6 4
5 0
City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Utilities
Meeting Date: August 11, 2025
Report #:2501-4081
TITLE
Approval of Resolutions Amending the Amended and Restated Water Supply Agreement Between the City and County of San Francisco and Wholesale Customers in Alameda County, San Mateo County and Santa Clara County and the Updated Tier 2 Drought Response Implementation Plan; CEQA Status: Not a Project and Categorically Exempt under CEQA Guidelines Sec. 15307, 15308
RECOMMENDATION
Staff recommends City Council approval of two resolutions (1) amending the Amended and Restated Water Supply Agreement between the City and County of San Francisco and Wholesale Customers in Alameda County, San Mateo County and Santa Clara County (Attachment A) and (2) approving the updated the Tier 2 Drought Response Implementation Plan (Attachment B)
EXECUTIVE SUMMARY
Approval of the two recommended resolutions will result in:
1. A revised Water Supply Agreement (WSA) that modifies the minimum purchase requirements and the drought allocation plan between the City of County of San Francisco and the wholesale customers (Tier 1) an includes various administrative adjustments.
2. A revised drought response implementation plan among the wholesale customers (Tier 2).
This is a final step in a multi-year negotiation process including coordination and collaboration with the 26 wholesale customers including neighboring jurisdictions such as Mountain View, Sunnyvale, and Santa Clara and reflects a package deal of terms. Overall, the amendments are minor in cost and operational impact, with some potential benefits to Palo Alto in drought scenarios.
6 4
5 0
Minimum Purchase Quantities 1 (MPQs): Adjustments to MPQs for four wholesale customers will result in a modest increase in water rates—estimated at $0.007 to $0.04 per ccf (0.13%–0.72%)—shared across all wholesale and SFPUC retail customers. This change addresses excess costs currently borne by some agencies, notably Mountain View.
Tier 1 Water Shortage Allocation Plan: The updated Tier 1 plan poses no risk to Palo Alto and may provide benefits. If Palo Alto exceeds its drought allocation but overall wholesale usage remains below limits, it will avoid excess use fees. General WSA Updates: Administrative in nature, these changes have no financial or resource impact.
Revised Tier 2 Drought plan slightly increases water cutbacks for Palo Alto during droughts (e.g., from 16% to 18% for a 20% system-wide reduction), and aligns with the City’s existing Water Shortage Contingency Plan and will not alter customer restrictions.
Resolution Amending the Amended WSA
The proposed amendments to the WSA aim to adjust the minimum purchase requirements and improve the Tier 1 Water Shortage Allocation Plan for the Wholesale Customers of the RWS, in response to evolving water use patterns and regional needs.
Resolution Approving Updated the Tier 2 Drought Response Implementation Plan The updated Tier 2 Plan refines how water from the RWS is allocated among Wholesale Customers during droughts, maintaining key features of the existing plan while introducing important updates to improve equity, resilience, and flexibility.
The new Tier 2 formula uses a structured, sequential approach to distribute available water taking into account minimum and maximum cutback percentages, residential indoor use, non- residential indoor use, and seasonal demand. Any remaining water is allocated to move each wholesale customer toward a “Target Allocation” that reflects both historical use and their Individual Supply Guarantee (ISG), while staying within the cutback bounds.
While the resulting changes are relatively minor for Palo Alto, they represent significant financial and operational benefits for other BAWSCA agencies, and as such are high priorities among these agencies. Notably, unanimous approval by all 26 BAWSCA agencies is required for the changes to become effective. The Utilities Advisory Commission discussed this topic at its June meeting and did not make a recommendation.
BACKGROUND
Water Supply Agreement History
1 Section 3.07.C of the Amended and Restated Water Supply Agreement (Attachment D) explains that it is a requirement for Alameda County Water District, and the cities of Milpitas, Mountain View and Sunnyvale to purchase a minimum annual quantity of water from San Francisco (Minimum Purchase Quantity or MPQ as set out in Attachment E of the Amended and Restated Water Supply Agreement). 6 4
5 0
In June 2009, the City of Palo Alto entered into a Water Supply Agreement with the City and County of San Francisco (San Francisco) and Wholesale Customers in Alameda County, San Mateo County and Santa Clara County (2009 WSA). The 2009 WSA establishes the terms by which the twenty-six Wholesale Customers purchase water from the RWS, including how water is allocated between SFPUC’s retail customers and the Wholesale Customers (Tier 1 Plan). The 2009 WSA builds upon the 1984 "Settlement Agreement and Master Water Sales Contract between the City and County of San Francisco and Certain Suburban Purchasers in San Mateo County, Santa Clara County and Alameda County."
In September 2017, the Bay Area Water Supply and Conservation Agency (BAWSCA) and the Water Management Representatives (WMR) of the BAWSCA member agencies began reviewing the issue of minimum purchase requirements, as described in Section 3.07.C of the WSA, and discussing the creation of a process to transfer minimum annual purchase quantities among the Wholesale Customers. Section 3.07 of the WSA provides that four Wholesale Customers (Alameda County Water District and the Cities of Milpitas, Mountain View, and Sunnyvale, collectively, the “Original Minimum Purchase Customers”) may purchase water from sources other than from San Francisco, but they are each obligated to purchase a specific minimum annual quantity of water from the San Francisco, referred to as a “Minimum Purchase Requirement."
Throughout 2017 and 2018, the WMR held multiple meetings during which the agencies currently subject to Minimum Purchase Requirements (Original Minimum Purchase Customers) and the other Wholesale Customers shared their interests and concerns regarding changes to the Minimum Purchase Requirements and allowing transfers of minimum annual purchase quantities.
On September 10, 2018, Council adopted Resolution 97912 appointing BAWSCA as its authorized representative in discussions and negotiations with San Francisco to amend the Agreement to address issues arising from implementation of the Agreement. The resolution also states this appointment continues unless and until revoked by the City Council. In 2019, the City of Palo Alto approved the 2018 Amended and Restated WSA (2018 WSA), at which time the Wholesale Customers expressed a collective interest in working together to develop a process for the expedited and permanent transfer of minimum annual purchase quantities. The Wholesale Customers directed BAWSCA to facilitate negotiation of a new WSA amendment to provide a procedure for expedited and permanent transfers of minimum annual purchase quantities in a manner that safeguards the financial and water supply interests of Wholesale Customers not participating in such transfers. This amendment was memorialized in the 2021 Amended and Restated WSA (2021 WSA).
Tier 2 Plan History and Negotiations and Development of Minimum Purchase Quantity Reset Proposal
2 Resolution 9791 https://www.paloalto.gov/files/assets/public/v/1/city-clerk/resolutions/reso- 9791.pdf?t=53184.44
6 4
5 0
The WSA authorizes the Wholesale Customers to adopt a methodology for allocating the water collectively available from the RWS among the twenty-six Wholesale Customers during system- wide shortages caused by drought (the Tier 2 Plan). San Francisco is not a party to the Tier 2 Plan. The existing Tier 2 Plan was adopted in 2011 and was originally set to expire in 2018. In 2018, the California State Legislature passed two bills to implement a long-term framework for water use efficiency, commonly referred to as, “Making Water Conservation a California Way of Life.” These bills were anticipated to impact urban water use, and the extent of those impacts to the Wholesale Customers was unknown at the time. As such, the WMR instructed BAWSCA to hold off on initiating an update to the existing Tier 2 Plan. In 2018, and every year since, the BAWSCA Board of Directors (BAWSCA Board) has extended the term of the exiting Tier 2 Plan by one year. In 2024, the BAWSCA Board extended the term of the existing Tier 2 Plan through the end of 2025 and specified that the existing Tier 2 Plan will be superseded by an updated Tier 2 Plan once unanimously adopted by the twenty-six Wholesale Customers.
Since the existing Tier 2 Plan was adopted in 2011, conditions impacting water use have changed (e.g., water supply sources, water use trends, land use, and customer base). During the 2021 to 2023 drought, the Tier 1 and Tier 2 Plans were implemented for the first time. At that time, it became clear that the existing Tier 2 Plan no longer operated as originally intended and that an update was necessary.
In January 2021, BAWSCA began facilitating an update to the Tier 2 Plan, the method for allocating water from the RWS among the Wholesale Customers during shortages caused by drought. The Tier 2 Plan is an agreement among the twenty-six Wholesale Customers, and must be unanimously adopted by them. Each Wholesale Customer appointed a lead negotiator to represent the interests of its agency in the negotiations. Between January 2022 and June 2024, BAWSCA and the lead negotiators, supported by a consulting firm providing technical and modeling expertise, met at least 62 times, most often for half-day, in-person meetings and smaller virtual sub-group sessions, to negotiate the terms of the updated Tier 2 Plan.
In November 2021, San Francisco declared a water shortage emergency in response to the Governor’s executive action declaring a drought state of emergency across most of California.
This action triggered implementation of the Tier 1 and Tier 2 Plans by BAWSCA and San Francisco for the first time.
Throughout the two and a half years of Tier 2 Plan negotiations, the Wholesale Customers gained insight into unique characteristics of each agency and specific challenges related to water supplies and droughts. During these discussions, Wholesale Customers subject to the Minimum Purchase Requirements (Minimum Purchase Customers) articulated the unique challenges that the Minimum Purchase Requirements present.
In June 2023, following several years of discussions regarding the Minimum Purchase Requirements, the SFPUC proposed amending the 2021 WSA to reset the existing minimum annual purchase quantities to align with current water consumption trends, while protecting investment in the RWS. For the remainder of 2023, the SFPUC, the Original Minimum Purchase 6 4
5 0
Customers, and BAWSCA held multiple meetings to identify amendments that would address challenges related to the Minimum Purchase Requirements. Once the SFPUC and the Original Minimum Purchase Customers finalized their recommended amendments to the Minimum Purchase Requirements, the Original Minimum Purchase Customers presented the proposals to the broader Wholesale Customers’ group to secure their support. Negotiations among the Wholesale Customers were concluded in Fall 2024.
In June 2024, the lead negotiators concluded negotiations on the updated Tier 2 Plan. The agency representatives collectively agreed that they were ready to recommend the Tier 2 Plan to their governing boards for adoption.
The Tier 1 and Tier 2 Plans are illustrated in the figure below.
Tier 1 Tier 2
Figure 1: Illustration of Tier 1 and Tier 2 Plans
ANALYSIS
Amendments to the Water Supply Agreement
Minimum Purchase Requirements
If a Minimum Purchase Customer does not meet its Minimum Purchase Requirement in a particular fiscal year, it must pay San Francisco for the difference between its metered water purchases during the fiscal year and its minimum annual purchase quantity set forth in Attachment E of the 2021 WSA.
It is assumed that the Minimum Purchase Requirements were originally designed to prevent four specific multi-source agencies from shifting from the RWS to other imported water sources. However, changed conditions, including recurring droughts, improved water use efficiency, and investments in local supplies have reduced demand on the RWS. Despite these improvements, the RWS remains vulnerable to severe droughts, prompting the SFPUC to invest
6 4
5 0
in alternative water supplies. The Minimum Purchase Customers are well-positioned to develop their own local, drought-resilient supplies, which would reduce the regional dry-year supply gap, improving reliability of the RWS for all users. These amendments may reduce a perceived existing disincentive to improve efficiency and develop alternative supplies.
1.1. Reduction of Minimum Annual Purchase Quantities (MPQ) MPQs set in the 1984 Settlement Agreement and Master Water Sales Contract (1984 Contract) were calculated based on 80% of each of the four Original Minimum Purchase Customer’s purchases from the RWS in the 1980s. The MPQs were later reduced by 5% as part of the 2009 WSA. Upon adoption of this 2025 WSA amendment, the minimum annual purchase quantities of the Original Minimum Purchase Customers will be reset to 80% of each of the Minimum Purchase Customer’s average purchases from the most recent four non-drought years and the amendment will establish a continuing, periodic review of the minimum annual purchase quantities on a 10-year schedule.
1.2. Rebound Year Minimum Annual Purchase Quantity
Existing Section 3.07.C of the 2021 WSA provides that Minimum Purchase Requirements will be waived during drought, other period of water shortage on the RWS, or if the Governor declares a state of emergency that impacts water supply use or deliveries from the RWS. Minimum Purchase Requirements are reinstated in the first year immediately following a drought. However, water use does not rebound to pre-drought levels for several years, depending on the level of conservation achieved.
The amendment provides a temporary, one-year reduction in the minimum annual purchase quantities equal to half of the demand reduction from pre-drought levels to allow for drought rebound. For example, if a Minimum Purchase Customer’s pre- drought use and minimum annual purchase quantity are 10 million gallons per day (MGD) and drought RWS purchases are 8 MGD, the Rebound Year minimum annual purchase quantity will be set at 9 MGD.
1.3. Collective Minimum Annual Purchase Quantities Considered Before Application of Imputed Sales
Existing Section 3.07 of the 2021 WSA provides that if a Minimum Purchase Customer does not meet its Minimum Purchase Requirement in a particular fiscal year, it must pay the SFPUC for the difference between its metered water purchases during the fiscal year and its minimum annual purchase quantity. This amendment provides that the collective purchases from Original Minimum Purchase Customers will be considered together before an individual Original Minimum Purchase Customer is required to pay 6 4
5 0
the difference between its metered water purchases and its Minimum Purchase Requirement. If collective purchases are more than the sum of minimum annual purchase quantities, payments to the SFPUC for an Original Minimum Purchase Customer(s) who did not meet its Minimum Purchase Requirement will not be required.
If collective purchases are less than the sum of minimum annual purchase quantities, payments to the SFPUC for an Original Minimum Purchase Customer(s) who did not meet its Minimum Purchase Requirement will be proportionate to its share of total under usage.
Tier 1 Water Shortage Allocation Plan
The Tier 1 Water Shortage Allocation Plan (“Tier 1 Plan” included as Attachment H of the WSA) is the method and process for allocating water from the RWS between San Francisco retail customers and the Wholesale Customers collectively during system-wide shortages caused by drought of 20% or less. Section 3.11.C.3 of the WSA provides that the SFPUC will honor allocations of water among the Wholesale Customers (“Tier 2 Allocations”) provided by BAWSCA or if unanimously agreed to by all Wholesale Customers.
The Tier 1 and Tier 2 Plans were implemented for the first time during the 2021 to 2023 drought. During the 2014 to 2017 drought, the Tier 1 and Tier 2 Plans were superseded by state-wide mandates from the Governor. During Tier 2 Plan negotiations, BAWSCA, the SFPUC, and the Wholesale Customers agreed to update the Tier 1 Plan to add a new “Tier 1 Family Plan.”
When the SFPUC declares a shortage emergency, it determines whether voluntary or mandatory rationing is required. At the end of the 12-month drought period, each Wholesale Customer’s purchases from the RWS are compared to their annual drought allocation. Excess use charges are only applied during mandatory rationing periods.
The new Tier 1 Family Plan ensures that excess use charges are only applied when the collective Wholesale Customer usage exceeds the Tier 1 allocation. If this occurs, excess use charges will be proportionally applied to agencies that exceeded their individual Tier 2 Allocations. For example, if the twenty-six Wholesale Customers collectively exceed the Tier 1 allocation by 2 MGD, and only two agencies exceed their Tier 2 Allocations by 3 MGD each, then these two agencies will share the excess use charges proportionally.
General Updates to the WSA
Sections 2.03, 3.09, 9.07, and Attachment A, Definitions of “Imputed Sales” and “Level of Service Goals and Objectives” have been updated with current cross references, dates and corrections.
Updated Tier 2 Drought Response Implementation Plan
The updated Tier 2 Plan maintains many of the key elements of the existing Tier 2 Plan, such as a rolling base period that captures service area growth over time and inclusion of Individual Supply Guarantee (ISG), but it also provides necessary updates to ensure a minimum supply of RWS water for base/indoor use for the portion of each service area where RWS is delivered. 6 4
5 0
Tier 2 Plan Update Process
Between January 2022 and June 2024, BAWSCA facilitated negotiations between the Wholesale Customers through a series of meetings, workshops, and workgroups to update the Tier 2 Plan.
The Wholesale Customers began by reviewing the prior Plan and other shortage allocation plans throughout the state, then discussed and agreed upon policy principles for a revised Tier 2 Plan. BAWSCA, with support from a technical consultant team, introduced potential elements of a formula to align with the agreed upon policy principles. In monthly workshops, the Wholesale Customers discussed these options and provided feedback on which elements should be included, along with suggested refinements. These workshops, and the discussions, suggestions, and comments expressed by the Wholesale Customers during this process, provided the primary forum through which the updated Tier 2 Plan was developed.
Tier 2 Plan Policy Principles
The Wholesale Customers collectively developed four policy principles to guide the development and performance of the updated Tier 2 Plan. These policy principles are outlined below.
Policy Principle #1 - Provide sufficient water for the basic health and safety needs of customers.
Policy Principle #2 - Minimize economic and other adverse impacts of water shortages on customers and the BAWSCA region.
Policy Principle #3 - Provide predictability of drought allocations through consistent and predetermined rules for calculation, while allowing for flexibility to respond to unforeseen circumstances.
Policy Principle #4 - Recognize benefits of, and avoid disincentives for, water use efficiency and development of alternative water supply projects.
Tier 2 Plan Allocation Formula
The updated Tier 2 Plan establishes a sequential allocation formula to determine how the available water from the RWS will be allocated among the individual Wholesale Customers.
The allocation formula can generally be described as follows:
The Minimum and Maximum Cutback establish the upper and lower bounds for each Wholesale Customer’s final allocation. The Minimum Cutback is equal to 1/3 of the Overall Average Wholesale Customer Reduction, but no less than 5%. The Maximum Cutback is equal to 1.5 times the Overall Average Wholesale Customer Reduction. 6 4
5 0
Each Wholesale Customer is allocated water on a residential per capita basis based on the State Indoor Water Use Efficiency Standard3 and the portion of each Wholesale Customer’s water demand met by the RWS.
Each Wholesale Customer is allocated water based on its estimated non-residential indoor use by applying a cutback factor equal to half of the Overall Average Wholesale Customer Reduction to each Wholesale Customer’s estimated non-residential indoor demand, also known as Base Period purchase, from the RWS. Each Wholesale Customer is allocated water based on its estimated seasonal purchases from the RWS.
Remaining water is allocated to bring each Wholesale Customer’s final allocation as close to its “Target Allocation” as possible, while ensuring that each Wholesale Customer’s final allocation is between the Minimum and Maximum Cutback bounds.
The Target Allocation is based on a weighted share of (1) the Wholesale Customer’s Base Period purchases from the RWS and (2) its ISG.
Tier 2 Plan Term
The term of the updated Tier 2 Plan is coordinated with the term of the WSA to avoid simultaneous renegotiation of these related agreements.
FISCAL/RESOURCE IMPACT
Amendments to the Water Supply Agreement
Minimum Purchase Requirements
The amendments to the WSA regarding the MPQs will have a small impact on the cost of water for all Wholesale Customers and SFPUC’s retail customers. Some of the four MPQ agencies are currently paying for water they are unable to use due to decreased demands and investments in alternative supplies. This is particularly true for Palo Alto’s neighbor, Mountain View, which has paid more than $11 million in penalties over the past several years.
Because the RWS revenue requirement must be recovered through water rates, reducing the MPRs for the four customers is estimated to cost all Wholesale Customers and SFPUC’s retail customers an additional $0.007-$0.04 per ccf (hundred cubic feet). This is approximately a
0.13%-0.72% water rate increase.
Tier 1 Water Shortage Allocation Plan
The amendments to the WSA regarding the Tier 1 Plan modification will have no adverse impact on Palo Alto. However, the amendments do have potential benefits. If Palo Alto were to 3 SB 1157 (Hertzberg), signed into law in September 2022, established the standard for efficient indoor residential water use be 47 gallons per capita per day, lowering to 42 GPCD in 2030. 6 4
5 0
exceed its water allocation during a drought, but the Wholesale Customers collectively use less than the total wholesale allocation, Palo Alto will not be charged excess use fees.
General Updates to the WSA
These amendments are administrative and have no fiscal or resource impact.
Updated Tier 2 Drought Response Implementation Plan
The negotiated Tier 2 Plan does not result in a fiscal or resource impact but does yield slightly higher water cutbacks for Palo Alto during droughts. This is mainly due to the large amount of outdoor water use in the City which is of relatively lower importance in times of shortage compared to indoor uses.
During times of water shortages, Palo Alto implements a Water Shortage Contingency Plan which lays out increasingly strict water use restrictions depending on the “stage” of shortage.
The differences between the current Tier 1 Plan and the new negotiated Tier 2 Plan are small enough such that the actions Palo Alto customers will be asked to take will not change.
For example, for a 20% Wholesale Customer cutback, the current Tier 1 Plan results in a 16% cutback for Palo Alto whereas the new Tier 2 Plan results in an 18% cutback for Palo Alto. Stage 2 of Palo Alto’s Water Shortage Contingency Plan covers cutbacks from 11%-20% and institutes water use restrictions such as the application of potable driveways and sidewalks.
STAKEHOLDER ENGAGEMENT
The San Francisco Public Utilities Commission voted unanimously to approve the WSA amendments at its May 13, 2025, Commission meeting via Resolution 25-00744.
As of the end of July 2025, 11 of the 26 BAWSCA agencies have approved the WSA amendments and the updated Tier 2 Drought Response Implementation Plan. Eight agencies, including Palo Alto, are scheduled to approve by August with the remaining 7 planned in the following month or shortly thereafter.
This item was discussed at the UAC's June 4, 2025, meeting, however, the Commission did not provide a recommendation. The majority of the Commissioners expressed agreement with the terms and conditions though some discussion was raised regarding additional costs to the City.
Staff clarified the additional cost of the Minimum Purchase Requirement amendment is $0.007 to $0.040 per ccf (0.13% to 0.72% rate increase). Other Commissioners opened the discussion beyond the agreements recommended for adoption and began discussing other efforts underway with SFPUC and BAWSCA and the desire to hold recommended approvals for leverage. Specifically, two Commissioners suggested holding the recommended approval until the UAC received additional information from SFPUC related to underlying assumptions and analysis for SFPUC’s worst-case drought scenario and demand projections for the purposes of 4 Resolution 25-0074 https://sfpuc.sharefile.com/share/view/s126c89893d1642f4b023bfb290442f85 6 4
5 0
alternative water supply planning. These Commissioners mentioned an upcoming BAWSCA Policy Committee meeting. Other Commissioners questioned whether and what additional information would be available next month and noted that staff was not working on preparing anything. The discussion was too far-reaching to summarize in full, the video can be seen here5 with the UAC discussion starting at about 1:37. Ultimately the Commissioners voted on two motions. The first motion to recommend Council approve these resolutions failed 3 (Scharff, Mauter, and Croft in favor): 3 (Tucher, Gupta, Metz against) with Commissioner Phillips absent.
A second motion for the item to be continued to the next month also failed 2 (Gupta and Tucher in favor): 4 (Scharff, Mauter, Metz, and Croft against), with Commissioner Phillips absent.
ENVIRONMENTAL REVIEW
Approval of a resolution amending the Amended and Restated Water Supply Agreement between the City and County of San Francisco and Wholesale Customers in Alameda County, San Mateo County and Santa Clara County is not a "project" for the purposes of CEQA as it involves an administrative activity that does not result in a direct change to the environment (see 14 CCR Section 15378(b)(5)), and would not result in a direct or reasonably foreseeable indirect physical change in the environment (see 14 CCR Section 15060(c)(2)). Approval of a resolution approving the updated the Tier 2 Drought Response Implementation Plan is categorically exempt from the California Environmental Quality Act as an action taken by a regulatory agency for the protection of natural resources (CEQA Guidelines Section 15307), and an as action taken by a regulatory agency for protection of the environment (CEQA Guidelines Section 15308).
ALTERNATIVE ACTIONS
The three components addressed in the two proposed resolutions are the result of several years of negotiations and cannot be disentangled from one another.
Amendments to the WSA must be and were approved by the SFPUC on May 13, 2025. All 26 BAWSCA agencies must also approve the amendments to enact these changes.
The negotiated Tier 2 Plan must be approved by all 26 BAWSCA agencies. If Palo Alto or any other Wholesale Customer fails to approve the Tier 2 Plan, the BAWSCA Board of Directors may determine a new methodology. If the BAWSCA Board takes no action or cannot come to an agreement, the SFPUC will determine a Tier 2 formula and decide how water will be allocated among the Wholesale Customers in a water supply shortage.
ATTACHMENTS
Attachment A: Resolution Amending the Amended and Restated Water Supply Agreement 5 UAC June 4, 2025 Meeting, UAC Discussion started at about 1:37 https://www.youtube.com/watch?v=agZwObaclBo
6 4
5 0
Attachment B: Resolution Approving the Updated Tier 2 Drought Allocation Implementation Plan
Attachment C: Redlines of the Water Supply Agreement Amendments Attachment D: CLEAN Water Supply Agreement Amendments
APPROVED BY:
Alan Kurotori, Director of Utilities
Staff: Karla Dailey, Assistant Director of Utilities, Resource Management Division