Andrew DeGraca
Water Quality Division Director
September 9, 2025
SFPUC
Cross-Connection Control Plan
and Program Manual
Outline of Presentation
• What is a Cross Connection?
• SFPUC Cross Connection Control Program
• New Regulations
• SFPUC Cross-Connection Control Plan
and Program Manual highlights
• Plan and Program Manual Schedule
WHAT IS A CROSS CONNECTION?
“An interconnection between a potable water
supply and a non-potable source via any actual
or potential connection or structural arrangement
between a public water system and any source
or distribution system containing liquid, gas, or
other substances not from an approved water
supply.” Source: SWRCB Cross-Connection Control Policy Handbook Cross Connection Hazards
Source: USEP A Cross-Connection Control Manual
Backflow Prevention
Backflow Prevention
Assemblies
SFPUC CROSS CONNECTION
CONTROL PROGRAM
• Established in 1984 by the Board of
Supervisors
• Ensure installation of appropriate backflow
prevention assemblies
• Ensure annual testing of >35,000 assemblies
• Respond to all 2+ alarm fires
• Respond to water quality complaints
NEW REGULATIONS
• Effective date July 1,
2024; replaced 1987
requirements
• SFPUC Manual required
by the Policy Handbook
• Describes SFPUC’s plan to
comply with the Policy
Handbook
• Provides guidance to City
staff and community
stakeholders
• Several new requirements
are challenging for utilities
to meet
Significant New Requirements
Hazard
Assessments
Improved
Protection on
Fire Services
Improved
Protection on
Temporary
Hydrant
Connections
Hazard Assessments Requirements
• Assess the hazard at every service
connection, including residential connections
• Provide a timeframe for completing the first
round of assessments and for subsequent
reassessments
➢ 6/30/49 or 25 years
• Some customers will need to install new or
upgraded backflow prevention assemblies on
standard services and test annually
Improved Protection on Fire Services
New regulations require backflow prevention
assemblies on dedicated fire services
Old Swing Check New Backflow Prevention
Assembly
Fire Services Needing New Devices*
Many have leaded weights
Well past useful service life
*Data from Customer Care & Billing database
Upgrading Protection on Fire Services
• Existing swing-check valves are SFPUC assets and will be removed at SFPUC expense
• Installation of backflow prevention assemblies is the customers’ responsibility and will be at their expense
➢ Estimated cost range $10,000 - $100,000 per assembly
➢ SFFD and SFDBI permits required
➢ Outreach program must be developed
• Swing-check removals should occur around the same day as assembly installation to minimize fire protection interruption • Proposed timeframe to complete is 6/30/44 or 20 years (10-year extension beyond regulatory deadline approved after draft plan) • Pilot program for first few years to develop better cost/resource estimates and full program
Upgrading Protection on Temporary
Hydrant Connections
Meter and Backflow Prevention Assembly
7/1/27 Deadline (3 years after regulatory effective date)
New Requirements Summary
• Assess all service connections for potential hazards and as needed, require customer installation of Backflow Protection Assemblies (BPAs)
➢Complete hazard assessments by 6/30/49 (25 years)
Hazard Assessments
• Improve protection for >4,200 existing dedicated fire services ➢Require customer installation of BPAs, and SFPUC removal of existing swing-check valves, by 6/30/44 (20 years)
Fire Services
• Improve protection on all temporary hydrant services
➢Deploy BPAs on all temporary hydrant connections by 7/1/27 Hydrant Connections
Resource Needs
Operating
• New Staffing
• SFPUC Bureau Support:
External Affairs,
Communications, CSB,
Finance…
• SF Fire Department and SF
Department of Building
Inspection
• Contractual and professional
services
• Hydrant assembly purchase
• Enforcement
Capital improvements
• Remove Swing-checks on
>4,200 fire services (SFPUC
cost)
• Install backflow prevention
assemblies (customer cost)
SFPUC will do a pilot (100 fire service upgrades and ~1,000 hazard assessments) over the next few years to get better cost and time estimates
PLAN AND PROGRAM MANUAL
SCHEDULE
• March to August 2025 - Draft Plan and Program
Manual Development
➢ Staff developed manual
➢ State Water Board District staff has approved the
schedule and high-level concepts
• September 9 – Commission approval of final
draft (allow GM to make minor edits based on
final State Water Board review)
• September 12 – Formally transmit to State
Water Board for input
Questions?
DEPARTMENT
Water Quality Division
AGENDA NO.
8 MEETING DATE
September 9, 2025
AGENDA ITEM
Public Utilities Commission
City and County of San Francisco
Calendar: Regular Calendar
Project Manager: Andrew DeGraca
Approve the Draft San Francisco Public Utilities Commission Cross-Connection Control Plan and Program Manual Required by the California State Water Resources Control Board
Summary of Proposed
Commission Action:
Approve the Draft San Francisco Public Utilities Commission Cross- Connection Control Plan and Program Manual , which documents SFPUC compliance with the California State Water Resources Control Board Cross-Connection Control Policy Handbook:
Standards and Principles for California’s Public Water Systems , and provides guidance regarding the requirements of the Cross - Connection Control Program; and authorize the General Manager to submit the Cross -Connection Control Plan and Program Manual to the State Water Resources Control Board and to make conforming revisions as needed.
Background: The San Francisco Public Utilities Commission (SFPUC) provides water service to the City and County of San Francisco (San Francisco) and certain retail and wholesale customers outside of San Francisco .
SFPUC procedures for establishing water connections and maintaining the safety of the water supply are set forth in its Rules and Regulations Governing Water Service to Customers, which the Commission first adopted on December 15, 1959, by Resolution No. 19-786.
The SFPUC is authorized to prevent cross-connections and backflow from contaminating the San Francisco drinking water system. A cross-connection is an actual or potential connection between the public water system and any source or distribution system containing liquid, gas, or other substances. SFPUC established its C ross- Connection Control P rogram to prevent cross connections with the drinking water system from causing backflow , or the undesired or unintended reversal of flow of water and/or other liquids, gases, or other substances, into the SFPUC drinking water system.
On June 17, 2016, by Ordinance No. 100-16, the San Francisco Board of Supervisors amended Article 12A of the San Francisco Health Code to establish updated cross-connection and backflow prevention requirements that would protect San Francisco’s public water system Agenda Title: Approve the San Francisco Public Utilities Commission Cross-Connection Control Plan and Program Manual Commission Meeting Date: September 9, 2025
and be consistent with current state and federal drinking water quality laws.
On September 13, 2016, by Resolution No. 16-0184, this Commission authorized the General Manager to add new Section G, entitled “Cross-Connection Control,” to the SFPUC’s existing Rules and Regulations Governing Water Service to Customers to implement the updated provisions of San Francisco Health Code Article 12A. On October 8, 2019, by Resolution No. 19- 0191, the Commission approved amendments to Section G that strengthened the SFPUC Cross-Connection Control Program.
On December 19, 2023, by Resolution No. 2023-0045, the California State Water Resources Control Board ( State Water Board ) adopted the Cross-Connection Control Policy Handbook: Standards and Principles for California’s Public Water Systems (Policy Handbook), in accordance with Assembly Bill 1671 and Assembly Bill 1180 authorizing the State Water Board to do so. The Policy Handbook, which became effective on July 1, 2024, and replaced the California regulations pertaining to cross -connection control in Title 17 of the California Code of Regulations, aims to protect public health through the establishment of standards intended to ensure that a public water distribution system will not be subject to the backflow of liquids, gases, or other substances. The Policy Handbook standards apply to all California public water systems, including San Francisco’s.
The Policy Handbook builds upon the state’s previous cross - connection control regulations with the addition of several significant new requirements .
For example, due to the new provisions of the
Policy Handbook, water utilities must (1) conduct hazard assessments of all service connections, (2) upgrade backflow protection on fire services, and (3) upgrade backflow protection on temporary connections to hydrants. On December 10, 2024, by Resolution No. 24-0252, this Commission approved amendments to Section G that were consistent with the Policy Handbook’s new standards and in alignment with current requirements in the San Francisco Plumbing Code and San Francisco’s
programs for municipally supplied
recycled water and alternative sources of water. The 2024 amendments also cl arified, reorganized, and expanded upon the Section G existing requirements to enhance the protection of the public water system from potential contaminants.
The Policy Handbook requires that water utilities, including the SFPUC, submit to the State Water Board by July 1, 2025, a Cross- Connection Control Plan that documents the utility’s compliance with the Policy Handbook requirements . SFPUC staff requested, and the State Water Board granted, an extension to submit its plan by October 1, 2025 . The Draft SFPUC Cross-Connection Control Plan and Agenda Title: Approve the San Francisco Public Utilities Commission Cross-Connection Control Plan and Program Manual Commission Meeting Date: September 9, 2025
Program Manual (Manual) attached to this agenda item and described further below will fulfill this requirement.
In addition to demonstrating SFPUC compliance with Policy Handbook requirements, the Manual will serve the secondary purpose of providing consolidated guidance to San Francisco staff and the public regarding the SFPUC Cross-Connection Control Program.
Compliance with the Policy Handbook will have costs , both for the SFPUC and for its customers. SFPUC costs are estimated to be $128 million in capital investments and $2 million per year for operation and maintenance. The SFPUC’s upcoming two-year budget requ est will include new capital and operating resources to begin to address the new requirements of the Policy Handbook. We estimate that customer costs for the installation of new Backflow Prevention Assemblies could fall between $50 million to $100 million.
Description of Draft
Manual:
The Manual describes how the SFPUC will comply with the requirements of the Policy Handbook. While the Manual primarily focuses on cross-connection control and backflow prevention within San Francisco, it addresses all seven community and two noncommunity water systems within the jurisdiction of the SFPUC.
SFPUC has prepared the Manual for informational purposes only, and it is solely intended to document the legal requirements regarding cross-connections to SFPUC drinking water systems, including those contained in Section G, Article 12A of the Health Code, and the Policy Handbook.
SFPUC staff have worked with State Water Board staff to develop the Manual. Upon this Commission ’s approval , SFPUC staff will formally submit the Manual to the State Water Board District Office, which forwards the Manual to the State Water Board for final review.
SFPUC staff anticipate there may be minor edits to the Manual as a result of State Water Board review. By this action, SFPUC staff requests that the Commission authorize the General Manager to revise the Manual to address any final comments or requ irements from the State Water Board review.
Following the State Water Board approval, t he Manual will be a living document requiring routine edits . For example, the General Manager may seek to revise the Manual to reflect SFPUC Cross- Connection Control Program staffing changes or updated administrative processes or forms. The General Manager may also need to update the Manual as necessary to ensure it accurately reflects the requirements of Section G and other relevant provisions of state and local laws and regulations, which may be amended from time to time. As the Manual, itself, is purely
explanatory and has no
regulatory effect, through this action, the Commission may authorize the General Manager to make revisions as needed to ensure the Agenda Title: Approve the San Francisco Public Utilities Commission Cross-Connection Control Plan and Program Manual Commission Meeting Date: September 9, 2025
information in the Manual continues to accurately reflect applicable legal and regulatory provisions, including any relevant substantive changes to Section G, Article 12A of the Health Code, and the Policy Handbook.
Attachment 1 to this agenda item provides the full text of the Manual.
As noted in the Background section, above, many of the requirements in the Policy Handbook are similar to those in the now-repealed Title 17, but some new requirements may cause the SFPUC and its customers to incur significant new compliance costs. These new requirements include: (1) hazard assessments of all service connections, (2) upgrading backflow protection on fire service connections, and (3) u pgrading backflow protection on temporary connections to hydrants . Each of these requirements is discussed below.
Hazard Assessments:
The Policy Handbook requires that water suppliers conduct initial and periodic hazard assessments of every service
connection in their
systems. The San Francisco Water System , alone (one of the seven community and two noncommunity water systems within the jurisdiction of the SFPUC), has roughly 182,000 service connections.
In the Manual, SFPUC must commit to a timeframe for completing the initial assessments as well as provide a frequency for reassessments. The SFPUC has proposed a 25- year deadline for completing initial hazard assessments followed by reassessments every 20 years.
The SFPUC will prioritize hazard assessments as follows: (1) SFPUC properties and facilities ; (2) other San Francisco -owned properties and facilities ; (3) commercial, industrial, and large multi- family residential customers ( five or more units ); (3) small multi- family residential customers (up to four units) ; and (4) single-family residential customers . If the SFPUC identifies cross -connection hazards on customer premises, the SFPUC may require customers to install appropriate backflow protection at the cus tomer’s expense. It is unknown how many customers will have to install backflow protection. Customers with backflow prevention assemblies must annually inspect and test them and inspect air gap separations.
Hazard assessments will involve customer outreach, review of existing records (e.g., satellite/street pictures, building permits, water use), customer surveys, and on-site inspections. In 2026, the SFPUC will conduct a pilot program to gauge the effort needed to complete these assessments.
Upgrading Backflow Protection on Fire Services:
The Policy Handbook requires that, by July 1, 2034, all dedicated fire services be protected by double-check detector assemblies (DCDAs) Agenda Title: Approve the San Francisco Public Utilities Commission Cross-Connection Control Plan and Program Manual Commission Meeting Date: September 9, 2025
or reduced pressure principle assemblies (RPDAs) . The SFPUC Water Quality Division requested, and the State Water Board granted, a five-year extension of this deadline, to July 1, 2039.
An estimated 4,240 dedicated fire services in San Francisco do not have the required backflow protection and are only protected by swing-check valves. Many of the swing- check valves in San Francisco are older, with some dating back to the early 1900s. The fire services that require upgrades are spread out over the City but are more concentrated in the northeast and other financial and commercial areas.
Upgrading dedicated fire services involves (1) the SFPUC removing existing swing- check valves , which are SFPUC assets, and (2) customers installing DCDAs or RPDAs , which will be customer assets, at the customer’s expense. Customers must have their plans to upgrade their dedicated fire services approved by the San Francisco Fire Department, and they must obtain permits for the installation of DCDAs and RPDAs from the Department of Building Inspection, Plumbing Insp
ection Division. After installation, customers must
ensure that their DCDAs and RPDAs are tested annually.
The SFPUC will prioritize upgrades to backflow prevention on f ire services based on the risk to the public water system . For example, the SFPUC will consider the date of service installation (older swing- checks may be in greater need of prompt replacement) and the size of the service line (larger service lines are associated with more extensive sprinkler systems, which have larger volumes and higher pressures of water that could backflow into the public water system).
Upgrading fire services will involve customer outreach, coordinating swing-check removal with customers’
installation of upgraded
protection, and site inspections.
Upgrading Backflow Protection on Temporary Connections to Hydrants:
The Policy Handbook requires backflow prevention assemblies on hydrants accessed for temporary water supply
uses, such as
construction, special events like music festivals, and commercial vehicles like street sweepers and water trucks . The SFPUC permits and regulates temporary connections to hydrants for
certain water
uses in San Francisco , and it issues hydrant meter equipment to permittees that they must use to access temporary water supply from hydrants. Currently, the SFPUC-issued equipment includes a water meter and swing-check valve for backflow protection. The SFPUC will procure about 300 new backflow prevention assemblies, totaling approximately $1 million, and issue them as part of the hydrant meter equipment. The SFPUC will also inspect, test, and maintain the assemblies.
Agenda Title: Approve the San Francisco Public Utilities Commission Cross-Connection Control Plan and Program Manual Commission Meeting Date: September 9, 2025
Public Outreach Activities:
The Policy Handbook also requires an ongoing public outreach and education program that includes educating staff, customers, and the community about backflow protection and cross -connection control.
Water Quality Division staff are working with SFPUC
Communications staff
to develop communications and outreach
materials (bill inserts, social media posts, promotional materials, etc.) for customers and appointed and elected officials.
Funding and Costs: No cost is associated with the approval of this Manual. Policy Handbook compliance will have costs, both for the SFPUC and for its customers. SFPUC costs are estimated to be $128 million ( capital) and $2 million per year (operations) . Customers ’ costs may be between $50 million and $100 million.
Schedule: If approved by this Commission, on or before October 1, 2025, SFPUC staff will submit the Manual to the State Water Board for final review and approval. SFPUC expects final approval by the end of the year.
Environmental
Review:
On December 19, 2023, by Resolution No. 2023 -0045, the State Water Resources Control Board, acting as the California Environmental Quality Act (CEQA) Lead Agency , determined the Policy Handbook to be categorically exempt from environmental review under the California Environmental Quality Act ( CEQA) Guidelines section 15301, Class 1 ( Existing Facilities ) and section 15302, Class 2 (Replacement or Reconstruction).
The SFPUC is a Responsible Agency under the CEQA Guidelines sections 15096 and 15381, acting within its discretionary approval power to approve the draft Cross -Connection Control Plan and Program Manual, in compliance the Policy Handbook. The SFPUC has reviewed the Lead Agency’s exemption determin ation and has determined that the a pproval of the draft Cross -Connection Control Plan and Program Manual is within the scope of the exemption, which is adequate for SFPUC’s proposed action.
The State Water Resources Control Board Resolution No. 2023-0045 and Notice of Exemption can be found here:
https://sfpuc.sharefile.com/public/share/web-
s2def1d5934da45df8a28c01e757bfa6d
Attachment(s): 1. Draft SFPUC Cross-Connection Control Plan and Program Manual
PUBLIC UTILITIES COMMISSION
City and County of San Francisco
RESOLUTION NO.
WHEREAS, The San Francisco Public Utilities Commission (SFPUC) provides water service to the City and County of San Francisco and maintains procedure s for establishing water connections and protecting the safety of the water supply as set forth in its Rules and Regulations Governing Water Service to Customers, first adopted by this Commission on December 15, 1959, by Resolution No. 19.786; and
WHEREAS, Cross-connections are actual or potential connections between the public drinking water system and any source or distribution system containing liquid, gas, or other substances not from an approved water supply; and
WHEREAS, The purpose of the SFPUC Cross-Connection Control Program is to protect customers from serious health risks by preventing backflow from cross-connections and thereby prevent contaminants from entering the public water system’s distribution system; and
WHEREAS, On June 17, 2016, by Ordinance No. 100- 16, the San Francisco Board of Supervisors amended Article 12A of the San Francisco Health Code to establish updated cross - connection and backflow prevention requirements that would protect the City and Count y of San Francisco public water system and be consistent with current state and federal drinking water quality laws; and
WHEREAS, On September 13, 2016, by Resolution No. 16- 0184, this Commission authorized the General Manager to add a new Section G, entitled “Cross-Connection Control,” to the SFPUC Rules and Regulations Governing Water Service to Customers to implement the updated provisions of San Francisco Health Code Article 12A; and
WHEREAS, On October 8, 2019, by Resolution No. 19-0191, this Commission approved amendments to Section G that provided clearer requirements for cross -connection control based on public feedback and incorporated additional requirements to strengthen the SFPUC Cross - Connection Control Program; and
WHEREAS, On December 19, 2023, the California State Water Resources Control Board (State Water Board) adopted new cross-connection control standards through its Cross-Connection Control Policy Handbook (Policy Handbook), which became effective July 1, 2024, and requires that water utilities, including the SFPUC, prepare and submit to the State Water Board for approval a Cross-Connection Control Plan documenting the utility’s compliance with the Policy Handbook standards; and
WHEREAS, On December 10, 2024, by Resolution No. 24- 0252, this Commission approved amendments to Section G that were consistent with the Policy Handbook’s new standards and in alignment with current requirements in the San Francisco Plumbing Code and San Francisco’s programs for municipally supplied recycled water and alternative sources of
water; the 2024 amendments also clarified, reorganized, and expanded upon the Section G requirements to enhance the protection of the public water system from potential contaminants; and
WHEREAS, SFPUC staff have prepared the Draft Cross-Connection Control Plan and Program Manual attached hereto and on file with the Director of Commission Affairs to document SFPUC compliance with the Policy Handbook standards and serve the secondary purpose of providing guidance to City and County of San Francisco staff and the public about the requirements of the SFPUC Cross-Connection Control Program; and
WHEREAS, With Commission approval and authorization, the General Manager will submit the SFPUC Cross-Connection Control Plan and Program Manual to the State Water Board for final review and approval by October 1, 2025, and the State Water Board may require further minor edits based on its review; and
WHEREAS, Following State Water Board approval, the Cross -Connection Control Plan and Program Manual will be a living document requiring routine edits, such as revisions to reflect SFPUC Cross-Connection Control Program staffing changes; amendments to Section G and other relevant provisions of state and local laws and regulations; new alternative compliance options consistent with state and local laws and regulations; and revisions of administrative processes or forms; and
WHEREAS, On December 19, 2023, by Resolution No. 2023-0045, the State Water Resources Control Board, acting as the California Environmental Quality Act (CEQA) Lead Agency, determined the Policy Handbook to be categorically exempt from environmental review under the California Environmental Quality Act ( CEQA) Guidelines section 15301, Class 1 (Existing Facilities) and section 15302, Class 2 (Replacement or Reconstruction); and
WHEREAS, The SFPUC is a Responsible Agency under the CEQA Guidelines sections 15096 and 15381, acting within its discretionary approval power to approve the draft Cross - Connection Control Plan and Program Manual, in compliance the Policy Handbook, and t he SFPUC has reviewed the Lead Agency’s exemption determination and has determined that the approval of the draft Cross -Connection Control Plan and Program Manual is within the scope of the exemption, which is adequate for SFPUC’s proposed action; and
WHEREAS, The Lead Agency’s Resolution No. 2023-0045 and Notice of Exemption are part of the record of this approval and are available for public review at the SFPUC offices, Environmental Management, 525 Golden Gate Avenue, 11th floor, San Francisco, California; and
WHEREAS, Since the Lead Agency made the exemption determination, there have been no substantial changes in the Project, changes in Project circumstances or new information that would change the conclusions set forth in the exemption determination; now, therefore, be it
RESOLVED, That this Commission hereby approves the SFPUC Cross-Connection Control Plan and Program Manual in the form attached hereto and on file with the Director of Commission Affairs , effective as of the date of this Resolution, and this Commission hereby
authorizes the General Manager to submit the SFPUC Cross-Connection Control Plan and Program Manual to the State Water Board for final review and approval; and be it
FURTHER RESOLVED, That this Commission hereby authorizes the General Manager, or the General Manager designee, to revise the SFPUC Cross-Connection Control Plan and Program Manual to address any further comments or requirements from the State Water Board; and be it
FURTHER RESOLVED, That this Commission hereby authorizes the General Manager, or the General Manager designee, following State Water Board review and approval, to revise the Manual to make non-substantive amendments, minor corrections, or administrative updates, and to ensure the Manual continues to accurately reflect the requirements of Section G of the SFPUC Rules and Regulations Governing Water Service to Customers and other relevant provisions of state and local laws and regulations, as they may be amended from time to time.
I hereby certify that the foregoing resolution was adopted by the San Francisco Public Utilities Commission on September 9, 2025.
Director of Commission Affairs
San Francisco Public Utilities Commission