CleanPowerSF Sfpuc Commission
June 23, 2026

Code
Section Code Requirement Summary of Action Taken Documentation (Attached after this Table)
Water Code
Section
10642
Prior to adoption, make the plan
available for public inspection.

March 12, 2026: Emailed a notification of the 2025 UWMP public hearing with details on how to watch the hearing and submit public comments to the UWMP contact list
March 16, 2026: Posted the Draft 2025 UWMP on the SFPUC website at www.sfwater.gov/uwmp
March 19, 2026: Provided two hardcopies of the Draft 2025 UWMP to the San Francisco Main Library
April 1, 2026: Sent a reminder email to the UWMP contact list regarding the availability of the Draft 2025 UWMP and the upcoming public hearing
Copy of the 3/12/2026 email (also
sent again on 4/1/2026)
Contact list
Copy of website posting
Water Code
Section
10642
Prior to adoption, hold a public
hearing.

April 14, 2026: Held a public hearing on the Draft 2025 UWMP during a regular meeting of the San Francisco Public Utilities Commission Copy of the Commission Meeting
Agenda on 4/14/2026
Compilation of public comments
received
Water Code
Section
10642
After the hearing, the plan shall be
adopted as prepared or as modified
after the meeting.

June 23, 2026: Adopted the 2025 UWMP (as amended) during a regular meeting of the San Francisco Public Utilities Commission To be inserted in Appendix G: Signed
Resolution to Adopt the 2025 UWMP
Water Code
Section
10644(a)
Within 30 days of plan adoption,
submit a copy to DWR.

By July 1, 2026 (exact date to be determined): Submitted the adopted 2025 UWMP electronically via the WUEdata Online Submittal Tool To be inserted: Copy of DWR
submittal confirmation
Water Code
Section
10644(a)
Within 30 days of plan adoption,
submit a copy to the California State
Library.

By July 14, 2026 (exact date to be determined): Mailed a copy of the adopted 2025 UWMP on compact disc to the California State Library To be inserted: Copy of delivery
confirmation to the California State
Library
Water Code
Section
10644(a)
Within 30 days of plan adoption,
submit a copy to any city or county
within which the supplier provides
water.

By July 14, 2026 (exact date to be determined): Emailed the adopted 2025 UWMP to all cities or counties within which the SFPUC provides water, including wholesale customers of the Regional Water System To be inserted: Copy of the 7/14/26
email (exact date to be determined)
Water Code
Section
10645
Within 30 days of submittal to DWR,
make the plan available for public
review during normal business hours.

By July 30, 2026 (exact date to be determined): Provided two hardcopies of the adopted 2025 UWMP to the San Francisco Main Library
By July 30, 2026 (exact date to be determined): Posted the adopted 2025 UWMP on the SFPUC website at www.sfwater.gov/uwmp
To be inserted: Copy of library
catalog record
To be inserted: Copy of website
posting

From: San Francisco Public Utilities Commission
To: Urban Water Management Plan
Subject: Notice of Preparation of the City and County of San Francisco’s 2025 Urban Water Management Plan and Water Shortage Contingency Plan
Date: Thursday, February 12, 2026 6:35:42 PM
Dear Customers, Community Members, and Interested Parties, The Urban Water Management Planning Act (California Water Code §10610-10657) requires urban water suppliers to update and adopt their Urban Water Management Plan (UWMP) and Water Shortage Contingency Plan (WSCP) every five years. The City and County of San Francisco is currently reviewing its UWMP and WSCP and will be preparing updates to these documents. The 2025 UWMP and WSCP are due to the California Department of Water Resources by July 1, 2026.

The 2025 UWMP will provide an overview of our water deliveries and uses, water supply sources, and water conservation programs. It will also include discussions on supply and demand projections over a 25-year planning horizon (from 2025 to 2050), available water supplies to meet existing and future demands under a range of water supply conditions, and our water demand management measures to reduce long-term water demand.

Proposed revisions to the UWMP and WSCP will be available for public review and comment. Information on the date and time of the public hearing, the procedure to submit comments, and where to access the Draft 2025 UWMP and WSCP will be provided in a later notification, prior to the start of the public review period. The City and County of San Francisco invites your agency to participate in this process.

In the meantime, if you have any questions about the UWMP or WSCP, please contact Jennifer Lee at [email protected].

Sincerely,
Julie Ortiz
Acting Director of Water Resources
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525 Golden Gate Ave | San Francisco, CA 94102 US
From: San Francisco Public Utilities Commission
To: Urban Water Management Plan
Subject: Notice of Preparation of the City and County of San Francisco Urban Water Management Plan 2025 Update and Public Hearing Date: Thursday, March 12, 2026 10:00:30 AM
Dear Customers, Community Members, and Interested Parties, The Urban Water Management Planning Act (California Water Code §10610-10657) requires urban water suppliers to update and adopt their Urban Water Management Plan (UWMP) and Water Shortage Contingency Plan (WSCP) every five years. The City and County of San Francisco is currently preparing its 2025 UWMP and WSCP and will be updating to these documents. The 2025 UWMP and WSCP are due to the California Department of Water Resources by July 1, 2026.

The 2025 UWMP will provide an overview of our water deliveries and uses, water supply sources, and water conservation programs. It will also include discussions on supply and demand projections over a 25-year planning horizon (from 2025 to 2050), available water supplies to meet existing and future demands under a range of water supply conditions, and our water demand management measures to reduce long-term water demand.

The UWMP and WSCP will be available for public review and comment from March 16, 2026 to April 20, 2026. The Draft 2025 UWMP and WSCP will be available for download on the SFPUC website at www.sfpuc.gov/uwmp
and available for physical review at the San
Francisco Main Library. The City and County of San Francisco invites you or your agency to review these plans.

Notice of Public Hearing
On Tuesday, April 14, 2026, at the regular San Francisco Public Utilities Commission (Commission) meeting that begins at 1:30PM, the Commission will hold a public hearing on the Draft 2025 UWMP and WSCP in San Francisco City Hall, Room 400, 1 Dr. Carlton B. Goodlett Place, San Francisco, California, 94102.

Interested members of the public are invited to attend the public hearing and may provide public comment. The public hearing can also be accessed virtually using the following information:

WATCH LIVE MEETING ON APRIL 14
Remote Public Comment Call-in: 1 (415) 655-0001 / Access Code: 2661 529 2962

Submission of Comments
Any interested parties may also submit written comments to the City during the public comment period in the following ways:

1. Written comments may be emailed to [email protected].

2. Written comments may be mailed to the address below. To ensure that comments can be reviewed and incorporated, any mailed comments must be post-marked by April 16, 2026.

Steve Ritchie, San Francisco Public Utilities Commission 525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
The final 2025 UWMP and WSCP will be adopted by the Commission no later than June 30, 2026. If you have any questions about the UWMP or WSCP, please contact Jennifer Lee at [email protected]
.

Sincerely,
Manisha Kothari
Acting Director of Water Resources

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525 Golden Gate Ave | San Francisco, CA 94102 US
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Contact List for 2025 UWMP
No. Organization Contact
1 Mayor's Office Daniel Lurie
2 Mayor's Office Alicia John-Baptiste
3 Board of Supervisor, District 1 Connie Chan
4 Board of Supervisor, District 2 Stephen Sherrill
5 Board of Supervisor, District 3 Danny Sauter
6 Board of Supervisor, District 4 Alan Wong
7 Board of Supervisor, District 5 Bilal Mahmood
8 Board of Supervisor, District 6 Matt Dorsey
9 Board of Supervisor, District 7 Myrna Melgar
10 Board of Supervisor, District 8 Rafael Mandelman
11 Board of Supervisor, District 9 Jackie Fielder
12 Board of Supervisor, District 10 Shamann Walton
13 Board of Supervisor, District 11 Chyanne Chen
14 SF Environment Barry Hooper
15 SF Environment Lowell Chu
16 SF Environment Sheehan Charles
17 SF Environment Esther Tang
18 SF Environment Pauli Ojea
19 SF Environment Kevin Kumataka
20 SF Planning Joshua Switzky
21 SFPUC Citizens' Advisory Committee Amy Nagengast
22 SFPUC Citizens' Advisory Committee Arthine Van Duyne 23 SFPUC Citizens' Advisory Committee Barklee Sanders
24 SFPUC Citizens' Advisory Committee Cal Law
25 SFPUC Citizens' Advisory Committee Douglas Jacuzzi
26 SFPUC Citizens' Advisory Committee Eliahu Perszyk
27 SFPUC Citizens' Advisory Committee Erin Roach
28 SFPUC Citizens' Advisory Committee Jennifer Clary
29 SFPUC Citizens' Advisory Committee Jodi Soboll
30 SFPUC Citizens' Advisory Committee Julia Hernandez
31 SFPUC Citizens' Advisory Committee Maika Pinkston
32 SFPUC Citizens' Advisory Committee Sally Chen
33 SFPUC Commission
34 City College of San Francisco Ted Aranas
35 SF State Davin Wentworth-Thrasher
36 SF State - Director of Sustainability and Energy Caitlin Steele 37 University of San Francisco Richard Hsu
38 Environmental Defense Fund Ann Hayden
39 Natural Resources Defense Council Ed Osann
40 Planning and Conservation League Jonas Minton
41 Restore Hetch Hetchy Spreck Rosekrans
42 Save the Bay- Executive Director David Lewis
43 Sierra Club San Francisco Mark Shahinian
44 Sierra Club San Francisco John Bauters
1 of 4
No. Organization Contact
45 Sierra Club San Francisco Miguel Miguel
46 Sierra Club San Francisco Sue Chow
47 SPUR
48 U.S. Environmental Protection Agency Jay Garland
49 U.S. Environmental Protection Agency, Region 9 Dena Vallano 50 U.S. Environmental Protection Agency, Region 9 Eric Byous 51 Garden for the Environment Maggie Guerra Marks
52 Bay Area Water Stewards
53 San Francisco Neighborhood Parks Council Meredith Thomas 54 East Bay Municipal Utility District
55 County of Alameda Susan Muranishi
56 County of San Mateo Mike Callagy
57 County of Santa Clara James Williams
58 County of San Joaquin Sandy Regalo
59 County of Tuolumne Roger Root
60 Imagine H2O Brian Matthay
61 Imagine H2O Scott Bryan
62 Imagine H2O Tamin Pechet
63 Pacific Institute Heather Cooley
64 Pacific Institute Peter Gleick
65 SF Power Steven Moss
66 Wholly H2O Elizabeth Dougherty
67 Yosemite Rivers Alliance Peter Drekmeier
68 Lawrence Livermore National Laboratory Bill Howing
69 Lawrence Livermore National Laboratory Waqas Iqbal
70 Lawrence Livermore National Laboratory Allen Lindauer 71 Lawrence Livermore National Laboratory Isaac Mason
72 Lawrence Livermore National Laboratory Glenn Shephard 73 Lawrence Livermore National Laboratory Joe Steadman
74 Menlo Country Club Kip Prahl
75 Department of Water Resources Ryan Bailey
76 Bay Area Water Supply and Conservation Agency Danielle McPherson 77 Bay Area Water Supply and Conservation Agency Tom Francis 78 Bay Area Water Supply and Conservation Agency Tom Smegal 79 Bay Area Water Supply and Conservation Agency Kyle Ramey 80 Bay Area Water Supply and Conservation Agency Negin Ashoori 81 NASA Jeanne Sabin
82 NASA Garrett Turner
83 Alameda County Water District Laura Hidas
84 Alameda County Water District Jonathan Wunderlich
85 Alameda County Water District Kelsi Oshiro
86 Alameda County Water District Tan Zi
87 City of Brisbane/Guadalupe Valley Municipal Improvement District Jerry Flanagan
88 City of Brisbane/Guadalupe Valley Municipal Improvement District Maz Bozorginia
89 City of Brisbane/Guadalupe Valley Municipal Improvement District Matthew Lee
90 City of Burlingame Kevin Okada
2 of 4
No. Organization Contact
91 California Water Service Company Scott Wagner
92 California Water Service Company Michael Bolzowski
93 California Water Service Company J Kooy
94 California Water Service Company Ross Moilan
95 California Water Service Company Dawn Smithson
96 California Water Service Company William Torsch
97 California Water Service Company Kevin Williams
98 Coastside County Water District Cathleen Brennan
99 Coastside County Water District Mary Rogren
100 Coastside County Water District Jeffrey Schneider
101 City of Daly City Joshua Cosgrove
102 City of Daly City Greg Krauss
103 City of East Palo Alto Matt Vining
104 City of East Palo Alto Humza Javed
105 City of East Palo Alto Anthony Harper
106 City of East Palo Alto Kevin Lewis
107 City of Foster City Zaheed Danish
108 City of Foster City Yelena Cappello
109 City of Hayward Alex Ameri
110 City of Hayward Cheryl Munoz
111 City of Hayward Management Analysts
112 Town of Hillsborough Paul Willis
113 Town of Hillsborough Ed Cooney
114 City of Menlo Park Scott Jaw
115 City of Menlo Park Azalea Mitch
116 City of Menlo Park Michael Fu
117 Mid-Peninsula Water District Drew Bost
118 Mid-Peninsula Water District Sarah Scheidt
119 Mid-Peninsula Water District Kat Wuelfing
120 City of Millbrae Craig Centis
121 City of Millbrae Andrea Pappajohn
122 City of Millbrae Heather Ruiz
123 City of Millbrae Elaine Marshall
124 City of Mountain View Lisa Au
125 City of Mountain View Elizabeth Flegel
126 City of Mountain View Kerry Holeman
127 North Coast County Water District Adrianne Carr
128 North Coast County Water District Brian McCarthy
129 City of Palo Alto Lisa Bilir
130 City of Palo Alto Adriana Artola
131 City of Palo Alto Lisa Bilir
132 City of Palo Alto Eric Wong
133 Purissima Hills Water District Cory Burkett
134 Purissima Hills Water District Pat Gillin
135 Purissima Hills Water District Jose Olivera
136 Purissima Hills Water District Tammy Rudock
3 of 4
No. Organization Contact
137 Purissima Hills Water District Samantha Vu
138 Purissima Hills Water District Erik Walter
139 City of Redwood City Justin Chapel
140 City of Redwood City Nathan Anderson
141 City of San Bruno Dennis Bosch
142 City of San Bruno Steven Salazar
143 City of San Bruno Matt Lee
144 City of San Bruno Hae Won Ritchie
145 City of San Bruno Scott Zayac
146 City of San Jose Nicole Harvie
147 City of San Jose Jeff Provenzano
148 City of San Jose Sukhpreet Manning
149 City of Santa Clara John Ramirez
150 City of Santa Clara Lawrence Tam
151 Stanford University Julia Nussbaum
152 Stanford University Brian Manning
153 City of Sunnyvale Joe De la Cruz
154 City of Sunnyvale Winola Cheong
155 City of Sunnyvale Ramana Chinnakotla
156 City of Sunnyvale Manuel Hernandez
157 Westborough Water District Patricia Mairena
158 Cordilleras Water District Rick Thall
159 Groveland Community Services District Peter Kampa
160 Groveland Community Services District Alfonso Manrique 4 of 4
• Home(/) About Us (/about-us) Policies and Plans (/about-us/policies-plans) Urban Water Management Plan Urban Water Management Plan
The Urban Water Management Planning Act (California Water Code Sections 10610-10657) requires urban water suppliers to update their Urban Water Management Plan (UWMP) and Water Shortage Contingency Plan (WSCP) every five years. The City and County of San Francisco adopted its 2020 UWMP, including the 2020 Water Shortage Contingency Plan, on June 11, 2021, and is currently preparing updates to these documents. The 2025 UWMP and WSCP are due to the California Department of Water Resources by July 1, 2026.

The 2025 UWMP will provide an overview of our water deliveries and uses, water supply sources, and water conservation programs. It will also include discussions on supply and demand projections over a 25-year planning horizon (from 2025 to 2050), available water supplies to meet existing and future demands under a range of water supply conditions, and our water demand management measures to reduce long-term water demand.

The public comment period for the Draft 2025 UWMP and WSCP ended on Monday, April 20, 2026. Members of the public may continue to review the draft plans using the link below or by visiting the San Francisco Main Library for a physical copy.

Public Hearing
On Tuesday, April 14, 2026, the San Francisco Public Utilities Commission (Commission) held a public hearing on the Draft 2025 UWMP and WSCP. A recording of the public hearing can be viewed online.

Submission of Comments
The public comment period has ended. Staff are reviewing all public comments and will prepare a final draft of the 2025 UWMP and WSCP. These plans will be brought to the Commission no later than June 30, 2026 for consideration of adoption. If you have any questions about the UWMP or WSCP, please contact Jennifer Lee at [email protected]_(mailto:[email protected].

Other Documents
• 2025 Conservation Plan IZl
Previous versions of the Urban Water Management Plan are available by contacting [email protected]_(mailto:[email protected])..

I © 2011-2025 San Francisco Public Utilities Commission. All Rights Reserved.

Lori Gomez
4/6/2026

SAN FRANCISCO PUBLIC UTILITIES COMMISSION
City and County of San Francisco
Daniel Lurie
May
or

REGULAR MEETING AGENDA
Tuesday, April 14, 2026
1:30 PM
1 Dr. Carlton B. Goodlett Place, City Hall, Room 400
Members of the San Fr ancisco Public Utilities Commission (SFPUC) will attend this meeting in-person. Members of the public are invited to observe the meeting in- person or remotely by watching live online as described below. Members of the public attending the meeting in person or remotely will have an opportunity to provide public comment on every action or discussion item.

Members of the public are encouraged to provide public comment by email. Send an em
ail to [email protected] by 4 pm the day before the meeting to ensure your comment is received by the Commission in advance of the meeting. All comments received will be made part of the official record.

REMOTE MEETING ACCESS
Watch: sfgovtv.org/sfpuc
REMOTE PUBLIC COMMENT CALL-IN: 1 (415) 655-0001 / ACCESS CODE 2661 529 2962 (No Passcode Required)
When y
our item of interest is called press *3 to be added to the speaker line.

Commenters will be allowed two minutes to speak. Call from a quiet location, speak clearly and slowly, and turn down your television, radio, or computer.

Commissioners
Josh
ua Arce, President
Stephen E. Leveroni, Vice President
Avni Jamdar
Kate H. Stacy
Meghan Thurlow
Dennis J. Herrera
General Manager
Tiffany Lennear
Director of Commission Affairs
SFPUC April 14, 2026 Regular Meeting Agenda Page 2 of 5 Accessible Meeting Policy : City Hall, Room 400 is wheelchair accessible. The meeting will be broadcast and captioned on SFGovTV. Remote public participation is available for individuals who cannot attend in person due to disability by making a request to the Director of Commission Affairs by 12 PM (noon), the day before the Commission meeting at [email protected] or 415-554-3165. Sign Language Interpretation is available upon request. If requesting Sign Language Interpretation, please submit an accommodation request, a minimum of four business hours before the start of the meeting.

Allowing a minimum of 48 business hours for all other accommodation requests (for example, all other auxiliary aids and services) helps ensure availability. To request accommodation, please contact the Director of Commission Affairs at [email protected] or 415-554-3165.

K
now Your Rights Under the Sunshine Ordinance: Government's duty is to serve the public, reaching its decision in full view of the public. Commissions, boards, councils and other agencies of the City and County exist to conduct the people's business. This ordinance assures that deliberations are conducted before the people and that City operations are open to the people's review. For more information on your rights under the Sunshine Ordinance or to report a violation of the ordinance, contact Administrator, by mail to Sunshine Ordinance Task Force, 1 Dr. Carlton B. Goodlett Place, Room 244, San Francisco, CA 94102.4689; by phone at 554.7724; by fax at 554.7854; or by email at [email protected]. Copies of the Sunshine Ordinance can be obtained from the Clerk of the Sunshine Task Force, the San Francisco Public Library and on the City’s website at http://www.sfgov.org. 311 Free Language Assistance: 免費語言協助/ Ayuda gratuita con el idioma / Бесплатная помощь переводчиков / Trợ giúp Thông dịch Miễn phí / Assistance linguistique gratuite / 無料の言語支 援/ 무료 언어 / 지원 / คว“มช◌ว ◌่ ยเหลอ◌◌ื ท“งภ“ษ“โดยไมเ◌◌่ ส’ยคาใชจ◌ ◌้ าย / Libreng tulong para sa wikang Tagalog ยเหลอ◌◌ื
Lobbyist Registration and Reporting Requirements: Individuals and entities that influence or attempt to influence local legislative or administrative action may be required by the San Francisco Lobbyist Ordinance [SF Campaign & Governmental Conduct Code §2.100] to register and report lobbying activity.

For more information about the Lobbyist Ordinance, please contact the San Francisco Ethics Commission at 25 Van Ness Avenue, Suite 220, San Francisco, CA 94102; telephone (415) 252 -3100; fax (415) 252-3112; web site at www.sfgov.org/ethics.

C
EQA Appeal Rights under Chapter 31 of the San Francisco Administrative Code : If the Commission’s action on a project constitutes the Approval Action for that project (as defined in S.F.

Administrative Code Chapter 31, as amended, Board of Supervisors Ordinance Number 161- 13), then the CEQA determination prepared in support of that Approval Action is thereafter subject to appeal within the time frame specified in S.F. Administrative Code Section 31.16. Typically, an appeal must be filed within 30 calendar days of the Approval Action for a project that has received an exemption or negative declaration pursuant to CEQA. For information on filing an appeal under Chapter 31, contact the Clerk of the Board of Supervisors at City Hall, 1 Dr. Carlton B. Goodlett Place, Room 244, San Francisco, CA 94102, or call (415) 554-5184. If the Planning Department’s Environmental Review Officer has deemed a project to be exempt from further environmental review, an exemption determination has been prepared and can be obtained on- line at http://www.sf- planning.org/index.aspx?page=3447. Under CEQA, in a later court challenge, a litigant may be limited to raising only those issues previously raised at a hearing on the project or in written correspondence delivered to the Board of Supervisors, Planning Commission, Planning Department or San Francisco Public Utilities Commission at, or prior to, such hearing, or as part of the appeal hearing process on the CEQA decision.

SFPUC April 14, 2026 Regular Meeting Agenda Page 3 of 5

ORDER OF BUSINESS

1. Call to Order

2. Roll Call

3. Approval of the Minutes of March 24, 2026

4. Gener
al Public Comment
Members of the public may address the Commission on matters that are within the Commission’s jurisdiction and are not on today’s agenda. The Commission values civic engagement and encourages respectful communication at the public meeting.

We ask that all public comment be made in a civil and courteous manner and that you refrain from the use of profanity. Thank you.

5. Report of the General Manager (discussion only)
a) Report on Recent San Francisco Public Utilities Commission Activities, Events and Announcements

6. CONSENT CALENDAR
a) Approve Amendment No. 1 to Contract No. PRO.0229, Emergency Planning, Response, Training and Technical Support, with AECOM Technical Services, Inc., increasing the contract duration by five years, for a total contract duration of nine years, with no change to the contract amount, for project continuity of several emergency planning projects in the Plan Update Schedule that require consultant support. (Flynn)
b) Approve the novation of Contract No. PUC-0002.C, Master As-Needed Security System Maintenance and Integration Services, to transfer the existing contract from Ojo Technology Inc., to Convergint Technologies LLC. (Flynn) c) Award Contract No. CS -1272, Point-of-Sale Electric Vehicle Incentive Program to Cohen Ventures, Inc. DBA Energy Solutions in the amount of $4,200,000 and with a duration of four years, seven months. (Hale) d) Approve the novation of Contract No. PRO.0239 New City Distribution Division Campus at 2000 Marin Construction Management Staff Augmentation Services, to transfer the existing contract from Consor PMCM, Inc., to Consor North America, Inc. (Robinson)
e) Approve Modification No. 1 to Job Order Contract No. JOC -110, General Engineering (A License) Construction, San Joaquin, Stanislaus, and Tuolumne Counties, Hetch Hetchy, with Robert E. Boyer Construction, Inc., to increase the contract not -to-exceed amount by $2,500,000, for a revised not -to-exceed contract amount of $7,500,000, with no change to the contract duration, to SFPUC April 14, 2026 Regular Meeting Agenda Page 4 of 5 provide additional capacity for facility and asset improvements. (Robinson) f) Modify Contract No. WW-752R, Various Locations Main Sewer Inspection No. 2, with Pipe and Plant Solutions, Inc., to decrease the contract amount by $585,098, for a revised total contract amount of $2,958,556, to adjust contract quantities to match actual completed quantities, with no change to the contract duration. (Robinson)

REGULAR CALENDAR

7. Public hearing to consider and possible action to adopt new Rules and Regulations Restricting Potable Water Use for Irrigation of Nonfunctional Turf to align with Assembly Bill 1572 ; and authorize the General Manager in consultation with the City Attorney, to approve any non-substantive edits or minor corrections to the Rules and Regulations Restricting Potable Water Use for Irrigation of Nonfunctional Turf that are necessary or appropriate to facilitate implementation of Assembly Bill 1572.

Pursuant to San Francisco Charter Section 4.104(a)(1), a Notice of Public Hearing was posted at the San Francisco Main Library and on the SFPUC’s website. (Ritchie)

8. Presentation and discussion only of the Draft 2025 Urban Water Management Plan, including the Draft 2025 Water Shortage Contingency Plan, prepared by the San Francisco Public Utilities Commission for the City and County of San Francisco pursuant to California Water Code Sections 10610-10657. The Commission will hold a second meeting to consider adoption of the f inal 2025 Urban Water Management Plan, following the public review and comment period on the Draft 2025 Urban Water Management Plan, no later than June 30, 2026. (Ritchie)

9. Approve the Water Supply Assessment for the proposed 536 Mission Street Project (located at 536 Mission Street) , pursuant to California Water Code Section 10910 et seq., California Environmental Quality Act (CEQA) Section 21151.9, and CEQA Guidelines Section 15155. (Ritchie)

10. Approve the Revised Water Supply Assessment for the proposed FlowerMart Project (located at 610- 640 & 644- 658 & 660 -670 & 674- 698 Brannan Street, 548- 5th Street, and 149 Morris Street) , pursuant to California Water Code Section 10910 et seq., California Environmental Quality Act (CEQA) Section 21151.9, and CEQA Guidelines Section 15155. (Ritchie)

11. Authorize the issuance of bonds or other forms of indebtedness to refund outstanding 2015 Power Revenue Bonds Series A with 2026 Power Bonds Series A (2026A Power Refunding Bonds) issued in a principal amount up to $30 million. (Hom)

12. Approve Amendment No. 1 to Contract No. PRO.0163(R), Engineering Services for the Emergency Firefighting Water System and City’s Water Distribution System , with SFPUC April 14, 2026 Regular Meeting Agenda Page 5 of 5 Lee+Ro and AGS Joint Venture, increasing the contract amount by $5,000,000, for a total not-to-exceed contract amount of $13,000,000, with no change to the contract duration, to provide additional engineering design and support for pipeline improvement projects, subject to Board of Supervisors approval under Charter Section 9.118. (Robinson)

13. COMMUNICATIONS (information only)
a. Advance Calendar
b. Contract Advertisement Report
c. Correspondence Log
d. Water Supply Conditions Update
e. Retail Water Conservation Plan Quinquennial (2025) Report f. Annual Municipal Energy Benchmarking Report

14. Items initiated by Commissioners (discussion only)

15. Public Comment on matters to be addressed during Closed Session

16. Motion on whether to assert the attorney-client privilege regarding the matters listed below:

The Commission will go into Closed Session to discuss the following item:

CLOSED SESSION
CONFERENCE WITH LEGAL COUNSEL regarding anticipated litigation (Government Code §54956.9, Administrative Code §67.10(d)):

Craig Banks v. City and City and County of San Francisco Unlitigated Claim File No.: 240239
Date Filed: September 27, 2020
Proposed settlement of employment dispute in the amount of $100,000, subject to final approval by the San Francisco Board of Supervisors. (Action Item) (Bregman) Following Closed Session, the Commission will reconvene in Open Session

17. Report following Closed Session

18. Motion regarding whether to disclose the discussion during Closed Session pursuant to San Francisco Administrative Code Section 67.12(a).

19. Adjournment
1 of 25
1 Public Comments and Responses on the Draft 2025 Urban Water Management Plan
This section details written and oral comments received on the Draft 2025 Urban Water Management Plan (UWMP), including the Draft 2025 Water Shortage Contingency Plan (WSCP), and the SFPUC’s responses to these comments. The public comment period began on March 16, 2026, and ended on April 20, 2026. SFPUC staff presented t he Draft 2025 UWMP to the SFPUC Citizens’ Advisory Committee (CAC) on March 17, 2026, and to the SFPUC Commission at a Public Hearing on April 14, 2026.

Table 1-1 provides a list of all agencies, organizations, and individuals who submitted comments on the Draft 2025 UWMP.

Table 1-1. Comments Received on the Draft 2025 Urban Water Management Plan Comment
ID Commenter Date Comment
Method
Page
No.

A Denise Louie 3/17/2026 CAC Meeting 8
B Peter Drekmeier, Yosemite Rivers Alliance 3/17/2026 CAC Meeting 8 C Mark Shahinian, Sierra Club San Francisco
Bay 3/17/2026 CAC Meeting 8
D Arthine Cossey van Duyne, CAC Member 3/18/2026 Email 8 E Barklee Sanders, CAC Member 4/1/2026 Email 12
F Dave Warner 4/6/2026 Email 14
G Peter Drekmeier, Yosemite Rivers Alliance 4/6/2026 Email 14 H Shannon McEntee 4/7/2026 Email 16
I Mark Shahinian, Sierra Club San Francisco
Bay 4/7/2026 Email 16
J Tom Smegal, CEO/General Manager,
BAWSCA 4/14/2026 Public Hearing 17
K Eileen Boken, Coalition for San Francisco
Neighborhoods 4/14/2026 Public Hearing 17
L Layne Fajeau, Sierra Club California 4/14/2026 Public Hearing 17 M Mary Butterwick 4/14/2026 Public Hearing 18
N George Cattlemore 4/14/2026 Public Hearing 18
O Christina Bertea, Greywater Action 4/14/2026 Public Hearing 18 P Mark Shahinian, Sierra Club San Francisco
Bay 4/14/2026 Public Hearing 18
Q Francisco Da Costa 4/14/2026 Public Hearing 19
R Douglas Jacuzzi, Westside Water Resources 4/14/2026 Public Hearing 19 S Tootas Cook 4/14/2026 Public Hearing 19
T Alex Ferris 4/14/2026 Public Hearing 19
U Hilary Hug 4/14/2026 Public Hearing 19
V David Schram 4/14/2026 Public Hearing 20
W Anne Schneider 4/14/2026 Public Hearing 20
2 of 25
Comment
ID Commenter Date Comment
Method
Page
No.

X Martin Gothberg 4/14/2026 Public Hearing 20
Y Les Kishler 4/14/2026 Public Hearing 20
Z Denise Louie 4/14/2026 Public Hearing 20
AA Peter Drekmeier, Yosemite Rivers Alliance 4/14/2026 Public Hearing 21 AB Julie Ann Frizzell 4/14/2026 Public Hearing 21
AC Lila Holzman 4/19/2026 Email 21
AD Peter Drekmeier, Yosemite Rivers Alliance 4/20/2026 Email 21 AE
John J. Bauters, Sierra Club San Francisco
Bay Chapter; Sue Chow, Sierra Club Loma
Prieta Chapter; Miguel Miguel, Sierra Club
California
2/19/2026
(before public
comment
period)
Email 24
Several comments raised the same or similar concerns . Rather than responding individually to recurring comments, the SFPUC developed global responses to address each recurring comment comprehensively. Global responses are provided for the following topics:

1. Water affordability

2. Retail population and demand projections

3. Wholesale demand projections

4. Design drought

5. Bay-Delta Plan Amendment

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1.1 Global Response 1: Water Affordability
Summarized Comment s: Several commenters raised concerns about water affordability, including: (1) the absence of a formal affordability analysis in the UWMP, (2) demand projections that may be overstated and drive unnecessary capital spending, which in turn could raises rates, and (3) perceptions that current rate-setting and capital planning processes do not fully incorporate affordability considerations.

Response:
1) The SFPUC is dedicated to delivering affordable water services to all customers. The scope and content of the UWMP , however, are governed by the UWMP Act (California Water Code Section 10610-10656), which establishes specific requirements for what must be included in the plan. The California Water Code does not require urban water suppliers to conduct or include a water affordability analysis . The UWMP Act focuses on ensuring that suppliers provide long -term water supply reliability assessments (Section 8 o f the 2025 UWMP) ; demand projections including for lower -income housing (Section 4.1.5 of the 2025 UWMP) ; water shortage contingency planning (Appendix F of the 2025 UWMP) ; and descriptions of water supply sources, conservation measures, and reliability (Sections 6, 7, and 10 of the 2025 UWMP).
2) The SFPUC developed the demand projections in the UWMP Scenario in accordance with the requirements of the UWMP Act. State law directs urban water suppliers to base long -term population and demand projections on data from local and regional planning authorities , including adopted housing and land use projections. The SFPUC developed two additional demand scenarios showing a range of future demands; see Global Response 2. The UWMP is not a rate-setting document and does not determine water, sewer, or power rates. 3) The preparation of the Capital Budget, the 10 -Year Financial Plan, and rates are complex processes that balance multiple needs of the SFPUC and its ratepayers. Central to these processes is affordability for the SFPUC’s ratepayers. In 2023, the SFPUC adopted a more stringent affordability policy to demonstrate the SFPUC ’s dedication to delivering cost - based, equitable, accessible, and affordable utility services for all customers. That commitment was made clear when staff cut $1 billion from t he proposed ca pital budget in the most recent budgeting process. While the UWMP describes major supply and reliability projects, the decision to fund and implement those projects, including how they affect future rates, is made through the capital budgeting, 10 -Year Financial P lan, and rate -setting processes, not through the UWMP update cycle.

While the UWMP is not a rate -setting document, the SFPUC remains committed to maintaining affordability as a core agency value, evaluating affordability impacts through the 10 -Year Financial Plan, and implementing customer assistance programs.

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1.2 Global Response 2: Retail Population and Demand Projections Summarized Comments: Several commenters claim that the retail population projections in the 2025 UWMP are overstated, which in turn leads to inflated retail water demand projections.

Commenters suggest that SFPUC ’s high demand projections are used to justify capital projects, which increases long -term financial obligations, and ultimately raises rates for customers.

Commenters urge the use of more realistic growth projections , such as t hose prepared by the California Department of Finance or used by the SFPUC Finance Bureau.

Response: Per the UWMP Act (California Water Code, Section 10631(a)):

The projected population estimates shall be based upon data from the state, regional, or local service agency population projections within the service area of the urban water supplier and shall be in five -year increments to 20 years or as far as data is av ailable. The description shall include the current and projected land uses within the existing or anticipated service area affecting the supplier’s water management planning. Urban water suppliers shall coordinate with local or regional land use authoriti es to determine the most appropriate land use information, including, where appropriate, land use information obtained from local or regional land use authorities.

In compliance with this requirement, the SFPUC coordinated with the San Francisco Planning Department, which is the City’s land use authority , and received housing and employment projections (see Section 4.1.2.1 of the 2025 UWMP). The SFPUC uses these projections as the basis for the demand projections under the UWMP Scenario to comply with state law.

As recommended in the 2024 Alternative Water Supply (AWS) Plan, the SFPUC developed two additional retail demand scenarios reflecting less housing and employment growth : a Department of Finance/Moody’s Scenario that projects demand declining from 62.5 million gall ons per day (MGD) in 2025 to 59.7 MGD by 2050 and a Historical Growth Scenario that projects demand increasing from 62.5 MGD in 2025 to 66.7 MGD by 2050. These scenarios provide a broader range for informational purposes and are described in Appendix C of the 2025 UWMP. The demand scenarios will be used to inform the AWS Plan Update, which is expected to begin in FY 2026-27.

The UWMP is intended to ensure there is enough water for existing and planned development .

Demand projections developed for the UWMP Scenario are conservative to demonstrate reliable supply, while demand forecasts developed for financial projections are conservative by estimating low potential growth to ensure sufficient revenues. SFPUC Finance has developed separate water projections that are the basis of setting rates and does not use the UWMP demand projections when setting rates.

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1.3 Global Response 3: Wholesale Demand Projections
Summarized Comments: The SFPUC received comments that it does not independently evaluate wholesale customer p urchase projections, that those projections influence capital planning and rate decisions, and that the UWMP should analyze how water shortages affect vulnerable communities in the wholesale service area.

Response: The SFPUC is responsible for projecting retail water demands. Wholesale customer s, including Bay Area Water Supply and Conservation Agency (BAWSCA) member agencies and the Groveland Community Services District, are responsible for preparing demand projections for their service area s and submi tting purchase projections to the SFPUC for inclusion in the UWMP (see Section 4.2 of the 2025 UWMP). This approach is consistent with state law and previous UWMPs. The SFPUC does not have land use authority i n the jurisdictions of its wholesale customers . It cannot substitute its own assumptions about the wholesale customers’ demands or purchase projections for those developed by the wholesale customers. The wholesale customers are responsible for determining which sources of supply to use and/or develop within their respective service areas and in some cases may not purchase water exclusively from the SFPUC.

Wholesale purchase projections in the UWMP do not determine the SFPUC’s wholesale rates or capital spending. Wholesale rates are established through a separate financial planning process that evaluates water sales, updated capital needs, and current financial conditions, consistent with the SFPUC’s water supply agreement with the wholesale customers . Furthermore, each of the wholesale customers sets rates for its own retail customers , and those rates must comply with Proposition 218. The SFPUC is not involved in setting retail rates in its wholesale service area.

Regarding the effects of water shortages on vulnerable communities in the wholesale service area, all urban water suppliers must prepare a Water Shortage Contingency Plan, implemented in the event of a water shortage and independent from long -term supply and demand projections. The SFPUC’s water supply agreement with its wholesale customers incorporates a Water Shortage Allocation Plan that governs how Regional Water System supplies are allocated between the wholesale customers collectively , on the one hand , and the retail customers collectively , on the other, during system-wide shortages (see Section 3 of the 2025 Water Shortage Contingency Plan) .

However, wholesale customers are responsible for contingency planning for their respective service areas including their vulnerable communities. The SFPUC does not dictate how a wholesale customer determines its sources of supply or how to allocate them.

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1.4 Global Response 4: Design Drought
Summarized Comments: Multiple commenters questioned the SFPUC’s 8.5-year design drought, arguing that it is longer than the scenarios used by peer agencies such as Valley Water and East Bay Municipal Utility District, is statistically unlikely to occur, and leads to more conservative rationing projections. Commenters also mention that the design drought drives unnecessary capital investment and should be shortened or replaced with a scenario more consistent with those used by other agencies.

Response: The design drought is an important water supply planning tool used by the SFPUC. The

8.5-year design drought combines two historically significant droughts (the 1987-1992 drought and the 1976 -1977 drought ) to create a planning drought that is longer and more severe than those observed in the historical record; this methodology allows the SFPUC to plan to operate the RWS and provide reliable water supply through extended droughts. The global climate is changing, and California weather may become mo re variable as a result. Preparing for this type of scenario helps the SFPUC safeguard the water supply needs of the 2.7 million residents and thousands of businesses that rely on this water supply.

As described in th e UWMP, the SFPUC relies primarily on the Tuolumne River watershed for water supply in all years, including droughts. During droughts, the available water supply on the Tuolumne River can be almost entirely allocated to senior water right holders, leaving very little for the RWS. As a result, the RWS depends on water supply that is stored prior to a drought; the storage in RWS reservoirs at the start of a drought is the main source of water supply that the SFPUC manages during a drought. Beyond its own reservoirs, the SFPUC does not have other sources of water supply that it can use or otherwise rely upon as a substitute for RWS supplies during an extended drought. The SFPUC’s reliance on stored water and lack of other sources are the drivers for using the design drought as part of the SFPUC’s water supply planning methodology ; with no backup supply to rely on, the SFPUC emphasizes maintaining reliable water supply in storage.

The SFPUC remains committed to adaptive management practices that enable responsiveness to changing conditions and will continue to revisit its planning tools periodically. The SFPUC will not modify its design drought as part of this UWMP process.

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1.5 Global Response 5: Bay-Delta Plan Amendment
Summarized Comments: Several commenters raised concerns about the Bay -Delta Plan Amendment, including its effects on Tuolumne River ecosystem health and salmon recovery, the SFPUC’s concerns regarding the plan, and whether a Healthy Rivers and Landscapes agreement (formerly referred to as a Voluntary Agreement) would be adequately protective of the environment.

Commenters also argued that more realistic demand projections would demonstrate that the SFPUC can accommodate both the Bay -Delta Plan Amendment’s requirements and its customers’ water needs without undue rationing.

Response: The 2025 UWMP and its future updates will continue to reflect the latest status of the Bay-Delta Plan Amendment, including the Health Rivers and Landscapes Program (see Section 7.3 and Section 8 of the 2025 UWMP). However, the UWMP is intended to inform the SFPUC and public about potential future water-supply scenarios; the UWMP process does not dictate the outcome of pending litigation or related state administrative proceedings. As explained in Global Response 2, the retail demand projections in the UWMP Scenario ensure that there is enough water to meet the needs of existing and planned development , but the SFPUC also prepared two additional demand scenarios that evaluate future demand assuming less housing and employment growth. Collectively, this broader range of retail demands will be considered in the SFPUC’s ongoing water supply planning.

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1.6 Comments and Reponses
The comments below summarize public input received at the March 17, 2026 SFPUC CAC meeting, the April 14, 2026 SFPUC Commission meeting, and through email submissions.

1.6.1 Comment A: Denise Louie
Comment A-1: The commenter asks whether affordability is a required component of the UWMP.

Response A-1: See Global Response 1 (Water Affordability).

1.6.2 Comment B: Peter Drekmeier, Yosemite Rivers Alliance Comment B-1: The commenter argues that the SFPUC has enough storage for six years of water. In an average year, the SFPUC receives entitlements equal to three years of demand. The commenter states other water agencies like Valley Water and East Bay M unicipal Utility District plan for a six- year drought of record whereas the SFPUC plans for th e 1987-1992 drought with the 1976-1977 drought. The commenter states that current demand could be managed under the six-year drought of record with the Bay -Delta Plan in place with no more than 15% rationing , and that the SFPUC presents an overly severe scenario described as 72% more severe and 19 times less likely to happen than peer agency scenarios.

Response B-1: Comment noted. See Global Response 4.

1.6.3 Comment C: Mark Shahinian, Sierra Club San Francisco Bay Chapter Water Committee Comment C -1: The commenter states that the Bay -Delta Plan is one of the top priorities for the Sierra Club because of its importance to the Tuolumne River ecosystem. The commenter links the 12% rate increase and the SFPUC’s support of a Healthy Rivers and Landscapes agreement to the agency’s response to the Bay -Delta Plan . The commenter states that i n 2024, ratepayers in San Franscisco conserved 40% more than they did in 2000, while the UWMP projects only a 7% additional per capita reduction going forward i n the next 25 years. The commenter notes that the Sierra Club has come up with a different model and urged members of the CAC to review it.

Response C-1: Comment noted. See Global Response 5.

1.6.4 Comment D: Arthine Cossey van Duyne, SFPUC Citizens Advisory Committee Member Comment D -1: The commenter identifies three s trengths to preserve in the final UWMP: San Francisco's low residential water use of about 43 gallons per person per day ; Section 4.1.5’s acknowledgement of water demands of lower-income households; and investments in local supply diversity, including the Westside Enhanced Water Recycling Project, the Treasure Island Water Resource Recovery Facility, and expanded groundwater production. 9 of 25
The commenter further notes that Treasure Island is identified as an environmental justice community in the City's EJ Framework.

Response D-1: Comment noted.

Comment D -2: The commenter states that t he UWMP evaluates system performance only at an aggregate level and does not assess who bears the greatest burden during shortages, where investments are geographically concentrated, or which populations face affordability stress. The commenter argues that while the UWMP Act does not explicitly require an environmental justice chapter, reliability, resilience, and demand management requirements should include a distributional analysis.

Response D-2: Comment noted.

Comment D-3: The commenter states that the plan does not map how infrastructure investment, conservation program delivery, or water reliability metrics vary across neighborhoods , making it difficult to assess whether public benefits are shared across all communities. The commenter recommends a GIS-based analysis that overlays the City's EJ Communities Map with infrastructure investment locations, recycled water service areas, conservation program delivery, pipe age and condition data, and system reliability metrics to demonstrate whether planned capital investments are aligned with the highest-need communities.

Response D-3: Comment noted. The SFPUC water cons ervation program evaluates its effectiveness in reaching communities with limited financial resources or language barriers to help ensure information about its water-saving assistance programs reach people in neighborhoods with lower median incomes and higher concentrations of non -English speaking residents. Although the commenter’s recommendation is outside the scope of the UWMP, it has been shared with appropriate SFPUC staff for further consideration.

Comment D-4: The commenter states that under the Bay-Delta Plan Amendment implementation, retail customers could face shortages of up to 29 percent and wholesale customers could face shortages of up to 49 percent. The commenter states that neither the UWMP nor the WSCP analyzes how shortage allocations and conservation mandates will fall across income levels or neighborhoods. The commenter recommends within the WSCP, to model household -level and neighborhood-level impacts of shortage scenarios, including ab ility to comply with conservation mandates, exposure to rate increases, and risk of service disruption. The commenter suggests that the SFPUC increase protections against service disconnections for lower-income customers during declared shortage events and that the SFPUC provide public reporting on shortage burden by neighborhood.

Response D-4: The SFPUC adopted a written policy on discontinuation of residential water service for nonpayment per the California Water Shutoff Protection Act ( California Health & Safety Code Section 116900 et seq. Under this policy, the SFPUC provides customer support for deferred or reduced payments, alternative payment schedules, bill contests and appeals , and discussion of options to avoid discontinuation of residential service for nonpayment. The SFPUC also provides the 10 of 25
Extenuating Circumstances for Water Shut -Off Lien Prevention Program for customers who make less than 80% of area median income. The SFPUC would continue programs to assist low -income customers during water shortages.

Comment D-5: The commenter states that Section 4.1.5 acknowledges lower -income households but does not estimate how many customers spend an unaffordable share of their income on water service. The commenter recommends estimating the number of retail customers spending 2 to 4.5 percent or more of household income on water bills, disaggregated by neighborhood and by tenure (renters vs. owners) ; assessing whether the tiered rate structure is functioning equitably for low - volume water users; evaluating whether bill assistance programs are reaching renters and non - account holders; and describing a plan to close any access gap identified.

Response D-5: Comment noted. See Global Response 1 (Water Affordability).

Comment D -6: The commenter states that the plan describes public participation activities but does not document which languages materials were provided in, whether meetings were held in the neighborhoods most affected, or which community organizations were engaged and what information was shared . The commenter recommends documenting which languages public materials were provided in , and the organizations engaged. The commenter also requests that the SFPUC confirm whether in -person meetings were held in Bayview Hunters Point, Chinatown, the Tenderloin, and the Mission. For the next UWMP cycle, the commenter recommends establishing a standing EJ community advisory group with documented feedback processes.

Response D-6: Public noticing for the preparation of and public hearing for the 2025 UWMP was provided and documented in Appendix B of the 2025 UWMP . While public engagement for the 2025 UWMP meets the Water Code requirements as described in Section 11.1 of the 2025 UWMP, and on March 17, 2026, the SFPUC presented the Draft 2025 UWMP to the Citizens’ Advisory Committee, whose members represent each of the supervisory districts in San Francisco, the SFPUC did not conduct UWMP-specific meetings directly with any individual neighborhoods or community organizations. The SFPUC continually and proactively engage s with historically underserved communities regarding rates, capital projects, customer assistance programs , and other community benefits programs. The UWMP and WSCP will continue to be updated to reflect the latest programs and services pertinent to the scope of both plans.

Comment D-7: The commenter states a pproximately 85 percent of San Francisco's water supply originates from the Tuolumne River watershed, the homeland of Indigenous peoples including speakers of Sierra Miwok languages , and that Hetch Hetchy Valley was inhabited and actively managed by Miwok and Paiute peoples for thousands of years before the O'Shaughnessy Dam was completed in 1923. The commenter states that the 2025 UWMP contains no acknowledgment of this history and no description of engagement with tribal nations. The commenter recommends adding a land and water acknowledgment , documenting engagement efforts with tribal nations , establishing a tribal liaison function within the SFPUC , and exploring funding commitments to support water access for tribal communities served by or adjacent to the Regional Water System. 11 of 25
Response D-7: The SFPUC recognizes the longstanding presence and stewardship of Native communities in these areas. For the UWMP, the SFPUC has elected not to include a land or water acknowledgement. However, the SFPUC values the importance of strengthening relationships with Tribal Nations and incorporating Indigenous perspectives, including traditional ecological knowledge and facilitating meaningful tribal collaboration.

Comment D-8: The commenter recommends replacing the plan’s reliance on CalEnviroScreen 4.0 for the local cumulative impact analysis with a locally calibrated cumulative impact analysis that combines CalEnviroScreen 4.0 scores as a baseline, SFDPH Air Pollution Exposure Zone and Areas of Vulnerability data, housing crowding and linguistic isolation data from the Census, rent burden and housing instability indicators, and SFPUC service complaint, leak history, and pipe age data disaggregated by neighborhood. The commenter also recommends u sing the resulting composite index to guide investment prioritization and drought protection commitments for high -burden communities and committing to using the City's supplemental EJ Communities Map as the primary geographic screening tool for planning purposes, not CalEnviroScreen alone.

Response D-8: Comment noted. Although the recommendation is outside the scope of the UWMP , it has been shared with appropriate SFPUC staff for further consideration.

Comment D-9: The commenter states that the plan does not evaluate stormwater capture as a local supply strategy in EJ communities. The commenter recommends evaluating targeted stormwater capture projects in EJ communities as part of the supply diversification strategy and assessing co- benefits for water quality and neighborhood health in areas currently affected by sewer overflows.

Response D-9: Comment noted. Although the recommendation is outside the scope of the UWMP, it has been shared with appropriate SFPUC staff for further consideration. Stormwater management is coordinated by the SFPUC’s Urban Watershed Planning Division. The SFPUC encourages property owners to capture and reuse stormwater onsite for non-potable uses, such as irrigation and toilet flushing, and provides resources and technical assistance to do so through various programs including the Stormwater Management and Onsite Water Reuse programs.

Comment D-10: The commenter states that the SFPUC's Community Benefits Policy recognizes the need to create green jobs in communities that have historically borne a disproportionate share of pollution burdens. The commenter recommends defining local and targeted hiring goals for capital projects in EJ communities, including the recycled water buildout and groundwater expansion ; tracking and reporting workforce equity outcomes as part of UWMP implementation ; and aligning capital program workforce commitments with the SFPUC's existing Community Benefits Policy.

Response D-10: While Section 7 of the 2025 UWMP describes anticipated capital investments over the planning horizon , local hiring goals, workforce equity metrics, and job creation strategies are outside the scope of the UWMP. These activities are guided by the SFPUC’s Community Benefits Policy, project-specific contracting requirements, and other agency workforce and procurement programs.
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Comment D-11: The commenter states that the plan projects wholesale customer shortages of up to 49 percent under modeled Bay-Delta Plan Amendment scenarios. The commenter states neither the UWMP nor the W ater Shortage Allocation Plan (WSAP) analyzes whether it produces equitable outcomes for the communities that wholesale customers serve. The commenter recommends assessing whether the WSAP allocation formula, as currently structured, produces disproportionate shortage impacts on wholesale customers whose se rvice areas include a high concentration of lower-income residents and communities of color. Where disproportionate impacts are identified, the commenter recommends consideration of whether adjustments to the allocation formula or supplemental technical assistance can reduce that disparity ; encourage wholesale customers to conduct their own distributional shortage analysis and offer SFPUC technical assistance to support that work; and include wholesale system equity outcomes in the SFPUC's annual EJ perform ance reporting.

Response D-11: See Global Response 3 (Wholesale Demand Projections).

Comment D -12: The commenter recommends annual EJ performance reporting that covers investment alignment, affordability outcomes, shortage burden by neighborhood, and wholesale system equity outcomes; integration of spatial EJ analysis and the local cumulative impact index into the Capital Improvement Program prioritization process ; alignment of rate -setting processes with affordability findings from the UWMP ; and a public-facing EJ dashboard that tracks plan implementation against equity commitments.

Response D-12: Comment noted. Although the recommendation is outside the scope of the UWMP, it has been shared with appropriate SFPUC staff for further consideration.

Comment D-13: The commenter notes that the SFPUC established national leadership by adopting an environmental justice policy before any other utility in the country. The commenter states that the 2025 UWMP is an opportunity to demonstrate that this commitment shapes real planning decisions, not only policy statements. The commenter states these recommendations are grounded in the SFPUC's policies, the City's EJ Framework, the requirements and intent of the California Urban Water Management Planning Act, and best practices from the Pacific Institute, DigDeep, the U.S. Water Alliance, and EPA guidance.

Response D-13: Comment noted.

1.6.5 Comment E: Barklee Sanders, SFPUC Citizens Advisory Committee Member Comment E -1: The commenter urges the adopt ion of the UWMP and WSCP with stronger accountability, clearer triggers, and enforceable implementation commitments. The commenter states that the plan should function as an operating manual for reliability, drought response, public communication, enforcement, financial consequences, and continuous reevaluation. The commenter requests a plain-English, front-of-document accountability table that shows, for each scenario, projected demand, available supply by source, shortage amount, trigger level, response actions, expected water savings or added yield, responsible department, legal authority, and 13 of 25
implementation deadline. The commenter also cites DWR’s 2025 UWMP Guidebook to describe water use and supply assumptions, account for climate change in long -term reliability and drought risk analyses, quantify water loss, and coordinate with affected agencies and communities.

Response E-1: The 2025 UWMP includes water use and supply assumptions (Section s 4, 6, and 8), climate change considerations (Sections 4.3, 6.1.3, and 6.2.4), quantified water loss reporting (Table 4-4), and coordination with surrounding agencies and communities (Section 2.3) consistent with DWR guidance. Additionally, the WSCP does function as a drought response plan, with actions that the SFPUC would take in the event of a water shortage emergency (including, but not limited to, communications, temporary restrictions, and enforcement).

Comment E-2: The commenter requests that the Commission convert local supply diversification from “planning” to “procurement -grade execution.” The commenter states that the SFPUC should attach milestone schedules for PureWaterSF, recycled water expansion, onsite reuse buildout, and other alternative supplies, with target online dates, expected annual yields, permitting path, and financing assumptions.

Response E -2: Local supply and reuse projects such as recycled water, onsite water reuse, and groundwater are described in Section 6 of the 2025 UWMP. Two additional reuse projects, PureWaterSF and PureWater Peninsula, are still in the planning phase and will be covered in subsequent UWMP updates once environmental review is completed and funding is secured. In the meantime, the SFPUC updates, at least every two years, its 10-Year Capital Plan, which contains the most current project information in between UWMP update cycles.

Comment E-3: The commenter requests that conservation be targeted where the remaining savings are still real, measurable, and fair. Specifically, the commenter states that the SFPUC should focus on leaks, commercial and institutional retrofits, large landscapes, and enforcement against waste.

Response E -3: The 2025 Retail Water Conservation Plan identifies future opportunities for conservation savings in Section 3 and in Table 6 -2, which notes the conservation measures the SFPUC already is implementing or plans to start implementing within the next five years.

Comment E-4: The commenter requests that the WSCP make equity and due process explicit. The commenter writes that the final WSCP should clearly state: the essential indoor health -and- sanitation baseline that will be protected; exemption and appeal procedures; protections for tenants and master -metered multifamily residents; multilingual outreach; transparent reporting of warnings, penalties, and exemptions by customer class; and the standards for escalating from voluntary to mandatory measures.

Response E-4: The activation of any shortage level is based on supply availability and the level of demands at the time a water shortage emergency declaration is being considered (Section 4.6 of the 2025 WSCP). Prior to initiating any water delivery reductions to its retail customers, the SFPUC will present a water shortage response plan at a regularly scheduled Commission meeting where members of the public will have the opportunity to comment (Section 2.5 of the 2025 WSCP ). This water shortage response plan will be prepared specific to the water shortage event at hand and will 14 of 25
more explicitly address some of the items requested by the commenter, including a minimum per - capita residential allocation, or water use “floor,” to ensure enough water is available for basic health and safety needs (Section 4.1.3 of the 2025 WSCP ). As part of the water shortage response plan, the SFPUC will notify customers of procedures for exemptions and appeals (Section 4.1.5 of the 2025 WSCP). All retail customer communications (Section 5 of the 2025 WSCP) will be provided in multiple languages per the SFPUC’s practice for customer communications. The SFPUC will comply with any required water shortage-related reporting including those described in Section 9 of the 2025 WSCP and disclosure of customers fine d for exceeding water use allocations in accordance with Chapter 3.3 to Division 1 of the California Water Code.

Comment E -5: The commenter requests regional accountability , specifically an annual public dashboard and hearing after each annual water shortage assessment showing actual supply conditions, the shortage level determination, triggered response actions, actual versus projected conservation savings, water loss performance, local supply project status, and wholesale -retail coordination outcomes.

Response E-5: SFPUC staff have and will continue to coordinate with BAWSCA staff on the retail and wholesale demand projections. In addition, SFPUC staff routinely provide supply condition updates to the Commission at its regularly scheduled meetings. The meeting agendas and a copy of these presentations are available at www.sfpuc.gov. In the event of a water shortage emergency, the SFPUC would follow the procedures outlined in the Water Shortage Contingency Plan ( WSCP).

Figure 2-1 of the WSCP illustrates what this process may look like in a drought , and Table 3-1 of the WSCP shows the retail and wholesale customers ’ respective shares of the available RWS supplies depending on the required level of system-wide reduction in water use.

1.6.6 Comment F: Dave Warner
Comment F-1: The commenter states that the SFPUC’s design drought model produces rationing estimates of 40% in the UWMP for the scenario with the Bay Delta Plan Amendment in effect. The commenter states that available scientific data exists suggesting that the design drought could have a chance of occurrence in the range of 0.013% to 0.001% (a return period between 8,000 and 70,000 years). The commenter expresses that a modest reduction to the drought model would substantially lower the listed rationing per centages. Additionally, the commenter states that current demand projections are lower than before and annual Regional Water System demand hasn’t been over 200 mgd for the last 11 years. The commenter asks SFPUC staff to quantify the risk (return period) of the design drought and lesser potential variants , and if warranted by the Long Term Vulnerability Assessment, to develop a more reasonable drought model.

Response F-1: Comment noted. See Global Response 4 (Design Drought).

1.6.7 Comment G: Peter Drekmeier, Yosemite Rivers Alliance Comment G -1: The commenter states that during the last UWMP process, conservation groups made efforts to encourage the SFPUC to revisit the Design Drought prior to finalizing the UWMP. The 15 of 25
commenter notes that the Commission has yet to consider amendments to the Design Drought. The commenter asks the SFPUC to hold a workshop on the Design Drought.

Response G-1: Comment noted. See Global Response 4 (Design Drought).

Comment G-2: The commenter states affordability risks are increasing because of overestimating demand and water sales, growing capital needs, and rationing projections. The commenter asks if the SFPUC’s estimated $10 billion in additional capital costs over the next 30 years been factored into future rates, and how higher rates may impact demand. Additionally, the commenter asks how an ensuing decrease in sales may affect further rate increases.

Response G-2: See Global Response 1 (Water Affordability).

Comment G -3: The commenter states that the SFPUC’s projected water supply shortages could lead to unnecessary rationing. The commenter cites a 7.4% wholesale water price increase and argues the SFPUC has a highly reliable water supply with sufficient storage and exceptional water rights in Wet, Normal and Below Normal years. The commenter expressed concern about language provided by the SFPUC for inclusion in the BAWSCA member agencies’ Urban Water Management Plans – specifically, Table 4e focusing on water supply availability during a five dry-year sequence.

Response G-3: The California Water Code Section 10631(b)(1) requires:

A detailed discussion of anticipated supply availability under a normal water year, single dry year, and droughts lasting at least five years, as well as more frequent and severe periods of drought, as described in the drought risk assessment. For each sour ce of water supply, consider any information pertinent to the reliability analysis conducted pursuant to Section 10635, including changes in supply due to climate change.

In compliance with the Water Code requirements, the SFPUC prepared a supply reliability analysis and letter for Wholesale Customers to use in their respective 2025 UWMPs.

Comment G-4: The commenter states that Table 8-3 from the Draft 2025 UWMP finds the SFPUC would only be able to provide 57% of baseline water demand in Years 2 through 5 of a five -year drought sequence if the Bay -Delta Plan Amendment is implemented but does not show how much water is left in storage at the end of each year. The commenter states under the SFPUC’s design drought scenario, at the end of the first five consecutive dry years , the SFPUC would still have more than 600 thousand acre-feet of water remaining in storage – enough water to last at least 2.5 years.

The commenter asserts , in reference to the driest historic five-year sequence, the SFPUC could manage the five consecutive dry years with the Bay -Delta Plan Amendment in effect and still have water remaining in storage. The commenter cites the LTVA , which suggests there is “no clear direction of change in mean annual precipitation over the planning horizon .” The commenter also recommends revising the length and severity of the Design Drought.

Response G-4: Comment noted. See Global Response 4 (Design Drought). 16 of 25

1.6.8 Comment H: Shannon McEntee
Comment H-1: The commenter states that the UWMP uses inflated population growth projections, projecting San Francisco to grow from 843,881 in 2025 to 1,231,654 in 2050 , an addition of 387,773 people in 25 years, or 15,511 people per year. The commenter compares this with 2005 to 2025 growth of 62,044, or 3,102 people per year, and asks whether San Francisco ’s population will grow five times as fast than in the recent past . The commenter requests that the SFPUC reconsider its population estimates in the final UWMP.

Response H-1: See Global Response 2 (Retail Population and Demand Projections).

1.6.9 Comment I: Mark Shahinian, Sierra Club San Francisco Bay Chapter Water Committee Comment I -1: The commenter states that the 2025 UWMP overpredicts projected customer demand. The commenter asserts that a dopting this plan would result in a variety of financial and environmental impacts . The commenter states the models that underlie the demand projections lack sufficient support. The commenter states SFPUC and BAWSCA models assume the following:
residences are 100% occupied; loss projections that exceed those allowable by state law; no increases in rates; and that all active conservation p rograms end in 2035. The commenter asks the SFPUC to revise its modeling assumptions in response to the commenter’s feedback , set up a working group to re-evaluate and issue a revised UWMP, and alter its approach towards the Bay Delta Plan Amendment.

Response I-1: As described in Global Response 2, the SFPUC coordinated with the San Francisco Planning Department to receive housing growth projections through 2050. The assumption that single family and multi-family residences will be 100% occupied starting in FY 2029-30 is consistent with the UWMP’s approach of ensuring enough water supply for the anticipated growth as projected by the SF Planning Department . This is described in Appendix C (2025 Retail Demand Model and Projections Technical Memorandum ). Regarding water loss projections , see Section 4.1.4 of the 2025 UWMP that discusses the SFPUC’s approach for estimating future water losses . Urban water supplies have until 2028 to meet new water-loss standard s. Regarding rates, t he demand model incorporates water, wastewater, and stormwater rate increases from the 10-Year Financial Plan (February 2025) approved by the San Francisco Public Utilities Commission. Lastly, the SFPUC does not assume that all active conservation programs end in 2035. As shown in Table 7-2 of the 2025 Retail Water Conservation Plan, active conservation program savings extend past 2035 and through 2050. Beyond 2035, the SFPUC cannot precisely predict participation rates, new measures yet to be implemented, or what the water savings would be for future measures. Therefore, the projected savings peak in 2035 and water conservation savings in subsequent years are lower but do not end in 2035. The SFPUC has committed to updating its Retail Water Conservation Plan and conservation savings model and to reviewing implemented and potential new conservation measures every five years, coinciding with the SFPUC’s update of the UWMP.
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1.6.10 Comment J: Tom Smegal, Bay Area Water Supply and Conservation Agency Comment J-1: The commenter noted that BAWSCA worked on a set of core common assumptions that all of BAWSCA’s member agencies agreed to as a basis for the BAWSCA demand study for the wholesale service area. The commenter stated that the results of the BAWSCA demand study were reviewed by all of BAWSCA’s member agencies and were used to develop the wholesale customer purchase requests data that BAWSCA provided to the SFPUC for its UWMP. The commenter stated that BAWSCA supports the adoption of the SFPUC 2025 UWMP based on its review and coordination efforts with the SFPUC . The commenter noted BAWSCA’s understanding that the UWMP is in compliance with the UWMP Act and that failing to adopt the UWMP within the State’s deadline may make SFPUC ineligible for State loans and grants. The commenter stated that BAWSCA has an interest in the SFPUC’s financial standing and its ability to remain eligible for grant funding.

Response J-1: Comment noted.

1.6.11 Comment K: Eileen Boken, Coalition for San Francisco Neighborhoods Comment K-1: The commenter suggests the current draft of the SFPUC's 2025 UWMP is based on outdated population projections from the Department of Finance. The commenter asserts that the State Department of Finance now projects population to remain flat for the foreseeable future.

According to the commenter, t he population projections in the UWMP lead to inflated demand projections and design -drought projections , resulting in increased rates to pay for unnecessary capital improvements. The commenter states m ost water agencies plan for a 6 -year drought, and the SFPUC’s 8.5-year design drought also seems beyond the norm. The commenter asserts that an

8.5-year drought deprives the Tuolumne River of the flows it needs for ecosystem health.

Response K-1: One of the two additional retail demand scenarios developed by the SFPUC , the Department of Finance/Moody’s Scenario, reflects a flat population project ion from the California Department of Finance. Development of this scenario is described in Appendix C of the 2025 UWMP.

Please also see Global Response 2 (Retail Population and Demand Projections ) and Global Response 4 (Design Drought).

1.6.12 Comment L: Layne Fajeau, Sierra Club California
Comment L-1: The commenter states that the SFPUC has overestimated water demands , which leads to increased capital spending and rapidly rising rates. In addition, the commenter states the SFPUC’s water demand projections affect the SFPUC’s perception of the impacts of the Bay-Delta Plan Amendment. The commenter urges the SFPUC to address errors in the demand modeling identified by the Sierra Club prior to the finalizing the 2025 UWMP , and to adopt more realistic demand projections that don't lead to overbuilding, rising costs, and environmental harm.

Response L-1: Please see Response I-1 regarding the demand modeling concerns identified by the Sierra Club, Global Response 1 (Water Affordability), and Global Response 2 (Retail Population and Demand Projections).
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1.6.13 Comment M: Mary Butterwick
Comment M-1: The commenter states that the UWMP, particularly the 8.5 -year design drough t, directly affects the management of flows of the Tuolumne River, which is in crisis due to inadequate instream flows. The commenter requests that the SFPUC revise the length of its design drought before submitting the UWMP to DWR. Specifically, the commenter states that the SFPUC should re- evaluate the return period for the design drought and conduct a risk analysis of the design drought compared with shorter drought m odels. The commenter cites a n analysis conducted by the Yosemite Rivers Alliance that showed significant volumes of water stored at the end of each year of the design drought without rationing.

Response M-1: See Global Response 1 (Water Affordability) and Global Response 4 (Design Drought).

1.6.14 Comment N: George Cattlemore
Comment N-1: The commenter expresses concern about the health of the local ecosystem due to over-pumping by farmers. The commenter suggests the SFPUC has overestimated water demands.

The commenter requests the SFPUC consider the Tuolumne watershed. The commenter also asserts that the SFPUC has underestimated the cost of water. The commenter asserts that , in addition to raising rates, the SFPUC is now planning $10 billion in capital improvements , and that there should be an audit of the Commission focusing on internal and external costs of the decisions and how these decisions are made.

Response N-1: See Global Response 2 (Retail Population and Demand Projections).

1.6.15 Comment O: Christina Bertea, Greywater Action
Comment O-1: The commenter asserts that UWMPs have historically over -projected demands , claims that the SFPUC’s design drought is statistically likely to occur once in 8,000 years , and requests that the SFPUC modify the design drought by using a six-year drought of record that other agencies use, so that the Bay -Delta Plan Amendment flow requirements can be implemented. The commenter expresses various environmental concerns.

Response O-1: See Global Response 4 (Design Drought).

1.6.16 Comment P: Mark Shahinian, Sierra Club San Francisco Bay Comment P-1: The commenter states that they performed the analysis presented in the letters sent by the Sierra Club regarding the 2025 UWMP . The commenter asserts that the SFPUC’s current demand projections are problematic. The commenter suggests that the UWMP informs the SFPUC’s understanding of the impacts that may be caused by the Bay-Delta Plan Amendment. 19 of 25
Response P-1: See Global Response 2 (Retail Population and Demand Projections) and Global Response 5 (Bay-Delta Plan Amendment) . Responses I -1 and AE-1 through AE -6 respond to the referenced letter sent by the Sierra Club.

1.6.17 Comment Q: Francisco Da Costa
Comment Q-1: The commenter references the former beauty of the Hetch Hetchy Valley and the need to respect the indigenous people in and near the Tuolumne River watershed.

Response Q-1: Comment noted.

1.6.18 Comment R: Doug Jacuzzi, Westside Water Resources Comment R-1: The commenter states that the SFPUC needs to consider the salmon and the Delta's ecosystem health and requests th at the SFPUC adjust the design drought to a more appropriate drought scenario.

Response R-1: Comment noted. See Global Response 4 (Design Drought).

1.6.19 Comment S: Tootas Cook
Comment S-1: The commenter also asserts that UWMPs have always over -projected water demands and the 2025 UWMP does it as well. The commenter also asserts that SFPUC has plenty of water for the Bay-Delta Plan Amendment and requests that the SFPUC alter its demand projections and the severity of the design drought. The commenter also supports the request for an independent audit of the Commission and its projections.

Response S-1: Comments noted. See Global Response 2 (Retail Population and Demand Projections) and Global Response 5 (Bay-Delta Plan Amendment).

1.6.20 Comment T: Alex Ferris
Comment T-1: The commenter states that the Bay Delta ecosystem is in collapse. The commenter claims that the SFPUC's proposed Healthy Rivers and Landscapes Agreement would harm fish , which are an important element of the ecosystem and should be protected.

Response T-1: See Global Response 5 (Bay-Delta Plan Amendment).

1.6.21 Comment U: Hilary Hug
Comment U-1: The commenter states they rely on the SFPUC to maintain the ecological integrity of the Tuolumne River watershed, the San Joaquin River , and the Bay Delta. The commenter requests the SFPUC change its position regarding the Bay -Delta Plan Amendment. The commenter also requests a workshop where critics and proponents of the draft UWMP can provide information essential for a science-based policy.
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Response U-1: See Global Response 5 (Bay-Delta Plan Amendment).

1.6.22 Comment V: David Schram
Comment V-1: The commenter expresses concern about ensuring high-quality and affordable water and about protecting the natural environment. The commenter asserts that the UWMP is based on overly high demand projections, which have been consistently decreasing.

Response V-1: See Global Response 2 (Retail Population and Demand Projections).

1.6.23 Comment W: Anne Schneider
Comment W-1: The commenter suggests that with the design drought, the UWMP plans for an event that would never happen, which affects SFPUC’s capital improvement plan and rates. The commenter asserts that in Millbrae, this will cause an increase of 10 to 14% in water rates, which will reduce the amount of water residents use, and reduce the amount of money that Millbrae has to invest in recycled water and other alternative water supplies.

Response W-1: Comment noted. See Global Response 4 (Design Drought).

1.6.24 Comment X: Martin Gothberg
Comment X-1: The commenter asserts that there is a need for revised demand projections and a shorter design drought to improve ecosystem health and to discharge less water in wet years. The commenter asserts that SFPUC’s design drought drives expenses and servicing of debt, which drives rates higher than people can afford. The commenter also states that Bay Area residents can do even more to conserve water.

Response X-1: Comments noted. See Global Response 1 (Water Affordability), Global Response 2 (Retail Population and Demand Projections). and Global Response 4 (Design Drought).

1.6.25 Comment Y: Les Kishler
Comment Y-1: The commenter expresses concern about the health and wellbeing of the San Francisco Bay and Delta. The commenter asserts over-estimating water needs ha s unintended consequences that are unnecessary and preventable and that the SFPUC should allow more water to reach the Bay-Delta.

Response Y-1: See Global Response 2 (Retail Population and Demand Projections) and Global Response 5 (Bay-Delta Plan Amendment).

1.6.26 Comment Z: Denise Louie
Comment Z-1: The commenter asserts that the UWMP is used to justify an expensive water supply system, which does not include the $10 billion of capital improvements or the expansion to the 21 of 25
emergency firefighting system. The commenter requests the SFPUC revisit its concerns regarding the Bay-Delta Plan Amendment.

Response Z-1: See Global Response 1 (Water Affordability) and Global Response 5 (Bay-Delta Plan Amendment).

1.6.27 Comment AA: Peter Drekmeier, Yosemite Rivers Alliance Comment A A-1: The commenter states that t he UWMP is used as a planning document and the Alternative Water Supply Plan is based on the UWMP. The commenter claims that there are two flaws with the UWMP : overly high demand projections and the design drought. The commenter asserts that there is an inadequate assumption of how costs impact demands and that the design drought is too conservative and unlikely to happen. The commenter requests a workshop before finalizing the UWMP.

Response A A-1: Comments noted. See Global Response 2 (Retail Population and Demand Projections) and Global Response 4 (Design Drought).

1.6.28 Comment AB: Julie Ann Frizzell
Comment AB-1: The commenter expresses concern about the environment and residential water bill rates. The commenter claims that the UWMP contains outdated information and that the SFPUC continues to project water demands incorrectly despite people in the Bay Area conserving water .

The commenter also asserts that no other water agencies in the State use an 8-year design drought, that the population data the SFPUC uses is too high and leads to costly projects and that the SFPUC raises water rates for BAWSCA members in order to pay for these projects.

Response AB-1: See Global Response 1 (Water Affordability), Global Response 2 (Retail Population and Demand Projections), and Global Response 4 (Design Drought).

1.6.29 Comment AC: Lila Holzman, SFPUC Citizens’ Advisory Committee Member Comment AC-1: The commenter states that they recently joined the Citizens’ Advisory Committee and heard a presentation about the Draft 2025 UWMP on March 17. During that meeting, the commenter also heard concerns about overestimating demand. The commenter requests that the SFPUC ensure its modeling doe s not unnecessarily result in unneeded investments or harm to California’s rivers and wetlands.

Response AC-1: See Global Response 2 (Retail Population and Demand Projections).

1.6.30 Comment AD: Peter Drekmeier, Yosemite Rivers Alliance Comment AD-1: The commenter states that Table 3-3 of the 2025 UWMP projects San Francisco’s population to grow by 15,511 people per year compared to Figure 4-2, which shows the population growing by 3,102 people per year. The commenter asserts that it is unlikely San Francisco will add 22 of 25
five times as many people per year in the near future than it did in the recent past and requests that SFPUC revisit the population projections and replace them with more realistic numbers.

The commenter states that Table 3-4 shows BAWSCA member agencies’ collective service area is projected to add 27,980 people per year , while Table 4 from the SFPUC’s 2005 UWMP shows the BAWSCA member agencies’ collective service area grew by 11,359 people per year. The commenter asserts that it is unlikely BAWSCA member agencies will add 2.4 times more people in the near future than in the recent past and requests that these numbers be revisited in the UWMP.

The commenter also asserts that Table 4-5 includes unrealistic demand growth for several BAWSCA member agencies, especially the City of Hayward, where 2025 purchases of 13.66 mgd are projected to rise to 19.71 mgd in 2050, an increase of 44% in the next 25 years. The commenter claims that BAWSCA’s 2025 demand study overstates regional population and jobs growth by using Plan Bay Area numbers , does not account for the impact of droughts on reducing future demand , and assumes the price of water will keep pace with inflation despite SFPUC capital needs totaling $10.1 billion.

Response AD-1: See Global Response 2 (Retail Population and Demand Projections ) and Global Response 4 (Wholesale Demand Projections).

Comment AD-2: The commenter states that the UWMP projects Regional Water System demand will be 197.5 MGD in 2035, while SFPUC’s Finance Bureau forecasts RWS sales will be 182.1 MGD in 2036, a difference of more than 15 MGD. The commenter cites an SFPUC report, “Water Enterprise and Finance Bureau Water Demand Projections” (July 5, 2022) , which states that Water Enterprise projections represent an outside bound of whatever demand will occur in the next 25 years, while Finance projections are intended to be close to actuals for budgeting and rate se tting. The commenter asks that the UWMP include alternative demand projections using Finance Bureau numbers and use these lower numbers to project rate increases and impact on demand.

Response AD-2: See Global Response 2 (Retail Population and Demand Projections) , which references California Water Code Section 10631 requiring urban water suppliers to use projected population estimates based on data from state, regional, or local service agency population projections within the urban water supplier’s service area.

The SFPUC has developed two additional demand scenarios as shown in Appendix C (2025 Retail Demand Model and Projections Technical Memorandum) of the 2025 UWMP. As discussed during the Public Hearing on April 14, 2026, the demand projections for the Department of Finance/Moody’s Scenario are lower than SFPUC Finance’s projections with water loss.

Comment AD-3: The commenter request s that S ection 6.1.1 include a table that shows total Tuolumne River runoff and the Tuolumne River irrigation districts’ water entitlements and San Francisco’s water entitlements for each of the previous 50 years, as well as a second table showing how these numbers would have changed had the Bay -Delta Plan Amendment been in place during those years.
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The commenter requests that Section 6.1.3 include information on how earlier runoff resulting from climate change might impact the SFPUC’s water entitlements , including two new tables that show what would happen if the design-drought years were to repeat, but the runoff arrived 10 and 20 days earlier, and how this would impact the SFPUC’s water entitlements.

The commenter requests that Section 6.1.3.1 add the following: the LTVA finding that runoff will shift to earlier in the season as a bullet point , Table 3-9 from the SFPUC’s LTVA with the Design Drought, Table 5-1 from the LTVA, and a return period for the Design Drought.

Response AD-3: As shown in Section 8 of the 2025 UWMP, the Bay-Delta Plan Amendment of 2018 may affect each agency’s access to reliable water supplies, the Bay-Delta Plan Amendment does not alter San Francisco’s or the Tuolumne River irrigation districts’ entitlements to water.

The LTVA does not find that a warmer climate “would likely benefit the SFPUC’s water entitlements” due to earlier runoff. Instead, the LTVA finds that the annual average water available to San Francisco would decrease due to climate change (Section 5.1.1.2 and Figure 5 -4(a) of the LTVA). Importantly, the LTVA finds that the variability in the water available to San Francisco increases with warming and estimated reductions in water availability can be much larger than any potential increases (Figure 5- 6 of t he LTVA). Understanding the changing variability in water available to San Francisco with warming is crucial in water supply planning to safeguard the SFPUC ’s water supply. It is not reasonable to assume that if the design drought scenario were perturbed by climate change, the only change would be runoff occurring 10 or 20 days earlier. The SFPUC has not evaluated the requested scenario.

On May 7, 2022, the SFPUC provided a memo randum to the Tuolumne River Trust (now Yosemite Rivers Alliance) describing issues with the Tuolumne River Trust’s design-drought return period calculation. These issues were related to (1) an error in Upcountry hydrologic models, and 2) a large uncertainty in drought frequency analysis for extreme drought events. The SFPUC views assessment of the effects of climate change as an ongoing need that requires regular updating to reflect improvements in climate science, atmospheric/ocean modeling, observations, and human response to the threat of greenhouse gas emissions. Climate change research by the SFPUC began in 2009 and continues to be refined.

Comment AD-4: The commenter requests that Section 7.1 include lessons learned, noting that when WSIP was adopted in 2008, projected 2018 demand was 285 mgd , the Phased WSIP capped water sales at 265 mgd, and actual demand in 2018 was 196 mgd.

The commenter requests that S ection 7.4 explain how Alternative Water Supply Plan “Demands” and “Obligations” were determined. The commenter recommends adding a second “Demands” column based on Finance Bureau sales projections.

Response AD-4: As recommended in the 2024 Alternative Water Supply Plan, the SFPUC developed additional retail demand scenarios that are reflected in the 2025 UWMP (see Appendix C) . These scenarios show a range of future demands and will be used to inform the upcoming Alternative Water 24 of 25
Supply Plan Update, which is expected to begin in FY 2026 -27. For wholesale demand projections, please see Global Response 3.

Comment AD-5: The commenter requests that the SFPUC justify the design drought with analyses and documentation or revise it based on new information, including the LTVA.

The commenter also requests that Table 8-3 start with Year 1 of the Design Drought (not Year 2) and include a row showing the amount of water remaining in storage at the end of each year.

Response AD-5: Comment noted. See Global Response 4 (Design Drought).

1.6.31 Comment AE: John J. Bauters , Sierra Club San Francisco Bay Chapter; Sue Chow , Sierra Club Loma Prieta Chapter; Miguel Miguel, Sierra Club California Comment AE-1: The commenters state that they have concerns that the draft 2025 UWMP demand projections present an unrealistically high future water demand. The commenters argue inflated demand projections are being used to justify expensive capital projects and large budgets, and that the SFPUC’s proposal to raise its wholesale water rates for the next two years will affect customers in San Francisco in the same way it will affect wholesale customers. In addition, the commenters assert that the SFPUC is usi ng these same demand projections to inform its response to the Bay- Delta Plan Amendment.

The commenters are also concerned that the SFPUC ’s 8.5-year design drought is 2.5 years longer than the six -year design drought used by peer agencies. The commenters argue this posture does not appear in line with guidance from the California Department of Water Resources to provide a realistic prediction of future water use based upon a supplier’s past and current water use, combined with considerations of anticipated growth, new regulations, changing climate conditions, and trends in customer water use behaviors.

Response AE-1: Comments noted. See Global Response 2 (Retail Population and Demand Projections) and Global Response 4 (Design Drought).

Comment AE-2: The commenters state that the SFPUC takes BAWSCA’s projections and incorporates them into its own projections, even though BAWSCA member agencies represent two- thirds of Regional Water System demand. The commenters note that from their conversation with the consulting team building the BAWSCA model, it appears that they are assuming in their model that many of the coefficients they derive from past correlations carry on into the future unchanged and that they also appear to be incorrectly inte rpreting what happens to water use in a hotter, drier future climate.

Response AE-2: Comment noted. See Global Response 3 (Wholesale Demand Projections).

Comment AE-3: The commenters assert that a Drought-Demand Model is a better predictor of water demand, every drought has resulted in large demand reductions, and post-drought demand has not rebounded to previous levels. They state that the Sierra Club has built a Drought-Demand Model that 25 of 25
uses a common drought measure to predict future water use. The commenters state that this model uses the California Department of Finance population projections for San Francisco and San Mateo County, which project 0.08% and 0.12% annual population growth to 2050, respectively. They state that the Sierra Club’s modeling and assumptions suggest a decline in water demand of about 45 MGD over the next 25 years . Commenters argue the Sierra Club’s modeling and assumptions indicate the retail and wholesale projections are overestimating demand by about 50% over the next 25 years. They assert that the model shows that 2050 retail and wholesale demand will be about 147 MGD. The commenters also assert that BAWSCA and the SFPUC use relatively high population growth projections based on the projections of planning departments or the Association of Bay Area Governments, while the Department of Finance projections have been accurate within 3% on a 10 - year basis.

Response AE-3: Comment noted. See Global Responses 3 (Wholesale Demand Projections) and 4 (Design Drought).

Comment AE-4: The commenters assert that over-estimation of demand negatively impacts riverine ecosystems. The commenters claim that the Bay-Delta Plan Amendment assures enough water for continued recovery of salmon and other species and for improved health of the ecosystem. The commenters argue that unproven claims of demand hardening and over-projections are driving identification of new supplies under the A lternative Water Supply Plan. The commenters urge the SFPUC to reconsider its demand projections.

Response AE-4: See Global Response 2 (Retail Population and Demand Projections).

Comment AE-5: The commenters assert that high demand projections encourage capital spending and lead to misleadingly low rate projections , where if demands do not materialize as forecasted, the SFPUC must increase rates above what was projected. The commenters also assert that higher water rates cause further reductions in demand, which has contributed to the decline in per capita demand in the past 20 years. Based on the SFPUC’s own projections, the commenters suggest combined water and sewer rates will be come unaffordable for typical San Francisco households in a decade and recommend utilizing more realistic demand projections to improve planning, reduce rate increases, reduce alternative water supplies, and help address affordability.

Response AE-5: See Global Response 1 (Water Affordability).

Comment AE-6: The commenters recommend three actions:(1) create a working group with SFPUC staff and interested parties to build revised demand scenarios; (2) reassess how supply and demand are conceived of in light of affordability and ecological concerns; and (3) work with interested parties in 2026 to re-examine the SFPUC’s approach to the Bay -Delta Plan Amendment in light of changed demand projections.

Response AE-6: Comments noted.

APPENDIX C
2025 Retail Demand Model and
Projections Technical Memorandum
2025 URBAN WATER MANAGEMENT PLAN
for the City and County of San Francisco

June 2026
Prepared by: The San Francisco Public Utilities Commission

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1 Water Demand Projections for
the City and County of San
Francisco
2025-2050
San Francisco Public Utilities Commission
David Sunding, Berkeley Research Group
Oliver Browne, WestWater Research

March 13, 2025

2 Table of Contents
Executive Summary ................................ ................................ .......... 4 1 Methodology ................................ ................................ .......... 7

1.1. Data ........................................................................................ 7

1.2. Econometric Model .................................................................. 9

1.3. Projection Data ...................................................................... 11 2 Single-Family Residential Projection................................ .... 13

2.1. Model Estimates .................................................................... 13

2.2. Demand Projection ................................................................ 14 3 Multi-Family Residential Demand Projection ....................... 17

3.1. Model Estimates .................................................................... 17

3.2. Demand Projection ................................................................ 18 4 Commercial and Industrial Demand Projection ................... 20

4.1. Model Estimates .................................................................... 20

4.2. Demand Projection ................................................................ 21 5 Comparison to 2020 and 2015 Demand Projections ............. 23 Appendix A: Discussion of Assumptions for Demand Projection and Sensitivity Analysis ................................ ................................ ......... 26 A. Purpose ................................................................................. 26 B. Scope of the Sensitivity Analysis ............................................. 26 C. Sensitivity Scenario Demand Projections ................................ 34

3 Tables and Figures
Table 1-1: Summary of Demand Projections by Sector (MGD) ..................................................... 6 Table 2-1: Demand Projection Assumptions – Housing Unit and Employment Growth ............... 12 Table 2-2: Demand Projection Assumptions- Covariates .......................................................... 12 Table 3-1: Model Estimates – Single Family Residential Sector .................................................. 14 Table 3-2: Demand Projection – Single Family Residential Sector .............................................. 16 Table 4-1: Model Estimates – Multi-Family Residential Sector ................................................... 18 Table 4-2: Demand Projection – Multi-Family Residential Sector ............................................... 19 Table 5-1: Model Estimates – Commercial and Industrial Sector ............................................... 21 Table 5-2: Demand Projection – Commercial and Industrial Sector ........................................... 22 Table A-1: Population per Household Estimates by Year ........................................................... 28 Table A-2: Historical and Average Demands for Other Retail Types ........................................... 34 Table A-3: Water Demand Scenarios and Corresponding Data Sources .................................... 35 Table A-4: Projected Retail Demands (MGD) by Scenario .......................................................... 35

Figure 6-1: Comparison of Demand Projections from 2025, 2020, and 2015 UWMPs ................ 23 Figure A-1: Historical and Projected Housing Growth by Source .............................................. 29 Figure A-2: Historical and Projected Employment by Source ................................................... 31 Figure A-3: Projected Water Demand by Scenario .................................................................. 36

4 1 Executive Summary
The San Francisco Public Utilities Commission (SFPUC) commissioned Berkeley Research Group (BRG) and WestWater Research to update the project of water demand within the SFPUC’s in-City retail service area, encompassing the City and County of San Francisco (CCSF). Previously, Brattle Research Group prepared projections to support the preparation of SFPUC's 2015 and 2020 Urban Water Management Plans, as well as in 2023 to align with San Francisco's Housing Element 2022 Update. We project demands for the following three types of accounts within the in-City retail service area:
• Single Family Residential,
• Multi-Family Residential, and
• Commercial and Industrial.

To project future water demands, we obtained data on monthly water consumption and billing for each account of the above types in the City and County of San Francisco. We merged this data with property characteristics held by the Office of the Assessor -Recorder, demographic characteristics from the American Community Survey (ACS) at the census block-group level, and historical climate data from the PRISM dataset.

We project account-level water demand based on each household’s or business’s historical average water consumption between 2010 and 2025 and statistical relationships between each household’s water consumption and demand drivers such as water rates, weather, and other factors such as drought and the COVID-19 pandemic (2020-2022). For each account, we estimate the relationship between water use and these demand factors using a multiple regression analysis. In a regression analysis, changes in the demand variable, namely account-level water use, are explained by the control variables such as rates, climate, and macro-economic factors. The statistical estimates are not based on differences in the average level of water use between accounts, which we adjust for using a statistical technique called ‘fixed-effects’. Rather, our estimates are based on the different trends in how each account’s water use changes in response to changes in rates, climate, and macro-economic factors.

The results of our statistical model are a set of “demand elasticities” with respect to water rates, average monthly temperature, and monthly precipitation. These elasticities describe the percentage change in water consumption predicted in response to a o ne-percentage change in each of these control variables.

For each account, future demand from 2025 to 2050 is based on historical aggregate water use, expected future changes in rates and climate, and revised growth assumptions. The 2050 planning horizon aligns with the planning period for the SFPUC’s 2025 Urban Water Management Plan (UWMP).

The assumptions for future rates and climate were developed in consultation with SFPUC. The projections assume that by 2050 total water rates (including wastewater) increase by almost 100% in

5 real terms (after inflation), average temperatures in San Francisco increase by 0.7°C relative to 2025, and average precipitation will increase by 3.4 mm per month.

San Francisco Planning Department (SF Planning) provides both the housing (units) and employment growth projections to the SFPUC. For each type of account, the SFPUC uses an econometric model that estimates the relationship between water consumption and demand factors (e.g., rates, temperature, precipitation) using multiple regression analysis with account-level fixed effects. These models generate monthly consumption projections for each individual account, which incorporate the projected housing and employment growth along with anticipated changes in rates and weather patterns. Total demand for the in -City retail service area is calculated by aggregating the monthly account-level projections by sector.

Table 1-1 summarizes our projections. Single family residential consumption assumes no increase in housing units and is projected to increase from 12.6 million gallons per day (MGD) in FY 2024-25 to 13.0 MGD in FY 2049-50; multi-family residential consumption assumes a 44% increase in housing units and is projected to grow from 22.2 MGD in FY 2024-25 to 32.2 MGD in FY 2049-50; and commercial and industrial consumption assumes a 28% increase in jobs but demands will slightly decline from 12.3 MGD in FY 2024-25 to 12.2 MGD in FY 2049-50. These projections account for all single family, multi- family, and commercial/industrial water use in the SFPUC retail service area. These projections are then combined with estimates of future demands for dedicated irrigation, municipal, and suburban retail accounts, which are assumed to be equal to the last fiscal year’s consumption (i.e., FY 2024-25). For water losses and unbilled consumption, the SFPUC projects these demands to be equal to the latest three-year average (i.e., FY 2022-23 through FY 2024-25). Total water demand is projected to change from 62.5 MGD in FY 2024-25 to 73.4 MGD in FY 2049-50.

This projection uses the same methodology as the demand projection produced as part of the 2020 UWMP process by the same authors. This report estimates the parameters of the econometric model after incorporating additional data from 2020-2024 into our dataset and updates the projection using the new econometric model parameters and updated projections for household and employment growth.

Compared to the 2020 water demand projections , t he 2025 projections made the following key updates:
• It recalibrates the baseline year from FY 2019-20 to FY 2023-24. • It applies updated housing and employment to projections. • This report also introduces two new demand scenarios (Appendix A) that reflect uncertainty in the long-term housing and employment growth rates within the City.

6 Table 1-1: Summary of Demand Projections by Sector (MGD) FY 2024-25
(Actual)
FY 2029-30 FY 2034-35 FY 2039-40 FY 2044-45 FY 2049-50
(millions of gallons per day)
Single Family Residential
Raw Prediction 12.6 13.4 13.1 13.1 13.1 13.1
Conservation: Active 0.0 -0.1 -0.1 -0.1 -0.1 -0.1
Total 12.6 13.3 13.0 13.0 13.0 13.0
Multi-Family Residential
Raw Prediction 22.2 26.3 27.3 29.0 30.6 32.4
Conservation: Active 0.0 -0.1 -0.1 -0.1 -0.1 -0.1
Non-Potable / Onsite Reuse 0.0 -0.1 -0.2 -0.2 -0.2 -0.2 Total 22.2 26.2 27.1 28.7 30.4 32.2
Commercial and Industrial
Raw Prediction 12.6 12.9 12.4 12.9 13.3 14.0
Conservation: Active 0.0 -0.4 -0.5 -0.4 -0.4 -0.4
Non-Potable / Onsite Reuse -0.2 -0.5 -1.3 -1.4 -1.4 -1.4 Total 12.4 12.0 10.7 11.1 11.5 12.2
Others
Estimations Irrigation 1.5 1.5 1.5 1.5 1.5 1.5
Municipal 2.2 2.2 2.2 2.2 2.2 2.2
Suburban Retail 4.0 4.1 4.2 4.3 4.4 4.5
Water Loss and Othera 7.6 7.8 7.8 7.8 7.8 7.8
Total 15.3 15.6 15.7 15.8 15.9 16.0
Grand Total

62.5 67.0 66.5 68.6 70.7 73.4
Notes: Raw predictions in each sector include both standard accounts and combination -fire accounts.

Minor ‘inconsistencies’ in subtotal are result of rounding significant figures . a Other uses include authorized, unbilled, unmetered consumption or water that is used in activities such as firefighting, water or sewer main flushing, street cleaning, etc.

7 2 Methodology
Our estimation process has several steps that we discuss in the respective subsections below. The first subsection discusses the raw data that we collect and how we pre-adjust our raw data to remove the impact of the SFPUC’s active water conservation programs, which we account for separately after projecting future demand. The second subsection discusses the econometric model that we built. The third subsection discusses the assumptions and calculations that we use to produce both individual- level and aggregate demand estimates from the econometric model.

2.1. Data

2.1.1 Data Sources and Construction
Our estimates rely on account-level data from the SFPUC’s in-City retail service area, matched with data on parcel characteristics, and local weather fluctuations. We matched the SFPUC’s monthly billing data from FY 2009 -10 through FY 2023-241 to publicly available data on land use and building characteristics based on addresses provided in San Francisco’s 2023 Tax Assessor roll2 and 2022 Land Use inventory.3 We then used these parcels to add characteristics about each water meter from the CCSF Assessor-Recorder Department and land use data, as well as historical weather data from the Oregon State University’s PRISM dataset, US Census block -group characteristics and tract characteristics from the 2019-2023 ACS five- year estimates, and e mployment and household projections provided by SF Planning.

San Francisco’s public agencies do not keep a data key that links information between the parcel identifiers in the Tax Assessor’s records and the account numbers used in the SFPUC’s records.

Therefore, to merge assessor information into our dataset, we matched accounts based on their reported addresses. Due to inconsistencies in address reporting between the two datasets, we could not match all records; however, we managed to match over 95 % of all accounts. Based on a comparison of summary statistics between all accounts and only matched summary statistics, these accounts appear to be a representative sample, and therefore, we are confident using these data as the basis for our projection model.

We use climate data from California’s Fourth Climate Change Assessment (data retrieved from Cal- Adapt, a climate adaptation planning tool developed by UC Berkeley with support from the California

1 In FY 2023-24, a technical problem led to some customers not receiving a water and sewer bill for several months. The problem was caused by certain transponders on water meters. The water meters were accurately reading the water usage, but the transponders were not sending that data electronically to the SFPUC’s billing system. As a result, while these customers continued to receive water and sewer service, they did not receive bills for a period of time. This caused raw billing consumption data for FY 2023-24 to be artificially lower (by about 0.4 mgd) than actual demands. To correct this error, the SFPUC has manually added the delayed consumption to the FY 2023-24 billing data to more accurately reflect usage during this period.
2 Property assessment data. SF.gov. https://www.sf.gov/resource--2024--secured-property-tax-data 3 2022 San Francisco Housing Inventory. https://sfplanning.org/sites/default/files/documents/reports/2022_Housing_Inventory.pdf

8 Energy Commission).4,5 This dataset gathers climate observations from a wide range of monitoring networks, applies sophisticated quality control measures, and develops spatial climate datasets to reveal short- and long-term climate patterns. Climate data uses Representative Concentration Pathway

4.5, which is "a 'medium' emissions scenario that models a future where societies attempt to reduce greenhouse gas emissions" (Pierce et. al). We use a dataset of monthly average temperature and precipitation at a resolution of 1/16° (about 6 km, or 3.7 miles) . These dataset’s spatial resolution allow us to identify microclimates at a high spatial resolution within San Francisco and identify how these microclimates affect water use.

From the assessor’s parcel data, we can match each account with the land use category of the property on which it lies.

The San Francisco Assessor’s dataset includes land use classifications and the North American Industry Classification System (NAICS) codes used for business and tax registration. We aggregate these NAICS codes into five broader categories — Office/Professional, Health/Education/Recreation, Manufacturing/Wholesale, Retail, and Other. These aggregated categories can then be linked to local em ployment projections produced by ABAG to support projections of future water demand by sector.

Consumption data is also matched with past water rate data (FY 2023-24) and projected rate increases out to 2050, which were provided by the SFPUC Financial Services.6 Rate data used in our analysis are adjusted for inflation to 2025 dollars using consumer price index (CPI) data from the St. Louis Federal Reserve’s Economic Data (FRED).7

2.1.2 Remove Water Conservation Policy from Raw Data
In addition to the fundamental determinants, we also explicitly adjust the projected demand based on expected future water conservation from active water conservation programs and non-potable onsite water reuse programs administered by the SFPUC. This approach of explicitly accounting for active conservation programs in demand projections has been advocated as best practice by local researchers and advocacy groups.8 However, explicitly adjusting for water conservation introduces

4 https://cal-adapt.org/
5 Pierce et al. (2018). Climate, drought, and sea level rise scenarios for California's fourth climate change assessment. California’s Fourth Climate Change Assessment, California Energy Commission. Publication Number: CNRA-CEC-2018-006. 6 The price elasticity estimates in this report are based on historical marginal volumetric water rates only. For each account and billing period, the econometric model identifies the applicable marginal Tier 1 or Tier 2 water rate corresponding to the customer’s actual consumption.

Consistent with the methodology adopted in the previous demand projection study, the historical price variable did not incorporate wastewater, nor did it include fixed service charges. However, during the review process, SFPUC highlighted that future wastewater and stormwater rate increases are expected to diverge materially from water-only increases (particularly given the phased introduction of the stormwater charge through FY 2029-30). Although the historical price elasticity was estimated using water-only marginal rates, the projection component of this study incorporates the updated water, wastewater and increases from the FYE 2026 Financial Plan, applying only the volumetric wastewater rate changes (SIC Group 4) and excluding fixed stormwater charges. This adjustment ensures that projected average customer bills reflect the anticipated relative growth in wastewater rates while maintaining consistency with the historical estimation framework based on marginal volumetric water prices.
7 U.S. Bureau of Labor Statistics, Consumer Price Index for All Urban Consumers: All Items (CPI-U) [CPIAUCSL], retrieved from FRED, Federal Reserve Bank of St. Louis; https://fred.stlouisfed.org/series/CPIEALL, October 15, 2025. 8 See, for example: Sarah E. Diringer, Heather Cooley, Matthew Heberger, Rapichan Phurisamban, Andrea Turner, John McKibbin, and Mary Ann Dickinson, “Integrating Water Efficiency Standards and Codes into Long-Term Demand Forecasting,” Water Research Foundation (2018); Sonali Abraham, Sarah Diringer, and Heather Cooley, An Assessment of Water Demand Forecasts in California, 2020 (Oakland, California: Pacific Institute).

9 some challenges into the demand estimation process. Specifically, care needs to be taken not to double-count savings from conservation programs with consumers’ responses to rates, drought, and climate. To do this, we adjust our historical data by adding back in the savings that the SFPUC estimates have been generated as a result of their active conservation programs. These savings are calculated using SFPUC’s customized version of the Alliance for Water Efficiency Conservation Tracking Tool.

Savings for water conservation are calculated at an aggregate level by sector, but we split these savings down to the household level by calculating the share of conservation attributable to each household and adding these savings back onto each household’s daily water use. 9 After adding these savings back in, we derive an estimate of “pre -conservation” demand, which describes what demand would have been but-for the SFPUC’s conservation programs. We estimate our statistical demand model and predict demand based on this “pre-conservation” data.

Future demand reductions from onsite water reuse programs are also incorporated into the multi- family and commercial sector models. Estimates of savings from onsite water reuse programs were provided by the SFPUC staff and are subtracted from the raw demand projections.

In the last step of our analysis, we add back in the active conservation savings and savings from non- potable onsite water reuse programs to generate the final demand estimate.

2.2. Econometric Model
For consistency, the methodology employed in this update remains the same as that used in the previous demand projection report included in the 2020 UWMP.

To predict how water demand in the SFPUC’s retail service area will change over time, it is necessary to estimate a relationship between water use and the demand factors used in this analysis (e.g., rates and climate). Generally, water use and water price are negatively correlated. In other words, as water becomes more expensive, users will reduce their demands to offset the higher costs. As temperature increases or precipitation decreases, water demand is expected to increase.

For each account, we estimate the relationship between water use and these demand factors using a regression analysis with account-level fixed effects. In a regression analysis, changes in the explanatory variable, customer water use, are explained by the dependent variables, such as rates, climate, and macro-economic factors. In a regression with account -level fixed effects, we also control for the average level of water consumption for every premise in the in-City retail service area. All explanatory variables in our empirical model are estimated in natural logarithms, which allows us to interpret their corresponding regression coefficients as elasticities.

9 Although we make explicit adjustments for active water conservation programs, demand for which is driven by SFPUC outreach, we do not make a similar adjustment for passive water saving. Passive water savings are primarily driven by consumers taking water-saving actions in response to changes in rates and so are implicitly accounted for in our demand elasticity estimates. Including an explicit adjustment for these savings would risk double-counting and underestimating future water use.

10 An elasticity is the relationship between a variable, such as price, and water demand, which is calculated and interpreted as the percent change in water demand for a given percent change in the variable, water price. For example, a price elasticity of -0.2 implies that users reduce water demand by

0.2% for each 1% increase in price. We estimate similar elasticities with respect to elements of climate such as temperature and precipitation. These elasticities can be used to estimate the impact of anticipated future climate change.

To estimate demand for single family and multi-family water use, we estimate the following equation, ln(𝑞𝑞
𝑖𝑖𝑖𝑖 ) = ln(𝑟𝑟𝑟𝑟𝑟𝑟𝑒𝑒𝑖𝑖 ) 𝛽𝛽𝑟𝑟𝑟𝑟𝑖𝑖𝑟𝑟 + ln(𝑟𝑟𝑒𝑒𝑡𝑡𝑝𝑝𝑖𝑖 ) 𝛽𝛽𝑖𝑖𝑟𝑟𝑡𝑡𝑡𝑡 + ln(𝑝𝑝𝑝𝑝𝑟𝑟𝑖𝑖𝑖𝑖 ) 𝛽𝛽𝑡𝑡𝑡𝑡𝑖𝑖 + 𝛾𝛾𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 + 𝛾𝛾𝑑𝑑𝑟𝑟𝑑𝑑ℎ𝑖𝑖 + 𝛾𝛾𝑖𝑖 + 𝜀𝜀𝑖𝑖𝑖𝑖 Where, the dependent variable, ln (𝑞𝑞𝑖𝑖𝑖𝑖), is the natural logarithm of household 𝑖𝑖’s pre-conservation water consumption in month t. Dependent Variables:
• Monthly Rate 𝑟𝑟𝑟𝑟𝑟𝑟𝑒𝑒𝑖𝑖 : The volumetric rate paid by households in each month. Rates are expressed as a Real Rate Index (year 2023 = 100), which adjusts nominal rates for inflation to enable consistent comparisons over time. An index value of 100 represents the average 2023 rates; values below 100 indicate lower inflation-adjusted rates, while values above 100 indicate higher inflation-adjusted rates.
• Weather
𝑟𝑟𝑒𝑒𝑡𝑡𝑝𝑝𝑖𝑖 and 𝑝𝑝𝑝𝑝𝑟𝑟𝑖𝑖𝑖𝑖 : We obtain panel of modelled climate characteristics of 1/16° (about 6 km, or 3.7 miles) from Cal-Adapt. We control each month’s average precipitation and mean temperature.
• Drought10 and COVID-19 Emergencies11 𝛾𝛾𝑑𝑑𝑟𝑟𝑑𝑑ℎ𝑖𝑖 and 𝛾𝛾𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶: We include fixed-effect dummy variables that take a value of 1 during periods of declared drought or COVID-19 emergency, and 0 otherwise. These variables capture temporary impacts on demand during those events. Both factors are not included in the projecti on period, as the projection assumes normal (non- emergency) conditions.
• Individual Fixed Effects 𝛾𝛾
𝑖𝑖: Using this high-resolution data, we can control the average level of water use for each account in our data. Adjusting the average level of our water use within each household allows us to estimate how an individual account responds to changes in rates, precipitation, and temperature, rather than basing the estimates on differences in average water use across accounts at a point in time.
• Idiosyncratic error term 𝜀𝜀𝑖𝑖𝑖𝑖: This term is standard in statistical regression analysis and is used to rationalize unexplained variation in the model. The model coefficients 𝛽𝛽 are chosen to minimize idiosyncratic errors. The variance of 𝜀𝜀𝑖𝑖𝑖𝑖 is a key factor that is used to calculate the 95% confidence interval that characterizes the uncertainty associated with the model’s

10 The drought variable in the model was defined based on the SFPUC’s Drought Emergency Declarations, covering February 2014 to April 2017 and November 2021 to April 2023.
11 The COVID variable in the model was defined based on San Francisco’s municipal COVID-19 restrictions, which were in effect between March 2020 and December 2022.

11 parameters estimates 𝛽𝛽. We adopt two-way cluster-robust method, clustered at the census block-group and year level to account for unexplained correlations in water use either within years or within neighborhoods.

To estimate demand for commercial and industrial accounts, we use the following equation:
ln(𝑞𝑞𝑖𝑖𝑖𝑖𝑖𝑖 ) = ln(𝑟𝑟𝑟𝑟𝑟𝑟𝑒𝑒𝑖𝑖 ) 𝛽𝛽𝑖𝑖
𝑟𝑟𝑟𝑟𝑖𝑖𝑟𝑟 + ln(𝑟𝑟𝑒𝑒𝑡𝑡𝑝𝑝𝑖𝑖𝑖𝑖 ) 𝛽𝛽𝑖𝑖𝑟𝑟𝑡𝑡𝑡𝑡 + ln(𝑝𝑝𝑝𝑝𝑟𝑟𝑖𝑖𝑖𝑖 ) 𝛽𝛽𝑡𝑡𝑡𝑡𝑖𝑖 + 𝛾𝛾𝑖𝑖 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 + 𝛾𝛾𝑑𝑑𝑟𝑟𝑑𝑑ℎ𝑖𝑖 + 𝛾𝛾𝑖𝑖 + 𝜀𝜀𝑖𝑖𝑖𝑖
This specification is the same as for the residential model, except the key differences is that the parameter estimates for rates 𝛽𝛽𝑖𝑖
𝑟𝑟𝑟𝑟𝑖𝑖𝑟𝑟 and for COVID-19 𝛾𝛾𝑖𝑖
𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 are allowed to vary by land use with a
different parameter being chosen in each different type of land use in the commercial and industrial sector.

2.3. Projection Data

2.3.1 Projection Assumptions
Table 2-1 and Table 2-2 summarize the assumptions that we adopt in our projections. Assumptions about growth in the number of single family and multi-family units come from SF Planning.12 Note that all future residential growth is expected to be in the multi-family sector, with no growth expected for single family units. Assumptions for the number of employees by sector are from the UWMP out to the year 2050. Assumptions about future climate are based on the average of outcomes across multiple climate models.

12 2023 San Francisco Housing Inventory, SF Planning. https://sfplanning.org/sites/default/files/resources/2024- 04/2023_Housing_Inventory.pdf

12 Table 2-1: Demand Projection Assumptions – Housing Unit and Employment Growth FY 2024-25
(Actual)
FY 2029-30 FY 2034-35 FY 2039-40 FY 2044-45 FY 2049-50
No. Housing Units Single Family Residential 95,071 95,071 95,071 95,071 95,071 95,071 Multi-Family Residential 322,753 363,262 388,529 413,929 438,929 463,929 Total 432,667 458,333 483,600 509,000 534,000 559,000 No. Employees Office/Professional 155,250 171,672 174,515 182,850 188,458 198,470 Health/Education/Recreation 306,304 338,704 344,313 360,758 371,822 391,575 Manufacturing/Wholesale 34,766 38,444 39,081 40,947 42,203 44,445 Retail 25,775 28,502 28,974 30,357 31,288 32,951 Other 203,204 224,698 228,419 239,329 246,668 259,773 Total 725,300 802,020 815,302 854,241 880,439 927,214

Table 2-2: Demand Projection Assumptions- Covariates
FY 2024-25
(Actual)
FY 2029-30 FY 2034-35 FY 2039-40 FY 2044-45 FY 2049-50
Real Rate Index (2023 = 100) 100 143 189 199 205 204
Monthly Average Temperature ( °C) 14.7 14.8 15.0 15.1 15.2 15.4 Monthly Average Precipitation (mm) 46.0 46.9 48.3 46.8 47.8 49.4 COVID-19 0.0 0.0 0.0 0.0 0.0 0.0
Drought 0.0 0.0 0.0 0.0 0.0 0.0

13 2.3.2 Econometric Projections
The econometric model that we use in the single family and multi-family sectors is estimated on a per- unit basis, and our projections are also on a per-unit basis. Characteristics and fixed-effects for existing accounts are estimated from our data. For new multi-family residential and commercial and industrial accounts, we simulate firm fixed-effects. Based on these individual effects, we estimate individual level demand using the following equation:
𝑞𝑞𝚤𝚤𝑖𝑖� = 𝑒𝑒ln(𝑟𝑟𝑟𝑟𝑖𝑖𝑟𝑟𝑡𝑡)𝛽𝛽𝑟𝑟𝑟𝑟𝑡𝑡𝑟𝑟+ln(𝑖𝑖𝑟𝑟𝑡𝑡𝑡𝑡𝑖𝑖𝑡𝑡)𝛽𝛽𝑡𝑡𝑟𝑟𝑡𝑡𝑡𝑡� +ln(𝑡𝑡𝑡𝑡𝑖𝑖𝑖𝑖𝑡𝑡)𝛽𝛽𝑡𝑡𝑡𝑡𝑡𝑡�+𝛾𝛾𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶� +𝛾𝛾𝑑𝑑𝑟𝑟𝑑𝑑ℎ𝑡𝑡� +𝛾𝛾𝑖𝑖 Once we have calculated individual-level demand for each account, we calculate total demand by aggregating each of the individual estimates in our data:

𝑄𝑄𝚤𝚤𝑖𝑖� 𝑅𝑅𝑟𝑟𝑅𝑅
= � 𝑞𝑞𝑖𝑖𝑖𝑖
𝑖𝑖

2.3.3 Reincorporating Conservation Estimates and Other Demand Adjustments
The final steps of the projection process are to (1) subtract the estimated savings from active conservation programs and non-potable onsite reuse programs, as well as (2) add the additional residential and commercial/industrial demands not covered in our model. Specifically, this includes residential and non -residential fire accounts, docks and ship s accounts, and builder/contractor accounts. The projections for these accounts are outside of our model and were developed by the SFPUC. Note that this econometric model does not project other sectors of water use, including water losses, dedicated irrigation accounts, municipal accounts, and suburban retail accounts.

𝑄𝑄𝑖𝑖�𝐹𝐹𝑖𝑖𝐹𝐹𝑟𝑟𝐹𝐹
= 𝑄𝑄𝑖𝑖�𝑅𝑅𝑟𝑟𝑅𝑅
− 𝑄𝑄𝐶𝐶𝐶𝐶𝐹𝐹𝐶𝐶𝑟𝑟𝑟𝑟𝐶𝐶𝑟𝑟𝑖𝑖𝑖𝑖𝐶𝐶𝐹𝐹 + 𝑄𝑄𝐶𝐶𝑖𝑖ℎ𝑟𝑟𝑟𝑟

3 Single Family Residential Projection

3.1. Model Estimates
Table 3-1 summarizes the estimates of the demand model for the single family residential sector. The model fits the data well due to account-level fixed effects that adjust for the average level of water use of every household. Specifically, the model has an R-squared value of 0.67, implying that our estimate explains 67% of the total variation in demand. This represents a strong model fit and is consistent with the R-squared value reported in the 2020 analysis.

14 Across all units in the sample, we estimate a price-elasticity of demand of -0.12. This elasticity implies that a 10% increase in water rates will lead to a 1.2% reduction in demand. This estimate is statistically significant and has a confidence interval from -0.17 to -0.08. Note that the SFPUC charges two tiers of variable rates and a fixed rate. The demand elasticity estimate is with respect to the two tiers of variable rates, but not the fixed rate.

We estimate an elasticity of demand with respect to temperature of 0.1 0 and with respect to precipitation of -0.0067. This estimate implies that a 10% increase in average temperature will lead to a 1.0% increase in demand, and that a 10% increase in precipitation will lead to a 0.067% decrease in demand. These estimates are also both statistically significant. The difference between these coefficients and those estimated in the 2020 report is not statistically significant.

During COVID-19 restrictions (2020-2022), single family residential water demand is estimated to be

2.6% lower; however, this effect is not statistically significant.13 Based on the patterns of water use in our data, we predict that during periods of drought single family residential water demand is 8.3% lower and this effect is statistically significant.14 Following the COVID-19 pandemic, water sales declined more rapidly than population and did not rebound following the end of the 2021-23 drought, suggesting a secular decline in water use due to more efficient consumption incentivized by both the drought and other conservation programs).

Table 3-1: Model Estimates – Single Family Residential Sector Coefficient 95% Confidence
Interval
Change in Consumption from 10%
Predictor Change
log(Marginal Rates) -0.12 [-0.17, -0.08] -1.2%
log(Temperature) 0.10 [0.02, 0.18] 1.0%
log(Precipitation) -0.007 [-0.012, -0.001] -0.07%
Change in Consumption from
Predictor Event
COVID-19 -0.026 [-0.06, 0.01] -2.6%
Drought -0.09 [-0.11, -0.06] -8.3%
Account Fixed-Effects Yes
R-squared 0.67

3.2. Demand Projection

13 The estimate COVID-19 coefficient differs from that estimated in our 2020 demand projections, which estimated a 9.3% increase in single family residential water use during COVID-19. The earlier report was based on data through July 2020 and reflected increased consumption during initial stay-at-home orders. The current coefficient captures the average effect across the entire pandemic (2020-2022), including both the initial increase and subsequent decline as San Francisco experienced significant population outmigration. 14 In the model drought periods are defined based on SFPUC drought declarations, which occurred from February 2014 to April 2017 and from November 2021 to April 2023. This model estimates a smaller drought coefficient than the previous report (-0.03 in 2025 compared to -0.13 in 2020). The reason for this is that water consumption showed little rebound following the end of the drought in April 2023, suggesting that the observed declines in water use represent secular reductions in average consumption rather than temporary drought-related impacts.

15 Table 3-2 summarizes our demand projection for the single family residential sector. The SF Planning Department does not anticipate any growth in San Francisco’s single family housing stock through FY 2049-50, keeping the inventory constant at 95,071 units. The projection is calibrated to FY 2024-25 consumption levels, where total demand was 12.6 MGD or 145.1 gallons per occupied unit per day and incorporates an 8.6% vacancy rate based on the latest estimate from the California Department of Finance. SFPUC’s conservation model indicates that active conservation programs will reduce single family demand by approximately 0.1 MGD by 2050. After accounting for these savings, total single family demand is projected to rise by 3.2% or to 13.0 MGD due to full occupancy of all units. On a per unit basis, however, average consumption is expected to decline by 5.7% or to 136.8 gallons per day by FY 2049-50.

16 Table 3-2: Demand Projection – Single Family Residential Sector FY 2024-25
(Actual) FY 2029-30 FY 2034-35 FY 2039-40 FY 2044-45 FY 2049-50 Number of Units 95,071 95,071 95,071 95,071 95,071 95,071 Residents per Unit

2.2 2.2 2.2 2.2 2.2 2.2
Avg. Consumption per Unit (gal / day)
Unadjusted Baseline Demand 145.1 141.1 138.2 137.7 137.5 137.7 Conservation Active 0.0 -1.0 -1.1 -1.0 -0.9 -0.9
Demand per Unit 145.1 140.1 137.0 136.7 136.6 136.8
Projection - Total Consumption (MGD)
Unadjusted Baseline Demand 12.6 13.4 13.1 13.1 13.1 13.1 Conservation Active 0.0 -0.1 -0.1 -0.1 -0.1 -0.1
Total Demand 12.6 13.3 13.0 13.0 13.0 13.0

Notes: Minor ‘inconsistencies’ in subtotal are result of rounding significant figures .

17 4 Multi-Family Residential Demand Projection

4.1. Model Estimates
Table 4-1 summarizes the estimates of the demand model for the multi-family residential sector. Note that projections are made on a per-unit rather than per-account basis, this distinction is important in the multi-family residential sector, where many accounts serve multiple units. The model has good fit to the data, with an R-squared value of 0.7, implying that our estimate explains 70% of the total variation in demand.

Across all units in the sample, we estimate a price-elasticity of demand of -0.14. This elasticity implies that a 10% increase in rates will lead to a 1.4% reduction in demand. This estimate is statistically significant and has a confidence interval from -0.16 to -0.11. Note that SFPUC charges two tiers of variable rates and a fixed rate. The demand elasticity estimate is with respect to the two tiers of variable rates, but not the fixed rate.

We estimate an elasticity of demand with respect to temperature of 0.03 and with respect to precipitation of -0.0014. This estimate implies that a 10% increase in average temperature will lead to a 0.3% increase in demand, and that a 10% increase in precipitation will lead to a 0.014% decrease in demand. The difference between the temperature coefficients estimated now and in the 2020 report is statistically significant; but that of precipitation is not. The temperature elasticity has moved closer to zero, suggesting that demand has become less responsive to temperature over time, consistent with demand hardening.

During periods with COVID-19 restrictions (2020-2022), multi-family residential water demand is estimated to be 1.4% higher; however, this effect is not statistically significant. During a drought, multi-family residential water demand is estimated to be 1.9% lower, and this effect is also not statistically significant. Similarly to what’s observed in the SFR sector, water sales declined more rapidly than population following the COVID-19 pandemic, likely due to more efficient water consumption (incentivized by the 2020-2022 drought or other conservation programs).

18 Table 4-1: Model Estimates – Multi-Family Residential Sector Coefficient
95% Confidence
Interval
Change in Consumption from
10% Predictor Change
log(Marginal Price) -0.14 [-0.16, -0.11] -1.4%
log(Temperature) 0.03 [0.01, 0.05] 0.3%
log(Precipitation) -0.001 [-0.002, -0.001] -0.01%
Change in Consumption from
Predictor Event
COVID-19 0.01 [-0.01, 0.04] 1.4%
Drought -0.02 [-0.03, -0.01] -1.9%
Account Fixed-Effects Yes
R-squared 0.70

4.2. Demand Projection
Table 4-2 summarizes the multi-family residential demand projection. The SF Planning Department expects growth in the stock of multi-family residential units to increase by 43.7% or from 322,753 units in FY 2024-25 to 463,929 units in FY 2049-50.15 The projection is calibrated to FY 2024-25 consumption levels, where total demand was 22.2 MGD or 75.4 gallons per occupied unit per day and incorporates an 8.6% vacancy rate based on the latest estimate from the California Department of Finance. After accounting the anticipated effects of active conservation programs and non -potable onsite reuse systems, average per-unit water demand in the multi-family sector is projected to decline from 75.4 gallons per unit per day in FY 2024-25 to 69.4 gallons per unit per day in FY 2049-50.

Because of the substantial increase in the number of multi -family units, total unadjusted baseline demand is expected to rise. Active conservation programs and the implementation of non-potable onsite reuse systems are expected to reduce water use by about 0.3 MGD by FY 2049-50. After accounting for these conservation savings, total multi-family demand is projected to increase by 45% or from 22.2 MGD in FY 2024-25 to 32.2 MGD due to full occupancy of all units. On a per unit basis, however, average consumption is expected to decline by 8.0% or to 69.4 gallons per day by FY 2049-

50. 15 SFPUC. 2023 Interim Water Demand Projections for the City and County of San Francisco. September 2023. 19 Table 4-2: Demand Projection – Multi-Family Residential Sector FY 2024-25 FY 2029-30 FY 2034-35 FY 2039-40 FY 2044-45 FY 2049-50 Number of Units Existing 322,753 322,753 363,262 388,529 413,929 438,929 New -- 40,509 25,267 25,400 25,000 25,000
Total 322,753 363,262 388,529 413,929 438,929 463,929
Residents per Unit 2.2 2.2 2.2 2.2 2.2 2.2
Avg. Consumption per Unit (gal / day)
Unadjusted Baseline Demand 75.4 72.5 70.4 70.0 69.8 69.8 Conservation Active 0.0 -0.2 -0.2 -0.2 -0.1 -0.1
Non-Potable / Onsite Reuse 0.0 -0.2 -0.4 -0.4 -0.4 -0.3 Demand per Unit 75.4 72.1 69.7 69.4 69.3 69.4
Projection - Total Consumption (MGD)
Unadjusted Baseline Demand 22.2 26.3 27.3 29.0 30.6 32.4 Conservation Active 0.0 -0.1 -0.1 -0.1 -0.1 -0.1
Non-Potable / Onsite Reuse 0.0 -0.1 -0.2 -0.2 -0.2 -0.2 Total Demand 22.2 26.2 27.1 28.7 30.4 32.2
Notes: Minor ‘inconsistencies’ in subtotal are result of rounding significant figures 20 5 Commercial and Industrial Demand Projection

5.1. Model Estimates
Table 5-1 summarizes the estimates of the demand model for the commercial and industrial sectors.

Note that we project on a per-unit account basis, but we present our results on a per-employee basis, as this is the input data into our projection model. The model has good fit to the data, with an R-squared value of 0.87, implying that our estimate explains 87% of the total variation in demand.

We estimate five price elasticities, varying from -0.16 in the Manufacturing/Wholesale sector to -0.34 in the Health/Education/Recreation sector. These elasticities imply that a 10% increase in water rates will lead to a reduction in demand between 1.6% and 3.4%, respectively. In general, unlike the residential sector, these elasticities are larger in magnitude compared to the 2020 analysis — that is, C&I sector remains more sensitive to price signals. We further estimate that these demand elasticities are statistically significant in the Office/Professional, Health/Education/Recreation, and Other sectors, but not in the Retail and Manufacturing/Wholesale sectors.16 We estimate an elasticity of demand with respect to temperature of 0.1 5 and with respect to precipitation of 0.00. This estimate implies that a 10% increase in average temperature will lead to a

1.5% increase in demand, and that changes in precipitation do not have a statistically or economically significant impact on demand.

The COVID-19 pandemic led to a statistically significant reduction in average water use among commercial and industrial customers of between 8.9% to 24.2% depending on the sector. We do not find a statistically significant impact of drought on commercial and industrial water use in San Francisco.
16 Our estimates are deemed to be statistically significant if the estimated 95% confidence interval does not include zero. If the estimated 95% confidence interval does include zero, the estimates are considered to not be statistically significant. Note that to obtain the best-fit model, we include all variables in our projections, regardless of whether or not they are statistically significant.

21 Table 5-1: Model Estimates – Commercial and Industrial Sector Coefficient
95% Confidence
Interval
Change in Consumption
from 10% Predictor Change
log(Marginal Price): Office/Professional -0.32 [-0.47, -0.18] -3.2% log(Marginal Price): Health/Education/Recreation -0.34 [-0.47, -0.21] -3.4% log(Marginal Price): Manuf./Wholesale/Trade/Trans. -0.16 [-0.28, -0.04] -1.6% log(Marginal Price): Other -0.31 [-0.46, -0.16] -3.1%
log(Marginal Price): Retail -0.31 [-0.44, -0.18] -3.1%
log(Temperature) 0.15 [0.08, 0.22] 1.5%
log(Precipitation) 0.00 [-0.004, 0.003] 0.00%
Change in Consumption
from Predictor Event
COVID-19: Office/Professional -0.21 [-0.31, -0.11] -18.7% COVID-19: Health/Education/Recreation -0.24 [-0.37, -0.11] -21.4% COVID-19: Manuf./Wholesale/Trade/Trans. -0.12 [-0.21, -0.04] -11.6% COVID-19: Other -0.09 [-0.16, -0.02] -8.9%
COVID-19: Retail -0.28 [-0.43, -0.13] -24.2%
Drought -0.002 [-0.06, 0.06] -0.2%
Account Fixed-Effects Yes

R-squared 0.87

5.2. Demand Projection
Table 5-2 summarizes the commercial and industrial demand projection. The SF Planning Department projects that the City will experience significant employment growth of 27.8%, where the number of jobs will increase from 725,300 in FY 2024-25 to 927,214 in FY 2049-50. The projection is calibrated to match total commercial and industrial consumption in FY 2024-25, which was 12.4 MGD where per- employee demand was 16.9 gallons per day. Active conservation programs and non-potable onsite reuse systems are expected to reduce commercial and industrial water use by 1.8 MGD in FY 2049-50.

With conservation, commercial and industrial water use is projected to decline by 13.7% or from 12.4 MGD in FY 2024-25 to 10.7 MGD in FY 2034-35 before rising by 14.0% or to 12.2 MGD in FY 2049-50.

On a per-employee basis, average water use is expected to decline by 21.9% or to 13.2 gallons per day, which is partially offset by growth in total employment.

22 Table 5-2: Demand Projection – Commercial and Industrial Sector FY 2024-25
(Actual)
FY 2029-30 FY 2034-35 FY 2039-40 FY 2044-45 FY 2049-50
Number of Employees 725,300 802,020 815,302 854,241 880,439 927,214 Avg. Consumption per Employee (gal / day)
Unadjusted Baseline Demand 1 7 .1 16.0 15.3 15.1 15.1 15.1 Conservation Active 0.0 -0.4 -0.6 -0.5 -0.4 -0.4
Non-Potable / Onsite Reuse -0.2 -0.7 -1.6 -1.6 -1.6 -1.6 Demand per Employee 16.9 14.9 13.1 13.0 13.0 13.2
Projection - Total Consumption (MGD)
Unadjusted Baseline Demand 12.6 12.9 12.4 12.9 13.3 14.0 Conservation Active 0.0 -0.4 -0.5 -0.4 -0.4 -0.4
Non-Potable / Onsite Reuse -0.2 -0.5 -1.3 -1.4 -1.4 -1.4 Total Demand 12.4 12.0 10.7 11.1 11.5 12.2
N
otes: Minor ‘inconsistencies’ in subtotal are result of rounding significant figures

23 6 Comparison to 2020 and 2015 Demand
Projections
Figure 6-1 compares the 2025 Demand Projection to the demand projections developed for the UWMPs in 2020 and 2015. The 2020 UWMP projection was produced using the same methodology as the 2025 projection—an econometric model of household-level water use for customers within the City and County of San Francisco—whereas the 2015 projection was based on utility-level econometric model that compared water use between San Francisco and other Bay Area utilities. As noted previously, these demand projections are for single family residential, multi -family residential, commercial, and industrial sectors and does not include other retail demands such as water losses, dedicated irrigation, municipal, or suburban retail accounts.

Figure 6-1: Comparison of Demand Projections from 2025, 2020, and 2015 UWMPs

Several key factors account for the lower projection of water use developed in 2025 relative to projections developed in 2020 and 2015:
• Lower per-capita water use: The 2025 projection incorporates more recent data with lower baseline per-capita water use than was included in the 2015 and 2020 analyses, contributing to lower projected total demand. Per-capita water use is 9% lower compared to that of the 2020

24 analyses (baseline year: 2019), and 17% lower than that of the 2015 analyses (baseline year:
2009).
• Higher water conservation: Projected water conservation is slightly higher (about 5% higher in terms of cumulative volume over the projection period) in 2025 than was predicted in the conservation model from 2020.
• Lower population and employment: Projected population and employment is lower in 2025 relative to that projected in the 2020 projections, for example, the projected number of employees in 2025 is 3% lower in 2025 than that in the 2020 analysis. • Drought and pandemic adjustments: Upward adjustments were made to the baseline water use projections in 2015 and 2020 to remove the temporary effects of the ongoing drought and the COVID-19 pandemic, respectively, from observed water use data. As a result, projected water use in those years was higher than the historical data. The 2025 projection does not include any such adjustments.

The 2025 projection assumes modest declines in per -capita water use —consistent with past projections—but incorporates increases in population and employment that offset these declines, resulting in an overall increase in total water demand. Retail demands are projected to decrease from

62.5 MGD to 58.8 MGD in FY 2034-35 primarily due to larger rate increases expected in the near-term.

From FY 2034-35 to FY 2049-50, demands are anticipated to increase to 73.4 MGD due to growth in housing unit and employment projections outpacing rate increases. To test the robustness of the projection to alternative assumptions about population and employment growth, Appendix A to this report contains a sensitivity analysis that evaluates how projected demand changes under projections from alternative data sources.
7 Conclusion
The 2025 demand model updates the 2020 demand model using the latest billed consumption data.

Using FY 2024-25 consumption as a baseline, the model calibrates residential use with an estimated vacancy rate of 8.6% from the California Department of Finance and then assumes full occupancy beginning in FY 2029-30 to reflect the SFPUC’s capacity to serve all future households. Under these conditions, single family demand rises modestly from 12.6 MGD to 13.0 MGD despite no increases in unit count, driven by the assumption of full occupancy with some declines in average consumption per household. Multi-family demand grows more substantially due to the addition of new housing and the assumption of full occupancy, yet per unit consumption also trends downward. In the commercial and industrial sectors, demand remains relatively stable through FY 2049-50, even though there is projected employment growth. This is because water use per employee is expected to fall and because conservation and onsite water reuse savings play a larger role than in the residential sectors combined.

25 Citywide demand increases through FY 2029-30 and decreases in FY 2034-35 due to near-term rate impacts and anticipated conservation savings based on known programs. Demand then gradually rises again as long -term growth in housing and employment become the dominant driver. Despite this growth, continued improvements in water efficiency keep projected demands lower than in past projections. Together, these trends illustrate a system in which expanding population and economic activity are balanced by sustained gains in efficiency.

26 A. Appendix A: Discussion of Assumptions for
Demand Projection and Sensitivity Analysis
This appendix contains further discussion of how the key assumptions used in the demand projections for the 2025 UWMP were developed. It also presents two additional demand scenarios based on alternative assumptions regarding housing and employment growth.

The following scenarios were developed by SFPUC staff in collaboration with Berkeley Research Group, WestWater Research, and Woodard & Curran. The narrative in this section was primarily prepared by SFPUC staff and reflects the collective discussions held among SFPUC and the consultant team. While the text wa s drafted by SFPUC, the authors of this report support the analytical framework and assumptions underlying this work.

A. Purpose
The SFPUC routinely updates its 20-year demand projections as part of its water supply planning.

Included in this effort is the UWMP, which is updated every five years and must reflect local land use planning. As such, the housing and employment growth projections in the UWMP are provided to the SFPUC by SF Planning. The water demand projections which are published in the UWMP are referred to as the “UWMP Scenario”.

In 2019, the SFPUC established the Alternative Water Supply (AWS) Program to help meet future dry- year needs. The roadmap for this program is laid out in the AWS Plan (February 2024). During the development of this plan, the SFPUC received several public c omments asking the agency to (1) develop additional demand scenarios and (2) conduct a sensitivity analysis similar to what the Bay Area Water Supply and Conservation Agency (BAWSCA) produced in their 2022 Regional Water Demand and Conservation Projections Update.17 The nature of these comments reflected the general observation across all water suppliers, not just SFPUC, that demand projections provided in the Urban Water Management Plans tend to be higher than actual demands. In response to these comments, the SFPUC included a recommendation in the AWS Plan to develop one to two additional demand scenarios and to conduct a sensitivity analysis. This memo documents the sensitivity analysis and development of the additional demand scenarios which will be used for future water supply planning and incorporated in the next AWS Plan Update (anticipated to begin following completion of the 2025 UWMP).

B. Scope of the Sensitivity Analysis
The SFPUC produces water demand projections for its retail service area, which includes both in-City and suburban demand. To determine future demands for the majority of accounts —in-City single family residential, multi -family residential, commercial, and industrial accounts —the SFPUC uses an econometric model that estimates the relationship between water consumption and demand factors (e.g.,

17 https://bawsca.org/uploads/userfiles/files/BAWSCA%202022%20Demand%20Study%20Update%20Final%20Report(1).pdf

27 rates, temperature, precipitation). This relationship is estimated for each household or business account using multiple regression analysis with account-level fixed effects.

Each variable used in the econometric model was evaluated for potential inclusion in the sensitivity analysis. Then, the sensitivity analysis examined the relative impact on demand from using one data source compared to another. For example, the sensitivity analysis estimates how much water demand changes if an additional 5% increase in water savings was assumed on top of the SFPUC’s c onservation model output. Additionally, the SFPUC closely reviewed the sensitivity analysis described in BAWSCA’s 2022 Regional Water Demand and Conservation Projections Update for additional variables to consider. This section describes all the variables and corresponding source data options considered in SFPUC’s sensitivity analysis.

Lastly, there are various types of demands that are not projected by an econometric model and instead are projected using estimates based on historical consumption or assumed to remain steady over time. These other types of demand that are not modeled include dedicated irrigation accounts, municipal accounts, suburban retail accounts, and water losses. While these demands are not projected by the SFPUC’s econometric model and not included in the sensitivity analysis, their corresponding projections, consistent with the UWMP, are included in the resulting projections of the three demand scenarios.

1. Housing Growth
This section describes the housing and population growth projections considered for the sensitivity analysis.

San Francisco Planning Department
Because the SFPUC is not a land use agency, housing growth projections is provided to the SFPUC by the San Francisco Planning Department for use in the UWMP. The SF Planning Department reviews the information in the City’s General Plan Housing Element and routinely updates the citywide Land Use Allocation when the Association of Bay Area Governments (ABAG) and Metropolitan Transportation Commission (MTC) update their regional projections, which is typically every four years as part of the Plan Bay Area adoption process. This plan is currently being updated, and the next iteration is called Plan Bay Area 2050+. The plan is anticipated to be adopted by early 2026. In the meantime, as of the preparation of this memo, the Final Blueprint for Plan Bay Area 2050+, which contains growth strategies for the region, has been advanced to the environmental phase of the planning process. To meet the timeline of the UWMP, the SF Planning Department has informed the SFPUC to use the housing projections published in the Housing Element (adopted in January 2023). These projections were also used to develop the 2023 Interim Water Demand Projections for the City and County of San Francisco. The average annual growth rate of SF Planning’s housing projections is 1.06%.

Historical Growth
Predicting future population based on historical estimates was considered for the sensitivity analysis since past growth may be an indicator of future growth. The SFPUC used historical population estimates from

28 the California Department of Finance (CA DOF) between 2000 and 202518 and applied a linear regression to estimate population through year 2050. This produced an average annual growth rate of 0.44%.

Moody’s
Moody’s Corporation is a globally recognized financial services company specializing in credit ratings, risk analysis, and data -driven insights. Moody’s provides credit ratings for bonds, governments, and corporations, including the SFPUC. Their subsidiary, Moody’s Analytics, provides economic forecasting and modeling solutions used by governments, financial institutions, corporations, and other organizations worldwide.
19 Population projections from Moody’s were used for the sensitivity analysis and the data show that these projections were slightly lower than CA DOF in the near- term but surpassed CA DOF’s projections in the long-term with an average annual growth rate at 0.44%.

California Department of Finance
The California Department of Finance releases population projections for the State and counties of California on a periodic basis.20 These population projections incorporate the latest historical population, birth, death, and migration data available and are informed by U.S. Census data products. The average annual growth rate of the CA DOF’s population projection is 0.077% as of September 2025.

Analysis of Housing Growth Inputs
For this sensitivity analysis, the SFPUC evaluated the impact on demand from changing SF Planning Department’s housing unit growth assumption to various population projections. However, since the SFPUC’s econometric model estimates demand on an account-level basis and the additional growth projections are in terms of population (i.e., number of people), an assumption of 2.2 persons per household was made to convert population to households. The persons per household estimate is an average of the latest estimates from the CA DOF
21 and the U.S. Census (Decennial Census and American
Community Survey [ACS] 5-year estimates),22 see Table A-1.

Table A-1: Population per Household Estimates by Year
Year CA DOF U.S. Census and ACS 5-year
Estimates
2020 2.26 2.35
2021 2.21 -
2022 2.15 -
2023 2.14 2.24
2024 2.12 -
2025 2.10 -

18 https://dof.ca.gov/forecasting/demographics/estimates 19 https://www.economy.com/products/data
20 https://dof.ca.gov/forecasting/demographics/projections/ 21 State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties and the State — January 1, 2021- 2025. Sacramento, California, May 2025. Retrieved September 17, 2025, from https://dof.ca.gov/forecasting/demographics/estimates/e-5- population-and-housing-estimates-for-cities-counties-and-the-state-2020-2025. 22 U.S. Census Bureau, U.S. Department of Commerce. (n.d.). Households and Families. American Community Survey, ACS 5-Year Estimates Subject Tables, Table S1101. Retrieved September 17, 2025, from https://data.census.gov/table/ACSST5Y2023.S1101?q=average+household+size+in+san+francisco,+ca.

29 A comparison of each of the housing projections is shown in Figure A-1. As mentioned above, the SF Planning Department relies on growth projections provided by the Plan Bay Area, which are expressed as the number of households. An assumption of 2.2 persons per household was used to convert CA DOF and Moody’s population projections into housing units since that is the unit used by the SF Planning Department. The SF Planning Department’s historical housing unit estimates and projected growth reflect the total inventory of the housing stock (i.e., occupied and unoccupied units). While the CA DOF and Moody’s population projections are converted into housing units and start with a lower number of housing units than historical estimates since it only reflects occupied units.

Population projections from Moody’s and CA DOF reflect a more conservative growth rate for San Francisco. Since CA DOF’s projections are the lowest of these data sources when looking at year 2050, it could serve as a low end for scenario planning. In coord ination with BAWSCA and their demand projections update, both SFPUC and BAWSCA will be aligned in using population projections from CA DOF as one of the additional demand scenarios.

Figure A-1: Historical and Projected Housing Growth by
Source

Note: As stated above, the SF Planning’s housing units reflect the total inventory of housing stock (i.e., occupied and unoccupied units). The CA DOF and Moody’s population projections have been converted into housing units and only reflect the number of occupied units, which is why there is initially fewer housing units in 2025 compared to historical estimates.

2. Employment Growth
This section describes the employment growth projections considered for the sensitivity analysis.

30 San Francisco Planning Department
In addition to providing household projections, SF Planning also provides employment growth projections. These projections are also based on the regional projections from ABAG and MTC’s Plan Bay Area. The average annual growth rate of SF Planning’s employment projections is 0.5%.

Historical Growth
Like estimating future population based on historical estimates, future employment was also estimated based on historical job estimates. The SFPUC used job estimates published by the California Employment Development Department (CA EDD) for the years 2000 through 2023 (the most current estimate available for the CCSF).
23 A linear regression was applied to project the number of jobs through year 2050, and this produced an average annual growth rate of 1.3%.

Moody’s
Employment projections from Moody’s were also used for sensitivity analysis. These projections were the lowest of the three considered. The average annual growth rate of the Moody’s employment projection is 0.5%.

State of California
SFPUC explored datasets published by two state agencies: CA DOF and CA EDD. While the CA DOF conducts economic projections, they do not have employment growth projections by county. The CA EDD publishes 10-year occupational employment projections.24 However, the most recent projection available was for 2022-2032, which does not cover the UWMP planning period. Moreover, even if the growth rate was assumed to remain constant through 2050, these employment projections were not available by city or county. The projections are only available by state or by metropolitan area where data for the County of San Francisco is combined with the County of San Mateo.

Analysis of Employment Growth Inputs
Three sources of employment growth projections were considered for the sensitivity analysis. The SF Planning Department’s projections have been and continue to be used for the UWMP. Additionally, the SFPUC applied a linear regression to historical job estimates which produced the highest growth rate of the three options. A 20+ year time horizon was used for this linear regression since a shorter time frame, particularly 2008-2023, would have yielded a higher average annual growth rate since the beginning of that period was during the Great Recession where the number of jobs steadily increased until the COVID-19 pandemic. Moody’s employment forecast was the third data source considered for this analysis and had the most conservative growth of all the options, which could serve as a low end for scenario planning. Refer to
Figure A-2 for a comparison of each of the employment projections.

23 https://data.ca.gov/dataset/current-employment-statistics-ces-2 24 https://labormarketinfo.edd.ca.gov/data/employment-projections.html

31 Figure A-2: Historical and Projected Employment by Source

3. Housing Density
The future proportion of single family housing units to multi -family housing units was explored in BAWSCA’s 2022 Regional Water Demand and Conservation Projections Update. The SFPUC relies on household growth data from the SF Planning Department and defers to their guidance for a breakdown of single family and multi-family households. In a memo25 provided by the SF Planning Department, the number of single family homes is expected to stay the same over the next 20 years. This assumption has been incorporated into the single family residential and multi-family residential demand projections for all scenarios.

4. Water Conservation
The SFPUC has an established data -informed process to evaluate and determine the suite of conservation measures to implement in its retail service area and uses conservative, industry-accepted methods and models to estimate water savings. The SFPUC implements some measures, such as public education, that do not have modelled water savings due to the lack of industry standards that make estimating savings difficult. The SFPUC draws on many sources to periodically review and update its conservation program offerings with the goal of maintaining a balanced and effective mix of program measures considered reasonably feasible to implement. Since 2005, the SFPUC has evaluated and implemented over 80 measures and continues to explore new measures. For more details about these measures, see SFPUC’s most recent Retail Water Conservation Plan. 26 The SFPUC’s conservation

25 Memo dated 10/27/2020. Re: Projected of growth for San Francisco 2020-2040 26 The SFPUC's Retail Conservation Plan is available at https://www.sfpuc.gov/about-us/policies-plans/urban-water-management-plan.

32 model output used for the 2025 UWMP assumes continued implementation of a comprehensive conservation program and generally reflects the upper end of what the SFPUC anticipates achieving.

Projections are more likely to overestimate rather than underestimate customer participation and water savings, based on an analysis of projections and actual participation rates for the last 10 years.

Achieving savings greater than SFPUC projections is deemed less likely, but not impossible. For this reason, the sensitivity analysis looked at the impact of further increasing conservation savings to up to 5% more and up to 10% under the standard conservation model output. A small amount of additional projected savings potentially could be assumed by counting savings from implemented measures not modeled, adding new potential measures not yet envisioned for which savings could be modeled, increasing incentive amounts, and reducing eligibility requirements for some existing measures where feasible. Conversely, a small to moderate decrease in projected savings potentially could be assumed if customer participation in some conservation programs declines, and overall demand continues to harden.

An additional 5% increase in water conservation savings translates to a decrease in total demand by about 0.1 MGD. Meanwhile, a decrease of 10% savings from the standard conservation model output translates to an increase in total demand by about 0.2 MGD. The impact from achieving slightly more or less water conservation savings than what the conservation model predicts equates to a small change in overall demand. Changes to the standard conservation model output were explored for this sensitivity analysis but were ultimately not included in the additional demand scenarios.

5. Climate Change
The econometric model uses the Representative Concentration Pathways 4.5 climate change scenario in its demand projections. This climate change scenario is associated with California’s Fourth Climate Change Assessment and the data were retrieved from the Cal-Adapt portal.

6. SFPUC Rates
Water, wastewater, and stormwater rates from the approved 10-Year Financial Plan (February 2025)27 were incorporated into the water demand model. Because the SFPUC Finance Division does not currently have alternative rate scenarios, the water rates in the approved 10-year Financial Plan were used for all demand scenarios.

7. Vacancy Rate
The SFPUC examined whether to apply a vacancy rate for each of the housing growth projections. The SF Planning Department’s housing growth projections come from the recently updated Housing Element 2022 Update which projects the number of housing units, not households. If an 8.6% vacancy

27 https://www.sfpuc.gov/about-us/policies-plans/financial-plans-and-policies

33 rate28 was applied to multi-family housing units, this could potentially reduce demands by about 3.2 mgd in 2050. However, for purposes of the UWMP, the SFPUC assumes that all housing units are fully occupied. For historical growth and CA DOF projections, this data are population, not housing units, so a vacancy rate is not applicable.

8. Additional Retail Demands
As described previously, the SFPUC’s econometric model estimates demand for single family, multi- family, commercial, and industrial accounts. Retail demands that are not modeled include dedicated irrigation, municipal, suburban retail, and water loss.

Historical irrigation demands have fluctuated between 1.3 to 1.9 MGD in the past five years. During the 2020-2023 drought when the SFPUC declared a water shortage emergency and requested customers to reduce wasteful water use, the SFPUC saw a decrease in irrigation demand from 1.9 to 1.3 MGD between FY 2020-21 to FY 2022-23. Since then, irrigation demand has steadily increased to 1.5 MGD in FY 2024-25. The quantity of dedicated irrigation accounts increases yearly as new projects with landscaping come online. Between 2020 and 2025 the quantity of accounts increased by about 5%, and the SFPUC anticipates the number of dedication irrigation accounts will continue to grow at a similar pace in the future. At the same time, demands from these accounts are also anticipated to use water more efficiently due to local and state water conservation regulations, such as the SFPUC’s Water Efficient Irrigation regulations, and State Water Resources Control Board’s “Making Conservation a California Way of Life” volumetric standards for efficient outdoor irrigation, and bans on irrigating non- functional turf. Continued efforts to seek greater landscape water efficiency are likely to offset the yearly increase in irrigation accounts, resulting in an estimated steady future demand for this sector over the coming years.

Municipal and suburban retail demands have varied within 1 MGD in the past five years. One of the SFPUC’s suburban retail customers, Groveland Community Services District, prepares an Urban Water Management Plan and has prepared water demand projections for their service area. These projections are incorporated into the SFPUC’s suburban retail demand projections for all demand scenarios.

Water loss and other demands include water losses from water main breaks, leaks, and unbilled authorized consumption, e.g., water used for firefighting, water main flushing, etc. These demand are projected to be equal to the latest three-year annual average (FY 2022-23 through FY 2024-25) to align with the State Water Resources Control Board’s water loss regulations.

Table A -2
shows historical and projected water consumption for these demands based on the assumptions described above.

28 State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties and the State — January 1, 2021- 2025. Sacramento, California, May 2025.

34 Table A-2: Historical and Projected Demands for Other Retail Types Irrigation Municipal Suburban Retail Water Loss and Other1 FY 2022-23 1.3 1.9 3.7 7.4
FY 2023-24 1.4 2.0 3.8 8.4
FY 2024-25 1.5 2.2 4.0 7.6
FY 2029-30 1.5 2.2 4.1 7.8
FY 2034-35 1.5 2.2 4.2 7.8
FY 2039-40 1.5 2.2 4.3 7.8
FY 2044-45 1.5 2.2 4.4 7.8
FY 2049-50 1.5 2.2 4.5 7.8
1 Other water demands include authorized unbilled unmetered consumption or water that is used in activities such as firefighting, water or sewer main flushing, street cleaning, etc.

C. Sensitivity Scenario Demand Projections
Three demand scenarios were generated from modifying the various inputs described above. These scenarios are described below and summarized in Table A-3.

UWMP Scenario
The UWMP Scenario uses housing and employment growth projections provided by the local land use authority, the SF Planning Department. The SF Planning Department’s growth projections are informed by regional growth estimates from ABAG and MTC’s Plan Bay Area 2050+. This scenario reflects the upper end of the range of three demand scenarios. Results from this scenario will be reflected in 2025 UWMP.

Historical Growth Scenario
The first additional demand scenario to the UWMP Scenario is the Historical Growth Scenario. This scenario is based on the historical population estimates from the California Department of Finance and historical employment estimates from the California Employment Development Department. A linear regression was applied to each data set to project population and employment growth through 2050 in San Francisco.

DOF / Moody’s Scenario
This scenario uses the population projection s from the California Department of Finance and employment projections from Moody’s Analytics. The lower forecasts of housing and employment result in lower forecasts of water demand compared to the UWMP Scenario and Historical Growth Scenario.

35 Table A-3: Water Demand Scenarios and Corresponding Data Sources Variable UWMP Scenario Historical Growth
Scenario DOF / Moody’s Scenario
Housing Growth and
Growth Rate
SF Planning

1.1%
Historical Growth

0.4%
California Department of
Finance

0.1%
Employment Growth
and Growth Rate
SF Planning

0.5%
Historical Growth

1.3%
Moody’s

0.5%
Housing Density SF Planning Department
Water Conservation
Savings Conservation Model Output
Climate Change Representative Concentration Pathway 4.5 Water Rates SFPUC’s 10-Year Financial Plan

The projected demands for the three scenarios are shown in Table A-4 and are displayed as a graph in Figure A-3.

Table A-4: Projected Retail Demands (MGD) by Scenario
UWMP Scenario
Single Family Residential 12.6 13.3 13.0 13.0 13.0 13.0 Multi-Family Residential 22.2 26.2 27.1 28.7 30.4 32.2
Commercial and Industrial 12.4 12.0 10.7 11.1 11.5 12.2 Others 15.3 15.6 15.7 15.8 15.9 16.0
Total 62.5 67.0 66.5 68.6 70.7 73.4

Historical Growth Scenario
Single Family Residential 12.6 12.2 11.9 11.9 11.9 11.9 Multi-Family Residential 22.2 23.0 22.9 23.5 24.1 24.7
Commercial and Industrial 12.4 12.4 11.8 12.4 13.2 14.1 Others 15.3 15.6 15.7 15.8 15.9 16.0
Total

62.5 63.2 62.3 63.5 65.0 66.7
DOF / Moody’s Scenario
Single Family Residential 12.6 12.2 11.9 11.9 11.9 11.9 Multi-Family Residential 22.2 21.4 20.9 20.9 20.8 20.8
Commercial and Industrial 12.4 11.3 10.3 10.4 10.7 11.0 Others 15.3 15.6 15.7 15.8 15.9 16.0
Total 62.5 60.4 58.8 58.9 59.2 59.7

36 Figure A-3: Projected Water Demand by Scenario

37 Disclaimer: This report was prepared for the San Francisco Public Utilities Commission, in accordance with WestWater Research and BRG’s engagement terms, and is intended to be read and used as a whole and not in parts. The opinions expressed in this report are those of the individual author(s) and do not represent the opinions of WestWater Research and BRG or its other employees and affiliates. There are no third -party beneficiaries with respect to this report, and WestWater Research and BRG does not accept any liabili ty to any third party in respect of the contents of this report or any actions taken or decisions made as a consequence of the information set forth herein.

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APPENDIX D
2025 Conservation Tracking Model Summary
2025 URBAN WATER MANAGEMENT PLAN
for the City and County of San Francisco

June 2026
Prepared by: The San Francisco Public Utilities Commission

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SFPUC
Conservation
Tracking
Model
Water and Energy
Savings Specifications
for Conservation
Program Measures
David Mitchell, M.Cubed
Last Updated: 02-03-2026
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 1 Overview
The SFPUC Conservation Tracking Model is a tool developed to track conservation program activity, water savings, and costs and benefits for SFPUC’s retail service area conservation programs. The model is a customized version of the Alliance for Water Efficiency’s (AWE) Water Conservation Tracking Tool, an Excel-based water conservation tracking model with more than four hundred registered water utility users throughout North America. In 2014, the SFPUC customized the AWE Conservation Tracking Tool for its retail service area and began using it to forecast water savings from conservation measures.

The purpose of this Water and Energy Savings Specifications for Conservation Program Measures Technical Memorandum is to document the assumptions and methodologies used to estimate water savings for every measure in the SFPUC’s Conservation Tracking Model and key updates made over time.

This document reflects all measures with modeled water savings included in the Conservation Tracking Model, including measures the SFPUC implements now or plans to in the next five years, implemented in the past, and ones SFPUC has evaluated and not implemented and may or may not do so in the future. It does not reflect conservation measures the SFPUC provides or provided in the past that don’t have established or sufficient water-savings methodologies.

History of SFPUC Conservation Forecast Modelling
The SFPUC developed its first model in 2004 to forecast both in-City retail water demands and water savings from conservation measures. The SFPUC used estimated conservation water savings generated by this model to develop its 2004 and 2011 conservation plans. The SFPUC migrated from using this combined demand/forecast model in 2014, and started using a separate econometric demand model originally developed by The Brattle Group to estimate retail demands and to the SFPUC Conservation Tracking Model to estimate water savings from conservation measures. Most recently, in 2025, the SFPUC updated its econometric demand model for its retail service area for use in preparing its 2025 Urban Water Management Plan and for providing updated demand estimates for its 2025 Retail Conservation Plan.

Model Structure
The Conservation Tracking Model is an Excel-based model with an extensive Visual Basic backend. Using the model requires completing Model Setup, Program Specification, and Annual Activity data input tasks. Each data input task is contained on a separate worksheet in the model.

Model Setup consists of providing the model with the baseline forecast of water demand, as well as other basic system information the model uses to calculate the costs and benefits of conservation programs. The baseline water demand forecast comes from the econometric demand models. Setup also includes providing the latest estimates of actual population, housing, and employment which are used to update the estimates of passive water savings to date.

Program Specification consists of parameterizing the conservation programs in the model. The model can hold up to 200 separate programs. Program parameters are grouped into five categories: water saving parameters, utility cost parameters, participant cost parameters, participant non water benefits parameters, and plumbing code parameters. The latter are used to specify interaction effects with plumbing codes to avoid double counting water savings jointly produced by plumbing codes and conservation programs. In terms of forecasting conservation program water savings, the most important parameters are the water savings parameters and the plumbing code interaction parameters.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 2 Annual Activity is simply the number of units of activity that have been done (in the case of historical years) or are expected to be done (in the case of future years). The user enters historical and projected annual activity for each conservation program that was specified during the Program Specification step.

For toilets, urinals, and clothes washers, the model includes fixture inventory modules to keep track of how many fixtures have been converted to efficient fixtures due to plumbing codes and conservation programs to ensure the user does not specify levels of fixture replacement that are physically infeasible.

Once the three data input tasks have been completed the model results can be reviewed. Model results are summarized into three categories: (1) program water savings, (2) retail water demand, and (3) costs and benefits.

• Program water savings are the projected annual water savings from each specified conservation program through 2050. Results can be grouped by program category and customer class or shown individually.

• Retail demand results summarize the baseline annual demand forecast with plumbing code and conservation program adjustments through 2050. It is grouped by customer class and shown separately for the in-city and suburban parts of SFPUC’s retail service area. Results can be shown in MGD or acre-feet. Gross per capita and residential per capita water use are also reported.
• Costs and benefits of conservation are reported for the utility and program participant perspectives. Unit costs, net present value, and benefit-cost ratios can be reported for the totality of all programs, for individual program categories (e.g. toilet replacement programs), or for individual programs. In addition to financial benefits and costs, the model calculates expected reductions in associated energy use and greenhouse gas emissions.

Model inputs can be saved as scenarios. This allows the model to simultaneously hold more than one set of data inputs. For example, a user could specify scenarios for alternative baseline population and demand forecasts or for alternative levels of conservation program investment. There is no practical limit to the number of scenarios the model can hold.

Summary of Key Updates since 2015

2015 Updates
The conservation program savings presented in SFPUC’s 2011 Conservation Plan were developed with the SFPUC’s original Retail Demand Model not the Conservation Tracking Model. While the Conservation Tracking Model can be calibrated to replicate the 2011 estimates, the final estimates developed for the 2015 Conservation Plan, which were developed with the Conservation Tracking Model, were generally lower after 2020 than was presented in the 2011 Plan for three main reasons:

• The SFPUC undertook a review of the water saving estimates and assumptions and made several adjustments, including to savings estimates for clothes washers and toilets, both of which were lowered to account for new efficiency standards affecting the long-term savings potential of these programs.
• The 2015 Plan updated the end dates for toilet and clothes washer incentives due to high fixture saturation levels.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 3 • The 2015 Plan focused mainly on the next five years, reflecting that beyond that horizon, there is much less certainty regarding what conservation programs SFPUC will find most beneficial and cost-effective to implement.

2020 Updates
In 2020, the SFPUC made the following changes to the model:

• Revised future participation levels for several measures to better reflect current trends. • Added several new conservation measures.
• Adjusted the water savings assumptions of several existing measures. • Updated the water savings module for clothes washer efficiency standards to align it with the approach used in Version 4 of the Alliance for Water Efficiency’s Water Conservation Tracking Tool.
• Incorporated the City of San Francisco Planning Department’s current population and housing estimates.
• Removed the calculation of plumbing code water savings for new development (post 2020) because they are already embedded in SFPUC’s updated retail demand projections.

These updates were based on analysis of historical program participation, updated fixture saturation rates, and new empirical and other water-savings studies and data available since 2015. This document reflects the assumptions and specifications used in the SFPUC’s Conservation Tracking Model for purposes of estimating water savings for the SFPUC’s 2020 Retail Conservation plan.

2025 Updates
In 2025, the following updates to the model were made:

• Revised the toilet fixture saturation module to account for replacement of 1.6 gpf toilets with

1.28 gpf or less toilets by SFPUC toilet replacement programs. • Updated savings assumptions of AMI leak alert measures to align with savings estimates reported in the February 2, 2024, technical memorandum: Water Savings Assessment of SFPUC Leak Alert Programs.
• Updated savings assumptions for HET replacement programs to account for replacement of existing toilets with HET toilets with flush ratings < 1.28 gpf. • Added new programs to the model, including direct install and rebate programs to replace 1.6 gpf toilets with ultra-high-efficiency toilets with flush ratings of <= 1.0 gpf; and multi-family and non-residential landscape irrigation timer rebate programs. • Incorporated into the model updated implementation costs provided by SFPUC for 39 programs. • Incorporated projected annual implementation levels through 2050 provided by SFPUC for 38 programs.
• Incorporated the estimates of 2025 population, housing, and employment; estimates for 2020 population were revised.

2025 Population and Housing Estimates
SFPUC expects new construction to be built at code and generate no additional passive savings.

All future passive savings will come from existing stock. As such, population and housing SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 4 estimates for 2025 were updated, as described below, and then held constant for the remainder of the planning horizon.

Population Estimate Update
Updated 2025 population of 842,027 was input based on Department of Finance E-5 Housing and Population Estimates (dated January 2025). Residential population in 2025 was updated from the same source. Additionally, the 2020 total population estimate of 941,269 provided by SF Planning was retroactively revised to 873,965 based on the 2020 estimated value from Department of Finance E-5 Housing and Population Estimates (dated January 2025).

The conservation model’s original and updated population projections are shown in Table 1. As shown in this table, the population stops growing after 2025 to reflect no additional passive savings to be generated from future growth.

Table 1: Population Projection Update
Year
Total Population Residential Population
2020
Model
2025 Model %
Difference
2020
Model
2025 Model %
Difference
2005 780,187 780,187 0.0% 756,678 756,678 0.0%
2010 805,235 805,235 0.0% 780,971 780,971 0.0%
2015 857,508 857,508 0.0% 831,995 831,995 0.0%
2020 941,269 873,965 -7.2% 913,031 840,986 -7.9%
2025 941,269 842,027 -10.5% 913,031 811,717 -11.1%
2030 941,269 842,027 -10.5% 913,031 811,717 -11.1%
2035 941,269 842,027 -10.5% 913,031 811,717 -11.1%
2040 941,269 842,027 -10.5% 913,031 811,717 -11.1%
2045 941,269 842,027 -10.5% 913,031 811,717 -11.1%
2050 941,269 842,027 -10.5% 913,031 811,717 -11.1%
Source: 2020 total population from San Francisco Planning Department, adjusted to residential population based on 3% group quarters (DOF E-5 and P-4)

Household Projection Update
Total housing units were sourced from San Francisco Planning’s 2024 Housing Inventory. This value is assumed to be an estimate of total constructed housing units as opposed to occupied housing units.

Occupied single-family housing units in 2025 were set equal to the number of single-family residential accounts in the SFPUC’s billing system as of June 2025. This includes the number of accounts with the service agreement type residential single family (RES-SWTR), regardless of dwelling unit count, and the service agreement type of residential combination service (COMBO-R) with 1 dwelling unit. Occupied single-family housing units for 2030 and beyond were kept the same as 2025.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 5 Total 2025 housing units from the Planning Department were adjusted to estimate occupied housing units using a vacancy rate of 11.25%, which is an average of the last two estimates provided by the ACS 1-year estimates for the City of San Francisco from 2023 (11.03%) and 2024 (11.48%). Total occupied multi-family housing units in 2025 were estimated by subtracting the number of occupied single-family housing units in 2025 from the total 2025 occupied housing units.

Calculation of Plumbing Code Water Savings

The Conservation Tracking Model calculates the water savings associated with plumbing codes and appliance efficiency standards using models of fixture inventory coupled with usage assumptions. These savings are commonly referred to as passive water savings because they occur regardless of actions taken by the utility. The Tracking Model includes passive savings models for residential toilets, showerheads, and clothes washers, and non-residential toilets, urinals, hotel showerheads, and coin-op clothes washers.

It is important to emphasize that the passive savings estimates do not actually impact the model’s estimates of final water demand. This is because the econometric demand model’s baseline demand forecasts used in the Tracking Model are net of passive water savings. However, the econometric forecast does not generate an explicit forecast of passive water savings because the adjustment for passive savings is enacted through the model’s trend term. Because SFPUC desired explicit estimates of passive water savings, modules for estimating these savings were included in the Conservation Tracking Model. These estimates are added to the econometric demand model’s baseline forecast before it is used in the Conservation Tracking Model so that they can be represented explicitly in the Conservation Tracking Model. It is the econometric demand model’s baseline forecast adjusted for passive savings that is entered on the conservation Model Setup worksheet. The adjusted baseline forecast is:1

Adjusted Baseline Forecast = Econometric Model Baseline Forecast + Passive Water Savings

The final demand forecast generated by the Conservation Tracking Model is then:

Final Demand Forecast = Adjusted Baseline Forecast – Passive Water Savings – Program Water Savings

This is also equal to:

Final Demand Forecast = Econometric Model Baseline Forecast – Program Water Savings

This means the only determinants of the final demand forecast are the Econometric Model Baseline Forecast and the forecast of programmatic water savings from future implementation of SFPUC conservation programs. While the passive savings forecast is useful because it provides an estimate of how much demand reduction can be ascribed to plumbing codes and appliance standards, it does not actually affect the final estimate of future demand.

1 The passive water savings adjustment also includes water savings expected to be realized after 2015 from the historical implementation of SFPUC conservation programs prior to the start of the Econometric Model’s baseline forecast. This is done to prevent the model from double counting these water savings.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 6 Following are descriptions of how passive savings are calculated for each fixture/appliance category.

The SFPUC Plumbing Fixture Population and Efficiency Saturation Estimates Technical Memorandum issued on January 13, 2014 and included in Appendix A of the 2015 Retail Conservation Plan and the updated saturation estimates memo dated August 19, 2019, and included in appendices of the 2020 Retail Conservation Plan provide more details on fixture population and saturation estimates.

Residential Toilets
The population of residential toilets is based on available estimates of actual single and multi-family housing units. These estimates are multiplied by the average number of toilets per dwelling unit, which are estimated from recent American Housing Survey data. The model uses an average of 2.22 and 1.26 toilets per dwelling unit for single and multi-family housing, respectively. Toilets installed in new housing constructed between 1991 and 2013 are assumed to be ULFT (1.6 gpf). Toilets installed in new housing constructed after 2013 are assumed to be HET (1.28 gpf). Toilets in existing housing constructed before 1991 are assumed to have an average flush volume of 3.5 gpf. Toilets in existing housing are assumed to be replaced at an annual rate of 3.1% per year. This is the average rate of residential toilet replacement reported in studies done by EBMUD and SCVWD. Existing toilets replaced between 1991 and 2013 are assumed to be replaced by ULFTs. Existing toilets replaced after 2013 are assumed to be replaced by HETs. Using this information, the model calculates the average flush volume for the inventory of new and existing toilets for each year between 1990 and 2064. Water savings per flush is calculated relative to the average flush volume in 1990. Average savings per flush is equal to the average flush volume in 1990 less the average flush volume in each year after 1990. Average savings per flush is multiplied by the estimated number of flushes per year to estimate annual water savings. The estimated number of flushes per year is equal to the residential population multiplied by the average daily per capita flush rate multiplied by 365. The residential population is derived from SFPUC’s service area population forecasts. The average daily per capita flush rate of 4.8 is taken from the results for San Francisco reported in the 2011 California Single Family Water Efficiency Study.

Non-Residential Toilets
The population of non-residential toilets for the period 1990-2012 is taken from the Fixture Saturation Task Memo. The population of non-residential toilets for the period 2013-2064 is a linear extrapolation based on the forecast of service area population. The same assumptions used for residential toilets regarding flush volume of new toilets and replacement rate of existing toilets are used for non- residential toilets. The average flush volume of the toilet inventory and the water savings per flush relative to 1990 are calculated the same way as for residential toilets. Average savings per flush is multiplied by the estimated number of flushes per year to estimate annual water savings. Vickers (2001) estimates annual flushes by multiplying daily flushes by a 260-day work year. Male workers are assumed to flush toilets (as opposed to urinals) an average of one time per day while female workers are assumed to flush toilets an average of three times per day. Male workers are assumed to comprise 54% of the labor force, per City of San Francisco (2009). Total employment is taken from SFPUC’s employment forecast.

Non-Residential Urinals
Based on an analysis of DBI data, the ratio of urinals to toilets is estimated to be 0.15. This ratio is applied to the estimated stock of non-residential toilets to estimate the stock of urinals. Urinals installed before 1992 are assumed to have an average flush volume of 2 gpf. Urinals installed between 1992 and 2013 are assumed to have an average flush volume of 1 gpd. Urinals installed in 2014 are assumed to have a flush volume of 0.5 gpf. Urinals installed after 2014 are assumed to have a flush volume of 0.125 gpf. Urinals are assumed to have the same replacement rate as toilets. The average SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 7 flush volume of the urinal inventory and the water savings per flush relative to 1990 are calculated the same way as for residential and commercial toilets. Average savings per flush is multiplied by the estimated number of flushes per year to estimate annual water savings. To calculate total flushes per year, male workers are assumed to have a daily flush rate of 2, per Vickers (2001). Male workers are assumed to comprise 54% of the labor force, per City of San Francisco (2009). Total employment is taken from SFPUC’s employment estimate.

Residential Showerheads
The population of residential showerheads is based on available estimates of actual single and multi- family housing units. These forecasts are multiplied by the average number of showerheads per dwelling unit, which are estimated from recent American Housing Survey data. The model uses an average of 1.34 and 1.21 showerheads per dwelling unit for single and multi-family housing, respectively. Showerheads installed in new housing constructed before 2005 are assumed to have an average flow rate of 2.3 gpm. Showerheads installed in new housing constructed between 2005 and 2017 are assumed to have an average flow rate of 2.0 gpm. Showerheads installed after 2017 are assumed to have an average flow rate of 1.8 gpm. Showerheads in existing housing are assumed to be replaced at an annual rate of 12% per year, per the Alliance for Water Efficiency. Using this information, the model calculates the average showerhead flow rate for the inventory of new and existing showerheads for each year between 2005 and 2064. Average savings per minute is equal to the average flow rate in 2005 less the average flow rate in each year after 2005. Annual water savings is calculated as the product of the average flow rate and the annual number of minutes for showering. The annual number of minutes for showering is equal to the average number of shower events per household per day multiplied by the average shower duration in minutes multiplied by the number of households multiplied by 365. An average of 2 shower events per day and an average duration of 9 minutes per shower event are taken from the results for San Francisco from the 2011 California Single Family Water Efficiency Study.2 The number of residential housing units is taken from SFPUC’s housing forecast.

Hotel Showerheads
The population of hotel showerheads is based on an estimate of the total number of hotel rooms in San Francisco. The model assumes one showerhead per room. Showerheads installed before 2005 are assumed to have an average flow rate of 2.5 gpm. Showerheads installed between 2005 and 2017 are assumed to have an average flow rate of 2.2 gpm. Showerheads installed after 2017 are assumed to have an average flow rate of 1.8 gpm. Showerheads are assumed to be replaced at an annual rate of 12% per year, per the Alliance for Water Efficiency. Using this information, the model calculates the average showerhead flow rate for the inventory of new and existing showerheads for each year between 2005 and 2064. Average savings per minute is equal to the average flow rate in 2005 less the average flow rate in each year after 2005. Annual water savings is calculated as the product of the average flow rate and the annual number of minutes for showering. The annual number of minutes for showering is equal to the average number of shower events per occupied room per day multiplied by the average shower duration in minutes multiplied by the number of occupied rooms multiplied by 365.

An average of 1.34 shower events per day per occupied room and an average duration of 10 minutes per shower event are taken from the AWWARF Commercial End Uses of Water Study. The average hotel occupancy rate is based on a review of various estimates published on the internet of hotel occupancy in San Francisco.

2 The estimate of average number of shower events per day for San Francisco from this study is used directly in the single-family residential calculation. For the multi-family calculation, it is scaled by the ratio of multi-family to single-family persons per household to consider the lower density in multi-family housing.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 8 Residential Clothes Washers
The stock of residential clothes washers is based on SFPUC’s housing forecast and the average number of washers per dwelling unit. The average number of washers per dwelling unit is 0.937 for single-family and 0.41 for multi-family. The multi-family estimate includes both in-unit and common room washers.

Existing washers are replaced at an annual rate of 9%, which is equivalent to assuming washers have an average useful life of 11 years, which is consistent with industry estimates. When a washer is replaced, it is replaced with either a conventional or high-efficiency (Energy Star) washer according to a forecast of market shares informed by market analyses done to support the setting of federal efficiency standards for washers. Water factors for new conventional and high-efficiency washers change over time in the model. Water factors for conventional washers are based on federal energy standards while water factors for high-efficiency washers are based on EPA Energy Star specifications. The average water factor for the stock of residential washers adjusts over the course of the forecast based upon the rate at which existing washers are replaced and new washers are added to the inventory. The model’s accuracy in predicting water use by clothes washers is checked against water use benchmarks for 1997, 2007, and 2012 taken from residential end use studies. Washer utilization in single-family households is drawn from the San Francisco End Use of Water Study. Washer utilization in multi-family households scales down the single-family estimate to account for smaller average household size. Water savings are calculated relative to 2005 and are equal to the difference in water use assuming average washer efficiency in 2005 versus average washer efficiency in the forecast year.

Coin-op Clothes Washers
Estimates of passive water savings for coin-op clothes washers use the same methodology used for residential clothes washers. The natural replacement rate for coin-op washers is the average of estimates developed by the Alliance for Water Efficiency (11.1%) and the Department of Energy (13.3%).

The stock of coin-op clothes washers is based on an internet search of coin-op washer facilities in San Francisco. The average number of washers per coin-op facility is taken from the Fixture Saturation Task Memo. The average number of loads per day is taken from a PG&E study of coin-op washer water and energy consumption. The water factors for new and replaced washers are based on existing federal efficiency regulations for commercial clothes washers.

Calculation of Programmatic Water Savings

The Conservation Tracking Model calculates the water savings associated with a program as the product of the estimated water savings per unit of activity and the amount of activity completed. These savings are commonly referred to as active water savings because they result from the utility’s direct investment in conservation programs intended to reduce demand. In other words, the savings result from the utility’s active pursuit of demand reduction.

In the Tracking Model, the user specifies a starting unit water savings for each program. The behavior and duration of the unit savings overtime can then be adjusted with the useful life, annual decay, and plumbing code interaction parameters. When the annual decay and plumbing code interaction parameters are both set to 0, annual savings is equal to the product of the initial unit savings and the amount of activity. Annual savings accrue until the measure’s useful life is reached, after which annual savings are assumed to be zero. Thus given initial unit savings S0, measure useful life u, and activity of As in year s, water savings in any year t ≥ s are:

𝑆𝑡 = 𝐴𝑠𝑆0 𝑖𝑓 𝑡 − 𝑠 + 1 ≤ 𝑢, 0 𝑜𝑡ℎ𝑒𝑟𝑤𝑖𝑠𝑒
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 9 When the annual decay parameter takes a value d in the range (0, 1], annual water savings in any year t ≥ s are:

𝑆𝑡 = 𝐴𝑠𝑆0(1 − 𝑑)𝑡−𝑠 𝑖𝑓 𝑡 − 𝑠 + 1 ≤ 𝑢, 0 𝑜𝑡ℎ𝑒𝑟𝑤𝑖𝑠𝑒

When the plumbing code interaction parameter takes a value p in the range (0, 1] and the plumbing code is in effect for any year t ≥ v, annual water savings in any year t ≥ s are:

𝑆𝑡 = {
𝐴𝑠𝑆0 𝑖𝑓 𝑢 ≥ 𝑡 − 𝑠 + 1 𝑎𝑛𝑑 𝑡 < 𝑣
𝐴𝑠(1 − 𝑝)𝑡−𝑠𝑆0 𝑖𝑓 𝑡 − 𝑠 + 1 ≤ 𝑢 𝑎𝑛𝑑 𝑡 ≥ 𝑣
0 𝑖𝑓 𝑡 − 𝑠 + 1 > 𝑢

When the plumbing code interaction parameter takes a value p in the range (0, 1], the plumbing code is in effect for any year t ≥ v, and the annual decay parameter takes a value d in the range (0, 1], annual water savings in any year t ≥ s are:

𝑆𝑡 = {
𝐴𝑠𝑆0(1 − 𝑑)𝑡−𝑠 𝑖𝑓 𝑡 − 𝑠 + 1 ≤ 𝑢 𝑎𝑛𝑑 𝑡 < 𝑣
𝐴𝑠(1 − 𝑝)𝑡−𝑠𝑆0(1 − 𝑑)𝑡−𝑠 𝑖𝑓 𝑡 − 𝑠 + 1 ≤ 𝑢 𝑎𝑛𝑑 𝑡 ≥ 𝑣
0 𝑖𝑓 𝑡 − 𝑠 + 1 > 𝑢

The specification of these parameters are based on current state and federal plumbing codes and appliance standards and findings from empirical evaluations of conservation program performance, as compiled by the California Water Efficiency Partnership (CalWEP) and Alliance for Water Efficiency (AWE). The specific data sources and assumptions used to create the water savings and plumbing code specifications for each program are provided in the remainder of this document.

The model’s toilet fixture inventory modules for single- and multi-family toilets also estimate water savings from the City’s toilet retrofit-on-resale ordinance that started in 2009. These estimates rest on two simplifying assumptions: (1) 3.5+ gpf toilets are uniformly distributed across the housing stock and (2) each housing unit is equally likely to be put on the market for sale each year. Given these two assumptions, ROR toilet replacements in any year t ≥ 2009 are calculated as:

(Stock of 3.5+ gpf toilets at beginning of year – SFPUC toilet replacements) x housing resale rate

The model assumes ROR toilets are replaced with ULFTs prior to 2014 and HETs thereafter.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 10 Program Water Savings Specifications
The remainder of this document presents the water savings specifications for each conservation measure included in the Conservation Tracking Model. Program specifications are grouped first by customer class and second by programs type.

Confidence in Estimates
The program water savings specifications utilize the best available information on water savings. Only measures with a sufficient level of confidence in the approach to estimating water-savings are included in the Tracking Model. The SFPUC implements a number of measures that are not included in the model that are likely to generate some water savings but for which there are insufficient empirical studies or standard engineering estimates to generate estimates with a reasonable level of confidence. For the measures included in the model there is a range of reliability of savings estimates. While all measures in the tool meet a base level of confidence, for established and widely deployed measures – e.g. toilet replacements -- there is strong empirical evidence on water savings from multiple empirical program evaluations. In other cases, less data is available or the program is so new that empirical performance data is limited or nonexistent. In these cases, the water savings estimates may be based on results of a single evaluation done elsewhere or they may be built up from utilization and flow rate assumptions – commonly referred to as engineering estimates.

A confidence score of 1, 2 and 3 is assigned to each program specification to indicate the level of confidence in the water savings specification. The confidence scores are subjective in the sense that they rely on professional judgement as to the quality and applicability of the data underlying the water savings specification.

Confidence
Score

Criteria
1 Savings are based on well-designed empirical evaluations of program performance. The program is widely deployed by other water suppliers and water savings have been evaluated in multiple locations and contexts. Savings estimates are directly applicable or can reasonably be re-scaled to be applicable to SFPUC’s service area.

2 Savings are based on simple empirics of program performance (e.g. a simple difference in means or difference-in-differences analysis). The program may not be widely deployed by other water suppliers and may not have been evaluated in multiple locations and contexts.

3 Empirical estimates of program performance are not available or are limited in their applicability to SFPUC’s service area. Savings are based on engineering estimates relying on general assumptions about water use with and without the program intervention

Measure Summary Tables
The following tables summarize the measures in the model at the time of this update (August 2020).

The tables provides:

• A brief description of each measure
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 11 • The unit savings estimate for the measure
• The basis for the estimate
• The expected annual water savings at the planned level of activity • The confidence score for the water savings estimate

Link to Detailed Specifications
The measure IDs in the summary tables are hyperlinked to the measure’s detailed specification. Ctr- clicking the specification ID will take the reader to the measure’s detailed specification. Ctr-clicking the ID the detailed specification will take the reader back to the summary table.

Basis for Savings Estimates
The basis for the savings estimate is either:

Empirical Program Evaluations – the savings estimate is based on results from one or more empirical evaluations of water savings for similar programs. The empirical estimate may be adjusted to account for differences between the location(s) where the empirical evaluation was completed and SFPUC’s service area. Such adjustments are explained in the measure’s detailed specification.

Engineering Estimate – the savings estimate is based on assumptions about fixture/device utilization and the water-using properties of the existing and new fixture/device. Engineering estimates are generally less reliable than estimates based on empirical program evaluations.

Annual Savings Estimates
The annual savings estimates show the expected water savings from one year of planned annual activity.

These savings would be expected to persist over the useful life of the measure. Savings for most measures are assumed to be stationary, meaning the model does not assume the savings will change significantly over its useful life. However, this assumption is not adopted for every measure. For example, the model assumes savings from surveys are not constant, but rather decrease with time. The estimates in the summary tables do not reflect these adjustments. Therefore, the estimates should be viewed as upper-bounds for measures whose savings are expected to decrease over time.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 12 Single-Family Measures

ID Measure
Name
Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
S1 Mandatory
CAP Audit
Free site evaluation required for single-family
residents to participate in the SFPUC’s Community
Assistance Program (CAP) for discounted water and
sewer rates. Identify inefficient plumbing fixtures and leaks and suggest improvements.

17.5 gpd Empirical
Program
Evaluations
Savings assumed to
decay by 20% per year
2 S2 WaterWise
Evaluation
Free indoor and outdoor site consultation: review
consumption history, check plumbing fixtures and
irrigation system components for leaks, determine
fixture flow rates, recommend improvements, identify
fixtures eligible for replacement through rebate
programs, and provide standard repair parts for faulty
toilets and free water-saving devices and materials.

Customized report of findings sent to customer after
visit.

17.5 gpd Empirical
Program
Evaluations
Savings assumed to
decay by 20% per year
2 S3a Leak Alerts SFPUC uses its AMI data to flag accounts that trigger continuous usage thresholds and alerts customers if a
leak is suspected. SFPUC provides alerted customers
with information on how to check for and repair
common leaks

0.56 gpd Empirical
Program
Evaluations
Unit savings is per
active Single-Family
account
1 S3b Custom
Water Use
Report
Report with customers' water use information,
comparison of water to similar properties, and
customized information on ways to save.

8.4 gpd Empirical
Program
Evaluations
Multiple empirical
evaluations have
found home water
reports reduce water
use by 5-6%. The
model assumes 5.5%.
1 S4 1.5 GPM
Showerhead
Distribution
Up to two free showerheads (as part of measure S2 or
in-person pickup from SFPUC) per household.

6.8 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
2 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 13 ID Measure
Name
Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
in 2018. Assumes 54%
installation rate
S5 1.5 GPM
Showerhead
Direct Install
Provides free installation of 1.5 gpm showerheads to
single family residents. WaterWise Evaluation (S2) is a pre-requisite to this measure.

12.6 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018
1 S6 HET Rebate Cash rebates of up to $125 to replace old toilets (3.5 gpf or more) with approved HETs (1.28 gpf or less).

20.9 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018. Direct install
savings reduced by
25% to account for
rebates used to
replace ULF toilets
and program free-
riders. Program
replaced existing
toilets rated >= 1.6 gpf
with toilets rated <=

1.0 gpf.
2 S7 CAP Direct
Install thru
SFPUC
Funding
Free installation of HETs (1.28 gpf) for single-family
residents who are also CAP participants. Only 3.5 gpf
toilets replaced except a small number of old, poorly
performing 1.6s.

Pre-requisite: Mandatory CAP Audits (Measure S1).

27.8 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018. Program
replaced existing
toilets rated >= 1.6 gpf
1 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 14 ID Measure
Name
Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
with toilets rated <=

1.0 gpf.

S8 HET Direct
Install (Non-
CAP)
Same as measure S7 but is open to single-family
residents who are not a CAP participant. Program did
not start until 2016

27.8 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018. Program
replaced existing
toilets rated >= 1.6 gpf
with toilets rated <=

1.0 gpf.
1 S8b HET Direct
Install (Non-
CAP,
replacing 1.6
gpf toilets)
Same measure as S8 but targets replacement of 1.6
gpf toilets

6.7 gpd Engineering
Estimate
Estimate prepared by
SFPUC Staff
3 S9 HET Voucher A voucher issued to eligible residents to replace their older toilets with HETs.

20.9 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018. Direct install
savings reduced by
25% to account for
rebates used to
replace ULF toilets
and program free-
riders. Program
replaced existing
toilets rated >= 1.6 gpf
2 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 15 ID Measure
Name
Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
with toilets rated <=

1.0 gpf.

S11 CEE Tier 3
Washer
Rebate (IWF

4.0)
Up to $100 rebate from SFPUC and $50 rebate from
PG&E for a combined $150 rebate for a washer with 4
IWF or lower.

10.2 gpd Engineering
Estimate
Engineering estimate
based on limited data
on clothes washer
market shares
3 S12 Energy Star
Most
Efficient
Washer
Rebate (IWF

3.5)
Up to $100 rebate from SFPUC and $50 rebate from
PG&E for a combined $150 rebate for a washer with

3.5 IWF or lower.

11.6 gpd Engineering
Estimate
Engineering estimate
based on limited data
on clothes washer
market shares
3 S16a Rain Barrel
Discount
(replaced by
S16c)
Subsidy program (through a vendor) that discounts
the purchase cost of rain barrel and provides training.

0.8 gpd Engineering
Estimate
60 gal capacity.

Estimated with AWE
Rain Barrel Harvest &
Application Model
3 S16b Rain Cistern
Discount
(replaced by
S16d)
Subsidy program (through a vendor) that discounts
the purchase cost of cisterns and provides training.

2.4 gpd Engineering
Estimate
205 gal capacity.

Estimated with AWE
Rain Barrel Harvest &
Application Model
3 S16c Rain Barrel
Rebate
In-house administered rebate program with required
proof of install.

0.8 gpd Engineering
Estimate
60 gal capacity.

Estimated with AWE
Rain Barrel Harvest &
Application Model
3 S16d Cistern
Rebate
In-house administered rebate program with required
proof of install.

2.4 gpd Engineering
Estimate
205 gal capacity.

Estimated with AWE
Rain Barrel Harvest &
Application Model
3 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 16 ID Measure
Name
Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
S18 Weather-
Based
Irrigation
Controller
Rebate
Financial rebate towards purchase and installation of
a weather-based irrigation controller that uses site
specific data and adjusts the irrigation time depending on the local weather.

3.7 gpd Empirical
Program
Evaluations
Estimate is based on
review of empirical
evaluations of WBIC
savings in Southern
and Northern CA
2 S20 Device
Distribution
Various water-efficient fixtures: bathroom aerators
(0.5/1.0/1.5 gpm), kitchen/bathroom laminar (1.5
gpm), kitchen aerators (1.5/2.2 gpm), utility aerators
(1.5/2.0/2.2), pre-rinse spray nozzles, garden spray
hose nozzles, toilet flappers, toilet fill valves, and soil moisture meters.

3.3 gpd Engineering
Estimate
Based on review of
end use studies and
engineering estimates
of savings potential of
aerators and other
devices
3 S21 ULFT to
Ultra-High-
Efficiency
Toilet Direct
Install
Same as S8 but targeting replacement of 1.6 gpf
toilets.

6.7 gpd Engineering
Estimate
Estimate prepared by
SFPUC Staff
3 S22 ULFT to
Ultra-High-
Efficiency
Toilet
Rebate
Same as S6 but targeting replacement of 1.6 gpf
toilets.

5.0 gpd Engineering
Estimate
Estimate prepared by
SFPUC Staff
3 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 17 Multi-Family Measures

ID Measure
Name
Measure Description Expected
Unit Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
M1 WaterWise
Direct
Installation
Evaluation
Free, required site evaluation for multi-family
residents to participate in the SFPUC’s HET/Urinal
Direct Install Program). Identify inefficient plumbing
fixtures and leaks and suggest improvements.

10.6 gpd Empirical
Program
Evaluations
Equal to indoor savings
for S1 and S2. Savings
assumed to decay by
20% per year
2 M2 WaterWise
Evaluation
Free site consultation: review consumption history,
check toilets for leaks, determine fixture flow rates,
recommend improvements, identify fixtures eligible
for replacement through rebate programs, provide
standard repair parts for faulty toilets and free water- saving devices and materials.

10.6 gpd Empirical
Program
Evaluations
Equal to indoor savings
for S1 and S2. Savings
assumed to decay by
20% per year
2 M3a Small Multi-
Family Leak
Alert
SFPUC uses its AMI data to flag 2-5 dwelling unit
multi-family accounts that trigger continuous usage
thresholds and alerts customers if a leak is suspected.

SFPUC provides alerted customers with information
on how to check for and repair common leaks

1.6 gpd Empirical
Program
Evaluations
Unit savings applies to
all Multi-Family
customers with 2-5
dwelling units
1 M3b Large Multi-
Family Leak
Alert
Same as M3a but targeting multi-family accounts with
more than 5 units

0.0 gpd Empirical
Program
Evaluations
Savings not statistically
different from 0 in
program evaluation
1 M4 Showerhead
Distribution
Buildings with 10 or less units are limited to one
showerhead per unit. These buildings can pick up
showerheads at the customer service counter. Also
includes buildings that receive showerheads that are
not installed during a Water Wise Evaluation.

Buildings with over 10 units must schedule a
WaterWise Evaluation (measure M2) in order to
receive the free devices

6.8 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018. Assumes 54%
installation rate
2 M5 Showerhead
Direct Install
Free installation of showerheads.

Pre-requisite: WaterWise Direct Install Evaluations
(Measure M1)

12.6 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
1 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 18 ID Measure
Name
Measure Description Expected
Unit Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
programs completed
in 2018
M6a
M6b
HET Rebate Cash rebates of up to $125 per tank-style HET or up to $300 per flushometer valve HET to replace a high-
flow toilet (3.5 gpf or more).
30 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018. Direct install
savings reduced by
25% to account for
rebates used to
replace ULF toilets and
program free-riders.

Program replaced
existing toilets rated
>= 1.6 gpf with toilets
rated <= 1.0 gpf.
2 M7a
M7b
HET Direct
Install
Free installation of tank-style (T) or flushometer valve (F) HETs.

Pre-requisite: WaterWise Direct Install Evaluation
(Measure M1)

38.6 gpd

38.6 gpd
Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018. Program
replaced existing
toilets rated >= 1.6 gpf
with toilets rated <=

1.0 gpf.
1 M7c HET Direct
Install
(replacing 1.6
gpf toilets)
Same as M7 but targeting replacement of 1.6 gpf
toilets

9.3 gpd Engineering
Estimate
Estimate prepared by
SFPUC Staff
3 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 19 ID Measure
Name
Measure Description Expected
Unit Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
M8 HET Voucher A voucher issued to eligible residents to replace their older toilets with HETs
30 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018. Direct install
savings reduced by
25% to account for
rebates used to
replace ULF toilets and
program free-riders.

Program replaced
existing toilets rated
>= 1.6 gpf with toilets
rated <= 1.0 gpf.
2 M9 HET Install
thru On-Bill
Financing
Partner with third-party vendors to find customers
with remaining savings opportunity, sell them the
program, and conduct the installation. The customer
pays for the program through savings received
through their water bill.

38.6 gpd Empirical
Program
Evaluations
Based on empirical
evaluation of
bathroom retrofit
programs completed
in 2018. Program
replaced existing
toilets rated >= 1.6 gpf
with toilets rated <=

1.0 gpf.
1 M10 CEE Tier 3
Washer
Rebate (IWF

4.0)
Rebate for coin-op, common area clothes washer
with IWF of 4 or lower.
(multi-family in-unit residential style washers are
covered under SF measure)
126 gpd Engineering
Estimate
Engineering estimate
based on limited data
on clothes washer
market shares
3 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 20 ID Measure
Name
Measure Description Expected
Unit Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
M17 Efficient
Irrigation
Timer Rebate
Financial rebate towards purchase and installation of
a weather-based irrigation controller that uses site
specific data and adjusts the irrigation time
depending on the local weather.

3.7 gpd Empirical
Program
Evaluations
Savings assumed to be
same as single-family
program (S18)
2 M20 Device
Distribution
Various water-efficient fixtures: bathroom aerators
(0.5/1.0/1.5 gpm), kitchen/bathroom laminar (1.5
gpm), kitchen aerators (1.5/2.2 gpm), utility aerators
(1.5/2.0/2.2), pre-rinse spray nozzles, garden spray
hose nozzles, toilet flappers, toilet fill valves, and soil moisture meters.

3.3 gpd Engineering
Estimate
Based on review of
end use studies and
engineering estimates
of savings potential of
aerators and other
devices
3 M21 ULFT to Ultra-
High-
Efficiency
Toilet Direct
Install
Same as M7 but targeting replacement of 1.6 gpf
toilets.

9.3 gpd Engineering
Estimate
Estimate prepared by
SFPUC Staff
3 M22 ULFT to Ultra-
High-
Efficiency
Toilet Rebate
Same as M6 but targeting replacement of 1.6 gpf
toilets.

6.9 gpd Engineering
Estimate
Estimate prepared by
SFPUC Staff
3 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 21 Non-Residential Measures

ID Measure Name Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
N1 WaterWise
Evaluations for
Commercial Buildings
Free site consultation: review consumption history,
check toilets for leaks, determine fixture flow rates,
recommend improvements, identify fixtures eligible
for replacement through incentive programs, provide
standard repair parts for faulty toilets and free water- saving devices and materials. Customized report of
findings sent after visit.
215 gpd Empirical
Program
Evaluations
Based on empirical
evaluations of CII
surveys done in
Southern California in
the 1990s
3 N2 Commercial Direct
Install Audits
Free site consultation similar to measure N1.

Required for commercial buildings that applied for
direct install programs.
215 gpd Empirical
Program
Evaluations
Based on empirical
evaluations of CII
surveys done in
Southern California in
the 1990s
3 N3a
N3b
N3c
Surveys – Hospitals,
Hotels, Schools
Free site consultation for hospitals, hotels, and
schools

4643 gpd
993 gpd
256 gpd
Empirical
Program
Evaluations
Based on empirical
evaluations of CII
surveys done in
Southern California in
the 1990s
3 N4 Surveys – Large
Landscape by
Contractors
Free landscape survey provided to eligible customers
(0.5 acres or more of irrigated landscapes) under the
Landscape Technical Assistance Program. Survey will
evaluate the water delivery system to check for
inefficiencies that lead to water losses, Surveyors will also determine the site’s water budget by cataloguing
plant type and will create site-specific
recommendations and a cost estimate for improving
irrigation efficiency.
161 gpd Engineering
Estimate
Unit savings per acre
surveyed. Assumes
10% reduction in
average landscape site
water use of 1.8
AF/Acre
3 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 22 ID Measure Name Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
N5 Surveys – CII Facilities
by Contractors
Free site consultation for other types of non-
residential customers provided by third-party
consultant or other funding sources.
5120 gpd Engineering
Estimate
SFPUC staff estimate
of water savings from
consultant audits
2 N6 Landscape Leak Alert SFPUC uses its AMI data to flag landscape accounts that trigger continuous usage thresholds and alerts
customers if a leak is suspected. SFPUC provides
alerted customers with information on how to check
for and repair common leaks

28.2 gpd Empirical
Program
Evaluations
1 N7 1.5 GPM Showerhead
Giveaway
Provides free, high-efficiency 1.5 gpm showerheads
for San Francisco businesses.

5.6 gpd Engineering
Estimate
Based on review of
hotel end use studies
and engineering
estimates of hotel
showerhead savings
potential. Assumes
54% installation rate
3 N8 1.5 GPM Showerhead
Direct Install
Free installation of high-efficiency 1.5 gpm
showerheads for San Francisco businesses.

Pre-requisite: Direct Install Audit (Measure N2)

10.4 gpd Engineering
Estimate
Based on review of
hotel end use studies
and engineering
estimates of hotel
showerhead savings
potential.
3 N9 Device Distribution Various water-efficient fixtures: bathroom aerators (0.5/1.0/1.5 gpm), kitchen/bathroom laminar (1.5
gpm), kitchen aerators (1.5/2.2 gpm), utility aerators
(1.5/2.0/2.2), pre-rinse spray nozzles, garden spray
hose nozzles, toilet flappers, toilet fill valves, and soil moisture meters.

3.3 gpd Engineering
Estimate
Based on review of
end use studies and
engineering estimates
of savings potential of
aerators and other
devices
3 N10a
N10b
HET Rebate Cash rebates of up to $125 per tank style toilet and up to $300 per flushometer valve toilet for replacing

28.4 gpd Empirical
Program
Evaluations
Based on CUWCC CII
Toilet Savings Study.

Estimate scales-up
2 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 23 ID Measure Name Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
high-flow toilets (3.5 gpf or more) with approved HET
models (1.28 gpf or less).

ULFT savings to
account for improved
efficiency of HET
N11a
N11b
N11c
N11d
N11e
N11f
HET Rebate – Schools,
Hotels, Muni
Cash rebates of up to $125 per tank style toilet and
up to $300 per flushometer valve toilet for replacing
high-flow toilets (3.5 gpf or more) with approved HET
models (1.28 gpf or less).

20.6 gpd Empirical
Program
Evaluations
Based on CUWCC CII
Toilet Savings Study.

Estimate scales-up
ULFT savings to
account for improved
efficiency of HET
2 N12a
N12b
HET Direct Install Free installation of High-Efficiency Toilets for businesses in SF
Pre-requisite: Direct Install Audit (Measure N2)
29 gpd Empirical
Program
Evaluations
Based on CUWCC CII
Toilet Savings Study.

Estimate scales-up
ULFT savings to
account for improved
efficiency of HET
2 N13 HET Direct Install –
Schools, Hotels
Free installation of HETs for schools or hotels in SF.

Pre-requisite: Direct Install Audit (Measure N2)

19.6 gpd Empirical
Program
Evaluations
Based on CUWCC CII
Toilet Savings Study.

Estimate scales-up
ULFT savings to
account for improved
efficiency of HET
2 N14 HET Voucher A voucher for HET purchase. 28.4 gpd Empirical Program
Evaluations
Based on CUWCC CII
Toilet Savings Study.

Estimate scales-up
ULFT savings to
account for improved
efficiency of HET
2 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 24 ID Measure Name Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
N15 HET Voucher –
Schools, Hotels
Same as N14 but directed at schools and hotels 17.8 gpd Empirical Program
Evaluations
Based on CUWCC CII
Toilet Savings Study.

Estimate scales-up
ULFT savings to
account for improved
efficiency of HET
2 N16 HET Install thru On-
Bill Financing
Partner with third-party vendors to find customers
with savings opportunity, sell them the program, and
conduct the installation. The customer pays for the
program through savings received through their
water bill.
29 gpd Empirical
Program
Evaluations
Based on CUWCC CII
Toilet Savings Study.

Estimate scales-up
ULFT savings to
account for improved
efficiency of HET
2 N17a
N17b
HEU Rebate Cash rebates of up to $300 per urinal for eligible commercial businesses when high flow urinals (1.5
gpf or more) are replaced with High-Efficiency Urinal
(HEU) models that are 0.125 gpf or less.

16.2 gpd Empirical
Program
Evaluations
Based on CUWCC
Urinal Savings
Potential PBMP Study
3 N18 HEU Direct Install A program for replacing 1.5 gallons per flush (gpf) high efficiency urinals with pint flush urinals.

16.2 gpd Engineering
Estimate
Based on CUWCC
Urinal Savings
Potential PBMP Study
3 N20 Energy Star Washer
Rebate (IWF 4.5)
Measure has been discontinued. Cash rebates for
commercial high-efficiency clothes washers with a
water factor of 4.5 or below.
39 gpd Engineering
Estimate
Engineering estimate
based on limited data
on clothes washer
market shares and
coin-op washer
utilization rates
3 N21 Energy Star Washer
Rebate (IWF 4)
Cash rebates of up to $200 for commercial high-
efficiency clothes washers with a water factor of 4.0
or below. For any business where 10 or more washers
are being installed, a pre-purchase inspection must be
scheduled.
45 gpd Engineering
Estimate
Engineering estimate
based on limited data
on clothes washer
market shares and
3 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 25 ID Measure Name Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
coin-op washer
utilization rates
N22a Landscape Grants (pre
2020)
Under Landscape Grant Program, landscapes with
over 0.5 acre of irrigated areas are eligible to receive funding to implement retrofits and install fixtures to
facilitate water conservation.
179
gpd/acre
Empirical
Program
Evaluations
Based on SFPUC staff
estimates of water
savings for 11 large
landscape grant
projects
2 N22b Landscape Grants
(post 2020)
Under Landscape Grant Program, landscapes with
10,000 sf to 0.5 acre or more of irrigated areas are
eligible to receive funding to implement retrofits and
install fixtures to facilitate water conservation.
179
gpd/acre
Empirical
Program
Evaluations
Assumed same as
N22a
2 N24 Equipment Retrofit
Rebates -
Unmetered/Estimated
Incentives to businesses to upgrade indoor
equipment. Projects must achieve an annual water
savings of 100 ccf or more to qualify. SFPUC will
provide qualifying projects incentives of $0.50 per ccf over a 10-year lifespan up to 50% of the equipment
costs. Program includes customized incentives as well
as standard incentives for equipment with predictable
water savings, such as water efficient ice machines,
and connectionless food steamers.

2.0 Engineering
Estimate
Annual activity
entered in units of
ccf/yr.
1 N25a Custom Equipment
Retrofit Rebates –
Metered (Pre-2025)
Similar to Measure N24, but allows applicants to
create customized project tailored toward their
specific business needs and water use patterns.

2.0 Engineering
Estimate
Annual activity
entered in units of
ccf/yr.
1 N25b Custom Equipment
Retrofit Rebates –
Metered (2025+)
Same as N25a, but with larger incentive cost. 2.0 Engineering Estimate
Annual activity
entered in units of
ccf/yr.
1 N26 Non-Residential Leak
Alert
SFPUC uses its AMI data to flag non-residential
accounts that trigger continuous usage thresholds
and alerts customers if a leak is suspected. SFPUC
provides alerted customers with information on how
to check for and repair common leaks

5.0 gpd Empirical
Program
Evaluations
1 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 26 ID Measure Name Measure Description Expected
Unit
Water
Savings
(GPD)
Basis for
Savings
Estimate
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
N27 Kitchen Low Flow
Spray Valves
Rebate or giveaway of high-efficiency kitchen
spray valves used primarily by dishwashing
stations
30 gpd Empirical
Program
Evaluations
Based on multiple
empirical evaluations
of savings from kitchen
spray-valve retrofits.

Estimate assumes 50%
installation/retention
rate
1 N29 Efficient Irrigation
Timer Rebate
Financial rebate towards purchase and installation of
a weather-based irrigation controller that uses site
specific data and adjusts the irrigation time
depending on the local weather.

13.4 gpd Empirical
Program
Evaluations
Lower-bound of 95%
CI of average savings
per station, per A&N
Technical's 2011 WBIC
savings evaluation.

Lower-bound is used
because of San
Francisco's climate and
lower landscape water
use.
2 N30 ULFT to Ultra-High-
Efficiency Toilet
Rebate
Cash rebates to replace tank and flushometer style
toilets and up to $300 per flushometer valve toilet.

Similar to N10 but targets replacement of 1.6 gpf
toilets

7.0 gpd Engineering
Estimate
Estimate prepared by
SFPUC
3 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 27 Measures Applicable to All Customers

ID Measure
Name
Measure Description Expected
Unit Water
Savings
(GPD)
Notes on Savings
Estimate
Water
Savings
Estimate
Confidence
Score
A3 Irrigation
Customer
Large
Landscape
Budget
(Discontinued)
The SFPUC calculates how water use for irrigated landscape sites that received an irrigation or landscape grant or were required to comply with San Francisco's Water Efficient Irrigation Ordinance (WEIO) compares to the maximum allowable water use (MAWA)
recommended for the plant types per state calculations. Staff are exploring how to potentially expand the program to all sites served by dedicated irrigation meters
357 gpd Unit savings per acre
surveyed. Assumes
10% reduction in
average pre-grant
water use of 4
AF/Acre for 9 large
landscapes enrolled
in SFPUC landscape
grant program
3 A4a Municipal
Large
Landscape
Budget
This measure is for informational/educational monthly water budget reports sent to dedicated irrigation account customers. The monthly water budget report indicates how their water use for the previous month (and all prior months in the year) compares with the estimated amount allotted for their site based on the state MAWA calculation, divided by month and factoring in precipitation. Prior to 2025, the SFPUC provided these reports only to dedicated irrigation customers that had received an irrigation meter or landscape grant from the SFPUC.
48 gpd Assumes 10%
reduction in average
pre-budget water use
of 0.54 AF/Ac
3 A4b Non-
Municipal
Large
Landscape
Budget
This measure is for informational/educational monthly water budget reports sent to dedicated irrigation account customers. The monthly water budget report indicates how their water use for the previous month (and all prior months in the year) compares with the estimated amount allotted for their site based on the state MAWA calculation, divided by month and factoring in precipitation. Prior to 2025, the SFPUC provided these reports only to dedicated irrigation customers that had received an irrigation meter or landscape grant from the SFPUC.
236 Assumes 10%
reduction in average
pre-budget water use
of 2.64 AF/Ac
3 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 0 Measure Specifications
This section contains the water savings specification for each measure used in the conservation savings model. The specifications are grouped by customer class: (1) single-family, (2) multi-family, and (3) non- residential.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 1 Single Family Measures

ID Name Class Category
S1 Mandatory CAP Audit Single Family Audits & Reports

Water Savings: Average of savings from residential survey savings reported by Whitcomb (2000), A&N Technical Services (1994b), and Chesnutt, et al. (1995) is 33.9 gpd. Whitcomb (2000) reported 60% of savings are from outdoor uses and 40% are from indoor uses. Single family irrigation area in SFPUC retail service is approximately 34% of state average reported by DeOreo and Mayer (2010). Estimate based on combination of behavioral and fixture retrofits induced by survey recommendations. Savings from showerheads removed from indoor component to avoid double counting savings from S11 and S12. The 3 gpd estimate for showerheads assumes half the site visits get a direct install showerhead and half get a showerhead left for owner-installation, in which 50% are installed.

Water savings = (0.4 x 33.9 gpd – 3 gpd) + 0.6 x 0.34 x 33.9 gpd = 17.5 gpd (6,388 gpy)

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: 20%. Lower-end of decay rate range reported in CUWCC (2005).

Useful Life: 5 yrs. Based on typical useful life of survey savings reported in CUWCC (2005).

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year, 80% of outdoor savings occur in peak period. Peak period runs from May 1 to Sep 30, representing 42% of days.

Peak % = 0.42 x (0.4 x 33.9 gpd – 3 gpd) + 0.8 x 0.6 x 0.34 x 33.9 gpd)/17.5 = 57%

Unit Sewer Savings: Sewer savings = 0.4 x 33.9 gpd – 3 gpd = 10.6 gpd (3,869 gpy) Wastewater to water savings ratio = 0.606

Unit Electricity Savings: NA

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006), that hot water comprises 67% of shower/faucet flow - per DOE (2006) – that half of indoor water savings involve reductions in shower/faucet flow, and that indoor savings comprise 66% of total survey savings.

Gas savings = 0.0072 therms/gal x 0.67 x 0.5 x 0.66 = 0.0016 therms/gal

Confidence Score: 2
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 2 ID Name Class Category
S2 WaterWise Evaluations Single Family Audits & Reports

All assumptions same as S1.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 3 ID Name Class Category
S3a Leak Alerts Single Family Audits & Reports

Water Savings: Detailed empirical analysis of SFPUC’s Single-Family Customer Leak Alert Program concluded:

• The Program reduced the mean duration of leak events lasting 72 or more hours by 32.6 hours, from 58 to 25.4 hours.
• The Program reduced the frequency of leak events lasting 72 or more hours from 0.194 to 0.113 leaks per meter-year.
• The Program reduced mean leakage volume from 437.1 to 233.7 gallons per meter-year, or by about 203 gallons per meter-year.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 1 year.

Peak Period Savings Percent: We assume the same savings pattern as S1 and S2 – where outdoor savings comprise 34% of total savings and 80% of outdoor savings occur in the peak period.

Peak period runs from May 1 to Sep 30, representing 42% of days.

Peak % = 0.42 x 0.66 + 0.8 x 0.34 = 55%

Unit Sewer Savings: We do not have data on how leakage is distributed between indoor and outdoor water uses. We assume the same distribution as indoor and outdoor water use.

Sewer savings = 0.66 x 203 gpy per meter = 134 gpy per meter Wastewater to water savings ratio = 0.66

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 4 ID Name Class Category
S3b Custom Water Use Report Single Family Audits & Reports

Water Savings: Average water savings are 5.5% of single family daily use, per Mitchell and Chesnutt (2014). Multiple other empirical estimates of water use report savings have measured average saving rates of 4-6% (https://www.watersmart.com/resources/). Median single family water use in SFPUC’s retail service area (circa 2005) is 153 gpd, per DeOreo and Mayer (2010a).

Water savings = 0.055 x 153 gpd = 8.4 gpd (3,066 gpy)

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 1 year.

Peak Period Savings Percent: Evaluations of water use reports have not had sufficient data to detect seasonal effects (Mitchell and Chesnutt, 2014). For now we assume the same savings pattern as S1 and S2 – where outdoor savings comprise 34% of total savings and 80% of outdoor savings occur in the peak period.

Peak period runs from May 1 to Sep 30, representing 42% of days.

Peak % = (0.42 x 0.66 x 8.4 gpd + 0.8 x 0.34 x 8.4 gpd) ÷ 8.4 = 55%

Unit Sewer Savings: Evaluations of water use reports have not had sufficient data to determine indoor and outdoor savings as a share of total (Mitchell and Chesnutt, 2014). For now we assume the same savings pattern as S1 and S2 – where indoor savings comprise 66% of total savings

Sewer savings = 0.606 x 8.4 gpd = 5.09 gpd (1,858 gpy)
Wastewater to water savings ratio = 0.606

Unit Electricity Savings: NA

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006), that hot water comprises 67% of shower/faucet flow - per DOE (2006) – that half of indoor water savings involve reductions in shower/faucet flow, and that indoor savings comprise 66% of total savings.

Gas savings = 0.0072 therms/gal x 0.67 x 0.5 x 0.66 = 0.0016 therms/gal

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 5 ID Name Class Category
S4 1.5 GPM Showerheads Distributions Single Family HESH

Water Savings: M.Cubed and A&N Technical Services (2018a, 2018b) estimated toilet, showerhead, and aerator water savings from direct installation bathroom retrofit programs in Bakersfield, Torrance, and East Los Angeles targeting both single- and multi-family bathrooms. Mean savings for showerheads installed in single-family households was 12.6 gpd. Field studies of retrofit kit distributions in Irvine (A&N Technical Services 1992d) and Los Angeles (A&N Technical Services 1991) have found initial installation probabilities that range from 49% to 59%. We assume a 54% installation probability.

Water savings = 0.54 x 12.6 gpd = 6.8 gpd (2482 gpy)

Plumbing Code Savings: Zero. SB 407 mandates showerheads have a maximum capacity of 2.5 gpm.

Currently, the average flow rate of showerheads in SFPUC’s retail service area is 1.95, per DeOreo and Mayer (2010a).

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 8 yrs, per Alliance for Water Efficiency (2014).

Peak Period Savings Percent:

Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 6.8 gpd (2482 gpy)
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006) and that hot water comprises 67% of shower/faucet flow - average of DOE (2006) and Aquacraft (1999). Gas savings = 0.0072 therms/gal x 0.67 = 0.0048 therms/gal

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 6 ID Name Class Category
S5 1.5 GPM Showerheads Direct Install Single Family HESH

Water Savings: M.Cubed and A&N Technical Services (2018a, 2018b) estimated toilet, showerhead, and aerator water savings from direct installation bathroom retrofit programs in Bakersfield, Torrance, and East Los Angeles targeting both single- and multi-family bathrooms. Mean savings for showerheads installed in single-family households was 12.6 gpd (4599 gpy).

Unit Sewer Savings: Sewer savings = 12.6 gpd (4599 gpy) Wastewater to water savings ratio = 1.000

All other assumptions same as S4.

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 7 ID Name Class Category
S6 HET Rebates (Tank) Single Family HET

Water Savings: M.Cubed and A&N Technical Services (2018a, 2018b) estimated toilet, showerhead, and aerator water savings from direct installation bathroom retrofit programs in Bakersfield, Torrance, and East Los Angeles targeting both single- and multi-family bathrooms. Installed HETs had flush rates of 1.1 gpf or less. Mean savings for HETs installed in single-family households was 27.8 gpd (10147 gpy).

Direct installation programs can more effectively screen out the replacement of ULF toilets than can rebate programs. Nearly all the toilets replaced in the direct installation programs evaluated by M.Cubed and A&N Technical Services were older non-ULFT toilets. Rebate programs may inadvertently issue rebates for the replacement of ULF toilets. To account for this possibility, mean daily savings estimated for the direct installation programs is reduced by 25%.

Water savings = 27.8 gpd x 0.75 = 20.9 gpd (7629 gpy)

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency. Period of savings attributed to program does not exceed useful life of toilet. On average savings are counted for 25 years, the average useful life of the toilet.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 20.9 gpd (7629 gpy) Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 8 ID Name Class Category
S7 CAP Direct Install thru SFPUC Funding Single Family HET

Water Savings: M.Cubed and A&N Technical Services (2018a, 2018b) estimated toilet, showerhead, and aerator water savings from direct installation bathroom retrofit programs in Bakersfield, Torrance, and East Los Angeles targeting both single- and multi-family bathrooms. Installed HETs had flush rates of 1.0 gpf or less. Mean savings for HETs installed in single-family households was 27.8 gpd (10147 gpy).

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency. Period of savings attributed to program does not exceed useful life of toilet. On average savings are counted for 33 years, the average useful life of the toilet.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 27.8 gpd (10147 gpy) Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 9 ID Name Class Category
S8 HET Direct Install (Non-Cap) Single Family HET

Water Savings: M.Cubed and A&N Technical Services (2018a, 2018b) estimated toilet, showerhead, and aerator water savings from direct installation bathroom retrofit programs in Bakersfield, Torrance, and East Los Angeles targeting both single- and multi-family bathrooms. Installed HETs had flush rates of 1.0 gpf or less. Mean savings for HETs installed in single-family households was 27.8 gpd (10147 gpy).

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency. Period of savings attributed to program does not exceed useful life of toilet. On average savings are counted for 33 years, the average useful life of the toilet.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 27.8 gpd (10147 gpy) Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 10 ID Name Class Category
S9 HET Vouchers Single Family HET

All assumptions same as S6.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 11 ID Name Class Category
S11 CEE Tier 3 Rebate (IWF 4.0) Single Family HEW

Water Savings: Assumes participant in market for washer. Without rebate, participant will purchase either top- or front-load washer. Current market share (circa 2012) of top-load washers is 52%, per DOE (2012). Current Energy Star market share (circa 2012) is 50%, per DOE (2012). Maximum allowed IWF for Energy Star washer after 2011 is 6. Maximum allowed IWF for non-Energy Star washer is 9.5, per National Appliance Standard. (National Appliance Standard changes in 2015 to 4.5 IWF for front-load and 8.0 IWF for top-load, and again in 2018 to 6.0 IWF for top-load). Average IWF of new washer is:

Avg IWF of New Washer Without Rebate = 0.5 x 6.0 + 0.5 x 9.5 = 7.75 (note this will overstate avg IWF after 2015 due to nat’l appl stdrd)

Average washer loads per day for single family households in SFPUC retail service area is 0.91, per DeOreo and Mayer (2010a). Average volume of new clothes washer is 3 cubic feet, per DOE (2012).

Water savings = (7.75 – 4.0) x 3 x 0.91 = 10.2 gpd (3,723 gpy)

Plumbing Code Savings: Effective Jan 1, 2015, appliance standard is 4.5 IWF for front-load and 8.0 IWF for top-load. Given current front- and top-load market shares and Energy Star market share, average IWF under appliance standard in 2015 is:

2015 Avg IWF under Nat’l Appl Std = 0.52 x (0.5 x 8.0 + 0.5 x 6.0) + 0.48 x 4.5 = 5.8

Effective Jan 1, 2018, appliance standard is 4.5 IWF for front-load and 6.0 for top-load. Average IWF under appliance standard in 2018 is:

2018 Avg IWF under Nat’l Appl Std = 0.52 x 6.0 + 0.48 x 4.5 = 5.3.

For modeling conservation program benefits, we use the average of these two water factors – 5.6 -- and start the standard in 2015. Plumbing code savings starting in 2015 are:

Plumbing code savings = (7.75 – 5.6) x 3 x 0.91 = 5.9 gpd (2,154)

Plumbing Code NRR: 7.1%. Based on average washer life of 14 years, per DOE (2012).

Annual Decay Rate: NA

Useful Life: 14 years, per DOE (2012)

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 10.2 gpd (3,723 gpy) Wastewater to water savings ratio = 1.000

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 12 Unit Electricity Savings: 0.0036 KWh/gal. Based on high efficiency washer electricity savings reported in FEMP (2000).

Unit Gas Savings: 0.0035 therms/gal. Based on high efficiency washer gas savings reported in FEMP (2000).

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 13 ID Name Class Category
S12 Energy Star Most Efficient (IWF 3.5) Washer Rebate Single Family HEW

Water Savings: See S11 for details.

Water savings = (7.75 – 3.5) x 3 x 0.91 = 11.6 gpd (4,234 gpy)

Unit Sewer Savings: Sewer savings = 11.6 gpd (4,234 gpy) Wastewater to water savings ratio = 1.000

All other assumptions same as S11.

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 14 ID Name Class Category
S16a, S16b
S16c, S16d
Rain Barrels and Cisterns Single Family, Multi Family,
Non-Residential
Grants

Water Savings: Savings based on M.Cubed Rain Barrel Harvest & Application Model (rainbarrel_harvest_and_application_model.xlsx)

60 gal barrel = 302 gpy (assumes 100 sqft irr area)
205 gal cistern = 887 gpy (assumes 300 sqft irr area)

The rain barrel water savings model simulates rain barrel catchment, filling, and application of stored water using daily rainfall and ETO data for the period 2/5/2001 to 10/22/2014. Daily weather data are from the Union City CIMIS weather station. The 60 gallon barrel savings estimate assumes a catchment area of 1000 square feet, irrigation area of 100 square feet, and landscape crop water coefficient (KL) of

0.25. The 205 gallon cistern savings estimate assumes irrigation area is 300 square feet. The other model assumptions are the same. Daily application of stored water is equal to the lesser of daily irrigation requirement and stored water. Daily irrigation requirement in cubic feet is equal to irrigation area x KL x net ETO ÷ 12.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 15 years. Assumed

Peak Period Savings Percent: 24%. Calculated with M.Cubed Rain Barrel Harvest & Application Model for a 100 gal. barrel. Peak period savings % increases with barrel size, since more water can be stored for use in peak season.

Unit Sewer Savings: NA

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 15 ID Name Class Category
S18 WBIC Single Family Grants

Water Savings: Several empirical program evaluations of WBIC performance have been completed since the early 2000s. A good summary of these studies can be found on the Cal WEP website. The following table summarizes findings from these studies.

Study % Reduction in
Outdoor Water
Use
% Reduction in
Total Household
Water Use
Mean Reduction
in Gal/Day
Sample Size
Orange County 2001 16-24% 7-10% 37-57 40 SF Homes
Orange County 2004 No estimate 10% 41 97 SF Homes
No & So Cal, 2009 7% No estimate 58 1,987 SF Homes
Orange County 2010 10% 7% 37 899 SF Homes
Orange County 2011 No estimate 9% 49 70 SF Homes

The mean percentage reduction in outdoor water use estimated by these studies range from 7 to 24%.

We are inclined to give more weight to the 2009 and 2010 studies that had large sample sizes. The mean percentage reduction in outdoor water use was 7-10%. We use the lower end of the range to be conservative.

Median single family water use in SFPUC’s retail service area (circa 2005) is 153 gpd, per DeOreo and Mayer (2010a). On average, outdoor water use is assumed to be 34% of total water use. Expected WBIC savings are thus: 153 x 0.34 x 0.07 = 3.7 gpd or 1,351 gpy.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 10 years. Assumed

Peak Period Savings Percent: 100% of savings assumed to occur in peak season.

Unit Sewer Savings: NA

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 16 ID Name Class Category
S20 Device Distribution Single Family Grants

Water Savings: Water savings are a quantity-weighted average of devices distributed by SFPUC. The devices, quantity weights, and annual savings are shown in the following table.

Devices
Annual
Quantity
Savings
(GPY)

1.5 gpm bathroom aerator 8229 210

1.0 gpm bathroom aerator 0 361

0.5 gpm bathroom aerator 1537 511

1.5 gpm kitchen laminar 0 210

1.5 gpm bathroom laminar 0 210

2.2 gpm kitchen aerator 265 0

1.5 gpm kitchen aerator 4641 210

1.5 utility aerator 54 210

2.0 utility aerator 54 60

2.2 utility aerator 16 0
Garden spray hose nozzle 295 0 No reliable estimates
Toilet flapper 3603 1212
Toilet fill valves 1819 1212 Assumed to be same as flapper savings Soil moisture meter 7 0 No reliable estimates
Total 20520
Weighted Avg Savings 491

Annual savings for aerators are based on the following data and assumptions:

• Median SFR faucet use is 29 gpd (source: Aquacraft SFPUC End Use Study). • An average of 4 faucets per household is assumed.
• Average use per faucet is 7.25 gpd. The calculation assumes uniform faucet usage, which while unlikely to be true is necessary given lack of data on faucet use. • Aerators reduce free flowing faucet water consumption. It is assumed half of faucet use is for free flowing uses (e.g. brushing teeth or washing vegetables) and half is for fixed volume uses (e.g. filling pots or getting a drink of water). Free flowing faucet use is therefore 3.63 gpd. • Average faucet flow is assumed to be 2.2 gpm. Therefore, faucets average 1.6 minutes of free flowing use per day.
• It is assumed half of distributed faucets are installed.

Given these assumptions, savings by aerator flow rate are:

Aerator
flow rate
(gpm)
Avg Use
GPD
Potential
Savings
(GPD) Install %
Actual
Savings
(GPD)
Actual
Savings
(GPY)

2.2 3.63 0.00 50% 0.00 0

2.0 3.30 0.33 50% 0.16 60

1.5 2.47 1.15 50% 0.58 210

1.0 1.65 1.98 50% 0.99 361

0.5 0.82 2.80 50% 1.40 511
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 17 Annual savings for flappers and fill valves are based on the following data and assumptions:

• Median SFR leakage rate is 8.3 gpd, per Aquacraft SFPUC End Use Study. • According to 2004 CUWCC Toilet Flapper Study and 1999 Residential End Use Study most household water leaks can be attributed to toilets. It is assumed toilet leaks account for 80% of the median leakage rate, or 6.64 gpd.
• It is assumed replacing flapper or fill valves will eliminate toilet-related leakage. • It is assumed half of distributed flappers and fill valves are installed.

Given these assumptions, water savings are 3.32 gpd, or 1212 gpy.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 5 years

Peak Period Savings Percent:

Unit Sewer Savings: Same as water savings

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 18 ID Name Class Category
S21 ULFT to Ultra-High-Efficiency
Toilet Direct Install
Single Family HET

Water Savings: 6.7 gpd (2446 gpy). Engineering estimate prepared by SFPUC staff.

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency. Period of savings attributed to program does not exceed useful life of toilet. On average savings are counted for 33 years, the average useful life of the toilet.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 6.7 gpd (2466 gpy)
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 19 ID Name Class Category
S22 ULFT to Ultra-High-Efficiency
Toilet Rebate
Single Family HET

Water Savings: 5.0 gpd (1825 gpy). Engineering estimate prepared by SFPUC staff.

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency. Period of savings attributed to program does not exceed useful life of toilet. On average savings are counted for 33 years, the average useful life of the toilet.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 5.0 gpd (1825 gpy)
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 20 Multi Family Measures

ID Name Class Category
M1 WaterWise Direct Install Evaluations Multi Family Audits & Reports

Water Savings: Assumes same as indoor share of savings for S1 and S2

Water savings = 10.6 gpd (3,869 gpy)

Plumbing Code NRR: NA

Annual Decay Rate: 20%. Same as S1 and S2. Lower-end of decay rate range reported in CUWCC (2005).

Useful Life: 5 yrs. Same as S1 and S2. Based on typical useful life of survey savings reported in CUWCC (2005).

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 10.6 gpd (3,869 gpy) Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006), that hot water comprises 67% of shower/faucet flow - per DOE (2006) – that half of indoor water savings involve reductions in shower/faucet flow, and that indoor savings comprise 100% of total survey savings.

Gas savings = 0.0072 therms/gal x 0.67 x 0.5 x 1.00 = 0.0024 therms/gal

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 21 ID Name Class Category
M2 WaterWise Evaluations Multi Family Audits & Reports

All assumptions same as M1.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 22 ID Name Class Category
M3a Small Multi-Family Leak Alert Multi Family Audits & Reports

Water Savings: Detailed empirical analysis of SFPUC’s Multi-Family Customer Leak Alert Program concluded:

• The Program reduced the mean duration of leak events lasting 72 or more hours from 235.7 to 137.0 hours.
• The Program reduced the frequency of leak events lasting 72 or more hours from 0.656 to 0.453 leaks per meter-year.
• The Program reduced the mean leak volume from 1519 to 925.5 gallons per meter-year, or 593.5 gallons per meter-year (1.6 gpd).

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 1 year.

Peak Period Savings Percent: We assume leaks are more or less distributed uniformly across the year.

Peak period runs from May 1 to Sep 30, representing 42% of days.

Unit Sewer Savings: We do not have data on how leakage is distributed between indoor and outdoor water uses. We assume multi-family water use is dominated by indoor water uses and so too are water savings from leak alerts.

Sewer savings = 0.9 x 593.5 gpy per meter = 534.2 gpy per meter Wastewater to water savings ratio = 0.9

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 23 ID Name Class Category
M3b Large Multi-Family Leak Alert Multi Family Audits & Reports

Water Savings: A statistically significant reduction in mean leakage volume between the pre- program and program periods was not detected. Thus, we do not estimate any water savings for the large multi- family leak alert program.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 1 year.

Peak Period Savings Percent: We assume leaks are more or less distributed uniformly across the year.

Peak period runs from May 1 to Sep 30, representing 42% of days.

Unit Sewer Savings: We do not have data on how leakage is distributed between indoor and outdoor water uses. We assume multi-family water use is dominated by indoor water uses and so too are water savings from leak alerts.

Sewer savings = 0.9 x 0 gpy per meter = 0 gpy per meter Wastewater to water savings ratio = 0.9

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 24 ID Name Class Category
M4 Showerheads Distributions Multi Family HESH

Water Savings: M.Cubed and A&N Technical Services (2018a, 2018b) estimated toilet, showerhead, and aerator water savings from direct installation bathroom retrofit programs in Bakersfield, Torrance, and East Los Angeles targeting both single- and multi-family bathrooms. Mean savings for showerheads installed in multi-family households was 12.6 gpd. Field studies of retrofit kit distributions in Irvine (A&N Technical Services 1992d) and Los Angeles (A&N Technical Services 1991) have found initial installation probabilities that range from 49% to 59%. We assume a 54% installation probability.

Water savings = 0.54 x 12.6 gpd = 6.8 gpd (2482 gpy)

Plumbing Code Savings: Zero. SB 407 mandates showerheads have a maximum capacity of 2.5 gpm.

Currently, the average flow rate of showerheads in SFPUC’s retail service area is 1.95, per DeOreo and Mayer (2010a).

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 8 yrs, per Alliance for Water Efficiency (2014).

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 6.8 gpd (2482 gpy)
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006) and that hot water comprises 67% of shower/faucet flow - average of DOE (2006) and Aquacraft (). Gas savings = 0.0072 therms/gal x 0.67 = 0.0048 therms/gal

Confidence Score: 2
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 25 ID Name Class Category
M5 Showerheads Direct Install Multi Family HESH

Water Savings: M.Cubed and A&N Technical Services (2018a, 2018b) estimated toilet, showerhead, and aerator water savings from direct installation bathroom retrofit programs in Bakersfield, Torrance, and East Los Angeles targeting both single- and multi-family bathrooms. Mean savings for showerheads installed in multi-family households was 12.6 gpd (4599 gpy).

Unit Sewer Savings: Sewer savings = 12.6 gpd (4599 gpy)

All other assumptions same as M4.

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 26 ID Name Class Category
M6a HET Rebate (Tank) Multi Family HET

Water Savings: M.Cubed and A&N Technical Services (2018a, 2018b) estimated toilet, showerhead, and aerator water savings from direct installation bathroom retrofit programs in Bakersfield, Torrance, and East Los Angeles targeting both single- and multi-family bathrooms. Installed HETs had flush rates of 1.0 gpf or less. Mean savings for HETs installed in multi-family households was 38.6 gpd (14089 gpy). Direct installation programs can more effectively screen out the replacement of ULF toilets than can rebate programs. Nearly all the toilets replaced in the direct installation programs evaluated by M.Cubed and A&N Technical Services were older non-ULFT toilets. Rebate programs may inadvertently issue rebates for the replacement of ULF toilets. To account for this possibility, mean daily savings estimated for the direct installation programs is reduced by 25%.

Water savings = 38.6 gpd x 0.75 = 30.0 gpd (10950 gpy)

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 30.0 gpd (10950 gpy) Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 27 ID Name Class Category
M6b HET Rebate (Flushometer) Multi Family HET

All assumptions same as M6a.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 28 ID Name Class Category
M7a HET Direct Install (Tank) Multi Family HET

Water Savings: M.Cubed and A&N Technical Services (2018a, 2018b) estimated toilet, showerhead, and aerator water savings from direct installation bathroom retrofit programs in Bakersfield, Torrance, and East Los Angeles targeting both single- and multi-family bathrooms. Installed HETs had flush rates of 1.0 gpf or less. Mean savings for HETs installed in multi-family households was 38.6 gpd (14089 gpy).

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 38.6 gpd (14089 gpy) Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 29 ID Name Class Category
M7b HET Direct Install (Flushometer) Multi Family HET

All assumptions same as M7a.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 30 SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 31 ID Name Class Category
M7c ULFT to Ultra-High-Efficiency
Toilet Direct Install
Multi Family HET

Water Savings: 9.3 gpd (3395 gpy). Engineering estimate prepared by SFPUC staff.

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency. Period of savings attributed to program does not exceed useful life of toilet. On average savings are counted for 33 years, the average useful life of the toilet.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 9.3 gpd (3395 gpy)
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 32 ID Name Class Category
M8 HET Voucher Multi Family HET

All assumptions same as M6a.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 33 ID Name Class Category
M9 HET/Fixture Install thru On-Bill Financing Multi Family HET

All assumptions same as M7a.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 34 ID Name Class Category
M10 CEE Tier 3 Rebate (IWF 4.0) Multi Family HEW

Note that the model has separate measures for M10a and M10b that are distinguished only by differing rebate amounts provided through time.

Water Savings: Assumes rebates are for common area laundry rooms, not individual apartments.

Without rebate, participant will purchase either top- or front-load washer. Current market share (circa 2012) of top-load washers is 52%, per DOE (2012). Current Energy Star market share (circa 2012) is 50%, per DOE (2012). Maximum allowed IWF for Energy Star washer after 2011 is 6. Maximum allowed IWF for non-Energy Star washer is 9.5, per National Appliance Standard. (National Appliance Standard changes in 2015 to 4.5 IWF for front-load and 8.0 IWF for top-load, and again in 2018 to 6.0 IWF for top- load). Average IWF of new washer is:

Avg IWF of New Washer Without Rebate = 0.5 x 6.0 + 0.5 x 9.5 = 7.75 (note this will overstate avg IWF after 2015 due to nat’l appl stdrd)

Average washer loads per day is 8.4, per M.Cubed (2014). Average volume of new clothes washer for common area use is assumed to be 4 cubic feet.

Water savings = (7.75 – 4.0) x 4 x 8.4 = 126 gpd (45,990 gpy) [Get energy star commercial list]

Plumbing Code Savings: Effective Jan 1, 2015, appliance standard is 4.5 IWF for front-load and 8.0 IWF for top-load. Given current front- and top-load market shares and Energy Star market share, average IWF under appliance standard in 2015 is:

2015 Avg IWF under Nat’l Appl Std = 0.52 x (0.5 x 8.0 + 0.5 x 6.0) + 0.48 x 4.5 = 5.8

Effective Jan 1, 2018, appliance standard is 4.5 IWF for front-load and 6.0 for top-load. Average IWF under appliance standard in 2018 is:

2018 Avg IWF under Nat’l Appl Std = 0.52 x 6.0 + 0.48 x 4.5 = 5.3.

For modeling conservation program benefits, we use the average of these two water factors – 5.6 -- and start the standard in 2015. Plumbing code savings starting in 2015 are:

Plumbing code savings = (7.75 – 5.6) x 4 x 8.4 = 72 gpd (26,280)

Plumbing Code NRR: 7.1%. Based on average washer life of 14 years, per DOE (2012).

Annual Decay Rate: NA

Useful Life: 14 years, per DOE (2012)

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 126 gpd (45,990 gpy) SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 35 Wastewater to water savings ratio = 1.000

Unit Electricity Savings: 0.0036 KWh/gal. Based on high efficiency washer electricity savings reported in FEMP (2000).

Unit Gas Savings: 0.0035 therms/gal. Based on high efficiency washer gas savings reported in FEMP (2000).

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 36 ID Name Class Category
M17 Efficient Irrigation Timer Rebate Multi Family HET

All assumptions same as S18.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 37 ID Name Class Category
M20 Device Distribution Multi Family Grants

Water Savings: Water savings are a quantity-weighted average of devices distributed by SFPUC. The devices, quantity weights, and annual savings are shown in the following table.

Devices
Annual
Quantity
Savings
(GPY)

1.5 gpm bathroom aerator 8229 210

1.0 gpm bathroom aerator 0 361

0.5 gpm bathroom aerator 1537 511

1.5 gpm kitchen laminar 0 210

1.5 gpm bathroom laminar 0 210

2.2 gpm kitchen aerator 265 0

1.5 gpm kitchen aerator 4641 210

1.5 utility aerator 54 210

2.0 utility aerator 54 60

2.2 utility aerator 16 0
Garden spray hose nozzle 295 0 No reliable estimates
Toilet flapper 3603 1212
Toilet fill valves 1819 1212 Assumed to be same as flapper savings Soil moisture meter 7 0 No reliable estimates
Total 20520
Weighted Avg Savings 491

Annual savings for aerators are based on the following data and assumptions:

• Median SFR faucet use is 29 gpd (source: Aquacraft SFPUC End Use Study). • An average of 4 faucets per household is assumed.
• Average use per faucet is 7.25 gpd. The calculation assumes uniform faucet usage, which while unlikely to be true is necessary given lack of data on faucet use. • Aerators reduce free flowing faucet water consumption. It is assumed half of faucet use is for free flowing uses (e.g. brushing teeth or washing vegetables) and half is for fixed volume uses (e.g. filling pots or getting a drink of water). Free flowing faucet use is therefore 3.63 gpd. • Average faucet flow is assumed to be 2.2 gpm. Therefore, faucets average 1.6 minutes of free flowing use per day.
• It is assumed half of distributed faucets are installed.

Given these assumptions, savings by aerator flow rate are:

Aerator
flow rate
(gpm)
Avg Use
GPD
Potential
Savings
(GPD) Install %
Actual
Savings
(GPD)
Actual
Savings
(GPY)

2.2 3.63 0.00 50% 0.00 0

2.0 3.30 0.33 50% 0.16 60

1.5 2.47 1.15 50% 0.58 210

1.0 1.65 1.98 50% 0.99 361

0.5 0.82 2.80 50% 1.40 511
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 38 Annual savings for flappers and fill valves are based on the following data and assumptions:

• Median SFR leakage rate is 8.3 gpd, per Aquacraft SFPUC End Use Study. • According to 2004 CUWCC Toilet Flapper Study and 1999 Residential End Use Study most household water leaks can be attributed to toilets. It is assumed toilet leaks account for 80% of the median leakage rate, or 6.64 gpd.
• It is assumed replacing flapper or fill valves will eliminate toilet-related leakage. • It is assumed half of distributed flappers and fill valves are installed.

Given these assumptions, water savings are 3.32 gpd, or 1212 gpy.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 5 years

Peak Period Savings Percent:

Unit Sewer Savings: Same as water savings

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 39 ID Name Class Category
M21 ULFT to Ultra-High-Efficiency
Toilet Direct Install
Multi Family HET

Water Savings: 9.3 gpd (3395 gpy). Engineering estimate prepared by SFPUC staff.

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency. Period of savings attributed to program does not exceed useful life of toilet. On average savings are counted for 33 years, the average useful life of the toilet.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 9.3 gpd (3395 gpy)
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 40 ID Name Class Category
M22 ULFT to Ultra-High-Efficiency
Toilet Rebate
Multi Family HET

Water Savings: 6.9 gpd (2519 gpy). Engineering estimate prepared by SFPUC staff.

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency. Period of savings attributed to program does not exceed useful life of toilet. On average savings are counted for 33 years, the average useful life of the toilet.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 6.9 gpd (2519 gpy)
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 41 Non Residential Measures

ID Name Class Category
N1 WaterWise Evaluations for Commercial Buildings Non Residential Audits & Reports

Water Savings: Assumes basic analyst or staff evaluations identify an average of 20% potential water savings per site, per CUWCC (2005). For calculating water savings, we assume 50% of potential savings are realized. Average realized water savings is therefore 10% of site use, which matches the assumption used by the SFPUC Retail Demand Model. Average water use per site (circa 2014) is 2,154 gpd, per SFPUC Retail Demand Model.

Water savings = 0.2 x 0.5 x 2,154 gpd = 215 gpd (78,475 gpy)

(NOTE: A higher estimate is warranted if SFPUC targets sites with higher than average use.)

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA. No savings persistence data reported in CUWCC (2005).

Useful Life: No savings persistence data reported in CUWCC (2005). We assume same average life as S1 – 5 years.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year, 80% of outdoor savings occur in peak period. Peak period runs from May 1 to Sep 30, representing 42% of days.

Assumes 18% of savings are irrigation-related, per CUWCC (2005).

Peak % = (0.42 x 0.82 x 215 gpd + 0.8 x 0.18 x 215 gpd)/215 gpd = 49%

Unit Sewer Savings: Sewer savings = 0.82 x 215 gpd = 176 gpd (64,240 gpy) Wastewater to water savings ratio = 0.820

Unit Electricity Savings: NA. No data on electricity savings

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006), that hot water comprises 67% of shower/faucet flow - per DOE (2006) – that one-quarter of indoor water savings involve reductions in shower/faucet flow, and that indoor savings comprise 82% of total survey savings. Gas savings = 0.0072 therms/gal x 0.67 x 0.25 x 0.82 = 0.001 therms/gal

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 42 ID Name Class Category
N2 Commercial Direct Install Audits Non Residential Audits & Reports

All assumptions same as N1.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 43 ID Name Class Category
N3a,N3b,N3c Surveys – Hospitals, Hotels, Schools Non Residential Audits & Reports

Water Savings: Number of sites and average daily use per site (circa 2013) shown in table are taken from the SFPUC Retail Demand Model.

Category Number of Sites Average Daily Use (gpd)
Hospitals 28 46,429
Hotels 421 9,929
Schools 297 2,559
Wtd Avg 8,365

Assumes basic analyst or staff evaluations identify an average of 20% potential water savings per site, per CUWCC (2005). For calculating water savings, we assume 50% of potential savings are realized.

Average realized water savings is therefore 10% of site use, which matches the assumption used by the SFPUC Retail Demand Model. Average water use per site is 8,365 gpd, per above table.

Water savings wtd average = 0.2 x 0.5 x 8,365 gpd = 837 gpd (305,505 gpy) Hospitals = 0.2 x 0.5 x 46,429 gpd = 4643 gpd (1,694,695 gpy) Hotels = 0.2 x 0.5 x 9,929 gpd = 993 gpd (362,445 gpy)
Schools = 0.2 x 0.5 x 2,559 gpd = 256 gpd (93,440 gpy)

(NOTE: A higher estimate is warranted if SFPUC targets sites with higher than average use.)

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA. No savings persistence data reported in CUWCC (2005).

Useful Life: No savings persistence data reported in CUWCC (2005). We assume same average life as S1 – 5 years.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year, 80% of outdoor savings occur in peak period. Peak period runs from May 1 to Sep 30, representing 42% of days.

Assumes 18% of savings are irrigation-related, per CUWCC (2005).

Peak % = (0.42 x 0.82 x 837 gpd + 0.8 x 0.18 x 837 gpd)/837 gpd = 49%

Unit Sewer Savings: Sewer savings = 0.82 x 837 gpd = 686 gpd (250,390 gpy) Hospitals = 3,807 gpd (1,389,555 gpy)
Hotels = 814 gpd (297,110 gpy)
Schools = 210 gpd (76,650 gpy)
Wastewater to water savings ratio = 0.820

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 44 Unit Electricity Savings: NA. No data on electricity savings

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006), that hot water comprises 67% of shower/faucet flow - per DOE (2006) – that 50% of indoor water savings involve reductions in shower/faucet flow, and that indoor savings comprise 82% of total survey savings. Gas savings = 0.0072 therms/gal x 0.67 x 0.5 x 0.82 = 0.002 therms/gal

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 45 ID Name Class Category
N4 Surveys – Large Landscape by Contractors Non Residential Audits & Reports

Water Savings: Per SFPUC Retail Demand Model, average use per site is 1.8 af/acre. Average water savings is 10%, also per SFPUC Retail Demand Model.

Water savings per acre = 0.1 x 1.8 x 325,851/365 = 161 gpd (58,765 gpy)

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA. No savings persistence data reported in CUWCC (2005).

Useful Life: No savings persistence data reported in CUWCC (2005). We assume same average life as S1 – 5 years. Same assumption used in SFPUC Retail Demand Model.

Peak Period Savings Percent: Assumes 80% of outdoor savings occur in peak period. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 80%

Unit Sewer Savings: NA

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 46 ID Name Class Category
N5 Surveys – CII Facilities by Contractors Non Residential Audits & Reports

Water Savings: SFPUC estimates consultant audits save from 2,450 to 7,790 gpd. Model assumes midpoint of range – 5,120 gpd.

Water savings = 0.5 x (2,450 gpd + 7,790 gpd) = 5,120 gpd (1,868,800 gpy)

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA. No savings persistence data reported in CUWCC (2005).

Useful Life: No savings persistence data reported in CUWCC (2005). We assume same average life as S1 – 5 years. Same assumption used in SFPUC Retail Demand Model.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year, 80% of outdoor savings occur in peak period. Peak period runs from May 1 to Sep 30, representing 42% of days.

Assumes 23% of savings are irrigation-related, per CUWCC (2005).

Peak % = (0.42 x 0.77 x 5120 gpd + 0.8 x 0.23 x 5120 gpd)/5120 gpd = 51%

Unit Sewer Savings: Sewer savings = 0.77 x 5120 gpd = 3,942 gpd (1,438,830 gpy)

Unit Electricity Savings: NA. No data on electricity savings

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006), that hot water comprises 67% of shower/faucet flow - per DOE (2006) – that one-quarter of indoor water savings involve reductions in shower/faucet flow, and that indoor savings comprise 82% of total survey savings. Gas savings = 0.0072 therms/gal x 0.67 x 0.25 x 0.77 = 0.0009 therms/gal

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 47 ID Name Class Category
N6 Landscape Leak Alerts Non Residential Audits & Reports

Water Savings: Detailed empirical analysis of SFPUC’s Landscape Customer Leak Alert Program concluded:

• The Program reduced the mean duration of leak events lasting 72 or more hours from 598.2 to 434.1 hours.
• The Program reduced the frequency of leak events lasting 72 or more hours from 1.048 to 0.840 leaks per meter-year.
• The Program reduced the mean leak volume by 10311 gallons per meter-year (28.2 gpd).

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 1 year.

Peak Period Savings Percent: We assume leaks are more or less distributed uniformly across the year.

Peak period runs from May 1 to Sep 30, representing 42% of days.

Unit Sewer Savings: Outdoor water use only

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 48 ID Name Class Category
N7 1.5 GPM Showerhead Giveaway Non Residential HESH

Water Savings: Water savings estimate assumes program targets lodging establishments where shower water use comprises a significant proportion of total facility water use. Hotel shower water use from data logging done for the 2000 AWWARF CII End Uses of Water Study are summarized in the following table.

Shower Water Use Estimates from AWWARF CII End Uses of Water Study, 2000

Implied Retrofit
Water Use
Utilization
Rate Water Use Savings

Hotel Location gpy/showerhead minutes/day gpy/showerhead gpy/showerhead % Hot Irvine 10,203 13 6,957 3,246 71%
Phoenix 13,724 17 9,357 4,367 28%
San Diego 12,446 15 8,486 3,960
Santa Monica 11,182 14 7,624 3,558
Average 11,889 15 8,106 3,783 50%

Mean flow rate (gpm) 2.2
Retrofit flow rate (gpm) 1.5

We assume installed showerheads will have a mean savings rate of 3,800 gpy. Field studies of retrofit kit giveaway programs in Irvine (A&N Technical Services 1992d) and Los Angeles (A&N Technical Services 1991) found initial installation probabilities that ranged from 49% to 59%. We assume a 54% installation probability.

Giveaway showerhead savings = 3,800 gpy/showerhead x 0.54 = 2,052 gpy/showerhead Plumbing Code Savings: Zero. SB 407 mandates showerheads have a maximum capacity of 2.5 gpm. It is assumed the flow rating of replaced showerheads will be 2.5 gpm or less

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 8 yrs, per Alliance for Water Efficiency (2014).

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 2,052 gpy
Wastewater to water savings ratio = 1.000

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 49 Unit Electricity Savings: NA

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006) and that hot water comprises 50% of shower flow per above table. Gas savings = 0.0072 therms/gal x 0.5 = 0.0036therms/gal

Confidence Score: 3
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 50 ID Name Class Category
N8 1.5 GPM Showerhead Direct Install Non Residential HESH

Water Savings: Water savings estimate assumes program targets lodging establishments where shower water use comprises a significant proportion of total facility water use. Hotel shower water use from data logging done for the 2000 AWWARF CII End Uses of Water Study are summarized in the following table.

Shower Water Use Estimates from AWWARF CII End Uses of Water Study, 2000

Implied Retrofit
Water Use
Utilization
Rate Water Use Savings

Hotel Location gpy/showerhead minutes/day gpy/showerhead gpy/showerhead % Hot Irvine 10,203 13 6,957 3,246 71%
Phoenix 13,724 17 9,357 4,367 28%
San Diego 12,446 15 8,486 3,960
Santa Monica 11,182 14 7,624 3,558
Average 11,889 15 8,106 3,783 50%

Assumed Mean flow rate (gpm) 2.2
Retrofit flow rate (gpm) 1.5

We assume installed showerheads will have a mean savings rate of 3,800 gpy/showerhead installed.

Plumbing Code Savings: Zero. SB 407 mandates showerheads have a maximum capacity of 2.5 gpm. It is assumed the flow rating of replaced showerheads will be 2.5 gpm or less

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 8 yrs, per Alliance for Water Efficiency (2014).

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 3,800 gpy
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: Assumes energy requirement of 0.0072 therms/gal for hot water heating, per DOE (2006) and that hot water comprises 50% of shower flow per above table. Gas savings = 0.0072 therms/gal x 0.5 = 0.0036therms/gal
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 51 Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 52 ID Name Class Category
N9 Device Distribution Non Residential Grants

Water Savings: Water savings are a quantity-weighted average of devices distributed by SFPUC. The devices, quantity weights, and annual savings are shown in the following table.

Devices
Annual
Quantity
Savings
(GPY)

1.5 gpm bathroom aerator 8229 210

1.0 gpm bathroom aerator 0 361

0.5 gpm bathroom aerator 1537 511

1.5 gpm kitchen laminar 0 210

1.5 gpm bathroom laminar 0 210

2.2 gpm kitchen aerator 265 0

1.5 gpm kitchen aerator 4641 210

1.5 utility aerator 54 210

2.0 utility aerator 54 60

2.2 utility aerator 16 0
Garden spray hose nozzle 295 0 No reliable estimates
Toilet flapper 3603 1212
Toilet fill valves 1819 1212 Assumed to be same as flapper savings Soil moisture meter 7 0 No reliable estimates
Total 20520
Weighted Avg Savings 491

Annual savings for aerators are based on the following data and assumptions:

• Median SFR faucet use is 29 gpd (source: Aquacraft SFPUC End Use Study). • An average of 4 faucets per household is assumed.
• Average use per faucet is 7.25 gpd. The calculation assumes uniform faucet usage, which while unlikely to be true is necessary given lack of data on faucet use. • Aerators reduce free flowing faucet water consumption. It is assumed half of faucet use is for free flowing uses (e.g. brushing teeth or washing vegetables) and half is for fixed volume uses (e.g. filling pots or getting a drink of water). Free flowing faucet use is therefore 3.63 gpd. • Average faucet flow is assumed to be 2.2 gpm. Therefore, faucets average 1.6 minutes of free flowing use per day.
• It is assumed half of distributed faucets are installed.

Given these assumptions, savings by aerator flow rate are:

Aerator
flow rate
(gpm)
Avg Use
GPD
Potential
Savings
(GPD) Install %
Actual
Savings
(GPD)
Actual
Savings
(GPY)

2.2 3.63 0.00 50% 0.00 0

2.0 3.30 0.33 50% 0.16 60

1.5 2.47 1.15 50% 0.58 210

1.0 1.65 1.98 50% 0.99 361
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 53 0.5 0.82 2.80 50% 1.40 511

Annual savings for flappers and fill valves are based on the following data and assumptions:

• Median SFR leakage rate is 8.3 gpd, per Aquacraft SFPUC End Use Study. • According to 2004 CUWCC Toilet Flapper Study and 1999 Residential End Use Study most household water leaks can be attributed to toilets. It is assumed toilet leaks account for 80% of the median leakage rate, or 6.64 gpd.
• It is assumed replacing flapper or fill valves will eliminate toilet-related leakage. • It is assumed half of distributed flappers and fill valves are installed.

Given these assumptions, water savings are 3.32 gpd, or 1212 gpy.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 5 years

Peak Period Savings Percent:

Unit Sewer Savings: Same as water savings

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 54 ID Name Class Category
N10a HET Rebates (Tank) - CII Non Residential HET

Water Savings: Savings based on CUWCC CII Toilet Savings Study (2001). Assume 10% of rebates replace ULFTs
Water savings = 0.9 x 1.15 x 25 gpd + 0.1 x 25 gpd = 28.4 gpd (10,366 gpy)

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency.

Peak Period Savings Percent:

Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days.

Peak % = 42%

Unit Sewer Savings: Sewer savings = same as water savings Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 55 ID Name Class Category
N10b HET Rebates (Flushometer) - CII Non Residential HET

Water Savings: Savings based on CUWCC CII Toilet Savings Study (2001). Assume 10% of rebates replace ULFTs
Water savings = 0.9 x 1.15 x 25 gpd + 0.1 x 25 gpd = 28.4 gpd (10,366 gpy)

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency.

Peak Period Savings Percent:

Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days.

Peak % = 42%

Unit Sewer Savings: Sewer savings = same as water savings Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 56 ID Name Class Category
N11a,N11b,N11c HET Rebates Schools, Hotels, Muni (Tank) Non Residential HET

Water Savings: Assumes program targets non-ULF toilets. CUWCC (2001) estimated replacing non-ULF toilets with ULF toilets in schools, hotels, and government facilities resulted in average daily savings shown in the table.

Category Avg Savings Per ULF Toilet (gpd) Imputed Flushes/Day Schools 18 8.4
Hotels 16 7.4
Government 25 11.6
Avg Savings 20 9.3
Note: GPD savings from CUWCC (2001). Imputed flushes/day assumes avg of replaced toilet was 3.75 gpf

Assume 10% of rebates replace ULFTs
Schools: [0.1(1.6-1.28)+0.9(3.75-1.28)] x 8.4 = 18.9 gpd (6,914) Hotels: [0.1(1.6-1.28)+0.9(3.75-1.28)] x 7.4 = 16.7 gpd (6,096) Gov: [0.1(1.6-1.28)+0.9(3.75-1.28)] x 11.6 = 26.2 gpd (9,563)

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency.

Peak Period Savings Percent:

Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days.

Peak % = 42%

Unit Sewer Savings: Sewer savings = same as water savings Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 57 ID Name Class Category
N11d,N11e,N11f HET Rebates Schools, Hotels, Muni
(Flushometer)
Non Residential HET

All assumptions same as N11a, N11b, N11c.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 58 ID Name Class Category
N12a HET Direct Install (Tank) - CII Non Residential HET

Water Savings: Assumes program targets non-ULF toilets. CUWCC (2001) estimated replacing non-ULF toilets with ULF toilets resulted in average daily savings of 25 gpd. Assuming non-ULF toilets have an average flush volume of 3.75, the HE toilet would save approximately 15% more than a ULF toilet.

Water savings = 1.15 x 25 gpd = 29 gpd (10,585 gpy)

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency.

Peak Period Savings Percent:

Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days.

Peak % = 42%

Unit Sewer Savings: Sewer savings = 29 gpd (10,585 gpy) Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 59 ID Name Class Category
N12b HET Direct Install (Flushometer) - CII Non Residential HET

All assumptions same as N12a.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 60 ID Name Class Category
N13 HET Direct Install School/Hotel Non Residential HET

Water Savings: Assumes program targets non-ULF toilets. CUWCC (2001) estimated replacing non-ULF toilets with ULF toilets in schools and hotels resulted in average daily savings shown in the table.

Category Avg Savings Per ULF Toilet (gpd) Imputed Flushes/Day Schools 18 8.4
Hotels 16 7.4
Avg Savings 17 7.9
Note: GPD savings from CUWCC (2001). Imputed flushes/day assumes avg of replaced toilet was 3.75 gpf

It is assumed direct install toilets would only replace non-ULF. Assuming non-ULF toilets have an average flush volume of 3.75, the HE toilet would save approximately 15% more than a ULF toilet.

Water savings = 1.15 x 17 gpd = 19.6 gpd (7,154 gpy)

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency.

Peak Period Savings Percent:

Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days.

Peak % = 42%

Unit Sewer Savings: Sewer savings = same as water savings Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 61 ID Name Class Category
N14 CII HET Voucher Non Residential HET

All assumptions same a N10

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 62 ID Name Class Category
N15 HET Voucher School/Hotel Non Residential HET
Water Savings: Assumes 90% of vouchers go to non-ULF and 10% go to ULF toilets. CUWCC (2001) estimated replacing non-ULF toilets with ULF toilets in schools and hotels resulted in average daily savings shown in the table.

Category Avg Savings Per ULF Toilet (gpd) Imputed Flushes/Day Schools 18 8.4
Hotels 16 7.4
Avg Savings 17 7.9
Note: GPD savings from CUWCC (2001). Imputed flushes/day assumes avg of replaced toilet was 3.75 gpf
Savings = [0.1 x (1.6 – 1.28) + 0.9 x (3.75 – 1.28)] x 7.9 = 17.8 gpd (6,497 gpy) Comparison to Retail Demand Model (RDM) Estimate: this measure is not in the RDM.

Plumbing Code NRR: 3% per M.Cubed (2014)
Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency.

Peak Period Savings Percent:

Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days.

Peak % = 42%
Unit Sewer Savings: Sewer savings = same as water savings Wastewater to water savings ratio = 1.000
Unit Electricity Savings: NA
Unit Gas Savings: NA
Confidence Score: 2
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 63 ID Name Class Category
N16 HET/Fixture Install thru On-Bill Financing Non Residential HET

All assumptions same as N12a

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 64 ID Name Class Category
N17a, N17b HEU Rebate - CII Non Residential HEU

Water Savings: From Koeller & Company (2005). Urinals in CA used an estimated 28,000 AFY in 2005.

Average flush rate is 2 times per day per male employee. Total employment in 2005 is 16.8 million, 55% male. Average flush volume = 28000 x 325851/[2 x 16.8 x 10^6 x 0.55 x 365) = 1.35 gpf

25 x 10^6 gal/day / 1.35 gal/flush = 18.5 x 10^6 flushes/day

18.5 x 10^6 flushes/day / 1.4 x 10^6 urinals (circa 2005) = 13.2 flushes/urinal/day

0.5 gpf: (1.35-.5) x 13.2 flush/day = 11.2 gpd (4,088 gpy)

0.25 gpf: (1.35-.25) x 13.2 flush/day = 14.5 gpd (5,293 gpy)

0.125 gpf: (1.35-.125) x 13.2 flush/day = 16.2 gpd (5,913 gpy)

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Same as water savings
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 65 ID Name Class Category
N18 HEU Direct Install - CII Non Residential HEU

All assumptions same as N17.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 66 ID Name Class Category
N20 Energy Star Washer Rebates (IWF

4.5)
Non Residential HEW

Water Savings: Assumes rebates are for common area laundry rooms, not individual apartments.

Without rebate, participant will purchase either top- or front-load washer. Current market share (circa 2012) of top-load washers is 52%, per DOE (2012). Current Energy Star market share (circa 2012) is 50%, per DOE (2012). Maximum allowed IWF for Energy Star washer after 2011 is 6. Maximum allowed IWF for non-Energy Star washer is 9.5, per National Appliance Standard. (National Appliance Standard changes in 2015 to 4.5 IWF for front-load and 8.0 IWF for top-load, and again in 2018 to 6.0 IWF for top- load). Average IWF of new washer is:

Avg IWF of New Washer Without Rebate = 0.5 x 6.0 + 0.5 x 9.5 = 7.75 (note this will overstate avg IWF after 2015 due to nat’l appl stdrd)

Average loads per day for machines with load capacity under 25 pounds is 3, per Sutter and Pope (2006).

Average washer volume is assumed to be 4 cubic feet.

Water savings = (7.75 – 4.5) x 4 x 3 = 39 gpd (14,235 gpy)

Plumbing Code Savings: Effective Jan 1, 2015, appliance standard is 4.5 IWF for front-load and 8.0 IWF for top-load. Given current front- and top-load market shares and Energy Star market share, average IWF under appliance standard in 2015 is:

2015 Avg IWF under Nat’l Appl Std = 0.52 x (0.5 x 8.0 + 0.5 x 6.0) + 0.48 x 4.5 = 5.8

Effective Jan 1, 2018, appliance standard is 4.5 IWF for front-load and 6.0 for top-load. Average IWF under appliance standard in 2018 is:

2018 Avg IWF under Nat’l Appl Std = 0.52 x 6.0 + 0.48 x 4.5 = 5.3.

For modeling conservation program benefits, we use the average of these two water factors – 5.6 -- and start the standard in 2015. Plumbing code savings starting in 2015 are:

Plumbing code savings = (7.75 – 5.6) x 4 x 3 = 26 gpd (9,490)

Plumbing Code NRR: 12.2%, average of the turnover rates assumed by AWE (11.1%) and DOE (13.3%) for commercial washers.

Annual Decay Rate: NA

Useful Life: 14 years, per DOE (2012)

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 39 gpd (14,235 gpy) Wastewater to water savings ratio = 1.000
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 67 Unit Electricity Savings: 0.0036 KWh/gal. Based on high efficiency washer electricity savings reported in FEMP (2000).

Unit Gas Savings: 0.0035 therms/gal. Based on high efficiency washer gas savings reported in FEMP (2000).

Confidence Score: 3
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 68 ID Name Class Category
N21 Energy Star Washer Rebates (IWF 4) Non Residential HEW

Note that the model has separate measures for N21a and N21b that are distinguished only by differing rebate amounts provided through time.

Water Savings: Assumes rebates are for common area laundry rooms, not individual apartments.

Without rebate, participant will purchase either top- or front-load washer. Current market share (circa 2012) of top-load washers is 52%, per DOE (2012). Current Energy Star market share (circa 2012) is 50%, per DOE (2012). Maximum allowed IWF for Energy Star washer after 2011 is 6. Maximum allowed IWF for non-Energy Star washer is 9.5, per National Appliance Standard. (National Appliance Standard changes in 2015 to 4.5 IWF for front-load and 8.0 IWF for top-load, and again in 2018 to 6.0 IWF for top- load). Average IWF of new washer is:

Avg IWF of New Washer Without Rebate = 0.5 x 6.0 + 0.5 x 9.5 = 7.75 (note this will overstate avg IWF after 2015 due to nat’l appl stdrd)

Average loads per day for machines with load capacity under 25 pounds is 3, per Sutter and Pope (2006).

Average washer volume is assumed to be 4 cubic feet.

Water savings = (7.75 – 4.0) x 4 x 3 = 45 gpd (16,425 gpy)

Plumbing Code Savings: Effective Jan 1, 2015, appliance standard is 4.5 IWF for front-load and 8.0 IWF for top-load. Given current front- and top-load market shares and Energy Star market share, average IWF under appliance standard in 2015 is:

2015 Avg IWF under Nat’l Appl Std = 0.52 x (0.5 x 8.0 + 0.5 x 6.0) + 0.48 x 4.5 = 5.8

Effective Jan 1, 2018, appliance standard is 4.5 IWF for front-load and 6.0 for top-load. Average IWF under appliance standard in 2018 is:

2018 Avg IWF under Nat’l Appl Std = 0.52 x 6.0 + 0.48 x 4.5 = 5.3.

For modeling conservation program benefits, we use the average of these two water factors – 5.6 -- and start the standard in 2015. Plumbing code savings starting in 2015 are:

Plumbing code savings = (7.75 – 5.6) x 4 x 3 = 26 gpd (9,490)

Plumbing Code NRR: 12.2%, average of the turnover rates assumed by AWE (11.1%) and DOE (13.3%) for commercial washers.

Annual Decay Rate: NA

Useful Life: 14 years, per DOE (2012)

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42% SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 69 Unit Sewer Savings: Sewer savings = 45 gpd (16,425 gpy) Wastewater to water savings ratio = 1.000

Unit Electricity Savings: 0.0036 KWh/gal. Based on high efficiency washer electricity savings reported in FEMP (2000).

Unit Gas Savings: 0.0035 therms/gal. Based on high efficiency washer gas savings reported in FEMP (2000).

Confidence Score: 3
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 70 ID Name Class Category
N22 Landscape Grants Non Residential Grants

Water Savings: Average savings for previous grant projects (implemented 2011-2019) is shown in the following table based on calculations performed by SFPUC. The pre-grant average water use per acre is

1.6 AFY/Acre and the average water savings per acre is 0.2 AFY/Acre (11%), or 65,170 gpy (179 gpd).

Project Name
Project
Size
(acres)
Pre-Grant
Use
(mgy)
Projected
Savings
(mgy)
Projected
Savings
(%)
Observed
Savings (mgy)1
Observed
Savings
(%)1
Balboa Park Water Conservation
Project 17.3 15.4 1.5 10% -1.24 -8%
Fort Mason Water Conservation
Irrigation Upgrades 12.3 25.8 4.6 18% 7.5 29%
Sunset Blvd. Landscape Irrigation
Retrofit 3.5 16.7 13.8 83% N/A N/A
Jefferson Square Park Water
Conservation Project 5.1 6.0 1.7 28% 0.52 9%
Alta Plaza Park Water
Conservation Project 4.0 9.7 3.8 39% -0.65 -7%
Laguna Honda Hospital Water
Conservation Project 2.5 2.9 0.96 33% N/A N/A
Moscone Recreation Center 6.2 8.8 2.7 30% -0.36 -4%
Alamo Square Park 9.4 8.8 1.4 16% 2.41 27%
Sunol Glen Elementary School 1.7 2.56 1.17 46% 0.03 1%
Washington Square Park 1.5 3.0 1.7 60% X X
Forest Hill Station 0.7 1.13 0.44 39% 0.0 0%
1 Based on simple comparison of billed consumption before and after project installation, with no controls for factors like weather, price, or drought restrictions.

Program N22a (Landscape Grants Pre2020) in the Tracking Model reflects landscapes with over 0.5 acre of irrigated area that were installed before 2020.

Program N22b (Landscape Grants Post 2020) in the Tracking Model reflects landscapes of 10,000 sf to

0.5 ac or more of irrigated area. Only one project of 10,000 sq ft has been completed between 2020- 2025 (Lombard Street in May 2023). The Filoli Center Irrigation System Update Project is 845,000 sq ft (19.4 ac) and begins construction in 2025. Water savings are assumed to be the same as those estimated for N22a projects until updated savings estimates can be calculated from newly installed projects.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA. No savings persistence data reported in CUWCC (2005).

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 71 Useful Life: SFPUC program assumption is 20 years.

Peak Period Savings Percent: Assumes 80% of outdoor savings occur in peak period. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 80%

Unit Sewer Savings: NA

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 72 ID Name Class Category
N24 Equipment Retrofit Rebates Non Residential Grants

Water Savings: Water savings are 1 CCF/Yr (748 gpy) because the savings are entered directly as CCF/Yr in the Annual Activity.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 10 years

Peak Period Savings Percent: 42%

Unit Sewer Savings: Same as water savings
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 73 ID Name Class Category
N25 Custom Equipment Retrofit Rebates Non Residential Grants

All assumptions same as N24
N25a and N25b are only distinguished by the unit cost for each program.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 74 ID Name Class Category
N26 Non-Residential Leak Alerts Non Residential Audits & Reports

Water Savings: Detailed empirical analysis of SFPUC’s Landscape Customer Leak Alert Program concluded:

• The Program reduced the mean duration of leak events lasting 72 or more hours from 495.6 to 438.4 hours.
• The Program did not reduce leak frequency.
• The Program reduced the mean leak volume by 1841.7 gallons per meter-year (5.0 gpd).

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 1 year.

Peak Period Savings Percent: We assume leaks are more or less distributed uniformly across the year.

Peak period runs from May 1 to Sep 30, representing 42% of days.

Unit Sewer Savings: We do not have data on how leakage is distributed between indoor and outdoor water uses. We assume non-residential water use is dominated by indoor water uses and so too are water savings from leak alerts.

Sewer savings = 0.9 x 1841.7 gpy per meter = 1657.5 gpy per meter Wastewater to water savings ratio = 0.9

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 75 ID Name Class Category
N27 Kitchen Low Flow Spray Valves Non Residential Grants

All assumptions taken directly from the SFPUC Retail Demand Model. The SFPUC Retail Demand Model used a daily water savings estimate of 30 gpd (10,950 gpy) and fixture useful life of 10 years. The estimate is based on empirical estimates of daily savings (60 gpd) and a 50% installation and retention rate.

Confidence Score: 1

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 76 ID Name Class Category
N29 Efficient Irrigation Timer
Rebate
Non-Residential Grants

Water Savings: 13.4 gpd or 4891 gpy. This is the lower-bound of 95% CI of average savings per station, per A&N Technical's 2011 WBIC savings evaluation. Lower-bound is used because of San Francisco's climate and lower landscape water use.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 10 years. Assumed

Peak Period Savings Percent: 100% of savings assumed to occur in peak season.

Unit Sewer Savings: NA

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 2

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 77 ID Name Class Category
N30 ULFT to Ultra-High-Efficiency
Toilet Rebate
Non-Residential HET

Water Savings: 7.0 gpd (2540 gpy). Engineering estimate prepared by SFPUC staff.

Plumbing Code Savings: Effective Jan 1, 2014, same as water savings

Plumbing Code NRR: 3% per M.Cubed (2014)

Annual Decay Rate: NA. Leakage and double flushing assumed no worse than toilets replaced.

Useful Life: NA. Plumbing code ensures toilet cannot revert to lower efficiency. Period of savings attributed to program does not exceed useful life of toilet. On average savings are counted for 33 years, the average useful life of the toilet.

Peak Period Savings Percent: Assumes indoor savings evenly distributed through year. Peak period runs from May 1 to Sep 30, representing 42% of days. Peak % = 42%

Unit Sewer Savings: Sewer savings = 7.0 gpd (2540 gpy)
Wastewater to water savings ratio = 1.000

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 78 ID Name Class Category
A3 Irrigation Customer Landscape
Budgets
Non Residential Audits & Reports

Water Savings: Many water suppliers have adopted water budgets for their large landscapes, which provides an effective way for both managing and evaluating large landscape programs. Landscape budgets are a form of customer education/information designed to help customers irrigate landscape efficiently. The effectiveness of this intervention can vary significantly depending on existing water use practices, types of landscapes subject to budgets, types of customers receiving budgets, cost of water, etc. There have been several empirical evaluations of landscape budget performance. Cal WEP provides a good summary of these studies.

The impact of landscape education on compliance with water budgets was evaluated in Orange County, California in a 2004 study. The education component was targeted at landscape contractors and property managers at home-owner associations (HOAs). The results were based on the experience of 47 HOAs that had participated in the program up to that point. The impact evaluation concluded that early participants in the program reduced their water demand by 9%, later participants by 20% (the difference between early and later participants was not explained).

Several studies are available that examine the impact of budget-based rates on large landscape water use. An early study, published in 1997 showed that tiered rates tied to landscape water budgets can reduce irrigation demand by about 20-25%.

Cal WEP compiled data from 12 Bay Area retailers on actual water use versus budget for a sample of large landscapes. On average, actual use exceeded budgeted use by 33%. Cal WEP also compared budget exceedence by type of customer. It found budget exceedence was greatest for HOAs and commercial properties (excluding gold courses) and lowest for parks and schools. The average exceedence for HOAs and commercial was 23% and 34%, respectively; for parks and schools it was 10% and 5%, respectively.

This measure assumes budgets would reduce large landscape water use by 10%, on average. This is at the lower-end of the savings range from empirical studies and significantly less than the average budget exceedence for the sample of 12 Bay Area water agencies. A conservative savings assumption is deemed appropriate because:

• Parks and schools, which tend to have lower budge exceedence, comprise most of the large landscape area in SFPUC’s retail service area.
• SFPUC’s high retail water rates already discourage wasteful irrigation and landscape water use. • SFPUC’s cool summer climate results in lower irrigation application rates relative to other parts of California with dryer, hotter summer climates.

The average pre-grant irrigation application rate at large landscape sites participating in SFPUC’s large landscape grant program is 4 AF/acre (see N22).

Savings = 4 AF/acre x 0.1 = 0.4 AF/acre (130,340 gpy/acre)

Plumbing Code Savings: NA
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 79 Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 1 year

Peak Period Savings Percent: 100%

Unit Sewer Savings: 0

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 80 ID Name Class Category
A4a Municipal Large Landscape Budget Non Residential Audits & Reports

Water Savings: Assumes 10% reduction in average pre-budget water use of 0.54 AF/Ac. See further detail in Measure A3.

Savings = 0.54 AF/acre x 0.1 = 0.054 AF/acre (17,596 gpy/acre; 48 gpd/acre)

SFPUC analyzed 2020 satellite imagery for all parcels associated with dedicated irrigation meters and identified the area of irrigable, irrigated landscape cover served by each meter and parcel. Based on calendar year 2024 billed consumption, the average pre-budget water use for municipal irrigation accounts was 0.54 AF/ac, based on 867 acres of irrigable, irrigated municipal landscape served by dedicated irrigation meters that are slated to receive regular water budget reports starting in late 2025.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 1 year

Peak Period Savings Percent: 100%

Unit Sewer Savings: 0

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 81 ID Name Class Category
A4b Non-Municipal Large Landscape
Budget
Non Residential Audits & Reports

Water Savings: Assumes 10% reduction in average pre-budget water use of 2.64 AF/Ac. See further detail in Measure A3.

Savings = 2.64 AF/acre x 0.1 = 0.264 AF/acre (86,025 gpy/acre; 236 gpd/acre)

SFPUC analyzed 2020 satellite imagery for all parcels associated with dedicated irrigation meters and identified the area of irrigable, irrigated landscape cover served by each meter and parcel. Based on calendar year 2024 billed consumption, the average pre-budget water use for non-municipal irrigation accounts was 2.64 AF/ac, based on 173 acres of irrigable, irrigated non-municipal landscape served by dedicated irrigation meters that are slated to receive regular water budget reports starting in late 2025.

Plumbing Code Savings: NA

Plumbing Code NRR: NA

Annual Decay Rate: NA

Useful Life: 1 year

Peak Period Savings Percent: 100%

Unit Sewer Savings: 0

Unit Electricity Savings: NA

Unit Gas Savings: NA

Confidence Score: 3
SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 82 References

A&N Technical Services (1991) Chesnutt, T.W. and C.N. McSpadden, “A Model-Based Evaluation of the Westchester Water Conservation Programs.” Prepared for the Metropolitan Water District of Southern California, January.

A&N Technical Services (1992d) Chesnutt, T.W., C.N. McSpadden, S.A. Rahman, and A. Bamezai, “A Model-Based Evaluation of Irvine Ranch Water District Residential Retrofit and Survey Water Conservation Projects.” Prepared for the Metropolitan Water District of Southern California, August.

A&N Technical Services (1994a) Bamezai, A. and T.W. Chesnutt, Public Facilities Toilet Retrofits:

Evaluation of Program Outcomes and Water Savings, A report for the Metropolitan Water District of Southern California, December.

A&N Technical Services (1994b) Bamezai, A. and T.W. Chesnutt, “Residential Water Audit Program:

Evaluation of Program Outcomes and Water Savings,” A report for the Metropolitan Water District of Southern California, December.

A&N Technical Services (1997) Pekelney, D. and T. W. Chesnutt, Landscape Water Conservation Programs: Evaluation of Water Budget Based Rate Structures, a report prepared for the Metropolitan Water District of Southern California, 1997

A&N Technical Services (2004) Chesnutt, T.W. et al., Evaluation of the Landscape Performance Certification Program, a report prepared for the Municipal Water District of Orange County, Metropolitan Water District of Southern California, and the US Bureau of Reclamation, 2004

A&N Technical Services (2011), “MWDOC Smart Timer Rebate Program Evaluation,” Report prepared for Municipal Water District of Orange County

A&N Technical Services (2013), “Statistical Analysis of Multifamily Residence Bathroom Retrofit Water Savings,” Report prepared for California Water Service.

Aquacraft (1999). Residential End Uses of Water Study.

California Urban Water Conservation Council. (2001). CII ULFT Savings Study, 2nd Edition. Sacramento:

California Urban Water Conservation Council.

California Urban Water Conservation Council. (2005). Draft Revision BMP Costs & Savings Study: A Guide to Data and Methods for Cost-Effectiveness Analysis of Urban Water Conservation Best Managemnet Practices. Sacramento: California Urban Water Conservation Council.

Chesnutt, T.W., C.N. McSpadden, and D.M. Pekelney (1995), “What is the Reliable Yield from Residential Home Water Survey Programs?” presented at the AWWA Conference in Anaheim CA, June.

DeOreo, W., Mayer, P., Henderson, J., Raucher, B., Gleick, P., Cooley, H., & Heberger, M. (2010).

California Single Family Home Water Use Efficiency Study. Bolder, CO: Aquacraft, Inc.

SFPUC Conservation Tracking Model
Water and Energy Savings Specifications for Conservation Program Measures 83 DeOreo, W., Mayer, P., Henderson, J., Raucher, B., Gleick, P., Cooley, H., & Heberger, M. (2010a). San Francisco Single Family Home Water Use Efficiency Study. Bolder, CO: Aquacraft, Inc.

Federal Energy Management Program (FEMP 2000), “Assessment of High-Performance, Family-Sized Commercial Clothes Washers.” Produced for the U.S. Department of Energy by Pacific Northwest National Laboratory, May.

Koeller & Company (2005), “High Efficiency Plumbing Fixtures – Toilets and Urinals.” Prepared analysis of Potential Best Management Practices for the California Urban Water Conservation Council.

Koeller, J. (2006). A Report on Potential Best Management Practices: Year Two Annual Report.

Sacramento: California Urban Water Conservation Council.

M.Cubed (2014). SFPUC Plumbing Fixture Population and Efficiency Saturation Estimates. Technical Memorandum prepared for San Francisco Public Utilities Commission.

M.Cubed and A&N Technical Services (2018a). Statistical Analysis of Bathroom Retrofit Water and Energy Savings: California Water Service Dominguez and East Lost Angeles Districts, DWR Grant Agreement No. 4600011093.

M.Cubed and A&N Technical Services (2018b). Statistical Analysis of Bathroom Retrofit Water and Energy Savings: California Water Service Bakersfield District, DWR Grant Agreement No. 4600011092.

M.Cubed (2024). Water Savings Assessment of SFPUC Leak Alert Programs. Technical Memorandum dated February 2, 2024, from David Mitchell, M.Cubed, to Chris Hewes, Woodard & Curran.

Mayer, P., et al., Water Budgets and Rate Structures: Innovative Management Tools, Journal AWWA, Volume 100:5, 2008

Mitchell D., and T. Chesnutt (2014). Evaluation of East Bay Municipal Utility District’s Pilot of WaterSmart Home Water Reports. Prepared for California Water Foundation.

Sutter, M., T. Pope, and E. Walther (2006). Estimating Commercial Clothes Washer Use in California Coin Laundry Stores. ACEEE Summer Study on Energy Efficiency in Buildings.

U.S. Department of Energy (DOE 2006), “Energy Cost Calculator for Faucets and Showerheads,” http://www1.eere.energy.gov/femp/procurement/eep_faucets_showerheads_calc.html#output . Last updated July 10, 2006.

U.S. Department of Energy (DOE 2012), Technical Support Document: Energy Efficiency Program for Consumer Products and Commercial and Industrial Equipment: Residential Clothes Washers, April 2012. Accessed at http://www.regulations.gov/#!documentDetail;D=EERE-2008-BT-STD- 0019-0047.

Whitcomb, J.B. (2000), “Residential Water Survey Evaluation,” prepared for Contra Costa Water District, May.

APPENDIX E
Supply Reliability Assessment With
Wholesale Customer Supply Assurance
2025 URBAN WATER MANAGEMENT PLAN
for the City and County of San Francisco
June 2026
Prepared by: The San Francisco Public Utilities Commission

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2025 Urban Water Management Plan for the City and County of San Francisco | 1 Supply Reliability Assessment with Wholesale Customer Supply Assurance The SFPUC has a Level of Service objective to provide an annual average of 265 MGD in normal years, as well as a contractual obligation to provide 184 MGD to the Wholesale Customers in accordance with the Supply Assurance in the Water Supply Agreement between the City and County of San Francisco and Wholesale Customers in Alameda County, San Mateo County, and Santa Clara County (WSA). In addition to the supply modeling presented in the main body of this UWMP, supply modeling was conducted to assess the SFPU C’s ability to meet its contractual obligations. For purposes of the 2025 UWMP, Groveland Community Services District is reported as a wholesale customer but is considered a retail customer of the SFPUC solely for purposes of allocating Regional Water System (RWS) supplies between retail customers and Wholesale Customers. Its demands would be met by the retail supply allocation of 81 MGD.

As discussed in Section 7.1 of the UWMP, deliveries from the RWS to both retail and Wholesale Customers are limited to an average annual of 265 MGD for the watersheds. Current and projected supply availability from the RWS is presented in Table E-1.

Table E-1. Regional Water System Supply Availability in Normal Years (MGD) RWS Supply Allocation 2030 2035 2040 2045 2050
Retail Customersa, b 81 81 81 81 81
Wholesale Customersc, d 184 184 184 184 184
Total RWS Supplies 265 265 265 265 265
a Groundwater and recycled water are assumed to be used before RWS supplies to meet retail demand. However, if these alternative supplies are not available, up to 81 MGD of RWS supply could be used in normal years. b The Supply Assurance is the 184 MGD maximum annual average metered supply of water dedicated by San Francisco to public use in the Wholesale Customer service area (not including the cities of San Jose and Santa Clara). c Cordilleras MWC is not a party to the WSA, and it is not included in the Wholesale Customer supply allocation of 184 MGD.

The demands of Cordilleras MWC are minor (projected to be less than 0.01 MGD) and are anticipated to be met with RWS supplies through 2050.

Table E-2 summarizes the expected availability of local groundwater and local recycled water which are only available to meet retail demands. Normal, single dry, and multiple dry year conditions are on a water year basis. Dry year availability is presented in terms of percentage of normal year availability. Groundwater and recycled water are assumed to be used before RWS supplies to meet retail demand. However, if groundwater and recycled water supplies are not available, up to 81 MGD of RWS supply could be used .

Groundwater and recycled water availability are not impacted by dry year conditions nor the implementation of the Bay-Delta Plan Amendment.
• Groundwater supplies are assumed to be equivalent to projected demands for the San Francisco Groundwater Supply Project (4.0 MGD starting in 2040) and Castlewood CSA (0.3 MGD). • Recycled water supplies are assumed to be equivalent to projected demands related to the Westside Recycled Water Project (1.7 MGD by 2050), Harding Park and Fleming Golf Courses (0.2 MGD), and Sharp Park Golf Course (up to 0.1 MGD) and Treasure Island (0.4 MGD starting in 2040).

2 | Appendix E: Supply Reliability Assessment with Wholesale Customer Supply Assurance Table E-2. Retail Groundwater and Recycled Water Supply Availability During Normal and Dry Years
Water Supply Normal
Year
Single
Dry Year
Dry Year
1 Dry Year
2 Dry Year
3 Dry Year
4 Dry Year
5 Local Groundwater 100% 100% 100% 100% 100% 100% 100%
Local Recycled Water 100% 100% 100% 100% 100% 100% 100%

Projected supply reliability for years 2030 through 2050 assume total demand is equivalent to the sum of the projected retail and wholesale demands on the RWS, which includes Wholesale Customer purchase projections provided to the SFPUC by BAWSCA on March 4, 2026. Refer to Table E-3 below.

Table E-3. Retail and Wholesale RWS Demand Assumptions Used for Supply Reliability Modeling (MGD)
Customer Base Year 2050
Retail Customers 66.7
Wholesale Customers 184.0
Total 250.7

The total amount of water the SFPUC can deliver to the retail and Wholesale Customers from the RWS depends on several factors, including (1) the amount of water that is available to the SFPUC from natural runoff, (2) the amount of water in reservoir storage, and (3) the amount of water that the SFPUC releases from the RWS for purposes other than customer deliveries (e.g., instrea m flow releases below RWS reservoirs). For planning purposes, the SFPUC “average year” or “normal year” is based on historical hydrology under conditions that allow the RWS reservoirs to be filled over the course of the snowmelt season, allowing full deliveries to customers. For “dry-year” supply scenarios, the SFPUC plans its water deliveries using a water-supply planning methodology with reference to a simulated 8.5-year design drought. Dry year availability is presented in terms of percentage of normal year availability.

Table E-4 shows RWS supplies under normal, single dry, and multiple dry year conditions (on a water year basis) and for each of the two supply scenarios. The SFPUC estimated RWS deliveries using the standard SFPUC procedure, which includes adding increased levels of rationing as needed in dry years to balance the demands on the RWS with available water supply. The five consecutive dry -year sequence shown in the tables below represent years 2 through 6 of the design drought. The SFPUC chose this sequence because year 2 is the first year in which system -wide water use reductions could take effect, as the design drough t sequence generally begins year 1 with full reservoirs. All simulations that the SFPUC has prepared for its 2025 UWMP have increased levels of rationing in the final years of the design drought sequence. The SFPUC has presented the results in the standard ized format prescribed by DWR. Additionally, the SFPUC has a Water Shortage Contingency Plan that defines six distinct shortage levels that the RWS may be in and the corresponding actions that the SFPUC would take to address the water shortage, ranging fro m use of dry year water supplies (when available), voluntary water use reductions, and mandatory water use reductions.

Supply modeling to assess whether the SFPUC can meet its Supply Assurance of providing an annual average of 184 MGD to Wholesale Customers in normal years was conducted using the same methodology described in Section 8.2. Because of the uncertainty surrounding implementation of the Bay -Delta Plan Amendment, the water supply reliability assessment includes a set of tables for each of the two future supply scenarios:

2025 Urban Water Management Plan for the City and County of San Francisco | 3 • With Implementation of the Bay-Delta Plan Amendment: Under this scenario, using the demand assumptions shown in Table E-3, the SFPUC anticipates RWS supplies will experience a reduction of up to 52% through the multiple dry-year sequence. The implementation of the Alternative Water Supply Program and associated potential projects will help reduce the anticipated supply shortfalls.

• Without Implementation of the Bay -Delta Plan Amendment: Under this scenario, using the demand assumptions shown in Table E-3, the SFPUC system can expect to experience RWS supply reductions of approximately 10% in a single dry year and across five consecutive dry years.

Table E-4. Water Supply Availability During Normal and Dry Years for Base Year 2050 With and Without Bay-Delta Plan Amendment
Supply Scenario Normal
Yeara
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Dry
Year 4
Dry
Year 5
With Bay-Delta Plan Amendment 100% 58% 58% 48% 48% 48% 48% Without Bay-Delta Plan Amendment 100% 90% 90% 90% 90% 90% 90%

The SFPUC utilized the Water Shortage Allocation Plan (WSAP) that is incorporated in the Water Supply Agreement between the SFPUC and the Wholesale Customers to allocate the RWS supply available during dry years between the retail customers and the Wholesale Customers in the 2025 UWMP supply reliability analysis. The WSAP, also known as the Tier 1 Plan, defines the method for allocating between the retail customers collectively and Wholesale Customers collectively the available RWS supplies during system-wide shortages. For example, when the required level of system-wide reduction in water use is 6 to 10%, the retail customer Tier 1 Allocation is 36% of the annual water supply available, and the Wholesale Customer Tier 1 Allocation is 64% of the annual water supply available. The SFPUC and the Wholesale Customers most recently amended the WSAP in 2025. Also in 2025, the Wholesale Customers adopted an updated Tier 2 Plan, which allocates the collective Wholesale Customers’ share of available RWS supplies from the Tier 1 Plan among each of the 26 Wholesale Customers. The WSAP addresses shortages that require a system- wide reduction in water use of 20% or less, consistent with the SFPUC’s Level of Service Goal. For any shortage scenario requiring a system-wide reduction in water use above 20% in the supply reliability analysis, the SFPUC applied the Tier 1 Plan’s allocation of supplies between the retail customers and Wholesale Customers for a shortage requiring a system-wide reduction in water use of 16 to 20%.

Under the WSAP, if the retail customers’ share of the available water supply results in the retail customers having a “positive allocation” (i.e., a supply of additional water rather than a percentage reduction in water use), then the retail customers’ percentage share of the available water supply would be reduced to eliminate any positive allocation to the retail customers, with a corresponding increase in the percentage share of the available water supply allocated to the Wholesale Customers. For any level of required reduction in system- wide water use, the SFPUC shall require the retail customers to conserve a minimum of 5%, with any resulting reallocated supply credited to storage for inclusion in the calculation of projected available RWS supply in a subsequent year.

Because of the uncertainty surrounding implementation of the Bay-Delta Plan Amendment, the RWS supply reliability assessment evaluates two future supply scenarios: (1) with implementation of the Bay-Delta Plan Amendment, and (2) without implementation of t he Bay -Delta Plan Amendment. It is unknown when implementation may begin on the Bay-Delta Plan Amendment; for the purposes of the 2025 UWMP analysis, the SFPUC included it beginning in the 2030 modeling scenarios. 4 | Appendix E: Supply Reliability Assessment with Wholesale Customer Supply Assurance The SFPUC incorporated additional modeling assumptions in the 2025 UWMP analysis regarding the State Water Resources Control Board (SWRCB) curtailments and assumptions regarding agreements with Turlock and Modesto Irrigation Districts pertaining to instream flow obligations.

1. During the last two drought periods, 2013 -2016 and 2021 -2023, the SWRCB implemented curtailments through emergency regulations and curtailment orders that attempted to limit diversions from Central Valley watersheds including the Tuolumne River at certain times. Due to the uncertain legality of the SWRCB’s curtailment actions as well as the uncertainties regarding any potential future curtailment actions against San Francisco, the SFPUC’s RWS supply reliability analyses do not assume curtailments are in effect.

2. Through a 1966 agreement with the Modesto and Turlock Irrigation Districts (Districts), who are more senior downstream appropriative water rights holders on the Tuolumne River, San Francisco may become responsible for up to approximately 51.7% of any flow releases the Federal Energy Regulatory Commission (FERC) may require through issuance of a new license for the Districts’ Don Pedro Hydropower Project. The exact flow contribution for which San Francisco may become responsible is highly uncertain and may depend on multiple currently unknown factors, including an anticipated Endangered Species Act biological opinion from the National Marine Fisheries Service and a Clean Water Act section 401 water quality certification from the SWRCB. San Francisco’s potential responsibility for FERC-ordered flows may further depend on San Francisco’s ability to enter into a new or extended agreement with the Districts to offset a portion of San Francisco’s flow contributions in exchange for payment. Due to the high levels of uncertainty surrounding the Districts’ FERC-relicensing process, as well as the unknown timing for license issuance, the SFPUC’s RWS water supply reliability analyses do not assume additional water supply losses from any potential new FERC-ordered flow releases.

3. The simulation of the Bay-Delta Plan Amendment scenario assumes that a 1996 agreement between San Francisco and the Districts (the Side Agreement), which allows San Francisco to pay the Districts in lieu of contributing a portion of current FERC-ordered flow releases, remains in effect, and that the San Francisco share of flows in excess of and not covered by the Side Agreement is approximately

51.7%. These assumptions were made for the purpose of completing the modeling for the UWMP update, and they do not represent a commitment by San Francisco or the Districts to any future agreement or of San Francisco accepting responsibility for any future FERC-ordered flow releases.

Based on current projected demands for retail customers and Wholesale Customers’ Supply Assurance of 184 MGD, supply modeling for the two future supply scenarios shows significantly different supply reliability projections for the RWS:
• With Implementation of the Bay -Delta Plan Amendment : During a normal year, no shortages are expected for the RWS. During a single dry year and year 1 of a multi -year drought, RWS supplies show an anticipated shortfall of 42% (or 145.4 MGD in available supplies) . At shortages 20% or greater , the retail customers’ allocation is assumed to be 37.5% (or 54.5 MGD) and the Wholesale Customers’ allocation is assumed to be 62.5% (or 90.9 MGD). The total retail supply is calculated by adding the retail RWS allocation with local supplies . For wholesale, the total supply is the wholesale allocation. The difference between total supply and total demand is the shortfall (or -12.2 MGD for retail and -93.1 MGD for wholesale ). During years 2 through 5 of a multi -year drought, RWS supplies show an anticipated shortfall of 52% (or 120.2 MGD in available supplies).

Similar to year 1, the same retail and wholesale allocation split is applied. The shortfall between total supply and total demand during these years for retail is -21.6 MGD and for wholesale is -108.8

2025 Urban Water Management Plan for the City and County of San Francisco | 5 MGD. For supply and demand comparisons, see Table E-5 and Table E-6 for retail and wholesale supply, respectively.

• Without Implementation of the Bay-Delta Plan Amendment: During a normal year, no shortages are expected for the RWS. During a single dry year and years 1 through 5 of a multi-year drought, RWS supplies show an anticipated shortfall of 10% (or 225.6 MGD in available supplies). At a 10% shortage, the retail customers’ allocation is 36% (or 81.2 MGD) and the Wholesale Customers’ allocation is 64% (or 144.4 MGD). Because the retail allocation is above the demand, excess allocation above 66.7 MGD is re-allocated to Wholesale Customers. Therefore, 14.5 MGD is added to the wholesale allocation bringing it to 158.9 MGD. The difference between total supply and total demand is the surplus/shortfall (or 14.5 MGD for retail and -25.1 MGD for wholesale). For supply and demand comparisons, see Table E-7 and Table E-8 for retail and wholesale supply, respectively.

Table E-5. Retail Supply and Demand Comparison for Projected Normal and Dry Year Scenarios With Bay-Delta Plan Amendment
Year Retail Supply and Demand Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Dry
Year 4
Dry
Year 5
2050 Total Retail Demand 73.4 73.4 73.4 73.4 73.4 73.4 73.4 2050 Total Retail Supply 73.4 61.2 61.2 51.8 51.8 51.8 51.8 2050 Retail Groundwater 4.3 4.3 4.3 4.3 4.3 4.3 4.3
2050 Retail Recycled Water 2.4 2.4 2.4 2.4 2.4 2.4 2.4
2050 RWS Supply Available to Retail 66.7 66.7 54.5 45.1 45.1 45.1 45.1 2050 Difference (Supply Surplus or
Shortfall) 0.0 -12.2 -12.2 -21.6 -21.6 -21.6 -21.6
2050 Difference as Percentage of
Demand 0.0% -16.6% -16.6% -29.4% -29.4% -29.4% -29.4%

Table E-6. Wholesale Supply and Demand Comparison for Projected Normal and Dry Year Scenarios With Bay-Delta Plan Amendment (MGD)
Year Wholesale Supply and Demand Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Dry
Year 4
Dry
Year 5
2050 Total Wholesale Demand 184.0 184.0 184.0 184.0 184.0 184.0 184.0 2050 Total Wholesale RWS Supply 184.0 90.9 90.9 75.2 75.2 75.2 75.2 2050 Difference (Supply Surplus or
Shortfall) 0.0 -93.1 -93.1 -108.8 -108.8 -108.8 -108.8
2050 Difference as Percentage of
Demand 0.0% -50.6% -50.6% -59.1% -59.1% -59.1% -59.1%

6 | Appendix E: Supply Reliability Assessment with Wholesale Customer Supply Assurance Table E-7. Retail Supply and Demand Comparison for Projected Normal and Dry Year Scenarios Without Bay-Delta Plan Amendment
Year Retail Supply and Demand Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Dry
Year 4
Dry
Year 5
2050 Total Retail Demand 73.4 73.4 73.4 73.4 73.4 73.4 73.4 2050 Total Retail Supply 73.4 87.9 87.9 87.9 87.9 87.9 87.9 2050 Retail Groundwater 4.3 4.3 4.3 4.3 4.3 4.3 4.3
2050 Retail Recycled Water 2.4 2.4 2.4 2.4 2.4 2.4 2.4
2050 RWS Supply Available to Retail 66.7 81.2a 81.2a 81.2a 81.2a 81.2a 81.2a 2050 Difference (Supply Surplus or
Shortfall) 0.0 14.5 14.5 14.5 14.5 14.5 14.5
2050 Difference as Percentage of
Demand 0.0% 19.8% 19.8% 19.8% 19.8% 19.8% 19.8%
a Per the WSA, at 10% shortage (Dry Years 1-5), the retail allocation is 36% (81.2 MGD) and the wholesale RWS supply allocation is 64% (144.4 MGD). Retail allocations above 66.7 MGD (or 14.5 MGD) are re-allocated to Wholesale Customers.

Table E-8. Wholesale Supply and Demand Comparison for Projected Normal and Dry Year Scenarios Without Bay-Delta Plan (MGD)
Year Wholesale Supply and Demand Normal
Year
Single
Dry
Year
Dry
Year 1
Dry
Year 2
Dry
Year 3
Dry
Year 4
Dry
Year 5
2050 Total Wholesale Demand 184.0 184.0 184.0 184.0 184.0 184.0 184.0 2050 Total Wholesale RWS Supply 184.0 158.9a 158.9a 158.9a 158.9a 158.9a 158.9a 2050 Difference (Supply Surplus or
Shortfall) 0.0 -25.1 -25.1 -25.1 -25.1 -25.1 -25.1
2050 Difference as Percentage of
Demand 0.0% -13.6% -13.6% -13.6% -13.6% -13.6% -13.6%
a Per the WSA, at 10% shortage (Dry Years 1-5), the wholesale RWS supply allocation is 64% (144.4 MGD) and the retail allocation is 36% (81.2 MGD). Retail allocations above 66.7 MGD are re-allocated to Wholesale Customers. Therefore, 14.5 MGD is added to the wholesale allocation, bringing it to 158.9 MGD.

APPENDIX F
Water Shortage Contingency Plan
2025 URBAN WATER MANAGEMENT PLAN
for the City and County of San Francisco

June 2026
Prepared by: The San Francisco Public Utilities Commission

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2025 WATER SHORTAGE CONTINGENCY PLAN

FOR THE CITY AND COUNTY OF SAN FRANCISCO

June 2026
Prepared by: The San Francisco Public Utilities Commission

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2025 Water Shortage Contingency Plan for the City and County of San Francisco | iii

TABLE OF CONTENTS
Section 1 Introduction ....................................................................................................................................... 1

1.1 Background and Application ...................................................................................................................... 1

1.2 Experience with Water Shortages Pre-2010.............................................................................................. 6

1.3 Experience with the 2012-2016 Drought ................................................................................................... 6

1.4 Experience with the 2020-2023 Drought ................................................................................................... 7 Section 2 Annual Water Supply and Demand Assessment Procedures ..................................................... 9

2.1 Demand Assessment ................................................................................................................................. 9

2.2 Supply Assessment.................................................................................................................................... 9

2.3 Infrastructure Considerations ................................................................................................................... 11

2.4 System Modeling...................................................................................................................................... 12

2.5 Decision-Making Process ........................................................................................................................ 12 Section 3 Water Shortage Levels and Water Shortage Allocation Plan (WSAP) ...................................... 15 Section 4 Retail Water Shortage Response Actions ................................................................................... 17

4.1 Retail Water Shortage Allocation ............................................................................................................. 17

4.1.1 Voluntary and Mandatory Demand Reduction ................................................................................................................... 17

4.1.2 Types of Allocation Methods for Mandatory Demand Reduction........................................................................................ 17

4.1.3 Per Capita Residential Water Use Floor ............................................................................................................................ 19

4.1.4 Water Shortage Allocation Process ................................................................................................................................... 19

4.1.5 Appeal Process .................................................................................................................................................................. 20

4.2 Water Waste Prohibitions ........................................................................................................................ 20

4.2.1 Artificially Supplied Water Features ................................................................................................................................... 23

4.3 Demand Reduction Actions ..................................................................................................................... 23

4.4 Operational Changes ............................................................................................................................... 24

4.5 Supply Augmentation Actions .................................................................................................................. 25

4.6 Summary of Retail Shortage Response Actions ..................................................................................... 25 Section 5 Communication Protocols ............................................................................................................. 28

5.1 Communications About Voluntary Reductions ........................................................................................ 28

5.2 Communications About Mandatory Demand Reduction.......................................................................... 28

5.3 Communications Related to Wholesale Customers ................................................................................ 29 Section 6 Compliance and Enforcement....................................................................................................... 30

6.1 Enforcement of Water Use Allocations for Retail Customers .................................................................. 30

6.2 Enforcement of Water Waste Prohibitions for Retail Customers ............................................................. 31

6.3 Enforcement of Water Use Allocations for Wholesale Customers .......................................................... 31 Section 7 Legal Authorities ............................................................................................................................ 32 Section 8 Financial Consequences of the WSCP ........................................................................................ 32 Section 9 Monitoring and Reporting ............................................................................................................. 33 iv
Section 10 Preparation for Catastrophic Supply Interruption ...................................................................... 33

10.1 Emergency Preparedness Plans .......................................................................................................... 33

10.2 Emergency Drinking Water Planning ................................................................................................... 34

10.3 Power Outage Preparedness and Response....................................................................................... 35

10.4 Seismic Risk Assessment and Mitigation Plan .................................................................................... 36 Section 11 WSCP Refinement Procedures ..................................................................................................... 37 Section 12 Plan Adoption, Submittal, and Availability .................................................................................. 37

APPENDICES
Appendix A Summary of San Francisco’s Response to 1987-1992 Drought Experience Appendix B Summary of San Francisco’s Response to 2012-2016 Drought Experience Appendix C Summary of San Francisco’s Response to 2020-2023 Drought Experience Appendix D San Francisco Public Utilities Commission Resolution Adopting 2025 Water Shortage Contingency Plan

LIST OF FIGURES
Figure 1-1: Retail Service Customers....................................................................................................................................... 4 Figure 1-2: Wholesale Service Area ......................................................................................................................................... 5 Figure 2-1: Water Supply and Demand Assessment Process ............................................................................................ 14

LIST OF TABLES
Table 1-1. Retail Public Water Systems ................................................................................................................................... 2 Table 1-2. Application of Water Shortage Contingency Plan for Retail vs. Wholesale Customers ................................... 3 Table 2-1. Regional Water System Supply Availability in Normal Years (MGD) ............................................................... 11 Table 2-2. Regional Water System Supply Utilized in Normal Years (MGD)..................................................................... 11 Table 3-1. Retail and Wholesale RWS Allocations during System-wide Shortage ........................................................... 16 Table 4-1. Demand Reduction Actions .................................................................................................................................. 27

2025 Water Shortage Contingency Plan for the City and County of San Francisco | v

ACRONYMS AND ABBREVIATIONS
AF Acre-feet
BAWSCA Bay Area Water Supply and Conservation Agency
City City and County of San Francisco
CSD Community Services District
CY Calendar Year
DWR California Department of Water Resources
EBMUD East Bay Municipal Utility District
EOP Emergency Operations Plan
FY Fiscal Year
ISL Interim Supply Limitation
LOS Levels of Service
MGD million gallons per day (flow or usage rate of water) RWS San Francisco Regional Water System
RWSAP Retail Water Shortage Allocation Plan
SAPS San Antonio Pump Station
SB Senate Bill
SFPUC San Francisco Public Utilities Commission
State State of California
SVCF Sunol Valley Chloramination Facility
SVWTP Sunol Valley Water Treatment Plant
SWRCB State Water Resources Control Board
UWMP Urban Water Management Plan
Valley Water or VW Santa Clara Valley Water District
WSA Water Supply Agreement between the City and County of San Francisco and Wholesale Customers in Alameda County, San Mateo County, and Santa Clara County WSAP Water Shortage Allocation Plan
WSCP or Plan Water Shortage Contingency Plan
WSDA Water Supply and Demand Assessment
WSIP Water System Improvement Program

vi
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2025 Water Shortage Contingency Plan for the City and County of San Francisco | 1 SECTION 1 INTRODUCTION
The San Francisco Public Utilities Commission (SFPUC) present s this Water Shortage Contingency Plan (WSCP or Plan) on behalf of the City and County of San Francisco (City). This WSCP complies with California Water Code Section 10632, which requires that every urban water supplier prepare and adopt a WSCP as part of its urban water management plan (UWMP). This WSCP presents the latest information about the SFPUC’s annual water supply and demand assessment (WSDA) procedures and describes the SFPUC’s water sho rtage contingency planning.

The WSCP describes the SFPUC’s water shortage levels and associat ed response actions to be implemented during a water shortage condition.

1.1 BACKGROUND AND APPLICATION
Over 2.7 million people and businesses in the San Francisco Bay Area rely on water supplied by the SFPUC, a City department, to meet their daily water needs. The San Francisco Regional Water System (RWS) is municipally owned infrastructure operated by the SFPUC that serves both retail and wholesale customers. The RWS supplies high-quality drinking water from the Tuolumne River watershed and from the local Alameda and Peninsula watersheds. The RWS draws an average of 85% of its supply from the Tuolumne River watershed, collected in Hetch Hetchy Reservoir in Yosemite National Park. This water feeds into an aqueduct system delivering water 167 miles by gravity to Bay Area reservoirs and customers. The remaining 15% of the RWS supply is drawn from local surface waters in the Alameda and Peninsula watersheds. The percentage split between these water sources varies from year to year depending on the water year hydrology and operational circumstances.

The SFPUC provides retail water service to customers both inside and outside of San Francisco (collectively referred to as the retail customers). The majority of the retail customers are located inside of San Francisco and are referred to as “in-City” retail customers. The small number of retail customers outside of San Francisco are located along the RWS transmission system and are referred to as “suburban” retail customers. The in-City distribution system serves a residential population of nearly 844,000 in addition to San Francisco-based businesses.

The suburban retail customers include a residential population of approximately 2,000, as well as businesses and institutions, in San Mateo, Santa Clara, Alameda, Tuolumne, and San Joaquin Counties. In-City retail customers are primarily served with RWS supply, but some customers also receive groundwater and recycled water from the SFPUC or other providers. Similarly, the suburban retail customers are primarily served with RWS supply, although one customer also receives groundwater from the SFPUC.

Traditional surface water supplies from the SFPUC’s Upper Tuolumne, Alameda, and Peninsula watersheds are the backbone of the RWS’s water supply. The SFPUC extends and protects those supplies in many ways, including, but not limited to, the following actions within its retail service area: (1) encouraging its retail customers to help save water through robust conservation programs; (2) reducing the need for additional water to serve new developments in San Francisco through an onsite water reuse program; (3 ) recycling wastewater resources in San Francisco to deliver water for large non -potable uses; (4) utilizing local groundwater supplies to supplement or offset surface water supplies; (5) investigating new, alternative dry -year water supply options such as purified water; and (6) investing in innovations that allow for creative solutions to meet diverse needs . These efforts help the SFPUC conserve water and diversify supplies to reduce the likelihood of a water shortage. 2 The contents of this WSCP are applicable to all retail customers as identified in Table 1-1 and shown on the map in Figure 1-1.

Table 1-1. Retail Public Water Systems
Public Water
System ID Public Water System Name Water Supply Type Description CA3810001 SAN FRANCISCO REGIONAL

WATER SYSTEM
Treated surface
water, groundwater,
and raw water
Regional Water System (RWS) that
serves the SFPUC’s suburban retail
customers that are not described in
the rows below (in addition to the
SFPUC’s wholesale customers).

CA3810011 SAN FRANCISCO WATER
SYSTEM
Treated surface
water and
groundwater
The City and County of San
Francisco’s water distribution system
that delivers water to in-City retail
customers.

CA3810702 TREASURE ISLAND WATER
SYSTEM
Treated surface
water
An island and neighborhood in the
City and County of San Francisco.

Water demand from Treasure Island
is part of in-City retail demands.

CA0110012 TOWN OF SUNOL WATER
SYSTEM
Treated surface
water
Domestic water system for the Town
of Sunol in unincorporated Alameda
County, which typically serves less
than 0.1 MGD.

CA3810008

THOMAS SHAFT

WHOLESALE WATER
SYSTEM
Treated surface
water
Water facilities are located at the
Lawrence Livermore National
Laboratory Site 300 at Thomas Shaft
of the Coast Range Tunnel.

CA3810003 MOCCASIN COMPOUND

WATER SYSTEM
Treated surface
water
Raw water from Hetch Hetchy
Reservoir that serves suburban retail
customers in the Town of Moccasin in
unincorporated Tuolumne County.

CA0110018 PLEASANTON WELL FIELD
WATER SYSTEM Groundwater
Referred to as the Castlewood Well
System where approximately 0.3
MGD of treated (potable)
groundwater is provided to the
Castlewood County Service Area in
unincorporated Alameda County.

CA3810005
O’SHAUGHNESSY DAM

COMPOUND WATER
SYSTEM
Raw water Raw water from Hetch Hetchy
Reservoir.

CA3810006 EARLY INTAKE COMPOUND
WATER SYSTEM Raw water Raw water from Hetch Hetchy
Reservoir.

Note: This list includes all public water systems owned and operated by the SFPUC. Pleasanton Well Field is not part of the RWS. The State does not require that the SFPUC report all public water systems on this list in the UWMP.

The SFPUC also delivers water to wholesale customers in the Bay Area that purchase RWS water for retail customers in their individual service areas. The Bay Area Water Supply and Conservation Agency (BAWSCA) represents the interests of 26 wholesale customers of the SFPUC that are in Alameda, Santa Clara, and San Mateo Counties (collectively, Wholesale Customers) and coordinates water conservation programming on their behalf .

One SFPUC wholesale customer not represented by BAWSCA is the Cordilleras Mutual Water Company , a small 2025 Water Shortage Contingency Plan for the City and County of San Francisco | 3 water association serving 18 single-family homes located in Redwood City in San Mateo County. Another SFPUC customer, the Groveland Community Services District (CSD), located in Tuolumne County , is considered a wholesale customer for the purposes of the SFPUC’s UWMP and WSCP because it produces its own UWMP and WSCP, but the SFPUC considers it among its retail customers in the context of allocating RWS supplies between retail and Wholesale Customers. Collectively, the wholesale customers on average receive over two thirds of the RWS’s annual deliveries, with the remaining approximately one third provided to the retail customers. See Figure 1-2 for a map showing the wholesale service area encompassing all of the SFPUC’s wholesale customers.

Parts of this WSCP are relevant for the SFPUC’s wholesale customers, particularly when the RWS is experiencing a system-wide water shortage condition. However, these wholesale customers are also urban water suppliers that are required to prepare their own WSCPs for the retail customers that they serve. Table 1-2 indicates which sections of this Plan, following this introduction section, are applicable to SFPUC’s wholesale customers.

This introduction section provides background and application of this Plan. A summary of the SFPUC’s response to past water shortages is found in the following sections:
• Pre-2010 water shortages: see Section 1.2, described in more detail in Appendix A • 2012-2016 drought: see Section 1.3, described in more detail in Appendix B • 2020-2023 drought: see Section 1.4, described in more detail in Appendix C Table 1-2. Application of Water Shortage Contingency Plan for Retail vs. Wholesale Customers Section Retail Wholesale

2. Annual Water Supply and Demand Assessment Procedures ✓ ✓

3. Water Shortage Levels ✓ ✓

4. Retail Water Shortage Response Actions ✓

5. Communication Protocols ✓ ✓*

6. Compliance and Enforcement ✓

7. Legal Authorities ✓ ✓*

8. Financial Consequences of the WSCP ✓ ✓*

9. Monitoring and Reporting ✓

10. Preparation for Catastrophic Supply Interruption ✓ ✓

11. WSCP Refinement Procedures ✓

12. Plan Adoption, Submittal, and Availability ✓
*Portions of this section are relevant for wholesale customers where noted.

4 Figure 1-1: Retail Service Customers
The suburban customers shown above represent the majority of water use in the suburban retail service area, but the list is not comprehensive. Castlewood Country Club receives groundwater from wells that are not connected to the RWS. The SFPUC reports Groveland CSD as a wholesale customer in its UWMP because Groveland CSD is an urban water supplier and prepares its own UWMP and WSCP. Outside of its UWMP and WSCP, the SFPUC considers Groveland CSD as a retail customer in the context of allocating RWS supplies between retail and wholesale customers.

HAYWARD
PALOALTOPacificOcean
San FranciscoBay
SAN
MATEO
SFO
NOT TO
SCALE

DALY CITY
HALF
MOON
BAY

SAN MATEO
COUNTY
San
Andreas
Reservoir
Pilarcitos
Reservoir
Crystal
Springs
Reservoir
SAN
JOSE

SANTA CLARA
COUNTY

ALAMEDA
COUNTY
Calaveras
Reservoir
San Antonio
Reservoir
3 456 7
8 9

CITY & COUNTY OF

SAN FRANCISCO
18 19
17 10
11 12
13 15
16 19
2 14

CONTRA COSTA COUNTY

SAN JOAQUIN
COUNTY
1 FREMONT

LIVERMORE
1 Don Pedro
Reservoir

TUOLUMNE
COUNTY

MOCCASIN
20 The suburban customers shown above represent the majority of water use in the suburban retail service area but are not comprehensive. The SFPUC reports Groveland Community Services District as a wholesale customer in its UWMP because it is an urban water supplier and prepares its own UWMP and WSCP.

Outside of its UWMP and WSCP, the SFPUC considers Groveland Community Services District a Retail Customer in the context of allocating RWS supplies between Retail and Wholesale Customers.
* Castlewood Country Club relies on groundwater wells that are not connected to the RWS.

In-City Retail Service Area
1 City and County of San Francisco
Suburban Retail Service Area
2 Residential and Non-residential
Customers in Daly City
3 Cemeteries in Colma
4 Golden Gate National Cemetery
5 San Francisco County Jail #5
6 Sharp Park Golf Course
7 San Francisco International Airport
8 SFPUC Millbrae Headquarters
9 Crystal Springs Golf Course
10 Penninsula Golf and Country Club
11 Residential Customers in
Redwood City
12 Filoli Center
13 Menlo Country Club
14 NASA Ames Research Center
15 Cargill Salt
16 Residential & Non-residential Customers in Sunol
17 GE Hitachi Nuclear
18 Castlewood Country Club*
19 Lawrence Livermore National Laboratory (Mocho
Shaft at Site 200 and Thomas Shaft at Site 300)
20 Residential & Non-residential Customers
in Moccasin

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 5 Figure 1-2: Wholesale Service Area
Notes: The SFPUC provides water on an interruptible basis to fixed service areas in the northern portions of the Cities of San Jose and Santa Clara. California Water Service Company (Cal Water), an investor-owned utility, provides water service to four separate districts in the SFPUC’s wholesale service area, which are consolidated into three operating districts: (1) Bear Gulch (serving Portola Valley, Woodside, Atherton, and portions of Menlo Park, Redwood City, and San Mateo County), (2) Mid-Peninsula (serving San Mateo and San Carlos), and (3) South San Francisco.

San Francisco Bay
Pacific
Ocean
Calaveras
Reservoir
San Antonio
Reservoir17 4San
Andreas
Reservoir
Pilarcitos
Reservoir
Crystal
Springs
Reservoir
Half
Moon
Bay
1 2
3 4
5 10
17 4 19
24 25
16 20
21 22 23
18 6
8 9
12 7
27 26
4 4
11 14
14 4
4 13
16 SFO
15 NOT TO
SCALE
Don Pedro
Reservoir

TUOLUMNECOUNTY

GROVELAND
Pine Mountain
Lake
28 GROVELAND
SAN

FRANCISCO

SANFRANCISCO

SAN MATEOCOUNTY

SANTA CLARACOUNTY

ALAMEDACOUNTY

CONTRACOSTACOUNTY
a The SFPUC provides water on an interruptible basis to fixed service areas in the northern portions of the Cities of San Jose and Santa Clara. b The SFPUC reports Groveland Community Services District as a wholesale customer in its 2025 UWMP because it is an urban water supplier and prepares its own UWMP and WSCP . Outside of its UWMP and WSCP , the SFPUC considers Groveland Community Services District a Retail Customer in the context of allocating RWS supplies between Retail and Wholesale Customers. c California Water Service Company (Cal Water), an investor-owned utility, provides water service to four separate districts in the SFPUC’s wholesale service area, which are consolidated into three operating districts: Bear Gulch (serving Portola Valley, Woodside, Atherton, and portions of Menlo Park, Redwood City, and San Mateo County), Mid-Peninsula (serving San Mateo and San Carlos), and South San Francisco. d Cordilleras Mutual Water Company is not a member of BAWSCA.

MUNICIPALITIES
2 City of Brisbane
9 City of Burlingame
1 City of Daly City
17 City of East Palo Alto
27 City of Hayward
16 City of Menlo Park
8 City of Millbrae
25 City of Milpitas
21 City of Mountain View
19 City of Palo Alto
14 City of Redwood City
7 City of San Bruno
24 City of San Josea
23 City of Santa Claraa
22 City of Sunnyvale
10 Town of Hillsborough

WATER PURVEYING DISTRICTS
26 Alameda County
Water District
12 Coastside County
Water District
11 Estero Municipal
Improvement District
3 Guadalupe Valley Municipal
Improvement District
13 Mid-Peninsula Water
District
5 North Coast County
Water District

OTHER ENTITIES
4 California Water
Service Companyc
18 Stanford University
15 Cordilleras Mutual
Water Companyd
20 Purissima Hills
Water District
6 Westborough
Water District
28 Groveland Community
Services Districtb
6 1.2 EXPERIENCE WITH WATER SHORTAGES PRE-2010
Every water system has vulnerabilities that could impact its ability to provide a safe and reliable supply of water.

Water shortages can occur in several ways. Very localized shortages can occur due to distribution system problems, and system-wide shortages can occur due to major facility failures. System-wide shortages may limit the amount of water that is available over a series of years. Water shortage conditions are also not necessarily caused by physical facility limitations. Within the past 50 years, San Francisco has experienced both localized shortages due to earthquakes and system-wide shortages due to drought.
• The 1976-1977 drought was one of the driest periods in California history , which led to severe water shortages across the state.
• In 1987-1992, San Francisco experienced a serious drought , during which the SFPUC adopted various action levels in response to low water levels at Hetch Hetchy Reservoir, which had been taxed to the point of running out of water.
• Following the October 17, 1989, Loma Prieta earthquake, the SFPUC worked with the Mayor’s Office of Emergency Response to reconnect water service for retail customers impacted by the earthquake. Most of the homes that lost water service were reconnected within 72 hours. • In April 2007, below normal precipitation and snowpack caused the SFPUC to initiate a 10% voluntary reduction in water use in its service area. The call for a voluntary reduction continued through 2009.

The SFPUC’s past experiences with water shortages during drought and following major earthquakes shaped its current water shortage preparedness plans and response policies. The longest drought that impacted the SFPUC’s ability to maintain full deliveries to its customers was the 1987-1992 drought. During that drought’s first few years, as reservoir storage continued to decline, it became evident that the SFPUC could not sustain full deliveries without the risk of running out of water before the drought ended. This circumstance became a reality in early 1991 when Hetch Hetchy Reservoir became so depleted (less than 25,000 AF of storage in a reservoir with over 360,000 AF of capacity) that minimum instream flow releases and anticipated demands required the SFPUC to initiate programs to achieve a 45% reduction in system-wide water deliveries to balance water supplies with deliveries. Fortunately, unexpected runoff in March 1991 relieved the severity of that shortage. The 1987-1992 drought illustrated the deficit between the SFPUC’s supplies and its customers’ demands. Appendix A provides a more detailed summary of San Francisco’s 1987-1992 drought experience and the actions taken at the time.

1.3 EXPERIENCE WITH THE 2012-2016 DROUGHT
In 2012-2016, California experienced a severe drought , which included the driest four consecutive water years based on statewide precipitation (2012 -2015) and the lowest April 1 statewide snowpack water equivalent (5 % of average in 2015) on record. The unprecedented dry -weather conditions prompted then-Governor Jerry Brown to declare a drought State of Emergency in January 2014, which remained in effect for most of California until 2017 .

The SFPUC took the following actions in response to the drought:

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 7 • Voluntary call for demand reduction: Spurred by the Governor’s declaration of a State of Emergency in January 2014, the SFPUC requested that all customers of the RWS voluntarily reduce water use by at least 10%. Soon after, the San Francisco Mayor’s Office issued a formal executive directive requiring all City departments to develop individual water conservation plans and take immediate steps to achieve a mandatory 10% reduction in water consumption. Ultimately, the SFPUC did not declare a water shortage emergency or impose mandatory system -wide demand reductions and shortage allocations because RWS customers exceeded the 10 % voluntary system-wide reduction in conjunction with the statewide mandatory reductions assigned by the State Water Resources Control Board (SWRCB) (see below). The SFPUC lifted the call for a voluntary 10% reduction in April 2017. • Statewide mandatory reductions: In July 2014, new emergency conservation regulations issued by the SWRCB prompted the SFPUC to implement outdoor water waste restrictions and impose a mandatory 10% reduction in outdoor water use only. Additional emergency conservation regulations issued by the SWRCB in the spring of 2015 established more statewide water use restrictions, a mandatory statewide water reduction of 25 % compared to 2013 water use, and conservation standards for individual urban water suppliers to meet the statewide 25% reduction. These emergency conservation regulations were the first of their kind , indicative of the State’s desire for swift and substantial action to cope with the drought. The State assigned the SFPUC retail service area a conservation standard of 8% in recognition of its already low residential per capita water use. In the SFPUC wholesale service area, Wholesale Customers were assigned a demand reduction standard ranging from 8 % to 36 %. The conservation standards took effect in June 2015 and remained in effect through April 2017. • Mandatory reduction of outdoor water use: As noted above, the SFPUC imposed a mandatory 10% reduction on outdoor irrigation in response to the State’s emergency conservation regulations, along with water use allocations and excess use fines for all retail irrigation customers , starting in August 2014.

Following the additional SWRCB regulations in the spring of 2015, the SFPUC increased this mandatory reduction on retail outdoor irrigation from 10 % to 25 % starting in July 2015. The SFPUC lifted the mandatory reduction on outdoor irrigation in July 2016.

Appendix B provides a more detailed overview of San Francisco’s response to the 2012-2016 drought.

1.4 EXPERIENCE WITH THE 2020-2023 DROUGHT
A few years after the 2012-2016 drought, California entered another drought beginning in the winter of 2019-2020.

This new drought coincided with the global COVID -19 pandemic, which altered lifestyle and water use patterns in unprecedented ways. In April 2021, after a second consecutive dry winter, Governor Newsom declared a drought State of Emergency Proclamation for Mendocino and Sonoma counties . By the end of October 2021 , the proclamation had extended the emergency to all 58 counties, including the City and County of San Francisco.

In November 2021, following the Governor’s statewide emergency declaration, the SFPUC declared a Level 1 water shortage emergency under its 2020 WSCP and requested a 10% system-wide water use reduction. In March 2022, the Governor directed the SWRCB to require all urban water suppliers to implement Level 2 actions from their WSCPs. That directive marked the first time the State required uniform implementation of WSCPs across California. 8 The SFPUC complied by moving from Level 1 (a 10% system-wide reduction request) to Level 2 (an 11% system- wide reduction request), effective July 2022. The SFPUC also implemented a temporary drought surcharge for the first time, beginning in April 2022, to offset operational costs as revenues declined.

A series of atmospheric rivers in the winter of 2022 -2023 ended the drought. The Governor gradually lifted emergency orders throughout the spring of 2023, and the SWRCB rescinded its emergency regulations in June 2023. The SFPUC ended its call for an 11% system-wide water use reduction in April 2023 and discontinued the temporary drought surcharge in May 2023.

Appendix C provides a more detailed overview of San Francisco’s response to the 2020-2023 drought.

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 9 SECTION 2 ANNUAL WATER SUPPLY AND DEMAND ASSESSMENT

PROCEDURES
The SFPUC has a robust process for assessing its annual water supply and demand. This process involves considering a range of input factors unique to the SFPUC’s water supplies and system configuration and provides the SFPUC with flexibility to consider new factors. The SFPUC reports on an assessment of its system’s water supply and demand to the State through the following methods:
• On or before July 1 of each year, the SFPUC prepares a Water Supply and Demand Assessment (WSDA), consistent with California Water Code Section 10632.1 requirements, by evaluating the total amount of water it expects to be in storage within the RWS that year and comparing that amount to expected retail and Wholesale Customer demands. The following subsections outline the SFPUC’s procedures for preparing the annual WSDA.
• Every month, the SFPUC completes the SWRCB’s Drought and Conservation Reporting on the SAFER Clearinghouse online portal.

2.1 DEMAND ASSESSMENT
To calculate unconstrained customer demand on the RWS for the purpose of its annual WSDA, the SFPUC collects information on the demands of both the retail and Wholesale Customers. The SFPUC estimates retail customer demand based on the best available information to date, typically including the previous year’s demands as well as consideration of current demand use patterns or other conditions impacting demands, such as weather and growth.

For estimated wholesale demands, each February, the SFPUC receives from BAWSCA a report of estimated Wholesale Customer demands on the RWS for the upcoming year. BAWSCA compiles this report based on demand estimates it receives from each of its 26 member agencies. The SFPUC estimates the relatively small demands of Cordilleras Mutual Water Company and Groveland CSD, its other two wholesale customers for UWMP purposes, in the same manner that it estimates retail customer demands. These customers are not parties to the WSA and are not BAWSCA member agencies.

2.2 SUPPLY ASSESSMENT
The RWS collects water from the Upper Tuolumne River watershed in the Sierra Nevada and from the local Alameda and Peninsula watersheds. The RWS draws an average of 85 % of its supply from the Tuolumne River watershed. This water feeds into an aqueduct system delivering water 167 miles by gravity to Bay Area reservoirs and customers. The remaining 15 % of the RWS supply is drawn from local surface waters in the Alameda and Peninsula watersheds. The percentage split between the Upper Tuolumne River and Bay Area watersheds varies from year to year depending on the water year hydrology and operational circumstances.

To evaluate water supply conditions each year, the SFPUC uses measurements of precipitation and snowpack in the watersheds above Hetch Hetchy, Cherry, and Eleanor Reservoirs. The Cooperative Snow Survey (conducted by the SFPUC in partnership with state and federal agencies) evaluates snowpack conditions every year beginning 10 in late January. The SFPUC also estimates snowpack conditions using information from the Airborne Snow Observatory, which is a developing technology that uses aerial surveys to quantify snowpack, along with other sources. The SFPUC maintains a hydrologic model of the upcountry watersheds that uses this information to project runoff for the coming year. This process also includes a statistical analysis of additional expected precipitation. In addition to projected runoff, the determination of projected avail able water supply also considers stored water throughout the RWS, water acquired by the SFPUC from non -SFPUC sources, reservoir losses, and allowances for carryover storage.

Additionally, the SFPUC accounts for groundwater provided by the San Francisco Groundwater Supply Project for the in-City retail system and recycled water provided for irrigation at Harding Park , Fleming, and Sharp Park Golf Courses.

The RWS relies on precipitation and snowmelt captured and stored in its reservoirs. During droughts, water supply deliveries can exceed inflows, requiring the use of water stored in previous years to meet demands. Because of the importance of carry -over storage, the SFPUC constantly monitors and evaluates water supply conditions in the RWS, updating look-ahead forecasts as a year’s hydrology and operations change. Generally, in early winter of any year, SFPUC staff can begin providing a forecast of water supply conditions for the upcoming year based on known and anticipated winter and spring precipitation and snowpack. The predictive power of this forecast improves greatly through the spring. The annual precipitation, snowmelt, and carry -over storage togethe r constitute the SFPUC’s reservoir storage conditions. Using data for each of these factors, the SFPUC can determine whether the reservoir system will be capable of serving full deliveries to its customers. Section 2.4 describes the system modeling SFPUC conducts.

The SFPUC sells water to 26 wholesale customers (collectively referred to as the Wholesale Customers) under the terms of a 25-year contract known as the Water Supply Agreement between the City and County of San Francisco and Wholesale Customers in Alameda County, San Mateo County, and Santa Clara County (WSA) and associated individual water sales contracts with each Wholesale Customer. Collectively, the Wholesale Customers on average receive over two-thirds of the RWS’s annual deliveries, with the remaining approximately one-third provided to the SFPUC’s retail customers.

The WSA carries forward many components of its predecessor agreement, including the SFPUC’s “Supply Assurance” of 184 million gallons per day ( MGD) to the Wholesale Customers. The SFPUC has agreed to deliver water to the Wholesale Customers up to the amount of the Supply Assurance, and this agreement is perpetual and survives the expiration of the WSA. The Supply Assurance is, however, subject to reduction due to water shortage, drought, scheduled RWS maintenance activities, and emergencies. As part of the Phased Water System Improvement Plan (WSIP) in 2008, the SFPUC established a temporary 265 MGD annual average limitation on water deliveries from RWS watersheds, the “Interim Supply Limitation” (ISL). The SFPUC has allocated the ISL as 81 MGD to the retail customers and 184 MGD to the Wholesale Customers.

Table 2-1 shows the availability of RWS supplies for the SFPUC’s retail customers and Wholesale Customers in normal years. Table 2-2 shows the current and projected RWS supply needs to meet retail and Wholesale Customer demands based on information and projections presented in the SFPUC’s 2025 UWMP.

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 11 Table 2-1. Regional Water System Supply Availability in Normal Years (MGD) RWS Supply 2030 2035 2040 2045 2050
Retail Customersa, b 81 81 81 81 81
Wholesale Customersc, d 184 184 184 184 184
Total RWS Supplies 265 265 265 265 265
a Groundwater and recycled water are assumed to be used before RWS supplies to meet retail demand. However, if these alternative supplies are not available, up to 81 MGD of RWS supply could be used in normal years. b The SFPUC reports Groveland CSD as a wholesale customer in its UWMP, but the SFPUC otherwise considers Groveland CSD a retail customer and includes Groveland CSD’s demands (approximately 0.3 MGD) within the retail supply allocation of 81 MGD.
c Projected Wholesale Customer deliveries are limited to 184 MGD, including the demands of the cities of San Jose and Santa Clara, which are supplied on a temporary and interruptible basis. d Cordilleras Mutual Water Company is a wholesale customer of the SFPUC, but is not a party to the WSA or a BAWSCA member agency, and it is not included in the Wholesale Customer supply allocation of 184 MGD. The demands of Cordilleras Mutual Water Company are minor (projected to be less than 0.01 MGD).

Table 2-2. Regional Water System Supply Utilized in Normal Years (MGD) RWS Supply 2030 2035 2040 2045 2050
Retail Customersa, b 62.7 61.2 61.9 64.0 66.7
Wholesale Customersc, d 133.9 136.3 140.6 144.1 148.4
Total RWS Supplies 196.6 197.5 202.5 208.1 215.1
a Groundwater and recycled water are assumed to be used before RWS supplies to meet retail demand. However, if these alternative supplies are not available, up to 81 MGD of RWS supply could be used in normal years. b The SFPUC reports Groveland CSD as a wholesale customer in its UWMP, but the SFPUC otherwise considers Groveland CSD a retail customer and includes Groveland CSD’s demands (approximately 0.3 MGD) within the retail supply allocation of 81 MGD.
c Projected Wholesale Customer deliveries are limited to 184 MGD, including the demands of the cities of San Jose and Santa Clara, which are supplied on a temporary and interruptible basis. d Cordilleras Mutual Water Company is a wholesale customer of the SFPUC, but is not a party to the WSA or a BAWSCA member agency, and it is not included in the Wholesale Customer supply allocation of 184 MGD. The demands of Cordilleras Mutual Water Company are minor (projected to be less than 0.01 MGD).

2.3 INFRASTRUCTURE CONSIDERATIONS
On an ongoing basis, three groups within the SFPUC’s Water Enterprise – Hetch Hetchy Water and Power, Water Supply and Treatment Division, and Hydrology and Water Systems – conduct analyses of the RWS that incorporate planned facility outages and multiple levels of projected system demands to evaluate operational capabilities and plan for potential water delivery constraints. These three groups meet quarterly to share plans and coordinate how facility outages, changes in service area demand, wet or dry weather, and other variables shape the operating plans each year. Facility outages due to maintenance or upgrades are coordinated in an adaptive manner to respond to changes as they occur. For new water supplies or new capital projects related to supply distribution, impacts on the RWS are evaluated extensively prior to initiation of any changes. Results from these modeling efforts are considered in the annual WSDA.
12 2.4 SYSTEM MODELING
To proactively plan for conditions that would result in a shortage of water supplies, t he SFPUC models conditions using a hypothetical drought that is more severe than what the RWS has historically experienced. This drought sequence is referred to as the “design drought” and serves as the basis for planning and modeling of future scenarios.

The design drought consists of an 8.5-year sequence of dry conditions.

In applying its water supply planning methodology, the SFPUC performs an initial model simulation of the system for the design drought sequence and then reviews the ability of the system to deliver water to the service area through the entire design drought sequence. If the projected water supply runs out before the end of the design drought sequence in the initial model run, system -wide water use is reduced by applying water supply reductions and the scenario is re-run. This process continues iteratively u ntil a model simulation of the system is achieved in which the water supply in storage at the end of the design drought sequence is brought to the system “dead pool,” where no additional storage is available for delivery (currently simulated as 96,775 acre -feet). Drawing system storage down to the dead pool without going below it indicates that water supply delivery, including the adjusted amount of water use, is maintained through the design drought sequence.

Estimated levels of water supply reduction and corresponding storage threshold values that initiate each level of supply reduction can then be used to simulate the operation of the system through the historical record of hydrology, or to evaluate system water supply conditions during an ongoing drought. While the design drought sequence does not occur in the historical hydrology, the reduced water use and storage threshold values that are adjusted to allow a system configuration to maintain water delivery through the design drought sequence can be used to evaluate system performance in the historical record, or as a basis for comparing with real-time system conditions. Through this planning method, the SFPUC can simulate a response to declining water supply in storage that is appropriate for the system conditions being evaluated.

The SFPUC plans its water deliveries using indicators for demand reduction that are developed through analysis with the design drought sequence. As a result, the SFPUC system operations are designed to provide sufficient carry-over water in SFPUC reservoirs to continue delivering water, although at reduced levels, during multiple-year droughts.

2.5 DECISION-MAKING PROCESS
Regardless of the expectation of shortage conditions, as part of the normal course of business, the SFPUC provides a water supply condition update to its executive team every two weeks throughout the year. Pursuant to the Water Shortage Allocation Plan ( WSAP), also known as the Tier 1 Shortage Plan, that is incorporated in the WSA and described further in Section 3 below, the SFPUC also provides an initial estimate of available water supply for the upcoming Supply Year (defined as the period between July 1 and June 30) to its Wholesale Customers on February 1 every year. An annual Wholesale Customer meeting is held in February at which the SFPUC makes a presentation on current water supply conditions and forecasts. The SFPUC issues a revised estimate of available water supply for the upcoming Supply Year on March 1 and uses the snow survey that occurs in the first week of April and an associated runoff forecast to refine an estimated total system storage expected on July 1. By the middle of April,

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 13 the SFPUC will issue a final estimate of available water supply and determine whether there will be a system-wide shortage for the coming Supply Year.

If the SFPUC determines that a water shortage exists, the SFPUC may call for voluntary demand reductions among its customers or issue a declaration of water shortage emergency pursuant to California Water Code Section 350 et seq. In support of a declaration of water shortage emergency, SFPUC staff will deliver a presentation to the Commission with information that explains the basis for the shortage conditions, such as conditions of precipitation to date, snowpack, and storage levels , with more information as necessary depending on the particulars of the supply forecast. Depending on the level of shortage, the SFPUC may determine that voluntary actions by its retail and Wholesale Customers will be sufficient to accomplish the necessary reduction in water use throughout its service area or that mandatory actions will be required.

Prior to initiating any water delivery reductions to its retail customers, whether it be initial implementation of delivery reductions or implementing a different water shortage level, the SFPUC will outline a water shortage response plan to address the following: the water supply situation; proposed demand reduction objectives; alternatives to demand reductions; methods to calculate water use allocations and adjustments; compliance methodology and enforcement measures; and budget considerations. Details on the expected allocation program are described further in Section

4. SFPUC staff will present t his water shortage response plan at a regularly scheduled Commission meeting and advertise it in accordance with the requirements of Section 6066 of the California Government Code. Water demand reductions that are applicable to Wholesale Customers will be formally communicated following the Commission’s declaration of a water shortage emergency under Section 350 of the California Water Code.

An example of the general WSDA process for water shortages caused by a drought is presented in Figure 2-1 for illustrative purposes. Other non-drought water shortages may not trigger the WSAP and therefore would not follow the same process shown below. For more information about procedures in response to non-drought water shortages, such as those caused by a catastrophic supply interruption, see Section 10.

14 Figure 2-1: Water Supply and Demand Assessment Process

Forecasted
Runoff
Reservoir
storage and
carryover
Conduct Supply vs
Demand Comparison
Supply Assessment
Decision Making Process
System Modeling &
Infrastructure Conditions
Demand Assessment
Writeup on results
provided in packet
to Commission
Implement
water shortage
response plan
Conduct formal
communication to
Wholesale Customers
Conduct formal
communication to
Wholesale Customers
• Presentation to Commission on conditions
• Commission adopts resolution for declaration
of a water shortage emergency condition
under Section 350 of the California Water Code
• Calculate allocations
Sum Total
System Demands
Trigger Water
Shortage Allocation
Plan (WSAP) Tier 1?
Retail
customer
demand
Wholesale
demand
(BAWSCA)
YES NO
Legend
Wholesale
Retail
Common to both
Calculate Total
System Storage

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 15 SECTION 3 WATER SHORTAGE LEVELS AND WATER SHORTAGE

ALLOCATION PLAN (WSAP)
Pursuant to California Water Code Section 10632(a)(3), water suppliers must include as an element within their WSCPs six standard water shortage levels that represent varying shortage conditions from their systems’ normal reliability. The State has standardized the six shortage levels to provide a consistent regional and statewide approach for addressing the relative severity of water supply shortage conditions. The six standard water shortage levels correspond to progressively increasing ranges of shortage conditions: up to 10%, 20%, 30%, 40%, and 50% shortages, and greater than 50% shortage compared to the normal reliability condition. This WSCP presents the shortage response actions aligned with each shortage level that the SFPUC would implement to meet the severity of such shortages.

The SFPUC has two plans that determine how to allocate RWS supplies in the event of a water shortage. First, the Water Shortage Allocation Plan (WSAP), also known as the Tier 1 Shortage Plan , which is an attachment to the WSA, defines the method for allocating RWS supplies between the retail customers collectively and the Wholesale Customers collectively. Second, this WSCP defines how supplies available to the retail customers will be allocated among them.

The WSAP identifies the retail customers’ and Wholesale Customers’ respective shares of the annual water supply available during shortages that require s ystem-wide reductions in water use of 20 % or less. These percentage shares, referred to as the retail customers’ Tier 1 Allocation and the Wholesale Customers’ Tier 1 Allocation , are shown in the first four rows of Table 3-1 (Shortage Levels 1 and 2). For example, when the required level of system- wide reduction in water use is 6 to 10 %, the retail customer Tier 1 Allocation is 36 % of the annual water supply available, and the Wholesale Customer Tier 1 Allocation is 64 % of the annual water supply available. Under the WSAP, if the retail customers’ Tier 1 Allocation results in the retail customers having a “positive” allocation (i.e., a supply of additional water rather than a required percentage reduction in water use), then the retail customers’ percentage share of the available water supply would be reduced to eliminate any positive allocation to retail customers, with a corresponding increase in the percentage share of the available water supply allocated to the Wholesale Customers. For any level of required reduction in system-wide water use, the SFPUC shall require retail customers to conserve a minimum of 5 %, with any resulting reallocated supply credited to storage for inclusion in the calculation of projected available RWS water supply in a subsequent year.

Table 3-1 includes a cross-reference relating to the existing WSAP levels of s ystem-wide water use reduction to the six standard water shortage levels, consistent with California Water Code Section 10632(a)(3). The WSAP does not define Tier 1 Allocations for the retail customers and the Wholesale Customers for system-wide shortages requiring greater than a 20% reduction in water use. For the purposes of this WSCP, the SFPUC assumes that the Tier 1 A llocations for the 16-20% reduction in water use level (37.5% for retail and 62.5% for Wholesale) would apply to all higher shortage levels. In practice, the WSAP defines a process for the SFPUC and the Wholesale Customers to determine whether the application of those Tier 1 Allocations to shortage levels greater than 20% is appropriate or whether a change is required.
16 The WSAP also implements a method for allocating the Wholesale Customers’ Tier 1 Allocation among the respective Wholesale Customers, known as the “Tier 2 Drought Response Implementation Plan,” which has separately been adopted by the Wholesale Customers and does not include the SFPUC.

The SFPUC’s shortage response actions as they relate to the Wholesale Customers are defined in the WSAP and are included in this WSCP by reference.

Table 3-1. Retail and Wholesale RWS Allocations during System-wide Shortage Shortage Level
Required Level of
System-wide Reduction
in Water Use
SFPUC Retail Share of
Available RWS Supplya
Collective Wholesale
Customers’ Share of
Available RWS Supply
1 5% or less 35.5% 64.5%
1 6 – 10% 36.0% 64.0%
2 11 – 15% 37.0% 63.0%
2 16 – 20% 37.5% 62.5%
3b Up to 30% 37.5% 62.5%
4b Up to 40% 37.5% 62.5%
5b Up to 50% 37.5% 62.5%
6b >50% 37.5% 62.5%
a While Groveland CSD is reported in the UWMP as a wholesale customer, it is not a party to the WSA, and it is considered a retail customer of the SFPUC for the purpose of allocating RWS supplies between retail and Wholesale Customers under the WSAP. Thus, RWS supplies to Groveland CSD are accounted for in the retail supply allocation. b The WSAP does not define supply allocations for the retail customers and the Wholesale Customers for system-wide shortages requiring greater than a 20% reduction in water use. Instead, the WSAP sets forth a process for the SFPUC and the Wholesale Customers to determine whether the application of the allocations for the 16-20% reduction in water use level to shortage levels greater than 20% is appropriate or whether a change is required.

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 17 SECTION 4 RETAIL WATER SHORTAGE RESPONSE ACTIONS
Once the SFPUC determines that a water shortage exists, the SFPUC will allocate available water supplies among its retail customers. The SFPUC also maintains permanent restrictions on retail customer water use , as well as potential prohibitions related to water use that may be enforced during a drought , and implements programs and activities that assist customers with reducing demands. The SFPUC may also, depending on the extent of water shortage, implement operational changes or pursue the development of emergency water supplies.

4.1 RETAIL WATER SHORTAGE ALLOCATION
The SFPUC initially adopted a Retail Water Shortage Allocation Plan (RWSAP) in 2001 to formalize a program of action to be taken in the retail customer service area to reduce water use during a drought. Since then, in response to the severe drought of 2012-2016, new legislation in 2018 created a WSCP mandate replacing the water shortage contingency analysis under the former law. This WSCP updates and replaces the standalone RWSAP and now outlines the actions the SFPUC may take in response to a declaration of a water shortage due to drought and other water shortage conditions. The actions to be taken depend on the applicable retail water shortage level shown in Table 4-1. The retail water shortage level also determines the total level of retail customer demand reduction that the SFPUC may require. Demand reduction begins as a voluntary measure and advances to a mandatory measure in higher retail water shortage levels.

4.1.1 Voluntary and Mandatory Demand Reduction
During a declared water shortage emergency, the SFPUC may implement voluntary and/or mandatory demand reductions, depending on the retail water shortage level. Based on its experience in previous droughts, the SFPUC will likely use voluntary calls for demand reduction if the required level of system-wide reduction is up to 30%. If the required level of system-wide reduction is greater than 30%, the SFPUC will likely implement mandatory demand reductions, which will be applied uniformly to all customers within the customer sector.

4.1.2 Types of Allocation Methods for Mandatory Demand Reduction In the event of a mandatory demand reduction, the SFPUC will adopt a system for allocating water among its retail customers. During a water shortage emergency, multiple allocation methods may be needed for different customer types. During the 1987-1992 drought, the SFPUC considered four allocation methods: (1) the per-capita allocation method, (2) the inside/outside or seasonal allocation method, (3) the uniform allocation method, and (4) the percentage allocation method. The following provides a description of each method and the potential advantages or disadvantages of applying each method.
• Per-capita allocation method. The per capita allocation method, which is only applicable for residential customer types, assigns each residential occupant a fixed daily amount of water. This method requires an accurate count of the number of occupants per metered account. Currently, customers can self-report this information, and the SFPUC has collected self-reported occupancy data for most residential accounts.

The method does not consider differences in dwelling type, existing landscaping needs , or special 18 individual circumstances. Implementing a per capita allocation is not possible with commercial and industrial customers; those customers would require a different method for determining allocations. • Inside/Outside allocation method. The inside/outside method, also referred to as the seasonal method, applies a percent age reduction to both indoor and outdoor water use by customers. To determine an individual customer’s allocation, a base year of water use is selected, and reductions are applied to both inside and outside use. Water use during the winter season is identified as reflecting typical “inside use.” The SFPUC would use t he average water used by a customer during the winter months (November, December, January, February) of the base year as the baseline for determining inside use for all 12 months. Water use more than the baseline during other months of the year is considered “outside use.” The monthly inside/outside allocation is a sum of the inside use and the outside use reduced by their respective percentages. This method is used to distribute water equitably and in previous decades was proven effective in achieving system-wide consumption goals. However, San Francisco’s residential water use patterns have changed significantly since the early 2000s, showing very little seasonal use, and San Francisco can only achieve limited savings by focusing on outdoor use only. Additionally, because this method reduces water allocations for all customers regardless of their current use, there is concern that the individual water users who are already consuming very low amounts of water could be disproportionately affected compared to individual water users consuming larger amounts of water. • Uniform allocation method. The uniform allocation method applies a fixed daily amount per dwelling unit for all residential customers. This method does not distribute water equitably to all customers, especially because it does not take into consideration the number of individuals living in each dwelling unit. As with the per capita allocation method , this method could not be applied to commercial and industrial customers.
• Percentage allocation method. The percentage allocation method requires customers to reduce their water use by a fixed percentage compared to past use. For example, to achieve a specified retail service area-wide reduction goal, all customers would need to reduce their water usage by a specified percentage in each billing period based on an established base year. The method requires a much greater reduction in inside use and could cause hardship on both residential and commercial customers. The base year would need to be carefully selected and should reflect demands in a normal, non-drought year.

During the 1987-1992 drought, the SFPUC implemented the inside/outside allocation method because it found this method to be the most fair and reasonable among the alternatives. At that time , the SFPUC applied a per -capita allocation to the accounts of those customers that appealed their allocations under the inside/outside allocation method. Since then, retail residential water consumption patterns have changed significantly , reflecting less seasonality and less outdoor use overall. The SFPUC has also improved its collection of occupancy data per metered account, allowing use of the per-capita method to become the preferred allocation method for residential accounts. The preferred allocation method for non-residential accounts (i.e., irrigation-only, commercial, industrial, and municipal ) is the percentage allocation method. During the 2012 -2016 drought, the SFPUC implemented mandatory reductions for irrigation customers and used a percentage allocation method.

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 19

4.1.3 Per Capita Residential Water Use Floor
SFPUC retail customers already have one of the lowest residential per capita water use rates in California, with an average water use rate of approximately 43 gallons per capita per day in recent years. If the SFPUC institutes a mandatory demand reduction during a water shortage emergency, the SFPUC will adopt a minimum per -capita residential allocation, or water use “floor,” to ensure enough water is available to its customers for basic health and safety needs. The SFPUC will determine an appropriate floor and will specify it in the water shortage response plan, as further described in Section 5.

4.1.4 Water Shortage Allocation Process
The SFPUC will use voluntary calls for demand reduction to the extent possible. If the SFPUC needs to declare a water shortage emergency to implement a mandatory demand reduction, the SFPUC may apply different actions to different customer types to minimize the economic impact of the mandatory demand reductions. All customers within the same customer sector will be treated equally. An example of how the SFPUC may apply different actions to different customer types is as follows:

1. The SFPUC will first apply reductions to irrigation-only accounts; different levels of reduction may be required among those accounts depending on whether an irrigation-only account is a residential, commercial, or municipal account type. Customers using recycled water for irrigation will not be required to reduce their use of recycled water.

2. If there is still a shortage remaining, the SFPUC will next apply reductions to municipal and other accounts, up to 30%.

3. If there is still a shortage remaining, the SFPUC will next apply reductions to single-family and multi-family residential accounts, up to 30% or down to the per capita water use floor, whichever occurs first.

4. If there is still a shortage remaining, the SFPUC will next apply reductions to commercial and industrial accounts, up to 30%.

5. If there is still a shortage remaining, the SFPUC will next return to irrigation-only accounts and make further reductions, proceeding in the same order with additional reductions from each sector.

The SFPUC will inform its retail customers if it determines that there will be a shortage in the new supply year starting July 1 . If the SFPUC implements mandatory demand reductions , t he SFPUC will determine water allocations for each retail customer account, subject to reductions , using the allocation method that the SFPUC determines to be the most appropriate at the time based on the nature of the water shortage and water use trends.

If the SFPUC chooses an allocation method that requires establishing baseline water use levels, the SFPUC will generally select customer water use levels in the last year prior to the water shortage emergency declaration as the baseline. Ideally, the selected baseline year would also avoid periods of sever e economic recession or other anomalous events resulting in abnormal water us e patterns. The SFPUC will provide water use allocations to all retail customers by May 31. The water use allocations will become effective July 1. Allocations for residential customers will not go below the per capita water use floor that the SFPUC establishes in the water shortage response plan.
20 4.1.5 Appeal Process
On or before May 31, the SFPUC will notify retail customers of their reduced water allocations. If the SFPUC applies a per-capita allocation method, each retail customer will have the opportunity to appeal the allocation assigned to its account based on higher actual occupancy than the SFPUC has registered for the property associated with the account, medical exemptions, increased business, or other miscellaneous reasons. The SFPUC will provide retail customers with instructions on how to file appeals at the time the customers are notified of the water use allocations.

Customers may be required to submit supplementa l information in support of their appeal. The SFPUC will also inform customers of the methodology the SFPUC will use to modify allocations if appeals are granted.

4.2 WATER WASTE PROHIBITIONS
Since the 1990s, the SFPUC has had restrictions against various forms of water waste, starting first as drought response measures and later becoming permanent conservation best management practices. During California’s 2012-2016 drought, the SFPUC updated and expanded its water waste restrictions to be consistent with the SWRCB’s 2015 emergency drought regulations. At that time, the SFPUC also updated its procedures for tracking and responding to reports of water waste, which included establishing the City’s 311 system as the central means for reporting water waste; assigning the SFPUC’s Water Conservation Section as the party responsible for investigating and responding to reports of water waste; and confirming the SFPUC’s policy of progressive notification and education to help people at sites identified with potential water waste. On June 28, 2016, the SFPUC adopted permanent water waste restrictions identical to the prohibited water uses in the SWRCB’s 2015 temporary regulations. In 2022, the State adopted new statewide emergency drought regulations that contain all the water waste restrictions that the SFPUC already implements, plus additional restrictions preventing homeowners ’ associations from penalizing or threatening individual owners who take measures to reduce irrigation use . The SFPUC amended its permanent water waste restrictions to align with this additional restriction and included a new provision that prohibits any homeowners’ associations or community service organization s from taking or threatening action against any property owner for reducing or eliminating irrigation during a drought or requiring any property owner to remove installed water -efficient landscaping measures once a drought ends. Most recently in 2023, the SFPUC added a new permanent restriction for using potable water for backfill consolidation around non- potable piping, soil comp action, or dust control for construction or demolition projects when recycled water, well water, or groundwater are available.

The permanent restrictions on retail customer water use are established in Section E, Rule 12 of the SFPUC Rules and Regulations Governing Water Service to Customers, and are reproduced below:

1. The customer will be in violation of the SFPUC’s Water Waste Restrictions if the customer is found to be using water in the following ways:
a. Application of potable water to outdoor landscapes in a manner that causes runoff such that water flows onto adjacent property, non-irrigated areas, private and public walkways, roadways, parking lots or structures
b. Use of hoses for any purpose without a positive shut-off valve

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 21 c. Use of potable water to wash sidewalks, driveways, plazas and other outdoor hardscapes for reasons other than health, safety, or to meet City and County of San Francisco standards for sidewalk cleanliness and in a manner that causes runoff to storm drains and sewer catch basins d. Use of single pass cooling systems, fountains and decorative water features, and commercial car washes
e. Application of potable water to outdoor landscapes during and within 48 hours after measurable rainfall
f. Irrigation with potable water of ornamental turf on public street medians g. Use of potable water for backfill consolidation around non-potable piping, soil compaction, or dust control for construction or demolition projects within San Francisco, if recycled water, well water, or groundwater are available. Recycled water must be us ed in accordance with State Water Resources Control Board, San Francisco Bay Regional Water Quality Control Board, San Francisco Department of Health, and SFPUC standards, regulations and requirements. The SFPUC will review the customer’s fire hydrant meter application and allow temporary water supply from fire hydrants, if SFPUC determines that recycled water, well water, or groundwater are not available for the construction or demolition project
h. Serving drinking water other than upon request at eating or drinking establishments, including restaurants, hotels, cafés, cafeterias, bars or other public places where food or drink are served i. To promote conservation, hotels and motels shall provide guests with the option of choosing not to have towels and linens laundered daily and display notice of this option in guestrooms

2. Any homeowner’s association or community service organization or similar entity is prohibited from:
a. Taking or threatening to take any action to enforce any provision of the governing documents or architectural or landscaping guidelines or policies of a common interest development where that provision is void or unenforceable under section 4735, subdivisions (a) and (b) of the Civil Code; b. Imposing or threatening to impose a fine, assessment, or other monetary penalty against any owner of a separate interest for reducing or eliminating the watering of vegetation or lawns during a declared drought emergency, as described in section 4735, subdivision (c) of the Civil Code; or c. Requiring an owner of a separate interest upon which water -efficient landscaping measures have been installed in response to a declared drought emergency, as described in section 4735, subdivisions (c) and (d) of the Civil Code, to reverse or remove the wa ter-efficient landscaping measures upon the conclusion of the state of emergency
The following restriction on the use of non-potable water for irrigation of nonfunctional turf is from Section F, Rule 17 of the SFPUC Rules and Regulations Governing Water Service to Customers, and is summarized below:

1. The Rules and Regulations would prohibit the use of potable water for irrigating nonfunctional turf on the following property types, in accordance with this schedule:
a. January 1, 2027, for properties owned by the Department of General Services b. January 1, 2027, for properties owned by local governments, the state and local governments, local or regional public agencies, and public water systems, but excluding such property located within a disadvantaged community
22 c. January 1, 2028, for all commercial, industrial, and institutional properties d. January 1, 2029, for all common areas of properties of homeowners’ associations, common interest developments, and community service organizations or similar entities e. January 1, 2031, for properties owned by local governments, local public agencies, and public water systems in a disadvantaged community or the date upon which a state funding source is made available to fund conversion of nonfunctional turf on these prope rties to climate-appropriate landscapes, whichever is later

2. In addition, as required by AB 1572, the Rules and Regulations require commercial, industrial, and institutional property owners, homeowners’ associations, common interest developments, and community service organizations with more than 5,000 square feet of irrigated area to certify compliance with AB 1572 to the State Water Resources Control Board. Commercial, industrial, and residential property owners must submit certifications beginning June 30, 2030, and every three years thereafter through 2039. Homeowners’ associations, common interest developments, and community service organizations must submit certifications beginning June 30, 2031, and every three years thereafter through 2040.

The following are potential temporary prohibitions related to water use that the SFPUC may implement during a water shortage emergency to supplement the permanent water use restrictions:

1. Limit the use of additional water for new or retrofitted landscaping or expansion of existing facilities under all conditions not otherwise subject to San Francisco’s Water Efficient Irrigation Ordinance

2. Restrict potable water supplies, other than groundwater or recycled water, for irrigation of golf courses, private median and sidewalk parkway strips, and other turf areas not already covered by the SFPUC’s permanent restrictions on use of potable water for turf irrigation

3. Restrict use of potable water on golf courses outside of irrigation of putting greens

4. Restrict use of potable water for street sweepers/washers

5. Restrict the washing of all automobiles, motorcycles, RVs, trucks, transit vehicles, trailers, boats, trains, and airplanes outside of a commercial washing facility , unless required to clean windows on all vehicles and such commercial or safety vehicles for health and safety reasons

6. Restrict the filling of new swimming pools, spas, hot tubs, or the draining and refilling of existing pools, hot tubs, and water features

7. Limit days or times for outdoor irrigation with potable water

8. Activate the SFPUC’s regulations regarding excessive residential use during drought (SFPUC Commission Resolution No. 17-0010), which would set an excessive residential household water use threshold and fine single family residential customers who exceed th e threshold; customers issued fines for excessive use would be subject to public disclosure

9. Expand water waste patrolling

10. Activate drought surcharge
Appendix A describes the various measures that the SFPUC employed during the 1987-1992 drought to achieve a 25% system-wide reduction in retail customer demands (compared to the pre-drought demand). These measures included absolute limitations on water use based on residential customer classification and a proportion of historical use within the non -residential sectors. Appendix B describes the various measures that the SFPUC employed

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 23 during the 2012 -2016 drought to achieve a primarily voluntary 10 % system-wide reduction in retail customer demands. Appendix C describes the actions the SFPUC took during the 2020-2023 drought, including implementing Level 2 of this WSCP in alignment with the State’s directive and increasing system-wide demand reductions to 11%.

The SFPUC’s implementation of each of the temporary prohibitions listed above is not directly linked to a particular water shortage level under this WSCP. The only water shortage response action that the SFPUC may implement specifically in response to a particular shortage level is demand reduction (either voluntary or mandatory).

4.2.1 Artificially Supplied Water Features
For the purposes of this WSCP, artificially supplied water features include, but are not limited to decorative ponds, artificial lakes, waterfalls, fountains, and other ornamental or aesthetic water features that rely on a continuous or intermittent supply of potable or non -potable water . These features are evaluated based on their water use characteristics, operational purpose, and potential for reduction in water use. During water shortage conditions, restrictions on these features may include reduced operation, recirculation requirements, or temporary shutdown, depending on the severity of the shortage stage. Additionally, the Water Efficient Irrigation Ordinance requires water features to use recirculating water systems and non-potable water for decorative water features, when available.

Consistent with the definition provided in Health and Safety Code Section 115921(a), swimming pools and spas are treated as a separate category due to their distinct public health, recreational, and operational considerations. Water shortage response actions for pools and spas may include limits on draining and refilling, requirements for covers to reduce evaporation, and other measures appropriate to the shortage level.

4.3 DEMAND REDUCTION ACTIONS
The SFPUC implements many customer assistance programs to help reduce water use in the retail service area. The SFPUC implements all programming methods on an ongoing basis or as needed, regardless of whether there is a water shortage. Many program methods are also demand-management measures that are described in more detail in the SFPUC’s UWMP and Water Conservation Plan . Some of these methods will increase in application, participation, or frequency because of a water shortage (e.g., public outreach, rebates, Water Wise Evaluations), but the increase is not necessarily triggered by a specific level of shortage. Some of the core actions that the SFPUC is most likely to increase during water shortages to reduce demand are as follows:
• Expand Public Information Campaigns: Through its conservation program, the SFPUC develops media campaigns and extensive informational materials in multiple languages , and staff performs widespread outreach activities to (1) inform the public of water shortage conditions, (2) relay information about demand reductions and prohibitions, and (3) promote conservation and customer use of the SFPUC’s conservation services. The SFPUC regularly notifies the highest residential and commercial water users of their consumption and the SFPUC’s conservation services to help reduce demands. • Enhance Customer Billing and Water Use Information: Since 2014, in conjunction with the deployment of its Automated Water Meter Program, the SFPUC has used a bill management system, monthly billing at the

0.01 unit level (i.e. 1 cubic foot), and a web portal to provide customers with more detailed information about their water use and efficiency. The online portal allows all in-City retail water service customers to view their 24 daily and hourly water use data provided by the automated water meter reading system . It also allows residential customers to see how their per capita water use compares to the SFPUC’s efficiency goals, and for any customer to see how their water use aligns with any reduction targets that might be in place during a declared water shortage . During a water shortage, the SFPUC may also add specif ic messages or information to customer bills about the water shortage condition and what voluntary or mandatory measures are in place.
• Offer Water Use Surveys: The SFPUC provides free Water-Wise Evaluations for homes and businesses through its conservation program. These Water-Wise Evaluations consist of an onsite or phone-based review of indoor fixtures and appliances as well as an onsite review of irrigation systems. Each assessment includes a summary report outlining recommendations to improve efficiency as well as estimated water savings.

Interest and participation in this service tends to increase during times of drought. • Provide Rebates and Incentives for Replacement of Inefficient Fixtures , Equipment, and Landscapes; and No-Cost Distribution of Water-Saving Devices: Through its conservation program, the SFPUC provides rebates for replacement of a wide range of plumbing fixtures and water-using equipment, including irrigation system components. It also provides water-saving devices at no cost to retail customers in and outside of San Francisco and tenants of properties served by a retail water service account . The SFPUC may enhance incentive programs during a water shortage by increasing rebate and grant amounts, expanding the types of fixtures and equipment covered, increasing participation opportunities, and using other means.
• Increase Water Waste Patrols: SFPUC field inspectors watch for, report, and respond to potential water waste they may encounter as part of their regular patrol throughout the City. The SFPUC also encourages the public to report potential water waste through the City’s 311 service request system, as described in Section 4.2. The SFPUC may expand these efforts during water shortages.

4.4 OPERATIONAL CHANGES
The SFPUC may employ the following operational changes to help reduce potable water use. While the SFPUC does not formally enact these methods in the event of a shortage, it may employ them at any time at the discretion of the SFPUC’s San Francisco Water Division.
• Decrease line flushing: The SFPUC may decrease pipeline and other system flushing, which it routinely conducts to maintain water quality, remove sediment, and ensure proper system operation. In past droughts, the SFPUC temporarily reduced programmatic flushing of dead ends within the in -City distribution system pipelines from a scheduled program to an as-needed basis to respond to water quality issues. The SFPUC has also temporarily reduced regular system maintenance flushing in the Town of Sunol during previous droughts to an as-needed basis.
• Reduce system water loss: The SFPUC conducts pressure management, collects main break data, and administers a Linear Asset Management Program to help control distribution system losses. In addition, to address water loss at the customer level, the SFPUC launched a Leak Alert Program in April 2015 to notify

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 25 single-family residential customers about potential plumbing leaks that may be occurring at their homes. Since then, the SFPUC has expanded this program to notify all customer sectors. This program also meets State mandates requiring water suppliers to notify customers when they are aware of leaks that are within the customer’s control.
• Increase recycled water and groundwater supply: The SFPUC may be able to further reduce reliance on RWS surface water supplies during a water shortage by increasing recycled water supply from the Westside Recycled Water Treatment Facility up to the peak design capacity of 4 MGD. The SFPUC could also potentially increase groundwater production, but this capacity is limited to 4 MGD.

4.5 SUPPLY AUGMENTATION ACTIONS
The SFPUC will seek voluntary or mandatory demand reduction during a declared water shortage emergency.

Depending on the severity and duration of the water shortage emergency, the SFPUC may also seek to develop emergency water supplies. This could include actions such as initiating water transfers.

4.6 SUMMARY OF RETAIL SHORTAGE RESPONSE ACTIONS
The SFPUC expects to meet water shortages primarily with voluntary demand reductions, escalating to mandatory reductions if needed, and will allocate water among its retail customers in accordance with Section 4.1 of this WSCP. The SFPUC will also enforce restrictions and prohibitions of certain water uses and implement additional programs to facilitate demand reduction in order to support meeting its demand reduction targets. The SFPUC may also implement operational changes to reduce water use. At this time, the SFPUC has not identified any supply augmentation shortage response actions as a specific response to a shortage , but they would be considered . As described at the beginning of Section 2 , the SFPUC already incorporates supply augmentation with dry -year supplies as a part of normal operations and water management planning to reduce the likelihood or severity of water shortage conditions.

This WSCP contains six water shortage levels corresponding to ranges of up to 10 %, 20%, 30%, 40%, and 50% shortages and greater than 50% shortage. For each shortage level, there are corresponding retail demand reduction actions to be implemented and an estimated percentage reduction to the water shortage gap . To calculate the estimated percentage reduction to the water shortage gap , the SFPUC first considers the baseline RWS supply availability in a normal year . If the WSAP applies, t he SFPUC then follows the WSAP process to determine the retail customers’ and Wholesale Customers ’ respective percentage shares of the annual RWS supply available during the shortage. The SFPUC then calculates the retail customers’ projected demands on the RWS (excluding local groundwater and recycled water supplies) and compares that to the retail customers’ RWS supply allocation to determine the retail water shortage level.

The retail water shortage level may be different from the system-wide water shortage level under the WSAP. For example, under the WSAP, when the required level of system-wide reduction in water use is 10 %, the retail 26 customers would receive an allocation of 81 MGD.0F
1 Because retail customer demands are projected to reach 73.4 MGD in 2050, there would not be a retail water shortage under such circumstances within the planning horizon of 2050. However, because the SFPUC has agreed to conserve a minimum of 5% in the event of any declared water shortage under the WSAP, in this scenario, the SFPUC would implement a 5% voluntary demand reduction for its retail customers.

At higher system-wide shortage levels under the WSAP, the retail customer allocation from the RWS results in a retail water shortage level that varies depending on retail customer demands. The demand reduction volumes necessary at a given shortage level will change based on the retail demands at the time of a declared water shortage emergency. The percentage reductions are based on the highest projected unconstrained SFPUC retail customer demands on the RWS in the UWMP planning horizon. The corresponding shortage response actions are intended for estimation purposes and are based on the highest projected retail demand as presented in the SFPUC’s 2025 UWMP. As retail demands increase, the associated necessary demand reductions will increase accordingly.

For Shortage Levels 1 -3, the SFPUC expects to have enough supply to meet projected unconstrained retail demands. However, the SFPUC has a contractual obligation to require retail customers to conserve a minimum of 5% for any required reduction in system-wide water use during shortages. The SFPUC plans for a 5% reduction in retail demand with a voluntary call for reductions in water use. If the RWS needs to reduce water use by more than 30%, the SFPUC will implement mandatory demand reductions that would begin at Shortage Level 4.

For Shortage Levels 4 through 6 , where there is a mandatory demand reduction , the SFPUC would identify the appropriate allocation methods for different customer types. A Shortage Level 6 could require the SFPUC to implement strict demand reduction actions such as requiring reductions of 50 % to irrigation-only accounts, 30 % reductions in other non-residential accounts, and using a per capita allocation of 25 gallons per day for single-family and multi-family residential accounts.

The Water and Wastewater Drought Surcharge in the SFPUC’s Rate Schedule s and Fees for Water and Sewer Service is based on Table 4-1, where shortage levels are referred to as shortage “stages.” The estimated water usage reduction and drought surcharge on volumetric water rates may change in 2028 when water and sewer rates are updated.
1 To arrive at this allocation, the baseline RWS supply availability 265 MGD of supply is first reduced by 10%, which results in 238.5 MGD of available RWS supply. Under the WSAP (see Table 3-1), the retail customer share of available RWS supply is 36.0% when the level of system-wide reduction in water use is 10%: 238.5 MGD * 36.0% = 85.9 MGD. Because this calculation results in the retail customers having a positive allocation (i.e., a supply of additional water rather than a required percentage reduction in water use, as 85.9 MGD > 81 MGD), the retail customer percentage share of the available RWS supply is reduced to the normal retail supply allocation of 81 MGD to eliminate any positive allocation to the retail customers.

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 27 Table 4-1. Demand Reduction Actions
[Submittal Table 8-3: Demand Reduction Actions]
Standard
Shortage
Level
Percent
Shortage
Range
Retail Demand Reduction
Action
Estimated
Reduction in
Shortage Gap
Penalty, Charge,
or Other
Enforcement?
1 Up to 10% Voluntary Reduction 5% No
2 Up to 20% Voluntary Reduction 5% No
3 Up to 30% Voluntary Reduction 5% No
4 Up to 40% Mandatory Reduction 18% Yes
5 Up to 50% Mandatory Reduction 32% Yes
6 >50% Mandatory Reduction 32% Yes

28 SECTION 5 COMMUNICATION PROTOCOLS
Regular communication with the SFPUC’s customers and the public is essential during a water shortage, especially when mandatory actions or restrictions are in effect. The SFPUC communicates demand reduction schedules and requirements early and often to all customers. The SFPUC will employ multiple methods and means to inform and educate customers and the public on water use restrictions and ways to conserve water.

Prior to initiating any water delivery reductions to its retail customers or increasing the severity of water shortage response measures, the SFPUC will prepare or revise a water shortage response plan that addresses the following:
the water supply situation; proposed demand reduction objectives; alternatives to demand reductions; methods to calculate water use allocations and adjustments; minimum per capita allocation (i.e., residential water use “floor”); enforcement measures; and budget considerations.

SFPUC staff will present this water shortage response plan at a regularly scheduled SFPUC Commission meeting advertised in accordance with the requirements of Section 6066 of the California Government Code. The public will be invited to comment on the SFPUC’s plan to address reduced water supply.

5.1 COMMUNICATIONS ABOUT VOLUNTARY REDUCTIONS
Customer and public outreach methods that the SFPUC may employ during a call for voluntary reductions include, but are not limited to:
• Press releases and briefings to media
• Social media posts
• Dedicated and regularly updated information about the drought on the SFPUC’s website • Articles in Currents, the SFPUC’s digital and print customer newsletter • Bill inserts and messages on customer bills
• Outdoor billboard, transit station, bus, television, radio, and newspaper ads • Email blasts to interested organizations and groups
• Community presentations
• Letters, emails, phone calls, and mobile text notices directly to customers • Updates to the SFPUC’s customer portal to communicate water reduction goals

5.2 COMMUNICATIONS ABOUT MANDATORY DEMAND REDUCTION
The SFPUC would employ multiple customer and public outreach methods during a call for mandatory demand reduction. Additional notifications to account holders that the SFPUC will disseminate include:
• Notification letter to all customers informing them of the upcoming activation of mandatory demand reduction measures, including potential excess use fines and the imposition of a drought surcharge. • Notification letter to all customers affected by mandatory reductions that provides their monthly allocations for the fiscal year, including information about the appeals process , availability of daily and hourly consumption data on the customer portal, and other resources for conservation assistance.

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 29 • Notification letter to customers with adjustments to their reduced flow factors, including information about the appeals process and resources for conservation assistance. • Notification letter to all customers informing them that the water shortage emergency has been lifted and the SFPUC is ending the mandatory demand reduction.
• Noticing for public hearings conducted at SFPUC Commission meetings that inform the Commissioners and public about the declaration of a water shortage emergency and any subsequent modifications to the water shortage stage.

5.3 COMMUNICATIONS RELATED TO WHOLESALE CUSTOMERS
As part of the normal course of business, SFPUC staff provides an initial estimate of available water supply for the upcoming Supply Year (defined as the period between July 1 through June 30) to its Wholesale Customers on February 1 every year. An annual Wholesale Customer meeting is held in February at which the SFPUC makes a presentation on current water supply conditions and forecasts. The SFPUC issues a revised estimate of available water supply for the upcoming Supply Year on March 1 and uses the snow survey that occurs in the first week of April and an associated runoff forecast to refine an estimated total system storage expected on July 1. By the middle of April, the SFPUC will issue a final estimate of available water supply and determines whether there will be a system-wide shortage for the coming Supply Year . A flowchart depicting an example annual Water Supply and Demand Assessment process for water shortages caused by a drought , including communication processes, is shown in Figure 2-1.

30 SECTION 6 COMPLIANCE AND ENFORCEMENT

6.1 ENFORCEMENT OF WATER USE ALLOCATIONS FOR RETAIL CUSTOMERS The SFPUC’s primary methods for enforcing mandatory water shortage actions applicable to retail customers include excess use fines, installation of flow restrictors on customers’ service lines, and/or water shut-off. In addition, a state law passed in 2016 (SB 814, adding Chapter 3.3 to Division 1 of the California Water Code) requires public disclosure of customers who are fined for exceeding water use allocations.

During the 1987 -1992 drought, the SFPUC applied drought excess use fines as outlined below. The fines only applied to the amount of water used over a customer’s allotment. • If a customer consumed up to 10% over its allotment, the customer was fined 2 times the normal rate; • If a customer consumed 10.01% to 20% over its allotment, the customer was fined 8 times the normal rate; and
• If a customer consumed 20.01% or more over its allotment, the customer was fined 10 times the normal rate.

During the 2012 -2016 drought, the SFPUC called for a 10 % voluntary reduction in water use by all customers system-wide. Additionally, the SFPUC applied mandatory reductions and excess use fines to irrigation customers, a small subset of all retail customers. The SFPUC’s actions during this drought included the following:
• Establishing a 25% mandatory demand reduction for dedicated irrigation customers, subject to excess use fines of 1 time the normal rate.
• Establishing a 30% mandatory demand reduction for Interruptible Water Service accounts , subject to excess use fines of 3 times the normal rate.

During the 202 0-2023 drought, the SFPUC declared a water shortage emergency at Shortage L evel 1 , on November 23, 2021, with a call for a voluntary 10% system-wide demand reduction. The SFPUC also instituted a temporary drought surcharge for retail water and wastewater customers of up to 5% on part of their bill, effective April 1, 2022. On April 21, 2022, the SFPUC released its final water supply availability estimate for the upcoming supply year (FY 2022-23), which indicated that despite lower-than-normal snowpack, Hetch Hetchy Reservoir was expected to fill but the water bank was not expected to fill, demonstrating that demand reductions continued to be necessary. At the same time, Governor Newsom issued Executive Order N -7-22, directing the SWRCB to adopt emergency drought regulations requiring urban water suppliers to implement Shortage Level 2 of their WSCPs. On May 24, 2022, the SFPUC adopted an 11% system-wide demand reduction associated with Shortage Level 2 of the SFPUC’s 2020 WSCP, which aligned with State requirements. In the months that followed, storms came through California that restored water storage levels in SFPUC reservoirs. As a result, on April 11, 2023, the SFPUC ended the water shortage emergency declaration and lifted the drought surcharge, effective May 1, 2023.

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 31 If an individual customer exceeds its water use allocation, the SFPUC may, after issuing one written warning, install a flow restriction device on the customer's service line. If a customer continues to consume water in excess of its allotment, the SFPUC has the authority to discontinue the customer’s water service and charge penalty fees for the violation and the cost of enforcement.

6.2 ENFORCEMENT OF WATER WASTE PROHIBITIONS FOR RETAIL CUSTOMERS Water waste activities can be reported through the City’s 311 service request system or observed by or reported directly to SFPUC staff. The SFPUC reviews each report of potential water waste, and if a report contains sufficient information and reflects a restricted water use, the SFPUC notifies the water account holder, property owner, and/or occupant. If there are additional water waste reports at the same property, the SFPUC may call or visit the site to verify that there is water waste. If water waste is verified and continues, the SFPUC will issue additional warnings to the water account holder. Account holders that receive multiple warnings of verified water waste may be subject to additional enforcement actions. The SFPUC also takes the same actions for incidents of water waste observed by SFPUC Water Conservation field inspectors, and the SFPUC may increase the number of inspectors patrolling for water waste during a drought.

Per the SFPUC Rules and Regulations Governing Water Service to Customers and the SFPUC’s water rate schedule, violation of any water use restriction may result in fines on the customer’s water bill, installation of flow restriction devices, injunctions, or other actions as deemed appropriate . Continued violation may result in termination of water service.

6.3 ENFORCEMENT OF WATER USE ALLOCATIONS FOR WHOLESALE CUSTOMERS Section 3 describes the allocation of RWS supplies between retail and Wholesale Customers in the event of a system-wide water shortage reduction. During periods of mandatory demand reduction, the SFPUC will not assess excess use charges on any of the Wholesale Customers if the Wholesale Customers ’ collective cumulative purchases over the course of the Supply Year are less than the Wholesale Customers’ Tier 1 allocation as reflected in Table 3-1. If the Wholesale Customers’ collective cumulative purchases exceed the Wholesale Customers’ Tier 1 allocation, the SFPUC can assess excess use charges on each individual Wholesale Customer that exceeded its individual Tier 2 allocation (as established in the Tier 2 Plan) over the course of the Suppl y Year in proportion to each individual Wholesale Customer’s share of the collective purchases that exceeded their Tier 1 allocation .

Monthly excess use charges will be determined by the SFPUC at the time of the declared water shortage consistent with the terms of the WSA. Information about excess use charges for Wholesale Customers are discussed in Section 4 of the WSAP.

32 SECTION 7 LEGAL AUTHORITIES
The SFPUC will declare a water shortage emergency in accordance with California Water Code Chapter 3, Sections 350-359 of Division 1 . The SFPUC will coordinate with any city o r county within which it provides water supply services for the possible proclamation of a local emergency (California Government Code Section 8558). The SFPUC is in regular communication with its Wholesale Customers about water supply conditions.

Additional legal authorities for implementation of the WSCP include, but are not limited to, the following:
• Water Supply Agreement between the City and County of San Francisco and Wholesale Customers in Alameda County, San Mateo County, and Santa Clara County (described in more detail in Section 3). • SFPUC Rules and Regulations Governing Water Service to Customers, originally established by Resolution No. 19.786 passed December 15, 1959, as they are amended from time to time. • Chapter 3.3 of Division 1 of the California Water Code (Excessive Residential Water Use During Drought).

SECTION 8 FINANCIAL CONSEQUENCES OF THE WSCP
The SFPUC’s rate structure is comprised of fixed and variable components. As a result, as per-unit sales decrease, revenues are lost. The marginal cost of water delivery is relatively small, which means that as demand decreases, the cost of providing water service remains the same . Meanwhile, the SFPUC may incur s ome new costs to implement its water shortage actions, such as efforts required to coordinate implementation of customer -specific allocations in the SFPUC’s billing system and the cost of notifying customers. For both retail and wholesale customers, a reduction in water purchases – whether voluntary or mandated – could result in challenges meeting financial obligations for debt -service coverage or financial reserves . To help mitigate these financial risks, the SFPUC’s retail water rates have a provision for a drought surcharge that automatically increases rates in the event of an SFPUC -declared water shortage. The SFPUC Commission may pass a resolution to impose a drought surcharge in the form of a percent age increase in the volumetric portion of retail water rates. The percent age increase would be in line with the expected water use reductions and would ensure the SFPUC recovers sufficient revenues to cover ongoing service costs despite lower demands. The drought surcharge would remain in effect until the Commission adopts a resolution to rescind the system-wide demand reduction. The drought surcharge is calculated so that, accounting for the expected reduction in retail water usage, total revenues are approximately equal to what they would have been without the demand reduction. The drought surcharge protects the SFPUC’s financial stability during water shortages. More information about drought surcharges is in the SFPUC’s Rate Schedules & Fees for Water and Sewer Service.

For Wholesale Customers, the rate-setting process is governed by the terms of the WSA, which provides that, in the event of a water shortage emergency, the SFPUC Commission may adjust wholesale rates in an expedited way concurrently with the imposition of drought surcharges on retail customers. Beyond drought rate setting and emergency rate setting, rates are set annually in coordination with the SFPUC ’s annual budget process and are based on the forecasted wholesale share of RWS expenditures and total purchases. If Wholesale Customer usage

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 33 is expected to decrease – either voluntarily or due to water shortages – this would be incorporated into the wholesale rate forecast, and rates may increase to make up for the revenue loss caused by reductions in water use.

SECTION 9 MONITORING AND REPORTING
With respect to water use monitoring and reporting, the SFPUC’s customer billing system generates monthly consumption reports through which the SFPUC will track actual water savings during a water shortage . These consumption reports are highly accurate as all retail and wholesale customers are metered. The SFPUC can determine how much both retail and wholesale customers reduced their water use in response to voluntary or mandatory demand reductions by comparing their consumption data month to month . The SFPUC will also use these data to evaluate the effectiveness of the water shortage response plan that the SFPUC will have prepared in accordance with the WSCP. State regulations require the SFPUC to report retail customer consumption to the State on a monthly, quarterly , and annual basis, whether or not water shortage conditions exist . State regulations also require the SFPUC to report to the State if water shortage conditions exist, and, if so, what demand reduction and water supply augmentation actions the SFPUC is taking in response. The SFPUC conducts ongoing monitoring of its watersheds, reservoirs, and other RWS components for reporting on the status of the SFPUC’s water supply to determine the applicable water shortage level.

SECTION 10 PREPARATION FOR CATASTROPHIC SUPPLY

INTERRUPTION
The SFPUC maintains various planning documents and strategies that collectively address its emergency preparedness and planned response in the event of a catastrophic interruption of water supplies due to power outages, earthquakes, or other disasters. These plans are described in the following subsections 10.1 (Emergency Preparedness Plans), 10.2 (Emergency Drinking Water Planning ), and 10.3 (Power Outage Preparedness and Response). Subsection 10.4 further addresses the Seismic Risk Assessment and Mitigation Plan required by California Water Code Section 10632.5(a). Should a catastrophic interruption occur, the SFPUC will coordinate with any city or county within which it provides water for the possible proclamation of a local emergency (California Government Code, California Emergency Services Act Article 2, Section 8558).

10.1 EMERGENCY PREPAREDNESS PLANS
Following the 1989 Loma Prieta earthquake, the SFPUC created a departmental Emergency Operations Plan (EOP). The SFPUC EOP was originally released in 1992 and has since been updated as necessary. The SFPUC EOP addresses a broad range of potential emergency situations that may affect the SFPUC and supplements the City’s Emergency Response Plan, which was prepared by the Department of Emergency Management and most recently updated in 2017 . The purpose of the SFPUC EOP is to describe the SFPUC’s emergency management organization, roles and responsibilities, and emergency policies and procedures.

In addition, the SFPUC’s enterprises each have their own emergency plans (in alignment with the SFPUC EOP), which detail each entity’s specific emergency management organization, roles and responsibilities, emergency policies and procedures, and response to hazardous events (e.g., hazardous materials, power interruption, etc.). In 2025, the 34 SFPUC developed a Water Emergency Operations Plan (Water EOP) to comply with the America’s Water Infrastructure Act passed in 2018. The Water EOP integrates directly into, and functions as an annex to, the SFPUC EOP. The Water EOP addresses SFPUC water transmission and distribution systems and identif ies the agency’s enterprises, divisions, and bureaus with direct roles and responsibilities for those systems . The SFPUC EOP functions as a front end for the SFPUC’s enterprise EOPs, covering emergency response at the department level, while each enterprise EOP covers enterprise-specific information on the enterprise’s emergency organization and response procedures specific to enterprise responsibilities, assets, technical scope, and operations.

The SFPUC exercises its EOPs on a regular basis by conducting emergency exercises and responding to real-world events. Through these exercises and activations, the SFPUC learns how well the plans and procedures will or will not work in response to an emergency. EOP improvements are based on the results of these exercises and real-world event response and evaluation. The SFPUC also has an emergency response training plan that is based on federal, State, and local standards and exercise and incident improvement plans. SFPUC employees have emergency training assignments based on their emergency response roles, as identified in the EOPs.

The types of events affecting the SFPUC that require emergency plans include but are not limited to:
• Major earthquake
• Loss of power
• Loss of water supply
• Major fire
• Hazardous material release that threatens water supply or the environment • Major pipeline breaks
• Dam incident
• Significant outage of SFPUC services
• Man-made or intentional acts of terrorism resulting in damage to the system or interruption in service In addition to the documents described above, the SFPUC also maintains various plans and procedures that deal with the possibility of alternate supply schemes and options. These plans and procedures include:
• Emergency Disinfection and Recovery Plan
• Emergency Response Action Plan
• Emergency Drinking Water Equipment and Alternatives Report • Disinfection of SFPUC Water Trailers Procedure
• San Francisco Water Division Hydrant Manifold Standard Operating Procedure

10.2 EMERGENCY DRINKING WATER PLANNING
The SFPUC has implemented several projects to increase its capability to provide emergency drinking water during a catastrophic emergency. These projects include:

2025 Water Shortage Contingency Plan for the City and County of San Francisco | 35 • Completion of many WSIP projects and other capital upgrades to improve security, detection, and communication (see Section 10.4);
• Development of public information and educational materials for residents and businesses; • Construction of a disinfection and fill station at the existing San Francisco Zoo well, and obtaining a permit to utilize this well as a standby emergency drinking water source; • Construction of six wells as part of the San Francisco Groundwater Supply Project, two of which also serve as emergency drinking water supplies, including a distribution system to fill emergency water tankers;
• Purchase and engineering of emergency -related equipment, including water tanker trucks and water distribution manifolds, to help with distribution post-disaster; and • Coordination of planning with other City departments, neighboring jurisdictions, and other public and private partners to maximize resources and supplies for emergency response.

The SFPUC also maintains a Water Quality Notifications and Communications Plan. Initially prepared in 1996 and most recently updated in 2022, this plan provides contact information and guidelines on notifications that SFPUC staff will issue in the event of water quality impacts that warrant communications internally and externally with the State, the Wholesale Customers, and/or the public. The plan treats water quality issues as potential or actual supply problems, which fall under the emergency response structure of the SFPUC EOP.

10.3 POWER OUTAGE PREPAREDNESS AND RESPONSE
The SFPUC’s water transmission system is primarily gravity fed from Hetch Hetchy Reservoir to the City. Within the in-City distribution system, key pump stations have generators on site, and all others have connections in place that would allow the use of portable generators.

Although power outages would not greatly impact water conveyance throughout the RWS because it is gravity fed, the SFPUC has prepared for potential regional power outages as follows:
• The Tesla Treatment Facility, the Sunol Valley Water Treatment Plant ( SVWTP), the Sunol Valley Chloramination Facility (SVCF), and the San Antonio Pump Station (SAPS) have back-up power on site in the form of generators. Additionally, SVWTP , SVCF, and SAPS would not be impacted by a failure of the regional power grid because these facilities are powered by hydropower generated by Hetch Hetchy Water and Power via the Calaveras Substation.
• Both the Harry Tracy Water Treatment Plant and the Baden Pump Station (part of the Peninsula System) have back-up generators in place.
• Administrative facilities that may act as emergency operation centers also have back-up power. • The SFPUC has a water supply connection with the Santa Clara Valley Water District ( Valley Water or VW), known as the SFPUC-VW Intertie, which also has back-up generators in place. • Additionally, as described in the next section, various WSIP projects expand ed the SFPUC’s ability to remain in operation during power outages and other emergency situations. 36 10.4 SEISMIC RISK ASSESSMENT AND MITIGATION PLAN
As part of the SFPUC’s Facilities Reliability Program and WSIP, the SFPUC performed an extensive multi -year evaluation of seismic risks to its water system that resulted in major capital improvements to increase seismic reliability. The goals of WSIP include enhancing the ability of the SFPUC water system to meet identified levels of service goals for water quality, seismic reliability, delivery reliability, and water supply. One of the reasons the SFPUC developed WSIP was to reduce the likelihood of shorta ges, thereby reducing the likelihood of needing to implement the WSCP. Several WSIP projects located in San Francisco improve d the seismic reliability of the in - City distribution system, such as additional wells that can be used as emergency drinking water sources. Many WSIP projects related to the RWS outside of San Francisco , the majority of which are now complete, addressed both seismic reliability and overall system reliability. The SFPUC completed the San Francisco portion of WSIP as of October 2020 and forecasts that the overall WSIP will be complete in June 2032.

WSIP seismic levels of service (LOS) informed development of WSIP capital projects and guided program implementation. The LOS established post-earthquake delivery and recovery objectives under the following seismic scenarios:
• Magnitude 7.9 event on the San Andreas fault
• Magnitude 7.3 event on the Hayward fault
• Magnitude 6.9 event on the Calaveras fault
An assessment of seismic risk and resilience is contained in the body of analysis performed to support the WSIP.

The risks associated with the seismic scenarios considered are reflected in the delivery objectives established in the LOS, specifically:
• Delivery of winter month demand 24 hours after a major earthquake, and • Delivery of average day demand 30 days after a major earthquake In addition to the improvements that have come or will come from the WSIP, the SFPUC has already constructed system interties for use during catastrophic emergencies, short -term facility maintenance and upgrade activities, and times of water shortages. These are listed below:
• EBMUD-Hayward-SFPUC Emergency Intertie: An intertie that may transfer up to 30 MGD among East Bay Municipal Utility District (EBMUD), the City of Hayward (an SFPUC Wholesale Customer) , and the SFPUC to boost water supply reliability during emergencies. EBMUD and the SFPUC own these facilities jointly, while the City of Hayward maintains and operates them in coordination with EBMUD and the SFPUC.
• SFPUC-Valley Water Intertie: The SFPUC and Valley Water maintain a 40-MGD intertie between their two systems at Milpitas to exchange water during emergencies and planned maintenance (as mentioned in Section 10.3). The intertie has been used on several occasions during maintenance of Valley Water’s system.
2025 Water Shortage Contingency Plan for the City and County of San Francisco | 37 • South Bay Aqueduct Intertie: An intertie connecting the South Bay Aqueduct and the SFPUC’s San Antonio Reservoir that the SFPUC used in 1991 -1992 for a two -year water transfer. The SFPUC may upgrade this intertie to receive State Water Project water in the event of a future emergency.

The WSIP also includes projects related to standby power facilities at various locations. These projects provide standby electrical power at six critical facilities to keep them in operation during power outages and other emergency situations. Permanent engine generators are located at four locations (San Pedro Valve Lot, Millbrae Facility, Alameda West, and Harry Tracy Water Treatment Plant), while hookups for portable engine generators are at two locations (San Antonio Reservoir and Calaveras Reservoir).

The City also has a Hazards and Climate Resilience Plan, which was last updated in July 2025, see www.onesanfrancisco.org/hazards-and-climate-resilience-plan. This plan is a roadmap to minimize the impacts of natural hazards and climate change on buildings, infrastructure, and communities. The plan also serves as San Francisco’s Local Hazard Mitigation Plan, which the City updates every five years to include the latest understanding of natural hazards and climate change impacts, local risks, and community priorities. Examples of hazards analyzed in the plan include dam or reservoir failure, flooding, drought, and wildfire.

SECTION 11 WSCP REFINEMENT PROCEDURES
The SFPUC considers the WSCP a dynamic tool that will be subject to regular refinement as needed to ensure shortage response actions are effective and produce the desired results. If planned shortage response actions are implemented in the future, the SFPUC will conduct an evaluation of their effectiveness using the monitoring and reporting described in Section 9 and incorporate edits as needed to the WSCP.

SECTION 12 PLAN ADOPTION, SUBMITTAL, AND AVAILABILITY
The SFPUC has informed all cities or counties within which the SFPUC provides water supplies of its intent to update the WSCP. In addition, the SFPUC made this WSCP available for public review within 30 days of the SFPUC Commission public hearing by posting an electronic copy on the SFPUC website at www.sfpuc.gov/uwmp.

The SFPUC prepared this 2025 WSCP and presented it to the SFPUC Commission for adoption. A copy of the SFPUC resolution adopting this 2025 WSCP is provided in Appendix D. Within 30 days of SFPUC Commission adoption, the SFPUC will submit the adopted 2025 WSCP electronically to DWR via its online submittal tool (WUEdata portal), submit the plan on a compact disk mailed to the California State Library, email an electronic copy to cities and counties within which the SFPUC provides water supplies, and upload an electronic copy to the SFPUC website at www.sfpuc.gov/uwmp.
2025 WATER SHORTAGE CONTINGENCY PLAN

FOR THE CITY AND COUNTY OF SAN FRANCISCO
June 2026
Prepared by: The San Francisco Public Utilities Commission

2025 WATER SHORTAGE CONTINGENCY PLAN

FOR THE CITY AND COUNTY OF SAN FRANCISCO

APPENDICES
June 2026
Prepared by: The San Francisco Public Utilities Commission

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Appendix A
Summary of San Francisco’s Response to
1987-1992 Drought Experience

JUNE 2026

WATER SHORTAGE CONTINGENCY PLAN
for the City and County of San Francisco

Prepared by the San Francisco Public Utilities Commission

Summary of San Francisco’s Response to 1987-92
Drought Experience
Background:

The 1987-92 six year drought provides an example of how the near -term drought management process works in times when the operational capabilities of Hetch Hetchy and other water supplies available to the SFPUC are taxed to a point that forces drastic actions to avoid running out of water. By the sixth year of that drought period, many of the programs and actions identified in San Francisco’s current Retail W ater Shortage Allocation Plan (adopted in December 2001) had been implemented. The following describes some of the major actions that occurred.

Demand Reductions:

The extended drought forced San Francisco to adopt a mandatory rationing program, enforced by stiff excess use charges and the threat of shut -off for continued violations of water use prohibitions. Mandatory rationing was in effect May of 1988 through May of 1989, re-instituted in May of 1990, and continued until March of 1993. A Water Shortage Emergency Resolution was passed by the SFPUC on April 28, 1988 declaring these rationing periods (Resolution No. 88-0155).

The SFPUC’s water rationing program was one of the toughest in the state and the most stringent imposed by any major urban water supply agency. Although the specifics of the program varied over time, the basic outline of the mandatory rationing program was to achieve a 25 percent reduction to 1987 (pre -drought) consumption (system - wide), with water allocations set on an account-by-account basis.

To provide a strong incentive for customers to use no more water than their allotment, the SFPUC adopted a rate structure that incorporated excess use charges. Any customer that used less water than its allotment was charged the normal rate per unit of wat er consumption, while any customer who used more than its allotment was charged a multiple of the normal rate for every unit of consumption above its allotment. As of January 1, 1992 (the last year of the rationing program), the rate structure shown in the table below applied to SFPUC customers.

Excess Use Charges
If Water Consumption Is
(Over Allotment)
Excess Use Charge Will Be
(Times Normal Rate)
Up to 10% 2

10.01 - 20% 8

20.01% or over 10
In the event that water was used in excess of the customer's specified allotment, the SFPUC could, after one written warning, install a flow restrictor on the customer's service line. The charge to install and remove the restricting device is shown in the table below. If a customer continued to consume water in excess of its allotment, the SFPUC had the authority to discontinue the customer’s water service and require the customer to bear the cost for the re - connection of water service.