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EKI ENVIRONMENT & WATER, INC.
Water Supply Assessment for
the City of San Carlos
Northeast Area Specific Plan
Mid-Peninsula District
California Water Service
March 2025
EKI C40175.00
www.ekiconsult.com
2001 Junipero Serra Blvd, Suite 300 • Daly City, CA 94014
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June 08, 2026 Packet Pg. 1891
Water Supply Assessment
City of San Carlos Northeast Area Specific Plan
Mid-Peninsula District, California Water Service
TABLE OF CONTENTS
1 INTRODUCTION ................................................................................................................ 5
1.1 WSA Determination ........................................................................................................ 6 2 GENERAL REQUIREMENTS FOR THE PREPARATION OF A WATER SUPPLY ASSESSMENT ... 11
2.1 Applicability of Senate Bill 610 to the Project ............................................................... 11
2.2 Responsibility for Preparation of the Water Supply Assessment .................................. 12
2.3 Components of a Water Supply Assessment ................................................................ 12
2.4 Cal Water’s Development Offset Program .................................................................... 13 3 PROJECT DESCRIPTION ................................................................................................... 14 4 PROJECT WATER DEMAND ............................................................................................. 16
4.1 Indoor Water Use ......................................................................................................... 16
4.1.1 Residential Use ...................................................................................................... 16
4.1.2 General Office/General Commercial/Retail Use .................................................... 17
4.1.3 Retail (Non-Food) Use ............................................................................................ 17
4.1.4 Total Indoor Water Use ......................................................................................... 17
4.2 Outdoor Water Use ...................................................................................................... 17
4.2.1 Covered Parking Water Use ................................................................................... 17
4.2.2 Landscape Water Use ............................................................................................ 17
4.2.3 Total Outdoor Water Use ...................................................................................... 18
4.3 Distribution System Losses ........................................................................................... 19
4.4 Existing Current Water Demand on the Proposed Project Site ..................................... 19
4.5 Total Project Water Demand ........................................................................................ 19 5 CAL WATER MID-PENINSULA DISTRICT WATER DEMAND................................................ 23
5.1 Current and Historical Water Demand Within the Cal Water Mid-Peninsula District Service Area ............................................................................................................................ 23
5.2 Mid-Peninsula District Water Demand Projections ...................................................... 24
5.3 Planned Development Projects within the Mid-Peninsula District ............................... 24
5.4 Total Projected Mid-Peninsula District Water Demand (Inclusive of the Proposed Project) ................................................................................................................................... 25 6 CAL WATER MID-PENINSULA DISTRICT WATER SUPPLY .................................................. 28
6.1 Identification of Water Supply Rights ........................................................................... 28
6.1.1 SFPUC Regional Water System .............................................................................. 28
6.1.2 Surface Water Supply ............................................................................................ 35
6.1.3 Groundwater Supply .............................................................................................. 37
6.1.4 Cal Water Bay Area Water Supply Reliability Study ............................................... 43
6.2 Total Potable Supply in Normal, Single Dry, and Multiple Dry Years ............................ 43
6.2.1 Scenario 1: Implementation of the Bay-Delta Plan Amendment ............................ 44 March 2025 1 of 69 EKI C40175.00
10.b
June 08, 2026 Packet Pg. 1892
6.2.2 Scenario 2: Without implementation of the Bay-Delta Plan Amendment or the Proposed Voluntary Agreement .......................................................................................... 45
6.2.3 Scenario 3: Implementation of the Proposed Voluntary Agreement ...................... 46 7 COMPARISON OF SUPPLY AND DEMAND ........................................................................ 61 8 CONCLUSIONS ................................................................................................................ 65 9 REFERENCES ................................................................................................................... 66 March 2025 2 of 69 EKI C40175.00
10.b
June 08, 2026 Packet Pg. 1893
Water Supply Assessment
City of San Carlos Northeast Area Specific Plan
Mid-Peninsula District, California Water Service
TABLE OF CONTENTS (CONTINUED)
FIGURES
Figure 1 City of San Carlos Northeast Area Specific Plan Figure 2 Cal Water’s Three Peninsula Districts
Figure 3 Regional Setting and Groundwater Basin
TABLES
Table 1 Project Buildout Phasing Schedule
Table 2 Summary of Estimated Incremental Annual Project Water Demand Table 3 Estimated Project Landscaping Water Demand
Table 4 Historical Water Demand for the Mid-Peninsula District Table 5 Projected Future Water Demand for the Mid-Peninsula District Table 6 Historical Water Supply for the Mid-Peninsula District Table 7 Historical and Projected Groundwater Pumping from the Westside Basin Table 8 Historical and Projected Water Supply and Demand by Source Table 9 Projected Normal Year Water Supply and Demand
Table 10a Scenario 1: Projected Single Dry Year Water Supply and Demand with Implementation of the Bay-Delta Plan Amendment
Table 10b Scenario 2: Projected Single Dry Year Water Supply and Demand without Implementation of the Bay-Delta Plan Amendment
Table 11a Scenario 1: Projected Multiple Dry Year Water Supply and Demand with Implementation of the Bay-Delta Plan Amendment
Table 11b Scenario 2: Projected Multiple Dry Year Water Supply and Demand without Implementation of the Bay-Delta Plan Amendment
APPENDICES
Appendix A City of San Carlos – Northeast Area Specific Plan NOP Appendix B Summary of Known Developments and their Cumulative Impacts in the Three Peninsula Districts
Appendix C 2021 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 (excluding attachments) Appendix D SFPUC Memorandum Re: Regional Water System Supply Reliability and UWMP 2020
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10.b
June 08, 2026 Packet Pg. 1894
calwater.com
March 14, 2025
Rendell Bustos
Senior Planner | Advance Planning Division
City of San Carlos
600 Elm Street
San Carlos, CA 94070
Dear Mr. Bustos,
This letter serves as the California Water Service Company's (Cal Water) formal approval of the Water Supply Assessment (WSA) for the City of San Carlos Northeast Area Specific Plan in the Mid-Peninsula District, California Water Service. This approval is contingent on the developer's compliance with any conditions set forth in the WSA by Cal Water.
Authority for this approval is pursuant to Cal Water's “Resolution to Approve Water Supply Assessment and Related Documents for New Developments” dated October 27, 2021 (attached).
Should you have any questions, please contact Michael Bolzowski at [email protected] or (408) 367-8338.
Sincerely,
Ken Jenkins
Chief Water Resource Sustainability Officer
CALIFORNIA WATER SERVICE
I Water Resource Sustainability Department 1720 North First Street San Jose, CA 95112
Quality. Service. Value:
10.b
June 08, 2026 Packet Pg. 1895
1 INTRODUCTION
Included herein is a Senate Bill (SB) 610-compliant water supply assessment (WSA) for the proposed City of San Carlos (City) Northeast Area Specific Plan (Proposed Project). The Proposed Project site is comprised of approximately 145 acres within the City of San Carlos' Harbor Industrial Area. It is roughly bounded by several mixed retail and commercial buildings to the northwest, U.S. Highway 101 to the northeast, Old County Road to the southwest, and a residential area to the southeast (Figure 1; MPWD, 2024a).
In total, the Proposed Project consists of approximately 4,508,000 gross square feet (sq ft) of new non-residential development and 1,890,000 gross sq ft of new residential development, which is comprised of 1,890 multi-family residential (MFR) dwelling units (MPWD, 2024a). Of this total square footage, an estimated 26,229 sq ft of non-residential and 361,000 sq ft (361 MFR dwelling units) of residential development fall within the California Water Service (Cal Water) Mid-Peninsula District’s (District’s) service area (MPWD, 2024c). The remaining Proposed Project area would be served by the Mid-Peninsula Water District (MPWD). Since the Proposed Project is partially located within the District’s service area, Cal Water will be a water service provider for the Proposed Project. It should be noted that the portions of the Proposed Project within MPWD’s service area boundaries are addressed in a WSA being separately prepared by MPWD.
The information provided in this WSA is consistent with California Water Code (CWC) §10910-10912 requirements and the California Department of Water Resources’ (DWR’s) Guidebook for Implementation of Senate Bill 610 and Senate Bill 221 of 2001: To Assist Water Suppliers, Cities, and Counties in Integrating Water and Land Use Planning, dated 8 October 2003.
The text of specific sub-sections of the CWC is included in greyed boxes and italicized font at the beginning of specific sections of this WSA. The information presented in those respective sections, and the associated tables and figures, respond directly to applicable CWC requirements.
The purpose of a WSA is to evaluate whether a water provider has sufficient water supply to meet the current and planned water demands within its service area, including the demands associated with the Proposed Project, during normal and dry hydrologic years over a 20-year time horizon.1 Given that the District shares its contractual allocation for its primary supply source (i.e., the City and County of San Francisco’s Regional Water System [RWS]) with Cal Water’s Bear Gulch and South San Fransisco Districts (referred to as the “three Peninsula Districts”, Figure 2), the collective projected supplies and demands for all three Peninsula Districts are considered in this WSA. More specifically, this WSA includes:
x A summary of the WSA requirements articulated in CWC §10910-10912 and a description of how they apply to the Proposed Project;
x A description and analysis of the current and projected future water demands of the Proposed Project through the year 2045;
1 The CWC specifies that a WSA must look at supplies and demand on a 20-year horizon (i.e., to 2044), but given the available data, this WSA looks beyond that to 2045.
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June 08, 2026 Packet Pg. 1896
x A description and analysis of the historical and current water demands for the District, and projected future water demands for the three Peninsula Districts’ service areas through the year 2045;
x A description and analysis of the current and projected future water supplies for the three Peninsula Districts’ service areas through the year 2045; and x A comparison of the water supplies and demands for the three Peninsula Districts’ service areas, including the projected water demands associated with the Proposed Project.
The information contained in this WSA is based primarily on Cal Water’s Mid-Peninsula, South San Francisco, and Bear Gulch Districts’ 2020 Urban Water Management Plans (UWMPs), except where updated with relevant water demand and supply reliability and other information provided by Cal Water, DWR, the San Francisco Public Utilities Commission (SFPUC), and the Bay Area Water Supply and Conservation Agency (BAWSCA).
1.1 WSA Determination
A significant source of uncertainty identified in this WSA is whether the Water Quality Control Plan for the San Francisco/Sacramento-San Joaquin Delta Estuary (Bay-Delta Plan Amendment)2 will be implemented and how it would affect the supply reliability of the RWS, which is Cal Water’s major source of supply. If implemented, the Bay-Delta Plan Amendment could significantly reduce water available from the Tuolumne River, which is the source of 85% of the water for the RWS. Following the State Water Resources Control Board’s (SWRCB’s) adoption of the Bay-Delta Plan Amendment, there were over a dozen active lawsuits challenging the Bay-Delta Plan Amendment given its potential to significantly reduce water supply available to the Bay Area. However, in March 2024, the Sacramento County Superior Court ruled in the SWRCB’s favor on all 116 claims by the 12 petitioners (BAWSCA, 2024a). In May 2024, the City and County of San Francisco and other water suppliers filed an appeal on this decision (BAWSCA, 2024b).
Since 2019, SFPUC has participated in negotiations with the State and other stakeholders to reach a compromise wherein a voluntary agreement could be adopted as an alternative or substitute for the Bay-Delta Plan Amendment that would minimize the impacts to the RWS. On 1 March 2019, SFPUC submitted a proposed voluntary agreement (Proposed Voluntary Agreement) to the State at the instruction of the SWRCB. On 9 November 2022, SFPUC signed a non-binding Memorandum of Understanding (MOU) with State representatives outlining conceptual deal points for a Tuolumne River Voluntary Agreement, described in further detail in Section 6.1.1.2. As of the date of this WSA, the MOU remains in effect, while the Proposed Voluntary Agreement is currently undergoing review and evaluation by the SWRCB (SFPUC, 2023b; BAWSCA, 2024b).
2 On 12 December 2018, through State Water Board Resolution 2018-0059, the State Water Board amended the Bay-Delta Plan. It adopted the amendments to the Bay-Delta Plan and the Final Substitute Environmental Document (SED) establishing the Lower San Joaquin River flow objectives and revised southern Delta salinity objectives. On 25 February 2019, the Office of Administrative Law approved the Bay-Delta Plan amendments, which are now in effect.
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10.b
June 08, 2026 Packet Pg. 1897
Given the ongoing negotiations, litigation, and regulatory proceedings surrounding the Bay-Delta Plan Amendment, and based on information provided by the SFPUC and BAWSCA, this WSA analyzes water supply and demands through 2045 under three scenarios:
1. Scenario 1: Implementation of the Bay-Delta Plan Amendment
2. Scenario 2: Without implementation of the Bay-Delta Plan Amendment or the Proposed Voluntary Agreement
3. Scenario 3: Implementation of the Proposed Voluntary Agreement Scenario 1 (Implementation of the Bay-Delta Plan Amendment): With the implementation of the Bay-Delta Plan Amendment, the three Peninsula Districts have sufficient water supply to meet all expected future water demands in normal years. In dry years, the District will implement its Water Shortage Contingency Plan (WSCP) and apply the appropriate water demand reduction actions in order to ensure demand is met. Regardless of whether the Proposed Project is constructed, as described in Section 6.2.1 herein, with implementation of the Bay-Delta Plan Amendment, the three Peninsula Districts are projecting supply shortfalls of up to 44% during single dry years and up to 53% during multiple dry years in 2045 and will require significant demand reductions or the development of additional water supply sources. Cal Water is working independently and with the other BAWSCA agencies to identify mitigation measures to improve the reliability of regional and local water supplies and to meet its customers’ water needs. If conditions for large drought cutbacks to the RWS supplies exist, the District will need to implement additional demand reduction actions, invoke strict restrictions on potable water use, and accelerate efforts to develop additional supplies of water to ensure that its supplies remain sufficient to serve all users, including those of the Proposed Project.
Scenario 2 (Without Implementation of the Bay-Delta Plan Amendment or the Proposed Voluntary Agreement): Without the implementation of the Bay-Delta Plan Amendment, the three Peninsula Districts have sufficient water supply to meet all expected future water demands in normal years, single dry years, and most multiple dry years. As discussed in Section 6.2.2 herein, it is anticipated that the three Peninsula Districts will face supply shortfalls of 14% during the fourth and fifth years of a multiple dry year scenario in 2045, during which the District will implement its WSCP to curtail demands and ensure that its supplies remain sufficient to serve all users, including those of the Proposed Project.
Scenario 3 (Implementation of the Proposed Voluntary Agreement): The SFPUC is in active negotiations with the State to see if a compromise can be reached wherein the impacts of the Bay-Delta Plan Amendment to the RWS can be minimized. Under this scenario, the three Peninsula Districts are assumed to have sufficient water to meet all of their future water demands in normal years. It is anticipated that, in single and multiple dry year scenarios, the District would implement its WSCP to curtail demands and ensure that its supplies remain sufficient to serve all users, including those of the Proposed Project. This scenario assumes that demand will not be curtailed beyond the SFPUC Level of Service (LOS) goal of not exceeding 20% system wide rationing.
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10.b
June 08, 2026 Packet Pg. 1898
This WSA concludes that the three Peninsula Districts’ supplies are sufficient to meet projected future demands, inclusive of the Proposed Project. Based on currently available information and conservative estimates of projected demand, Cal Water expects to be able to meet all future demands within its existing District service area (as well as the South San Francisco and Bear Gulch Districts), inclusive of the Proposed Project, in normal hydrologic years. The shortfalls that are currently projected during dry years will be addressed through planned implementation of the District’s WSCP. In addition, as described herein and in Cal Water’s 2020 UWMP, BAWSCA, Cal Water, and SFPUC are pursuing the development of additional water supplies to improve the RWS and District supply reliability.
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10.b
June 08, 2026 Packet Pg. 1899
Date of Issue: 01/27/2015
Date of Update: 01/27/2015 Data Source:
CalWater: February 2025
ESRI World Topo Map: September 2024
Legend
Northeast Area Specific Plan
MPWD Service Area
Cal Water Service Area
Cal Water Portion
San Carlos City Boundary
Figure 1:
City of San Carlos Northeast Area
Specific Plan
CALIFORNIA WATER
SERVICE
1720 North First Street
San Jose, CA 95112
(408) 367 - 8200
Project Site
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CJ
~ ..... -.. • I L •. - ••
10.b
June 08, 2026 Packet Pg. 1900
San Francisco County
San Mateo County
San Francisco County
Alameda County
San Mateo County
Santa Clara County
Project Site
± 12,000 0 12,000 6,000 Feet
Date of Issue: 01/27/2015
Date of Update: 01/27/2015 Data Source:
CalWater: October 2024
ESRI World Topo Map: September 2024
Legend
Project Boundary
County Boundary
District
Bear Gulch
Mid-Peninsula
South San Francisco
Figure 2:
Cal Water's Three Peninsula Districts
CALIFORNIA WATER
SERVICE
1720 North First Street
San Jose, CA 95112
(408) 367 - 8200
March 2025 10 of 69 EKI C40175.00
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10.b
June 08, 2026 Packet Pg. 1901
2 GENERAL REQUIREMENTS FOR THE PREPARATION OF A WATER SUPPLY
ASSESSMENT
The purpose of this section is to outline the types of projects that require the preparation of a WSA, who is responsible for preparation, and the necessary components of a WSA. This section also discusses the requirements of Cal Water’s existing Development Offset Program.
2.1 Applicability of Senate Bill 610 to the Project
In total, the Proposed Project consists of 1,890 dwelling units of new residential development.
Therefore, the Proposed Project satisfies the definition of a “project” requiring a WSA pursuant to SB 610 (CWC §10910(a) and CWC 10912(a)(6)).
; CWC § 10910
(a) Any city or county that determines that a project, as defined in Section 10912, is subject to the California Environmental Quality Act (Division 13 (commencing with Section 21000) of the Public Resources Code) under Section 21080 of the Public Resources Code shall comply with this part. ; CWC § 10912
For the purposes of this part, the following terms have the following meanings:
(a) "Project" means any of the following:
(1) A proposed residential development of more than 500 dwelling units. (2) A proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space.
(3) A proposed commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space.
(4) A proposed hotel or motel, or both, having more than 500 rooms. (5) A proposed industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area. (6) A mixed-use project that includes one or more of the projects specified in this subdivision. (7) A project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500 dwelling unit project.
(b) If a public water system has fewer than 5,000 service connections, then “project” means any proposed residential, business, commercial, hotel or motel, or industrial development that would account for an increase of 10 percent or more in the number of the public water system’s existing service connections, or a mixed-use project that would demand an amount of water equivalent to, or greater than, the amount of water required by residential development that would represent an increase of 10 percent or more in the number of the public water system’s existing service connections.
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10.b
June 08, 2026 Packet Pg. 1902
2.2 Responsibility for Preparation of the Water Supply Assessment The City is served by two water purveyors: the District and MPWD. While the Proposed Project impacts both purveyors, this WSA specifically applies to the portion of the Proposed Project within the District’s service area, in which water will be supplied by Cal Water. Therefore, in accordance with Water Code §10910(b), Cal Water is the entity responsible for preparation and adoption of a WSA for the portions of the Proposed Project within the District’s service area.
2.3 Components of a Water Supply Assessment
As listed above in CWC §10910(c)(4), the primary purpose of a WSA is to evaluate whether sufficient water supply is available to meet all future demands within the water supplier’s service area, including those associated with the Proposed Project, during normal and dry hydrologic years for a 20-year planning horizon.3 Given that the District shares its contractual allocation for its primary supply source (i.e., the City and County of San Francisco’s RWS) with Cal Water’s three 3 The Water Code specifies that a WSA must look at supplies and demand on a 20-year horizon (i.e., to 2040), but given the available data, this WSA looks beyond that to 2045. ; CWC § 10910
(b) The city or county, at the time that it determines whether an environmental impact report, a negative declaration, or a mitigated negative declaration is required for any project subject to the California Environmental Quality Act pursuant to Section 21080.1 of the Public Resources Code, shall identify any water system that is, or may become as a result of supplying water to the project identified pursuant to this subdivision, a public water system, as defined in Section 10912, that may supply water for the project. If the city or county is not able to identify any public water system that may supply water for the project, the city or county shall prepare the water assessment required by this part after consulting with any entity serving domestic water supplies whose service area includes the project site, the local agency formation commission, and any public water system adjacent to ; CWC § 10910
(c)(4) If the city or county is required to comply with this part pursuant to subdivision (b), the water supply assessment for the project shall include a discussion with regard to whether the total projected water supplies, determined to be available by the city or county for the project during normal, single dry, and multiple dry water years during a 20-year projection, will meet the projected water demand associated with the proposed project, in addition to existing and planned future uses, including agricultural and manufacturing uses. ; CWC § 10911
(b) The city or county shall include the water supply assessment provided pursuant to Section 10910, and any information provided pursuant to subdivision (a), in any environmental document prepared for the project pursuant to Division 13 (commencing with Section 21000) of the Public Resources Code. (c) The city or county may include in any environmental document an evaluation of any information included in that environmental document provided pursuant to subdivision (b). The city or county shall determine, based on the entire record, whether projected water supplies will be sufficient to satisfy the demands of the project, in addition to existing and planned future uses. If the city or county determines that water supplies will not be sufficient, the city or county shall include that determination in its findings for the project.
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10.b
June 08, 2026 Packet Pg. 1903
Peninsula Districts (Figure 2), the collective projected supplies and demands for all three Peninsula Districts are considered in this WSA. More specifically, this WSA includes:
x A description and analysis of the current and projected future water demands of the Proposed Project through the year 2045;
x A description and analysis of the historical and current water demands for District, and projected future water demands for the three Peninsula Districts’ service areas through the year 2045;
x A description and analysis of the current and projected future water supplies for the three Peninsula Districts’ service areas through the year 2045; and x A comparison of the water supplies and demands for the three Peninsula Districts’ service areas, including the projected water demands associated with the Proposed Project.
2.4 Cal Water’s Development Offset Program
In July 2021, Cal Water began development of a Development Offset Program (Program) for its three Peninsula Districts, which share the same SFPUC supply allocation. The purpose of the Program is to ensure that overall customer demand for water does not exceed available current or future supply under a range of hydrologic conditions, and to ensure the availability of water for residential, commercial, and other purposes for future water use in the three Peninsula Districts (Cal Water, 2022).
As described in Advice Letter No. 2453 to the California Public Utilities Commission (CPUC), dated 7 June 2022, the Program will require any new residential, commercial, or industrial development within any of the three Peninsula Districts that is projected to increase net demand by more than 50 acre-feet per year (AFY) to pay a special facilities fee, referred to as a “developer offset fee”, of $15,400 per acre-feet of net demand increase. The developer offset fee will be used to fund accelerated water supply projects and expanded customer conservation programs. The net demand increase is defined as the expected total potable water use for the development once it is completed, minus the average annual existing potable water use on the property over the previous five years. As described in Section 4.5, the water demand estimated for the Proposed Project is less than 50 AFY, and therefore the Proposed Project is not required to comply with the Program at this time. Cal Water will verify the requirements for compliance with this Program prior to establishing a water service connection. As noted above, the findings of this WSA are contingent upon compliance with this Program. Final determination will be made when the Proposed Project is connected to the Cal Water system, based on the Program requirements at that time.
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10.b
June 08, 2026 Packet Pg. 1904
3 PROJECT DESCRIPTION
The Proposed Project site is comprised of approximately 145 acres located in the City of San Carlos, California. The Proposed Project site is currently bordered by several mixed retail and commercial buildings to the northwest, a residential area to the southeast, U.S. Highway 101 to the northeast, and Old County Road to the southwest (Figure 1; MPWD, 2024a). In total, the Proposed Project involves the construction of approximately 4,508,000 sq ft of non-residential development and 1,890,000 sq ft of residential development, including a total of 1,890 MFR dwelling units (MPWD, 2024a). Of this, an estimated 26,229 sq ft of non-residential and 361,000 sq ft of residential development, comprising 361 MFR units, fall within Cal Water’s service area.
In addition to these land uses, approximately 143,160 sq ft of covered parking and 16,557 sq ft of irrigated landscaping are expected to fall within Cal Water’s service area as part of the Proposed Project (MPWD, 2024b; 2024c).
A detailed site plan for the Proposed Project is included in Appendix A and shows the “Sub Areas” used in the Proposed Project to identify growth and zoning. Residential Mixed-Use Sub Area 1 and Residential Mixed-Use Sub Area 2 include areas served by both MPWD and Cal Water. Based on the area distribution, Cal Water serves approximately 31% of Residential Mixed-Use Sub Area 1 and 17% of Residential Mixed-use Sub Area 2. These percentages were applied to the land use categories for each Block to estimate the total land use allocated to each service area. Based on this analysis, it is projected that within the Cal Water service area these blocks will include:
x 361 MFR dwelling units;
x Approximately 21,560 sq ft of general office/general commercial/retail space use; x Approximately 4,669 sq ft of retail use;
x Approximately 143,160 sq ft of covered parking; and
x Approximately 16,557 sq ft of irrigated landscaping.
The Proposed Project would be built out over an approximate 20-year period, and it is assumed that the incremental buildout for the Proposed Project from 2025 to 2045 is linear (MPWD, 2024a). Table 1 shows the estimated land use and completion date for the Proposed Project site.
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10.b
June 08, 2026 Packet Pg. 1905
309 51 361 du
21,560 0 21,560
3,125 1,544 4,669
122,760 20,400 143,160
18,466
Abbreviations:
"Cal Water" = California Water Service "Proposed Project" = San Carlos Northeast Area Specific Plan "du" = dwelling units "sq ft" = square feet
Notes:
(a)
(b) Estimated full buildout date per Reference 2.
(c)
(d)
References:
1. 2.
3. Completion Date (b) Land Use
Units
Multi-Family Residential (c)
Land Use
General Office/General
Commercial/Retail
Retail
Total Land Use (a)
Landscaped Irrigation
Table 1
Project Buildout Phasing Schedule
San Carlos Northeast Area Specific Plan, City of San Carlos, California Block G Block I
Estimated square footage of irrigated landscaping is assumed to be 10% of the total parcel area of Block G and Block I for the Proposed Project within Cal Water’s service area, per Reference 3.
MPWD, 2024b. Email response to questions, provided by Cal Water on 22 November 2024. sq ft
(d)
2045
Estimated land use square footages for the general office/general commercial/retail, retail, and covered parking land uses and the number of dwelling units per Reference 1.
Covered Parking
MPWD, 2024c. Updated project information, provided by Cal Water on 19 December 2024.
City of San Carlos, 2024. City of San Carlos Planning Division Notice of Preparation of a Draft Environmental Impact Report for the San Carlos Northeast Area Specific Plan, dated 1 July 2024, provided by MPWD on 3 July 2024.
Since the portion of the Proposed Project served by Cal Water is based on the area distribution (process described in further detail in Section 3), the totals of multi-family residential units do not sum due to rounding.
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10.b
June 08, 2026 Packet Pg. 1906
4 PROJECT WATER DEMAND
The City of San Carlos has adopted green building standards and water efficient landscaping ordinances consistent with previous versions of the California Green Building Standards Code— Part 11, Title 24, California Code of Regulations (CalGreen) building standards and the California Model Water Efficient Landscape Ordinance (MWELO). Proposed Project landscaping will also be consistent with Assembly Bill (AB) 1572. As part of state requirements, all new developments must comply with these efficiency standards. As such, the Proposed Project development is expected to include a number of water-efficient features, including, but not limited to:
x Use of low-flow lavatory faucets, kitchen faucets, toilets, and urinals in accordance with CalGreen Code; and
x Inclusion of low-water use landscaping and high-efficiency irrigation systems to minimize outdoor water use in accordance with MWELO and AB 1572.
As described below, annual water demand for the portion of the Proposed Project within Cal Water’s service area was estimated based on: (1) the Cal Water WSA Water Factor Tool developed based on 2016-2018 water use data for the District (Cal Water, 2019); (2) water demand factors from various literature sources; and (3) information provided by MPWD in coordination with Cal Water (MPWD, 2024a; 2024b; 2024c). Table 2 includes a summary of the water demand projections associated with the proposed land uses within Cal Water’s service area at completion of the Proposed Project. Full buildout of the Proposed Project is assumed to be completed by 2045 (City of San Carlos, 2024).
4.1 Indoor Water Use
Table 2 provides a summary of the land uses, unit demand factors, and respective water demands associated with each land use anticipated in the portion of the Proposed Project within Cal Water’s service area. The following sections provide a summary of the calculations and assumptions for each indoor land use category.
4.1.1 Residential Use
The portion of the Proposed Project within Cal Water’s service area includes the construction of 361 MFR dwelling units. The water use factor for the proposed MFR dwelling units was developed by Cal Water using the Cal Water WSA Water Factor Tool, which was developed based on customer-level metered water use records for 2016 through 2018 for the District customers (Cal Water, 2019). The WSA Water Factor Tool allows the user to select appropriate water use factors for a proposed development based on factors including the mean characteristics of the sample data (e.g., existing service area building stock) or to customize the water use factors based on the expected characteristics of the proposed development.
Based on the WSA Water Factor Tool, the MFR dwelling units associated with the portion of the Proposed Project within Cal Water’s service area are estimated to use 99 gallons per day per dwelling unit (GPD/du). Applying this water factor, the MFR component of the Proposed Project is expected to use approximately 40 AFY at full buildout as shown in Table 2.
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10.b
June 08, 2026 Packet Pg. 1907
4.1.2 General Office/General Commercial/Retail Use
The portion of the Proposed Project within Cal Water’s service area includes approximately 21,560 sq ft of general office/general commercial/retail land use (MPWD, 2024c). The water use factor used for office space is 0.055 GPD/sq ft from the Draft Environmental Impact Report (EIR) for the Genentech Campus Master Plan Update (Genentech, 2019). Based on this demand factor, the resultant water demand associated with the general office/general commercial/retail use for the portion of the Proposed Project within Cal Water’s service area by full buildout is estimated to be 1.3 AFY.
4.1.3 Retail (Non-Food) Use
The portion of the Proposed Project within Cal Water’s service area includes approximately 4,669 sq ft of retail space not intended for food use (MPWD, 2024c). The water use factor used in calculating the demands for retail use is 0.032 GPD/sq ft from the United States Energy Information Administration (USEIA) Water Consumption in Large Buildings Summary (USEIA, 2012). Based on this demand factor, the total estimated retail use for the portion of the Proposed Project within Cal Water’s service area by full buildout is estimated to be 0.17 AFY.
4.1.4 Total Indoor Water Use
Based on the above calculations and assumptions, total indoor water use for the portion of the Proposed Project within Cal Water’s service area is estimated to be 42 AFY at full buildout. This excludes the distribution system losses discussed in Section 4.3.
4.2 Outdoor Water Use
4.2.1 Covered Parking Water Use
The portion of the Proposed Project within Cal Water’s service area includes approximately 143,160 sq ft of covered parking (City of San Carlos, 2024; MPWD, 2024c). Water use associated with this space is anticipated to be minimal, limited to cleaning of the facility. For purposes of this WSA, it is assumed that the garage will be cleaned 12 times per year and that
0.02 gallons/sq ft will be used per each cleaning event (City of Los Angeles Bureau of Engineering, 2012). Thus, it is estimated that by full buildout 0.11 AFY will be used for the purpose of cleaning the parking garage.
4.2.2 Landscape Water Use
The projected water demand for the landscaped area included as part of the Proposed Project within Cal Water’s service area was estimated based on the Maximum Applied Water Allowance (MAWA; DWR, 2020). The MWELO requires that the annual estimated total water use for landscape irrigation does not exceed the MAWA (DWR, 2020). As shown below, the MAWA is calculated based on the regional reference evapotranspiration rate, an evaporation adjustment March 2025 17 of 69 EKI C40175.00
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factor, the total landscaped area, and the area of “special landscaped area.”4 Water use for the Proposed Project landscaping irrigation has been conservatively assumed to be equal to the MAWA, which is the upper limit of annual applied water for established landscaped areas.
The MAWA is calculated using the following equation:
MAWA = ETo × [(ETAF x LA) + (1-ETAF) × SLA]
where:
ETo = The regional reference evapotranspiration rate
ETAF = Evapotranspiration Adjustment Factor
For SLAs = 1.0
For non-residential uses = 0.45
For residential uses = 0.55
LA = Total landscape area (including SLA)
SLA = Special Landscape Area
Based on the above methodology and assuming a total landscape area of 18,466 sq ft for the portion of the Proposed Project within Cal Water’s service area (MPWD, 2024b; 2024c), the total annual water use for the community landscaping is estimated to be 0.68 AFY at full buildout as shown in Table 3 (excluding the distribution system losses discussed in Section 4.3).
AB 1572 was signed into law in October 2023 and took effect in January 2024. This regulation prohibits the use of potable water for the irrigation of nonfunctional turf5 located on commercial,
industrial, and institutional (CII) properties, other than a cemetery, and on properties of homeowners’ associations, common interest developments,6 and community service organizations or similar entities. AB 1572, however, does not prohibit the use of potable water for irrigation of other types of landscaping, such drought-tolerant landscaping. It is important to note that MAWA already incorporates conservative measures that limit the total water use for landscape irrigation. Therefore, this WSA assumes that landscaping for the Proposed Project will be equal to the MAWA and comply with AB 1572.
4.2.3 Total Outdoor Water Use
Based on the above calculations and assumptions, total outdoor water use for the Proposed Project is estimated to be 0.78 AFY at full buildout. This excludes the distribution system losses discussed in Section 4.3.
4 Special Landscaped Area includes landscaping dedicated solely to edible plants, recreational areas, areas irrigated with recycled water, or water features using recycled water. 5 Nonfunctional turf is defined as any turf that is not functional turf, and includes turf located within street rights-ofway and parking lots. Nonfunctional turf excludes recreational areas, or areas designated by a property owner or a governmental agency to accommodate human foot traffic for recreation, including, but not limited to, sports fields, golf courses, playgrounds, picnic grounds, or pet exercise areas. 6 A common interest development is defined as a community apartment project, a condominium project, a planned development, or a stock cooperative.
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4.3 Distribution System Losses
Water distribution systems experience a degree of water loss over the course of transmission from the source to the customer. Although distribution system losses from the newly constructed portion of the system’s infrastructure associated with the Proposed Project would initially be expected to be minimal, it is conservatively assumed that distribution system losses associated with delivering water for the portion of the Proposed Project within Cal Water’s service area will ultimately be consistent with the proportion of real and apparent water loss per the most recent (2022) water loss audit submitted to DWR for the San Carlos system of the District (i.e., 3.9%; Cal Water, 2023). Table 2 shows the distribution system losses for the Proposed Project, estimated to be 1.7 AFY at full buildout.
4.4 Existing Current Water Demand on the Proposed Project Site The portion of the Proposed Project within Cal Water’s existing service area has historically been used for mixed commercial and retail use. Historical water use at the site ranged between 2.5 AFY and 3.5 AFY between 2019 and 2023, and averaged 2.8 AFY (Cal Water, 2024b). Water demand by the new development is considered incremental to this existing demand, and thus, as shown in Table 2, the average of the last five years of existing site demand is subtracted from the estimated demands associated with the Proposed Project.
4.5 Total Project Water Demand
Based on the above methodologies and assumptions, the water demand associated with the portion of the Proposed Project within Cal Water’s service area at full buildout and occupancy is estimated to be 41 AFY, as shown in Table 2.
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Table 2
Summary of Estimated Incremental Annual Project Water Demand 2025 2030 2035 2040 2045
361 du 99 gpd/du 8.0 16 24 32 40
21,560 0.055 0.27 0.53 0.80 1.1 1.3
4,669 0.032 0.033 0.067 0.10 0.13 0.17
Covered Parking (d) 143,160 0.020 gal/sq
ft/cleaning 0.021 0.042 0.063 0.084 0.11
Landscape Irrigation (e) 18,466 -- -- 0.14 0.27 0.41 0.54 0.68 -- 3.9% -- 0.3 0.7 1.0 1.4 1.7
Existing Site Demand (g) -- -- -2.8 -2.8 -2.8 -2.8 -2.8 0 15 24 32 41
Abbreviations:
"gpd" = gallons per day
"Cal Water" = California Water Service "MAWA" = Maximum Applied Water Allowance "Proposed Project" = San Carlos Northeast Area Specific Plan "DWR" = California Department of Water Resources "sq ft" = square feet "gal" = gallons "WSA" = Water Supply Assessment
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)
"du" = dwelling units
Demand
Factor Units
Notes:
"AFY" = acre-feet per year
sq ft
San Carlos Northeast Area Specific Plan, City of San Carlos, California Land Use
Units
Net Annual Water Demand (h)
Water Use Total Water Demand (AFY) (c)
General Office/General
Commercial/Retail
Retail
Total Land
Use (a)
Demand
Factor (b)
gpd/sq ft
Distribution System
Losses (f)
Multi-Family Residential
Estimated land use square footages and number of dwelling units per Reference 1.
Demand factors for retail per Reference 2, for general office/general commercial/retail land use per Reference 3, and for multi-family residential use per Reference 4.
Estimated full buildout date and schedule per Reference 5.
Existing site demands per Reference 9. Existing demands are subtracted from total projected water demands to show the incremental increase in demands associated with the Proposed Project (i.e., net increase in water demand).
Existing demands are estimated as the average of the last five years of water use at the project site based on available metered data (2019-2023).
Irrigation demands are calculated using the MAWA, per Reference 7.
Estimated distribution system water loss associated with delivery of water to the Proposed Project is based on a rate of
3.9% per Reference 8 and includes both real and apparent losses.
Totals may not sum due to rounding.
Water use associated with the covered parking is anticipated to be minimal, limited to cleaning of the facility. For purposes of this WSA, it is conservatively assumed that the facility will be cleaned twelve times per year and that 0.020 gal/sq ft will be used per each cleaning event, per Reference 6.
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Table 2
Summary of Estimated Incremental Annual Project Water Demand San Carlos Northeast Area Specific Plan, City of San Carlos, California References:
1. 2.
3. 4.
5. 6.
7. 8.
9. Cal Water, 2024b. Billed water consumption data provided by Cal Water on 12 December 2024.
Genentech, 2019. Genentech Campus Master Plan Update Draft Environmental Impact Report, prepared by LamphierGregory, dated October 2019.
MPWD, 2024a. Project information, provided by Cal Water on 31 October 2024.
City of Los Angeles Bureau of Engineering, 2012. City of Los Angeles Bureau of Engineering, City of Los Angeles Bureau of Sanitation, Sewer Generation Rates Table, dated 6 April 2012.
MPWD, 2024c. Updated project information, provided by Cal Water on 19 December 2024.
USEIA, 2012. US Energy Information Administration 2012 Commercial Buildings Energy Consumption Survey: Water Consumption in Large Buildings Summary.
DWR, 2020. California Code of Regulations, Title 23, Division 2, Chapter 2.7, Model Water Efficient Landscape Ordinance, 29 September 2020.
Cal Water, 2023. California Water Service Company Mid-Peninsula 2022 Water Audit Data Report, accessed via the WUEdata - Water Audit Report Data website on 12 November 2024, (https://wuedata.water.ca.gov/awwa_plans).
Cal Water, 2019. Cal Water WSA Water Factor Tool, developed by M.Cubed, dated 22 October 2019.
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[A] [B] [C] [F]
Area of Annual Reference Maximum Applied Water
Land Use Evapotranspiration Allowance (MAWA)
(ac) (a) Rate (in) (b) (AFY)
F = A x B x C (d)
0.42 43 0.45 0.68
0.68 Abbreviations:
"ac" = acre
"AFY" = acre-feet per year
"ETAF" = Evapotranspiration Adjustment Factor
"in" = inches
"MAWA" = Maximum Applied Water Allowance
"Proposed Project" = San Carlos Northeast Area Specific Plan Notes:
(a)
(b) Annual reference evapotranspiration rate for the City of Redwood City area per Reference 2. (c)
(d) The MAWA calculations are described in Reference 3.
References:
1. 2.
3. DWR, 2020. California Code of Regulations, Title 23, Division 2, Chapter 2.7, Model Water Efficient Landscape Ordinance, 29 September 2020.
Table 3
Estimated Project Landscaping Water Demand
San Carlos Northeast Area Specific Plan, City of San Carlos, California Landscaping Land Use
An ETAF of 0.45 was used for non-residential landscaping area per Reference 3. Although there are multi-family residential uses associated with the Proposed Project, the non-residential landscaping ETAF was applied for the total landscaped area as these residential areas will be developed as mixed-use.
Evapotranspiration
Adjustment Factor
(ETAF) (c)
Estimated Total Outdoor Water Use for Landscaping
MPWD, 2024b. Email response to questions, provided by Cal Water on 22 November 2024.
DWR, 2012. California Irrigation Management Information System Reference Evapotranspiration Zones, January 2012.
Non-Residential Landscaped
Area
Landscaping area is assumed to be 10% of the total parcel area for the Proposed Project within Cal Water’s service area per Reference 1.
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5 CAL WATER MID-PENINSULA DISTRICT WATER DEMAND
Consistent with the UWMP Act (CWC §10610-10656), the 2020 UWMPs for the three Peninsula Districts present estimates of projected future water demand for each respective District service area in five-year increments, between the years 2025 and 2045 (Cal Water, 2021a; 2021b; 2021c).
The 2020 UWMP projections include all existing demands within the District.7 A summary of water demands associated with other planned development projects within the three Peninsula Districts is provided in Appendix B.
Although the Proposed Project is not explicitly mentioned in the District’s 2020 UWMP, the demands associated with the Proposed Project fall within the projected account growth and total projected increase in water demand for the District. Therefore, demands associated with the portion of the Proposed Project within Cal Water’s service area are assumed to be accounted for in the District’s 2020 UWMP’s demand projections.
5.1 Current and Historical Water Demand Within the Cal Water Mid-Peninsula District Service Area
Historical water demand within the District’s service area from 2000 through 2023 is summarized in Table 4. The largest proportion of water demand within the District is from the single family residential sector, which represented 58% of the demand in the 2018-2023 period. The remainder of the demand was split between commercial (19% of overall demand), MFR (16% of 7 Demand estimates for the District’s service area through 2045 were developed using Cal Water’s demand forecast model, which estimates future demands based on current water use for the District, anticipated growth based on projections by the Association of Bay Area Governments (ABAG), projected water conservation efforts, and anticipated passive conservation savings.
; CWC § 10910
(c)(1) The city or county, at the time it makes the determination required under Section 21080.1 of the Public Resources Code, shall request each public water system identified pursuant to subdivision (b) to determine whether the projected water demand associated with a proposed project was included as part of the most recently adopted urban water management plan adopted pursuant to Part 2.6 (commencing with Section 10610). (2) If the projected water demand associated with the proposed project was accounted for in the most recently adopted urban water management plan, the public water system may incorporate the requested information from the urban water management plan in preparing the elements of the assessment required to comply with subdivisions (d), (e), (f), and (g).
(3) If the projected water demand associated with the proposed project was not accounted for in the most recently adopted urban water management plan, or the public water system has no urban water management plan, the water supply assessment for the project shall include a discussion with regard to whether the public water system's total projected water supplies available during normal, single dry, and multiple dry water years during a 20-year projection will meet the projected water demand associated with the proposed project, in addition to the public water system's existing and planned future uses, including agricultural and manufacturing uses.
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the overall demand), institutional/government (5.6% of the overall demand), other (0.74% of overall demand), and industrial (0.26% of overall demand; Cal Water, 2024a).
Water use from 2000 to 2008 within the District remained fairly consistent, at an average of 18,578 AFY. A slight decrease in water use occurred from 2008 to 2012, which generally corresponds with the 2007 to 2009 drought and the economic downturn. Then, a significant drop in water demand occurred in 2014 and 2016, corresponding with the historic drought and mandatory statewide water use restrictions and water conservation targets. The water use slightly increased from 2016 to 2020, before decreasing once more due to the recent 2021-2023 drought. Based on the data summarized in Table 4, total water demand for the District averaged 13,733 AFY from 2019 through 2023.
5.2 Mid-Peninsula District Water Demand Projections
Projected water demands for the District are documented in the District’s 2020 UWMP and presented in Table 5 in five-year increments. Taking into account historical water use, expected population increase and other growth, climatic variability, and other assumptions, the 2020 UWMP estimates that water demand within the District is projected to increase to 15,279 AFY by 2045,7 an increase of 13% over the 2019-2023 average.
5.3 Planned Development Projects within the Mid-Peninsula District The District 2020 UWMP water demand projections account for growth within the District’s service area through 2045. The 2020 UWMP projections are based on population, housing, and employment projections developed by the Association of Bay Area Governments (ABAG).
As discussed in Section 5.2 above, the updated water demand projections account for growth within the current District, and the Proposed Project is assumed to be included in this growth. In addition to the Proposed Project, Cal Water recently completed WSAs for the following projects, all of which are also located within the District:
x Alexandria District for Science and Technology project – An approximately 1,735,000 sq ft office/R&D development over a 25-acre site (EKI, 2022a); x 803-851 Old County Road project – An approximately 325,500 sq ft office/R&D development over a 3.4-acre site (EKI, 2022b); and
x 789 Old County and 1026 Bransten Road project – An approximately 295,000 sq ft office/R&D development over a 3.4-acre site (EKI, 2023).
Through implementation of Cal Water’s Development Offset Program (see Section 2.4), the Alexandria District for Science and Technology project would not result in a net increase in water demand for the District relative to those projected in the 2020 UWMP. However, the demands associated with the 803-851 Old County Road project and the 789 Old County and 1026 Bransten Road project are below the threshold for qualifying for Cal Water's Development Offset Program and thus are additive to District demands (Table 5).
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5.4 Total Projected Mid-Peninsula District Water Demand (Inclusive of the Proposed Project)
Table 5 shows the projected water demands for the District inclusive of the estimated Proposed Project water demands. As shown, the Proposed Project is assumed to be within the District’s total account growth and demand projections and will not increase the District’s projected demand beyond what was planned for in the 2020 UWMP.
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2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 San Mateo System 14,186 14,507 14,306 13,813 14,372 13,719 13,373 13,500 13,481 12,784 11,949 11,542 11,819 11,496 10,890 9,561 9,533 10,267 10,495 10,630 10,904 10,496 9,942 9,598 San Carlos System 4,820 4,794 4,791 4,572 4,827 4,536 4,363 4,569 4,679 4,285 4,008 4,047 4,059 4,369 3,786 3,129 3,002 3,335 3,430 3,418 3,679 3,488 3,330 3,179 Total Water Demand 19,006 19,301 19,097 18,385 19,198 18,255 17,736 18,069 18,160 17,069 15,957 15,589 15,878 15,865 14,676 12,690 12,535 13,602 13,925 14,047 14,584 13,984 13,272 12,778 Notes:"Cal Water" = California Water Service"AFY" = acre-feet per year Abbreviations:
(a) Historical water demands per Reference 1.
References:
1. Cal Water, 2024a. Historical demand and production data provided by Cal Water on 9 May 2024.
Category Cal Water Historical Annual Water Demand (AFY) (a) Historical Water Demand for the Mid-Peninsula District
San Carlos Northeast Area Specific Plan, City of San Carlos, California Table 4
0 5,000
10,00015,00020,00025,000
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
Total Water Use (AFY)
Historical Water Demand and Supply
San Mateo System San Carlos System
Single Family
58%
Multi-Family
Commercial 19%
16%
Institutional/
Industrial 0.26%
Governmental 5.6%
0.74%Other
2019-2023 Water Demand by Customer Sector
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Table 5
Projected Future Water Demand for the Mid-Peninsula District 2025 2030 2035 2040 2045
14,418 14,530 14,786 14,977 15,279
46 87 87 87 87
14,464 14,617 14,873 15,064 15,366
Abbreviations:
"AFY" = acre feet per year "Proposed Project" = San Carlos Northeast Area Specific Plan "District" = Mid-Peninsula District, Cal Water "UWMP" = Urban Water Management Plan Notes:
(a)
(b)
(c)
References:
1. Other Known Developments within the District (c)
Total Water Demand
Water demand projections for the District were updated in 2021 and are presented per Reference 1.
The demands associated with the Proposed Project are within the account and total water demand growth anticipated for District and are therefore assumed to be included in the 2020 UWMP demand projections.
Demands for other known developments that are not subject to Cal Water's Development Offset Program within the District can be found in Appendix B.
Cal Water, 2021a. 2020 Urban Water Management Plan, Mid-Peninsula District, prepared by California Water Service, dated June 2021.
San Carlos Northeast Area Specific Plan, City of San Carlos, California Water Demand Projected Annual Water Demand (AFY)
District 2020 UWMP (a)
Proposed Project (b) Included in District Demand Projections 0 2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
18,000
2025 2030 2035 2040 2045
Projected Water Demand (AFY)
Projected Water Demands
District 2020 UWMP (a) Other Known Developments within the District (c) March 2025 27 of 69 EKI C40175.00
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I
I
I
I
I
I
■
• • • • • • •
• • • • • • • ■
• • • • • • •
• • • • • • •
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6 CAL WATER MID-PENINSULA DISTRICT WATER SUPPLY
This section identifies the District’s water supplies and discusses the vulnerability of the various supplies to drought and other factors affecting water supply reliability.
6.1 Identification of Water Supply Rights
Pursuant to CWC §10910(d)(1), a WSA is required to include identification of all water supply entitlements, water rights, and water service contracts relevant to the identified water supply for the Proposed Project. In accordance with these requirements, this WSA includes a summary of Cal Water’s water supply sources in the District service area and the agreements between Cal Water and its wholesale supplier, the SFPUC, and other parties.
As discussed further below, three Cal Water Districts share one contractual allocation of supply from the City and County of San Francisco’s RWS, and thus manage the supplies for all three Peninsula Districts collectively. Therefore, the consideration of supply availability below for the District considers the collective supply available to all three Peninsula Districts (i.e., the Mid-Peninsula, Bear Gulch, and South San Francisco Districts).
6.1.1 SFPUC Regional Water System
6.1.1.1 RWS Supply Sources and Allocation
As shown in Table 6, the singular source of the water supply to the District is treated water purchased from the City and County of San Francisco’s RWS, which is operated by the SFPUC.
Within the District, Cal Water takes delivery from eleven active and three standby metered turnouts from RWS transmission lines (Cal Water, 2021a). The RWS supply originates predominantly from the Sierra Nevada but also includes treated water produced by the SFPUC from its local watersheds and facilities in Alameda and San Mateo Counties. Approximately 85% of the RWS supply is from the Tuolumne River via the Hetch-Hetchy Reservoir and aqueducts.
The Cal Water RWS supply is sourced from the remaining 15%, which is derived from local watersheds and the San Antonio, Calaveras, Crystal Springs, Pilarcitos, and San Andreas Reservoirs.
The business relationship between the City and County of San Francisco and its Wholesale Customers (including Cal Water) is largely defined by the Water Supply Agreement between the City and County of San Francisco and Wholesale Customers in Alameda County, San Mateo County, and Santa Clara County (Agreement) entered into in July 2009. The Agreement, which ; CWC § 10910
(d)(1) The assessment required by this section shall include an identification of any existing water supply entitlements, water rights, or water service contracts relevant to the identified water supply for the proposed project, and a description of the quantities of water received in prior years by the public water system, or the city or county if either is required to comply with this part pursuant to subdivision (b), under the existing water supply entitlements, water rights, or water service contracts.
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has a 25-year term, addresses water supply availability for the RWS as well as the methodology used by the SFPUC in setting wholesale water rates. This Agreement supersedes an earlier 25-year agreement signed in 1984 and was amended in 2019. The amendments included extending the deadline for SFPUC to decide whether to make San Jose and Santa Clara permanent customers, a revision to the drought allocation formula, and a deadline extension for completion of its Water Supply Improvement Plan, among other things (SFPUC, 2021c). A copy of this Agreement (without signatures) is included in Appendix C .
The Agreement provides a 184 MGD Supply Assurance to the SFPUC’s Wholesale Customers collectively (Cal Water, 2021a). This allocation was reached through negotiation in the early 1990s between the SFPUC and the Bay Area Water Users Association (BAWUA), the predecessor organization to BAWSCA. The Agreement was first signed by Cal Water, along with 29 other Bay Area water suppliers, as part of the 1984 Settlement Agreement and Master Water Sales Contract with San Francisco, supplemented by individual Water Supply Contracts (Cal Water, 2016). The Supply Assurance is subject to reduction during periods of water shortage due to drought, emergencies, or other scenarios resulting in a water shortage. Each Wholesale Customer’s share of the 184 MGD is referred to as their Individual Supply Guarantee (ISG). Although the Agreement expires in 2034, the Supply Assurance and ISG continue in perpetuity as both are subject to separate binding water allocation agreements described above and would continue beyond the term of the Agreement. At expiration of the Agreement, it is likely that a new agreement will be entered into as was done at the termination of the prior 1984 agreement.
Cal Water’s contractual allocation of SFPUC supply is shared among its Bear Gulch, Mid-Peninsula, and South San Francisco Districts. Cal Water’s ISG for the three Peninsula Districts was originally 35.39 MGD (39,642 AFY). However, the acquisition of the Los Trancos County Water District in July 2005 resulted in the transfer of 0.11 MGD of ISG to Cal Water, and in 2009 Cal Water acquired the Skyline County Water District, which also transferred its 0.181 MGD ISG to Cal Water. These acquisitions increased Cal Water’s total ISG to 35.68 MGD (39,993 AFY) (Cal Water, 2016).
Information regarding the Agreement and subsequent amendments was provided by BAWSCA in coordination with SFPUC in support of 2020 UWMP development and is provided verbatim below.
In the 2009 Water Supply Agreement, the SFPUC committed to make three decisions before 2018 that affect water supply development:
x Whether or not to make the cities of San Jose and Santa Clara permanent customers,
x Whether or not to supply the additional unmet supply needs of the Wholesale Customers beyond 2018, and
x Whether or not to increase the wholesale customer Supply Assurance above 184 mgd.
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Events since 2009 made it difficult for the SFPUC to conduct the necessary water supply planning and CEQA analysis required to make these three decisions before 2018.
Therefore, in the 2018 Amended and Restated Water Supply Agreement, the decisions were deferred for 10 years to 2028.
Additionally, there have been recent changes to instream flow requirements and customer demand projections that have affected water supply planning beyond 2018. As a result, the SFPUC has established an Alternative Water Supply Planning program to evaluate several regional and local water supply options. Through this program, the SFPUC will conduct feasibility studies and develop an Alternative Water Supply Plan by July 2023 to support the continued development of water supplies to meet future needs.
6.1.1.2 RWS Supply Reliability
The RWS has historically met demand in its service area in all year types. Factors that will affect future reliability of the RWS are discussed below. Detailed information regarding factors that impact the SFPUC RWS supply reliability are provided in the 2020 UWMP.
The water available to SFPUC’s Retail and Wholesale Customers from the RWS is constrained by hydrology, physical facilities, and the institutional parameters that allocate the water supply of the Tuolumne River (Cal Water, 2021a). In addition, statewide regulations and other factors can impact the system reliability. For example, the adoption of the Water Quality Control Plan for the Bay-Delta Plan Amendment is anticipated to impact the reliability of the RWS supplies in the future.
Based on an analysis by BAWSCA, if the current Bay-Delta Plan Amendment (July 2018) is implemented, the proposed unimpaired flow volumes would significantly reduce water supply available through the RWS during future drought conditions, and BAWSCA member agencies (including the Cal Water Mid-Peninsula District) would be required to reduce their water use by as much as 50% during drought years (BAWSCA, 2018).
In support of 2020 UWMP development, SFPUC provided a detailed discussion of the factors contributing to the significant uncertainties surrounding the Bay-Delta Plan Amendment. This discussion is excerpted below:
In December 2018, the State Water Resources Control Board (SWRCB) adopted amendments to the Water Quality Control Plan for the San Francisco Bay/SacramentoSan Joaquin Delta Estuary (Bay-Delta Plan Amendment) to establish water quality objectives to maintain the health of the Bay-Delta ecosystem. The SWRCB is required by law to regularly review this plan. The adopted Bay-Delta Plan Amendment was developed with the stated goal of increasing salmonid populations in three San Joaquin River tributaries (the Stanislaus, Merced, and Tuolumne Rivers) and the Bay-Delta. The BayMarch 2025 30 of 69 EKI C40175.00
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Delta Plan Amendment requires the release of 30-50% of the “unimpaired flow”8 on the
three tributaries from February through June in every year type. In SFPUC modeling of the new flow standard, it is assumed that the required release is 40% of unimpaired flow.
If the Bay-Delta Plan Amendment is implemented, the SFPUC will be able to meet the projected water demands presented in this Urban Water Management Plan (UWMP) in normal years but would experience supply shortages in single dry years or multiple dry years. Implementation of the Bay-Delta Plan Amendment will require rationing in all single dry years and multiple dry years. The SFPUC has initiated an Alternative Water Supply Planning Program (AWSP) to ensure that San Francisco can meet its Retail and Wholesale Customer water needs, address projected dry years shortages, and limit rationing to a maximum 20 percent system-wide in accordance with adopted SFPUC policies. This program is in early planning stages and is intended to meet future water supply challenges and vulnerabilities such as environmental flow needs and other regulatory changes; earthquakes, disasters, and emergencies; increases in population and employment; and climate 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.
…
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 8 "Unimpaired flow represents the natural water production of a river basin, unaltered by upstream diversions, storage, or by export or import of water to or from other watersheds." (Water Quality Control Plan for the San Francisco Bay/Sacramento-San Joaquin Delta Estuary (Dec. 12, 2018) p.17, fn. 14, available at:
https://www.waterboards.ca.gov/plans_policies/docs/2018wqcp.pdf.) March 2025 31 of 69 EKI C40175.00
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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. 9, ,10
The 2020 UWMP further summarized the current sources of uncertainty regarding RWS dry year water supply projections. This discussion is excerpted (with minor refinements) below:
x Benefits of the AWSP are not accounted for in current supply projections. As discussed above, SFPUC is exploring options to increase its supplies through the AWSP.
Implementation of feasible projects developed under the AWSP is not yet reflected in the supply reliability scenarios presented herein and is anticipated to reduce the projected RWS supply shortfalls.
x Methodology for Tier One and Tier Two Wholesale drought allocations have not been established for wholesale shortages greater than 20%. As discussed further in Section
6.1.1.4, the current Tier One and Tier Two Plans are not designed for RWS supply shortages of greater than 20%. For UWMP planning purposes per BAWSCA guidance, the Tier One Wholesale share for a 16% to 20% supply reduction (62.5%) has been applied for reductions greater than 20% and an equal percent reduction has been applied across all Wholesale Customers. BAWSCA member agencies have not formally agreed to adopt this shortage allocation methodology and are in discussions about jointly developing an alternative allocation method that would consider additional equity factors if SFPUC is unable to deliver its contractual supply volume and cutbacks to the RWS supply exceed 20%.
x RWS demands are subject to change. The RWS supply availability is dependent upon the system demands. The supply scenarios are based on the total projected Wholesale Customer purchases provided by BAWSCA to SFPUC in January 2021. Many BAWSCA agencies have refined their projected demands during the UWMP process after these estimates were provided to SFPUC. Furthermore, the RWS demand projections are subject to change in the future based upon future housing needs, increased conservation, and development of additional local supplies.
x Frequency and duration of cutbacks are also uncertain. While the projected shortfalls presented in the UWMP appear severe, the actual frequency and duration of such shortfalls are uncertain. Based on the Hetch Hetchy and Local Simulation Model (HHLSM) simulations provided by BAWSCA for the Bay-Delta Plan Amendment scenario, rationing 9 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/. 10 As of 29 October 2021, state regulators announced that the Voluntary Agreement negotiations process has ceased, with no agreement reached. San Francisco Chronicle, “California Drought: Key Talks Over Water Use Break Down, SF May Face Tighter Regulation,” available at https://www.sfchronicle.com/sf/article/California-drought-Key-talks-over-water-use-16576132.php March 2025 32 of 69 EKI C40175.00
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is anticipated to be required 20% of years for base year 2025 through 2035, 23% of all years for base year 2040, and 25% of years for base year 2045. In addition to the supply volumes, the above listed uncertainties would also impact the projected frequency and duration of shortfalls. As such, in addition to evaluating local options to increase supply reliability, Cal Water has placed high priority on working with BAWSCA and SFPUC in the upcoming years to better refine the estimates of RWS supply reliability and may amend the 2020 UWMP when new information becomes available.
x Voluntary Agreement may be reached. The SFPUC 2020 UWMP also discussed that the implementation of the Bay-Delta Plan Amendment was under negotiation, through Voluntary Agreement negotiations between SFPUC, in partnership with other key stakeholders, and SWRCB. In November 2022, SFPUC, along with Governor Newsom's senior water policy officials and the Modesto and Turlock Irrigation Districts, reached an agreement on an MOU with an eight-year term. The MOU includes, among other things, protection of water supplies for RWS customers, as well as a commitment by the Tuolumne River parties for new flows in the Tuolumne River to benefit native fish species that are in addition to the current requirements. The MOU also provides that pending litigation concerning the adopted 2018 Bay-Delta Plan Amendment will be the subject of future negotiations.
x Appeal of Sacramento Superior Court Decision. On 10 May 2024, the City and County of San Francisco and other water suppliers filed an appeal of the Sacramento County Superior Court’s 2024 decision (discussed in more detail below). The appeal process is on-going (BAWSCA, 2024b).
Regardless of the recent progress made through the November 2022 MOU, a Voluntary Agreement has yet to be approved by the SWRCB as an alternative to the Bay-Delta Plan Amendment, and shortages and supply cutback values associated with this alternative are unknown. Despite this uncertainty, the relative degree of shortfall associated with the Voluntary Agreement is assumed to be less than under the Bay-Delta Plan Amendment, as further explained in a recently approved SFPUC WSA (SFPUC, 2022):
However, given that the objectives of the Voluntary Agreement are to provide fishery improvements while protecting water supply through flow and non-flow measures, the RWS supply shortfalls under the Voluntary Agreement would be less than those under the Bay-Delta Plan Amendment, and therefore would require water use reductions of a lesser degree. The degree of water use reduction would also more closely align with the SFPUC’s RWS [Level of Service] LOS goal of limiting water use reduction to no more than 20% on a system-wide basis in drought years.
Following SWRCB’s adoption of the Bay-Delta Plan Amendment, there were over a dozen active lawsuits challenging the Bay-Delta Plan Amendment given its potential to significantly reduce water supply available to the Bay Area. However, in March 2024, the Sacramento County Superior Court ruled in the SWRCB’s favor on all 116 claims by the 12 petitioners (BAWSCA, 2024a). In May 2024, the City and County of San Francisco and other water suppliers filed an appeal of the Sacramento County Superior Court’s 2024 decision (BAWSCA, 2024b). This is a dynamic situation, and the projected drought cutback allocations may need to be revised before March 2025 33 of 69 EKI C40175.00
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the next (i.e., 2025) UWMP process depending on court decisions and/or an adopted implementation policy.
Per the above, numerous uncertainties remain surrounding the implementation of the Bay-Delta Plan Amendment. The water supply projections presented in SFPUC’s 2020 UWMP likely represent a worst-case scenario in which the Bay-Delta Plan Amendment is implemented as adopted, and do not account for implementation of SFPUC’s AWSP or a Voluntary Agreement.
Additional information regarding drought allocations can be found in Section 8 of the SFPUC 2020 UWMP.
6.1.1.3 Efforts to Increase RWS Supply Reliability
On 2 June 2021, the SFPUC released a memorandum which outlines numerous options the SFPUC is pursuing to improve the supply reliability projected in its 2020 UWMP and meet its LOS Goals.
This memorandum is included as Appendix D. Furthermore, the SFPUC’s Water Supply Improvement Program (WSIP) and its Alternative Water Supply Plan (AWS Plan) articulate the SFPUC’s goals and objectives to improve the delivery reliability of the RWS, including water supply reliability.
The WSIP program goal is to improve the SFPUC’s ability to reliably meet its Retail and Wholesale Customers water needs in non-drought and drought periods. In 2008, the SFPUC adopted LOS Goals and Objectives in conjunction with the adoption of the WSIP. The SFPUC’s LOS Goals and Objectives include: (a) meeting average annual water demand of 265 MGD from the SFPUC watersheds for Retail and Wholesale Customers during non-drought years for system demands through 2028; (b) meeting dry-year delivery needs through 2028 while limiting rationing to a maximum 20% system-wide reduction in water service during extended droughts; (c) diversifying water supply options during non-drought and drought periods; and (d) improving use of new water sources and drought management, including groundwater, recycled water, conservation, and transfers (SFPUC, 2018). As of May 2023, WSIP local projects are 100% complete and regional projects are 92% complete, with the remaining regional projects forecasted to be approved and completed by February 2027 (SFPUC, 2023a).
Through the AWSP, the SFPUC developed its AWS Plan, which was released in February 2024.
The AWS Plan is a roadmap to guide water supply planning to help address projected supply shortfalls through 2045. The AWS Plan is intended to guide the AWSP decision-making process and provide recommendations on project implementation and areas for future analysis. The AWS Plan includes:
x Identification of the anticipated water supply gap through the 2045 planning horizon; x Description of ongoing efforts to reduce demands and optimize RWS supply availability; x Description of AWS Projects that can augment RWS supply and address the future water supply gap; and
x Recommendations that will further advance the AWSP (SFPUC, 2024a).
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Through implementation of its 2015 Long-Term Water Supply Reliability Strategy (2015 Strategy), BAWCSA is also actively evaluating opportunities to increase the supply reliability of the RWS (BAWSCA, 2015). The strategy includes short- and long-term implementation plans including water supply management projects that could be implemented to meet identified needs.
Potential projects include recycled water projects, desalination projects, water transfer projects, and local capture and reuse projects. Additionally, BAWSCA is currently updating its 2015 Strategy for a planning horizon of 2050 (Strategy 2050) as several significant changes on the supply, demand, project development, and regulatory fronts have impacted the regional water supply picture.
6.1.1.4 RWS Water Shortage Allocations
The Agreement includes a Water Shortage Allocation Plan (WSAP) that allocates water from the RWS to Retail and Wholesale Customers during system-wide shortages of 20% or less. As described in detail in the 2020 UWMP, the WSAP has two components:
1. The Tier One Plan, which allocates water between San Francisco and the Wholesale Customers collectively; and
2. The Tier Two Plan, which allocates the collective Wholesale Customer share among the Wholesale Customers.
It is noted that the dry year supply reliability projections provided herein under the Scenario 1 (Section 6.2) are obtained from the 2020 UWMP based on application of BAWSCA-provided revised methodology to allocate RWS supplies during projected future single dry and multiple dry years in the instance where the supply shortfalls are greater than 20%.11 However, BAWSCA member agencies are in discussions about jointly developing an allocation method that would consider additional equity factors in the event that SFPUC is not able to deliver its contractual supply volume, and its cutbacks to the RWS supply exceed 20%. While Cal Water is working independently and with the other BAWSCA agencies to identify regional mitigation measures to improve reliability for regional and local water supplies and meet its customers’ water needs, Cal Water expects that SFPUC’s LOS Goals and Objectives will be met and is comfortable assuming its contract with SFPUC will be honored as written.
6.1.2 Surface Water Supply
Surface water supplies a small portion of the three Peninsula Districts’ water demands. From 2016 to 2020, it supplied an average of 573 AFY, or less than 2% of total supplies (Cal Water, 2021b). Surface water is collected from the Bear Gulch Creek by two diversion facilities and is stored in Bear Gulch Reservoir prior to use.
11 The projected SFPUC RWS supplies presented in this WSA are based on dry year allocation projections included in the Mid-Peninsula, Bear Gulch, and South San Francisco District 2020 UWMPs based on the methodology, assumptions and information utilized and provided by SFPUC and BAWSCA; however, actual future supply allocations may vary based on actual shortage levels and the then-applicable allocation methodology being applied by BAWSCA and SFPUC.
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The Bear Gulch District diverts water from two points of diversion (PODs) along the creek – the Upper POD (with an upstream area of 2.5 square miles) and the Lower POD (with an upstream area of 9.4 square miles). Diversions from the Upper and Lower PODs are each governed by separate SWRCB-administered water rights (i.e., pre-1914 claimed water rights and post-1914 SWRCB-issues diversion permits/licenses) that specify the volumes, rates, and timing of allowed diversions at each POD. In addition to these SWRCB-administered water rights, diversions are further constrained by certain diversion limitations and minimum instream flow requirements imposed by the California Department of Fish and Wildlife (CDFW) at the Upper POD and by the National Oceanic and Atmospheric Administration (NOAA) at the Lower POD. There also exists a 1936 agreement with Stanford University that prohibits Cal Water from diverting more than 50% of the flows that pass by (i.e., are not diverted at) the Upper POD.
Water diverted from the Upper POD flows through a gravity conveyance pipeline to a junction point where it is joined by water diverted from the Lower POD, at which point the water is pumped into the Bear Gulch District-owned Bear Gulch Reservoir, a man-made storage facility impounded by an earthen dam. The Bear Gulch Reservoir is operated to have a minimum “dead pool” storage of 50 million gallons (MG), or approximately 153 AF. The maximum storage capacity of the reservoir has been reduced from 149 MG (547 AF) to 142.7 MG (438 AF), a limit imposed by the California Division of Safety of Dams (DSOD), based on a maximum storage elevation of 230 feet above mean sea level. Cal Water is undertaking capital improvements to Bear Gulch Reservoir to address DSOD’s seismic safety concerns and may also consider increasing the maximum storage capacity. Outflows from Bear Gulch Reservoir are currently limited by the DSOD to the rate that causes a water surface elevation decline of 0.3 feet per day.
Water stored in Bear Gulch Reservoir is released and sent through the Bear Gulch District-owned Bear Gulch Water Treatment Plant (BGWTP) prior to addition to the distribution system. The BGWTP, which was placed into operation in 1977, has a rated capacity of 6.0 MGD. There the water is clarified, filtered, and chloraminated in compliance with the Surface Water Treatment Rule and the Safe Drinking Water Act. Based on data from Water Years 1981 through 2019, annual production from the reservoir has ranged from a high of 2,809 AF (915 MG) in 1983 to a low of 0 AF (0 MG) in 2014.
Recent analysis by the Bear Gulch District has shown that the projected long-term average annual diversion amount by the Bear Gulch District from the Bear Gulch local surface water system is approximately 840 AFY. This estimate considers the hydrology of the watershed, the various regulatory constraints that govern diversions and current infrastructure limitations (i.e., pump, pipeline and treatment plant capacity). The storage capacity of Bear Gulch Reservoir is relatively small compared to average annual diversion/production, and therefore there is typically no carryover storage from one year to the next. Furthermore, given the various constraints on diversions at the Bear District’s two PODs under the SWRCB-administered water rights and the CDFW/NOAA-governed minimum instream flow requirements, the allowable diversions by the Bear Gulch District are significantly lower during dry years even though the creek itself maintains flow. Although local surface water diversions (and subsequent treatment and use of local surface water) have occurred historically during dry years, and the Bear District’s analysis indicates that March 2025 36 of 69 EKI C40175.00
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some diversions are likely to occur in future dry years12, for the purposes of its 2020 UWMP the Bear Gulch District conservatively assumed that local surface water supplies will be zero during single dry and multiple dry years over the planning horizon.
6.1.3 Groundwater Supply
12 Diversions from the Bear Gulch Creek system are estimated at 291 AF with a 90% exceedance probability. ; CWC § 10910
(f) If a water supply for a proposed project includes groundwater, the following additional information shall be included in the water supply assessment:
(1) A review of any information contained in the urban water management plan relevant to the identified water supply for the proposed project.
(2)(A) A description of any groundwater basin or basins from which the proposed project will be supplied. (B) For those basins for which a court or the board has adjudicated the rights to pump groundwater, a copy of the order or decree adopted by the court or the board and a description of the amount of groundwater the public water system, or the city or county if either is required to comply with this part pursuant to subdivision (b), has the legal right to pump under the order or decree. (C) For a basin that has not been adjudicated that is a basin designated as high- or medium-priority pursuant to Section 10722.4, information regarding the following:
(i) Whether the department has identified the basin as being subject to critical conditions of overdraft pursuant to Section 12924.
(ii) If a groundwater sustainability agency has adopted a groundwater sustainability plan or has an approved alternative, a copy of that alternative or plan. (D) For a basin that has not been adjudicated that is a basin designated as low- or very low priority pursuant to Section 10722.4, information as to whether the department has identified the basin or basins as overdrafted or has projected that the basin will become overdrafted if present management conditions continue, in the most current bulletin of the department that characterizes the condition of the groundwater basin, and a detailed description by the public water system, or the city or county if either is required to comply with this part pursuant to subdivision (b), of the efforts being undertaken in the basin or basins to eliminate the long-term overdraft condition.
(3) A detailed description and analysis of the amount and location of groundwater pumped by the public water system, or the city or county if either is required to comply with this part pursuant to subdivision (b), for the past five years from any groundwater basin from which the proposed project will be supplied. The description and analysis shall be based on information that is reasonably available, including, but not limited to, historic use records.
(4) A detailed description and analysis of the amount and location of groundwater that is projected to be pumped by the public water system, or the city or county if either is required to comply with this part pursuant to subdivision (b), from any basin from which the proposed project will be supplied. The description and analysis shall be based on information that is reasonably available, including, but not limited to, historic use records.
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The San Mateo Plain Basin (DWR Basin No. 2-009.03) underlies a portion of the Proposed Project and the majority of the District’s service area, as shown on Figure 3. The District does not currently pump groundwater to serve its customers and does not have future plans to add groundwater to its supply portfolio. However, groundwater pumped from the Westside Basin (DWR Basin No. 2-35) constitutes a portion of supply to the South San Francisco District, which as described in Section 6.1, shares its contractual allocation of SFPUC supply with the Mid-Peninsula and Bear Gulch Districts. Additional detail regarding Westside Basin description, groundwater management, and historical groundwater use in the Westside Basin is included below.
6.1.3.1 Basin Description
The Westside Basin underlies approximately 92% of the South San Francisco District service area, as shown in Figure 3. The Westside Basin covers an area of approximately 25,400 acres and is separated from the Lobos Basin to the north by a northwest trending bedrock ridge through the northeastern part of Golden Gate Park. The San Bruno Mountains bound the Westside Basin on the east. The San Andreas Fault and Pacific Ocean form its western boundary and its southern limit is defined by a bedrock high that separates it from the San Mateo Plain Subbasin. The Westside Basin is connected to the Pacific Ocean on the northwest and San Francisco Bay on the southeast (Cal Water, 2021a). The Westside Basin is not adjudicated and, in its recent evaluation of California groundwater basins, DWR determined that the Westside Basin was not in a condition of critical overdraft and designated the Westside Basin as low priority (DWR, 2019).
Geologically, the Westside Basin is comprised of two groups, consisting of bedrock and unconsolidated materials. The impermeable bedrock is composed of consolidated sediment of the Franciscan Complex and the Great Valley Sequence of late Jurassic and Cretaceous age.
Unconsolidated materials overlying the bedrock comprise the water bearing formations. These consist of dune sands, the Colma Formation of Pleistocene age and the Merced Formation of Pleistocene/ Pliocene age (Phillips and others, 1993; DWR, 2006).
Groundwater used for water supply within the Westside Basin is generally pumped from in the Merced and Colma Formations. The Merced Formation is composed of sand and thin interbedded silt and clay layers of shallow marine depositional origin. The Colma Formation overlies the Merced Formation and consists of fine-grained sand, silty sand, and inter-fingered clay layers (DWR, 2006; 2016). Water is produced from the coarse-grained layers within these complex, layered formations (WRIME, 2012).
; CWC § 10910
(f) If a water supply for a proposed project includes groundwater, the following additional information shall be included in the water supply assessment:
(5) An analysis of the sufficiency of the groundwater from the basin or basins from which the proposed project will be supplied to meet the projected water demand associated with the proposed project. A water supply assessment shall not be required to include the information required by this paragraph if the public water system determines, as part of the review required by paragraph (1), that the sufficiency of groundwater necessary to meet the initial and projected water demand associated with the project was addressed in the description and analysis required by paragraph (4) of subdivision (b) of Section 10631.
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The Westside Basin is subdivided for management purposes into northern and southern portions by the county line separating San Francisco and San Mateo counties. The county-line boundary between the “North Westside Basin” and the “South Westside Basin” does not have hydrogeological significance other than influencing the jurisdictional distribution of groundwater pumping. No geologic features restrict groundwater flow between the northern and southern parts of the Westside Basin (SFPUC, 2016). Groundwater pumping has historically provided up to 50% of local water supply in the South Westside Basin for the communities of San Bruno, Daly City, and South San Francisco (WRIME, 2012), although current usage is significantly less as a proportion.
The Westside Basin is not adjudicated and, in its recent evaluation of California groundwater basins, DWR determined that the Westside Basin was not in a condition of critical overdraft and was a low priority basin (DWR, 2019). Evaluations by others have also found that current pumping is estimated to be within the Westside Basin’s safe yield (WRIME, 2012).
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San Francisco County
Alameda County
San Mateo County
Santa Clara County
Project Site
WESTSIDE BASIN
(2-035)
SAN MATEO PLAIN BASIN
(2-009.03)
±
101 0.5 Miles
Data Source:
CalWater: October 2024
ESRI World Topo Map: September 2024
Legend
Project Boundary
Groundwater Basin
CWS Mid Peninsula Service Area
County Boundary
Figure 3:
Regional Setting & Groundwater Basin
CALIFORNIA WATER
SERVICE
1720 North First Street
San Jose, CA 95112
(408) 367 - 8200
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1111
Cl
IZI
I
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6.1.3.2 Groundwater Management
As described below, several groundwater management programs are actively implemented within the Westside Basin that have relevance to the Cal Water South San Franscisco District, and thus relevance to the Mid-Peninsula and Bear Gulch District given the shared contractual allocation of SFPUC supply between the three Cal Water Districts.
South Westside Basin Groundwater Management Plan
The South Westside Basin Groundwater Management Plan (GWMP) was completed in July 2012 as a joint effort between Cal Water, the SFPUC, and the Cities of Daly City and San Bruno that superseded prior groundwater management and planning efforts (WRIME, 2012). The GWMP was prepared pursuant to Assembly Bill 3030 (AB 3030; codified in CWC §10750 et seq.).13 The goal of the GWMP is to ensure a sustainable, high quality, reliable water supply at a fair price for beneficial uses achieved through local groundwater management (WRIME, 2012). The GWMP development was supported by a companion effort by the City of Daly City to develop a numerical groundwater model for the South Westside Basin. The GWMP includes the following elements:
x Groundwater Storage and Quality Monitoring;
x Control of Saltwater Intrusion;
x Conjunctive Use;
x Recycled Water; and
x Source Water Protection
Among other things, the GWMP provides steps for monitoring water quality and quantity in the South Westside Basin. Each groundwater well identified in the GWMP has defined triggers for overdraft, seawater intrusion, and various water quality measures. The GWMP also identifies two levels of trigger thresholds for each groundwater well based on historical water levels and actions to address the trigger that is met.
Regional Groundwater Storage and Recovery Project
In a joint effort between SFPUC, Cal Water, Daly City, and San Bruno, the Regional Groundwater Storage and Recovery Project (RGSR Project) was developed to support groundwater and surface water management in the South Westside Basin and improve the reliability of the RWS (Cal Water, 2021c; SFPUC, 2013). The RGSR Project agreement was signed in December 2014 following two phases of successful pilot programs. As part of the RGSR project agreement, the municipal pumpers within the South Westside Basin agreed to self-limit pumping within the South Westside basin to no more than 6.9 MGD, of which Cal Water’s designated quantity is an annual average rate of 1.37 MGD or 1,534 AFY.
13 AB 3030 provided a systematic procedure to develop a groundwater management plan by local agencies overlying DWR Bulletin 118 groundwater basins. Upon adoption of such plan, these agencies could possess the same authority as a water replenishment district to "fix and collect fees and assessments for groundwater management” (CWC §10754) (WRIME, 2012).
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Under the RGSR project, the SFPUC will provide supplemental RWS water to Cal Water and the other “Partner Agencies” (i.e. Cal Water, Daly City, and San Bruno) during normal and wet years and in turn the Partner Agencies will reduce their groundwater pumping in their own wells to allow the South Westside Basin to recharge.14 During dry years, the Partner Agencies may pump from RGSR project wells in addition to resuming use of their own wells up to designated quantities. The in-lieu recharge (i.e., “put”) and additional groundwater pumping from RGSR wells (i.e., “take”) under the RGSR project are tracked under the Westside Basin Storage Account.
Production wells in the South Westside Basin are considered to be either a RGSR Well Facility or a Partner Agency Facility, where only production from RGSR Well facilities is tracked under the RGSR project.
The RGSR Project is one of the SFPUC’s WSIP projects and provides additional dry-year water supply to help achieve the WSIP goals to increase RWS supply reliability. Phase 1 of the RGSR Project consisted of the construction of 13 well stations to produce approximately 6.2 MGD and associated facilities, such as pumping systems, pipelines, and chemical treatment equipment.
Phase 2 consisted of the installation of up to 3 test wells. The Phase 2 test wells will not be converted to production wells at this time, but will allow for determination as to whether the identified sites could be viable future production wells, and will provide valuable information related to water quality and potential pumping capacities that can be used for future planning and decision making. Construction for this project began in April 2015 and was completed in March 2023 (SFPUC, 2024c).
Sustainable Groundwater Management Act
In 2014, the California State Legislature enacted the Sustainable Groundwater Management Act (SGMA), with subsequent amendments in 2015. The SGMA requires the formation of Groundwater Sustainability Agencies (GSAs) and the development and implementation of Groundwater Sustainability Plans (GSPs) for groundwater basins that are designated by DWR as medium or high priority.
The Westside Basin is currently categorized by DWR as a very low priority basin (DWR, 2019). As such, the Westside Basin is not subject to the requirements of SGMA. However, as discussed above, the Westside Basin has been actively managed for years, including the establishment of pumping limitations.
6.1.3.3 Groundwater Use
Cal Water operates five groundwater production wells within its South San Francisco District service area (Cal Water, 2021c). The Basin is not adjudicated and, in its recent evaluation of 14 Supplemental deliveries do not count towards the Member Agencies’ ISGs.
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California groundwater basins, DWR determined that the Basin was not in a condition of critical overdraft and designated the Basin as low priority (DWR, 2019).
Historical groundwater pumping from 2010 through 2020 and projected groundwater pumping through 2045 for the four municipal groundwater users in the Basin are shown in Table 7. From 2010 through 2020, the average total groundwater production by these entities was approximately 5,065 AFY, of which 421 AFY was by Cal Water (SFPUC, 2024b). The total projected groundwater pumping by the RGSR Partner Agencies is conservatively assumed to be equal to each agency’s agreed-upon pumping limitation from 2020 through 2045, of which Cal Water is projected to pump up to 1,534 AFY (Cal Water, 2021c). The projected groundwater pumping by the City of San Francisco is based on projected pumping values included in Table 6-5 of SFPUC’s 2020 UWMP (SFPUC, 2021b).
6.1.4 Cal Water Bay Area Water Supply Reliability Study Cal Water recently completed the Bay Area Regional Water Supply Reliability Study (WSRS), which employs integrated resource planning practices to create a long-term supply reliability strategy through 2050 for the three Peninsula Districts (Woodard and Curran, 2022). The study creates long-term strategies to address a wide range of water supply challenges including climate change, new regulatory requirements (e.g., the Bay-Delta Plan Amendment), and potential growth in demands due to new development.
The Bay Area WSRS explores potential recycled water developments to augment supply in the three Peninsula Districts. Recycled water is not currently provided in the District service area and Cal Water has not projected recycled water use in its 2020 UWMP (Cal Water, 2021a). However, there is a coordinated effort between Cal Water and other partners to potentially develop recycled water for various uses. Cal Water is currently looking into purchasing recycled water from the City of Redwood City to serve portions of San Carlos. For purposes of this WSA, recycled water is not assumed as a supply source for the District.
6.2 Total Potable Supply in Normal, Single Dry, and Multiple Dry Years The projected potable water supply sources to the three Peninsula Districts, as described above, are surface water purchased from the RWS, local surface water from the Bear Gulch Reservoir, and groundwater from the Westside Basin. Historical supplies from 2019 through 2023 and projected normal year supplies through 2045 for each source are shown in Table 8. 15 This table
also shows the historical and projected demand for each of the three Peninsula Districts, based on updated demand projections included in their respective 2020 UWMPs along with projected demands associated with known developments in the Peninsula Districts that do not comply with Cal Water’s Development Offset Program. It should be noted that the jump in supply capacity from 2023 to 2025 is because the projected water supply is assumed to be equal to Cal Water's ISG from SFPUC, which is shared among the Bear Gulch, Mid-Peninsula, and South San Francisco 15 Projected groundwater and Bear Gulch Reservoir supply is shown based on the 2020 UWMP. Projected purchased SFPUC supply in normal years is based on Cal Water’s contract allocation of 35.68 MGD (39,993 AFY).
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June 08, 2026 Packet Pg. 1934
Districts, plus 840 AFY from the Bear Gulch Reservoir and 1,534 AFY from the South San Francisco District wells, 16 for a total supply of 42,367 AFY through 2045. This table also shows the historical and projected demand for each of the three Peninsula Districts, based on the demand projections included in their respective 2020 UWMPs.
Table 9 shows the projected demand by the three Peninsula Districts, with the inclusion of the Proposed Project and other known developments, and the total available supply through 2045.
The current and planned future water supply within the three Peninsula Districts for normal hydrologic years is assumed equal to the projected supplies presented in Table 9. Given the numerous uncertainties surrounding the implementation of the Bay-Delta Plan Amendment discussed above, this WSA analyzes water supply reliability through 2045 under three scenarios:
1. Scenario 1. Implementation of the Bay-Delta Plan Amendment as presented in the District’s 2020 UWMP. This scenario likely represents a worst-case scenario in which the Bay-Delta Plan Amendment is implemented as written and does not account for implementation of SFPUC’s AWSP.
2. Scenario 2. No implementation of the Bay-Delta Plan Amendment or the Proposed Voluntary Agreement based on information provided by SFPUC and BAWSCA included in Appendix I of the 2020 UWMP.
3. Scenario 3. Implementation of the Proposed Voluntary Agreement based on the assumption that demand will not be curtailed beyond the SFPUC LOS goal to not exceed 20% system-wide rationing as result of implementation of the Proposed Voluntary Agreement under negotiation.
A discussion of each scenario, along with the projected supplies and demands for the three Peninsula Districts under normal, single dry, and multiple dry year conditions, is presented below.
6.2.1 Scenario 1: Implementation of the Bay-Delta Plan Amendment As discussed above, this scenario likely represents a worst-case scenario where the Bay-Delta Plan is implemented as written. The anticipated dry-year supply estimates presented are based on the delivery estimates provided by Cal Water as part of the 2020 UWMP (Cal Water, 2021a; Cal Water, 2021b; Cal Water, 2021c).17 As discussed above, BAWSCA provided a revised methodology to allocate RWS supplies during projected future single dry and multiple dry years in the instance where the supply shortfalls are greater than 20% in support of 2020 UWMP development. However, BAWSCA member agencies are in discussions about jointly developing 16 These projected supply values for normal hydrologic years differ from what is presented in the 2020 UWMPs, which estimate a normal year supply equal to projected demand. 17 The projected SFPUC RWS supplies presented in this WSA are based on dry year allocation projections included in the South San Francisco, Bear Gulch, and Mid-Peninsula District 2020 UWMPs based on the methodology, assumptions and information utilized and provided by SFPUC and BAWSCA; however, actual future supply allocations may vary based on actual shortage levels and the then-applicable allocation methodology being applied by BAWSCA and SFPUC.
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an allocation method that would consider additional equity factors in the event that SFPUC is not able to deliver its contractual supply volume, and its cutbacks to the RWS supply exceed 20%.
During single dry years, assuming implementation of the Bay-Delta Plan Amendment, the annual supply within the three Peninsula Districts’ service areas will be reduced to 21,039 AFY by 2045.
Supply shortfalls relative to total demands during single dry years are estimated to range between 34% in 2025 and 44% in 2045 (see Table 10a).
During multiple dry years, the 2020 UWMP estimates that annual supply within the three Peninsula Districts’ service areas will be reduced to 23,615 AFY in 2025 during the first year of a drought, and 20,492 AFY in 2025 in the second, third, fourth, and fifth years of drought, assuming implementation of the Bay-Delta Plan Amendment. The 2020 UWMP further estimates that in 2045, annual supply will be reduced to 20,954 AFY during the first three years of a drought, and 18,061 AFY in fourth and fifth years of drought. Supply shortfalls relative to total demands are estimated to range between 36% during the first year of a drought in 2025 to 53% during the fifth year of a drought in 2045 (see Table 11a).
If the “worst-case” supply scenario described under Section 6.1.1.2 in which the Bay-Delta Plan Amendment is implemented as written, and not accounting for the implementation of actions identified as part of the Settlement Agreements, SFPUC’s AWSP, BAWSCA’s 2015 Strategy, or Cal Water’s WSRS, shortfalls of up to 53% are projected during drought years. To address this issue, under Rule 14.1, Cal Water plans to enact its WSCP, which includes Mandatory Staged Restrictions of Water Use. The WSCP systematically identifies ways in which the South San Francisco, Bear Gulch, and Mid-Peninsula Districts can reduce water demands during dry years.
The overall reduction goals in the WSCP are established for six drought stages and address water demand reductions of over 50%. The WSCPs for all three Peninsula Districts were revised as part of the 2020 UWMP update process and include detailed information about how drought risks are evaluated by Cal Water on an annual basis to determine the potential need for reductions.
6.2.2 Scenario 2: Without implementation of the Bay-Delta Plan Amendment or the Proposed Voluntary Agreement
This scenario represents the supply outlook for the three Peninsula Districts without implementation of the Bay-Delta Plan Amendment or the Proposed Voluntary Agreement. Under this scenario, all BAWSCA member agencies would be allocated 100% of their contractual supply volume during single and multiple dry years up through the third year of a multi-year drought in 2045, at which point the members would be subject to their Tier Two drought cutbacks.
As shown in Table 10b, during single dry years, the three Peninsula Districts are expected to meet all projected demands, which are estimated to be 37,743 AFY by 2045. During multiple dry years in which no Bay-Delta Plan Amendment is implemented, the three Peninsula Districts are expected to have sufficient supply to meet projected demands through the third year of a multi-year drought in 2045 (see Table 11b). During the fourth and fifth years of a multi-year drought in 2045, supplies would be reduced to 33,014 AFY, resulting in supply shortfalls of 14%.
These shortfalls would be addressed through implementation of the District’s WSCP.
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6.2.3 Scenario 3: Implementation of the Proposed Voluntary Agreement The 1 March 2019 Proposed Voluntary Agreement has yet to be accepted by SWRCB as an alternative to the Bay-Delta Plan Amendment and thus the shortages that would occur with its implementation are not known with certainty. However, given that the objectives of the Voluntary Agreement are to provide fishery improvements while protecting water supply through flow and non-flow measures, the RWS supply shortfalls under the Voluntary Agreement would be less than those projected under the Bay-Delta Plan Amendment, and therefore would require water use reductions of a lesser degree than that which would occur under Scenario 1.
Because negotiations of a Proposed Voluntary Agreement are not complete, no values are available to explicitly model this scenario.
It is anticipated that under this scenario, the District would have sufficient water to meet all projected demands in normal years. It is expected that the degree of water use reduction during dry years would also more closely align with the SFPUC’s RWS LOS goal of limiting water use reduction to no more than 20% on a system-wide basis in drought years. The Mid-Peninsula District would enact its WSCP to curtail demands and ensure that its supplies remain sufficient to serve all users, including those of the Proposed Project.
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2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Purchased Surface Water (b) 18,255 17,736 18,069 18,160 17,069 15,957 15,589 15,878 15,865 14,676 12,690 12,535 13,602 13,925 14,047 14,584 13,984 13,272 12,778 Total Water Supply 18,255 17,736 18,069 18,160 17,069 15,957 15,589 15,878 15,865 14,676 12,690 12,535 13,602 13,925 14,047 14,584 13,984 13,272 12,778 Abbreviations:"AFY" = acre-feet per year"Cal Water" = California Water Service Notes:
(a) Historical water supplies per Reference 1.
(b)
References:
1. Cal Water, 2024a. Historical demand and production data provided by Cal Water on 9 May 2024.
Table 6
Historical Purchased Water for the Mid-Peninsula District from SFPUC San Carlos Northeast Area Specific Plan, City of San Carlos, California Water purchased from the San Francisco Public Utilities Commission Regional Water System. Cal Water has an Individual Supply Guarantee of 35.68 million gallons per day (39,993 AFY), which is shared among its Mid-Peninsula, Bear Gulch, and South San Francisco Districts.
Historical Water Supply (AFY) (a) Water Supply Source
0 8,0006,0004,0002,000
20,00018,00016,00014,00012,00010,000
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Purchased Water (AFY)
Historical Purchased Water
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Table 7
Historical and Projected Groundwater Pumping from the Westside Basin San Carlos Northeast Area Specific Plan, City of San Carlos, California 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2025 2030 2035 2040 2045 Cal Water, SSF District (c) 453 515 606 995 1,028 1,312 528 0.40 35 31 52 101 34 199 1,534 1,534 1,534 1,534 1,534Daly City 1,743 2,699 3,772 3,351 3,452 1,980 941 62 59 56 51 1,167 2,355 1,478 3,840 3,840 3,840 3,840 3,840 San Bruno 2,364 2,129 1,596 2,198 2,025 2,164 937 303 333 277 311 1,076 2,314 1,053 2,350 2,350 2,350 2,350 2,350 San Francisco Municipal and Irrigation (d) 1,256 1,197 1,339 1,651 1,672 1,570 1,359 1,435 1,911 1,960 2,286 2,026 1,587 1,531 1,569 2,690 3,811 4,932 4,932 Total Groundwater Supply 5,816 6,540 7,313 8,195 8,177 7,026 3,765 1,800 2,338 2,324 2,700 4,370 6,290 4,261 9,293 10,414 11,535 12,656 12,656 Abbreviations:
"AFY" = acre-feet per year "SFPUC" = San Francisco Public Utilities Commission"Cal Water" = California Water Service "SSF" = South San FranciscoNotes:
(a)
(b)
(c)
(d)
References:
1. SFPUC, 2024b. 2023 Annual Groundwater Monitoring Report, Westside Basin, San Francisco and San Mateo Counties, California prepared by the San Francisco Public Utilities Commission, dated June 2024.2.3.
Projected Groundwater Production (AFY) (b)
Historical groundwater pumping as reported on Table 1 in Reference 1.SFPUC, 2021a. 2020 Urban Water Management Plan for the City and County of San Francisco, prepared by the San Francisco Public Utilities Commission, dated June 2021.Projected groundwater pumping by the South San Francisco District, City of Daly City, and City of San Bruno is conservatively estimated as the maximum apportionment for each partner agency as dictated by the Regional Groundwater Storage and Recovery Project, per Reference 2.
Historical Groundwater Production (AFY) (a)
Water Supplier
SFPUC, 2013. Draft Environmental Impact Report for the San Francisco Public Utilities Commission's Regional Groundwater Storage and Recovery Project, dated April 2013.
Cal Water is currently participating in an in-lieu program with SFPUC. From June 2016 to June 2021, Cal Water reduced pumping to 20% of the Designated Quantity (1,534 AFY) and received in-lieu water from SFPUC. From July 2021 to February 2023, all pumping and in-lieu deliveries were halted due to drought conditions. Reduced pumping and in-lieu deliveries resumed in March 2023.
Projected groundwater pumping by San Francisco Municipal and Irrigation provided per Reference 3. 0 8,0006,0004,0002,000
14,00012,00010,000
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2025 2030 2035 2040 2045 Water Supply (AFY)
Historical and Projected Groundwater Production
San Francisco Municipal and Irrigation (d) San Bruno Daly City Cal Water, SSF District (c) March 2025 48 of 69 EKI C40175.00
■
■
■
■
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June 08, 2026 Packet Pg. 1939
Table 8
Historical and Projected Water Supply and Demand by Source San Carlos Northeast Area Specific Plan, City of San Carlos, California 2019 2020 2021 2022 2023 2025 2030 2035 2040 2045
Historical and Projected Demand (a)
14,047 14,584 13,984 13,272 12,778 14,418 14,530 14,786 14,977 15,279 Proposed Project (b) -- -- -- -- --
South San Francisco District 6,866 6,627 6,455 6,518 6,348 7,016 6,956 7,108 7,473 7,896 Bear Gulch District 11,772 12,972 12,280 11,681 10,945 12,796 12,699 12,730 12,675 12,694 -- -- -- -- -- 537 617 617 617 617
Total Demand 32,685 34,183 32,720 31,471 30,071 34,767 34,802 35,241 35,742 36,486 Historical and Projected Supply (All Districts) (d)
Purchased (SFPUC) 30,311 32,644 31,959 31,210 29,382 39,993 39,993 39,993 39,993 39,993 Bear Gulch Reservoir 839 0 0 261 0 840 840 840 840 840
Groundwater 1,535 1,539 761 0 689 1,534 1,534 1,534 1,534 1,534 Total Supply 32,685 34,183 32,720 31,471 30,071 42,367 42,367 42,367 42,367 42,367 Supply Minus Demand 0 0 0 0 0 7,600 7,565 7,126 6,625 5,881 Abbreviations:
"AFY" = acre-feet per year "Proposed Project" = San Carlos Northeast Area Specific Plan "BG" = Bear Gulch "SFPUC" = San Francisco Public Utilities Commission "Cal Water" = California Water Service "SSF" = South San Francisco "ISG" = Individual Supply Guarantee "UWMP" = Urban Water Management Plan "MPS" = Mid-Peninsula
Other Known
Developments (c)
Supply and Demand Historical Supply and Demand (AFY) Projected Supply and Demand (AFY) Mid-Peninsula District
Included in District Demand Projections
0 5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
2019 2020 2021 2022 2023 2025 2030 2035 2040 2045
Water Supply and Demand (AFY)
Historical and Projected Normal Year Supply and Demand
Bear Gulch District South San Francisco District
Mid-Peninsula District Other Known Developments (c)
Total Supply
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,, ____________ _
,
--·
-
-
-
-
10.b
June 08, 2026 Packet Pg. 1940
Table 8
Historical and Projected Water Supply and Demand by Source San Carlos Northeast Area Specific Plan, City of San Carlos, California Notes:
(a)
(b)
(c)
(d)
References:
1. 2.
3. It should be noted that the jump in total supply capacity from 2023 to 2025 is because the projected water supply is assumed equal to the supplies available for all three districts during normal hydrologic years, which includes 840 AFY from the BG Reservoir, 1,534 AFY from the SSF wells (per References 2 and 3), and Cal Water's ISG of 39,993 AFY from SFPUC, which is shared among the BG, MPS, and SSF Districts. These projected supply values for normal hydrologic years differ from what is presented in the 2020 UWMPs, which estimate a normal year supply equal to projected demand.
Cal Water, 2021a 2020 Urban Water Management Plan, Mid-Peninsula District, prepared by California Water Service, dated June 2021.
Cal Water, 2021c. 2020 Urban Water Management Plan, South San Francisco District, prepared by California Water Service, dated June 2021.
Cal Water, 2021b. 2020 Urban Water Management Plan, Bear Gulch District, prepared by California Water Service, dated June 2021.
Demands for other known developments that are not subject to Cal Water's Development Offset Program within the SSF, MPS, and BG Districts can be found in Appendix B.
Cal Water updated its water demand projections for the SSF, BG, and MPS Districts in 2021, per References 1-3. It should be noted that the projected demands for the SSF District have decreased by 527 AFY relative to those reported in the SSF District 2020 UWMP because the Southline Specific Plan Project, which had previously been included in the demand projections for the SSF District, is now expected to comply with the Development Offset Program and will not result in a net increase in demands.
The demands associated with the Proposed Project are within the account and total water demand growth anticipated for the MPS District and are accounted for in the 2020 UWMP demand projections.
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2025 2030 2035 2040 2045
Total Normal Year Supply (All Districts) (a) 42,367 42,367 42,367 42,367 42,367 14,418 14,530 14,786 14,977 15,279
7,016 6,956 7,108 7,473 7,896
12,796 12,699 12,730 12,675 12,694
537 617 617 617 617
34,767 34,802 35,241 35,742 36,486
None None None None None
Abbreviations:
"AFY" = acre-feet per year "Proposed Project" = San Carlos Northeast Area Specific Plan "BG" = Bear Gulch "SFPUC" = San Francisco Public Utilities Commission "Cal Water" = California Water Service "SSF" = South San Francisco "ISG" = Individual Supply Guarantee "UWMP" = Urban Water Management Plan "MPS" = Mid-Peninsula
Supply Shortfall (% demand)
Mid-Peninsula District
Proposed Project (c)
South San Francisco District
Bear Gulch District
Other Known Developments (d)
Total Potable Water Demand Inclusive of Project
and Other Known Development
Included in District Demand Projections
Demand (b)
Table 9
Projected Normal Year Water Supply and Demand
San Carlos Northeast Area Specific Plan, City of San Carlos, California Supply and Demand
Projected Normal Year Supply and Demand (AFY)
2025 2030 2035 2040 2045
Projected Water Supply/Demand (AFY)
Normal Year Water Supply and Demand
South San Francisco District Mid-Peninsula District
Bear Gulch District Other Known Developments (d)
Total Normal Year Supply (All Districts) (a)
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45,000
...................................................... 40,000 35,000
30,000
25,000
20,000
15,000
10,000
5,000
0 - -
--·
- -
10.b
June 08, 2026 Packet Pg. 1942
Table 9
Projected Normal Year Water Supply and Demand
San Carlos Northeast Area Specific Plan, City of San Carlos, California Notes:
(a)
(b)
(c)
(d)
References:
1. 2.
3. Projected supply is assumed equal to the supplies available for all three districts during normal hydrologic years, which includes 840 AFY from the BG Reservoir, 1,534 AFY from the SSF wells (per References 1 and 2), and Cal Water's ISG of 39,993 AFY from SFPUC, which is shared among the BG, MPS, and SSF Districts. These projected supply values for normal hydrologic years differ from what is presented in the 2020 UWMPs, which estimate a normal year supply equal to projected demand.
Cal Water updated its water demand projections for the SSF, BG, and MPS Districts in 2021, per References 1-3. It should be noted that the projected demands for the SSF District have decreased by 527 AFY relative to those reported in the SSF District 2020 UWMP because the Southline Specific Plan Project, which had previously been included in the demand projections for the SSF District, is now expected to comply with Cal Water's Development Offset Program and will not result in a net increase in demands.
The demands associated with the Proposed Project are within the account and total water demand growth anticipated for the MPS District and are accounted for in the 2020 UWMP demand projections.
Demands for other known developments that are not subject to Cal Water's Development Offset Program within the SSF, MPS, and BG Districts can be found in Appendix B.
Cal Water, 2021a. 2020 Urban Water Management Plan, Mid-Peninsula District, prepared by California Water Service, dated June 2021.
Cal Water, 2021c. 2020 Urban Water Management Plan, South San Francisco District, prepared by California Water Service, dated June 2021.
Cal Water, 2021b. 2020 Urban Water Management Plan, Bear Gulch District, prepared by California Water Service, dated June 2021.
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2025 2030 2035 2040 2045
23,580 23,546 23,835 23,809 21,039
14,797 14,908 15,168 15,359 15,662
7,304 7,240 7,398 7,777 8,216
13,354 13,253 13,285 13,228 13,248
537 617 617 617 617
35,992 36,018 36,468 36,981 37,743
34% 35% 35% 36% 44%
Abbreviations:
"AFY" = acre-feet per year "MPS" = Mid-Peninsula
"BAWSCA" = Bay Area Water Supply and Conservation Agency "Proposed Project" = San Carlos Northeast Area Specific Plan "BDP" = Bay-Delta Plan Amendment "SFPUC" = San Francisco Public Utilities Commission "BG" = Bear Gulch "SSF" = South San Francisco
"Cal Water" = California Water Service "UWMP" = Urban Water Management Plan Bear Gulch District
Other Known Developments (d)
Total Potable Water Demand Inclusive of
Project and Other Known Development
Supply Shortfall (% demand)
South San Francisco District
Table 10a
Scenario 1: Projected Single Dry Year Water Supply and Demand with Implementation of the BayDelta Plan Amendment San Carlos Northeast Area Specific Plan, City of San Carlos, California Supply and Demand
Projected Single Dry Year Supply and Demand (AFY)
Total Supply with Implementation of BDP (All
Districts) (a)
Demand (b)
Mid-Peninsula District
Proposed Project (c) Included in MPS District Demand Projections 0 5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
2025 2030 2035 2040 2045
Projected Water Supply/Demand (AFY)
Single-Dry Year Water Supply and Demand
Other Known Developments (d) Bear Gulch District
South San Francisco District Mid-Peninsula District
Total Supply with Implementation of BDP (All Districts) (a) March 2025 53 of 69 EKI C40175.00
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Table 10a
Scenario 1: Projected Single Dry Year Water Supply and Demand with Implementation of the BayDelta Plan Amendment San Carlos Northeast Area Specific Plan, City of San Carlos, California Notes:
(a)
(b)
(c)
(d)
References:
1. 2.
3. Cal Water, 2021a. 2020 Urban Water Management Plan, Mid-Peninsula District, prepared by California Water Service, dated June 2021.
Cal Water, 2021c. 2020 Urban Water Management Plan, South San Francisco District, prepared by California Water Service, dated June 2021.
Cal Water, 2021b. 2020 Urban Water Management Plan, Bear Gulch District, prepared by California Water Service, dated June 2021.
Demands for other known developments that are not subject to Cal Water's Development Offset Program within the SSF, MPS, and BG Districts can be found in Appendix B.
Projected supply is inclusive of supplies available for all three districts that share the same contractual allocation of water from SFPUC, per References 1-3. The projected purchase volumes are based on having full local supply (i.e., 1,534 AFY) from the South San Francisco wells. Although local surface water diversions in the BG District (and subsequent treatment and use of local surface water) have occurred historically during dry years, the BG District conservatively assumes that local surface water supplies will be zero during single dry and multiple dry years over the planning horizon, per Reference 3. Projected SFPUC supply is based on dry year allocation projections included in the SSF, BG, and MPS District 2020 Urban Water Management Plans based on the methodology, assumptions and information utilized and provided by SFPUC and BAWSCA; however, actual future supply allocations may vary based on actual shortage levels and the then-applicable allocation methodology being applied by BAWSCA and SFPUC.
Cal Water updated its water demand projections for the SSF, BG, and MPS Districts in 2021, per References 1-3. It should be noted that the projected demands for the SSF District have decreased by 527 AFY relative to those reported in the SSF District 2020 Urban Water Management Plan because the Southline Specific Plan Project, which had previously been included in the demand projections for the SSF District, is now expected to comply with Cal Water's Development Offset Program and will not result in a net increase in demands.
The demands associated with the Proposed Project are within the account and total water demand growth anticipated for the MPS District and are accounted for in the 2020 UWMP demand projections.
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June 08, 2026 Packet Pg. 1945
2025 2030 2035 2040 2045
42,367 42,367 42,367 42,367 42,367
14,797 14,908 15,168 15,359 15,662
7,304 7,240 7,398 7,777 8,216
13,354 13,253 13,285 13,228 13,248
Other Known Developments (d) 537 617 617 617 617
35,992 36,018 36,468 36,981 37,743
None None None None None
Abbreviations:
"AFY" = acre-feet per year "MPS" = Mid-Peninsula
"BAWSCA" = Bay Area Water Supply and Conservation Agency "Proposed Project" = San Carlos Northeast Area Specific Plan "BDP" = Bay-Delta Plan Amendment "SFPUC" = San Francisco Public Utilities Commission "BG" = Bear Gulch "SSF" = South San Francisco
"Cal Water" = California Water Service "UWMP" = Urban Water Management Plan Supply Shortfall (% demand)
Demand (b)
Mid-Peninsula District
Proposed Project (c)
Bear Gulch District
Total Potable Water Demand Inclusive of
Project and Other Known Development
South San Francisco District
Table 10b
Scenario 2: Projected Single Dry Year Water Supply and Demand without Implementation of the BayDelta Plan Amendment San Carlos Northeast Area Specific Plan, City of San Carlos, California Supply and Demand
Projected Single Dry Year Supply and Demand (AFY)
Total Supply w/out Implementation of BDP
(All Districts) (a)
Included in District Demand Projections
0 5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
2025 2030 2035 2040 2045
Projected Water Supply/Demand (AFY)
Single-Dry Year Water Supply and Demand
Other Known Developments (d) Bear Gulch District
South San Francisco District Mid-Peninsula District
Total Supply w/out Implementation of BDP (All Districts) (a) March 2025 55 of 69 EKI C40175.00
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- - --- - -
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June 08, 2026 Packet Pg. 1946
Table 10b
Scenario 2: Projected Single Dry Year Water Supply and Demand without Implementation of the BayDelta Plan Amendment San Carlos Northeast Area Specific Plan, City of San Carlos, California Notes:
(a)
(b)
(c)
(d)
References:
1. 2.
3. 4. Cal Water, 2021b. 2020 Urban Water Management Plan, Bear Gulch District, prepared by California Water Service, dated June 2021.
Water supply available to the three Peninsula Districts during single dry years is based on dry year allocation projections if the BDP is not adopted, based on the methodology, assumptions and information utilized and provided by SFPUC and BAWSCA per Table N in Reference 1.
Cal Water updated its water demand projections for the SSF, BG, and MPS Districts in 2021, per References 2-4. It should be noted that the projected demands for the SSF District have decreased by 527 AFY relative to those reported in the SSF District 2020 UWMP because the Southline Specific Plan Project, which had previously been included in the demand projections for the SSF District, is now expected to comply with Cal Water's Development Offset Program and will not result in a net increase in demands.
The demands associated with the Proposed Project are within the account and total water demand growth anticipated for the MPS District and are accounted for in the 2025 UWMP demand projections.
Demands for other known developments that are not subject to Cal Water's Development Offset Program within the SSF, MPS, and BG Districts can be found in Appendix B.
SFPUC, 2021c. Regional Water System Supply Reliability and BAWSCA Tier 2 Drought Implementation Scenarios, Updated Drought Allocations, dated 1 April 2021.
Cal Water, 2021a. 2020 Urban Water Management Plan, Mid-Peninsula District, prepared by California Water Service, dated June 2021.
Cal Water, 2021c. 2020 Urban Water Management Plan, South San Francisco District, prepared by California Water Service, dated June 2021.
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June 08, 2026 Packet Pg. 1947
2025 2030 2035 2040 2045
Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 23,615 20,492 20,492 20,492 20,492 23,483 20,383 20,383 20,383 20,383 23,647 20,313 20,313 20,313 18,849 23,762 20,594 20,594 18,424 18,424 20,954 20,954 20,954 18,061 18,061 Demand (c)Mid-Peninsula District 15,031 15,031 15,031 15,031 15,031 15,143 15,143 15,143 15,143 15,143 15,405 15,405 15,405 15,405 15,405 15,595 15,595 15,595 15,595 15,595 15,900 15,900 15,900 15,900 15,900 Proposed Project (d)
South San Francisco District 7,482 7,482 7,482 7,482 7,482 7,416 7,416 7,416 7,416 7,416 7,577 7,577 7,577 7,577 7,577 7,965 7,965 7,965 7,965 7,965 8,413 8,413 8,413 8,413 8,413 Bear Gulch District 13,699 13,699 13,699 13,699 13,699 13,595 13,595 13,595 13,595 13,595 13,629 13,629 13,629 13,629 13,629 13,570 13,570 13,570 13,570 13,570 13,591 13,591 13,591 13,591 13,591 537 537 537 537 537 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 36,749 36,749 36,749 36,749 36,749 36,771 36,771 36,771 36,771 36,771 37,228 37,228 37,228 37,228 37,228 37,747 37,747 37,747 37,747 37,747 38,521 38,521 38,521 38,521 38,521 Supply Shortfall (% demand) 36% 44% 44% 44% 44% 36% 45% 45% 45% 45% 36% 45% 45% 45% 49% 37% 45% 45% 51% 51% 46% 46% 46% 53% 53% Included in District Demand Projections
Total Supply with Implementation of BDP (All Districts) (b) Other Known Developments (e) Total Potable Water Demand Inclusive of Project and Other Known Development Table 11a
Scenario 1: Projected Multiple Dry Year Water Supply and Demand with Implementation of the Bay-Delta Plan Amendment San Carlos Northeast Area Specific Plan, City of San Carlos, California Supply and Demand
Projected Water Supply and Demand During Multiple Dry Years (AFY) (a) 0 5,000
45,00040,00035,00030,00025,00020,00015,00010,000
Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 2025 2030 2035 2040 2045
Projected Water Supply and
Demand (AFY)
Multiple Dry Year Water Supply and Demand
Mid-Peninsula District South San Francisco District Bear Gulch District Other Known Developments (e) Total Supply with Implementation of BDP (All Districts) (b) March 2025 57 of 69 EKI C40175.00
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Table 11a
Scenario 1: Projected Multiple Dry Year Water Supply and Demand with Implementation of the Bay-Delta Plan Amendment San Carlos Northeast Area Specific Plan, City of San Carlos, California Abbreviations:"AFY" = acre-feet per year "Cal Water" = California Water Service "SSF" = South San Francisco "BAWSCA" = Bay Area Water Supply and Conservation Agency "MPS" = Mid-Peninsula "UWMP" = Urban Water Management Plan "BDP" = Bay-Delta Plan Amendment "Proposed Project" = San Carlos Northeast Area Specific Plan "WSA" = Water Supply Assessment "BG" = Bear Gulch "SFPUC" = San Francisco Public Utilities Commission Notes:
(a)
(b)
(c)
(d)
(e)
References:
1.2. Cal Water, 2021c. 2020 Urban Water Management Plan, South San Francisco District, prepared by California Water Service, dated June 2021.3.
The demands associated with the Proposed Project are within the account and total water demand growth anticipated for the MPS District and are accounted for in the 2020 UWMP demand projections.
Demands for other known developments that are not subject to Cal Water's Development Offset Program within the SSF, MPS, and BG Districts can be found in Appendix B.Cal Water, 2021a. 2020 Urban Water Management Plan, Mid-Peninsula District, prepared by California Water Service, dated June 2021.
Cal Water, 2021b. 2020 Urban Water Management Plan, Bear Gulch District, prepared by California Water Service, dated June 2021.While WSA regulations only require an analysis of a three-year drought scenario, UWMP regulations were updated in 2018 to include a five-year drought scenario (California Water Code §10635), Therefore, a five-year drought scenario is presented here.
Projected supply is inclusive of supplies available for all three districts that share the same contractual allocation of water from SFPUC, per References 1-3. The projected purchase volumes are based on having full local supply (i.e., 1,534 AFY) from the SSF wells.
Although local surface water diversions in the BG District (and subsequent treatment and use of local surface water) have occurred historically during dry years, the BG District conservatively assumes that local surface water supplies will be zero during single dry and multiple dry years over the planning horizon, per Reference 3. Projected SFPUC supply is based on dry year allocation projections included in the SSF, BG, and MPS District 2020 UWMPs based on the methodology, assumptions and information utilized and provided by SFPUC and BAWSCA; however, actual future supply allocations may vary based on actual shortage levels and the then-applicable allocation methodology being applied by BAWSCA and SFPUC.Cal Water updated its water demand projections for the SSF, BG, and MPS Districts in 2021, per References 1-3. It should be noted that the projected demands for the SSF District have decreased by 527 AFY relative to those reported in the SSF District 2020 UWMP because the Southline Specific Plan Project, which had previously been included in the demand projections for the SSF District, is now expected to comply with the Development Offset Program and will not result in a net increase in demands.
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2025 2030 2035 2040
Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 42,367 33,014 33,014 Demand (c)Mid-Peninsula District 15,031 15,031 15,031 15,031 15,031 15,143 15,143 15,143 15,143 15,143 15,405 15,405 15,405 15,405 15,405 15,595 15,595 15,595 15,595 15,595 15,900 15,900 15,900 15,900 15,900 Proposed Project (d)
South San Francisco District 7,482 7,482 7,482 7,482 7,482 7,416 7,416 7,416 7,416 7,416 7,577 7,577 7,577 7,577 7,577 7,965 7,965 7,965 7,965 7,965 8,413 8,413 8,413 8,413 8,413 Bear Gulch District 13,699 13,699 13,699 13,699 13,699 13,595 13,595 13,595 13,595 13,595 13,629 13,629 13,629 13,629 13,629 13,570 13,570 13,570 13,570 13,570 13,591 13,591 13,591 13,591 13,591 537 537 537 537 537 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 617 36,749 36,749 36,749 36,749 36,749 36,771 36,771 36,771 36,771 36,771 37,228 37,228 37,228 37,228 37,228 37,747 37,747 37,747 37,747 37,747 38,521 38,521 38,521 38,521 38,521 Shortfall 15% 15% 15% 15% 15% 15% 15% 15% 15% 15% 14% 14% 14% 14% 14% 12% 12% 12% 12% 12% 10% 10% 10% 14% 14 3% Supply Shortfall (% demand) None None None None None None None None None None None None None None None None None None None None None None None 14% 14% Total Supply w/out Implementation of BDP (All Districts) (b)Other Known Developments (e) Total Potable Water Demand Inclusive of Project and Other Known Development Included in MPS District Demand Projections (d)
Table 11b
Scenario 2: Projected Multiple Dry Year Water Supply and Demand without Implementation of the Bay-Delta Plan Amendment San Carlos Northeast Area Specific Plan, City of San Carlos, California Supply and Demand
Projected Water Supply and Demand During Multiple Dry Years (AFY) (a) 2045
0 5000
4500040000350003000025000200001500010000
Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 2025 2030 2035 2040 2045
Projected Water Supply and
Demand (AFY)
Multiple Dry Year Water Supply and Demand
Mid-Peninsula District South San Francisco District Bear Gulch District Other Known Developments (e) Total Supply w/out Implementation of BDP (All Districts) (b) March 2025 59 of 69 EKI C40175.00
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10.b
June 08, 2026 Packet Pg. 1950
Table 11b
Scenario 2: Projected Multiple Dry Year Water Supply and Demand without Implementation of the Bay-Delta Plan Amendment San Carlos Northeast Area Specific Plan, City of San Carlos, California Abbreviations:"AFY" = acre-feet per year "Cal Water" = California Water Service "SSF" = South San Francisco "BAWSCA" = Bay Area Water Supply and Conservation Agency "MPS" = Mid-Peninsula "UWMP" = Urban Water Management Plan "BDP" = Bay-Delta Plan Amendment "Proposed Project" = San Carlos Northeast Area Specific Plan "WSA" = Water Supply Assessment"BG" = Bear Gulch "SFPUC" = San Francisco Public Utilities Commission Notes:
(a)
(b)
(c)
(d)
(e)
References:
1. SFPUC, 2021c. Regional Water System Supply Reliability and BAWSCA Tier 2 Drought Implementation Scenarios, Updated Drought Allocations, dated 1 April 2021.
2.3. Cal Water, 2021c. 2020 Urban Water Management Plan, South San Francisco District, prepared by California Water Service, dated June 2021.4. Cal Water, 2021b. 2020 Urban Water Management Plan, Bear Gulch District, prepared by California Water Service, dated June 2021.
The demands associated with the Proposed Project are within the account and total water demand growth anticipated for the MPS District and are accounted for in the 2020 UWMP demand projections.Demands for other known developments that are not subject to Cal Water's Development Offset Program within the SSF, MPS, and BG Districts can be found in Appendix B.Cal Water, 2021a. 2020 Urban Water Management Plan, Mid-Peninsula District, prepared by California Water Service, dated June 2021.While WSA regulations only require an analysis of a three-year drought scenario, UWMP regulations were updated in 2018 to include a five-year drought scenario (California Water Code §10635), Therefore, a five-year drought scenario is presented here.
Projected supply is based on dry year allocation projections if the BDP is not adopted, based on the methodology, assumptions and information utilized and provided by SFPUC and BAWSCA per Tables N and O2 in Reference 1. Supply allocations in the fourthand fifth- year drought in 2045 represent the BG, MPS, and SSF Tier Two drought cutbacks.
Cal Water updated its water demand projections for the SSF, BG, and MPS Districts in 2021, per References 2-4. It should be noted that the projected demands for the SSF District have decreased by 527 AFY relative to those reported in the SSF District 2020 UWMP because the Southline Specific Plan Project, which had previously been included in the demand projections for the SSF District, is now expected to comply with the Development Offset Program and will not result in a net increase in demands.
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7 COMPARISON OF SUPPLY AND DEMAND
Pursuant to CWC §10910(c)(3), this WSA must include an estimate of the projected water supplies available to the District under normal, single dry, and multiple dry years, and a discussion of whether those supplies will meet the projected demand associated with the Proposed Project, in addition to the water system’s existing and planned future uses. This assessment is parallel to the multiple dry year supply reliability analysis required for UWMPs under CWC §10635. In 2018, CWC §10635 was revised to require UWMPs to extend this analysis to consider “a drought lasting five consecutive water years.” Although CWC §10910(c)(3) has not yet been updated to require this for WSAs, a five-year drought scenario is also evaluated herein.
Table 9 through Table 11b provide a comparison of the demands and supplies in normal year, single-dry year, and multiple dry year hydrologic scenarios for the Mid-Peninsula, Bear Gulch, and South San Francisco Districts under: (1) implementation of the Bay-Delta Plan Amendment scenario (Scenario 1) and (2) without implementation of the Bay-Delta Plan Amendment or the ; CWC § 10910
(c)(3) If the projected water demand associated with the proposed project was not accounted for in the most recently adopted urban water management plan, or the public water system has no urban water management plan, the water supply assessment for the project shall include a discussion with regard to whether the public water system's total projected water supplies available during normal, single dry, and multiple dry water years during a 20-year projection will meet the projected water demand associated with the proposed project, in addition to the public water system's existing and planned future uses, including agricultural and manufacturing uses.
; CWC § 10911
(a) If, as a result of its assessment, the public water system concludes that its water supplies are, or will be, insufficient, the public water system shall provide to the city or county its plans for acquiring additional water supplies, setting forth the measures that are being undertaken to acquire and develop those water supplies. If the city or county, if either is required to comply with this part pursuant to subdivision (b), concludes as a result of its assessment, that water supplies are, or will be, insufficient, the city or county shall include in its water supply assessment its plans for acquiring additional water supplies, setting forth the measures that are being undertaken to acquire and develop those water supplies. Those plans may include, but are not limited to, information concerning all of the following:
(1) The estimated total costs, and the proposed method of financing the costs, associated with acquiring the additional water supplies.
(2) All federal, state, and local permits, approvals, or entitlements that are anticipated to be required in order to acquire and develop the additional water supplies.
(3) Based on the considerations set forth in paragraphs (1) and (2), the estimated timeframes within which the public water system, or the city or county if either is required to comply with this part pursuant to subdivision (b), expects to be able to acquire additional water supplies. ; CWC § 10911
(c) The city or county may include in any environmental document an evaluation of any information included in that environmental document provided pursuant to subdivision (b). The city or county shall determine, based on the entire record, whether projected water supplies will be sufficient to satisfy the demands of the project, in addition to existing and planned future uses. If the city or county determines that water supplies will not be March 2025 61 of 69 EKI C40175.00
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Proposed Voluntary Agreement scenario (Scenario 2). Because negotiations of a Proposed Voluntary Agreement are not complete, no values are available to explicitly model Scenario 3. It is projected that available water supplies will be sufficient to meet the demands under normal year hydrologic conditions through 2045, inclusive of the Proposed Project under all scenarios.
Under Scenario 1, shortfalls of up to 53% are possible in drought periods representing, as discussed above, the “worst-case” supply scenario is realized in which the Bay-Delta Plan Amendment is implemented as written, and not accounting for the implementation of actions identified as part of the Settlement Agreement, SFPUC’s AWSP, BAWSCA’s 2015 Strategy, or Cal Water’s WSRS. As discussed in Section 6.1.1.4, Cal Water is working independently and with the other BAWSCA agencies to identify regional mitigation measures to improve reliability for regional and local water supplies and meet its customers’ water needs. As a result, Cal Water expects that SFPUC’s LOS Goals and Objectives will be met and is comfortable assuming its contract with SFPUC will be honored as written. Thus, any dry year shortfalls would be expected to be lower than those shown in Table 10a and Table 11a.
Under Scenario 2, in which the Bay-Delta Plan Amendment or the Proposed Voluntary Agreement are not implemented, the three Peninsula Districts will have sufficient supply to meet the demands in all year types through 2040 and would only anticipate a supply shortfall of 14% during the fourth and fifth year of a multi-year drought by 2045 as shown in Table 11b.
Under Scenario 3, it is anticipated that the degree of water use reduction during dry years would also more closely align with the SFPUC’s RWS LOS goal of limiting water use reduction to no more than 20% on a system-wide basis in drought years. However, as above, because negotiations of a Proposed Voluntary Agreement are not complete, no values are available to explicitly model Scenario 3.
As described in Section 6, in response to anticipated future dry-year shortfalls, Cal Water has developed a WSCP that systematically identifies ways in which the District can reduce water demands during dry years. The overall reduction goals in the WSCP are established for six drought stages ranging from 10% to greater than 50% shortfalls.
The SFPUC RWS has historically met demand in its service area in all year types, and prior to 2021, only called for voluntary 10% rationing during 2007 to 2009 and 2014 to 2015. Although the District has not experienced any shortage of RWS deliveries, during the 2015/2016 drought, it was subject to the SWRCB’s mandatory water reduction target at 16% between June 2015 and March 2025 62 of 69 EKI C40175.00
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May 2016.18 During this period, the District surpassed its reduction targets in each month and achieved an average water demand reduction of 24% compared to its water use in 2013 (SWRCB, 2016). The South San Francisco and Bear Gulch Districts were required to reduce water use by 8% and 36%, respectively, and through May 2016 exceeded their targets with cumulative reductions of 20% and 37%, respectively (SWRCB, 2016). On 24 May 2022, in response to Governor Newsom’s Executive Order N-7-22 and calls for water conservation from the SWRCB, the SFPUC entered into Level 2 of its WSCP, resulting in a voluntary water use reduction goal of 11%. However, as of 5 June 2023, the SWRCB no longer requires water agencies to remain in Level 2 of their WSCPs (SWRCB, 2023).
In July 2024, SWRCB officially adopted the Making Water Conservation a California Way of Life regulation to implement SB 606/AB 1668 annual water use objective requirements. As part of this regulation urban water suppliers are required to calculate and report their Urban Water Use Objective (UWUO) beginning in January 2024 and every year thereafter. The UWUO is an estimate of efficient urban water use based on the adopted urban water use efficiency standards and local service area characteristics. By January 2027, compliance with the UWUO will be enforced. Based on the three Peninsula Districts’ most recent UWUO Reports submitted to DWR in 2023, the Mid-Peninsula District’s actual water use was approximately 28% below its estimated UWUO, the South San Francisco District’s actual water use was approximately 41% below its estimated UWUO, and the Bear Gulch District’s actual water use was approximately 20% above its estimated UWUO in 2022 (DWR, 2023a; 2023b; 2023c). It is expected that UWUOs will become incrementally more stringent over time, and achieving UWUOs in the future could potentially require an increase in the three Peninsula Districts’ conservation programming.
As a customer within the District, the Proposed Project would be obligated to comply with the demand reduction efforts imposed by Cal Water through implementation of the WSCP in any future water shortage condition.
While the SFPUC RWS reliability is constrained by hydrology, physical facilities, institutional parameters including state and federal regulations, the SFPUC is implementing both capital improvement and planning processes to enhance RWS reliability and meet its contractual commitment to Wholesale Customers through 2045 (see SFPUC memorandum included as Appendix D). Within and outside the RWS, BAWSCA is also leading multiple efforts to develop additional water supply for its member agencies through implementation of its 2015 Strategy and development of its Strategy 2050 update.
18 On 5 May 2015, the SWRCB adopted Resolution 2015-0032 that mandates minimum actions by water suppliers and their customers to conserve water supplies into 2016 and assigned a mandatory water conservation goal to each water supplier based on their residential gallons per capita per day (R-GPCD). The Resolution was adopted pursuant to Executive Order B-29-15 that directed SWRCB to impose mandatory restrictions on urban water suppliers to achieve a statewide 25% reduction in potable urban water usage to address California’s severe drought conditions.
Based on its R-GPCD, District was required to reduce water use by 8% relative to its 2013 water use. The MidPeninsula and Bear Gulch Districts were required to reduce water use by 16% and 36%, respectively. All three Peninsula Districts exceeded their mandatory savings targets by May 2016.
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Cal Water is also striving to increase the water supply portfolio for the Mid-Peninsula, Bear Gulch, and South San Fransisco Districts through: (1) investment in water conservation, (2) participation in the RGSR Project and the regional water recycling project (i.e., Potable Reuse Exploratory Plan [PREP]), and (3) development of a regional WSRS using integrated resource planning practices to create a long-term supply reliability strategy through 2050 for Cal Water districts in the Bay Area, among other things as described in the 2020 UWMPs for each District. As described above, the three Peninsula Districts share access to Cal Water’s SFPUC supply and, as such, any supply added to one of these Districts will benefit the others.
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8 CONCLUSIONS
As listed in Water Code §10910(c)(4), the primary purpose of this WSA is to evaluate whether sufficient water supply is available to meet all future water demands within the water supplier’s service area, including those associated with the Proposed Project, during normal and dry hydrologic years for a 20-year time horizon.
As described in Section 4, the net water demand of the Proposed Project (i.e., estimated at 41 AFY at buildout) has been conservatively estimated, and as discussed in Section 6.2, the current and planned future water supply within the three Peninsula Districts for normal hydrologic years is expected to meet all projected demands.
It should be noted that if the “worst-case” supply scenario (Scenario 1) described under Section
6.1.1.2 in which the Bay-Delta Plan Amendment is implemented as written and not accounting for the implementation of actions identified as part of the Settlement Agreement, SFPUC’s AWSP, BAWSCA’s 2015 Strategy, or Cal Water’s WSRS, shortfalls of up to 53% are projected during drought years. However, as described in Section 6.1.1, Cal Water expects that SFPUC’s LOS Goals will be met and is comfortable assuming its contract with SFPUC will be honored as written. If drought conditions should arise, Cal Water will meet its demands through the implementation of its WSCP, as described in Section 7. In addition, Cal Water, through local and regional efforts, is striving to increase its water supply portfolio for the District and the other two Peninsula Districts.
This WSA concludes that the three Peninsula Districts’ supplies are sufficient to meet projected future demands, inclusive of the Proposed Project. Based on currently available information and conservative estimates of projected demand, Cal Water expects to be able to meet all future demands within its existing District service area (as well as the South San Francisco and Bear Gulch Districts), inclusive of the Proposed Project, in normal hydrologic years. The shortfalls that are currently projected during dry years will be addressed through planned implementation of the District’s WSCP. In addition, as described herein and in Cal Water’s 2020 UWMP, BAWSCA, Cal Water, and SFPUC are pursuing the development of additional water supplies to improve the RWS and District supply reliability.
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9 REFERENCES
Bay Area Water Supply & Conservation Agency (BAWSCA), 2015. Long-Term Reliable Water Supply Strategy, Phase II Final Report, dated February 2015.
BAWSCA, 2018. Statement from Tom Francis, Acting Chief Executive Officer, Before the State Water Resources Control Board (State Board) in Regards to their “Draft Final Bay-Delta Plan Update,” Which Could Severely Reduce the Water Supply for Residents and Businesses in Alameda, San Mateo, and Santa Clara Counties, dated August 2018, (http://bawsca.org/uploads/userfiles/files/08-21-
18_BAWSCA's%20SWRCB%20Statement%20-%20TBF%20Final.pdf).
BAWSCA, 2024a. Statement from Nicole Sandkulla, Chief Executive Officer for the Bay Area Water Supply and Conservation Agency (BAWSCA), Regarding the recent Court Decision in the State Water Board Cases related to the State Water Resources Control Board's (State Water Board) Bay-Delta Updated Plan (Plan), dated 20 March 2024, (https://bawsca.org/uploads/news/2024_0320_BAWSCA%20Statement%20re%20Court %20Decision%20in%20State%20Water%20Board%20Cases_ns.pdf).
BAWSCA, 2024b. Statement from Nicole Sandkulla, Chief Executive Officer for the Bay Area Water Supply and Conservation Agency (BAWSCA), Regarding an Appeal of the recent Court Decision in the State Water Board Cases related to the State Water Resources Control Board's (State Water Board) Updated Bay-Delta Plan (Plan), dated 10 May 2024, (https://bawsca.org/uploads/news/2024_0510_BAWSCA%20Statement%20re%20State %20Water%20Board%20Cases%20Appeal_FINAL.pdf).
Cal Water, 2016. 2015 Urban Water Management Plan, South San Francisco District, prepared by California Water Service, dated June 2016.
Cal Water, 2019. Cal Water WSA Water Factor Tool, developed by M.Cubed, dated 22 October 2019.
Cal Water, 2021a. 2020 Urban Water Management Plan, Mid-Peninsula District, prepared by California Water Service, dated June 2021.
Cal Water, 2021b. 2020 Urban Water Management Plan, Bear Gulch District, prepared by California Water Service, dated June 2021.
Cal Water, 2021c. 2020 Urban Water Management Plan, South San Francisco District, prepared by California Water Service, dated June 2021.
Cal Water, 2022. Advice Letter No. 2453, Rule 15 Update for Developer Offset Fee, dated 7 June 2022.
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Cal Water, 2023. California Water Service Company Mid-Peninsula 2022 Water Audit Data Report, accessed via the WUEdata - Water Audit Report Data website on 12 November 2024, (https://wuedata.water.ca.gov/awwa_plans).
Cal Water, 2024a. Historical demand and production data provided by Cal Water on 9 May 2024.
Cal Water, 2024b. Billed water consumption data provided by Cal Water on 12 December 2024.
City of San Carlos, 2024. City of San Carlos Planning Division Notice of Preparation of a Draft Environmental Impact Report for the San Carlos Northeast Area Specific Plan, dated 1 July 2024, provided by MPWD on 3 July 2024.
City of Los Angeles Bureau of Engineering, 2012. City of Los Angeles Bureau of Engineering, City of Los Angeles Bureau of Sanitation, Sewer Generation Rates Table, dated 6 April 2012.
DWR, 2006. California’s Groundwater Bulletin 118, Westside Groundwater Basin, dated January 2006.
DWR, 2012. California Irrigation Management Information System Reference Evapotranspiration Zones, January 2012.
DWR, 2016. California’s Groundwater Bulletin 118, Interim Update 2016, dated 22 December 2016.
DWR, 2019. Sustainable Groundwater Management Act 2018 Basin Prioritization, State of California, dated January 2019.
DWR, 2020. California Code of Regulations, Title 23, Division 2, Chapter 2.7, Model Water Efficient Landscape Ordinance, 29 September 2020.
DWR, 2023a. California Water Service Company Mid-Peninsula 2023 Urban Water Use Objective Report, accessed via the WUEdata - Urban Water Use Objective website on 23 December 2024, (https://wuedata.water.ca.gov/uwuo_plans).
DWR, 2023b. California Water Service Company Bear Gulch 2023 Urban Water Use Objective Report, accessed via the WUEdata - Urban Water Use Objective website on 23 December 2024, (https://wuedata.water.ca.gov/uwuo_plans).
DWR, 2023c. California Water Service Company South San Francisco 2023 Urban Water Use Objective Report, accessed via the WUEdata - Urban Water Use Objective website on 23 December 2024, (https://wuedata.water.ca.gov/uwuo_plans).
EKI Environment & Water, Inc. (EKI), 2022a. Water Supply Assessment for the Alexandria District for Science and Technology, prepared for Cal Water, dated September 2022.
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EKI, 2022b. Water Supply Assessment for the 803-851 Old County Road Project, prepared for Cal Water, dated October 2022.
EKI, 2023. Water Supply Assessment for the 789 Old County and 1026 Bransten Road Project, prepared for Cal Water, dated July 2023.
Genentech, 2019. Genentech Campus Master Plan Update Draft Environmental Impact Report, prepared by Lamphier-Gregory, dated October 2019.
Mid-Peninsula Water District (MPWD), 2024a. Project information, provided by Cal Water on 31 October 2024.
MPWD, 2024b. Email response to questions, provided by Cal Water on 22 November 2024.
MPWD, 2024c. Updated project information, provided by Cal Water on 19 December 2024.
Phillips, Steven P., Scott N. Hamlin, Eugene B. Yates. Geohydrology, Water Quality, and Estimation of Ground-Water Recharge in San Francisco, California 1987-92. US Geological Survey Water-Resources Investigations Report 93-4019, 1993.
San Francisco Public Utilities Commission (SFPUC), 2013. Draft Environmental Impact Report for the San Francisco Public Utilities Commission's Regional Groundwater Storage and Recovery Project, dated April 2013,
(https://sfplanning.s3.amazonaws.com/sfmea/2008.1396E_DEIR1.pdf).
SFPUC, 2016. 2015 Urban Water Management Plan, City and County of San Francisco District, prepared by the San Francisco Public Utilities Commission, dated June 2016.
SFPUC, 2018. Amended and Restated Water Supply Agreement between the City and County of San Francisco and Wholesale Customers in Alameda County, San Mateo and Santa Clara County, prepared by SFPUC, dated November 2018.
SFPUC, 2021a. 2020 Urban Water Management Plan for the City and County of San Francisco, prepared by the San Francisco Public Utilities Commission, dated June 2021.
SFPUC, 2021b. 2020 Annual Groundwater Monitoring Report Westside Basin San Francisco and San Mateo Counties, California, Prepared by the San Francisco Public Utilities Commission, dated April 2021.
SFPUC, 2021c. Regional Water System Supply Reliability and BAWSCA Tier 2 Drought Implementation Scenarios, Updated Drought Allocations, dated 1 April 2021.
SFPUC, 2022. Water Supply Assessment for the 395 3rd Street Project, prepared by SFPUC, dated 28 December 2022.
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SFPUC, 2023a. WSIP Quarterly Reports, Regional Projects Q3 FY 2022-2023, published 25 May 2023.
SFPUC, 2023b. Revised Water Supply Assessment for the 3251 20th Avenue (Stonestown) Project, prepared by SFPUC, dated 26 September 2023.
SFPUC, 2024a. Alternative Water Supply Plan, published February 2024.
SFPUC, 2024b. 2023 Annual Groundwater Monitoring Report, Westside Basin, San Francisco and San Mateo Counties, California prepared by the San Francisco Public Utilities Commission, dated June 2024.
SFPUC, 2024c. Regional Groundwater Storage & Recovery, accessed 31 July 2024, (https://www.sfpuc.gov/construction-contracts/construction-projects/regionalgroundwater-storage).
State Water Resources Control Board (SWRCB), 2016. May 2016 Supplier Conservation Compliance, State Water Resources Control Board, Water Conservation Portal, (https://www.waterboards.ca.gov/water_issues/programs/conservation_portal/conserv ation_reporting.html).
SWRCB, 2023. Water Conservation Emergency Regulations Update, https://www.waterboards.ca.gov/water_issues/programs/conservation_portal/regs/em ergency_regulation.html, accessed 12 July 2023.
US Energy Information Administration (USEIA), 2012. US Energy Information Administration 2012 Commercial Buildings Energy Consumption Survey: Water Consumption in Large Buildings Summary.
Woodard and Curran, 2022. Bay Area Region Water Supply Reliability Study, prepared by Woodard and Curran, dated December 2022.
WRIME, 2012. South Westside Basin Groundwater Management Plan, City and County of San Francisco, prepared by the San Francisco Public Utilities Commission, City of San Bruno, Daly City, and Cal Water South San Francisco District, dated July 2012.
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APPENDIX A
City of San Carlos – Northeast Area Specific Plan NOP
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City Hall
600 Elm Street
San Carlos, CA 94070-3085
Planning Division
TELEPHONE (650) 802–4263
FAX (650) 595-6763
http://www.cityofsancarlos.org
NOTICE OF PREPARATION and
NOTICE OF PUBLIC SCOPING MEETING
Date July 1, 2024
To: State Clearinghouse
Governor’s Office of Planning and Research
San Mateo County Clerk
Responsible and Trustee Agencies
Interested Individuals and Organizations
From: Lisa Porras
Planning Manager
City of San Carlos
600 Elm Street
San Carlos, CA 94070-3085
Email: [email protected]
Subject: Notice of Preparation (NOP) of a Draft Environmental Impact Report (EIR) for the San Carlos Northeast Area Specific Plan (NEASP)
Lead Agency: City of San Carlos
Project Title: San Carlos Northeast Area Specific Plan (project) Project Location: Northeast Plan Area of San Carlos (north of Holly Street, to the San Carlos city limits at Belmont Creek, and between U.S. Highway 101 and Old Country Road) Call for Comments:
The City of San Carlos (City) is requesting written comments from responsible agencies and the public regarding the scope and content of the San Carlos Northeast Area Specific Plan (NEASP) Draft Environmental Impact Report (EIR). The program-level EIR will evaluate the environmental impacts associated with the likely type and amount of development projected under the 2045 horizon year. This EIR will not evaluate detailed, site-specific activities and future development projects under the NEASP.
The City requests your written comments as to the scope of the EIR, including mitigation measures and/or project alternatives to reduce potential environmental impacts from the proposed project.
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Preparing an Environmental Impact Report:
Notice is hereby given that the City will be the Lead Agency and will prepare an EIR for the project pursuant to the California Environmental Quality Act (CEQA) Guidelines (14 California Code of Regulations Section 15060(d) as identified above and described in the attached materials.
Comment Submittal:
Written comments on the NOP are due no later than the close of the 36-day NOP review period at 5:00 p.m. on August 6th, 2024. Please send your written comments to Lisa Porras, Planning Manager, at the address or email address shown below with “San Carlos Northeast Area Specific Plan EIR” as the subject.
Public agencies providing comments are asked to include a contact person for the agency.
City of San Carlos Planning Division
Attention: Lisa Porras, Planning Manager
600 Elm Street, San Carlos California 94070-3085
[email protected]
Scoping Meeting:
Pursuant to CEQA Guidelines section 15082(c), notice is hereby given that the City will conduct a public Scoping Meeting on August 5, 2024 at 7:00 PM. This meeting will be conducted both in person at City Hall and virtually via Zoom.
In-Person Participation
The meeting will be held at the Planning and Transportation Commission regular meeting location in the City Hall Council Chambers, 600 Elm Street.
To address the Commission on any item on the posted agenda, fill out a Request to Speak Form located in the back of the Council Chambers and submit it to staff; or you may raise your hand when the Chair calls for public comments.
Masks are no longer required, but are still recommended by the California Department of Health. To maintain public health and safety, please do not attend in person if you are experiencing respiratory symptoms (e.g. cough, runny nose, and/or sore throat).
Remote Participation
This meeting may also be attended remotely via the following options:
x Zoom: https://us02web.zoom.us/j/88635467439; or call 1-669-900-9128 and enter the Meeting ID #: 886 3546 7439
x Meeting Webportal: www.cityofsancarlos.org/agenda
x Local TV: Comcast Channel 27 and AT&T Uverse Channel 99 If you are participating remotely and plan to make a public comment on any item on the posted agenda, please observe the meeting via Zoom (see above access information), and, during the public comment period for the agenda item you wish to address, use the “raise hand” feature. If joining Zoom by phone, press *9 to “raise hand”.
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Notice of Preparation for an Environmental Impact Report for the City of San Carlos Northeast Area Specific Plan
Date of Distribution: July 1, 2024
Introduction
The purpose of an Environmental Impact Report (EIR) is to inform decision-makers and the general public of the environmental impacts of a proposed project that an agency (in this case, the City of San Carlos) may implement or approve. The EIR process is intended to: (1) provide information sufficient to evaluate a project and its potential for significant impacts on the environment; (2) examine methods (e.g., projectspecific mitigations, uniformly applied development regulations) for avoiding or reducing significant impacts; and (3) consider alternatives to the proposed project.
In accordance with CEQA, the Draft EIR will include the following:
x A summary of the project, its potential significant environmental impacts, and mitigations required to avoid or reduce those significant impacts;
x A project description;
x A description of the existing environmental setting, potential environmental impacts, and mitigations for the project;
x Alternatives to the proposed project; and
x Other environmental consequences of the project, including o (1) growth-inducing effects
o (2) significant unavoidable impacts
o (3) irreversible environmental changes
o (4) cumulative impacts, and
o (5) effects found not to be significant.
Project Location:
The Northeast Area Specific Plan (NEASP) area consists of approximately 145 acres, roughly bound by Belmont Creek, U.S Highway 101 (U.S. 101), the western property lines of the residential parcels along Northwood Drive, the northeastern property lines of the residential parcels along Fairfield Drive, and the southeast property line of the Palo Alto Medical Facilities (PAMF) and Old County Road. For the purposes of this analysis, Belmont Creek will be considered north, U.S. 101 will be considered east, the residential parcels along Northwood Drive and Fairfield Drive and the southeast property line of PAMF will be considered south, and Old County Road will be considered west. Please refer to Figures 1 through 3 for maps showing the project location and surrounding context.
Project Description
The purpose of the NEASP is to create a vision, policies, and standards to guide new development within the Plan area in a way that supports existing and new businesses, residents, and the overall community. The NEASP will manage and direct changes in the development patterns within the Plan area and guide present and future land uses, zoning changes, economic development, urban design, infrastructure, transportation circulation management and mobility, service provisions, and community benefits.
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The NEASP would be built out over an approximate 20-year period and would allow for a net increase of 1,890 residential units (no residential units exist within the Plan area currently), as well as an increase in the net square footage of existing non-residential land uses within the Plan area, as summarized in Table 1 below.
Table 1 NEASP Development Projections
Land Use Allowable Square Footage Net Increase
Non Residential Development 4,508,000
Residential Development 1,890,000 (1,890 Units)
Maximum building heights within the NEASP area would range from a minimum of 75 to 100 feet and a maximum of 90 to 155 feet, depending on the land use designation. Additional height increases for specific land uses would be permitted by the City should bonus conditions determined by the City be met, as shown in Table 2 below. The Comprehensive Airport Land Use Compatibility Plan for the Environs of San Carlos Airport (ALUCP) dictates the maximum height permitted within the NEASP to protect navigable airspace around the airport.
Table 2 Maximum Height Allowances
Land Use Base Height Assumption Bonus Height Permitted
Light Industrial Sub Area 1 100 155
Light Industrial Sub Area 2 75 155
Light Industrial Sub Area 3 75 75
Residential Mixed Use Sub Area 1 90 N/A
Residential Mixed Use Sub Area 2 75 N/A
The land use categories identified in Table 2 include Sub-Areas, which would be facets of zoning districts that include a base height allowance as well as a bonus maximum height allowance and floor area. These height and density standards will vary depending on location within the Plan area.
The NEASP is proposing a step down of building heights for properties directly abutting the Greater East San Carlos Neighborhood.
A new street segment from Quarry Road to Bragato Road would be implemented as part of the NEASP.
Additionally, the NEASP would include improvements to the existing transportation network, such as a pedestrian/bicycle connection to Belmont Creek from Quarry Road and the redesign of Industrial Road as a multi-modal district boulevard. The NEASP would increase the setback from Belmont Creek for properties adjacent to Belmont Creek.
A General Plan Amendment and rezoning are proposed to allow for the addition of residential land uses to the Plan area. Please see Figure 4 for a map of the proposed land uses within the NEASP.
Potential Environmental Impacts of the Project
The EIR will identify the significant environmental effects anticipated to result from development and operation of the project as proposed. The EIR will include the following specific environmental categories as related to the proposed project:
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1. Aesthetics
The EIR will describe the existing visual setting of the NEASP area and the visual changes that are anticipated to occur as a result of the NEASP. Aesthetic impacts will be evaluated pursuant to California Public Resources Code Section 21099. Mitigation measures will be identified for significant impacts, as warranted.
2. Agricultural and Forestry Resources
The EIR will describe the NEASP’s impact (if any) on existing farmland, forest land, and timberland.
According to the San Mateo County Important Farmland 2018 Map, properties within the Plan area are designated as Urban and Built-Up Land and therefore the Plan area does not include land mapped as farmland.
3. Air Quality
The EIR will describe the regional air quality conditions in the San Francisco Bay Area and evaluate the air quality impacts from implementation of the NEASP in conformance with the criteria identified by the Bay Area Air Quality Management District (BAAQMD). Given the timing and nature of individual construction projects are unknown, construction air quality impacts and health risk impacts would be addressed qualitatively. Operational emissions of criteria air pollutants from buildout of the Plan would be computed using the CalEEMod model supplemented with the most recently available on-road mobile emission factors, and compared to relevant BAAQMD thresholds. Mitigation measures will be identified for significant impacts, as warranted.
4. Biological Resources
The NEASP area is mostly developed and consists of four habitat types/land uses: developed/landscaped (143.2 acres), riparian (1.2 acres), freshwater marsh (0.6 acre), and aquatic riverine (0.4 acre). There are also a variety of trees present throughout the Plan area, on private properties and within the public right-of-way. The EIR will evaluate the NEASP’s impact on biological resources within and near the Plan area, including sensitive habitats and special-status species. The NEASP’s consistency with local policies and ordinances protecting biological resources will also be discussed. Mitigation measures will be identified for significant impacts, as warranted.
5. Cultural Resources
There are numerous existing buildings within the Plan area, many of which are older than 50 years and may be historic resources. Additionally, the area is adjacent to Belmont Creek, and may be sensitive for archaeological resources. The EIR will include a discussion of potential impacts to cultural and archaeological resources that could result from implementation of the NEASP. Mitigation measures will be identified for significant impacts, as warranted.
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6. Energy
The EIR will examine the potential for the NEASP to result in excessive or inefficient use of energy and discuss the energy conservation measures to be included in future development implementing the NEASP. Mitigation measures will be identified for significant impacts, as warranted.
7. Geology and Soils
The project site is in one of the most seismically active regions in the United States. The EIR will describe the general geologic and soil conditions within the NEASP area and discuss possible geological impacts associated with seismic activity and the existing soil conditions. The potential for future development construction activity to encounter paleontological resources (i.e. fossils) will also be assessed. Mitigation measures will be identified for significant impacts, as warranted.
8. Greenhouse Gas Emissions
The EIR will qualitatively discuss the NEASP’s consistency and conformance with applicable plans, policies, and/or regulations adopted for the purpose of reducing greenhouse gas emissions. Mitigation measures will be identified for significant impacts, as warranted.
9. Hazards and Hazardous Materials
There are sites within the NEASP area with reported spill incidents impacting soil, soil vapor, and/or groundwater. The EIR will evaluate the potential for the NEASP to result in a hazard to the public or environment from the transport, use, disposal, or upset of hazardous materials. The Plan area is located within the San Carlos Airport Influence Area. The EIR will discuss the NEASP’s conformance with applicable Airport Land Use Commission polices governing development near the San Carlos Airport, located to the southeast of the Plan area. Mitigation measures will be identified for significant impacts, as warranted.
10. Hydrology and Water Quality
The NEASP area is bounded by Belmont Creek to the north, and the area has experienced localized flooding. The EIR will describe the general hydrologic and drainage conditions of the NEASP area and any changes in site drainage and hydrological conditions resulting from implementation of the proposed NEASP. The EIR will also describe impacts on stormwater runoff quantity/quality and groundwater resources. Impacts related to inundation and the potential for subsidence will also be discussed.
Mitigation measures will be identified for significant impacts, as warranted.
11. Land Use
The EIR will evaluate if the NEASP would physically divide an established community or cause a significant environmental impact due to a conflict with relevant land use plans, policies, and regulations adopted for the purpose of avoiding or mitigating an environmental effect. Land use impacts that would
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occur as a result of the proposed project will be analyzed, including the consistency of the project with the City’s General Plan and zoning code and compatibility of the proposed and existing land uses in the project area. The effect of the project on the City’s jobs/housing balance will also be analyzed. Mitigation measures will be identified for significant impacts, as warranted.
12. Noise and Vibration
The existing, predominate noise sources in the NEASP area include vehicular traffic along roadways (including US 101, Industrial Road, and Old Country Road), trains along Caltrain’s tracks, and aircraft operations associated with the San Carlos Airport. The EIR will evaluate noise and vibration impacts from buildout of the NEASP with respect to existing standards. The EIR will also discuss the NEASP’s consistency with the San Carlos Airport Land Use Compatibility Plan, particularly its potential to expose people residing or working in the NEASP area to excessive aircraft noise levels. Mitigation measures will be identified for significant impacts, as warranted.
13. Mineral Resources
The EIR will describe whether the NEASP would result in the loss of availability of a known mineral resource or locally-important mineral resource recovery site.
14. Population and Housing
Currently, there are no residential uses within the NEASP area. For this reason, the NEASP would not displace existing housing or residents. The NEASP proposes 1,890 new housing units, which would house a population of approximately 3,700 residents. The EIR will discuss if the NEASP would induce substantial unplanned population growth in the area, beyond what is proposed as part of the NEASP, either directly or indirectly. Mitigation measures will be identified for significant impacts, as warranted.
15. Public Services
The EIR will describe the available public services (e.g., fire and police protection, schools, libraries, and parks) in the NEASP area and the potential for the NEASP to require the expansion or construction of additional facilities. The EIR discussion will focus on whether the expansion or construction of additional facilities would result in significant environmental impacts. Mitigation measures will be identified for significant impacts, as warranted.
16. Recreation
The EIR will describe the available recreational facilities in the NEASP area and the potential for the NEASP to substantially accelerate the deterioration of those facilities or require the expansion or construction of additional facilities, and whether the expansion or new construction of additional facilities would result in significant environmental impacts.
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17. Transportation
The EIR will evaluate possible transportation impacts from implementation of the NEASP using the Vehicle Miles Traveled (VMT) metric. The EIR will discuss the NEASP’s consistency with programs, plans, ordinances, and policies addressing the circulation system (including transit, roadway, bicycle, and pedestrian facilities). Mitigation measures will be identified for significant impacts, as warranted.
18. Tribal Cultural Resources
The EIR will identify whether tribal cultural resources have been identified in the area, including through consultation with a tribe(s) culturally affiliated with the area, per Assembly Bill 52. Mitigation measures will be identified for significant impacts, as warranted.
19. Utilities
The EIR will describe the existing sanitary sewer, storm drain, water, and solid waste services for the NEASP area. The EIR will discuss the adequacy of the existing utilities and service systems to accommodate the demand from the proposed NEASP and identify necessary improvements. Pursuant to SB 610, a Water Supply Assessment for the NEASP will be completed by the local water retailer serving the area and included in the EIR. Mitigation measures will be identified for significant impacts, as necessary.
20. Wildfire
The proposed project is located within an urbanized area of the City of San Carlos and is not within a State Responsibility Area or lands classified as very high fire hazard severity zones according to CalFire.
The EIR will discuss whether the NEASP would impact or exacerbate wildfire risk and/or impair emergency response.
21. Alternatives
The EIR will examine alternatives to the NEASP including a “No Project” alternative and one or more alternative development scenarios depending on the impacts identified. Alternatives discussed will be chosen based on their ability to reduce or avoid identified significant impacts of the proposed project while achieving most of the identified objectives of the project.
22. Significant Unavoidable Impacts
The EIR will identify those significant impacts that cannot be avoided, if the project is implemented as proposed.
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23. Cumulative Impacts
The EIR will include an analysis of potentially significant cumulative impacts of the project when considered with other past, present, and reasonably foreseeable future projects in the development area.
24. Other Required Sections
In conformance with the CEQA Guidelines, the EIR will also include the following sections: 1) growthinducing impacts, 2) significant irreversible environmental changes, 3) references and organizations/persons consulted, and 4) EIR authors.
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San Mateo
Foster City
Belmont
San Carlos
Redwood City
East Palo
Alto
Palo Alto
Menlo Park
Woodside
Portola
Valley
Los Altos
Hills
San Mateo
Foster City
Belmont
San Carlos
Redwood City
East Palo
Alto
Palo Alto
Menlo Park
Woodside
Portola
Valley
Los Altos
Hills
280
280
82 82
92 84
92 101
101
SAN
FRANCISCO
BAY
REGIONAL MAP FIGURE 1
01 .5 5 Miles
San Francisco Bay
PaciĮc Ocean
Monterey Bay
San José
Fremont
Oakland
San Francisco
Santa Cruz
Morgan Hill
San José
Fremont
Oakland
San Francisco
Santa Cruz
Mountain
View
Morgan Hill
Project Site
Project Site
San Carlos
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Industrial Road
Holly Street
Taylor Way
Bragato Road
Quarry Road
Harbor Boulevard
Belmont Creek
Belmont Creek
Twin Dolphin Drive
Redwood Shores Parkway
Shorelin e D r vi e
Ralston Avenue
El Camino Real
Old County Road
Old County Road
Caltrain
Caltrain
Industrial Road
Holly Street
Taylor Way
Bragato Road
Quarry Road
Harbor Boulevard
Belmont Creek
Belmont Creek
Twin Dolphin Drive
Redwood Shores Parkway
Shorelin e Dr ve i
Ralston Avenue
El Camino Real
Old County Road
Old County Road
Caltrain
Caltrain
101
101
Project Boundary
Base Map: ESRI, ArcGIS
0 200 800 1,200 2,000 Feet
VICINITY MAP FIGURE 2
z~ I
/
/
I
I
I J
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Holly Street
Redwood Shores Parkway
Industrial Road
Old County Road
Old County Road
Harbor Boulevard
Quarry Road
Belmont Creek
Bragato Road
Glenn Way
Taylor Way
El Camino Real
Holly Street
Redwood Shores Parkway
Industrial Road
Old County Road
Old County Road
Caltrain Caltrain
Caltrain Caltrain
Harbor Boulevard
Quarry Road
Belmont Creek
Bragato Road
Glenn Way
Taylor Way
El Camino Real
Twin Dolphin Drive Twin Dolphin Drive
101
101
Photo Date: Apr. 2022
0 150 600 900 1,500 Feet
Project Boundary
Aerial Source: Google Earth Pro, Jun. 6, 2024.
San Carlos
AERIAL PHOTOGRAPH OF THE PROJECT SITE FIGURE 3
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Light Industrial 1
Light Industrial 2 Light Industrial 3
Residential Mixed-Use 1
Residential Mixed-Use 2
Institutional
Source: Perkins & Will.
NEW STREET SEGMENT
WZKWK^
LAND USES FIGURE 4
!EAL
0 co
"" 0
<{
I
,, San Carlos City Boundary
I
I
I
us 1011
I
I
r
INDUSTRIAL ROAD
-
To Son Carlos Airport
LIGHT INDUSTRIAL
SUB AREA 1
LIGHT INDUSTRIAL
SUBAREA2
LIGHT INDUSTRIAL
SUB AREA 3
RESIDENTIAL MIXED-USE
SUB AREA 1
RESIDENTIAL MIXED-USE
SUB AREA 2
INSTITUTIONAL
June 08, 2026 Packet Pg. 1974
APPENDIX B
Summary of Known Developments and their Cumulative Impacts in the Three Peninsula Districts
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2025 2030 2035 2040 2045
Normal Year Projected Water Supply (b) 42,367 42,367 42,367 42,367 42,367 UWMP Normal Year Projected Demands (c) 34,230 34,185 34,624 35,125 35,869 Total South San Francisco District WSA Demands (d) 2,075 3,982 4,531 4,909 5,047 WSA Demands Included in UWMP Demands 1,642 1,642 1,642 1,642 1,642 WSA Demands Subject to Development Offset Program (e) 804 2,673 3,221 3,618 3,756 WSA Demands Additive to UWMP Projections 186 225 225 206 206 Total Mid-Peninsula District WSA Demands 110 302 310 319 328 WSA Demands Included in UWMP Demands 0 15 24 32 41
WSA Demands Subject to Development Offset Program 64 200 200 200 200 WSA Demands Additive to UWMP Projections 4687878787
Total Bear Gulch District WSA Demands 448 448 448 448 448 WSA Demands Included in UWMP Demands 00000
WSA Demands Subject to Development Offset Program 00000 WSA Demands Additive to UWMP Projections 448 448 448 448 448 Total WSA Demands Subject to Development Offset Program (f) 868 2,873 3,421 3,818 3,956 Total Additive Demand to UWMP Demands 680 760 760 741 741 Abbreviations:
"AFY" = acre-feet per year "MPS" = Mid-Peninsula
"BG" = Bear Gulch "SFPUC" = San Francisco Public Utilities Commission "EKI" = EKI Environment & Water, Inc. "SSF" = South San Francisco "ISG" = Individual Supply Guarantee "UWMP" = Urban Water Management Plan "MOU" = memorandum of understanding "WSA" = Water Supply Assessment Appendix B
Summary of Known Developments and their Cumulative Impacts in the Three Peninsula Districts Supply and Demand
Net Annual Water Supply and Demand (AFY) (a)
34,230 34,185 34,624 35,125 35,869
680 760 760 741
741 868
2,873 3,421 3,818
3,956
42,367 42,367 42,367 42,367 42,367
0 5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
2025 2030 2035 2040 2045
Water Supply and Demand (AFY)
Projected Normal Year Supply and Demand
UWMP Normal Year Projected Demands (c) Total Additive Demand to UWMP Demands Total WSA Demands Subject to Development Offset Program (f) Normal Year Projected Water Supply (b) - - l!ZZZJ
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Appendix B
Summary of Known Developments and their Cumulative Impacts in the Three Peninsula Districts Notes:
(a) Water demands associated with known developments per References 1 through 19. (b)
(c)
(d)
(e)
(f)
References:
1. EKI, 2019. Water Supply Assessment for the South San Francisco SFPUC Site, prepared for the Cal Water, dated May 2019.
2. EKI, 2021. Water Supply Assessment for the Southline Specific Plan Project, prepared for the Cal Water, dated December 2021.
3. EKI, 2022a. Water Supply Assessment for the 121 East Grand Avenue Project, prepared for the Cal Water, dated August 2022.
4. EKI, 2022b. Water Supply Assessment for the Alexandria District for Science and Technology, prepared for the Cal Water, dated September 2022.
5. EKI, 2022c. Water Supply Assessment for the 803-851 Old County Road Project, prepared for the Cal Water, dated October 2022.
6. EKI, 2022e. Water Supply Assessment for the 800 Dubuque Avenue Project, prepared for the Cal Water, dated November 2022.
7. EKI, 2023a. Water Supply Assessment for the Healthpeak Vantage Project, prepared for the Cal Water, dated March 2023.
8. EKI, 2023c. Water Supply Assessment for the 789 Old County Road Project, prepared for the Cal Water, dated July 2023.
9. EKI, 2023d. Water Supply Assessment for the Infinite 101 Project, prepared for Cal Water, dated July 2023.
10. EKI, 2023e. Water Supply Assessment for 573 Forbes Avenue Project, prepared for Cal Water, dated October 2023.
11. EKI, 2024a. Water Supply Assessment for the 439 Eccles Project, prepared for Cal Water, dated February 2024.
12. EKI, 2024b. Water Supply Assessment for the Infinite 131 Project, prepared for Cal Water, dated March 2024.
13. EKI, 2024c. Water Supply Assessment for the 691 & 695 Gateway Boulevard Project, prepared for Cal Water, dated July 2024.
14. EKI, 2024d. Water Supply Assessment for the 175 Sylvester Road Project, prepared for Cal Water, dated September 2024.
15. EKI, 2025. Water Supply Assessment for the Baylands Specific Plan, prepared for Cal Water, dated January 2025.
16. EKI, 2024f. Draft Water Supply Assessment for the Sierra Point Towers Project, prepared for Cal Water, dated September 2024.
17. EKI, 2024g. Draft Water Supply Assessment for the Sierra Point Hotel and Life Science Project, prepared for Cal Water, dated September 2024.
18. 19.
20. Cal Water, 2021a. 2020 Urban Water Management Plan, South San Francisco District, prepared by California Water Service, dated June 2021.
21. Cal Water, 2021b. 2020 Urban Water Management Plan, Bear Gulch District, prepared by California Water Service, dated June 2021.
22. Cal Water, 2021c. 2020 Urban Water Management Plan, Mid-Peninsula District, prepared by California Water Service, dated June 2021.
Projected supply is assumed equal to the supplies available for all three districts during normal hydrologic years, which includes 840 AFY from the BG Reservoir, 1,534 AFY from the SSF wells (per References 20 and 21), and Cal Water's ISG of 39,993 AFY from SFPUC, which is shared among the BG, MPS, and SSF Districts.
These projected supply values for normal hydrologic years differ from what is presented in the 2020 UWMP, which estimates a normal year supply equal to projected demand.
Includes projected demands for all three Peninsula Districts per References 20, 21, and 22. It should be noted that the projected demands for the SSF District have decreased by 527 AFY relative to those reported in the SSF District 2020 UWMP because the Southline Specific Plan Project, which had previously been included in the demand projections for the SSF District, is now expected to comply with the Offset Program and will not result in a net increase in demands.
City of Menlo Park, 2022. Draft City of Menlo Park Housing Element Update, Water Supply Assessment for the Water Service Provided by the California Water Service (Bear Gulch District) and Menlo Park Municipal Water, prepared by Environmental Science Associates (ESA), dated September 2022.
Cal Water, 2018. Water Supply Assessment for 201 Haskins Way Rezoning and General Plan Amendment Project, dated 6 September 2018, prepared by Cal Water.
The WSA demand subtotals do not sum up to the total WSA demands for the SSF District because 527 AFY out of the 557 AFY total project demands for the Southline Specific Plan were accounted for in the SSF District's 2020 UWMP; however, the Southline Specific Plan is now expected to comply with the Offset Program and is therefore required to offset the total project demands.
Includes the preliminary demand estimates for the Sierra Point Towers and Sierra Point Hotel and Life Science projects based on previously received project information per References 16 and 17. The demands for the Sierra Point Towers and Sierra Point Hotel and Life Science may be updated to reflect more current project information upon completion of the respective WSAs.
Total offset volume will be met by accelerated water supply projects and/or mitigated through expanded customer conservation programs rather than Cal Water's ISG or other supplies from the BG Reservoir and the SSF wells.
10.b
June 08, 2026 Packet Pg. 1977
APPENDIX C
2021 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 (excluding attachments)
10.b
June 08, 2026 Packet Pg. 1978
17162043.1
2021
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
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June 08, 2026 Packet Pg. 1979
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2021 Amended and Restated WSA 17162043.1
TABLE OF CONTENTS
Article 1. Parties, Effective Date, And Defined Terms.............................................................. 1
1.01. Definitions................................................................................................................. 1
1.02. Parties ...................................................................................................................... 1
1.03. Effective Date ........................................................................................................... 2 Article 2. Term; Amendments During Term.............................................................................. 4
2.01. Term......................................................................................................................... 4
2.02. Extension and Renewal of Term............................................................................... 4
2.03. Amendments ............................................................................................................ 5 Article 3. Water Supply............................................................................................................ 8
3.01. Supply Assurance..................................................................................................... 8
3.02. Allocation of Supply Assurance................................................................................. 9
3.03. Wholesale Customer Service Areas ........................................................................10
3.04. Permanent Transfers of Individual Supply Guarantees and Minimum Annual Purchase Quantities ................................................................................................12
3.05. Restrictions on Resale.............................................................................................16
3.06. Conservation; Use of Local Sources; Water Management Charge ..........................16
3.07. Restrictions on Purchases of Water from Others; Minimum Annual Purchases .......17
3.08. Water Quality...........................................................................................................18
3.09. Completion of WSIP ................................................................................................19
3.10. Regional Water System Repair, Maintenance and Operation ..................................19
3.11. Shortages ................................................................................................................20
3.12. Wheeling of Water from Outside SFPUC System ....................................................22
3.13. Limits on New Customers........................................................................................23
3.14. Measurement of Water ............................................................................................24
3.15. New Sources of Water Supply to Maintain Supply Assurance .................................26
3.16. New Sources of Water Supply to Increase Supply Assurance .................................27
3.17. Westside Basin Groundwater Storage and Recovery Project ..................................28
3.18. Water Supply Agreement Amendment Required. ....................................................32 Article 4. Implementation of Interim Supply Limitation.............................................................34
4.01. Interim Supply Limitation Imposed by SFPUC .........................................................34
4.02. Retail and Wholesale Customer Allocations Under Interim Supply Limitation ..........34
4.03. Transfers of Interim Supply Allocations....................................................................34
4.04. Environmental Enhancement Surcharge..................................................................35
4.05. San Jose/ Santa Clara Interim Supply Allocation and Process for Reduction/ Termination..............................................................................................................37
4.06. San Francisco Decisions in 2028 Regarding Future Water Supply ..........................39
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4.07. Retained Discretion of SFPUC and Wholesale Customers ......................................39 Article 5. Wholesale Revenue Requirement ...........................................................................41
5.01. Scope of Agreement................................................................................................41
5.02. General Principles ...................................................................................................41
5.03. Capital Cost Recovery - Existing Regional Assets ...................................................43
5.04. Capital Cost Contribution - New Regional Assets ....................................................45
5.05. Water Enterprise Operation and Maintenance Expenses.........................................47
5.06. Water Enterprise Administrative and General Expenses..........................................49
5.07. Water Enterprise Property Taxes.............................................................................51
5.08. Hetch Hetchy Enterprise Expenses .........................................................................51
5.09. Hetch Hetchy Enterprise Capital Costs....................................................................53
5.10. Additional Agreements Related to Financial Issues .................................................54
5.11. Classification of Existing System Assets..................................................................57 Article 6. Integration of Wholesale Revenue Requirement with SFPUC Budget Development and Rate Adjustments .............................................................................................60
6.01. General....................................................................................................................60
6.02. Budget Development ...............................................................................................60
6.03. Rate Adjustments ....................................................................................................60
6.04. Rate Structure .........................................................................................................62
6.05. Balancing Account...................................................................................................63
6.06. Wholesale Revenue Coverage Reserve ..................................................................65
6.07. Working Capital Requirement ..................................................................................67
6.08. Wholesale Capital Fund...........................................................................................68
6.09. SFPUC Adoption of Regional Water System 10-Year Capital Improvement Program .............................................................................................70 Article 7. Accounting Procedures; Compliance Audit ..............................................................75
7.01. SFPUC Accounting Principles, Practices .................................................................75
7.02. Calculation of and Report on Wholesale Revenue Requirement..............................76
7.03. Appointment of Compliance Auditor.........................................................................77
7.04. Conduct of Compliance Audit ..................................................................................78
7.05. Issuance of Compliance Auditor’s Report ................................................................80
7.06. Wholesale Customer Review...................................................................................81 Article 8. Other Agreements of the Parties..............................................................................82
8.01. Arbitration and Judicial Review................................................................................82
8.02. Attorneys’ Fees........................................................................................................86
8.03. Annual Meeting and Report .....................................................................................87
8.04. Administrative Matters Delegated to BAWSCA ........................................................88
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2021 Amended and Restated WSA 17162043.1
8.05. Preservation of Water Rights; Notice of Water Rights Proceedings .........................89
8.06. SFPUC Rules and Regulations................................................................................89
8.07. Reservations of, and Limitations on, Claims ............................................................90
8.08. Prohibition of Assignment ........................................................................................92
8.09. Notices ....................................................................................................................93
8.10. Incorporation of Attachments...................................................................................94
8.11. Interpretation ...........................................................................................................94
8.12. Actions and Approvals by San Francisco.................................................................94
8.13. Counterparts............................................................................................................94
8.14. Limitations on Damages ..........................................................................................95
8.15. Force Majeure .........................................................................................................95
8.16. No Third-Party Beneficiaries ....................................................................................96
8.17. Good Faith and Fair Dealing....................................................................................96 Article 9. Implementation and Special Provisions Affecting Certain Wholesale Customers.....97
9.01. General; Individual Water Sales Contracts ..............................................................97
9.02. California Water Service Company ..........................................................................97
9.03. City of Hayward .......................................................................................................99
9.04. Estero Municipal Improvement District...................................................................100
9.05. Stanford University ................................................................................................100
9.06. City of San Jose and City of Santa Clara ...............................................................101
9.07. City of Brisbane, Guadalupe Valley Municipal Improvement District, Town of Hillsborough...........................................................................................................102
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2021 Amended and Restated WSA 17162043.1
LIST OF ATTACHMENTS
A
B
C
D
E
E-1
E-2
F
G
H
I
J
K-1
K-2
K-3
K-4
K-5
L-1
L-2
L-3
M-1
Definitions
Wholesale Customer Regional Water System Purchases 2007-2008 (Section 1.03) List of Agencies and Individual Supply Guarantees (Section 3.02) Procedure for Pro Rata Reduction of Individual Supply Guarantees if Total Use Exceeds 184 MGD (Section 3.02)
Minimum $QQXDO3XUFKDVHQuantities (Section 3.07.C)
Temporary Modified Minimum Annual Purchase Quantities (Sections 3.04 and
3.07.C)
Illustrations of a Transfer of a Portion of a Minimum Annual Purchase Quantity Pursuant to Sections 3.04 and 3.07.C
Sample Individual Water Sales Contract (Section 9.01)
Water Quality Notification and Communications Plan (2019 Update of 2017 Plan, Rev. 6) (Section 3.08.B)
Tier 1 Shortage Plan (Section 3.11.C)
NOT USED
Water Use Measurement and Tabulation (Section 3.14)
Wholesale Customers’ Share of Net Book Value of Existing Assets (Section 5.03) Wholesale Customers’ Share of the Revenue-Funded Capital Expenditures (Section
5.03)
Annual Payments for Wholesale Share of 6/30/09 Net Plant & CWIP (Water Assets) (Section 5.03)
Annual Payments for Wholesale Share of 6/30/09 Net Plant & CWIP (Hetch Hetchy Assets) (Section 5.03)
10-Year Payoff Schedules for Existing Rate Base (Section 5.03) Identification of WSIP Projects as Regional/Retail (Section 5.04) Certificate of Use of Proceeds (Section 5.04.A)
Annual Report on Expenditures of and Earnings on Proceeds (Section 5.04.A) Revenue-Funded Capital Additions (Section 5.04.B)
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2021 Amended and Restated WSA 17162043.1
M-2 Revenue-Funded Capital Annual Reporting Requirements (Section 5.04.B) M-3 Wholesale Capital Fund and Balancing Account Adjustment (Section 6.08) N-1 Balancing Account/Rate Setting Calculation Table (Section 6.03.A.3.a) N-2 Wholesale Revenue Requirement Schedules (Section 6.03.A.3.b) N-3 Schedule of Projected Water Sales, Wholesale Revenue Requirement and Wholesale Rates (Section 6.03.A.3.c)
O Statement of Wholesale Revenue Requirement/Changes in Balancing Account (Section 7.02.B.1)
P Management Representation Letter (Section 7.02.B.5)
Q-1 San Jose Service Area (Section 9.06)
Q-2 Santa Clara Service Area (Section 9.06)
R Classification of Existing System Assets (Section 5.11)
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June 08, 2026 Packet Pg. 1984
1 2021 Amended and Restated WSA 17162043.1
AMENDED AND RESTATED
WHOLESALE WATER SUPPLY AGREEMENT
Introductory Statement
Both San Francisco, as the Regional Water System owner and operator, and its Wholesale Customers share a commitment to the Regional Water System providing a reliable supply of high quality water at a fair price, and achieving these goals in an environmentally sustainable manner.
Article 1. Parties, Effective Date, And Defined Terms
1.01. Definitions
The capitalized terms used in this Agreement shall have the meanings set forth in Attachment A.
1.02. Parties
The parties to this Agreement are the City and County of San Francisco and such of the following entities (all of which purchase water from San Francisco) as have executed this Agreement:
Alameda County Water District
California Water Service Company
City of Brisbane
City of Burlingame
City of Daly City
City of East Palo Alto
City of Hayward
City of Menlo Park
City of Millbrae
City of Milpitas
City of Mountain View
City of Palo Alto
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2 2021 Amended and Restated WSA 17162043.1
City of Redwood City
City of San Bruno
City of San José
City of Santa Clara
City of Sunnyvale
Coastside County Water District
Estero Municipal Improvement District
Guadalupe Valley Municipal Improvement District
Mid-Peninsula Water District
North Coast County Water District
Purissima Hills Water District
Stanford University
Town of Hillsborough
Westborough Water District
The entities listed above which have executed this Agreement shall be collectively referred to as the “Wholesale Customers.”
1.03. Effective Date
A. Except as provided in subsection C, this Agreement shall become effective only when it has been approved by San Francisco and by each of the entities listed in Section 1.02 and when San Francisco and each of those entities (except for the City of Hayward) have entered into an Individual Water Sales Contract as provided in Section 9.01.
B. If San Francisco and all of the entities listed in Section 1.02 approve this Agreement and (except for the City of Hayward) an Individual Water Sales Contract on or before July 1, 2009, the effective date shall be July 1, 2009. If San Francisco and all of the entities listed in Section 1.02 approve this Agreement and (except for the City of Hayward) an Individual Water Sales Contract after July 1, 2009 but on or before September 1, 2009, the effective date shall be the date on which the last entity listed in Section 1.02 approves this Agreement and, if required, an Individual Water Sales Contract.
C. If by September 1, 2009 this Agreement has been approved by fewer than all of the entities listed in Section 1.02 or fewer than all of such entities (other than the City of Hayward) have entered into an Individual Water Sales Contract, but it has been approved by entities representing at least 75% in number and 75% of the water purchased from SFPUC by
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all listed agencies during FY 2007-08 (i.e., 173.39 MGD), then San Francisco shall have the option to waive the requirement in subsection A that all listed agencies have approved this Agreement and an Individual Water Sales Contract as a condition precedent to this Agreement and any Individual Water Sales Contract becoming effective. San Francisco shall have 60 days from September 1, 2009 (i.e., until October 31, 2009) within which to decide whether or not to waive the condition. If San Francisco decides to waive the condition, those listed agencies that have approved this Agreement and Individual Water Sales Contract before October 31, 2009 will be bound thereby and this Agreement and Individual Water Sales Contracts will become effective as to them, as of the date of San Francisco’s waiver. For purposes of determining whether listed agencies that have approved this Agreement represent at least 75% of the water purchased during FY 2007-08, the quantity of water attributable to each listed entity shall be as set forth on Attachment B.
D. The provisions of Article 9 that apply to fewer than all Wholesale Customers (i.e., Sections 9.02 - 9.07) shall not become effective unless San Francisco and the entity to which the section applies have each approved (1) this Agreement, and (2) the underlying Individual Water Sales Contract, unless otherwise provided in Article 9. This provision does not affect the continued enforceability of provisions in those sections that derive from independently enforceable judgments, orders or agreements.
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Article 2. Term; Amendments During Term
2.01. Term
The term ("Term") of this Agreement shall be twenty five (25) years. The Term shall begin on July 1, 2009, regardless of whether the Effective Date is before or after that date, and shall end on June 30, 2034. Except as provided in Article 9, the term of all Individual Water Sales Contracts shall also begin on July 1, 2009 and end on June 30, 2034.
2.02. Extension and Renewal of Term
A. In December 2031, the SFPUC may provide written notice to the Wholesale Customers that it is willing to extend the Term of this Agreement. Between January 1, 2032 and June 30, 2032, any Wholesale Customer may accept the SFPUC's offer to extend the Term by providing a written notice of extension to the SFPUC. If such notices of extension are received from Wholesale Customers representing at least two-thirds in number as of June 30, 2032 and seventy five percent (75%) of the quantity of water delivered by the SFPUC to all Wholesale Customers during fiscal year 2030-31, the Term shall be extended for another five (5) years ("First Extension Term"), through June 30, 2039. No party to this Agreement which does not wish to remain a party during the Extension Term shall be compelled to do so by the actions of other parties under this section.
B. In December 2036, the SFPUC may provide written notice to the Wholesale Customers that it is willing to extend the Term of this Agreement. Between January 1, 2037 and June 30, 2037, any Wholesale Customer may accept the SFPUC's offer to extend the Term by providing a written notice of extension to the SFPUC. If such notices of extension are received from Wholesale Customers representing at least two-thirds in number as of June 30, 2037 and seventy five percent (75%) of the quantity of water delivered by the SFPUC to all Wholesale Customers during fiscal year 2035-36, the Term shall be extended for another five (5) years ("Second Extension Term"), through June 30, 2044. No party to this Agreement which does not wish to remain a party during the Extension Term shall be compelled to do so by the actions of other parties under this section.
C. After the expiration of the Term, and, if applicable, the Extension Terms, this Agreement may be renewed by mutual consent of the parties, subject to any modifications thereof which may be determined at that time. If fewer than all of the parties desire to renew this Agreement beyond its Term, with or without modifications, the SFPUC and the Wholesale
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5 2021 Amended and Restated WSA 17162043.1
Customers who wish to extend the Agreement shall be free to do so, provided that no party to this Agreement which does not wish to become a party to such a renewed Agreement shall be compelled to do so by the actions of other parties under this section.
2.03. Amendments
A. Amendments to Agreement; General
1. This Agreement may be amended with the written consent of all parties.
2. This Agreement may also be amended with the written consent of San Francisco and of Wholesale Customers representing at least two-thirds in number (i.e., 18 as of July 1, 2009) and seventy five percent (75%) of the quantity of water delivered by San Francisco to all Wholesale Customers during the fiscal year immediately preceding the amendment.
3. No amendment which adversely affects a Fundamental Right of a Wholesale Customer may be made without the written consent of that customer. Amendments to Article 5 which merely affect the allocation of costs between City Retail customers on the one hand and Wholesale Customers collectively on the other, and amendments to Articles 6 and 7 which merely alter budgetary, accounting and auditing procedures do not affect Fundamental Rights and may be made with the consent of parties meeting the requirements of Section
2.03.A.2.
4. When an amendment has been approved by San Francisco and the number of Wholesale Customers required in Section 2.03.A.2, San Francisco shall notify each of the Wholesale Customers in writing of the amendment's adoption. Notwithstanding any provision of law or this Agreement, any Wholesale Customer that claims that the amendment violates its Fundamental Rights under Section 2.03.A.3, shall have 30 days from the date San Francisco delivers the notice of its adoption in which to challenge the amendment’s validity through a judicial action. If no such action is filed within 30 days, the amendment shall be finally and conclusively deemed to have been adopted in compliance with this section.
B. Amendments to Article 9
1. Notwithstanding the provisions of Sections 2.03.A.2 and 2.03.A.3, any provision of Article 9 which applies only to an individual Wholesale Customer may be amended with the written concurrence of San Francisco and the Wholesale Customer to which it applies;
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provided that the amendment will not, directly or indirectly, adversely affect the Fundamental Rights of the other Wholesale Customers.
2. Before making any such amendment effective, San Francisco shall give notice, with a copy of the text of the proposed amendment, to all other Wholesale Customers.
The Wholesale Customers shall have 30 days in which to object to the amendment on the ground that it is not permissible under this subsection. If no such objection is received by San Francisco, the proposed amendment shall become effective. If one or more Wholesale Customers object to the amendment, San Francisco, the individual Wholesale Customer with which San Francisco intends to effect the amendment, and the Wholesale Customer(s) which lodged the objection shall meet to discuss the matter.
3. If the dispute cannot be resolved and San Francisco and the Wholesale Customer involved elect to proceed with the amendment, either San Francisco or the Wholesale Customer shall give written notice of such election to each Wholesale Customer that has objected. Any Wholesale Customer that has objected to such amendment shall have 30 days from receipt of this notice within which to commence an action challenging the validity of such amendment, and such amendment shall be deemed effective as of the end of this 30-day period unless restrained by order of court.
C. Amendments to Attachments. The following attachments may be amended with the written concurrence of San Francisco and BAWSCA on behalf of the Wholesale Customers:
Attachment Name
C Individual Supply Guarantees (amendments reflecting Section
3.04 transfers only)
E Minimum Annual Purchase Quantities (amendments reflecting Section 3.04 transfers only)
E-1 Temporary Modified Minimum Annual Purchase Quantities G Water Quality Notification and Communications Plan
(2019 Update of 2017 Plan, Rev. 6)
J Water Use Measurement and Tabulation
L-1 Identification of WSIP Projects as Regional/Retail
N-1 Balancing Account/Rate Setting Calculation Table
N-2 Wholesale Revenue Requirement Schedules
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N-3 Schedule of Projected Water Sales, Wholesale Revenue Requirement and Wholesale Rates
P Management Representation Letter
R Classification of Existing System Assets (subject to Section
5.11)
Amendments to these attachments shall be approved on behalf of San Francisco by the Commission and on behalf of BAWSCA by its Board of Directors, unless the Commission by resolution delegates such authority to the General Manager of the SFPUC or the Board of Directors by resolution delegates such authority to the General Manager/CEO of BAWSCA.
D. Amendments to Individual Water Sales Contracts. Individual Water Sales Contracts described in Section 9.01 may be amended with the written concurrence of San Francisco and the Wholesale Customer which is a party to that Individual Water Sales Contract; provided that the amendment is not inconsistent with this Agreement or in derogation of the Fundamental Rights of other Wholesale Customers under this Agreement.
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Article 3. Water Supply
3.01. Supply Assurance
A. San Francisco agrees to deliver water to the Wholesale Customers up to the amount of the Supply Assurance. The Supply Assurance is for the benefit of the entities listed in Section 1.02, irrespective of whether or not they have executed this Agreement. Water delivered by San Francisco to Retail Customers shall not be included in the Supply Assurance.
Until December 31, 2018, the foregoing commitment is subject to Article 4.
B. Both the Supply Assurance and the Individual Supply Guarantees identified in Section 3.02 are expressed in terms of daily deliveries on an annual average basis and do not themselves constitute a guarantee by San Francisco to meet peak daily or hourly demands of the Wholesale Customers, irrespective of what those peak demands may be. The parties acknowledge, however, that the Regional Water System has been designed and constructed to meet peak daily and hourly demands and that its capacity to do so has not yet been reached.
San Francisco agrees to operate the Regional Water System to meet peak requirements of the Wholesale Customers to the extent possible without adversely affecting its ability to meet peak demands of Retail Customers. This Agreement shall not preclude San Francisco from undertaking to meet specific peak demand requirements of individual Wholesale Customers in their Individual Water Sales Contracts.
C. The Supply Assurance is perpetual and shall survive the expiration or earlier termination of this Agreement. Similarly, the Individual Supply Guarantees identified in Section
3.02 and/or the Individual Water Sales Contracts are perpetual and shall survive the expiration or earlier termination of this Agreement or the Individual Water Sales Contracts.
D. Notwithstanding the Supply Assurance established by this section, the Individual Supply Guarantees identified in Section 3.02 and the Individual Water Sales Contracts, the amount of water made available by San Francisco to the Wholesale Customers is subject to reduction, to the extent and for the period made necessary by reason of water shortage, Drought, Emergencies, or by malfunctioning or rehabilitation of facilities in the Regional Water System. Any such reduction will be implemented in accordance with Section 3.11. The amount of water made available to the Wholesale Customers may not be reduced, however, merely because the water recycling and groundwater projects which the WSIP envisions to be constructed within San Francisco, or the conservation programs intended to reduce water use
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by Retail Customers that are included in the WSIP, do not generate the yield or savings (10 MGD combined) anticipated by San Francisco.
3.02. Allocation of Supply Assurance
A. Pursuant to Section 7.02 of the 1984 Agreement, a portion of the Supply Assurance has been allocated among 24 of the 26 Wholesale Customers. These Individual Supply Guarantees are also expressed in terms of annual average metered deliveries of millions of gallons per day and are listed in Attachment C.
B. Three Wholesale Customers do not have Individual Supply Guarantees. The cities of San Jose and Santa Clara do not have an Individual Supply Guarantees because San Francisco has provided water to them on a temporary and interruptible basis as described in Sections 4.05 and 9.06. The City of Hayward does not have an Individual Supply Guarantee because of the terms of the 1962 contract between it and San Francisco, as further described in Section 9.03.
C. If the total amount of water delivered by San Francisco to Hayward and to the Wholesale Customers that are listed on Attachment C exceeds 184 MGD over a period of three consecutive fiscal years (i.e., July 1 through June 30), then the Individual Supply Guarantees of those Wholesale Customers listed on Attachment C shall be reduced pro rata so that their combined entitlement and the sustained use by Hayward does not exceed 184 MGD. The procedure for calculating the pro rata reduction in Individual Supply Guarantees is set out in Attachment D.
1. The provisions of this subsection C are not in derogation of the reservation of claims to water in excess of the Supply Assurance which are contained in Section
8.07. Nor do they constitute an acknowledgement by Wholesale Customers other than Hayward that San Francisco is obligated or entitled to reduce their Individual Supply Guarantees in the circumstances described herein. The provisions of this subsection C shall, however, be operative unless and until a court determines that its provisions violate rights of the Wholesale Customers derived independently of this Agreement.
2. The foregoing paragraph is not intended to and shall not constitute a contractual commitment on the part of San Francisco to furnish more water than the Supply Assurance to the Wholesale Customers or a concession by San Francisco that the provisions of this subsection violate any rights of the Wholesale Customers.
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D. Notwithstanding the reservation of claims contained in Sections 3.02.C and 8.07, it shall be the responsibility of each Wholesale Customer to limit its purchases of water from San Francisco so as to remain within its Individual Supply Guarantee. San Francisco shall not be liable to any Wholesale Customer or be obligated to supply more water to any Wholesale Customer individually or to the Wholesale Customers collectively than the amount to which it or they are otherwise entitled under this Agreement due to the use by any Wholesale Customer of more water than the amount to which it is entitled under this Agreement.
E. San Francisco shall install such new connections between the Regional Water System and the distribution system of any Wholesale Customer that are necessary to deliver the quantities of water to which the Wholesale Customer is entitled under this Agreement. San Francisco shall have the right to determine the location of such connections, in light of the need to maintain the structural integrity of the Regional Water System and, where applicable, the need to limit peaking directly off of Regional Water System pipelines by a Wholesale Customer's individual retail customers, the need to ensure that a Wholesale Customer's individual retail customers have access to alternative sources of water in the event of a reduction in San Francisco's ability to provide them with water, and other factors which may affect the desirability or undesirability of a particular location. San Francisco's decisions regarding the location of new connections and the location, size and type of any new meters shall not be reviewable by a court except for an abuse of discretion or failure to provide a Wholesale Customer with connections and meters adequate to deliver the quantity of water to which it is entitled under this Agreement.
3.03. Wholesale Customer Service Areas
A. Each of the Individual Water Sales Contracts described in Section 9.01 will contain, as an exhibit, a map of the Wholesale Customer’s service area. A Wholesale Customer may not deliver water furnished to it by San Francisco outside the boundary of its service area without the prior written consent of San Francisco, except for deliveries to another Wholesale Customer on an emergency and temporary basis pursuant to Section 3.07.B.
B. If a Wholesale Customer wishes to expand its service area, it shall request San Francisco's consent to the expansion and provide information reasonably requested by San Francisco about the amount of water projected to be purchased from San Francisco to meet demand within the area proposed to be added to the service area.
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C. San Francisco may refuse a Wholesale Customer's request to expand its service area on any reasonable basis. If San Francisco denies a request by a Wholesale Customer to expand its service area, or fails to act on the request for six months after it has been submitted, the Wholesale Customer may challenge San Francisco's denial or delay in court. Such a challenge may be based on the Wholesale Customers’ claim, reserved in Section 8.07, that San Francisco is obligated under federal or state law to furnish water, included within its Individual Supply Guarantee, to it for delivery outside its then-existing service area and that it is entitled to enlarge its service area to supply water to such customers. San Francisco reserves the right to contest any such claim on any applicable ground. This subsection does not apply to San Jose and Santa Clara, whose maximum service areas are fixed pursuant to Section 9.06.
D. This section will not prevent San Francisco and any Wholesale Customer, other than San Jose and Santa Clara, from agreeing in an Individual Water Sales Contract or an amendment thereto that:
x the Wholesale Customer may expand its service area without subsequent San Francisco approval to a definitive size but no larger, or
x the Wholesale Customer will not expand its service area beyond its present limits without San Francisco approval
and waiving the provisions of this section with respect to any additional expansion.
E. If two or more Wholesale Customers agree to adjust the boundaries of their respective service areas so that one assumes an obligation to serve customers in an area that was previously within the service area of another Wholesale Customer, they may also correspondingly adjust their respective Individual Supply Guarantees. Such adjustments are not subject to the requirements of Section 3.04 and shall require only the consent of San Francisco and the Wholesale Customers involved, so long as the Supply Assurance and the Individual Supply Guarantees of other Wholesale Customers are not affected. Service area boundary adjustments that would result in the expansion of any California Water Service Company service areas are subject to the requirements of Section 9.02.D. Any adjustment of service area boundaries that would result in the supply of water in violation of this Agreement or the Act shall be void.
F. San Francisco acknowledges that it has heretofore consented in writing to deliveries of water by individual Wholesale Customers outside their service area boundaries and
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agrees that nothing in this Agreement is intended to affect such prior authorizations, which remain in full force and effect according to their terms. Such authorizations shall be identified in the Individual Water Sales Contracts.
3.04. Permanent Transfers of Individual Supply Guarantees and Minimum Annual Purchase Quantities
A. A Wholesale Customer that has an Individual Supply Guarantee may transfer a portion of it to one or more other Wholesale Customers, as provided in this section.
B. Transfers of a portion of an Individual Supply Guarantee must be permanent, as opposed to temporary or time-limited. Notwithstanding the previous sentence, a portion of an Individual Supply Guarantee that has been transferred under this section may be included in another transfer under this section at a later date. The minimum quantity that may be transferred is 1/10th of a MGD.
C. Transfers of a portion of a Minimum Annual Purchase Quantity may be included in transfers of a portion of an Individual Supply Guarantee and are subject to the same requirements for Individual Supply Guarantee transfers in this section as well as the following conditions:
1. Transferor of Minimum Annual Purchase Quantity. A Wholesale Customer subject to the minimum annual purchase requirements of Section 3.07.C may transfer both a portion of its Individual Supply Guarantee and a portion of its Minimum Annual Purchase Quantity to one or more Wholesale Customers that have an Individual Supply Guarantee. The process by which such a transfer may be proposed and approved is set forth in subparts D and E of this section. A Wholesale Customer that had a Minimum Annual Purchase Quantity at the start of the Term of this Agreement may not cumulatively transfer, over the course of one or multiple transfers, more than half (50%) of its Minimum Annual Purchase Quantity as first specified in Attachment E at the start of the Term of this Agreement. Wholesale Customers that had a Minimum Annual Purchase Quantity at the start of the Term of this Agreement may not cumulatively transfer, over the course of one or multiple transfers, more than 6 MGD of the total aggregate Minimum Annual Purchase Quantity specified in Attachment E at the start of the Term of this Agreement. A Wholesale Customer that received a Minimum Annual Purchase Quantity through a transfer under this section may cumulatively transfer, over the course of one or multiple transfers, a portion of or all of the Minimum Annual Purchase Quantity it received
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pursuant to this section. The effect of such a transfer will be a reduction in the transferor’s Individual Supply Guarantee, specified in Attachment C, and a reduction in the transferor’s Minimum Annual Purchase Quantity, specified in Attachment E. The SFPUC and BAWSCA will update Attachments C and E to reflect such changes, pursuant to Section 3.04.F. The reduction in the transferor’s permanent Minimum Annual Purchase Quantity shall become effective in the same fiscal year in which the transfer becomes effective.
2. Transferee of Minimum Annual Purchase Quantity. A Wholesale Customer that has an Individual Supply Guarantee may be the recipient, or transferee, of both a portion of Individual Supply Guarantee and a portion of Minimum Annual Purchase Quantity from another Wholesale Customer that has an Individual Supply Guarantee, whether or not the transferee is already subject to the minimum annual purchase requirements of Section 3.07.C.
When such a transfer is approved and effective, the transferee will initially have a revised Individual Supply Guarantee and a Temporary Modified Minimum Annual Purchase Quantity, which will be reflected on Attachments C and E-1, respectively, pursuant to Section 3.04.F. A Temporary Modified Minimum Annual Purchase Quantity will become effective in the same fiscal year in which the transfer becomes effective. The transferee’s Temporary Modified Minimum Annual Purchase Quantity will ultimately be replaced by a permanent Minimum Annual Purchase Quantity, as described in this sub-section, which will be reflected on Attachment E pursuant to Section 3.04.F.
3. Calculation of Temporary Modified Minimum Annual Purchase Quantity.
The Temporary Modified Minimum Annual Purchase Quantity that a transferee receives from a transfer under this sub-section is the sum of (1) the average annual (fiscal year) quantity of water purchased by the transferee from the SFPUC (plus Imputed Sales, if applicable) in the most recent five previous non-drought fiscal years, plus (2) the relevant reduction in the transferor's Minimum Annual Purchase Quantity. For this calculation, the five previous nondrought fiscal years need not be consecutive. Notwithstanding the preceding sentences in this paragraph, if a transferee has an existing Temporary Modified Minimum Annual Purchase Quantity at the time of a new transfer under this sub-section, the transferee’s new Temporary Modified Minimum Annual Purchase Quantity under the new transfer will be the sum of (1) the transferee’s existing Temporary Modified Minimum Annual Purchase Quantity, plus (2) the relevant reduction in the transferor’s Minimum Annual Purchase Quantity. Attachment E-2 contains sample calculations of the Temporary Modified Minimum Annual Purchase Quantity for
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transferees who are subject to, or not yet subject to, the minimum annual purchase requirements of Section 3.07.C.
4. Duration and Expiration of Temporary Modified Minimum Annual Purchase Quantity.
a. Once a transfer under this sub-section is approved and effective, the transferee is required to purchase from the SFPUC its Temporary Modified Minimum Annual Purchase Quantity until the quantity of water delivered annually to the transferee by the SFPUC meets or exceeds the Temporary Modified Minimum Annual Purchase Quantity for three consecutive fiscal years. It may take many years for the quantity of water delivered to meet or exceed this amount. The transferee’s Temporary Modified Minimum Annual Purchase Quantity is subject to waiver by the SFPUC as described in Section 3.07.C. However, even in the event of such a waiver, a fiscal year in which the transferee still purchases from the SFPUC an amount of water that meets or exceeds its Temporary Modified Minimum Annual Purchase Quantity will count as a fiscal year in which the transferee has met or exceeded its Temporary Modified Minimum Annual Purchase Quantity for the purposes of this paragraph. b. Once the quantity of water delivered to the transferee by the SFPUC reaches the milestone described in the preceding paragraph, the transferee will no longer be subject to the Temporary Modified Minimum Annual Purchase Quantity. Instead, the transferee will have a new permanent Minimum Annual Purchase Quantity, which will equal the sum of (1) its previous Minimum Annual Purchase Quantity, if applicable, plus (2) the relevant reduction in the transferor’s Minimum Annual Purchase Quantity. The transferee’s new permanent Minimum Annual Purchase Quantity will be reflected on Attachment E, and its expired Temporary Modified Minimum Annual Purchase Quantity will be removed from Attachment E-1, pursuant to Section 3.04.F. Any other Temporary Modified Minimum Annual Purchase Quantities of the transferee will remain in effect on Attachment E-1 D. Transfers of portions of Individual Supply Guarantees, including transfers of portions of Minimum Annual Purchase Quantities, are subject to approval by the SFPUC.
SFPUC review is limited to determining (1) whether a proposed transfer complies with the Act, and (2) whether the affected facilities in the Regional Water System have sufficient capacity to accommodate delivery of the increased amount of water to the proposed transferee.
E. The participants in a proposed transfer shall provide written notice to the SFPUC and BAWSCA specifying (1) the amount of the Individual Supply Guarantee proposed to be
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transferred, (2) the proposed effective date of the transfer, which shall not be less than 60 days after the notice is submitted to the SFPUC, and (3) the Individual Supply Guarantees of both participants resulting from the transfer. If a proposed transfer includes the transfer of a portion of Minimum Annual Purchase Quantity, then the participants will provide additional written notice specifying (4) the amount of the Minimum Annual Purchase Quantity proposed to be transferred, (5) transferee's Temporary Modified Minimum Annual Purchase Quantity and permanent Minimum Annual Purchase Quantity under the transfer, and (6) the transferor's new Minimum Annual Purchase Quantity under the transfer. The SFPUC may require that the participants in any proposed transfer provide additional information reasonably necessary to evaluate the operational impacts of the proposed transfer and any additional information that will assist the SFPUC in its review of the proposed transfer. The SFPUC will not unreasonably withhold or delay its approval of a proposed transfer; if the SFPUC does not act on the written notice provided by the participants within 60 days, the transfer will be deemed to have been approved. An approved transfer becomes effective on the proposed effective date set forth in the written notice of the proposed transfer provided to the SFPUC and BAWSCA.
F. Within 30 days after the transfer has become effective, both the transferor and the transferee will provide written notice to the SFPUC and BAWSCA. By September 30 of each year during the Term, the SFPUC and BAWSCA will prepare an updated Attachment C, and updated Attachments E and E-1 where applicable, to reflect the effects of transfers occurring during the immediately preceding fiscal year. By September 30 of each year during the Term, the Individual Water Sales Contracts between San Francisco and any Wholesale Customers who are participants in a transfer under this Section will be amended with the written concurrence of San Francisco and those Wholesale Customers to reflect the effects of transfers occurring during the immediately preceding fiscal year, as necessary.
G. Amounts transferred will remain subject to pro rata reduction under the circumstances described in Section 3.02.C and according to the formula set forth in Attachment D.
H. A proposed transfer that does not satisfy the requirements of this section may be presented as an amendment to this Agreement pursuant to Section 2.03.
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3.05. Restrictions on Resale
Each Wholesale Customer agrees that it will not sell any water purchased from San Francisco to a private party for resale by such private party to others in violation of the Act.
Each Wholesale Customer also agrees that it will not sell water purchased from San Francisco to another Wholesale Customer without prior written approval of the SFPUC, except on a temporary and emergency basis as permitted in Section 3.07.B.2. The SFPUC agrees that it will not unreasonably withhold its consent to a request by a Wholesale Customer to deliver water to another Wholesale Customer for resale.
3.06. Conservation; Use of Local Sources; Water Management Charge A. In order to support the continuation and expansion of water conservation programs, water recycling, and development of alternative supplies within the Wholesale Customers’ service areas, the SFPUC will, if requested by BAWSCA, include the Water Management Charge in water bills sent to Wholesale Customers. The SFPUC will deliver all Water Management Charge revenue to BAWSCA monthly and shall deliver an annual accounting of Water Management Charge revenue to BAWSCA within 90 days after the end of each fiscal year. The SFPUC’s obligations to collect and deliver Water Management Charge revenue to BAWSCA under this subsection are conditioned on BAWSCA’s delivery to the SFPUC of an annual report describing the projects and programs on which Water Management Charge funds received from the SFPUC during the previous fiscal year were expended and an estimate of the amount of water savings attributable to conservation programs and of the yield of alternative supplies developed. This report will be due within 180 days after the end of each fiscal year during which Water Management Charge funds were received.
B. The SFPUC will work together with BAWSCA to explore ways to support water conservation programs, recycling projects, and conjunctive use alternatives outside the Wholesale Service Area, in particular projects and programs that have the potential to increase both flows in the lower Tuolumne River (downstream of New Don Pedro Reservoir) and water deliveries to the Regional Water System.
C. Each Wholesale Customer shall take all actions within its legal authority related to water conservation that are necessary to insure that the SFPUC (a) remains eligible for (i) state and federal grants and (ii) access to the Drought Water Bank operated by the California Department of Water Resources, as well as other Drought-related water purchase or transfer
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programs, and (b) complies with future legal requirements imposed on the Regional Water System by the federal government, the State, or any other third party as conditions for receiving funding or water supply.
D. San Francisco and each Wholesale Customer agree that they will diligently apply their best efforts to use both surface water and groundwater sources located within their respective service areas and available recycled water to the maximum feasible extent, taking into account the environmental impacts, the public health effects and the effects on supply reliability of such use, as well as the cost of developing such sources.
3.07. Restrictions on Purchases of Water from Others; Minimum Annual Purchases A. Each Wholesale Customer (except for Alameda County Water District and the cities of Milpitas, Mountain View and Sunnyvale) agrees that it will not contract for, purchase or receive, with or without compensation, directly or indirectly, from any person, corporation, governmental agency or other entity, any water for delivery or use within its service area without the prior written consent of San Francisco.
B. The prohibition in subsection A does not apply to:
1. recycled water;
2. water necessary on an emergency and temporary basis, provided that the Wholesale Customer promptly gives San Francisco notice of the nature of the emergency, the amount of water that has been or is to be purchased, and the expected duration of the emergency; or
3. water in excess of a Wholesale Customer’s Individual Supply Guarantee.
C. Alameda County Water District and the cities of Milpitas, Mountain View and Sunnyvale may purchase water from sources other than San Francisco, provided that San Francisco shall require that each purchase a minimum annual quantity of water from San Francisco. These Minimum Annual Purchase Quantities are set out in Attachment E and shall also be included in the Individual Water Sales Contracts between San Francisco and each of these four Wholesale Customers. Pursuant to Section 3.04, certain Wholesale Customers may also be required to purchase Temporary Modified Minimum Annual Purchase Quantities, set out in Attachment E-1, from San Francisco. Attachment E will be updated pursuant to Section 3.04 to reflect any reduction in existing Minimum Annual Purchase Quantities and any addition of
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new Minimum Annual Purchase Quantities when Temporary Modified Minimum Annual Purchase Quantities expire and are removed from Attachment E-1; Individual Water Sales Contracts between San Francisco and any Wholesale Customers who are participants in a transfer under Section 3.04 will similarly be amended, as necessary. After the end of each fiscal year, the SFPUC will send a written notice to each Wholesale Customer that is subject to the minimum annual purchase requirements of this section with a copy to BAWSCA. The notice will include: (1) the quantity of water delivered to the Wholesale Customer during the previous fiscal year; (2) whether or not the Wholesale Customer met its minimum annual purchase requirement under this section; (3) any Imputed Sales charged to the Wholesale Customer; and (4) the status of any Temporary Modified Minimum Annual Purchase Quantity of the Wholesale Customer, if applicable. The minimum annual purchase requirements set out in Attachments E and E-1 will be waived during a Drought or other period of water shortage if the water San Francisco makes available to these Wholesale Customers is less than its Minimum Annual Purchase Quantity, and may be waived during a state of emergency declared by the Governor of California that impacts water supply use or deliveries from the Regional Water System.
3.08. Water Quality
A. San Francisco shall deliver treated water to Wholesale Customers (except Coastside County Water District, which receives untreated water from Crystal Springs and Pilarcitos Reservoirs) that complies with primary maximum contaminant level and treatment technique standards at the regulatory entry points designated in the San Francisco Regional Water System Domestic Water Supply Permit (currently Permit No. 02-04-04P3810001) issued by the California Department of Public Health (CDPH).
B. San Francisco will provide notice to the Wholesale Customers in accordance with the Water Quality Notification and Communications Plan (2019 Update of 2017 Plan, Rev. 6), attached hereto as Attachment G. San Francisco will regularly update its plan in consultation with the Wholesale Customers and the CDPH. The next update will be completed one year after the Effective Date and include expanded coverage of secondary maximum contaminant level exceedances and water quality communication triggers. The plan will note that the Wholesale Customers will receive the same notification no later than the San Francisco water system (currently Permit No. 02-04-01P3810011) except for distribution-related issues.
C. San Francisco and the Wholesale Customers will establish a Water Quality Committee. The Water Quality Committee will meet at least quarterly to collaboratively address
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water quality issues, such as Water Quality Notification and Communications Plan updates, regulatory issues, and water quality planning studies/ applied research. San Francisco and each Wholesale Customer will designate a representative to serve on the committee. There will be a Chair and Vice Chair position for the Water Quality Committee. The Chair and Vice Chair positions will be held by San Francisco and the Wholesale Customers and rotate between them on an annual basis.
3.09. Completion of WSIP
San Francisco will complete construction of the physical facilities in the WSIP by December 30, 2021. The SFPUC agrees to provide for full public review and comment by local and state interests of any proposed changes that delay previously adopted project completion dates or that delete projects. The SFPUC shall meet and consult with BAWSCA before proposing to the Commission any changes in the scope of WSIP projects which reduce their capacity or ability to achieve adopted Level of Service Goals and Objectives. The SFPUC retains discretion to determine whether to approve the physical facilities in the WSIP until after it completes the CEQA process as set forth in Section 4.07.
3.10. Regional Water System Repair, Maintenance and Operation A. San Francisco will keep the Regional Water System in good working order and repair consistent with prudent utility practice.
B. San Francisco will submit reports to its Retail and Wholesale Customers on the "State of the Regional Water System," including reports on completed and planned maintenance, repair or replacement projects or programs, by September of every evennumbered year, with reports to start in September 2010.
C. San Francisco will cooperate with any audit of the SFPUC's asset management practices that may be initiated and financed by BAWSCA or the Wholesale Customers.
BAWSCA may contract with third parties to conduct the audits. San Francisco will consider the findings and recommendations of such audits and will provide a written response indicating agreement with the recommendations, or disagreement with particular recommendations and the reasons why, within 90 calendar days after receipt.
D. San Francisco will continue to operate its reservoirs in a manner that assigns higher priority to the delivery of water to the Bay Area and the environment than to the
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generation of electric power. The SFPUC, as the Regional Water System operator, is solely responsible for making day-to-day operational decisions.
3.11. Shortages
A. Localized Water Reductions. Notwithstanding San Francisco's obligations to deliver the Supply Assurance to the Wholesale Customers collectively and the Individual Supply Guarantees to Wholesale Customers individually, San Francisco may reduce the amount of water available or interrupt water deliveries to specific geographical areas within the Regional Water System service area to the extent that such reductions are necessary due to Emergencies, or in order to install, repair, rehabilitate, replace, investigate or inspect equipment in, or perform other maintenance work on, the Regional Water System. Such reductions or interruptions may be imposed by San Francisco without corresponding reductions or interruptions in the amount of water available to SFPUC water users outside the specific geographical area where reductions or interruptions are necessary, if the system's ability to supply water outside the specific geographical area has not been impaired. In the event of such a reduction or interruption, San Francisco will restore the supply of water to the specific geographical area as soon as is possible. Except in cases of Emergencies (during which oral notice shall be sufficient), San Francisco will give the affected Wholesale Customer(s) reasonable written notice of such localized reductions or interruptions, the reasons therefor, and the probable duration thereof.
B. System-Wide Shortages and SFPUC Response to Regional Emergencies.
Following a major system emergency event, the SFPUC will work closely with its Wholesale Customers to monitor customer demand, including the demand source. In the event that any individual Wholesale Service Area or Retail Service Area customer’s uncontrolled distribution system leaks could result in major water waste and endanger the supply provided by the Regional Water System as a whole, flow through some customer connections may need to be temporarily reduced or terminated. SFPUC will work closely with customers to assess the nature of the demand (e.g. fire-fighting versus leakage), so that public health and safety protection can be given top priority.
1. All emergencies that require use of non-potable source water will require use of chlorine, or other suitable disinfectant, if feasible.
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2. San Francisco will use its best efforts to meet the seismic reliability and delivery reliability Level of Service Goals and Objectives adopted by the Commission in conjunction with the WSIP. San Francisco will distribute water on an equitable basis throughout the Regional Water System service area following a regional Emergency, subject to physical limitations caused by damage to the Regional Water System.
3. San Francisco's response to Emergencies will be guided by the thencurrent version of the ERRP. The SFPUC shall periodically review, and the Commission may amend, the ERRP to ensure that it remains an up-to-date and effective management tool.
4. The SFPUC will give the Wholesale Customers notice of any proposal to amend the ERRP in a manner that would affect them. The notice will be delivered at least thirty days in advance of the date on which the proposal is to be considered by the Commission and will be accompanied by the text of the proposed amendment.
C. Shortages Caused by Drought; Acquisition of Dry Year Supplies.
Notwithstanding San Francisco's obligations to deliver the Supply Assurance to the Wholesale Customers collectively and the Individual Supply Guarantees to Wholesale Customers individually, San Francisco may reduce the amount of water available to the Wholesale Customers in response to Drought.
1. The Tier 1 Shortage Plan (Attachment H) will continue to be used to allocate water from the Regional Water System between Retail and Wholesale Customers during system-wide shortages of 20% or less.
2. San Francisco and the Wholesale Customers may negotiate in good faith revisions to the Tier 1 Shortage Plan to adjust for and accommodate anticipated changes due to demand hardening in the SFPUC's Wholesale and Retail Service Areas. Until agreement is reached, the current Tier 1 Shortage Plan will remain in effect.
3. 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. If BAWSCA or all Wholesale Customers do not provide the SFPUC with Tier 2 Allocations, then the SFPUC may make a final allocation decision after first meeting and discussing allocations with BAWSCA and the Wholesale Customers. For Regional Water System shortages in excess of 20%, San Francisco shall (a) follow the Tier 1 Shortage Plan allocations up to the 20% reduction, (b) meet and discuss how to implement incremental
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reductions above 20% with the Wholesale Customers, and (c) make a final determination of allocations above the 20% reduction. After the SFPUC has made the final allocation decision, the Wholesale Customers shall be free to challenge the allocation on any applicable legal or equitable basis.
4. San Francisco will use its best efforts to identify potential sources of dry year water supplies and establish the contractual and other means to access and deliver those supplies in sufficient quantity to meet a goal of not more than 20 percent system-wide shortage in any year of the design drought.
5. San Francisco will cooperate with BAWSCA to improve water supply reliability. As an example of such cooperation, San Francisco may invite a representative of BAWSCA to attend and participate in meetings with third parties for development of dry year water supplies. If San Francisco does not invite a BAWSCA representative to attend a specific scheduled meeting, it will promptly (within 30 days of any such meeting) provide BAWSCA with a written or oral report on the meeting, including any decisions reached at it, as well as information about planned subsequent meetings. Progress in securing dry year water supplies will be reported to the SFPUC and the BAWSCA board of directors during the first quarter of each calendar year.
3.12. Wheeling of Water from Outside SFPUC System
Subject to the Wheeling Statute, the SFPUC will not deny use of Regional Water System unused capacity for wheeling when such capacity is available for wheeling purposes during periods when the SFPUC has declared a water shortage emergency under Water Code Section 350 if the following conditions are met:
A. The transferor pays reasonable charges incurred by the SFPUC as a result of the wheeling, including capital, operation, maintenance, administrative and replacement costs (as such are defined in the Wheeling Statute).
B. Wheeled water that is stored in the Regional Water System spills first.
C. Wheeled water will not unreasonably: (1) impact fish and wildlife resources in Regional Water System reservoirs; (2) diminish the quality of water delivered for consumptive uses; or (3) increase the risk of exotic species impairing Regional Water System operations.
The transferor may at its own expense provide for treatment to mitigate these effects.
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D. Priority will be given to wheeling by Wholesale Customers or BAWSCA over arrangements for third-party public entities.
3.13. Limits on New Customers
A. New Wholesale Customers Prior to December 31, 2028. Until December 31, 2028, San Francisco will not enter into contracts to supply water to any entity other than a Wholesale Customer (whether permanent or temporary, firm or interruptible) unless:
1. It completes any necessary environmental review under CEQA of the proposed new wholesale water service obligations as provided in Section 4.07;
2. It concurrently completes any necessary environmental review under CEQA as provided in Section 4.07 and commits to make both San Jose and Santa Clara permanent customers with Individual Supply Guarantees equal to at least 9 MGD; and
3. This Agreement is amended to incorporate any commitments to proposed new wholesale customers and to San Jose and Santa Clara, and to address the effects, if any, of the new customer(s) on water supply reliability, water quality and cost to existing customers of the Regional Water System.
B. New Wholesale Customers After December 31, 2028. As of January 1, 2029, San Francisco will not enter into contracts to supply water to any entity other than a Wholesale Customer (whether permanent or temporary, firm or interruptible) unless:
1. It completes any necessary environmental review under CEQA of the proposed new wholesale water service obligations as provided in Section 4.07;
2. It concurrently completes any necessary environmental review under CEQA as provided in Section 4.07 and commits to make both San Jose and Santa Clara permanent customers with Individual Supply Guarantees equal to at least 9 MGD;
3. Doing so increases the reliability of the Regional Water System; and
4. This Agreement is concurrently amended (a) to reflect that increased reliability by means of an increased commitment by San Francisco to deliver water during Droughts and (b) to address the effects, if any, of the new customer(s) on water supply, water quality and cost to existing customers of the Regional Water System.
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C. New Retail Customers. San Francisco may enter into new retail water service obligations outside of the City and County of San Francisco:
1. Only in Alameda, San Mateo, Santa Clara, San Joaquin and Tuolumne Counties;
2. That are within or immediately adjacent to areas in which it currently serves other Retail Customers; and
3. Until the aggregate additional demand represented by the new retail customers reaches 0.5 MGD.
The limitations on serving new Retail Customers described in this subsection do not apply to historical obligations to supply water that may be contained in prior agreements between the SFPUC or its predecessor the Spring Valley Water Company, and individual users or property owners located adjacent to Regional Water System transmission pipelines.
D. Water Exchanges and Cost Sharing Agreements with Other Water Suppliers. Subject to completion of necessary environmental review under CEQA, San Francisco may at any time enter into water exchanges or cost sharing agreements with other water suppliers to enhance dry year or normal year water deliveries, provided that San Francisco cannot incur new water service obligations to such other water suppliers unless the requirements for taking on new wholesale customers in subsections A and B above are met.
3.14. Measurement of Water
A. The parties recognize that continuous and accurate measurement of water deliveries to and from the Regional Water System and maintenance of complete and accurate records of those measurements is necessary (1) for the costs of the Regional Water System to be allocated in accordance with this Agreement, (2) for implementation of other provisions of this Agreement, and (3) for effective operation and maintenance of a water system serving a large urbanized region.
B. It is the responsibility of the SFPUC to obtain and record these measurements.
To do so, the SFPUC shall install, maintain and operate measuring and recording equipment at the following locations: (1) inputs to the Regional Water System from all water sources (“System Input Meters”), (2) internal flow meters to support operation of the Regional Water System (“InLine Meters”), (3) deliveries to the City at the San Francisco-San Mateo County line (“County10.b June 08, 2026 Packet Pg. 2008
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Line Meters”) and to three reservoirs in San Francisco (“In-City Terminal Reservoir Meters”), (4) deliveries to SFPUC Retail Customers located outside the boundaries of the City, and (5) deliveries to the Wholesale Customers, as described and illustrated in Attachment J.
C. The SFPUC shall inspect, test, service, and calibrate the measuring and recording equipment installed at the locations described in subsection B and will repair or replace them when necessary, in order to ensure that their accuracy is consistent with specifications provided in Attachment J.
D. The SFPUC shall continue to contract with a qualified independent metering consultant to perform periodic inspection, testing, servicing and calibration of the County-Line Meters, the In-City Terminal Reservoir Meters, and the System Input and In-Line Meters described in Attachment J, as well as the portion of the SFPUC’s Supervisory Control and Data Acquisition (SCADA) system that utilizes the flow signals produced by that measuring and recording equipment. The method, schedule and frequency for calibration and maintenance of the County-Line Meters and the In-City Terminal Reservoir Meters are specified in Attachment J. The SFPUC shall provide copies of the metering consultant's reports to BAWSCA.
E. System Input Meters measure water deliveries into the Regional Water System from sources such as Hetch Hetchy and the SFPUC’s water treatment plants. System Input Meters also measure deliveries from the Regional Water System to outside sources or from such sources to the Regional Water System through interties with the Santa Clara Valley Water District and the East Bay Municipal Utility District. In-Line Meters measure internal system flows and are located on the Bay Division Pipelines and other main transmission pipelines. These meters are collectively referred to as the “System Input and In-line Meters.” Similar to the County-Line Meters, the System Input and In-Line Meters have secondary metering equipment, such as differential pressure transmitters and flow recorders. The System Input and In-Line Meters, and all associated secondary metering equipment, shall be calibrated and maintained according to the method, schedule, and frequency specified in the Procedures Manual described in subsection G, below.
F. The locations of the smaller and more numerous meters described in subsection B (4) and (5) are not illustrated in Attachment J; however, they are also critical in the determination of cost allocations, and accordingly require continued maintenance and
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calibration. It is the responsibility of the SFPUC to maintain the accuracy of these meters and their secondary metering equipment.
G. The SFPUC will prepare a Procedures Manual which will describe in detail the procedures for periodic inspection, testing, servicing and calibration of the measuring and recording equipment described in subsection B. Once the Procedures Manual is completed, the SFPUC and BAWSCA may agree that it should supersede some or all of the requirements in Attachment J regarding the County-Line and the In-City Terminal Reservoir Meters. Unless and until such an agreement is reached and documented, however, the requirements in Attachment J, Section D will continue in force as minimum standards for meter maintenance and calibration of the County-Line and In-City Terminal Reservoir Meters (subject to modification under the circumstances described in Attachment J, Section A.4).
H. If BAWSCA and the SFPUC are unable to agree on the water use calculations required by Attachment J for a particular year, the Wholesale Customers may file a demand for arbitration challenging the SFPUC's determination of the Wholesale Revenue Requirement for that year on the basis of its reliance on disputed water use calculations. Such a challenge must be brought in the manner and within the time specified in Section 8.01.
3.15. New Sources of Water Supply to Maintain Supply Assurance A. Urgent Reductions of Existing Surface Water Supplies. Sudden and unanticipated events may require San Francisco to act promptly to protect the health, safety and economic well-being of its Retail and Wholesale Customers. Such sudden events include, but are not limited to drought, earthquakes, terrorist acts, catastrophic failures of facilities owned and operated by San Francisco, and other natural or man-made events. If such events diminish San Francisco’s ability to maintain the Supply Assurance, San Francisco may increase the Wholesale Revenue Requirement to pay for planning, evaluation and implementation of replacement sources of supply when such needs arise and without the prior approval of the Wholesale Customers. San Francisco will keep the Wholesale Customers informed of actions being taken under this subsection, progress made, and contingency actions the Wholesale Customers may need to consider taking. To the extent appropriate and applicable, San Francisco will act in accordance with Section 3.11 and the ERRP. Nothing in this subsection limits San Francisco’s obligations under Section 3.11 to pursue additional sources of supply to augment supplies available during drought.
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B. Non-Urgent Reductions of Existing Surface Water Supplies. Climate change, regulatory actions and other events may impact San Francisco’s ability to maintain the Supply Assurance from its existing surface water supplies, but on timescales long enough to permit San Francisco to collaborate with its Wholesale Customers on how best to address possible impacts to water supply. If such events diminish San Francisco’s ability to maintain the Supply Assurance, San Francisco may increase the Wholesale Revenue Requirement to pay for planning, evaluation and implementation of replacement sources of supply when such needs arise and without the prior approval of the Wholesale Customers. San Francisco will keep the Wholesale Customers informed of actions being taken under this subsection, progress made, and contingency actions the Wholesale Customers may need to consider taking. San Francisco will solicit input and recommendations from BAWSCA and the Wholesale Customers, and take those recommendations into consideration. Prior to Commission approval of plans or taking other actions that would impact the Wholesale Revenue Requirement, San Francisco will hold a public hearing to receive written and oral comments. Nothing in this subsection modifies San Francisco’s obligation to maintain the ability to provide the Supply Assurance under this Agreement.
3.16. New Sources of Water Supply to Increase Supply Assurance A. Surface Water Supplies From Existing Watersheds After 2018. The Commission action in SFPUC Resolution Number 08-0200, adopted October 30, 2008 requires certain decisions by San Francisco regarding whether to supply more than 265 MGD from its watersheds following 2018. Such decisions are to be made by December 31, 2018, subject to the exercise of San Francisco's retained CEQA discretion in Section 4.07. San Francisco's future decisions may include an offer to increase the Supply Assurance at the request of some or all of its Wholesale Customers. Costs associated with providing additional water from its existing water supplies in San Mateo, Santa Clara, Alameda, Tuolumne, and Stanislaus Counties shall be allocated to Wholesale and Retail Customers as described in Article 5.
B. New Water Supplies. If San Francisco seeks to develop additional water supplies from new sources to increase the Supply Assurance available to Wholesale Customers, studies and resulting water supply projects will be conducted jointly with BAWSCA under separate agreement(s) specifying the purpose of the projects, the anticipated regional benefits and how costs of studies and implementation will be allocated and charged. Nothing in this Agreement shall serve as precedent for the allocation of such new supply capital costs
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between Retail and Wholesale Customers or associated operational expenses, which shall only occur following approval of both parties and amendment of this Agreement, if necessary, under Section 2.03.
3.17. Westside Basin Groundwater Storage and Recovery Project In August 2014, the SFPUC approved a WSIP project called the Groundwater Storage and Recovery Project (“Project”), which authorized the SFPUC to enter into an agreement governing the operation of the Project with the Participating Pumpers entitled “Agreement for Groundwater Storage and Recovery from the Southern Portion of the Westside Groundwater Basin by and among the San Francisco Public Utilities Commission, the City of Daly City, the City of San Bruno, and California Water Service Company” (“Project Operating Agreement”), which became effective on December 16, 2014. The Project produces Regional benefits for all customers of the Regional Water System by making use of available groundwater storage capacity in the Southern portion of the Westside Basin through the supply of additional surface water (“In Lieu Water”) to the Participating Pumpers from the Regional Water System, in exchange for a corresponding reduction in groundwater pumping at existing wells owned by the Participating Pumpers. The new groundwater supply that accrues to storage as a result of delivery of In Lieu Water will be recovered from the SFPUC Storage Account during water shortages using new Regional Project Facilities or Shared Facilities operated by the Participating Pumpers and the SFPUC. Project mitigation capital costs and annual Project operations and maintenance expenses and water supplies shall be allocated as follows:
A. All In Lieu Water delivered to the Participating Pumpers shall be (1) temporary and interruptible in nature and (2) at the sole discretion of the SFPUC based on the total volume of water available to the Regional Water System.
B. All In Lieu Water delivered to the Participating Pumpers shall be considered a delivery of water to storage and shall not be construed to affect or increase the Individual Supply Guarantees of these Wholesale Customers or to otherwise entitle them to any claim of water in excess of their Individual Supply Guarantees.
C. In the event that it is necessary to reduce the Participating Pumpers’ aggregate designated quantity of groundwater production allocation pursuant to Section 4.7 of the Project Operating Agreement, the SFPUC may supply an annual maximum of up to 500 acre feet of Participating Pumper Replacement Water from the Regional Water System at a price
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comparable to the Participating Pumpers’ then-current groundwater cost, as may be adjusted annually as provided for in Section 4.7 of the Project Operating Agreement. Each of the Participating Pumpers may elect to take delivery of its share of Participating Pumper Replacement Water either as interruptible surface water deliveries from the Regional Water System or as a transfer of storage credits from the SFPUC Storage Account. All revenue received from such water sales or transfers shall be considered revenue related to the sale of water and allocated between Retail Customers and Wholesale Customers on the basis of Proportional Water Use. All volumes of Participating Pumper Replacement Water delivered shall not be construed to affect or increase the Individual Supply Guarantees of these Wholesale Customers or to otherwise entitle them to any claim of water in excess of their Individual Supply Guarantees.
D. Any operation and maintenance expenses incurred by the Participating Pumpers and the SFPUC that are related to the operation of Project Facilities and Shared Facilities for Project purposes shall be included as Regional pumping expenses under Section 5.05.B of this Agreement and included as part of the Wholesale Revenue Requirement. For rate setting purposes, estimated Project operation and maintenance expenses shall be used as set forth in Section 6.01 of this Agreement. Operation and maintenance expenses associated with the Participating Pumpers' Existing Facilities that do not provide Regional benefits shall not be included in the Wholesale Revenue Requirement. On a case-by-case basis, the SFPUC may include operation and maintenance expenses associated operation of the Participating Pumpers’ Existing Facilities in the Wholesale Revenue Requirement provided that such expenses (1) are solely attributable to Project operations for a Regional benefit and (2) are not caused by the Participating Pumper's failure to operate and maintain its existing wells in a reasonable and prudent manner consistent with water utility industry standards. The SFPUC shall provide the Wholesale Customers with copies of Project Operation and Maintenance Expenses documentation provided by the Participating Pumpers under Section 9.2 of the Project Operating Agreement.
E. The Project Mitigation, Monitoring and Reporting Program (“MMRP”) adopted by the SFPUC included mitigation measure HY-6 to prevent well interference impacts to the Irrigation Well Owners. In mitigation measure HY-6, the SFPUC agreed to provide standby supplies of Irrigation Well Owner Replacement Water from the Regional Water System, to alter Project operations, and implement other actions (e.g., well replacement) to avoid well interference impacts that require the consent of the Irrigation Well Owners. The SFPUC’s
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Project mitigation and other obligations to the Irrigation Well Owners are memorialized in substantially identical “Groundwater Well Monitoring and Mitigation Agreements” with one or more of the Irrigation Well Owners. For purposes of this Agreement, water supplies, and the capital costs and operations and maintenance expenses associated with providing Irrigation Well Owner Replacement Water and implementing other mitigation actions identified in the Project MMRP, shall be allocated as follows:
1. Irrigation Well Owner Replacement Water shall be limited to a cumulative maximum of 1.76 mgd and shall be delivered only in volumes necessary for mitigating well interference impacts as provided in the Project MMRP. The supply of Irrigation Well Owner Replacement Water by the SFPUC shall not be considered a new water supply commitment to Retail Customers or Wholesale Customers under Section 3.13 of this Agreement. The annual volume of Irrigation Well Owner Replacement Water supplied shall be metered and allocated as water from the Regional Water System during shortages between Retail Customers and Wholesale Customers in proportion to and consistent with the provisions of the Shortage Allocation Plan. All revenue received from Irrigation Well Owners for metered deliveries of Irrigation Well Owner Replacement Water shall be considered revenue related to the sale of water and allocated between Retail Customers and Wholesale Customers on the basis of Proportional Water Use.
2. All Project capital costs incurred by the SFPUC in complying with the mitigation measures in the Project MMRP shall be considered Regional capital costs under Section 5.04 of this Agreement.
3. Operations and maintenance expenses incurred by the SFPUC in maintaining Project mitigation assets described in the Project MMRP shall be considered Regional transmission and distribution expenses under Section 5.05.D of this Agreement. Well pumping expenses that are required to be paid by the SFPUC in the agreements with the Irrigation Well Owners shall be considered Regional pumping expenses under Section 5.05.B of this Agreement.
4. Any wheeling charges imposed by California Water Service Company for delivery of Irrigation Well Owner Replacement Water shall be considered Regional transmission and distribution expenses under Section 5.05.D of this Agreement.
F. The SFPUC will audit (1) operation and maintenance expenses submitted by the Participating Pumpers, and (2) well pumping expenses submitted by the Irrigation Well Owners,
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for reimbursement to confirm that such costs were incurred, respectively, as a result of (1) operating Project Facilities and Shared Facilities for a Regional benefit and (2) complying with mitigation obligations in the Project MMRP. Costs associated with the use of Project Facilities or Shared Facilities for Direct Retail or Direct Wholesale purposes, or that do not otherwise provide Regional benefits, shall not be included in the Wholesale Revenue Requirement. The SFPUC is responsible for resolving disputes with the Participating Pumpers and Irrigation Well Owners concerning expense allocations. Project expense documentation, including documentation of negotiation and settlement of disputed costs, will be available for review during the Compliance Audit described in Section 7.04 of this Agreement. The Wholesale Customers may dispute the SFPUC’s resolution of expense allocations through the arbitration provisions in Section 8.01 of this Agreement.
G. The SFPUC may direct the Participating Pumpers to recover water from the SFPUC Storage Account for any type of shortage referenced in Section 3.11 of this Agreement.
Water recovered from the SFPUC Storage Account using Project Facilities and Shared Facilities may be used for (1) the benefit of all Regional Water System customers; (2) Retail Customers; or (3) one or more of the Participating Pumpers. The Wholesale Revenue Requirement shall only include operation and maintenance expenses incurred due to the operation of Project Facilities and Shared Facilities for Regional benefits, including expenses incurred due to compliance with mitigation measures in the Project MMRP.
H. All water recovered during shortages caused by drought from the SFPUC Storage Account for Regional benefit, by the Participating Pumpers and by the SFPUC for delivery to Retail and Wholesale Customers, shall be used to free up a comparable volume of surface water from the Regional Water System for allocation in accordance with the Tier 1 Shortage Plan.
I. If the Project is terminated for any reason, including breach of the Project Operating Agreement by one or more of the Participating Pumpers or the SFPUC, a force majeure event as specifically defined by the Project Operating Agreement, or due to regulatory action or legal action, then:
1. Any water remaining in the SFPUC Storage Account shall be used for the benefit of all customers of the Regional Water System;
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2. Outstanding eligible operation and maintenance expenses, including costs incurred during recovery of remaining stored water, will be allocated as provided in this Section 3.17 of this Agreement; and
3. If Project Facilities are no longer capable of being used for a Regional benefit, the Wholesale Customers will be credited with their share of proceeds from disposition of Project Facilities or reimbursed their share of such capital costs for any Project Facilities which are retained by the SFPUC for Direct Retail benefit and not used for the benefit of the Wholesale Customers, on the basis of (a) original cost less depreciation and outstanding related Indebtedness or (b) original cost less accumulated depreciation for revenue funded Project Facilities.
J. In the event that a Participating Pumper establishes the occurrence of a force majeure event as defined in the Project Operating Agreement, the SFPUC may enter into negotiations with the Participating Pumper to take over the operation of the portion of any Shared Facilities used for Project purposes for continued Regional use. If the SFPUC cannot reach agreement regarding the continued use of Shared Facilities for ongoing Regional benefit, the Participating Pumper shall reimburse the SFPUC and the Wholesale Customers for their respective shares of previously incurred Project capital costs used to upgrade the Shared Facilities on the basis of (a) original cost less depreciation and outstanding related Indebtedness or (b) original cost less accumulated depreciation for revenue funded Shared Facilities. In the event that the SFPUC seeks to take over the operation of Shared Facilities for Direct Retail use, or one or more Wholesale Customers seeks to negotiate with a Participating Pumper to take over the operation of Shared Facilities for individual use or Direct Wholesale use, the party or parties benefiting from such transfer of Shared Facilities shall reimburse the other parties to this Agreement with their respective shares of previously incurred Project capital costs on the basis described in the previous sentence, or as the parties may otherwise agree.
3.18. Water Supply Agreement Amendment Required.
San Francisco may not change the existing condition of the Hetch Hetchy Reservoir by:
1. Abandoning or decommissioning O'Shaughnessy Dam; or
2. Draining Hetch Hetchy Reservoir, except for purposes of (i) repair, rehabilitation, maintenance, improvement, or reconstruction of O'Shaughnessy Dam or appurtenances, (ii) supplying water to the Bay
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Area during drought, or (iii) meeting water release requirements under the Raker Act, or federal or state law,
unless the parties enter into an amendment to the Water Supply Agreement, in full force and effect, adopted in accordance with Section 2.03.
The amendment shall state, or restate, as the case may be:
A. The level of service goals for seismic reliability and delivery reliability adopted by the Commission in conjunction with such proposed changes to the Regional Water System, provided such goals are at least as protective of the Wholesale Customers as the Level of Service Goals and Objectives;
B. The level of water quality to be delivered, which is currently provided for in Section 3.08, and
C. The specific cost allocation procedures, written as an amendment to Article 5, which apply to (1) the abandonment or decommissioning of O'Shaughnessy Dam, or (2) the draining of Hetch Hetchy Reservoir, and (3) the development, operation and maintenance of New Regional Assets that may be required to replace water supplied by Hetch Hetchy Reservoir and delivered to the Bay Area.
In the event that the parties are not able to agree upon and approve an amendment to the Water Supply Agreement as set forth above, San Francisco may not abandon or decommission O'Shaughnessy Dam or drain Hetch Hetchy Reservoir.
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Article 4. Implementation of Interim Supply Limitation.
4.01. Interim Supply Limitation Imposed by SFPUC
In adopting the WSIP in Res. No. 08-0200, the Commission included full implementation of all proposed WSIP capital improvement projects to achieve Level of Service Goals and Objectives relating to public health, seismic safety, and delivery reliability, but decided to adopt a water supply element that includes the Interim Supply Limitation. This article describes how the parties will implement the Interim Supply Limitation imposed by the SFPUC between the Effective Date and December 31, 2018, and how the SFPUC will conduct water supply planning after December 31, 2018.
4.02. Retail and Wholesale Customer Allocations Under Interim Supply Limitation The Interim Supply Limitation is allocated as follows between Retail and Wholesale Customers:
Retail Customers' allocation: 81 MGD
Wholesale Customers' allocation: 184 MGD
The Wholesale Customers' collective allocation of 184 MGD under the Interim Supply Limitation includes the demand of the cities of San Jose and Santa Clara, whose demand is not included in the Supply Assurance, as provided in Section 3.02.B. By December 31st, 2010, the Commission will establish each Wholesale Customer's Interim Supply Allocation at a public meeting.
4.03. Transfers of Interim Supply Allocations
A. Any Wholesale Customer, including Hayward, may transfer a portion of its Interim Supply Allocation to one or more other Wholesale Customers, as provided in this section. All Wholesale Customers are also eligible transferees, including California Water Service Company up to its Individual Supply Guarantee.
B. Transfers of a portion of an Interim Supply Allocation must be prospective. The duration of a transfer cannot be less than the balance of the fiscal year. The minimum quantity that may be transferred is 1/10th of a MGD.
C. Transfers of portions of Interim Supply Allocations are subject to approval by the SFPUC. SFPUC review is limited to determining (1) whether a proposed transfer complies with
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the Act, and (2) whether the affected facilities in the Regional Water System have sufficient capacity to accommodate delivery of the increased amount of water to the proposed transferee.
D. The participants in a proposed transfer shall provide notice to the SFPUC specifying the amount of the Interim Supply Allocation proposed to be transferred and the proposed effective date of the transfer, which shall not be less than 60 days after the notice is submitted to the SFPUC. The SFPUC may require additional information reasonably necessary to evaluate the operational impacts of the transfer. The SFPUC will not unreasonably withhold or delay its approval; if the SFPUC does not act on the notice within 60 days, the transfer will be deemed to have been approved.
E. Within 30 days after the transfer has become effective, both the transferor and the transferee will provide written notice to the SFPUC and BAWSCA.
F. Transfers of Interim Supply Allocations shall continue in effect until the earlier of (1) delivery of written notice to the SFPUC by the transfer participants that the transfer has been rescinded or (2) December 31, 2018.
4.04. Environmental Enhancement Surcharge
A. Establishment of Environmental Enhancement Surcharge. Beginning with wholesale water rates for fiscal year 2011-2012, and continuing for the duration of the Interim Supply Limitation, the Commission will establish the Environmental Enhancement Surcharge concurrently with the budget-coordinated rate process set forth in Article 6 of this Agreement.
The monetary amount of the Environmental Enhancement Surcharge per volume of water, such as dollars per acre-foot, will be equivalent for Retail Customer use in excess of 81 MGD and Wholesale Customer use in excess of 184 MGD. The Environmental Enhancement Surcharge will be simple to calculate so that Wholesale Customers can estimate potential surcharges for budgeting purposes and establish retail rates within their service areas.
B. Application of Environmental Enhancement Surcharge. Beginning in fiscal year 2011-12, the Environmental Enhancement Surcharge will be levied only if and when combined Retail Customer and Wholesale Customer purchases exceed the Interim Supply Limitation of 265 MGD and if the fund described in subsection D below has been established by the San Francisco Board of Supervisors. In that event, the Environmental Enhancement Surcharge will apply to Retail Customers for use in excess of 81 MGD and to individual
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Wholesale Customers for use in excess of their Interim Supply Allocations established by the Commission pursuant to Section 4.02.
1. Environmental Enhancement Surcharges related to the Retail Customers’ use in excess of their 81 MGD Retail Customer Allocation will be paid by the SFPUC, and no portion of such surcharges may be allocated to Wholesale Customers. The method of recovering the Environmental Enhancement Surcharges imposed upon Retail Customers shall be within the sole discretion of the SFPUC.
2. Environmental Enhancement Surcharges related to the individual Wholesale Customers’ use in excess of their respective Interim Supply Allocations will be paid to the SFPUC by individual Wholesale Customers.
C. Collection of Environmental Enhancement Surcharge. Notwithstanding the budget-coordinated rate setting process contemplated in Article 6 of this Agreement, the Environmental Enhancement Surcharge for any given year will be determined retrospectively based on actual annual usage during the fiscal year in excess of the Interim Supply Allocation and paid in equal monthly installments over the remainder of the immediately following fiscal year.
D. Establishment of Fund for Environmental Enhancement Surcharge Proceeds. Environmental Enhancement Surcharges paid by the SFPUC and by Wholesale Customers will be placed into a restricted reserve fund. The SFPUC will request the San Francisco Board of Supervisors to establish this fund by ordinance and, if adopted, the fund will be subject to the following restrictions:
1. Interest earnings will stay in the reserve fund.
2. The reserve fund shall (a) be subject to automatic appropriation; (b) require unexpended and unencumbered fund balances to be carried forward from year to year; and (c) not be transferred to the San Francisco General Fund.
3. The reserve fund may be used only for specific environmental restoration and enhancement measures for the Sierra and local watersheds, such as those included in the Watershed Environmental Improvement Program.
4. Environmental Enhancement Surcharge proceeds shall be expended in an expeditious manner. Any Environmental Enhancement Surcharge
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proceeds that remain in the reserve fund as of December 31, 2018 shall be used to complete projects previously approved under subsection E.
Upon completion of the identified projects, the balance of any unexpended sums in the reserve fund shall be distributed to BAWSCA and the SFPUC in proportion to the total amount of surcharges assessed to the Wholesale and Retail Customers, respectively.
E. Use of Environmental Enhancement Surcharge Proceeds. Specific uses of Environmental Enhancement Surcharges will be decided by the SFPUC and BAWSCA General Managers following input from environmental stakeholders and other interested members of the public. If parties are unable to agree, then they will jointly select a third person to participate in making the decision.
4.05. San Jose/ Santa Clara Interim Supply Allocation and Process for Reduction/ Termination.
San Francisco will supply a combined annual average of 9 MGD to the cities of San Jose and Santa Clara through 2028. Water supplied by San Francisco may only be used in the defined service areas of San Jose and Santa Clara shown on Attachment Q-1 and Q-2, respectively. San Francisco may reduce the quantity of water specified in this section when it establishes the Interim Supply Allocations for Wholesale Customers in Section 4.02. The establishment of Interim Supply Allocations for San Jose and Santa Clara shall not be considered a reduction of supply within the meaning of this section, provided that the Interim Supply Allocations assigned to San Jose and Santa Clara do not effect a reduction greater than the aggregate average reduction in Individual Supply Guarantees for Wholesale Customers that have such guarantees. The application of Interim Supply Allocations to San Jose and Santa Clara, and water supply planning after December 31, 2018, are subject to the following provisions:
A. In December 2010 and in each December thereafter through 2027, the SFPUC shall prepare and the Commission shall consider, at a regularly scheduled public meeting, a Water Supply Development Report detailing progress made toward (1) meeting the Interim Supply Limitation by June 30, 2018 and (2) developing additional water supplies that will allow the Commission to designate San Jose and Santa Clara as permanent Wholesale Customers of the Regional Water System with a combined Individual Supply Guarantee of up to 9 MGD by the end of the Term on June 30, 2034.
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B. The annual Water Supply Development Report shall be based on water purchase projections and work plans prepared by the SFPUC for the Retail Customers and by BAWSCA for the Wholesale Customers, respectively, and submitted to the Commission in June of each year beginning in 2010.
C. If the Commission finds that the projections in the Water Supply Development Report show that (1) the Interim Supply Limitation will not be met by June 30, 2018, as a result of Wholesale Customers' projected use exceeding 184 MGD, or (2) the purchases of the Wholesale Customers, including San Jose and Santa Clara, are projected to exceed 184 MGD before June 30, 2028, the Commission may issue a conditional ten year notice of interruption or reduction in supply of water to San Jose and Santa Clara.
D. Upon issuance of the conditional notice of interruption or reduction, the SFPUC will prepare a new analysis of water supply that will be utilized by the San Francisco Planning Department in its preparation of any necessary documentation under CEQA pursuant to Section
4.07 on the impacts of interrupting or reducing service to San Jose and Santa Clara.
E. Such notice of interruption or reduction will be rescinded if the Commission finds, based upon a subsequent annual Water Supply Development Report, that (1) sufficient progress has been made toward meeting the Interim Supply Limitation, or (2) projections show that the projected purchases of the Wholesale Customers, including San Jose and Santa Clara, will not exceed 184 MGD by June 30, 2028.
F. In no case shall any interruption or reduction of service to San Jose or Santa Clara pursuant to this section become effective less than two years from the completion of the CEQA process (not including resolution of any appeals or litigation) or ten years from the notice, whichever is longer. If the ten year notice is issued after 2018, such interruption or reduction would be effective after 2028.
G. If deliveries to San Jose and Santa Clara are interrupted, existing turnout facilities to San Jose and Santa Clara will remain in place for possible use during emergencies.
H. San Francisco and the cities of San Jose and Santa Clara will cooperate with BAWSCA and the Santa Clara Valley Water District in the identification and implementation of additional water sources and conservation measures for the cities’ service areas that are
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relevant to the water supply and the possible offer of permanent status for the two cities by the SFPUC.
4.06. San Francisco Decisions in 2028 Regarding Future Water Supply A. By December 31, 2028, San Francisco will have completed any necessary CEQA review pursuant to Section 4.07 that is relevant to making San Jose and Santa Clara permanent customers of the Regional Water System and will decide whether or not to make San Jose and Santa Clara permanent customers of the Regional Water System with a combined Individual Supply Guarantee of 9 MGD allocated equally between the two cities, as well as how much water in excess of 9 MGD it will supply to San Jose and Santa Clara. San Francisco will make San Jose and Santa Clara permanent customers only if, and to the extent that, San Francisco determines that Regional Water System long term water supplies are available. In the event that San Francisco decides to afford permanent status to San Jose and Santa Clara, this Agreement will be amended pursuant to Section 2.03.
B. By December 31, 2028, San Francisco will have completed any necessary CEQA review pursuant to Section 4.07 and will decide how much water, if any, in excess of the Supply Assurance it will supply to Wholesale Customers from the Regional Water System to meet their projected future water demands until the year 2040, and whether to offer a corresponding increase in the Supply Assurance as a result of these determinations.
4.07. Retained Discretion of SFPUC and Wholesale Customers A. This Agreement contemplates discretionary actions that the SFPUC and the Wholesale Customers may choose to take in the future that could result in physical changes to the environment ("Discretionary Actions"). The Discretionary Actions include decisions to:
1. Develop additional or alternate water resources by the SFPUC or one or more Wholesale Customers;
2. Implement the physical facilities comprising the WSIP by December 30, 2021;
3. Approve wheeling proposals by Wholesale Customers;
4. Approve new wholesale customers and water exchange or cost sharing agreements with other water suppliers;
5. Provide additional water to San Jose and/or Santa Clara;
6. Offer permanent status to San Jose and/or Santa Clara;
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7. Reduce or terminate supply to San Jose and/or Santa Clara;
8. Provide additional water to Wholesale Customers in excess of the Supply Assurance to meet their projected future water demands;
9. Offer a corresponding volumetric increase in the Supply Assurance; and
10. Implement the Hetch Hetchy Water and Power projects listed in Attachment R-2.
The Discretionary Actions may require the SFPUC or Wholesale Customers to prepare environmental documents in accordance with CEQA prior to the SFPUC or the Wholesale Customers determining whether to proceed with any of the Discretionary Actions. Accordingly, and notwithstanding any provision of this Agreement to the contrary, nothing in this Agreement commits the SFPUC or the Wholesale Customers to approve or carry out any Discretionary Actions that are subject to CEQA. Furthermore, the SFPUC’s or Wholesale Customers’ decisions to approve any of these Discretionary Actions are subject to the requirement that San Francisco and each Wholesale Customer, as either a “Lead Agency” (as defined in Section 21067 of CEQA and Section 15367 of the CEQA Guidelines) or a “Responsible Agency” (as defined in Section 21069 of CEQA and Section 15381 of the CEQA Guidelines) shall have completed any CEQA-required environmental review prior to approving a proposed Discretionary Action.
B. In considering any proposed Discretionary Actions, the SFPUC and Wholesale Customers retain absolute discretion to: (1) make such modifications to any of the proposed Discretionary Actions as may be necessary to mitigate significant environmental impacts; (2) select feasible alternatives to the proposed Discretionary Actions that avoid significant adverse impacts; (3) require the implementation of specific measures to mitigate the significant adverse environmental impacts as part of the decision to approve the Discretionary Actions; (4) balance the benefits of the proposed Discretionary Actions against any significant environmental impacts before taking final actions to approve the proposed Discretionary Actions if such significant impacts cannot otherwise be avoided; or (5) determine not to proceed with the proposed Discretionary Actions.
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Article 5. Wholesale Revenue Requirement
5.01. Scope of Agreement
This Article shall be applicable only to the water rates charged by San Francisco to the Wholesale Customers. Nothing contained in this Agreement shall limit, constrain, or in any way affect the rates which San Francisco may charge for water sold to Retail Customers or the methodology by which such rates are determined.
5.02. General Principles
This Article sets forth the method by which the Wholesale Customers’ collective share of expenses incurred by the SFPUC in delivering water to them will be determined. This collective share is defined as the “Wholesale Revenue Requirement.” A. The SFPUC currently operates several enterprises, including the Water Enterprise, the Wastewater Enterprise, and the Hetch Hetchy Enterprise.
B. The Wastewater Enterprise is responsible for treating sewage within San Francisco and provides no benefit to the Wholesale Customers.
C. The Hetch Hetchy Enterprise is responsible for storing and transmitting water to the Water Enterprise, generating hydroelectric power and transmitting it to San Francisco, generating electric power within San Francisco, and distributing electricity and steam heat within San Francisco. Its water supply operations provide benefits to the Wholesale Customers.
D. The Water Enterprise delivers water to both Retail Customers, which are located both within and outside San Francisco, and to the Wholesale Customers, all of which are located outside San Francisco.
E. This Article implements two general principles as follows: (1) the Wholesale Customers should not pay for expenses of SFPUC operations from which they receive no benefit and (2) the Wholesale Customers should pay their share of expenses incurred by the SFPUC in delivering water to them on the basis of Proportional Annual Use unless otherwise explicitly provided in this Agreement.
F. To implement these general principles, the Wholesale Revenue Requirement will consist of, and be limited to, the Wholesale Customers’ shares of the following categories of expense:
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1. Capital cost recovery of Water Enterprise Existing Assets, and Hetch Hetchy Enterprise Existing Assets classified as Water-Only and the Water-Related portion of Joint assets (Section 5.03)
2. Contribution to the capital cost of Water Enterprise New Regional Assets (Section 5.04)
3. Water Enterprise operation and maintenance expenses, including power purchased from the Hetch Hetchy Enterprise that is used in the operation of the Water Enterprise (Section 5.05)
4. Water Enterprise administrative and general expenses (Section 5.06)
5. Water Enterprise property taxes (Section 5.07)
6. The Water Enterprise’s share of the Hetch Hetchy Enterprise’s operation and maintenance, administrative and general, and property tax expenses (Section 5.08)
7. The Water Enterprise’s share of the Hetch Hetchy Enterprise’s capital cost of New Assets classified as Water-Only and the Water-Related portion of Joint assets (Section 5.09)
In each of these cost categories, Direct Retail Expenses will be allocated entirely to Retail Customers. Direct Wholesale Expenses will be allocated entirely to the Wholesale Customers. Regional Expenses will be allocated between Retail Customers and Wholesale Customers as provided in this Article.
G. For purposes of establishing the rates to be charged Wholesale Customers, expenses will be based on the budget for, and estimates of water purchases in, the following fiscal year, as provided in Article 6. For purposes of accounting, the Wholesale Revenue Requirement will be determined on the basis of actual expenses incurred and actual water use, as provided in Article 7.
H. In addition, rates charged to Wholesale Customers may include the Wholesale Customers’ contribution to a Wholesale Revenue Coverage Reserve, as provided in Section
6.06, which is not included in the Wholesale Revenue Requirement itself.
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5.03. Capital Cost Recovery - Existing Regional Assets
A. SFPUC has previously advanced funds to acquire or construct Existing Assets used and useful in the delivery of water to both Wholesale Customers and Retail Customers.
The parties estimate that the Wholesale Customers’ share of the net book value of these assets, as of the expiration of the 1984 Agreement on June 30, 2009, will be approximately $366,734,424, as shown on Attachment K-1.
B. In addition, SFPUC has also previously advanced funds received from Retail Customer revenues to acquire or construct assets included in Construction-Work-In-Progress (CWIP) as of June 30, 2009. The parties estimate that the Wholesale Customers’ share of the book value of these revenue funded capital expenditures, as of the expiration of the 1984 Agreement on June 30, 2009, will be approximately $15,594,990, as shown on Attachment K-2.
The Wholesale Customers shall pay their share of the cost of Existing Assets and revenuefunded CWIP by amortizing the amounts shown on Attachment K-1 and Attachment K-2 over 25 years at an interest rate of 5.13 percent. The amounts to be included in the Wholesale Revenue Requirement pursuant to this section shall be the sum of the annual principal and interest amounts shown on Attachments K-3 (for Water Enterprise Regional Assets and the one Direct Wholesale Asset) and K-4 (for Hetch Hetchy Enterprise Water-Only Assets and the Water-Related portion [45 percent] of Joint assets) calculated on the basis of monthly amortization of principal as set forth on Attachments K-3 and K-4.
C. In addition, the Commission has previously appropriated funds, advanced through rates charged to Retail Customers, for construction of capital projects. Some of these projects are active, and have unexpended balances of appropriated funds that are not included in CWIP as of June 30, 2009. These projects, and the associated balances, are shown on Attachment K-5. Expenditures of funds from these balances during FY 2009-10, FY 2010-11 and FY 2011-12 will be reviewed in FY 2012-13. The SFPUC will prepare a report showing the amount expended in each year on each project and the total expended during all years on all projects that are categorized as Regional or, in the case of Hetch Hetchy Enterprise, are categorized as either Water-Only or Joint. The wholesale share of that total will be determined using the allocation principles in this Agreement based on Proportional Water Use during those three years. The result, plus accrued interest at the rate specified in Section 6.05.B, will be calculated by the SFPUC and its calculation reviewed by the Compliance Auditor as part of the Compliance Audit for FY 2012-13. The audited total will be paid based on a schedule of level
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annual principal and interest amounts over ten years at an interest rate of 4.00%, calculated on a monthly amortization basis. All or any portion of the balance may be prepaid. The first year’s payment will be included in the Wholesale Revenue Requirement for FY 2014-15.
D. The parties agree that the Wholesale Customers’ share of the net book values of Existing Regional Assets as of June 30, 2008 as shown on Attachment K-1 are accurate. The compliance audit conducted on the calculation of the FY 2008-09 Suburban Revenue Requirement required by the 1984 Agreement will determine the actual amounts of depreciation on, and capital additions to, plant in service during that fiscal year. Those amounts will be compared to the corresponding estimates shown on Attachments K-1 and K-2. The differences will be added to or subtracted from the estimated asset values shown on Attachments K-1 and K-2 and the amortization schedules in Attachments K-3 and K-4 will be recalculated. The wholesale allocation factors shall be fixed at 70.1% for the Water Enterprise Existing Assets and
64.2% for Hetch Hetchy Enterprise Existing Assets for both the preliminary and final payment schedules. The SFPUC will prepare and provide to the Wholesale Customers revised Attachments K-1 through K-4 based on the Wholesale Customers’ share of the net book value of the assets placed in service as of June 30, 2009 used to provide water service to the Wholesale Customers and the net book value of revenue-funded CWIP expended as of June 30, 2009. The revised Attachments K-1 through K-4 shall be approved by the General Manager of the SFPUC and the General Manager/CEO of BAWSCA and will be substituted for the original Attachments K-1 through K-4.
E. The original Attachments K-1 through K-4, based on estimates, shall be used for estimating the Wholesale Revenue Requirement for the fiscal year beginning July 1, 2009. The revised Attachments, based on audited actuals, shall be used to determine the actual Wholesale Revenue Requirement for FY 2009-10 and to determine the Wholesale Revenue Requirement(s) in all subsequent years, except as may be provided elsewhere in this Agreement.
F. The Wholesale Customers, acting through BAWSCA, may prepay the remaining unpaid Existing Assets principal balance, in whole or in part, at any time without penalty or early payment premium. Any prepayments will be applied in the month immediately following the month in which the prepayment is made and the revised monthly amount(s) will be used to calculate the Wholesale Revenue Requirement. Any partial prepayments must be in an amount at least equal to $10 million. In the event of a partial prepayment, an updated schedule for the
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remaining payments shall be prepared reflecting the unpaid balance after prepayment, amortized through the end of FY 2034, calculated as provided in this section. The updated schedule, approved by the General Manager of the SFPUC and the General Manager/CEO of BAWSCA, will be substituted for Attachment K-3 and/or Attachment K-4.
5.04. Capital Cost Contribution - New Regional Assets
A. Debt-Funded Capital Additions. The Wholesale Customers shall pay the wholesale share of Net Annual Debt Service for New Regional Assets. The Regional projects in the WSIP are identified in Attachment L-1.
1. The amount of Net Annual Debt Service for New Regional Assets will be determined for each series of Indebtedness issued. Until the proceeds of a particular series are Substantially Expended, the amount attributable to specific projects will be based on the expected use of proceeds shown in the “Certificate Regarding Use of Proceeds” executed by the SFPUC General Manager on behalf of the Commission in connection with the sale of the Indebtedness, provided such certificate identifies the use of proceeds at a level of detail equivalent to that shown on Attachment L-2, which is a copy of the certificate prepared for the 2006 Revenue Bonds, Series A. If a certificate does not identify the use of proceeds at that level of detail, the SFPUC General Manager shall prepare and execute a separate certificate which does identify the use of proceeds at the level of detail shown on Attachment L-2 and deliver it to BAWSCA within 15 days from the closing of the sale of the Indebtedness.
2. After the proceeds of a series are Substantially Expended, the SFPUC General Manager will prepare and execute a certificate showing the actual expenditure of proceeds at a level of detail equivalent to the initial General Manager certificate. The resulting allocation of Net Debt Service to New Regional Assets for a series of bonds will be used in the fiscal year in which the proceeds have been Substantially Expended and thereafter. Differences between the amount of Net Debt Service paid by Wholesale Customers prior to that year and the amount of Net Debt Service that they should have paid during that time based on the actual expenditure of proceeds will be taken into account in calculation of the balancing account for the fiscal year in which the proceeds were Substantially Expended. The application of the remaining proceeds shall be proportionate to the allocation of the Net Debt Service to New Regional Assets.
3. The Wholesale Customers’ share of Net Annual Debt Service for the New Regional Assets that are categorized as Direct Wholesale will be 100 percent. (None of the
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projects in the WSIP are categorized as Direct Wholesale.) The Wholesale Customers’ share of Net Annual Debt Service for all other New Regional Assets will be determined each year and will be equal to the Wholesale Customers’ Proportional Annual Use.
4. If Indebtedness is issued by the SFPUC to refund the 2006 Revenue Bonds, Series A or to refund any other long-term Indebtedness issued after July 1, 2009, the Net Annual Debt Service attributable to proceeds used for refunding will be allocated on the same basis as the Indebtedness being refunded.
5. The SFPUC will prepare an annual report showing for each issue of Indebtedness and through the most recently completed fiscal year: (1) net financing proceeds available to pay project costs, (2) actual earnings on proceeds, (3) actual expenditures by project. The report shall be substantially in the form of Attachment L-3 and shall be delivered to BAWSCA on or before November 30 of each year, commencing November 2009.
6. In addition to Net Debt Service, Wholesale Customers will pay a proportionate share of annual administrative costs associated with Indebtedness, such as bond trustee fees, credit rating agency fees, letter of credit issuer fees, San Francisco Revenue Bond Oversight Committee fees, etc., but only to the extent such fees are neither paid from proceeds of Indebtedness nor included in SFPUC operation and maintenance or administrative and general expenses.
B. Revenue-Funded Capital Additions. The Wholesale Customers shall pay the wholesale share of the appropriation contained in the SFPUC annual budget for each year to be used to acquire or construct New Regional Assets. If such appropriations are reimbursed from proceeds of Indebtedness, the Wholesale Customers will be credited for prior payments made under this Section 5.04.B.
The Wholesale Customers’ share of the annual appropriation for revenue-funded New Regional Assets that are categorized as Direct Wholesale will be 100 percent. (None of the Repair and Replacement projects in the SFPUC’s most recent capital improvement program updated on February 10, 2009, is categorized as Direct Wholesale.) The Wholesale Customers’ share of the annual appropriation for all other revenue-funded New Regional Assets will be determined each year and will be equal to the Wholesale Customers’ Proportional Annual Use in each fiscal year. The amount appropriated in each fiscal year for the wholesale share of New Regional Assets shall be contributed to the Wholesale Capital Fund described in Section 6.08 and reported on and administered as shown in that section and Attachments M-1 through M-3.
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5.05. Water Enterprise Operation and Maintenance Expenses There are five categories of Water Enterprise Operation and Maintenance Expenses, described below:
A. Source of Supply
1. Description: This category consists of the costs of labor, supervision and engineering; materials and supplies; and other expenses incurred in the operation and maintenance of collecting and impounding reservoirs, dams, wells and other water supply facilities located outside San Francisco; watershed protection; water supply planning; and the purchase of water.
2. Allocation: Direct Retail expenses, including water supply planning for Retail operations (such as City Retail water conservation programs), will be assigned to the Retail Customers. Regional expenses will be allocated between Retail Customers and Wholesale Customers on the basis of Proportional Annual Use. Direct Wholesale expenses will be assigned to the Wholesale Customers. (As of the Effective Date there are no Direct Wholesale expenses in the Source of Supply category.)
B. Pumping
1. Description: This category consists of the costs of labor, supervision and engineering; materials and supplies; and other expenses incurred in the operation and maintenance of water pumping plants, ancillary structures and equipment and surrounding grounds; and fuel and power purchased for pumping water.
2. Allocation: Direct Retail expenses will be assigned to the Retail Customers. Regional expenses will be allocated between Retail Customers and Wholesale Customers on the basis of Proportional Annual Use. Direct Wholesale expenses will be assigned to the Wholesale Customers. (As of the Effective Date there are no Direct Wholesale expenses in the Pumping category.)
C. Treatment
1. Description: This category consists of the costs of labor, supervision and engineering; materials and supplies and other expenses incurred in the operation and maintenance of water treatment plants and drinking water quality sampling and testing. The cost of water quality testing will not include expenses incurred on behalf of the Wastewater
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Enterprise. Any remaining costs, after adjusting for the Wastewater Enterprise, will be reduced by the amount of revenue received for laboratory analyses of any type performed for agencies, businesses and/or individuals other than the Water and Hetch Hetchy Enterprises.
2. Allocation: Direct Retail expenses will be assigned to the Retail Customers. Regional expenses will be allocated between Retail Customers and Wholesale Customers on the basis of Proportional Annual Use. Direct Wholesale expenses will be assigned to the Wholesale Customers. (As of the Effective Date there are no Direct Wholesale expenses in the Treatment category.)
D. Transmission and Distribution
1. Description: This category consists of the cost of labor, supervision and engineering; materials and supplies; and other expenses incurred in the operation and maintenance of transmission and distribution pipelines, appurtenances, meters (other than those expenses payable by individual Wholesale Customers pursuant to Section 5.10.C.3), distribution reservoirs storing treated water, craft shops and auto shops servicing vehicles used for operation and maintenance of the Regional Water System rather than for Direct Retail facilities, and miscellaneous facilities related to the transmission and distribution of water.
2. Allocation: Direct Retail Transmission and Distribution expenses will be assigned to the Retail Customers. Regional Transmission and Distribution expenses will be allocated between Retail and Wholesale Customers on the basis of Proportional Annual Use.
Expenses incurred for the operation and maintenance of three terminal reservoirs, i.e., Sunset Reservoir (North and South Basins), University Mound Reservoir (North and South Basins), and Merced Manor Reservoir, as well as transmission pipelines delivering water to them, are classified as Regional expenses notwithstanding the location of the reservoirs within San Francisco. Direct Wholesale expenses will be assigned to the Wholesale Customers. (As of the Effective Date the only Direct Wholesale expenses in the Transmission and Distribution category are associated with the Palo Alto pipeline.)
E. Customer Services
1. Description: This category consists of labor; materials and supplies; and other expenses incurred for meter reading, customer record keeping, and billing and collection for the Water Enterprise.
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2. Allocation: Customer Services expenses will be allocated among the Water Enterprise, the Wastewater Enterprise, and Hetch Hetchy Enterprise in proportion to the time spent by employees in Customer Services for each operating department/enterprise. The Water Enterprise’s share of Customer Services expense will be allocated 98 percent to the Retail Customers and two percent to the Wholesale Customers, as illustrated on Attachment N2, Schedule 1.
5.06. Water Enterprise Administrative and General Expenses Administrative and General expenses consist of the Water Enterprise’s share of the cost of general government distributed through the full-cost Countywide Cost Allocation Plan, the services of SFPUC support bureaus, Water Enterprise administrative and general expenses that cannot be directly assigned to a specific operating and maintenance category, and the cost of the Compliance Audit. These four subcategories, and the method by which costs in each are to be calculated and allocated, are as follows:
A. Countywide Cost Allocation Plan
1. Description: This subcategory consists of the Water Enterprise’s share of the costs of San Francisco general government and other City central service departments which are not directly billed to the Water Enterprise or other operating departments. All San Francisco operating departments are assigned a prorated share of these costs through the fullcost Countywide Cost Allocation Plan (COWCAP) prepared annually by the San Francisco Controller.
2. Allocation: The Water Enterprise’s assigned share of central government costs as shown in the annual full-cost COWCAP prepared by the San Francisco Controller, will be allocated between Retail Customers and Wholesale Customers on the basis of the composite percentage of the allocated expenses in the five categories of operation and maintenance expense described in Section 5.05. The composite wholesale percentage shown on Attachment N-2, Schedule 1 is 42.07 percent, derived by dividing the wholesale share of Operation and Maintenance expenses ($46,573,883) by total Operation and Maintenance expenses ($110,700,133).
B. Services of SFPUC Bureaus
1. Description: This subcategory consists of the support services provided to the Water Enterprise by the SFPUC Bureaus, which presently consist of the General
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Manager’s Office, Business Services, External Affairs, and Infrastructure Bureau. Business Services presently includes Financial Services, Information Technology Services, Human Resource Services, Fleet Management, and Customer Services.
2. Allocation: There are three steps involved in determining the Wholesale Customers’ share of SFPUC Bureau costs.
a. Step One: Bureau expenses which have either been recovered separately or which provide no benefit to Wholesale Customers will be excluded. Examples of Bureau expenses recovered separately include (1) Customer Services expenses, which are recovered as provided in Section 5.05.E, and (2) Infrastructure expenses, which are assigned to individual projects and capitalized. An example of a Bureau expense that provides no benefit to Wholesale Customers is Information Technology Services expenses for support of the San Francisco Municipal Railway. In addition, the SFPUC will continue its practice of assigning City Attorney Office expenses charged to the General Manager's Office for projects or lawsuits that relate to only one enterprise directly to that enterprise. For example, costs related to a lawsuit involving the Wastewater Enterprise will not be assigned to the Water Enterprise. b. Step Two: Bureau expenses adjusted as provided in Step One will be allocated among the Water Enterprise, the Wastewater Enterprise and the Hetch Hetchy Enterprise on the basis of the actual salaries of employees in each enterprise or department, as illustrated on Attachment N-2, Schedule 7.
c. Step Three: The amount allocated to the Water Enterprise through Step Two will be allocated between Retail Customers and Wholesale Customers on the basis of Proportional Annual Use.
C. Water Enterprise Administrative and General
1. Description: This category includes expenses incurred by the Water Enterprise that are not readily assignable to specific operating divisions. This category includes the following expenses:
a. Water Administration: This includes the costs of labor and other expenses of the administrative section of the Water Enterprise, supervision and engineering expenses, professional services, travel and training, equipment purchases, and materials and supplies not directly assignable to a specific operating unit. b. Services Provided by Other City Departments: This includes charges of other San Francisco departments directly billed to the Water Enterprise
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administration by other San Francisco departments for services ordered by the Water Enterprise, such as legal services, risk management, telecommunications, employee relations, purchasing, mail services, and workers compensation claims paid. c. Litigation and Claims Paid: This includes charges incurred for attorney services and claims and judgments paid in litigation arising from the operation of the Water Enterprise.
2. Allocation: In each of these three subcategories, expenses that benefit only Retail Customers will be excluded. For example, the cost of claims and judgments resulting from a break in or leak from pipelines or reservoirs in the Retail Service Area (with the exception of the three terminal reservoirs and pipelines delivering water to them) will be assigned to the Retail Customers. Remaining Water Enterprise Administrative and General expenses will be allocated between Retail Customers and Wholesale Customers on the basis of the composite percentage of allocated operation and maintenance expense categories described in Section 5.05.
D. Compliance Audit. The cost of the Compliance Audit described in Section 7.04 will be assigned 50 percent to the Retail Customers and 50 percent to the Wholesale Customers.
5.07. Water Enterprise Property Taxes
A. Description: This category consists of property taxes levied against property owned by San Francisco located in Alameda, San Mateo and Santa Clara counties and used and managed by the SFPUC.
B. Allocation: All property taxes paid, net of (1) reimbursements received from lessees and permit holders, and (2) refunds from the taxing authority, are Regional expenses.
Net property taxes will be allocated between Retail Customers and Wholesale Customers on the basis of Proportional Annual Use.
5.08. Hetch Hetchy Enterprise Expenses
A. Introduction. There are two steps involved in determining the amount of the Wholesale Customers’ share of Hetch Hetchy Enterprise expenses.
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1. The first step is to determine the Water Enterprise’s share of Hetch Hetchy Enterprise operation expenses, maintenance expenses, administrative and general expenses, and property taxes.
2. The second step is to determine the Wholesale Customers’ share of expenses allocable to the Water Enterprise.
B. Determination of the Water-Related Portion of Hetch Hetchy Enterprise Expenses
1. Operation and Maintenance Expenses: This category consists of the cost of labor, materials and supplies, and other expenses incurred in operating and maintaining Hetch Hetchy Enterprise physical facilities.
a. Description: Expenses associated exclusively with the production and distribution of hydroelectric power (e.g., generating plants and power transmission lines and towers, transformers and associated electric equipment, purchased power, wheeling charges, rental of power lines, etc.) are categorized as Power-Only and are allocated to power.
Expenses associated exclusively with the operation and maintenance of facilities that serve only the water function (e.g., water transmission pipelines and aqueducts, activities related to compliance with federal and state drinking water quality laws, etc.) are categorized as WaterOnly and are allocated entirely to water. Expenses associated with the operation and maintenance of facilities that serve both the water and power functions (e.g., dams, security programs, etc.) are categorized as Joint and are reallocated as 55 percent Power-Related and 45 percent Water-Related.
2. Administrative and General Expenses: There are three subcategories of Hetch Hetchy Enterprise Administrative and General expenses. a. Full-Cost Countywide Cost Allocation Plan: This subcategory consists of the cost of San Francisco general government and other City central service departments which are not directly billed to operating departments but allocated through the fullcost Countywide Cost Allocation Plan described in Section 5.06.A. Costs in this subcategory are classified as Joint, and are reallocated as 55 percent Power-Related and 45 percent WaterRelated. b. SFPUC Bureau Costs: This subcategory consists of the expenses described in Section 5.06.B. One hundred percent of Customer Services expenses allocated to the Hetch Hetchy Enterprise are categorized as Power-Only. The remaining amount of Bureau
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expenses allocated to the Hetch Hetchy Enterprise pursuant to Section 5.06.B will be reallocated between power and water in proportion to the salaries of Hetch Hetchy Enterprise employees assigned to each function as shown on Attachment N-2, Schedule 7.1. c. Other Administrative and General: This subcategory includes payments to the United States required by the Act, labor, supervision and engineering and other costs not readily assignable to a specific operation or maintenance function or program. Costs related to power administration (such as long range planning and policy analysis for energy development, administration of power contracts, and administration of work orders to City departments for energy services) are Power-Only costs. Costs related to water administration (such as legal and professional services for the protection of the City's water rights) are WaterOnly costs and will be assigned to the Water Enterprise. Costs related to both power administration and water administration (such as general administration, office rents, office materials and supplies, and services of other City departments benefitting to both power and water are Joint administrative and general costs and are reallocated as 55 percent PowerRelated and 45 percent Water-Related.
3. Property Taxes. This category consists of property taxes levied against property owned by San Francisco in Tuolumne, Stanislaus, San Joaquin, and Alameda counties and operated and managed by the Hetch Hetchy Enterprise.
Allocation: Property taxes are classified as Joint costs. They will be reallocated as 55 percent Power-Related and 45 percent Water-Related.
C. Calculation of Wholesale Customers’ Share of Hetch Hetchy Enterprise Expenses. The Water Enterprise’s share of Hetch Hetchy Enterprise expenses consist of 100 percent of Water-Only expenses and the Water-Related portion (45%) of Joint expenses.
The Wholesale Customers’ share of the sum of the Water Enterprise’s share of Hetch Hetchy Enterprise expenses determined under subsection B shall be calculated by multiplying that dollar amount by Adjusted Proportional Annual Use.
5.09. Hetch Hetchy Enterprise Capital Costs
A. Introduction. Wholesale Customers are also allocated a share of Hetch Hetchy Enterprise capital costs.
B. Components of Capital Costs. The components of Hetch Hetchy Enterprise capital costs are as follows:
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1. Existing Assets Cost Recovery. The Wholesale Customers’ repayment of their share of Hetch Hetchy Existing Assets (Water-Only and the Water-Related portion [45 percent] of Joint assets) is shown on Attachment K-4 accompanying Section 5.03.
2. Debt Service on New Assets. The Water Enterprise will be assigned 100 percent of Net Annual Debt Service attributable to acquisition and construction of New Hetch Hetchy Enterprise assets that are Water-Only and the Water-Related portion (45 percent) of Net Annual Debt Service on New Hetch Hetchy Enterprise Joint assets. The provisions of Section
5.04.A apply to debt service on New Hetch Hetchy Enterprise assets.
3. Revenue-Funded Capital Additions. The Water Enterprise will be assigned 100 percent of capital expenditures from revenues for New Hetch Hetchy Enterprise assets that are Water-Only and the Water-Related portion (45 percent) of such expenditures for new Hetch Hetchy Enterprise Joint assets. The provisions of Section 5.04.B apply to the payment of New revenue-funded Hetch Hetchy Enterprise assets.
C. Calculation of Wholesale Customers’ Share of Hetch Hetchy Enterprise Capital Costs. The Wholesale Customers’ share of the Net Annual Debt Service and revenue funded capital expenditures determined under subsections B.2 and 3 shall be calculated by multiplying that dollar amount by Adjusted Proportional Annual Use.
5.10. Additional Agreements Related to Financial Issues A. Wholesale Customers Not Entitled to Certain Revenues. The Wholesale Customers have no entitlement to any of the following sources of revenue to the SFPUC.
1. Revenues from leases or sales of SFPUC real property.
2. Revenues from the other utility services such as the sale of electric power, natural gas and steam.
3. Revenues from the sale of water to customers and entities other than the Wholesale Customers.
4. Revenues earned from the investment of SFPUC funds other than funds contributed by the Wholesale Customers to the Wholesale Revenue Coverage Reserve described in Section 6.06 or the Wholesale Capital Fund described in Section 6.08. Wholesale Customers are also entitled to the benefit of earnings on proceeds of Indebtedness (through
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expenditure on New Regional Assets and /or application to Debt Service) and to interest on the Balancing Account as provided in Section 6.05.B.
5. Revenues not related to the sale of water.
B. Wholesale Customers Not Charged with Certain Expenses. The Wholesale Customers will not be charged with any of the following expenses:
1. Capital costs for assets constructed or acquired prior to July 1, 1984 other than Existing Asset costs that are repaid pursuant to Section 5.03.
2. Expenses incurred by the SFPUC for generation and distribution of electric power, including Hetch Hetchy Enterprise Power-Only expenses and the Power-Related share of Hetch Hetchy Enterprise Joint expenses. An exception to this is Regional energy costs incurred by the Water Enterprise, for which Wholesale Customers are charged on the basis of Proportional Annual Use.
3. Expenses incurred by SFPUC in providing water to Retail Customers.
4. Expenses associated with the SFPUC’s accruals or allocations for uncollectible Retail Water accounts.
5. Attorneys’ fees and costs incurred by the Wholesale Customers that a court of competent jurisdiction orders San Francisco to pay as part of a final, binding judgment against San Francisco as provided in Section 8.03.B.2.
6. Any expenses associated with funding any reserves (other than the required Wholesale Revenue Coverage Reserve described in Section 6.06) accrued and not anticipated to be paid within one year unless such reserve is established by mutual agreement of the SFPUC and BAWSCA.
7. Any expenses accrued in respect to pending or threatened litigation, damage or personal injury claims or other loss contingencies unless projected to be paid within one year. Otherwise, such expenses will be charged to the Wholesale Customers when actually paid.
8. Any expense associated with installing, relocating, enlarging, removing or modifying meters and service connections at the request of an individual Wholesale Customer.
9. The Retail Customers’ portion of any Environmental Enhancement Surcharges imposed to enforce the Interim Supply Limitation set forth in Section 4.04.
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C. Revenues Not Credited to Payment of Wholesale Revenue Requirement.
The following payments by Wholesale Customers, individually or collectively, are not credited as Wholesale revenues for purposes of Section 6.05.B:
1. Payments by individual Wholesale Customers of the Environmental Enhancement Surcharge imposed to enforce the Interim Supply Limitation set forth in Section 4.04.
2. Payments of attorneys’ fees and costs incurred by San Francisco that a court of competent jurisdiction orders the Wholesale Customers to pay as part of a final, binding judgment against the Wholesale Customers, as provided in Section 8.03.B.3.
3. Payments by individual Wholesale Customers for installation, relocation, enlargement, removal or modification of meters and service connections requested by, and charged to, a Wholesale Customer.
4. Payments applied to the amortization of the ending balance in the balancing account under the 1984 Agreement, pursuant to Section
6.05.A.
5. Payments of the Water Management Charge which are delivered to BAWSCA pursuant to Section 3.06.
6. Payments directed to the Wholesale Revenue Coverage Reserve pursuant to Section 6.06.
7. Prepayments authorized by Sections 5.03.C and 5.03.F.
D. Other
1. The Wholesale Customers will receive a proportional benefit from funds received by the SFPUC from (a) governmental grants, rebates, reimbursements or other subventions, (b) private-sector grants for Regional capital or operating purposes of the Water Enterprise and the Water-Only and Water-related portion of Joint Hetch Hetchy Water Enterprise expenses, or (c) a SFPUC use of taxable bonds.
2. The Wholesale Customers will receive a proportionate benefit from recovery of damages, including liquidated damages, by SFPUC from judgments against or settlements with contractors, suppliers, sureties, etc., related to Regional Water System projects and the Water-Only and Water-Related portion of Joint Hetch Hetchy Enterprise projects.
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3. The SFPUC will continue to charge Wholesale Customers for assets acquired or constructed with proceeds of Indebtedness on which Wholesale Customers paid Debt Service during the Term of this Agreement on the “cash” basis (as opposed to the “utility” basis) after the expiration or earlier termination of this Agreement. The undertaking in this Section 5.10.D.3 will survive the expiration or earlier termination of this Agreement.
5.11. Classification of Existing System Assets.
Existing System Assets of the Regional Water System include the water storage, transmission, and treatment systems owned and operated by San Francisco in Tuolumne, Stanislaus, San Joaquin, Alameda, Santa Clara, San Mateo and San Francisco Counties.
These assets are managed by either the Water Enterprise or the Hetch Hetchy Enterprise and the assets have been classified for purposes of cost allocation.
A. Water Enterprise Assets. Water Enterprise assets are currently managed, operated, and maintained by the Water Enterprise and are generally located west of Alameda East Portal, in addition to the treatment facilities located at Tesla and the Thomas Shaft Emergency Disinfection Facility. These assets are classified as Direct Retail, Direct Wholesale, or Regional.
B. Hetch Hetchy Enterprise Assets. Hetch Hetchy Enterprise assets are currently managed, operated and maintained by the Hetch Hetchy Enterprise and are generally located east of the Alameda East Portal of the Coast Range Tunnel in Sunol Valley, Alameda County.
These assets are classified as Power-Only, Water-Only, or Joint, in accordance with Sections
5.08 and 5.09. Through the Wholesale Revenue Requirement, the Wholesale Customers pay Existing System Asset capital costs and operating expenses in accordance with Section 5.02.F and do not pay capital costs or operating expenses associated with assets classified as Direct Retail, Power-Only, and the Power-Related portion of Joint assets.
C. Attachment R Documents Classifications. To facilitate WSA administration, Attachment R documents the classification of major Existing System Assets operated by the Hetch Hetchy Enterprise. Attachment R consists of three documents: R-1 Introduction, R-2 Special Classification of Discrete Projects for 2018 Amendment Purposes, and R-3 Major Hetch Hetchy Enterprise Existing System Assets. Attachment R may be modified as specified in Section 5.11.D and in the manner set forth in Section 2.03.C.
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D. Attachment R-3, Major Hetch Hetchy Enterprise Existing System Assets, is Not Exhaustive. Existing System Assets include, but are not limited to, land; fixed infrastructure such as dams, tunnels, buildings, water treatment plants and pipelines; equipment such as pumps and vehicles; and related appurtenances. Major Hetch Hetchy Enterprise Existing System Assets, and their classifications, are listed in Attachment R-3. Attachment R-3 does not include all assets of the Regional Water System, but represents the parties' best efforts to document major Hetch Hetchy Enterprise Existing System Assets that would incur capital costs and operating expenses subject to cost allocation. The classification of assets listed on R-3 may not be changed during the Term, any Extension Term, and any renewal of the Agreement, however, Attachment R-3 may be modified by mutual agreement in accordance with Section
2.03.C to (1) add an asset that was inadvertently omitted, (2) to add a new asset, and (3) remove a destroyed or obsolete asset. In the event that the parties cannot agree on the classification of any omitted or new assets, the dispute shall be subject to arbitration under Section 8.01.
E. Attachment R-3, Major Hetch Hetchy Enterprise Existing System Assets, Classifications are Fixed. The classification of the major Hetch Hetchy Enterprise Existing System Assets is fixed and shall control the allocation of capital costs and operating expenses for the remainder of the Term, any Extension Terms, and any renewal of the Agreement.
However, changes may be proposed in accordance with subsection G below. Capital costs and operating expenses are meant to be inclusive of all costs related to assets, including, but not limited to, any alterations, additions, improvements, rehabilitation, replacement of assets, and equipment that is appurtenant thereto. Since asset classifications are fixed in Attachment R-3, asset classifications may not be modified by mutual agreement in accordance with Section
2.03.C.
F. Attachment R-2, Special Classification of Discrete Projects for 2018 Amendment Purposes. Past, ongoing and future capital projects involving five Hetch Hetchy Enterprise Existing System Assets defined in Attachment R-2 have classifications that differ from the underlying asset classifications. These project-related classification changes shown on Attachment R-2, are part of the 2018 amendments to the Agreement and are not precedential for any other asset-related capital cost or operating expense. With the exception of the defined projects related to the five assets listed on R-2, the capital projects for all assets follow the asset classifications. Capital projects listed on Attachment R-2 must be approved by the SFPUC following necessary CEQA review.
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G. Five Year Notice of Intent to Renegotiate Cost Allocation. In the event San Francisco or the Wholesale Customers, which may be represented by BAWSCA, wish to propose and negotiate a change in Existing System Asset classifications, or a change in the Water-Related portion (45 percent) of Joint expenses, for the next Water Supply Agreement, such party must provide the other at least 5 years' written notice prior to the expiration of the Term or Extension Term, or the renewal of the Agreement. At a minimum, the noticing party must provide a comprehensive analysis of the financial and rate impacts of the proposed change at least two years prior to the expiration of the Term or Extension Term, or the renewal of the Agreement.
To meet this requirement, the parties may agree to jointly analyze, under a separate agreement, system capacity and usage and/or new assets, as well as other possible alternative cost allocation methodologies. Either party may also unilaterally initiate such studies by consultants of their choice and bear all their own costs.
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Article 6. Integration of Wholesale Revenue Requirement with SFPUC Budget Development and Rate Adjustments
6.01. General
A. The purpose of the allocation bases set forth in Article 5 is to determine the Wholesale Revenue Requirement for each fiscal year. The Wholesale Revenue Requirement can only be estimated in advance, based on projected costs and water deliveries. These projections are used to establish water rates applicable to the Wholesale Customers.
B. After the close of each fiscal year, the procedures described in Article 7 will be used to determine the actual Wholesale Revenue Requirement for that year, based on actual costs incurred, allocated according to the provisions of Article 5, and using actual water delivery data. The amount properly allocated to the Wholesale Customers shall be compared to the amount billed to the Wholesale Customers for the fiscal year, other than those identified in Section 5.10.C. The difference will be entered into a balancing account to be charged to, or credited to, the Wholesale Customers, as appropriate.
C. The balancing account shall be managed as described in Section 6.05.
6.02. Budget Development
The SFPUC General Manager will send a copy of the proposed SFPUC budget to BAWSCA at the same time as it is sent to the Commission. In addition, a copy of materials submitted to the Commission for consideration at meetings prior to the meeting at which the overall SFPUC budget is considered (including (a) operating budgets for the Water Enterprise and the Hetch Hetchy Enterprise, (b) budgets for SFPUC Bureaus, and (c) capital budgets for the Water Enterprise and the Hetch Hetchy Enterprise) will also be sent to BAWSCA concurrently with their submission to the Commission.
6.03. Rate Adjustments
A. Budget Coordinated Rate Adjustments. Adjustments to the rates applicable to the Wholesale Customers shall be coordinated with the budget development process described in this section except to the extent that Sections 6.03.B and 6.03.C authorize emergency rate increases and drought rate increases, respectively.
If the SFPUC intends to increase wholesale water rates during the ensuing fiscal year, it will comply with the following procedures:
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1. Adjustments to the wholesale rates will be adopted by the Commission at a regularly scheduled meeting or at special meeting, properly noticed, called for the purpose of adjusting rates or for taking any other action under the jurisdiction of the Commission.
2. The SFPUC will send a written notice by mail or electronic means to each Wholesale Customer and to BAWSCA of the recommended adjustment at least thirty (30) days prior to the date of the meeting at which the Commission will consider the proposed adjustment.
The notice will include the date, time and place of the Commission meeting.
3. The SFPUC shall prepare and provide to each Wholesale Customer and to BAWSCA the following materials: (a) a table illustrating how the increase or decrease in the Wholesale Revenue Requirement and wholesale rates were calculated, substantially in the form of Attachment N-1, (b) a schedule showing the projected expenses included in the Wholesale Revenue Requirement for the fiscal year for which the rates are being proposed, and supporting materials, substantially in the form of Attachment N-2, and (c) a schedule showing projected water sales, Wholesale Revenue Requirements and wholesale rates for the fiscal year for which rates are being set and the following four years, substantially in the form of Attachment N-3.
These materials will be included with the notification required by Section 6.03.A.2.
4. Rate adjustments will be effective no sooner than thirty (30) days after adoption of the wholesale rate by the Commission.
5. San Francisco will use its best efforts to provide the Wholesale Customers with the information described above. San Francisco's failure to comply with the requirements set forth in this section shall not invalidate any action taken by the Commission (including, but not limited to, any rate increase or decrease adopted). In the event of such failure, the Wholesale Customers may either invoke arbitration, as set forth in Section 8.01, or seek injunctive relief, to compel San Francisco to remedy the failure as soon as is reasonably practical, and San Francisco shall be free to oppose the issuance of the requested judicial or arbitral relief on any applicable legal or equitable basis. The existence of this right to resort to arbitration shall not be deemed to preclude the right to seek injunctive relief.
6. Because delays in the budget process or other events may cause San Francisco to defer the effective date of Wholesale Customer rate adjustments until after the beginning of San Francisco's fiscal year, nothing contained in this Agreement shall require San Francisco to make any changes in the water rates charged to Wholesale Customers effective at
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the start of San Francisco's fiscal year or at any other specific date. Nothing in the preceding sentence shall excuse non-compliance with the provisions of Section 6.02 and this section.
B. Emergency Rate Increases. The Commission may adjust the Wholesale Customers’ rates without complying with the requirements of Section 6.03.A in response to an Emergency that damages the Regional Water System and disrupts San Francisco’s ability to maintain normal deliveries of water to Retail and Wholesale Customers. In such an Emergency, the Commission may adopt an emergency rate surcharge applicable to Wholesale Customers without following the procedures set forth in this section, provided that any such rate surcharge imposed by the Commission shall be applicable to both Retail and Wholesale Customers and incorporate the same percentage increase for all customers. Any emergency rate surcharge adopted by the Commission shall remain in effect only until the next-budget coordinated ratesetting cycle.
C. Drought Rates. If the Commission declares a water shortage emergency under Water Code Section 350, implements the Tier 1 Shortage Plan (Attachment H) described in Section 3.11.C, and imposes drought rates on Retail Customers, it may concurrently adjust wholesale rates independently of coordination with the annual budget process. Those adjustments may be designed to encourage water conservation and may constitute changes to the structure of the rates within the meaning of Section 6.04. The parties agree, however, that, in adopting changes in rates in response to a declaration of water shortage emergency, the Commission shall comply with Section 6.03.A.1 and 2 but need not comply with Section 6.04.B.
Drought Rate payments and payments of excess use charges levied in accordance with the Tier 1 Shortage Plan described in Section 3.11.C constitute Wholesale Customer Revenue and count towards the Wholesale Revenue Requirement. The SFPUC may use these revenues to purchase additional water for the Wholesale Customers from the State Drought Water Bank or other willing seller.
6.04. Rate Structure
A. This Agreement is not intended and shall not be construed to limit the Commission’s right (a) to adjust the structure of the rate schedule applicable to the Wholesale Customers (i.e., the relationship among the several charges set out therein) or (b) to add, delete, or change the various charges which make up the rate schedule, provided that neither such charges nor the structure of the rate schedule(s) applicable to the Wholesale Customers shall be arbitrary, unreasonable, or unjustly discriminatory as among said customers. The
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SFPUC will give careful consideration to proposals for changes in the rate schedule made jointly by the Wholesale Customers but, subject to the limitations set out above, shall retain the sole and exclusive right to determine the structure of the rate schedule.
B. If the SFPUC intends to recommend that the Commission adopt one or more changes to the structure of wholesale rates (currently set forth in SFPUC Rate Schedule W-25), it shall prepare and distribute to the Wholesale Customers and BAWSCA a report describing the proposed change(s), the purpose(s) for which it/they are being considered, and the estimated financial effect on individual Wholesale Customers or classes of customers. Wholesale Customers may submit comments on the report to the SFPUC for sixty (60) days after receiving the report. The SFPUC will consider these comments and, if it determines to recommend that the Commission adopt the change(s), as described in the report or as modified in response to comments, the SFPUC General Manager shall submit a report to the Commission recommending specific change(s) in the rate structure. Copies of the General Manager’s report shall be sent to all Wholesale Customers and BAWSCA at least thirty (30) days prior to the Commission meeting at which the changes will be considered.
C. The SFPUC may recommend, and the Commission may adopt, changes in the structure of wholesale rates at any time. However, the new rate schedule implementing these changes will become effective at the beginning of the following fiscal year.
6.05. Balancing Account
A. Balancing Account Established Under 1984 Agreement. The amount of credit in favor of San Francisco as of the expiration of the term of 1984 Agreement (June 30, 2009) is not known with certainty as of preparation and execution of this Agreement. It will not be known with certainty until the Compliance Audit for FY 2008-09 is completed and disputes, if any, that the Wholesale Customers or the SFPUC may have with the calculation of the Suburban Revenue Requirement for that fiscal year and for previous fiscal years have been settled or decided by arbitration.
The parties anticipate that the amount of the credit in favor of San Francisco as of June 30, 2009 may be within the range of $15 million to $20 million.
In order to reduce the credit balance due San Francisco under the 1984 Agreement in an orderly manner, while avoiding unnecessary fluctuations in wholesale rates, the parties agree to implement the following procedure.
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1. In setting wholesale rates for FY 2009-10, SFPUC will include a balancing account repayment of approximately $2 million.
2. In setting wholesale rates for FY 2010-11 and following years, SFPUC will include a balancing account repayment of not less than $2 million and not more than $5 million annually until the full amount of the balance due, plus interest at the rate specified in Section
6.05.B, is repaid.
3. The actual ending balance as of June 30, 2009 will be determined, by the parties’ agreement or arbitral ruling, after the Compliance Audit report for FY 2008-09 is delivered to BAWSCA. That amount, once determined, will establish the principal to be amortized through subsequent years’ repayments pursuant to this Section 6.05.A.
B. Balancing Account Under This Agreement
1. Operation. After the close of each fiscal year, the SFPUC will compute the costs allocable to the Wholesale Customers for that fiscal year pursuant to Article 5, based on actual costs incurred by the SFPUC and actual amounts of water used by the Wholesale Customers and the Retail Customers. That amount will be compared to the amounts billed to the Wholesale Customers for that fiscal year (including any Excess Use Charges, but excluding revenues described in Section 5.10.C). The difference will be posted to a “balancing account” as a credit to, or charge against, the Wholesale Customers. Interest shall also be posted to the balancing account calculated by multiplying the amount of the opening balance by the average net interest rate, certified by the Controller as earned in the San Francisco Treasury for the previous fiscal year on the San Francisco County Pooled Investment Account. Interest, when posted, will carry the same mathematical sign (whether positive or negative) as carried by the opening balance. The amount posted to the balancing account in each year shall be added to, or subtracted from, the balance in the account from previous years. The calculation of the amount to be posted to the balancing account shall be included in the report prepared by the SFPUC pursuant to Section 7.02.
The opening balance for fiscal year 2009-10 shall be zero.
2. Integration of Balancing Account with Wholesale Rate Setting Process. If the amount in the balancing account is owed to the Wholesale Customers (a positive balance), the SFPUC shall take it into consideration in establishing wholesale rates. However, the SFPUC need not apply the entire amount to reduce wholesale rates for the immediately ensuing
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year. Instead, the SFPUC may prorate a positive ending balance over a period of up to three successive years in order to avoid fluctuating decreases and increases in wholesale rates. a. If a positive balance is maintained for three successive years and represents 10 percent or more of the Wholesale Revenue Requirement for the most recent fiscal year, the SFPUC shall consult with BAWSCA as to the Wholesale Customers’ preferred application of the balance. The Wholesale Customers shall, through BAWSCA, direct that the positive balance be applied to one or more of the following purposes: (a) transfer to the Wholesale Revenue Coverage Reserve, (b) amortization of any remaining negative balance from the ending balancing account under the 1984 Agreement, (c) prepayment of the existing asset balance under Section 5.03, (d) water conservation or water supply projects administered by or through BAWSCA, (e) immediate reduction of wholesale rates, or (f) continued retention for future rate stabilization purposes. In the absence of a direction from BAWSCA, the SFPUC shall continue to retain the balance for rate stabilization in subsequent years. b. If the amount in the balancing account is owed to the SFPUC (a negative balance), the SFPUC shall not be obligated to apply all or any part of the negative balance in establishing wholesale rates for the immediately ensuring year. Instead, the SFPUC may prorate the negative balance in whole or in part over multiple years in order to avoid fluctuating increases and decreases in wholesale rates.
6.06. Wholesale Revenue Coverage Reserve
A. The SFPUC may include in wholesale rates for any fiscal year an additional dollar amount (“Wholesale Revenue Coverage”), which for any fiscal year shall equal the following:
1. The lesser of (i) 25% of the Wholesale Customers’ share of Net Annual Debt Service for that fiscal year determined as described in Section 5.04.A, or (ii) the amount necessary to meet the Wholesale Customers’ proportionate share of Debt Service coverage required by then-current Indebtedness for that fiscal year, minus
2. A credit for (i) the actual amounts previously deposited in the “Wholesale Revenue Coverage Reserve” (as defined in subsection B below), (ii) accrued interest on the amounts on deposit in the Wholesale Revenue Coverage Reserve, and (iii) an amount equal to any additional interest that would have accrued on the actual amounts previously deposited in the Wholesale Revenue Coverage Reserve assuming no withdrawals had been made therefrom.
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B. During each fiscal year, the SFPUC will set aside and deposit that portion of revenue equal to Wholesale Revenue Coverage into a separate account that the SFPUC will establish and maintain, to be known as the “Wholesale Revenue Coverage Reserve.” Deposits into the Wholesale Revenue Coverage Reserve shall be made no less frequently than monthly.
The Wholesale Revenue Coverage Reserve shall be credited with interest at the rate specified in Section 6.05.B. The SFPUC may use amounts in the Wholesale Revenue Coverage Reserve for any lawful purpose. Any balance in the Wholesale Revenue Coverage Reserve in excess of the Wholesale Revenue Coverage amount as of the end of any fiscal year (as calculated in subsection 6.06(A) above) shall be applied as a credit against wholesale rates in the immediately following fiscal year unless otherwise directed by BAWSCA.
C. Within 180 days following the later of expiration of the Term or final payment of Debt Service due on Indebtedness issued during the Term to which Wholesale Customers were contributing, SFPUC shall rebate to the Wholesale Customers an amount equal to the Wholesale Revenue Coverage amount in effect for the fiscal year during which the Term expires or the final payment of Debt Service on Indebtedness is made based on each Wholesale Customer’s Proportional Annual Use in the fiscal year during which the Term expires or the final payment of debt service on Indebtedness is made.
D. SFPUC shall provide a schedule of debt issuance (with assumptions), and the Wholesale Customers’ share of Net Annual Debt Service (actual and projected) expected to be included in wholesale rates starting in 2009-10 through the expected completion of the WSIP.
The schedule is to be updated annually prior to rate setting. If estimated Debt Service is used in rate setting, the SFPUC must be able to demonstrate that the Water Enterprise revenues will be sufficient to meet the additional bonds test for the proposed bonds and rate covenants for the upcoming year.
E. Conditions in the municipal bond market may change from those prevailing in 2009. If, prior to expiration of the Term, the SFPUC determines that it would be in the best financial interest of both Retail Customers and Wholesale Customers of the Regional Water System for the Debt Service coverage requirement to be increased in one or more series of proposed new Indebtedness above 1.25%, or for the coverage covenant to be strengthened in other ways, it will provide a written report to BAWSCA. The report will contain (1) a description of proposed covenant(s) in the bond indenture; (2) an explanation of how savings are expected to be achieved (e.g., increase in the SFPUC’s credit rating over the then-current level; ability to
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obtain credit enhancement, etc.); (3) the estimated all-in true interest cost savings; (4) a comparison of the Wholesale Revenue Requirements using the Debt Service coverage limitation in subsection A and under the proposed methodology; and (5) a comparison of the respective monetary benefits expected to be received by both Retail and Wholesale Customers.
The SFPUC and BAWSCA agree to meet and confer in good faith about the proposed changes.
F. Any increase in Debt Service coverage proposed by the SFPUC shall be commensurate with Proportional Water Use by Retail and Wholesale Customers. If the SFPUC demonstrates that an increase in Debt Service coverage will result in equivalent percentage reductions in total Wholesale and Retail Debt Service payments over the life of the proposed new Indebtedness, based on Proportional Water Use, BAWSCA may agree to a modification of the Wholesale Revenue Coverage requirement in subsection A. If BAWSCA does not agree to a proposed modification in coverage requirements in the covenants for new Indebtedness, SFPUC may nevertheless proceed with the modification and the issuance of new Indebtedness.
Any Wholesale Customer, or BAWSCA, may challenge an increase in the Wholesale Revenue Requirement resulting from the modification in Debt Service coverage through arbitration as provided in Section 8.01.A. If the arbitrator finds that the increase in Debt Service coverage (1) did not and will not result in equivalent percentage reductions in total Wholesale and Retail Debt Service payments over the life of the proposed new Indebtedness, based on Proportional Water Use, or (2) was not commensurate with Proportional Water Use, the arbitrator may order the Wholesale Revenue Requirement to be recalculated both retrospectively and prospectively to eliminate the differential impact to Wholesale or Retail Customers, subject to the limitation in Section 8.01.C.
6.07. Working Capital Requirement
A. The SFPUC maintains working capital in the form of unappropriated reserves for the purpose of bridging the gap between when the SFPUC incurs operating expenses required to provide service and when it receives revenues from its Retail and Wholesale Customers.
The Wholesale Customers shall fund their share of working capital as part of the annual Wholesale Revenue Requirement calculation. The amount of wholesale working capital for which the Wholesale Customers will be responsible will be determined using the 60-day standard formula approach.
B. Applying this approach, annual wholesale working capital equals one-sixth of the wholesale allocation of operation and maintenance, administrative and general, and property tax
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expenses for the Water and Hetch Hetchy Enterprises. Wholesale working capital shall be calculated separately for the Water and Hetch Hetchy Enterprises.
C. Each month, the sum of the Water Enterprise and Hetch Hetchy Enterprise working capital components will be compared with the ending balance in the Wholesale Revenue Coverage Reserve to determine if the Wholesale Customers provided the minimum required working capital. If the Wholesale Revenue Coverage Reserve is greater than the total Water Enterprise and Hetch Hetchy Enterprise working capital requirement, the Wholesale Customers will have provided their share of working capital. If the Wholesale Revenue Coverage Reserve is less than the total Water Enterprise and Hetch Hetchy Enterprise working capital requirement, the Wholesale Customers will be charged interest on the difference, which will be included in the adjustment to the Balancing Account under Section 6.05.B for the subsequent fiscal year.
6.08. Wholesale Capital Fund
A. The SFPUC currently funds revenue-funded capital projects through annual budget appropriations that are included in rates established for that fiscal year and transferred to a capital project fund from which expenditures are made. Consistent with the San Francisco Charter and Administrative Code, the SFPUC appropriates funds in advance of construction in order to maintain a positive balance in the capital project fund. The capital project fund also accrues interest and any unspent appropriations in excess of total project costs. It is the SFPUC’s practice to regularly monitor the capital project fund balance to determine whether a surplus has accumulated, which can be credited against the next fiscal year’s capital project appropriation.
B. The SFPUC shall establish a comparable Wholesale Revenue-Funded Capital Fund (Wholesale Capital Fund) to enable the Wholesale Customers to fund the wholesale share of revenue-funded New Regional Assets. The Wholesale Capital Fund balance is zero as of July 1, 2009. The SFPUC may include in wholesale rates for any fiscal year an amount equal to the wholesale share of the SFPUC’s appropriation for revenue funded New Regional Assets for that year, which sum will be credited to the Wholesale Capital Fund. The wholesale share of other sources of funding, where legally permitted and appropriately accounted for under GAAP, will also be credited to the Wholesale Capital Fund, together with interest earnings on the Wholesale Capital Fund balance.
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C. The SFPUC will expend revenues appropriated and transferred to the Wholesale Capital Fund only on New Regional Assets. The annual capital appropriation included in each fiscal year’s budget will be provided to BAWSCA in accordance with Section 6.02 and will take into account the current and projected balance in the Wholesale Capital Fund, as well as current and projected unexpended and unencumbered surplus, as shown on attachment M-1, which will be prepared by the SFPUC each year.
D. Commencing on November 30, 2010 and thereafter in each fiscal year during the Term, the SFPUC will also provide an annual report to BAWSCA on the status of individual revenue-funded New Regional Assets, substantially in the form of Attachment M-2.
E. In order to prevent the accumulation of an excessive unexpended and unencumbered balance in the Wholesale Capital Fund, the status of the fund balance will be reviewed through the annual Compliance Audit, commencing in FY 2018-19. The FY 2018-19 Compliance Audit and the Wholesale Customer/BAWSCA review under Section 7.06 shall include Wholesale Capital Fund appropriations, expenditures and interest earnings for FY 2014- 15 through 2017-18 for the purpose of determining whether a Balancing Account transfer is required. If the June 30 unencumbered balance of the Wholesale Capital Fund exceeds the lesser of the following: (i) the Target Balance; (ii) the unencumbered remaining cumulative appropriations, the amount of such excess shall be transferred to the credit of the Wholesale Customers to the Balancing Account described in Section 6.05.
In order to avoid funding delays for New Regional Asset capital projects resulting from prior year transfers of excess Wholesale Capital fund balances to the Wholesale Customers, if the June 30 unencumbered balance of the Wholesale Capital Fund is below the lesser of the following: (i) the Target Balance; (ii) the unencumbered remaining cumulative appropriation, such deficiency shall be posted to the Balancing Account described in Section 6.05 as a charge to the Wholesale Customers. Notwithstanding the foregoing, no such charge to the Wholesale Customers shall exceed $4 million annually.
Amended Attachment M-3 illustrates the process for determining the Wholesale Capital Fund balance as of June 30, 2019.
F. Three years prior to the end of the Term, the SFPUC and BAWSCA will discuss the disposition of the Wholesale Capital Fund balance at the end of the Term. Absent
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agreement, any balance remaining in the Wholesale Capital Fund at the end of the Term shall be transferred to the Balancing Account, to the credit of the Wholesale Customers.
6.09. SFPUC Adoption of Regional Water System 10-Year Capital Improvement Program A. Established Level of Service Goals and Objectives. In approving the WSIP, the Commission adopted Level of Service Goals and Objectives that are, in part, used to develop capital programs related to water, including the 10-Year Capital Improvement Program for the Regional Water System (“10-Year CIP”). BAWSCA and the Wholesale Customers shall have the opportunity to review and provide written or oral comments on any changes to the Level of Service Goals and Objectives that may be submitted to the Commission for approval.
B. Submittal of an Asset Management Policy. Prior to December 31, 2020, the SFPUC shall develop and submit to the Commission for approval an Asset Management Policy applicable to the Regional Water System.
C. Coordination of 10-Year CIP and SFPUC Budget Meetings. The Commission annually reviews, updates, and adopts a 10-Year CIP pursuant to Section 8B.123 of the San Francisco Charter. At two-year intervals, the Commission holds two budget meetings concerning the 10-Year CIP. Over the course of the two budget meetings, the SFPUC reviews its budget priorities, potential changes to projects in the previously adopted 10-Year CIP, and the potential financial implications of such changes. In the event that Charter amendments are placed on the ballot that could alter or amend the City’s budget preparation and adoption efforts, BAWSCA shall be notified in advance of any proposed change that could result in a less robust CIP development effort, and BAWSCA and the SFPUC shall meet to consider BAWSCA’s comments on maintaining a robust CIP development effort.
D. Mid-cycle Changes to the 10-Year CIP. The SFPUC shall include within the Water Enterprise Capital Improvement Program Quarterly Projects Reports that it provides to the Commission (“CIP Quarterly Projects Reports”) discussion of any material changes proposed to projects that are included in the most recently adopted 10-Year CIP. The SFPUC defines a material change as a change that applies to a CIP project whose approved CIP budget is equal to or greater than $5,000,000 that results in one or more of the following:
1. Increases the cost of the CIP project by more than 10%.
2. Increases the schedule of the CIP project by extending said schedule by 12 calendar months or greater.
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3. Affects the SFPUC’s ability to meet the Level of Service Goals and Objectives.
The SFPUC shall also include within the CIP Quarterly Projects Reports discussion of any new capital project that is not included in the most recently adopted 10-Year CIP if the SFPUC has 1) begun spending on the project and 2) anticipates that it will require total funding in excess of $5,000,000. For such projects, the parties recognize that the work may be of an urgent nature and that details of those projects may be developing quickly to address a critical need. The SFPUC commits that, for these projects, an expanded discussion will be provided in quarterly reports generated 6 months following the creation of the project in the City’s finance and accounting system. At a minimum, the discussion will include: 1) a detailed scope of work, 2) schedule, 3) cost breakdown, and 4) proposed source of funding. This level of detail shall continue to be included in subsequent quarterly reports through either the completion of the work or until the work is included as part of an adopted 10-Year CIP.
E. BAWSCA and Wholesale Customer Notice and Review. Beginning in 2020, at least 30 days before the first budget meeting, the SFPUC shall provide BAWSCA and the Wholesale Customers with written notice of the dates of the two budget meetings. At least 30 days before the first budget meeting, the SFPUC shall also provide BAWSCA and the Wholesale Customers with a draft of the 10-Year CIP and meet with those same parties to review potential candidate projects that it is considering for inclusion in the 10-Year CIP. Final materials for the first budget meeting will be made available to BAWSCA and the Wholesale Customers no less than 14 days prior to that budget meeting. Final materials for the second budget meeting will be made available to BAWSCA and the Wholesale Customers on the same date that they are made available to the Commission. Prior to the Commission’s adoption of the 10-Year CIP at the second budget meeting, San Francisco shall respond, in writing, to all written comments by BAWSCA and the Wholesale Customers on the 10-Year CIP that were submitted prior to the date of the first budget meeting.
F. Contents of Draft 10-Year CIP – Projects in Years One and Two of 10-Year Schedule. The SFPUC’s CIP projects generally fall into three categories: defined projects, placeholder concepts that could become projects, and programmatic spending for expenses likely to be made but for which there is no schedule. Projects in the near-term years of the 10- Year CIP have more definition than those in the outer years, and as a result more detailed information is available for them. For each project listed that has significant expected
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expenditures identified in the first two years of the 10-Year CIP, the draft 10-Year CIP made available to BAWSCA and the Wholesale Customers shall include the following elements:
1. Project name.
2. Project description and justification.
3. Description of the project’s relationship to the Level of Service Goals and Objectives.
4. Project asset classification for cost-allocation purposes, pursuant to Attachment R for Hetch Hetchy Enterprise assets, or as Regional or Retail for Water Enterprise assets.
5. Project schedule where applicable, broken down by phase, through to completion.
6. Total project budget estimate including a proposed inflation rate.
G. Contents of Draft 10-Year CIP – Projects Listed After First Two Years of 10- Year Schedule. For each project that is listed in years three through ten of the 10-Year CIP, the draft 10-Year CIP made available to BAWSCA and the Wholesale Customers shall include the following elements:
1. Project name.
2. Project description and justification.
3. Description of the project’s relationship to the Level of Service Goals and Objectives.
4. Project asset classification for cost-allocation purposes, pursuant to Attachment R for Hetch Hetchy Enterprise assets, or as Regional or Retail for Water Enterprise assets.
5. Project schedule information that forms the basis for project planning if available.
6. Total project budget estimate.
H. Additional Contents of Draft 10-Year CIP. The draft 10-Year CIP made available to BAWSCA and the Wholesale Customers shall also include the following:
1. A discussion of any changes to projects in the previously adopted 10- Year CIP, the reasons for such changes, any impact of the proposed changes on the SFPUC’s ability to achieve the Level of Service Goals
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and Objectives, and the SFPUC’s proposal for meeting the specific Level of Service Goals and Objectives in question.
2. A discussion of factors that have influenced the 10-Year CIP budget or identified projects, or have the potential to influence the overall budget or the number, cost and scale of identified projects, such as rate increase considerations, local rate setting policies, etc.
3. A discussion of how the CIP will be staffed.
4. A cash flow estimate for each project included as part of the first five years of the 10-Year CIP that considers historical spending and changes in the amount of work to be done.
5. Project spreadsheets that separate new projects from existing projects.
6. A summary roll-up for Regional costs, including all programmatic costs budgeted in the 10-Year CIP.
I. Quarterly Reporting and Meetings.
1. CIP Quarterly Projects Reports. The SFPUC shall include within the CIP Quarterly Projects Reports a detailed status update of each Regional project in the 10-Year CIP that has an estimated cost greater than $5 million and a summary of the work completed to date for such projects. The CIP Quarterly Projects Reports shall focus on the first two years’ projects in the 10-Year CIP, but shall also demonstrate a connection to the 10-Year CIP asset classification and the Level of Service Goals and Objectives. The CIP Quarterly Projects Reports shall identify any Regional project in the 10-Year CIP with an estimated cost greater than $5 million that is behind schedule, and, for each project so identified, shall describe the SFPUC’s plan and timeline for either making up the delay or adopting a revised project schedule. In each fourth quarter of the fiscal year CIP Quarterly Projects Report, the SFPUC will also address the status of Regional projects in the 10-Year CIP that have an estimated cost of less than $5 million, noting any such projects that are behind schedule and describing the SFPUC’s plan and timeline for either making up the delay or adopting a revised project schedule.
2. Quarterly Meetings. If requested by BAWSCA, the SFPUC shall hold quarterly meetings with BAWSCA to review each CIP Quarterly Projects Report, during which the SFPUC shall present information and detail about the individual projects and overall implementation of the 10-Year CIP, as well as the need for re-prioritization and/or the proposal
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of new candidate projects for consideration as part of the next update of the 10-Year CIP. As part of the meeting held in each fourth quarter of the fiscal year, the SFPUC shall provide additional information and detail regarding the CIP development schedule and associated coordination proposed with BAWSCA.
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Article 7. Accounting Procedures; Compliance Audit
7.01. SFPUC Accounting Principles, Practices
A. Accounting Principles. San Francisco will maintain the accounts of the SFPUC and the Water and Hetch Hetchy Enterprises in conformity with Generally Accepted Accounting Principles. San Francisco will apply all applicable pronouncements of the Governmental Accounting Standards Board (GASB) as well as statements and interpretations of the Financial Accounting Standards Board and Accounting Principles Board opinions issued on or before March 30, 1989, unless those pronouncements or opinions conflict with GASB pronouncements.
B. General Rule. San Francisco will maintain the accounting records of the SFPUC and the Water and Hetch Hetchy Enterprises in a format and level of detail sufficient to allow it to determine the annual Wholesale Revenue Requirement in compliance with this Agreement and to allow its determination of the Wholesale Revenue Requirement to be audited as provided in Section 7.04.