San Clemente City Council
June 16, 2026

in collaboration with and
2025 Water Shortage
Contingency Plan
FINAL DRAFT / May 2026
Exhibit A
2025 Water Shortage Contingency Plan
May 2026 / FINAL DRAFT
Prepared By: Prepared For:

Carollo Engineers, Inc. City of San Clemente
707 Wilshire Boulevard, Suite 3920 910 Calle Negocio
Los Angeles, California 90017 San Clemente, California 92673 Phone: 213.489.1587 Phone: 949.361.8200
https://www.carollo.com https://www.sanclemente.gov
In collaboration with:
2025 WATER SHORTAGE CONTINGENCY PLAN
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pw://Carollo/CA/MWDOC/204447-000000/03 Reports and Studies/02 Deliverables/Grp4_San Clemente UWMP/SanClemente_2025 WSCP.docx Contents
SECTION 1 INTRODUCTION AND WSCP OVERVIEW 1

1.1 Water Shortage Contingency Plan Requirements and Organization 1

1.2 Integration with Other Planning Efforts 2
SECTION 2 BACKGROUND INFORMATION 3

2.1 City Service Area 3

2.2 Relationship to Wholesalers 4

2.3 Relationship with Wholesaler Water Shortage Planning 6

2.3.1 MET Water Surplus and Drought Management Plan 6

2.3.2 MET Water Supply Allocation Plan 8

2.3.3 MWDOC Water Supply Allocation Plan 9
SECTION 3 WATER SHORTAGE CONTINGENCY PREPAREDNESS AND
RESPONSE PLANNING 10

3.1 Water Supply Reliability Analysis 10

3.2 Annual Water Supply and Demand Assessment Procedures 11

3.2.1 Decision-Making Process 11

3.2.2 Data and Methodologies 12

3.3 Six Standard Water Shortage Levels 16

3.4 Shortage Response Actions 17

3.4.1 Supply Augmentation 17

3.4.2 Demand Reduction 18

3.4.3 Operational Changes 18

3.4.4 Additional Mandatory Restrictions 18

3.4.5 Emergency Response Plan (Hazard Mitigation Plan) 18

3.4.6 Seismic Risk Assessment and Mitigation Plan 20

3.4.7 Shortage Response Action Effectiveness 20

3.5 Communication Protocols 21

3.6 Compliance and Enforcement 21

3.7 Legal Authorities 22

3.8 Financial Consequences of WSCP 22

3.9 Monitoring and Reporting 24

3.10 WSCP Refinement Procedures 24

3.11 Special Water Feature Distinction 25

3.12 Plan Adoption, Submittal, and Availability 25
SECTION 4 REFERENCES 26
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Appendices

APPENDIX A DWR SUBMITTAL TABLES
APPENDIX B SAN CLEMENTE MUNICIPAL CODE CHAPTER 13.12 WATER CONSERVATION AND WATER

SUPPLY SHORTAGE PROGRAM

APPENDIX C NOTICE OF PUBLIC HEARING (PENDING)

APPENDIX D ADOPTED WSCP RESOLUTION (PENDING)
Tables
Table 1 Cross-Reference for Standard vs Supplier Shortage Levels 17 Table 2 Communication Protocols by Shortage Level 21
Table 3 Agency Contacts and Coordination Protocols 22
Table 4 Proposed Demand Management Rates (Fixed and Variable Rate Surcharges) as of January 1, 2020 23
Figures
Figure 1 City Service Area 4
Figure 2 Regional Location of the City of San Clemente and Other MWDOC Member Agencies 6
Figure 3 Resource Stages, Anticipated Actions, and Supply Declarations 7 Figure 4 AWSDA Reporting Timeline 12
Figure 5 Water Shortage Contingency Plan AWSDA Framework 13 2025 WATER SHORTAGE CONTINGENCY PLAN
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Abbreviations
% Percent
AF Acre-Feet
AWSDA Annual Water Supply and Demand Assessment
BPP Basin Production Percentage
City City of San Clemente
CMMS Computer Maintenance Management System
DDW Division of Drinking Water
DRA Drought Risk Assessment
DVL Diamond Valley Lake
DWR California Department of Water Resources
EOC Emergency Operations Center
EOP Emergency Operations Plan
FY Fiscal Year
IAWP Interim Agricultural Water Program
JRWSS Joint Regional Water Supply System
LHMP Local Hazard Mitigation Plan
M&I Municipal and Industrial
MCL Maximum Contaminant Level
MET Metropolitan Water District of Southern California
MWDOC Municipal Water District of Orange County
NIMS National Incident Management System
OC Basin Orange County Groundwater Basin
PFAS Per- and Polyfluoroalkyl Substances
PFOA Perfluorooctanoic Acid
PFOS Perfluorooctane Sulfanate
PPT Parts Per Trillion
Producers Groundwater Producers
RL Response Level
SCWD South Coast Water District
SEMS California Standardized Emergency Management System Supplier Urban Water Supplier
SWP State Water Project
UWMP Urban Water Management Plan
Water Code California Water Code
WEROC Water Emergency Response Organization of Orange County WSAP Water Supply Allocation Plan
WSCP Water Shortage Completion Plan
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WSDM Water Surplus and Drought Management Plan
WTP Water Treatment Plant
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SECTION 1 INTRODUCTION AND WSCP OVERVIEW
The Water Shortage Contingency Plan (WSCP) is a strategic planning document designed to prepare for and respond to water shortages. This WSCP complies with California Water Code (Water Code) Section 10632, which requires that every Urban Water Supplier (Supplier) shall prepare and adopt a WSCP as part of its Urban Water Management Plan (UWMP). This level of detailed planning and preparation is intended to help maintain reliable supplies and reduce the impacts of supply interruptions.

The WSCP is the City of San Clemente (City)’s operating manual that is used to prevent catastrophic service disruptions through proactive, rather than reactive, management. A water shortage, when the water supply available is insufficient to meet the normally expected customer water use at a given point in time, may occur due to a number of reasons, such as drought, climate change, and catastrophic events.

This WSCP provides a structured guide for the City to deal with water shortages, incorporating prescriptive information and standardized action levels, along with implementation actions in the event of a catastrophic supply interruption. This way, if and when shortage conditions arise, the City’s governing body, its staff, and the public can easily identify and efficiently implement pre-determined steps to manage a water shortage. A well-structured WSCP allows real-time water supply availability assessment and structured steps designed to respond to actual conditions, enabling efficient management of any shortage with predictability and accountability.

The WSCP also describes the City’s procedures for conducting an Annual Water Supply and Demand Assessment (AWSDA) that is required by Water Code Section 10632.1 and is to be submitted to the California Department of Water Resources (DWR) on or before July 1 of each year, or within 14 days of receiving final allocations from the State Water Project (SWP), whichever is later. The City’s 2025 WSCP is included as an appendix to its 2025 UWMP which will be submitted to DWR by July 1, 2026. However, while developed in conjunction with the UWMP, this WSCP is a standalone document and can be amended, as needed, without amending the UWMP. Furthermore, the Water Code does not prohibit a Supplier from taking actions not specified in its WSCP, if needed, without having to formally amend its UWMP or WSCP.

1.1 Water Shortage Contingency Plan Requirements and
Organization
The WSCP provides the steps and water shortage response actions to be taken in times of water shortage conditions. The WSCP has prescriptive elements, such as an analysis of water supply reliability; the water shortage response actions for each of the six standard water shortage levels that correspond to water shortage percentages ranging from 10 percent (%) to greater than 50%; an estimate of potential to close supply gap for each measure; protocols and procedures to communicate identified actions for any current or predicted water shortage conditions; procedures for an AWSDA; monitoring and reporting requirements to determine customer compliance; and reevaluation and improvement procedures for evaluating the WSCP.
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This WSCP is organized into three main sections, with Section 3 aligned with Water Code Section 16032 requirements:
 Section 1 Introduction and WSCP Overview gives an overview of the WSCP fundamentals.  Section 2 Background Information provides a background on the City’s water service area.  Section 3 Water Shortage Contingency Preparedness and Response Planning. » Section 3.1 Water Supply Reliability Analysis provides a summary of the water supply analysis and water reliability findings from the 2025 UWMP.
» Section 3.2 Annual Water Supply and Demand Assessment Procedures provides a description of procedures to conduct and approve the AWSDA.
» Section 3.3 Six Standard Water Shortage Stages explains the WSCP’s six standard water shortage levels corresponding to progressive ranges of up to 10, 20, 30, 40, 50, and more than 50% shortages.
» Section 3.4 Shortage Response Actions describes the WSCP’s shortage response actions that align with the defined shortage levels.
» Section 3.5 Communication Protocols addresses communication protocols and procedures to inform customers, the public, interested parties, and local, regional, and state governments, regarding any current or predicted shortages and any resulting shortage response actions. » Section 3.6 Compliance and Enforcement describes customer compliance, enforcement, appeal, and exemption procedures for triggered shortage response actions. » Section 3.7 Legal Authorities describes the legal authorities that enable the City to implement and enforce its shortage response actions.
» Section 3.8 Financial Consequences of the WSCP provides a description of the financial consequences of and responses for drought conditions.
» Section 3.9 Monitoring and Reporting describes monitoring and reporting requirements and procedures that ensure appropriate data is collected, tracked, and analyzed for purposes of monitoring customer compliance and to meet state reporting requirements. » Section 3.10 WSCP Refinement Procedures addresses reevaluation and improvement procedures for monitoring and evaluating the functionality of the WSCP. » Section 3.11 Special Water Feature Distinction provides a required definition for inclusion in a WSCP per the Water Code.
» Section 3.12 Plan Adoption, Submittal, and Availability describes the process the City followed to adopt its WSCP.

1.2 Integration with Other Planning Efforts
As a retail water supplier in Orange County, the City considered other key entities in the development of this WSCP, including the Municipal Water District of Orange County(MWDOC) (regional wholesale supplier), the Metropolitan Water District of Southern California (MET) (regional wholesaler for Southern California and the direct supplier of imported water to MWDOC), and South Coast Water District (SCWD) (operates the Joint Regional Water Supply System [JRWSS] for agencies in South Orange County). As a MWDOC member agency, the City also developed this WSCP with input from several coordination efforts led by MWDOC.
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Some of the key planning and reporting documents that were used to develop this WSCP are:
 MWDOC’s 2025 UWMP provides the basis for the projections of the imported supply availability over the next 25 years for the City’s service area.
 MWDOC’s 2025 WSCP provides a water supply availability assessment and structured steps designed to respond to actual conditions that will help maintain reliable supplies and reduce the impacts of supply interruptions.
 MWDOC’s 2023 Orange County Water Reliability Study is a planning document to help guide planning for future water supply reliability for water providers in Orange County and provide input on regional water supply issues for MET.
 2025 Orange County Water Demand Projection Model Technical Memorandum is a collaborative effort amongst MWDOC, OCWD, and all retail water suppliers in Orange County that developed water demand projections to produce regionally consistent forecasts across all Orange County water agencies.
 MET’s 2025 UWMP uses assumptions that fall within the plausible futures contemplated in MET’s Integrated Water Resources Plan to evaluate MET’s future imported water supply reliability.  MET’s 2025 WSCP provides a water supply availability assessment and guide for MET’s intended actions during water shortage conditions.
 City of San Clemente’s 2025 Local Hazard Mitigation Plan (LHMP) provides the basis for the seismic and other natural and natural disaster risk analysis of the water system facilities.  San Clemente Capital Improvement Program provides information on water infrastructure planning projects and plans to address any required water system improvements.

SECTION 2 BACKGROUND INFORMATION
The City is governed by a five-member City Council. Its Utilities Department is responsible for ensuring a safe and reliable means of water supply to City residents within its service area.

2.1 City Service Area
The City spans 18.5 square miles in South Orange County, bounded to the south by San Diego County, to the west by the Pacific Ocean and to the north and east by the Cities of Dana Point and San Juan Capistrano and portions of unincorporated area of Orange County. The City's water service area covers 14.7 square miles and excludes a small section in the northern portion of the City that is serviced by SCWD, and the inland community of Talega that is serviced by Santa Margarita Water District.

The City operates 16 pumping stations, 56 pressure reducing stations, one filtration plant, 14 local and two regional reservoirs, two wells and two systems for imported water supply, and manages a 232-mile water mains system with approximately 17,588 service connections. 2025 WATER SHORTAGE CONTINGENCY PLAN
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Figure 1 City Service Area

2.2 Relationship to Wholesalers
The Metropolitan Water District of Southern California: MET is the largest water wholesaler for domestic and municipal uses in California, serving approximately 19 million customers. MET wholesales imported water supplies to 26 member cities and water districts in six Southern California counties. Its service area covers the Southern California coastal plain, extending approximately 200 miles along the Pacific Ocean from the City of Oxnard in the north to the international boundary with Mexico in the south.

This encompasses 5,200 square miles and includes portions of Los Angeles, Orange, Riverside, San 2025 WATER SHORTAGE CONTINGENCY PLAN
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Bernardino, San Diego, and Ventura counties. Approximately 85% of the population from the aforementioned counties reside within MET's boundaries.

MET is governed by a Board of Directors comprised of 38 appointed individuals with a minimum of one representative from each of MET’s 26 member agencies. The allocation of directors and voting rights are determined by each agency’s assessed valuation. Each member of the Board shall be entitled to cast one vote for each ten million dollars ($10,000,000) of assessed valuation of property taxable for district purposes, in accordance with Section 55 of the Metropolitan Water District Act. Directors can be appointed through the chief executive officer of the member agency or by a majority vote of the governing board of the agency. Directors are not compensated by MET for their service.

MET is responsible for importing water into the region through its operation of the Colorado River Aqueduct and its contract with the State of California for SWP supplies. Member agencies receive water from MET through various delivery points and pay for service through a rate structure made up of volumetric rates, capacity charges and readiness to serve charges. Member agencies provide estimates of imported water demand to MET annually in April regarding the amount of water they anticipate they will need to meet their demands for the next five years.

The Municipal Water District of Orange County: In Orange County, MWDOC and the cities of Anaheim, Fullerton, and Santa Ana are MET member agencies that purchase imported water directly from MET.

Furthermore, MWDOC purchases both treated potable and untreated water from MET to supplement its retail agencies’ local supplies.

The City is one of MWDOC’s 27 member agencies purchasing imported water from MWDOC. The City’s location within MWDOC’s service area is shown in Figure 2. 2025 WATER SHORTAGE CONTINGENCY PLAN
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Figure 2 Regional Location of the City of San Clemente and Other MWDOC Member Agencies

2.3 Relationship with Wholesaler Water Shortage Planning The WSCP is designed to be consistent with MET’s Water Surplus and Drought Management (WSDM) Plan, MWDOC’s Water Supply Allocation Plan (WSAP), and other emergency planning efforts as described below. MWDOC’s WSAP is integral to the WSCP’s shortage response strategy in the event that MET or MWDOC determines that supply augmentation (including storage) and lesser demand reduction measures would not be sufficient to meet a projected shortage levels needed to meet demands.

2.3.1 MET Water Surplus and Drought Management Plan
MET evaluates the level of supplies available and existing levels of water in storage to determine the appropriate management stage annually. Each stage is associated with specific resource management actions to avoid extreme shortages to the extent possible and minimize adverse impacts to retail customers should an extreme shortage occur. The sequencing outlined in the WSDM Plan reflects anticipated responses towards MET’s existing and expected resource mix.

Surplus stages occur when net annual deliveries can be made to water storage programs. Under the WSDM Plan, there are four surplus management stages that provides a framework for actions to take for 2025 WATER SHORTAGE CONTINGENCY PLAN
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surplus supplies. Deliveries in Diamond Valley Lake (DVL) and in SWP terminal reservoirs continue through each surplus stage provided there is available storage capacity. Withdrawals from DVL for regulatory purposes or to meet seasonal demands may occur in any stage.

The WSDM Plan distinguishes between shortages, severe shortages, and extreme shortages. The differences between each term are listed below:
 Shortage: MET can meet full-service demands and partially meet or fully meet interruptible demands using stored water or water transfers as necessary (Stages 1-3).  Severe Shortage: MET can meet full-service demands only by making withdrawals from storage, calling on its water transfers, and possibly calling for extraordinary conservation and reducing deliveries under the Interim Agricultural Water Program (IAWP) (Stages 4-5).  Extreme Shortage: MET must allocate available imported supplies to full-service customers (Stage 6).

There are six shortage management stages to guide resource management activities. These stages are defined by shortfalls in imported supply and water balances in MET’s storage programs. When MET must make net withdrawals from storage to meet demands, it is considered to be in a shortage condition.

Figure 3 gives a summary of actions under each surplus and shortage stages when an allocation plan is necessary to enforce mandatory cutbacks. The goal of the WSDM plan is to avoid Stage 6, an extreme shortage (MET, 2026b).

Source: MET, 2026.

Figure 3 Resource Stages, Anticipated Actions, and Supply Declarations MET’s Board of Directors adopted a Water Supply Condition Framework in June 2008 to communicate the urgency of the region’s water supply situation and the need for further water conservation practices. The 2025 WATER SHORTAGE CONTINGENCY PLAN
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framework has four conditions, each calling increasing levels of conservation. Descriptions for each of the four conditions are listed below:
 Baseline Water Use Efficiency: Ongoing conservation, outreach, and recycling programs to achieve permanent reductions in water use and build storage reserves.  Condition 1 Water Supply Watch: Local agency voluntary dry-year conservation measures and use of regional storage reserves.
 Condition 2 Water Supply Alert: Regional call for cities, counties, member agencies, and retail water agencies to implement extraordinary conservation through drought ordinances and other measures to mitigate use of storage reserves.
 Condition 3 Water Supply Allocation: Implement MET’s WSAP.

As noted in Condition 3, should supplies become limited to the point where imported water demands cannot be met, MET will allocate water through the WSAP (MET, 2026a).

2.3.2 MET Water Supply Allocation Plan
MET’s imported supplies have been impacted by a number of water supply challenges as noted earlier. In case of extreme water shortage within the MET service area is the implementation of its WSAP.

MET’s Board of Directors adopted the WSAP in February 2008 to fairly distribute a limited amount of water supply and applies it through a detailed methodology to reflect a range of local conditions and needs of the region’s retail water consumers (MET, 2026a).

The WSAP includes the specific formula for calculating member agency supply allocations and the key implementation elements needed for administering an allocation. MET’s WSAP is the foundation for the urban water shortage contingency analysis required under Water Code Section 10632 and is part of MET’s 2025 UWMP.

MET’s WSAP was developed in consideration of the principles and guidelines in MET’s 1999 WSDM Plan with the core objective of creating an equitable “needs-based allocation.” The WSAP’s formula seeks to balance the impacts of a shortage at the retail level while maintaining equity on the wholesale level for shortages of MET supplies of greater than 50% cutbacks. The formula takes into account a number of factors, such as the impact on retail customers, growth in population, changes in supply conditions, investments in local resources, demand hardening aspects of water conservation savings, recycled water, extraordinary storage and transfer actions, and groundwater imported water needs.

The formula is calculated in three steps: 1) base period calculations, 2) allocation year calculations, and 3) supply allocation calculations. The first two steps involve standard computations, while the third step contains specific methodology developed for the WSAP.

Step 1: Base Period Calculations – The first step in calculating a member agency’s water supply allocation is to estimate their water supply and demand using a historical based period with established water supply and delivery data. The base period for each of the different categories of supply and demand is calculated using data from the two most recent non-shortage years.

Step 2: Allocation Year Calculations – The next step in calculating the member agency’s water supply allocation is estimating water needs in the allocation year. This is done by adjusting the base period estimates of retail demand for population growth and changes in local supplies. 2025 WATER SHORTAGE CONTINGENCY PLAN
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Step 3: Supply Allocation Calculations – The final step is calculating the water supply allocation for each member agency based on the allocation year water needs identified in Step 2.

In order to implement the WSAP, MET’s Board of Directors makes a determination on the level of the regional shortage, based on specific criteria, typically in April. The criteria used by MET includes current levels of storage, estimated water supplies conditions, and projected imported water demands. The allocations, if deemed necessary, go into effect in July of the same year and remain in effect for a 12-month period. The schedule is made at the discretion of the Board of Directors (MET, 2026b).

As demonstrated by the findings in MET’s 2025 UWMP, both the Water Reliability Assessment and the Drought Risk Assessment (DRA) demonstrate that MET is projecting to be able to mitigate the challenges posed by hydrologic variability, potential climate change, and regulatory risk on its imported supply sources through the significant storage capabilities it has developed over the last two decades, both dry-year and emergency storage (MET, 2026b).

Although MET’s 2025 UWMP forecasts that MET will be able to meet projected imported demands throughout the projected period from 2026 to 2050, uncertainty in supply conditions can result in MET needing to implement its WSAP to preserve dry-year storage and curtail demands (MET, 2026b).

2.3.3 MWDOC Water Supply Allocation Plan
To prepare for the potential allocation of imported water supplies from MET, MWDOC worked collaboratively with its 27 retail agencies to develop its own WSAP that was adopted in January 2009 and amended in 2016. The MWDOC WSAP outlines how MWDOC will determine and implement each of its retail agency’s allocation during a time of shortage.

The MWDOC WSAP uses a similar method and approach, when reasonable, as that of the MET’s WSAP.

However, MWDOC’s plan remains flexible to use an alternative approach when MET’s method produces a significant unintended result for the member agencies. The MWDOC WSAP model follows five basic steps to determine a retail agency’s imported supply allocation:

Step 1: Determine Baseline Information – The first step in calculating a water supply allocation is to estimate water supply and demand using a historical base period with established water supply and delivery data. The base period for each of the different categories of demand and supply is calculated using data from the last two non-shortage years.

Step 2: Establish Allocation Year Information – In this step, the model adjusts for each retail agency’s water need in the allocation year. This is done by adjusting the base period estimates for increased retail water demand based on population growth and changes in local supplies.

Step 3: Calculate Initial Minimum Allocation Based on MET’s Declared Shortage Level – This step sets the initial water supply allocation for each retail agency. After a regional shortage level is established, MWDOC will calculate the initial allocation as a percentage of adjusted base period imported water needs within the model for each retail agency.

Step 4: Apply Allocation Adjustments and Credits in the Areas of Retail Impacts and Conservation – In this step, the model assigns additional water to address disparate impacts at the retail level caused by an across-the-board cut of imported supplies. It also applies a conservation credit given to those agencies that have achieved additional water savings at the retail level as a result of successful implementation of water conservation devices, programs, and rate structures. 2025 WATER SHORTAGE CONTINGENCY PLAN
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Step 5: Sum Total Allocations and Determine Retail Reliability – This is the final step in calculating a retail agency’s total allocation for imported supplies. The model sums an agency’s total imported allocation with all of the adjustments and credits and then calculates each agency’s retail reliability compared to its Allocation Year Retail Demand.

The MWDOC WSAP includes additional measures for plan implementation, including the following (MWDOC, 2016):
 Appeal Process – An appeal process to provide retail agencies the opportunity to request a change to their allocation based on new or corrected information. MWDOC anticipates that under most circumstances, a retail agency’s appeal will be the basis for an appeal to MET by MWDOC.  Melded Allocation Surcharge Structure – At the end of the allocation year, MWDOC would only charge an allocation surcharge to each retail agency that exceeded their allocation if MWDOC exceeds its total allocation and is required to pay a surcharge to MET. MET enforces allocations to retail agencies through an allocation surcharge to a retail agency that exceeds its total annual allocation at the end of the 12-month allocation period. MWDOC’s surcharge would be assessed according to the retail agency’s prorated share (acre-feet [AF] over usage) of MWDOC amount with MET. Surcharge funds collected by MET will be invested in its Water Management Fund, which is used in part to fund expenditures in dry-year conservation and local resource development.  Tracking and Reporting Water Usage – MWDOC will provide each retail agency with water use monthly reports that will compare each retail agency’s current cumulative retail usage to their allocation baseline. MWDOC will also provide quarterly reports on its cumulative retail usage versus its allocation baseline.
 Timeline and Option to Revisit the Plan – The allocation period will cover 12 consecutive months and the Regional Shortage Level will be set for the entire allocation period. MWDOC only anticipates calling for allocation when MET declares a shortage; and no later than 30 days from MET’s declaration will MWDOC announce allocation to its retail agencies.

SECTION 3 WATER SHORTAGE CONTINGENCY PREPAREDNESS AND

RESPONSE PLANNING
The City’s WSCP is a detailed guide of how the City intends to act in the case of an actual water shortage condition. The WSCP anticipates a water supply shortage and provides pre-planned guidance for managing and mitigating a shortage. Regardless of the reason for the shortage, the WSCP is based on adequate details of demand reduction and supply augmentation measures that are structured to match varying degrees of shortage to ensure the relevant stakeholders understand what to expect during a water shortage situation.

3.1 Water Supply Reliability Analysis
Per Water Code Section 10632 (a)(1), the WSCP shall provide an analysis of water supply reliability conducted pursuant to Water Code Section 10635, and the key issues that may create a shortage condition when looking at the City’s water asset portfolio. 2025 WATER SHORTAGE CONTINGENCY PLAN
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Understanding water supply reliability, factors that could contribute to water supply constraints, availability of alternative supplies, and what effect these have on meeting customer demands provides the City with a solid basis on which to develop appropriate and feasible response actions in the event of a water shortage. For the 2025 UWMP, the City worked collaboratively with MWDOC, OCWD, and MWDOC’s other retail water agencies to produce long-term projected water use over the next 25 years, in five-year increments, for each agency (MWDOC, 2025).

The City also conducted a DRA to evaluate a drought period that lasts five consecutive water years starting from the year following when the assessment is conducted (2026-2030). An analysis of both assessments determined that the City is capable of meeting all customers’ demands from 2025 through 2050 for a normal year, a single dry year, and a drought lasting five consecutive years with significant imported water supplemental drought supplies from MWDOC/MET and ongoing conservation program efforts.. As a result, there is no projected shortage condition due to drought that will trigger customer demand reduction actions until MWDOC notifies the City of insufficient imported supplies. More information is available in the City’s 2025 UWMP Sections 6 and 7 (San Clemente, 2026).

The City of San Clemente’s Utilities Department meets all of its demands with a combination of imported water, local groundwater, and recycled water. The City works together with MET and MWDOC to ensure a safe and reliable imported water supply that will continue to serve the community in periods of drought and shortage. The sources of imported water supplies include water from the Colorado River and the SWP provided by MET and delivered through MWDOC.

3.2 Annual Water Supply and Demand Assessment Procedures Per Water Code Section 10632.1, the City will conduct an AWSDA pursuant to subdivision (a) of Section 10632 and by July 1st of each year, beginning in 2022, submit an AWSDA with information for anticipated shortage, triggered shortage response actions, compliance and enforcement actions, and communication actions consistent with the Supplier’s WSCP.

The City must include in its WSCP the procedures used for conducting an AWSDA. The AWSDA is a determination of the near-term outlook for supplies and demands and how a perceived shortage may relate to WSCP shortage level response actions in the current calendar year. This determination is based on information available to the City at the time of the analysis. Starting in 2022, the AWSDA is due by July 1 of every year.

This section documents the decision-making process required for formal approval of the City’s AWSDA determination of water supply reliability each year, the key data inputs, and the methodologies used to evaluate the water system reliability for the coming year, while considering that the year to follow would be considered dry.

3.2.1 Decision-Making Process
The following decision-making process describes the functional steps that the City will take to formally approve the AWSDA determination of water supply reliability each year. 2025 WATER SHORTAGE CONTINGENCY PLAN
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3.2.1.1 City Steps to Approve the AWSDA Determination
Each May, the completed AWSDA will be reviewed and signed by the City’s authority and submitted to DWR by July 1. In the event that a shortage is identified, the AWSDA, including any water shortage response actions recommended there within, will be presented to the San Clemente City Council. The City Council will then review and take appropriate action related to the recommendations of the Assessment and the guidance of Utilities staff and management in the interests of mitigating potential gaps between water supply and demand.

Figure 4 AWSDA Reporting Timeline

3.2.2 Data and Methodologies
The following paragraphs document the key data inputs and methodologies that are used to evaluate the water system reliability for the coming year, while considering that the year to follow would be considered dry.

3.2.2.1 Assessment Methodology
The City will evaluate water supply reliability for the current year and one dry year for the purpose of the AWSDA. The AWSDA determination will be based on considerations of unconstrained water demand, local water supplies, MWDOC imported water supplies, planned water use, and infrastructure considerations. The balance between projected in-service area supplies, coupled with MWDOC imported supplies, and anticipated unconstrained demand will be used to determine what, if any, shortage level is expected under the WSCP framework as presented in Figure 5. The WSCP’s standard shortage levels are defined in terms of shortage percentages. Shortage percentages will be calculated by dividing the 2025 WATER SHORTAGE CONTINGENCY PLAN
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difference between water supplies and unconstrained demand by total unconstrained demand. This calculation will be performed separately for anticipated current year conditions and for assumed dry year conditions.

Figure 5 Water Shortage Contingency Plan AWSDA Framework

3.2.2.2 Locally Applicable Evaluation Criteria
The primary source of evaluation criteria for the City’s AWSDA will be monthly supply-demand reporting.

Specifically, water shortage demand management reporting from MWDOC, which informs much of the City’s regular reporting, will be a significant criterion in evaluating the state of the City’s water supply reliability, since roughly 80% of its water is imported from MET through MWDOC. Less critically, the current productivity of the City’s wells and its capacity for treating and delivering recycled water to offset potable irrigation demands may also be used to inform supply reliability each year. Finally, any currently valid agreements for emergency water supplies, along with MWDOC’s ongoing commitment to provide adequate quantities of imported water to its members, will be included in the analysis of current year reliability.

The City will also continue to monitor emerging supply and demand conditions related to supplemental imported water from MWDOC/MET and take appropriate actions consistent with the flexibility and adaptiveness inherent to the WSCP. The City’s AWSDA was based on the City’s service area, water sources, water supply reliability, and water use as described in Water Code Section 10631, including available data from state, regional, or local agency population, land use development, and climate change projections within the service area of the City. Some conditions that affect MWDOC’s wholesale supply and demand, such as groundwater replenishment, surface water, and local supply production, can differ significantly from earlier projections throughout the year.

If a major earthquake on the San Andreas Fault occurs, it has the potential to damage all three key regional water aqueducts and disrupt imported supplies for up to six months. The region would likely impose a water use reduction ranging from 25-35% until the system is repaired. However, MET has taken proactive steps to handle such disruption, such as constructing DVL, and prepositioning necessary reconstruction resources to quickly recover from such a seismic event, which mitigates potential impacts. 2025 WATER SHORTAGE CONTINGENCY PLAN
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DVL, along with other local reservoirs, can store a six to twelve-month supply of emergency water (MET, 2026a).

3.2.2.3 Water Supply
As detailed in the City’s 2025 UWMP, the City meets its customers’ demands with a combination of imported water and local recycled water.

In FY 2024-25, the City’s main source of water supply was imported water from MWDOC (at 90 percent), which is treated by both MET and the Baker Water Treated Plant (WTP), and non-potable recycled water (at 10 percent). The Baker WTP is a jointly operated facility for several water agencies in South Orange County.

It is projected that by 2050, the City’s water portfolio will change to approximately 14% recycled water and 86% imported water. It should be noted that these representations of supply match the projected demand. However, the City can purchase more MET imported water through MWDOC, should the need arise.

3.2.2.4 Unconstrained Customer Demand
The WSCP and AWSDA define unconstrained demand as expected water use prior to any projected shortage response actions that may be taken under the WSCP. Unconstrained demand is distinguished from observed demand, which may be constrained by preceding, ongoing, or future actions, such as emergency supply allocations during a multi-year drought. WSCP shortage response actions to constrain demand are inherently extraordinary; routine activities such as ongoing conservation programs and regular operational adjustments are not considered as constraints on demands.

The City’s DRA reveals that its supply capabilities are expected to balance anticipated total water use and supply, assuming a five-year consecutive drought from FY 2025-26 through FY 2029-30 (San Clemente, 2026). This is based on the water demand projection model, in a single dry year, demand is expected to increase by six percent above a normal year (MWDOC, 2025).

For the City, the five consecutive dry year demand scenario is based on the demand model’s multiple dry year methodology. In accordance with the econometric demand model approach used to develop UWMP demand projections, a single hot/dry year was first identified based on weather conditions that produced the greatest demand response. Consecutive dry years were then represented by applying incremental scaling factors to this single hot/dry year demand to account for the compounding effects of persistent warm and dry conditions over time. These scaling factors show long‑term relationships between regional water use and multi‑year temperature and precipitation deficits and are applied sequentially to simulate second through fifth consecutive dry years. This approach is consistent with the demand modeling framework summarized in Chapter 7 of the City’s UWMP.

3.2.2.5 Planned Water Use for Current Year Considering Dry Subsequent Year Water Code Section 10632(a)(2)(B)(ii) requires the AWSDA to determine “current year available supply, considering hydrological and regulatory conditions in the current year and one dry year.” The AWSDA will include two separate estimates of City’s annual water supply and unconstrained demand using: 1) current year conditions, and 2) assumed dry year conditions. Accordingly, the AWSDA’s shortage 2025 WATER SHORTAGE CONTINGENCY PLAN
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analysis will present separate sets of findings for the current year and dry year scenarios. The Water Code does not specify the characteristics of a dry year, allowing discretion to the Supplier. The City will use its discretion to refine and update its assumptions for a dry year scenario in each AWSDA as information becomes available and in accordance with best management practices.

Supply and demand analyses for the single-dry year case were based on conditions affecting the SWP as this supply availability fluctuates the most among MET’s, and therefore MWDOC and the City’s, sources of supply. Severe drought conditions in 2021-2022 affected must of the Western United States, including the Colorado River system, which caused its water supply decrease. As conditions worsened, Lake Mead and Lake Powell (the largest storage units in the system), had a combined total storage capacity of 25% in 2022, a significant decrease from 39% in 2021 (DWR, 2024).

The Orange County Water Demand Projection Model isolated the impacts that weather and future climate can have on water demand through the use of a statistical model. The impacts of hot/dry weather conditions are reflected as a percentage increase in water demands from the normal year condition. For a single dry year condition (FY 2013-14), the model projects a 6% increase in demand for the Orange County Basin (OC Basin) area where the City’s service area is located (MWDOC, 2025). Detailed information of the model is included in the City’s 2025 UWMP.

The City has documented that it is 100% reliable for single dry year demands from 2025 through 2050 with a demand increase of 6% from normal demand with significant reserves held by MET, local groundwater supplies, and conservation (San Clemente, 2026).

3.2.2.6 Infrastructure Considerations
The AWSDA will include consideration of any infrastructure issues that may pertain to near-term water supply reliability, including repairs, construction, and environmental mitigation measures that may temporarily constrain capabilities, as well as any new projects that may add to system capacity. The City imports water through two large pipelines, the Water Importation Pipeline and the Joint Transmission Main, which are operated by adjacent water agencies. The regular preventive and corrective maintenance these pipelines and related facilities serving the City’s reservoirs may require shutdowns. These shutdowns involve a high level of planning and coordination with the City’s Utilities Department staff, resulting in temporary operational adjustments, water shortage response outreach, or a combination of the two.

MWDOC closely coordinates with MET and its member agencies, including the City, on any planned infrastructure work that may impact water supply availability. Throughout each year, MET regularly carries out preventive and corrective maintenance of its facilities within the MWDOC service area that may require shutdowns to inspect and repair pipelines and facilities and support capital improvement projects.

These shutdowns involve a high level of planning and coordination between MWDOC, MWDOC’s member agencies, and MET to ensure that major portions of the distribution system are not out of service at the same time. Operational flexibility within MET’s system and the cooperation of member agencies allow shutdowns to be successfully completed while continuing to meet all system demands.

Specifically for the City, as of March 2026 there are no foreseen near-term infrastructure issues that would impact supply.
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3.2.2.7 Other Factors
For the AWSDA, any known issues related to water quality would be considered for their potential effects on water supply reliability.

Per- and polyfluoroalkyl substances (PFAS) are a group of thousands of manmade chemicals that includes perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). PFAS compounds were once commonly used in many products including, among many others, stain- and water-repellent fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning products, and fire-fighting foams.

MET has voluntarily monitored PFAS in its source and treated waters since 2017. Most samples have shown non detect (ND) for all tested PFAS, including PFOA and PFOS. A limited number of other PFAS— such as PFHxA, PFBA, PFPeA, PFDoA, PFTA, and PFBS, have been detected only at trace levels below their method detection limits. PFOA and PFOS have not been detected in MET’s imported or treated water supplies. Some member agencies, however, have detected these compounds in local groundwater wells, which may require treatment or source management to comply with emerging Division of Drinking Water (DDW) regulations. As DDW and U.S. Environmental Protection Agency (EPA) establish enforceable maximum contaminant levels (MCLs) for PFOA and PFOS, some agencies may supplement their local supplies with increased purchases of MET water (MET, 2025).

EPA finalized the first national drinking water standards for six PFAS compounds in April 2024. These standards include enforceable MCLs for PFOA and PFOS set at 4 parts per trillion (ppt). In May 2025 the EPA announced that it would extend the compliance deadline for PFOA and PFOS from 2029 to 2031 to provide additional time for testing, planning, and installation of treatment technologies. While MET and its member agencies continue to monitor and test PFAS in imported and local sources, the delay in the federal compliance date allows additional time to evaluate treatment options, coordinate funding, and plan system upgrades necessary to meet forthcoming federal PFAS standards.

3.3 Six Standard Water Shortage Levels
Per Water Code Section 10632 (a)(3)(A), the City must include the six standard water shortage levels that represent shortages from the normal reliability as determined in the AWSDA or cross-reference their shortage levels to the standard levels. The shortage levels have been standardized to provide a consistent regional and statewide approach to conveying the relative severity of water supply shortage conditions.

This is an outgrowth of the severe statewide drought of 2012-2016, and the widely recognized public communication and state policy uncertainty associated with the many different local definitions of water shortage levels.

The six standard water shortage levels correspond to progressively increasing estimated shortage conditions (up to 10, 20, 30, 40, 50, and greater than 50% shortage compared to the normal reliability condition) and align with the response actions the Supplier would implement to meet the severity of the impending shortages. The five shortage levels the City uses in their water shortage planning and documented in the WSCP are compared to DWR’s six standard shortage levels in Table 1. 2025 WATER SHORTAGE CONTINGENCY PLAN
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Table 1 Cross-Reference for Standard vs Supplier Shortage Levels Submittal Table 8-1: Cross-reference for Standard vs Supplier Shortage Levels Water Code Section 10632(a)(3)(B)
Check the box if the Supplier uses the Standard six levels of water shortage.

Proceed to the next table.

Standard Shortage Levels Percent Shortage Range Suppliers Shortage Levels Percent Shortage Range 1 Up to 10% 1 – Water Watch Up to 10%
2 Up to 20% 2 – Water Alert Up to 20%
3 Up to 30% 3 – Water Warning Up to 30%
4 Up to 40% 4 – Water Shortage Up to 40%
5 Up to 50% 4 – Water Shortage Up to 50%
6 >50% 5 – Water Emergency >50%
NOTES: See full cross-reference table with San Clemente shortage levels in WSCP.

3.4 Shortage Response Actions
Water Code Section 10632 (a)(4) requires the WSCP to specify shortage response actions that align with the defined shortage levels. The City has defined specific shortage response actions that align with the defined shortage levels in DWR Tables 8-2 and 8-3 (Appendix A). These shortage response actions were developed with consideration to the system infrastructure and operations changes, supply augmentation responses, customer-class or water use-specific demand reduction initiatives, and increasingly stringent water use prohibitions.

3.4.1 Supply Augmentation
The supply augmentation actions are described in DWR Table 8-2 (Appendix A). These augmentations represent short-term management objectives triggered by the MET’s WSDM Plan and do not overlap with the long-term new water supply development or supply reliability enhancement projects. Supply Augmentation is made available to the City through MWDOC and MET. The City relies on MET’s reliability portfolio of water supply programs including existing water transfers, storage and exchange agreements to supplement gaps in the City’s supply/demand balance. MET has developed significant storage capacity (over 5 million AF) in reservoirs and groundwater banking programs both within and outside of the Southern California region. Additionally, MET can pursue additional water transfer and exchange programs with other water agencies to help mitigate supply/demand imbalances and provide additional dry-year supply sources.

MWDOC, and in turn its retail agencies, including the City, have access to supply augmentation actions through MET. MET may exercise these actions based on regional need, and in accordance with their WSCP, and may include the use of supplies and storage programs within the Colorado River, SWP, and in-region storage. The City has the ability to augment its supply to reduce the shortage gap by up to 100% by purchasing additional imported water through MWDOC. 2025 WATER SHORTAGE CONTINGENCY PLAN
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3.4.2 Demand Reduction
The demand reduction measures that would be implemented to address shortage levels are described in DWR Table 8-3 (Appendix A). This table indicates which actions align with specific defined shortage levels and estimates the extent to which the actions will reduce the gap between supplies and demands to deliver the outcomes necessary to meet the requirements of a given shortage level. This table also identifies the enforcement action, if any, associated with each demand reduction measure.

3.4.3 Operational Changes
During shortage conditions, operations may be affected by supply augmentation or demand reduction responses. The City will consider their operational procedures when it completes its AWSDA or as needed to identify changes that can be implemented to address water shortage on a short-term basis, such as temporarily altering maintenance cycles, deferring planned system outages, and adjusting the flow and routing of water through its system to more effectively distribute available supply across the service area.

3.4.4 Additional Mandatory Restrictions
Water Code Section 10632(a)(4)(D) calls for “additional, mandatory prohibitions against specific water use practices that are in addition to state-mandated prohibitions and appropriate to the local conditions” to be included among the WSCP’s shortage response actions. The City will identify additional mandatory restrictions as needed based on the San Clemente Municipal Code Chapter 13.12 Water Conservation and Water Supply Shortage Program (Appendix B). The City intends to update any mandatory restrictions in a subsequently adopted ordinance which will supersede the existing ordinance.

3.4.5 Emergency Response Plan (Hazard Mitigation Plan)
A catastrophic water shortage would be addressed according to the appropriate water shortage level and response actions. It is likely that a catastrophic shortage would immediately trigger Shortage Level 6 and response actions have been put in place to mitigate a catastrophic shortage. In addition, there are several Plans that address catastrophic failures and align with the WSCP, including MET’s WSDM and WSAP, the City’s Local Hazard Mitigation Plan (LHMP), and the Water Emergency Response Organization of Orange County (WEROC)’s Emergency Operations Plan (EOP).

3.4.5.1 MET’s WSDM and WSAP
MET has comprehensive plans for stages of actions it would undertake to address a catastrophic interruption in water supplies through its WSDM and WSAP. MET also developed an Emergency Storage Requirement to mitigate against potential interruption in water supplies resulting from catastrophic occurrences within the southern California region, including seismic events along the San Andreas Fault. In addition, MET is working with the state to implement a comprehensive improvement plan to address catastrophic occurrences outside of the southern California region, such as a maximum probable seismic event in the Delta that would cause levee failure and disruption of SWP deliveries. 2025 WATER SHORTAGE CONTINGENCY PLAN
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3.4.5.2 Water Emergency Response Organization of Orange County Emergency Operations Plan
In 1983, the Orange County water community identified a need to develop a plan on how agencies would respond effectively to disasters impacting the regional water distribution system. The collective efforts of these agencies resulted in the formation of the WEROC to coordinate emergency response on behalf of all Orange County water and wastewater agencies, develop an emergency plan to respond to disasters, and conduct disaster training exercises for the Orange County water community. WEROC, administered by MWDOC, was established through the creation of an indemnification agreement among its member agencies to protect each other against civil liabilities and to facilitate the exchange of resources. WEROC is unique in its ability to provide a single point of contact for the representation of all water and wastewater utilities in Orange County during a disaster. This representation is to the county, state, and federal disaster coordination agencies. Within the Orange County Operational Area, WEROC is the recognized contact for emergency response for the water community, including the City.

As a member of WEROC, the District will follow WEROC’s EOP in the event of an emergency and coordinate with WEROC to assess damage, initiate repairs, and request and coordinate mutual aid resources in the event that the District is unable to provide the level of emergency response support required by the situation.

The EOP defines the actions to be taken by WEROC Emergency Operations Center (EOC) staff to reduce the loss of water and wastewater infrastructure; to respond effectively to a disaster; and to coordinate recovery operations in the aftermath of any emergency involving extensive damage to Orange County water and wastewater utilities. The EOP includes activation notification protocol that will be used to contact partner agencies to inform them of the situation, activation status of the EOC, known damage or impacts, or resource needs. The EOP is a standalone document that is reviewed annually and approved by the MWDOC Board every three years.

WEROC is organized on the basis that each member agency is responsible for developing its own EOP in accordance with the California Standardized Emergency Management System (SEMS), National Incident Management System (NIMS), and Public Health Security and Bioterrorism Preparedness and Response Act of 2002 to meet specific emergency needs within its service area.

The WEROC EOC is responsible for assessing the overall condition and status of the Orange County regional water distribution and wastewater collection systems including MET facilities that serve Orange County. The EOC can be activated during an emergency situation resulting from both natural and man-made causes, and can be activated through automatic, manual, or standby for activation.

WEROC recognizes four primary phases of emergency management, which include:
 Preparedness: Planning, training, and exercises that are conducted prior to an emergency to support and enhance response to an emergency or disaster.
 Response: Activities and programs designed to address the immediate and short-term effects of the onset of an emergency or disaster that helps to reduce effects on water infrastructure and speed recovery. This includes alert and notification, EOC activation, direction and control, and mutual aid. 2025 WATER SHORTAGE CONTINGENCY PLAN
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 Recovery: This phase involved restoring systems to normal, in which short-term recovery actions are taken to assess the damage and return vital life-support systems to minimum operating standards, while long-term recovery actions have the potential to continue for many years.  Mitigation/Prevention: These actions prevent the occurrence of an emergency or reduce the area’s vulnerability in ways that minimize the adverse impacts of a disaster or emergency.

The EOC Action Plans provide frameworks for EOC staff to respond to different situations with the objectives and steps required to complete them, which will in turn serve the WEROC member agencies. In the event of an emergency that results in a catastrophic water shortage, the City will declare a water shortage condition of up to Level 3 for the impacted area depending on the severity of the event, and coordination with WEROC is anticipated to begin at Level 4 or greater (WEROC, 2021).

3.4.5.3 City of San Clemente Emergency Response Plan
The City of San Clemente, in accordance with the America’s Water Infrastructure Act of 2018 Section 2013(b), recently revised its Emergency Response Plan to incorporate findings of its risk and resilience assessment (RRA). This ERP describes strategies, resources, plans, and procedures to be utilized during a natural or anthropogenic catastrophe that results in disruption to the City’s water supplies. The City also recently updated its LHMP which provides City staff and City leaders with clear direction for hazard mitigation action planning, including for any potential impacts to the potable water system. The water supply specific mitigation measures include increased backup power and generator capacity at critical facilities, relocating water mains off of slopes and easements, and upgrading aging pipelines (San Clemente, 2025).

3.4.6 Seismic Risk Assessment and Mitigation Plan
Per the Water Code Section 10632.5, Suppliers are required to assess seismic risk to water supplies as part of their WSCP. The plan also must include the mitigation plan for the seismic risk(s). Given the great distances that imported supplies travel to reach Orange County, the region is vulnerable to interruptions along hundreds of miles of aqueducts, pipelines and other facilities associated with delivering the supplies to the region. Additionally, the infrastructure in place to deliver supplies is susceptible to damage from earthquakes and other disasters.

In lieu of conducting a seismic risk assessment specific to the City’s 2025 UWMP, the City has included their LHMP, as required under the federal Disaster Mitigation Act of 2000 (Public Law 106-390). The LHMP describes the City’s approach to proactively decreasing threats before disaster occurs, including water supply specific mitigation actions such as improving security and alert systems, upgrading back-up power systems, and retrofitting existing flood control infrastructure. (San Clemente, 2025).

3.4.7 Shortage Response Action Effectiveness
The effectiveness of the shortage response actions in Tables 2 and 3 above are anticipated to either reduce demand or increase supply according to the anecdotally estimated percentages in the tables.

Given its geographical location, relatively small utilities system, and reliance on imported water, the City anticipates that addressing any significant or regional water shortage with demand reduction actions will be necessary, rather than primarily relying on supply augmentation actions. 2025 WATER SHORTAGE CONTINGENCY PLAN
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For each specific Shortage Response Action identified in the plan, the WSCP also estimates the extent to which that action will reduce the gap between supplies and demands identified in DWR Tables 8-2 and 8-3 (Appendix A). To the extent feasible, the City has estimated percentage savings for the chosen suite of shortage response actions, which can be anticipated to deliver the expected outcomes necessary to meet the requirements of a given shortage level.

3.5 Communication Protocols
Following the preparation of the AWSDA, or any sudden or catastrophic change in water supply conditions, any current or predicted water shortage will be communicated to the City’s water customers and other members of the public; neighboring water agencies; and local, regional, and State government agencies as appropriate, broadly and through a diverse suite of media. Communications will also include the related shortage response actions being implemented by the City at the time.

Protocols for dissemination of key information regarding the shortage and response actions will vary depending on the severity of the shortage. Table 2 summarizes the type of messaging that will be delivered for each Water Shortage Level.

Table 2 Communication Protocols by Shortage Level
Water Shortage Level Percent Shortage
Range
Communication Protocols, Procedures, and Channels
1 – Water Watch Up to 10% Updates on City website and social media accounts, press releases, advertisements in local newspaper (print/digital)
2 – Water Alert Up to 20% Messaging in monthly water bill, plus all of the above 3 – Water Warning Up to 30% Traffic sign boards and/or regional messaging, such as through Caltrans sign boards, plus all of the above
4 – Water Shortage Up to 40% Direct mail messages to customers and/or email to City Recreation and Environmental Programs email lists, as available, plus all of the above Local television advisory and radio spots, as part of regional campaign when applicable, plus all of the above
Up to 50%
5 – Water Emergency >50% Regional television station coverage, targeted online advertising, plus all of the above
In the case that the water shortage is of a regional nature, the City may also incorporate communications materials developed by MWDOC and/or MET’s Public Affairs team into their customer outreach, customizing such materials whenever possible with the City logo, City staff contacts, and other identifying information for their water customers who may be unaware of the role of wholesalers in the delivery of their water.

The City also participates in the Water Emergency Response of Orange County (WEROC) program and, should a regional water supply emergency occur, can utilize communications through the AlertOC program, incorporating any or all of the abovementioned City protocols into the regional approach as well.

3.6 Compliance and Enforcement
Per the Water Code Section 10632 (a)(6), the City has defined customer compliance, enforcement, appeal, and exemption procedures for triggered shortage response actions. Communication procedures to ensure 2025 WATER SHORTAGE CONTINGENCY PLAN
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customer compliance are described in Section 3.5 Communication Protocols and customer enforcement, appeal, and exemption procedures are defined in the San Clemente Municipal Code Chapter 13.12 Water Conservation And Water Supply Shortage Program (Appendix B).

3.7 Legal Authorities
Per Water Code Section 10632 (a)(7)(A), the City has provided a description of the legal authorities that empower the City to implement and enforce its shortage response in the San Clemente Municipal Code Chapter 13.12 Water Conservation And Water Supply Shortage Program (Appendix B). The City intends to update any legal authorities in a subsequently adopted ordinance which will supersede the existing ordinance.

Per Water Code Section 10632 (a)(7)(B), the City shall declare a water shortage emergency condition to prevail within the area served by such wholesaler whenever it finds and determines that the ordinary demands and requirements of water consumers cannot be satisfied without depleting the water supply of the distributor to the extent that there would be insufficient water for human consumption, sanitation, and fire protection.

Per Water Code Section 10632 (a)(7)(C), the City shall coordinate with any agency or county within which it provides water supply services for the possible proclamation of a local emergency under California Government Code, California Emergency Services Act (Article 2, Section 8558). Table 3 identifies the contacts for all cities or counties for which the Supplier provides service in the WSCP, along with developed coordination protocols, can facilitate compliance with this section of the Water Code in the event of a local emergency as defined in subpart (c) of Government Code Section 8558.

Table 3 Agency Contacts and Coordination Protocols
Contact Agency Coordination Protocols
Director of Public Works Orange County Public Works Department Call/email Public Works Department City of San Clemente Call/email

3.8 Financial Consequences of WSCP
Per Water Code Section 10632(a)(8), Suppliers must include a description of the overall anticipated financial consequences to the Supplier of implementing the WSCP. This description must include potential reductions in revenue and increased expenses associated with implementation of the shortage response actions. This should be coupled with an identification of the anticipated mitigation actions needed to address these financial impacts.

The implementation of the monitoring and reporting requirements as well as demand reduction measures in this Water Shortage Contingency Plan have the potential to impact the City’s revenues and expenditures. In particular, additional public education on water use efficiency, extended prohibitions on certain water uses, and increased enforcement and patrols of these prohibitions are all anticipated to reduce water use and associated commodity rate charges and revenues, while at the same time increasing certain expenditures for conservation-related projects and staff utilization. Decreased revenues require the City to fund more of its fixed costs from its water fund reserves, delay capital improvements, and entertain other such suboptimal financial management practices.
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To assess the impacts of future water shortages on revenues, the City reviewed the impacts of previous droughts and analyzed three decreased water demand scenarios in its 2017 cost of service study. In this study, it was determined that the City’s fixed costs are approximately 42 percent of its cost of service but that 77 percent of fixed costs were paid for through the variable component of the water rate structure at the time, so fixed cost recovery was a key objective in determining the City’s current water rates. By January 1, 2022, the fixed charge for one-inch meters will be 57% higher than it was in 2016, with larger connections seeing even greater increases in fixed charges. In driving a greater percentage of revenues to come from fixed charges, the City has already set itself up for greater financial resiliency during times of water shortage, while more accurately billing its customers for system maintenance that is not dependent on their individual water consumption.

The City also recognized the impact of reduced commodity charges during periods of restrictions on water use, so in the last rate structure change, the City Council approved the availability of demand management rates that can be temporarily implemented in order to stabilize revenues during times of decreasing water demands. These water rate surcharges could be approved by City Council during water supply shortages, and as they also discourage excessive water use, can serve as response actions to the first three levels of water shortage in this WSCP. Demand management rates are detailed in Table 4 below.

Table 4 Proposed Demand Management Rates (Fixed and Variable Rate Surcharges) as of January 1, 2020 5-10% Demand
Reduction
11-20% Demand
Reduction
Greater than 20%
Demand Reduction
Fixed Rate ($/meter equivalent) N/A $0.74 $0.74
Variable Rate ($/unit of water [CCF]) $0.19 $0.30 $0.57 Notably, water rate surcharges do not increase further beyond a Level 3 Water Warning. It is anticipated that at Level 4 and 5 water shortages, tapping into water fund reserves and postponing capital projects will also be used to temporarily supplement the anticipated reductions in commodity rate revenues.

Another key aspect of the City’s current water rate structure is the decoupling of wholesale water rates from its own variable rates. Should wholesaler rates be increased as part of MET’s own water shortage contingency response actions, or for any other operational reason, these increased rates will be directly passed through to the City’s customers as part of its current rate structure, and not absorbed into its operating costs.

The costs of additional conservation tracking and reporting during a water shortage will be covered by existing overtime budget in the Water Conservation Fund, building on existing water use monitoring and report preparation and submission activities that are already a part of staff’s regular duties. Because the City already has everyday restrictions on wasteful water practices and does regular enforcement of its Water Conservation Ordinance regardless of water shortage conditions, the costs of discouraging excessive water use by customers in compliance with Chapter 3.3 (commencing with Section 365) of Division 1 of the Water Code will largely be addressed by the City’s existing Water Conservation budget.

In order to manage the costs of increased enforcement during times of water shortage, additional patrolling may be implemented by recruiting the City’s stormwater program staff and/or Code Compliance officers to assist in the investigation of water conservation ordinance violations in between their regular duties. The City may also utilize Retired Senior Volunteer Program (RSVP) officers to assist in reporting violations for enforcement by authorized City staff. In the long run, it is the City’s intent to invest 2025 WATER SHORTAGE CONTINGENCY PLAN
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up front in public education and outreach about current water use restrictions, thereby reducing the number of violations that require additional investigation and enforcement in order for the City to realize its desired demand reduction.

3.9 Monitoring and Reporting
Per Water Code Section 10632(a)(9), the City is required to provide a description of the monitoring and reporting requirements and procedures that have been implemented to ensure appropriate data is collected, tracked, and analyzed for purposes of monitoring customer compliance and to meet state reporting requirements.

In order to ensure that water shortage response actions are achieving their intended water use reduction purposes, and to help inform the AWSDA, the City will monitor implementation of this Water Shortage Contingency Plan using a suite of existing reporting and tracking tools that evaluate water supplies, demands, and demand reduction measure utilization and effectiveness on a monthly basis. These tools include the database queries and spreadsheets used to inform monthly water production reports required by SWRCB and submitted to DWR, which help inform the City on its overall current water demands while breaking those demands down into the various account types, such as CII, irrigation, and residential, for tracking by customer class. Water consumption by account type is also reviewed on a monthly basis and compared to 2013 baseline usage for the same month, as part of previous efforts to monitor compliance with SBx7-7. Monthly reporting on residential and commercial water use also continues in an effort to comply with the State Water Resources Control Board’s Resolution 2020-0009.

To monitor customer complaints, outreach, enforcement, and compliance, the City uses its Computer Maintenance Management System (CMMS) to record each initial contact about or observation of water waste and the steps and staff time taken to resolve the issue. Staff can query these “work orders” to evaluate program effectiveness and enforcement costs, among other metrics, for any appropriate time frame. Both the frequency of customer water waste complaints, which corresponds to public outreach success, and the number of resolved outreach/enforcement cases, which corresponds to water savings, can help inform the effectiveness of current water shortage response actions.

On the supply side, monthly water supply reports from MWDOC, the City’s wholesaler, are received, reviewed, and filed, and pertinent information is made available to the City’s water customers on its website. Similarly, groundwater extraction and treatment is tracked and recorded monthly by City staff.

These supply monitoring efforts ensure that the City has access to water supplies within the range prescribed by its current water shortage stage, if any, and can help inform any need to increase or decrease its water shortage stage in the near future.

3.10 WSCP Refinement Procedures
Per Water Code Section 10632 (a)(10), the City must provide reevaluation and improvement procedures for systematically monitoring and evaluating the functionality of the water shortage contingency plan in order to ensure shortage risk tolerance is adequate and appropriate water shortage mitigation strategies are implemented as needed.

This Water Shortage Contingency Plan has been prepared as an adaptive management plan and will be revised and refined according to the results of the City’s WSCP monitoring and reporting program, including during its AWSDA as described in Section 2.
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In particular, in the years following a period of water shortage, staff will assess each component of this WSCP and determine which elements were effective at bridging the gap between supplies and demands, and which sections require revision to better serve the City and its water customers in future water supply shortages. Staff may conduct this analysis by observing seasonal trends in water use reductions for attribution to specific irrigation restrictions; tracking the types of violations addressed in enforcement cases; conducting customer or public surveys; and/or reviewing the shift in its portfolio of water supplies during the shortage.

Through its CMMS, the City may also record customer complaints about the implementation of the WSCP itself, so yearly or other periodic reports can be run to determine the possibility of negative impacts on the City’s water customers or their satisfaction with the Utilities Department’s ability to manage and safely deliver a reliable source of drinking water to the community. The City Council may also receive public input for staff to consider when refining the current WSCP.

Should areas for revision be identified in this WSCP, ideas for improvement will be gathered from City staff, neighboring water agencies and their WSCPs, and possibly a customer focus group, and an updated WSCP will be drafted. As with this WSCP, any subsequent versions of the WSCP will undergo public notification, review, and hearing, to ultimately be adopted by the City Council prior to implementation and filing of the new WSCP with DWR, as described in Section 3.12.

3.11 Special Water Feature Distinction
Water features in the City’s service area are identified as having either an “aesthetic” or a “recreational” purpose, and distinct water use restrictions and shortage response actions shall apply to each type of water feature.

Aesthetic water features include decorative fountains, ponds, and lakes, and pursuant to the current Water Conservation Ordinance, shall only be permitted to operate while using a water recirculation device, with two exceptions: (1) features utilizing recycled/non-potable water and (2) features listed in the National Register of Historic Places, for which installing a recirculation device may impact the integrity of the feature.

Recreational water features include swimming pools, spas, and children’s water play areas, where using potable water is required for health and safety reasons. While these features can typically be maintained during water supply shortages, there are limitations on draining and refilling of any pool or spa unless necessary to repair the functionality of the feature.

3.12 Plan Adoption, Submittal, and Availability
Per Water Code Section 10632 (a)(c), the City provided notice of the availability of the Public Review Draft 2025 UWMP and 2025 WSCP and notice of the public hearing to consider adoption of the WSCP. The Public Review Drafts of the 2025 UWMP and the 2025 WSCP were posted prominently on the City’s website in advance of the public hearing on June 2, 2026. Copies of the Draft WSCP were also made available for public inspection at the City Clerk’s and Utilities Department offices and public hearing notifications were published in local newspapers. A copy of the published Notice of Public Hearing is included in Appendix C.
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The City held the public hearing for the Draft 2025 UWMP and Draft WSCP on June 2, 2026, at the City Council meeting. The City Council reviewed and approved the 2025 UWMP and the WSCP at its June 2, 2026 meeting after the public hearing. See Appendix D for the resolution approving the WSCP.

By July 1, 2026, the City’s adopted 2025 UWMP and WSCP was filed with DWR, California State Library, and the County of Orange. The City will make the WSCP available for public review on its website no later than 30 days after filing with DWR.

Based on DWR’s review of the WSCP, the City will make any amendments to its adopted WSCP, as required and directed by DWR.

If the City revises its WSCP after the UWMP is approved by DWR, then an electronic copy of the revised WSCP will be submitted to DWR within 30 days of its adoption.

SECTION 4 REFERENCES
City of San Clemente. (2026). 2025 Urban Water Management Plan.

City of San Clemente. (2025, April). Local Hazard Mitigation Plan.

Metropolitan Water District of Southern California (MET). (2026a). 2025 Water Shortage Contingency Plan.

Metropolitan Water District of Southern California (MET). (2026b). 2025 Urban Water Management Plan.

Municipal Water District of Orange County. (2023, July). 2023 Orange County Water Reliability Study.

Municipal Water District of Orange County. (2025, December 30). Orange County Water Demand Projection Model Technical Memorandum.

Water Emergency Response Organization of Orange County (WEROC). (2025). WEROC 2025 Annual Report.
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APPENDIX A DWR SUBMITTAL TABLES
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Submittal Table 8-1: Cross Reference for Standard vs Supplier Shortage Level Submittal Table 8-1: Cross-reference for Standard vs Supplier Shortage Levels Water Code Section 10632(a)(3)(B)
Check the box if the Supplier uses the Standard six levels of water shortage.

Proceed to the next table.

Standard Shortage Levels Percent Shortage Range Suppliers Shortage Levels Percent Shortage Range 1 Up to 10% 1 – Water Watch Up to 10%
2 Up to 20% 2 – Water Alert Up to 20%
3 Up to 30% 3 – Water Warning Up to 30%
4 Up to 40% 4 – Water Shortage Up to 40%
5 Up to 50% 4 – Water Shortage Up to 50%
6 >50% 5 – Water Emergency >50%
NOTES: See full cross-reference table with San Clemente shortage levels in WSCP.

Submittal Table 8-2: Supply Augmentation and Other Actions Submittal Table 8-2 Retail: Supply Augmentation and Other Actions Water Code Section 10632(a)(4)(A),(C) and (E)
No Is the Supplier completing this table using the standard six levels? (yes/no) Shortage
Level
Supply Augmentation
Methods and Other Actions
by Water Supplier
Drop down list
These are the only categories
that will be accepted by the
WUE data online submittal tool
How much is this going to
reduce the shortage gap?
Additional Explanation or Reference
(OPTIONAL) Volume or
Percentage
Drop down
Shortage Gap
Reduction Value
(May be a range)
(AF)
Add additional rows as needed
1 Stored Emergency Supply Percentage 0-10% Pumping of additional groundwater, within safe short-term yield limits
2 Other Purchases Percentage 11-20%
Purchase of additional water supplies from
MET/MWDOC or through emergency
agreement with IRWD
3 Other Purchases Percentage 21-30%
Purchase of additional water supplies from
MET/MWDOC or through emergency
agreement with IRWD
4 Other Purchases Percentage 31-50%
Purchase of additional water supplies from
MET/MWDOC or through emergency
agreement with IRWD
5 Other Purchases Percentage >50%
Purchase of additional water supplies from
MET/MWDOC or through emergency
agreement with IRWD
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.

NOTES: Additional Imported Water Purchases to meet the supply gap may have financial ramifications per the MET's Water Supply Allocation Plan. Additional Groundwater Pumping in the Orange County Groundwater Basin is subject to OCWD's policies and may be subject to financial ramifications. 2025 WATER SHORTAGE CONTINGENCY PLAN
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Submittal Table 8-3: Demand Reduction Actions
Submittal Table 8-3 Retail: Demand Reduction Actions
Water Code Section 10632(a)(4)(B) and (E)
No Is the Supplier completing this table using the standard six levels? (yes/no) Shortage
Level
Demand Reduction Actions
Drop down list
These are the only categories that will be accepted by the WUEdata online submittal tool. Select those that apply.

How much is this going to reduce the shortage gap?
Additional Explanation or Reference
(OPTIONAL)
Penalty, Charge, or Other
Enforcement?
For Retail Suppliers Only
Drop Down List
Volume or Percentage
Drop down
Shortage Gap Reduction Value
(May be a range)
(AF)
Add additional rows as needed
0 Landscape - Prohibit certain types of landscape irrigation Statewide Prohibition is Required Watering or irrigation of nonfunctional turf on publicly owned landscapes, commercial, industrial and institutional owned landscapes, or homeowners' associations common area landscapes is prohibited.

Yes
1 Expand Public Information Campaign Percentage 0-4% Press releases, social media posts, and/or bill messaging No 1 Implement or Modify Drought Rate Structure or Surcharge Percentage 0-10% Variable rate surcharge Yes 2 Landscape - Limit landscape irrigation to specific days Percentage 11-15% 3 days/week Mar-Nov*; 1 day/week Dec-Feb*** Yes 2 Increase Water Waste Patrols Percentage 16-20% Recruitment of additional, temporary, and/or existing staff for increased patrols Yes 2 Implement or Modify Drought Rate Structure or Surcharge Percentage 11-20%^ Fixed and variable rate surcharges Yes 3 Other - Prohibit use of potable water for washing hard surfaces Percentage 21-25% Yes 3 Landscape - Limit landscape irrigation to specific days Percentage 26-30% 2 days/week Mar-Nov**; 1 day/week Dec-Feb*** Yes 3 Implement or Modify Drought Rate Structure or Surcharge Percentage >20%^ Variable rate surcharge Yes 4 Other - Prohibit vehicle washing except at facilities using recycled or recirculating water Percentage 31-35% Yes
4 Landscape - Other landscape restriction or prohibition Percentage 36-40% Potable irrigation prohibited during the months of November through March. Yes 4 Landscape - Prohibit certain types of landscape irrigation Percentage 41-45% Non-functional landscapes (i.e. with the exception of parks and golf courses) may, with notice, have potable irrigation turned off at the meter. No 4 Other - Prohibit use of potable water for construction and dust control Percentage 46-50% No will-serve letters will be provided for potable water for use in construction. No 5 Other water feature or swimming pool restriction Percentage 51-55% Refilling of pools and spas prohibited beyond a 1-inch top off Yes 5 Landscape - Prohibit all landscape irrigation Percentage >55% Recycled water irrigation is exempt, unless otherwise directed by the City Council. Yes DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.

NOTES: All shortage response actions for the prior shortage level(s) also apply to the consequent shortage level. With the exception of that for the rate surcharges which is figured as cumulative savings from implementation of prior rate surcharges only (see below), percent reduction in shortage is figured as cumulative savings from implementation of all prior shortage response actions. *Even residential addresses may run irrigation on Mondays, Wednesdays, and Fridays; odd residential addresses may irrigate on Tuesdays, Thursdays, and Saturdays; and commercial and irrigation accounts may irrigate on Sundays, Tuesdays, and Fridays. **Even residential addresses may run irrigation on Mondays and Thursdays; odd residential addresses may irrigate on Wednesdays and Saturdays; and commercial and irrigation accounts may irrigate on Tuesdays and Fridays. ***Even residential addresses may run irrigation on Mondays; odd residential addresses may irrigate on Saturdays; and commercial and irrigation accounts may irrigate on Thursdays. ^The second and third phase of demand management rates, as proposed by the current rate structure in the San Clemente Municipal Code, can be implemented by action of the City Council in addition to, or in lieu of, other proposed demand reduction actions. 2025 WATER SHORTAGE CONTINGENCY PLAN
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APPENDIX B SAN CLEMENTE MUNICIPAL CODE
CHAPTER 13.12 WATER CONSERVATION

AND WATER SUPPLY SHORTAGE

PROGRAM
Below is the weblink to the current ordinance (last accessed on April 30, 2026) https://library.municode.com/ca/san_clemente/codes/code_of_ordinances?nodeId=TIT13PUSE_CH13.12W ACO
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APPENDIX C NOTICE OF PUBLIC HEARING (PENDING)
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APPENDIX D ADOPTED WSCP RESOLUTION (PENDING)