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
June 2, 2025 through June 12, 2025
(Page 1 of 2)
Date Received From Subject
June 2, 2025 Daisy Ozim Reminder: 6/10 Environmental Justice Roundtable! (email and attachment)
June 6, 2025 Lourdes Enriquez June 11, 2025 BAWSCA Board Policy Committee Special Meeting Agenda (email and attachments)
June 6, 2025 The Marina 94123 Environmental, Procedural, and Legal Failures Related to the Closure of the Pierce Street Outfall and the
Proposed Redevelopment of the East Harbor (Gas
House Cove)
June 9, 2025 SolutionsNotSandbags
San Francisco
Pierce St. Outfall & Gas House Cove and Related
Environmental, Procedural, and Legal Failures
June 9, 2025 SolutionsNotSandbags
San Francisco
Re: Environmental, Procedural, and Legal Failures
Related to the Closure of the Pierce Street Outfall and the Proposed Redevelopment of the East Harbor (Gas
House Cove)
June 10, 2025 David Capelli David Capelli shared ENVIRONMENTAL JUSTICE ROUNDTABLE in Otter
June 10, 2025 David Capelli Meeting Summary for ENVIRONMENTAL JUSTICE
ROUNDTABLE
June 10, 2025 Daisy Ozim ENVIRONMENTAL JUSTICE ROUNDTABLE
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
June 2, 2025 through June 12, 2025
(Page 2 of 2)
Date Received From Subject
June 11, 2025 Peter Drekmeier Re: Palo Alto Info Request to SFPUC (email and attachments)
June 12, 2025 David Friedman Announcing SPUR’s New CEO
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From: Daisy Ozim
To: Daisy Ozim
Cc: Berry II, Larry (REC)
Subject: Reminder: 6/10 Environmental Justice Roundtable! Date: Monday, June 2, 2025 1:35:45 PM
Attachments: TOOLSFOREV.pdf
Greetings Community,
Just a reminder of the Environmental
Justice Roundtable on 6/10. In conjunction
with Parks and Rec and Department of the
Environment/SFPUC, we will be hosting a teach-in regarding new tools for environmental health
and justice, network
opportunities, how
to position your organization or project for EJ funding and what initiated mass removal of funding and closing of organizations. This is a precursor to a budget proposal that will be submitted
to the federal government for multiple states to receive continued funding for environmental
justice and indigenous preservation support. Make sure to bring your young people! This is a great opportunity for youth as well to join. Please spread the word by sending to at least 3 organizations who can join us.
The event will be held June 10th from 2:30-4:00pm.
Here is the link to RSVP:
https://tinyurl.com/nkenvevent
https://calendar.google.com/calendar/event?
action=TEMPLATE&tmeid=MHViMjUxZHNoMnJxYmVsNWVoYWR0YWp0Mm0gZG96aW05MUBt&tmsrc=dozim91%40gmail.com *Daisy Ozim*
Research, Technology and Health
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New tools forNew tools forenvironmental justiceenvironmental justiceand equityand equity Topics Include:Topics Include:
new toolsnew tools fundingfundingopportunitiesopportunities emerging policyemerging policyreviewreview JUNE 10JUNE 10 2:30- 2:30-4:00PM4:00PM
THTH
Carl the Fog?Carl the Fog?Mass power outages?Mass power outages?Hidden satellites forHidden satellites forwhite families only andwhite families only andenvironmentalenvironmentaldestruction?destruction? Environmental JusticeEnvironmental Justicedefunding?defunding?Technology that causesTechnology that causesbacterial resistance?bacterial resistance? Join us for an intro into new tools for environmental justiceJoin us for an intro into new tools for environmental justiceand equity. We introduce tangible tools for organizations andand equity. We introduce tangible tools for organizations andadvocates focusing on varying areas of environmental justiceadvocates focusing on varying areas of environmental justicesuch as soil, water, air and electricity. Due to budget cuts, wesuch as soil, water, air and electricity. Due to budget cuts, wewill also provide organizations with a proper pathway intowill also provide organizations with a proper pathway intostabilizing their funding.stabilizing their funding.
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From: Lourdes Enriquez
To: BAWSCA WMR
Cc: Smegal, Tom; Deborah Grimes; Christiane Barth
Subject: June 11, 2025 BAWSCA Board Policy Committee Special Meeting Agenda Date: Friday, June 6, 2025 1:09:46 PM
Attachments: 25_BPC_June 11_Notice Special Meeting_Final.pdf 25_BPC_June11_Agenda_Special Meeting_FINAL.pdf
Attached is a Notice of Special Meeting and the agenda for the BAWSCA Board Policy Committee meeting on Wednesday, June 11, 2025 at 1:30pm.
Pls. note that it is a Special Meeting due to the different meeting location, which will be Burlingame Library – Lane Room, 480 Primrose Rd, Burlingame, CA 94010
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 June 11, 2025 at 1:30PM
due to a different location
Burlingame Library – Lane Room
480 Primrose Rd., Burlingame, CA 94010
Please note that this meeting will not be
livestreamed due to technical obstacles.
A recording will be posted on the
BAWSCA website following the meeting.
If you have any questions, please call the
BAWSCA office at (650) 349-3000.
See next page for Agenda
SPECIAL MEETING OF THE
BOARD POLICY COMMITTEE
June 11, 2025
1:30 p.m.
At a different location:
Burlingame Library – Lane Room
480 Primrose Rd, Burlingame, CA 94010
This meeting will not be livestreamed due to technical obstacles.
A recording will be posted on the BAWSCA website following the meeting.
AGENDA
Agenda Item Presenter Page#
1. Call To Order, and Roll Call (Hardy)
Roster of Committee Members (Attachment)
Pg 3
2. Comments by Chair (Hardy)
3. Consent Calendar (Hardy)
A. Approval of Minutes from the April 9, 2025 meeting (Attachment)
Pg 5
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. Reports and Discussions
A. BAWSCA’s 2021–2023 Drought Report (Attachment) (Francis) Issue: What are the findings from the 2021-23 Drought Report? Information to Committee: Staff report and oral report.
Committee Action Requested: Comments and Questions.
Pg 19
B. CEO/General Manager Performance Evaluation Process (Chambers) Issue: Are there any changes to the evaluation process? Information to Committee: Oral Report
Committee Action Requested: Comments and Questions.
6. CEO Reports (Smegal)
A. 2025 Demand Study Update
B. Water Supply Conditions
C. FERC/Bay Delta Plan Update
D. CEO/General Manager’s Letter (Attachment)
E. Board Policy Committee Calendar (Attachment)
F. Correspondence Packet (Under Separate Cover)
Pg 21
Pg 23
7. 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)
8. Report from Closed Session (Schutte)
9. Comments by Committee Members (Hardy)
10. Adjournment to the Next Meeting (Hardy)
August 13, 2025 at Foster City Community Building – Wind Room
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: The Marina 94123
To: [email protected]; Mayor Daniel Lurie; Eileen White@Waterboards; Sherrill, Stephen (BOS); Johnston, Timothy (CPC); Pollak, Josh (CPC); Ionin, Jonas (CPC); [email protected]; Ko, Albert (DPW); SF-Supervisors; Commission; Prather, Joel
Cc: [email protected]; KWART, JEN (CAT); John-Baptiste, Alicia (MYR); Bill Johnson@Waterboards; Sam Plummer@Waterboards; Brian Thompson@Waterboards; Thomas Mumley@Waterboards; Robert Schlipf@Waterboards; Board Support@waterboards; Yana Garcia@StEPA; commentletters; Joel Jones@EPA; Martha Guzman EPA; Samantha Ricci@USDOJ; Daniel Kostek; Ellen Blake; Becky Mitschele; Dharia Ekta@usdoj; Amy Miller-EPA; [email protected]; Eric Magnan; Sejal@baykeeper; [email protected]; Jeff Ruch; TRT; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; SolutionsNotSandbags San Francisco; Neighbors Against Flooding; Mission Creek; [email protected]
Subject: Environmental, Procedural, and Legal Failures Related to the Closure of the Pierce Street Outfall and the Proposed Redevelopment of the East Harbor (Gas House Cove) Date: Friday, June 6, 2025 4:29:13 PM
Dear Mayor, Board of Supervisors, SFPUC, SFDPW, Rec and Parks and The Regional Water Board.
As you are aware The Pierce Street outfall, part of San Francisco’s Combined Sewer System (CSS), was permanently decommissioned in 2021 resulting in major sewerage failure in the Marina District. We found it surprising that such a decision was made to improve water quality in the West Marina Harbor but that no Supplemental Environmental Impact Report (SEIR) or CEQA Addendum was filed with the Planning Department in connection with the closure. Read our record request findings HERE Now we are facing the redevelopment of The East Harbor (Gas House Cove under the 2007 Final Environmental Impact Report (FEIR), which assumed the outfall remained operational and did not assess the impacts of its closure.
On further investigation we have the following serious concerns:
1. CEQA Violations – Substantial Project Changes Without New Review The 2007 FEIR is now legally and scientifically obsolete.
The 2021 closure of the Pierce Street outfall constitutes a “substantial change” in project circumstances and environmental conditions under CEQA Guidelines § 15162(a)(2).
Significant impacts include:
Increased CSO volume at the Laguna outfall
Repeated flooding on Marina Boulevard
Increased contamination of Gas House Cove and surrounding waters Under § 15162(a)(3), newly available information (e.g. sewage-related boat capsizing, increased bacteria levels, and failed mitigation) triggers the legal requirement for a Supplemental EIR.
Proceeding without this review is a procedural violation of CEQA and undermines transparency and public trust.
2. Lack of Updated CEQA Review
The decommissioning of the outfall fundamentally altered stormwater routing and discharge points.
The 2007 FEIR cannot serve as the governing document for current project decisions.
An updated environmental analysis is legally required before any harbor redevelopment proceeds.
3. Withholding of Critical Internal Flood Risk Modeling A 2017 SFDPW study warned of increased flooding risk due to the outfall’s closure during Level of Service (LOS) storms.
SFPUC engineers recommended raising the weir or modeling the impact of redirected flows—yet these warnings were never disclosed publicly or presented to Planning.
4. Procedural Failures: Lack of Notice and Public Engagement No neighborhood meetings or public hearings were held post-closure.
No CEQA review or Planning Commission hearing occurred regarding the environmental effects of the CSO re-routing.
This violates San Francisco Administrative Code Chapter 31 and Planning Code § 303 (Public Notice and Hearing Requirements).
5. Public Health Hazards in Water Contact Areas
CSO discharges from Laguna outfall have increased contamination near Crissy Field and the Marina Harbor.
Despite Title 17 of the California Code of Regulations requiring public notification, no water quality signage has been posted in the harbor, and Crissy Field signage is minimal and insufficient.
2024–2025 test results show water samples exceeding state bacterial standards for safe recreational use.
6. Failure to Coordinate Across City Agencies
Under San Francisco Charter § 4.102 and the California Constitution (Art. XX, Sec. 3), all City officials have a duty to act in the public interest and coordinate on issues affecting public health and safety.
No records indicate coordinated reviews between SFPUC, Rec and Parks, Planning, and SFDPH—either before or after the outfall closure.
7. Current Redevelopment Plans Compound Known Hazards
Rec and Parks is moving forward with redesigning the East Harbor, including shallow water recreational areas, in a zone now subject to heightened sewage contamination.
The design mirrors the same public health risks that led to the Pierce outfall’s closure.
Sediment remediation standards were developed prior to the outfall closure and are now inadequate.
8. Charter Obligations of the Mayor and Board of Supervisors Under San Francisco Charter §§ 3.100–3.104, the Mayor is responsible for coordinating departments and ensuring operations are carried out in the public interest.
Under Charter §§ 2.100–2.115, the Board of Supervisors have:
§ 2.114 – Investigative Powers:
May investigate any City department and compel testimony or documentation.
§ 2.115 – Policy Oversight and Direction:
Must ensure departmental alignment with health, safety, and environmental protections.
All elected officials are bound by Article XX § 3 of the California Constitution to uphold laws such as CEQA and safeguard public welfare.
The siloed decisions made here constitute a Charter-level failure of oversight and coordination.
REQUESTED ACTIONS
1. Immediately suspend all permitting and development activities related to East Harbor/Gas House Cove until a Supplemental EIR is completed.
2. Mandate cross-agency review of the post-closure CSO redirection and its implications for flooding, recreation, and water quality.
3. Hold public meetings to inform Marina residents and address the health and safety consequences of the 2021 Pierce St outfall closure.
4. Launch a formal investigation into whether CEQA and Planning Code procedural requirements were violated.
5. Require immediate public signage warning of water quality issues in the Marina Harbor and increase warning signage the full lenght of Crissy Field.
Respectfully submitted,
The Marina 94123
Coalition of Marina Residents
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From: SolutionsNotSandbags San Francisco
Subject: Pierce St. Outfall & Gas House Cove and Related Environmental, Procedural, and Legal Failures Date: Monday, June 9, 2025 3:22:16 PM
Dear Friends of SNS,
Please see below for the latest messages to the Mayor Lurie and others regarding the sewer- flooding in SF.
Please let us know if you have any questions.
Thank you,
SNS
June 9, 2025
Dear Mayor Lurie,
The letter from U.S. EPA Administrator Andrew Wheeler to California Governor Gavin Newsom in 2019 appears to have encouraged the San Francisco Bay Area Regional Water Quality Board to take action against the SFPUC regarding the sewage discharges into “homes, businesses, streets, and sidewalks.”
However, San Francisco has not fully complied with the Cleanup and Abatement Order. We welcome the new EPA Region 9 administrator, Mr. Josh Cook, to this conversation. We hope his guidance and cooperation with the Regional Water Board will lead us to a good and fair resolution to this matter.
We also look forward to your strong leadership and interest in public health and safety combined with your desire for transparency and accountability in all city departments. We ask for an examination of the SFPUC's management, dating back to 2010, and the decision to remove funding for the Sewer System Improvement Project. This decision was catastrophic and led to increased sewer-flooding, delays, and increased costs to the ratepayers.
The problems resulting from the closure of the Pierce Street Outfall and the plans for the Gashouse Cove pollution remediation plan (which is currently under review by the SF Planning Dept.) are intricately connected.
We agree this project is important. However we are concerned that the 2007 SF Marina Renovation Project FEIR may cause more problems for the project then redoing the problematic sections on "Hydrology and Water Quality" as a supplemental EIR (SEIR).
Marina community members raised concerns during the 2002-2007 EIR process claiming that building new slips and enclosing the existing sewage outfall would increase pollution problems (see page 273.) Staff from Rec & Park also downplayed the impacts of sewage discharges from the Pierce St. Outfall.
However, soon after the work on the 2011 project began there were problems—sewage was being discharged into the newly enclosed area. In 2015 SFPUC engineers did a study to improve SF's Bayside CSO operations. They considered raising the Pierce Street Outfall due to "complaints from boat owners." This probably resulted from the construction of the new breakwater east of the Pierce Street Outfall in 2011 and the new boat slips in front of the existing Pierce Street Outfall. In 2017, instead of following up on this suggestion to raise the weir at the Pierce Street Outfall, SFPUC decided to entirely block it off. This led to never- before-seen sewer-flooding into approximately fifty homes along Marina Blvd. It also caused an increase in sewage discharges from the Laguna Street Outfall into the Gashouse Cove area —the very same area which the Rec & Park Department now plans to make into a water recreation area. The closure of the Pierce Street Outfall has directed sewage out of the city- owned marina into Crissy Field, Gashouse Cove, and into the broader baywaters where people swim year-round.
This has all led to the current permit violation and legal actions by the US EPA, State Regional Water Board, and environmental non-profit organizations. In 2019 SFPUC staff provided limited information to city planners
, which led to the improperly issued Categorical
Exemption for the closure project.
Closure of the Pierce Street Outfall was without proper approvals, is now a major factor in the ongoing enforcement action, and is creating hazardous and negative impacts to public health and safety.
Additionally, as long as the dredging and the PG&E cleanup continues, and especially when there is rain, the sewage problems will spread into Gashouse Cove. There needs to be a supplemental EIR which considers all of these factors. Until San Francisco returns the system to its previously permitted state, both the West Basin and East Basin (Gashouse Cove) projects should be put on hold. Until the sewer system corrections are made, there is no way for those projects to be successful.
We agree that this PG&E remediation project needs to proceed as soon as possible. The costs are rapidly accelerating and there are limits to what PG&E will pay—which means the taxpayers of San Francisco will probably end up footing the bill.
Conflicts and lack of
communication and planning between city agencies will only—especially when it comes to sea level rise.
That is why we request that you take control of this situation by demanding improved coordination and communication between departments. Who ends up paying for all the litigation, confusion, and institutional blunders? The ratepayers and taxpayers of San Francisco—who now, along with the increased costs, have to deal with sewage-tainted waters.
Thank you for your attention to this important matter and entrenched problem.
Sincerely,
Solutions Not Sandbags
--
SOLUTIONS NOT SANDBAGS
Bringing Awareness to SF's Failing Sewer System
Website: SolutionsNotSandbags.org
YouTube I Instagram I Twitter I Facebook
On Fri, Jun 6, 2025 at 4:29 PM The Marina 94123 <[email protected]> wrote:
Dear Mayor, Board of Supervisors, SFPUC, SFDPW, Rec and Parks and The Regional Water Board.
As you are aware The Pierce Street outfall, part of San Francisco’s Combined Sewer System (CSS), was permanently decommissioned in 2021 resulting in major sewerage failure in the Marina District. We found it surprising that such a decision was made to improve water quality in the West Marina Harbor but that no Supplemental Environmental Impact Report (SEIR) or CEQA Addendum was filed with the Planning Department in connection with the closure. Read our record request findings HERE Now we are facing the redevelopment of The East Harbor (Gas House Cove under the 2007 Final Environmental Impact Report (FEIR), which assumed the outfall remained operational and did not assess the impacts of its closure.
On further investigation we have the following serious concerns:
1. CEQA Violations – Substantial Project Changes Without New Review The 2007 FEIR is now legally and scientifically obsolete.
The 2021 closure of the Pierce Street outfall constitutes a “substantial change” in project circumstances and environmental conditions under CEQA Guidelines § 15162(a)(2).
Significant impacts include:
Increased CSO volume at the Laguna outfall
Repeated flooding on Marina Boulevard
Increased contamination of Gas House Cove and surrounding waters Under § 15162(a)(3), newly available information (e.g. sewage-related boat capsizing, increased bacteria levels, and failed mitigation) triggers the legal requirement for a Supplemental EIR.
Proceeding without this review is a procedural violation of CEQA and undermines transparency and public trust.
2. Lack of Updated CEQA Review
The decommissioning of the outfall fundamentally altered stormwater routing and discharge points.
The 2007 FEIR cannot serve as the governing document for current project decisions.
An updated environmental analysis is legally required before any harbor redevelopment proceeds.
3. Withholding of Critical Internal Flood Risk Modeling A 2017 SFDPW study warned of increased flooding risk due to the outfall’s closure during Level of Service (LOS) storms.
SFPUC engineers recommended raising the weir or modeling the impact of redirected flows—yet these warnings were never disclosed publicly or presented to Planning.
4. Procedural Failures: Lack of Notice and Public Engagement No neighborhood meetings or public hearings were held post-closure.
No CEQA review or Planning Commission hearing occurred regarding the environmental effects of the CSO re-routing.
This violates San Francisco Administrative Code Chapter 31 and Planning Code § 303 (Public Notice and Hearing Requirements).
5. Public Health Hazards in Water Contact Areas
CSO discharges from Laguna outfall have increased contamination near Crissy Field and the Marina Harbor.
Despite Title 17 of the California Code of Regulations requiring public notification, no water quality signage has been posted in the harbor, and Crissy Field signage is minimal and insufficient.
2024–2025 test results show water samples exceeding state bacterial standards for safe recreational use.
6. Failure to Coordinate Across City Agencies
Under San Francisco Charter § 4.102 and the California Constitution (Art. XX, Sec. 3), all City officials have a duty to act in the public interest and coordinate on issues affecting public health and safety.
No records indicate coordinated reviews between SFPUC, Rec and Parks, Planning, and SFDPH—either before or after the outfall closure.
7. Current Redevelopment Plans Compound Known Hazards
Rec and Parks is moving forward with redesigning the East Harbor, including shallow water recreational areas, in a zone now subject to heightened sewage contamination.
The design mirrors the same public health risks that led to the Pierce outfall’s closure.
Sediment remediation standards were developed prior to the outfall closure and are now inadequate.
8. Charter Obligations of the Mayor and Board of Supervisors Under San Francisco Charter §§ 3.100–3.104, the Mayor is responsible for coordinating departments and ensuring operations are carried out in the public interest.
Under Charter §§ 2.100–2.115, the Board of Supervisors have:
§ 2.114 – Investigative Powers:
May investigate any City department and compel testimony or documentation.
§ 2.115 – Policy Oversight and Direction:
Must ensure departmental alignment with health, safety, and environmental protections.
All elected officials are bound by Article XX § 3 of the California Constitution to uphold laws such as CEQA and safeguard public welfare.
The siloed decisions made here constitute a Charter-level failure of oversight and coordination.
REQUESTED ACTIONS
1. Immediately suspend all permitting and development activities related to East Harbor/Gas House Cove until a Supplemental EIR is completed.
2. Mandate cross-agency review of the post-closure CSO redirection and its implications for flooding, recreation, and water quality.
3. Hold public meetings to inform Marina residents and address the health and safety consequences of the 2021 Pierce St outfall closure.
4. Launch a formal investigation into whether CEQA and Planning Code procedural requirements were violated.
5. Require immediate public signage warning of water quality issues in the Marina Harbor and increase warning signage the full lenght of Crissy Field.
Respectfully submitted,
The Marina 94123
Coalition of Marina Residents
SOLUTIONS NOT SANDBAGS
Bringing Awareness to SF's Failing Sewer System
Website: SolutionsNotSandbags.org
YouTube I Instagram I Twitter I Facebook
This Message Is From an External Sender
This message came from outside your organization.
Report Suspicious
From: SolutionsNotSandbags San Francisco
To: Mayor Daniel Lurie; [email protected]; Ionin, Jonas (CPC); Eileen White@Waterboards; [email protected]; The Marina 94123
Cc: [email protected]; Sherrill, Stephen (BOS); Johnston, Timothy (CPC); Pollak, Josh (CPC); Ko, Albert (DPW); SF-Supervisors; Commission; Prather, Joel; KWART, JEN (CAT); John-Baptiste, Alicia (MYR); Bill Johnson@Waterboards; Sam Plummer@Waterboards; Brian Thompson@Waterboards; Thomas Mumley@Waterboards; Robert Schlipf@Waterboards; Yana Garcia@StEPA; commentletters; Joel Jones@EPA; Martha Guzman EPA; Samantha Ricci@USDOJ; Daniel Kostek; Ellen Blake; Becky Mitschele; Dharia Ekta@usdoj; Amy Miller-EPA; [email protected]; Eric Magnan; Sejal@baykeeper; [email protected]; Jeff Ruch; TRT; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Neighbors Against Flooding; Mission Creek; [email protected]; Save SF Marina Green; [email protected]; Board Support@waterboards Subject: Re: Environmental, Procedural, and Legal Failures Related to the Closure of the Pierce Street Outfall and the Proposed Redevelopment of the East Harbor (Gas House Cove) Date: Monday, June 9, 2025 2:50:57 PM
June 9, 2025
Dear Mayor Lurie,
The
letter from U.S. EPA Administrator Andrew Wheeler to California Governor Gavin Newsom in 2019 appears to have encouraged the San Francisco Bay Area Regional Water Quality Board to take action against the SFPUC regarding the sewage discharges into “homes, businesses, streets, and sidewalks.”
However, San Francisco has not fully complied with the Cleanup and Abatement Order. We welcome the new EPA Region 9 administrator, Mr. Josh Cook, to this conversation. We hope his guidance and cooperation with the Regional Water Board will lead us to a good and fair resolution to this matter.
We also look forward to your strong leadership and interest in public health and safety combined with your desire for transparency and accountability in all city departments. We ask for an examination of the SFPUC's management, dating back to 2010, and the decision to remove funding for the Sewer System Improvement Project. This decision was catastrophic and led to increased sewer-flooding, delays, and increased costs to the ratepayers.
The problems resulting from the closure of the Pierce Street Outfall and the plans for the Gashouse Cove pollution remediation plan (which is currently under review by the SF Planning Dept.) are intricately connected.
We agree this project is important. However we are concerned that the 2007 SF Marina
Renovation Project FEIR may cause more problems for the project then redoing the problematic sections on "Hydrology and Water Quality" as a supplemental EIR (SEIR).
Marina community members raised concerns during the 2002-2007 EIR process claiming that building new slips and enclosing the existing sewage outfall would increase pollution problems (see page 273.) Staff from Rec
& Park also downplayed the impacts of sewage
discharges from the Pierce St. Outfall.
However, soon after the work on the 2011 project began there were problems—sewage was being discharged into the newly enclosed area. In 2015 SFPUC engineers did a study to improve SF's Bayside CSO operations. They considered raising the Pierce Street Outfall due to "complaints from boat owners." This probably resulted from the construction of the new breakwater east of the Pierce Street Outfall in 2011 and the new boat slips in front of the existing Pierce Street Outfall. In 2017, instead of following up on this suggestion to raise the weir at the Pierce Street Outfall, SFPUC decided to entirely block it off. This led to never- before-seen sewer-flooding into approximately fifty homes along Marina Blvd. It also caused an increase in sewage discharges from the Laguna Street Outfall into the Gashouse Cove area —the very same area which the Rec & Park Department now plans to make into a water recreation area. The closure of the Pierce Street Outfall has directed sewage out of the city- owned marina into Crissy Field, Gashouse Cove, and into the broader baywaters where people swim year-round.
This has all led to the current permit violation and legal actions by the US EPA, State Regional Water Board, and environmental non-profit organizations. In 2019 SFPUC staff provided limited information to city planners
, which led to the improperly issued Categorical
Exemption for the closure project.
Closure of the Pierce Street Outfall was without proper approvals, is now a major factor in the ongoing enforcement action, and is creating hazardous and negative impacts to public health and safety.
Additionally, as long as the dredging and the PG&E cleanup continues, and especially when there is rain, the sewage problems will spread into Gashouse Cove. There needs to be a supplemental EIR which considers all of these factors. Until San Francisco returns the system to its previously permitted state, both the West Basin and East Basin (Gashouse Cove) projects should be put on hold. Until the sewer system corrections are made, there is no way for those projects to be successful.
We agree that this PG&E remediation project needs to proceed as soon as possible. The costs are rapidly accelerating and there are limits to what PG&E will pay—which means the taxpayers of San Francisco will probably end up footing the bill.
Conflicts and lack of
communication and planning between city agencies will only—especially when it comes to sea level rise.
That is why we request that you take control of this situation by demanding improved coordination and communication between departments. Who ends up paying for all the litigation, confusion, and institutional blunders? The ratepayers and taxpayers of San Francisco—who now, along with the increased costs, have to deal with sewage-tainted waters.
Thank you for your attention to this important matter and entrenched problem.
Sincerely,
Solutions Not Sandbags
--
SOLUTIONS NOT SANDBAGS
Bringing Awareness to SF's Failing Sewer System
Website: SolutionsNotSandbags.org
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On Fri, Jun 6, 2025 at 4:29 PM The Marina 94123 <[email protected]> wrote:
Dear Mayor, Board of Supervisors, SFPUC, SFDPW, Rec and Parks and The Regional Water Board.
As you are aware The Pierce Street outfall, part of San Francisco’s Combined Sewer System (CSS), was permanently decommissioned in 2021 resulting in major sewerage failure in the Marina District. We found it surprising that such a decision was made to improve water quality in the West Marina Harbor but that no Supplemental Environmental Impact Report (SEIR) or CEQA Addendum was filed with the Planning Department in connection with the closure. Read our record request findings HERE Now we are facing the redevelopment of The East Harbor (Gas House Cove under the 2007 Final Environmental Impact Report (FEIR), which assumed the outfall remained operational and did not assess the impacts of its closure.
On further investigation we have the following serious concerns:
1. CEQA Violations – Substantial Project Changes Without New Review The 2007 FEIR is now legally and scientifically obsolete.
The 2021 closure of the Pierce Street outfall constitutes a “substantial change” in project circumstances and environmental conditions under CEQA Guidelines § 15162(a)(2).
Significant impacts include:
Increased CSO volume at the Laguna outfall
Repeated flooding on Marina Boulevard
Increased contamination of Gas House Cove and surrounding waters Under § 15162(a)(3), newly available information (e.g. sewage-related boat capsizing, increased bacteria levels, and failed mitigation) triggers the legal requirement for a Supplemental EIR.
Proceeding without this review is a procedural violation of CEQA and undermines transparency and public trust.
2. Lack of Updated CEQA Review
The decommissioning of the outfall fundamentally altered stormwater routing and discharge points.
The 2007 FEIR cannot serve as the governing document for current project decisions.
An updated environmental analysis is legally required before any harbor redevelopment proceeds.
3. Withholding of Critical Internal Flood Risk Modeling A 2017 SFDPW study warned of increased flooding risk due to the outfall’s closure during Level of Service (LOS) storms.
SFPUC engineers recommended raising the weir or modeling the impact of redirected flows—yet these warnings were never disclosed publicly or presented to Planning.
4. Procedural Failures: Lack of Notice and Public Engagement No neighborhood meetings or public hearings were held post-closure.
No CEQA review or Planning Commission hearing occurred regarding the environmental effects of the CSO re-routing.
This violates San Francisco Administrative Code Chapter 31 and Planning Code § 303 (Public Notice and Hearing Requirements).
5. Public Health Hazards in Water Contact Areas
CSO discharges from Laguna outfall have increased contamination near Crissy Field and the Marina Harbor.
Despite Title 17 of the California Code of Regulations requiring public notification, no water quality signage has been posted in the harbor, and Crissy Field signage is minimal and insufficient.
2024–2025 test results show water samples exceeding state bacterial standards for safe recreational use.
6. Failure to Coordinate Across City Agencies
Under San Francisco Charter § 4.102 and the California Constitution (Art. XX, Sec. 3), all City officials have a duty to act in the public interest and coordinate on issues affecting public health and safety.
No records indicate coordinated reviews between SFPUC, Rec and Parks, Planning, and SFDPH—either before or after the outfall closure.
7. Current Redevelopment Plans Compound Known Hazards
Rec and Parks is moving forward with redesigning the East Harbor, including shallow water recreational areas, in a zone now subject to heightened sewage contamination.
The design mirrors the same public health risks that led to the Pierce outfall’s closure.
Sediment remediation standards were developed prior to the outfall closure and are now inadequate.
8. Charter Obligations of the Mayor and Board of Supervisors Under San Francisco Charter §§ 3.100–3.104, the Mayor is responsible for coordinating departments and ensuring operations are carried out in the public interest.
Under Charter §§ 2.100–2.115, the Board of Supervisors have:
§ 2.114 – Investigative Powers:
May investigate any City department and compel testimony or documentation.
§ 2.115 – Policy Oversight and Direction:
Must ensure departmental alignment with health, safety, and environmental protections.
All elected officials are bound by Article XX § 3 of the California Constitution to uphold laws such as CEQA and safeguard public welfare.
The siloed decisions made here constitute a Charter-level failure of oversight and coordination.
REQUESTED ACTIONS
1. Immediately suspend all permitting and development activities related to East Harbor/Gas House Cove until a Supplemental EIR is completed.
2. Mandate cross-agency review of the post-closure CSO redirection and its implications for flooding, recreation, and water quality.
3. Hold public meetings to inform Marina residents and address the health and safety consequences of the 2021 Pierce St outfall closure.
4. Launch a formal investigation into whether CEQA and Planning Code procedural requirements were violated.
5. Require immediate public signage warning of water quality issues in the Marina Harbor and increase warning signage the full lenght of Crissy Field.
Respectfully submitted,
The Marina 94123
Coalition of Marina Residents
--
SOLUTIONS NOT SANDBAGS
Bringing Awareness to SF's Failing Sewer System
Website: SolutionsNotSandbags.org
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1 From: David Capelli via Otter.ai <[email protected]>
Sent: Tuesday, June 10, 2025 2:30 PM
To: Commission
Subject: David Capelli shared ENVIRONMENTAL JUSTICE ROUNDTABLE in Otter This Message Is From an Untrusted Sender
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1 From: David Capelli via Otter.ai <[email protected]>
Sent: Tuesday, June 10, 2025 4:16 PM
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From: Google Calendar on behalf of Daisy Ozim
To: [email protected]; [email protected]; [email protected]; Anderson, Alonzo (DPH); [email protected]; [email protected]; [email protected]; Commission; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Lee, Janice (DPH); Arce, Julio C; [email protected]; [email protected]; [email protected]; [email protected]; Du, Montien; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Daisy Ozim
Subject: ENVIRONMENTAL JUSTICE ROUNDTABLE
Date: Tuesday, June 10, 2025 1:03:35 PM
Hi all, Just a reminder the roundtable is at 2:30pm. I am sending out a lunch time reminder just in case! Below is the original email.
I am sorry if you haven't gotten my messages! My email is wonky these days. ////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////// Greetings Community,
Just a reminder of the Environmental Justice Roundtable on 6/10. In conjunction with Parks and Rec and Department of the Environment/SFPUC, we will be hosting a teach-in regarding new tools for environmental health and justice, network opportunities, how to position your organization or project for EJ funding and what initiated mass removal of funding and closing of organizations. This is a precursor to a budget proposal that will be submitted to the federal government for multiple states to receive continued funding for environmental justice and indigenous preservation support. Make sure to bring your young people! This is a great opportunity for youth as well to join. Please spread the word by sending to at least 3 organizations who can join us.
The event will be held June 10th from 2:30-4:00pm.
Here is the link to RSVP:
https://tinyurl.com/nkenvevent
https://calendar.google.com/calendar/event?
action=TEMPLATE&tmeid=MHViMjUxZHNoMnJxYmVsNWVoYWR0YWp0Mm0gZG96aW05MUBt&tmsrc=dozim91%40gmail.com Best,
Daisy
ENVIRONMENTAL JUSTICE ROUNDTABLE
)Tuesday Jun 10, 2025 ⋅ 2pm – 4:30pm )Pacific Time - Los Angeles ,Greetings Community
In conjunction with SFPUC and Department of the Environment, we will be hosting a roundtable regarding new tools for environmental health and justice, how to position your organization or project for EJ funding and what initiated mass removal of funding and closing of organizations. This is a precursor to a budget proposal that will be submitted to the federal government for multiple states to receive continued funding for environmental justice and indigenous preservation support. There are new requirements set forth that we will go .over during the training. Please spread the word by sending to at least 3 organizations who can join us .The event will be held June 10th from 2:30-4:00pm
:Here is the link to RSVP
https://tinyurl.com/nkenvevent
https://us02web.zoom.us/j/8458678694?pwd=dStGTE4zU0RwdFh0c21jNmc0MXdlZz09 Guests
organizer - Daisy Ozim
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This message came from outside your organization. Report Suspicious From: Peter Drekmeier
To: Commission
Subject: Re: Palo Alto Info Request to SFPUC
Date: Wednesday, June 11, 2025 7:29:36 AM
Attachments: 20250415_UAC_Letter_to_SFPUC_-_Greer_Stone.pdf SFPUC Response to Councilmember Stone Palo Alto Ltr 05.12.25.pdf Dear Commissioners:
Water rates has increased fourfold over the past 17 years, sending a strong price signal to consumers to use water more efficiently. As a result, water demand has decreased 25%, yet fixed costs for the Regional Water System continue to increase, creating an even stronger incentive for people to conserve. This is known by economists as a death spiral — water rates increase, people use less water, rates must increase further to cover fixed costs, and the cycle continues.
Earlier this year, Palo Alto's Utilities Advisory Commission (UAC) reviewed a $559,000 One Water Plan, which explored alternative water supplies that Palo Alto might need to develop.
The UAC rejected the Plan, finding it was based on a false premise that Palo Alto might be subject to 50% rationing. After thorough review of the available information, they were convinced that the 50% rationing figure provided by the SFPUC was unreasonable and unjustified.
Seeking additional information to help with prudent water supply and financial planning, the UAC recommended that Palo Alto request answers from the SFPUC to several questions.
Palo Alto’s BAWSCA Director then sent a letter to the SFPUC with that request (letter attached). The SFPUC refused to provide the information (letter attached).
Given the challenging financial burden ratepayers already face, it's imperative that additional investments that will further increase rates only be made based on the best available information and analysis. Transparency is of critical importance. Please direct your staff to answer the questions posed by Palo Alto.
Thank you for your consideration.
Sincerely,
Peter Drekmeier
-----------------------
Peter Drekmeier
Policy Director
Tuolumne River Trust
[email protected]
From The Desk of Councilmember Greer Stone
CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | (650) 329-2571
General Manager Dennis Herrera
San Francisco Public Utilities Commission
525 Golden Gate Avenue
San Francisco, CA 94102
Dear GM Herrera:
The City of Palo Alto appreciated the participation of Steve Ritchie from your staff at our Utilities Advisory Commission (UAC) meeting on November 6, 2024.
Since then, the UAC has reviewed Palo Alto’s One Water Plan (a roadmap for addressing potential water supply shortfalls) and is recommending the City Council reject the plan as is. They are concerned that the impetus of the plan (Palo Alto might experience 50% rationing at some point) is unreasonable, and that before committing to large-scale investments in alternative water supplies, we should feel confident they are needed. The City Council has yet to review the plan and discuss further the UAC’s recommendation, but your assistance in answering the following questions would be helpful in our future decision making.
The UAC is recommending that we request the following information from the SFPUC to help inform our decision.
1. What is the return period of the design drought and the calculations behind it? Please also provide sensitivity analyses evaluating the impacts of two less severe design droughts on the return period, the water supply deficit, and associated financial impacts (costs). The first alternative design drought would simply remove the final year from the current design drought.
The second would replace the 1976-1977 drought in the current design drought with the average water supply deficit during the 1987-1992 drought.
2. What is the impact of using lower demand projections (including the SFPUC's Finance Bureau assumptions and projections informed by BAWSCA’s 2022 demand study low scenario) on the potential water supply deficit? How would these lower demand projections influence the SFPUC’s Alternative Water Supply Plan and associated revenue requirements and cost/acre foot to wholesale customers?
3. How would the combination of the two less conservative design droughts and lower demand projections influence potential water rationing and the need to pursue alternative water supplies?
4. Using current demand and the three droughts presented in the Long-Term Vulnerability Assessment, what would the low point of the SFPUC’s total system storage have been had the Bay Delta Plan been in affect at the time of those droughts?
From The Desk of Councilmember Greer Stone
CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | (650) 329-2571
We would appreciate responses to these questions by the end of April to help us with our long-term financial planning.
Thank you for your attention,
Greer Stone, Palo Alto Councilmember
BAWSCA Director
Services of the San Francisco Public Utilities Commission
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
May 12, 2025
Councilmember Greer Stone
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Councilmember Stone,
Thank you for your recent undated letter containing questions related to our water supply planning.
As a regional water provider, we work diligently to ensure critical water supply is available to our
customers now and into the future, in consideration of drought and climate change as well as new regulations that may impact our water supplies.
To address regional water supply planning, the SFPUC works collaboratively with the Bay Area Water Supply and Conservation Agency (BAWSCA) to understand the interests and needs
of our wholesale customers, and the residents and businesses they serve. This effort ensures our cooperative planning addresses the needs of the
1.8 million residents and thousands of businesses who depend on the Hetch Hetchy Regional Water System for their health and wellbeing. The SFPUC looks to BAWSCA to gather current customer demand and future demand projections in alignment with the individual wholesale customers and their respective planning agencies.
Though we appreciate your questions, the SFPUC cannot effectively undertake water supply planning through response to individual wholesale customers, elected or appointed officials. Additionally, your questions request new analyses that are not available nor currently planned.
As we shared with Palo Alto’s Utility Advisory Commission in November 2024, the SFPUC’s design drought is a planning model utilized to assess how the Hetch Hetchy Regional Water System will perform under drought conditions worse than any we have experienced. There are no calculations on the
return period of the design
drought, as a return period has no relevance to the need to plan for a drought worse than any we have experienced.
The Alternative Water Supply Plan is also a planning document intended to examine the alternative water supplies needed to be developed to address dry year shortages
in the regional water system. Spending on the Alternative Water Supply Plan currently
represents minimal annual expenditures, and future expenditures for construction of any alternative water supply project will be undertaken when water supply and demands are projected to require this new supply. Planning for projects related to recycled water or purified water takes considerable time, frequently decades. To ensure we have supply for our regional needs, we must prepare now so we can move projects forward when regional needs are fully developed.
What we do know is our Tuolumne River and local water supplies are limited and are not expected to grow over time. Through active and passive conservation by all our customers,
the implementation of water efficient plumbing standards, and development of alternative water supplies that utilize the best water for specific end uses, we are amongst the most water efficient areas in California. However, we can only harden water demand so much. As our population continues to grow, and we face extended droughts and climate change, we must be prepared to respond to these new demands for the health and wellbeing of our future generations.
Thank you for your inquiry. We look forward to continued engagement through our work with BAWSCA on our regional water supply needs and planning.
Sincerely,
Dennis J.
Herrera
General Manager
cc: Steven R. Ritchie, Assistant General Manager, Water, SFPUC Tom Smegal, BAWSCA CEO/General Manager
1 From: David Friedman <[email protected]>
Sent: Thursday, June 12, 2025 8:07 AM
To: Commission
Subject: Announcing SPUR’s New CEO
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Dear Ann,
I’m pleased to share that SPUR’s Board of Directors has appointed Sean Elsbernd as the organization’s next President and CEO.
Many of you may know Sean from his years of public service, most recently as Chief of Staff to San Francisco Mayor London Breed, where he led city and county operations and oversaw the city’s regional partnerships and state legislative work. He previously served as State Director for U.S. Senator Dianne Feinstein and as a member of the San Francisco Board of Supervisors.
Sean has also held key transit leadership roles, including serving as Chair of the Caltrain Board of Directors and as a Director of the Golden Gate Bridge, Highway and Transportation District. He brings deep experience in public policy, a strong understanding of regional governance and a long-standing commitment to making the Bay Area a more sustainable, equitable and vibrant place to live.
As interim CEO, I’ve had the privilege of working closely with the SPUR team and Board throughout this transition. I’ve seen firsthand the dedication and talent that drive this work forward every day. I’ve also been reminded how much SPUR’s progress depends on the support of its members and partners.
Thanks to you, we’ve continued to advance our 2025 agenda: pushing for more inclusive housing policies, reimagining our downtowns, advocating for reliable transit and 2 sustainable infrastructure and championing good government across the region.
With Sean’s leadership and this incredible team in place, SPUR is entering its next chapter from a position of strength and clarity. I am proud to have helped guide the organization through this moment and excited to see what comes next.
Thank you again for being part of the SPUR community.
Sincerely,
David
David Friedman
Interim President and CEO, SPUR
SPUR Urban Center, 654 Mission Street, San Francisco, CA 94105-4015 (415) 781-8726 | [email protected]
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