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San Francisco Public Utilities Commission
Correspondence Log
October 26, 2025 through October 29, 2025
Date Received From Subject
October 26, 2025 Kristen Mercer URGENT Demand to Halt Oct 28 CalFire Burn SFPUC Land
October 27, 2025 Dave Warner Another View on Water Supply Planning (attachment) October 27, 2025 Peter Drekmeier TRT Comments re: Item 5a - SF Water Supply Planning (email + 2 attachments)
October 29, 2025 Karen Frye Potable Emergency Firefighting Water System Project CEQA Preliminary Mitigated Negative Declaration (email
+ attachment)
1 From: [email protected]
Sent: Sunday, October 26, 2025 9:57 PM
To: Commission; Arce, Julio C; Leveroni, Stephen; Jamdar, Avni; Stacy, Kate H; Thurlow, Meghan E Cc: Rando, Casey; Ramirez, Tim
Subject: URGENT Demand to Halt Oct 28 CalFire Burn of SFPUC Land Follow Up Flag: Follow up
Flag Status: Completed
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Dear SFPUC Commissioners,
I urge you to HALT the planned October 28th CalFire prescribed burn of Unit 4 of Crystal Springs watershed.
Sunday CalFire announced an October 28th prescribed burn of SFPUC shrubland (below).
This burn ignores a recent court ruling AGAINST the California Board of Forestry’s (Cal Fire’s boss) programmaƟc EIR with regards to burning shrub habit.
On Ma
y 30, 2025, the California Appellate Court ruled against the Board and their prescribed burn programmaƟc EIR plan with respect to burns of shrub habitat. The court found in favor of the plainƟffs, California Chaparral InsƟtute, on every point:
the Board of Forestry’s findings are not supported by substanƟal evidence, The Board was required under CEQA, and failed to consider the adverse environmental effects of type conversion of chaparral and sage scrub to non‐naƟve, weedy landscapes, most specifically, the increased wildfire danger ,
By cerƟfying the report, the Board prejudicially abused its discreƟon, Cal Fire's habitat clearance projects will cause type conversion, with the potenƟal to increase the flammability of the landscape.
The ruling concluded:
“We end by noƟng the irony of the Board’s argument that type conversion, which results in a more flammable landscape, is not a significant impact of prescribed burns when th e express goals of the Program are to (1) “treat vegetaƟon that could become fire fuel,” (2) “reduc[e] the likelihood of a ground fire increasing in intensity and helping suppression forces more easily 30 contain a fire,”13 and (3) “reduce risks to life, property, and natural resources by ma naging the amount and conƟnuity of hazardous vegetaƟve fuels that promote wildland fire.” (p.29)
Further, on June 30th 2025, the California Appellate Court rejected a request from the Board of Forestry for a rehearing, amending its decision to further affirm the fact that the EIR failed to address serious environmental impacts.
The court affirmed what Belmont residents argued against your adopƟon of the 2021 CalFire Plan: bu rning chaparral and California coastal sage scrub does not decrease fire risk. To the contrary, the risk of fire increases due to invasive flammable grasses. California's chaparral biome is the state's most characterisƟc, yet most imperiled, naƟve shrubland ecosystem. Unit 4, the SFPUC area slated for burning on Tu esday, is a knoll of mixed chaparral habitat with a few oaks, and one of the few remaining in its natural condiƟon with few nonnaƟve, invasive plants. This unit is thus a perfect 2 example of the natural sustainability of this complete ecosystem absent human interference. It does not need human “management” .
I witnessed and documented CalFire’s September 28, 2023 burn of nearby Unit 5. Countless gallons of propellant were broad sprayed before the shrubs would ignite, much less sustain fire. It was NOT naturally flammable. In fact, the wildfire risk – the propensity to ignite ‐ of the unit was never established by CalFire in their assessment. The majority of hillsides flanking the reservoir feature similar green vegetaƟon, and CalFire cannot site any history of wildfires in the surrounding watershed basin.
SFPUC needs to demand a redo of the CalFire “Prescribed Burn Project” relaƟng to chaparral and sage scrub, to address the risk of habitat type conversion and the increased flammability it will cause. I urge you to direct staff to HALT the CalFire burn of Unit 4 to
comply with CEQA standards, to prevent increased wildfire risk to adjacent neighborhoods, and to avoid inflicƟng irreparable damage to our public lands.
Respecƞully,
KrisƟn Mercer
2535 Somerset Drive, Belmont 94002
Links to court records:
05/30/2025 hƩps://www4.courts.ca.gov/opinions/nonpub/D083484.PDF 06/30/2025 file:///C:/Users/DELL/Downloads/6‐30‐2025‐D083484‐CerƟf‐ModOpinion‐1.pdf
3 4
October 27, 2025
Re: The SFPUC’s Water Supply Planning Methodology is Out of Date Dear Commissioners,
Disclaimer: Mr. Ritchie is a valuable leader with a wealth of institutional knowledge. However, this letter is critical of his long-held water supply planning views, which I believe he holds out of respect for Anson Moran, who was also a valuable leader.
For the most part, The SFPUC’s water supply planning methodology to be presented on Tuesday dates back more than 30 years, while our knowledge has advanced in important ways, and the metropolis we support has changed. The methodology should be updated.
1 Things to note regarding Mr. Ritchie’s presentation:
1) Terrific water rights: The SFPUC, while having junior water rights to the Irrigation Districts, has robust water entitlements. During the 1987-92 drought, the SFPUC still received an average of 110 mgd from the Tuolumne.
2) Stunning amounts in storage: Since changing to a “Water First” policy, the SFPUC has not seen storage levels drop below 3½ years of supply (water “in the bank”) in any drought.
3) Note that the drought planning scenario is for 265 mgd: Demand has not exceeded 200 mgd in the last 11 years. Even with aggressive growth, demand is not projected to exceed 244 mgd and the SFPUC’s own finance department projects 2045 demand to be 207 mgd.
4) The premise that there will be a worse drought [than 1987-92] in the future doesn’t justify an excessive drought model: The drought planning
1 To the SFPUC’s credit, the Long Term Vulnerability Assessment (LTVA) was commissioned in the last 10 years which, among other things, did not find a significant change in the amount of precipitation through the year 2070. But even those climate change findings are becoming out of date as the associated climate change workshop was now six years ago (2019) while climate science continues to advance. I hope staIgW“8 will do an update.
scenario assumes a drought 72% worse than the worst drought on record (including 1,100 years of tree ring data). 72% is a big jump from the 1987-92 drought—shouldn’t the risk of such a drought be understood?
5) Risk management becomes an incendiary term: Despite numerous requests and available data, the SFPUC has refused to conduct a risk analysis on its drought planning scenario. An essential best practice is to understand risk. 2
6) Anson Moran’s 1994 quote might have been an appropriate statement for the 1990s, but not today : Much has changed since then. Our population has swelled while demand has plummeted. Tree ring data now lets us look back 1,100 years on Tuolumne watershed precipitation, providing a better sense of drought risk. Climate science has vastly improved and continues to do so.
7) Population growth uncertain: While Plan Bay Area projects substantial population growth for the region, the California Department of Finance projections do not. In either event, per capita demand has been on a remarkable long term decline, which will likely continue. 8) Long-term demand projections have *Always* exceeded realized demand: Like most California water agencies, the SFPUC consistently overestimates long-term demand, which has caused the SFPUC to underestimate cost increases.
The implications are significant. Storing unneeded water and overestimating demand lead to a variety of problems, including high water rates, over-reliance on debt, environmental problems and ultimately financial health problems, as the San Diego County Water Authority (SDCWA) is experiencing. As I’ve written before, The SDCWA is the first, or among the first California water agencies, to now forecast declining demand in hopes of righting their financial ship.
2 A personal emotional statement: How can the SFPUC even mention risk management when it refuses to do basic risk analysis?
I’m a believer in having a safety margin. But having multiple safety margins built in, such as overestimated demand and an excessive drought model at the expense of high rates and financial risk, doesn’t make sense.
Let’s address excessive planning margins, incorporate statistical risk data and update the LTVA to bring our water supply planning methodology to current state of the art.
Kind regards,
Dave Warner
cc: Dennis Herrera, SFPUC General Manager
Steven Ritchie, SFPUC Assistant General Ma nager, Water Enterprise Nancy Hom, SFPUC Chief Financial Officer
Laura Busch, SFPUC Deputy Chief Financial Officer
Erin Corvinova, SFPUC Financial Planning D irector
SFPUC Citizens’ Advisory Committee
Tom Smegal, BAWSCA CEO
1 From: Peter Drekmeier <[email protected]>
Sent: Monday, October 27, 2025 12:48 PM
To: Commission
Subject: TRT Comments re: Item 5a - SF Water Supply Planning Attachments: TRT Letter to SFPUC re- Water Supply Planning.pdf; 20250415 _UAC_Letter_to_SFPUC_-_Greer_Stone.pdf
Dear President Arce and Commissioners: Something really weird is going on at the SFPUC. The presentation for Item 5a on tomorrow’s agenda — San Francisco’s Water Supply Planning — is exactly the same as the staff presentation given on January ZjQcmQRYFpfptBannerStart
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Dear President Arce and Commissioners:
Something really weird is going on at the SFPUC. The presentation for Item 5a on tomorrow’s agenda — San Francisco’s Water Supply Planning — is exactly the same as the staff presentation given on January 28, 2025 (also Item 5a on that agenda).
I’m atta
ching TRT’s comments on the January 28 presentation. Not one of the issues we raised has been addressed, nor one question answered. Shouldn’t a response to our letter be the focus of tomorrow’s meeting? At tomorrow’s meeting, please ask staff the following questions:
1) Why does the SFPUC plan for a drou ght that is so much more severe than what other water agencies use for planning? If the SFPUC were to plan for a drought similar to those used by Valley Water and EBMUD, how would it affect perceived potential water shortages.
2) How would using the SFPUC’s Finance Bureau sales projections, in place of Water Ent erprise demand projections, impact future perceived water needs? How would the resulting reduction in the potential need to invest in alternative water supplies affect rates?
3) What is staff’s estimated range for the return period (likelihood of occurrence) of the Design Drought? 4) How migh t earlier runoff due to climate change impact the SFPUC’s water entitlements? Please have them respond to TRT’s analysis (we found that the SFPUC would pick up enough water over the course of the Design Drought to last more than a year at current demand).
Also, please direct staff to re spond to the information request (attached) submitted by the City of Palo Alto earlier this year.
Thank you for your attention.
‐Peter
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BOARD MEMBERS
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Marty McDonnell
Homero Mejia
John Nimmons
Iris Stewart-Frey
Bart Westcott
Brad Wurtz
January 27, 2025
President Kate Stacy and Commissioners
San Francisco Public Utilities Commission
Via email: [email protected]
Re: Item 5a: San Francisco Water Supply Planning.
Dear President Stacy and Commissioners:
Palo Alto recently spent half a million dollars to produce a One Water Plan. The Plan was premised on the following statement:
“Based upon the City’s forecasted water demand presented in the City’s 2020 UWMP and projections of water supply availability provided by SFPUC at the time, the City anticipates the need to implement water use reductions of approximately 50 percent from pre-drought usage levels in dry years post Bay-Delta Plan implementation.”
The 50% rationing figure espoused by the SFPUC is based on the manufactured Design Drought, which might occur once in 8,000 years. Furthermore, it’s based on unrealistic demand projections, acknowledged in the SFPUC’s own document – “Water Enterprise and Finance Bureau Water Demand Projections” (July 5, 2022) – as “an outside bound.”
The SFPUC’s unreasonable drought planning scenario is already leading wholesale customers to invest in costly and unwise planning. Palo Alto’s One Water Plan will likely just sit on a shelf. Making matters worse, the SFPUC’s Alternative Water Supply (AWS) Plan suggests the possible need to develop 92 to 122 mgd of AWS at a cost of $17 to $25 billion – an imprudent investment that would lead to a financial fiasco of epic proportion.
The Design Drought is clearly beyond conservative, yet despite seven conclusive deep-dive SFPUC workshops between 2020 and 2022, the Commission declined to even discuss the prudence of the Design Drought. This was an extreme disservice to ratepayers, wholesale customers and the Bay-Delta ecosystem.
Please schedule a workshop ASAP to focus on the practicality of the Design Drought before more money is squandered on unnecessary studies or the development of unneeded infrastructure.
Following are a few comments on tomorrow’s staff presentation.
2 Slide 3 – Wise Water Use and Regular Planning
SFPUC Statement: “San Francisco currently averages 41 gallons of residential per capita use, and Wholesale Customers average 55.1 gpcd (a 52% decrease since 1975-78 in residential per capita use).”
TRT Response: In 1979, a water demand study by Brown & Caldwell projected demand would reach 425 mgd by 2030. Last year, the SFPUC delivered only 184 mgd to the Bay Area. SFPUC demand projections have always been highly inflated. In response to inflated historic demand projections, the SFPUC invested in a massive amount of reservoir storage (enough to last six years). The SFPUC is well positioned for the Bay Delta Plan, which would have a much smaller impact on water supply than over-projected water demand. According to the SFPUC’s Long- Term Vulnerability Assessment (LTVA), the impact of the Bay Delta Plan on supply would be the equivalent of a 15% increase in demand.
SFPUC Statement: “Urban Water Management Planning: Every 5 years, all water agencies need to demonstrate that they have enough supply to accommodate anticipated growth over the ensuing 25 years.”
TRT Response: For the 2020 UWMP, the SFPUC attempted to use contractual obligations (265 mgd) to represent current demand (198 mgd). TRT uncovered this deception, and the SFPUC was forced to use actual demand projections. This simple, honest correction reduced the perceived potential rationing in Year 3 of a drought by 27%.
UWMPs require water providers to assess whether they could meet projected future demand under a repeat of their worst “Five-Consecutive-Year Drought.” TRT has demonstrated that the SFPUC could manage its worst Six-Consecutive-Year Drought (1987-92) with the Bay Delta Plan in place without requiring any rationing. Rationing would extend the SFPUC’s water supply to last more than seven years, and a modest investment in AWS would ensure an even longer drought could be managed.
TRT and our allies invested a lot of time reviewing the 2020 UWMP and identifying flaws. We advocated for a workshop prior to the UWMP being finalized, but SFPUC staff stalled. The workshop did finally occur on July 16, 2021 – 16 days after the UWMP was submitted. Let’s not allow this to happen again.
Slide 4 – Smart Operations and Water Supply
SFPUC Statement: “Our management decisions and planning are guided by “Water First”, Experience, and Risk Management.”
TRT Response: The SFPUC’s Water First policy has been extremely successful. According to the following information (presented by SFPUC staff on July 12, 2021), precipitation in 2020/21 was
3 almost identical to 1976/77. Yet on June 10, 2021, the SFPUC had 917 thousand acre feet (TAF) of water in storage compared to 563 TAF on the same date in 1977. The 354 TAF difference is enough water to last one-and-a-half years. Despite big improvements in water management, the SFPUC has never adjusted its thinking.
SFPUC Statement: “Risk Management: How bad can conditions get, knowing that we cannot operate to zero storage at any point?”
TRT Response: While planning for a worse drought is prudent, there are reasonable limits. The SFPUC’s de facto policy of “reliability at all cost” is driving the agency toward insolvency. In November 2021, when the SFPUC declared a “Water Shortage Emergency,” there was enough water in storage to last 4.5 years. Storage never dropped below four years-worth, yet the SFPUC imposed a drought surcharge on San Francisco customers. The SFPUC then irrationally assumed the surcharge would extend into FY 2023/24, but when it didn’t, the SFPUC faced a $20 million deficit.
The SFPUC’s paranoia over running out of water has led to a practice of “hoard and spill.” Whenever the reservoirs aren’t all topped off, the SFPUC only releases minimum baseflows, creating terrible conditions for fish. You’ll see from the graph below that the pattern repeats every time there’s a dry year sequence. For example, between 2012 and 2016 (five years) unimpaired flow in the lower Tuolumne average just 12%. Then in 2017, all the water that was conserved during the drought (and much more) had to be spilled, leading to 79% of unimpaired flow. This is no way to manage an ecosystem.
4 Slide 8 – Consequences of Being Wrong
SFPUC Statement: Quote by Anson Moran (January 1994): “When considering all the factors associated with the City’s entitlements to water, its physical system and the dire consequences of just being wrong in the forecasting of the length of drought that may hit the City, I cannot agree with any comment that the City’s operation rule is overly conservative.”
TRT Response: This quote is from 30 years ago and shows that even then the Design Drought was criticized for being overly conservative. Much has changed since the Design Drought was conceived, including the following:
• Water demand heading into the six-year drought of record (1987-92) was at a peak of 293 mgd. Demand has been under 200 mgd for the past ten years. • The Water First policy was implemented.
• Cherry Lake (273 TAF of storage – ¾ the capacity of Hetch Hetchy) was drained for maintenance in 1989, adding to the challenge of the six-year drought. • The SFPUC’s Long-Term Vulnerability Assessment (LTVA – climate change study) was completed in 2021, finding “no clear direction of change in mean annual precipitation over the planning horizon.”
Despite all these major changes, the SFPUC has refused to even consider possible amendments to the Design Drought.
5 Slide 9 – Challenges Ahead
SFPUC Statement: “Population will continue to grow (e.g. State Housing General Plan Elements).”
TRT Response: According to the SFPUC’s 2020 UWMP, between 2005 and 2020 the population of San Francisco grew from 781,806 to 899,732. That amounted to 15% growth over a 15-year period, or 1% per year. The 2020 UWMP projected San Francisco’s population would grow by 25% over the next 15 years, reaching 1,251,214 by 2035. That’s a substantially higher growth rate of 1.67% per year. This obviously is not happening. The 2020 UWMP forecasted San Francisco’s population would grow by 39% over 25 years, but the California Department of Finance forecasted growth of only 10% – a huge difference, and worthy of analysis.
SFPUC Statement: “Climate Change: Studies indicate shifts to more precipitation as rain than snow and more extreme events.”
TRT Response: The LTVA projects a three-week shift in runoff by 2070. TRT modeled what would happen if the Design Drought occurred and runoff came three weeks earlier. We found that the SFPUC would pick up more than a years-worth of water over the course of the Design Drought (at the expense of the Irrigation Districts). This is because a fair amount of runoff would shift from a two-month period in the spring when the Districts are entitled to the first 4,000 cfs of runoff to earlier in the year when they are only entitled to the first 2,400 cfs. SFPUC staff have refused to respond to our analysis.
Slide 10 – Alternative Water Supply Plan for the Regional Water System
SFPUC Statement: “[The AWS Plan] is a living planning document that gives decision-makers information regarding potential future water supply issues and potential actions to augment the Regional Water System supplies to retain our current, appropriate risk management approach.”
TRT Response: The AWS Plan is a political document aimed at supporting the SFPUC’s false narrative that the Bay Delta Plan would lead to either extreme rationing or the need to invest heavily in expensive AWS. The Plan only provides an extreme worst-case scenario, depriving the Commission and others of all the facts needed to make wise decisions. The AWS Plan does not include a cost/benefit analysis, leading wholesale customers like Palo Alto to make expensive and unnecessary investments.
The Plan only includes figures SFPUC staff have acknowledged to be an “outside envelope”.
SFPUC demand projections have been inflated by an average of 22% over the past 25 years, yet the AWS Plan does not include a range in potential future demand (sensitivity analysis). Using SFPUC Finance Bureau sales projections rather than Water Enterprise demand projections would knock 37 mgd off of perceived need. According to the SFPUC’s “Water Enterprise and
6 Finance Bureau Water Demand Projections,” “the [Water Enterprise] projections [used in the UWMP] represent an outside bound of whatever demand will occur in the next 25 years…For budgeting and rate setting we use [Finance Bureau] demand projections that are as close to actual as we can make them.”
Removing one year from the Design Drought (it would still be the most conservative plan in the state) would knock another 25 mgd off the perceived need for AWS.
Conclusion
Please direct staff to respond to the issues raised in this letter, and to schedule a workshop to address these issues. Your ratepayers and wholesale customers will be pleased.
Thank you for considering this request.
Sincerely,
Peter Drekmeier
Policy Director
[email protected]
Cc: BAWSCA Board of Directors
Palo Alto Utilities Advisory Commission
SFPUC Citizens’ Advisory Committee
1 From: Frye, Karen
Sent: Wednesday, October 29, 2025 4:14 PM
To: Commission
Cc: Young, Hannah M; Andresen, Josh S; Zhu, Ada L
Subject: Potable Emergency Firefighting Water System Project CEQA Preliminary Mitigated Negative Declaration
Attachments: Memo to Comm Secretary - PEFWS PMND.pdf
Follow Up Flag: Follow up
Flag Status: Completed
Please see aƩached for transmiƩal to the Commissioners and City AƩorney Sheryl Bregman. Thank you! Karen E. Frye, AICP
San Francisco Public UƟliƟes Commission | Manager, Environmental Management 525 Golden Gate Ave, 11th Fl. | San Francisco, CA 94102 | Office: (415) 554‐1652 | Cell: (415) 694‐1227 Delivering excellence in the environmental review and permitting process through teamwork, knowledge, integrity, and respect
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.
MEMORANDUM
DATE: October 29, 2025
TO: Tiffany Lennear, Director of Commission Affairs
FROM: Karen Frye, AICP, Manager, Environmental Management
SUBJECT: Transmittal of the CEQA Preliminary Mitigated Negative Declaration (PMND) for the SFPUC Westside Potable
Emergency Firefighting Water System Project
The San Francisco Planning Department has published the Preliminary Mitigated Negative Declaration (PMND) for the SFPUC Westside Potable Emergency Firefighting Water System Project. The public comment review period ends on November 28, 2025. Please transmit the document link to the Commissioners and City Attorney Sheryl Bregman.
https://sfpuc.sharefile.com/public/share/web-
s08fe0e78c7c344648594640d4c97f7e2
The document is also available on the Planning Department’s website here.
cc: Hannah Young, Senior Environmental Project Manager, SFPUC Ada Zhu, Project Manager, SFPUC
Josh Andresen, Senior Project Manager, SFPUC