability for the RWS.
Under current RWS infrastructure conditions, either state-amended WQCP [Bay Delta Plan] for additional IFR [instream flow requirement] on the Tuolumne River or an increase in demand by 15% have significant impacts on the RWS performance that are equivalent to a decrease in mean annual precipitation of around 15%. (LTVA, p. 250)
In other words, the Bay Delta Plan instream flow requirement is equivalent to either a 15% increase in demand, or a 15% decrease in precipitation.
RWS demand has been under 200 mgd for the past nine years. Assuming demand remains flat at around 200 mgd, the 244 mgd projection for 2045 in the AWS Plan would increase demand
6 SFPUC workshop on Water Demand Projections and Demand Management, July 16, 2021 – https://sanfrancisco.granicus.com/player/clip/38991?view_id=22&redirect=true&h=28ea534dd1acf1e58ebb0321a 7db1492 (22:40).
5 by 22%. This inflated demand projection is the most pronounced driver affecting water availability.
The baseline demand figure used in the LTVA is 227 mgd, which is 15% greater than what RWS demand has been for the past nine years. This means that results included in the LTVA based on the baseline demand figure are essentially incorporating the Bay Delta Plan instream flow requirement into actual current demand. Furthermore, most of the analysis in the LTVA is based on 240 mgd demand, which is 20% greater than 200 mgd demand. The LTVA suggests there is an extremely small chance the SFPUC would run out of water unless water demand grows substantially, which is very unlikely to happen (see comments on demand projections below).
IV. The AWS Plan Needs to Address the Design Drought
Despite numerous references to “climate uncertainty,” the AWS Plan dedicates a mere three paragraphs to the LTVA, with no citations to justify the Design Drought. The AWS states, “Impacts related to climate change are not currently quantified in the AWS planning efforts;” (p. 39)
Removing one year from the Design Drought, which is justified by the LTVA, would have a big impact on the perceived need to invest in expensive alternative water supplies. Removing the final year from the Design Drought would reduce “Demands” in the AWS Plan by about 25 mgd.
This would reduce costs (passed on to ratepayers) by at least $90 million per year – an opportunity that is certainly worth exploring.
The LTVA found that the Design Drought is extremely unlikely to occur, yet the SFPUC continues to use it as its primary planning tool. The LTVA included return periods (likelihood of occurrence) for the known droughts, but inexplicably did not include a return period for the Design Drought. A Public Records Act request uncovered a document revealing that the study authors had produced a return period for the Design Drought of once-in-25,000 years,7 but this information was not included in the final report. Information that was included in the final report suggests the Design Drought is even less likely to occur. We addressed this at the August 23, 2022 SFPUC workshop, and SFPUC staff had no response. Please review the workshop video.
The Design Drought was conceived following the 1987-92 drought of record. It was arbitrary and has never been backed up by supporting evidence. Much has changed since the 1987-92 drought. For example:
• Heading into the drought, water demand was at an all-time high of 293 mgd. It has been under 200 mgd for the past nine years.
• The SFPUC adopted its Water First Policy, prioritizing water supply over hydropower generation. According to an SFPUC presentation, precipitation in 1976/77 was 39.14
7Hydrological Drought Frequency Analysis for the Upper Tuolumne River, December 8, 2020. 6 inches, and was similar in 2020/21 at 39.28 inches. Yet, while total system storage was 563,298 acre feet on June 10, 1977, it was substantially higher at 917,455 acre feet on the same date in 2021.
• Cherry Lake, the SFPUC’s second largest reservoir in the Tuolumne watershed (3/4 the capacity of Hetch Hetchy) was drained for maintenance in 1989, and that storage was lost.
The LTVA 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] 8.5), respectively, with no clear direction of change in mean annual precipitation over the planning horizon.” (LTVA, p. xxii)
In other words, we might expect wetter years and drier years, but on average precipitation isn’t expected to change much. In fact, the report suggests that the Hetch Hetchy watershed is more likely to experience slightly more precipitation in the future. Interestingly, earlier runoff projected by the study would likely benefit the SFPUC’s water entitlements based on how water rights were established on the Tuolumne River under the Raker Act. Based on the study’s projection that runoff will likely come three weeks earlier by 2070, if the Design Drought were to occur, the SFPUC would pick up an additional year’s-worth of water over the course of the
8.5-year drought. We explained this at the August 23, 2022 workshop.
V. The AWS Plan Needs to Address Inflated Water Demand Projections
The issue of inflated water demand projections has been raised many times, and was addressed at the July 16, 2021 workshop. AGM 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 accuracy of water demand projections was again addressed in an SFPUC report titled “Water Enterprise and Finance Bureau Water Demand Projections,” dated July 5, 2022. The report stated:
It [UWMP Act] was not intended to establish the projected water demands that would be used for all operational and planning purposes…the projections represent an outside bound of whatever demand will occur in the next 25 years...These demands will likely always be greater than actual demands because not all developments materialize, or they materialize slower than projected.
And:
7 By contrast, for the purpose of financial planning and for short term water system management, we estimate the demand that we are likely to experience. For budgeting and rate setting we use demand projections that are as close to actual as we can make them.
The report included graphs showing that both the SFPUC Water Enterprise and Finance Bureau have historically over-projected demand, but Finance has always been closer to the actuals. The Finance Bureau currently projects sales will remain flat for at least the next decade.
The primary driver for current inflated water demand projections is inflated population growth projections. This issue came up at the July 16, 2021 workshop, to which then SFPUC President Anson Moran gave the following directive:
…we be given information about the differences between Department of Finance and the Plan Bay Area and what those differences really are, and within that, what portion of that reflects legal mandates such as affordable housing targets and what is more aspirational.
After a ninth month delay, staff finally provided two paragraphs explaining how the CDOF and ABAG (Plan Bay Area) determine population growth projections, but ignored the question raised by President Moran.8
The latest CDOF projections (July 2023) suggest that the populations of San Francisco and San Mateo Counties will likely decline over the coming decades.
VI. SFPUC “Rationing Methodology” Vs. “Rationing Policy”
The AWS Plan should explain the difference between the SFPUC’s “rationing methodology” and “rationing policy.” The rationing methodology is explained in Appendix K of the 2020 Urban Water Management Plan as follows:
In applying its water supply planning methodology, the SFPUC performs an initial model simulation of the system for the design drought sequence and then reviews the ability of the system to deliver water to the service area through the entire design drought sequence. If the projected water supply runs out before the end of the design drought sequence in the initial model run, system-wide water use reduction is added and the scenario is re-run. This process continues iteratively until a model simulation of the system is achieved in which the water supply in storage at the end of the design drought sequence is brought to the system “dead pool,” where no additional storage is available for delivery (currently simulated as 96,775 acre-feet). Drawing system storage down to
8 Department of Finance and Plan Bay Area Projections, email from AGM Steve Ritchie to Anson Moran dated April 14, 2022 (included in the April 26, 2022 SFPUC correspondence log). 8 the dead pool without going below it indicates that water supply delivery, including the adjusted amount of water use, is maintained through the design drought sequence.
The rationing methodology was not used to produce the 122 mgd of “Obligations” nor the 92 mgd of “Demands” cited in the AWS Plan. Instead, the SFPUC used rationing figures produced in 2008 for the WSIP using the rationing methodology. Back then, what staff now refers to as the “rationing policy” conformed with the rationing methodology. Now that the State Water Board adopted the Bay Delta Plan, it no longer does. Staff should have rerun the numbers using the rationing methodology, which is the SFPUC’s true rationing policy. Doing so would require rationing to begin earlier in the Design Drought and increase more rapidly.
SFPUC staff explained the “rationing policy” as follows:
The estimate of SFPUC water supply without Bay Delta Plan contributions is 257 MGD of total yield, which is the sum of the system firm yield of 227 MGD and the volume associated with the rationing policy established for the WSIP program. That rationing policy includes 3 years of 10% rationing and 3.5 years of 20% rationing over the 8.5-year design drought. The volume associated with the rationing policy changes as the firm yield changes, as noted above. In this case, the volume of the rationing policy is 30 MGD. That gives a total yield (firm yield + rationing) equal to 227+30 or 257 MGD.9
In other words, the rationing figures used to determine “Demands” in the AWS Plan assume no rationing in Years 1 and 2 of the Design Drought, 10% rationing in Years 3 to 5, and 20% rationing in Years 6 to 8.5.
The rationing numbers and timing that was determined necessary to manage the Design Drought at the time the WSIP was approved would fail to enable the SFPUC to manage the Design Drought under the Bay Delta Plan. In fact, the SFPUC has argued it could not manage the Bay Delta Plan flows without exceeding its Level of Service Goal of limiting rationing to no more than 20%.
It is clear that starting rationing at 10% in Year 3, and not increasing it to 20% until Year 6 is not how the SFPUC would impose rationing if the Bay Delta Plan is implemented. Imposing rationing earlier and at higher levels would reduce “Demands” substantially. Starting 20% rationing in Year 3 rather than Year 6 would have an incremental favorable impact on water available in storage, which should be factored when considering alternative water supplies.
The AWS Plan acknowledges this in a hidden way. Figure 3-3 includes “Estimated Contribution of Rationing,” which is another way of saying “using the SFPUC’s rationing methodology.” The 81 mgd “Demands” cited in Figure 3-3 should be the upper demand used in the AWS Plan, saving at least $36 million per year in unnecessary investments.
9 Email from Matt Moses (SFPUC) to Peter Drekmeier (TRT), October 26, 2022.
9 VII. Alternative Water Supply Investments
As discussed above, we believe that, particularly with a modest adjustment to the Design Drought and the use of realistic demand projections, even with full implementation of the Bay Delta Plan, the SFPUC could maintain a highly reliable water supply. Under this approach, the SFPUC would not face the need for a large scale investment in alternative water supplies.
The AWS Plan, however, follows a different path with regard to the Design Drought and demand projections. We recommend that the SFPUC develop multiple scenarios for analysis in this document. At one end, this should include the assumptions we have suggested regarding the Design Drought and demand projections. At the other end, if the SFPUC choses to use higher demand projections, that assumption should be paired with a greater investment in alternative water supplies. For example:
Denitrification and Direct Potable Reuse
It is likely that in coming years Bay Area wastewater treatment plants will be required to reduce nutrient discharges into the Bay through investments in denitrification. At the same time, the State Water Board is developing regulations for direct potable reuse. We believe water agencies, particularly the SFPUC, are presented with an important opportunity to develop a cost-effective solution to two problems – excessive nutrient discharges and ensuring long-term reliable water supplies. We urge the SFPUC to include, as needed in the scenario approach discussed above, significant investments in purified water and denitrification.
On August 21, 2023, the San Jose Mercury News published an article titled “Fighting Future ‘Red Tides’ in San Francisco Bay.” San Francisco Bay suffered a significant harmful algal bloom (HAB) in August 2022, killing thousands of fish and endangering people and their pets. A second less severe bloom occurred in July 2023.
In response, Eileen White, Executive Director of the San Francisco Bay Water Quality Control Board (SF Bay Water Board), is quoted, “The science is telling us that we need to reduce nutrient loads as quickly as possible. What has happened is a game changer.”
San Francisco’s discharges into San Francisco Bay are responsible for 20% of the nutrient loading. The Mercury News article states that San Francisco and the East Bay Municipal Utilities District (EBMUD) are running behind other municipalities in dealing with this problem. The article also states that some of the South Bay agencies have reduced nitrogen releases by about 85% from previous levels. As a major contributor of nutrient pollution, the SFPUC should take the lead in solving this problem. The AWS Plan should be amended to specifically make this a priority goal.
As noted in the Mercury News article, some of the newer technologies for reducing nutrients do not always result in available water. The SFPUC should avoid using those technologies unless 10 they are proven to be very cost-effective on a short-term basis. The long-term plan should be a combination of reducing nutrient loading and water recycling and reuse.
An SFPUC presentation on the “San Francisco Purified Water Opportunities Study” (Carollo, May 2022) included the following slide. Despite mentioning that staff were preparing a recommendation, it is not included in the AWS Plan. This is a lost opportunity.
Collaboration with the Irrigation Districts on Groundwater Banking
Implementation of the Sustainable Groundwater Management Act (SGMA) is leading Central Valley water agencies to invest in significant groundwater recharge programs. Implementing these programs on a large scale will be expensive, and may lead the Modesto and Turlock Irrigation Districts to be receptive to collaborating with the SFPUC. We continue to urge the SFPUC to explore a conjunctive use partnership in Stanislaus County that could assist with SGMA implementation while providing the SFPUC with additional storage and reliability benefits.
Collaboration with the Irrigation Districts on More Efficient Water Delivery
Similar to groundwater banking, the SFPUC could partner with the Irrigation Districts on developing pressurized water systems that enable more efficient delivery of water to farms.
The SFPUC could fund the infrastructure for a share in the savings. Conserving agricultural irrigation water is far less expensive than developing alternative water supplies in the Bay Area, and the opportunity is huge. For example, a pilot project implemented by the South San Joaquin Irrigation District installed a pressurized water system on 2,000 acres of farmland that decreased water use by 30% while increasing crop yield by 30%.
11 For the above water supply scenarios, we recommend the following:
• The document’s scenarios should explicitly pair higher growth assumptions with higher investments in alternative water supplies.
• The document should include a scenario that would include ambitious direct potable reuse and denitrification of wastewater effluent in the service area. • The document should include the potential for a conjunctive use program partnership between the SFPUC and the Irrigation Districts, as well as an analysis of the potential to partner on water efficient delivery to farms.
VIII. Conclusion
In order to greatly improve the AWS Plan, we recommend the following:
1) Direct staff to model “Demands” using a 7.5-year Design Drought. 2) Direct staff to model “Demands” using CDOF population growth projections. 3) Direct staff to model “Demands” using a combination of a 7.5-year Design Drought and CDOF population growth projections.
4) Amend Figure 3-4 (Obligations and Demands) to include a third column titled “Lower Demands” that is based on a 7.5-year Design Drought and CDOF population growth projections. Rename the current “Demands” column “Upper Demands.” 5) Pair higher growth assumptions with higher investments in alternative water supplies, specifically direct potable reuse and denitrification, groundwater banking in Stanislaus County, and collaboration with the Irrigation Districts on water delivery efficiency.
Thank you for the opportunity to share our thoughts and recommendations.
Sincerely,
Molly Culton Peter Drekmeier
Chapter Organizing Manager Policy Director
Sierra Club California Tuolumne River Trust
Scott Artis Chris Shutes
Executive Director Executive Director
Golden State Salmon Association California Sportfishing Protection Alliance
12 Chance Cutrano Kristina Pappas
Chapter Chair President
Sierra Club, SF Bay Chapter San Francisco League of Conservation Voters
CC: San Francisco Board of Supervisors
San Francisco Capital Planning Committee
BAWSCA Board of Directors
SFPUC Citizens Advisory Committee
Please scroll down for Attachment A.
13 Attachment A – BAWSCA’s Water Demand Sensitivity Analysis
BAWSCA’s 2022 Regional Water Demand and Conservation Projections Update10 assessed how different factors affect demand projections. The study looked at alternative future scenarios based on:
• Population and jobs growth
• Housing density
• Water rates
• Water conservation
• Climate change
Scenarios A through E are summarized in the following table.
Among other assumptions, Scenario E used California Department of Finance population growth projections (prior to the recently released numbers). Scenario E is presented in the following table.
10 BAWSCA Regional Water Demand and Conservation Projections Update, December 2022 – https://bawsca.org/uploads/userfiles/files/BAWSCA%202022%20Demand%20Study%20Update %20Final%20Report(1).pdf
14 The table below shows projected water demand for Scenarios A through E. Note that under Scenario E, BAWSCA’s total water demand in 2045 is projected to be 204 million gallons per day (mgd). To put this in perspective, BAWSCA’s total water use in FY 2020/21 was 205.4 mgd.11 Note that these figures are for total BAWSCA demand, including water provided by sources other than the SFPUC.
11 BAWSCA Annual Survey, March 2023, Table 3B: Historical Total Water Use among BAWUA/BAWSCA Agencies, 1975-76 to Present. -- https://bawsca.org/uploads/userfiles/files/Annual%20Survey_FY21-22_FINAL.pdf
15 155 Bovet Road, Suite 650 ⚫ San Mateo, CA 94402 ⚫ ph 650 349 3000 ⚫ fx 650 349 8395 ⚫ www.bawsca.org
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August 31, 2023
Via email
Steven Ritchie
Assistant General Manager, Water Enterprise
San Francisco Public Utilities Commission
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
RE: BAWSCA’s Review of the SFPUC’s Draft Alternative Water Supply (AWS) Plan
Dear Mr. Ritchie,
BAWSCA has reviewed the SFPUC’s Draft Alternative Water Supply (AWS) Plan made available for public review on June 28, 2023. BAWSCA commented on earlier versions of key sections of the AWS Plan and appreciates that most of these earlier comments have been incorporated or adequately considered by the SFPUC. This letter focuses on significant comments BAWSCA views as meriting further attention by the SFPUC.
General Comments
BAWSCA strongly supports both the AWS Plan and the overall AWS Program. The SFPUC must be prepared to face potential future reductions to its existing water supply that could require the development of new supplemental sources to improve long-term water supply reliability in order to meet its legal and contractual obligations to the BAWSCA Member Agencies as well as the water needs of its Retail Customers in San Francisco. Climate change and future regulatory uncertainties could exacerbate the need for new diversified and distributed water supply sources. The AWS Plan meets these critical planning needs.
Components of the AWS Plan provide the roadmap for the development of projects needed to address the water supply shortfall (gap) that is calculated to be present through the planning horizon (2045). That gap is acutely related to shortage of supply during times of drought.
The AWS Plan presents detailed information regarding estimated project costs and development times and estimated rate impacts to both SFPUC Retail and Wholesale Customers for the AWS planning work estimated to take place within the SFPUC’s 10- year Capital Improvement Plan (CIP). While BAWSCA agrees that the presented rate impacts are correct for the purposes of the SFPUC's 10-year CIP, the full rate impact of the implementation of the suite of AWS Plan projects has not been estimated at this time as more details are needed that can only be provided following further planning work.
Steven Ritchie
August 31, 2023
19798123.6
This complete cost and rate impact information will be necessary for the SFPUC and BAWSCA to support future decision making.
The AWS Plan includes recommendations for the Commission to consider that, if embraced, will work to: 1) Avoid widening the water supply gap; 2) Fill the water supply gap; and 3) Reduce the water supply gap. BAWSCA supports those recommendations, particularly those that call for additional staffing as needed to better implement the AWS Program.
There remains uncertainty related to how regulatory and other pressures can widen the supply shortfall. The AWS Plan is clear that, although implementing the projects listed can contribute substantially to lessening that gap, additional projects beyond those documented in the Plan will be necessary to fill the water supply gap.
BAWSCA recognizes that efforts by both the SFPUC and BAWSCA's Member Agencies have and can continue to result in lowered water demands. It also must be recognized that demand hardening is not simply a concept, but a reality that must be addressed as part of long-term water supply planning. Our respective agencies continue to be committed to water use efficiency, and the fundamentals of continued population growth coupled with realistic expectations as to what level of per capita water use can be achieved, further support the need for the AWS Plan.
The AWS Plan better positions San Francisco to fulfill its contractual obligation under the 2021 Amended and Restated Water Supply Agreement between San Francisco and the Wholesale Customers (WSA) to decide, by December 31, 2028, whether to make the cities of San Jose and Santa Clara permanent Wholesale Customers of the SFPUC. It is appropriate for the AWS Plan to acknowledge and be informed by the requirement that the SFPUC make this decision.
Specific Comments
1. Section 1.3.2 – Role of Wholesale Customers and BAWSCA in the AWS Program Development and Implementation
The SFPUC's responsibility to inform the Wholesale Customers of the actions and progress of the AWS Program stems not only from the SFPUC's role as a regional supplier (as the first paragraph of Section 1.3.2 notes), but also from the SFPUC's contractual obligations under the Amended and Restated 2021 Water Supply Agreement between San Francisco and the Wholesale Customers (WSA). BAWSCA requests the first paragraph of Section 1.3.2 be revised to emphasis this point.
2. Section 2.2.4 – RWS Infrastructure and WSIP
The second paragraph of Section 2.2.4 mentions that the SFPUC will use Level of Service (LOS) Goals and Objectives to inform the SFPUC’s approach to future water supply planning and the AWS Program. San Francisco’s perpetual obligation to provide the Supply Assurance to the Wholesale Customers is another critical factor Steven Ritchie
August 31, 2023
19798123.6
that must inform the SFPUC’s approach to future water supply planning and the AWS Program, and should be acknowledged in this specific discussion. BAWSCA requests that Section 2.2.4 be revised to acknowledge that San Francisco's perpetual obligation to provide the Supply Assurance to the Wholesale Customers will also inform the SFPUC's approach to future water supply planning and the AWS Program's efforts.
3. Section 2.4.3 – Current and Historical Demands
While BAWSCA acknowledges that the AWS Plan is focused on the SFPUC’s obligations through the 2045 planning horizon (which may or may not include the City of San Jose and the City of Santa Clara as permanent Wholesale Customers), it is important that the AWS Plan captures the SFPUC's existing contractual obligations to San Jose and Santa Clara under the WSA, including but not limited to, (i) SFPUC's contractual obligation to supply San Jose and Santa Clara with a combined annual average of 9 mgd through 2028, and (ii) the 10-year notice requirement to terminate San Jose and Santa Clara if such a decision regarding their status is reached.
BAWSCA requests that the following sentence be added to the end of the first paragraph in Section 2.4.3 to clarify the SFPUC's contractual obligation to San Jose and Santa Clara: "Additionally, the AWS Program must account for the SFPUC's contractual obligation to supply San Jose and Santa Clara with a combined annual average of 9 mgd through 2028."
4. Section 5.2.2 - AWS Staff Considerations
BAWSCA supports the SFPUC’s identification of additional staffing needs as required for the implementation of the AWS Plan, including at both the project level and programmatic level. As AWS Projects move toward implementation, BAWSCA anticipates that additional staffing, beyond that included in the AWS Plan’s Recommendations, may be needed.
5. Section 5.2.3 - AWS Cost Considerations
BAWSCA understands that the development of project cost estimates are based on the stage of the planning and development cycle that a particular project is in, and further understands that greater detail on how those estimates were developed has been provided in Appendix C of the AWS Plan. BAWSCA notes, however, that the SFPUC will continue to refine these costs as more project information is developed.
With respect to the Rate Impacts discussion in Section 5.2.3, BAWSCA understands that the rate impacts in the AWS Plan provide a planning level assessment and are only representative of the portion of the AWS Plan’s total project costs that will be expended during the SFPUC 10-year CIP term. Rate impacts are of great interest to BAWSCA's Member Agencies and their water customers. As more cost information is developed as part of the implementation of the AWS Plan, BAWSCA will expect the SFPUC to provide the necessary additional clarity on total costs and potential rate impacts.
Steven Ritchie
August 31, 2023
19798123.6
6. Section 6.1.1 - Recommendation 1
The Regional Groundwater Storage and Recovery (RGSR) Project’s yield of 6.2 mgd listed in the Recommendation 1 in Section 6.1.1 is less than the project yield in the adopted Water System Improvement Program. This difference needs to be reconciled by the SFPUC. If and when the SFPUC proposes to adjust the RGSR Project’s yield, the SFPUC will need to comply with AB 1823 and BAWSCA recommends the SFPUC provide a formal process involving BAWSCA, stakeholders, and the public to evaluate alternatives for treatment, infrastructure, and staffing needed to achieve the RGSR Project's proposed dry-year supply by 2045.
7. Section 6.1.2 - Recommendation 3
BAWSCA requests Recommendation 3 be revised to specifically mention groundwater banking and conjunctive use opportunities. In particular, BAWSCA requests that the first sentence of Recommendation 3 be revised as follows: “Continue reporting progress on negotiations related to the Proposed Voluntary Agreement, a possible groundwater banking and conjunctive use project in partnership with Groundwater Sustainability Agencies in the San Joaquin Valley, and other potential transfers and projects in the area that could contribute to instream flow releases.”
8. Section 6.1.3 - Local Projects – Wholesale Service Area
Section 6.1.3 notes that in 2008, when the SFPUC Commission adopted WSIP by Resolution 08-0200, the Commission directed the SFPUC to offset demand by 10 mgd in the retail service area through additional conservation or the development of new recycled water or groundwater sources. The Commission also asked the same of the Wholesale Customers. To illustrate the Wholesale Customers' compliance with this request, BAWSCA asks that a table (or Figure) be added to Section 6.1.3 documenting that, since FY 2008-09, Wholesale Customer SFPUC purchases have been reduced by 35.6 mgd or 22%. The table would include the following data:
• FY 2008-09 SFPUC purchases – 80,034,009 Ccf (164.01 mgd) • FY 2021- 22 SFPUC purchases – 62,647,759 Ccf (128.38 mgd) • Increase/Decrease in 2021-22 purchases compared to 2008-09 – 22% reduction
9. Glossary – Bay Area Water Supply and Conservation Agency (BAWSCA)
The text incorrectly states that BAWCA is an “entity”. BAWSCA is a public agency, and the term “entity” should be replaced as such.
10. Appendix C – AWS Program Cost Development Approach
BAWSCA appreciates the inclusion of Appendix C in the AWS Plan. However, as noted in Appendix C, the SFPUC is still in the process of developing program costs, and in particular preparing a Proforma Model to more fully assess program costs.
BAWSCA will reserve comments on individual project costs until the Proforma Model is completed and its results are shared with BAWSCA.
Steven Ritchie
August 31, 2023
19798123.6
BAWSCA appreciates this opportunity to provide comments on the SFPUC’s AWS Plan and looks forward to continuing to work with the SFPUC as the AWS Plan is finalized and the AWS Program is implemented.
Sincerely,
Nicole Sandkulla
CEO / General Manager
NS/tf:le
cc: SFPUC Commission
SFPUC Citizens’ Advisory Committee
Manisha Kothari, SFPUC, Manager, Alternative Water Supply (AWS) Program Alison Kastama, SFPUC, BAWSCA Liaison
Board of Directors
Water Management Representatives
Allison Schutte, Hanson Bridgett, LLP, Legal Counsel
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
Jose Borroel
Eddie Corwin
Eric Gonzalez
Camille King
Marty McDonnell
Homero Mejia
John Nimmons
Eric Riemer
Iris Stewart-Frey
Bart Westcott
Brad Wurtz
August 31, 2023
AWS Planning Team
SFPUC
[email protected]
Re: Draft Alternative Water Supply Plan
Dear Manisha, Steve and Others:
Please accept the following comments on the SFPUC’s draft Alternative Water Supply Plan. I would appreciate responses to the questions I raise.
1) Problems with Figure 2-6.
The historic purchases graph appears to have several problems. a) It is missing FY 14-15.
b) The bars for FY 09/10, 12/13 and 13/14 appear to be about the same, but the purchases are different (significantly for FY 13/14).
c) Purchases for FY 20/21 are higher than reported in the Water Resources Annual Report (195 mgd).
Please correct Figure 2-6.
2) Rationing should be based on demand, not supply.
The following statement from Table 3-1 is confusing, and potentially incorrect. Rationing is based on a percentage of demand, not supply.
2 Look at it this way. Imagine your salary is $100,000/year, and you spend $90,000/year on living expenses, banking $10,000/year for your retirement. $100,000 is your annual “supply,” and $90,000 is your annual “demand.”
The economy experiences a recession, and your boss is forced to cut your salary by 20%, bringing your annual income (supply) down to $80,000/year. You now need to cut costs and reduce your spending (demand) by $10,000/year in order to preserve your retirement fund. This is the equivalent of rationing.
Reduced spending (rationing) is based on your spending (demand), not your salary (supply).
The statement in the Plan that “The volume of delivery reduction is proportional to the available water supply” appears incorrect, or at least misleading.
Please explain.
3) Water supply loss figures related to the Bay Delta Plan don’t match.
The AWS Plan states:
The Bay-Delta Plan Amendment, if implemented as adopted in 2018, would result in new instream flow requirements that would reduce the SFPUC’s available water supply by an estimated 93 mgd per year. (p. 36)
And:
The Bay-Delta Plan Amendment, if implemented as adopted in 2018, would result in new instream flow requirements that would reduce projected water availability from the RWS in dry years from 257 mgd to 152 mgd. (p. XII)
The second statement suggests the Bay Delta Plan would reduce supply by 105 mgd (257 mgd minus 152 mgd). One would think the two figures should match up, but there’s a difference of 12 mgd. Why is this?
Could it be that the 105 mgd figure was calculated using the SFPUC’s “rationing policy” rather than its rationing methodology?
Please explain.
4) How was the SFPUC’s “rationing policy” adopted?
The AWS Plan states:
The SFPUC estimates that the water demand addressed through rationing is 30 mgd, based on the adopted rationing policy that was adopted under the WSIP Programmatic Environmental Impact Report (PEIR) in 2008. This policy assumes that rationing is approximately 12% as an
3 annual average over the 8.5-year design drought sequence. Over the 8.5 years of simulated drought, rationing is initially 0% and increases up to a maximum of 20%, with the annual average over the sequence being about 12%. (p. 23)
Resolution 08-0200, which codified the WSIP, does not mention the SFPUC’s “rationing policy.” Please explain how it was adopted.
5) Several BAWSCA agencies are requesting more water than their ISGs allow.
I looked at the BAWSCA agencies’ purchase request projections for 2045 (provided in 2021), and discovered that four agencies requested more water than they are entitled to under their Individual Supply Guarantees (ISG). Following are those agencies.
The total difference between ISGs and requests is 3.61 mgd. If this is correct, shouldn’t 3.61 mgd be subtracted from the 244 mgd cited as “Demands” in the AWS Plan?
6) The South Bay Purified Water Project would widen the water supply gap.
The first goal listed in Chapter 6 of the AWS Plan is to “Avoid widening the water supply gap.” (p. 111)
Most people who follow SFPUC issues have been under the impression the South Bay Purified Water Project was conceived to meet the current demand of 9 mgd from San Jose and Santa Clara. We assumed this was aimed at making the decision on whether to make the cities permanent customers without increasing BAWSCA’s Water Supply Assurance a little easier. It turns out this is not the case. The Plan states:
The cities of San Jose and Santa Clara are currently interruptible customers of the SFPUC and have requested permanent status, as discussed in Chapter 2 (Background). The two cities’ combined projected demand is 15.5 mgd for the planning horizon. They have requested a guaranteed supply from the SFPUC of 9 mgd (total). In order for the SFPUC to consider granting San Jose and Santa Clara permanent status and to minimize impacts to the existing permanent Wholesale Customers, the two cities must secure a reliable supply to meet their additional demands beyond the 9 mgd that they have requested as a guarantee. This project would produce 6.5 mgd of purified water to serve the needs of San Jose and Santa Clara beyond the cities’ purchases from the SFPUC, while augmenting RWS supplies by 3.5 mgd in dry years.
Implementation of this project would support the SFPUC’s decision to make San Jose and Santa Clara permanent customers. (Appendix A)
4 The project would produce 6.5 mgd to meet the additional requests from San Jose and San Jose in all years. In dry years, the project would produce an additional 3.5 mgd for use by the SFPUC. Assuming the SFPUC would use its 3.5 mgd to help meet the cities’ existing demands (9 mgd) from the RWS, the water supply gap would still be 5.5 mgd (9 mgd minus 3.5 mgd).
Making San Jose and Santa Clara permanent customers would widen the SFPUC’s water supply gap.
7) Which AWS projects are covered by the $4 billion to $10 billion cost estimate?
Does the $4 billion to $10 billion cost estimate cited on page 124 apply only to the AWS projects listed in Table 1? How many mgd would the $4 to $10 billion produce?
8) Will more than half of the initial AWS Plan funding be used for the Daly City Recycled Water Project?
I find it hard to believe that $116 million of the recommended $209 million for the AWS Project and Programmatic Recommendations would be used to develop only 0.7 mgd of recycled water in Daly City.
Am I reading the Plan correctly?
9) Why isn’t a partnership with the Irrigation Districts a top priority?
The AWS Plan makes it appear that the SFPUC and Irrigation Districts are holding collaboration on water supply projects in Stanislaus County hostage to the Tuolumne River Voluntary Agreement. Collaboration has tremendous potential, and failing to at least analyze opportunities in the AWS Plan is a lost opportunity. The Plan states:
These projects [joint projects with Irrigation Districts] are part of the Proposed Voluntary Agreement and are not the focus of the AWS Program. These projects may be included as part of future updates to the AWS Program. However, the results of Proposed Voluntary Agreement negotiations will determine how these actions may progress and potentially reduce the impact of the Bay-Delta Plan Amendment on SFPUC’s future water supply gap and are therefore an essential component of the SFPUC’s long-term water supply planning efforts. (p. 52)
In 2012, while attempting to gain public support for the proposed water transfer between the Modesto Irrigation District and the SFPUC, MID staff gave a presentation to their board titled “Comprehensive Water Resources Management Plan.” Staff identified 25,000 to 40,000 acre feet of water that could be saved if they had the funding for infrastructure improvements. It was proposed that the funding would come through the sale of water to the SFPUC. The total estimated cost of all the proposed improvements was $115 million.
The AWS Plan should at least analyze the potential for water conservation and groundwater recharge in the Irrigation Districts’ service areas.
5 Thank you for the opportunity to provide comments and raise questions.
Sincerely,
Peter Drekmeier
Policy Director
From: David Happs
To: Commission
Cc: Alternative Water Supply; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; White, Eileen@Waterboards; Solutions Not Sandbags; [email protected]; [email protected]
Subject: SFPUC Alternative Water Supply Comments
Date: Thursday, August 31, 2023 12:22:11 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.
SF Public Utilities Commissioners:
Thank you for the chance to comment on SFPUC's current plans to expand the water usage from the Tuolumne River and Delta instead of cooperating with the Bay-Delta Water Quality Control Plan. We find the approach SFPUC has had in many different legal areas confusing and harmful, not only to the environment, which SFPUC provides lip service to, but also to the pocket books of its ratepayers and wholesale customers as SFPUC's strategy of constantly fighting meaningful
environmental regulations has backfired many times, leading to more legal requirements placed on the ratepayers by courts then might have been achieved with reasonable negotiation, and collaboration. We also feel there have been many opportunities to provide more meaningful water recycling and groundwater improvements with SFPUC has not only ignored, but shown outright hostility to which should be a concern to the regulators, other bay area agencies, the citizens of California and most importantly, to the ratepayers who end up ultimately footing the bill for excessive and in some cases unwarranted infrastructure.
This overly litigious
approach is problematic not only on the water supply side, but also on the sewer side. SFPUC has been given many opportunities to incrementally improve its combined sewer system but instead fights for the right to discharge untreated sewage into SF Bay. Please note that although the SFPUC claims the combined sewer overflows are "treatment" this is clearly not the case at some of the larger sewage outfalls around SF where discharges contain large floatable sanitary
sewage debris as well as sediment which was supposed to be trapped in its system. But instead of finding ways to incrementally improve, it has spent $10 millions of dollars on attorneys to fight the US EPA and Regional Board attempting to avoid even marginal improvements. SFPUC has similarly
been spending $10millions on attorneys to fight
statewide collaboration on the Delta, which is likely to cause judges to eventually decide SFPUC should be penalized for its intransigence.
When looking at SFPUC's demands to expand its water supply and attempts to provide for "Alternatives", Californian's should be shocked to learn that SFPUC refuses to provide anything other then token "green" projects to redirect stormwater away from its combined sewer system and back into the ground to recharge the water table. SF has also avoided using it's existing infrastructure to distribute recycled water and instead continues to use Hetch Hetchy where even simply replumbing can greatly reduce it's reliance on water imports. Here is a quick list of low hanging fruit throughout SF that SFPUC has refused to deal with or outright ignored:
1. Downspout disconnect: Currently, San Francisco buildings are required by SF's plumbing code to channel their roof downspouts directly into the combined sewer, from which it is sent to the sewage treatment plant and in many storms a year get discharged into the Bay and ocean without any treatment other then token sedimentation. This is especially infuriating on the City's westside where any water that returns to the ground can help recharge the Westside Basin and help both SF and its neighbors use local groundwater. Removing the requirement from the building code, at least throughout the westside, should be a first step in improving not only the ocean's water quality but also improving our groundwater supplies. Simply channelizing the storm water from roofs and pavement areas such as the large concrete patios throughout the sunset into the roadway gutters and then providing simple infiltration chambers ahead of the sewer catch basins could be a simple starting point. Even if the water does end up back into the combined sewer system from the gutter, just the change in the timing of the flow due to the decreased speed would help improve both flooding and combined sewage discharges. SF's plumbing code requirement to directly connect roof drains is something that is very rare in the United States, in fact in the world. One of the "Only in San Francisco" things that SF officials have taken for granted instead of working out strategies to overcome.
2. Disconnect large areas specifically to recharge groundwater and replace SFPUC's use of Hetch Hetchy Water:
A. Lake Merced Area: Throughout the westside of SF, there are many opportunities to directly disconnect large facilities and paved areas from the combined sewer system and have the storm water return to the water table. For example, the area from Brotherhood Way to Eucalyptus Drive between 19th Ave and Lake Merced is approx. 960 acres covered mostly by parking lots and large institutional buildings (churches, shopping mall, schools, apt. complexes). Currently most of the water from these areas all drain directly into the combined sewer system. Although there was some effort by the developer of Park Merced to remove that area from combined sewage
and SFSU has also attempted to improve, mostly these are only token "green infrastructure" and do not incorporate the potential for large scale disconnect from the combined sewage system. Roadway drains surrounding Lake Merced could be retrofitted to allow decanted water to flow towards the lake during storms as Daly City's Vista Grande canal is (partially) doing today.
This is an incredible opportunity first brought up in
the 2008 Sewer System Master Plan but has since been ignored by SFPUC.
B. West Portal, down Trocadero Creek to Pine Lake: This area was identified to have a substantial green infrastructure project to address flooding but SFPUC chose to replumb the combined sewers there instead. Currently the Wawona and 15th area is prone to flooding due to the lack of adequate roadway conveyance to handle the flows that exceed the combined sewer system capacity. The project could have done a substantial roadway and rooftop disconnect upstream and allowed the rain to flow into the low areas of Tocadero Creek, with smaller storms infiltrating in the creek bed and larger overflow events eventually leading to Pine Lake.
Currently, when local groundwater tables are lower, Hetch Hetchy water is used to supplement Pine Lake. Pine Lake suffers because the primary source of water has historically been springs immediately east of 19th Ave. When 19th Ave was built in the early 1900s, the roadway embankment blocked the flows from that spring. Instead of putting a culvert to maintain the historical source of Pine Lake, the spring flows were routed to a sewer catchbasin at the bottom of the sump created east of 19th Ave. This means that for the last 120 years, SF has been dumping the source of Pine Lake out the sewers and instead filling Pine Lake with Hetch Hetchy water.
C. Laguna Honda/Twin Peaks: the Mid Town Terrace, Forest Knolls and Laguna Honda Hospital areas are all upstream of the Laguna Honda reservoir. These areas could have the downspouts easily disconnected (most are external), and along with flows from the roadways, sent into the low sump area south of Clarendon and then infiltrating and overflowing into the old Laguna Honda Reservoir which would be used as a buffer for larger storms, allowing the water to slowly infiltrate back into the ground. It is likely this area is actually upstream of the Lobos Creek ground water basin in which case it would benefit the Presidio water supply as well as reduce SFPUC reliance on Hetch Hetchy.
D. Various other local opportunities: Probably the easiest opportunity which has been ignored by SFPUC is to disconnect most of the street drains along the sides of Golden Gate Park and redirect the surface water into the Park.
3. Recycled Water:
Recycling waste water not only reduces reliance on supplies from Hetch Hetchy, but also reduces the impacts of sewage discharges into the bay, which are currently the major contributor to the harmful algal blooms killing fish and wildlife in the Bay. Opportunites include:
A. Provide recycled water to Mission Bay properties: SF required the Mission Bay developers to install "purple pipe" to use recycled water for flushing and irrigation but has never actually provided them with water. This has lead to frustration by the excessive costs and lawsuits by the builders. One of the interesting points about this is there already is an existing, unused 10" force main that goes from the Southeast Sewer Treatment Plant(SEP) along 7th St, right next to Mission Bay. This pipe used to carry sewage sludge from the North Point Plant near Pier 39, down to the digesters at the SEP in Bayview. Along with Mission Bay users, there are numerous other potential recycled water uses nearby the force main alignment including the SF Downtown Steam loop, parks, etc. Instead of repurposing that pipe, SF has chosen to fight the developers even though SF itself was the one requiring "purple pipes".
B. AWSS System: SF is one of the few cities in the world that have are "double plumbed" with a separate water distribution network for high pressure fire fighting. This system runs throughout much of the northern and eastern parts of SF and there are plans to expand more into the southwest neighborhoods. with modest changes and institutional controls such as advising firemen to not drink from their hoses (which they probably shouldn't do anyway) this system could be using "title 22" reclaimed water instead of Hetch Hetchy. With simple pressure regulators at the various users, water from this system could be provided for irrigation and other reclaimed waste water uses.
https://sfpuc.org/programs/future-water-supply-planning/alternative-water-supplies https://water.ca.gov/-/media/DWR-Website/Web-Pages/Programs/Groundwater- Management/Bulletin-118/Files/2003-Basin-Descriptions/2_035_Westside.pdf