Daly City City Council
January 22, 2024

2. SFPUC Common Language

change. As the region faces future challenges – both known and unknown – the SFPUC is considering this suite of diverse non-traditional supplies and leveraging regional partnerships to meet Retail and Wholesale Customer needs through 2045.

The SWRCB has stated that it intends to implement the Bay-Delta Plan Amendment on the Tuolumne River by the year 2022, assuming all required approvals are obtained by that time.

But implementation of the Plan Amendment is uncertain for multiple reasons.

First, since adoption of the Bay-Delta Plan Amendment, over a dozen lawsuits have been filed in both state and federal courts, challenging the SWRCB’s adoption of the Bay-Delta Plan Amendment, including a legal challenge filed by the federal government, at the request of the U.S. Department of Interior, Bureau of Reclamation. This litigation is in the early stages and there have been no dispositive court rulings as of this date.

Second, the Bay-Delta Plan Amendment is not self-implementing and does not automatically allocate responsibility for meeting its new flow requirements to the SFPUC or any other water rights holders. Rather, the Bay-Delta Plan Amendment merely provides a regulatory framework for flow allocation, which must be accomplished by other regulatory and/or adjudicatory proceedings, such as a comprehensive water rights adjudication or, in the case of the Tuolumne River, may be implemented through the water quality certification process set forth in section 401 of the Clean Water Act as part of the Federal Energy Regulatory Commission’s licensing proceedings for the Don Pedro and La Grange hydroelectric projects. It is currently unclear when the license amendment process is expected to be completed. This process and the other regulatory and/or adjudicatory proceedings would likely face legal challenges and have lengthy timelines, and quite possibly could result in a different assignment of flow responsibility (and therefore a different water supply impact on the SFPUC).

Third, in recognition of the obstacles to implementation of the Bay-Delta Plan Amendment, the SWRCB Resolution No. 2018-0059 adopting the Bay-Delta Plan Amendment directed staff to help complete a “Delta watershed-wide agreement, including potential flow measures for the Tuolumne River” by March 1, 2019, and to incorporate such agreements as an “alternative” for a future amendment to the Bay-Delta Plan to be presented to the SWRCB “as early as possible after December 1, 2019.” In accordance with the SWRCB’s instruction, on March 1, 2019, SFPUC, in partnership with other key stakeholders, submitted a proposed project description for the Tuolumne River that could be the basis for a voluntary substitute agreement with the SWRCB (“March 1st Proposed Voluntary Agreement”). On March 26, 2019, the Commission adopted Resolution No. 19-0057 to support the SFPUC’s participation in the Voluntary Agreement negotiation process. To date, those negotiations are ongoing under the California Natural Resources Agency and the leadership of the Newsom administration.3 Water Supply – All Year Types
The SFPUC historically has met demand in its service area in all year types from its watersheds, which consist of:
 Tuolumne River watershed
 Alameda Creek watershed
3 California Natural Resources Agency, “Voluntary Agreements to Improve Habitat and Flow in the Delta and its Watersheds,” available at https://files.resources.ca.gov/voluntary-agreements/.

2. SFPUC Common Language

 San Mateo County watersheds
In general, 85 percent of the supply comes from the Tuolumne River through Hetch Hetchy Reservoir and the remaining 15 percent comes from the local watersheds through the San Antonio, Calaveras, Crystal Springs, Pilarcitos and San Andreas Reservoirs. The adopted WSIP retains this mix of water supply for all year types.

WSIP Dry Year Water Supply Projects
The WSIP authorized the SFPUC to undertake a number of water supply projects to meet dryyear demands with no greater than 20 percent system-wide rationing in any one year. Those projects include the following:
 Calaveras Dam Replacement Project
Calaveras Dam is located near a seismically active fault zone and was determined to be seismically vulnerable. To address this vulnerability, the SFPUC constructed a new dam of equal height downstream of the existing dam. Construction on the project occurred between 2011 and July 2019. The SFPUC began impounding water behind the new dam in accordance with California Division of Safety of Dams (DSOD) guidance in the winter of 2018/2019.
 Alameda Creek Recapture Project
As a part of the regulatory requirements for future operations of Calaveras Reservoir, the SFPUC must implement bypass and instream flow schedules for Alameda Creek. The Alameda Creek Recapture Project will recapture a portion of the water system yield lost due to the instream flow releases at Calaveras Reservoir or bypassed around the Alameda Creek Diversion Dam and return this yield to the RWS through facilities in the Sunol Valley. Water that naturally infiltrates from Alameda Creek will be recaptured into an existing quarry pond known as SMP (Surface Mining Permit)-24 Pond F2. The project will be designed to allow the recaptured water to be pumped to the Sunol Valley Water Treatment Plant or to San Antonio Reservoir. Construction of this project will occur from spring 2021 to fall 2022.
 Lower Crystal Springs Dam Improvements
The Lower Crystal Springs Dam (LCSD) Improvements were substantially completed in November 2011. The joint San Mateo County/SFPUC Bridge Replacement Project to replace the bridge across the dam was completed in January 2019. A WSIP follow up project to modify the LCSD Stilling Basin for fish habitat and upgrade the fish water release and other valves started in April 2019. While the main improvements to the dam have been completed, environmental permitting issues for reservoir operation remain significant. While the reservoir elevation was lowered due to DSOD restrictions, the habitat for the Fountain Thistle, an endangered plant, followed the lowered reservoir elevation. Raising the reservoir elevation now requires that new plant populations be restored incrementally before the reservoir elevation is raised. The result is that it may be several years before pre-project water storage volumes can be restored.  Regional Groundwater Storage and Recovery Project
The Groundwater Storage and Recovery (GSR) Project is a strategic partnership between SFPUC and three San Mateo County agencies – the California Water Service Company (serving South San Francisco and Colma), the City of Daly City, and the City

2. SFPUC Common Language

of San Bruno – to conjunctively operate the south Westside Groundwater Basin. The project sustainably manages groundwater and surface water resources in a way that provides supplies during times of drought. During years of normal or heavy rainfall, the project would provide additional surface water to the partner agencies in San Mateo County in lieu of groundwater pumping. Over time, reduced pumping creates water storage through natural recharge of up to 20 billion gallons of new water supply available during dry years.

The project’s Final Environmental Impact Report was certified in August 2014, and the project also received Commission approval that month. Phase 1 of this project consists of construction of thirteen well sites and is over 99 percent complete. Phase 2 of this project consists of completing construction of the well station at the South San Francisco Main site and some carryover work that has not been completed from Phase 1. Phase 2 design work began in December 2019.
 2 mgd Dry-year Water Transfer
In 2012, the dry-year transfer was proposed between the Modesto Irrigation District and the SFPUC. Negotiations were terminated because an agreement could not be reached. Subsequently, the SFPUC had discussions with the Oakdale Irrigation District for a one-year transfer agreement with the SFPUC for 2 mgd (2,240 acre-feet). No progress towards agreement on a transfer was made in 2019, but the irrigation districts recognize SFPUC’s continued interest and SFPUC will continue to pursue transfers.

In order to achieve its target of meeting at least 80 percent of its customer demand during droughts with a system demand of 265 mgd, the SFPUC must successfully implement the dryyear water supply projects included in the WSIP.

Furthermore, the permitting obligations for the Calaveras Dam Replacement Project and the Lower Crystal Springs Dam Improvements include a combined commitment of 12.8 mgd for instream flows on average. When this is reduced for an assumed Alameda Creek Recapture Project recovery of 9.3 mgd, the net loss of water supply is 3.5 mgd.

Alternative Water Supply Planning Program
The SFPUC is increasing and accelerating its efforts to acquire additional water supplies and explore other projects that would increase overall water supply resilience through the Alternative Water Supply Planning Program. The drivers for the program include: (1) the adoption of the Bay-Delta Plan Amendment and the resulting potential limitations to RWS supply during dry years, (2) the net supply shortfall following the implementation of WSIP, (3) San Francisco’s perpetual obligation to supply 184 MGD to the Wholesale Customers, (4) adopted Level of Service Goals to limit rationing to no more than 20 percent system-wide during droughts, and (5) the potential need to identify water supplies that would be required to offer permanent status to interruptible customers. Developing additional supplies through this program would reduce water supply shortfalls and reduce rationing associated with such shortfalls. The planning priorities guiding the framework of the Alternative Water Supply Planning Program are as follows:

1. Offset instream flow needs and meet regulatory requirements

2. Meet existing obligations to existing permanent customers

3. Make interruptible customers permanent

4. Meet increased demands of existing and interruptible customers

2. SFPUC Common Language

In conjunction with these planning priorities, the SFPUC considers how the program fits within the LOS Goals and Objectives related to water supply and sustainability when considering new water supply opportunities. The key LOS Goals and Objectives relevant to this effort can be summarized as:
 Meet dry-year delivery needs while limiting rationing to a maximum of 20 percent system-wide reduction in water service during extended droughts;  Diversify water supply options during non-drought and drought periods;  Improve use of new water sources and drought management, including groundwater, recycled water, conservation, and transfers;
 Meet, at a minimum, all current and anticipated legal requirements for protection of fish and wildlife habitat;
 Maintain operational flexibility (although this LOS Goal was not intended explicitly for the addition of new supplies, it is applicate here).

Together, the planning priorities and LOS Goals and Objectives provide a lens through which the SFPUC considers water supply options and opportunities to meet all foreseeable water supply needs.

In addition to the Daly City Recycled Water Expansion project4, which was a potential project identified in the 2015 UWMP and had committed funding at that time, the SFPUC has taken action to fund the study of potential additional water supply projects. Capital projects under consideration to develop additional water supplies include surface water storage expansion, recycled water expansion, water transfers, desalination, and potable reuse. A more detailed list and descriptions of these efforts are provided below.

The capital projects that are under consideration would be costly and are still in the early feasibility or conceptual planning stages. Because these water supply projects would take 10 to 30 years to implement, and because required environmental permitting negotiations may reduce the amount of water that can be developed, the yield from these projects are not currently incorporated into SFPUC’s supply projections. State and federal grants and other financing opportunities would be pursued for eligible projects, to the extent feasible, to offset costs borne by ratepayers.
 Daly City Recycled Water Expansion (Regional, Normal- and Dry-Year Supply) This project can produce up to 3 mgd of tertiary recycled water during the irrigation season (~7 months). On an average annual basis, this is equivalent to 1.25 mgd or 1,400 acre-feet per year. The project is envisioned to provide recycled water to 13 cemeteries and other smaller irrigation customers, offsetting existing groundwater pumping from the South Westside Groundwater Basin; this will free up groundwater, enhancing the reliability of the Basin. The project is a regional partnership between the SFPUC and Daly City. The irrigation customers are located largely within California Water Service's (Cal Water's) service area. RWS customers will benefit from the increased reliability of the South Westside Basin for additional drinking water supply during droughts. In this way, this project supports the GSR Project, which is under construction.
4 While this potential project was identified in the 2015 UWMP, it has since been approved by Daly City following environmental review and has a higher likelihood of being implemented.

2. SFPUC Common Language

 ACWD-USD Purified Water Partnership (Regional, Normal- and Dry-Year Supply) This project could provide a new purified water supply utilizing Union Sanitary District's (USD) treated wastewater. Purified water produced by advanced water treatment at USD could be transmitted to the Quarry Lakes Groundwater Recharge Area to supplement recharge into the Niles Cone Groundwater Basin or put to other uses in Alameda County Water District’s (ACWD) service area. With the additional water supply to ACWD, an in-lieu exchange with the SFPUC would result in more water left in the RWS. Additional water supply could also be directly transmitted to the SFPUC through a new intertie between ACWD and the SFPUC.
 Crystal Springs Purified Water (Regional, Normal- and Dry-Year Supply) The Crystal Springs Purified Water (PREP) Project is a purified water project that could provide 6-12 mgd of water supply through reservoir water augmentation at Crystal Springs Reservoir, which is a facility of the RWS. Treated wastewater from Silicon Valley Clean Water (SVCW) and/or the City of San Mateo would go through an advanced water treatment plant to produce purified water that meets state and federal drinking water quality standards. The purified water would then be transmitted 10-20 miles (depending on the alignment) to Crystal Springs Reservoir, blended with regional surface water supplies and treated again at Harry Tracy Water Treatment Plant. Project partners include the SFPUC, BAWSCA, SVCW, CalWater, Redwood City, Foster City, and the City of San Mateo. Partner agencies are contributing financial and staff resources towards the work effort.
 Los Vaqueros Reservoir Expansion (Regional, Dry Year Supply) The Los Vaqueros Reservoir Expansion (LVE) Project is a storage project that will enlarge the existing reservoir located in northeastern Contra Costa County from 160,000 acre-feet to 275,000 acre-feet. While the existing reservoir is owned and operated by the Contra Costa Water District (CCWD), the expansion will have regional benefits and will be managed by a Joint Powers Authority (JPA) that will be set up prior to construction. Meanwhile, CCWD is leading the planning, design and environmental review efforts. CCWD’s Board certified the EIS/EIR and approved the LVE Project on May 13, 2020. The additional storage capacity from the LVE Project would provide a dry year water supply benefit to the SFPUC. BAWSCA is working in concert with the SFPUC to support their work effort on the LVE project.
o Conveyance Alternatives: The SFPUC is considering two main pathways to move water from storage in a prospective LVE Project to the SFPUC’s service area, either directly to RWS facilities or indirectly via an exchange with partner agencies. The SFPUC is evaluating potential alignments for conveyance. o Bay Area Regional Reliability Shared Water Access Program (BARR SWAP): As part of the BARR Partnership, a consortium of 8 Bay Area water utilities (including ACWD, BAWSCA, CCWD, EBMUD, Marin Municipal Water District (MMWD), SFPUC, Valley Water, and Zone 7 Water Agency) are exploring opportunities to move water across the region as efficiently as possible, particularly during times of drought and emergencies. The BARR agencies are proposing two separate pilot projects in 2020-2021 through the Shared Water Access Program (SWAP) to test conveyance pathways and identify potential hurdles to better prepare for sharing water during a future drought or emergency.

A strategy report identifying opportunities and considerations will accompany these pilot transfers and will be completed in 2021.

2. SFPUC Common Language

 Bay Area Brackish Water Desalination (Regional, Normal- and Dry-Year Supply) The Bay Area Brackish Water Desalination (Regional Desalination) Project is a partnership between CCWD, the SFPUC, Valley Water, and Zone 7 Water Agency.

East Bay Municipal Utilities District (EBMUD) and ACWD may also participate in the project. The project could provide a new drinking water supply to the region by treating brackish water from CCWD's existing Mallard Slough intake in Contra Costa County.

While this project has independent utility as a water supply project, for the current planning effort the SFPUC is considering it as a source of supply for storage in LVE.

While the allocations remain to be determined among partners, the SFPUC is considering a water supply benefit of between 5 and 15 mgd during drought conditions when combined with storage at LVE.
 Calaveras Reservoir Expansion (Regional, Dry Year Supply) Calaveras Reservoir would be expanded to create 289,000 AF additional capacity to store excess Regional Water System supplies or other source water in wet and normal years. In addition to reservoir enlargement, the project would involve infrastructure to pump water to the reservoir, such as pump stations and transmission facilities.  Groundwater Banking
Groundwater banking in the Modesto Irrigation District (MID) and Turlock Irrigation District (TID) service areas could be used to provide some additional water supply to meet instream releases in dry years reducing water supply impacts to the SFPUC service area. For example, additional surface water could be provided to irrigators in wet years, which would offset the use of groundwater, thereby allowing the groundwater to remain in the basin rather than be consumptively used. The groundwater that remains in the basin can then be used in a subsequent dry year for irrigation, freeing up surface water that would have otherwise been delivered to irrigators to meet instream flow requirements.

A feasibility study of this option is included in the proposed Tuolumne River Voluntary Agreement. Progress on this potential water supply option will depend on the negotiations of the Voluntary Agreement.
 Inter-Basin Collaborations
Inter-Basin Collaborations could provide net water supply benefits in dry years by sharing responsibility for in-stream flows in the San Joaquin River and Delta more broadly among several tributary reservoir systems. One mechanism by which this could be accomplished would be to establish a partnership between interests on the Tuolumne River and those on the Stanislaus River, which would allow responsibility for streamflow to be assigned variably based on the annual hydrology.

As is the case with Groundwater Banking, feasibility of this option is included in the proposed Tuolumne River Voluntary Agreement.

If all the projects identified through the current planning process can be implemented, there would still be a supply shortfall to meet projected needs. Furthermore, each of the supply options being considered has its own inherent challenges and uncertainties that may affect the SFPUC’s ability to implement it.

Given the limited availability of water supply alternatives - unless the supply risks are significantly reduced or our needs change significantly - the SFPUC will continue to plan,

2. SFPUC Common Language

develop and implement all project opportunities that can help bridge the anticipated water supply gaps during droughts. In 2019, the SFPUC completed a survey among water and wastewater agencies within the service area to identify additional opportunities for purified water. Such opportunities remain limited, but the SFPUC continues to pursue all possibilities.

Projected SFPUC Regional Water System Supply Reliability The SFPUC will provide tables presenting the projected RWS supply reliability under normal, single dry year, and multiple dry year scenarios.

Climate Change
The issue of climate change has become an important factor in water resources planning in the State, and is frequently considered in urban water management planning processes, though the extent and precise effects of climate change remain uncertain. There is convincing evidence that increasing concentrations of greenhouse gasses have caused and will continue to cause a rise in temperatures around the world, which will result in a wide range of changes in climate patterns. Moreover, observational data show that a warming trend occurred during the latter part of the 20th century and virtually all projections indicate this will continue through the 21st century. These changes will have a direct effect on water resources in California, and numerous studies have been conducted to determine the potential impacts to water resources. Based on these studies, climate change could result in the following types of water resource impacts, including impacts on the watersheds in the Bay Area:
 Reductions in the average annual snowpack due to a rise in the snowline and a shallower snowpack in the low and medium elevation zones, such as in the Tuolumne River basin, and a shift in snowmelt runoff to earlier in the year;  Changes in the timing, annual average, intensity and variability of precipitation, and an increased amount of precipitation falling as rain rather than snow;  Long-term changes in watershed vegetation and increased incidence of wildfires that could affect water quality and quantity;
 Sea level rise and an increase in saltwater intrusion;  Increased water temperatures with accompanying potential adverse effects on some fisheries and water quality;
 Increases in evaporation and concomitant increased irrigation need; and  Changes in urban and agricultural water demand.

Both the SFPUC and BAWSCA participated in the 2020 update of the Bay Area Integrated Regional Water Management Plan (BAIRWMP), which includes an assessment of the potential climate change vulnerabilities of the region’s water resources and identifies climate change adaptation strategies. In addition, the SFPUC continues to study the effect of climate change on the Regional Water System (RWS). These works are summarized below.

Bay Area Integrated Regional Water Management Plan
Climate change adaptation continues to be an overarching theme for the 2019 BAIRWMP update. As stated in the BAIRWMP, identification of watershed characteristics that could

2. SFPUC Common Language

potentially be vulnerable to future climate change is the first step in assessing vulnerabilities of water resources in the Bay Area Region (Region). Vulnerability is defined as the degree to which a system is exposed to, susceptible to, and able to cope with or adjust to, the adverse effects of climate change. A vulnerability assessment was conducted in accordance with the Department of Water Resources’ (DWR’s) Climate Change Handbook for Regional Water Planning and using the most current science available for the Region. The vulnerability assessment, summarized in the table below, provides the main water planning categories applicable to the Region and a general overview of the qualitative assessment of each category with respect to anticipated climate change impacts.

Summary of BAIRWMP Climate Change Vulnerability Assessment Vulnerability
Areas General Overview of Vulnerabilities
Water Demand Urban and Agricultural Water Demand – Changes to hydrology in the Region as a result of climate change could lead to changes in total water demand and use patterns. Increased irrigation (outdoor landscape or agricultural) is anticipated to occur with temperature rise, increased evaporative losses due to warmer temperature, and a longer growing season. Water treatment and distribution systems are most vulnerable to increases in maximum day demand.

Water Supply Imported Water – Imported water derived from the Sierra Nevada sources and Delta diversions provide 66 percent of the water resources available to the Region. Potential impacts on the availability of these sources resulting from climate change directly affect the amount of imported water supply delivered to the Region.

Regional Surface Water – Although future projections suggest that small changes in total annual precipitation over the Region will not change much, there may be changes to when precipitation occurs with reductions in the spring and more intense rainfall in the winter.

Regional Groundwater – Changes in local hydrology could affect natural recharge to the local groundwater aquifers and the quantity of groundwater that could be pumped sustainably over the long-term in some areas. Decreased inflow from more flashy or more intense runoff, increased evaporative losses and warmer and shorter winter seasons can alter natural recharge of groundwater. Salinity intrusion into coastal groundwater aquifers due to sea-level rise could interfere with local groundwater uses. Furthermore, additional reductions in imported water supplies would lead to less imported water available for managed recharge of local groundwater basins and potentially more groundwater pumping in lieu of imported water availability.

Water Quality Imported Water – For sources derived from the Delta, sea-level rise could result in increases in chloride and bromide (a disinfection byproduct (DBP) precursor that is also a component of sea water),

2. SFPUC Common Language

Vulnerability
Areas General Overview of Vulnerabilities
potentially requiring changes in treatment for drinking water. Increased temperature could result in an increase in algal blooms, taste and odor events, and a general increase in DBP formation
Regional Surface Water – Increased temperature could result in lower dissolved oxygen in streams and prolong thermocline stratification in lakes and reservoirs forming anoxic bottom conditions and algal blooms. Decrease in annual precipitation could result in higher concentrations of contaminants in streams during droughts or in association with flushing rain events. Increased wildfire risk and flashier or more intense storms could increase turbidity loads for water treatment.

Regional Groundwater – Sea-level rise could result in increases in chlorides and bromide for some coastal groundwater basins in the Region. Water quality changes in imported water used for recharge could also impact groundwater quality.

Sea-Level Rise Sea-level rise is additive to tidal range, storm surges, stream flows, and wind waves, which together will increase the potential for higher total water levels, overtopping, and erosion.

Much of the bay shoreline is comprised of low-lying diked baylands which are already vulnerable to flooding. In addition to rising mean sea level, continued subsidence due to tectonic activity will increase the rate of relative sea-level rise.

As sea-level rise increases, both the frequency and consequences of coastal storm events, and the cost of damage to the built and natural environment, will increase. Existing coastal armoring (including levees, breakwaters, and other structures) is likely to be insufficient to protect against projected sea-level rise. Crest elevations of structures will have to be raised or structures relocated to reduce hazards from higher total water levels and larger waves.

Flooding Climate change projections are not sensitive enough to assess localized flooding, but the general expectation is that more intense storms would occur thereby leading to more frequent, longer and deeper flooding.

Changes to precipitation regimes may increase flooding.

Elevated Bay elevations due to sea-level rise will increase backwater effects exacerbating the effect of fluvial floods and storm drain backwater flooding.

2. SFPUC Common Language

Vulnerability
Areas General Overview of Vulnerabilities
Ecosystem and
Habitat
Changes in the seasonal patterns of temperature, precipitation, and fire due to climate change can dramatically alter ecosystems that provide habitats for California’s native species. These impacts can result in species loss, increased invasive species ranges, loss of ecosystem functions, and changes in vegetation growing ranges.

Reduced rain and changes in the seasonal distribution of rainfall may alter timing of low flows in streams and rivers, which in turn would have consequences for aquatic ecosystems. Changes in rainfall patterns and air temperature may affect water temperatures, potentially affecting coldwater aquatic species.

Bay Area ecosystems and habitat provide important ecosystem services, such as: carbon storage, enhanced water supply and quality, flood protection, food and fiber production. Climate change is expected to substantially change several of these services.

The region provides substantial aquatic and habitat-related recreational opportunities, including: fishing, wildlife viewing, and wine industry tourism (a significant asset to the region) that may be at risk due to climate change effects.

Hydropower Currently, several agencies in the Region produce or rely on hydropower produced outside of the Region for a portion of their power needs. As the hydropower is produced in the Sierra, there may be changes in the future in the timing and amount of energy produced due to changes in the timing and amount of runoff as a result of climate change.

Some hydropower is also produced within the region and could also be affected by changes in the timing and amount of runoff.

Source: 2019 Bay Area Integrated Regional Water Management Plan (BAIRWMP), Table 16-3.

SFPUC Climate Change Studies
The SFPUC views assessment of the effects of climate change as an ongoing project requiring regular updating to reflect improvements in climate science, atmospheric/ocean modeling, and human response to the threat of greenhouse gas emissions. Climate change research by the SFPUC began in 2009 and continues to be refined. In its 2012 report “Sensitivity of Upper Tuolumne River Flow to Climate Change Scenarios,” the SFPUC assessed the sensitivity of runoff into Hetch Hetchy Reservoir to a range of changes in temperature and precipitation due to climate change. Key conclusions from the report include the following:
 With differing increases in temperature alone, the median annual runoff at Hetch Hetchy would decrease by 0.7-2.1% from present-day conditions by 2040 and by 2.6-10.2% from

2. SFPUC Common Language

present-day by 2100. Adding differing decreases in precipitation on top of temperature increases, the median annual runoff at Hetch Hetchy would decrease by 7.6-8.6% from present-day conditions by 2040 and by 24.7-29.4% from present-day conditions by 2100.  In critically dry years, these reductions in annual runoff at Hetch Hetchy would be significantly greater, with runoff decreasing up to 46.5% from present day conditions by 2100 utilizing the same climate change scenarios.
 In addition to the total change in runoff, there will be a shift in the annual distribution of runoff. Winter and early spring runoff would increase and late spring and summer runoff would decrease.
 Under all scenarios, snow accumulation would be reduced and snow would melt earlier in the spring, with significant reductions in maximum peak snow water equivalent under most scenarios.

Currently, the SFPUC is conducting a comprehensive assessment of the potential effects of climate change on water supply using a wide range of plausible increases in temperature and changes in precipitation to address the wide uncertainty in climate projections over the planning horizon 2020 to 2070. There are many uncertain factors such as climate change, changing regulations, water quality, growth and economic cycles that may create vulnerabilities for the Regional Water System’s ability to meet levels of service. The uncertainties associated with the degree to which these factors will occur and how much risk they present to the water system is difficult to predict, but nonetheless they need to be considered in SFPUC planning. To address this planning challenge, the project uses a vulnerability-based planning approach to explore a range of future conditions to identify vulnerabilities, assess the risks associated with these vulnerabilities that could lead to developing an adaptation plan that is flexible and robust to a wide range of future outcomes.

3. UWMPs: Procedures, Legal Updates and Best Practices
155 Bovet Road, Suite 650,  San Mateo, CA 94402  ph 650 349 3000  fx 650349 8395  www.bawsca.org

February 2, 2021
TO: BAWSCA Member Agencies
FROM: Danielle McPherson, Tom Francis
SUBJECT: Urban Water Management Plans: Procedures, Legal Updates and Best Practices This memorandum provides agencies that are updating their Urban Water Management Plans (UWMPs) with a general overview of the process, new legal requirements, and best practices for updating a UWMP pursuant to the Urban Water Management Planning Act (Act) (Wat. Code, §§ 10610 et seq.). Please note that this memorandum offers a high-level summary. More detailed and comprehensive guidance is available in the California Department of Water Resources (DWR) Draft Urban Water Management Plan Guidebook 2020 (Draft Guidebook).1 Agencies are also encouraged to consult with their legal counsel to ensure compliance with all applicable procedural and substantive requirements.

1. Procedural Overview and Timeline
Each urban water supplier serving more than 3,000 acre-feet per year or 3,000 customers must update its UWMP to include current and new information at least once every five years on or before July 1, in years ending in six and one, in accordance with the Act. (Wat. Code, § 10620, 10621). Under SB 606 (effective January 1, 2019), every urban water supplier must also prepare and adopt a Water Shortage Contingency Plan (WSCP) as part of its UWMP consisting of certain elements described in Water Code Section 10632. This new mandate replaces the water shortage contingency analysis under former UWMP law. Agencies will generally follow the same notice and public hearing requirements for both UWMPs and WSCPs. The timeline below shows an example coordinated notice and submittal process.

Example Notice and Submittal Timeline (Key Dates in Red) 1 Draft UWMP Guidebook 2020: https://water.ca.gov/-/media/DWR-Website/Web-Pages/Programs/Water-Use-AndEfficiency/Urban-Water-Use-Efficiency/Urban-Water-Management-Plans/Draft-2020-UWMPGuidebook.pdf?la=en&hash=266FE747760481ACF779F0F2AAEE615314693456 Release Draft
UWMP and
Draft WSCP for
Public Review &
Comment
Legal Notice of
Public Hearing
60 days prior to
hearing
Public Input
Hearing
Notice of Adoption
Hearing 60 days
prior to hearing
Adoption
Hearing
Submit Adopted
UWMP and
WSCP to DWR,
State Library, &
Cities/Counties
Make Submitted
UWMP and
WSCP Publicly
Available
Provide Reliability
Assessment &
Drought Risk
Assessment to
Cities/Counties
Mar
2021
Apr
2021
May
2021
Jun
2021
Jul 1,
2021
Aug 1,
2021
Aug 30,
2021

3. UWMPs: Procedures, Legal Updates and Best Practices

a) Legal Notice of Public Hearing
Each urban water supplier must "encourage the active involvement of diverse social, cultural, and economic elements of the population within the service area prior to and during the preparation" of both its UWMP and its WSCP (Wat. Code, § 10642). Prior to adopting a UWMP or WSCP, an agency must make its UWMP and WSCP available for public inspection and hold a properly noticed public hearing in accordance with Section 10642 of the Water Code.

Notice of the time and place of the public hearing must be: (1) published within the water supplier's jurisdiction pursuant to Government Code Section 6066;2 (2) provided pursuant to the DymallyAlatorre Bilingual Services Act (Government Code Section 7290 et seq.);3 (3) provided to any city or county within which the supplier provides water supplies; and (4) provided "within its service area," if the water supplier is privately owned (Id.). If your agency is a city and doesn’t supply water outside your jurisdictional boundaries, you should send the notice to the county in which you are located. While not expressly required by the Water Code, BAWSCA and DWR also recommend that the notice of public hearing include: (1) where the UWMP and WSCP can be viewed, (2) the UWMP revision schedule, and (3) and who at your agency to contact for questions.

The notice of the public hearing for the UWMP must be published and circulated at least 60 days before the public hearing on the UWMP (Wat. Code, § 10621(b)). To streamline the process, BAWSCA recommends consolidating the notices and public hearings for both the UWMP and the WSCP, as illustrated in the timeline above.

BAWSCA recommends agencies issue notice of the public hearing on the UWMP and WSCP as soon as the draft plans are available. For your reference, a Sample Notice to of Public Hearing, prepared by Hanson Bridgett, is enclosed as Attachment 1. Consult with your legal counsel to make sure your notice meets the requirements of Government Code Section 10642. Agencies may use Table 10-1. Retail. Notification to Cities and Counties, shown in Section 10.2.1.3 and Appendix E of the Draft Guidebook to verify noticing requirements were met.

Agencies must “coordinate” the preparation of their UWMP with "other appropriate agencies in the area, including other water suppliers that share a common source, water management agencies, and relevant public agencies, to the extent practicable" (Wat. Code, § 10620(d)(3)). To satisfy this requirement, BAWSCA recommends that you notify BAWSCA,4 the sanitation agency that serves your area, and (for agencies in Santa Clara County) the Santa Clara Valley Water District that you are updating your UWMP and WSCP, in addition to all cities or counties within which you supply water. Chapter 2.6.2 of the Draft Guidebook provides a non-comprehensive list of agencies and organizations DWR recommends water suppliers coordinate with. You may identify other agencies that could be considered “appropriate” or “relevant” to whom the notice should also be sent. A sample letter to other public agencies is enclosed as Attachment 2. 2 Gov. Code, § 6066 provides: "Publication of notice pursuant to this section shall be once a week for two successive weeks. Two publications in a newspaper published once a week or oftener, with at least five days intervening between the respective publication dates not counting such publication dates, are sufficient. The period of notice commences upon the first day of publication and terminates at the end of the fourteenth day, including therein the first day."
3 This is new legal requirement was added by SB 606. Consult with your legal counsel to determine if any additional information must be included in the notice to comply with the Dymally-Alatorre Bilingual Services Act. 4 Sending the notice to BAWSCA will do double duty because BAWSCA is both (1) a “water management agency” and (2) the vehicle through which you can “coordinate” preparation of your Plan with “other water suppliers that share a common source.”

3. UWMPs: Procedures, Legal Updates and Best Practices

b) Additional Efforts to Encourage Public Participation You may further encourage diverse social, cultural, and economic elements of the population within your service area to be involved in the development of your updated UWMP and WSCP by publishing and/or displaying an advertisement (not a “legal” notice) in a newspaper of general circulation in your service area (see Wat. Code, § 10642). To assist your agency in providing such notice, a sample advertisement, also drafted by Hanson Bridgett, is enclosed as Attachment

3. Note that this advertisement is different than the legal notice of public hearing. In light of the Act’s requirement that public participation is to be encouraged "prior to and during the preparation of both the plan and the water shortage contingency plan," BAWSCA suggests circulating this advertisement as soon as possible (Id.).

This advertisement should by no means be considered the only way to invite your community’s participation. Other methods could include notices sent with water bills, press releases to local media, ads in community/neighborhood newspapers, and posts on Nextdoor or other social media platforms. BAWSCA recommends you keep a copy of the notices, the advertisements, and any other public outreach materials you distribute.
c) Noticed Public Hearing(s)
The UWMP and WSCP must be adopted as prepared or as modified after the public hearing(s) (Wat. Code, § 10642). The public hearing may take place at the same meeting as the adoption hearing of your governing board, but the final version adopted must include any modifications made as a result of the public hearing. If you choose to combine these meetings, the agenda must include the public hearing as a separate agenda item that occurs before adoption. If you chose to hold the public input hearing and adoption hearing at separate meetings, both hearings must be properly noticed in accordance with the requirements discussed above.

DWR recommends including a copy of the adoption resolution in the UWMP and WSCP. d) Transmittal of Adopted Plan: Timing, Format, and Submittal Instructions Within 30 days after adoption, you must send a copy of the adopted UWMP to DWR, the California State Library, and any city or county within which your agency supplies water (Wat. Code, § 10644(a)(1)). Water suppliers must submit their adopted 2020 UWMP to DWR by July 1, 2021 (Wat. Code, § 10621(f)). Water suppliers must submit their WSCP to the DWR no later than 30 days of adoption (Wat. Code, § 10644(b)).

UWMPs and WSCPs must be submitted to DWR electronically and must include any standardized forms, tables, or displays specified by the department (Wat. Code, § 10644(a)(2)). Draft versions of the standardized forms and tables can be viewed in Appendix E of the Draft Guidebook and Excel versions can be downloaded from the DWR SharePoint site.5 DWR is updating the online submittal tool (i.e., WUE Data Portal)6 for the UWMPs and anticipates making the standardized forms and tables and the WUE Data Portal accessible in the Spring of 2021.

The Draft Guidebook provides that it is permissible to submit your adopted UWMP to any city or county within which your agency supplies water in electronic format. You must submit a CD or hardcopy of your adopted UWMP to the California State Library at:
5 Email [email protected] to gain access to the DWR SharePoint site. 6 WUEdata Portal: https://wuedata.water.ca.gov/secure/login_auth.asp?msg=inactivity&referer=/secure/Default.asp?

3. UWMPs: Procedures, Legal Updates and Best Practices

California State Library
Government Publications Section
Attention: Coordinator, Urban Water Management Plans
P.O. Box 942837
Sacramento, CA 94237-0001
e) Public Access to Adopted UWMP and WSCP
You must make the UWMP and WSCP available for public review during normal business hours no later than 30 days after filing copies of the adopted UWMP and WSCP with the DWR (Wat.

Code, § 10645).

2. Water Shortage Contingency Plans
In 2018, the Legislature modified the Water Code to require a WSCP with specific elements. The WSCP is a document that provides a supplier with an action plan for a drought or catastrophic water supply shortage. Although the new requirements are more prescriptive than previous versions, many of these elements have long been included in WSCPs, other sections of UWMPs, or as part of a supplier’s standard procedures and response actions. Many of these actions were implemented by suppliers during the last drought, to successfully meet changing local water supply challenges. The WSCP will also have statewide utility for DWR, the State Water Board, and the Legislature in addressing extreme drought conditions or statewide calamities that impact water supply availability (Water Code section 10632.1).

The Water Code was also amended to require six standard water shortage levels in your WSCP (Water Code 10632(a)(3)). The change was intended to provide consistency across agencies.

However, Water Code Section 10632 (a)(3)(B) authorizes suppliers to continue using their own water shortage levels that may have been included in past WSCPs. If your agency chooses to continue using existing water shortage levels, you must include a “crosswalk” that clearly translates your agencies water shortage levels to those mandated by the statute. An example “crosswalk” is provided in the Draft Guidebook.

Substantive and procedural WSCP requirements are included Water Code 10632 and Chapter 8 of the Draft Guidebook.

3. Changes to the Water Code since Adoption of 2015 Plans The following is a non-exhaustive list of new requirements adopted since 2015 that focus on specific information about BAWSCA water supply and conservation efforts. A full list of new requirements is provided at the beginning of each chapter in the Draft Guidebook. a) Lay Description
The Legislature added a new statutory requirement for water suppliers to include a lay description of the fundamental determinations of the UWMP, especially regarding water service reliability, challenges ahead, and strategies for managing reliability risks. The lay description could be viewed as a go-to synopsis for new staff, new members of the agency's legislative body, customers, and the media, and it can ensure a consistent representation of the supplier’s detailed analysis (Wat. Code, § 10630.5).

3. UWMPs: Procedures, Legal Updates and Best Practices

How and where you include the lay description in your UWMP is up to you. For example, you may include the lay description in the introduction to your UWMP or within each chapter.

BAWSCA recommends including the lay description in both the introduction and in each chapter so that each section is easily understood and accessible to the public. BAWSCA also recommends that the lay description be written at the eighth-grade reading level. b) Coordination with other Agencies and Land Use Projections Water Code Section 10631(a) requires suppliers to provide a description of both current and projected land uses in the current and anticipated service area(s) and coordination with local and regional land use authorities to identify the most appropriate land use information to use.

BAWSCA’s Regional Water Demand and Conservation Projections Report (Demand Study) utilized the Association of Bay Area Governments’ (ABAG) population and employment projections. If your agency uses those projections in your UWMP, the Demand Study is one example of coordination with local and regional land use authorities. BAWSCA does not suggest that referencing ABAG data in the Demand Study is the only way your agency can or should meet this requirement.
c) Other Social, Economic, and Demographic Factors
Water Code Section 10631 requires UWMPs to include a description of social, economic and demographic factors affecting the supplier’s water management planning. Some factors suppliers may choose to consider include: income and poverty levels, amount of unemployment, major languages spoken or cultural clusters, education levels, general health status and age distribution of population served, economic viability and types of non-residential uses, redevelopment and special tax districts, types and proportions of housing, age of buildings, and others. Recent trends or shifts in these factors may also affect water management and planning.

The Econometric Model used in BAWSCA’s Demand Study7 considers unemployment rates and projects demands assuming a normal economy. Age of buildings is also considered with regard to end uses as a result of plumbing code changes/assumed fixture replacement rates. If your agency is using the Demand Side Management Least Cost Planning Decision Support System (DSS) Model developed as part of the Demand Study, you may consider including reference to these assumptions in your UWMP as one way of satisfying this new requirement. BAWSCA does not suggest that this is the only way your agency can or should meet this requirement. d) Water Loss
The UWMP must quantify the distribution system water loss for each of the five years preceding the plan update, in accordance with rules adopted pursuant to Water Code Section 10608.34, and in the data must show whether the urban retail water supplier met the distribution loss standards enacted by the State Water Resource Control Board pursuant to Section 10608.34 (Wat. Code, § 10631(d)(3)(A) and (C)). If the State Water Resources Control Board adopts a water loss standard before the 2020 UWMP submittal, your agency’s UWMP must include data demonstrating whether your agency has met the standard or not. e) Five Consecutive Dry-Year Water Reliability Assessment 7 Demand Study: http://bawsca.org/uploads/pdf/BAWSCA_Regional_Water_Demand_and_Conservation%20 Projections%20Report_Final.pdf

3. UWMPs: Procedures, Legal Updates and Best Practices

The Legislature modified the dry-year water reliability planning from a “multiyear” time period to a “drought lasting five consecutive water years” designation (Wat. Code, § 10635(a)). This statutory change requires a supplier to analyze the reliability of its water supplies to meet its water use over an extended drought period (Id.). The SFPUC has provided tables presenting the projected Regional Water System (RWS) supply reliability under normal, single dry year, and multiple dry year scenarios.
f) Climate Change Impacts
The Water Code now requires consideration of climate change impacts on water use, supply, and reliability (Wat. Code, § 10635(b)). A qualitative description of climate change impacts can also be included in your UWMP’s section on system and service area description. BAWSCA’s Demand Study describes how climate change impacts were included in the study and your agency’s DSS model. For sample language to include in your agency’s UWMP, please refer to Chapter 3.6 of the Demand Study.

The SFPUC intends to provide BAWSCA agencies with common language that discusses findings from their climate change study. An alternative resource is the State of California’s Fourth Climate Change Assessment completed in 2018 for nine regions, including the San Francisco Bay Area.8 If available for your service area, your agency might also consider using maps and map layers to depict climate change impacts. For example, you may include map layers projecting sea level rise, storm surges, extreme heat, and wildfires in relation to your water system assets. g) Mandatory Reporting of Energy Intensity
Water Code Section 10631.2(a) provides that water suppliers shall include estimates of the amount of energy used to extract, convey, treat, and distribute water supplies. An estimate of the amount of energy used to place water into or withdraw from storage is also required. Finally, a supplier must include a comparison of the estimated amount of energy used for treated and nontreated supplies. Any other energy-related information the supplier deems appropriate may be included in your UWMP.

Your agency is only required to estimate energy intensity for the water system that you manage and operate. The SFPUC will include estimates of energy intensity for the SF RWS in their Plan. h) Drought Risk Assessment
The Legislature created a new UWMP requirement for drought planning in part because of the significant duration of recent California droughts and the predictions about hydrological variability attributable to climate change. The Drought Risk Assessment (DRA) must include an assessment of water supply reliability over a five-year period from 2021 to 2025 that examines water supplies, water uses, and the resulting water supply reliability under a reasonable prediction for five consecutive dry years (Wat. Code, § 10635(b)).

Please feel free to contact Danielle McPherson at [email protected] or Negin Ashoori at [email protected] if you have any questions.

Attached: Attachment 1: Sample Notice of Public Hearing 8 San Francisco Bay Area Climate Change Assessment: https://www.energy.ca.gov/sites/default/files/2019- 11/Reg_Report-SUM-CCCA4-2018-005_SanFranciscoBayArea_ADA.pdf

3. UWMPs: Procedures, Legal Updates and Best Practices

Attachment 2: Sample Notification Letter to Other Agencies Attachment 3: Sample Advertisement

cc: Nicole Sandkulla
Allison Schutte
Katherine Tsou

3.a. Attachment 1: Sample Notice of Public Hearing

ATTACHMENT 1:

SAMPLE NOTICE OF PUBLIC HEARING
(FOR PUBLICATION ONCE A WEEK FOR TWO SUCCESSIVE WEEKS)
<Agency Name>

PUBLIC HEARING ON UPDATE OF URBAN WATER MANAGEMENT PLAN AND

WATER SHORTAGE CONTINGENCY PLAN
California law requires <Agency Name> review and update its Urban Water Management Plan (UWMP) every five years. Additionally, the California Department of Water Resources has imposed new requirements for urban water suppliers to adopt a Water Shortage Contingency Plan (WSCP). The <City Council/Board of Directors> will hold a public hearing to consider proposed revisions and updates to its UWMP for 2020- 2025 and its WSCP on:
<date, time virtual location (include access instructions for virtual meetings)> <Agency’s> draft 2020 UWMP and WSCP can be viewed at <link>.

Our revision schedule is as follows: <Insert schedule if available> If you have any questions about <Agency’s> UWMP or WSCP, please contact <name>, <title>, at <phone and/or email>.

Date: _________________, 2021

3.b. Attachment 2: Sample Notification Letter to Other Agencies

ATTACHMENT 2:

SAMPLE UWMP AND WSCP REVIEW NOTIFICATION LETTER TO

OTHER AGENCIES

ON AGENCY LETTERHEAD
<Date>
<Recipient's Address>
Re: Review of <Agency’s> Urban Water Management Plan and Water Shortage Contingency Plan
Dear <City/County/BAWSCA/Water or Sanitation Agency>,
This letter is to notify you that <Agency> will be reviewing and considering amendments and changes to its Urban Water Management Plan (UWMP) and Water Shortage Contingency Plan (WSCP). We invite your agency’s participation in this process. <Agency’s> draft 2020 UWMP and WSCP can be viewed at <link>. Our revision schedule is as follows:
<Insert schedule if available>
<Agency> will make revisions to its UWMP and WSCP available for public review and will hold a public hearing later this year. <City/County/BAWSCA/Water or Sanitation Agency> will be given notice of the <Agency’s City Council or Board of Directors> meeting in which the UWMP update and WSCP will be considered.

If you have any questions about <Agency’s> UWMP or WSCP, please contact <name>, <title>, at <phone and/or email>.

Sincerely,
<Agency>

3.c. Attachment 3: Sample Advertisement

ATTACHMENT 3:

SAMPLE ADVERTISEMENT
<AGENCY NAME>

UPDATE OF URBAN WATER MANAGEMENT PLAN AND WATER SHORTAGE

CONTINGENCY PLAN
<Agency Name> will be reviewing and updating its Urban Water Management Plan (UWMP) and Water Shortage Contingency Plan (WSCP) in 2021. The UWMP was last updated in 2015. We encourage all of our customers to participate in this review process. We will make revisions to the UWMP and the WSCP available for public review and will hold a public hearing on both plans in 2021. The current UWMP is available here: <link>. If you would like to learn more about the UWMP and WSCP, the schedule for revising and adopting these plans, or how to participate in the process, please contact:
<Name of contact person>
<Address>
<Telephone number>
< Facsimile number>
<Email address>

4. Memo on SFPUC Supply Reliability Letter and Drought Cutbacks 155 Bovet Road, Suite 650,  San Mateo, CA 94402  ph 650 349 3000  fx 650349 8395  www.bawsca.org February 18, 2021
TO: BAWSCA Member Agencies
FROM: Danielle McPherson, Senior Water Resources Specialist Tom Francis, Water Resources Manager
SUBJECT: San Francisco Regional Water System Supply Reliability for 2020 Urban Water Management Plans
The purpose of this memorandum is to provide updated drought allocations among the Member Agencies under the various scenarios provided in the San Francisco Public Utilities Commission (SFPUC) Regional Water System (RWS) Supply Reliability Letter dated January 22, 2021 and transmitted to the Member Agencies via email on January 25th (“Supply Reliability Letter”, Attachment A). As presented and discussed at the February 12th BAWSCA Urban Water Management Plan (UWMP) Workshop, the Tier 2 Drought Allocation Plan was not designed for RWS shortages greater than 20 percent. As a result, the Tier 2 allocation tables shared with the Supply Reliability Letter showed unexpected and wide-ranging results between Member Agencies that should not be used for UWMP purposes.

As provided for in the 2018 Amended and Restated Water Supply Agreement (WSA), the SFPUC will honor new Tier 2 allocations agreed upon by all Member Agencies if an RWS shortage greater than 20 percent is declared. However, at this time, there is no method for allocating supplies under such significant cutbacks. Additionally, the time it would take to negotiate a modified Tier 2 plan to address those significant cutbacks would be extensive and greater than the timeline required for BAWSCA to provide your agency with numbers for input into your 2020 UWMP submittals.

For these reasons, BAWSCA is recommending that for the purpose of the 2020 UWMP updates, allocation of wholesale RWS supplies should be as follows:

1. When the average Wholesale Customers’ RWS shortages are 10 percent or less, an equal percent reduction will be applied across all agencies. This is consistent with the existing Tier 2 requirement of a minimum 10 percent cutback in any Tier 2 application scenario.

2. When average Wholesale Customers’ shortages are between 10 and 20 percent, the Tier 2 Drought Allocation Plan will be applied.

3. When the average Wholesale Customers’ RWS shortages are greater than 20 percent, an equal percent reduction will be applied across all agencies.

Attachment B “Updated 2020 UWMP Drought Cutbacks” provides further detail, including recommended wholesale RWS allocation tables, for use in your agency’s 2020 UWMP.

BAWSCA recognizes that this is not an ideal situation or method for allocation of available drought supplies. In the event of actual RWS shortages greater than 20 percent, the Member Agencies would have the opportunity to negotiate and agree upon a more nuanced and equitable approach. Such an approach would likely consider basic health and safety needs, the

4. Memo on SFPUC Supply Reliability Letter and Drought Cutbacks

water needs to support critical institutions such as hospitals, and minimizing economic impacts on individual communities and the region.

Enclosed: Attachment A: Supply Reliability Letter
Attachment B: Updated 2020 UWMP Drought Cutbacks
cc: Nicole Sandkulla
Allison Schutte

OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
T 415.554.3155
F 415.554.3161
TTY 415.554.3488
January 22, 2021
Danielle McPherson
Senior Water Resources Specialist
Bay Area Water Supply and Conservation Agency
155 Bovet Road, Suite 650
San Mateo, CA 94402
Dear Ms. McPherson,
Attached please find the information you requested on the Regional Water System’s supply reliability for use in the Wholesale Customer’s 2020 Urban Water Management Plan (UWMP) updates. The SFPUC has assessed the water supply reliability under the following planning scenarios:
• Projected supply reliability for year 2020 through 2045 • Projected single dry year and multiple dry year reliability for base year 2020, both with and without implementation of the Bay-Delta Plan Amendment
• Projected single dry year and multiple dry year reliability for base year 2025, both with and without implementation of the Bay-Delta Plan Amendment
The tables presented below assume full implementation of the Bay-Delta Plan Amendment will begin in 2023. All tables assume that the wholesale customers will purchase 184 mgd from the RWS through 2045. Assumptions about the status of the dry-year water supply projects included in the Water Supply Improvement Program (WSIP) are provided below in the table ‘WSIP Project Assumptions’. The tables reflect instream flow requirements at San Mateo and Alameda Creeks, as described in the common language provided to BAWSCA separately.

Concerning allocation of supply during dry years, the Water Shortage Allocation Plan (WSAP) was utilized to allocate shortages between the SFPUC and the Wholesale Customers collectively. The WSAP implements a method for allocating water between the SFPUC retail customers and wholesale customers collectively which has been adopted by the Wholesale Customers per the July 2009 Water Supply Agreement between the City and County of

San Francisco and Wholesale Customers in Alameda County, San Mateo County, and Santa Clara County. The WSAP, also known as the Tier One Plan, was amended in the 2018 Amended and Restated Water Supply Agreement. The wholesale customers have adopted the Tier Two Plan, the second component of the WSAP, which allocates the collective wholesale customer share among each of the 26 wholesale customers.

Compared to the reliability projections that were provided previously for the 2015 UWMP update, the biggest difference in projected future deliveries is caused by the implementation of the Bay-Delta Plan Amendment. Given the uncertainty about the implementation of the Amendment (described further in the common language provided to BAWSCA), tables are included to show future projected supplies both with and without the Bay-Delta Plan Amendment.

It is our understanding that you will pass this information on to the Wholesale Customers. If you have any questions or need additional information, please do not hesitate to contact Sarah Triolo, at [email protected] or (628) 230 0802.

Sincerely,
Paula Kehoe
Director of Water Resources

Table 1: WSIP Project Assumptions
2020 2025 and Beyond
Calaveras Dam
Replacement Project
Calaveras Reservoir
partially refilled at
spring 2020 level of
63,900 AF
Calaveras Reservoir
fully refilled
Lower Crystal Springs
Dam Improvements Crystal Springs storage not restored
Regional Groundwater
Storage and Recovery
(GSR) Project
GSR account partially
filled at spring 2020
level of 23,500 AF;
GSR recovery rate of

6.2 mgd
GSR account fully
filled; GSR recovery
rate of 6.2 mgd
Alameda Creek
Recapture Project Project not built Project built
Dry-year Transfers Not in effect
Table 2: Projected Wholesale Supply from Regional Water System [For Table 6-9]:

Year 2020 2025 2030 2035 2040 2045
RWS
Supply
(mgd)
265 265 265 265 265 265
Wholesale
Supply
(mgd)
184 184 184 184 184 184

Table 3: Basis of Water Supply Data [For Table 7-1], 2020 Infrastructure Conditions With Bay Delta Plan Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale Supply
Average year 2020 265 100% 184
Single dry year 238.5 90% 157.5
• At 10% shortage, wholesale allocation is
64%, or 152.6 mgd
• Retail allocation is 36%, or 85.9 mgd
• Retail allocations above 81 mgd are reallocated to Wholesale Customers, per the 2018 WSA
• 4.9 mgd added to wholesale allocation,
bringing it to 157.5 mgd
Consecutive 1st Dry year 238.5 90% 157.5 • Same as above Consecutive 2nd Dry year 212 80% 132.5
• At a 20% shortage, wholesale allocation is

62.5%, or 132.5 mgd
• Retail allocation is 37.5%, or 79.5 mgd
Consecutive 3rd Dry year1 119.25 45% 74.5
• WSA does not define percentage split
above a 20% shortage level
• Assume same split as for a 20% shortage
level, i.e. Wholesale Customers receive

62.5%
Consecutive 4th Dry year 119.25 45% 74.5 • Same as above Consecutive 5th Dry year 119.25 45% 74.5 • Same as above 1 Assuming this year represents 2023, when Bay Delta Plan Amendment would come into effect.

Table 4: Basis of Water Supply Data [For Table 7-1], 2020 Infrastructure Conditions Without Bay Delta Plan Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale Supply
Average year 2020 265 100% 184
Single dry year 238.5 90% 157.5
• At 10% shortage, wholesale allocation is
64%, or 152.6 mgd
• Retail allocation is 36%, or 85.9 mgd
• Retail allocations above 81 mgd are reallocated to Wholesale Customers, per the 2018 WSA
• 4.9 mgd added to wholesale allocation,
bringing it to 157.5 mgd
Consecutive 1st Dry year 238.5 90% 157.5 • Same as above Consecutive 2nd Dry year 212 80% 132.5
• At a 20% shortage, wholesale allocation is

62.5%, or 132.5 mgd
• Retail allocation is 37.5%, or 79.5 mgd
Consecutive 3rd Dry year 212 80% 132.5 • Same as above
Consecutive 4th Dry year 212 80% 132.5 • Same as above
Consecutive 5th Dry year 212 80% 132.5 • Same as above

Table 5: Basis of Water Supply Data [For Table 7-1], 2025 Infrastructure With Bay Delta Plan Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale Supply
Average year 2025 265 100% 184
Single dry year 132.5 50% 82.8
• WSA does not define percentage split above a
20% shortage level
• Assume same split as for a 20% shortage level,
i.e. Wholesale Customers receive 62.5%
Consecutive 1st Dry year 132.5 50% 82.8 • Same as above Consecutive 2nd Dry year 119.25 45% 74.5 • Same as above Consecutive 3rd Dry year 119.25 45% 74.5 • Same as above Consecutive 4th Dry year 119.25 45% 74.5 • Same as above Consecutive 5th Dry year 119.25 45% 74.5 • Same as above Table 6: Basis of Water Supply Data [For Table 7-1], 2025 Infrastructure Without Bay Delta Plan Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale Supply
Average year 2025 265 100% 184
Single dry year 238.5 90% 157.5
• At 10% shortage, wholesale allocation is 64%
• Retail allocation is 36%, or 85.9 mgd; retail
allocations above 81 mgd are re-allocated to
Wholesaler Customers, per the 2018 WSA
• 4.9 mgd added to wholesale allocation, bringing
it to 157.5 mgd
Consecutive 1st Dry year 238.5 90% 157.5 • Same as above Consecutive 2nd Dry year 238.5 90% 157.5 • Same as above Consecutive 3rd Dry year 238.5 90% 157.5 • Same as above Consecutive 4th Dry year 212 80% 132.5
• At a 20% shortage, wholesale allocation is

62.5%, or 132.5 mgd
• Retail allocation is 37.5%, or 79.5 mgd
Consecutive 5th Dry year 212 80% 132.5 • Same as above

Table 7: Projected Multiple Dry Years Wholesale Supply from RWS [For Table 7-4], With Bay Delta Plan 2025 2030 2035 2040 2045
First year 82.8 82.8 82.8 82.8 82.8
Second year 74.5 74.5 74.5 74.5 74.5
Third year 74.5 74.5 74.5 74.5 74.5
Fourth year 74.5 74.5 74.5 74.5 74.5
Fifth year 74.5 74.5 74.5 74.5 74.5
Table 8: Projected Multiple Dry Years Wholesale Supply from RWS [For Table 7-4], Without Bay Delta Plan 2025 2030 2035 2040 2045
First year 157.5 157.5 157.5 157.5 157.5
Second year 157.5 157.5 157.5 157.5 157.5
Third year 157.5 157.5 157.5 157.5 157.5
Fourth year 132.5 132.5 132.5 132.5 132.5
Fifth year 132.5 132.5 132.5 132.5 132.5
Table 9: Projected Regional Water System Supply for 5-Year Drought Risk Assessment [For Table 7-5], With Bay Delta Plan. This table assumes Bay Delta Plan comes into effect in 2023.

Year 2021 2022 2023 2024 2025
RWS Supply (mgd) 238.5 212 119.25 119.25 119.25
Wholesale Supply (mgd) 157.5 132.5 74.5 74.5 74.5
Table 10: Projected Regional Water System Supply for 5-Year Drought Risk Assessment [For Table 7-5], Without Bay Delta Plan
Year 2021 2022 2023 2024 2025
RWS Supply (mgd) 238.5 212 212 212 212
Wholesale Supply (mgd) 157.5 132.5 132.5 132.5 132.5

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

The January 22, 2021, SFPUC Regional Water System (RWS) Supply Reliability Letter (Supply Reliability Letter) provides RWS supplies available to the Wholesale Customers under two scenarios:
(1) With Bay-Delta Plan, and (2) Without Bay-Delta Plan. Your agency must choose which scenario to use for your agency’s 2020 UWMP submittal tables. However, you may discuss both scenarios in the body of your agency’s UWMP. The purpose of this attachment is to provide further detail about your agency’s allocation of total RWS supplies available to the Wholesale Customers under both scenarios.

Data Sources for Projected RWS Purchases
Supply allocations are based on projected RWS purchases provided to BAWSCA by the Member Agencies. Following the completion of the Demand Study in June 2020, BAWSCA used the results to develop a table for each Member Agency listing possible supplies and total demand for 2025, 2030, 2035, 2040, and 2045. BAWSCA populated the tables with total demand after passive conservation and entered active conservation, as calculated in the agencies’ DSS Model, as a source of supply.

Multi-source agencies were asked to complete the table with supply projections, including from the RWS, to meet total demand. Single-source agencies were offered the opportunity to review the tables upon request. Because active conservation was treated as a source of supply, projected RWS purchases are after passive and active conservation.

Water Management Representatives (WMRs) received a draft copy of all projected wholesale RWS purchase requests as part of the January 7, 2021 WMR meeting agenda packet and meeting slides.

Agencies were asked to notify BAWSCA if changes were necessary regarding their purchase requests prior to BAWSCA sending those purchase requests to the SFPUC. Purchase requests were transmitted to the SFPUC via a letter dated January 15, 2021 for use in their 2020 UWMP efforts.

Note that the projected RWS purchases used by BAWSCA for fiscal years 2020-21 and for 2021-22 were provided to Christina Tang, BAWSCA’s Finance Manager, by each Member Agency in January 2021. This annual reporting is part of the SFPUC’s wholesale rate setting process. Member Agencies have provided BAWSCA with these projected purchases annually for the past 10 years.

UWMP Tables 7-1 and 7-5
UWMP Table 7-1 requests supply reliability for a normal year, a single dry year, and multiple (five) dry years. Tables 3, 4, 5, and 6 provided in the Supply Reliability Letter will help your agency complete UWMP Table 7-1. The Drought Risk Assessment (DRA) in UWMP Table 7-5 also requests a five-year drought sequence but specifies years 2021 through 2025. Supply Reliability Letter Tables 9 and 10 will help your agency complete UWMP Table 7-5.

The Supply Reliability Letter provides four scenarios to select from for completing UWMP Table 7-1.

The Supply Reliability Letter Tables 3 (with Bay-Delta Plan) and 4 (without Bay-Delta Plan) use 2020 as the base year. Depending on which scenario you choose, these will be the basis for your agency’s fiveyear DRA (UWMP Table 7-5). The Supply Reliability Letter Tables 5 (with Bay-Delta Plan) and 6 (without Bay-Delta Plan) use 2025 as the base year. Depending on which scenario you choose, these will be the basis for UWMP Tables 7-2 through 7-4.

Total RWS supplies available to the Wholesale Customers in the first through fifth consecutive dry years in Supply Reliability Letter Table 3 align with those in Table 9 of the same letter. Similarly, Supply Reliability Letter Table 4 aligns with Table 10 of the same letter.

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

Table A below provides a summary of the Member Agencies’ RWS supply drought cutbacks under each of the four supply availability conditions and is intended to help you complete UWMP Tables 7- 1and 7-5.

Table A: Wholesale Customer Drought Cutbacks Based on a Single Dry Year and Multiple Dry Years (Base Year 2020)
(a) (b) (c) (d) (e) (f) (g)
(1) Projected SF RWS
Wholesale Purchases
132.2
MGD
138.6
MGD
140.8
MGD
142.5
MGD
144.3
MGD
146.0
MGD
(2) Supply Available to the
Wholesale Customers
Percent Cutback on Wholesale RWS Purchases
2020 2021 2022 2023 2024 2025
(3) 157.5 MGD 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
(4) 132.5 MGD 0.0% -4.4% -5.9% -7.0% -8.2% -9.3%
(5) 82.8 MGD -37.4% -40.3% -41.2% -41.9% -42.6% -43.3%
(6) 74.5 MGD -43.7% -46.3% -47.1% -47.7% -48.4% -49.0%
Table A, column (a), rows 3 through 6 lists total RWS supplies available to the Wholesale Customers as provided in the Supply Reliability Letter tables. Row 1 provides cumulative actual wholesale RWS purchases for 2020 and projected purchases for 2021 through 2025. Projected RWS purchases for years 2021 and 2022 were provided to Christina Tang, BAWSCA’s Finance Manager, by the Member Agencies in January. Projected RWS purchases for 2025 were provided to BAWSCA by the Member Agencies as described previously in this memo. Projected wholesale RWS purchases for 2023 and 2024 were derived assuming a linear change between 2022 and 2025.

Table B below provides a summary of the Member Agencies’ RWS supply drought cutbacks under each of the four supply availability conditions and is intended to help you complete UWMP Table 7-1.

Table B: Wholesale Customer Drought Cutbacks Based on a Single Dry Year and Multiple Dry Years (Base Year 2025)
(a) (b) (c) (d) (e) (f) (g)
(1) Projected SF RWS
Wholesale Purchases
146.0
MGD
146.4
MGD
146.8
MGD
147.1
MGD
147.5
MGD
147.9
MGD
(2) Supply Available to the
Wholesale Customers
Percent Cutback on Wholesale RWS Purchases
2025 2026 2027 2028 2029 2030
(3) 157.5 MGD 0.0% 0.0% 0.0% 0.0%

0.0%

0.0%
(4) 132.5 MGD -9.2% -9.5% -9.7% -9.9% -10.2% -10.4%
(5) 82.8 MGD -43.3% -43.4% -43.6% -43.7% -43.9% -44.0%
(6) 74.5 MGD -49.0% -49.1% -49.3% -49.4% -49.5% -49.6%
Table B, column (a), rows 3 through 6 lists total RWS supplies available to the Wholesale Customers as provided in the Supply Reliability Letter tables. Row 1 provides cumulative projected wholesale RWS purchases for 2025 through 2030. Projected wholesale RWS purchases for years 2025 and 2030 were

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

provided to BAWSCA by the Member Agencies as described previously in this memo. Projected wholesale RWS purchases for 2026 through 2029 were derived assuming a linear change between 2025 and 2030.

To complete UWMP Tables 7-1 and 7-5, reference tables in the Supply Reliability Letter to identify total RWS supplies available to the Wholesale Customers and apply the percent cutback in the corresponding year of the drought sequence using Tables A and B. For example, in Supply Reliability Letter Table 3, in the 5th consecutive year of a drought, the volume available to the Wholesale Customers is 74.5 MGD. To calculate RWS supplies available to your agency in 2025 using table A, locate the row with 74.5 MGD on the table – row 6 – and the column for 2025 – column (g). Then apply the percent cutback to your agency’s RWS demand in 2025.

A list of purchase projections by agency are provided in Tables C, D, E, and F. The table also indicates the percent cutback that should be applied based on total RWS supplies available to the Wholesale Customers. Tables C and E use Scenario 1: With Bay-Delta Plan. Tables D and F use Scenario 2:

Without Bay-Delta Plan. Tables C and D use 2020 as the base year and Tables E and F use 2025 as the base year.

BAWSCA understands that agencies are updating projected demands for their 2020 UWMPs and that projected RWS purchases may change from what was previously provided. Additionally, BAWSCA recognizes that not all Member Agencies will choose the same scenario for their UWMP supply reliability tables. For both reasons, projected RWS purchases in each Member Agency’s 2020 UWMP may not add up to total Wholesale demands in the SFPUC’s 2020 UWMP. This is consistent with direction given by the Department of Water Resources, which encourages suppliers use the UWMP tables to represent what they believe to be the most likely supply reliability scenario and to characterize the five-consecutive year drought in a manner that is best suited for understanding and managing their water service reliability and individual agency level of risk tolerance.

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

2020 (184 MGD) 2021 (157.5 MGD) 2022 (132.5 MGD) 2023 (74.5 MGD) 2024 (74.5 MGD) 2025 (74.5 MGD) Agenc
y
Actual
Purchases
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
ACWD 7.87 0.0% 9.44 0.0% 9.46 -5.9% 8.87 -47.7% 8.27 -48.4% 7.68 -49.0% Brisbane/GVMID 0.64 0.0% 0.62 0.0% 0.65 -5.9% 0.73 -47.7% 0.81 -48.4% 0.89 -49.0% Burlin game 3.48 0.0% 3.34 0.0% 3.35 -5.9% 3.67 -47.7% 4.00 -48.4% 4.33 -49.0% Coastside 1.02 0.0% 1.54 0.0% 1.23 -5.9% 1.29 -47.7% 1.34 -48.4% 1.40 -49.0% CalWater Total 29.00 0.0% 29.66 0.0% 29.81 -5.9% 29.87 -47.7% 29.93 -48.4% 29.99 -49.0% Dal y Cit
y 3.97 0.0% 4.00 0.0% 4.01 -5.9% 3.86 -47.7% 3.72 -48.4% 3.57 -49.0% East Palo Alto 1.57 0.0% 1.63 0.0% 1.69 -5.9% 1.75 -47.7% 1.81 -48.4% 1.88 -49.0% Estero 4.34 0.0% 4.48 0.0% 4.51 -5.9% 4.36 -47.7% 4.22 -48.4% 4.07 -49.0% Ha yward 13.92 0.0% 14.47 0.0% 15.12 -5.9% 16.03 -47.7% 16.94 -48.4% 17.86 -49.0% Hillsborou
gh 2.62 0.0% 2.95 0.0% 3.05 -5.9% 3.12 -47.7% 3.19 -48.4% 3.26 -49.0% Menlo Park 2.96 0.0% 2.92 0.0% 2.93 -5.9% 3.14 -47.7% 3.35 -48.4% 3.55 -49.0% Mid-Peninsula 2.66 0.0% 2.65 0.0% 2.80 -5.9% 2.82 -47.7% 2.84 -48.4% 2.86 -49.0% Millbrae 1.90 0.0% 1.95 0.0% 2.15 -5.9% 2.19 -47.7% 2.24 -48.4% 2.29 -49.0% Milpitas 5.92 0.0% 5.88 0.0% 5.34 -5.9% 5.76 -47.7% 6.17 -48.4% 6.59 -49.0% Mountain View 7.67 0.0% 7.80 0.0% 8.05 -5.9% 8.23 -47.7% 8.42 -48.4% 8.60 -49.0% North Coast 2.37 0.0% 2.58 0.0% 2.66 -5.9% 2.56 -47.7% 2.45 -48.4% 2.34 -49.0% Palo Alto 9.75 0.0% 9.44 0.0% 9.66 -5.9% 9.79 -47.7% 9.93 -48.4% 10.06 -49.0% Purissima Hills 1.75 0.0% 1.97 0.0% 2.02 -5.9% 2.04 -47.7% 2.06 -48.4% 2.09 -49.0% Redwood Cit y 8.76 0.0% 8.72 0.0% 9.07 -5.9% 8.86 -47.7% 8.66 -48.4% 8.46 -49.0% San Bruno 0.95 0.0% 3.39 0.0% 3.40 -5.9% 3.35 -47.7% 3.29 -48.4% 3.24 -49.0% San José 4.26 0.0% 4.31 0.0% 4.51 -5.9% 4.51 -47.7% 4.50 -48.4% 4.50 -49.0% Santa Clara 3.27 0.0% 3.29 0.0% 3.50 -5.9% 3.83 -47.7% 4.17 -48.4% 4.50 -49.0% Stanford 1.43 0.0% 1.40 0.0% 1.54 -5.9% 1.70 -47.7% 1.85 -48.4% 2.01 -49.0% Sunn yvale 9.33 0.0% 9.35 0.0% 9.45 -5.9% 9.35 -47.7% 9.26 -48.4% 9.16 -49.0% Westborou
gh 0.82 0.0% 0.84 0.0% 0.81 -5.9% 0.83 -47.7% 0.84 -48.4% 0.86 -49.0% Wholesale Total 132.2 132.2† 138.6 138.6† 140.8 132.5† 142.5 74.5† 144.3 74.5† 146.0 74.5† † Total supply available to the Wholesale Customers after drought cutback.

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

2020 (184 MGD) 2021 (157.5 MGD) 2022 (132.5 MGD) 2023 (132.5 MGD) 2024 (132.5 MGD) 2025 (132.5 MGD) Agenc
y
Actual
Purchases
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
ACWD 7.87 0.0% 9.44 0.0% 9.46 -5.9% 8.87 -7.0% 8.27 -8.2% 7.68 -9.2% Brisbane/GVMID 0.64 0.0% 0.62 0.0% 0.65 -5.9% 0.73 -7.0% 0.81 -8.2% 0.89 -9.2% Burlin game 3.48 0.0% 3.34 0.0% 3.35 -5.9% 3.67 -7.0% 4.00 -8.2% 4.33 -9.2% Coastside 1.02 0.0% 1.54 0.0% 1.23 -5.9% 1.29 -7.0% 1.34 -8.2% 1.40 -9.2% CalWater Total 29.00 0.0% 29.66 0.0% 29.81 -5.9% 29.87 -7.0% 29.93 -8.2% 29.99 -9.2% Dal y Cit
y 3.97 0.0% 4.00 0.0% 4.01 -5.9% 3.86 -7.0% 3.72 -8.2% 3.57 -9.2% East Palo Alto 1.57 0.0% 1.63 0.0% 1.69 -5.9% 1.75 -7.0% 1.81 -8.2% 1.88 -9.2% Estero 4.34 0.0% 4.48 0.0% 4.51 -5.9% 4.36 -7.0% 4.22 -8.2% 4.07 -9.2% Ha yward 13.92 0.0% 14.47 0.0% 15.12 -5.9% 16.03 -7.0% 16.94 -8.2% 17.86 -9.2% Hillsborou
gh 2.62 0.0% 2.95 0.0% 3.05 -5.9% 3.12 -7.0% 3.19 -8.2% 3.26 -9.2% Menlo Park 2.96 0.0% 2.92 0.0% 2.93 -5.9% 3.14 -7.0% 3.35 -8.2% 3.55 -9.2% Mid-Peninsula 2.66 0.0% 2.65 0.0% 2.80 -5.9% 2.82 -7.0% 2.84 -8.2% 2.86 -9.2% Millbrae 1.90 0.0% 1.95 0.0% 2.15 -5.9% 2.19 -7.0% 2.24 -8.2% 2.29 -9.2% Milpitas 5.92 0.0% 5.88 0.0% 5.34 -5.9% 5.76 -7.0% 6.17 -8.2% 6.59 -9.2% Mountain View 7.67 0.0% 7.80 0.0% 8.05 -5.9% 8.23 -7.0% 8.42 -8.2% 8.60 -9.2% North Coast 2.37 0.0% 2.58 0.0% 2.66 -5.9% 2.56 -7.0% 2.45 -8.2% 2.34 -9.2% Palo Alto 9.75 0.0% 9.44 0.0% 9.66 -5.9% 9.79 -7.0% 9.93 -8.2% 10.06 -9.2% Purissima Hills 1.75 0.0% 1.97 0.0% 2.02 -5.9% 2.04 -7.0% 2.06 -8.2% 2.09 -9.2% Redwood Cit y 8.76 0.0% 8.72 0.0% 9.07 -5.9% 8.86 -7.0% 8.66 -8.2% 8.46 -9.2% San Bruno 0.95 0.0% 3.39 0.0% 3.40 -5.9% 3.35 -7.0% 3.29 -8.2% 3.24 -9.2% San José 4.26 0.0% 4.31 0.0% 4.51 -5.9% 4.51 -7.0% 4.50 -8.2% 4.50 -9.2% Santa Clara 3.27 0.0% 3.29 0.0% 3.50 -5.9% 3.83 -7.0% 4.17 -8.2% 4.50 -9.2% Stanford 1.43 0.0% 1.40 0.0% 1.54 -5.9% 1.70 -7.0% 1.85 -8.2% 2.01 -9.2% Sunn yvale 9.33 0.0% 9.35 0.0% 9.45 -5.9% 9.35 -7.0% 9.26 -8.2% 9.16 -9.2% Westborou
gh 0.82 0.0% 0.84 0.0% 0.81 -5.9% 0.83 -7.0% 0.84 -8.2% 0.86 -9.2% Wholesale Total 132.2 132.2† 138.6 138.6† 140.8 132.5† 142.5 132.5† 144.3 132.5† 146.0 132.5† † Total supply available to the Wholesale Customers after drought cutback.

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

2025 (184 MGD) 2026 (82.8 MGD) 2027 (74.5 MGD) 2028 (74.5 MGD) 2029 (74.5 MGD) 2030 (74.5 MGD) Agenc
y
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
ACWD 7.68 0% 7.68 -43.4% 7.68 -49.3% 7.68 -49.4% 7.68 -49.5% 7.68 -49.6% Brisbane/GVMID 0.89 0% 0.89 -43.4% 0.89 -49.3% 0.89 -49.4% 0.89 -49.5% 0.89 -49.6% Burlin game 4.33 0% 4.34 -43.4% 4.35 -49.3% 4.37 -49.4% 4.38 -49.5% 4.40 -49.6% Coastside 1.40 0% 1.40 -43.4% 1.39 -49.3% 1.39 -49.4% 1.38 -49.5% 1.38 -49.6% CalWater Total 29.99 0% 29.94 -43.4% 29.89 -49.3% 29.84 -49.4% 29.79 -49.5% 29.74 -49.6% Dal y Cit
y 3.57 0% 3.56 -43.4% 3.55 -49.3% 3.54 -49.4% 3.53 -49.5% 3.52 -49.6% East Palo Alto 1.88 0% 1.89 -43.4% 1.91 -49.3% 1.92 -49.4% 1.93 -49.5% 1.95 -49.6% Estero 4.07 0% 4.08 -43.4% 4.08 -49.3% 4.09 -49.4% 4.10 -49.5% 4.11 -49.6% Ha yward 17.86 0% 18.02 -43.4% 18.19 -49.3% 18.35 -49.4% 18.52 -49.5% 18.68 -49.6% Hillsborou
gh 3.26 0% 3.26 -43.4% 3.26 -49.3% 3.26 -49.4% 3.26 -49.5% 3.25 -49.6% Menlo Park 3.55 0% 3.58 -43.4% 3.60 -49.3% 3.63 -49.4% 3.66 -49.5% 3.68 -49.6% Mid-Peninsula 2.86 0% 2.85 -43.4% 2.85 -49.3% 2.85 -49.4% 2.84 -49.5% 2.84 -49.6% Millbrae 2.29 0% 2.33 -43.4% 2.37 -49.3% 2.41 -49.4% 2.46 -49.5% 2.50 -49.6% Milpitas 6.59 0% 6.62 -43.4% 6.65 -49.3% 6.68 -49.4% 6.72 -49.5% 6.75 -49.6% Mountain View 8.60 0% 8.66 -43.4% 8.72 -49.3% 8.78 -49.4% 8.84 -49.5% 8.90 -49.6% North Coast 2.34 0% 2.34 -43.4% 2.33 -49.3% 2.33 -49.4% 2.33 -49.5% 2.33 -49.6% Palo Alto 10.06 0% 10.08 -43.4% 10.10 -49.3% 10.12 -49.4% 10.13 -49.5% 10.15 -49.6% Purissima Hills 2.09 0% 2.09 -43.4% 2.09 -49.3% 2.09 -49.4% 2.09 -49.5% 2.09 -49.6% Redwood Cit y 8.46 0% 8.46 -43.4% 8.47 -49.3% 8.48 -49.4% 8.49 -49.5% 8.49 -49.6% San Bruno 3.24 0% 3.23 -43.4% 3.23 -49.3% 3.22 -49.4% 3.22 -49.5% 3.22 -49.6% San José 4.50 0% 4.50 -43.4% 4.50 -49.3% 4.50 -49.4% 4.50 -49.5% 4.50 -49.6% Santa Clara 4.50 0% 4.50 -43.4% 4.50 -49.3% 4.50 -49.4% 4.50 -49.5% 4.50 -49.6% Stanford 2.01 0% 2.04 -43.4% 2.08 -49.3% 2.11 -49.4% 2.15 -49.5% 2.18 -49.6% Sunn yvale 9.16 0% 9.19 -43.4% 9.22 -49.3% 9.24 -49.4% 9.27 -49.5% 9.30 -49.6% Westborou
gh 0.86 0% 0.86 -43.4% 0.86 -49.3% 0.86 -49.4% 0.85 -49.5% 0.85 -49.6% Wholesale Total 146.0 146.0† 146.4 82.8† 146.8 74.5† 147.1 74.5† 147.5 74.5† 147.9 74.5† † Total supply available to the Wholesale Customers after drought cutback.

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

2025 (184 MGD) 2026 (157.5 MGD) 2027 (157.5 MGD) 2028 (157.5 MGD) 2029 (132.5 MGD) 2030 (132.5 MGD) Agenc
y
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
Projected
Demand
Drought
Cutback
ACWD 7.68 0.0% 7.68 0.0% 7.68 0.0% 7.68 0.0% 7.68 -10.2% 7.68 -10.4% Brisbane/GVMID 0.89 0.0% 0.89 0.0% 0.89 0.0% 0.89 0.0% 0.89 -10.2% 0.89 -10.4% Burlin game 4.33 0.0% 4.34 0.0% 4.35 0.0% 4.37 0.0% 4.38 -10.2% 4.40 -10.4% Coastside 1.40 0.0% 1.40 0.0% 1.39 0.0% 1.39 0.0% 1.38 -10.2% 1.38 -10.4% CalWater Total 29.99 0.0% 29.94 0.0% 29.89 0.0% 29.84 0.0% 29.79 -10.2% 29.74 -10.4% Dal y Cit
y 3.57 0.0% 3.56 0.0% 3.55 0.0% 3.54 0.0% 3.53 -10.2% 3.52 -10.4% East Palo Alto 1.88 0.0% 1.89 0.0% 1.91 0.0% 1.92 0.0% 1.93 -10.2% 1.95 -10.4% Estero 4.07 0.0% 4.08 0.0% 4.08 0.0% 4.09 0.0% 4.10 -10.2% 4.11 -10.4% Ha yward 17.86 0.0% 18.02 0.0% 18.19 0.0% 18.35 0.0% 18.52 -10.2% 18.68 -10.4% Hillsborou
gh 3.26 0.0% 3.26 0.0% 3.26 0.0% 3.26 0.0% 3.26 -10.2% 3.25 -10.4% Menlo Park 3.55 0.0% 3.58 0.0% 3.60 0.0% 3.63 0.0% 3.66 -10.2% 3.68 -10.4% Mid-Peninsula 2.86 0.0% 2.85 0.0% 2.85 0.0% 2.85 0.0% 2.84 -10.2% 2.84 -10.4% Millbrae 2.29 0.0% 2.33 0.0% 2.37 0.0% 2.41 0.0% 2.46 -10.2% 2.50 -10.4% Milpitas 6.59 0.0% 6.62 0.0% 6.65 0.0% 6.68 0.0% 6.72 -10.2% 6.75 -10.4% Mountain View 8.60 0.0% 8.66 0.0% 8.72 0.0% 8.78 0.0% 8.84 -10.2% 8.90 -10.4% North Coast 2.34 0.0% 2.34 0.0% 2.33 0.0% 2.33 0.0% 2.33 -10.2% 2.33 -10.4% Palo Alto 10.06 0.0% 10.08 0.0% 10.10 0.0% 10.12 0.0% 10.13 -10.2% 10.15 -10.4% Purissima Hills 2.09 0.0% 2.09 0.0% 2.09 0.0% 2.09 0.0% 2.09 -10.2% 2.09 -10.4% Redwood Cit y 8.46 0.0% 8.46 0.0% 8.47 0.0% 8.48 0.0% 8.49 -10.2% 8.49 -10.4% San Bruno 3.24 0.0% 3.23 0.0% 3.23 0.0% 3.22 0.0% 3.22 -10.2% 3.22 -10.4% San José 4.50 0.0% 4.50 0.0% 4.50 0.0% 4.50 0.0% 4.50 -10.2% 4.50 -10.4% Santa Clara 4.50 0.0% 4.50 0.0% 4.50 0.0% 4.50 0.0% 4.50 -10.2% 4.50 -10.4% Stanford 2.01 0.0% 2.04 0.0% 2.08 0.0% 2.11 0.0% 2.15 -10.2% 2.18 -10.4% Sunn yvale 9.16 0.0% 9.19 0.0% 9.22 0.0% 9.24 0.0% 9.27 -10.2% 9.30 -10.4% Westborou
gh 0.86 0.0% 0.86 0.0% 0.86 0.0% 0.86 0.0% 0.85 -10.2% 0.85 -10.4% Wholesale Total 146.0 146.0† 146.4 146.4† 146.8 146.8† 147.1 147.1† 147.5 132.5† 147.9 132.5† † Total supply available to the Wholesale Customers after drought cutback.

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

UWMP Table 7-4
Supply Reliability Letter Tables 7 and 8 will help your agency complete UWMP Table 7-4. Table G below provides a summary of the Member Agencies’ RWS supply drought cutbacks under each of the four supply availability conditions and is intended to help you complete UWMP Table 7-4. The table assumes (1) the Tier 2 Plan will be used to allocate supplies available to the Wholesale Customers when average Wholesale Customers’ RWS shortages are greater than 10 and up to 20 percent, and (2) an equal percent reduction will be shared across all Wholesale Customers when average Wholesale Customers’ RWS shortages are 10 percent or less or greater than 20 percent.

Table G: Drought Cutbacks Based on Projected Demands Under All Water Supply Availability Conditions
(a) (b) (c) (d) (e) (f)
(1) Projected SF RWS
Wholesale Purchases 146.0 MGD 147.9 MGD 151.9 MGD 156.3 MGD 162.8 MGD (2) Supply Available to the
Wholesale Customers
% Cutback on Wholesale RWS Purchases
2025 2030 2035 2040 2045
(3) 157.5 MGD 0.0% 0.0% 0.0% 0.0% -3.2%
(4) 132.5 MGD -9.3% -10.4% Tier 2
Avg. -14%*
Tier 2
Avg. -16%*
Tier 2
Avg. -19%*
(5) 82.8 MGD -43.3% -44.0% -45.5% -47.0% -49.1%
(6) 74.5 MGD -49.0% -49.6% -51.0% -52.3% -54.2%
* Calculated average. Individual agency cutbacks are calculated in Table H.

Table G, column (a) lists total RWS supplies available to the Wholesale Customers as provided in the Supply Reliability Letter tables. Row 1 provides cumulative projected wholesale RWS purchases for 2025, 2030, 2035, 2040, and 2045.

Tables H, I, J and K provide additional detail by agency for each of the four supply availability conditions listed in Table G. To complete UWMP Table 7-4, reference Table 7 or 8 (depending on which Bay-Delta Plan scenario you choose) in the Supply Reliability Letter to identify total RWS supplies available to the Wholesale Customers and apply the percent cutback in the corresponding year using Table G or input the volumetric drought allocation using Tables H, I, J and K below.

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

Table H: Drought Allocations when Total Supplies Available to the Wholesale Customers are Equal to 157.5 MGD
Projected SF RWS
Wholesale Purchases 146.0 MGD 147.9 MGD 151.9 MGD 156.3 MGD 162.8 MGD Agency
Drought Allocation (MGD)
2025 2030 2030 2040 2045
ACWD 7.68 7.68 7.68 7.68 8.82
Brisbane/GVMID 0.89 0.89 0.88 0.89 0.87
Burlingame 4.33 4.40 4.47 4.58 4.54
Coastside 1.40 1.38 1.36 1.33 1.28
CalWater Total 29.99 29.74 29.81 30.27 29.71
Daly City 3.57 3.52 3.49 3.46 3.32
East Palo Alto 1.88 1.95 2.10 2.49 2.80
Estero 4.07 4.11 4.18 4.23 4.24
Hayward 17.86 18.68 19.75 20.82 21.43
Hillsborough 3.26 3.25 3.26 3.26 3.15
Menlo Park 3.55 3.68 3.87 4.06 4.15
Mid-Peninsula 2.86 2.84 2.88 2.89 2.83
Millbrae 2.29 2.50 2.45 2.82 3.10
Milpitas 6.59 6.75 7.03 7.27 7.29
Mountain View 8.60 8.90 9.20 9.51 9.61
North Coast 2.34 2.33 2.34 2.34 2.27
Palo Alto 10.06 10.15 10.28 10.51 10.44
Purissima Hills 2.09 2.09 2.12 2.13 2.08
Redwood City 8.46 8.49 8.64 8.74 8.62
San Bruno 3.24 3.22 3.20 3.20 3.11
San José 4.50 4.50 4.50 4.50 4.35
Santa Clara 4.50 4.50 4.50 4.50 4.35
Stanford 2.01 2.18 2.35 2.53 2.61
Sunnyvale 9.16 9.30 10.70 11.44 11.71
Westborough 0.86 0.85 0.85 0.84 0.82
Wholesale Total 146.0 147.9 151.9 156.3 157.5

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

Table I: Drought Allocations when Total Supplies Available to the Wholesale Customers are Equal to 132.5 MGD
Projected SF RWS
Wholesale Purchases 146.0 MGD 147.9 MGD 151.9 MGD 156.3 MGD 162.8 MGD Agency
Drought Allocation (MGD)
2025 2030 2030 2040 2045
ACWD 6.97 6.88 6.91 6.91 8.20
Brisbane/GVMID 0.81 0.79 0.73 0.73 0.72
Burlingame 3.93 3.94 3.96 3.89 3.80
Coastside 1.27 1.24 1.22 1.20 1.19
CalWater Total 27.21 26.65 26.46 25.69 24.69
Daly City 3.24 3.15 3.04 3.01 2.98
East Palo Alto 1.70 1.75 1.97 2.30 2.62
Estero 3.69 3.68 3.76 3.87 3.77
Hayward 16.20 16.74 17.32 17.69 18.07
Hillsborough 2.96 2.92 2.90 2.75 2.56
Menlo Park 3.22 3.30 3.37 3.33 3.26
Mid-Peninsula 2.59 2.54 2.59 2.62 2.54
Millbrae 2.07 2.24 2.16 2.32 2.45
Milpitas 5.98 6.05 6.25 6.31 6.35
Mountain View 7.80 7.97 8.28 8.49 8.34
North Coast 2.12 2.09 2.11 2.11 2.11
Palo Alto 9.13 9.09 9.26 9.46 9.71
Purissima Hills 1.89 1.87 1.42 1.38 1.32
Redwood City 7.67 7.61 7.89 7.70 7.49
San Bruno 2.94 2.88 2.56 2.51 2.45
San José 4.08 4.03 3.03 2.91 2.76
Santa Clara 4.08 4.03 3.03 2.91 2.76
Stanford 1.82 1.95 2.06 2.13 2.16
Sunnyvale 8.31 8.33 9.46 9.51 9.43
Westborough 0.78 0.76 0.76 0.76 0.76
Wholesale Total 132.5 132.5 132.5 132.5 132.5

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

Table J: Drought Allocations when Total Supplies Available to the Wholesale Customers are Equal to 82.8 MGD
Projected SF RWS
Wholesale Purchases 146.0 MGD 147.9 MGD 151.9 MGD 156.3 MGD 162.8 MGD Agency
Drought Allocation (MGD)
2025 2030 2030 2040 2045
ACWD 4.36 4.30 4.19 4.07 4.64
Brisbane/GVMID 0.51 0.50 0.48 0.47 0.45
Burlingame 2.45 2.46 2.44 2.43 2.39
Coastside 0.79 0.77 0.74 0.71 0.68
CalWater Total 17.00 16.65 16.25 16.03 15.62
Daly City 2.02 1.97 1.90 1.83 1.75
East Palo Alto 1.06 1.09 1.14 1.32 1.47
Estero 2.31 2.30 2.28 2.24 2.23
Hayward 10.13 10.46 10.77 11.03 11.26
Hillsborough 1.85 1.82 1.78 1.73 1.66
Menlo Park 2.01 2.06 2.11 2.15 2.18
Mid-Peninsula 1.62 1.59 1.57 1.53 1.49
Millbrae 1.30 1.40 1.34 1.49 1.63
Milpitas 3.74 3.78 3.83 3.85 3.83
Mountain View 4.88 4.98 5.01 5.04 5.05
North Coast 1.33 1.30 1.28 1.24 1.19
Palo Alto 5.71 5.68 5.61 5.57 5.49
Purissima Hills 1.18 1.17 1.15 1.13 1.10
Redwood City 4.80 4.76 4.71 4.63 4.53
San Bruno 1.83 1.80 1.75 1.70 1.63
San José 2.55 2.52 2.45 2.38 2.29
Santa Clara 2.55 2.52 2.45 2.38 2.29
Stanford 1.14 1.22 1.28 1.34 1.37
Sunnyvale 5.19 5.21 5.83 6.06 6.16
Westborough 0.49 0.48 0.46 0.45 0.43
Wholesale Total 82.8 82.8 82.8 82.8 82.8

4.b. Attachment B: Updated 2020 UWMP Drought Cutbacks

Table K: Drought Allocations when Total Supplies Available to the Wholesale Customers are Equal to 74.5 MGD
Projected SF RWS
Wholesale Purchases 146.0 MGD 147.9 MGD 151.9 MGD 156.3 MGD 162.8 MGD Agency
Drought Allocation (MGD)
2025 2030 2030 2040 2045
ACWD 3.92 3.87 3.77 3.66 4.17
Brisbane/GVMID 0.46 0.45 0.43 0.42 0.41
Burlingame 2.21 2.21 2.19 2.18 2.15
Coastside 0.71 0.70 0.67 0.64 0.61
CalWater Total 15.30 14.98 14.62 14.43 14.05
Daly City 1.82 1.77 1.71 1.65 1.57
East Palo Alto 0.96 0.98 1.03 1.19 1.32
Estero 2.08 2.07 2.05 2.02 2.00
Hayward 9.11 9.41 9.69 9.92 10.14
Hillsborough 1.66 1.64 1.60 1.55 1.49
Menlo Park 1.81 1.86 1.90 1.94 1.96
Mid-Peninsula 1.46 1.43 1.41 1.38 1.34
Millbrae 1.17 1.26 1.20 1.34 1.47
Milpitas 3.36 3.40 3.45 3.47 3.45
Mountain View 4.39 4.48 4.51 4.53 4.54
North Coast 1.19 1.17 1.15 1.12 1.07
Palo Alto 5.14 5.11 5.04 5.01 4.94
Purissima Hills 1.06 1.05 1.04 1.02 0.99
Redwood City 4.31 4.28 4.24 4.17 4.08
San Bruno 1.65 1.62 1.57 1.53 1.47
San José 2.30 2.27 2.21 2.14 2.06
Santa Clara 2.30 2.27 2.21 2.14 2.06
Stanford 1.03 1.10 1.15 1.21 1.24
Sunnyvale 4.67 4.69 5.25 5.45 5.54
Westborough 0.44 0.43 0.41 0.40 0.39
Wholesale Total 74.5 74.5 74.5 74.5 74.5

5. Common Language about Rate Impacts of Water Shortages

Common Language for Wholesale Customers about Rate Impacts of Water Shortages The SFPUC includes a variable component to water rates for most customer classes. As a result, as sales decrease, revenues are lost on a per unit basis. Because the marginal cost of water production is relatively small, as production is reduced, the cost of service remains the same. For both retail and wholesale customers, a reduction in water purchases – whether voluntary or mandated – would require the SFPUC to raise rates, cut costs, or use existing fund balance reserves to cover its expenses. The financial planning and rate‐setting process is complex and iterative. While major impacts of a water shortage on rates are described below, the full process, especially for large water shortages, would incorporate significant stakeholder discussion about tradeoffs and financial impacts.

The SFPUC’s current retail water rates have a provision for a “drought surcharge” that automatically increases adopted rates in the event of a declared water shortage. The drought surcharge is calculated so that, accounting for the expected reduction in retail water usage, total revenues are equal to what they would have been without the reduction. The drought surcharge protects the SFPUC’s financial stability during water shortages, and provides customers an incentive to meet conservation targets.

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 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 annual budget process and are based on the forecasted wholesale share of regional water system expenditures and total purchases. If wholesale customer usage is expected to decrease – either voluntarily, or due to shortages – this would be incorporated into the wholesale rate forecast, and rates may increase.

OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
T 415.554.3155
F 415.554.3161
TTY 415.554.3488
March 30, 2021
Danielle McPherson
Senior Water Resources Specialist
Bay Area Water Supply and Conservation Agency
155 Bovet Road, Suite 650
San Mateo, CA 94402
Dear Ms. McPherson,
Attached please find additional supply reliability modeling results conducted by the SFPUC. The SFPUC has conducted additional supply reliability modeling under the following planning scenarios:
• Projected supply reliability for years 2020 through 2045, assuming that demand is equivalent to the sum of the projected retail demands on the Regional Water System (RWS) and Wholesale Customer purchase request projections provided to SFPUC by BAWSCA on January 21st (see Table 1 below).
• Under the above demand conditions, projected supply reliability for scenarios both with and without implementation of the Bay-Delta Plan Amendment starting in 2023.

The SFPUC will be using this supply modeling in the text of its draft UWMP and moving the original modeling results into an appendix.

Table 1: Retail and Wholesale RWS Demand Assumptions Used for Additional Supply Reliability Modeling (mgd)
2020 2025 2030 2035 2040 2045
Retail 66.5 67.2 67.5 68.6 70.5 73.7
Wholesale1, 2 132.1 146.0 147.9 151.9 156.3 162.8
Total 198.6 213.2 215.4 220.5 226.8 236.5
1 Wholesale purchase request projections provided to the SFPUC by BAWSCA on January 21
st, 2021
2 Includes demands for Cities of San Jose and Santa Clara Please note the following about the information presented in the attached tables:

• Assumptions about infrastructure conditions remain the same as what was provided in our January 22nd letter.
• The Tier 1 allocations were applied to the RWS supplies to determine the wholesale supply, as was also described in the January 22nd letter; for any system-wide shortage above 20%, the Tier 1 split for a 20% shortage was applied.
• The SFPUC water supply planning methodology, including simulation of an 8.5-year design drought, is used to develop these estimates of water supply available from the RWS for five dry years. In each demand scenario for 2020 through 2045, the RWS deliveries are estimated using the standard SFPUC procedure, which includes adding increased levels of rationing as needed to balance the demands on the RWS system with available water supply. Some simulations may have increased levels of rationing in the final years of the design drought sequence, which can influence the comparison of results in the first five years of the sequence.
• Tables 7 and 8 in the attached document provide RWS and wholesale supply availability for the five-year drought risk assessment from 2021 to 2025. SFPUC’s modeling approach does not allow for varying demands over the course of a dry year sequence. Therefore, the supply projections for 2021 to 2025 are based on meeting 2020 levels of demand. However, in years when the Bay-Delta Plan Amendment is not in effect, sufficient RWS supplies will be available to meet the Wholesale Customers’ purchase requests assuming that they are between the 2020 and 2025 projected levels. This is not reflected in Tables 7 and 8 because SFPUC did not want to make assumptions about the growth of purchase requests between 2020 and 2025.

In our draft UWMP, we acknowledge that we have a Level of Service objective of meeting average annual water demand of 265 mgd from the SFPUC watersheds for retail and Wholesale Customers during non-drought years, as well as a contractual obligation to supply 184 mgd to the Wholesale Customers. Therefore, we will still include the results of our modeling based on a demand of 265 mgd in order to facilitate planning that supports meeting this Level of Service objective and our contractual obligations. The results of this modeling will be in an appendix to the draft UWMP. As will be shown in this appendix, in a normal year the SFPUC can provide up to 265 mgd of supply from the RWS. The RWS supply projections shown in the attached tables are more accurately characterized as supplies that will be used to meet projected retail and Wholesale Customer demands.

It is our understanding that you will pass this information on to the Wholesale Customers. If you have any questions or need additional information, please do not hesitate to contact Sarah Triolo, at [email protected] or (628) 230 0802.

Sincerely,
Paula Kehoe
Director of Water Resources

Table 2: Projected Total RWS Supply Utilized and Portion of RWS Supply Utilized by Wholesale Customers in Normal Years [For Table 6-9]:

Year 2020 2025 2030 2035 2040 2045
RWS Supply Utilized (mgd) 198.6 213.2 215.4 220.5 226.8 236.5 RWS Supply Utilized by
Wholesale Customersa(mgd) 132.1 146.0 147.9 151.9 156.3 162.8 a RWS supply utilized by Wholesale Customers is equivalent to purchase request projections provided to SFPUC by BAWSCA on January 21, 2021, and includes Cities of San Jose and Santa Clara.

Basis of Water Supply Data: With Bay-Delta Plan Amendment Table 3a: Basis of Water Supply Data [For Table 7-1], Base Year 2020, With BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale
Supply
Average year 2020 198.6 100% 132.1
Single dry year 198.6 100% 132.1
Consecutive 1st Dry year 198.6 100% 132.1
Consecutive 2nd Dry year 198.6 100% 132.1
Consecutive 3rd Dry year1 119.2 60% 74.5 • At shortages 20% or greater, wholesale allocation is assumed to be 62.5%
Consecutive 4th Dry year 119.2 60% 74.5 • Same as above Consecutive 5th Dry year 119.2 60% 74.5 • Same as above 1 Assuming this year represents 2023, when Bay Delta Plan Amendment would come into effect.

Table 3b: Basis of Water Supply Data [For Table 7-1], Base Year 2025, With BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale
Supply
Average year 2025 213.2 100% 146.0
Single dry year 149.2 70% 93.3
• At shortages 20% or greater,
wholesale allocation is assumed to
be 62.5%
Consecutive 1st Dry year 149.2 70% 93.3 • Same as above Consecutive 2nd Dry year 127.9 60% 80.0 • Same as above Consecutive 3rd Dry year 127.9 60% 80.0 • Same as above Consecutive 4th Dry year 127.9 60% 80.0 • Same as above Consecutive 5th Dry year 127.9 60% 80.0 • Same as above

Table 3c: Basis of Water Supply Data [For Table 7-1], Base Year 2030, With BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale
Supply
Average year 2030 215.4 100% 147.9
Single dry year 150.8 70% 94.2
• At shortages 20% or greater,
wholesale allocation is assumed to
be 62.5%
Consecutive 1st Dry year 150.8 70% 94.2 • Same as above Consecutive 2nd Dry year 129.2 60% 80.8 • Same as above Consecutive 3rd Dry year 129.2 60% 80.8 • Same as above Consecutive 4th Dry year 129.2 60% 80.8 • Same as above Consecutive 5th Dry year 129.2 60% 80.8 • Same as above Table 3d: Basis of Water Supply Data [For Table 7-1], Base Year 2035, With BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale
Supply
Average year 2035 220.5 100% 151.9
Single dry year 154.4 70% 96.5
• At shortages 20% or greater,
wholesale allocation is assumed to
be 62.5%
Consecutive 1st Dry year 154.4 70% 96.5 • Same as above Consecutive 2nd Dry year 132.3 60% 82.7 • Same as above Consecutive 3rd Dry year 132.3 60% 82.7 • Same as above Consecutive 4th Dry year 132.3 60% 82.7 • Same as above Consecutive 5th Dry year 121.3 55% 75.8 • Same as above Table 3e: Basis of Water Supply Data [For Table 7-1], Base Year 2040, With BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale
Supply
Average year 2040 226.8 100% 156.3
Single dry year 158.8 70% 99.2
• At shortages 20% or greater,
wholesale allocation is assumed to
be 62.5%
Consecutive 1st Dry year 158.8 70% 99.2 • Same as above Consecutive 2nd Dry year 136.1 60% 85.1 • Same as above Consecutive 3rd Dry year 136.1 60% 85.1 • Same as above Consecutive 4th Dry year 120.2 53% 75.1 • Same as above Consecutive 5th Dry year 120.2 53% 75.1 • Same as above

Table 3f: Basis of Water Supply Data [For Table 7-1], Base Year 2045, With Bay-Delta Plan Amendment
Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of Wholesale
Supply
Average year 2045 236.5 100% 162.8
Single dry year 141.9 60% 88.7
• At shortages 20% or greater,
wholesale allocation is assumed to
be 62.5%
Consecutive 1st Dry year 141.9 60% 88.7 • Same as above Consecutive 2nd Dry year 141.9 60% 88.7 • Same as above Consecutive 3rd Dry year 141.9 60% 88.7 • Same as above Consecutive 4th Dry year 120.6 51% 75.4 • Same as above Consecutive 5th Dry year 120.6 51% 75.4 • Same as above Table 3g: Projected RWS Supply Availability [Alternative to Table 7-1], Years 2020- 2045, With Bay-Delta Plan Amendment
Year 2020 2025 2030 2035 2040 2045
Average year 100% 100% 100% 100% 100% 100%
Single dry year 100% 70% 70% 70% 70% 60%
Consecutive 1st Dry year 100% 70% 70% 70% 70% 60%
Consecutive 2nd Dry year 100% 60% 60% 60% 60% 60%
Consecutive 3rd Dry year1 60% 60% 60% 60% 60% 60%
Consecutive 4th Dry year 60% 60% 60% 60% 53% 51%
Consecutive 5th Dry year 60% 60% 60% 55% 53% 51%
1 Assuming that at base year 2020, this year represents 2023, when Bay Delta Plan Amendment would come into effect.

Basis of Water Supply Data: Without Bay-Delta Plan Amendment Table 4a: Basis of Water Supply Data [For Table 7-1], Base Year 2020, Without BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of
Wholesale Supply
Average year 2020 198.6 100% 132.1
Single dry year 198.6 100% 132.1
Consecutive 1
st Dry year 198.6 100% 132.1
Consecutive 2nd Dry year 198.6 100% 132.1
Consecutive 3rd Dry year 198.6 100% 132.1
Consecutive 4th Dry year 198.6 100% 132.1
Consecutive 5th Dry year 198.6 100% 132.1
Table 4b: Basis of Water Supply Data [For Table 7-1], Base Year 2025, Without BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of
Wholesale Supply
Average year 2025 213.2 100% 146.0
Single dry year 213.2 100% 146.0
Consecutive 1
st Dry year 213.2 100% 146.0
Consecutive 2nd Dry year 213.2 100% 146.0
Consecutive 3rd Dry year 213.2 100% 146.0
Consecutive 4th Dry year 213.2 100% 146.0
Consecutive 5th Dry year 213.2 100% 146.0
Table 4c: Basis of Water Supply Data [For Table 7-1], Base Year 2030, Without BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation
of Wholesale Supply
Average year 2030 215.4 100% 147.9
Single dry year 215.4 100% 147.9
Consecutive 1st Dry year 215.4 100% 147.9
Consecutive 2
nd Dry year 215.4 100% 147.9
Consecutive 3rd Dry year 215.4 100% 147.9
Consecutive 4th Dry year 215.4 100% 147.9
Consecutive 5th Dry year 215.4 100% 147.9

Table 4d: Basis of Water Supply Data [For Table 7-1], Base Year 2035, Without BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation
of Wholesale Supply
Average year 2035 220.5 100% 151.9
Single dry year 220.5 100% 151.9
Consecutive 1st Dry year 220.5 100% 151.9
Consecutive 2nd Dry year 220.5 100% 151.9
Consecutive 3rd Dry year 220.5 100% 151.9
Consecutive 4th Dry year 220.5 100% 151.9
Consecutive 5th Dry year 220.5 100% 151.9
Table 4e: Basis of Water Supply Data [For Table 7-1], Base Year 2040, Without BayDelta Plan Amendment Year Type Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation
of Wholesale Supply
Average year 2040 226.8 100% 156.3
Single dry year 226.8 100% 156.3
Consecutive 1st Dry year 226.8 100% 156.3
Consecutive 2nd Dry year 226.8 100% 156.3
Consecutive 3rd Dry year 226.8 100% 156.3
Consecutive 4th Dry year 226.8 100% 156.3
Consecutive 5th Dry year 226.8 100% 156.3
Table 4f: Basis of Water Supply Data [For Table 7-1], Base Year 2045, Without BayDelta Plan Amendment Year Type
Base
Year
RWS
Volume
Available
(mgd)
% of
Average
Supply
Wholesale
Volume
Available
(mgd)
Notes on Calculation of
Wholesale Supply
Average year 2045 236.5 100% 162.8
Single dry year 236.5 100% 162.8
Consecutive 1st Dry year 236.5 100% 162.8
Consecutive 2nd Dry year 236.5 100% 162.8
Consecutive 3rd Dry year 236.5 100% 162.8
Consecutive 4th Dry year 212.8 90% 139.1
• At a 10% shortage level,
the wholesale allocation is
64% of available supply
• The retail allocation is
36% of supply, which
resulted in a positive
allocation to retail of 2.9
mgd, which was reallocated to the Wholesale
Customers
Consecutive 5th Dry year 212.8 90% 139.1 • Same as above

Table 4g: Projected RWS Supply [Alternative to Table 7-1], Years 2020-2045, Without Bay-Delta Plan Amendment
Year 2020 2025 2030 2035 2040 2045
Average year 100% 100% 100% 100% 100% 100%
Single dry year 100% 100% 100% 100% 100% 100%
Consecutive 1st Dry year 100% 100% 100% 100% 100% 100%
Consecutive 2nd Dry year 100% 100% 100% 100% 100% 100%
Consecutive 3rd Dry year 100% 100% 100% 100% 100% 100%
Consecutive 4th Dry year 100% 100% 100% 100% 100% 90%
Consecutive 5th Dry year 100% 100% 100% 100% 100% 90%

Supply Projections for Consecutive Five Dry Year Sequences Table 5: Projected Multiple Dry Years Wholesale Supply from RWS [For Table 7-4], With Bay-Delta Plan Amendment
2025 2030 2035 2040 2045
First year 93.3 94.2 96.5 99.2 88.7
Second year 80.0 80.8 82.7 85.1 88.7
Third year 80.0 80.8 82.7 85.1 88.7
Fourth year 80.0 80.8 82.7 75.1 75.4
Fifth year 80.0 80.8 75.8 75.1 75.4
Table 6: Projected Multiple Dry Years Wholesale Supply from RWS [For Table 7-4], Without Bay-Delta Plan Amendment
2025 2030 2035 2040 2045
First year 146.0 147.9 151.9 156.3 162.8
Second year 146.0 147.9 151.9 156.3 162.8
Third year 146.0 147.9 151.9 156.3 162.8
Fourth year 146.0 147.9 151.9 156.3 139.1
Fifth year 146.0 147.9 151.9 156.3 139.1
Table 7: Projected Regional Water System Supply for 5-Year Drought Risk Assessment [For Table 7-5], With Bay-Delta Plan Amendment. This table assumes Bay Delta Plan comes into effect in 2023.

Year 2021 2022 2023 2024 2025
RWS Supply (mgd) 198.6 198.6 119.2 119.2 119.2
Wholesale Supply (mgd) 132.1 132.1 74.5 74.5 74.5
Table 8: Projected Regional Water System Supply for 5-Year Drought Risk Assessment [For Table 7-5], Without Bay Delta Plan
Year 2021 2022 2023 2024 2025
RWS Supply (mgd) 198.6 198.6 198.6 198.6 198.6
Wholesale Supply (mgd) 132.1 132.1 132.1 132.1 132.1

Jefferson Union High School District Master Plan Project B
Appendix B: Figure LUE-1, Existing Land Use and Figure
LUE-3, Future Land Use, in the Daly City 2030 General Plan

Jefferson Union High School District Master Plan Project B
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Daly City 2030 General Plan | Land Use Element 3
Figure LUE-1

EXISTING LAND USE

CITY OF DALY CITY

LAND USE ELEMENT

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Daly City 2030 General Plan | Land Use Element 17
Figure LUE-3

FUTURE LAND USE

CITY OF DALY CITY

LAND USE ELEMENT

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Jefferson Union High School District Master Plan Project C
Appendix C: JUHSD Phasing Plan

Jefferson Union High School District Master Plan Project C
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255 Shoreline Drive, Suite 200, Redwood City, CA 94065 | 650.482.6300

MEMORANDUM
Date: April 21, 2021 BKF Job Number: 20190078
To: To whom it may concern, City of Daly City
Cc: Alan Katz, Brookwood Group
From: Tim Heffernan
Subject: Jefferson Union High School District – Master Plan Water System Modeling Request
Jefferson Union High School District is planning a Master Plan for the expansion of the Workforce Housing District located at 699 Serramonte Boulevard in the City of Daly City. The project improvements include new high density residential buildings, a mixed-use building, pedestrian pathways, landscaping, surface parking, and utilities. The project will include the removal of an existing school building, modular buildings, and its corresponding existing parking lot and roadways.

Existing Water System
The existing City water system in the vicinity of the project consists of a 6 inch AC water main in Serramonte Boulevard and a 10 inch water main in Entry Drive constructed with the previous project. Figure 1 shows the existing water system within the development area (refer to Attachment 1 for city maps). The existing domestic water system for the school campus is fed by a 3” service near the main entrance off Serramonte Blvd while the existing fire service for the campus is served from an 8” line from Callan Blvd. The existing Jefferson Union High School District Workforce Housing project is fed from the existing 10 inch main.

Proposed Water System
The onsite water system consists of both public and private water facilities. As part of the approval process the city has been engaged to perform additional studies including a Water Supply Assessment and a System Capacity Study to assess the City’s ability to serve the project. Public water mains will be constructed in the private streets and will connect to existing infrastructure recently constructed with the Workforce Housing project, intercept the existing system at Campus Drive, and serve the proposed development.

To accommodate the proposed development the 10” water main constructed with the Workforce Housing project will be relocated to West Drive and provide the same loop between Campus Drive and Serramonte Boulevard. The relocated main will connect to the existing mains in Campus Drive and North Drive and serve Parcel F. The 10” water main in East Drive will connect to the existing mains in Campus Drive and North Drive and Serve Parcels C1, C2 and D.

255 Shoreline Drive, Suite 200, Redwood City, CA 94065 | 650.482.6300 The Public water mains will be located in a Public Utility Easement to be dedicated to the city.

Private onsite water facilities will be owned and maintained by the owner. The public and private water systems will consist of pipes, valves, hydrants, meters, and backflows.

Phasing
The Plan Area is to be built-out in phases over a period anticipated to be eight to twelve years but may be up to 15 years. Each phase of development includes the infrastructure necessary to support development, open space and public improvements associated with specific parcels as follows:
• Phase I is the development of Parcel B housing, retail, overlook park, portions of North Drive, north side of North Access Way and associated utility improvements. • Phase II is the development of Parcel C affordable housing, Headstart, East Drive, south side of North Access Way, South Access Way and Parcel D housing, and associated utility improvements.
• Phase III is the development of Parcel E housing and Central Park together, Parcel F housing, West Drive, the remaining portion of North Drive, and associated utility improvements. Parcel E or Parcel F may develop independently and in any order.

It is anticipated the below grade utilities will be constructed with the associated surface improvements for any given phase. Surface improvements will be constructed to the build-out condition where possible but at a minimum will accommodate a road network to provide pedestrian, bicycle, vehicular, and emergency vehicle access for each parcel. In addition, utility infrastructure, including but not limited to, water, sewer, storm drainage, stormwater treatment will be installed to support the current phase or future phases of development.

The number of phases, number of units, and timeline for the project build-out will ultimately depend on market conditions. The rate of the build-out of housing will fluctuate with the regional economy, capital expectations and availability, costs for development and the conditions of the Daly City housing market.

Water Generation Calculations
We understand the City establishes water demand numbers for different types of building uses.

We have provided a summary of the existing and proposed building type, areas, and number of units. Table 1 identifies the existing demands. Table 2 identifies the proposed building type and areas. Table 3 identifies the area of existing irrigated landscape area to be removed and the area of proposed irrigated landscape area to be constructed with the new project. This information will be used by the City to determine the water demand for the proposed project. The flows generated by the proposed project and the reduction in flows from the existing building and landscaping being removed will be used in the City’s model to determine if the City’s water system has enough capacity to serve the project.

255 Shoreline Drive, Suite 200, Redwood City, CA 94065 | 650.482.6300 Table 1 - Existing Demands
Building Type Area Levels
(Description) (sf) (ea)
School Site School 154,046 1
Modular 1 School 7,283 1
Modular 2 School 1,448 1
Modular 3 School 1,451 1
Modular 4 School 4,588 1
Total 168,816

255 Shoreline Drive, Suite 200, Redwood City, CA 94065 | 650.482.6300 Table 2A – Proposed Demands Low Rise Option
Building Type Approximate
Area with
Standard
Parking
Approximate
Area-assuming
50% of the Area
is Puzzle Lifts
Unit Count Levels (Assumes
Puzzle Lifts for
1/2 of the parking
area)
Construction
Type
(Description) (sf) (sf) (ea) (ea) (Type)
Phase 1 Parcel B
Apartment
Not Applicable
231,150 201 5 III-A
Retail/Restaurant (located at grade in parking structure) 24,427 - 0 I-A Parking (including 40 spaces for Retail)(Standard) 54,338 345 2 Parking (including 40 spaces for Retail)(Puzzle Lift) 54,338 I-A Sub-Total Parcel B 364,252 7
Phase 2
Parcels C1/C2
Apartment 115,000 115,000 100 5 III-A HeadStart (located either in podium or stand-alone) 1,400 1,400 - 0 I-A / III-A* Parking (Standard) 45,000 17,500 100 2 Parking (Puzzle Lift) 17,500 I-A Sub-Total Parcel C 161,400 151,400 7
Parcel D
Apartment 276,000 276,000 240 5 III-A
Parking (Standard) 149,400 56,700 360 2 Parking (Puzzle Lift) 56,700 I-A Sub-Total Parcel D 425,400 389,400 7
Phase 3
Parcel E
Apartment 276,000 276,000 240 5 III-A
Parking (Standard) 149,400 56,700 360 2 Parking (Puzzle Lift) 56,700 I-A Sub-Total Parcel E 425,400 389,400 7
Parcel F
Apartment 381,800 381,800 332 5 III-A
Parking (Standard) 206,670 78,435 498 2 Parking (Puzzle Lift) 78,435 I-A Sub-Total Parcel F 588,470 538,670 7 Total Residential 1,279,950 1,279,950 1,113 Total Other (Retail/General Office/Preschool) 25,827 25,827 Total Parking 659,145 527,345 1,663 Total 1,964,922 1,833,122

255 Shoreline Drive, Suite 200, Redwood City, CA 94065 | 650.482.6300 Table 2B – Proposed Demands High Rise Option
Building Type Approximate
Area with
Standard Parking
Approximate
Area--assuming
50% of the Area
is Puzzle Lifts
Unit Count Levels (Assumes
Puzzle Lifts for 1/2
of the parking
area)
Construction
Type
(Description) (sf) (sf) (ea) (ea) (Type)
Phase 1 Parcel B
Apartment
Refer to Low Rise Option Retail/Restaurant (located at grade in parking structure) Parking (including 40 spaces for Retail)(Standard) Parking (including 40 spaces for Retail)(Puzzle Lift)
Sub-Total Parcel B
Phase 2
Parcels C1/C2
Apartment
Refer to Low Rise Option HeadStart (located either in podium or stand-alone) Parking (Standard) Parking (Puzzle Lift)
Sub-Total Parcel C
Parcel D
Apartment 309,350 309,350 269 11 I-A
Parking (Standard) 167,453 63,551 404 3 Parking (Puzzle Lift) 63,551 I-A Sub-Total Parcel D 476,803 436,453 14
Phase 3
Parcel E
Apartment 379,500 379,500 330 11 I-A
Parking (Standard) 205,425 77,963 495 3 Parking (Puzzle Lift) 77,963 I-A Sub-Total Parcel E 379,500 457,463 14
Parcel F
Apartment 391,000 391,000 340 11 I-A
Parking (Standard) 211,650 80,325 510 3 Parking (Puzzle Lift) 80,325 I-A Sub-Total Parcel F 602,650 551,650 14 Total Residential 1,426,000 1,426,000 1,240 Total Other (Retail/General Office/Preschool) 25,827 25,827 Total Parking 738,203 587,353 1,854 Total 2,190,030 2,039,180

255 Shoreline Drive, Suite 200, Redwood City, CA 94065 | 650.482.6300 Table 3: Irrigated Landscape Areas
Existing (sf) Proposed (sf)
221,560 176,900

Phase 1 Phase 2 Phase 3

Jefferson Union High School District Master Plan Project D
Appendix D: South Westside Basin GWMP
The South Westside Basin GWMP (WRIME, 2012) provides a framework for the sustainable use of the South Westside Basin. The report is also available online at: http://sfwater.org/

Jefferson Union High School District Master Plan Project D
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Jefferson Union High School District Master Plan Project E
Appendix E: BAWSCA Tier 2 Drought Implementation Plan
The latest Tier 2 allocations (including Daly City allocations) under normal, dry, and multi-dry year for with Bay-Delta Plan implementation scenario and without. April 1st, 2021.

Jefferson Union High School District Master Plan Project E
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Agency 2025 2030 2035 2040 2045
ACWD 7.87 7.68 7.68 7.68 7.68 9.11
Brisbane/GVMID 0.64 0.89 0.89 0.88 0.89 0.89
Burlingame 3.48 4.33 4.40 4.47 4.58 4.69
Coastside 1.02 1.40 1.38 1.36 1.33 1.33
CalWater Total 29.00 29.99 29.74 29.81 30.27 30.70
Daly City 3.97 3.57 3.52 3.49 3.46 3.43
East Palo Alto 1.57 1.88 1.95 2.10 2.49 2.89
Estero 4.34 4.07 4.11 4.18 4.23 4.38
Hayward 13.92 17.86 18.68 19.75 20.82 22.14
Hillsborough 2.62 3.26 3.25 3.26 3.26 3.26
Menlo Park 2.96 3.55 3.68 3.87 4.06 4.29
Mid-Peninsula 2.66 2.86 2.84 2.88 2.89 2.93
Millbrae 1.90 2.29 2.50 2.45 2.82 3.20
Milpitas 5.92 6.59 6.75 7.03 7.27 7.53
Mountain View 7.67 8.60 8.90 9.20 9.51 9.93
North Coast 2.37 2.34 2.33 2.34 2.34 2.34
Palo Alto 9.75 10.06 10.15 10.28 10.51 10.79
Purissima Hills 1.75 2.09 2.09 2.12 2.13 2.15
Redwood City 8.76 8.46 8.49 8.64 8.74 8.90
San Bruno 0.95 3.24 3.22 3.20 3.20 3.21
San Jose 4.26 4.50 4.50 4.50 4.50 4.50
Santa Clara 3.27 4.50 4.50 4.50 4.50 4.50
Stanford 1.43 2.01 2.18 2.35 2.53 2.70
Sunnyvale 9.33 9.16 9.30 10.70 11.44 12.10
Westborough 0.82 0.86 0.85 0.85 0.84 0.84
Total 132.22 146.01 147.87 151.90 156.31 162.76
a
Wholesale RWS purchase projections for 2025, 2030, 2035, 2040, and 2045 were provided to BAWSCA between July 2020 and January 2021 by the Member Agencies following the completion of the June 2020 Demand Study.
2020
Actual
Projected Wholesale RWS Purchases
Section 1: Basis for Calculations. Projected Wholesale RWS Purchases Through 2045 Table A: Wholesale RWS Actual Purchases in 2020 and Projected Purchases for 2025, 2030, 2035, 2040, and 2045 (mgd)a

Agency 2021b 2022b 2023c 2024c 2025c
ACWD 7.87 9.44 9.46 9.46 9.46 9.46
Brisbane/GVMID 0.64 0.62 0.65 0.65 0.65 0.65
Burlingame 3.48 3.34 3.35 3.35 3.35 3.35
Coastside 1.02 1.54 1.23 1.23 1.23 1.23
CalWater Total 29.00 29.66 29.81 29.81 29.81 29.81
Daly City 3.97 4.00 4.01 4.01 4.01 4.01
East Palo Alto 1.57 1.63 1.69 1.69 1.69 1.69
Estero 4.34 4.48 4.51 4.51 4.51 4.51
Hayward 13.92 14.47 15.12 15.12 15.12 15.12
Hillsborough 2.62 2.95 3.05 3.05 3.05 3.05
Menlo Park 2.96 2.92 2.93 2.93 2.93 2.93
Mid-Peninsula 2.66 2.65 2.80 2.80 2.80 2.80
Millbrae 1.90 1.95 2.15 2.15 2.15 2.15
Milpitas 5.92 5.88 5.34 5.34 5.34 5.34
Mountain View 7.67 7.80 8.05 8.05 8.05 8.05
North Coast 2.37 2.58 2.66 2.66 2.66 2.66
Palo Alto 9.75 9.44 9.66 9.66 9.66 9.66
Purissima Hills 1.75 1.97 2.02 2.02 2.02 2.02
Redwood City 8.76 8.72 9.07 9.07 9.07 9.07
San Bruno 0.95 3.39 3.40 3.40 3.40 3.40
San Jose 4.26 4.31 4.51 4.51 4.51 4.51
Santa Clara 3.27 3.29 3.50 3.50 3.50 3.50
Stanford 1.43 1.40 1.54 1.54 1.54 1.54
Sunnyvale 9.33 9.35 9.45 9.45 9.45 9.45
Westborough 0.82 0.84 0.81 0.81 0.81 0.81
Total 132.22 138.61 140.77 140.77 140.77 140.77
c
The SFPUC's supply reliability tables assume the Bay-Delta Plan takes effect in 2023. In the event of a shortage, the Tier 2 Plan specifies that each agencies' Allocation Factor would be calculated once at the onset of a shortage based on the previous year's use and remains the same until the shortage condition is over.

Therefore, for the purpose of drought allocations for the 5-year Drought Risk Assessment, wholesale RWS demand is assumed to remain static from 2022 through the drought sequence. b
Wholesale RWS purchase projections for 2021 and 2022 were provided to Christina Tang, BAWSCA's Finance Manager, by the Member Agencies in January 2021. 2020
Actual
Projected and Estimated Wholesale RWS Purchases
Table B: Basis for the 5-Year Drought Risk Assessment Wholesale RWS Actual Purchases in 2020 and 2021-2025 Projected Purchases (mgd)

2020e 2025 2030 2035 2040 2045
Projected Purchasesd 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 1st Dry Year 138.6 93.3 94.2 96.5 99.2 88.7 Consecutive 2nd Dry Year 140.8 80.0 80.8 82.7 85.1 88.7 Consecutive 3rd Dry Year 74.5 80.0 80.8 82.7 85.1 88.7
Consecutive 4th Dry Year 74.5 80.0 80.8 82.7 75.1 75.4
Consecutive 5th Dry Year 74.5 80.0 80.8 75.8 75.1 75.4
2020 2025 2030 2035 2040 2045
Projected Purchasesd 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 1st Dry Year 138.6 146.0 147.9 151.9 156.3 162.8 Consecutive 2nd Dry Year 140.8 146.0 147.9 151.9 156.3 162.8 Consecutive 3rd Dry Year 140.8 146.0 147.9 151.9 156.3 162.8 Consecutive 4th Dry Year 140.8 146.0 147.9 151.9 156.3 162.8 Consecutive 5th Dry Year 140.8 146.0 147.9 151.9 156.3 162.8 2020 2025 2030 2035 2040 2045
Projected Purchasesd 0% 0% 0% 0% 0% 0%
Consecutive 1st Dry Year 0% 36% 36% 36% 37% 46%
Consecutive 2nd Dry Year 0% 45% 45% 46% 46% 46%
Consecutive 3rd Dry Year 47% 45% 45% 46% 46% 46%
Consecutive 4th Dry Year 47% 45% 45% 46% 52% 54%
Consecutive 5th Dry Year 47% 45% 45% 50% 52% 54%
g
Agencies that wish to use new or different projected RWS purchases may use the percent cutbacks listed in this table to determine their drought allocation.

Table D: Wholesale RWS Demand (Combined Totals from Tables A and B) (mgd)f Table E: Percent Cutback to the Wholesale Customers With Bay-Delta Plang f
The SFPUC's modeling approach does not allow for varying demands over the course of a dry year sequence.

Additionally, the Tier 2 Plan calculates each agencies' Allocation Factor once at the onset of a drought and it remains the same until the shortage condition is over. When system-wide shortages are projected, wholesale RWS demand is assumed to be static for the remainder of the drought sequence. e
In years when the Bay-Delta Plan is not in effect, sufficient RWS supplies will be available to meet the Wholesale Customers’ purchase requests assuming that they are between the 2020 and 2025 projected levels.

As such, RWS supply available to the Wholesale Customers in the 1st and 2nd consecutive dry years under base year 2020 is equal to the cumulative projected wholesale RWS purchases for 2021 and 2022, respectively. d
Values for 2020 are actual purchases. This row aligns with what is labeled as an "Average Year" in Tables 3a3f in the SFPUC's March 30th letter. However, these values do not represent an average year and instead are actual purchases for 2020 or projected purchases for 2025 through 2045.

Section 2: Drought Allocations With Bay-Delta Plan
Table C: RWS Supply Available to the Wholesale Customers (Combined Tables 3a-3f from the SFPUC's March 30th letter) With Bay-Delta Plan (mgd)

Year 2020 2021 2022 2023 2024 2025
Consecutive Dry Year Actual 1st 2nd 3rd 4th 5th
Wholesale RWS Demand 132.2 138.6 140.8 140.8 140.8 140.8 Wholesale RWS Supply Available 132.2 138.6 140.8 74.5 74.5 74.5 Percent Cutback 0% 0% 0% 47% 47% 47%
Agency 2021 2022 2023 2024 2025
ACWD 7.87 9.44 9.46 5.01 5.01 5.01
Brisbane/GVMID 0.64 0.62 0.65 0.34 0.34 0.34
Burlingame 3.48 3.34 3.35 1.77 1.77 1.77
Coastside 1.02 1.54 1.23 0.65 0.65 0.65
CalWater Total 29.00 29.66 29.81 15.78 15.78 15.78
Daly City 3.97 4.00 4.01 2.12 2.12 2.12
East Palo Alto 1.57 1.63 1.69 0.89 0.89 0.89
Estero 4.34 4.48 4.51 2.39 2.39 2.39
Hayward 13.92 14.47 15.12 8.00 8.00 8.00
Hillsborough 2.62 2.95 3.05 1.61 1.61 1.61
Menlo Park 2.96 2.92 2.93 1.55 1.55 1.55
Mid-Peninsula 2.66 2.65 2.80 1.48 1.48 1.48
Millbrae 1.90 1.95 2.15 1.14 1.14 1.14
Milpitas 5.92 5.88 5.34 2.83 2.83 2.83
Mountain View 7.67 7.80 8.05 4.26 4.26 4.26
North Coast 2.37 2.58 2.66 1.41 1.41 1.41
Palo Alto 9.75 9.44 9.66 5.11 5.11 5.11
Purissima Hills 1.75 1.97 2.02 1.07 1.07 1.07
Redwood City 8.76 8.72 9.07 4.80 4.80 4.80
San Bruno 0.95 3.39 3.40 1.80 1.80 1.80
San Jose 4.26 4.31 4.51 2.39 2.39 2.39
Santa Clara 3.27 3.29 3.50 1.85 1.85 1.85
Stanford 1.43 1.40 1.54 0.82 0.82 0.82
Sunnyvale 9.33 9.35 9.45 5.00 5.00 5.00
Westborough 0.82 0.84 0.81 0.43 0.43 0.43
Total 132.2 138.6 140.8 74.5 74.5 74.5
Table F2: Individual Agency Drought Allocations [For Tables 7-1 and 7-5], Base Year 2020, With Bay-Delta Plan (mgd)
2020
Actual
Wholesale RWS Drought Allocations
Table F1: Basis of Water Supply Data [For Tables 7-1 and 7-5], Base Year 2020, With BayDelta Plan (mgd)

Consecutive Dry Year 1st 2nd 3rd 4th 5th
Wholesale RWS Demand 146.0 146.0 146.0 146.0 146.0
Wholesale RWS Supply Available 93.3 80.0 80.0 80.0 80.0 Percent Cutback 36% 45% 45% 45% 45%
Consecutive Dry Year 1st 2nd 3rd 4th 5th
ACWD 4.91 4.21 4.21 4.21 4.21
Brisbane/GVMID 0.57 0.49 0.49 0.49 0.49
Burlingame 2.76 2.37 2.37 2.37 2.37
Coastside 0.89 0.77 0.77 0.77 0.77
CalWater Total 19.16 16.43 16.43 16.43 16.43
Daly City 2.28 1.96 1.96 1.96 1.96
East Palo Alto 1.20 1.03 1.03 1.03 1.03
Estero 2.60 2.23 2.23 2.23 2.23
Hayward 11.41 9.78 9.78 9.78 9.78
Hillsborough 2.08 1.79 1.79 1.79 1.79
Menlo Park 2.27 1.95 1.95 1.95 1.95
Mid-Peninsula 1.83 1.57 1.57 1.57 1.57
Millbrae 1.46 1.25 1.25 1.25 1.25
Milpitas 4.21 3.61 3.61 3.61 3.61
Mountain View 5.49 4.71 4.71 4.71 4.71
North Coast 1.49 1.28 1.28 1.28 1.28
Palo Alto 6.43 5.51 5.51 5.51 5.51
Purissima Hills 1.33 1.14 1.14 1.14 1.14
Redwood City 5.40 4.63 4.63 4.63 4.63
San Bruno 2.07 1.77 1.77 1.77 1.77
San Jose 2.88 2.47 2.47 2.47 2.47
Santa Clara 2.88 2.47 2.47 2.47 2.47
Stanford 1.28 1.10 1.10 1.10 1.10
Sunnyvale 5.85 5.02 5.02 5.02 5.02
Westborough 0.55 0.47 0.47 0.47 0.47
Total 93.3 80.0 80.0 80.0 80.0
Table G2: Individual Agency Drought Allocations [For Tables 7-1 and 7-4], Base Year 2025, With Bay-Delta Plan (mgd)
Wholesale RWS Drought Allocations
Table G1: Basis of Water Supply Data [For Tables 7-1 and 7-4], Base Year 2025, With Bay-Delta Plan (mgd)

Consecutive Dry Year 1st 2nd 3rd 4th 5th
Wholesale RWS Demand 147.9 147.9 147.9 147.9 147.9
Wholesale RWS Supply Available 94.2 80.8 80.8 80.8 80.8 Percent Cutback 36% 45% 45% 45% 45%
Consecutive Dry Year 1st 2nd 3rd 4th 5th
ACWD 4.89 4.20 4.20 4.20 4.20
Brisbane/GVMID 0.56 0.48 0.48 0.48 0.48
Burlingame 2.80 2.40 2.40 2.40 2.40
Coastside 0.88 0.75 0.75 0.75 0.75
CalWater Total 18.94 16.25 16.25 16.25 16.25
Daly City 2.24 1.92 1.92 1.92 1.92
East Palo Alto 1.24 1.07 1.07 1.07 1.07
Estero 2.62 2.24 2.24 2.24 2.24
Hayward 11.90 10.21 10.21 10.21 10.21
Hillsborough 2.07 1.78 1.78 1.78 1.78
Menlo Park 2.35 2.01 2.01 2.01 2.01
Mid-Peninsula 1.81 1.55 1.55 1.55 1.55
Millbrae 1.59 1.37 1.37 1.37 1.37
Milpitas 4.30 3.69 3.69 3.69 3.69
Mountain View 5.67 4.86 4.86 4.86 4.86
North Coast 1.48 1.27 1.27 1.27 1.27
Palo Alto 6.47 5.55 5.55 5.55 5.55
Purissima Hills 1.33 1.14 1.14 1.14 1.14
Redwood City 5.41 4.64 4.64 4.64 4.64
San Bruno 2.05 1.76 1.76 1.76 1.76
San Jose 2.87 2.46 2.46 2.46 2.46
Santa Clara 2.87 2.46 2.46 2.46 2.46
Stanford 1.39 1.19 1.19 1.19 1.19
Sunnyvale 5.92 5.08 5.08 5.08 5.08
Westborough 0.54 0.47 0.47 0.47 0.47
Total 94.2 80.8 80.8 80.8 80.8
Table H2: Individual Agency Drought Allocations [For Tables 7-1 and 7-4], Base Year 2030, With Bay-Delta Plan (mgd)
Wholesale RWS Drought Allocations
Table H1: Basis of Water Supply Data [For Tables 7-1 and 7-4], Base Year 2030, With Bay-Delta Plan (mgd)

Consecutive Dry Year 1st 2nd 3rd 4th 5th
Wholesale RWS Demand 151.9 151.9 151.9 151.9 151.9
Wholesale RWS Supply Available 96.5 82.7 82.7 82.7 75.8 Percent Cutback 36% 46% 46% 46% 50%
Consecutive Dry Year 1st 2nd 3rd 4th 5th
ACWD 4.88 4.18 4.18 4.18 3.83
Brisbane/GVMID 0.56 0.48 0.48 0.48 0.44
Burlingame 2.84 2.44 2.44 2.44 2.23
Coastside 0.86 0.74 0.74 0.74 0.68
CalWater Total 18.94 16.23 16.23 16.23 14.88
Daly City 2.22 1.90 1.90 1.90 1.74
East Palo Alto 1.33 1.14 1.14 1.14 1.05
Estero 2.66 2.28 2.28 2.28 2.09
Hayward 12.55 10.75 10.75 10.75 9.86
Hillsborough 2.07 1.78 1.78 1.78 1.63
Menlo Park 2.46 2.10 2.10 2.10 1.93
Mid-Peninsula 1.83 1.57 1.57 1.57 1.44
Millbrae 1.56 1.34 1.34 1.34 1.22
Milpitas 4.47 3.83 3.83 3.83 3.51
Mountain View 5.84 5.01 5.01 5.01 4.59
North Coast 1.49 1.27 1.27 1.27 1.17
Palo Alto 6.53 5.60 5.60 5.60 5.13
Purissima Hills 1.34 1.15 1.15 1.15 1.06
Redwood City 5.49 4.70 4.70 4.70 4.31
San Bruno 2.03 1.74 1.74 1.74 1.60
San Jose 2.86 2.45 2.45 2.45 2.25
Santa Clara 2.86 2.45 2.45 2.45 2.25
Stanford 1.49 1.28 1.28 1.28 1.17
Sunnyvale 6.80 5.83 5.83 5.83 5.34
Westborough 0.54 0.46 0.46 0.46 0.42
Total 96.5 82.7 82.7 82.7 75.8
Table I2: Individual Agency Drought Allocations [For Tables 7-1 and 7-4], Base Year 2035, With Bay-Delta Plan (mgd)
Wholesale RWS Drought Allocations
Table I1: Basis of Water Supply Data [For Tables 7-1 and 7-4], Base Year 2035, With Bay-Delta Plan (mgd)

Consecutive Dry Year 1st 2nd 3rd 4th 5th
Wholesale RWS Demand 156.3 156.3 156.3 156.3 156.3
Wholesale RWS Supply Available 99.2 85.1 85.1 75.1 75.1 Percent Cutback 37% 46% 46% 52% 52%
Consecutive Dry Year 1st 2nd 3rd 4th 5th
ACWD 4.87 4.18 4.18 3.69 3.69
Brisbane/GVMID 0.56 0.48 0.48 0.43 0.43
Burlingame 2.91 2.49 2.49 2.20 2.20
Coastside 0.85 0.73 0.73 0.64 0.64
CalWater Total 19.21 16.48 16.48 14.54 14.54
Daly City 2.20 1.88 1.88 1.66 1.66
East Palo Alto 1.58 1.36 1.36 1.20 1.20
Estero 2.69 2.30 2.30 2.03 2.03
Hayward 13.21 11.34 11.34 10.00 10.00
Hillsborough 2.07 1.78 1.78 1.57 1.57
Menlo Park 2.58 2.21 2.21 1.95 1.95
Mid-Peninsula 1.84 1.58 1.58 1.39 1.39
Millbrae 1.79 1.53 1.53 1.35 1.35
Milpitas 4.62 3.96 3.96 3.49 3.49
Mountain View 6.03 5.18 5.18 4.57 4.57
North Coast 1.49 1.27 1.27 1.12 1.12
Palo Alto 6.67 5.72 5.72 5.05 5.05
Purissima Hills 1.35 1.16 1.16 1.03 1.03
Redwood City 5.55 4.76 4.76 4.20 4.20
San Bruno 2.03 1.74 1.74 1.54 1.54
San Jose 2.86 2.45 2.45 2.16 2.16
Santa Clara 2.86 2.45 2.45 2.16 2.16
Stanford 1.61 1.38 1.38 1.22 1.22
Sunnyvale 7.26 6.23 6.23 5.49 5.49
Westborough 0.54 0.46 0.46 0.41 0.41
Total 99.2 85.1 85.1 75.1 75.1
Table J2: Individual Agency Drought Allocations [For Tables 7-1 and 7-4], Base Year 2040, With Bay-Delta Plan (mgd)
Wholesale RWS Drought Allocations
Table J1: Basis of Water Supply Data [For Table 7-1 and 7-4], Base Year 2040, With Bay-Delta Plan (mgd)

Consecutive Dry Year 1st 2nd 3rd 4th 5th
Wholesale RWS Demand 162.8 162.8 162.8 162.8 162.8
Wholesale RWS Supply Available 88.7 88.7 88.7 75.4 75.4 Percent Cutback 46% 46% 46% 54% 54%
Consecutive Dry Year 1st 2nd 3rd 4th 5th
ACWD 4.97 4.97 4.97 4.22 4.22
Brisbane/GVMID 0.49 0.49 0.49 0.41 0.41
Burlingame 2.56 2.56 2.56 2.17 2.17
Coastside 0.72 0.72 0.72 0.61 0.61
CalWater Total 16.73 16.73 16.73 14.22 14.22
Daly City 1.87 1.87 1.87 1.59 1.59
East Palo Alto 1.58 1.58 1.58 1.34 1.34
Estero 2.39 2.39 2.39 2.03 2.03
Hayward 12.07 12.07 12.07 10.26 10.26
Hillsborough 1.78 1.78 1.78 1.51 1.51
Menlo Park 2.34 2.34 2.34 1.99 1.99
Mid-Peninsula 1.59 1.59 1.59 1.36 1.36
Millbrae 1.74 1.74 1.74 1.48 1.48
Milpitas 4.11 4.11 4.11 3.49 3.49
Mountain View 5.41 5.41 5.41 4.60 4.60
North Coast 1.28 1.28 1.28 1.09 1.09
Palo Alto 5.88 5.88 5.88 5.00 5.00
Purissima Hills 1.17 1.17 1.17 1.00 1.00
Redwood City 4.85 4.85 4.85 4.12 4.12
San Bruno 1.75 1.75 1.75 1.49 1.49
San Jose 2.45 2.45 2.45 2.08 2.08
Santa Clara 2.45 2.45 2.45 2.08 2.08
Stanford 1.47 1.47 1.47 1.25 1.25
Sunnyvale 6.59 6.59 6.59 5.61 5.61
Westborough 0.46 0.46 0.46 0.39 0.39
Total 88.7 88.7 88.7 75.4 75.4
Table K2: Individual Agency Drought Allocations [For Tables 7-1 and 7-4], Base Year 2045, With Bay-Delta Plan (mgd)
Wholesale RWS Drought Allocations
Table K1: Basis of Water Supply Data [For Tables 7-1 and 7-4], Base Year 2045, With Bay-Delta Plan (mgd)

2020 2025 2030 2035 2040 2045
Projected Purchasesi 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 1st Dry Year 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 2nd Dry Year 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 3rd Dry Year 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 4th Dry Year 132.2 146.0 147.9 151.9 156.3 139.1 Consecutive 5th Dry Year 132.2 146.0 147.9 151.9 156.3 139.1 2020 2025 2030 2035 2040 2045
Projected Purchasesi 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 1st Dry Year 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 2nd Dry Year 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 3rd Dry Year 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 4th Dry Year 132.2 146.0 147.9 151.9 156.3 162.8 Consecutive 5th Dry Year 132.2 146.0 147.9 151.9 156.3 162.8 2020 2025 2030 2035 2040 2045
Projected Purchasesi 0% 0% 0% 0% 0% 0%
Consecutive 1st Dry Year 0% 0% 0% 0% 0% 0%
Consecutive 2nd Dry Year 0% 0% 0% 0% 0% 0%
Consecutive 3rd Dry Year 0% 0% 0% 0% 0% 0%
Consecutive 4th Dry Year 0% 0% 0% 0% 0% 15%
Consecutive 5th Dry Year 0% 0% 0% 0% 0% 15%
h The SFPUC's modeling approach does not allow for varying demands over the course of a dry year sequence. However, the SFPUC has indicated that sufficient supplies are available to meet wholesale RWS demand so long as they reasonably stay within 2020 and 2040 levels. The SFPUC's modeling does not indicate cutbacks will be required till the 4th and 5th consecutive dry year at 2045 levels. i
Values for 2020 are actual purchases. This row aligns with what is labeled as an "Average Year" in Tables 4a4f in the SFPUC's March 30th letter. However, these values do not represent an average year and instead are actual purchases for 2020 or projected purchases for 2025 through 2045.

Table M: Wholesale RWS Demand (Combined Totals from Tables A and B) (mgd) Table N: Percent Cutback to the Wholesale Customers Without Bay-Delta Plan Section 3: Drought Allocations Without Bay-Delta Plan
Table L: RWS Supply Available to the Wholesale Customers (Combined Tables 4a-4f from the SFPUC's March 30th letter) Without Bay-Delta Plan (mgd)h

1st 2nd 3rd 4th 5th
162.8 162.8 162.8 162.8 162.8
162.8 162.8 162.8 139.1 139.1
0% 0% 0% Tier 2 Plan Tier 2 Plan
Consecutive Dry Year 1st 2nd 3rd 4th 5th
ACWD 9.11 9.11 9.11 8.20 8.20 10.0%
Brisbane/GVMID 0.89 0.89 0.89 0.74 0.74 16.8%
Burlingame 4.69 4.69 4.69 4.02 4.02 14.3%
Coastside 1.33 1.33 1.33 1.19 1.19 10.0%
CalWater Total 30.70 30.70 30.70 26.73 26.73 12.9%
Daly City 3.43 3.43 3.43 3.01 3.01 12.4%
East Palo Alto 2.89 2.89 2.89 2.68 2.68 7.3%
Estero 4.38 4.38 4.38 3.94 3.94 10.0%
Hayward 22.14 22.14 22.14 18.67 18.67 15.7%
Hillsborough 3.26 3.26 3.26 2.93 2.93 10.2%
Menlo Park 4.29 4.29 4.29 3.58 3.58 16.5%
Mid-Peninsula 2.93 2.93 2.93 2.63 2.63 10.0%
Millbrae 3.20 3.20 3.20 2.54 2.54 20.7%
Milpitas 7.53 7.53 7.53 6.55 6.55 13.1%
Mountain View 9.93 9.93 9.93 8.91 8.91 10.3%
North Coast 2.34 2.34 2.34 2.11 2.11 10.0%
Palo Alto 10.79 10.79 10.79 9.71 9.71 10.0%
Purissima Hills 2.15 2.15 2.15 1.41 1.41 34.5%
Redwood City 8.90 8.90 8.90 7.92 7.92 11.1%
San Bruno 3.21 3.21 3.21 2.60 2.60 19.1%
San Jose 4.50 4.50 4.50 2.95 2.95 34.5%
Santa Clara 4.50 4.50 4.50 2.95 2.95 34.5%
Stanford 2.70 2.70 2.70 2.27 2.27 16.0%
Sunnyvale 12.10 12.10 12.10 10.11 10.11 16.5%
Westborough 0.84 0.84 0.84 0.76 0.76 10.0%
Total 162.8 162.8 162.8 139.1 139.1
Table O2: Individual Agency Drought Allocations [For Tables 7-1 and 7-4], Base Year 2045, Without Bay-Delta Plan (mgd)
Table O1: Basis of Water Supply Data [For Tables 7-1 and 7-4], Base Year 2045, Without BayDelta Plan (mgd) Tier 2 Drought
Cutback
Wholesale RWS Drought Allocations
Consecutive Dry Year
Wholesale RWS Demand
Wholesale RWS Supply Available
Percent Cutback

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Final Environmental Impact Report
Serramonte Del Rey Campus Redevelopment
SCH# 2023060571
November 2023
In Consultation with
Prepared by

Serramonte Del Rey Campus Redevelopment i Draft Final EIR City of Daly City November 2023
Table of Contents
Section 1.0 Introduction....................................................................................................................1 Section 2.0 Draft EIR Public Review Summary ..................................................................................3 Section 3.0 Draft EIR Recipients........................................................................................................4 Section 4.0 Responses to Draft EIR Comments.................................................................................5 Section 5.0 Refinements to the Precise Plan ................................................................................131 Section 6.0 Draft EIR Text Revisions..............................................................................................140 Appendix A: Draft EIR Comment Letters
Appendix B: Draft EIR Comment Letter Attachments

Serramonte Del Rey Campus Redevelopment 1 Draft Final EIR City of Daly City November 2023
Section 1.0 Introduction
This document, together with the Draft Environmental Impact Report (Draft EIR), constitutes the Final Environmental Impact Report (Final EIR) for the Serramonte Del Rey Campus Redevelopment project.

1.1 Purpose of the Final EIR
In conformance with the California Environmental Quality Act (CEQA) and CEQA Guidelines, this Final EIR provides objective information regarding the environmental consequences of the proposed project. The Final EIR also examines mitigation measures and alternatives to the project intended to reduce or eliminate significant environmental impacts. The Final EIR is intended to be used by the City of Daly City and any Responsible Agencies in making decisions regarding the project.

Pursuant to CEQA Guidelines Section 15090(a), prior to approving a project, the lead agency shall certify that:
(1) The Final EIR has been completed in compliance with CEQA; (2) The Final EIR was presented to the decision-making body of the lead agency, and that the decision-making body reviewed and considered the information contained in the final EIR prior to approving the project; and
(3) The Final EIR reflects the lead agency’s independent judgment and analysis.

1.2 Contents of the Final EIR
CEQA Guidelines Section 15132 specify that the Final EIR shall consist of:
a) The Draft EIR or a revision of the Draft;
b) Comments and recommendations received on the Draft EIR either verbatim or in summary; c) A list of persons, organizations, and public agencies commenting on the Draft EIR; d) The Lead Agency’s responses to significant environmental points raised in the review and consultation process; and
e) Any other information added by the Lead Agency.

1.3 Public Review
In accordance with CEQA and the CEQA Guidelines (Public Resources Code Section 21092.5[a] and CEQA Guidelines Section 15088[b]), the City shall provide a written response to a public agency on comments made by that public agency at least 10 days prior to certifying the EIR. The Final EIR and all documents referenced in the Final EIR are available for public review at the City’s Planning Division office located at 333 90th Street, Daly City, CA 94015 on weekdays during normal business

Serramonte Del Rey Campus Redevelopment 2 Final EIR
City of Daly City November 2023
hours. The Final EIR is also available for review on the City’s website:
https://link.edgepilot.com/s/c4d7a134/mxgGDUo1yEKLLB8SOFJHUg?u=http://www.dalycity.org/fei r.

Serramonte Del Rey Campus Redevelopment 3 Final EIR
City of Daly City November 2023
Section 2.0 Draft EIR Public Review Summary
The Draft EIR for the Serramonte Del Rey Campus Redevelopment project, dated June 2023, was circulated to affected public agencies and interested parties for a 45-day review period from July 25, 2023 through September 8, 2023. The City of Daly City undertook the following actions to inform the public of the availability of the Draft EIR:
• A Notice of Availability (NOA) of Draft EIR was published on the City’s website (https://www.dalycity.org/1153/8941/Serramonte-Del-Rey-Campus-Redevelopment-) and filed at the County Clerk Recorder’s Office on July 25, 2023. • Notification of the availability of the Draft EIR was mailed to property owners and tenants within a 300 foot radius of the project boundary and other members of the public who had indicated interest in the project;
• The Draft EIR was delivered to the State Clearinghouse on July 25, 2023, as well as sent to various governmental agencies, organizations, businesses, and individuals (see Section 3.0 for a list of agencies, organizations, businesses, and individuals that received the Draft EIR); and
• Copies of the Draft EIR were made available on the City’s website (https://www.dalycity.org/1153/8941/Serramonte-Del-Rey-Campus-Redevelopment-) and at the City’s Planning Division office located at 333 90th Street, Daly City, CA 94015.

Serramonte Del Rey Campus Redevelopment 4 Final EIR
City of Daly City November 2023
Section 3.0 Draft EIR Recipients
CEQA Guidelines Section 15086 requires that a local lead agency consult with and request comments on the Draft EIR prepared for a project of this type from responsible agencies (government agencies that must approve or permit some aspect of the project), trustee agencies for resources affected by the project, adjacent cities and counties, and transportation planning agencies.

The NOA for the Draft EIR was sent to owners and occupants within 300 feet of the project site and to adjacent jurisdictions. The following agencies received a copy of the Draft EIR from the City or via the State Clearinghouse:
• California Air Resources Board
• California Coastal Commission
• California Department of Conservation
• California Department of Education
• California Department of Fish and Wildlife
• California Department of Fish and Wildlife, Bay Delta Region 3 • California Department of Fish and Wildlife, Marin Region 7 • California Department of Forestry and Fire Protection • California Department of Housing and Community Development • California Department of Parks and Recreation
• California Department of Transportation, District 4
• California Department of Water Resources
• California Highway Patrol
• California Native American Heritage Commission
• California Natural Resources Agency
• California Public Utilities Commission
• California Regional Water Quality Control Board, San Francisco Bay Region 2 • California State Lands Commission
• Department of General Services
• Department of Toxic Substances Control
• Office of Historic Preservation
• State Water Resources Control Board, Division of Drinking Water • State Water Resources Control Board, Division of Drinking Water, District 17 • State Water Resources Control Board, Division of Water Quality

Serramonte Del Rey Campus Redevelopment 5 Final EIR
City of Daly City November 2023
Section 4.0 Responses to Draft EIR Comments
In accordance with CEQA Guidelines Section 15088, this document includes written responses to comments received by the City of Daly City on the Draft EIR.

Comments are organized under headings containing the source of the letter and its date. The specific comments from each of the letters and/or emails are presented with each response to that specific comment directly following. Copies of the letters and emails received by the City of Daly City are included in their entirety in Appendix A of this document. Comments received on the Draft EIR are listed below. None of the comments raised on the Draft EIR represent new significant information that would warrant recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5(a).

Comment Letter and Commenter Page of Response
Federal and State Agencies.............................................................................................................. 14 A. California Department of Transportation (dated September 6, 2023)............................ 14 Regional and Local Agencies............................................................................................................ 19 B. San Francisco International Airport (dated August 10, 2023).......................................... 19 C. San Francisco Bay Regional Water Quality Control Board (dated September 8, 2023)... 22 Organizations, Businesses, and Individuals...................................................................................... 24 D. Nancy Lacsamana (dated July 30, 2023) .......................................................................... 24 E. Sabrina Brennan (dated July 31, 2023)............................................................................. 24 F. Grassetti Environmental Consulting (dated August 21, 2023)......................................... 25 G. Anonymous 1 (dated September 1, 2023) ....................................................................... 32 H. Anonymous 2 (dated September 1, 2023) ....................................................................... 33 I. Anonymous 3 (dated September 1, 2023) ....................................................................... 34 J. Anonymous 4 (dated September 1, 2023) ....................................................................... 34 K. Chloe Costa Amado (dated September 1, 2023).............................................................. 35 L. Christina Francisco (dated September 1, 2023)............................................................... 36 M. Casey Quon (dated September 1, 2023) .......................................................................... 37 N. Catherine Van Etten (dated September 1, 2023)............................................................. 37 O. Eduardo Silva Amado (dated September 1, 2023)........................................................... 38 P. Erick Campbell (dated September 1, 2023)...................................................................... 39 Q. Javier Lopez (dated September 1, 2023).......................................................................... 39 R. Kerry Quendens-Bonham (dated September 1, 2023)..................................................... 40 S. Monica Costa Amado (dated September 1, 2023)........................................................... 41

Serramonte Del Rey Campus Redevelopment 6 Final EIR
City of Daly City November 2023
T. Monica Bidegain (dated September 1, 2023)................................................................... 41 U. Matthew Piccardo (dated September 1, 2023)................................................................ 42 V. Patrick Robertson (dated September 1, 2023)................................................................. 43 W. Shasta Student 1 (dated September 1, 2023) .................................................................. 44 X. Shasta Student 2 (dated September 1, 2023) .................................................................. 44 Y. Andrew Sielen (dated September 3, 2023) ...................................................................... 45 Z. Emma Hartung (dated September 4, 2023) ..................................................................... 46 AA. Melissa Kallstrom (dated September 6, 2023)................................................................. 46 BB. Muchia Te (dated September 6, 2023)............................................................................. 48 CC. Cossart-Daly Law, A.P.C. (dated September 7, 2023) ...................................................... 49 DD. Althouse and Meade, Inc. (dated September 7, 2023) .................................................... 64 EE. Pacifica Social Justice (dated September 7, 2023) ........................................................... 81 FF. Debbie Santiago (dated September 7, 2023)................................................................... 85 GG. NAACP (dated September 8, 2023) .................................................................................. 86 HH. Daly City Community Garden Alliance (dated September 8, 2023)................................. 94 II. Nancy Lacsamana (dated September 8, 2023)............................................................... 120 JJ. Erick Campbell (received September 8, 2023) ............................................................... 122 KK. Nick Occhipinti (dated September 8, 2023) ................................................................... 123 LL. Sabrina Brennan (dated September 8, 2023)................................................................. 130

Serramonte Del Rey Campus Redevelopment 7 Final EIR
City of Daly City November 2023

4.1 Master Responses
A number of comments received during the public circulation of the Draft EIR raised similar concerns and questions; therefore, master responses have been prepared to respond to those common concerns/questions. The master responses address the following topics:
• Master Response 1: Demonstration Garden
• Master Response 2: Regional Housing Needs Allocation
• Master Response 3: Inclusionary Housing Ordinance and State Affordable Housing Law • Master Response 4: Project Description
• Master Response 5: Wetlands
• Master Response 6: Recreation
• Master Response 7: Tribal Cultural Resources
• Master Response 8: Alternatives
Master Response 1: Demonstration Garden
Several comments claim the demonstration garden on the project site should qualify as a unique or rare resource that should be protected as part of the CEQA process. CEQA does not define when a garden, park, or other recreational facility should be considered a significant resource, which indicates the lead agency has discretion, based on substantial evidence, in deciding whether to treat a recreational facility as a significant resource. In considering whether the demonstration garden should be treated as a protected resource under CEQA, the City considered whether it is a designated recreational use (i.e. included on official public agency maps), a historical resource (associated with important persons or events or designed by a master designer or featuring a unique design), or a unique biological habitat for special status species. Absent these characteristics or associations, a typical community garden, while understood to be a valuable resource to the community who uses it, would not rise to the standard of a protected resource under CEQA.

Examples of gardens in the Bay Area that would presumably be considered significant resources under CEQA include the San José Rose Garden (1927), the Tilden Regional Parks Botanic Garden in Berkeley (1940), and the Japanese Tea Garden in San Francisco (1894), in that each is an officially recognized facility with a long, storied history and/or association with important persons or events and have been considered integral, for nearly a century or more, to the community they are located in.

The demonstration garden on the project site is described in Section 2.2.1.1 of the Draft EIR (page 10). The Jefferson Union High School District (JUHSD) created the approximately 0.5 acre garden 20 years ago as a demonstration garden to be used by the adult education building on-site.1 Students and members of the public who signed up for gardening classes were allowed to use the 1 October 11, 2023 Ltr. From Jefferson Union High School District.

Serramonte Del Rey Campus Redevelopment 8 Final EIR
City of Daly City November 2023
demonstration garden. JUHSD has not offered gardening classes since 2007. In 2018, an application to list the demonstration garden as a “community garden” was submitted to the San Mateo County Office of Sustainability; however, the application was sent without JUHSD’s knowledge or authorization. The “community garden” designation was removed in 2019 per JUHSD’s request.

Since the discontinuation of gardening classes in 2007, the demonstration garden has been used sparingly by members of the public on an informal, unsanctioned basis. Security staff for the garden report an average of two to four people per week visiting the garden, and about half of these individuals visit for durations of 10 minutes or less. In addition, JUHSD has made it clear to the public that use of the demonstration garden is temporary and provisional. For these reasons, the demonstration garden is not an environmental resource that is rare or unique to the region. The Draft EIR has described the garden’s size, history, characteristics, and status so that the public and decision-makers are informed of the loss of the demonstration garden, should the project be approved and implemented.

Master Response 2: Regional Housing Needs Allocation
The proposed project is adding 1,235 residential units to the City, including 20 percent affordable units (13.5 percent low-income and 6.5 percent moderate-income), which is double the City required 10 percent affordable units. Thus, the proposed project would contribute towards the City’s Regional Housing Needs Allocation (RHNA) target for both market-rate and affordable housing. The City’s current RHNA targets are 1,971 market-rate units and 2,867 affordable units).

Requiring the project to provide additional affordable units beyond what is required by City’s Inclusionary Housing Ordinance is not relevant to the project’s environmental impacts under CEQA and, therefore, is not discussed in the Draft EIR. Additional information regarding the project and the City’s RHNA targets will be included in the City’s staff report. It is not expected or a requirement that each residential development project would provide a range of units in the precise distribution to match the City’s overall RHNA unit requirements for various income levels and types of units.

Some projects will provide the minimum affordable units specified by the City’s Inclusionary Ordinance, while others, including both this project and those projects designed to be 100% affordable housing developments, will exceed the minimum, and the City would monitor implementation of the Housing Element over this RHNA cycle to ensure the various unit income targets are met.

Master Response 3: Inclusionary Housing Ordinance and State Affordable Housing Law The project’s compliance with the City’s Inclusionary Housing Ordinance is discussed under Impact LU-2 in Section 3.11 Land Use of the Draft EIR (page 124). The project complies with the Inclusionary Housing Ordinance by providing a 20 percent affordable housing component, which is double the required 10 percent. It also offers units at affordability levels that are deeper than what is required by law, allowing for a more diverse population of project residents than what otherwise might be provided. Further after the publication of the Draft EIR, and in response to community input, it has been clarified that the amount of affordable housing required for the project is 20 percent of all constructed dwelling units. These additional units will be dispersed through all project parcels. The Draft EIR takes into account the inclusion of at least 10 percent affordable units into

Serramonte Del Rey Campus Redevelopment 9 Final EIR
City of Daly City November 2023
its analysis of environmental impacts, and additional required affordable housing was foreseen in the project description. The clarification of a 20 percent affordability component would not cause or increase an environmental impact. The timing and distribution of the affordable units across the project site, however, are not CEQA issues. All project units will be subject to the same restrictions on physical development, including density maximums. Moreover, both the project’s market-rate and affordable units will have the same amenities, meaning there would not be any land use incompatibilities or other physical discrepancies that would impact the environment. The City's Inclusionary Housing Ordinance requires that “[t]he quality of design and overall quality of construction of the inclusionary units shall be consistent with the design of all market-rate units in the residential development … have the same amenities as the market-rate units, including the same access to and enjoyment of common open space and facilities in the residential development.” (See City Ordinance Sec. 17.47.100.) The Affordable Housing Agreement for the Project will require that the inclusionary units on Parcels C-F shall be comparable to the other units on Parcels A through F of the Project, in terms of appearances, finishes, and features, and the inclusionary units shall be provided, or have access to, the same neighborhood amenities as the other units on Parcels A through F of the Project (e.g., parks and recreation trails). Assertions that units will be concentrated in a single portion of the project site, and that such units will be inferior in quality when compared to market-rate units, are not based on any facts or evidence in the record.

Some comments suggest that the Parcel B building amenities described in the DEIR must be made available to all residents of the Precise Plan area in order to comply with Health and Safety Code section 17929 (enacted by Assembly Bill 491). This is not required under State law, and does not raise any physical impacts with the potential to affect the environment. Health and Safety Code section 17929 requires that occupants of affordable units within a residential structure must have access to the same entrances, common areas, and amenities of that structure that are available to market rate occupants. (Health and Safety Code § 17929 (a)(1)). All units within the Parcel B development will have similar access and, as explained above, the project will ensure parity across all parcels. Accordingly, buildings on Parcels C-F will have access to the same entrances, common areas, and amenities of that building that are available to market rate occupants of that building, in accordance with Health and Safety Code section 17929. From an environmental standpoint, accessibility of units to a particular entrance, common areas, or amenity would not have any implications regarding emissions, noise, or other environmental topics. Regardless, as explained above, the project will ensure all units in all buildings be situated similarly.

Some commentors suggest that placement of majority of affordable units on a single parcel would violate the Unruh Civil Rights act and Fair Employment Housing Act (Cal. Civil Code § 51; Gov. Code § 12900 et seq), and could interfere with the City’s obligation to affirmatively further fair housing under State housing element law and avoid discrimination in any program or activity funded by the state of California. (See Gov. Code §§ 65584(e), 11135). These statutes are designed to prevent discrimination on the basis of recognized protected classes. The laws address important social issues and, as with similar local and other state rules identified above, do not implicate environmental issues under CEQA. Moreover, as stated above, all affordable units will be

Serramonte Del Rey Campus Redevelopment 10 Final EIR
City of Daly City November 2023
comparable to the market-rate units on Parcels A through F of the Project, in terms of appearances, finishes, and features, and the inclusionary units shall be provided, or have access to, the same neighborhood amenities as the other units on Parcels A through F of the Project. There is no basis for any claim that the Project's affordable housing units will discriminate against any person on the basis of a protected class. In addition to avoiding discrimination, the State mandates that cities take further "meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity." (Gov. Code §§ 65584(e).) The Project helps the City accomplish this by providing affordable housing well in excess of the 10% inclusionary housing requirement imposed under the Daly City Municipal Code, and ensuring the school district's student population, which is the least-funded population in San Mateo County, have better access to educational opportunities. A fundamental objective of the Project is to "advance an innovative land use master plan to attract investment, stabilize District finances, increase funding for student education and attract and retain highly qualified teachers and staff." (Draft EIR, page 18.) The assertions the commentors make about non-compliance with certain City ordinances or state laws are not environmental in nature, but rather consist of claims pertaining to legal and/or social issues, and are not discussed in the Draft EIR. Such issues are important, nevertheless, and additional information regarding the project’s compliance with the Inclusionary Housing Ordinance will be included in the City’s staff report.

Master Response 4: Project Description
Several comments contested the adequacy of the project description included in Section 2.2 of the Draft EIR (pages 3-18), specifically the description of the proposed Precise Plan and development on Parcels C-F. Specific development plans for these parcels have not been developed yet; however, the Draft EIR describes the maximum allowed development for each parcel in Table 2.2-1 and the maximum height allowed on each parcel (see page 4 of the Draft EIR). Analysis in the Draft EIR is based on the assumption that the maximum allowed residential units at the site of 1,235, and the maximum allowed commercial uses of 14,000 square feet, will be constructed. This provides the most conservative environmental analysis. In order to complete the Air Quality and GHG Assessment (Appendix C of the Draft EIR) and Noise and Vibration Assessment (Appendix K of the Draft EIR), JUHSD provided assumptions for the number of units to be built on Parcels C-F. Future building placements on Parcels C-F were based on figures provided in the proposed Precise Plan (see Appendix B of the Draft EIR). Based on this project information, the Draft EIR conservatively analyzed the proposed project’s impacts on the environment, including development on Parcels CF, utilizing the maximum development assumptions noted above. Insofar as commenters suggest the development of Parcels C-F must be described in the same detail as Parcel B, such is not required under any law, including CEQA. While development of some portions of the Project site include greater design level detail, the project is a precise plan, meaning it is a zoning entitlement.

While the exact buildout of this zoning district has not been designed, the precise plan contains detailed development standards, design guidelines, and other restrictions that provide the decisionmakers with a clear idea of the project’s scope and potential impacts on the environment.

Further design details for Parcel C-F would not add any meaningful information, including without

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limitation because the project, because of its infill location, is exempt from evaluation of its aesthetic impacts under state law.

Master Response 5: Wetlands
Several comments disagreed with the Draft EIR’s conclusion that the meadow and arroyo willows on-site do not qualify as state or federally protected wetlands. Checklist question c) under Biological Resources in Appendix G of the CEQA Guidelines specifically asks if a project would have a substantial adverse effect on state or federally protected wetlands. The City, as the Lead Agency, has the discretion, based on substantial evidence, to make a CEQA determination about whether there are wetlands protected under federal or state law on the project site. Other public agencies with independent regulatory authority over wetlands may reach their own, potentially different, conclusions when the project applicant proceeds to seek a determination, permit, or other approval from those agencies later in the development process. But as the Lead Agency, the City may consider thresholds of significance based on environmental standards that other agencies have adopted but which are generally applicable. As discussed under Impact BIO-3 of the Draft EIR (page 67), the City agrees with, and based the Draft EIR’s conclusions on, the findings of the Wetland Assessment (Appendix E of the Draft EIR) and the Biological Peer Review (Appendix F of the Draft EIR), both of which constitute substantial evidence as defined by CEQA, that the meadow on-site does not appear to qualify as a jurisdictional wetland; thus, it would not be considered a state or federally protected wetland. However, the City, as CEQA lead agency, is not in the Draft EIR making a jurisdictional determination under the US Clean Water Act, Porter-Cologne Water Quality Control Act, or Fish & Game Code, as those determinations, if the applicant were to proceed to implement the project, will ultimately be made later in the development process by separate public agencies charged with implementing those laws. The U.S. Army Corps of Engineers, the Regional Water Quality Control Board (RWQCB), and California Department of Fish & Wildlife may exert jurisdiction through their own procedural requirements separate from the CEQA process.

In addition, while the Draft EIR concludes that there are no state or federally protected wetlands on-site, the Draft EIR discusses impacts to special-status species, which may be present in the meadow, under Impact BIO-1 of the Draft EIR (pages 64-66).

Master Response 6: Recreation
The Demonstration Garden on the project site is not considered a recreation resource by the City of Daly City, as it is not identified in the City’s Park and Open Space Master Plan as a recreational use, and the garden is not being relied upon by the City to meet the recreation needs of the current and planned population of the City, as demonstrated in the General Plan EIR’s discussion of the future recreation needs from planned population growth, which omits any discussion of the garden. In addition, as discussed above in Master Response 1, JUHSD never officially sanctioned the public use of the garden, and a very limited number of community members (i.e., two to four) have been using the garden informally and without an expectation such use would be permanent. For these reasons, the garden was not considered a significant, recognized recreational resource and its removal was not considered a significant impact.

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The gymnasium on the project site is similarly not considered a recreational resource by the City.

The gymnasium is not open to the public for everyday use and current programs utilizing the gym have obtained permission from JUHSD. Specifically, JUHSD has indicated there are two groups who have permission to use its facilities for limited purposes, and that these program operators are allowed on the site on a month-to-month basis, and access is limited to the program operators and the individuals they invite to participate. Moreover, the gymnasium on the site is not relied upon in the City’s Parks and Open Space Master Plan as a resource relied upon to meet the City’s recreational needs. Finally, similar gymnasiums at public schools and recreational centers exist within the City; therefore, the removal of the gymnasium at the project site would not eliminate or significantly reduce this type of use from the City.

In addition, CEQA requires the Draft EIR to analyze whether a project would cause an increase in the use of existing recreational facilities such that substantial deterioration would occur, or if a project includes recreational facilities, would the construction of those facilities cause adverse impacts on the environment (see Section 3.16.2.1 of the Draft EIR, page 165). As discussed under Impact REC-1, the project proposes new park space for future residents to use and would be required to pay park in-lieu fees to offset recreational demand. Thus, impacts to gymnasiums within the City would be reduced to a less than significant level. As discussed under Impact REC-2, the demolition of the existing gymnasium and construction of new park space on-site would not result in any significant environmental impacts.

Master Response 7: Tribal Cultural Resources
Several comment letters contend that the Demonstration Garden on the project site should be considered a tribal cultural resource; however, these comment letters were not from designated tribal representatives. As discussed in Section 3.3 Cultural Resources (pages 71-77) and 3.18 Tribal Cultural Resources (191-193) in the Draft EIR, a Cultural Resources Study was prepared for the project that did not identify any known tribal cultural resources on-site. In addition, a Sacred Lands File search was requested from the Native American Heritage Commission (NAHC) and results came back negative. The NAHC provided a list of tribes associated with the project area, and those tribes (Amah Mutsun Tribal Band of Mission San Juan Bautista, Costanoan Rumsen Carmel Tribe, Indian Canyon Mutsun Band of Costanoan, Muwekma Ohlone Indian Tribe) were contacted by the City on June 30, 2021 for further consultation, per Assembly Bill (AB) 52 and Senate Bill (SB) 18. The City received no responses from designated tribal representatives; therefore, the City concluded consultation and determined that no known tribal cultural resources exist on-site.

In addition, tribal cultural resources are typically associated with pre-contact history, i.e. resources important to a tribe at the time of the arrival of Europeans, and not sites, features, objects developed by modern society. The Demonstration Garden was constructed in the last 20 years and is a modern day feature, and as such, would not meet the definition of a tribal cultural resource as defined by Section 15064.5 of the CEQA Guidelines. Finally, the Demonstration Garden does not exist in a natural landscape. The entire project site was graded and redeveloped for school uses decades ago, and in fact there is a tennis court and drainage infrastructure underlaying at least a

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significant portion of the Demonstration Garden. The setting is therefore a disturbed, urban environment. Accordingly, there are no historical, natural facilities, topography, or other features existing within the footprint of the Demonstration Garden.

Master Response 8: Alternatives
Section 7.0 of the Draft EIR (pages 209-216) discusses alternative to the proposed project. As required by CEQA, alternatives to the project should be identified to avoid or substantially lessen any significant effects of the project and still meet the project’s basic objective. As discussed throughout the Draft EIR, the proposed project would not result in any significant and unavoidable impacts. The project would only result in less than significant impacts with mitigation incorporated for the following environmental resource areas:
• Air Quality (construction criteria pollutants, TAC health risk) • Biological Resources (bats, nesting birds)
• Cultural Resources (archaeological resource/human remains) • Geology and Soils (paleontological resources)
• Hazards and Hazardous Materials (underground/aboveground storage tanks) • Noise (construction noise)
• Transportation (vehicle miles traveled, construction traffic, pedestrian/bicycle safety, emergency access)
• Tribal Cultural Resources (unknown buried tribal cultural resources) Of the impacts identified above, any type of development project requiring site/ground disturbance would result in similar impacts related to biological resources, cultural resources, geology and soils, hazards and hazardous materials, and tribal cultural resources. As such, alternatives to lessen these impacts were not considered in the Draft EIR. An alternative to preserve the Demonstration Garden was not included in the Draft EIR as the removal of the garden is not considered an environmental impact (see Master Responses 5, 6, and 7 above), and alternatives related the City’s Inclusionary Housing Ordinance and RHNA targets were not included as they are not CEQA impacts (see Master Response 2 and 3 above).

The Draft EIR considered alternatives that could substantially lessen the project’s air quality, noise, and vehicle miles traveled (VMT) impacts. Section 7.4.1 of the Draft EIR (211-212) identifies three alternatives that were considered but rejected due to either infeasibility (Location Alternative) or because they would not substantially lessen the project’s impact (Mixed-Use Alternative and Reduced Housing Alternative). No other feasible alternatives were identified by the City; therefore, the Draft EIR included the No Project Alternative and the No Project – Existing Zoning Alternative as the only analyzed alternatives. As discussed in Section 7.4.2.2 of the Draft EIR (pages 214-215), the No Project – Existing Zoning Alternative also acted as a reduced development alternative given the total square footage at build-out under existing zoning is anticipated to be 500,000 square feet less than the proposed project.

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Federal and State Agencies
A. California Department of Transportation (dated September 6, 2023) Comment A.1: Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the Serramonte Del Rey Campus Redevelopment Project. We are committed to ensuring that impacts to the State’s multimodal transportation system and to our natural environment are identified and mitigated to support a safe, sustainable, integrated and efficient transportation system.

The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities. The following comments are based on our review of the July 2023 DEIR.

Project Understanding
This project proposes to redevelop the site of the Jefferson Union High School District office buildings into a mix use development. It would have up to 1,235 units of affordable housing and market-rate rental housing with 14,000 square feet of retail and commercial use space. The project site is located across the on- and off-ramps at Serramonte Blvd.

Response A.1: This is an introductory statement; therefore, no further response is required.

Comment A.2: Travel Demand Analysis
With the enactment of Senate Bill (SB) 743, Caltrans is focused on maximizing efficient development patterns, innovative travel demand reduction strategies, and multimodal improvements. For more information on how Caltrans assesses Transportation Impact Studies, please review Caltrans’ Transportation Impact Study Guide (link).

The project VMT analysis and significance determination are undertaken in a manner consistent with the Office of Planning and Research’s (OPR) Technical Advisory. Per the DEIR, this project is found to have less than significant impacts with mitigation. Caltrans commends the Lead Agency in developing the Transportation Demand Management (TDM) Plan to reduce employee and guest VMT, therefore working towards meeting the State’s goal of a 15-percent reduction. The proposed measures identified in the TDM plan should be documented with annual monitoring reports to demonstrate effectiveness.

Please reach out to Caltrans for further information about TDM measures and a toolbox for implementing these measures in land use projects. Additionally, refer to the California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (link).

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Response A.2: Mitigation measure MM TRN-2.1 (page 179 of the Draft EIR) requires annual monitoring for the first six years of project occupancy.

Comment A.3: State Projects within Vicinity
The following Caltrans’ projects are planned and included in the State Highway Operation and Protection Program (SHOPP), the State’s “fix-it-first” program that funds the repair, safety improvements, some highway operational improvements, and preservation of the State Highway System (SHS).

Response A.3: These state highway improvement projects are noted. Both were not listed as cumulative projects in the Draft EIR as the first one involves stormwater and trash management efforts on the state highways and would be completed prior to the construction start of proposed project, and the second one would involve negligible construction. This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.

Comment A.4: Transportation Impact Fees
Please identify project-generated travel demand and estimate the costs of transit and active transportation improvements necessitated by the proposed project; viable funding sources such as development and/or transportation impact fees should also be identified. We encourage a sufficient allocation of fair share contributions toward multi-modal and regional transit improvements to fully mitigate cumulative impacts to regional transportation. We also strongly support measures to increase sustainable mode shares, thereby reducing VMT.

Response A.4: The Draft EIR estimates that project would generate 170 new transit users (see page 176 of the Draft EIR). These transit users are expected to use BART and SamTrans routes 24 and 120. The Draft EIR concluded that the additional 170 transit users would not exceed the capacity of existing bus or BART services within the project area; thus, no additional transit improvements are proposed as part of the project. The project would implement mitigation measure MM TRN-2.1, which includes Transportation Demand Management (TDM) strategies to increase mode share. As part of the Development Agreement (DA), the applicant shall pay for and

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implement the majority of the off-site improvement identified on page 11 of the Draft EIR: in addition, the applicant shall make two separate cash contributions to the City. One to implement off-site park, bicycle, and/or pedestrian improvements at the City’s discretion, and another to help fund the Clarinda Avenue/Highway 1 intersection signalization. The City has determined that these contributions address any project-specific impacts and in fact confer, pursuant to the project’s development agreement, community benefits that leave the local circulation network in a condition that is superior when compared to existing conditions.

Comment A.5: Construction-Related Impacts
Potential impacts to the State Right-of-Way (ROW) from project-related temporary access points should be analyzed. Mitigation for significant impacts due to construction and noise should be identified. Project work that requires movement of oversized or excessive load vehicles on State roadways requires a transportation permit that is issued by Caltrans. To apply, please visit Caltrans Transportation Permits (link).

Response A.5: The need for a transportation permit for oversize construction vehicles is noted. Impacts related to construction of the proposed project are discussed throughout the Draft EIR, including potential impacts on State ROWs. MM AIR-2.1 requires the project to implement Bay Area Air Quality Management District’s (BAAQMD’s) recommended best management practices (BMPs) and additional measures to reduce construction equipment exhaust emissions. MM AIR2.2 requires the project to meet emissions standards for certain construction equipment. Impacts specific to noise are discussed in Section 3.13 of the Draft EIR (pages 128-148), and MM NOI-1.1 requires that project to develop a construction noise control plan for each construction phase. The Draft EIR includes a specific analysis of the impacts of construction traffic on existing vehicle traffic near the project site (page 180), and MM TRN-3.1 requires the project to prepare and implement a Construction Traffic Management Plan to minimize impacts of project construction on the transportation system. Each of the aforementioned mitigation measures will reduce construction impacts to a less-than-significant level.

Comment A.6: Prior to construction, coordination may be required with Caltrans to develop a Transportation Management Plan (TMP) to reduce construction traffic impacts to the STN.

Response A.6: The project shall implement mitigation measure MM TRN-3.1, which requires the project to prepare a Construction Traffic Management Plan. The City is open to coordinating with Caltrans on implementation of the plan.

Comment A.7: Lead Agency
As the Lead Agency, the City of Daly City is responsible for all project mitigation, including any needed improvements to the State Transportation Network (STN). The project’s fair share

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contribution, financing, scheduling, implementation responsibilities and lead agency monitoring should be fully discussed for all proposed mitigation measures.

Response A.7: The Draft EIR evaluated impacts on off-site circulation networks, including State facilities, with respect to both CEQA topics (e.g., vehicle miles traveled and safety considerations) and non-CEQA topics (e.g., traffic congestion).

This latter category of impact was included for information only. The DEIR determined there would be no impacts to any pertinent portion of the State Transportation Network, and therefore appropriately does not include any mitigation measures that.

Comment A.8: Equitable Access
If any Caltrans facilities are impacted by the project, those facilities must meet American Disabilities Act (ADA) Standards after project completion. As well, the project must maintain bicycle and pedestrian access during construction. These access considerations support Caltrans’ equity mission to provide a safe, sustainable, and equitable transportation network for all users.

Response A.8: As discussed under Impact TRN-1 in Section 3.17 Transportation of the Draft EIR (page 177), all pedestrian facilities improved by the project would be ADA compliant. In addition, the project would implement mitigation measure MM TRN-3.1, which requires the project to provide safe and adequate pedestrian and bicycle access during project construction.

Comment A.9: Encroachment Permit
In Section 3.17, two planned improvements are mentioned involving the intersection of State Route (SR)-1/ Clarinada and of SR-1/ Serramonte Boulevard. Please be advised that any permanent work or temporary traffic control that encroaches onto Caltrans’ ROW requires a Caltrans-issued encroachment permit. As part of the encroachment permit submittal process, you may be asked by the Office of Encroachment Permits to submit a completed encroachment permit application package, digital set of plans clearly delineating Caltrans’ ROW, digital copy of signed, dated and stamped (include stamp expiration date) traffic control plans, this comment letter, your response to the comment letter, and where applicable, the following items: new or amended Maintenance Agreement (MA), approved Design Standard Decision Document (DSDD), approved encroachment exception request, and/or airspace lease agreement. Your application package may be emailed to [email protected].

To obtain information about the most current encroachment permit process and to download the permit application, please visit Caltrans Encroachment Permits (link).

Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter, please contact Marley Mathews, Transportation Planner, via LDR[email protected].

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For future early coordination opportunities or project referrals, please contact [email protected].

Response A.9: The need for an encroachment permit for work within Caltrans rightof-way is noted. This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.

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Regional and Local Agencies
B. San Francisco International Airport (dated August 10, 2023) Comment B.1: Thank you for notifying the San Francisco International Airport (SFO or the Airport) of the availability of the Draft Environmental Impact Report (DEIR) for the Serramonte Del Rey Campus Redevelopment Project (Proposed Project), located in the City of Daly City (City). We appreciate this opportunity to review and provide comments on the DEIR.

As described in the DEIR, the Proposed Project is located on the south side of Serramonte Boulevard between the intersections of Callan Boulevard/Serramonte Boulevard and St. Francis Boulevard/Serramonte Boulevard on an approximately 22-acre site (Assessor’s Parcel Number 091- 211-230). The site is occupied by the following land uses: a 1960s-era building containing nonprofit organizations and offices for the Jefferson Union High School District (JUHSD); some temporary buildings; surface parking; and a construction staging area for the JUHSD faculty and staff housing project.

In 1985, the City approved the Serramonte Del Rey Precise Plan (1985 Precise Plan) for a larger 50- acre area that includes the Proposed Project site. Phase I of the 1985 Precise Plan, which covered the 28-acre area to the south of the Proposed Project site, has been implemented, and Phase II allows for the development of up to 175 residential units and approximately 700,000 square feet of office space on the Proposed Project site.

The Proposed Project consists of a new Serramonte Del Rey Precise Plan (2023 Precise Plan) and a specific development project at the northeast corner of the site. The 2023 Precise Plan would replace Phase II of the 1985 Precise Plan; it would divide the Proposed Project site into six parcels and allow for the development of up to 1,235 residential units, approximately 14,000 square feet of retail space, a 1,400-square-foot childcare facility, and various infrastructure improvements.

Allowable building heights under the 2023 Precise Plan would range from 77 feet to 150 feet.

The specific development project, which would be on Parcel B at the northeast corner of the site, consists of demolishing the existing temporary education building and surface parking lot and constructing a seven-story building containing 201 residential units and approximately 8,000 square feet of retail space.

Response B.1: This is an introductory comment and restates the proposed project.

No further response is required.

Comment B.2: The Proposed Project site is within two Airport Influence Areas (AIAs): Area A – Real Estate Disclosure Area (all of San Mateo County) and Area B – Policy/Project Referral Area (a smaller subarea in the northern part of San Mateo County), as defined by the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP). Within Area A, the real estate disclosure requirements of state law apply (see attachment). A property

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owner offering a property for sale or lease must disclose the presence of planned or existing airports within two miles of the property. Within Area B, the Board of Directors of the City/County Association of Governments of San Mateo County, acting as the designated Airport Land Use Commission (ALUC), shall review proposed land use policy actions, including new general plans, specific plans, zoning ordinances, plan amendments and rezonings, and land development proposals (see attachment). The real estate disclosure requirements in Area A also apply in Area B.

The Proposed Project site is located outside of the 65-decibel Community Noise Equivalent Level (CNEL) contour and all safety compatibility zones and, therefore, the Proposed Project would not appear to be inconsistent with the Noise and Safety Compatibility Policies adopted in the SFO ALUCP.

As described in Exhibit IV-17 of the SFO ALUCP (see attachment), the critical aeronautical surfaces at the Proposed Project location are at an elevation of approximately 800 feet above mean sea level (AMSL) as defined from the origin of the North American Vertical Datum of 1988. The elevation of the Proposed Project site is approximately 485 feet AMSL. The maximum building height proposed under the Precise Plan is 150 feet above ground level (AGL), and the height of the Parcel B development project is 85 feet AGL, measured to the top of the elevator penthouse. Both of these heights would be below the height of the lowest critical aeronautical surfaces (315 feet AGL), and the Proposed Project would not appear to be inconsistent with the Airspace Protection Policies of the SFO ALUCP, subject to the issuance of a Determination of No Hazard from the Federal Aviation Administration (see below) for any proposed structures and determinations from the City/County Association of Governments of San Mateo County as the designated ALUC.

Response B.2: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.

Comment B.3: This evaluation does not waive the requirement for the Proposed Project sponsor to undergo Federal Aviation Administration airspace review as described in 14 Code of Federal Regulations Part 77 for both (1) the permanent structures and (2) any equipment taller than the permanent structures required to construct those structures.

Response B.3: On September 9, 2021, both the proposed Precise Plan and Parcel B Development Project were reviewed by the San Mateo County Airport Land Use Commission and were approved for consistency with the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francsico International Airport.

Comment B.4: The Airport recommends the following revisions (deletions shown in strikethrough and new text shown in double underline) on page 102 of the DEIR:

San Mateo County Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport

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Daly City is within the jurisdiction of the San Francisco Airport (SFO) Land Use Plan component of the San Mateo County Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport (SFO ALUCP), adopted in December 1996 and updated in 2001 November 2012. Established in the CLUP SFO ALUCP are procedures used by the San Mateo City and County Association of Governments (C/CAG) to review land use decisions in the vicinity of San Mateo County airports Francisco International Airport. Airport planning boundaries define where height, noise and safety standards, policies, and criteria are applied to certain proposed land use policy actions.

The Airport recommends the following revisions (deletions shown in strikethrough and new text shown in double underline) to the last paragraph on page 104 of the DEIR:

The project site is located within the SFO CLUP ALUCP Airport Influence Area B, which requires projects to be consistent with the goals and policies of the CLUP SFO ALUCP. The project site is approximately five miles northwest from the runway termination point of the San Francisco International Airport, beyond the outer boundary of safety compatibility zones and outside of the Community Noise Equivalent Level (CNEL) noise contours for the airport, as delineated in the CLUP SFO ALUCP.

The text at the bottom of page 128 of the DEIR includes a cross reference to Section 4.10, Land Use, but Section 4.10 does not exist. Furthermore, the Land Use section of the DEIR does not discuss airport land use compatibility issues. The Airport recommends the following revisions (deletions shown in strikethrough and new text shown in double underline) to the text at the bottom of page 128 and the top of page 129 of the DEIR:

Comprehensive Airport Land Use Compatibility Plan for the Environs of the San Francisco International Airport
As discussed in more detail in Section 4.10 Land Use, tThe project site is located within the Airport Influence Area (AIA) of the San Francisco International Airport (SFO). Properties within the AIA may be subject to some of the annoyances or inconveniences associated with proximity to airport operations (e.g., noise, vibration, and odors). The airport/land use compatibility of a proposed development or land use policy action shall be determined by comparing the proposed development or land use policy action with the safety compatibility criteria, noise compatibility criteria, and airspace protection/height limitation criteria in the SFO ALUCP. The site is located outside of the SFO 65 dB CNEL noise contour.

Response B.4: The City agrees with the suggested clarifications to the land use plan name and typos. Please refer to Section 5.0 Draft EIR Text Revisions below for revised text.

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C. San Francisco Bay Regional Water Quality Control Board (dated September 8, 2023) Comment C.1: We have reviewed Draft Environmental Impact Report (DEIR) (State Clearinghouse No. 2023060571) for the Serramonte Del Rey Campus Redevelopment (Project). The Project consists of development of a new approximately 22-acre Serramonte Del Rey Precise Plan and a specific development proposal for the approximately 4.3-acre Parcel B within a portion of the new Precise Plan.

We appreciate the importance of redevelopment projects that include affordable and market-rate rental housing as well as infrastructure improvements. However, we have concerns about the existing wetlands on-site and the corresponding Wetland Assessment provided in Appendix E of the DEIR. Specifically, we are concerned that there has been a wetlands jurisdictional determination made without consultation with the Water Board. Moving forward that jurisdictional determination, without securing Waste Discharge Requirements (WDRs), via the Porter-Cologne Act, from the Water Board, or a concurrence that no state regulated wetlands exist at the site, is not recommended because we do not agree with the assertion made in the DEIR that waters of the State do not exist that the Project site.

Comments on Appendix E, Wetland Assessment
The memo in Appendix E states that the Porter-Cologne Act’s jurisdiction does not extend to the site, but the reasons provided in Appendix E are not sufficient to determine whether jurisdictional waters of the State exist at the site. Furthermore, the Water Board, as the agency that issues WDRs, has not been consulted about this jurisdictional determination.

The Water Board does not agree with the basis used in determining whether the on-sites wetlands are waters of the State. The jurisdictional determination made regarding the wetlands on-site is premised on the assumptions that 1) the wetland does not meet the U.S. Army Corps of Engineers’(Corps) three-wetland parameter test, and 2) the wetlands are artificial and transient.

First, a jurisdictional wetland determination (JD) does not appear to have been conducted. Instead, the memo in Appendix E references excerpts from the Exhibits therein, which do not make any definitive determinations regarding whether wetlands exist. Both Exhibits in Appendix E were conducted to assess the site drainage. A JD must be conducted to verify whether there are hydric soils, wetland vegetation, and wetland hydrology. Additionally, Procedures for Discharges of Dredged of Fill Material to Waters of the State (Dredge and Fill Procedures) states that only two of the three Corps parameters must be fulfilled to qualify as a State regulated wetland. Second, Appendix E focuses on excerpts from Dredge and Fill Procedures that are taken out of context and misinterprets the terms “transient” and “artificial” regarding regulated waterbodies. For example, seasonal wetlands, intermittent streams, and ephemeral streams, are all transient waterbodies that are waters of the State. Under the Dredge and Fill Procedures, an area is defined as wetland as follows: “An area is wetland if, under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2) the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation.”

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This definition is further elaborated on in the Dredge and Fill Procedures, but the on-site wetland can still be a water of the State if it was formed from a lack of maintenance over the years and is currently functioning as a wetland without intervention, which appears to be the case on-site. We encourage you to coordinate with the Water Board to further examine the on-site wetlands to verify whether or not State wetlands exist and determine whether WDRs are required to fill the wetlands.

Projects with potential fill-related impacts to State waters, such as the Project, must first demonstrate their design avoids and minimizes those impacts to the extent practicable. As part of the WDRs process, we will require a thorough analysis of all the proposed alternatives, including their long-term indirect effects. The Water Board adopted U.S. Environmental Protection Agency’s Section 404(b)(1), “Guidelines for Specification of Disposal Sites for Dredge or Fill Material,” dated December 24, 1980, in its Basin Plan and Dredge and Fill Procedures for determining the circumstance under which filling of waters of the State may be permitted. The Section 404(b)(1) Guidelines and Dredge and Fill Procedures prohibit discharges of fill material into waters of the United States and in the case of the Dredge and Fill Procedures, waters of the State, unless a discharge, as proposed, constitutes the least environmentally damaging practicable alternative that will achieve the project purpose. To accomplish this, the Guidelines and Procedures sequence the order in which proposals must be approached: 1) Avoid - avoid impacts to waters; 2) Minimize – once impacts have been avoided to the maximum extent practicable, modify the project to minimize impacts to waters; and 3) Compensate – once impacts have been fully minimized, compensate for unavoidable impacts to waters.

Summary
We are supportive of the Project’s intent, but the determination regarding jurisdictional waterbodies at the Project site must be made by the Water Board. The arguments for why the wetlands on-site are not considered waters of the State is insufficient, and a JD must be conducted, and the Water Board must be consulted about potentially jurisdictional features to determine whether WDRs are needed. We look forward to hearing from and working on this Project as it moves forward. If you have any questions, please do not hesitate to reach out.

Response C.1: Please refer to Master Response 5: Wetlands above.

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Organizations, Businesses, and Individuals
D. Nancy Lacsamana (dated July 30, 2023)
Comment D.1: pg 161
Serramonte condominiums/ Daly City is noted as being in the Brisbane School district.

It is not. location 525-595 Serramonte Blvd. on table 3.0-1 Response D.1: The Serramonte Condominiums project is located within the Jefferson Elementary School District. This error has been corrected. Please refer to Section 5.0 Draft EIR Text Revisions for corrected discussion.

E. Sabrina Brennan (dated July 31, 2023)
Comment E.1: Please provide a current draft of the SOR development agreement. Based on the DEIR it appears the JUHSD project has changed since the City Council last discussed it at a public meeting. We would like to know what's included in the development agreement. Please also provide the time line for completing the development agreement.

Response E.1: The development agreement is in draft form as it is being negotiated between the City and applicant. The off-site improvements contemplated in the development agreement are described in the Draft EIR Section 2.2.2.1., and the EIR has been written to cover the development agreement as one of the discretionary actions required for the project. The terms under negotiation do not involve physical improvements, but concern legal terms regarding risk allocation and other nontangible issues. There is no potential for these negotiations to alter the physical scope of the project and affect the project’s environmental analysis.

Comment E.2: I noticed that the links provided in NOP letters are not working in the DEIR. Please provide working links here:https:ljlink.edgepilot.com/s/38461664/bBzNCQrJdkCXS4pthPSzA?u=https://www.dalycity.org/DocumentCenter/View/7812/Appendix-ANOPComments?bidId%3D.

I mean the links included in various NOP letters are not working, they are published here: https://Iink.edgepilot.com/s/38461664/bBzNCQrJdkCXS4pthPSzA?u=https://www.dalycity.org/DocumentCenter/View/7812/Appendix-A-NOPComments ?bidld%3D.

The public should be able to click on working links provided in NOP letters. It appears you stripped out all the links so we cannot read the letters as they were intended by the sender.

Response E.2: Links in the NOP letters on the City’s website were fixed.

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Comment E.3: The links appear to be working now.

Are you planning to include letters from the NAACP, other organizations and individuals? Link to Sierra Club Letters:
https://link.edgepilot.com/s/cffab6ee/csUuYiF8BkmXPnlroHo1WA?u=https://www.communitygard enalliance.org/sierra-club-letters
Link to NAACP Letters:
https://link.edgepilot.com/s/4547fa78/MbR_Btrfn0GwUUU4G5b5Uw?u=https://www.communityg ardenalliance.org/naacp-letters
Link to Pacifica Social Justice Letter:
https://link.edgepilot.com/s/f91f3444/nm5Xdq9mYU6tqDI4Mcm0sg?u=https://www.communityga rdenalliance.org/pacifica-social-justice
Response E.3: The Sierra Club letter mentioned in the comment above is included in Appendix A of the Draft EIR. The two other letters from the NAACP and Pacifica Social Justice were sent a year after the initial NOP period between May 7, 2021 and June 7, 2021; therefore, they are not included in Appendix A, but are part of the public record for the project. None of the above letters include comments about the Draft EIR as they were written before the Draft EIR was circulated; therefore, no further response is required.

F. Grassetti Environmental Consulting (dated August 21, 2023) Comment F.1: Grassetti Environmental Consulting (GECo) is submitting this comment letter on the Serramonte Del Rey Project Draft EIR on behalf of Pacifica Social Justice. As GECo’s Principal, I have reviewed the document and offer comments on three issue areas: Project Description, Inclusionary Housing, and Alternatives. My experience includes over 40 years of preparing, reviewing, and teaching about the California Environmental Quality Act (CEQA) processes and documents. My qualifications are attached to this letter.

As detailed below, the DEIR is deficient in fully and accurately describing the project, its analysis of inclusionary housing policy conformance, and the range of alternatives considered in the document.

In addition, the DEIR fails to correctly describe and characterize the use of, and potential impacts on, the approximately 1-2-acre community garden on the project site.

Response F.1: This is an introductory comment that summarizes the comment letters main concerns. Please refer to the responses below regarding specific issues raised by comment letter.

Comment F.2: Discussion

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Project Description Issues
An “accurate, stable, and finite project description” “is the sine qua non of an informative and legally sufficient EIR.” (Save Our Capitol! v. Department of General Services (2023) 87 Cal.App.5th 655, 673.). Further, The project description shouldn’t supply extensive detail beyond that needed to evaluate the project’s environmental impacts, but should contain a sufficient degree of analysis to allow decisionmakers to make an informed decision intelligently considering environmental consequences; impact evaluation needn’t be exhaustive, and is reviewed in light of what is reasonably feasible, with courts looking not for perfection, but adequacy, completeness, and a good faith effort at full disclosure. (Tiburon, at 738, 726; CEQA Guidelines, §§ 15124, 15151.) The DEIR’s Project Description describes in detail an entirely unrelated project (the District Offices Project – Figure 2.2-6) yet fails to identify any potential development plans on Areas C-F of the project site. That said, the hydrology section includes impervious/pervious surface calculations down to the exact square foot. Similarly, the noise analysis identifies each specific piece of equipment and duration of operation for each of the project phases.

Response F.2: The JUHSD District Office and Adult Education site plan shown on Figure 2.2-6 of the Draft EIR was included to disclose that the existing demonstration garden would be replaced at JUHSD’s new adult education building.

The proposed Precise Plan is described in Section 2.2.1 of the Draft EIR (pages 3-10) and development plans for Parcels C-F are shown in Table 2.2-1 of the Draft EIR (page 4). The post-construction impervious/pervious surfaces calculations are based on preliminary open space, infrastructure, and building layouts provided by the applicant. Construction equipment identified in the air quality and noise analyses are based on CalEEMod defaults for the proposed project type (e.g., residential, commercial), size, and acreage. The project applicant provided the anticipated construction phasing and duration of the project. Please also refer to Master Response 4: Project Description above.

Comment F.3: The Precise Plan is available on the District’s website (https://www.juhsd.net/site/handlers/filedownload.ashx?moduleinstanceid=5196&datai d=8067&FileName=Serramonte%20Del%20Rey%20Precise%20Plan_Draft%20Precise%20Pl an.pdf) yet it is not described in the DEIR, which includes only the parcel plan (Figure 2.2-5) and Area B plans from the Precise Plan. The DEIR fails to show even the most basic development plans other than for Areas A and B – no access improvements, no infrastructure improvements, no general site layout, no maximum building heights, nothing.

Response F.3: Please refer to Master Response 4: Project Description above.

Comment F.4: Further, the Precise Plan shows most of the trees surrounding the site being retained (see, for example, Figures 3.4, Street Frontage, and 4.2, Vehicular Circulation in the Precise Plan). In fact, the Precise Plan states,

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“A distinguishing feature of the Precise Plan are the hillsides to the west and east of the plan area which contain numerous trees, all trees planted as part of development of District property. Trees range from young to mature, are in varying health and are densely planted.

The intent is to care for the hillside wooded areas to reduce fire hazards, enhance existing vegetation and promote urban forestry. A tree succession plan for aging mature trees will guide the replacement of existing trees over time due to age or fire vulnerability. Removed trees will be replaced with a diverse plant ecology governed by the area’s unique coastal/Mediterranean climate including evergreen and deciduous species.” However, the EIR analyses appear to assume that most of the existing trees (and the community garden) will be removed. Similarly, the visual simulations contained in the Precise Plan also show them being removed. The DEIR Project Description is mute on the topic. These contradictions and lack of detail in the DEIR result in an unstable Project Description, which is inadequate for the environmental analysis.

Response F.4: The proposed Precise Plan does not include detailed site plans for Parcels C-F; therefore, the number of trees to be removed or preserved is currently unknown, but will be defined as applications for specific buildings are filed for each parcel. Specific tree removal and planting details are available for the Parcel B Development Project and is described in Section 2.2.2.2 of the Draft EIR (page 16).

The Draft EIR assumes some tree removal will be necessary to construct the proposed project and impacts related to tree removal are discussed under Impact BIO-5 in Section 3.4 Biological Resources of the Draft EIR (page 68). As described in the Draft EIR, pursuant to Municipal Code Chapter 12.40 – Urban Forestry, the City does not regulate the removal of trees except those within the public right-of-way, therefore the removal of trees on the school campus would not conflict with a local tree preservation policy. The Draft EIR further describes that the project is committed to replacing any removed trees at a 2:1 ratio.

It is not clear what visual simulation the comment is referring to; however, on page 19 of Appendix B (draft Precise Plan) to the Draft EIR, a visual simulation shows the proposed project with the existing trees transparent in order to provide a better understanding of the project. The project does not propose to remove all existing trees surrounding the site.

Comment F.5: Failure to Accurately Consider the Land Use Impacts of the Community Garden and Groves of Mature Trees Surrounding the Site.

A review of comments submitted to the City in response to the Notice of Preparation and prior to that time indicates that the Community Garden that has occupied a portion of Parcel D for decades is an important land use. Representatives of the Native American community have also stated that it is important as a cultural resource (https://www.change.org/p/juslyn-manalo-save-mysticcommunity-garden), and over 4,000 community members have identified it as a unique and valued

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land use. Yet the DEIR fails entirely to accurately characterize this land use and therefore fails to correctly identify the significance of its loss. The proposed extirpation of the garden represents a significant land use impact.

Response F.5: Please refer to Master Response 1: Demonstration Garden, Master Response 5: , Master Response 6: Recreation, and Master Response 7: Tribal Cultural Resources above regarding impacts related to removal of the Demonstration Garden.

Comment F.6: The EIR blindly uses only the Initial Study Checklist as its significance criteria.

However, the Courts have ruled that even if a project impact is not identified in the Checklist questions, it must be considered (see: Protect the Historic Amador Waterways v. Amador Water Agency, 116 Cal.App.4th 1099, 2004). Therefore, loss of important land uses also should be considered as a land use impact, as it is a physical impact on the environment. In this case, there is substantial evidence on the record that the garden comprises a unique and highly valued community open space, cultural, and educational resource. The EIR must fully identify and consider the land use, cultural, educational, and agricultural value of the garden and forest of mature trees surrounding the site, and the significance of their loss as a land use impact. Further, as discussed below, one or more alternatives that preserve the garden must be added to the EIR.

Response F.6: Please refer to Master Response 1: Demonstration Garden, Master Response 6: Recreation, Master Response 7: Tribal Cultural Resources, and Master Response 8: Alternatives above. Impacts related to agriculture and trees are discussed in Sections 3.2 and 3.4 of the Draft EIR.

Comment F.7: Failure to Adequately Consider Wetlands Habitats The DEIR states (p.67):

While the Biological Resource Assessment identifies the presence of wetland features, it does not reach a definitive conclusion about the meadow qualifying as a jurisdictional wetland and recommends a formal wetland delineation be performed prior to project implementation to allow the US Army Corp and/or the Regional Water Quality Control Board to determine whether to assert jurisdiction over the meadow as a wetland. The Biological Peer Review, however, agrees with the findings of the Wetland Assessment and concludes that the meadow would not qualify as a jurisdictional wetland under the Clean Water Act or Porter-Cologne Act.

CEQA does not care about legal definitions of jurisdictional wetlands. It cares about the habitat values afforded by the wetlands. The DEIR finds no impact on wetlands solely on the basis of legal administrative classifications. Please revise to address the impacts associated with the actual habitats.

Response F.7: Please refer to Master Response 5: Wetlands above.

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Comment F.8: Project Non-Conformance with RHNA and City Inclusionary Housing Ordinance As noted in numerous comments on the NOP, including comments from the City’s Director of Economic and Community Development, Housing and Community Development Supervisor, and Housing Coordinator (Memo from the above to the Mayor, Affordable Housing Community, and Councilmember Glenn Sylvester, November 15, 2021) the project fails to conform with the City’s inclusionary housing ordinance:

The affordable housing proposed by JUHSD for the Serramonte Del Rey site is not strictly consistent with the terms of the City’s Inclusionary Housing Ordinance in two ways:

1. The City’s Inclusionary Housing Ordinance requires that affordable units are phased in at the same time as market rate units. Subsequent to the development of housing for District staff on Parcel A, the JUHSD proposal envisions completion of 201 market rate units on Parcel B before any affordable housing units for the general public are developed. The result of this phasing is that the 20 inclusionary units required from the 200 units developed on Parcel B, would be delayed for an estimated two years until the 100 affordable units are Parcel C are constructed.

2. The City’s Inclusionary Housing Ordinance requires that affordable units are physically distributed equally through a development. In the JUHSD proposal, the majority of the affordable units would be concentrated on one of six parcels.

The EIR must address this non-conformance, which brings the project further into conflict with its own objectives, discussed above.

Further, the project would do nothing to achieve, the City’s compliance with its RHNA objectives.

According to RHNA Plan, Daly City is allocated a total of 4,838 total housing units. This includes 1,336 very-low-income units, 769 low-income units, 762 moderate-income units, and 1,971 abovemoderate-income units. The proposed project’s minimal provision of affordable units makes it nearly impossible for the City to achieve its overall RHNA requirement of about 43% very-low and low-income units. The project’s 1235 units comprise about 26 % of the 4838 total units, but it proposes to provide only 6% of the required affordable units. This means that future residential development in the City would be required to exceed 50% affordable units in order to meet its RHNA/Housing Element requirements. Table HE 49a in the Draft Housing Element shows this shortfall. Instead of helping the City meet its RHNA requirements, the project further impedes this.

The EIR should describe conformance with the RHNA/Housing Element this would be achieved.

Response F.8: Please refer to Master Response 2: Regional Housing Needs Allocation and Master Response 3: Inclusionary Housing Ordinance and State Affordable Housing Law above.

Comment F.9: Project Objectives Deficiencies

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Project objectives inform, in part, the selection of project alternatives. Alternatives are intended to reduce potentially significant project impacts while achieving most of the project objectives (Guidelines Section 15126.6 (a)). One of the project objectives is to maximize affordable housing, yet, as discussed above, the project includes the minimum number of affordable units per the City’s Inclusionary Housing ordinance, fails to comply with the unit distribution and timing components of that ordinance, and substantially impedes the City’s compliance with its own RHNA requirements.

Further, as detailed above, the project makes it nearly impossible for the City to achieve its RHNA affordable housing requirements. In this case, the project does not meet its own objective.

Response F.9: The project objectives are defined by the applicant JUHSD’s goals for the proposed project. The objective the commenter appears to be referring to is to “Maximize the number of new high-quality market-rate and affordable housing units as a well-designed, economically feasible, urban residential neighborhood with sufficient density to create a safe, active neighborhood, with development phasing subject to market conditions that provides flexibility with the sequence of construction of buildings, open space, streets, and infrastructure.” (page 210). The project provides 20 percent affordable units, twice the City’s minimum requirement that 10 percent of the units be affordable, therefore, the comment is incorrect in stating the project provides the minimum amount of affordable housing, and would not contribute to the City’s RHNA goals. Please also refer to Master Response 2:

Regional Housing Needs Allocation and Master Response 3: Inclusionary Housing Ordinance and State Affordable Housing Law above.

Comment F.10: Inadequate Range of Alternatives
The project includes only the no-project alternative, with variants for existing conditions and future development conditions. It then identifies the latter no-project alternative variant as the CEQAmandated environmentally superior alternative. Per CEQA Guidelines Section 15126.6(e)(2), the two variants comprise the CEQA-mandated No Project Alternative. This minimal range of alternatives fails to meet CEQA’s requirement of a reasonable range of potentially feasible alternatives that may reduce project impacts and meet most of the project objectives (Guidelines Section 15126.6(a)). Project-related impacts to vehicular emissions, noise, VMT, biological resources, and land use (i.e., impacts from removal of the community park and non-conformance with the RNHA) must be considered in selecting alternatives. At a minimum, given the potential land use and plan non-conformance issues discussed above, one or more alternatives that preserve the community garden (i.e. no development or reduced development in Parcel D), preserve the mature trees surrounding the property, and meet the City’s Inclusionary Housing Ordinance and RNHA affordable housing mandates must be included.

Response F.10: Please refer to Master Response 8: Alternatives above.

Comment F.11: In addition, the City of Daly City is highly unbalanced in terms of jobs/housing, with under 0.5 jobs/resident. This means that residents need to travel longer distances to their jobs,

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resulting in relatively high VMT levels. A project alternative that included a larger employment component (and also preserved the garden and trees) would further reduce project impacts, and should be added to the EIR.

Response F.11: Section 7.4.1.2 of the Draft EIR (page 212) considers but rejects a mixed-use alternative that included 230,000 square feet of office space and 1,035 residential units. This alternative would result in the same VMT per resident as the proposed project and result in a higher VMT per employee than the countywide threshold; thus, creating a new VMT impact compared to the proposed project. For these reasons, such an alternative would not be environmentally superior, and would not reduce project impacts as suggested by the commentor, and was rejected in the Draft EIR.

Comment F.12: Impermissible Environmentally Superior Alternative CEQA further requires that an EIR to identify an environmentally superior alternative “among the other alternatives” if the no-project alternative is otherwise the environmentally superior alternative to the project (Guidelines section 15126.6(e)(2)). In this case there are no other alternatives from which to pick. One or more actual “environmentally superior” alternatives must be developed and analyzed in the EIR.

Response F.12: The environmentally superior alternative is picked from among the range of analyzed alternatives. As discussed in Master Response 8: Alternatives above, the City considered but rejected three alternatives and only found two alternatives to be feasible. The Draft EIR concludes the No Project Alternative, which assumes the site remains in its current condition, is the environmentally superior alternative. However, as noted in the comment, CEQA requires that when the No Project Alternative is determined to be the environmentally superior alternative, that an environmentally superior alternative be identified. Thus, the Draft EIR identifies the No Project – Existing Zoning Alternative, which assumes development of the site as allowed under current plans and policies and considering available infrastructure, as the ‘next best’ environmentally superior alternative. This alternative does not assume the site remains in its current condition, as opposed to the No Project -No Development alternative which retains the site as is. Developing the site in accordance with the existing zoning would be environmentally superior to the proposed project, for the reasons provided in Draft EIR Section 7.4.2.2.

Comment F.13: Conclusions
It is my professional opinion, supported by the facts summarized above, that the DEIR is inadequate to meet basic CEQA requirements, particularly with respect to its treatment of project alternatives.

In addition, the project fails to meaningfully contribute to the City’s RHNA affordable housing

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allocation as described in the City’s Draft Housing Element. The City should revise and re-circulate the DEIR for the statutory 45-day minimum review period.

Response F.13: This is a concluding statement that references issues that were raised in prior comments, and were each responded to previously in detail; therefore, no further response is required.

G. Anonymous 1 (dated September 1, 2023)
Comment G.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response G.1: This comment advocates for preservation of the demonstration garden and does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Master Response 1: Demonstration Garden. The comment also expresses an opinion about cultural resources, but does not raise any issues about the adequacy of the Draft EIR analysis of such resources.

Please refer to Master Response 1: Demonstration Garden, Master Response 6:

Recreation, Master Response 7: Tribal Cultural Resources above.

Comment G.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Response G.2: As discussed under Impact AIR-2 and Impact AIR-3 in Section 3.3 Air Quality of the Draft EIR (pages 38-50), air quality impacts as a result of project construction would be below BAAQMD thresholds for construction period emissions and health risk with implementation of mitigation measures MM AIR-2.1 through MM AIR-2.3 and MM AIR-3.1, and the construction of the project would therefore have a less than significant impact on air quality. This analysis conservatively

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assumed a six-year construction period, since compressing the total construction activity into a shorter period of time results in higher daily emissions than if the project were built over a longer period of time, Accordingly, assuming six years rather than fifteen years overstates the construction emissions, making the analysis in the Draft EIR inherently conservative. (page 41). While implementation of the campus redevelopment could take as long as 15 years, there would not be continuous heavy construction activity over that time, and emissions would be expected to be at a lower daily emission level than forecast in the Draft EIR. As each phase is implemented, there would be periods of intense construction activity specific to that phase for that portion of the site.

As discussed under Impact NOI-1 in Section 3.13 Noise of the Draft EIR (pages 135- 141), the proposed project’s construction noise could exceed ambient noise levels by five dBA or more; however, construction noise levels would not exceed the significance thresholds of 90 dBA Leq at any residential land uses or 100 dBA Leq at any commercial land uses surrounding the project site. In addition, the project shall implement mitigation measure MM NOI-1.1, which requires the project to implement additional best management practices to further reduce construction noise to a less than significant level.

H. Anonymous 2 (dated September 1, 2023)
Comment H.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response H.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment H.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry?

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I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Response H.2: Please refer to Response G.2: above regarding air quality and noise impacts.

I. Anonymous 3 (dated September 1, 2023)
Comment I.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response I.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment I.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Response I.2: Please refer to Response G.2: above regarding air quality and noise impacts.

J. Anonymous 4 (dated September 1, 2023)
Comment J.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables

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• lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response J.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment J.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Save the garden!
Response J.2: Please refer to Response G.2: above regarding air quality and noise impacts.

K. Chloe Costa Amado (dated September 1, 2023)
Comment K.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response K.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment K.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways

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• Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Response K.2: Please refer to Response G.2: above regarding air quality and noise impacts.

L. Christina Francisco (dated September 1, 2023)
Comment L.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response L.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment L.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

I personally have been enjoying the garden since I moved in 2019. The welcoming vibe is amazing.

Keep the good work Erick your work makes the difference.

Response L.2: Please refer to Response G.2: above regarding air quality and noise impacts.

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M. Casey Quon (dated September 1, 2023)
Comment M.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response M.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment M.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

This is a great environment.

Response M.2: Please refer to Response G.2: above regarding air quality and noise impacts.

N. Catherine Van Etten (dated September 1, 2023)
Comment N.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature

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Response N.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment N.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Please don’t destroy this environmental gem.

Response N.2: Please refer to Response G.2: above regarding air quality and noise impacts.

O. Eduardo Silva Amado (dated September 1, 2023)
Comment O.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response O.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment O.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

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Response O.2: Please refer to Response G.2: above regarding air quality and noise impacts.

P. Erick Campbell (dated September 1, 2023)
Comment P.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response P.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment P.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Response P.2: Please refer to Response G.2: above regarding air quality and noise impacts.

Q. Javier Lopez (dated September 1, 2023)
Comment Q.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians

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• It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response Q.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment Q.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Save the Garden!
Response Q.2: Please refer to Response G.2: above regarding air quality and noise impacts.

R. Kerry Quendens-Bonham (dated September 1, 2023)
Comment R.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response R.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment R.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry?

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I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

My dogs and I enjoy relaxing in the gorgeous park when I get home from work. It’s a shame that someone wants to ruin this awesome park.

Response R.2: Please refer to Response G.2: above regarding air quality and noise impacts.

S. Monica Costa Amado (dated September 1, 2023)
Comment S.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response S.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment S.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Response S.2: Please refer to Response G.2: above regarding air quality and noise impacts.

T. Monica Bidegain (dated September 1, 2023)
Comment T.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

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Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response T.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment T.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

I love the garden, it’s a place where I find myself, when I need to lose myself! TO PLANT A GARDEN IS TO BELIEVE IN TOMORROW. SAVE THIS GARDEN.

Response T.2: Please refer to Response G.2: above regarding air quality and noise impacts.

U. Matthew Piccardo (dated September 1, 2023)
Comment U.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response U.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

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Comment U.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Daly City resident for 49 years.

Response U.2: Please refer to Response G.2: above regarding air quality and noise impacts.

V. Patrick Robertson (dated September 1, 2023)
Comment V.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response V.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment V.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

I’ve been coming to this beautiful garden for the past 15 years. I’ve seen a beautiful place grow.

Kids growing…

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How much money is really enough… When you need to get away from the work where do you go… Come by the garden with your lunch and some music and enjoy the real garden experience.

Response V.2: Please refer to Response G.2: above regarding air quality and noise impacts.

W. Shasta Student 1 (dated September 1, 2023)
Comment W.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables • lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response W.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment W.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Response W.2: Please refer to Response G.2: above regarding air quality and noise impacts.

X. Shasta Student 2 (dated September 1, 2023)
Comment X.1: I am a resident of the Serramonte Ridge Apartments and will be greatly affected by the destruction of the Community Garden and the 15-year timeline in construction of this phased development.

Please SAVE The Garden
• Where the community grows herbs, fruits and vegetables

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• lt is home to over 100 trees and many different animals, birds, butterflies • The location has special significance and recognition for Native Ohlone Indians • It is an area that is shared and respected by people from all over Daly City along with students at Shasta High School by peacefully being in Nature
Response X.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Response G.1 above.

Comment X.2: The Long Construction Timeline
• Last over 15 years? This is not fair to our community for quality of living. • Air Quality with the fog and dust will linger on our cars and walkways • Constant Noise of Construction on weekdays 8-5pm with many of us working remotely or trying to get day sleep for those of us who work in the service industry? I understand that this is the Environmental Review of the Project --- but my health and Safety living and renting thru this project development should be a consideration.

Response X.2: Please refer to Response G.2: above regarding air quality and noise impacts.

Y. Andrew Sielen (dated September 3, 2023)
Comment Y.1: My family and I moved to Daly City in 2020, we bought a house in Westlake and we plan on making it our forever home. One disappointment though is that this city does not seem to invest in community spaces and the school district is hostel to the community. Locking its gates to families who would benefit from some extra space for their kids to run around (and in the case of Westlake, the neighborhood was specifically built around the elementary school grounds as a park for neighborhood children, now it is just locked up and only used by the school a couple times a year) and now looking to destroy the only community garden in the city.

It is important to me that my son has exposure to where our food comes from, community gardens are a great opportunity to show him this. We have been attempting to grow vegetables in our backyard (photos attached) and frequent the seed bank at Westlake Library. Our foggy weather makes this difficult and we would benefit from a meeting ground such as this garden where we can meet and learn from our neighbors who have been doing this for years.

The school district has already taken out other community space when they decided to develop the land next to Westmoor High. Don't let them take this one away also. They are not a private corporation, and they should be accountable to us the tax payers. It is great we are building so much more housing, but without the community, we are just housing people who may live here but spend their lives in our neighbor cities like SF or South City. Let's make our city a place to thrive.

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This city has so much promise, great neighbors and community but it needs some new energy, taking aways these spaces is going in the wrong direction. We don't want to go in the direction of SF.

As my family and I establish our roots in this city, we look forward to getting more engaged.

Response Y.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.

Z. Emma Hartung (dated September 4, 2023)
Comment Z.1: I am writing to comment on the Serramonte Del Rey Redevelopment DEIR and to urge you to oppose the demolition of Daly City's only community garden. The DEIR makes it clear that this project would have detrimental impact to local habitat that is already severely limited by negatively impacting foliage, wetlands, wildlife habitat and the creek. This community garden is a resource that is crucial to the local community. I hope that Daly City will reflect on these negative impacts found and act swiftly to preserve the garden in recognition of the critical environmental and social resources that it provides.

Response Z.1: Please refer to Master Response 1: Demonstration Garden above.

Further, as discussed in Section 3.4 Biological Resources of the Draft EIR (pages 54- 70), the project would result in a less than significant impact on special-status species through implementation of mitigation measures MM BIO-1.1 and MM BIO1.2. In addition, the Draft EIR concluded, based on biological studies, that there is substantial evidence that there are no wetlands or riparian areas on the project site that are protected under federal or state law. Please refer to Master Response 5:

Wetlands above.

AA. Melissa Kallstrom (dated September 6, 2023)
Comment AA.1: Visualize the place that you go that brings you peace and helps calm your mind and soul, the Daly City Community Garden is that place for me and many people and their families. This garden is the only community garden in Daly City which has less than 5% of the urban canopy of trees that cover our city (Excellence, 2020). This unique garden is located across from the Jefferson High School District building and is part of the Serramonte Del Rey Campus Development. This only green space includes over 100 redwood trees, 100 fruit trees, and native trees that include Douglas Firs, Madrones, Buckeyes, Live Oak, White Oak, Catalina, and Ironwood trees.

Response AA.1: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Master Response 1 above.

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Comment AA.2: The Mission Blue Butterfly has also found a home in our garden and because of habitat loss in response to land degradation as a result of housing and retail development, this beautiful species is almost extinct and, on the Fish and Wildlife website is categorized in red as endangered (Endangered Species, 2023). I have seen these butterflies’ multiple times in the garden with Erik, the caretaker. What will happen to the ecosystem if the small piece of land is destroyed to build more apartments which are for market rate and more retail stores, has the city noticed that retail industry has taken a financial hit which will just be more stores that are empty, once the development is finished. Daly City residents will also not be able to afford to live in these for market rate apartments and the affordable housing that we are promised is under the requirements of percentage that is necessary. They will also have one building out of the five that will house all the affordable housing, that should be considered discrimination.

Response AA.2: Please refer to Response DD.6: below, and Master Response 3:

Inclusionary Housing Ordinance and State Affordable Housing Law above.

Comment AA.3: I have lived at the Serramonte Ridge Apartments since January 2015, and I have been going to the garden soon after I moved in. My son attends Summit Shasta High School, he started his freshman year at Shasta High School in 2020 during Covid and the garden became our sanctuary since we could not leave our apartment. He currently is a senior and is in his last year of high school. Throughout the time that we lived at Serramonte Ridge, together we planted potatoes, sun flowers, peas, green beans, beets, rosemary, and sage. I am a single mom, and this food source helps with our food expenses. People from the community that go to the garden, leave with fresh fruit, vegetables, and herbs that are completely free and so fresh, garden to table.

The garden is a place for kids of all ages to go and spend time with friends and family, this is especially important for high school kids. My son goes and hangs out with friends or works in the garden, he has helped build fences, learned about landscaping, and even has a plot where he has planted different types of lettuce. It puts my mind at ease knowing that he is in the garden and not out running the streets causing trouble. Shasta High School also has a plot for the students to grow a variety of plants, vegetables, and herbs. This opportunity gives them hands on learning that they will take with them long after graduation. Global warming is a threatening presence, and the youngest generations are dealing with how to help, and the garden will teach them the importance of ecology and conservation.

Change.org has a petition of over 4,500 signatures of people agreeing to Daly City’s need of this community garden, mother nature has an amazing resilience to the harm humans have caused but the time to help her is of extreme importance for all things living. Nature is a healing spiritual resource for anyone that can enjoy the magic and the healing nature of places like the Daly City Community Garden. The earth has an adaptable nature but if all of nature has been turned into developments of apartments and office space with an area on top of a parking garage, that does not have the resource of over twenty years of growth in that location, and nature will not have the ability to heal itself or us. I request that you read this letter and all the letters you receive, in the Daly City Community Garden. It might open your mind and the minds of the people that are in

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support of this development. Instead of following the dollar signs, listen to the community that is seeing the signs that this earth will not be able to continue in its destruction.

Thank you for your time working with us and for reading my letter.

Response AA.3: This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required. Please refer to Master Response 1 above.

BB. Catalina Gomes (dated September 6, 2023)
Comment BB.1: My name is Catalina Gomes and I am a descendant of the Ramaytush people from Timigtac Village site near Calera Creek. I am writing to express the need to protect the Daly City Community Garden which is situated nearby the land my ancestors lived. There has been a long Indigenous history on that land - most of which has been obscured, erased, and violently destroyed.

Given the historical context and what little remains, it is of the utmost importance that this garden not also be destroyed for the benefit of a private development opportunity.

Response BB.1: The demonstration garden has no relationship to the pre-contact tribal habitation of the area, as the demonstration garden is a recent, modern feature installed by the JUHSD, as discussed in Master Response 7: Tribal Cultural Resources above.

Comment BB.2: Being the only community garden in Daly city, it provides much needed green space (most of which is rapidly disappearing) while also acting as a food source for people who are food compromised. Filled with native trees, established fruit trees, soil that has been built over years, and a diverse array of wildlife that has built complex interspecies relationships, replacing this would certainly not be achievable with a few raised beds as it would take decades to replace the mature trees that would be destroyed by this proposed development.

Response BB.2: Please refer to Master Response 1: Demonstration Garden above.

Comment BB.3: Daly City is in great need of an urban forest. There are several other phases of this project that could take place without the destruction of this vital, thriving, living asset to the community! Not only as a green oasis, in an urban setting, but also as a place of cultural relevance.

As the site of decades, if not thousands of years of Indigenous ceremonies. I am hopeful that you take advantage of this opportunity to protect this garden that is of great value to the community at large!
Response BB.3: There is no evidence to suggest the site of the demonstration garden was used for pre-contact Native American ceremonies, as the site had been a sloping hillside prior to the extensive grading that was completed to construct the school campus. Please refer to Master Response 7: Tribal Cultural Resources above.

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This comment does not raise any issues about the adequacy of the Draft EIR; therefore, no further response is required.

CC. Cossart-Daly Law, A.P.C. (dated September 7, 2023)
Comment CC.1: Cossart-Daly Law, A.P.C. represents the Loma Prieta Chapter of the Sierra Club (“Sierra Club”) with respect to the Serramonte Del Rey Campus Redevelopment Draft Environmental Impact Report.

The Loma Prieta Chapter of the Sierra Club offers local members and supporters opportunities to actively contribute to the environmental work of the Sierra Club, which promotes the responsible use of the earth’s ecosystems and resources, and aims to protect and restore the quality of the natural and human environment. Sierra Club has a strong interest in addressing the environmental and environmental justice impacts of development projects, including the proposed Serramonte Del Rey Campus Redevelopment in Daly City (the “Project”). Cossart-Daly Law, A.P.C. submits the following comments on the Draft Environmental Impact Report (“DEIR”) on Sierra Club’s behalf.

The Project is a massive undertaking that will result in significant environmental impacts. In order to construct the Project, the City of Daly City (“City”) developed an approximately 22- acre Serramonte Del Rey Precise Plan (“Precise Plan”) unique to the Project, as well as a specific development proposal for an approximately 4.3-acre Parcel B within a portion of the Precise Plan. (DEIR p. iv.) The Project, as proposed, would include a project site area with “up to” 1,235 units of affordable and market-rate rental housing. (DEIR p. iv.) Affordable housing would primarily be segregated into Parcels A and C. (DEIR Appendix A, p. 14; Jefferson Union High School District, The Serramonte Del Rey Neighborhood, available at https://serramontedelrey.org/masterplan/.) The Project would also include “up to” 14,000 square feet of retail or commercial use area. (Ibid.) 22 acres of the Project site would be used to construct “up to” 1,113 units of affordable and market- rate rental housing, in addition to the 122 currently-existing units on Parcel A. (Ibid.) It would also include the construction of a mixed-use building with 201 residential units and approximately 8,000 square feet of retail space including two levels of parking on a 4.3 acre portion of the site. (Ibid.) There is a long standing Community Garden, a wetland, many trees, and greenspace, including a meadow, located on the Project site. (DEIR, pp. 10, 67, Figs. 2.2-5, 3.4-1.) The Community Garden and a majority of the parcel’s green space is located on Parcel F. (See DEIR Fig. 2.2-5.) According to the DEIR, “[t]he proposed Precise Plan would remove the existing garden and use the space as a construction staging area until Parcel F is fully developed with up to 400 units and 6,000 square feet of retail uses.” (DEIR, p. 10.) This would result in the destruction of the Community Garden, the wetland, and a majority, if not all, of the green space located around the Community Garden.

This Project will create significant environmental impacts, and thus requires a careful, complete and thorough environmental analysis under the California Environmental Quality Act (“CEQA”). “CEQA was enacted to advance four related purposes: to (1) inform the government and public about a proposed activity's potential environmental impacts; (2) identify ways to reduce, or avoid,

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environmental damage; (3) prevent environmental damage by requiring project changes via alternatives or mitigation measures when feasible; and (4) disclose to the public the rationale for governmental approval of a project that may significantly impact the environment.” (Union of Medical Marijuana Patients, Inc. v. City of San Diego [“Union of Medical Marijuana Patients”] (2019) 7 Cal.5th 1171, 1184, citing California Building Industry Assn. v. Bay Area Air Quality Management Dist. (2015) 62 Cal.4th 369, 382.) “CEQA embodies a central state policy to require state and local governmental entities to perform their duties ‘so that major consideration is given to preventing environmental damage.’” (Union of Medical Marijuana Patients, supra 7 Cal.5th at 1185, citing Friends of the Eel River v. North Coast Railroad Authority (2017) 3 Cal.5th 677, 711- 712.) As explained herein, the DEIR mischaracterizes the Project setting, relies on an unstable Project description, and does not provide an adequate analysis or mitigation for impacts to Biological Resources, Recreation, or Land Use. Most importantly, the DEIR alternatives analysis is insufficient because it does not include nor adopt an alternative that would disperse affordable housing throughout the Project and preserve the Community Garden, wetland, and surrounding green space. Please remedy these deficiencies as outlined and requested below in order to ensure that the environmental review documents for the Project comply with CEQA.

Response CC.1: This is an introductory comment and restates the proposed project.

The comment raises general concerns regarding the Draft EIR that are the subject of more detailed comments that follow, for which responses are provided. No further response is required.

Comment CC.2: I. The DEIR’s Description of the Project Site is Inaccurate, As it Mischaracterizes the On-Site Community Garden, Wetland, and Greenspace.

According to the CEQA Guidelines, an EIR must correctly describe the environmental setting for the project. (14 Cal Code Regs § 15125(a), (c); San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal. App. 4th 713, 726 [voiding EIR for failure to contain accurate site description].) The description of the environmental setting should include “the area in which significant effects would occur either directly or indirectly as a result of the project.” (Id. at § 15360.) These existing physical conditions “will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant.” (See Neighbors for Smart Rail v Exposition Metro Line Constr. Auth. (2013) 57 C4th 439, 448, Communities for a Better Env't v South Coast Air Quality Mgmt. Dist. (2010) 48 C4th 310, 320.) “[S]pecial emphasis should be placed on environmental resources that are rare or unique to the region and that would be affected by the project.” (14 Cal Code Regs §15125(c).) “The purpose of this requirement is to give the public and decision makers the most accurate and understandable picture practically possible of the project's likely near-term and long-term impacts.” (Id. at §15125(a).) Courts and lead agencies “must interpret the Guidelines to afford the fullest possible protection to the environment.” (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 720.)

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Environmental conditions must be described as they exist. (Id. at §15125(a).) Including a correct and pertinent description of existing environmental resources is critical for a DEIR to comply with CEQA. (See San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal. App. 4th 713, 726; Sierra Watch v County of Placer (2021) 69 Cal. App. 5th 86; League to Save Lake Tahoe Mtn.

Area Preservation Found. v County of Placer (2022) 75 CA5th 63, 97.) Without correct and comprehensive information of environmental resources that will be potentially impacted, the lead agency cannot correctly assess significant impacts nor what measures, if any, could mitigate these impacts. (See ibid.)
As described herein, the DEIR mischaracterizes the Project site. It states that no sensitive plant or animal species have been observed onsite, when several endangered or special status species have been observed on and around the Community Garden, wetland, and open space located on Parcel F. (Compare DEIR p. 61, 62 with Exhibit A, Althouse and Meade, Inc. Correspondence, pp. 2-4.) The DEIR indicates that there is a wetland onsite, but fails to describe how this wetland may or may not support riparian habitat, what it entails, and what wetland- specific species exist on site. (Compare DEIR, p. 59 with Exhibit A, Althouse and Meade, Inc. Correspondence, pp. 2-4.) Response CC.2: The issues raised by the comment concerning the environmental conditions on the site are based on detailed comments provided by another party who commented on the Draft EIR, for which responses have been provided below.

Please refer to Response DD.4: through Response DD.9: below regarding wetlands and special-status species.

Comment CC.3: The DEIR also does not adequately describe the Community Garden. The Biological Resources Environmental Setting only briefly mentions the Community Garden, and does not discuss its function or importance in supporting sensitive species. (See DEIR, p. 59 [“although native plant species are present in the Demonstration Garden as a result of being planted by gardeners…”]). But, as further explained herein, the Community Garden and the surrounding trees and open space serve as important habitat for sensitive species, an important wildlife corridor, and important urban “green space [which] supports a diverse array of nesting habitat with varied vegetation strata to support cavity-, ground-, shrub-, and canopy-nesting birds.” (See Exhibit A, Althouse and Meade, Inc. Comment Letter, p. 10.)
Response CC.3: The issues raised by the comment concerning the biological habitat value of the demonstration garden are based on detailed comments provided by another party who commented on the Draft EIR, for which responses have been provided below. Please refer to Response DD.2: and Response DD.13: below regarding sensitive natural communities and wildlife movement corridors.

Comment CC.4: What’s more, the DEIR downplays the important recreational, historic, and community functions of the Community Garden. The DEIR’s only full description of the Community Garden states:

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There is an approximately 0.5-acre school demonstration garden located in the southwest corner of the Precise Plan area. This garden was started 20 years ago and used by JUHSD for adult education as a demonstration garden. In 2019, the garden was listed as a “community garden” by the County of San Mateo; however, the listing occurred without the knowledge or permission of JUHSD leadership, and therefore the garden was removed from the list. (DEIR, p. 10.)
The Community Garden has not been used as a “demonstration garden,” as claimed by the DEIR, but has existed as a community garden, open to the public, for an extended period of time. (See Exhibit B, video from CBS Bay Area, Daly City Housing Development Squeezing out Beloved Community Garden, available at https://www.cbsnews.com/sanfrancisco/news/daly-city-housingdevelopment-plans-squeezing-out-beloved-community-garden/?intcid=CNM-00-10abd1h; see also Exhibit C, Petition, Help Save Daly City’s Only Community Garden.) Residents of the Serramonte Ridge Apartment Homes, adjacent to the Project Site, have used the Community Garden since the construction of Serramonte Ridge in the 1980s. (See Figure 3.17-1; Serramonte Ridge Renters Association September 26, 2021 Comment Letter, available at https://static1.squarespace.com/static/52a4b6b8e4b020f5799aacd9/t/623f69221e2f0172f42a9e8/ 1648322851095/Serramonte+Ridge+Renters+Association+Letter+to+City+of+Daly+City+v.3.pdf.) The DEIR, likewise, does not discuss or disclose that the Community Garden is Daly City’s only community garden, or that the Community Garden provides a unique space which permits community members to grow culturally relevant foods, provides access to gardening for those who would not otherwise have it, and provides on open space for indigenous community members to hold religious ceremonies. (See Exhibit C, Petition, Help Save Daly City’s Only Community Garden; Sierra Club August 12, 2021 Comment Letter, available at https://www.sierraclub.org/sites/www.sierraclub.org/files/sce/loma-prieta chapter/conserveletters/Letter%20to%20David%20Canepa%208.13.21.pdf.) Response CC.4: Please refer to Master Response 1: Demonstration Garden above.

Comment CC.5: As discussed herein, removal of the Community Garden will result in significant impacts to habitat for sensitive and endangered species and on recreation. Because the DEIR mischaracterizes the Community Garden, it does not analyze the removal of the Community Garden as having a significant impact on Biological Resources, and does not provide appropriate mitigation for such impacts.

Response CC.5: Please refer to Response DD.2: below regarding sensitive natural communities and Response DD.3: through Response DD.9: below regarding specialstatus species. In addition, please refer to Master Response 6: Recreation above.

Comment CC.6: If the City adopts the DEIR without updating the description and analysis of the wetland, open space, and Community Garden, it will violate CEQA. In order to comply with CEQA, please update the DEIR to accurately reflect the function, history, and use of the Community Garden, and conduct adequate studies on and identify the sensitive species that currently exist