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Correspondence Log

CleanPowerSF Sfpuc Commission
February 11, 2025

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Correspondence Log
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February 11, 2025
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OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.

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

San Francisco Public Utilities Commission
Correspondence Log
January 25, 2025 through January 30, 2025

Date Received From Subject
January 25, 2025 Steve Lawrence Elephant
January 27, 2025 Dave Warner Address Affordability with the Budget/Financial Plan January 27, 2025 Peter Drekmeier TRT Letter Re: Water Supply Planning January 27, 2025 Joanna and Leo Mankiewicz Overcharging of Water Usage January 27, 2025 Solutions Not Sandbags

SF’s Lack of Comprehensive Drainage Planning Costing Us Billions
January 27, 2025 Solutions Not Sandbags

Re: SF’s Lack of Comprehensive Drainage Planning Costing Us Billions
January 28, 2025 Martin Gothberg

SFPUC Agenda Item 5A - Water Supply Planning
January 30, 2025 Francisco Da Costa SFPU Commission - how are we doing when it comes to our hydrants, cisterns, and preparation for a surging fire in San Francisco?

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From: Steve Lawrence
To: Ritchie, Steve
Cc: Commission
Subject: elephant
Date: Saturday, January 25, 2025 6:37:39 PM
Steve, Your power points for Tuesday have only the barest--one--line about curtailment, and nothing specific about the state's mandate to allow 40-60% of the river water to flow freely.

That's the elephant in the room. Unless there's been a settlement, the risk of running way short is huge, and should be discussed.

Too, what if an L.A. fire happens here? How much water is used to quelch fires? An earthquake will surely come.

Steve Lawrence

Page 1 of 4 ends

January 27, 2025
Re: Address Affordability with the Budget/Financial Plans Dear Commissioners,
Thank you for your service.

The most significant drivers of retail water and sewer rates/affordability are SFPUC budgets and financial plans. When reviewing the proposed financial plans at the February 11
th commission meeLg3A)ng, please pay parLg3A)cular aLg3()enLg3A)on to the associated affordability projecLg3A)ons. Last year’s financial plans were parLg3A)cularly hard on affordability. AcLg3A)on should be considered to bring affordability projecLg3A)ons back to past norms (as for example with the 2023/24 projecLg3A)ons).

Last year (2024/25 Financial Plans)
Last year’s projected combined water and sewer bills climbed so much that the cushion between the affordability threshold shrank to less than 1% by 2044 (figure 1). The increases were driven by an increase in the 10 year capital plan from $8.8 billion to $11.8 billion (a 34% increase in just one year), combined with the required increases in debt service to fund the capital plans.

Figure 1: 20 year affordability projecLg3A)ons presented as part of the 2024/25 proposed financial projecLg3A)ons. Note how the ~40% cushion between projected bills and the affordability target for 2024 decreases to less than 1% by 2044.

Page 2 of 4 ends

ProjecLg3A)ng a 1% cushion 20 years from now is troubling at best given the challenges of accurately projecLg3A)ng out 20 years. There are a wealth of uncertainLg3A)es. Will the affordability threshold grow at the rate projected? Will capital projects stay within budget? What happens if sales don’t grow as expected or the number of assumed new accounts doesn’t materialize? The capital plan didn’t include alternaLg3A)ve water supply (AWS) investments—what if AWS are needed?
The Prior Year (2023/24)
The 2023/24 affordability projecLg3A)ons were more reasonable (figure 2). A significant cushion was maintained between the combined bills and the affordability threshold, allowing for a beLg3()er chance of bills remaining affordable in the context of results diverging from projecLg3A)ons. 1

1 It should be noted that the SFPUC improved its affordability metrics between FY 2023/24 and 2024/25. However, the change in metrics had liLg3()le impact on the size of the cushion in either 2043 or 2044.

Figure 2: 20 year affordability projecLg3A)ons presented as part of the 2023/24 proposed financial projecLg3A)ons. Note how the distance between the combined water and sewer bills and the affordability threshold stays relaLg3A)vely constant (roughly a 30% cushion in 2043).

Page 3 of 4 ends

Other uncertainSg4f5es:

Lower than Projected Demand, PopulaSg4f5on, New Accounts, Household Size, to name a few
Lower than projected demand means that the SFPUC would need to raise rates to offset lower sales. For those consumers that reduce their demand in proporLg3A)on to rate increases, their water bills wouldn’t change. Otherwise their bills increase.

It should be studied whether or not lower income households can reduce demand as easily as more affluent households.

The SFPUC models the number of new accounts added over Lg3A)me as an important component of projecLg3A)ng average bills. Should the number of new accounts not grow as expected, perhaps due to lower than assumed populaLg3A)on increases, water bills would need to be higher (figure 3).

Should household size decrease, perhaps due to individuals moving into newly built units, then the bills are borne by a smaller number individuals in the unit, which in turn can affect household income, which would affect affordability.

Figure 3: How 2044 projected average bills change with changes to underlying populaLg3A)on assumpLg3A)ons. Note that the SFPUC uses number of accounts rather than populaLg3A)on for average bill calculaLg3A)ons. This analysis assumes new account growth and populaLg3A)on growth are closely correlated.

Page 4 of 4 ends

Consider SeSg4C7ng an Affordability Cushion Policy
It was disappoinLg3A)ng to see the SFPUC provide a projecLg3A)on where there was no meaningful cushion between average bills and affordability targets 20 years in the future. Please consider establishing a policy where the SFPUC targets a long-term affordability cushion in the range of 20-30%, where projected average bills stay 20-30% below affordability thresholds. Short term excepLg3A)ons are fine, but certainly on a 20 year horizon a significant affordability cushion should be maintained.

Kind regards,

Dave Warner

cc: Dennis Herrera, SFPUC General Manager
Steven Ritchie, SFPUC Assistant General Manager, Water Enterprise Nancy Hom, SFPUC Chief Financial Officer
Laura Busch, SFPUC Deputy Chief Financial Officer
Erin Corvinova, SFPUC Financial Planning Director

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
Eddie Corwin, Vice Chair
Eric Riemer, Treasurer
Marek Robinson, Secretary
Jose Borroel
Cindy Charles
Harrison “Hap” Dunning
Eric Gonzalez
Camille King
Marty McDonnell
Homero Mejia
John Nimmons
Iris Stewart-Frey
Bart Westcott
Brad Wurtz

January 27, 2025

President Kate Stacy and Commissioners
San Francisco Public Utilities Commission
Via email: [email protected]

Re: Item 5a: San Francisco Water Supply Planning.

Dear President Stacy and Commissioners:

Palo Alto recently spent half a million dollars to produce a One Water Plan. The Plan was premised on the following statement:

“Based upon the City’s forecasted water demand presented in the City’s 2020 UWMP and projections of water supply availability provided by SFPUC at the time, the City anticipates the need to implement water use reductions of approximately 50 percent from pre-drought usage levels in dry years post Bay-Delta Plan implementation.”

The 50% rationing figure espoused by the SFPUC is based on the manufactured Design Drought, which might occur once in 8,000 years. Furthermore, it’s based on unrealistic demand projections, acknowledged in the SFPUC’s own document – “Water Enterprise and Finance Bureau Water Demand Projections” (July 5, 2022) – as “an outside bound.”

The SFPUC’s unreasonable drought planning scenario is already leading wholesale customers to invest in costly and unwise planning. Palo Alto’s One Water Plan will likely just sit on a shelf. Making matters worse, the SFPUC’s Alternative Water Supply (AWS) Plan suggests the possible need to develop 92 to 122 mgd of AWS at a cost of $17 to $25 billion – an imprudent investment that would lead to a financial fiasco of epic proportion.

The Design Drought is clearly beyond conservative, yet despite seven conclusive deep-dive SFPUC workshops between 2020 and 2022, the Commission declined to even discuss the prudence of the Design Drought. This was an extreme disservice to ratepayers, wholesale customers and the Bay-Delta ecosystem.

Please schedule a workshop ASAP to focus on the practicality of the Design Drought before more money is squandered on unnecessary studies or the development of unneeded infrastructure.

Following are a few comments on tomorrow’s staff presentation.

2 Slide 3 – Wise Water Use and Regular Planning
SFPUC Statement: “San Francisco currently averages 41 gallons of residential per capita use, and Wholesale Customers average 55.1 gpcd (a 52% decrease since 1975-78 in residential per capita use).”

TRT Response: In 1979, a water demand study by Brown & Caldwell projected demand would reach 425 mgd by 2030. Last year, the SFPUC delivered only 184 mgd to the Bay Area. SFPUC demand projections have always been highly inflated. In response to inflated historic demand projections, the SFPUC invested in a massive amount of reservoir storage (enough to last six years). The SFPUC is well positioned for the Bay Delta Plan, which would have a much smaller impact on water supply than over-projected water demand. According to the SFPUC’s Long- Term Vulnerability Assessment (LTVA), the impact of the Bay Delta Plan on supply would be the equivalent of a 15% increase in demand.

SFPUC Statement: “Urban Water Management Planning: Every 5 years, all water agencies need to demonstrate that they have enough supply to accommodate anticipated growth over the ensuing 25 years.”

TRT Response: For the 2020 UWMP, the SFPUC attempted to use contractual obligations (265 mgd) to represent current demand (198 mgd). TRT uncovered this deception, and the SFPUC was forced to use actual demand projections. This simple, honest correction reduced the perceived potential rationing in Year 3 of a drought by 27%.

UWMPs require water providers to assess whether they could meet projected future demand under a repeat of their worst “Five-Consecutive-Year Drought.” TRT has demonstrated that the SFPUC could manage its worst Six-Consecutive-Year Drought (1987-92) with the Bay Delta Plan in place without requiring any rationing. Rationing would extend the SFPUC’s water supply to last more than seven years, and a modest investment in AWS would ensure an even longer drought could be managed.

TRT and our allies invested a lot of time reviewing the 2020 UWMP and identifying flaws. We advocated for a workshop prior to the UWMP being finalized, but SFPUC staff stalled. The workshop did finally occur on July 16, 2021 – 16 days after the UWMP was submitted. Let’s not allow this to happen again.

Slide 4 – Smart Operations and Water Supply

SFPUC Statement: “Our management decisions and planning are guided by “Water First”, Experience, and Risk Management.”

TRT Response: The SFPUC’s Water First policy has been extremely successful. According to the following information (presented by SFPUC staff on July 12, 2021), precipitation in 2020/21 was

3 almost identical to 1976/77. Yet on June 10, 2021, the SFPUC had 917 thousand acre feet (TAF) of water in storage compared to 563 TAF on the same date in 1977. The 354 TAF difference is enough water to last one-and-a-half years. Despite big improvements in water management, the SFPUC has never adjusted its thinking.

SFPUC Statement: “Risk Management: How bad can conditions get, knowing that we cannot operate to zero storage at any point?”

TRT Response: While planning for a worse drought is prudent, there are reasonable limits. The SFPUC’s de facto policy of “reliability at all cost” is driving the agency toward insolvency. In November 2021, when the SFPUC declared a “Water Shortage Emergency,” there was enough water in storage to last 4.5 years. Storage never dropped below four years-worth, yet the SFPUC imposed a drought surcharge on San Francisco customers. The SFPUC then irrationally assumed the surcharge would extend into FY 2023/24, but when it didn’t, the SFPUC faced a $20 million deficit.

The SFPUC’s paranoia over running out of water has led to a practice of “hoard and spill.” Whenever the reservoirs aren’t all topped off, the SFPUC only releases minimum baseflows, creating terrible conditions for fish. You’ll see from the graph below that the pattern repeats every time there’s a dry year sequence. For example, between 2012 and 2016 (five years) unimpaired flow in the lower Tuolumne average just 12%. Then in 2017, all the water that was conserved during the drought (and much more) had to be spilled, leading to 79% of unimpaired flow. This is no way to manage an ecosystem.

4 Slide 8 – Consequences of Being Wrong

SFPUC Statement: Quote by Anson Moran (January 1994): “When considering all the factors associated with the City’s entitlements to water, its physical system and the dire consequences of just being wrong in the forecasting of the length of drought that may hit the City, I cannot agree with any comment that the City’s operation rule is overly conservative.”

TRT Response: This quote is from 30 years ago and shows that even then the Design Drought was criticized for being overly conservative. Much has changed since the Design Drought was conceived, including the following:

• Water demand heading into the six-year drought of record (1987-92) was at a peak of 293 mgd. Demand has been under 200 mgd for the past ten years. • The Water First policy was implemented.
• Cherry Lake (273 TAF of storage – ¾ the capacity of Hetch Hetchy) was drained for maintenance in 1989, adding to the challenge of the six-year drought. • The SFPUC’s Long-Term Vulnerability Assessment (LTVA – climate change study) was completed in 2021, finding “no clear direction of change in mean annual precipitation over the planning horizon.”

Despite all these major changes, the SFPUC has refused to even consider possible amendments to the Design Drought.

5 Slide 9 – Challenges Ahead

SFPUC Statement: “Population will continue to grow (e.g. State Housing General Plan Elements).”

TRT Response: According to the SFPUC’s 2020 UWMP, between 2005 and 2020 the population of San Francisco grew from 781,806 to 899,732. That amounted to 15% growth over a 15-year period, or 1% per year. The 2020 UWMP projected San Francisco’s population would grow by 25% over the next 15 years, reaching 1,251,214 by 2035. That’s a substantially higher growth rate of 1.67% per year. This obviously is not happening. The 2020 UWMP forecasted San Francisco’s population would grow by 39% over 25 years, but the California Department of Finance forecasted growth of only 10% – a huge difference, and worthy of analysis.

SFPUC Statement: “Climate Change: Studies indicate shifts to more precipitation as rain than snow and more extreme events.”

TRT Response: The LTVA projects a three-week shift in runoff by 2070. TRT modeled what would happen if the Design Drought occurred and runoff came three weeks earlier. We found that the SFPUC would pick up more than a years-worth of water over the course of the Design Drought (at the expense of the Irrigation Districts). This is because a fair amount of runoff would shift from a two-month period in the spring when the Districts are entitled to the first 4,000 cfs of runoff to earlier in the year when they are only entitled to the first 2,400 cfs. SFPUC staff have refused to respond to our analysis.

Slide 10 – Alternative Water Supply Plan for the Regional Water System

SFPUC Statement: “[The AWS Plan] is a living planning document that gives decision-makers information regarding potential future water supply issues and potential actions to augment the Regional Water System supplies to retain our current, appropriate risk management approach.”

TRT Response: The AWS Plan is a political document aimed at supporting the SFPUC’s false narrative that the Bay Delta Plan would lead to either extreme rationing or the need to invest heavily in expensive AWS. The Plan only provides an extreme worst-case scenario, depriving the Commission and others of all the facts needed to make wise decisions. The AWS Plan does not include a cost/benefit analysis, leading wholesale customers like Palo Alto to make expensive and unnecessary investments.

The Plan only includes figures SFPUC staff have acknowledged to be an “outside envelope”.

SFPUC demand projections have been inflated by an average of 22% over the past 25 years, yet the AWS Plan does not include a range in potential future demand (sensitivity analysis). Using SFPUC Finance Bureau sales projections rather than Water Enterprise demand projections would knock 37 mgd off of perceived need. According to the SFPUC’s “Water Enterprise and

6 Finance Bureau Water Demand Projections,” “the [Water Enterprise] projections [used in the UWMP] represent an outside bound of whatever demand will occur in the next 25 years…For budgeting and rate setting we use [Finance Bureau] demand projections that are as close to actual as we can make them.”

Removing one year from the Design Drought (it would still be the most conservative plan in the state) would knock another 25 mgd off the perceived need for AWS.

Conclusion

Please direct staff to respond to the issues raised in this letter, and to schedule a workshop to address these issues. Your ratepayers and wholesale customers will be pleased.

Thank you for considering this request.

Sincerely,

Peter Drekmeier
Policy Director
[email protected]

Cc: BAWSCA Board of Directors
Palo Alto Utilities Advisory Commission
SFPUC Citizens’ Advisory Committee

Thank you,
Leo and JoAnna Mankiewicz
cc: Mayor Dan Lurie
City Attorney David Chiu
District Attorney Brooke Jenkins
JoAnna and Leo Mankiewicz
13956W Maui Lane
Surprise, AZ 85379
(415) 722-8532
leorn.a.n.k@gm_aiLc_om
January 15, 2025
Kate H. Stacy, Commission President
San Francisco PUC
Water Department
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
Re: Overcharging of Water Usage
at 185 Farnum Street
Acct No. 7735523562
Dear Commissioner Stacy,
We have owned the home at 185 Farnum in San Francisco for over 40 years. The Account is in the name of our son Christopher, and we have recently been added back on the account. We have noticed that during extended periods in 2024 when the water at the house was shut off, we have been incurring charges for water usage. There are no leaks at the house that would account for this.

Upon contacting Customer Service at the Water Department, when I finally got through after nearly an hour on hold, I requested that my water meter be checked for malfunction or leakage. However, it was explained to me that the minimum charge for water usage of 0.67 units, or 501 gallons, is routinely charged to an account even if there is no water being consumed; therefore, no one would be sent to check out the meter based on the water usage because, Customer Service said, there is probably no leak. Since the water meter is wireless and computerized, this is apparently an IT problem, and it's frankly unfair to charge for water we don't even use. Other charges such as wastewater and stormwater are calculated based upon the meter reading, which adds to the unfair charges.

Except for two periods in 2024 during August and October, the water at the house has been shut off.

Therefore, we would request an adjustment for the months of January through July, September, and November through December of 2024. Based on our calculation, that adjustment would be in the amount of ($10.68+$7.84) x 10 months, or $185.20. Please credit that amount to our account.

In addition, you must do something to improve your customer phone contact experience, which is terrible right now. Either hire more staff to answer phones or at least provide a callback service so customers don't have to remain on hold for extended periods, sometimes over an hour (in our experience).

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From: SolutionsNotSandbags San Francisco
To: Mayor Daniel Lurie; Commission; Commission; SF Port Commission; SF Rec Park Commission; Ko, Albert (DPW); Ionin, Jonas (CPC)
Cc: White, Eileen@Waterboards; Bill Johnson; [email protected]; Daniel Kostek; Ellen Blake; Magnan, Eric@EPA; [email protected]; [email protected]
Subject: SF’s Lack of Comprehensive Drainage Planning Costing Us Billions Date: Monday, January 27, 2025 3:25:31 PM
Attachments: image.png
To: Mayor Lurie, From: Solutions Not Sandbags San Francisco Board of Supervisors,
PUC Commission,
RecPark Commissioner,
SF Port Commission,
SF Planning Commission
SF City Engineer
Over the last 15 years, San Francisco has attempted to avoid dealing with the 3 biggest problems facing our sewer collection and treatment system:

Sewage backups caused by undersized sewers downstream leading to raw sewage flooding SF residents
Raw sewage being dumped into the bay and ocean beaches untreated Sewer backups caused by rising sea levels.

With the lack of an adequate plan to address these 3 problems, SF has been backed into corners forcing it to solve these problems individually, in ways that are counterproductive to solving the other 2. This lack of a comprehensive and coherent plan causes other projects from other departments to begin on uncertain ground and end with solutions that are more problematic than simply doing nothing.

SF is being required to address sewage backups into SF residents homes under a 2021 Cleanup and Abatement Order enforced by the Regional Water Quality Control Board, after pressure from the US EPA in 2019. Currently SF is preparing to construct 2 large tunnels to address sewage backups. These 2 tunnels are currently estimated to cost over $700million but once bids are in this will likely rise and with construction cost overruns, the total will likely be over $1bil. Unfortunately, according to SFPUC’s estimates, these 2 projects will ultimately make our untreated sewage discharges worse, and likely make any attempt to reduce the impacts of sea level rise on our drainage discharge systems much harder to address. Even after spending nearly a billion dollars, the combined sewage these projects bring to the bay will still be polluted and will have an increasingly hard time getting out of the system due to the failure of SFPUC to maintain the outfalls, the closure of outfalls, and the rising sea levels downstream. image.png
While the 2021 Cleanup and Abatement Order was being negotiated, SFPUC decided to close the Pierce St. outfall off Marina Blvd., which had until that time carried 65% of the combined sewer flows in the Marina area out to the Bay. PUC’s reason for closing the outfall was to “reduce pollution into the marina”.

So far we can find no complaints from boaters nor RecPark staff. Closing the outfall not only caused flooding on Marina Blvd, sending sewage out of the manholes, into the street then into homes but as shown in the image above, increased pollution around Crissy field and possibly Aquatic Park, both areas where swimmers use the bay year round. The image is a water quality modeling graphic showing the improvements inside the marina where there are no water contact sports, but increases at Crissy field, where there is. In this image, the model doesn’t consider the increased sewage discharged from Laguna St. outfall which is likely to make it considerably worse towards Aquatic Park.

With the closure of the Pierce St. outfall, the Laguna St. sewer outfall, a sewage overflow pipe that dumps raw sewage into Gashouse Cove, now discharges 1-2 times a year. SFPUC is preparing to spend several million to rehabilitate the Laguna St. outfall even though the elevation of the pipe is so high that it is only helpful after flooding has started on Marina Blvd. This outfall discharges into the location where SF RecPark is currently required to spend $180million to clean up PGE manufactured gas plant pollution.

RecPark’s plan is to avoid cleaning up the PGE pollution in the south end of Gashouse Cove, instead creating a shallow recreational boat center for paddle boards, kayaks and other human powered craft on top of the PGE pollution. These recreation uses will put users in direct contact with raw, untreated sewage, such as we currently see 10-12 times a year at RecPark’s kayak hut on Mission Creek. The $180million RecPark project in Gashouse cove could make the sewage pollution worse, and make it harder for SF to adequately address flooding and pollution, especially as the sea levels rise.

SFPUC spent $6million to close the Pierce. St. outfall, causing geysers of raw sewage to inundate the streets, making San Francisco’s streets open sewers. At some point, SFPUC will have to return to at least the minimum safety levels from before the closure of the Pierce St. outfall.

SF Port is attempting to get the US Government to agree to supplying 65% of a $14billion program to reduce seismic risk to the seawall under The Embarcadero, as well as help rehab the older wharfs that are increasingly at risk to structural damage from wind driven waves as sea levels rise. This project is likely to be put on hold however, without a clear plan on how SF would deal with the pollution from the raw sewage as well as the upstream sewage backups caused by higher tides. Neither of these could be addressed in the Port’s plan due to lack of a clear, city-wide plan to address these problems. Any improvements to the sea wall would make fixing the pollution and sewer backups harder. So far, the only consideration in the SF Port plan for drainage during storms is to take the sewage off the streets and pump it over the new seawall into the bay. Any questions about current drainage problems are glossed over, and any flooding made worse by the inoperation of the gates along The Embarcadero and Mission Creek is ignored. These gates were all built using grants from the US EPA in the 1980s. In only 40 years they have been allowed to decay to the point of non-operation contributing to sewer backups upstream.

This lack of attention to the small detail of maintenance and ongoing improvement suggest that any investment by the US Government in San Francisco's facilities will likely also be wasted by decay and only require more federal money to maintain.

SFPUC has attempted to avoid dealing with flooding, saying it isn’t their problem and blaming the victims of flooding because they live in "low lying areas". SFPUC has accelerated the impacts of sea level rise by closing the outfalls leading to flooding that should not have been seen for another 40-75 years. SFPUC and David Chiu have spent $10millions on legal consultants to avoid dealing with our pollution. Their approach is to fight for the right to dump raw sewage into the bay instead of working on a plan to address the problem rationally. Even if they “win” their lawsuit, the US EPA will still have plenty of authority to require SF to implement David Chiu’s very problematic $10billion plan to address pollution. When (not if) SF is finally forced to reduce the over 1.2billion gallons of raw, untreated sewage we discharge every year, it will be doing it under a court order, which like the Regional Board’s Cleanup and Abatement Order, will force SF into a corner to fix that problem with little or no real consideration of sea level rise or flooding. The type of project proposed by David Chiu’s consultants is likely to make responding to sea level rise much harder.

With thousands of pages of “studies” San Francisco has discussed climate change and rising sea levels, but when faced with having to actually deal with the impacts of sea levels currently backing up our system San Francisco does the opposite of what would actually help the system. Instead of maintaining and improving our system, they have allowed it to degrade to the point that SF residents today are more impacted by storms occurring at lower tides than they were 20 years ago. Needless to say, the ever rising tides we're seeing are even worse.

SF has been able to avoid adequate enforcement of the Clean Water Act over the last 20 years because of powerful political allies in Sacramento and Washington. With the 2019 US EPA forcing them to address the situation and Baykeeper starting the enforcement of the permit violations has this situation started to change. SF has been able to rely on Federal grants and loans to address its problems in the past, but this situation is also changing. The lack of having a clear plan with projects already starting to address all of its problems in a comprehensive manner is not only costing the SFPUC ratepayers billions of dollars, it is starting to negatively impact the other City Depts. attempting to address their needs.

Solutions Not Sandbags is asking all the City Depts. to work together to require SFPUC to address the problems of sewer backups and raw sewage into the Bay and beaches in a way that addresses both the current and future compounding problem of sea level rise.

Thank you

SOLUTIONS NOT SANDBAGS
Bringing Awareness to SF's Failing Sewer System
Website: SolutionsNotSandbags.org
YouTube I Instagram I Twitter I Facebook
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From: SolutionsNotSandbags San Francisco
To: Mayor Daniel Lurie; Commission; Commission; SF Port Commission; SF Rec Park Commission; Ko, Albert (DPW); Ionin, Jonas (CPC); [email protected]; Board of Supervisors (BOS) Cc: White, Eileen@Waterboards; Bill Johnson; [email protected]; Daniel Kostek; Ellen Blake; Magnan, Eric@EPA; [email protected]; [email protected]
Subject: Re: SF’s Lack of Comprehensive Drainage Planning Costing Us Billions Date: Monday, January 27, 2025 3:30:05 PM
Attachments: image.png
Sorry,
We forgot the Board of Supervisors.

On Mon, Jan 27, 2025 at 3:25 PM SolutionsNotSandbags San Francisco <[email protected]> wrote:

To: Mayor Lurie, From: Solutions Not Sandbags San Francisco Board of Supervisors,
PUC Commission,
RecPark Commissioner,
SF Port Commission,
SF Planning Commission
SF City Engineer
Over the last 15 years, San Francisco has attempted to avoid dealing with the 3 biggest problems facing our sewer collection and treatment system:

Sewage backups caused by undersized sewers downstream leading to raw sewage flooding SF residents
Raw sewage being dumped into the bay and ocean beaches untreated Sewer backups caused by rising sea levels.

With the lack of an adequate plan to address these 3 problems, SF has been backed into corners forcing it to solve these problems individually, in ways that are counterproductive to solving the other 2.

This lack of a comprehensive and coherent plan causes other projects from other departments to begin on uncertain ground and end with solutions that are more problematic than simply doing nothing.

SF is being required to address sewage backups into SF residents homes under a 2021 Cleanup and Abatement Order enforced by the Regional Water Quality Control Board, after pressure from the US EPA in 2019. Currently SF is preparing to construct 2 large tunnels to address sewage backups. These 2 tunnels are currently estimated to cost over $700million but once bids are in this will likely rise and with construction cost overruns, the total will likely be over $1bil. Unfortunately, according to SFPUC’s estimates, these 2 projects will ultimately make our untreated sewage discharges worse, and likely make any attempt to reduce the impacts of sea level rise on our drainage discharge systems much harder to address. Even after spending nearly a billion dollars, the combined sewage these projects bring to the bay will still be polluted and will have an increasingly hard time getting out of the system due to the failure of SFPUC to maintain the outfalls, the closure of outfalls, and the rising sea levels downstream.
image.png
While the 2021 Cleanup and Abatement Order was being negotiated, SFPUC decided to close the Pierce St. outfall off Marina Blvd., which had until that time carried 65% of the combined sewer flows in the Marina area out to the Bay. PUC’s reason for closing the outfall was to “reduce pollution into the marina”. So far we can find no complaints from boaters nor RecPark staff. Closing the outfall not only caused flooding on Marina Blvd, sending sewage out of the manholes, into the street then into homes but as shown in the image above, increased pollution around Crissy field and possibly Aquatic Park, both areas where swimmers use the bay year round. The image is a water quality modeling graphic showing the improvements inside the marina where there are no water contact sports, but increases at Crissy field, where there is. In this image, the model doesn’t consider the increased sewage discharged from Laguna St. outfall which is likely to make it considerably worse towards Aquatic Park.

With the closure of the Pierce St. outfall, the Laguna St. sewer outfall, a sewage overflow pipe that dumps raw sewage into Gashouse Cove, now discharges 1-2 times a year. SFPUC is preparing to spend several million to rehabilitate the Laguna St. outfall even though the elevation of the pipe is so high that it is only helpful after flooding has started on Marina Blvd. This outfall discharges into the location where SF RecPark is currently required to spend $180million to clean up PGE manufactured gas plant pollution. RecPark’s plan is to avoid cleaning up the PGE pollution in the south end of Gashouse Cove, instead creating a shallow recreational boat center for paddle boards, kayaks and other human powered craft on top of the PGE pollution. These recreation uses will put users in direct contact with raw, untreated sewage, such as we currently see 10-12 times a year at RecPark’s kayak hut on Mission Creek. The $180million RecPark project in Gashouse cove could make the sewage pollution worse, and make it harder for SF to adequately address flooding and pollution, especially as the sea levels rise.

SFPUC spent $6million to close the Pierce. St. outfall, causing geysers of raw sewage to inundate the streets, making San Francisco’s streets open sewers. At some point, SFPUC will have to return to at least the minimum safety levels from before the closure of the Pierce St. outfall.

SF Port is attempting to get the US Government to agree to supplying 65% of a $14billion program to reduce seismic risk to the seawall under The Embarcadero, as well as help rehab the older wharfs that are increasingly at risk to structural damage from wind driven waves as sea levels rise. This project is likely to be put on hold however, without a clear plan on how SF would deal with the pollution from the raw sewage as well as the upstream sewage backups caused by higher tides. Neither of these could be addressed in the Port’s plan due to lack of a clear, city-wide plan to address these problems. Any improvements to the sea wall would make fixing the pollution and sewer backups harder. So far, the only consideration in the SF Port plan for drainage during storms is to take the sewage off the streets and pump it over the new seawall into the bay. Any questions about current drainage problems are glossed over, and any flooding made worse by the inoperation of the gates along The Embarcadero and Mission Creek is ignored. These gates were all built using grants from the US EPA in the 1980s. In only 40 years they have been allowed to decay to the point of non-operation contributing to sewer backups upstream. This lack of attention to the small detail of maintenance and ongoing improvement suggest that any investment by the US Government in San Francisco's facilities will likely also be wasted by decay and only require more federal money to maintain.

SFPUC has attempted to avoid dealing with flooding, saying it isn’t their problem and blaming the victims of flooding because they live in "low lying areas". SFPUC has accelerated the impacts of sea level rise by closing the outfalls leading to flooding that should not have been seen for another 40-75 years. SFPUC and David Chiu have spent $10millions on legal consultants to avoid dealing with our pollution. Their approach is to fight for the right to dump raw sewage into the bay instead of working on a plan to address the problem rationally. Even if they “win” their lawsuit, the US EPA will still have plenty of authority to require SF to implement David Chiu’s very problematic $10billion plan to address pollution. When (not if) SF is finally forced to reduce the over 1.2billion gallons of raw, untreated sewage we discharge every year, it will be doing it under a court order, which like the Regional Board’s Cleanup and Abatement Order, will force SF into a corner to fix that problem with little or no real consideration of sea level rise or flooding. The type of project proposed by David Chiu’s consultants is likely to make responding to sea level rise much harder.

With thousands of pages of “studies” San Francisco has discussed climate change and rising sea levels, but when faced with having to actually deal with the impacts of sea levels currently backing up our system San Francisco does the opposite of what would actually help the system. Instead of maintaining and improving our system, they have allowed it to degrade to the point that SF residents today are more impacted by storms occurring at lower tides than they were 20 years ago. Needless to say, the ever rising tides we're seeing are even worse.

SF has been able to avoid adequate enforcement of the Clean Water Act over the last 20 years because of powerful political allies in Sacramento and Washington. With the 2019 US EPA forcing them to address the situation and Baykeeper starting the enforcement of the permit violations has this situation started to change. SF has been able to rely on Federal grants and loans to address its problems in the past, but this situation is also changing. The lack of having a clear plan with projects already starting to address all of its problems in a comprehensive manner is not only costing the SFPUC ratepayers billions of dollars, it is starting to negatively impact the other City Depts. attempting to address their needs.

Solutions Not Sandbags is asking all the City Depts. to work together to require SFPUC to address the problems of sewer backups and raw sewage into the Bay and beaches in a way that addresses both the current and future compounding problem of sea level rise.

Thank you

SOLUTIONS NOT SANDBAGS
Bringing Awareness to SF's Failing Sewer System
Website: SolutionsNotSandbags.org
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SOLUTIONS NOT SANDBAGS
Bringing Awareness to SF's Failing Sewer System
Website: SolutionsNotSandbags.org

YouTube I Instagram I Twitter I Facebook
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From: Martin Gothberg
To: Commission
Subject: SFPUC Agenda Item 5A - Water Supply Planning
Date: Tuesday, January 28, 2025 7:11:48 AM
SFPUC President Stacy and Members,
I am unable to call in to today's meeting so please accept my comments on the subject agenda item.

As a Bay Area consumer of water and ratepayer I am increasingly concerned about the direction SFPUC staff continuing to rely on INFLATED demand projections in all aspects of operation.

SFPUC plans to develop more than 92 mgd of alternative supplies at a cost of greater than $17 billion will have enormous downstream effects including a doubling of water rates and additional CAPEX that will drive additional rate increases over years.

Further, using an overly conservative and highly controversial ‘design drought’ that is highly unlikely to occur, the SFPUC is courting financial disaster that may take decades to play out.

I hope the Commissioners will hold SFPUC staff to the highest of standards in terms of modeling and analytics needed to properly address assumptions and the health of the Tuolumne. To date the public has not seen this analysis and is therefore unaware of what they face as ratepayers.

Every assumption in the Plan needs to be challenged by the Commission and subjected to a ‘sensitivity analysis’ that will better allow decision- makers to get closest to what is optimal for Californians and the entire river ecosystem.

Today we do not have that mindset, rather, the SFPUC is still geared to maximize water diversion and storage to the detriment of river flow based on INFLATED demand.

Every overly conservative assumption has cost and flow repercussions.

SFPUC staff must be held accountable and respond to NGO concerns like the Tuolumne River Trust. For years staff has continued to blow off responding to detailed and reasonable analysis of their water planning and operation.

This is pure arrogance on the part of the SFPUC staff.

Thank you,
Martin Gothberg
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From: Francisco Da Costa
To: Mandelman, Rafael (BOS); [email protected]; Dorsey, Matt (BOS); [email protected]; Joshua Arce; Lennear, Tiffany; [email protected]; Ritchie, Steve; Steve Zeltzer; Robinson, Stephen D; Chan, Connie (BOS); Engardio, Joel (BOS); Mahmood, Bilal (BOS); Fielder, Jackie (BOS); Melgar, Myrna (BOS); Sauter, Danny (BOS); [email protected]; [email protected]; [email protected]; [email protected]
Subject: SFPU Commission - how are we doing when it comes to our hydrants, cisterns, and preparation for a surging fire in San Francisco?
Date: Thursday, January 30, 2025 9:01:12 AM
While we are fully aware of the fire that destroyed so much in Southern California - the Santa Ana winds and fire - are now being studied - how are we doing here in San Francisco - with our SF Emergency Services lacking plans and assets to tackle a vast surging fire - more on the West Side of San Francisco:
https://kilamanjaro-kilamanjaro.blogspot.com/2025/01/the-raker-act-sf-public-utilities.html Francisco Da Costa
Director
Environmental Justice Advocacy

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