Correspondence Log — CleanPowerSF Sfpuc Commission, May 13, 2025

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

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

San Francisco Public Utilities Commission
Correspondence Log
April 3, 2025 through May 1, 2025

Page 1 of 2 ends

Date Received From Subject
April 3, 2025 Julie Moore, Principal Environmental
Planner, Environmental Planning
Division
Draft Environmental Impact Report Comment
Period Extended - PG&E Power Asset
Acquisition Project
April 4, 2025 Lourdes Enriquez, Assistant to the
CEO/General Manager Bay Area Water
Supply & Conservation Agency
April 9, 2025 BAWSCA Board Policy
Committee Special Meeting Agenda (email
and attachment)
April 7, 2025 Lourdes Enriquez, Assistant to the
CEO/General Manager Bay Area Water
Supply & Conservation Agency
REVISED Agenda for April 9, 2025
BAWSCA Board Policy Committee Special
Meeting (email and attachment)
April 7, 2025 Spreck Rosekrans, Executive Director
Restore Hetch Hetchy
FW: groundwater banking letter (email and
attachment)
April 14, 2025 Lourdes Enriquez, Assistant to the
CEO/General Manager Bay Area Water
Supply & Conservation Agency
BAWSCA Statement in support of SFPUC’s
efforts to move the HRL analysis forward
(email and attachment)
April 14, 2025 Justin Baringer 6900 Mission Rd Property in Sunol, CA April 16, 2025 Peter Drekmeier, Policy Director
Tuolumne River Trust
TRT Letter Regarding Sensitivity Analysis
(email and attachments)
April 17, 2025 SFPUC Capital Finance Water Enterprise Refunding Bond Sale Results
April 18, 2025 Mariah Lauritzen Cancelled Meeting
April 21, 2025 Anne Galli Water for SF and the Bay Area

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

San Francisco Public Utilities Commission
Correspondence Log
April 3, 2025 through May 1, 2025

Page 2 of 2 ends

Date Received From Subject
April 22, 2025 Dennis Herrera, SFPUC General Manager FY 23-24 Onsite Water Reuse Program Commission Memo
April 23, 2025 Judy West PUC Budget Cuts- No rain gardens in old mud flats
April 25, 2025 Solutions Not Sandbags Re: Public Records Request #24-2478? (email and attachment)
May 1, 2025 Karen Frye, SFPUC Environmental
Management Manager
Informational item for Commissioners
(email and attachment)

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From: CPC.PGEPowerAssetsEIR
To: CPC.PGEPowerAssetsEIR
Subject: Draft Environmental Impact Report Comment Period Extended - PG&E Power Asset Acquisition Project Date: Thursday, April 3, 2025 4:36:31 PM
The San Francisco Planning Department published a Draft Environmental Impact Report (EIR) for the PG&E Power Asset Acquisition Project on March 19, 2025, available at Environmental Review Documents | SF Planning
. This email is an update to inform you
that the public review period has been extended to May 19, 2025.

If you wish to comment on the adequacy of the Draft EIR, you may submit comments in either or both of the following ways: (1) in person at the San Francisco Planning Commission public hearing on April 17th; or (2) written comments to San Francisco Planning department due by 5 p.m. on May 19, 2025.

Julie Moore
Principal Environmental Planner
Environmental Planning Division
San Francisco Planning Department
49 South Van Ness Avenue, Suite 1400, San Francisco, CA 94103 Direct: 628.652.7566 | www.sfplanning.org
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From: Lourdes Enriquez
To: BAWSCA WMR
Cc: Smegal, Tom; Deborah Grimes; Christiane Barth
Subject: April 9, 2025 BAWSCA Board Policy Committee Special Meeting Agenda Date: Friday, April 4, 2025 11:22:51 AM
Attachments: 25_BPC_April9_Agenda_FINAL_withNotice.pdf
Attached is the agenda for the BAWSCA Board Policy Committee Special meeting on Wednesday, April 9, 2025 at 1:30pm.

Pls. note that it is a Special Meeting due to the different meeting location, which is Foster City Community Building Wind Room, 1000 E. Hillsdale Blvd., Foster City.

Supporting documentation for each agenda items are not included in this email because of its volume. Click here
to download a complete copy of the agenda and attachments for this meeting from our website, or go to: http://bawsca.org/about/board/agendas

If you have questions, please call (650) 349-3000.

Thank you,
Lourdes Enriquez

Lourdes Verzosa-Enriquez
Assistant to the CEO/General Manager
Bay Area Water Supply & Conservation Agency
155 Bovet Road, #650
San Mateo, CA 94402
650-349-3000
www.bawsca.org

155 Bovet Road, Suite 302, ⚫ San Mateo, CA 94402 ⚫ ph 650 349 3000 ⚫ fx 650349 8395 ⚫ www.bawsca.org

NOTICE OF

SPECIAL MEETING
of the

BOARD POLICY COMMITTEE

on April 9, 2025 at 1:30PM

due to a different location

Foster City Community Building – Wind Room
1000 E. Hillsdale Blvd., Foster City, CA

If you have any questions, please call the
BAWSCA office at (650) 349-3000.

See next page for Agenda

(This page was intentionally left blank)

BOARD POLICY COMMITTEE
April 9, 2025
1:30 p.m.

SPECIAL MEETING
Due to Different Location:

Foster City Community Building – Wind Room,
1000 E. Hillsdale Blvd. Foster City

CLICK HERE TO VIEW LIVESTREAM

AGENDA
Agenda Item Presenter Page#

1. Call To Order, and Roll Call (Hardy)
Roster of Committee Members (Attachment)

Pg 5

2. Comments by Chair (Hardy)

3. Consent Calendar (Hardy)
A. Approval of Minutes from the February 12, 2025 meeting (Attachment)

Pg 7

4. Public Comment (Hardy)
Members of the public may address the committee on any issues not listed on the agenda that are within the purview of the committee.

Comments on matters that are listed on the agenda may be made at the time the committee is considering each item. Each speaker is allowed a maximum of three (3) minutes.

5. Action Item
A. Proposed Fiscal Year 2025-26 Work Plan, Results to be Achieved, and (Smegal) Operating Budget (Attachment)
Issue: What critical results must be achieved in FY 2025-26 to accomplish BAWSCA’s goals and water reliability objectives?
Information to Committee: Memorandum presenting Proposed Fiscal Year 2025-26 Work Plan, Results to be Achieved, and Operating Budget.

Committee Action Requested: That the Committee recommend Board approval of the:

1. Proposed Fiscal Year 2025-26 Work Plan and Results to be Achieved;

2. Proposed Operating Budget of $5,547,732; and

3. Recommended funding plan of Option 2a or 2b.

Pg 23

B. Approval and Adoption of BAWSCA Pay Schedules for FY 2025-26 (Smegal) (Attachment)
Issue: What is required of BAWSCA, as a participating agency in the California Public Employees' Retirement System (CalPERS), to comply with California Code Regulations (CCR) Title 2 § 570.5? Information to Committee: Memorandum and oral report.

Committee Action Requested: That the Committee recommend Board approval of the proposed action.

Pg 57
C. Second Amendment to Hanson Bridgett Professional Services Contract (Smegal) (Attachment)
Issue: What additional legal resources are needed to achieve the results in FY 2024-25?
Information to Committee: Memorandum and oral report.

Committee Action Requested: That the Committee recommend Board approval of the proposed action.

Pg 61

6. Report and Discussion
A. BAWSCA’s Long-Term Reliable Water Supply Strategy 2050 - Risk (Ashoori) Assessment and Scenario Planning (Attachment)
Issue: What is the approach to and goal of the Board Planning Session in May?
Information to Committee: Memorandum and oral report.

Committee Action Requested: Comments and feedback.

Pg 65

7. CEO Report (Smegal)
A. Water Supply Conditions
B. Water Supply Amendment/Tier 2 Drought Plan Update
C. CEO/General Manager’s Letter (Attachment)
D. Board Policy Committee Calendar (Attachment)
E. Correspondence Packet (Under Separate Cover)

Pg 67
Pg 69

8. Closed Session (Schutte)
A. Conference with Legal Counsel – Existing Litigation pursuant to Paragraph (1) of subdivision (d) of Government Code Section 54956.9 Federal Energy Regulatory Commission Final License Application Proceedings for Don Pedro Hydroelectric Project, P-2299-082, and La Grange Hydroelectric Project, P-14581-002.

B. Conference with Legal Counsel – Existing Litigation pursuant to Paragraph (1) of subdivision (d) of Government Code Section 54956.9 - State Water Board Cases (Third Appellate District Court Case No.

C101232)

9. Report from Closed Session (Schutte)

10. Comments by Committee Members (Hardy)

11. Adjournment to the Next Meeting (Hardy)
NOTE DIFFERENT LOCATION for June 11, 2025 at 1:30pm
Foster City Community Building – Wind Room, 1000 E. Hillsdale Blvd. Foster City.

Accessibility for Individuals with Disabilities
Upon request, BAWSCA will provide for written agenda materials in appropriate alternative formats, or disability-related modification or accommodation, including auxiliary aids or services, to enable individuals with disabilities to participate in and provide comments at/related to public meetings.

Please submit a request, including your name, phone number and/or email address, and a description of the modification, accommodation, auxiliary aid, service or alternative format requested at least two days before the meeting. Requests should be emailed to [email protected] or submitted by phone at 650-349-3000. Requests will be granted whenever possible and resolved in favor of accessibility.

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From: Lourdes Enriquez
To: BAWSCA WMR
Cc: Smegal, Tom; Schutte, Allison C; Deborah Grimes; Christiane Barth Subject: REVISED Agenda for April 9, 2025 BAWSCA Board Policy Committee Special Meeting Date: Monday, April 7, 2025 12:11:08 PM
Attachments: 25_BPC_April9_REVISED_Agenda_FINAL_withNotice.pdf Attached is a REVISED Agenda for the BAWSCA Board Policy Committee Special Meeting on Wednesday, April 9, 2025 at 1:30pm.

Agenda items remain the same. The agenda is REVISED to reflect remote participation of one Committee member.

Supporting documentation for each agenda items are not included in this email because of its volume. Click here
to download a complete copy of the REVISED agenda and attachments for this meeting from our website, or go to: http://bawsca.org/about/board/agendas.

Thank you
Lourdes Enriquez

Lourdes Verzosa-Enriquez
Assistant to the CEO/General Manager
Bay Area Water Supply & Conservation Agency
155 Bovet Rd., #650
San Mateo, CAÂ 94402
www.bawsca.org

From: Lourdes Enriquez
Sent: Friday, April 4, 2025 11:23 AM
To: BAWSCA WMR <[email protected]>
Cc: Tom Smegal <[email protected]>; Deborah Grimes <[email protected]>; Christiane Barth <[email protected]>
Subject: April 9, 2025 BAWSCA Board Policy Committee Special Meeting Agenda

Attached is the agenda for the BAWSCA Board Policy Committee Special meeting on Wednesday, April 9, 2025 at 1:30pm.

Pls. note that it is a Special Meeting due to the different meeting location, which is Foster City Community Building Wind Room, 1000 E. Hillsdale Blvd., Foster City.

Supporting documentation for each agenda items are not included in this email because of its volume. Click here to download a complete copy of the agenda and attachments for this meeting from our website, or go to: http://bawsca.org/about/board/agendas

If you have questions, please call (650) 349-3000.

Thank you,
Lourdes Enriquez

Lourdes Verzosa-Enriquez
Assistant to the CEO/General Manager
Bay Area Water Supply & Conservation Agency
155 Bovet Road, #650
San Mateo, CA 94402
650-349-3000
www.bawsca.org

155 Bovet Road, Suite 302, ⚫ San Mateo, CA 94402 ⚫ ph 650 349 3000 ⚫ fx 650349 8395 ⚫ www.bawsca.org

NOTICE OF

SPECIAL MEETING
of the

BOARD POLICY COMMITTEE

on April 9, 2025 at 1:30PM

due to a different location

Foster City Community Building – Wind Room
1000 E. Hillsdale Blvd., Foster City, CA

If you have any questions, please call the
BAWSCA office at (650) 349-3000.

See next page for Agenda

(This page was intentionally left blank)

BOARD POLICY COMMITTEE
April 9, 2025
1:30 p.m.

SPECIAL MEETING
Due to Different Location:

Foster City Community Building – Wind Room,
1000 E. Hillsdale Blvd. Foster City

CLICK HERE TO VIEW LIVESTREAM

AGENDA
Agenda Item Presenter Page#

1. Call To Order, and Roll Call (Hardy)
Roster of Committee Members (Attachment)

Pg 5

2. Comments by Chair (Hardy)

3. Consent Calendar (Hardy)
A. Approval of Minutes from the February 12, 2025 meeting (Attachment)

Pg 7

4. Public Comment (Hardy)
Members of the public may address the committee on any issues not listed on the agenda that are within the purview of the committee.

Comments on matters that are listed on the agenda may be made at the time the committee is considering each item. Each speaker is allowed a maximum of three (3) minutes.

Committee Action Requested: That the Committee recommend Board approval of the:

1. Proposed Fiscal Year 2025-26 Work Plan and Results to be Achieved;

2. Proposed Operating Budget of $5,547,732; and

3. Recommended funding plan of Option 2a or 2b.

Pg 23

Committee Action Requested: That the Committee recommend Board approval of the proposed action.

Pg 61

Committee Action Requested: Comments and feedback.

Pg 65

Pg 67
Pg 69

C101232)

9. Report from Closed Session (Schutte)

10. Comments by Committee Members (Hardy)

11. Adjournment to the Next Meeting (Hardy)
NOTE DIFFERENT LOCATION for June 11, 2025 at 1:30pm
Foster City Community Building – Wind Room, 1000 E. Hillsdale Blvd. Foster City.

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From: [email protected]
To: Lennear, Tiffany; Herrera, Dennis J; Ritchie, Steve Subject: FW: groundwater banking letter
Date: Monday, April 7, 2025 2:45:21 PM
Attachments: Restore Hetch Hetchy letter to SFPUC re groundwater 2025-4-4.pdf Tiffany, Dennis & Steve:

Please see attached groundwater letter addressed to President Stacy and General Manager Herrera.

I was motivated to write again on this subject after watching a video of the East Turlock GSA and hearing them talk about their overdraft situation.

Always happy to discuss.

Best,

Spreck

Spreck Rosekrans
Executive Director
Restore Hetch Hetchy
510-393-4593

The vision of Restore Hetch Hetchy is to return to the people Yosemite Valley’s lost twin, Hetch Hetchy – a majestic glacier-carved valley with towering cliffs and waterfalls, an untamed place where river and wildlife run free, a new kind of national park.

Kate H. Stacy, President & Dennis Herrera, General Manager San Francisco Public Utilities Commission
April 4, 2025
Groundwater banking in the Central Valley

Page 2 ends

April 4, 2025
Kate H. Stacy, President
Dennis Herrera, General Manager
San Francisco Public Utilities Commission
Subject: Groundwater banking in the Central Valley
Dear President Stacy and General Manager Herrera:

I am writing again to encourage the San Francisco Public Utilities Commission to pursue opportunities to bank groundwater in the Central Valley.1 Groundwater banking has the potential, at relatively low cost, to improve SFPUC water supplies while simultaneously helping agricultural communities to address critical aquifer overdraft. Improved supplies could then be used in a number of ways, including as a hedge against drought, to accommodate growth or for environmental enhancement.

Groundwater banking has been the most popular and successful approach for water supply investments in California for the last three decades, even before our landmark Sustainable Groundwater Management Act was passed in 2014. Farmers have invested in groundwater banking for their own use, and cities have invested in groundwater banking in rural areas (see attachment 1).

The SFPUC’s Regional Groundwater Storage and Recovery Project (RGSR) is an excellent groundwater banking program, but it only provides a maximum of 61,000 acre-feet in additional storage. There is far greater opportunity in the much depleted “cone of depression” within the Eastside Water District – not far from the Tuolumne River and the SFPUC’s San Joaquin Pipelines (see attachment 2).

In a 1993 study the SFPUC’s own consultants described groundwater banking in the Eastside Water District as “ideal”, but ranked the opportunity only as “fair” because of “institutional complexity”.2 While institutional complexity no doubt continues to be a challenge, California’s Sustainable Groundwater Management Act has provided strong incentives for farmers in the Central Valley to find ways to recharge their aquifers.

BOARD OF DIRECTORS
Roger Williams, Chair
Virginia Johannessen, Vice- Chair
Peter Van Kuran, Treasurer
Mark Palley, Secretary
Barbara Andrews
Mark Cederborg
James Fousekis
Ann Hayden
Lance Olson
Craig Reynolds
Lucho Rivera
Mecia Serafino

STAFF
Spreck Rosekrans
Executive Director
Julene Freitas
Office Manager

3286 Adeline St. Suite 8
Berkeley, California 94703
510.893.3400

Tax ID # 77-0551533
Kate H. Stacy, President & Dennis Herrera, General Manager San Francisco Public Utilities Commission
April 4, 2025
Groundwater banking in the Central Valley

Page 2 ends

Excess water in the Tuolumne watershed is often available for groundwater recharge. For example, the river’s annual flow, measured at Modesto, exceeded 1,000,000 acre-feet in 6 of the last 20 years (see Attachment 3). While some of those flows certainly provided important environmental benefits to the lower Tuolumne River and to the Sacramento-San Joaquin Delta, there could have been significant diversions for groundwater recharge that would have benefited both farming communities and SFPUC customers.

It is time to realize the substantial opportunity to improve water supply at low cost, and to address institutional address challenges directly and in good faith. The San Francisco Public Utilities Commission should engage Stanislaus County interests, including the Eastside Water District, the Turlock and Modesto Irrigation Districts, and the East Turlock Groundwater Sustainability Agency to develop and implement a groundwater recharge plan that would benefit all parties.

It is in everyone’s interest to pursue this low hanging fruit as so many other California water agencies have done successfully.

Sincerely,

Spreck Rosekrans
Executive Director
CC:

Alicia John-Baptiste, Mayor’s Chief of Infrastructure, Climate, and Mobility Tom Smegal, Chief Executive Officer/General Manager, BAWSCA Tom Chambers, Chair, BAWSCA
Peter Drekmeier, Tuolumne River Trust
Sarah Woolf, General Manager, Eastside Water District
Karla Nemeth, Director, California Department of Water Agencies

1 Previous communications include Restore Hetch Hetchy Comments on SFPUC Alternative Water Supply Plan (2023-8-25), RHH Groundwater Banking Presentation for Bay Area Water Stewards (2023- 9-15), Group Flood-MAR letter re Tuolumne watershed (2024-7-16), in person meetings with staff and commissioners as well as public comments during Commission meetings. 2 City and County of San Francisco Hetch Hetchy Water and Power, Reconnaissance Evaluation of Alternative Sites for Groundwater Banking, Bookman-Edmonston Engineering Inc, and Luhdorff and Scalmanini Consulting Engineers, unpublished work July 1993 Kate H. Stacy, President & Dennis Herrera, General Manager San Francisco Public Utilities Commission
April 4, 2025
Groundwater banking in the Central Valley
Attachment 1

Kate H. Stacy, President & Dennis Herrera, General Manager San Francisco Public Utilities Commission
April 4, 2025
Groundwater banking in the Central Valley
Attachment 2

Kate H. Stacy, President & Dennis Herrera, General Manager San Francisco Public Utilities Commission
April 4, 2025
Groundwater banking in the Central Valley
Attachment 3

0 500,000
1,000,000
1,500,000
2,000,000
2,500,000
3,000,000
3,500,000
4,000,000
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Attachment 3: Tuolumne River Flow at
Modesto (2005-2024)
(acre-feet)
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From: Lourdes Enriquez
To: Herrera, Dennis J; Ritchie, Steve; Kastama, Alison A Cc: Lennear, Tiffany; Smegal, Tom; Schutte, Allison C
Subject: BAWSCA Statement in support of SFPUC’s efforts to move the HRL analysis forward Date: Monday, April 14, 2025 9:42:46 AM
Attachments: 2025_0410 Smegal Comments on HRL Evaluation_FINAL.pdf Dear Dennis, Steve and Alison,

Attached is Tom Smegal’s statement on the timely and continued evaluation of the Tuolumne Healthy Rivers and Landscapes (HRL) Proposal by the State Water Board.

By copy of this email to Tiffany Lennear, we request that it be included in your correspondence packet for the April 22
nd meeting.

Thanks,
Lourdes

Lourdes Verzosa-Enriquez
Assistant to the CEO/General Manager
Bay Area Water Supply & Conservation Agency
155 Bovet Rd., #650
San Mateo, CA 94402
www.bawsca.org

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

Statement from Tom Smegal, Chief Executive Officer for the Bay Area Water Supply and Conservation Agency (BAWSCA), Supporting the Timely and Continued Evaluation of the Tuolumne Healthy Rivers and Landscapes (HRL) Proposal by the State Water Board
April 10, 2025
Last month, the Tuolumne River Partners (TRP) comprising the San Francisco Public Utilities Commission (SFPUC) and Modesto and Turlock Irrigation Districts sent a letter to Governor Newsom reiterating that the Tuolumne HRL proposal is integral to the State Water Board’s overall evaluation of a Bay Delta Plan. BAWSCA supports that position.

BAWSCA appreciates the administration’s commitment to getting a comprehensive HRL agreement ready for the State Water Board’s consideration this summer. However, BAWSCA shares the TRPs’ concern that action on the Tuolumne HRL Proposal is delayed and might not be included in this summer’s action.

In 2018, the State Water Board adopted Phase 1 of the Bay-Delta Plan, which if implemented severely restricts flows that can be used for water supply purposes during droughts from the Tuolumne River, which is the source of 85% of the water for the San Francisco Regional (Hetch Hetchy) Water System (System), which in turn provides two- thirds of the water used by BAWSCA’s agencies.

Soon thereafter, as encouraged by the State Board in its adoption of Phase 1, the SFPUC and its Tuolumne River partners came forward with the Tuolumne River Voluntary Agreement (TRVA) which proposed that a combination of river flows, river operations, and habitat enhancements could provide equal or better results for species protection with less impact to water supplies.

In January 2021, then BAWSCA Chair Barbara Pierce stated BAWSCA’s clear and sensible request: that the TRVA be evaluated by the State Water Board to determine whether it was indeed equal to or better than the adopted Bay-Delta Plan in terms of the State’s environmental objectives while maintaining a reliable supply of water at a fair price for the water customers that BAWSCA represents. That evaluation of the TRVA, now called the Tuolumne HRL Proposal, has been taking place since 2023.

BAWSCA’s support for the State Board’s evaluation of the Tuolumne HRL Proposal is consistent with BAWSCA’s mandate from the California Legislature to protect the water- supply needs of BAWSCA’s 26 members and the 1.8 million people, and over 40,000 businesses and community organizations in Alameda, Santa Clara, and San Mateo Counties that they serve. A reliable supply of high-quality water at a fair price is BAWSCA’s goal, as it has been for more than 20 years.

# # #
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From: j baringer
To: Commission
Subject: 6900 Mission Rd Property in Sunol, CA
Date: Monday, April 14, 2025 10:18:28 PM
Attachments: 1744693218921blob.jpg
Hi Commissioners,
Are there any plans for the old golf course that was located at 6900 Mission Road in Sunol, CA? Or could a section of that building be leased for commercial purposes? Here is the latest picture I could find of the building to give you an idea of what it looks like.

This Message Is From an External Sender
This message came from outside your organization. Report Suspicious From: Peter Drekmeier
To: Commission
Subject: TRT Letter Regarding Sensitivity Analysis
Date: Tuesday, April 15, 2025 7:45:22 PM
Attachments: TRT Letter to SFPUC re- Sensitivity Analysis.pdf Attachment A - BAWSCA Sensitivity Analysis.pdf
NGO Letter Re- Workshops Follow Up.pdf
TRT Letter Re- Workshops Follow-Up.pdf
NGO Requests of the SFPUC.pdf
TRT UWMP Comments - SFPUC.pdf
Hi Tiffany,
Attached, please find a letter and attachments for the Commission.

Thanks for all your good work!
-Peter
-----------------------
Peter Drekmeier
Policy Director
Tuolumne River Trust
[email protected]

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

April 15, 2025

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

Dear President Stacy and Commissioners:

With the 2025 Urban Water Management Plan (UWMP) update approaching quickly, I hope we can avoid a problem we experienced during the 2020 UWMP process.

Specifically, I encourage the Commission to direct staff to complete a sensitivity analysis on demand projections, similar to the one produced by BAWSCA in their 2022 demand study (see Attachment A) by the end of 2025. This information should be available for inclusion in the 2025 UWMP, which is due to the State by July 1, 2026.

What Happened During the 2020 UWMP Process?

First of all, the SFPUC and BAWSCA attempted to use the 265 mgd sales cap (“obligations”) as current demand in 2020, which inflated the potential water supply impacts of the Bay Delta Plan dramatically. We caught them, and eventually they were forced to use actual demand figures. This is not the purpose of this letter, but deserves mention. Should you be interested in what happened, the pertinent documents are posted at https://www.tuolumne.org/data-for-urban-water-management-plans.

On to my main point, TRT and our NGO partners were very engaged in the 2020 UWMP process. It coincided with the first few SFPUC deep dive workshops, so we were optimistic we could have a productive influence. We participated in meetings and submitted written comments (attached for your reference). In the end, we were extremely disappointed that staff stalled on engaging the Commission on important decisions until after the UWMP was submitted to the State.

After months of prodding, on July 16, 2021 – two weeks after the 2020 UWMP had been finalized and submitted – the SFPUC hosted a workshop on “SFPUC Water Demand Projections and Demand Management.” The workshop recording is posted at https://sanfrancisco.granicus.com/player/clip/38991?view_id=22&redirect=true

None of the new information and insights presented at the July 16 workshop made it into the UWMP, which has since guided many SFPUC policies and actions for the past four years. I will follow up with some of the things we learned at that workshop at a future date.

The important thing we need to do now is avoid making the same mistake (intentional or not). Let’s make sure a water demand sensitivity analysis is completed by the end of 2025 for inclusion in the UWMP. Let’s have a workshop to hear from experts, including those of us in the NGO community who have followed SFPUC issues closely for many years. We’re counting on the Commission to ensure an open, honest and transparent process.

2 Thank you for considering this request.

Sincerely,

Peter Drekmeier
Policy Director
[email protected]

Attachment A – BAWSCA’s Water Demand Sensitivity Analysis

BAWSCA’s 2022 Regional Water Demand and Conservation Projections Update1 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.

1 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

2 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.2 Note that these figures are for total BAWSCA demand, including water provided by sources other than the SFPUC.

2 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_FINALv2.pdf

3 March 4, 2022 President Anson Moran and Commissioners SFPUC 525 Golden Gate Avenue San Francisco, CA 94102 Via email Re: Need to Prioritize Action on the Design Drought and Water Demand Projections. Dear President Moran and Commissioners: On November 30, 2020, the SFPUC embarked on the first of six very productive workshops focusing on the Tuolumne River and water supply. 11 months later, on October 29, 2021, the workshops culminated with a presentation and discussion on the Long-Term Vulnerability Assessment. Four months have passed since then, and the SFPUC has yet to take the next step of acting upon the wealth of information received over the past 15 months. At your most recent meeting, President Moran asked staff to prepare a schedule to address the unfinished business related to items identified at the workshops. This is a step in the right direction, but we are concerned we will experience a series of delays, as we have in the past. It is important that you, the Commissioners, take the lead on driving next steps to ensure the momentum generated by the workshops is not lost. Following the October LTVA workshop, we encouraged you to request additional information from staff to help make your process for making changes to the Design Drought a little clearer. We submitted letters on November 5, 2021 and January 19, 2022, and commented at a number of SFPUC meetings, but didn’t receive responses. On February 4, 2022, we followed up with our own analysis of the LTVA, but again were met with silence. If you were provided with the additional information we requested, which we believe exists, it should not be a difficult decision to reduce the length of the Design Drought. Staff has a long history of withholding information from the public and dismissing NGO recommendations. They also have failed to respond to requests from Commissioners. Putting former Commissioner Vietor’s numerous unmet requests aside, we present the following three recent examples of staff’s failure to address your requests.

2 1) At the July 16, 2021 water demand and demand management workshop, Commissioner Moran requested information about the difference between CA. Dept. of Finance and Plan Bay Area population projections. Seven months have passed, yet there has been no response. 2) On November 9, 2021, former Commissioner Harrington requested regular updates on environmental metrics focusing on the health of the Tuolumne, specifically salmon returns to the river. Four months have passed, yet there has been no response. In the meantime, Dave Warner, a member of public, provided bi-monthly salmon count graphs throughout the spawning season. 3) On January 7, 2022, Commissioner Ajami requested a graph comparing historic water demand projections from the Water Enterprise and the SFPUC’s financial division. Two months have passed, yet there has been no response. Meanwhile, the Tuolumne salmon run dropped to less than 600 fish last fall, as compared to more than 6,000 salmon returning to the Stanislaus River. The clear difference between the two rivers is the magnitude of instream flow. The SFPUC has known for decades that major action is needed to restore the Tuolumne River ecosystem and prevent the extirpation of salmon, yet little action has been taken. In 1996, a settlement agreement during a FERC proceeding for the Tuolumne River was signed by the SFPUC, MID and TID, government agencies and NGOs. Much like the proposed Tuolumne River Voluntary Agreement (TRVA), the 1996 settlement was based primarily on non-flow measures. The agreement failed to restore fish populations. In fact, the number of spawning fish in the Tuolumne has declined precipitously since 1996. Of the 10 priority habitat restoration projects identified in the 1996 agreement, only four were completed. The signature project of the 1996 settlement involved filling in an old in-river mining pit that harbored non-native bass. It was a sound idea partially, but it failed because it was not accompanied by the flows that might have made it effective. The post-project monitoring report was very clear that high flows are an essential element of controlling predator habitat. The report states: During extremely wet years, high flows can flush largemouth bass out of a stream, but typically a sufficient number of adults can find shelter in flooded areas to repopulate the stream during lower flow conditions (Moyle 2002)…During the years following the flood, largemouth bass abundance was controlled by spring and summer flow conditions that were unfavorable for reproduction. Largemouth bass require low water velocities and warm water temperatures to reproduce. (Moyle 2002, Swingle and Smith 1950, Harlan and Speaker 1956, Mraz 1964, Clugston 1966, Allan and Romero 1975, all as cited in Stuber et al 1982) (p 130).1 1 Special Run Pool 9 and 7/11 Reach: Post-project Monitoring Report, McBain & Trush and Stillwater Sciences, June 30, 2006, p. 130. 3 Though the science shows that low river flows are the primary cause of salmon mortality, the SFPUC and Irrigation Districts have for many years pursued the TRVA, which focuses almost exclusively on non-flow measures. Notwithstanding messaging and policy statements about environmental stewardship, the SFPUC and Irrigation Districts have failed the Tuolumne River ecosystem. During the five-year period from 2012 through 2016, the total volume of flow in the Tuolumne River averaged just 12% of unimpaired flow. Over the past two years, it averaged 14% of unimpaired flow. As a result, the salmon population has plummeted.

Graphs produced by Dave Warner. Recommendations The conservation and fishing organizations on this letter recommend that the Commission: 1) Direct staff to produce specific information you need to make well-informed decisions regarding the length of the Design Drought and realistic water demand projections. We encourage you to revisit our letters for suggestions. Specifically, you should direct staff to: 1) produce graphs similar to those identified in the January 19, 2022 NGO letter that use current demand and incorporate the Bay Delta Plan instream flow requirements; 2) determine the occurrence interval (likelihood) of the Design Drought and the Design Drought minus its final year; and 3) respond to the NGO analysis of how earlier runoff might affect the SFPUC’s water entitlements. 2) Schedule a final workshop to go over the LTVA and new information provided by staff, as well as information provided by the NGOs. This workshop should take place within the next six weeks. 3) Schedule a discussion at your next meeting following the workshop to address the outcomes of the workshop and revisit policy decisions regarding the Design Drought and water demand projections. We are convinced the SFPUC can meet the Bay Delta Plan instream flow requirements without compromising water supply security. The workshops and LTVA have helped make this clear. The Tuolumne River and Bay-Delta ecosystems are on the brink of collapse and cannot wait any longer. The time for action is now.

4 Thank you for considering our comments and recommendations. Sincerely.

Peter Drekmeier Tuolumne River Trust
Chris Shutes California Sportfishing Protection Alliance John McManus Golden State Salmon Association Bill Martin Sierra Club Bay Chapter

OFFICES 57 Post Street, Suite 711 San Francisco, CA 94104 (415) 882-7252 1031 15th Street, Suite 6 Modesto, CA 95354 (209) 236-0330 67 Linoberg Street Sonora, CA 95370 (209) 588-8636 www.tuolumne.org BOARD MEMBERS John Kreiter, Chair Harrison “Hap” Dunning, Vice Chair Cindy Charles, Treasurer Kerstyn Crumb, Secretary Eric Heitz, Chair Emeritus Eddie Corwin Bob Hackamack Camille King Bill Maher Marty McDonnell John Nimmons Eric Riemer Bart Westcott April 26, 2021 President Sophie Maxwell and Commissioners SFPUC 525 Golden Gate Ave. San Francisco, CA 94102 Via Email Re: April 27 Agenda Item 7: Discussion of the Commission Water Workshops. Dear President Maxwell and Commissioners: Thank you again for hosting the three workshops focusing on the Tuolumne River. We appreciated the deep dives, and look forward to working with you to achieve the State’s co-equal goals of restoring the greater Bay-Delta ecosystem and ensuring reliable water supplies. We’re optimistic a balance can be achieved, and we’re pleased the Commission will be considering next steps at tomorrow’s meeting. One issue we hope you will consider soon is the possibility of removing one year from the Design Drought. If a decision is made before the Urban Water Management Plans (UWMP) are submitted to the State by July 1, this simple change would make it much easier for San Francisco and the BAWSCA agencies to approve housing projects over the next five years. Two weeks ago, I attended a Menlo Park City Council meeting where they discussed some process issues for their UWMP. I was pleased to hear their consultant from EKI Environment and Water mention that several BAWSCA agencies had joined TRT in encouraging the SFPUC to use demand projections rather than contractual obligations to represent water demand. The BAWSCA agencies were concerned the higher rationing figures from the initial SFPUC document would provide ammunition for anti-growth advocates to oppose housing projects. By simply using demand projections instead of the sales cap, rationing in Year 3 of a drought was reduced from 55% to 40%. We now ask you to go a step further and consider removing a year from the Design Drought. The new, improved 7.5-year Design Drought still would be more severe than any drought over the past 1,100 years, based on tree-ring data. Regarding climate change, the SFPUC’s water entitlements will likely improve due to earlier runoff, shifting water from the post-April 15 time frame, when the Irrigation Districts are entitled to the first 4,000 cfs, to earlier in the season, when the Districts are entitled to the first 2,350 cfs.

2 Scenario VII at the March 26 workshop demonstrated that removing a year from the Design Drought would add between 27 and 33 mgd to Total Yield. That’s a lot of water, and would reduce potential rationing considerably. This would help remove a substantial barrier to the approval of much-needed housing. We request that you take up this issue in time to amend the 2020 UWMP, which will guide development decisions for the next five years. Other Factors that Influence Potential Rationing In addition to the length of drought planning, several other factors influence potential rationing. These include unimpaired flow requirements, population growth, water demand and the development of alternative water supplies. We believe the population and demand forecasts in the UWMP are highly inflated, and the pace of developing alternative water supplies is extremely slow. We request that the SFPUC schedule a deep dive into these issues to better understand past over-projections and how they might be avoided in the current UWMP. Population Growth According to the draft 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 is projecting San Francisco’s population will grow by 25% over the next 15 years, reaching 1,251,214. That’s a substantially higher growth rate of 1.67% per year. Given the increase in outmigration from California in recent years and growing community opposition to development, we believe these projections are unreasonable. While the UWMP forecasts San Francisco’s population will grow by 39% over the next 25 years, the California Department of Finance forecasts growth of only 10%. That’s a huge difference, and worthy of analysis. Between 2005 and 2020 the population of the BAWSCA agencies grew from 1.69 million to 1.86 million. That amounted to 10% growth in population over the 15-year period. The current UWMP is projecting the BAWSCA agencies will grow to 2.19 million by 2035 – a considerably higher growth rate of 18% over the same time period. While the UWMP forecasts the population of the BAWSCA territory to grow by 31% over the next 25 years, the Department of Finance forecasts the population of the three counties with BAWSCA member agencies (San Mateo, Santa Clara and Alameda) will grow by only 14%. The UWMP projections are more than twice those of the Department of Finance.

3 Demand Projections SFPUC and BAWSCA demand projections have always been highly inflated. Since UWMPs were first required in 2000, demand has been over-projected by an average of 22%. Leading up to the Water System Improvement Program (WSIP) in 2008, demand in the Regional Water System service area was projected to reach 285 mgd by 2018. Actual demand was only 196 mgd, a difference of 31% over the 10-year period. The main reason demand has decreased so much has been rising water rates, which send a strong price signal to consumers. Water rates have tripled over the past 13 years to pay for the $4.8 billion (plus debt service) incurred by the WSIP. Rates are now expected to increase by another 33% over the next five years. The SFPUC’s water supply division and BAWSCA have been slow to grasp the major role price plays in demand. Most recently, demand projections from the SFPUC’s 2015 UWMP were off by 15% in 2020. The SFPUC’s financial division has been much more accurate, with good reason. If they were to over-project sales, the SFPUC would face a deficit. The SFPUC’s current 10-Year Financial Plan forecasts water sales will remain flat over the next decade. These projections are 8% lower than those assumed in the UWMP. Following is a table showing the difference between demand projections in the previous four UWMPs and actual demand.

4 Alternative Water Supplies The SFPUC has identified about 35 mgd of alternative water supplies, but the UWMP assumes none of these potential sources will become available in the next 25 years. It states: The capital projects that are under consideration would be costly and are still in the early feasibility or conceptual planning stages. Because these water supply projects would take 10 to 30 years to implement, and because required environmental permitting negotiations may reduce the amount of water that can be developed, the yield from these projects are not currently incorporated into the SFPUC’s supply projections. If the SFPUC were to prioritize the development of these alternative water supplies, they could be available by 2040. This seems worthy of a discussion to determine whether they should be factored into future supply in the UWMP. Thank you for considering these comments. Sincerely, Peter Drekmeier Policy Director

May 5, 2021 President Sophie Maxwell and Commissioners San Francisco Public Utilities Commission (SFPUC) 525 Golden Gate Ave. San Francisco, CA 94102 Via Email Re: Request for timely actions to address population and demand projections, alternative water supplies, and the length of the Design Drought. Dear President Maxwell and Commissioners: On behalf of the above environmental and fishing groups, we would like to thank you for hosting the three workshops focusing on the Tuolumne River. The depth of information provided and productive dialogue were refreshing. We request that you take three immediate actions to advance some of the issues identified at the March 26 workshop focusing on water supply and demand. They are:

2 1) Direct your staff to produce an appendix for the SFPUC and BAWSCA Urban Water Management Plans (UWMP) that analyzes the impact on water supply of reducing the Design Drought to 7.5 years. This could be inserted easily into the UWMPs, and if in the future the SFPUC were to adopt this policy change, water agencies could simply use figures from the appendix in their Water Supply Assessments and other planning documents. We believe the BAWSCA agencies would support this addition, as it would make the approval of future housing projects much less problematic. 2) Commit to developing alternative water supplies, and incorporate the yield into the SFPUC’s water supply projections in the UWMP. The current draft does not commit the SFPUC to developing any new water supplies for the next 25 years. Recycling water provides the additional benefit of reducing the nutrient load from wastewater entering the Bay, and with stricter limits on the horizon, developing recycled water projects would give the SFPUC a jumpstart on adhering to future effluent reduction requirements. 3) Commission a peer review of San Francisco’s and BAWSCA’s population and demand projections. The review should explore why past UWMP demand projections were off by as much as 33%, and what has been done to correct over-projections. It should explain how population forecasts in the UWMP were determined, and why they are so much greater than those produced by the California Department of Finance. It also should explain why the demand projections in the UWMP are so far afield from those forecasted by the SFPUC’s financial department. Thank you for your prompt consideration of these requests. Sincerely, Peter Drekmeier Tuolumne River Trust Heinrich Albert Sierra Club San Francisco Bay Chapter Carol Steinfeld Sierra Club Loma Prieta Chapter Kristina Pappas San Francisco League of Conservation Voters Jeff Miller Alameda Creek Alliance Eric Wesselman Friends of the River Chris Shutes California Sportfishing Protection Alliance Cindy Charles Golden West Women Flyfishers Allison Boucher Tuolumne River Conservancy Mark Rockwell Fly Fishers International, Northern California Council 3 Mike Conroy Pacific Coast Federation of Fishermen’s Associations Institute for Fisheries Resources Dick Allen Lake Merced Task Force Lauren Weston Acterra: Action for a Healthy Planet Greg Reis The Bay Institute Laura Allen Greywater Action Elizabeth Dougherty Wholly H2O Larry Collins San Francisco Community Fishing Association San Francisco Crab Boat Owners Association John Buckley Central Sierra Environmental Resource Center Stuart Gross San Francisco Herring Association Konrad Fisher Water Climate Trust Bill Uyeki Peninsula Fly Fishers

OFFICES 57 Post Street, Suite 711 San Francisco, CA 94104 (415) 882-7252 1031 15th Street, Suite 6 Modesto, CA 95354 (209) 236-0330 67 Linoberg Street Sonora, CA 95370 (209) 588-8636 www.tuolumne.org BOARD MEMBERS John Kreiter, Chair Harrison “Hap” Dunning, Vice Chair Cindy Charles, Treasurer Kerstyn Crumb, Secretary Eric Heitz, Chair Emeritus Eddie Corwin Bob Hackamack Camille King Bill Maher Marty McDonnell John Nimmons Eric Riemer Bart Westcott May 5, 2021 Steve Ritchie San Francisco Public Utilities Commission 525 Golden Gate Avenue, 13th Floor San Francisco, CA 94102 Re: Comments on the SFPUC’s Draft 2020 Urban Water Management Plan. Dear Mr. Ritchie and Team: Thank you for the opportunity to comment on the SFPUC’s draft 2020 Urban Water Management Plan (UWMP). I’ll jump right in. 1) Population Growth Population growth is the main driver of water demand, so it’s critically important for the UWMP to include accurate projections. We believe the draft UWMP fails to do so. We encourage the SFPUC to prioritize this issue in the coming weeks in order to include defensible numbers in the final UWMP. According to the draft 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 is projecting San Francisco’s population will grow by 25% over the next 15 years, reaching 1,251,214. That’s a substantially higher growth rate of 1.67% per year, and very questionable. While the UWMP forecasts San Francisco’s population will grow by 39% over the next 25 years, the California Department of Finance forecasts growth of only 10% during the same time period. That’s a huge difference, and worthy of assessment. Between 2005 and 2020, the population of the BAWSCA agencies grew from 1.69 million to 1.86 million. That amounted to 10% growth over the 15-year period. The current UWMP is projecting the BAWSCA agencies will grow to 2.19 million by 2035 – a considerably higher growth rate of 18% over a similar 15-year time period. While the UWMP forecasts the population of the BAWSCA territory to grow by 31% over the next 25 years, the Department of Finance forecasts the population of the three counties with BAWSCA member agencies (San Mateo, Santa Clara and Alameda) to grow by only 14%. The UWMP projections are more than twice those of the Department of Finance.

2 A major problem with the SFPUC and BAWSCA population projections is that they give too much credibility to numbers produced for Plan Bay Area. Appendix E of the UWMP acknowledges, “Assumptions for the number of employees are from the Plan Bay Area out to the year 2045.” Plan Bay Area is more of a roadmap than a legitimate forecasting document. Plan Bay Area clearly states, “The projections illustrate how the region will accommodate growth if local jurisdictions adopt a set of policies consistent with the vision of Plan Bay Area.” That’s a huge qualifier: “if local jurisdictions adopt a set of policies consistent with the vision of Plan Bay Area.” In other words, Plan Bay Area hopes communities throughout the Bay Area will embrace much higher density and adopt policies to make it happen. That’s not going to happen, at least not across the board. Cities and counties are already facing community pushback against what is seen as over-development, and the Plan Bay Area projections are fueling opposition. Ultimately, Plan Bay Area’s overly-ambitious development targets will likely be self-defeating. Recommendation: The SFPUC should use Department of Finance population projections for both retail and wholesale customers. Time will show they are much more accurate than those of Plan Bay Area. 2) Demand Projections SFPUC and BAWSCA demand projections have always been highly inflated. Since UWMPs were first required in 2000, demand has been over-projected by an average of 22%. Leading up to the Water System Improvement Program (WSIP) in 2008, demand in the Regional Water System service area was projected to reach 285 mgd by 2018. Actual demand was only 196 mgd, a difference of 31% over the 10-year period. The main reason demand has decreased so much has been rising water rates, which send a strong price signal to consumers. Water rates have tripled over the past 13 years to pay for the $4.8 billion (plus debt service) incurred by the WSIP. Wholesale rates are expected to increase by another 33% just in the next five years. The SFPUC’s water supply department and BAWSCA have been slow to grasp the major role price plays in demand. Most recently, demand projections from the SFPUC’s 2015 UWMP were off by 15% in 2020. The SFPUC’s financial department has been much more accurate, with good reason. If they were to over-project sales, the SFPUC would face a deficit. The SFPUC’s current 10-Year Financial Plan forecasts water sales will remain flat over the next decade. These projections are 8% lower than those assumed in the UWMP. Following is a table showing the difference between demand projections in the previous four UWMPs and actual demand.

3 Appendix E: San Francisco Water Demand Forecast 2020-2045 correctly states, “Generally, water use and water price are negatively correlated. In other words, as water becomes more expensive, users will reduce their demands to offset the higher costs.” It continues, “The forecasts assume that by 2045 water rates increase by 50% in real terms…” A 50% increase in water rates over 25 years seems extremely low given recent history. Sewer rates are going to skyrocket to pay for the SSIP, and sewer rates are based on water rates. The following SFPUC table (not from the UWMP) suggests water rates are going to increase by 65% by 2036, and combined water/wastewater rates will increase by 91%.

4 Because sewer rates are tied to water rates, people will learn that when they use less water, both line items on their bill decrease, driving efficiency. Has the SFPUC’s financial department reviewed Appendix E, and do they agree that the increase in water rates will be only 50% over the next 25 years? Recommendation: Pull together a group of stakeholders to meet with the Brattle Group to go over Appendix E. There’s still time to make improvements if we act quickly. 3) Design Drought Section 8.2.2 does a fair job of describing the Design Drought, but doesn’t explain how the scenario was developed. It has always appeared to us that two droughts were randomly slapped together, but some SFPUC personnel get offended when we refer to the Design Drought as being “arbitrary,” suggesting some thought and analysis went into it. I have heard it explained as being based on historic conditions, and while it’s true the 1987-92 and 1976/77 droughts did both occur, they were not sequential. If there was some real thought and analysis that went into the Design Drought, the UWMP would be a good place to record it. Otherwise, the Design Drought appears to be arbitrary. A coalition of 20+ environmental and fishing groups recently asked the Commission to address the length of the Design Drought in a way that provides flexibility. Our request is: Direct your staff to produce an appendix for the SFPUC and BAWSCA Urban Water Management Plans (UWMP) that analyzes the impact on water supply of reducing the Design Drought to 7.5 years. This could be inserted easily into the UWMPs, and if in the future the SFPUC were to adopt this policy change, water agencies could simply use figures from the appendix in their Water Supply Assessments and other planning documents. We believe the BAWSCA agencies would support this addition, as it would make the approval of future housing projects much less problematic. Recommendation: We encourage SFPUC staff to support our request to the Commission to include an appendix in the UWMP that analyzes a 7.5-year Design Drought. Eventually, the SFPUC should produce a probability analysis that explores the likelihood of a Design Drought (of different lengths) occurring, but we’ll cross that bridge at a later date. 4) Climate Change The UWMP includes “Section 6.1.3: Climate Change Impacts to RWS Supplies.” Understandably, this section doesn’t go into a lot of detail, but it does give the impression that the impacts of climate change will all be negative. The UWMP predicts, “a shift in snowmelt runoff to earlier in the year,” but then fails to explain how this might benefit the SFPUC’s water rights and supply.

5 Turlock Irrigation District’s 2020 Agricultural Water Management Plan includes a fairly robust chapter on climate change. Following are two quotes that should be of interest to the SFPUC. “From 1901 to 2019, unimpaired flow…shows a decreasing trend in April to July runoff. Conversely, increasingly more runoff has occurred during the fall-winter period.” “The projections suggest that Tuolumne River runoff at Don Pedro Reservoir occurring during the April to July period could decrease from around 60 percent of total runoff in 2010 to only 30 to 40 percent of total runoff in 2100.” This expected change in the timing of runoff bodes well for SFPUC water entitlements, as runoff will increase in the pre-April 15 time-period when the SFPUC is entitled to everything above 2,350 cfs, and decrease during in the April 15-June 13 window when the SFPUC’s entitlements don’t kick in until runoff tops 4,000 cfs. Recommendation: The UWMP should include a section on the potential benefits to water supply from earlier runoff caused by climate change. 5) Alternative Water Supplies It’s extremely disappointing how slowly the SFPUC has pursued the development of alternative water supplies. The SFPUC’s 2005 UWMP notes: The construction of HHWP (Hetch Hetchy Water and Power) Project began in earnest in 1914, and after almost 20 years of construction, including building of the Hetch Hetchy Reservoir, and the acquisition of the Spring Valley Water Company by San Francisco, Sierra Nevada water began flowing into the local distribution system. The Hetch Hetchy System was built in a twenty-year period, and yet today recycled water projects have been lagging for three decades. Compare the construction of Hetch Hetchy to the following citation from the 2010 UWMP: In 1991, the San Francisco Board of Supervisors passed Ordinances 390-91 and 391-91 that outline specific components to be addressed in a Recycled Water Master Plan (RWMP), designate recycled water use areas within San Francisco, and require the installation of dual-plumbing systems for recycled water use within the designed recycled water use areas for the following situations: • New or remodeled buildings and all subdivisions with a total area of 40,000 square feet or more. • New and existing irrigated areas of 10,000 square feet or more. The SFPUC first developed a RWMP that outlined a phased water recycling project for San Francisco in 1996. However, the Plan was not implemented due to limited funding. An

6 updated RWMP was subsequently completed in 2006. The 2006 RWMP identifies recycled water project alternatives and a plan for implementation of recycled water projects in the City. These projects will help the City meet its long-term water demands with a local resource in a more reliable and sustainable manner. Here we are 30 years after Ordinances 390/391-91 were adopted, and according to the 2020 UWMP, San Francisco is using a total of 0.1 mgd of recycled water. And the draft UWMP is non-committal on whether any new alternative water supplies will be brought online in the next 25 years. Regarding alternative supplies, it states: The capital projects that are under consideration would be costly and are still in the early feasibility or conceptual planning stages. Because these water supply projects would take 10 to 30 years to implement, and because required environmental permitting negotiations may reduce the amount of water that can be developed, the yield from these projects are not currently incorporated into the SFPUC’s supply projections. The SFPUC has identified about 35 mgd of alternative water supplies. If the SFPUC were to prioritize these projects, the water could be available by 2040. This seems worthy of a discussion to determine whether at least some alternative water supplies should be factored into future supply in the UWMP. 6) Interruptible Customers Regarding “Table 8-3. Regional Water System Supply Availability During Normal and Dry Years,” It is unclear whether the interruptible customers (San Jose and Santa Clara) are included in the calculations. We assume they are. Given that the SFPUC does not have contractual obligations with San Jose and Santa Clara, and it has long been understood that they are not permanent customers, the UWMP needs to be clear whether the interruptible customers are included or not in any table related water demand and supply. Recommendation: The UWMP should include a table similar to Table 8-3, but excluding the interruptible customers. Stakeholders have a right to know how an eventual decision on San Jose and Santa Clara might impact their interests. Thank you for the opportunity to comment. We look forward to working with you to improve upon the UWMP prior to the July 1 deadline. Sincerely, Peter Drekmeier Policy Director

From: SFPUC Capital Finance
To: Commission
Subject: Water Enterprise Refunding Bond Sale Results
Date: Thursday, April 17, 2025 5:00:18 PM

SFPUC Logo
SFPUC Team secures $56 million in Water
Ratepayer Savings through Financing Closed
Today
April 17, 2025

Water Revenue Bonds, 2025 Series ABC
2025 Sub-Series A (Refunding) (WSIP) (Green Bonds) (2025A Bonds) 2025 Sub-Series B (Refunding) (Regional Water and Local Water) (2025B Bonds)
2025 Sub-Series C (Refunding) (Hetch Hetchy Water) (2025C Bonds) On April 17, 2025, the San Francisco Public Utilities Commission (SFPUC) successfully closed a tax-exempt bond sale of $523,435,000 Water Revenue Bonds, 2025 Series ABC (2025 ABC Bonds) pursuant to authorizing legislation from the Board of Supervisors of the City and County of San Francisco, Ordinance No. 131-24, finally passed on June 18, 2024. The Commission authorized this issuance at the March 11, 2025, meeting under Resolution 25- 0044. The transaction consisted of three Sub-series of 2025 ABC Bonds:
$467.960 million of the 2025A Bonds were issued to refund certain outstanding taxable and tax-exempt bonds that funded Water Enterprise Water System Improvement Program (WSIP) projects to generate significant savings via two different refinancing strategies (a current refunding and tender refunding).
$37.400 million of the 2025B Bonds were issued to refund certain outstanding taxable and tax-exempt bonds that funded Water Enterprise Regional Water and Local Water capital projects to generate significant savings via a current refunding and tender refunding.
$18.075 million of the 2025C Bonds were issued to refund certain outstanding taxable and tax-exempt bonds that funded Water Enterprise Hetch Hetchy Water capital projects to generate significant savings via a current refunding and tender refunding.

Pursuant to the tender refunding, the SFPUC repurchased a portion of the SFPUC’s outstanding taxable bonds at below face value and certain callable tax-exempt bonds. The SFPUC financed these repurchases by issuing tax- exempt 2025ABC Bonds at rates below the market yields on the taxable bonds and the 4% and 5% coupons on the callable tax-exempt bonds. This enabled the SFPUC to reduce future Water Enterprise bond repayment costs over the next 22 years by approximately $56.2 million. Bond refinancing savings are typically evaluated in today’s dollars with a “present value” analysis. The present value of the savings is $42.4 million or 7.2% of the refunded bond par amount, exceeding the 3% minimum present value savings requirement set forth in the Board's ordinance and the SFPUC's debt policy.

New Irvington Tunnel project, which was one of the many projects financed by bonds that were refinanced with this transaction.

Tender Background
The SFPUC was successful in
executing both taxable and tax-
exempt refundings for the Water
Revenue Bonds in July 2023. The
tax-exempt vs. taxable ratios
continued to remain wide, allowing
the SFPUC to pursue another
tender refunding in April 2025, of
certain outstanding taxable and
tax-exempt bonds to capture
significant savings. Long-term
taxable bonds issued prior to the
The Official Statement setting forth the terms of the
rise in interest rates over the past
year had lost market value. The
price of the outstanding bonds
goes down as interest rates rise,
because buyers can now buy
newly issued bonds offering higher
interest rates. While all bond
holders can receive their full
investment back plus interest by
holding the bonds to maturity,
certain taxable bond holders are
likely to be interested in selling
their bonds.

The ability to issue new tax-exempt
refunding bonds at yields below
the 4% and 5% coupon bonds on
certain outstanding tax-exempt
bonds callable between 2026 and
2027 also enabled the SFPUC to
buy back these bonds and
generate significant interest cost
savings.

By offering the taxable and tax-
exempt bond holders repurchase
prices slightly higher than the
prices generally available in the
secondary market, the SFPUC was
able to create a win-win situation,
benefiting both investors and the
SFPUC.

The SFPUC identified
approximately $861.2 million of
taxable bond tender candidates
and approximately $728.2 million
of tax-exempt bond tender
candidates. With the assistance of
a Dealer Manager (Jefferies LLC),
the SFPUC released an offer to
purchase such bonds through a
formal Invitation to Tender
(Invitation). Pursuant to the
Invitation and other related public
notices, the SFPUC specified
purchase prices for the bonds
(which the investors were free to
accept or reject), communicated
bonds is posted online.

Sale Results
At the time of pricing, the broader
U.S. financial markets awaited clarity
on economic, fiscal, trade and
political developments. The SFPUC's
bond sale received substantial
investor attention and was the sixth
largest transaction in the bond market
during the week of the sale and one
of three California sales that week.

The SFPUC offering included
2025ABC Bonds maturing each year
from 2025 to 2047.

On the first day of pricing, the SFPUC
offered the 2025ABC Bonds to
individual investors only. Retail orders
totaled about $598.7 million. On the
second day of pricing, the SFPUC
offered the 2025ABC Bonds to
institutional investors. Demand from
institutional investors was sufficient to
fully subscribe all maturities, except
bonds maturing in 2026 and the 4%
coupon bonds maturing in 2029,
which were required for structuring
purposes. Yields on the bonds
maturing in 2026 and the 4% coupon
bonds maturing in 2029 were
increased by 0.03% and 0.05%,
respectively, and Jefferies underwrote
the unsold balances in these
maturities. Good final subscription
levels and a positive market tone
ahead of federal announcements on
April 2 enabled the underwriters to
lower yields on the various bond
maturities by 0.01% to 0.04% over
the course of the pricing process, with
the largest reduction on the 5%
coupon bonds maturing in 2039.

The bonds were offered with a 5%
coupon for bonds maturing in 2025 to
2047 and a 4% coupon for certain
which tender offers it would accept
and the final prices at which the
accepted bonds would be
purchased.

The 2025ABC Bonds were priced
over two days (April 1, and April 2,
2025), with a bond underwriting
syndicate led by Jefferies and
Wells Fargo Securities as Co-
Senior Managers, and Barclays
Capital Inc, RBC Capital Markets,
LLC, Siebert Williams Shank &
Co., LLC, and T.D. Securities
(USA) LLC as Co-Managers.

These firms were selected through
a competitive Request For
Proposals process from firms in
the City Controller’s prequalified
bond underwriting pool.

Prior to pricing, the SFPUC
presented at the J.P. Morgan
Public Finance Transportation &
Utility Investor Forum in New York
City one week earlier on March 25
and March 26 and met with
investors to discuss the financing
plan for all of its Capital
Improvement Programs and the
upcoming bond sales for the Water
Enterprise.

While many factors determine the
rates paid on municipal bonds, one
of the key factors is the bond credit
rating assigned by bond rating
agencies. Following in-depth
presentations from the SFPUC
leadership team led by General
Manager Dennis Herrera, Assistant
General Manager of Business
Services and CFO Nancy Hom,
Assistant General Manager of the
Water Enterprise Steve Ritchie,
and Assistant General Manager of
Infrastructure Stephen Robinson,
and other key managers, the
outstanding bond ratings for the
bonds maturing in 2029. However,
bond yields were much less than the
coupon rates, and were therefore sold
to investors at a substantial additional
premium, which reduced the size of
the borrowing needed. The SFPUC
generated $582.8 million of bond
proceeds needed for the refinancing
by issuing only $523.4 million of
bonds.

Yields on the bonds range from a low
of 2.53% for bonds maturing in 2027,
to a high of 4.12% for bonds maturing
in 2047. Accounting for all costs
associated with the financing, the
overall interest rate on the bonds (the
all-in true interest cost) was 3.284%.

The SFPUC designated the 2025A
Bonds as “Green Bonds” because
these bonds refunded WSIP projects
certified under the Climate Bonds
Standard Water Sector Criteria, which
was established and is managed by
the Climate Bonds Initiative.

The investor presentation for the 2025ABC Bonds
is posted online.

Water Enterprise were affirmed
and new ratings on the 2025ABC
Bonds were assigned. Moody’s
Investors Service rated the bonds
"Aa2" with a Stable Outlook and
S&P Global Ratings rated the
bonds "AA-" with a Stable Outlook.

These high ratings have
contributed to the SFPUC’s
comparatively low municipal bond
interest rates.

Tender Results and
Overall Savings
Investors tendered $134.8 million
(or 16.3%) of the taxable bond
tender candidates and the SFPUC
accepted $133.7 million of these
tender offers, producing 6.48%
present value savings of $9.2
million. In addition to the debt
service savings generated by this
transaction, the SFPUC created
future potential refunding
opportunities in its debt portfolio by
replacing low coupon taxable
bonds with tax-exempt bonds
which can generate potential
additional refunding savings in
about 10 years, when they will be
subject to optional redemption by
the SFPUC. Investors tendered
$238.1 million (or 46.2%) of the
tax-exempt tender candidates and
the SFPUC accepted $152.4
million, producing 6.8% present
value savings of $10.5 million.

Together with $22.7 million in
present value savings from current
refunding certain outstanding
bonds, the 2025ABC Bonds
produced an overall 7.2% present
value savings of $42.4 million.

The SFPUC's Capital Finance team would like to thank and congratulate our team of advisors, attorneys, bankers, and all of our internal partners across the organization who helped to successfully bring this transaction to market. The SFPUC was advised by municipal advisory firms Montague DeRose & Associates, LLC and Backstrom McCarley Berry & Co., LLC. Norton Rose Fulbright US LLP served as Bond Counsel and Orrick, Herrington & Sutcliffe, LLP served as Disclosure Counsel to the SFPUC. The City Attorney's Office advised the SFPUC on legal matters. U.S. Bank Trust Company, National Association served as Bond Trustee. AW Smith LLC served as the Independent Accountant verifying savings. PFM Financial Advisors served as the Independent Pricing Consultant.

For more information, please contact the SFPUC's Capital Finance team:

Nikolai J. Sklaroff, Capital Finance Director, [email protected] Edward Kwong, Capital Finance Analyst, [email protected] Dan Fuchs, Capital Finance Analyst, [email protected]
Eric Kwak, Debt Analyst, [email protected]
Earl Dunivan, Debt Analyst, [email protected]
Gisele de Araujo, San Francisco Fellow, [email protected]

SFPUC Mission
To provide customers with high-quality, efficient, and reliable services in a manner that values environmental and community interests and sustains the resources entrusted to our care.

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From:

To:

Subject:

Date:

Mariah Lauritzen
Commission
Cancelled Meeting
Friday, April 18, 2025 10:21:24 AM
This Message Is From an Untrusted Sender
You have not previously corresponded with this sender.

Dear SFPUC Commission,
Why was the SFPUC meeting on April 22nd cancelled?
Best Regards,
Mariah Lauritzen
Nothing in life is to be feared, it is only to be understood. ~Marie Curie
Anfangen ist leicht, Behan-en eine Kunst.
~Sprichwo1i
Report suspicious
This Message Is From an Untrusted Sender
You have not previously corresponded with this sender.

Report Suspicious ‌
From: Anne Galli
To: Commission
Subject: water for SF and the Bay area
Date: Monday, April 21, 2025 11:11:26 AM
Hello from Anne Galli.

I am writing with a concern about two issues. Long term planning for water for the Bay area and environmental concerns for the Tuolumne River.

When planning a move from greater Boston, MA (Quabbin Reservoir) to CA in 1998, I learned about the Hetch Hetchy Reservoir and its source, the Tuolumne River, fed largely by snowmelt and by the Lyle Glacier. I have lived in Portola Valley, appreciating the high quality water.

Drought years, the downgrading in 2012 of the Lyle Glacier to a snow field, and increasing uncertainty of annual snowpack due to climate change, are very concerning for the long term viability of this system for an increasing population. Also, spending time annually in the high Sierras and the Tuolumne watershed, I have concerns about the management of the River by SFPUC. Both the ecology of the Tuolumne and the Bay Delta require sophisticated science based methods to protect both the environment and the water source, requiring modeling and proactively working to design better for the now inevitable droughts. I have no answers, but future generations and the ecosystems under your purview depend on your forward looking precautions. Yes, a great deal of money will be required. Many will need to be educated to raise and spend it wisely. I will be following your work and wishing you well in it.

Anne Galli

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

MEMORANDUM

Date: April 21, 2025

To: Commissioner Kate Stacy, President
Commissioner Joshua Arce, Vice President
Commissioner Avni Jamdar
Commissioner Steve Leveroni

From: Dennis J. Herrera, General Manager

Through: Steven R. Ritchie, Assistant General Manager, Water

Subject: Onsite Water Reuse Program Update – FY 23/24
_______________________________________________________________

Onsite Water Reuse Program Key Updates

The City and County of San Francisco implements an oversight and management program of onsite non- potable water systems to ensure the safe design, installation, and ongoing operation of these systems. The San Francisco Public Utilities Commission (SFPUC) actively participates in the permitting program by approving water budget applications, managing the Cross - connection Control Program, and providing technical assistance on navigating the permitting process. The SFPUC also develops partnerships with the private sector to educate and assist with the implementation of onsite water systems.

Onsite water systems are contributing to the SFPUC’s OneWaterSF approach to manage our resources efficiently.

Notable program highlights led by SFPUC for FY 23-24 include:

• Completed a Lessons Learned Guidebook with t
ips and
recommendations from practitioners with real -world experience on how to design and implement successful onsite water systems in San Francisco;

2 Figure 1. The San Francisco Museum of Modern Art (SFMOMA) features a living wall irrigated with treated rainwater.
• Completed a study that established a framework for evaluating water treatment requirements for single -family water recycling , and applie d the framework to three specific cases including household graywater systems, recirculating showers, and recirculating washing machines; • Collaborated with the United States environmental Protection Agency (U.S. EPA- Office of Research and Development) and the Swiss Federal Institute of Aquatic Science and Technology (Eawag) on a webinar to
share the state-of- the-science on single -family water recycling applications;
• Spearheaded a two -day Onsite Water Reuse Summit in Washington D.C. in partnership with U.S. EPA and WateReuse Association to explore the integration of science, policy, and operation for the safe and effective implementation of onsite water reuse systems

Background: San Francisco’s Onsite Water Reuse
Program

In September 2012, the City and County of San Francisco adopted the Non- potable Water Ordinance, adding Article 12C to the San Francisco Health Code. San Francisco is the first municipality to establish an ordinance and mandate the collection, treatment, and use of alternate water sources such as graywater, rainwater, stormwater, blackwater, and foundation drainage for non- potable applications such as toilet flushing and irrigation.

The ordinance established the roles and responsibilities of the SFPUC, San Francisco Department of Public Health (SFDPH), San

3 Francisco Department of Building Inspection (SFDBI), and San Francisco Department of Public Works (SFPW) in the oversight of onsite non-potable water systems in buildings.

The ordinance require s new development projects that apply for a site permit after January 1, 2022 of 100,000 gross square feet or more to install and operate an onsite water reuse system. The required alternate water sources and required non- potable uses are based on development project type. For commercial buildings, the project must meet its toilet and urinal flushing and drain trap priming demands through the collection, treatment, and use of available blackwater and condensate. For residential and mixed -use buildings, the project must meet its toilet and urinal flushing, irrigation, clothes washing, and drain trap priming demands through the collection, treatment, and use of available graywater and condensate. The requirements apply to both development projects consisting of a single building or multiple buildings.

New development projects that have applied for a site permit before January 1, 2022 of 250,000 gross square feet or more are still required to install and operate an operate water reuse system. For the required building types, the project must meet its toilet and urinal flushing and irrigation demands through the collection, treatment, and use of available graywater, rainwater, and foundation drainage.

To continuously improve inter-agency collaboration, the SFPUC and SFDPH meet monthly to review the status of onsite water reuse projects and all four City agencies meet quarterly to share updates.

For more information, visit www.sfpuc.gov/npo
.

Onsite Water Reuse Project Case Studies

Figure 2. MIRA tower (image courtesy of Aquacell by PHOENIX)

4 Mira at 160 Folsom Street:

This 40- story tower consists of an 8 -story mid -rise tower, a collection of 4 -story townhomes, 3 levels of below grade parking, and a 2 nd level residential courtyard. The unique twisting shape of the tower provides shade for residents and breaks up the flat, reflective glass exterior that can confuse birds. The onsite water reuse system captures roof and terrace level rainwater along with graywater from sinks, showers, and washing machines, which is then treated and reused for toilet/urinal flushing within the buildings and irrigation of site landscaping, both within the parcel and in the surrounding right-of-way. The system is expected to save 1.9 million gallons annually.

Figure 3. Rainwater harvesting system at 1036 Mission

Mission Street Family Housing at 1036 Mission Street:

This affordable housing residential building in the heart of San Francisco’s SOMA neighborhood. Rainwater collected from the building’s roof is used to flush residential toilets. Prior to entering the cistern, harvested rainwater goes through a prescreen and a treatment system consisting of disc filtration, GAC filtration, bag filtration, UV disinfection, and chlorination. Given the small size and urban infill nature of the site, a rainwater harvesting system was the best way to meet stormwater management requirements at the site. The system is expected to save about 90,000 gallons of potable water annually.

5 Figure 4. Chorus at 30 Otis Street (image credit: Andrew Pogue) 30 Otis:

30 Otis is a 27- story mixed- use building designed by Multistudio Architects, consisting of 416 residential units, City Ballet School, Chorus Hall (Theater) public retail, and a 2 -level underground parking garage. Rainwater collected from the building roof is directed to a collection tank, then treated using disc filtration, GAC adsorption, UV and chlorination disinfection. Greywater collected from showers, bathtubs and clothes washers in residential units is collected in a separate tank and treated using disc filtration, biological digestion, membrane filtration, UV and chlorination disinfection. Treated water is delivered to a treated water storage tank where distribution pumps supply the toilets, urinals and irrigation needs.

Additional case studies that feature San Francisco’s onsite water reuse projects, as well as other innovative water recycling and resource recovery projects across the globe are available at www.sfpuc.gov/npo
.

Potable Water Offsets

To date, there are 118 total water budget applications approved by the SFPUC for onsite water systems. As of April 2025, t here are 58 operating onsite water systems, the majority of which are capturing, treating, and using rainwater, stormwater, and/or condensate for non- potable demands such as toilet flushing and/or irrigation. 7 of the operating systems are graywater treatment systems. There are 2

6 operating blackwater treatment systems, one at the Salesforce Tower and another at Mission Rock. There are 2 operating foundation drainage reuse systems, one at Moscone Center and another at Energy Center San Francisco. More information on these projects and others can be found in the case studies report posted on www.sfpuc.gov/npo
.

The current potable water offset for the Onsite Water Reuse Program is 47,450,000 gallons per year, which is equivalent to 0.13 million gallons per day (MGD). This is also equivalent to offsetting the average annual home water use of 3,250 San Franciscans. By 2040, the expected potable water offset will be approximately 1.5 MGD , which is equivalent to offsetting the average annual home water use of 30,000 San Franciscans.

An estimated 6 2% of the total number of projects are implementing stormwater or rainwater harvesting systems to comply with the Stormwater Management Ordinance (SMO). Figures 5 and Table 1 provide an overview of San Francisco’s onsite water reuse projects.

Figure 5. San Francisco's Voluntary, Mandatory, and Grant-Supported Onsite Water Reuse Projects

7 Onsite Water Reuse Grant Program

The SFPUC’s Onsite Water Reuse Grant Program provides grant funding to encourage retail water users to reduce SFPUC water supply usage by collecting, treating, and using alternate water sources including rainwater, stormwater, graywater, foundation drainage, air conditioning condensate, and blackwater for non- potable uses such as toilet flushing, irrigation, and cooling tower makeup.

Grant applicants must demonstrate the ability to achieve at least one of the following thresholds to eligible for grant funding:

• Projects that replace at least 450,000 gallons of SFPUC water per year are eligible for grant funding up to $200,000; or • Projects that replace at least 1,000,000 gallons of SFPUC water per year are eligible for grant funding up to $500,000; or
• Projects that replace at least 3,000,000 gallons of SFPUC water per year are eligible for grant funding up to
$1,000,000.

The SFPUC is also promoting innovation through the Grant Program. For example, the SFPUC is providing grant funds to breweries to collect, treat, and reuse process water generated onsite.

Collecting and reusing process water onsite can provide significant offsets to potable water usage as breweries use large quantities of water for cleaning tanks, bottles, and equipment. The SFPUC’s water recycling program specifically for breweries includes guidance and requirements for water characterization, treatment, and ongoing monitoring to ensure the water is safe for the intended reuse.

Additionally, the SFPUC is incentivizing the implementation of wastewater heat recovery systems within development projects installing onsite water reuse systems. The Grant Program requires all applicants to estimate the potential energy offset that can be achieved with wastewater heat recovery. In addition, mixed-used and multi-family buildings that are grant recipients are required to implement wastewater heat recovery. SFPUC’s goal is to gather more information about the potential benefits of these systems in terms of how they can reduce the overall energy demands of buildings with onsite water systems.

555 Bryant is the most recent recipient of an onsite water reuse grant. The new development project is under construction and will be installing a graywater treatment system to meet non-potable water demands for toilet flushing, irrigation, and clothes washing. The

8 project will offset approximately 3.6 million gallons of SFPUC water each year. The project will also install a wastewater heat recovery system, which will reduce the energy consumption of the onsite water treatment system by using the extracted thermal energy to pre-heat the potable water supplied to the building’s water heater.

National Blue Ribbon Commission for Onsite Water
Systems

The SFPUC has been on the forefront of innovation in advancing onsite water reuse in North America. As chair of the National Blue Ribbon Commission for Onsite Water Systems (NBRC), the SFPUC is leading a collaborative of utilities and public health agencies from 15 states, the District of Columbia, the city of Toronto, the city of Vancouver, US EPA, and US Army Engineer Research and
Development Center.

Supported by the WateReuse Association, the NBRC has developed resources to support implementation of onsite water systems and foster strong collaborations between water and wastewater utilities and public health agencies. The NBRC has made significant research contributions as well as advanced policies and regulations for onsite water reuse nationally.

The NBRC embraces a risk -based framework to onsite water reuse by addressing not only log reduction targets and appropriate treatment trains, but critical control point monitoring, permitting, and oversight and management. In September 2023, the NBRC published the document Health Risk -based Benchmarks for Onsite Treatment of Water , which outlined the current state of the science for determining the level of treatment required for onsite water systems. For utilities and regulators looking to implement onsite water reuse programs, the NBRC document provides examples of actions being taken by communities advancing onsite reuse.

In addition, the NBRC recognized the need to accelerate the adoption of onsite water systems. The NBRC’s 2024 Action Plan addresses the research needs and goals for increasing adoption. The 2024 Action Plan served as the basis for a new initiative called Building Infrastructure Locally for Decentralized Water Systems (BILD). BILD is a partnership among NBRC, WateReuse
Association, US EPA, regulators, utilities, design engineers, product manufacturers, operators, non- governmental organizations, and academia working together in the spirit of collaboration to implement decentralized water infrastructure. BILD is chaired by the SFPUC.

9 For more information about the NBRC and BILD , visit www.watereuse.org/nbrc and www.watereuse.org/nbrc/bild.

cc: Paula Kehoe, SFPUC
Ken Payne, SFPUC-WQD
Steve Panelli, SFDBI-PID
Doug Obana, SFDPH-EH
Eleanor Tang and Jon Kwong, SFPW

10 Table 1: Current Onsite Water Reuse Projects

Project Name
Onsite Alternate Water Sources Non-potable Applications Rainwater
Stormwater
Graywater
Blackwater
Foundation
Drainage
Condensate
Brewery
process water
Toilet Flushing
Irrigation
Cooling
Street
Sweeping
Brewery
processes
Trap Priming
Fiscal Year 2012-2013
55 9th Street X X
SF Public Safety Building X X X X
45 Lansing X X
350 Mission X X X X
Market Street Place X X
Fiscal Year 2013-2014
Salesforce East X X X
Salesforce Tower X X X
200 6th Street X X X
Alta Laguna X X
535 Mission X X
333 Brannan X X X
1255 Columbus X X
St Anthony’s X X

SFMOMA X X X X X
345 Brannan X X
181 Fremont X X X X
41 Tehama X X X
Whole Foods Mixed-Use X X
Fiscal Year 2014-2015
CPMC Cathedral Hill X X
2558 Mission X X
1634 Pine X X
Starr King School X X
2051 3rd Street X X
Shipyard 51 Innes Court X X
Shipyard 52 Innes Court X X
Avalon Dogpatch X X
340 Fremont X X X X
Trinity Phase 3 X X

11 Project Name
Onsite Alternate Water Sources Non-potable Applications Rainwater
Stormwater
Graywater
Blackwater
Foundation
Drainage
Condensate
Brewery
process water
Toilet Flushing
Irrigation
Cooling
Street
Sweeping
Brewery
processes
Trap Priming
ECSF-BART Project X X
85 Bluxome X X
Fiscal Year 2015-2016
Moscone Center X X X X X X
UN Plaza Project X X X
1395 22nd Street X X X X
350 8th Street X X
5050 Mission X X
CPMC St. Luke’s X X
CPMC Van Ness Medical
Office Building

X X
510 Townsend X X X X X

UBER X X X X
Transbay Block 9 X X X X
Park Tower X X X
Transbay Block 8 X X X X
Fiscal Year 2016-2017
Chase Center X X X X
India Basin X X X X
115 Telegraph Hill X X
SFSU Recreation
Wellness Center

X X X
Salesforce Tower X X X X
160 Folsom X X X X
505 Brannan X X X X
Shipyard 10 Kennedy
Place

X X X
Shipyard 10 Innes Court X X X
706 Mission X X X
Fiscal Year 2017-2018
1301 16th Street X X
Modera Rincon X X
1598 Bay Street X X
1066 Market X X

12 Project Name
Onsite Alternate Water Sources Non-potable Applications Rainwater
Stormwater
Graywater
Blackwater
Foundation
Drainage
Condensate
Brewery
process water
Toilet Flushing
Irrigation
Cooling
Street
Sweeping
Brewery
processes
Trap Priming
Rebuild Potrero Block X X X
240 Pacific Avenue X X
999 Folsom X X
Hyatt Place X X X X X
Splunk X X X X
830 Eddy X X X
1036 Mission X X X
1500 Mission Residential X X X X
88 Broadway X X X
UC Hastings Academic
Building

X X X
49 South Van Ness X X X X
Fiscal Year 2018-2019
1515 S Van Ness X X
1965 Market X X
Lumina X X
300 Grant X X X
75 Howard X X X X
145 Leavenworth X X X X
361 Turk X X X X
30 Otis X X X X
Fiscal Year 2019-2020
Mission Rock X X X
1629 Market X X X X
88 Bluxome X X X X
598 Brannan X X X X
950 Tennesseee X X
681 Florida Street
Housing

X X
1111 Pennsylvania X X
2465 Van Ness X X
1001 Van Ness X X
65 Ocean Ave X X
4200 3rd Street X X

13 Project Name
Onsite Alternate Water Sources Non-potable Applications Rainwater
Stormwater
Graywater
Blackwater
Foundation
Drainage
Condensate
Brewery
process water
Toilet Flushing
Irrigation
Cooling
Street
Sweeping
Brewery
processes
Trap Priming
1140 Harrison Street X X X X
434 Minna (5M) X X X X
120 Stockton X X X X
Francisco Park X X X
415 Natoma (5M) X X X X X
725 Harrison X X X X
Pier 70 E2 X X X X
Pier 70A X X X X
Hillside Block 48, Phase
1B, Bldg G

X X X
450 O'Farrell X X X X
Fiscal Year 2020-2021
921 Howard Street X X
Lofton at Nopo X X
Potero Hope SF Block B X X
531 Bryant Street X X
2177 3rd St X X X
30 Van Ness Avenue X X X X X
Pier 70 Parcel K North X X X X
UC Hastings School of
Law Campus Housing

X X X X
Fiscal Year 2021-2022
CCSF New STEAM Center X X
San Francisco Wholesale
Flower Market

X X
555 Bryant X X X X
Fiscal Year 2022-2023
PG&E Block X X X X X X
One Vassar X X X X X
988 Harrison X X
University High School X X
80 Julian X X
350 2nd Street Hotel X X X X X
490 Brannan Street X X X X X

14 Project Name
Onsite Alternate Water Sources Non-potable Applications Rainwater
Stormwater
Graywater
Blackwater
Foundation
Drainage
Condensate
Brewery
process water
Toilet Flushing
Irrigation
Cooling
Street
Sweeping
Brewery
processes
Trap Priming
200 Kansas X X X X
Fiscal Year 2023-2024
No projects proposed

This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious From: Judy West
To: Commission
Subject: PUC Budget Cuts- No rain gardens in old mud flats Date: Wednesday, April 23, 2025 1:31:46 PM
Attachments: ltr to Mayor Lurie.2.docx
To Kate Stacy, I attach herewith a letter I sent to the Mayor about a pending project that would be a good candidate for your budget cuts. The PUC should NOT be installing rain gardens in muddy soil that is not permeable. The project at 499 Alabama St, Project Artaud proposes a plastic lined garden
with pipes to the sewer. We are only a block away from the new Folsom sewer on Harrison St. This is an expensive project and a waste of money. Thank you, Judy West

Honorable Mayor Lurie April 21, 2025
San Francisco City Hall

Re: PUC Budget Cuts: NO “permeable landscaping” projects in mud flat areas.

I am a geologist who spent 6 years as a member of the Citizens Advisory Committee of the SFPUC in the early 2000s, primarily focused on the Wastewater system, while they were developing the Low Impact Design guidelines. I am concerned that good intentions have created incentives for a financially wasteful program which could be a prime target for your current cost cutting mandate.

Permeable landscaping projects should not be allowed in low-lying mud-flat areas, which cannot absorb rain water. A clear example of this wasteful spending can be found in the pending project located at 401-499 Alabama Street (in the Mission Creek area) in a parking lot of Project Artaud, a non-profit organization which owns the subject property. I am familiar with the details because I am a resident member of the organization.

Our Building Permits are near approval and construction could begin in May, costing the City about $500,000.

The project is being funded through a $684,409 grant from the SF PUC Green Infrastructure Grants Program.

We hired a consultant, Lotus Water Engineering, to write the grant application, perform design, engineering and construction management for us. It is hard to estimate what we and the PUC have paid so far for admin, design and engineering. Construction is expected to be another $500k very soon. DBI applic #2024-12247385

The project was originally understood to be a “permeable landscaping” project, but the geologic testing revealed too much clay to allow storm-water to permeate into the ground. So now, in order to follow through and spend the grant money, the designers have proposed plastic-lined rain-gardens, which are very expensive to build, not effective and disruptive to the current use of the property. Our property is a good candidate for storm-water capture from our extensive roofs, but NOT from plastic lined “permeable landscaping” projects.

Our consultants have exhausted their budget for design and planning, such that we can no longer pursue other alternatives. We feel like we are being forced into this wasteful approach to meet PUC goals because of budget constraints in our contract and the need to meet deadlines. Our board of directors has been led to believe that we will never get assistance from the PUC again, if we try to delay the current project to pursue a more cost-effective approach, which requires more time.

Specifically for Project Artaud, my recommendation would be to cancel or delay the concrete removal portions of our project and maintain the roof drain capture and cistern elements of our grant. Separating the building permit approvals for the different elements of our scope of work would be a clear way to proceed.

With what we have learned through this design process, we could likely fund additional design ourselves, if we were to remain in good standing for PUC construction funds in the future. We have a large roof replacement coming up, ideal for rain-water capture with cisterns, that we can reuse for gardening etc.

Thank you so much for your consideration.

Judy West, geologist
499 Alabama St. SF. 94110
This Message Is From an External Sender
This message came from outside your organization.

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From: SolutionsNotSandbags San Francisco
To: Prather, Joel; Sherrill, Stephen (BOS); [email protected]; Commission; Mayor Daniel Lurie Cc: [email protected]; KWART, JEN (CAT); John-Baptiste, Alicia (MYR) Subject: Re: Public Records Request #24-2478?
Date: Friday, April 25, 2025 10:47:57 AM
Attachments: Pierce St Closure Findings from Record Requests.pdf Dear Mr. Prather
Thank you for letting us know. Is this also why the City has refused to comply with the California Public Records Act.?As we stated in our email below:

Solutions Not Sandbags has been waiting nearly a year for public records request #24-2478 to be fulfilled. These are documents from Mr. Norby and Mr. Prather.

We remind you that this public records request remains unfilled. Is it possible the delay is related to the desire to avoid potential criminal liability as well as public scrutiny and discussion? Unfortunately, the desire to hide information furthers the appearance of guilt.

We appreciate the City Attorneys efforts to protect the City. This raises another question, rhetorical in nature but important:

Do you and Mr. Norby have your own private attorneys yet ?
If the City is taking efforts to hide behind attorney-client privilege in order to mask potential wrong-doing, what are the consequences to individuals? As shown by the Kelly-Nuru fiasco, the City Family will happily "throw individuals under the bus" to protect Sr. level officials from embarrassing details. According to press reports it appears Mr. Nuru received additional sentence terms for having contacted the City Family when he found out he was under investigation, presumably to warn others or impending investigations. We hope this doesn't happen to yourselves. It may be that if you have been involved in efforts which leave the appearance of inappropriate behavior you might need to have your own representation. Your own attorneys may advise you to follow then US Attorney David Anderson's sage advice:
"Run, don’t walk to the FBI, before it is too late for you to cooperate .”
Dear Board of Supervisors, Mayor Lurie and Public Utility Commission Members; We are concerned that the actions of SFPUC officials and others appear to have led to a very dangerous decision based on misinformation. As stated below, the report (dated March, 2017) by Public Works engineers clearly stated "Removing Pierce CSD increases flooding particularly in the Marina” and "Removing Pierce CSD does cause more acres to be flooded".

However the "Summary Report" (dated June 2017, see this link "exhibit A") prepared by unnamed parties at SFPUC, uses the exact data from that study but changes the engineers statement to exactly the opposite statement: “Closure of the Pierce CSD will not increase the frequency or severity of flooding”. A further summary states it is a "SFPW" report although it was clearly "Prepared by San Francisco Public Utilities Commission". This summary report was subsequently provided to the San Francisco Bay Area Regional Water Quality Control Board as information for the enforcement of the US Clean Water Act. In this capacity, the Regional Board was acting for the US EPA in its duty to enforce federal law.

According to the neighborhood group The Marina 94123, based on information obtained through public records act requests (also attached to this email), there appears to be a nexus between the closure of the Pierce St. outfall and the desire to use the expansion of the San Francisco Marina West Basin. The reasoning appears to suggest that expansion of the marina would have further trapped combined sewage discharges inside the enclosed marina and made the marketing of high end mega-yacht slips harder. Closure of the outfall would make future expansion of the marina west basin more tenable and therefore justify a settlement with PGE, reducing its responsibility to cleanup of pollution in Gashouse cove by offsetting lost small boat slips in Gashouse Cove with larger, more economically beneficial mega-yacht slips.

Our concerns are twofold:

1. Was misleading information provided to regulators enforcing federal laws?

2. Was misleading information used to justify the closure of the outfall to further policy decisions made outside of legislative and oversight bodies? First, if misleading information is provided to regulators enforcing federal laws, it may trigger an investigation into potential violations of 18 U.S.C. § 371- Conspiracy to Defraud the United States. We refer you to the US DOJ Criminal Resource Manual to decide if this is a
concern that San Francisco and those representing San Francisco need to be made aware of.

We leave the determination of this issue to both the US EPA and US DOJ. We also point out that there is a "crime-fraud" exception to attorney client privilege. Again, this is outside of our expertise and we refer this issue to the US DOJ to make any determination of criminality.

Secondly, and more critical to your roles in government, if misleading information was used to justify a legal tactic it may have led the City into a legal entanglement that was not wise nor needed. As shown by subsequent decisions by the SF Board of Supervisors, the City itself did
not want the loss of the waterfront to private mega-yachts, leaving the rationale for the closure of Pierce stuck in limbo. Since the closure of the Pierce St. outfall, SF officials have continued to deny any problem with the closure of the outfall, standing behind the statement : "All of our
studies and hydraulic modeling have found that the project does not cause a substantial increase in flood depth in the area." We now know this statement is the exact opposite of what the hydraulic study actually found, but instead of correcting this statement, City officials continue to repeat it
.

City elected officials who are responsible for establishing policy have been precluded from discussing the policy behind these decisions under the guise of "attorney-client" privilege.

During a recent SF District 2 Town Hall meeting to discuss Resilience and Preparedness when Mr. Sherrill was asked about reopening the Pierce St. outfall, he responded as Mr. Prather did, stating he couldn't talk about it because "there is a lawsuit".

Clearly preparing for sewage coming into the homes of residents would be a matter of resilience and preparation, but the topic was "off limits", apparently on the advice of attorneys.

If our elected officials cannot clearly discuss and debate public policy in the open, where does that leave our democracy? If our elected officials are prevented from acting to protect public health and safety to meet some hidden legal tactic, where does it leave our residents' safety? We understand that at times public officials have to balance competing needs. But if the alleged nexus between the closure of the Pierce St. outfall and the PGE agreement exists, it has occured without any input nor direction from elected officials and in fact, against their stated policy. San Francisco has traded the closure of the outfall, which has lead to numerous events of substantial street flooding and 2 major events of feet of raw, untreated sewage in the homes of San Francisco residents, to justify an agreement to allow PGE to avoid cleaning up substantial pollution on our public lands, as well as enlarging the Marina for very expensive yachts.

Where else has San Francisco's elected officials given up their policy roles "on the advice of their attorneys"?
We urge the Board of Supervisors and the Mayor to take back the policy role we elected you to do. Override the decision to avoid public discussion of this problem. We will all benefit from having a better understanding of exactly how and why this happened so that we can avoid similar situations in the future.

Thank you for your attention to this important matter.

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

YouTube I Instagram I Twitter I Facebook

On Fri, Apr 18, 2025 at 11:52 AM Prather, Joel <[email protected]> wrote:

Hello Solutions Not Sandbags,

Thank you for reaching out.

I cannot comment on this matter because it is the subject of pending litigation. Please direct your inquiries to Jen Kwart, [email protected]
, at the San Francisco City Attorney’s
Office.

Joel Prather
Assistant General Manager – Wastewater Enterprise
(415) 385-5977

San Francisco Water Power Sewer | Services of the San Francisco Public Utilities Commission

From: SolutionsNotSandbags San Francisco <[email protected]> Sent: Wednesday, April 16, 2025 1:13 PM
To: [email protected]; Prather, Joel <[email protected]> Subject: Public Records Request #24-2478?

April 16, 2025 Dear Mr. Joel Prather and Mr. Greg Norby: We, at Solutions Not Sandbags, hope to work with you to shine some light on the circumstances which led to the November 19th, 2018 decision to close the Pierce Street Outfall in the Marina April 16, 2025

Dear Mr. Joel Prather and Mr. Greg Norby:

We, at Solutions Not Sandbags, hope to work with you to shine some light on the circumstances which led to the November 19th, 2018 decision to close the Pierce Street Outfall in the Marina District.

After reviewing some SPUC documents provided through a public records request we have serious concerns about potentially misleading information. Some of these documents, which were also provided to regulators, were signed by yourselves. We are reaching out to you for clarification about your understanding of the issue and your efforts to address them.

For example, in March 2017 Mira Chokshi of the SFPUC requested an engineering report to examine the impacts of the backflow valves being installed in SFPUC outfalls. The engineers were also asked to examine the closure of the Pierce Street Outfall. The study clearly stated "Removing Pierce CSD increase flooding particularly in the Marina” and "Removing Pierce CSD does cause more acres to be flooded". It appears that this study was not provided to the SFPUC managers who made the decision to close the Pierce Street Outfall or to the regulators tasked with enforcing federal laws.

Because, in fact, what was submitted to SFPUC managers and regulators stated the opposite:
“Closure of the Pierce CSD will not increase the frequency or severity of flooding”. This statement came from an unsigned SFPUC report, dated June 2017, which used the data from the March 2017 report but came to the opposite conclusion.

This is just one example of the inconsistencies we have discovered. And why we have concerns and questions about the SFPUC's decision-making process.

The residents along Marina Boulevard have many questions about the decision to close the outfall. They wonder if it is related to the longstanding lawsuit between San Francisco and PG&E over the Gashouse Cove clean-up? Could this be related to the City's desire to expand the SF Marina West Basin harbor?

Solutions Not Sandbags has been waiting nearly a year for public records request #24-2478 to be fulfilled. These are documents from Mr. Norby and Mr. Prather.

We hope these documents will clarify exactly what information the SFPUC Wastewater Enterprises Assistant General Managers used to make their decision to close the Pierce Street Outfall. We hope to learn what roles the consultants, staff, and managers played in this decision. We also hope to understand the justifications for this decision and the actions taken to address the resulting public health and safety issues.

Thank you for your help in discovering these requested documents.

We will all benefit from having a better understanding of exactly how and why this happened so that we can avoid similar situations in the future.

Thank you for your attention to this important matter.

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

YouTube I Instagram I Twitter I Facebook

SOLUTIONS NOT SANDBAGS
Bringing Awareness to SF's Failing Sewer System
Website: SolutionsNotSandbags.org
YouTube I Instagram I Twitter I Facebook
Dear Residents,
The following information was received via record requests that Solution Not Sandbags and The Marina 94123 obtained. We have broken some of them down so you can easily understand the path taken on decommissioning the Pierce St outfall. The North Shore Basin includes the following outfalls: Baker St, Pierce St, Laguna St, Beach St, Sansome St, and Jackson St.

IMPORTANT
The SFDPW did a report that stated that closing the Pierce St. outfall would cause flooding in the Marina. This was downplayed when SFPUC presented their summary report to SFPUC and the City proceeded to close the Pierce St outfall, even though it showed that San Francisco's relatively frequent "5 Year Storm" called a Level of Service storm (LOS), the Marina would experience slightly under half a foot of untreated combined sewage flooding. This is a low standard, as the national standard is a 100 year storm.

They apparently did not give all the information to the SF Planning Dept. and obtained a CEQA Exemption. Also, at the same time, Rec and Parks were proposing the redevelopment of the West and East Harbors. By closing the Pierce St. outfall it appears Subscribe Past Issues Translate
4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 1/18 that it allowed for the redevelopment of the West Harbor as it would "provide substantial improvements to the water quality in San Francisco Bay " 2017 THE NORTH SHORE PERMANENT PREVENTION

FEASIBILITY STUDY FROM SFDPW TO SFPUC
In Mar, 2017 The San Francisco Department of Public Utilities (SFPUC) asked The Department of Public Works (SFDPW) to prepare a study on Back Flow prevention. Later they asked them to include the decommissioning of the Pierce St outfall. Back flows are placed at the discharge point of an outfall to prevent bay or ocean water entering back into the sewage system.

In this SFDPW report, by David Reyla, clearly states and informs SFPUC that "Removing Pierce CSD increases flooding particularly in the Marina"

READ SFDPW

PRESENTATION
HERE
IN 2017 SFPUC SUMMARY

REPORT PRESENTED
TO CLOSE PIERCE ST. OUTFALL.

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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 2/18 David Reyla (SFDPW) gave SFPUC the report based on data from modeling. SFPUC then prepared a summary report. The chart above, the summary prepared by SFPUC shows that if Pierce St outfall was closed it would result in close to half a foot of untreated combined sewage flooding the Marina.

Important quotes from the SFPUC Summary report presented:
"the impact of closing the CSD outfall has marginal impact in increasing flooding in the flood sensitive areas in the North Shore basin" would we as residents feel that half a foot of untreated combined sewage is marginal?
"closure of the Pierce CSD outfall will not affect the long-term average annual CSD frequency for the Northshore, will not increase the frequency or severity of flooding" This conclusion is the opposite of what the SFDPW engineer stated.

READ FULL REPORT
HERE
SFPUC POST OCT 24th 2021 STORM ASSESSMENT
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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 3/18 After the Oct. 2021 storm, SFPUC did an internal presentation to their management. This assessment by SFPUC engineers clearly shows a substantial increase in both depth and extent of untreated combined sewage on Marina Blvd onto resident property and also onto Marina Green, that is a recreational area for families, children, pets, sports and events.

SFPUC

POST STORM PRESENTATION
HERE
SFDPW POST OCT 24th 2021 STORM ASSESSMENT
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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 4/18 This is an internal Department of Public Works presentation done by the engineers that did the initial modeling to the SFDPW Director, Carla Short and City Engineer Albert Ko. As you can read SFDPW Engineers were extremely upset that their initial report by David Reyla was ignored as SFPUC's upper management and AECOM decided to close the Pierce St outfall. You can read that as professionals in their field of engineering they likened this to the Flint Water Crisis.

REVIEW PRESENTATION
HERE

Page 5 ends

important to know that in 2005-2006 SFDPW have sent monitoring teams out to areas that experienced flooding, to see first hand the impact. The Marina, was never monitored as it never flooded.

Page 7 ends

Page 14 ends

without our input”
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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 5/18

Page 17 ends

closure of Pierce St outfall.

CORRESPONDENCE BETWEEN DISTRICT 2 SUPERVISOR'S

OFFICE AND SFPUC GENERAL MANAGER DENNIS
HERRERA AFTER THE OCT 21st 2021 STORM
Marina residents reached out to the District 2 Supervisor's office for an explanation as to why the Marina District experienced a failure in the sewerage system in the Marina.

Supervisor Catherine Stefanie's Letter to SFPUC's General Manager Dennis Herrera. Read HERE
Dennis Herrera's response. Read HERE
Supervisor's email request ignored: HERE

THE ISSUE RESIDENTS

HAVE WITH HERRERA'S RESPONSE

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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 6/18 QUOTE “The drainage the City provides in the Marina area is comparable to the drainage it provides in other neighborhoods. Additionally, the area has a lower flood risk compared to other low-lying areas.” OUR RESPONSE: Prior internal reports (e.g. from DPW) suggested the Marina would be disproportionately impacted by outfall changes. This is omitted here.

QUOTE “I asked SFPUC staff, in partnership with the City Attorney's Office, to complete an investigation...

No credible evidence exists of sewer system failure during the October storm.” “The cause of flooding... was the large storm itself, not the City's sewer system.” OUR RESPONSE: The Northshore Basin's was knowingly affected with the closure of the Pierce outfall. Herrera’s framing avoids discussing the changes and the impact on the Laguna St. outfall, Rec and Parks had that area under consideration for a recreational area. Mr. Herrera was fully aware of this because of his prior role as San Francisco's City Attorney, Mr. Herrera would have had full knowledge of the PG&E negotiations, that included the redevelopment of the West and East Harbor.

QUOTE "The Pierce Street outfall project was completed in 2021, and its purpose was to decommission a pipe that was in poor structural condition and to provide substantial improvements to the water quality in San Francisco Bay.” OUR RESPONSE : In his past position as City Attorney, Mr. Herrera would have been a key figure in overseeing the PG&E and The City of San Francisco agreement. He would have been well versed that the city cannot confer a benefit to one party at the unjust expense of another— especially when it results in property damage, decreased property value, or a shift in public burden onto private individuals.

QUOTE "All of our studies and hydraulic modeling have found that the project does not cause a substantial increase in flood depth in the area.” OUR RESPONSE: Mr. Herrera was no doubt aware that their studies and hydraulic modeling that showed untreated combined sewage flooding impacting the Marina even during a low storm of 5 years.

QUOTE" “The results show that the flooding on Marina Boulevard... would have occurred even if the outfall decommissioning project never occurred.” OUR RESPONSE: The Marina did not flood before in storms of this magnitude. If SFPUC knew that the Marina would flood, why were there no mitigation options considered like other cities do?
QUOTE “Because eradicating all flooding through SFPUC capital projects is not possible, owners of properties... should take steps to protect their properties.” OUR RESPONSE: Why should homeowners burden the failure of known poor decisions of upper management at the SFPUC? The City is so kind to offer ten free sandbags, while Subscribe Past Issues Translate
4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 7/18 the true costs to health and property damage and loss was in the millions. And when it is resolved, it will be us, the residents and business that will pay this burden. We find this unacceptable.

Dennis Herrera served as San Francisco City Attorney from 2001 to 2021 In October 2021, he stepped down as City Attorney after being appointed General Manager of the San Francisco Public Utilities Commission (SFPUC) — the very agency responsible for the Pierce Street outfall project.

CEQA EXEMPT PASSED BY THE SF PLANNING

DEPARTMENT
We must revert back to SFPUC'S and AECOM. How did the SF Planning Department issue a CEQA Category Exemption and therefore no EIR.

Read CEQA-Exempt
HERE
SFPUC’s modeling revealed that close to half a foot of combined sewage would be released into the Marina during a standard Level of Service storm. The closure should not have been CEQA-exempt.

CEQA Guidelines § 15064 and § 15300.2 in our opinion are clear: foreseeable sewage discharges Subscribe Past Issues Translate
4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 8/18 constitute significant environmental impacts and disqualify projects from exemption. The fact that this outcome was both predictable and ignored only compounds the legal and ethical failures of all higher management from all agencies involved that approved the closure,

RECORD REQUEST INTERNAL EMAILS
Through record request internal emails show that SFPUC and SFDPW employees were seriously concerned that the Pierce St outfall closure would cause untreated combined sewage flooding and questioned the internal process.
"Megan,I found the report on Pierce St. decommissioning with the minutes attached. The meeting was in November 2018. No one from Collection system is represented" Jon Loiacono, 2019
"Wow, they did not even look at any larger storms beyond LOS, let alone address redundancy or cost of rehab. Even if this particular decision to close Pierce proves ultimately OK, the document you forwarded is a severely incomplete model / precedent for evaluating outfall closures in general." Megan Abadie (SFDPW)
"If the tools we have now don’t work, I am hoping there is some quantitative tool / criteria we can recommend" Megan Abadie, questions the modeling, Subscribe Past Issues Translate
4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 9/18 "Pandora’s Box has been opened" Wallis Lee, SFDPW Engineer.

READ INTERNAL EMAILS
HERE
It appears to be evident that SFDPW and SFPUC employees were upset with the decisions of higher management. They excluded them from meetings, decisions, and disregarded their valid concerns that were backed up by modeling.

EAST AND WEST HARBOR

DEVELOPMENT AND TIMELINE
LAYOUT OPTION EAST AND WEST MARINA 2018

RECENT LAYOUT OPTION EAST AND WEST MARINA
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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 10/18 March 7, 2017
The Department of Public Works's North Shore Permanent Outfall Improvements Memorandum explores scenarios for permanent backflow prevention and the decommissioning of the Pierce ST. Outfall. Analysis identifies flooding risks if Pierce is removed. READ: AttachmentA_Permanent Outfall Improvements Memorandum.pdf NOV 5, 2018
Revised Block M G View Concepts drawings completed. Early planning for the Harbor redevelopment.

Nov 19, 2018
Pierce Decommissioning Meeting with SFPUC Assistant General Manager, Greg Norby approves closure.

READ: Pierce Decommissioning- Minutes of Meeting with AGM_11192018.pdf NOV 26, 2018
Harbor Stakeholders list prepared by Rec & Parks. Early community engagement for redevelopment underway.

FEB 13, 2019
PMC Final Memo on Pierce Closure concludes closure shifts discharge volume to Laguna and Baker, with modeled increased flood depths near Marina Blvd.

READ: PMC Final Memo on Pierce Closure.pdf
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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 11/18 April 25, 2019
Conceptual Layout for Marina Improvement Project finalized. Shows integration of recreational elements, kayak access, and public spaces.

MAY 23, 2019
Pierce CSD Decommissioning TSC Presentation given. PMC (AECOM) presents hydraulic impacts, claiming minimal flood risk increase.

READ: 2019.05.23_Pierce CSD Decommissioning_TSC_CER Presentation-FINAL.pdf SEPT 13, 2019
Non-Binding Term Sheet & MOU finalized between PG&E and CCSF for Harbor redevelopment. Was Pierce outfall closure or increased impact to Laguna mentioned? SEPT 18, 2019
CSD Operational Reliability Draft shows closing Pierce (OF 010) and Laguna (OF 011) increases flooding risks on Marina Blvd. READ: CSD Operational Reliability - OF 010 and 011 Closure_Draft (2) 2.pdf
OCT 22, 2019
SFPUC submits CEQA Exemption Request for Pierce Street outfall closure. Claims minor maintenance.

READ: CEQA EXEMPT.pdf
OCT 29 2019
CEQA Categorical Exemption approved for Pierce closure, even as Harbor CEQA review is unclear. No cumulative impact analysis completed. (See Pages 1-2) READ: CEQA EXEMPT.pdf
JAN 15, 2021
PG&E settlement announced by City Attorney Dennis Herrera: PG&E agrees to $190 million to clean up East Harbor and redevelop.

READ: Exec Copy_Settlement Agmt_Item 3 SF Marina Design Exhibit A 060122 MARCH 2 2021
CCSF Resolution No. 93-21 passed by Board of Supervisors, approving PG&E settlement.

READ Resolution No. 95-21
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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 12/18 MARCH 25, 2021
PG&E & CCSF finalize settlement agreement.

READ: HERE
MAY 2021
Pierce St outfall decommissioned.

OCT 24th 2021
53-Year Storm results in Marina Green and Marina Blvd flooding. Pre-closure models underestimated the impact.

READ: 1_Marina_Green_Flooding.pdf
JAN 26th 2022
Letter from SFPUC General Manager Dennis Herrera to Supervisor Stefani denies Pierce closure impacted flooding, despite internal modeling showing otherwise. "its purpose was to decommission a pipe that was in poor structural condition and to provide substantial improvements to the water quality in San Francisco Bay, especially the enclosed Marina, a heavily used area of the waterfront"
READ: Letter from the San Francisco Public Utilities Commission_Attachment.pdf Dec 31ST 2022 storm response
View the Mayor's Press conference. No warning was given to residents, even though the National Weather Service warned SF a week before. In fact, the Department of Emergency Management sent out a warning after the storm had passed.

VIEW
Press conference: Here
SF Standard Article: Here
Jan 16, 2024
The Budget and Legislative Analyst’s report found the Marina Yacht Harbor does not generate revenue to operate independently of the General Fund. While the West Harbor already charges the highest berth fees in the Bay Area, ranging from fee hikes to implementing paid parking—that could eliminate the Marina’s $930,000 annual subsidy, particularly if the PG&E-funded East and West Harbor Project proceeds as planned.

READ BLA Financial Report_2024.pdf
FEB 21, 2024,
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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 13/18 The San Francisco Board of Supervisors passed Ordinance No. 231191 on February 13, 2024. Mayor Breed approve on Feb 21st, 2024 prohibiting the Recreation and Park Department and the Planning Department from implementing any project that would extend the West Harbor Marina by more than 150 feet from its current boundary.

READ: Ord No. 231191
VIEW ORD PATH: Here

STORMS

STORMS OF IMPACT AFTER PIERCE ST
OUTFALL CLOSURE MAY 2019
Oct 24, 2021
Dec 31, 2022
Nov 22, 2024
Feb 4, 2025
Feb 13, 2025
PHOTOS AND VIDEO OF STORMS
Feb 13th no media as it happened at 2 am
HERE

STORMS OF INTENSITY BEFORE

CLOSURE OF PIERCE ST OUTFALL WITH NO FLOODING IMPACT
Oct 19, 2009, 100 year storm
Feb 25, 2004, 100 year storm
Jan 18, 2010
April 12, 2012
Dec 2, 2012
Dec 3, 2014
Dec 11, 2014

PG&E AND CITY OF SAN FRANCISCO AGREEMENT

PG&E AND SF AGREEMENT
PG&E and the City of San Francisco have been in a dispute for decades. They decided on Subscribe Past Issues Translate
4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 14/18 mediation. Through mediation they agreed on a collaborative project for the renovation and environmental remediation of the Marina East and West Harbors, known as the Marina Improvement Project.

As stated: "The City and PG&E desire to collaborate to design and construct a project to remediate environmental impacts and improve the East and West Harbors of the San Francisco Marina."

READ FULL AGREEMENT
HERE
Rec & Parks held public meetings:

March 11 & 15, 2023: RPD Community Meetings and Engagement Phase #1 (157 attendees)
March 11-April 11, 2023: Online and Paper Project Survey 1 Open (657 received) April 24-June 9 2023: Water Board Feasibility Study Public Comment & Public Meeting: May 11, 2023
August 23 & 26, 2023: RPD and PG&E Community Meetings and Engagement Phase #2 (279 attendees)
August 23-September 23, 2023: Online and Paper Project Survey 1 Open (171 received)
October 4, 2023: Rec & Park Commission – Capital Committee presentation October 19, 2023: Rec & Park Commission – presentation
December 5, 2024: RPD Community Meeting & Engagement Phase #3 (84 attendees)
December 19, 2024: Rec & Park Commission – presentation January 6, 2025 : BCDC Design Review Board Meeting

CONCERNS
Charter Section 4.113: Public Hearings and Transparency Requires that all significant changes to public land use or infrastructure be preceded by meaningful public hearings and notification. If Rec & Parks knew that Laguna outfalls flow would and had increased, and that untreated combined sewage was entering the bay because of the closure of the Pierce st outfall but proceeded with planning without disclosing this, that could be seen as a failure to disclose material environmental and public health risks.

Charter Section 4.115: Responsibilities of City Commissions (Rec & Park Subscribe Past Issues Translate
4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 15/18 Commission)
Mandates Rec & Park Commission decisions be in the public interest, with proper due diligence and public accountability. Proceeding with the project after the outfall decommission — while knowing about flooding — could this be seen as acting against the public interest, especially if risk assessments weren’t updated.

Charter Section 3.104: City Administrator’s Duty to Ensure Coordination Coordination is required across departments, including SFDPW, SFPUC and Rec & Parks, especially when decisions impact critical infrastructure like sewage outflows. If SFPUC didn’t properly coordinate with SFDPW and Rec and Park, after the Pierce outfall closed, that could be a procedural failure.

Charter Section 9.105 – Budgetary and Fiscal Responsibilities Requires all departments, including Rec & Parks and SFPUC, to ensure that funds are used responsibly, efficiently, and in the public interest. If SFPUC and Rec & Parks knowingly advanced a project for recreational use (like kayaking) after being informed that the Laguna outfall was now essential to the functioning of the sewage system, that can be seen as: Misuse of funds. Negligent planning. Willful disregard for public safety and critical infrastructure
Charter Section 3.102 – General Powers and Duties of Officers and Employees Public officials are obligated to act in good faith and in the interest of the public.This includes a duty not to approve projects that:

Undermine existing infrastructure (e.g., sewage outfall use) Create avoidable liabilities or future costs to taxpayers Proceed with expensive community outreach and consulting, without disclosing known risks
Misuse of Public Funds – Potential Violations
Under the California Government Code and reinforced by the SF Charter, any city department or official:

Cannot spend public money on planning or outreach for projects that they know would be infeasible, dangerous, or fiscally irresponsible Subscribe Past Issues Translate
4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 16/18 Could be subject to an audit or ethics investigation if it's shown that: They had knowledge of increased flooding due to outfall closure. They concealed this information during public engagement
They continued to fund outreach, planning, and consulting without revisiting environmental or engineering data. This creates a potential breach of:

Public trust
Charter-mandated fiscal responsibility
CEQA environmental due diligence
Disaster preparedness protocols

CONCLUSION
SFPUC was aware of sewage surface overflow flooding in a LOS storm. Rec and Parks proceeded with the project, knowing the environmental impact around the Laguna outfall area. The untreated combined sewage discharge has an increased velocity into a proposed recreational area even in a 2 year storm (Feb 4th 2025). This area has carcinogenic coal tar residue that was to be remediated at a certain depth. Was the pierce St. outfall closed to allow the expansion of the West Harbor? Sure looks that way.

Please share as it is important that we understand how our City is governed, and demand that the Oath of Office, the SF City Charter, the California Constitution, US Constitution and local laws are upheld.

Thank you for taking the time to review and reflect.

The Marina 94123
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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 17/18 You can update your preferences or unsubscribe from this list.

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4/25/25, 9:41 AM Pierce St Closure Findings from Record Requests https://mailchi.mp/65c0ec5f37a7/city-closes-pierce-st-outfall-14052925 18/18 From: Frye, Karen
To: Lennear, Tiffany
Cc: Chau, Sue
Subject: Informational item for Commissioners
Date: Thursday, May 1, 2025 2:40:59 PM
Attachments: Memo to Comm Secretary - PGE EIR.pdf
Please see attached memo for information to be provided to the Commissioners for their information – no action for the Commissioners at this time. Once the Final EIR is done, the item will go to the Commissioners for project approval (not expected until next year). I’m copying Sue Chau who is the Environmental Project Manager for this project. Let me know if you have any questions, thank you.

Karen E. Frye, AICP
San Francisco Public Utilities Commission | Manager, Environmental Management 525 Golden Gate Ave, 11th Fl. | San Francisco, CA 94102 | Office: (415) 554-1652 | Cell: (415) 694-1227 P Delivering excellence in the environmental review and permitting process through teamwork, knowledge, integrity, and respect

l
Environmental Management
525 Golden Gate Avenue, 11th Floor
San Francisco, CA 94102
T 415.934.5700
F 415.934.5750
TTY 415.554.3488

INTER-OFFICE MEMORANDUM

DATE: May 1, 2025

TO: Commission Secretary

FROM: Karen Frye, AICP
Manager – Environmental Management

SUBJECT: Transmittal of CEQA Draft Environmental Impact Report for the SFPUC PG&E Power Asset Acquisition Project

The San Francisco Planning Department has published the Draft Environmental Impact Report for the SFPUC PG&E Power Asset Acquisition Project. The public comment review period has been extended to May 19, 2025. Please transmit the document link to the Commissioners and City Attorney Sheryl Bregman.

https://sfpuc.sharefile.com/d-s91757054644d4a1495efd706206d4548

The document is also available on the Planning Department’s website at https://sfplanning.org/sfceqadocs

CleanPowerSF Sfpuc CommissionMay 13, 2025

CleanPowerSF Sfpuc Commission
May 13, 2025