CleanPowerSF Sfpuc Commission
April 28, 2026

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San Francisco Public Utilities Commission
Correspondence Log
April 7, 2026 through April 19, 2026

Date
Received
From Subject

April 7, 2026 Mark Shahinian Sierra Club Comment on UWMP Draft – for inclusion in April 14 meeting agenda
packet (email + attachment)
April 7, 2026 Shannon McEntee Fwd: Emailing the SFPUC (email + attachments)
April 9, 2026 Chinese Chamber of
Commerce
Opposition Letter to SFPUC Regarding
Recent Rate Hike Proposal (email +
attachment)
April 11, 2026 Anna Chan Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation
April 11, 2026 Tony R. Figueroa Opposition to Artificial Turf for Crocker Amazon Ball Field Re
April 12, 2026 Michael Rich Stop the plastic pollution
April 12, 2026 Mary Butterwick Comments on the Draft 2025 Urban Water Management Plan (email +
attachment)
April 13, 2026 Peter Drekmeier YRA Letter to SFPUC re: Earlier Runoff April 13, 2026 Marvin C Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation
April 14, 2026 SPUR Events Join Mayor Lurie and SPUR: Good Government Awards – May 13
April 14, 2026 Gregory Stevens Faith Sides with Crocker Amazon Park residents
April 14, 2026 Barbara Bagot-López Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation--and to
the illegal "gift"
April 15, 2026 Francisco Da Costa This video was recorded before we met SF Inspector General.

April 15, 2026 Francisco Da Costa Here is the SFPUC meeting - post today - that took place April 4, 2026.

April 15, 2026 Stephen Cosbey Opposition to Artificial Turf for Crocker Amazon Ball Field and Proposed
Renovation
April 15, 2026 Beth Rubenstein Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation
April 15, 2026 Judith Kirk Please...

April 15, 2026 Jesus Estrada, Jr. Senator Durazo Invites You — Medi-Cal Supporter Activation Call Tomorrow
(Thurs, April 16 | 1:30 PM)
April 15, 2026 Valerie Howard Re: Crocker Amazon Baseball Diamond Project
April 16, 2026 Catherine Dodd Crocker Amazon renovation, artificial turf and tree removal (email + attachment)
April 16, 2026 Barklee Sanders Public Comment — Draft 2025 UWMP — Request to Revise Design Drought Basis
Before Adoption
April 16, 2026 Barklee Sanders Request to Revise Design Drought Basis Before Adoption (email + attachment)
April 18, 2026 Denise Louie UWMP and the Bay Delta
April 19, 2026 Francisco Da Costa We believe in fair play and justice - not so the SFPUC - the time has come to
bring them to book.

1 From: Mark Shahinian <[email protected]>
Sent: Tuesday, April 7, 2026 6:49 PM
To: Commission
Cc: Ritchie, Steve; Lee, Jennifer; Kothari, Manisha; Heinrich Albert Subject: Sierra Club Comment on UWMP Draft – for inclusion in April 14 meeting agenda packet Attachments: Sierra Club Comment on SFPUC Draft Urban Water Management Plan.pdf This Message Is From an External Sender
This message came from outside your organization. Report Suspicious Please find attached the Sierra Club's comments on the SFPUC 2025 Draft UWMP.

Thank you,
Mark Shahinian
Serving Alameda, Contra Costa, Marin and San Francisco counties To: SFPUC Commissioners RE: UWMP comments April 7, 2026 San Francisco Public Utilities Commission 525 Golden Gate Avenue San Francisco, CA 94102 Dear Commissioners, The Sierra Club has reviewed the 2025 SFPUC Draft Urban Water Management Plan. This plan repeats

fundamental

methodologic

errors

of

past

plans

that

have

consistently

overpredicted

customer

demand.

Adopting

this

plan

would

result

in:
● Unwarranted investments in unnecessary new supplies and infrastructure that would cost

ratepayers

billions

of

dollars,

and;
● Preventable and lasting harm to California’s rivers and wetlands. As part of our review of the UWMP, we have obtained, through public records requests, the models

that

underlie

the

demand

projections

for

the

SFPUC

and

its

BAWSCA

member

agencies.

Our

analysis

below

includes

a

detailed

examination

of

the

assumptions

and

structure

of

those

models.

We

are

troubled

by

the

number

of

instances

where

the

models

do

not

meet

the

legal

standard

of

substantial

evidentiary

support

laid

out

by

the

California

courts.

Errors

we

have

found

in

the

SFPUC

and

BAWSCA

models

include

an

assumption

that

single

family

and

multi-family

residences

are

100%

occupied,

when

the

occupancy

figure

includes

vacant

units

and

units

up

for

sale

and

100%

has

never

been

reached

in

San

Francisco

as

long

as

occupancy

statistics

have

been

collected;

loss

projections

that

exceed

those

allowable

by

state

law;

assumptions

around

no

increase

in

rates,

even

though

a

city

council

has

approved

a

rate

increase;

assuming

all

active

conservation

programs

come

to

a

halt

in

2035.

If the actual demand modeling errors in the SFPUC retail model that we are able to quantify are added

up,

we

find

demand

in

2050

would

be

10 MGD

lower.

If

the

lack

of

passive

demand

were

similarly

addressed,

we

estimate

retail

demand

would

drop

a

further

5-10

MGD

to

about

55 MGD.

These

reductions

would

occur

even

without

altering

the

inflated

population

growth

projections

in

the

model.

We

have

not

been

able

to

quantify

the

errors

in

the

BAWSCA

models,

but

given

the

scale

of

the

BAWSCA

agencies’

water

demand,

we

estimate

the

magnitude

of

the

error

to

be

double

what

we

find

in

the

retail

model.

Serving Alameda, Contra Costa, Marin and San Francisco counties We urge the SFPUC commissioners to reject this draft UWMP and: 1) Direct staff to fix modeling errors and to re-evaluate assumptions in this UWMP that are not supported

by

facts

or

by

sufficient

evidence
2) Set up a funded working group that brings interested parties together to re-evaluate the UWMP

process

with

a

mandate

to

issue

a

new

UWMP

within

24 months.

The

new

UWMP

should

be

based

on

more

sophisticated

modeling

of

demand

and

supply,

such

as

using

Monte

Carlo

simulations

and

drought

impacts

to

project

outcomes.

When the UWMP is revised, we believe the numbers will show that the SFPUC can accommodate

both

the

Bay

Delta

Plan

and

its

water

users’

needs.

To

that

end,

we

ask

that

the

SFPUC

pause

its

opposition

to

the

Bay

Delta

Plan.

Details of our analysis follow in the attached appendix. Sincerely, Mark Shahinian Sierra Club SF Bay Chapter Water Committee cc: Steve Ritchie, Jennifer Lee, Manisha Kothari

Serving Alameda, Contra Costa, Marin and San Francisco counties Appendix: Detailed Analysis
SFPUC retail demand projections The SFPUC’s 2025 demand projections ignore all the hard work its customers have done to save water

over

the

previous

25 years.

Its

projections

appear

to

assume

that

its

customers’

ability

to

conserve

water

is

largely

a

thing

of

the

past.

We

disagree,

and

we

find

many

of

the

key

assumptions

behind

the

SFPUC’s

calculations

to

be

erroneous

or

not

based

in

fact. We

also

calculate,

for

many

issues

below,

the

demand

reduction

that

would

result

from

a

correction.

Note

that

the

totals

below

add

to

more

than

the

summary

total

above

because

the

total

above

is

calculated

to

avoid

double-counting.

The graph below illustrates the inaccuracy with which the SFPUC has, over time, projected water

demand

on

its

system.

We

are

concerned

that

the

2025

projection

is

similar

in

slope

and

accuracy

to

previous

projections,

albeit

with

a

different

starting

point.

Serving Alameda, Contra Costa, Marin and San Francisco counties Modeling assumptions in the UWMP retail demand projections which are not supported

by

substantial

evidence:
1) Unit occupancy a) SFR: the demand model brings occupancy up from 91.4% today to 100% in 2030.

This

includes

units

that

are

vacant,

for

rent

or

for

sale,

so

it

is

difficult

to

understand

100%

occupancy

as

an

input.

The

91.4%

matches

2020

census

data,

so

a

post-pandemic

rebound

is

not

a

factor

here.

Historical

occupancy

rates

in

San

Francisco

have

trended

downward,

from

about

95%

in

2000

to

88.5%

in

2024,

according

to

U.S.

Census

data.

There

is

no

documented

instance

of

overall

occupancy

in

San

Francisco

reaching

100%.
1 b) MFR: Same comment as for SFR c) This occupancy modeling input has a surprisingly large effect. Keeping this input at

the

2020

level

for

MFR

and

SFR

would

lower

2050

demand

by

about

4 MGD
.
2) Active conservation a) Active conservation programs come to a halt in the SFPUC demand model in 2030

or

2035.

Considering

the

tens

of

millions

of

dollars

the

SFPUC

has

poured

into

active

conservation

programs,

and

the

benefits

ratepayers

have

seen

from

these

programs,

it

is

hard

to

understand

the

rational

basis

for

a

complete

halt

to

these

programs

at

a

future

date.

The

argument

that

future

savings

cannot

be

predicted

and

therefore

cannot

be

used

flies

in

the

face

of

the

entire

point

of

an

exercise

that

is

supposed

to

model

the

future.
b) This omission, if corrected and the growth of passive conservation were continued

in

the

model,

would

result

in

a

2.9 MGD

drop

in

forecasted

demand

by

2050.
3) Onsite water reuse a) Onsite reuse of graywater is mandated for new residential and commercial buildings

>100,000

square

feet

by

the

city’s

Onsite

Water

Reuse

Program.

b) Much like the active conservation calculation, the growth of onsite potable reuse calculation

in

the

SFPUC

model

slows

after

2030

and

comes

to

an

end

in

2035.

The

SFPUC

staff

says

this

is

because

they

do

not

have

visibility

into

future

residential

and

commercial

projects

that

would

make

use

of

onsite

reuse.

Proper

use

of

the

power

of

models

to

project

the

future

should

be

able

to

address

this

issue.

1 Per the US Census definition: “A housing unit which is occupied temporarily by persons who usually live elsewhere

is

interviewed

as

a

vacant

unit

provided

that

a

usual

place

of

residence

is

held

for

the

household

which

is

not

offered

for

rent

or

for

sale.

For

example,

a

beach

cottage

occupied

at

the

time

of

the

interview

by

a

family

which

has

a

usual

place

of

residence

in

the

city

is

included

in

the

count

of

vacant

units.”

Serving Alameda, Contra Costa, Marin and San Francisco counties c) The planning department has insights into what percent of residential units and commercial

square

footage

would

be

over

100,000

sq.

ft

and

therefore

be

required

to

perform

onsite

reuse.

That

percentage

should

be

applied

to

the

tens

of

thousands

of

new

units

of

MFR

and

millions

of

square

feet

of

commercial

that

both

Planning

and

the

SFPUC

are

projecting

will

be

built

in

the

next

25 years.
4) Baseline issues a) MFR baseline issues i) In the model, new MFR units use the same gallons per unit per day as existing

units.

This

appears

to

be

a

modeling

error,

as

new

units,

according

to

data

buried

further

back

in

the

model

on

the

Baseline

Water

Use

tab,

are

estimated

to

use

18%

less

than

the

MFR

existing

units.

ii) Correcting this error will result in a 2050 demand reduction of 2.4 MGD. b) Commercial baseline issues i) There appears to be an error in the model, where baseline C&I demand is calculated

as

12.37 MGD

on

the

Baseline

tab,

but

this

value

is

not

properly

carried

through

to

the

CI

Forecast

tab.

The

value

of

the

forecast

tab

is

12.40 5) Losses a) The current average SFPUC retail real loss level at 7.1 MGD, or 33.0 gallons per connection,

exceeds

by

about

18%

the

loss

threshold

set

by

state

law.

Yet

the

UWMP

carries

this

level

of

losses

forward

well

beyond

the

2028

target

date

for

enforcement

of

the

state

law.

Because

many

new

MFRs

will

use

one

service

connection

to

serve

dozens

of

units,

the

unit

growth

will

not

lower

the

per-connection

number

enough

to

bring

SFPUC

back

into

compliance.
b) The SFPUC says this UWMP loss estimate is a “conservative” estimate. “Conservative”

cannot

mean

“in

violation

of

the

law”

and

so

this

high

estimate

should

not

be

used

for

water

losses.
c) Simply resetting this assumption to meet the state standard would lower demand

by

between

1 and

1.3 MGD.
6) Rate inputs into model a) Because there is no passive conservation built into the model except onsite reuse,

and

active

conservation

measures

are

not

modeled

beyond

2030/35,

nearly

all

conservation

comes

from

price

sensitivity

of

water

users

to

increases

in

rates.

However,

the

rates

built

into

the

model

are

problematic

in

several

ways:
i) The SFPUC shows high rate increases over the next several years, averaging

over

9%

through

2031.

However,

after

2035,

rate

increases

drop

to

just

above

the

rate

of

inflation.

This

cannot

be

correct,

as

it

does

not

account

for

all

planned

spending,

even

if

that

spending

is

not

in

the

current

capital

spending

plan.

ii) On March 23 2026, the SFPUC finance team presented the 10-year Capital Plan

with

multiple

billions

of

dollars

in

SFPUC

water

and

wastewater

Serving Alameda, Contra Costa, Marin and San Francisco counties projects that will be started during the current 10-year capital plan but incur

most

of

their

costs

between

2035

and

2050.

Funding

these

projects

would

increase

rates

far

beyond

the

level

of

inflation

in

the

2035-2050

time

period.
iii) In the years 2044 and 2045, rate increases drop below the level of inflation.

This

does

not

appear

in

line

with

historical

experience.
iv) In the years 2045-2050, rate increases and inflation both drop to zero in the

model.

This

appears

to

be

a

modeling

error.
b) Setting nominal rate increases past 2036 to 3% above inflation would result in a 3 MGD

drop

in

demand

by

2050.

Whether

3%

is

the

right

answer

or

not

we

do

not

know,

but

more

in-depth

analysis

should

be

done

on

this

projection.

SFPUC

retail

modeling

assumptions

which

detailed

analysis

does

not

appear

to

support:

7) Passive conservation a) Passive conservation has been one of the biggest drivers of the 36% per-capita decline

in

demand

we

saw

in

San

Francisco

from

2000

to

2024.

Yet

the

model

does

not

incorporate

passive

conservation

into

its

calculations,

with

the

partial

exception

of

onsite

potable

reuse

noted

above.
b) The lack of passive conservation is an obvious structural flaw in the SFPUC model,

and

perhaps

explains

its

relatively

low

R-squared

in

SFR

and

MFR

of

about

0.7.,

meaning

the

model

explains

only

about

70%

of

observed

variation

in

demand,

suggesting

a

significant

missing

variable.

We

have

not

seen

how

the

model

coefficients

are

constructed

but

suspect

that

passive

savings

is

a

large

missing

variable.
c) The SFPUC has said they do not include passive conservation for fear of double counting.

But

in

not

including

passive

conservation

the

model

badly

undercounts

conservation

as

a

whole.

In

fact,

while

San

Franciscans

in

2024

used

36%

less

water

per

capita

than

they

did

in

2000,

over

the

next

25 years

the

UWMP

shows

San

Franciscans

using

only

12%

less

water

per

capita

in

2050

than

they

do

now.

This

shows

that

if

anything,

water

conservation

is

being

undercounted.
d) We are not able to quantify the overshoot here, but our analysis suggests this number

is

in

the

5-10

MGD

range.

8) MFR Housing unit growth in baseline scenario a) A growth in multi-family housing units to accommodate 310,000 more residents in

San

Francisco

over

the

next

25 years

seems

improbable.

This

would

be

a

sustained

growth

rate

over

a

25-year

period

that

is

more

than

2x

the

historical

average

and

25 times

what

the

California

DOF

predicts.

Serving Alameda, Contra Costa, Marin and San Francisco counties b) We believe the base case for population growth should follow the Department of Finance,

rather

than

the

high

case.
c) Holding MFR persons per housing unit the same over the next 25 years, particularly

as

it

is

also

the

same

as

the

SFR

persons

per

housing

unit,

seems

an

unsophisticated

and

likely

inaccurate

view

of

the

future

of

San

Francisco’s

demographics.
d) We appreciate that two other housing and job scenarios have been created. We expect

that

if,

at

the

time

of

the

2030

UWMP,

the

housing

trajectory

set

in

this

UWMP

has

not

proved

accurate,

there

will

be

a

revision

to

a

lower

trajectory

instead

of

a

continuation

along

the

same

path.

9) Droughts set to zero a) Both the SFPUC model and the model the Sierra Club demand model agree that droughts

have

a

significant

effect

on

water

demand.

However,

the

SFPUC

model

has

its

drought

factor

set

to

zero

for

the

next

25 years.

b) The Sierra Club has found in its own modeling previously shared with the SFPUC that

droughts

and

drought

history

are

the

key

factor

in

determining

future

water

demand
c) The SFPUC assumption that there will be no droughts over the next 25 years does

not

appear

rooted

in

facts

or

science.

We

request

that

the

SFPUC

incorporate

drought

projections

into

its

simulations,

as

its

model

is

prepared

to

do.

BAWSCA wholesale demand projections incorporated in UWMP

Two-thirds

of

the

SFPUC’s

water

is

distributed

to

its

wholesale

customers,

most

of

which

are

BAWSCA

members.

The

demand

projections

of

these

customers

therefore

have

an

outsized

influence

on

the

future

of

demand.

We

obtained,

via

public

records

request,

the

models

underlying

the

demand

projections

of

BAWSCA

members.

We

analyzed

five

of

these

demand

models

in

depth

–

from

the

cities

of

Mountain

View,

Hayward,

Redwood

City,

Hillsborough

and

Palo

Alto.

We

were

surprised

to

learn

that

SFPUC

staff

had

not

seen

these

models,

on

which

so

much

of

their

future

planning

depends.

There

were

some

common

errors

and

problematic

characteristics

to

these

BAWSCA

models,

which

we

highlight

below.

The

SFPUC

has

chosen

to

accept

the

BAWSCA

numbers

without

adjustment.

That

choice,

we

believe,

is

a

poor

one.

Serving Alameda, Contra Costa, Marin and San Francisco counties Modeling assumptions in the BAWSCA demand projections which are not supported

by

substantial

evidence:
1) Most active conservation programs end in 2034 or 2035 a) The BAWSCA models stop most gains from active conservation programs in 2034 or 2035.

Like

San

Francisco,

these

cities

have

invested

millions

of

dollars

into

active

conservation

programs,

and

we

can

find

no

reasonable

basis

for

the

assumption

that

these

programs

will

come

to

a

halt

in

10 years

time.

2) Future water rates held constant a) The BAWSCA models have the capability to evaluate water demand as water rates go

up.

However,

nearly

all

BAWSCA

agency

models

have

frozen

rates

in

real

terms.

Palo

Alto

is

the

one

exception,

and

even

Palo

Alto

stops

all

rate

increases

in

the

year

2030.

SFPUC

staff

seemed

surprised

when

they

learned

this.

This

assumption

effectively

takes

the

“econo”

out

of

BAWSCA’s

“econometric”

model.

b) As justification for not changing rates, BAWSCA cites a year-old SFPUC document, when

a

more

recent

update,

released

before

BAWSCA

finalized

their

demand

numbers,

showed

a

much

higher

increase

in

wholesale

rates.

In

addition,

BAWSCA

cities

are

faced

with

the

same

declining-demand

and

increasing-costs

problems

of

San

Francisco.

c) BAWSCA’s board, at their XX meeting, was notified that “Beyond the 10-Year CIP, SFPUC

estimates

approximately

$10.1

billion

of

capital

improvement

projects

over

the

next

30 years

that

will

mostly

focus

on

rehabilitation

of

dams

and

spillways

for

reservoirs

throughout

the

regional

water

system

to

comply

with

California

dam

safety

regulatory

requirements.

For

comparison,

Mr.

Francis

referenced

the

Water

System

Improvement

Program

(WSIP)

which

has

a

total

cost

of

$4.8

billion

and

is

nearing

completion

after

20+

years.

The

implications

that

costs

will

rise

in

real

terms

are

clear.
d) For example, Redwood City gave notice in November 2025 of a 20% increase in its water

rates

over

2.5 years,

but

this

is

not

reflected

in

Redwood

City’s

BAWSCA

model.

e) BAWSCA has said they do not incorporate rate rises into their models so as to establish

a

“neutral,

defensible

baseline”.

However,

while

BAWSCA

cities

lowered

per-capita

water

use

by

39%

over

the

past

25 years,

their

forecast

for

the

next

25 years

predicts

lowering

per-capita

use

by

only

19%.

This

suggests

that

if

anything,

the

baseline

established

is

not

neutral

and

not

defensible.
f) Building in price sensitivity would likely reduce projected demand by dozens of MGD

by

2050.

For

example,

increasing

Mt

View’s

prices

to

3%

per

year

above

inflation

would

drop

Mt

View’s

projected

demand

by

about

11%

by

2050.

Serving Alameda, Contra Costa, Marin and San Francisco counties

BAWSCA

modeling

assumptions

which

detailed

analysis

does

not

appear

to

support:

3) Residential population growth is the largest issue with the BAWSCA projections a) Overall, the BAWSCA members project population growth over the next 25 years will

be

1.5%

per

year.

This,

however,

contradicts

historical

growth

trends.

The

growth

rate

for

the

past

25 years

was

0.61%,

so

the

BAWSCA

growth

projections

exceed

the

historical

average

by

2.4x.

The

BAWSCA

territory

has

not

grown

by

1.5%

even

on

a

decade-long

basis,

much

less

25 years,

since

1993.

b) Accepting this inflated population projection costs the residents of San Francisco, because

San

Franciscans

pay

their

current

proportional

share

of

infrastructure

projects

to

cover

population

growth

in

BAWSCA

cities

which

will

likely

never

materialize.
c) Changing this assumption alone to match the CA Department of Finance population

growth

projection

number

would

result

in

a

57 MGD

drop

in

projected

water

use,

down

to

165

MGD

(total

BAWSCA

demand,

about

two-thirds

of

which

is

served

by

the

RWS),

assuming

per-capita

water

use

levels

also

drop

as

projected

in

the

BAWSCA

model.

4) CII job growth a) Hayward in particular appears to have an ambitious take on their future job growth,

projecting

a

doubling

of

jobs

in

Hayward

in

the

next

25 years,

and

a

sharp

rise

in

water

use

along

with

it.

Hayward

stands

out

in

previous

UWMPs

as

consistently

over-projecting

water

demand.
5) Passive savings a) Passive savings are hard-coded into the BAWSCA models, so it is impossible to verify

the

amounts

or

sources

of

these

passive

savings.

In

general

this

hard-coding

of

values

is

a

modeling

practice

that

makes

verification

difficult

and

calls

into

question

the

numbers

that

are

hard-coded.
b) Passive savings total about 5% of total use in 2050. We find this number unsupportably

small

given

the

success

BAWSCA

customers

have

had

in

saving

water

over

the

past

25 years.

6) Climate modeling a) BAWSCA has chosen a different forward-looking climate model than the SFPUC.

This

is

problematic

and

the

climate

models

should

be

reconciled.
7) Droughts set to zero a) Like the SFPUC, BAWSCA’s model can take droughts into account. Like the SFPUC, BAWSCA’s

model

does

not

currently

factor

any

droughts

into

the

next

25 years

of

planning.

This

lack

of

droughts

is

at

odds

with

historical

experience

and

with

what

climate

science

tells

us.

Serving Alameda, Contra Costa, Marin and San Francisco counties Drought scenario projections
We have not been able to fully evaluate the drought scenarios due to insufficient documentation

in

the

UWMP

and

lack

of

access

to

the

underlying

models.

We

request

that

the

following

critically

important

questions

be

addressed

before

UWMP

adoption:
1) How statistically likely (i.e. what is the return period) is the synthetic 8.5 year design drought?

The

public

should

be

able

to

verify

the

model

that

calculates

this

likelihood.

We

believe

the

SFPUC

should

not

synthesize

a

design

drought

that

is

so

unlikely

to

occur

that

it

is

not

useful

for

planning

purposes.
2) The demand model is well documented. Similar documentation should be provided in an appendix

around

the

synthetic

design

drought

and

Shortfall

amounts.

Please

provide

all

associated

models

that

calculate,

for

the

entire

design

drought:
a) Precipitation and runoff at the most granular available data, both historic and future

looking

under

the

SFPUC’s

chosen

climate

scenario(s)
b) Shortfall amounts at daily timesteps c) Storage volumes at daily timesteps 3) A more sophisticated modeling of demand during a drought would show that demand declines

after

the

first

year.

We

request

SFPUC

run

its

WSRA

and

DRA

numbers

with

modeled

demand

declines

and

publish

them

in

the

UWMP

along

with

the

tables

it

already

has

in

place.

1 From: Shannon Rose <[email protected]>
Sent: Tuesday, April 7, 2026 9:48 PM
To: Commission
Subject: Fwd: Emailing the SFPUC
Attachments: SF.'s exodus still hasn't reversed. Here's how the population trend compares to other regions.pdf; PastedGraphic-1.png; PastedGraphic-2.png; PastedGraphic-3.png This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Dear Commissioners:

I'm writing in regards to the Urban Water Management Plan. I am very concerned because it would focus on inflated population growth projections. Here’s the problem. The UWMP projects the population of SF will grow from 843,881 in 2025 to 1,231,654 in 2050. That would be the addition of 387,773 people in 25 years, or 15,511 people per year.

However, between 2005 and 2025 the population of SF grew by only 62,044, or 3,102 people per year. Do you really think SF’s population will grow five times as fast in the near future as it has done in the recent past?
You should revisit the population growth projections and include defensible numbers in the final UWMP. I am attaching an article from the Chronicle on March 26. It points out that the population of SF has actually shrunk since 2020. There’s a nice graphic that is cut off in the pdf I attached, so I’m including it separately.

Thank you for giving this important issue your attention.

Sincerely,
Shannon McEntee
410 Sheridan Avenue
Palo Alto, CA 94306
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SF.'s exodus still hasn't reversed.

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After a sharp decline during the pandemic, the San Francisco metro area's population failed to grow again in 2025, despite a swelling boom in AI. Unlike in almost every other major metro in the country, that's left the region's total population well below its 2020 level, according to newly released U.S. Census estimates.

The number of residents in the San Francisco metropolitan area, which also includes the East Bay, Peninsula and Marin County, was still 2.6% less in July 2025 than it was in April 2020, the most recent metro-level data show. Among metro areas with more than 1.5 million residents, that population loss is only outpaced by Los Angeles, which was down

2.7%.

The San Jose metro area, which spans Sunnyvale and Santa Clara, saw a slightly smaller dip over the five year span, with its July 2025 estimate coming in at 0.8% smaller than its April 2020 estimate.

Elsewhere across the Sun Belt, Austin, Dallas, Houston and San Antonio in Texas, Jacksonville and Orlando in Florida and Charlotte in North Carolina all saw growth rates at or above 10% over the same time frame.

The data underscore how the rapid changes brought on by the pandemic in 2020 have continued to have lasting effects in the Bay Area, where remote work has firmly taken hold, allowing workers to leave the area for cheaper homes elsewhere. On top of that, states like Texas are also building housing at a far faster pace than the Bay Area.

Even affluent coastal places more similar to the Bay, like Boston and Seattle, are outpacing the region when it comes to new homes.

Pedestrians walk towards the Ferry Building in San Francisco, Jan. 23, 2026. The metro's population still hasn't recovered to pre-pandemic levels, unlike other major metros throughout the country. (Giselle Garza Lerma/S.F. Chronicle) Sponsored
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Chevron said it is threatening to close its oil refineries in California due to overregulation, which the oil company said is contributing to price spikes amid the war in Iran.

Due to California’s taxes, emissions rules and other regulations, which hit gas costs harder than in many other states, the price per gallon is well over the national average.

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In turn, Chevron, which imports fuel from China, South Korea and Singapore, is facing the brunt of the blockade. Amid the energy crisis, Beijing has banned fuel exports.

Andy Walz, who heads Chevron’s oil refining efforts, said leaders in California should be worried about the possibility of a fuel deficit in the Golden State.
“We have refineries in Asia that are having to cut crude, and so they’re going to make less products,” Walz said in an interview with Bloomberg on Tuesday. “What if San Francisco doesn’t have the jet fuel it needs? Or Los Angeles? Or maybe gasoline?”
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1 From: Chinese Chamber of SF <[email protected]> Sent: Thursday, April 9, 2026 2:48 PM
To: Commission; Arce, Julio C; [email protected]; Herrera, Dennis J Cc: SFChinese Chamber of Commerce; Donald Luu; david .ho; Judy Lee Subject: Opposition Letter to SFPUC Regarding Recent Rate Hike Proposal Attachments: 04_08_26 Chamber Opposition Letter to SFPUC.pdf This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Dear SFPUC President Arce and Commissioners,
Please see attached the Chinese Chamber of Commerce's opposition letter addressing the recent rate hike proposal.

Thanks,
Chinese Chamber of Commerce

CHINESE CHAMBER OF COMMERCE
730 Sacramento Street, San Francisco, CA 94108
(415) 982-3000 Fax: (415) 982-4720
April 8, 2026
Dear SFPUC Commissioners,
On behalf of the San Francisco Chinese Chamber of Commerce, we write to express our strong opposition to the proposed water and wastewater rate increases currently under consideration by the San Francisco Public Utilities Commission.

At our monthly board meeting held on March 10, 2026, we hosted representatives from the SFPUC, including Financial Planning Director Erin Corvinova and Senior Communications Officer Angela Lowry, who presented the proposed rate adjustments. We appreciate the agency’s outreach and the detailed explanation provided. We understand that much of San Francisco’s water infrastructure is approaching 100 years old and requires ongoing upgrades to prevent system failures, meet stricter regulatory requirements, and ensure reliability. We also recognize additional cost pressures, including reduced federal investment, debt service obligations, and rising construction costs.

However, despite these considerations, the scale and timing of the proposed increases raise serious concerns for our members and the broader small business community. According to the presentation, the average residential monthly bill is expected to increase by $21 in FY2027 and $23 in FY2028—representing annual increases of approximately 12.6% and 12.5%. If approved, these new rates would take effect as early as July 1, 2026.

For small businesses—particularly restaurants, retail establishments, and service providers—water and wastewater services are essential and non-discretionary. Many of our members are still recovering from prolonged economic challenges and continue to face rising costs in rent, labor, insurance, and utilities. Additional increases of this magnitude will place significant strain on already thin operating margins and may ultimately lead to price increases for consumers, reduced hiring, or even business closures.

We urge the Commission to carefully consider the cumulative economic impact of these increases, especially on small, immigrant-owned, and legacy businesses that form the backbone of San Francisco’s neighborhood commercial corridors. While we support necessary infrastructure investments, we believe there must be a more balanced and equitable approach.

Specifically, we respectfully request that the Commission:
● Reevaluate the proposed rate increases and consider more gradual, phased adjustments; ● Expand financial assistance and rate relief programs for small businesses; ● Increase transparency regarding project prioritization and cost controls; ● Engage in deeper and ongoing consultation with impacted communities before finalizing any decision.

CHINESE CHAMBER OF COMMERCE
730 Sacramento Street, San Francisco, CA 94108
(415) 982-3000 Fax: (415) 982-4720
We respectfully ask that implementation of the proposed rate increases be delayed to allow for further stakeholder input and exploration of alternatives that mitigate the burden on vulnerable communities.

Thank you for your attention to this critical issue and for your continued service to the residents and businesses of San Francisco. We stand ready to work collaboratively with the Commission to find solutions that ensure both infrastructure reliability and economic sustainability.

Sincerely,
Donald Luu
President
San Francisco Chinese Chamber of Commerce
Cc: Dennis Herrera, General Manager, SFPUC

1 From: Anna Chan <[email protected]>
Sent: Saturday, April 11, 2026 10:25 PM
To: [email protected]
Cc: Chen, Chyanne (BOS); Mauer, Dan (REC); John-Baptiste, Alicia (MYR); [email protected]; Madland, Sarah (REC); [email protected]; Board of Supervisors (BOS); Commission
Subject: Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Dear Commissioners,
As someone who has grown up in this neighborhood and lived here my entire life, I am writing to urge you to protect Crocker Amazon Park from a proposal that would replace its natural open space with a fenced-in artificial turf sports complex.

The plan proposed by the San Francisco Recreation and Park Department in partnership with the San Francisco Giants and team owner/Trump donor Charles B. Johnson is being framed as a "gift." However, many neighbors did not ask for this project and do not support paving over meadows, cutting down mature trees, and fencing off large portions of a beloved community park.

Artificial turf also raises serious concerns. Synthetic fields are associated with higher surface temperatures, increased injury rates compared to well- maintained natural grass,
and exposure to toxins like PFAS and microplastics. It's particularly troubling that the majority of artificial turf installations have been clustered in neighborhoods already burdened by asthma and environmental justice challenges.

I strongly support renovating Crocker Amazon Park, but doing so the right way:
- Yes to meaningful community input.
- Yes to natural grass fields and open green space.
- Yes to preserving mature trees and the park's character. - Yes to space for seniors, families, cricket players, dog walkers, and youth sports alike. - No to expanding toxic artificial turf.
- No to increased traffic, noise, and late-nightly bright field lighting. - No to privatization and fencing that limits access.
- No to cutting down the majority of existing trees.
2 Please stand with neighborhood residents and protect this city treasure. Invest in improvements that enhance public health, environmental justice, and shared access, not in plastic infrastructure that narrows and intensifies use.

Sincerely,
Anna Chan
1 From: Tony Rafael Figueroa <[email protected]>
Sent: Saturday, April 11, 2026 10:25 PM
To: [email protected]
Cc: Madland, Sarah (REC); Chen, Chyanne (BOS); [email protected]; John-Baptiste, Alicia (MYR); [email protected]; Board of Supervisors (BOS); Commission Subject: Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation This Message Is From an External Sender
This message came from outside your organization. Report Suspicious Dear Commissioners,
I'm writing to urge you to revise and substantially improve the proposed renovation plan for Crocker Amazon Park.

Crocker Amazon is a city treasure, enjoyed by generations of San Franciscans. Please do not allow the San Francisco Recreation and Park Department to cut down over 100 mature trees and convert natural grass meadows into a fenced-in, 20-acre artificial turf baseball complex. Artificial turf is petroleum-based, sheds microplastics, and has been associated with higher rates of ACL and Achilles injuries compared to well-maintained natural grass.

Converting this shared, multi-generational and multi-ethnic public space into a specialized facility serving a narrow user group would fundamentally change the character of the park and limit access for many current users.

Organically managed natural grass fields do not carry the same environmental justice burdens as plastic turf. Rec & Park has already concentrated approximately 85% of its synthetic turf installations in neighborhoods with the highest asthma rates and a documented history of racial and environmental inequities. As currently proposed, this project would increase that concentration to roughly 90% of the City's total artificial turf acreage in historically disenfranchised communities.

We can and must do better. Investing in high-quality, organically managed natural grass fields, similar to the improvements made at West Sunset Playground, would preserve trees, avoid unnecessary plastic pollution, and maintain a welcoming, multi-use park for residents of all ages.

I ask that you prioritize a renovation plan that protects public health, advances environmental justice, preserves mature trees, and keeps Crocker Amazon a park for everyone, young and old. --
Best,
--
Tony R. Figueroa
University of California, Berkeley | Class of 2023
B.S. Nutritional Science - Physiology & Metabolism
[email protected] | (323) 500-8697
1 From: Michael Rich <[email protected]>
Sent: Sunday, April 12, 2026 3:17 PM
To: Commission
Subject: Stop the plastic pollution
This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious As a park loving resident I demand that our park not be bullied into a plastic nightmare because of the SF Giants. Artificial turf creates heat and pollution. I never in my life would have thought that I would have to beg for parks not to be covered in plastic.

Michael Rich
1045 Prague Street
San Francisco 94112
Sent from my iPhone
1 From: Mary Butterwick <[email protected]>
Sent: Sunday, April 12, 2026 7:49 PM
To: Commission
Subject: Comments on the Draft 2025 Urban Water Management Plan Attachments: SFPUC April 14 2026 Item 8.docx
This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Chair Josh Arce and Commissioners,
Attached are my written comments on the Draft 2025 Urban Water Management Plan. Thank you for the opportunity to comment on this important document.

Sincerely,
Mary Butterwick
1 April 13, 2026

Chair Josh Arce and Commissioners
San Francisco Public UƟliƟes Commission
[email protected]

Re: Comments on the DraŌ 2025 Urban Water Management Plan

Dear Chair Arce and Commissioners:

My name is Mary BuƩerwick. I am a resident of San Francisco and a ratepayer. These comments are intended to supplement those I plan to provide in public comment on April 14, 2026. As a reƟred botanist, I have worked with riverine systems for most of my professional career and appreciate the many funcƟons provided by a healthy river.

Tragically, the Tuolumne River and the larger Bay-Delta ecosystems are in crisis, due mainly to inadequate flows. NaƟve fish and wildlife populaƟons are crashing. We now have seven naƟve species on the brink of exƟncƟon. Salmon populaƟons are in severe decline. Toxic algal blooms have conƟnued to get worse. These dire condiƟons all indicate that the reasonable protecƟon of beneficial uses is not being achieved here. Central to the lack of instream flows is the SFPUC’s conƟnued use of an 8.5-year Design Drought as its primary tool for managing flow releases.
2 I am wriƟng today to share my concerns regarding certain aspects of the DraŌ 2025 Urban Water Management Plan that directly affect the management of flows in the Tuolumne River. The Urban Water Management Plan (UWMP) is an important document in that it incorporates a 5-year update of water demand projecƟons, supply reliability, and strategies to meet future challenges. It essenƟally sets the direcƟon of the SFPUC for the next five years. The 8.5-year Design Drought has not been revisited for some 30 years. This reassessment needs to happen soon, before the UWMP is finalized.

Return period of 8.5-year Design Drought
SFPUC has never done an analysis of the risk of its 8.5-year Design Drought occurring. How rare an event are we talking about? Other water agencies, such as Valley Water and East Bay Municipal UƟlity District, use the 1987-1992 drought of record with a return period of 1:797 years. EsƟmaƟng return periods is an important tool for communicaƟng to the public the relaƟve risk that a drought of the magnitude of an 8.5-year Design Drought will actually occur. Yet even in the absence of any risk analysis, the SFPUC conƟnues to predict that extreme levels of raƟoning, up to 43% beginning in Dry Year 2 of a 5- year drought by 2050, will be needed with the Bay-Delta Plan Amendment in place (UWMP , Table 8-3). This dire predicƟon is likely the primary reason the SFPUC objects to the Bay-Delta Plan Amendment, which is the best opportunity we have to restore a reasonable level of instream flows to the Tuolumne River. However, it is unclear how the SFPUC calculated its water availability numbers. As Dave Wagner recently observed, to provide the threat of such high raƟoning percentages without providing the probability of such a drought actually occurring is not only misleading and unnecessarily 3 alarmist, but it also raises significant transparency issues. The SFPUC’s 2021 Long Term Vulnerability Analysis (LTVA) indicates that the 8.5-year Design Drought’s probability is somewhere in the once in 8,000 to 70,000-year Ɵmeframe, including considering the impact of climate change. I recommend that the SFPUC reengage Dr. Casey Brown, the lead author of the LTVA, to specifically help determine the return period for the Design Drought. Also please follow Dave Wagner’s recommendaƟon that the SFPUC provide a probability analysis on the risk of the 8.5-year Design Drought occurring along with risk analyses for lesser drought models so that a science-based drought model can be developed. The public deserves to know!
Water Supply Availability
Table 8-3 also fails to show how much water is leŌ in storage at the end of each year making it impossible to determine whether the extreme level of raƟoning is jusƟfied. Using data provided by the SFPUC, the Yosemite Rivers Alliance provided an alternaƟve table showing each year of the 8-year Design Drought and the volume of water leŌ in storage at the end of each year. With the Bay Delta Plan in effect, using SFPUC 2050 demand projecƟons, and including storage, the table shows that even aŌer the fiŌh year of the Design Drought the Regional Water System would sƟll have 606 thousand-acre-feet of water in storage.

That volume represents almost 3 more years of water supply using SFPUC demand projecƟons, without any raƟoning! It seems to me that SFPUC has plenty of water for the environment and people.

Affordability
I conƟnue to be alarmed that the Commission is facing a real fiscal crisis. My water/sewer rates are going up and likely to triple in the next 4 15 years, with 8% increases each year. How can low-income families possibly afford these increases? Within the next 10 years, debt service will account for more than half of the esƟmated cost for the water and sewer enterprises. This amount of debt service may severely constrain the Commission’s ability to fund future projects. More recently, I learned that SFPUC idenƟfied the need for an addiƟonal $10 billion of capital improvement projects over the next 30 years. And this doesn’t account for the enormous costs associated with developing alternaƟve water supplies, thought to require an addiƟonal $17-25 billion dollars.

How will these addiƟonal costs be factored into future rates? I do not believe that ratepayers should have to invest in very expensive water supplies that will not be needed. It is my understanding that by reducing the length of the Design Drought applying realisƟc demand projecƟons, one can substanƟally reduce the need for these costs.

San Francisco residents, such as myself, care deeply about the environment. We look to the Commission to be responsible stewards of the river by increasing flows in the Tuolumne River. With the salmon count in the Tuolumne so criƟcally low, we are running out of Ɵme to act. My husband and I were here during the 1987-92 drought and experienced raƟoning then. We discovered several ways of cuƫng back on water use. I would be more inclined to support future raƟoning if I knew the saved water would go to protect the environment.

Please revise the length and severity of the Design Drought before the UWMP is due to the Department of Water Resources on July 1. Thank you for the opportunity to comment of the draŌ UWMP .

Sincerely,
Mary BuƩerwick
1 April 13, 2026 President Josh Arce and Commissioners San Francisco Public Utilities Commission [email protected] Re: Earlier Runoff Benefits the SFPUC. Dear President Arce and Commissioners: As a result of climate change, more precipitation will fall as rain and the snowpack will melt sooner. Runoff will shift to earlier in the season. The Long-Term Vulnerability Assessment states: “A +2°C warming leads to a spring runoff arrival 10 days prior to the baseline temperature conditions. Median of projections estimate warming around +2°C by 2040 with most projections and elicitations between +1°C and +4°C. At +4°C, the shift in timing would be closer to 20 days prior to baseline conditions. By 2070 RCP8.5, warming could reach around +4°C with most projections and elicitations between +3°C and +6°C.” (p. 147) Due to this year’s warm, dry March, runoff has come earlier in the season. This has favored the SFPUC’s water entitlements as you see in the current Water Supply Conditions Update. Most of the snowmelt is happening prior to mid-April when the water rights delineation between the SFPUC and Irrigation Districts changes from about 2,400 cfs of runoff to about 4,000 cfs. Had the runoff occurred between mid-April and mid-June there would have been less Water Available to the City (WAC).

Source: SFPUC Water Supply Conditions Update, April 6, 2026

2 The following graph shows the average runoff in the Tuolumne River. The dashed black line delineates the cutoff between the Irrigation Districts’ and SFPUC’s water rights.

Source: SFPUC presentation, February 5, 2021 In the next two slides, two vertical lines were added to represent a three-week shift in runoff. Imagine everything shifting to the left, except the dashed black line, until the added vertical lines line up with the vertical dashed lines of the water rights delineation. In a “Critical” water year the runoff shown in red shifts from the period when the SFPUC is entitled to any flow above 4,000 cfs to the period when the SFPUC is entitled to any flow above 2,400 cfs. This is water the SFPUC would pick up as a result of earlier runoff.

3 In a “Dry” water year the SFPUC would pick up the water shown in the yellow rectangle below and would lose a much smaller amount of water shown in the yellow triangle.

Since we know what the daily runoff was in the past, it’s easy to quantify how a shift to earlier runoff would impact WAC. The following scatterplot (1971-2012) shows the results of a three-week shift in runoff. Zero on the vertical axis represents no change in water entitlements. Dots above zero represent years in which the SFPUC would pick up water. Years below zero represent years in which the Irrigation Districts would pick up water. The horizonal axis represents WAC – the further to the right, the greater the SFPUC’s water entitlements are.

Source: Dave Warner, Yosemite Rivers Alliance

4 Averaging out all the years, there is little to no change in WAC. The diagonal line crosses zero on the vertical axis at 750 TAF, which is the SFPUC’s current average annual entitlement. However, you see that in dry years (on the left) the SFPUC tends to pick up water, and in wet years the SFPUC tends to lose water. Losing water entitlements in wet years is not a problem, because in those years water is usually spilled and it doesn’t matter who the spilled water belonged to. The following table shows the results of a three week shift in runoff. If the eight years of the Design Drought were to repeat, but runoff came earlier, the SFPUC would pick up a total of 237 TAF over the course of the Design Drought. To put this in perspective, last year’s demand was 191 mgd, which is 214 mgd. In other words, the SFPUC would pick up more than a year’s-worth of water as a result of a three-week shift in runoff. Note that if 1976 and 1977 (very dry years) were not included in this analysis, the SFPUC would still pick up 217 TAF – a year’s-worth of water – if the drought of record (1987-92) were to repeat with a three-week shift in runoff.

Source: Dave Warner, Yosemite Rivers Alliance Please direct staff to respond to this analysis and incorporate any findings into future documents. Avoiding unnecessary investments in alternative water supplies would help reduce water rate increases dramatically. Thank you for your consideration. Sincerely, Peter Drekmeier Policy Director Cc: BAWSCA Board of Directors SFPUC Citizens Advisory Committee

1 From: asmilk <[email protected]>
Sent: Monday, April 13, 2026 12:15 AM
To: Commission
Subject: Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Dear Commissioners,
I'm writing to urge you to revise and substantially improve the proposed renovation plan for Crocker Amazon Park.

Crocker Amazon is a city treasure, enjoyed by generations of San Franciscans.

Please do not allow the San Francisco Recreation and Park Department to cut down over 100 mature trees and convert natural grass meadows into a fenced-in, 20-acre artificial turf baseball complex. Artificial turf is petroleum- based, sheds microplastics, and has been associated with higher rates of ACL and Achilles injuries compared to well-maintained natural grass. Converting this shared, multi-generational and multi-ethnic public space into a specialized facility serving a narrow user group would fundamentally change the character of the park and limit access for many current users.

Organically managed natural grass fields do not carry the same environmental justice burdens as plastic turf. Rec & Park has already concentrated approximately 85% of its synthetic turf installations in neighborhoods with the highest asthma rates and a documented history of racial and environmental inequities. As currently proposed, this project would increase that concentration to roughly 90% of the City's total artificial turf acreage in historically disenfranchised communities.

We can and must do better. Investing in high-quality, organically managed natural grass fields, similar to the improvements made at West Sunset Playground, would preserve trees, avoid unnecessary plastic pollution, and maintain a welcoming, multi-use park for residents of all ages.

I ask that you prioritize a renovation plan that protects public health, advances environmental justice, preserves mature trees, and keeps Crocker Amazon a park for everyone, young and old.

Sincerely,
Marvin.C
Sent from my Galaxy
1 From: SPUR Events <[email protected]>
Sent: Tuesday, April 14, 2026 10:02 AM
To: Commission
Subject: Join Mayor Lurie and SPUR: Good Government Awards – May 13 This Message Is From an External Sender
This message came from outside your organization. Report Suspicious Register Now!
Join San Francisco Mayor Daniel Lurie and SPUR at the 45th Annual Good Government Awards for an evening celebrating the civic leaders dedicated to making local government work for all of us.
궁궂궃궄궅궆궇권궈궉궊궋 Wednesday, May 13, 2026 | 꾷꾸꾹꾬꾺 4:00–6:30 p.m. 궼궾궽 San Francisco City Hall
蘪蘫蘮蘬蘭 Early bird tickets available now through April 29! This year's awards recognize exceptional public servants who have strengthened San Francisco's transit infrastructure, safeguarded essential services, and led the City and County to achieve national distinction in forensic testing.

Announcing the 2026 Good Government Award Honorees:

Charles Drane
Chief Maintenance Officer
San Francisco Municipal Transportation Agency
Dr. Luke Rodda, Ph.D.

Chief Forensic Toxicologist and Director of the Forensic Laboratory Division Office of the Chief Medical Examiner
2 CalFresh Grocery Card Team
Shane Balanon, Rod Finetti, Rose Johns, Cindy Lin, Teresa Young, Cindy Sanchez SF Human Services Agency
SFO AIOC Team
Andrea Caporale, Jacob Ehrenberg, Anthony Nguyen, Nancy Byun Riedel, Ralf Ruckelshausen
San Francisco International Airport
These leaders represent the best of what public service can be — innovative, inclusive, and deeply committed to the people of San Francisco.

SPUR Urban Center, 654 Mission Street, San Francisco, CA 94105-4015 (415) 781-8726 | [email protected]
Change your email preferences

1 From: Gregory Stevens <[email protected]>
Sent: Tuesday, April 14, 2026 12:46 PM
To: Commission; Board of Supervisors (BOS); [email protected]; John-Baptiste, Alicia (MYR); [email protected]; Chen, Chyanne (BOS); Madland, Sarah (REC); [email protected]
Subject: Faith Sides with Crocker Amazon Park residents This Message Is From an External Sender
This message came from outside your organization. Report Suspicious Dear Commissioners,
I write to you out of a deep sense of moral responsibility and love for our shared creation. Crocker Amazon Park is not simply land to be developed, but a living part of our community. It is a place where people, trees, soil, and sky come together in relationship. To care for it is to care for one another.

The proposal to replace natural open space with a fenced-in artificial turf complex, advanced by the San Francisco Recreation and Park Department in partnership with the San Francisco Giants and Charles B.

Johnson, is being framed as a gift. But a true gift is one that is freely desired, life-giving, and rooted in justice. Many neighbors have not asked for this, and experience it instead as a loss.

Our traditions teach us to be stewards, not dominators. Paving over meadows, removing mature trees, and enclosing public land for intensified and restricted use moves us away from that sacred responsibility. It diminishes biodiversity, community access, and the quiet, restorative presence of nature that so many rely on.

Artificial turf raises additional ethical concerns. It brings increased heat, higher injury risks, and exposure to harmful substances such as PFAS and microplastics. It is especially troubling that these installations are often concentrated in communities already burdened by environmental injustice. We must ask ourselves: who bears the cost of these decisions, and who benefits? I support caring for and investing in Crocker Amazon Park. But we must do so in a way that honors both people and the Earth:

Yes to meaningful community input, where all voices are heard with dignity.

Yes to natural grass, open green space, and the preservation of mature trees.

Yes to a park that welcomes seniors, families, cricket players, dog walkers, and youth alike.

No to expanding artificial turf and the harms it brings.

No to increased traffic, noise, and intrusive lighting that disrupts community life.

No to privatization or fencing that limits access to what should remain a commons.

No to the unnecessary removal of the trees that have long stood as witnesses to this community.

In this moment, you are called not only to make a policy decision, but to exercise moral leadership. I urge you to choose the path of care, justice, and right relationship with the land and with one another. 2 Please protect this beloved park, and invest in a future that reflects our highest values.

Sincerely,
__
Rev. Gregory Stevens (they/he)
California Interfaith Power & Light
Northern California Director
(650) 313-3998

1 From: Barbara Bagot-López <[email protected]>
Sent: Tuesday, April 14, 2026 1:15 PM
To: [email protected]; Madland, Sarah (REC)
Cc: Fielder, Jackie (BOS); Chen, Chyanne (BOS); [email protected]; Commission; John- Baptiste, Alicia (MYR)
Subject: Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation--and to the illegal "gift"
This Message Is From an External Sender
This message came from outside your organization. Report Suspicious Hello.

If the RecPark Commission accepts the $28 million "gift", it is making construction commitments that illegally predetermine the outcome of the meetings, reviews and approvals--and compromising the integrity of both the Department and the Commission.

More artificial turf is not a "gift" to the neighbors-- nor to the children who play sports there. It is a health and environmental hazard.

I strongly support renovating Crocker Amazon Park--the right way:
 Yes to meaningful community input.
 Yes to natural grass fields and open green space.
 Yes to preserving mature trees and the park's character.  Yes to space for seniors, families, cricket players, dog walkers, and youth sports alike.  No to expanding toxic artificial turf.
 No to increased traffic, noise, and late-nightly bright field lighting.  No to privatization and fencing that limits access.
 No to cutting down the majority of existing trees.

Sincerely,
Barbara Bagot-López
1 From: Francisco Da Costa <[email protected]>
Sent: Wednesday, April 15, 2026 6:47 AM
To: Francisco Da Costa
Subject: This video was recorded before we met SF Inspector General.

This Message Is From an External Sender
This message came from outside your organization. Report Suspicious We are all on the right track.

I was at the SFPUC meet yesterday April, 4, 2026. That video has not been posted yet - it will be later today or tomorrow.

As and when the video dated April 4, 2026, is posted, I will send it to our team.

In the meantime, enjoy the video - posted before we met the SF General Inspector - who saw our presentation - and has yet to adjudicate - even though she promised us to look into the matter:
https://sanfrancisco.granicus.com/player/clip/52065?view_id=22&redirect=true We meet today, April 15, 2026, at 11 am at 150 Executive Park - Room 1300 - San Francisco - CA 94134.

Francisco Da Costa
Director
Environmental Justice Advocacy
1 From: Francisco Da Costa <[email protected]>
Sent: Wednesday, April 15, 2026 8:41 AM
To: Francisco Da Costa
Subject: Here is the SFPUC meeting - post today - that took place April 4, 2026.

This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Check this out:
https://sanfrancisco.granicus.com/player/clip/52186?view_id=22&redirect=true Here is the video that just got posted - please review it - my comments during Public Comment.

Francisco Da Costa
Director
Environmental Justice Advocacy
1 From: Stephen Cosbey <[email protected]>
Sent: Wednesday, April 15, 2026 8:27 PM
To: [email protected]; [email protected]; Board of Supervisors (BOS); Commission Subject: Opposition to Artificial Turf for Crocker Amazon Ball Field and Proposed Renovation This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Dear All,
I am writing to urge you to protect Crocker Amazon Park from a proposal that would replace its natural open space with a fenced-in artificial turf sports complex.

The plan proposed by the San Francisco Recreation and Park Department in partnership with the San Francisco Giants and team owner/Trump donor Charles B. Johnson is being framed as a "gift." However, many neighbors did not ask for this project and do not support paving over meadows, cutting down mature trees, and fencing off large portions of a beloved community park.

Privatization of a "Public Park" removes the "Public" from Public Park. WHAT ARE YOU THINKING?
Artificial turf also raises serious concerns. Synthetic fields are associated with higher surface temperatures, increased injury rates compared to well- maintained natural grass, and exposure to toxins like PFAS and microplastics.

It's particularly troubling that the majority of artificial turf installations have been clustered in neighborhoods already burdened by asthma and environmental justice challenges.

I strongly support renovating Crocker Amazon Park, but doing so the right way:
- Yes to meaningful community input.
- Yes to natural grass fields and open green space.
- Yes to preserving mature trees and the park's character. - Yes to space for seniors, families, cricket players, dog walkers, and youth sports alike.
- No to expanding toxic artificial turf.
2 - No to increased traffic, noise, and late-nightly bright field lighting. - No to privatization and fencing that limits access.
- No to cutting down the majority of existing trees.

Please stand with neighborhood residents and protect this city treasure. Invest in improvements that enhance public health, environmental justice, and shared access, not in plastic infrastructure that narrows and intensifies use.

Sincerely,
Stephen H Cosbey
Alligator Plumbing
San Francisco, CA

1 From: Beth rubenstein <[email protected]>
Sent: Wednesday, April 15, 2026 9:41 AM
To: [email protected]; Madland, Sarah (REC); Chen, Chyanne (BOS); [email protected]; John-Baptiste, Alicia (MYR); [email protected]; Board of Supervisors (BOS); Commission
Subject: Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious Dear Commissioners,
I'm writing to urge you to revise and substantially improve the proposed renovation plan for Crocker Amazon Park.

Crocker Amazon is a city treasure, enjoyed by generations of San Franciscans.

Please do not allow the San Francisco Recreation and Park Department to cut down over 100 mature trees and convert natural grass meadows into a fenced-in, 20-acre artificial turf baseball complex. Artificial turf is petroleum- based, sheds microplastics, and has been associated with higher rates of ACL and Achilles injuries compared to well-maintained natural grass. Converting this shared, multi-generational and multi-ethnic public space into a specialized facility serving a narrow user group would fundamentally change the character of the park and limit access for many current users.

Organically managed natural grass fields do not carry the same environmental justice burdens as plastic turf. Rec & Park has already concentrated approximately 85% of its synthetic turf installations in neighborhoods with the highest asthma rates and a documented history of racial and environmental inequities. As currently proposed, this project would increase that concentration to roughly 90% of the City's total artificial turf acreage in historically disenfranchised communities.

We can and must do better. Investing in high-quality, organically managed natural grass fields, similar to the improvements made at West Sunset Playground, would preserve trees, avoid unnecessary plastic pollution, and maintain a welcoming, multi-use park for residents of all ages.

I ask that you prioritize a renovation plan that protects public health, advances environmental justice, preserves mature trees, and keeps Crocker Amazon a park for everyone, young and old.
2 Sincerely,
Beth
Beth Rubenstein
415-846-4732
1 From: Judith Kirk <[email protected]>
Sent: Wednesday, April 15, 2026 5:21 PM
To: Commission
Subject: Please...

This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious I testified before the Commission yesterday and am asking you to agendize a workshop, incl. NGO presentations, before you vote on June 8th. I feel that this is a priority because of the grossly inflated estimates on population and water needed in future; it will make all the difference if more talking and information sharing can be done.

Thank you,
Judith Kirk
Redwood City
1 From: Estrada Jr, Jesus <[email protected]>
Sent: Wednesday, April 15, 2026 11:06 AM
To: Estrada Jr, Jesus
Subject: Senator Durazo Invites You — Medi-Cal Supporter Activation Call Tomorrow (Thurs, April 16 | 1:30 PM)
This Message Is From an External Sender
This message came from outside your organization. Report Suspicious Hello,
My name is Paco Estrada, and I'm reaching out on behalf of Senator María Elena Durazo's o Ưice.

Senator Durazo is hosting a supporter activation call for us to come together to strategize and build momentum for SB 1422, as well as the broader budget eƯort to fully restore and protect Medi-Cal for all Californians, regardless of immigration status. With the May Revise just around the corner, your support is needed now more than ever to help ensure we can make this happen.

We are energized that the bill has passed the Senate Health Committee with all Democrats voting in support and know the work doesn’t stop there. We know it will take a visible and strong coalition.

Please join us on Thursday, April 16 at 1:30 PM at this link: [https://health-access- org.zoom.us/j/81680273083?pwd=makfUWQ4uuBoomnLH5XtubbkAG0Waq.1] We hope to see you there and join us for this important conversation! Best,
Jesus “Paco” Estrada
LegislaƟve Assistant
Senator Maria Elena Durazo
26th Senate District
1021 O Street, Suite 7530
Sacramento, CA 95814
(p) 916-651-4026
Stay Connected with Senator Durazo

1 From: [email protected]
Sent: Thursday, April 16, 2026 1:53 AM
To: ChenStaff
Cc: [email protected]; SherrillStaff; SauterStaff; WongStaff (BOS); MahmoodStaff; DorseyStaff (BOS); MelgarStaff (BOS); MandelmanStaff (BOS); FielderStaff; Waltonstaff (BOS); ChanStaff (BOS); [email protected]; [email protected]; [email protected]; [email protected]; Herrera, David; Commission; John-Baptiste, Alicia (MYR); Madland, Sarah (REC)
Subject: Re: Crocker Amazon Baseball Diamond Project
This Message Is From an External Sender
This message came from outside your organization. Report Suspicious Dear Supervisor Chen:

As the elected representative for the Crocker Amazon Neighborhood, you are the public servant entrusted with preserving and protecting Crocker Amazon Park as the public neighborhood park for the recreational benefit of all the residents of the Crocker Amazon Neighborhood. I am a lifelong Crocker Amazon resident who lives one block from Crocker Amazon Park, and attended Guadalupe Elementary, Denman Junior High, Balboa High and City College, as well as having voted in every single election since I was eighteen years old.

There are already more than plenty of sports facilities (such as for baseball, tennis, basketball, soccer and skateboarding) available for those Crocker Amazon Neighborhood residents who participate in sports. The balance of space in Crocker Amazon Park needs to remain available to meet the multitude of diverse recreational needs of the other extremely diverse Crocker Amazon Neighborhood residents WHO DO NOT PARTICIPATE IN SPORTS.

We, the residents, have a right for that remaining space to be natural—the hundred-years-old trees, meadows and fields with real grass, open and unfenced, that we may renew and refresh, each of us pursuing our own recreational needs in our own ways. For example, I bird watch in the park. What a thrill it was to me watching a great blue heron stalking around the field between the soccer fields and the children’s playground, looking for gophers for breakfast. With your plan, there won’t be any herons or other birds at all. There won't even be gophers. I have a right to hear birds call, sit on real green grass, and breathe the clean air produced by plants. 2 My point is simply that Crocker Amazon Park is a PUBLIC PARK that belongs to we, the residents of the Crocker Amazon Neighborhood, for our recreational needs. You have a fiduciary duty to defend and assert our right to this park. As such, I am demanding that at the next Board of Supervisors meeting, you introduce a motion to immediately halt the Crocker Amazon Baseball Diamond Renovation Project, and initiate a thorough investigation into it, from inception to date, and then release a report to inform us of exactly everything (public and in secret) that has taken place and is going on, and exactly who is behind this attempted illegal land grab and theft of public property, what their motivations are, what regulations and procedures have not been followed, why there is such an intense effort to ram this through and avoid transparency, who will actually benefit from this project, etc. As part of the investigation, I demand that members of the group, “Keep Crocker Real”, who represent the best interests of the residents of the Crocker Amazon Neighborhood in regards to this project, have time to present their research and findings to the Board of Supervisors. Please remember that it is San Francisco citizens and taxpayers who are “The Boss”. All who are employed by the City work for and are paid by the citizens. We citizens demand much more involvement in this decision.

The Crocker Amazon Neighborhood residents and general public must be informed about every aspect of what is going on, because the appearance is, to paraphrase Hamlet, that “Something is rotten in the San Francisco Park and Recreation Department.”

Sincerely,

Your Constituent,

Valerie Howard

1 From: catherine dodd <[email protected]>
Sent: Thursday, April 16, 2026 11:05 AM
To: Commission, Recpark (REC); Chen, Chyanne (BOS); [email protected]; John- Baptiste, Alicia (MYR); Board of Supervisors (BOS); Madland, Sarah (REC); Commission; [email protected]; MandelmanStaff (BOS)
Subject: Crocker Amazon rennovation, artificial turf and tree removal Attachments: April 16. rec and park hearingdocx.docx
This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious please find attached letter opposing tree removal and installation of dangerous artificial turf. There are affordable natural grass GOFER free turf fields that are safer for kids and the environment.

May we all be well,
Catherine Dodd PhD RN Public Health Nurse
SF resident since 1977
Environmental Health Expert
Catherine Dodd PhD RN PHN
963 Duncan Street
San Francisco, CA 94131

April 16, 2026
Recreation & Parks Commission [email protected] SFRPD Interim General Manager Sarah Madland [email protected] District 11 Supervisor Chyanne Chen [email protected] Mayor Dan Lurie [email protected]
Chief of Infrastructure, Climate and Mobility Alicia Jean-Baptiste [email protected] Giants Foundation Liaison for Crocker Amazon [email protected] Board of Supervisors [email protected]
SF Public Utilities Commission [email protected]
Subject: Item 9 -Crocker Amazon Park
Opposition to Artificial Turf for Crocker Amazon Ball Field Renovation To: [email protected]
Cc: [email protected], [email protected], [email protected]

Dear Commissioners,
I'm writing to urge you to revise and substantially improve the proposed renovation plan for Crocker Amazon Park.

Your decision will long outlive you. It will damage the park for generations. The environment of our parks cannot be remediated from the damage proposed in this renovation. Removal of carbon sequestering trees, and the replacement of natural grass turf with plastic blades and backing will damage the park AND the surrounding environment for decades.

Rushing this proposal through is NOT a transparent process. It fails to meet the test of the Precautionary Principle which is City Policy. The Precautionary Principle requires not using something until it has been proven safe. Plastic grass (aka artificial turf) contains known chemicals that cause cancer and reproductive harm. Infill made of natural cork and sand infill both require glue polymers that have never been evaluated for human (or environmental) as they break down. Cork and sand glued together are not “natural products.” Would you use products in your home that you did not know were safe? Would you eat or drink food or beverages if you did not know what was in them and what the long-term effects would be?
In this case we know many of the short term and long term effects and you have been warned and are still going forward. We know that plastic grass AKA artificial turf is NOT recyclable (contrary to the Rec & Park report – there is no where in the US that recycles plastic grass).

If at some point plastic grass becomes recyclable, It becomes a type of fuel – advanced recycling produces many many air pollutants and tons of micro plastics that are known carcinogens and cause reproductive harm. Meanwhile you are agreeing to add tons of plastic to the waste stream every 8 years (more often if hours of use are more than 8 per day). 2 Plastic turf degrades from the day it is rolled onto the truck for transport. When it is played on, cleaned regularly washed (with POTABLE water) it degrades – the “cushioning” infill degrades leading to more injuries, and micro plastics and nano plastics are produced by the ton which pollute not only the surrounding environment but which children inhale, ingest, and absorb.

Microplastics accumulate in organs and more peer reviewed articles have been published each week about the dangers of micro and nano plastics.

San Francisco was the first city to ban plastic straws! But did you know that 1 field of plastic gras = 46 million plastic straws, 3.2 million plastic bags, 2 million plastic bottles? Multiply these numbers by 10 if synthetic infill is used.

Decreasing the demand for plastic, a fossil fuel (petrochemical) product, helps prevent climate change and keeps dangerous chemicals and micro and nano plastics out of the waste stream, out of the aquatic environment and out of our bodies.

The contribution to climate change during production is immeasurable. Plastics “off gas” during their entire life. Once Plastic grass arrives and installed it off-gasses above and near the playing field, off gassing increases during warm weather. One of the major chemicals that is off- gassed is METHANE a potent greenhouse gas. polyethylene is the plastic type that releases methane (CH4), ethylene (C2H4), ethane and propylene at the highest concentrations. Bad news, polyethylene is also the most prevalent plastic produced.

As plastic degrades, the surface area of the plastic increases. Hence, there is more surface to react with the sunlight and a tremendous increase in concentrations of methane and also ethylene, another greenhouse gas. This means that with time for the plastic grass field, more and more greenhouse gases will be produced as the plastic grass degrades and its surface area increases.

Synthetic turf has a huge surface area because of all the small pieces it is made out of, hence the amount of greenhouse gases emitted from synthetic is much higher than a flat sheet of polyethylene, all this surface area also degrades at a highest rate. Synthetic turf is on land and exposed to air directly and therefore responsible for a greater amount of greenhouse gases emitted to the atmosphere.

As recently as 2024,
The California Department of Toxic Substances Control (DTSC) has identified artificial turf as a source of Candidate Chemicals of Concern, including PFAS ("forever chemicals"), phthalates, U V stabilizers, and antioxidants. These chemicals are associated with various health and environ mental hazards, such as respiratory toxicity, endocrine toxicity, developmental and reproductive toxicity, immunotoxicity, environmental persistence, and bioaccumulation.

The report also points out that Senate Bill 676 of 2023 (ch. 498, stats. 2023) specifies that the installation of synthetic grass or artificial turf is no longer included in the definition of drought-tolerant landscaping, once again allowing municipalities and counties to restrict the use of the product.

This will NOT save water, in fact, it requires potable not recycled water to clean. 3 From a health perspective, I cannot underscore the dangers of plastic and infill chemical exposure. Plastic grass requires PFAS (non stick) chemicals in the manufacturing process to keep the blades from sticking together. There are over 15,000 PFAS chemicals known as forever chemicals because they bio accumulate in our bodies and take forever to biodegrade in the environment. PFAS are endocrine disrupting chemicals EDCs which affect our hormones associated with puberty, reproductive development, breast and liver cancer and organ development. PFAS slows metabolism and has explained why people regain weight after losing it. Other key chemicals in plastics include phthalates used to soften plastic, these are EDCs are associated with thyroid abnormalities, brain development and lower IQ. Pthalates change the gene expression related to how the body responds to lipid and carbohydrate loads in the body and is associated with weight gain, pediatric obesity, and heart disease. In little boys, phthalates change the development of genitals and eventually decreased sperm production. In girls they are linked to early breast cancer. Another class of plastic chemicals are Bisphenols used to produce polymers and resins, which are then used to make plastic materials, they are polymers and plastic materials. They are known for making fat cells bigger – they are a synthetic estrogen linked to endocrine related cancers.

Please keep this part of your mission as a guidepost. The San Francisco Recreation and Park Department’s Mission is to provide enriching recreational activities, maintain beautiful parks and preserve the environment for the well-being of everyone in our diverse community.

All our children in every neighborhood deserve to play in healthy environments. Our tax dollars should not be spent on products that endanger the health and well-being of park users and of the environment.

Your decision has implications for generations please base it on science this is not a solution for the “unmet need” for recreation spaces. Do not approve this renovation without a full EIR.

Sincerely,

Health Policy Advisor Families Advocating for Chemical and Toxics Safety FACTS Member, Alliance of Nurses for Healthy Environments
Former Region IX USDHHS Director, Former Deputy Chief of StaƯ for Health and Human Services to Mayor Newsom,
Former District Director Speaker Emeritus Nancy Pelosi
Former Director Women’s Health SFGH
Former Maternal Child Health Advisory Board Member

1 From: Barklee Sanders <[email protected]>
Sent: Thursday, April 16, 2026 4:25 PM
To: Commission
Cc: [email protected]; [email protected] Subject: Public Comment — Draft 2025 UWMP — Request to Revise Design Drought Basis Before Adoption
This Message Is From an External Sender
This message came from outside your organization. Report Suspicious Barklee Sanders
San Francisco, CA
[email protected]
April 16, 2026
President Josh Arce and Commissioners
San Francisco Public Utilities Commission
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
[email protected]
**Re: Public Comment on the Draft 2025 Urban Water Management Plan — Request to Revise the Design Drought Framework and Associated Capital Plan Before Adoption** Dear President Arce and Commissioners,
I am writing as a San Francisco ratepayer to support and extend the April 6 and April 13, 2026 letters submitted by Peter Drekmeier of the Yosemite Rivers Alliance, and to formally request specific corrections to the Draft 2025 UWMP before it is adopted on or before June 30, 2026.

I have independently verified the numerical claims in both YRA letters against their primary sources: the Raker Act of 1913 (§9(b) and §9(c)), the SFPUC Long-Term Vulnerability Assessment (LTVA) Phase I Report (Table 5-1 p.157 and page 147), the Draft 2025 UWMP Table 8-3, and standard USGS unit conversions. Of thirteen numerical claims tested, ten verified exactly against primary sources, two qualified with disclosure of method (not error), and one was unverifiable only because it requires access to the author's raw daily-flow dataset. **Zero claims failed.** A full verification table is available on request.

In the course of that verification I identified one additional supporting fact the YRA letters did not cite, which I bring to your attention below.
---
2 ## I. The LTVA admits its own model overstates SFPUC's drought-era water supply by ~37%

On page 156 of the LTVA Phase I Report, the authors state:

> "the flow computed at the Tuolumne River at La Grange is overestimated, and therefore San Francisco's allocation is also overestimated by about 482,000 acre-feet during the drought sequence 1987-1992 (observed is 813,000 acre-feet versus simulated is 1,295,000 acre-feet). This volume of water is significant and is about equal to the volume of rationing that was required by customers during the six- year period, and so overstating the RWS water supply reliability."

The ratio 813 / 1,295 = **0.628**. SFPUC's own consultant has disclosed that the PRMS hydrologic model used to generate every water-availability projection in the LTVA overestimates dry-year streamflow at La Grange by ~59%. The Design Drought numbers driving UWMP Table 8-3 and the Alternative Water Supply (AWS) program are therefore already biased in SFPUC's favor — and even so they yield the extreme rationing percentages ratepayers are being asked to accept as inevitable.

No UWMP scenario currently applies a correction factor for this model bias. That alone is grounds to delay adoption of Table 8-3 as presently drafted.

---

## II. Ten specific corrections requested before UWMP adoption

### 1. Retire the 8-year Design Drought as the planning baseline

The Design Drought is a synthetic 8-year composite (1987-92 + 1976-77) with a return period of 7,831 years (using the LTVA's own scaling method on the December 8, 2020 consultant slide obtained by YRA via Public Records Act) to approximately 70,000 years (reading LTVA Figure 5-11 directly). Neither Valley Water nor EBMUD plan for a drought of this severity. Water Code §10631(b)(1) and the DWR 2025 UWMP Guidebook require "droughts lasting at least five years" — a standard the SFPUC has operationally replaced with eight.

**Request:** Adopt the 1987-92 drought of record (420-year return period per LTVA Table 5-1) as the UWMP planning basis. Retain the Design Drought as a labeled stress-test scenario only, explicitly flagged as <1-in-8,000-year, and remove it from the basis of demand, CIP, and rationing-trigger calculations.

### 2. Apply a model-bias correction factor of 0.63 to PRMS dry-year outputs

**Request:** Publish an appendix applying a 0.63 multiplier (observed/simulated ratio from LTVA's own 1987-92 disclosure) to all PRMS dry-year water-availability projections used in the UWMP. If staff believe a different correction is warranted, disclose the basis.

### 3. Rewrite Table 8-3 in YRA Table YRA-3 format

YRA Table YRA-3 demonstrates that with 10% rationing in Years 3–4 and 20% in Years 5–6, SFPUC meets 100% of 2050 demand through the drought of record with the Bay-Delta Plan in effect, and ends Year 6 with 98 TAF in storage. This replaces Table 8-3's implied 57% rationing with a realistic 10–20% rationing ladder and a storage column the public can audit.
3 **Request:** Reissue Table 8-3 to include end-of-year storage (TAF) and a storage-visible rationing ladder consistent with YRA-3 for the drought-of-record scenario.

### 4. Follow the DWR 2025 UWMP Guidebook five-year standard literally

**Request:** Publish the "five consecutive dry year" analysis using the actual driest 5-year observed sequence (1987-92 core), not years 2–6 of the Design Drought composite. YRA Table YRA-2 shows the system meets 100% of 2050 demand with no rationing and 217 TAF in storage at end of Year 5 under this standard.

### 5. Correct the 2050 demand projection to trend

Current 2050 demand projection of 215.1 mgd implies a 12.6% increase over FY24–25 actual demand of 191 mgd, against a 20-year trend of declining per-capita use. As SFPUC is a fixed-cost utility, overstating future demand forces rate increases when demand does not materialize — the dynamic producing the

7.4% FY26 wholesale rate preview.

**Request:** Revise the 2050 baseline demand projection to no more than 200 mgd (=224 TAF/yr) and publish the per-capita and population assumptions underlying whatever value is adopted.

### 6. Adopt storage-triggered rationing

**Request:** Replace year-count rationing (triggered by position in a modeled drought sequence) with storage-triggered rationing (triggered by actual end-of-year reservoir storage). A reasonable ladder:

- Total SFPUC storage > 1,200 TAF: 100% delivery
- 900–1,200 TAF: voluntary 10% reduction
- 600–900 TAF: mandatory 10% rationing
- 400–600 TAF: 20% rationing
- 250–400 TAF: 25% rationing
- < 250 TAF: 35%+ emergency

This aligns SFPUC with peer California agencies and prevents 2022-style drought surcharges when reservoirs held 4.5 years of supply.

### 7. Right-size the Alternative Water Supply (AWS) Program and 30-year CIP

The February 11, 2026 BAWSCA Board Policy Committee notes disclosed approximately $10.1 billion of projected SFPUC capital improvement projects over 30 years beyond the 10-year CIP. For comparison, the Water System Improvement Program (WSIP) was $4.8 billion, and WSIP debt service is cited by SFPUC as the principal driver of the quadrupling of water rates over the past two decades. A $10.1 billion supplemental capital program, if validated, portends another generational rate increase.

**Request:** Publish the AWS portfolio in priority tiers indicating which projects are justified under the drought-of-record planning basis vs. the Design Drought. Cancel or defer projects whose justification depends on the Design Drought. A proposed envelope of $3–4 billion over 30 years is consistent with seismic resilience, demand management, water purification (PureWater Marin, Crystal Springs), and 4 groundwater recharge — while deferring speculative desalination and new-dam participation.

### 8. Publish the climate-timing upside

LTVA page 147 is explicit: +2°C warming by 2040 will advance spring runoff by approximately 10 days, and +4°C by 2070 will advance it by approximately 20 days. Under Raker Act §9(b) and §9(c), earlier runoff crosses the 2,350 cfs Modesto/Turlock Irrigation District threshold *before* April 15, rather than the higher 4,000 cfs threshold that applies during April 15 – June 13. YRA's analysis estimates this shift yields approximately +237 TAF of additional Water Available to the City (WAC) over a repeat 8-year Design Drought cycle — more than a full year of current SFPUC demand.

**Request:** Model and publish this climate-timing upside in the UWMP alongside downside scenarios.

A climate-risk disclosure that quantifies only the downside is incomplete.

### 9. Report the Bay-Delta Plan case in three tiers

**Request:** Rather than a single worst-case Bay-Delta Plan scenario, publish three tiers — (a) best- available mitigation; (b) literal Bay-Delta Plan compliance under drought-of-record (YRA-3 style); (c) legacy SFPUC scenario with Design Drought + full Bay-Delta Plan as stress test only. Peer-reviewed analysis in *Environmental Science & Technology* (2024, "Water Supply Planning in the Face of Drought and Ecosystem Flows") finds Bay-Delta Plan shortfalls materially smaller than SFPUC's published figures and should be cited in the analysis.

### 10. Standard transparency template for every scenario

**Request:** Adopt a one-page standard disclosure template applied to every supply/demand scenario in the UWMP, showing: starting storage, ending storage each year, rationing assumed, rationing trigger logic, drought return period, model bias correction applied, Raker Act timing assumption, and demand- projection basis. Commissioners and ratepayers cannot govern what they cannot compare.

---

## III. The single action that delivers most of the benefit

If the Commission can adopt only one correction before the July 1 deadline, I respectfully request it be this: **formally adopt the 1987-92 drought of record as the UWMP planning basis, direct staff to apply the 0.63 PRMS bias correction, and reissue Table 8-3 in storage-visible format consistent with YRA Table YRA-3.**

This single resolution would reset demand projections, shrink the CIP target, and end the rate-trajectory that produces 7.4% annual increases — without under-planning. SFPUC would retain every WSIP investment, all of its 1,517 TAF of storage capacity, and full flexibility to stress-test the Design Drought as a resilience exercise.

---

## IV. The stakes

5 Ratepayers across the Regional Water System are absorbing a 7.4% FY26 wholesale increase, on top of two decades of compounding increases tied to WSIP debt service. A $10.1 billion supplemental CIP, if adopted on the current Design Drought basis, would compound those increases for another generation.

The environmental cost — most acutely to the Tuolumne River salmon run, which has the steepest decline of any major Central Valley salmon population — is already the subject of a formal Unreasonable Use of Water complaint filed by the Tuolumne River Trust with the State Water Resources Control Board in April 2025.

The corrections requested above are not calls to under-plan. They are calls to plan on the basis of the most severe drought California has actually experienced, and to disclose the uncertainty and the upside alongside the risk.

---

## V. Specific requests for action

1. Hold a public workshop on the Design Drought before UWMP adoption, per YRA's April 6 request

2. Direct staff to respond in writing to the YRA analysis and this public comment on the points enumerated above, before the public hearing closes

3. Direct staff to publish the PRMS model bias correction methodology or disclose why it will not be applied

4. Defer final adoption of Table 8-3 until revised in storage-visible format

5. Disclose the $10.1 billion 30-year CIP in full, with project-level justification tied to the adopted planning basis

Thank you for your consideration, and thank you for your service to the ratepayers and ecosystems of the Bay Area.

Sincerely,

Barklee Sanders
San Francisco, CA
[email protected]

---

**Attachments and references (available on request):**
- Independent verification report (13 claims tested against primary sources) - Primary source citations: Raker Act §9(b)(c); LTVA Phase I Report (Table 5-1, pp. 147, 156, 157); Draft 2025 UWMP Table 8-3; USGS unit conversion standard; BAWSCA Feb 11 & Feb 19, 2026 committee materials; ES&T 2024 Bay-Delta Plan modeling; TRT Unreasonable Use Complaint (April 2025) - YRA letters dated April 6, 2026 and April 13, 2026

**cc:**
- BAWSCA Board of Directors
- SFPUC Citizens Advisory Committee
- Peter Drekmeier, Yosemite Rivers Alliance
- Tuolumne River Trust
1 From: Barklee Sanders <[email protected]>
Sent: Thursday, April 16, 2026 4:27 PM
To: Commission
Cc: [email protected]; [email protected] Subject: Re: Public Comment — Draft 2025 UWMP — Request to Revise Design Drought Basis Before Adoption
Attachments: The Fix — What SFPUC's Plan Should Actually Be · April 16, 2026.pdf This Message Is From an External Sender
This message came from outside your organization. Report Suspicious See attached pdf also!
Barklee Sanders
Technology Consultant
More about me: barkleesanders.com
Schedule a meeting: https://cal.com/barkleesanders
On Thu, Apr 16, 2026 at 4:24 PM Barklee Sanders <[email protected]> wrote:

Barklee Sanders
San Francisco, CA
[email protected]
April 16, 2026
President Josh Arce and Commissioners
San Francisco Public Utilities Commission
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
[email protected]
**Re: Public Comment on the Draft 2025 Urban Water Management Plan — Request to Revise the Design Drought Framework and Associated Capital Plan Before Adoption** Dear President Arce and Commissioners,
I am writing as a San Francisco ratepayer to support and extend the April 6 and April 13, 2026 letters submitted by Peter Drekmeier of the Yosemite Rivers Alliance, and to formally request specific corrections to the Draft 2025 UWMP before it is adopted on or before June 30, 2026.

I have independently verified the numerical claims in both YRA letters against their primary sources: the Raker Act of 1913 (§9(b) and §9(c)), the SFPUC Long-Term Vulnerability Assessment (LTVA) Phase I Report (Table 5-1 p.157 and page 147), the Draft 2025 UWMP Table 8-3, and standard USGS unit 2 conversions. Of thirteen numerical claims tested, ten verified exactly against primary sources, two qualified with disclosure of method (not error), and one was unverifiable only because it requires access to the author's raw daily-flow dataset. **Zero claims failed.** A full verification table is available on request.

In the course of that verification I identified one additional supporting fact the YRA letters did not cite, which I bring to your attention below.

---

## I. The LTVA admits its own model overstates SFPUC's drought-era water supply by ~37%

On page 156 of the LTVA Phase I Report, the authors state:

> "the flow computed at the Tuolumne River at La Grange is overestimated, and therefore San Francisco's allocation is also overestimated by about 482,000 acre-feet during the drought sequence 1987-1992 (observed is 813,000 acre-feet versus simulated is 1,295,000 acre-feet). This volume of water is significant and is about equal to the volume of rationing that was required by customers during the six-year period, and so overstating the RWS water supply reliability."

The ratio 813 / 1,295 = **0.628**. SFPUC's own consultant has disclosed that the PRMS hydrologic model used to generate every water-availability projection in the LTVA overestimates dry-year streamflow at La Grange by ~59%. The Design Drought numbers driving UWMP Table 8-3 and the Alternative Water Supply (AWS) program are therefore already biased in SFPUC's favor — and even so they yield the extreme rationing percentages ratepayers are being asked to accept as inevitable.

No UWMP scenario currently applies a correction factor for this model bias. That alone is grounds to delay adoption of Table 8-3 as presently drafted.

---

## II. Ten specific corrections requested before UWMP adoption

### 1. Retire the 8-year Design Drought as the planning baseline

The Design Drought is a synthetic 8-year composite (1987-92 + 1976-77) with a return period of 7,831 years (using the LTVA's own scaling method on the December 8, 2020 consultant slide obtained by YRA via Public Records Act) to approximately 70,000 years (reading LTVA Figure 5-11 directly). Neither Valley Water nor EBMUD plan for a drought of this severity. Water Code §10631(b)(1) and the DWR 2025 UWMP Guidebook require "droughts lasting at least five years" — a standard the SFPUC has operationally replaced with eight.

**Request:** Adopt the 1987-92 drought of record (420-year return period per LTVA Table 5-1) as the UWMP planning basis. Retain the Design Drought as a labeled stress-test scenario only, explicitly flagged as <1-in-8,000-year, and remove it from the basis of demand, CIP, and rationing-trigger calculations.

### 2. Apply a model-bias correction factor of 0.63 to PRMS dry-year outputs 3 **Request:** Publish an appendix applying a 0.63 multiplier (observed/simulated ratio from LTVA's own 1987-92 disclosure) to all PRMS dry-year water-availability projections used in the UWMP. If staff believe a different correction is warranted, disclose the basis.

### 3. Rewrite Table 8-3 in YRA Table YRA-3 format

YRA Table YRA-3 demonstrates that with 10% rationing in Years 3–4 and 20% in Years 5–6, SFPUC meets 100% of 2050 demand through the drought of record with the Bay-Delta Plan in effect, and ends Year 6 with 98 TAF in storage. This replaces Table 8-3's implied 57% rationing with a realistic 10–20% rationing ladder and a storage column the public can audit.

**Request:** Reissue Table 8-3 to include end-of-year storage (TAF) and a storage-visible rationing ladder consistent with YRA-3 for the drought-of-record scenario.

### 4. Follow the DWR 2025 UWMP Guidebook five-year standard literally

**Request:** Publish the "five consecutive dry year" analysis using the actual driest 5-year observed sequence (1987-92 core), not years 2–6 of the Design Drought composite. YRA Table YRA-2 shows the system meets 100% of 2050 demand with no rationing and 217 TAF in storage at end of Year 5 under this standard.

### 5. Correct the 2050 demand projection to trend

Current 2050 demand projection of 215.1 mgd implies a 12.6% increase over FY24–25 actual demand of 191 mgd, against a 20-year trend of declining per-capita use. As SFPUC is a fixed-cost utility, overstating future demand forces rate increases when demand does not materialize — the dynamic producing the

7.4% FY26 wholesale rate preview.

**Request:** Revise the 2050 baseline demand projection to no more than 200 mgd (=224 TAF/yr) and publish the per-capita and population assumptions underlying whatever value is adopted.

### 6. Adopt storage-triggered rationing

**Request:** Replace year-count rationing (triggered by position in a modeled drought sequence) with storage-triggered rationing (triggered by actual end-of-year reservoir storage). A reasonable ladder:

- Total SFPUC storage > 1,200 TAF: 100% delivery
- 900–1,200 TAF: voluntary 10% reduction
- 600–900 TAF: mandatory 10% rationing
- 400–600 TAF: 20% rationing
- 250–400 TAF: 25% rationing
- < 250 TAF: 35%+ emergency

This aligns SFPUC with peer California agencies and prevents 2022-style drought surcharges when reservoirs held 4.5 years of supply.

### 7. Right-size the Alternative Water Supply (AWS) Program and 30-year CIP 4 The February 11, 2026 BAWSCA Board Policy Committee notes disclosed approximately $10.1 billion of projected SFPUC capital improvement projects over 30 years beyond the 10-year CIP. For comparison, the Water System Improvement Program (WSIP) was $4.8 billion, and WSIP debt service is cited by SFPUC as the principal driver of the quadrupling of water rates over the past two decades. A $10.1 billion supplemental capital program, if validated, portends another generational rate increase.

**Request:** Publish the AWS portfolio in priority tiers indicating which projects are justified under the drought-of-record planning basis vs. the Design Drought. Cancel or defer projects whose justification depends on the Design Drought. A proposed envelope of $3–4 billion over 30 years is consistent with seismic resilience, demand management, water purification (PureWater Marin, Crystal Springs), and groundwater recharge — while deferring speculative desalination and new-dam participation.

### 8. Publish the climate-timing upside

LTVA page 147 is explicit: +2°C warming by 2040 will advance spring runoff by approximately 10 days, and +4°C by 2070 will advance it by approximately 20 days. Under Raker Act §9(b) and §9(c), earlier runoff crosses the 2,350 cfs Modesto/Turlock Irrigation District threshold *before* April 15, rather than the higher 4,000 cfs threshold that applies during April 15 – June 13. YRA's analysis estimates this shift yields approximately +237 TAF of additional Water Available to the City (WAC) over a repeat 8-year Design Drought cycle — more than a full year of current SFPUC demand.

**Request:** Model and publish this climate-timing upside in the UWMP alongside downside scenarios.

A climate-risk disclosure that quantifies only the downside is incomplete.

### 9. Report the Bay-Delta Plan case in three tiers

**Request:** Rather than a single worst-case Bay-Delta Plan scenario, publish three tiers — (a) best- available mitigation; (b) literal Bay-Delta Plan compliance under drought-of-record (YRA-3 style); (c) legacy SFPUC scenario with Design Drought + full Bay-Delta Plan as stress test only. Peer-reviewed analysis in *Environmental Science & Technology* (2024, "Water Supply Planning in the Face of Drought and Ecosystem Flows") finds Bay-Delta Plan shortfalls materially smaller than SFPUC's published figures and should be cited in the analysis.

### 10. Standard transparency template for every scenario

**Request:** Adopt a one-page standard disclosure template applied to every supply/demand scenario in the UWMP, showing: starting storage, ending storage each year, rationing assumed, rationing trigger logic, drought return period, model bias correction applied, Raker Act timing assumption, and demand- projection basis. Commissioners and ratepayers cannot govern what they cannot compare.

---

## III. The single action that delivers most of the benefit

If the Commission can adopt only one correction before the July 1 deadline, I respectfully request it be this: **formally adopt the 1987-92 drought of record as the UWMP planning basis, direct staff to apply the 0.63 PRMS bias correction, and reissue Table 8-3 in storage-visible format consistent with YRA Table 5 YRA-3.**

This single resolution would reset demand projections, shrink the CIP target, and end the rate-trajectory that produces 7.4% annual increases — without under-planning. SFPUC would retain every WSIP investment, all of its 1,517 TAF of storage capacity, and full flexibility to stress-test the Design Drought as a resilience exercise.

---

## IV. The stakes

Ratepayers across the Regional Water System are absorbing a 7.4% FY26 wholesale increase, on top of two decades of compounding increases tied to WSIP debt service. A $10.1 billion supplemental CIP, if adopted on the current Design Drought basis, would compound those increases for another generation.

The environmental cost — most acutely to the Tuolumne River salmon run, which has the steepest decline of any major Central Valley salmon population — is already the subject of a formal Unreasonable Use of Water complaint filed by the Tuolumne River Trust with the State Water Resources Control Board in April 2025.

The corrections requested above are not calls to under-plan. They are calls to plan on the basis of the most severe drought California has actually experienced, and to disclose the uncertainty and the upside alongside the risk.

---

## V. Specific requests for action

1. Hold a public workshop on the Design Drought before UWMP adoption, per YRA's April 6 request

2. Direct staff to respond in writing to the YRA analysis and this public comment on the points enumerated above, before the public hearing closes

3. Direct staff to publish the PRMS model bias correction methodology or disclose why it will not be applied

4. Defer final adoption of Table 8-3 until revised in storage-visible format

5. Disclose the $10.1 billion 30-year CIP in full, with project-level justification tied to the adopted planning basis

Thank you for your consideration, and thank you for your service to the ratepayers and ecosystems of the Bay Area.

Sincerely,

Barklee Sanders
San Francisco, CA
[email protected]

---

**Attachments and references (available on request):**
6 - Independent verification report (13 claims tested against primary sources) - Primary source citations: Raker Act §9(b)(c); LTVA Phase I Report (Table 5-1, pp. 147, 156, 157); Draft 2025 UWMP Table 8-3; USGS unit conversion standard; BAWSCA Feb 11 & Feb 19, 2026 committee materials; ES&T 2024 Bay-Delta Plan modeling; TRT Unreasonable Use Complaint (April 2025) - YRA letters dated April 6, 2026 and April 13, 2026

**cc:**
- BAWSCA Board of Directors
- SFPUC Citizens Advisory Committee
- Peter Drekmeier, Yosemite Rivers Alliance
- Tuolumne River Trust
VOL. I · NO. 02 PRESCRIPTION EDITION APRIL 16, 2026
The fix.

What SFPUC's 2025 UWMP should actually be — ten
corrections, concrete numbers, one governance decision.

Grounded in the LTVA's own disclosures and the Raker Act of 1913.

EDITION
Apr 16, 2026

DEADLINE
Apr 20 comment
close

GOVERNING BODY
SFPUC
Commission

ADOPT BY
June 30, 2026
NO. 01 · THE THESIS
01Plan for the worst droughtCalifornia has actually had.Not the worst one the modelcan imagine.

The entire fix turns on one governance decision: adopt the 1987- 92 drought of record — a 420-year return period that Valley Water and EBMUD already use — as the UWMP planning basis.

Retain the Design Drought as a stress test only. Apply the 0.63 model-bias correction the LTVA itself discloses. Publish Table 8- 3 with storage visible. Everything else follows.

P r e s c r i p t i o n · B a r k l e e S a n d e r s · g r o u n d e d i n L T V A T a b l e 5 - 1 · S F P U C D r a f t 2 0 2 5 U W M P NO. 02 · THE NUMBER THAT SHOULD ANCHOR THE PLAN
02 420 years
The LTVA's own return period forthe 1987-92 drought at the 269TAF threshold.

Published in LTVA Table 5-1, page 157 — the same table SFPUC's consultants wrote. This is the planning basis used by Valley Water and EBMUD. It's the standard California water agencies built decades of resilience around. Adopting it as SFPUC's basis requires no new analysis — just a Commission resolution to use the number the LTVA already produced.

SFPUC's current 8-year Design Drought has a return period somewhere between 7,831 years (proportional scaling) and 70,000 years (LTVA Figure 5-11 read directly). That's the

99.98th-percentile event being used as the plan for a utility serving 2.7 million people and 27 wholesale agencies.

S o u r c e · L T V A P h a s e I R e p o r t T a b l e 5 - 1 p .1 5 7 · v e r i f i e d c l a i m # 3 o f 1 3 NO. 03 · MODEL CORRECTION
03 Apply the bias correction theLTVA already admitted to —0.63.

On page 156 of the LTVA, the authors disclose that the PRMS hydrologic model overstates dry-year streamflow at La Grange. For the 1987-92 drought alone, simulated flow was 1,295,000 AF vs. observed 813,000 AF — an overstatement of SFPUC's allocation by 482,000 acre-feet, "about equal to the volume of rationing that was required by customers during the six-year period."
observed / simulated = 813 TAF / 1,295 TAF = 0.628
every PRMS dry-year inflow projection
× 0.63 correction factor
= realistic water availability
applied to Table 8-3:
raw 57% delivery scenario
× (inflow 0.63×, demand 0.93×)
= corrected ≈ 68-75% delivery
= rationing need drops by HALF
= $10.1B AWS plan loses most of its justification.

S o u r c e · L T V A P h a s e I R e p o r t p .1 5 6 · a r i t h m e t i c i n d e p e n d e n t l y v e r i f i e d NO. 04 · TABLE 8-3 · REWRITE
PROPOSED · DRAFT 2025 UWMP · REVISION
04 The table SFPUC publishes vs. the ta-ble SFPUC should publish.

CURRENT TABLE 8-3 (2050, BAY-
DELTA)
Normal ............... 100%
Single Dry Year ...... 68%
Dry Year 1 ........... 68%
Dry Year 2 ........... 57%
Dry Year 3 ........... 57%
Dry Year 4 ........... 57%
Dry Year 5 ........... 57%
(no storage column)
(Design Drought basis)
(no bias correction)
PROPOSED (YRA-3 · DROUGHT OF

RECORD)
Year 1 ... 100% storage 1,048 TAF
Year 2 ... 100% storage 708 TAF
Year 3 ... 90% storage 669 TAF
Year 4 ... 90% storage 383 TAF
Year 5 ... 80% storage 313 TAF
Year 6 ... 80% storage 98 TAF
6-year drought of record
Bay-Delta Plan in effect
Storage column visible
S o u r c e · Y R A T a b l e Y R A - 3 · S F P U C - p r o v i d e d m o d e l d a t a · D W R W a t e r C o d e § 1 0 6 3 1 ( b ) ( 1 ) NO. 05 · RATIONING LADDER
05 Trigger rationing on actualreservoir storage — not on po-sition in a model.

Year-count rationing is why SFPUC imposed a 5% drought surcharge in 2022 while reservoirs held 4.5 years of supply. Every other major California utility triggers conservation based on what is actually in storage. SFPUC should too. Here is the proposed ladder:
> 1,200 TAF 100% delivery · normal operations
900 – 1,200 TAF Voluntary 10% reduction · public messaging 600 – 900 TAF Mandatory 10% rationing
400 – 600 TAF 20% rationing · surcharge activates
250 – 400 TAF 25% rationing · mandatory outdoor restrictions < 250 TAF Emergency · 35%+ · inter-agency transfers
S o u r c e · s t a n d a r d p r a c t i c e ( E B M U D / V a l l e y W a t e r / M W D ) · S F P U C t o t a l s y s t e m c a p a c i t y ≈ 1 , 5 1 7 T A F
No. 06 — Raker Act §9(b) & §9(c), 1913 — The upside SFPUC refuses to book
06 Model the climate upside, not just thedownside.

T
he LTVA is explicit (p. 147): +2°C warming by 2040 will advance spring runoff by approximately 10 days; +4°C by 2070 will advance it by approximately 20 days. The Raker Act, enacted in 1913, requires SFPUC to pass the first 2,350 cfs to the Modesto and Turlock Irrigation Districts year-round, and the first 4,000 cfs during the sixty days beginning April 15. SFPUC's water supply is any flow above those thresholds.

Earlier runoff shifts water across the lower 2,350 cfs threshold, before April 15.

That is a structural gain to San Francisco — not a loss. Dave Warner's 1971– 2012 scatterplot estimates a three-week shift adds approximately +237 TAF of Water Available to the City over a repeat Design Drought cycle, and +217 TAF over 1987-92 alone. More than a full year of current demand. This number belongs in the UWMP.

A climate risk disclosure that reports only downside — higher costs, more rationing, bigger AWS program — while omitting the mechanical upside that the governing 1913 statute produces under precisely the same warming scenarios is not a climate analysis. It is an advocacy document.

S o u r c e · R a k e r A c t § 9 ( b ) ( c ) · L T V A p .1 4 7 · W a r n e r a n a l y s i s · h e t c h h e t c h y . o r g −60%
NO. 07 · CAPITAL PLAN · RIGHT-SIZE
$10.1B → $3–4B
07Keep the projects justified by reality.Defer the ones justified by the Design Drought.

The 30-year supplemental CIP disclosed in the February 11, 2026 BAWSCA Policy Committee minutes is $10.1 billion — more than twice the WSIP that quadrupled rates. Under a drought-of-record planning basis with the 0.63 bias correction applied, the gap those projects were sized to close shrinks by ~60%. Here is the proposed cut list:

PROJECT CATEGORY STATUS RATIONALE
Conservation & efficiency KEEP
100% Cheapest water is water not used.

PureWater Marin / Crystal Springs
purification
KEEP
100% Proven, local, drought-resilient.

Groundwater recharge & banking KEEP
100% Storage diversification.

WSIP seismic completion KEEP
100%
Hayward / San Andreas risk is independent
of drought.

NO. 08 · TRANSPARENCY

PROJECT CATEGORY STATUS RATIONALE
Ocean desalination participation
(~$2B) DEFER Unneeded under drought-of-record
planning.

New Sites Reservoir equity (~$1B) DEFER 1,517 TAF of existing storage suffices.

Speculative new dams / diversions
(~$2B) CANCEL Not justified at 420-yr planning basis.

Non-seismic pipeline duplications
(~$1B) HALF Keep redundancy where real; defer the
rest.

S o u r c e · B A W S C A F e b 1 1 , 2 0 2 6 m i n u t e s · p r o p o s e d a l l o c a t i o n b y B a r k l e e S a n d e r s · p u b l i c c o m m e n t 2 0 2 6 - 0 4 - 1 6
08 Every UWMP scenario mustanswer these eight questionson one page.

Commissioners cannot govern what they cannot compare. Ratepayers cannot challenge what they cannot audit. A standard disclosure template, appended to every supply/demand scenario in the UWMP, removes the informational asymmetry that has let the Design Drought drive three decades of planning without formal adoption.

Starting storage — TAF at simulation start☐
End-of-year storage — TAF for every modeled year, table form☐ Rationing assumed — % and the trigger logic (year-count vs. storage- triggered)
☐
Drought return period — cited against LTVA Table 5-1 or equivalent☐ Model bias correction — PRMS 0.63 factor applied, or explicit justification for not applying
☐
Raker Act timing assumption — baseline runoff vs. climate-shifted earlier runoff
☐
Demand-projection basis — per-capita trend, population, conservation expected
☐
Bay-Delta Plan tier — best-available mitigation / literal compliance / legacy stress test
☐
P r o p o s e d U W M P A p p e n d i x · a p p l i e s t o e v e r y s c e n a r i o i n T a b l e s 7 - x t h r o u g h 8 - x NO. 09 · THE ASK
09ONERESOLUTION.

BEFOREJULY 1.

If the Commission can adopt only one correction before the UWMP deadline, let it be this: formally adopt 1987-92 as the planning basis, direct staff to apply the 0.63 PRMS bias correction, and reissue Table 8-3 in storage-visible YRA-3 format. The other nine fixes follow from this one governance decision.

FILE BY: APRIL 20, 2026 — PUBLIC COMMENT CLOSES
ADOPT BY: JUNE 30, 2026 — COMMISSION VOTE
DUE TO DWR: JULY 1, 2026 — UWMP SUBMISSION
COMMENT TO: [email protected]
R e q u e s t f i l e d A p r i l 1 6 , 2 0 2 6 · B a r k l e e S a n d e r s · S F r a t e p a y e r · c c : B A W S C A B o a r d · S F P U C C A C The math is already done.

Every correction in this edition is grounded in a primary source the SFPUC itself produced, funded, or operates under: the Raker Act of 1913, the Long- Term Vulnerability Assessment of 2022, the Draft 2025 UWMP, and the BAWSCA wholesale financial disclosures. Thirteen claims tested in the companion verification report. Ten verified exactly. Zero failed. The question is not whether the numbers are right — it is whether the Commission will direct staff to use them.

SUBMIT YOUR COMMENT BEFORE APRIL 20
[email protected]
Hearing: April 14, 2026 · Final vote: June 30, 2026 · DWR deadline: July 1, 2026 PRESCRIPTION EDITION · NO. 02 · APR 16 2026 · COMPILED FOR BARKLEE

SANDERS
1 From: Denise Louie <[email protected]>
Sent: Saturday, April 18, 2026 8:40 AM
To: Commission
Cc: Peter Drekmeier
Subject: UWMP and the Bay Delta
Follow Up Flag: Follow up
Flag Status: Completed
This Message Is From an External Sender
This message came from outside your organization. Report Suspicious Hi President Arce and Commissioners,
I strongly urge you to hold an Urban Water Management Plan workshop, as Peter Drekmeier suggested. This will enable you to dive deep into the details. Details matter. Further, I strongly urge you to withdraw the PUC from lawsuits, Voluntary Agreements and obstruction of the 2018 Bay Delta Plan.

PUC staff presentations may sound reasonable, but you need to see the whole picture before you vote on the UWMP. What staff haven't included in their presentations is arguably more important than what has been included. Because understanding what hasn't been included should lead to better informed decisions.

The UWMP is particularly important. Because it can be used to justify an unnecessary and expensive Alternative Water Supply System, as well as continuing obstruction of the 2018 Bay Delta Plan. We knew Delta Smelt (an ecosystem health indicator species) were in trouble decades ago. It took the State Water Resources Control Board a decade to draft and vet the Plan, which represented a compromise for increases to freshwater flows. The PUC's participation in obstruction has led to the extinction of Delta Smelt and the collapse of the Bay Delta ecosystem.

Again, I urge you to withdraw the PUC from lawsuits, Voluntary Agreements and obstruction of the 2018 Bay Delta Plan. Only you can prevent the PUC and SF from being known for pushing the Bay Delta ecosystem into final collapse.

Thanks for your attention to these matters,
Denise Louie
SF 'retail customer'
Member, Center for Biological Diversity
https://www.biologicaldiversity.org/about/
1 From: Francisco Da Costa <[email protected]>
Sent: Sunday, April 19, 2026 7:07 AM
To: Francisco Da Costa
Subject: We believe in fair play and justice - not so the SFPUC - the time has come to bring them to book.

This Message Is From an Untrusted Sender
You have not previously corresponded with this sender. Report Suspicious The time has come to take the SFPUC to task and bring justice and fair play to the many innocent SFPUC employers who have been fired without cause:
https://kilamanjaro-kilamanjaro.blogspot.com/2026/04/san-francisco-public-utlities.html Francisco Da Costa
Director
Environmental Justice Advocacy