in collaboration with and
2025 Water Shortage
Contingency Plan
FINAL DRAFT / May 2026
CITY OF SANTA ANA
2025 Water Shortage Contingency Plan
May 2026 / DRAFT
Prepared By: Prepared For:
Carollo Engineers, Inc. City of Santa Ana
707 Wilshire Boulevard, Suite 3920 20 Civic Center Plaza Los Angeles, California 90017 Santa Ana, California 92701 Phone: 213.489.1587 Phone: 714.647.5400
https://www.carollo.com https://www.santa-ana.org
In collaboration with:
This document is released for the purpose of information exchange review and planning only under the authority of Lisa Maddaus, Exp. June 30, 2026, California, C 60047.
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pw://Carollo/CA/MWDOC/204447-000000/03 Reports and Studies/02 Deliverables/Grp3_Santa Ana UWMP/SantaAna_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 4
2.2 Relationship to Wholesalers 5
2.3 Relationship with Wholesaler Water Shortage Planning 7
2.3.1 MET Water Surplus and Drought Management Plan 7
2.3.2 MET Water Supply Allocation Plan 8
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 10
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 17
3.4.3 Operational Changes 17
3.4.4 Additional Mandatory Restrictions 17
3.4.5 Emergency Response Plan (Hazard Mitigation Plan) 18
3.4.6 Seismic Risk Assessment and Mitigation Plan 19
3.4.7 Shortage Response Action Effectiveness 20
3.5 Communication Protocols 20
3.6 Compliance and Enforcement 20
3.7 Legal Authorities 20
3.8 Financial Consequences of WSCP 21
3.9 Monitoring and Reporting 22
3.10 WSCP Refinement Procedures 22
3.11 Special Water Feature Distinction 23
3.12 Plan Adoption, Submittal, and Availability 23
SECTION 4 REFERENCES 24
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Appendices
APPENDIX A DWR SUBMITTAL TABLES
APPENDIX B SANTA ANA MUNICIPAL CODE CHAPTER 39 ARTICLE VI WATER SHORTAGE
CONTINGENCY PLAN
APPENDIX C WATER SHORTAGE COMMUNICATION PROTOCOL
APPENDIX D NOTICE OF PUBLIC HEARING (PENDING)
APPENDIX E ADOPTED WSCP RESOLUTION (PENDING)
Tables
Table 1 Cross-Reference for Standard vs Supplier Shortage Levels 16 Table 2 Agency Contacts and Coordination Protocols 21
Figures
Figure 1 City of Santa Ana Service Area 4
Figure 2 Regional Location of the City of Santa Ana and Other MET Member Agencies 6 Figure 3 Resource Stages, Anticipated Actions, and Supply Declarations 8 Figure 4 AWSDA Reporting Timeline 11
Figure 5 Water Shortage Contingency Plan AWSDA Framework 12
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Abbreviations
% percent
AF acre-feet
AMI advanced metering infrastructure
AWSDA Annual Water Supply and Demand Assessment
BPP Basin Production Percentage
City City of Santa Ana
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
EPA Environmental Protection Agency
FY fiscal year
GAP Green Acres Project
GRP Groundwater Resilience Plan
GSWC Golden State Water Company
GSP Groundwater Sustainability Plan
IAWP Interim Agricultural Water Program
LHMP Local Hazard Mitigation Plan
MCL maximum contaminant level
MET Metropolitan Water District of Southern California
MWDOC Municipal Water District of Orange County
ND non detect
NIMS National Incident Management System
OC Basin Orange County Groundwater Basin
OCWD Orange County Water District
PFAS per- and polyfluoroalkyl substances
PFOA perfluorooctanoic acid
PFOS perfluorooctane sulfonate
ppt parts per trillion
Producers Groundwater Producers
SEMS California Standardized Emergency Management System Supplier Urban Water Supplier
SWP State Water Project
UWMP Urban Water Management Plan
Water Code California Water Code
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WEROC Water Emergency Response Organization of Orange County WSAP Water Supply Allocation Plan
WSCP Water Shortage Contingency Plan
WSDM Water Surplus and Drought Management Plan
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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 Santa Ana (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 plan 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. 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 to greater than 50 percent; 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 percent 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 Metropolitan Water District of Southern California (MET), regional wholesaler for Southern California and the direct supplier of imported water to the City; and Orange County Water 2025 WATER SHORTAGE CONTINGENCY PLAN
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District (OCWD), Orange County Groundwater Basin (OC Basin) manager and provider of recycled water in North Orange County.
Some of the key planning and reporting documents that were used to develop this WSCP are:
Municipal Water District of Orange County (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.
OCWD’s 2025 Groundwater Resilience Plan (GRP) is an adaptive strategies management plan outlining strategic projects to secure reliable future water supplies in the OC Basin. MET’s 2025 UWMP uses assumptions that fall within the plausible futures contemplated in MET’s IRP 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.
OCWD’s -2424 Engineer’s Report provides information on the groundwater conditions, water supply, and basin utilization of the OC Basin.
OCWD’s 2022 Basin 8-1 Alternative is an alternative to the Groundwater Sustainability Plan (GSP) for the OC Basin, provides significant information related to sustainable management of the basin in the past and hydrogeology of the basin, including groundwater quality and basin characteristics, and addresses DWR’s recommendations to ensure long-term basin sustainability. City of Santa Ana’s 2022 Local Hazard Mitigation Plan (LHMP) provides the basis for the seismic and other natural and natural disaster risk analysis of the water system facilities.
SECTION 2 BACKGROUND INFORMATION
The City is one of the oldest cities in Orange County that was incorporated in 1886 and became an original member agency of MET on February 27, 1931. The City is governed by a non-partisan seven-member City Council, elected to serve staggered four-year terms, except for the Mayor, who serves a two-year term. The City Council appoints the City Manager and various members of commissions, committees, and citizen advisory groups, all of which may weigh in on water management issues and decisions for the City.
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2.1 City Service Area
The City is in the heart of Orange County and is the eleventh largest City in California. The City’s Water Utility provides water service within a 27.5 square mile service area. The service area includes the City of Santa Ana and a small neighborhood in the City of Orange, near Tustin Avenue and Fairhaven by the northeast corner of Santa Ana. A map of the City’s water service area is shown in Figure 1.
Figure 1 City of Santa Ana Service Area
Although the City supplements its water supply portfolio with recycled water, the WSCP only applies to its potable water supply. The City is directly involved in wastewater services through its ownership and operation of the wastewater collection system in its service area and sends all collected wastewater to
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Orange County Sanitation District for treatment and disposal. The City provides OCWD Green Acres Project (GAP) recycled water to the southern part of the City, as detailed in Section 6.6 of the City’s 2025 UWMP (Santa Ana, 2026). The City will determine the recycled water demand reduction actions for recycled water based on the availability of supply and to meet necessary wastewater discharge permit requirements.
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 6 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 Bernardino, San Diego, and Ventura counties. Approximately 85 percent 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 1 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 1 vote for each 10 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 City is one of MET’s member agencies that purchases water directly from MET. The City’s location within MET’s service area and Orange County is shown in Figure 2.
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Figure 2 Regional Location of the City of Santa Ana and Other MET Member Agencies
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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 and Water Supply Allocation Plan (WSAP), and other emergency planning efforts as described below.
MET’s WSAP is integral to the WSCP’s shortage response strategy in the event that MET determines that supply augmentation (including storage) and lesser demand reduction measures would not be sufficient to meet 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 provide a framework for actions to take for 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 at 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 supply 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).
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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 in order to communicate the urgency of the region’s water supply situation and the need for further water conservation practices. The 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.
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MET’s Board of Directors originally 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, 2026).
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 up to greater than 50 percent. 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.
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 include 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, 2026).
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, 2026).
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). 2025 WATER SHORTAGE CONTINGENCY PLAN
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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.
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 MET and ongoing conservation program efforts. The City receives the majority of its water supply from groundwater from the OC Basin, as well as supplemental supplies from local recycled water from the OCWD GAP that adds reliability for non-potable water demand. As a result, there is no projected shortage condition due to drought that will trigger customer demand reduction actions until MET notifies the City of insufficient imported supplies. More information is available in the City’s 2025 UWMP Sections 6 and 7 (Santa Ana, 2026).
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 1 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 stage 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.
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This section documents the decision-making process required for formal approval of the City’s AWSDA determination of water supply reliability each year and 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.
3.2.1.1 City Steps to Approve the AWSDA Determination
The AWSDA will be predicated primarily on the OCWD Basin Production Percentage (BPP) and secondarily on MET’s AWSDA outcomes. Figure 4 shows the AWSDA reporting timeline for the City of Santa Ana.
Figure 4 AWSDA Reporting Timeline
The City produces local groundwater from the OC Basin managed by OCWD. The OC Basin is not adjudicated and as such, pumping from the OC Basin is managed through a process that uses financial incentives to encourage Groundwater Producers (Producers) to pump a sustainable amount of water. The framework for the financial incentives is based on establishing the BPP, the percentage of each Producer’s total water supply that comes from groundwater pumped from the OC Basin. The BPP is set uniformly for all Producers by the OCWD Board of Directors on an annual basis. Based on the projected water demand and modeled water supply, over the long-term, OCWD anticipates sustainably supporting a BPP of 85 percent; however, volumes of groundwater and imported water may vary depending on OCWD's actual BPP projections. A supply reduction that may result from the annual BPP projection will be included in the AWSDA.
While the City’s primary source of water is OCWD groundwater, any remaining water to meet retail demands comes from recycled water and the purchase of imported water from MET. As a direct MET member, the AWSDA will be predicated on MET’s WSDM supply demand tracking, which is reported
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monthly to their Board of Directors. MET WSDM planning involves the examination of developing demand and supply conditions for the calendar year, as well as considerations of potential actions consistent with the WSDM Plan. Additionally, City staff simultaneously provide water supply and demand reports to MET to inform them of emerging demand and supply conditions. These monthly analyses provide key information for MET to manage resources to meet a range of estimated demands and adjust to changing conditions throughout the year. Based on the year’s supply conditions and WSDM actions, MET will present a completed AWSDA for its member agencies’ review from which they will then seek Board approval in April of each year. Additionally, MET expects that any triggers or specific shortage response actions that result from the AWSDA will be approved by their Board at that time and this information will be incorporated into the City’s AWSDA.
The Water Resources Manager, or Designee, will be responsible for approval of an AWSDA in June and formally submit to DWR prior to the July 1 deadline.
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, MET imported water supplies, planned water use, and infrastructure considerations.
The balance between projected in-service area supplies, coupled with MET 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 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
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3.2.2.2 Locally Applicable Evaluation Criteria
Within Orange County, there are no significant local applicable criteria that directly affect reliability.
Through the years, the water agencies in Orange County have made tremendous efforts to integrate their systems to provide flexibility to interchange with different sources of supplies. There are emergency agreements in place to ensure all parts of the County have an adequate supply of water. In the northern part of the County, agencies have the ability to meet a majority of their demands through groundwater with very little limitation, except for the OCWD BPP.
The City will also continue to monitor emerging supply and demand conditions related to supplemental imported water from 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 MET’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 to 35 percent 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. 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 all of its customers’ demands with a combination of local groundwater, imported water from MET, and local recycled water. The City’s main source of water supply is groundwater from the OC Basin, with imported water from MET and recycled water making up the rest of the City’s water supply portfolio. In fiscal year (FY) 2024-25, the City relied on approximately 87 percent groundwater and 13 percent imported water. It is projected that by 2050, the water supply portfolio will change to approximately 85 percent groundwater and 15 percent imported water (Santa Ana, 2026).
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 (Santa Ana, 2026). 2025 WATER SHORTAGE CONTINGENCY PLAN
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Water demands in a five-year consecutive drought are calculated as a 3 percent increase in water demand above a normal year for each year of the drought (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 the City’s annual water supply and unconstrained demand using:
(1) current year conditions; and (2) assumed dry year conditions.
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 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 scenarios in each AWSDA as information becomes available and in accordance with best management practices.
Supply and demand analyses for the single-dry year case was based on conditions affecting the SWP as this supply availability fluctuates the most among MET’s, and therefore 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 percent in 2022, a significant decrease from 39 percent in 2021 (MWDOC, 2025).
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 conditions. For a single dry year condition (FY 2013-14), the model projects a 3 percent increase in demand for the OC Basin area where the City’s service area is located (MWDOC, 2025). Detailed information about the model is included in the City’s 2025 UWMP.
The City has documented that it is 100 percent reliable for single dry year demands from 2025 through 2050 with a demand increase of 3 percent from normal demand with significant reserves held by MET, local groundwater supplies, and conservation (Santa Ana, 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 2025 WATER SHORTAGE CONTINGENCY PLAN
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temporarily constrain capabilities, as well as any new projects that may add to system capacity. MET closely coordinates with 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 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 MET and their member agencies 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.
Following is a list of considerations that have the potential to negatively impact water supply reliability and will be considered in the AWSDA:
MET pipeline outages (Orange County Feeder and/or East Orange County Feeder No. 2). City currently has 13 groundwater wells impacted by per- and polyfluoroalkyl substances (PFAS) contamination.
Planned well/pump station rehabilitation/construction projects Unplanned facility outages
Following is a list of considerations that have the potential to positively impact water supply reliability and will be considered in the AWSDA:
Drilling and constructing new wells (such as Washington Well and Flower Well). Completion of PFAS Water Treatment Plant Projects & Well/Pump Station Rehabilitation Projects. Advanced metering infrastructure (AMI) project implementation (expected to result in lower water use and less system losses).
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.
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. Beginning in the summer of 2019, the California State Division of Drinking Water (DDW) began requiring testing for PFAS compounds in some groundwater production wells in the OCWD area.
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 DDW regulations. As DDW 2025 WATER SHORTAGE CONTINGENCY PLAN
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and United States 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.
PFAS have been detected in the OC Basin in very small amounts (ppt), entering primarily via the Santa Ana River whose flows infiltrate into the basin. Despite playing no role in releasing PFAS into the environment, OCWD is working with its cities and retail water districts to remove it from local water supplies in order to comply with new state and federal regulations. More than 100 wells have been impacted due to various state and federal regulations. Fifteen impacted agencies will have to temporarily purchase more costly imported water to replace PFAS contaminated supplies. As of 2025, 53 impacted wells are back online due to close to a billion dollars being spent on state-of-the-art testing, research and piloting of different treatment systems, and design and construction of treatment plants that are now operational.
3.3 Six Standard Water Shortage Levels
Per Water Code Section 10632 (a)(3)(A), Suppliers 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 percent 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 (Table 1).
Table 1 Cross-Reference for Standard vs Supplier Shortage Levels Standard Shortage Levels Percent Shortage Range Suppliers Shortage Levels Percent Shortage Range 1 Up to 10% 1 Up to 10%
2 Up to 20% 2 Up to 20%
3 Up to 30% 3 Up to 30%
4 Up to 40% 4 Up to 40%
5 Up to 50% 5 Up to 50%
6 Greater than 50% 6 Greater than 50%
Source: Water Code Section 10632(a)(3)(B)
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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 MET and OCWD. The City has the ability to pump additional groundwater from the OC Basin or purchase additional imported water from MET as a MET member agency. However, both additional pumped groundwater and purchased imported water are subject to rate penalties from OCWD and MET, respectively.
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 acre-feet [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.
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 considered their operational procedures 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 2025 WATER SHORTAGE CONTINGENCY PLAN
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restrictions as needed based on the existing Santa Ana Municipal Code Chapter 39 Article VI (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 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 Sacramento-San Joaquin River Delta that would cause levee failure and disruption of SWP deliveries.
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 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 City 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 City 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 2025 WATER SHORTAGE CONTINGENCY PLAN
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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 manmade 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 to water infrastructure and speed recovery. This includes alert and notification, EOC activation, direction and control, and mutual aid. 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 6 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 Santa Ana Emergency Response Plan
The City will also refer to its current American Water Infrastructure Act Risk and Resilience Assessment, Emergency Response Plan, and Local Hazard Mitigation Plan in the event of a locally isolated catastrophic supply interruption. The LHMP describes the City’s approach to enhancing emergency services and protecting life and property, among other goals. The water supply specific mitigation measures include increased security, backup power, and reducing flooding risk at water facilities (Santa Ana, 2022).
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 2025 WATER SHORTAGE CONTINGENCY PLAN
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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. (Santa Ana, 2022).
3.4.7 Shortage Response Action Effectiveness
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
Timely and effective communication is a key element of the WSCP implementation. Per the Water Code Section 10632 (a)(5), the City has established communication protocols and procedures to inform customers, the public, interested parties, and local, regional, and state governments regarding any current or predicted shortages as determined by the AWSDA described pursuant to Section 10632.1; any shortage response actions triggered or anticipated to be triggered by the AWSDA described pursuant to Section 10632.1; and any other relevant communications. The City’s Water Shortage Communication Plan is documented in Appendix C.
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. Procedures to ensure customer compliance are described in Section 3.5 Communication Protocols and customer enforcement, appeal, and exemption procedures as defined in the existing Santa Ana Municipal Code Chapter 39 Article VI (Appendix B). The City intends to update any enforcement procedures in a subsequently adopted ordinance which will supersede the existing ordinance.
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 as directed in the City’s Water Shortage Response Ordinance (Appendix B).
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.
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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 2 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 2 Agency Contacts and Coordination Protocols
Contact Agency Coordination Protocols
Executive Director of Public Works City of Santa Ana Public Works Agency Call/email/ Water Resource Manager City of Santa Ana Public Works Agency Call/email Water Manager City of Orange Public Works Department Call/email Director of Public Works City of Garden Grove Call/email Director of Public Works Orange County Public Works Department 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.
During a catastrophic interruption of water supplies, prolonged drought, or water shortage of any kind, the City will experience a reduction in revenue due to reduced water sales. Throughout this period of time, expenditures may increase or decrease with varying circumstances. Expenditures may increase in the event of significant damage to the water system, resulting in emergency repairs. Expenditures may also decrease as less water is pumped through the system, resulting in lower power costs. Water shortage mitigation actions will also impact revenues and require additional costs for drought response activities such as increased staff costs for tracking, reporting, and communications.
The City receives water revenue from a service charge and a commodity charge based on consumption.
The service charge recovers costs associated with providing water to the serviced property. The service charge does not vary with consumption, and the commodity charge is based on water usage. Rates have been designed to recover the full cost of water service in the charges. Therefore, the total cost of purchasing water would decrease as the usage or sale of water decreases. In the event of a drought emergency, the City will impose excessive water use penalties on its customers, which may include additional costs associated with reduced water revenue, staff time taken for penalty enforcement, and advertising the excessive use penalties. The excessive water use penalties are further described in the City’s Municipal Code Chapter 39 Article VI (Appendix B).
However, there are significant fixed costs associated with maintaining a minimal level of service. The City will monitor projected revenues and expenditures should an extreme shortage and a large reduction in water sales occur for an extended period of time. To overcome these potential revenue losses and/or expenditure impacts, the City may use reserves. If necessary, the City may reduce expenditures by delaying implementation of its Capital Improvement Program and equipment purchases to reallocate 2025 WATER SHORTAGE CONTINGENCY PLAN
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funds to cover the cost of operations and critical maintenance, adjust the work force, implement a drought surcharge, and/or make adjustments to its water rate structure.
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.
Monitoring and reporting key water use metrics is fundamental to water supply planning and management. Monitoring is also essential in times of water shortage to ensure that the response actions are achieving their intended water use reduction purposes, or if improvements or new actions need to be considered (see Section 3.10). Monitoring for customer compliance tracking is also useful in enforcement actions.
Under normal water supply conditions, potable water production figures are recorded daily. Weekly and monthly reports are prepared and monitored. In addition, once the Advanced Meter Infrastructure project is complete, the City will be able to monitor the consumption of various customer classes. This data will be used to measure the effectiveness of any water shortage contingency level that may be implemented. As levels of water shortage are declared by MET, the City will follow implementation of those levels as appropriate based on the City’s risk profile provided in UWMP Chapter 6 and continue to monitor water demand levels. When MET calls for extraordinary conservation, MET’s Drought Program Officer will coordinate public information activities with the City and monitor the effectiveness of ongoing conservation programs.
The City will participate in monthly member agency manager meetings with both MET and OCWD to monitor and discuss monthly water allocation charts. This will enable the City to be aware of imported and groundwater use on a timely basis as a result of specific actions taken responding to the City’s WSCP.
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.
The City’s WSCP is prepared and implemented as an adaptive management plan. The City will use the monitoring and reporting process defined in Section 3.9 to refine the WSCP. In addition, if certain procedural refinements or new actions are identified by City staff, or suggested by customers or other interested parties, the City will evaluate their effectiveness, incorporate them into the WSCP, and implement them quickly at the appropriate water shortage level.
It is envisioned that the WSCP will be periodically re-evaluated to ensure that its shortage risk tolerance is adequate and the shortage response actions are effective and up to date based on lessons learned from implementing the WSCP. The WSCP will be revised and updated during the UWMP update cycle to incorporate updated and new information. For example, new supply augmentation actions will be added, and actions that are no longer applicable for reasons such as program expiration will be removed. 2025 WATER SHORTAGE CONTINGENCY PLAN
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However, if revisions to the WSCP are warranted before the UWMP is updated, the WSCP will be updated outside of the UWMP update cycle. In the course of preparing the AWSDA each year, City staff will routinely consider the functionality of the overall WSCP and will prepare recommendations for the Director of Public Works if changes are found to be needed.
3.11 Special Water Feature Distinction
Per Water Code Section 10632 (b), the City has defined water features that are artificially supplied with water, including ponds, lakes, waterfalls, and fountains, separately from swimming pools and spas, as defined in subdivision (a) of Section 115921 of the Health and Safety Code, in the City’s Municipal Code Chapter 39 Article VI (Appendix B).
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 14 days in advance of the public hearing on May 19, 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 D.
City held the public hearing for the Draft 2025 UWMP and Draft WSCP on May 19, 2026 at the City Council meeting. The City Council reviewed and approved the 2025 UWMP and the WSCP at its May 19, 2026 meeting after the public hearing. See Appendix E 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.
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SECTION 4 REFERENCES
City of Santa Ana. (2026). 2025 Urban Water Management Plan.
City of Santa Ana. (2022, October). 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.