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
San Francisco Public Utilities Commission
Correspondence Log
January 9, 2024 through January 16, 2024
Date Received From Subject
January 9, 2024 Lalitha Visveswarnan Concerns Regarding ACRCD’s Management of Sunol AgPark
January 13, 2024 Spreck Rosekrans Restore Hetch Hetchy Comments on the Water Quality Control Plan for the
San Francisco Bay/Sacramento–San Joaquin
Delta Estuary
January 16, 2024 Lalitha Visveswarnan Formal Complaint Regarding Unclaimed Certified Mail and Grievance Handling by
ACRCD
Dave Warner Possible Questions for SFPUC Deputy CFO
From: Lalitha Visveswaran
To: Commission
Cc: Dawson, Amy L; Info; Jellicles Farm; jellicles farm Subject: Concerns Regarding ACRCD’s Management of Sunol AgPark Date: Tuesday, January 9, 2024 12:04:21 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.
To: San Francisco Public Utilities Commission
CC: Amy Dawson, SFPUC
Dear San Francisco Public Utilities Commission,
I am writing to express my concerns regarding the Alameda County Resource Conservation District’s (ACRCD) management of Sunol AgPark. Based on my experiences, I believe that ACRCD may not be the most suitable entity to hold the lease for this valuable agricultural space.
During my decade-long tenure as a licensed farmer at Sunol AgPark, I encountered several issues under ACRCD’s management that significantly impacted my operations and well- being.
The issues that would need to be investigated include:
1. Discriminatory Practices: Particularly against solo female farmers, impacting an inclusive and fair working environment.
2. Lack of Support and Harassment During Medical Recuperation: Neglecting the needs of farmers during critical periods of health recovery.
3. Unilateral Contract Modifications: Making changes to agreements without proper consent or discussion.
4. Retaliatory Actions: Including the non-renewal of farming licenses in response to raised grievances.
5. Procedural Irregularities and Ethical Concerns: As evidenced in management decisions and interactions with farmers.
6. Financial and Emotional Impact: The consequent financial loss, emotional distress, and reputational damage to affected farmers.
7. Lack of Responsiveness: ACRCD’s failure to engage in discussions or mediation, and their Board of Directors’ non-acknowledgment of complaints, indicating a disregard for resolving issues amicably.
This situation has unfortunately led to the termination of my decade-long farming career and significant financial loss, particularly due to investments in equipment made during the COVID-19 lockdown in anticipation of future farming activities.
Given these concerns, I urge the SFPUC to reconsider ACRCD’s lease and to initiate an investigation into their management practices.
I respectfully request SFPUC’s assistance in investigating and resolving these issues to address the wrongs done to me by ACRCD and to ensure fair practices in the future management of Sunol AgPark.
Ensuring that Sunol AgPark is managed by an entity that upholds principles of fairness, support for farmers, and adherence to proper procedures is crucial for the success of this community resource.
I am available to discuss these concerns in more detail and provide evidence to support these claims, should the SFPUC find it necessary as part of its investigation into ACRCD’s management practices.
Thank you for your attention to this matter.
Sincerely,
Lalitha Visveswaran
Jellicles Farm
Restore Hetch Hetchy Comments on the
Water Quality Control Plan for the San Francisco Bay/Sacramento–San Joaquin Delta Estuary
January 13, 2024
Restore Hetch Hetchy Comments
on the Water Quality Control Plan for the
San Francisco Bay/Sacramento–San Joaquin Delta Estuary
January 13, 2024
The concept of V oluntary Agreements as alternative solutions to a flow-only approach provides the State Water Board the opportunity to adopt an efficient and effective Bay-Delta Plan using a wide variety of tools. Habitat restoration, monitoring and dedicated funding streams are, in addition to flows, appropriate tools indeed. The State Water Board should, however, use this opportunity to encourage water agencies to maximize the beneficial uses of available water supplies in other ways, including recharge of groundwater basins in wet years.
Improving groundwater recharge would be particularly valuable for agricultural and urban communities which rely on supplies in the Tuolumne River watershed as well as for the environment. Low-cost water banking could be dedicated to several purposes: (1) supplementing supplies for cities and farms, (2) providing additional instream flows, and/or (3) obviating the need to retain a reservoir flooding Yosemite National Park’s Hetch Hetchy Valley.
The State Water Board should approve a V A for the Tuolumne River only if water agencies managing the river’s supplies demonstrate a substantially expanded program to recharge groundwater.
Restore Hetch Hetchy’s comments herein pertain specifically to the Tuolumne River, but the principles of sensible groundwater management should be applied throughout the state. Certainly, California’s Sustainable Groundwater Management Act, passed in 2014, will provide enormous long-term benefits throughout the State and, indeed, will bring groundwater basins into balance. SGMA, however, does not require recharging depleted basins, nor does it encourage investment in effective groundwater management from water agencies which physically lie outside a Groundwater Sustainability Agency even if their surface supplies originate from within the GSA’s watershed.
BOARD OF DIRECTORS
Roger Williams, Chair
Virginia Johannessen, Vice- Chair
Peter Van Kuran, Treasurer
Mark Palley, Secretary
Kathy Bowler
Mark Cederborg
James Fousekis
Ann Hayden
Lance Olson
Craig Reynolds
Lucho Rivera
Mecia Serafino
Melanie Webber
STAFF
Spreck Rosekrans
Executive Director
Julene Freitas
Office Manager
Marissa Leonard
Engagement and Development
Director
3286 Adeline St. Suite 7
Berkeley, California 94703
510.893.3400
Tax ID # 77-0551533
Restore Hetch Hetchy Comments on the
Water Quality Control Plan for the San Francisco Bay/Sacramento–San Joaquin Delta Estuary January 13, 2024
Other than to expect and demand that water agencies improve groundwater recharge programs, Restore Hetch Hetchy does not take a position on how the State Water Board should rule with respect to the specific elements included in the proposed Voluntary Agreements.
Groundwater recharge on the Tuolumne River is much less than on the San Joaquin River.
The Tuolumne River is very close in volume and character to the San Joaquin River (i.e. natural flows into Don Pedro Reservoir are similar to those into Millerton Reservoir). Yet while the Tuolumne River includes far greater amounts of surface storage, it “spills” more often and in far greater magnitude. For example, in 2005 and 2006 alone, flows on the Tuolumne River exceeded those on the San Joaquin River by more than 1,500,000 acre-feet. While some of this water no doubt provided instream benefits, much of this additional flow could have been better redirected to groundwater recharge for any or all of the uses outlined above. See Attachment 1, Comparing Hydrology and Water Management on the Tuolumne and San Joaquin Rivers.
San Francisco does not bank groundwater in the Central Valley.
Unlike many urban water suppliers in California, the San Francisco Public Utilities Commission has not engaged in groundwater banking in the Central Valley, but is instead considering a series of projects that would provide lesser supply at far greater cost. The necessary institutional cooperation, between the SFPUC, the Turlock and Modesto Irrigation Districts, and perhaps the Eastside Water District, is absent. This absence of cooperation is especially striking in comparison to the groundwater banking agreements
put in place over the past several decades between so
many agencies – especially customers of the State
Water Project (see Attachment 2, page 4, of
Yosemite's Opportunity: Options For Replacing
Hetch Hetchy Reservoir).
Sincerely,
Spreck Rosekrans
Executive Director
Cc: Dennis Herrera, San Francisco Public Utilities Commission Nicole Sandkulla, Bay Area Water Supply and Conservation Agency Michelle Reimers, Turlock Irrigation District
Jimi Netniss, Modesto Irrigation District
Banking opportunities in Eastside Water District have
long been apparent - a 1993 study commissioned by the
SFPUC identified the location as ideal but institutionally complex. Sadly, progress has not been made.
Comparing Hydrology and Water
Management on the Tuolumne and
San Joaquin Rivers
Compiled by Restore Hetch Hetchy
1 Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 1 San Joaquin and Tuolumne Rivers
Tuolumne River
San Joaquin River
2 Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 1 The Tuolumne and San Joaquin are very similar in flow volume 3 Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 1 0 500,000
1,000,000
1,500,000
2,000,000
2,500,000
3,000,000
Tuolumne River Reservoirs San Joaquin River Reservoirs
Florence
Huntington
Mammoth Pool
Shaver
Millerton
Eleanor
Cherry
Hetch Hetchy
Don Pedro
Tuolumne and San Joaquin Watershed Reservoir Capacities (acre-feet)
The Tuolumne Watershed has more than twice as much
surface storage
4 Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 1 5 0
500,000
1,000,000
1,500,000
2,000,000
2,500,000
3,000,000
3,500,000
2001 2002 2003 2004 2005 2006 2007 2008 2009
Tuolumne River below Don Pedro
Modesto & Turlock IDs
San Francisco
Full Natural Flow
Tuolumne River Flow Distribution: 2001-2009
(acre-feet)
Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 1 6 0
500,000
1,000,000
1,500,000
2,000,000
2,500,000
3,000,000
3,500,000
2001 2002 2003 2004 2005 2006 2007 2008 2009
San Joaquin River flow below Friant
Friant Kern Canal
Madera Canal
Full Natural Flow
San Joaquin River Flow Distribution:
2001-2009
Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 1 7 0
500,000
1,000,000
1,500,000
2,000,000
2,500,000
3,000,000
3,500,000
2001 2002 2003 2004 2005 2006 2007 2008 2009
Tuolumne River below Don Pedro
Modesto & Turlock IDs
San Francisco
San Joaquin River flow below Friant
Friant Kern Canal
Madera Canal
Tuolumne and San Joaquin River Flow Distribution Comparison (acre-feet)
San Joaquin River
diversions to canals
exceeded Tuolumne
River Flow diversions
by 831,000 af in 2005
and 643,000 af in
2006 – almost 1.5
MAF over two years!
Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 1 Two answers:
• Much of the Tuolumne’s storage is managed
by San Francisco – cities have lower levels of
demand but can little tolerate shortages
• Most of the San Joaquin’s flow is diverted into
Kern County where agreements are in place to
recharge groundwater basins in wet years
8 Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 1 Yosemite's Opportunity
Options For Replacing Hetch Hetchy Reservoir
“The ultimate removal of the reservoir would
make possible the restoration of the Valley a few
miles from Yosemite Valley and, amazingly, a
near twin of that extraordinary gift of nature.
In the case of Hetch Hetchy, it isn’t that San
Francisco’s water supply now stored at the
O’Shaughnessy Dam will be lost. Rather,
it would be stored at existing dams
downstream and perhaps off-stream or
in groundwater basins.”
— Carl Boronkay
Former General manaGer oF the
metropolitan Water DistriCt oF southern CaliFornia
O’ShaughneSSy Dam anD
hetch hetchy ReSeRvOiR
Hetch Hetchy Reservoir is a storage tank — one of four reservoirs on the Tuolumne River and one of nine in San Francisco’s Regional Water System. Hetch Hetchy is not a source of water.
The reservoir can be replaced and Hetch Hetchy Valley restored while continuing to meet 100% of the water and power needs of every community that depends on the Tuolumne River.
California water agencies have found many ways to reverse environmental damage, restoring ecosystems and wildlife populations on rivers and in wetlands — in the Central Valley, at Mono Lake, in the Bay-Delta and on the Trinity River. The same can be done for Yosemite’s Hetch Hetchy Valley.
The recent investments that California’s cities have made in groundwater, recycling and local surface storage would replace Hetch Hetchy Reservoir more than 15 times over . The San Francisco Public Utilities Commission has the opportunity to pursue any or all of these technologies.
Customer Demand
Annual Supply
(Average)
Annual Supply
(Drought)
Storage
Photo: Level Par
Photo: Tim Connor
YOSEMITE'S OPPORTUNITY Options For Replacing Hetch Hetchy Reservoir 1 Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 2 The San Francisco Public Utilities Commission delivers about 250,000 acre-feet1 of water annually. Flows in the Tuolumne River are more than adequate to meet that demand in
most years.2
In dry years, water is withdrawn from storage. The driest period on record for San Francisco’s Regional Water System is the 6-year drought from 1987–1992, when the Tuolumne River provided only 151,000 acre-feet per year.
To make up the shortage in a repeat of that drought lasting six years, or even a worse one, the SFPUC has invested in multiple storage projects to meet customer needs (see Figure 1).
The San Francisco Public Utilities Commission (SFPUC) performs an essential public service by delivering water to homes and businesses in San Francisco as well as to other Bay Area communities. Hetch Hetchy Reservoir is an important component of San Francisco’s Regional Water System — but it can be fully replaced, and then some, with alternative investments.
The San Francisco
Regional Water System
Customer Demand
Annual Supply
(Average)
Annual Supply
(Drought)
Storage
0 500,000 1,000,000 2,000,0001,500,000
Don Pedro Water Bank Bay AreaCherry-Eleanor Tuolumne RiverHetch Hetchy Bay Area Watersheds 1 One acre-foot equals 325,851 gallons, roughly enough to supply two households for a year. 2 References for this document can be found at hetchhetchy.org/yosemites-opportunity/ 3 Like all water agencies, the SFPUC also increases reliability with demand-side programs — by encouraging conservation and efficient use through a variety of regulations and incentives.
FIGURE 1
San Francisco Regional Water System: Demand, Annual Supply & Storage (acre-feet) Replacing Hetch Hetchy Reservoir requires additional
investments.3 Other urban water agencies throughout
California are actively continuing to invest in groundwater storage, local surface storage, and recycling. The SFPUC can and should do the same.
2 YOSEMITE'S OPPORTUNITY Options For Replacing Hetch Hetchy Reservoir Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 2 RiveR anD WetlanD ReStORatiOn
Californians have supported ecosystem and wildlife renewal throughout the state, including restoration of rivers and wetlands in the Central Valley, at Mono Lake, in the Bay-Delta and on the Trinity River. Affected water agencies have found ways to invest in additional supplies and/or use water more efficiently.
Restoration of Hetch Hetchy Valley in Yosemite National Park would require system improvements to replace 360,000 acre-feet of storage (or 60,000 acre-feet each year over a 6-year drought). Water flowing through Hetch Hetchy Valley would be used or captured downstream — it would not go to waste.
Mono Lake
Trinity &
Lower Klamath Rivers
Upper
Sacramento River
Gray Lodge
Wildlife Area
San Luis
National Wildlife
Refuge Complex
Los Banos
Wildlife Area
Kern National
Wildlife Refuge
Volta
Wildlife Area
Grassland Resource
Conservation District
Merced National
Wildlife Refuge
Pixley National
Wildlife Refuge
Mendota Wildlife Area
North Grasslands
Wildlife Area
Sacramento
National Wildlife
Refuge Complex
Sacramento NWR
Delevan NWR
Colusa NWR
Sutter NWR
San Luis Unit
West Bear Creek Unit
East Bear Creek Unit
Kesterson Unit
Freitas Unit
China Island Unit
Salt Slough Unit
Bay Delta
The Central Valley Project Improvement
Act, enacted by Congress in 1992, added
250,000 acre-feet per year to wildlife
refuges in the Central Valley.
The 1994 Bay-Delta Accord, an agreement
to protect endangered estuarine /f_ish
including long/f_in smelt, reduces
diversions to cities and farms by 316,000
acre-feet per year below previous levels.
The Trinity River Restoration program,
jointly developed by the federal
government and the Hoopa Valley Tribe,
restores /f_low to the river, reducing
diversions to cities and farms by 83,000
acre-feet per year.
Court rulings in 2007 and 2008 to protect
endangered salmon and other species
have reduced diversions to cities and
farms by 980,000 acre-feet per year.
In 1994, the State Water Board ruled
that the Public Trust Doctrine required
additional in/f_low to Mono Lake,
resulting in reduced diversions to Los
Angeles by 46,000 acre-feet per year.
San Jose
Sacramento
Los Angeles
San Diego
Y osemite National Park
Hetch Hetchy
San Francisco
YOSEMITE'S OPPORTUNITY Options For Replacing Hetch Hetchy Reservoir 3 Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 2 califORnia gROunDWateR inveStmentS
Many California cities have agreements with agricultural water agencies to recharge and manage groundwater, allowing aquifers to be used as "banks" to exchange supplies using California's vast network of canals. California’s “Sustainable Groundwater Management Act”, passed in 2014, requires long-term sustainability throughout the state and provides incentives for additional agreements.
Banking San Francisco’s excess water in aquifers in the eastern portions of the Turlock and Modesto Irrigation Districts and in the Eastside Water District would replace the storage function of Hetch Hetchy Reservoir.
California
Aqueduct
Santa Clara Valley
Water District
Alameda County
Water District
Modesto
Irrigation District
Turlock
Irrigation District
Eastside
Water District
EBMUD
Metropolitan Water District of
Southern California
Mojave Water Agency
Antelope Valley
Water District
Semitropic
Water Storage District
Arvin-Edison
Water Storage District
Kern Delta
Water District
The Metropolitan Water District of
Southern California, serving most of
urban southern California, manages
212,000 acre-feet of groundwater
storage within its service territory, and
banks 350,000 acre-feet in Semitropic,
350,000 acre-feet in Arvin Edison,
250,000 acre-feet in Kern Delta, 330,000
acre-feet in Mojave and 30,000
acre-feet in Antelope Valley.
Examples of similar programs abound.
Several Bay Area water districts bank
groundwater in Semitropic, including
Santa Clara Valley (350,000 acre-feet),
Alameda County (150,000 acre-feet)
and Zone 7 (65,000 acre-feet).
Operating a groundwater bank in
Stanislaus County in conjunction with San
Francisco’s surface storage facilities
would eliminate the need for Hetch
Hetchy Reservoir and allow Hetch Hetchy
Valley in Yosemite National Park to be
restored. Groundwater plans in these
areas show unsustainable pumping rates
that limit farm production over time. Wet
year recharge with San Francisco’s water
would provide bene/f_its to all parties.
Geology and proximity to the California
Aqueduct make Kern County an ideal site
for groundwater recharge. Urban water
agencies bank groundwater in Semitropic
(970,500 acre-feet), Arvin Edison
(350,000 acre-feet), Kern Delta (250,000
acre-feet) and other aquifers.
Option available to the San Francisco
Public Utilities Commission
San Francisco
San Jose
Sacramento
Los Angeles
San Diego
Y osemite
National Park
San Francisco
4 YOSEMITE'S OPPORTUNITY Options For Replacing Hetch Hetchy Reservoir Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 2 Recycling WateR in califORnia
Increases in demand, limits on groundwater pumping and worries of drought have led to a boom in wastewater recycling projects — in California as well as other states and countries.
While Orange County has long been a recycling leader, others are catching up quickly. Most of California’s large urban agencies have initiated robust recycling plans, but so far San Francisco has not. Recycled water provides a reliable, drought-proof supply, and the enhanced treatment process reduces pollution to rivers, bays and beaches.
Replacing the water storage function of Hetch Hetchy Reservoir could be accomplished by recycling 60,000 acre-feet per year (360,000 acre-feet over a 6-year drought).
San Diego’s PureWater program is
scheduled to provide a third of its total
supply (83,000 acre-feet per year, or
498,000 acre-feet over a 6-year
drought), and will also reduce pollution
along its famous beaches. San Diego will
store its recycled water locally in
Miramar and San Vicente Reservoirs.
The Orange County Water District
recycling plant is the largest in the world.
It presently recycles 100,000,000 gallons
per day — soon to be increased to
130,000,000 gallons per day (146,000
acre-feet per year or 876,000 acre-feet
over a 6-year drought). After a multi-step
treatment process which includes
nano/f_iltration (shown above), the water
is stored underground.
The San Francisco Public Utilities
Commission reports a capacity to recycle
49,000 acre-feet per year ( 294,000
acre-feet over a 6-year drought) at its water
treatment plants but has no plans to move
forward at this time. San Francisco’s
wholesale customers, who use 2/3 of the
system’s water, operate their own treatment
plants and have similar opportunities.
The Santa Clara Valley Water District plans
to recycle 40,000 acre-feet per year
(240,000 acre-feet over a 6-year drought)
by 2035, about 10% of its supply.
Governor Newsom praises the Los
Angeles County Sanitation District’s
recycling plan, describing it as a model
for others to follow. When completed, the
plant will produce 168,000 acre-feet per
year of recycled water (1,008,000
acre-feet over a 6-year drought).
Option available to the San Francisco
Public Utilities Commission
Orange County
Water District
Sanitation District of
Los Angeles
San Diego
Water Agency
Santa Clara Valley
Water District
San Diego
Water Agency
Sacramento
Los Angeles
San Diego
San Jose
Y osemite
National Park
San Francisco
San Francisco
YOSEMITE'S OPPORTUNITY Options For Replacing Hetch Hetchy Reservoir 5 Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 2 DevelOping lOcal StORage in califORnia
Today, most of California's major rivers are either already dammed, protected by law, or too remote to be economically developed.
Many water agencies have, however, found advantage in building “off stream” reservoirs close to their service areas to assure supply reliability during dry years. These reservoirs are built in canyons with little natural flow, avoiding the damage of damming a large river.
San Francisco has long-term plans to enlarge Calaveras Reservoir, allowing it to hold imported Tuolumne River supplies as well as local runoff. Enlarging Calaveras would replace 90% of the 360,000 acre-feet of water storage that Hetch Hetchy Reservoir provides.
In 2009, San Diego enlarged San
Vicente Reservoir to 242,000 acre-feet.
It not only holds runoff from San
Vicente Creek, but also water supplies
diverted from the Colorado River.
Diamond Valley Reservoir, /f_irst /f_illed in
2003, holds up to 800,000 acre-feet of
water for customers of the Metropolitan
Water District of Southern California.
Above, Metropolitan General Manager
Jeff Kightlinger dedicates a dam at
Diamond Valley in honor of his visionary
predecessor, Carl Boronkay. Boronkay
called Hetch Hetchy Valley a “national
treasure” and, after retirement, joined the
Restore Hetch Hetchy Board of Advisors.
Calaveras Reservoir, the largest of the San
Francisco Public Utilities Commission’s Bay
Area reservoirs, was rebuilt in 2019 and
presently holds 97,000 acre-feet. The
SFPUC has plans to increase its capacity by
323,000 acre-feet (almost the volume of
Hetch Hetchy Reservoir). Some of the
foundation work to support this larger
project has already been accomplished.
Los Vaqueros Reservoir, initially
constructed by the Contra Costa Water
District in 1998, was expanded in 2012 to
hold 160,0000 acre-feet of water. It will
be expanded further, and San Francisco
should consider taking part in the project.
Option available to the San Francisco
Public Utilities Commission
Metropolitan Water District of
Southern California
Diamond Valley
Reservoir
San Diego County
Water Authority
San Vicente
Reservoir
Contra Costa
Water District
Los Vaqueros
Reservoir
Calaveras
Reservoir
San Jose
Sacramento
Los Angeles
San Diego
Y osemite
National Park
San Francisco
San Francisco
6 YOSEMITE'S OPPORTUNITY Options For Replacing Hetch Hetchy Reservoir Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 2 FIGURE 2
Summary of Recent and Ongoing Water Storage and Supply Projects for Cities in California
AVAILABLE WATER SUPPLY OVER A SIX-YEAR DROUGHT (ACRE-FEET) Surface Storage
Recycling
Groundwater
Needed to Replace
Hetch Hetchy Reservoir
0 Contra Costa
San Francisco
San Diego
Southern California
Southern California
Orange County
Valley Water
San Diego
Los Angeles
Bay Area
200,000 400,000 600,000 800,000 1,000,000 1,200,000
Recent investments by California’s cities in groundwater, recycling and local surface storage would replace Hetch Hetchy Reservoir more than 15 times over. The San Francisco Public Utilities Commission has the opportunity to pursue any or all of these technologies. aDDitiOnal neceSSaRy impROvementS
While water storage and/or supply are the most obvious system improvements necessary to restore Hetch Hetchy Valley in Yosemite National Park, other steps must be taken as well. • Replace 350 gigawatt-hours of electricity that will be lost when water from Hetch Hetchy Reservoir will no longer
generate hydropower at the Kirkwood Powerhouse in
summer and fall;
• Expand the Sunol Water Treatment Plant so the San
Francisco Regional Water System has capacity to filter all system supplies; and
• Build new interties to connect Cherry and/or Don
Pedro Reservoir to existing pipelines crossing the San
Joaquin Valley.
Plans to remove the reservoir while maintaining water and power supplies have been proposed in a variety of reports by government agencies, environmental groups and academics.
The estimated costs in the various reports of restoring Hetch Hetchy Valley without loss of water or power have been the subject of public disagreement but have never been independently reviewed.
Restore Hetch Hetchy’s most recent cost estimate, published in a 2015 Superior Court filing, projects a cost of 2 billion dollars over a fifty year period, including 199 million dollars for additional interties, 372 million dollars for water supply, 387 million dollars for water treatment, 669 million dollars for renewable electric power, and 374 million dollars for modifying O’Shaughnessy Dam.
cRitical StakehOlDeRS
The Turlock and Modesto Irrigation Districts are intertwined with the SFPUC on the Tuolumne River and at Don Pedro Reservoir. A restoration plan must guarantee, at a minimum, that the Districts suffer no loss of water supply or hydropower production.
Tribal communities were the original inhabitants of Hetch Hetchy. Indigenous peoples must be consulted in all stages of restoration and, if they desire, should be involved in the future management of the valley.
Rafters and kayakers flock to the Tuolumne River for its world-class whitewater. A restoration plan should assure recreational flows are protected.
The Bay-Delta Plan — Restore Hetch Hetchy supports the State’s ongoing effort to improve flows and habitat for fish and wildlife on the Tuolumne River below Don Pedro Reservoir, as well as downstream into the Bay-Delta.
Photo: Sierra Mac River Trips
YOSEMITE'S OPPORTUNITY Options For Replacing Hetch Hetchy Reservoir 7 Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 2 Restore Hetch Hetchy urges the
San Francisco Public Utilities Commission
to pursue system improvements so
Hetch Hetchy Reservoir can be replaced
without any loss of water supply or electric
power production.
Hetch Hetchy, Yosemite Valley's lost twin, can be returned to its natural splendor; a majestic glacier-carved valley with towering cliffs and waterfalls where river and wildlife run free.
Hetch Hetchy can be a new kind of national park, with limited development, an improved visitor experience, shared stewardship with Native peoples, and permanent protection of its natural and cultural heritage for future generations.
RESTORE HETCH HETCHY
BOARD OF DIRECTORS
Roger Williams, Chairman
Virginia Johannessen, Vice-Chairman
Peter Van Kuran, Treasurer
Mark Palley, Secretary
Kathy Bowler | Mark Cederborg | James Fousekis
Ann Hayden | Rex Hime | Lance Olson | Craig Reynolds
Lucho Rivera | Mecia Serafino | Melanie Webber
STAFF
Spreck Rosekrans, Executive Director
Julene Freitas, Office Manager
Mike Gaffney, Community Outreach Liaison
3286 Adeline St., Suite 7, Berkeley, CA 94703 | 510.893.3400 | Tax ID # 77-0551533 HetchHetchy.org
Yosemite's Opportunity
Options For Replacing Hetch Hetchy Reservoir
Restore Hetch Hetchy urges
San Francisco, the State of California and
the United States Congress to return
Hetch Hetchy Valley to all people.
“The Bay Area does not need Hetch Hetchy
reservoir to continue delivery of high-quality
water from the Tuolumne River.”
— Jay lunD
proFessor oF Civil anD environmental enGineerinG anD
Co-DireCtor oF the Center For WatersheD sCienCes at uC Davis Painting: Tom Coyle
8 YOSEMITE'S OPPORTUNITY Options For Replacing Hetch Hetchy Reservoir Restore Hetch Hetchy Comments on Bay-Delta Plan, Jan 13, 2024 - Attachment 2 From: Jellicles Farm
To: Karen Sweet; Commission; Dawson, Amy L
Cc: 1 Haubert; [email protected]; Lalitha Visveswaran; jellicles farm Subject: Formal Complaint Regarding Unclaimed Certified Mail and Grievance Handling by ACRCD Date: Tuesday, January 16, 2024 5:14:10 PM
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To Whom It May Concern,
I am writing to file a formal complaint about the Alameda County Resource Conservation District (ACRCD) and their handling of a significant grievance matter pertaining to the unfair non-renewal of my farming license at Sunol AgPark.
Complaint Overview:
I recently sent a certified letter(dated Nov 9, 2023) to ACRCD, which contained a grievance about their conduct and decision-making process regarding the non-renewal of my farm license at Sunol AgPark.
To my concern, this certified mail was unclaimed by ACRCD and returned to me(Jan 16, 2024), indicating a refusal to acknowledge or address my grievance.
Background of the Grievance Mail:
Before sending the certified mail, I had sent a copy of the grievance letter via email to ACRCD.
Therefore, they were aware of its contents and the nature of the grievances it contained. The decision to not claim the certified letter, despite this prior knowledge, clearly implies a deliberate failure on ACRCD’s part to formally acknowledge and address the grievance.
This grievance was never acknowledged despite multiple email communications suggesting a rejection and disregard of due process.
This is especially concerning given that all previous certified mails sent to ACRCD via USPS have been claimed and acknowledged.
Implications of ACRCD’s Actions:
1. Failure to Acknowledge Grievance: As a public agency and a leaseholder of the San Francisco Public Utilities Commission (SFPUC) , ACRCD has a responsibility to responsibly manage and respond to grievances. Their failure to claim and acknowledge my certified mail raises serious concerns about their commitment to transparency and accountability.
2. Impact on My Rights: This action directly impacts my ability to seek fair resolution and justice, as my attempts to communicate and resolve this matter have been repeatedly ignored.
3. Concerns About Public Agency Conduct: ACRCD’s approach to handling this grievance contradicts the expected standards of operation for a public agency, especially in matters involving the livelihoods and rights of individuals.
Request for Intervention and Investigation:
Given the seriousness of this matter, I am seeking intervention and a thorough investigation by relevant authorities, including the Board of Supervisors, SFPUC, and higher officials overseeing public agencies and special districts.
I urge the respective authorities to:
- Investigate ACRCD’s handling of my grievance and their general procedures for addressing public concerns. - Ensure that ACRCD adheres to proper standards of transparency and accountability in their role as a public agency and leaseholder. - Provide guidance or intervention to address the failure in acknowledging my grievances and to facilitate a fair resolution.
Enclosures and Availability:
Enclosed with this letter, you will find copies of the returned certified mail and other relevant documentation. I am available for further discussion or to provide additional information as needed.
I appreciate your prompt attention to this matter and look forward to your support in rectifying this situation and upholding the standards of public agency conduct.
Sincerely,
Lalitha Visveswaran
Jellicles Farm.
Cc: Amy Dawson SFPUC, BOS District 1, SFPUC Commission
January 15, 2024
Re: CAC: Possible Questions for SFPUC Deputy CFO
Dear Citizens Advisory Committee Members,
Thank you for your service and thank you for having Laura Busch, the SFPUC Deputy CFO present to you at this Tuesday’s meeting. As much as Ms. Busch may say otherwise, the SFPUC is in a financially risky situation, as would be any organization with declining water sales and increasing spending. As you know, water demand, particularly for San Francisco, has been on a 30 year decline. The 10 year capital plan has jumped, previously up to the $8.8 billion. $8.8 billion was a stunning number. You may recall, the Water System Improvement Program, approved back in 2008 was a $4.8 billion plan (plus debt service), that at the time was shockingly large. I believe it also led to the formation of the CAC.
But now previewing Ms. Busch’s presentation, the SFPUC is proposing to increase the 10 year Capital Plan another $3 billion, to $11.8 billion, and this does not count last year’s capital spending, which was projected to be $1.4 billion, making the 11 years a total of $13.2 billion.
And still basic financial analysis is missing.
Potential questions to ask:
1) How does each $1 billion of capital spending impact rates? More specifically, how much would combined San Francisco water, sewer and stormwater rates go down if capital spending were reduced by $1 billion? Knowing this information helps decision makers understand the relationship between rates and capital spending. It is surprising that such information has not been presented to commissioners.
2) What demand projections were used for projecting San Francisco water and sewer rates? This has been presented, but the question is added here as a precursor to question 3 below. The chart below was taken from the February 14, 2023 budg et
presentation, where it appears that flat demand was assumed. Flat demand is risky as for the last 30 years demand has been declining.
3) What would water rates look like should water demand continue its downward decline and using the latest San Francisco population projections from the California department of finance? By my calculation 2045 San Francisco water demand wou ld be 39 mgd, 28% below demand projected in the above chart. Here are the results I came up with, but the SFPUC should do its own analysis. This is important information to understand the rates risk associated with lower demand. It is surprising that such information has not been presented to commissioners. Clearly a $605 average monthly household water and sewer bill would well exceed any affordability measure.
4) Is the $11.8 billion a complete picture of capital ne eds over the next 10 years? If not, what does the complete picture look like and how much should we set aside for these unnamed projects? My understanding is that this 10 year capital plan ha s little to no spending on alternative water supplies, despite that the Alternative Water Supply Plan is based on a 92 mgd shortfall. It’s important to understand the full picture for capital planning purposes. Leaving things out exacerbates financial management c hallenges in the future.
5) 60% of the 10 year capital plan is spent in the first 5 years— how would rates change if the spending was spread more evenly over the 10 years? It’s important to understand the time pressure on spending sooner and the financial impact of the time pressure.
6) How would rates change if the 10 year capital plan wa s instead spread out over 15 years? Often the retort to such a question is, which project would you delay? But that’s not our job. That’s a question for a professional manager. If a professional manager had to spread capital investment over 15 years, how would he or she do it? Instead we’re trying to assess how risk has been analyzed for capital spending (and alternatives) relative to rates and against the risk of declining demand. And right now basic information is missing, which is troublesome.
Feb 14'23 chart Nov 28'23 chart Jan 16'24 chart
Lower
demand*
Current combined average bill 138$ 133$ 142$ 142$ +10 years combined average bill 224$ 287$ 308$ +20 years combined average bill 305$ 406$ 436$ 605$ Growth over 10 years Stated 90% 116% 117%
Growth over 20 years St ated 164% 205% 207% 326%
* Assumes demand of 39 mgd rather than 54.1 mgd.
San Francisco Projected Average Monthly Water and Sewer Bill
7) Most, if not all of these questions should have been addressed in the presentation material, without the need for asking. The questions are not rocket science. This brings into question the level of financial expertise with SFPUC leadership. Has the general manager or the COO led an organization with such large capital spending? Shouldn’t either of them have asked these questions? Prior to the SFPUC, what’s the size of the largest organization they’ve led? This is important in order to know their level of expertise managing large financial obligations.
8) The lack of addressing these questions prior to being asked also brings into question the level of financial expertise of the five commissioners. From a financial size perspective, what are the largest organizations where each commissioner has had an oversight responsibility, other than the SFPUC?
9) For the CFO: O ther than the SFPUC, what is the largest organizatio n, in terms of budgets managed, where the SFPUC CFO had a CFO role? This is important for understanding the CFO’s level of expertise.
10) Who does the SFPUC CFO report to? I f it is anyone other than the General Manager, that’s a problem. Given the massive spending plans, the CFO needs to be viewed as just as important as the COO or any other executive that reports to the general manager.
It’s not ok to just say that the CFO participates in the GM’s meetings, but reports to the COO. The CFO needs to be a full peer of the water, wastewater and power Assistant General Managers. Otherwise, the CFO’s views will not be perceived as being as important.
I hope you will ask some of these questions or similar. The SFPUC needs to get real about risk of declining water demand and the associated financial risks for the organization and its rate payers.
Best regards,
Dave Warner
cc: SFPUC Commissioners
Dennis Herrera, General Manager
Laura Busch, Deputy Chief Financial Officer
Nancy Hom, Chief Financial Officer
San Francisco Board of Supervisors