HomeMy WebLinkAbout2017-01-11 Utilities Advisory Commission Agenda Packet
NOTICE IS POSTED IN ACCORDANCE WITH GOVERNMENT CODE SECTION 54954.2(a) OR 54956
I. ROLL CALL
II. ORAL COMMUNICATIONS
Members of the public are invited to address the Commission on any subject not on the agenda. A reasonable
time restriction may be imposed at the discretion of the Chair. State law generally precludes the UAC from
discussing or acting upon any topic initially presented during oral communication.
III. APPROVAL OF THE MINUTES
Approval of the Minutes of the Utilities Advisory Commission Meeting held on November 2, 2016
IV. AGENDA REVIEW AND REVISIONS
V. REPORTS FROM COMMISSIONER MEETINGS/EVENTS
VI. DIRECTOR OF UTILITIES REPORT
VII. COMMISSIONER COMMENTS
VIII. UNFINISHED BUSINESS
None
IX. NEW BUSINESS
1. Staff Recommendation that the Utilities Advisory Commission Recommend that the Action
City Council Adopt a Resolution Approving the Updated City of Palo Alto Utilities Legislative
Policy Guidelines
2. Recommendation that Council Approve the 2017 Water Integrated Resource Action
Plan Guidelines
3. Amendment to Utilities Rule and Regulation 27, Generating Facility Interconnections Discussion
4. Selection of Potential Topic(s) for Discussion at Future UAC Meeting Action
NEXT SCHEDULED MEETING: February 1, 2017
ADDITIONAL INFORMATION
The materials below are provided for informational purposes, not for action or discussion during UAC Meetings (Govt.
Code Section 54954.2(a)(2)).
Informational Report
Public Letter(s) to the UAC
UTILITIES ADVISORY COMMISSION – SPECIAL MEETING
WEDNESDAY, JANUARY 11, 2017 – 7:00 P.M.
COMMUNITY MEETING ROOM
Palo Alto City Hall – 250 Hamilton Avenue
Chairman: James F. Cook Vice Chair: Michael Danaher: Commissioners: Arne Ballantine, Lisa Forssell, A. C. Johnston, Judith Schwartz and Terry Trumbull Council Liaison: Gregory Scharff
Utilities Advisory Commission Minutes Approved on: Page 1 of 13
UTILITIES ADVISORY COMMISSION MEETING
MINUTES OF NOVEMBER 2, 2016
CALL TO ORDER
Chair Cook called to order at 7:00 p.m. the meeting of the Utilities Advisory Commission (UAC).
Present: Chair Cook, Vice Chair Danaher, Commissioners Forssell, Johnston, and Trumbull
Absent: Commissioners Ballantine, Schwartz, and Council Liaison Scharff
ORAL COMMUNICATIONS
Richard Cassel, speaking on behalf of the Unitarian Universalist Church at 505 East Charleston,
discussed the solar CLEAN project they began planning one year ago and were ready to start
construction until the City of Palo Alto Utilities told them they could not connect to the 4,160V
(4kV) system. They were told they would need to pay an additional $100,000 in order to
connect to the 12,000V (12kV) system. Conversion of the 4kV system was supposed to be
completed already, based on the CIP project map, and the City should cover the additional
costs to allow the system to connect to the 12 kV system as part of the capital improvement
project for 4kV conversion projects.
Utilities General Manager Ed Shikada asked Mr. Cassel to speak with Dean Batchelor, Utilities
Chief Operating Officer, about his project.
APPROVAL OF THE MINUTES
Commissioner Trumbull proposed the following changes to the minutes: (1) page 4, second
paragraph under “Discussion of Energy Storage and Microgrid Applications in Palo Alto” to:
“Commissioner Trumbull noted the Commission’s recent discussion of potentially encouraging
customers to switch from natural gas to electricity, and asked about reliability if a customer
used only electricity.”; and (2) page 5, delete first sentence of third to last paragraph or
substitute under “Discussion of Energy Storage and Microgrid Applications in Palo Alto” to:
“Commissioner Trumbull again asked what storage techniques could be used to protect
customers from electrical outages if the City adopted an electrification strategy.”
Commissioner Trumbull moved to approve the minutes from the October 5, 2016 UAC meeting
and Vice Chair Danaher seconded the motion. The motion carried unanimously (5-0) with Chair
Cook, Vice Chair Danaher, and Commissioners Forssell, Johnston, and Trumbull voting yes and
Commissioners Ballantine and Schwartz absent.
DRAFT
Utilities Advisory Commission Minutes Approved on: Page 2 of 13
AGENDA REVIEW AND REVISIONS
Chair Cook advised that New Business Item #4 (Fiber and Wireless Update) would be taken up
prior to the other New Business items.
REPORTS FROM COMMISSION MEETINGS/EVENTS
Commissioner Forssell reported that she attended the Global Climate and Energy Project at
Stanford, a two-day symposium covering topics such as climate change policy, solar PV
technology, other renewable energy policy, biomass and transportation.
UTILITIES DIRECTOR REPORT
1. The Carbon Neutral Gas Plan was discussed by the Finance Committee on October 18 . The
committee discussed the relative values of biogas versus environmental offsets and voted
to maximize emissions reductions with the funds. Thank you to Chair Cook and
Commissioner Forssell for attending the meeting and assisting the Finance Committee with
its discussion. The plan will be discussed at the City Council on November 14.
2. New Customer Service Integrated Voice Response: On October 20, CPAU completed a
“soft launch” of a new Integrated Voice Response (IVR) phone system for Utilities customer
billing and payment. The new system is designed to enhance the service and convenience
for City residents and businesses interacting with us for utility account services. Customers
will be able to call CPAU at their convenience and pay their utility bill over the phone using a
credit card, as well as listen to recorded information about their account, such as balance,
due date, amount and date of last payment. This new system will allow Customer Service
Center staff and management to better track and report on critical metrics such as call
volumes, call trends, follow-up to customer interactions and customer satisfaction.
3. Japanese Call Center Association Visit: On October 26, the Call Center Association of Japan
visited CPAU to learn about our Utilities Customer Service Call Center operations. Customer
Service Manager Anthony Enerio and Communications Manager Catherine Elvert presented
to the group about CPAU services, IVR rollout, initiatives to facilitate paperless interactions
with Utilities customers, and exploration of advanced metering and other technologies to
improve efficiency. The delegation also toured the Customer Service Call Center.
4. Utilities Customer Satisfaction Surveys: This month, CPAU is conducting online customer
satisfaction surveys of our business and residential utility customers. The surveys are
designed to assess customer opinions of issues such as quality of services, reliability,
affordability, communication, customer service and program uptake. Surveys of large
business, Key Account and small to medium-sized commercial customers are currently
being administered by E Source, a company that provides market research and technical
advisory services for electric and natural gas utilities. Later this month, CPAU will survey a
sample of residential electric customers in partnership with RKS Research and Consulting.
This survey of Palo Alto residents follows a similar statewide survey conducted in July of
municipal and investor-owned utility customers.
5. Recent and Upcoming Events or Workshops
a. October 23: CPAU tabled at an Emergency Preparedness Fair at Addison Elementary
b. November 5: Home Efficiency Genie Workshop at the Mitchell Park Community Center
Utilities Advisory Commission Minutes Approved on: Page 3 of 13
6. The Joint Study Session between the Council and UAC is being re-scheduled for early 2016
so that it will be with the new Council.
7. Finally, I would like to announce that Jane Ratchye has announced her retirement from the
City effective at the end of this year. She will miss her time spent with the UAC.
COMMISSIONER COMMENTS
None.
UNFINISHED BUSINESS
None.
NEW BUSINESS
ITEM 1: ACTION: Staff Recommendation that the Utilities Advisory Commission Recommend
that the City Council Adopt a Resolution to Continue the Palo Alto Clean Local Energy Accessible
Now (CLEAN) Program and Amend Associated Program Rules: (1) for Local Solar Resources with
a Tiered Pricing Structure Starting at 16.5 ¢/kWh to a 3 MW Cap Which Declines to the City’s
Avoided Cost Value Upon Receiving 6 MW of Program Capacity; and (2) for Local Non -Solar
Resources With No Capacity Limit at a Price of 8.4 ¢/kWh to 8.5 ¢/kWh
Assistant Director Jane Ratchye provided a presentation summarizing the written report . She
noted the history of the Palo Alto CLEAN program, including the Council confirming the 16.5
cents per kilowatt-hour (¢/kWh) price for local solar many times since December 2012. Ratchye
noted that the program has received applications this year totally about 1.5 megawatts (MW)
and that another customer is interested in the program for a large system . She said that the
program cap is 3 MW and that the new customer is determining how big a system to install and
could use up the remaining available capacity. That customer is interested in what the program
price for capacity in excess of the 3 MW cap.
Ratchye noted that since the program was launched in 2012, the avoided cost of local solar
(including the cost of the energy, the environmental attributes, local capacity value,
transmission and ancillary service value, avoided transmission and distribution system losses,
and congestion value) has declined to the current avoided cost of 8.9 ¢/kWh for a 20-year
contract. She said that the avoided cost of local non-solar renewable supplies has increased
from last year from 8.1 ¢/kWh to 8.4 ¢/kWh for a 20-year contract.
Ratchye described staff’s recommendation , which is to continue the 16.5 ¢/kWh price for the
first 3 MW of local solar projects, but to expand the program while lowering the price until 6
MW of capacity is reached, then reducing the price to the avoided cost value. She said that the
proposal is to reduce the price to 14 ¢/kWh for the 4th MW, 12 ¢/kWh for the 5th MW, and 10
¢/kWh for the 6th MW. For local non-solar projects, staff recommends that the price continue at
the avoided cost, which has increased to 8.4 ¢/kWh for a 20-year contract and 8.5 ¢/kWh for a
25-year contract. The 3 MW cap would be removed for both solar and non -solar projects since
there is no rate impact when the price is equal to the avoided cost . Ratchye noted that staff’s
recommendation increases the excess cost from $380,000/year to $535,000/year, or $10.7
million over 20 years.
Utilities Advisory Commission Minutes Approved on: Page 4 of 13
Ratchye explained that staff considered several alternatives including the following:
1. Option 1 would end the program when 3 MW is reached.
2. Option 2 would extend the program after 3 MW is reached, but reduce the price to the
avoided cost for all capacity after the first 3 MW.
3. Option 3 would end the program when the last project is added which would push the
program over the 3 MW limit.
4. Option 4 would eliminate the cap and continue the 16.5 ¢/kWh for an unlimited amount
of capacity.
Ratchye noted that in Option 3, since applications for projects totally about 1.5 MW have
already been received, if the last project was sized at 3 MW, the total capacity at 16.5 ¢/kWh
could be 4.5 MW, well over the existing program’s 3 MW limit.
Public Comment
Richard Cassel said that solar system developers and site owners need certainty around the
costs they may incur to install a system. He said that the utility should include a guarantee that
they will pay the cost to interconnect and not have a lot of costs that an applicant to the
program must pay since those costs are not calculated in. When someone makes a proposal,
the utility should provide the interconnection.
Commissioner Forssell asked what the rate that would be provided to solar systems and how
this relates to the Net Energy Metering (NEM) program cap, which was recently raised. Ratchye
explained that NEM is for energy designed to be used at the building loca tion, but that the
CLEAN program is a feed-in tariff program whereby all the energy generated by the solar
system is purchased by the City of Palo Alto Utilities (CPAU) under a long -term power purchase
agreement (PPA). She said that the projects could have chosen NEM instead of the CLEAN
program, but there is a 1 MW per project cap under the NEM program. The CLEAN price is the
subject of this discussion—and it is unrelated to the NEM program, or the NEM cap—and the
price currently 16.5 cents/kWh for a 20- or 25-year PPA term so the price is known and all the
energy produced is purchased by CPAU.
Commissioner Johnston asked what non-solar local renewable energy options there are in the
City. Ratchye indicated that they are unlikely, but could include small wind generators, or an
anaerobic digester, for example.
Vice Chair Danaher asked why we would the City pay more for solar energy than its pays for
solar energy located elsewhere. He said that in 2012 when the CLEAN Program was established,
we didn’t have any solar renewable energy in the portfolio or carbon neutral supplies and
encouraging local solar was valuable. However, he recommended that the program limit be
reduced to 2 MW from 3 MW and end the program early since there is no carbon benefit given
the City’s electric supply portfolio. He said that if the program was extended, the additional
benefit of local solar beyond the avoided cost should be very low, perhaps a penny per kWh . He
said that the additional cost of $380,000 per year for 20 or 25 years could instead be used to
hire additional staff or to do many other beneficial things. He recommended capping the
program at the applications that are already in hand, but no more than 3 MW.
Chair Cook asked about the process for determining interconnection costs (to address the
question from the public). He said that for remotely located solar projects, there is a process for
Utilities Advisory Commission Minutes Approved on: Page 5 of 13
determining interconnection costs early in the project development. General Manager Shikada
said that CPAU is working on the question and expects to be able to figure out a path forward
for the applicant in question.
Chair Cook agreed with the solar developers need certainty. He said that the CLEAN program
does have certainty with respect to the price. Chair Cook said that he understands that remote
solar is cheaper and that the avoided cost calculation captures the value of local solar. He said
that he is torn about the program or whether there is another incentive for local solar that the
City should offer. He said it makes sense to limit the program to 3 MW including the existing
applications and then go to the avoided cost price, which includes the value of local solar. Chair
Cook added that he would like to continue to have programs to clean the air, but the carbon
benefits of local solar are the same as for remote solar. He said that the stepping down the
benefits over time as proposed by staff also makes sense and mimics the state’s SB1 program
that reduced the solar rebates over time.
Vice Chair Danaher noted that the additional $130,000/year per MW ($380,000 divided by 3
MW) in excess cost to extend the incentive above the avoided cost beyond 3 MW is not the
best use of ratepayer funds and that ratepayer money could be used for other valuable
purposes such as expanding electric vehicle charging infrastructure and electrification initiatives
that would result in carbon reductions. He noted that applicants are not pounding on the City’s
door for this program and that there wouldn’t be a problem with stopping the program after
processing the applications received to date. Vice Chair Danaher said that when Council
extended the program, it had not yet approved the latest large scale, very low price solar PPA .
Commissioner Johnston asked if local solar provides resilience or reliability for the local electric
distribution system. Vice Chair Danaher said that he talked to Commissioner Ballantine and
confirmed that the common inverters used do not allow the system to remain energized and
producing energy when there is an outage on the distribution system . It is possible to change
that requirement and require them to be “grid -independent”, but he is not sure how
complicated that is.
Ratchye said that there is a distinction between the NEM application for local solar when the
energy is used on-site versus a feed-in tariff application, in which all the energy generated is fed
into the distribution grid. In the latter case, which is what the CLEAN program is for, CPAU does
not want the system to continue to generate electricity in an electric outage on the distribution
system for safety reasons. There may be other technologies that can address this, but it is a
bigger issue that just requiring smart inverters. Ratchye added that Commissioner Ballantine
has mentioned that Rule 21 that is applicable to the investor -owned utilities at the California
Public Utilities Commission (CPUC) is being updated to address this issue . She advised that
CPAU is planning this December to update its Rule 27 related to interconnections to be
consistent with the CPUC’s Rule 21.
Commissioner Forssell said that the City should not reduce the system cap, but should honor
the 3 MW cap in the current program. She indicated that she is supportive of reducing the price
to the avoided cost after 3 MW is reached.
Vice Chair asked why the City should maintain the 3 MW cap since there is only 1.5 MW of
applications so reducing the cap to 2 MW or 1.5 MW would not affect anyone . Commissioner
Utilities Advisory Commission Minutes Approved on: Page 6 of 13
Forssell said that there is another customer who is interested in participating in the program .
Ratchye confirmed that there is a customer who is contemplating a large system that would
take the program over the 3 MW cap. That customer is waiting until they understand what will
happen to the program after the 3 MW cap is reached before deciding on what size system they
will submit an application for. If the cap was cut to the amount equal to the systems for which
there are currently applications (about 1.5 MW), or even to 2 MW, that would shrink the
system that this customer would consider and we know that they are considering a large
enough system that would take the program well over the current 3 MW cap.
Commissioner Forssell said that she supported maintaining the 3 MW cap sin ce that
information is being used by potential applicants, but she also sees no reason to extend the
program beyond 3 MW by stepping down the price an supports moving to the avoided cost
after reaching 3 MW. The avoided cost should still provide an incentive for local solar as the
cost of local solar continues to fall. She asked if the avoided cost calculation would be
recalculated every year to keep pace with the best estimates . Ratchye said that she anticipates
that staff would return every year with any adjustments to the avoided cost estimates.
Commissioner Johnston asked if there is a benefit to promoting local solar. He said that if the
contract price is reduced to the avoided cost after reaching 3 MW, then that is effectively
ending the program after reaching 3 MW. He said that would mean that the City does not
believe that there are any extra benefits to local solar beyond the components of the avoided
cost calculation.
Vice Chair Danaher replied that he didn’t believe there are any additional benefits of local solar
beyond those captured in the avoided cost calculation . He said that there may be a benefit
from shading, but that awnings are inexpensive. He added that the City could put signs up that
advertise that the City has 100% carbon neutral electric supplies.
Chair Cook noted that we are still supporting the NEM program, which is an incentive for local
solar as well as the NEM successor program.
Commissioner Johnston noted that the City still buys some non-renewable power throughout
the year. Vice Chair Danaher agreed, but said that this program won’t change that. Vice Chair
Danaher said that non-renewable power will still be needed to balance loads on certain hours,
days, and months.
Chair Cook said that in normal hydro year, the City doesn’t buy extra power. He suggested
designing a program that doesn’t overcommit the renewable energy.
Vice Chair Danaher reiterated that he sees better uses for the money than overpaying for local
solar energy. He noted that he read through the Water Integrated Resource Plan and saw that
there are far better uses for ratepayer funds than local solar such as recycled water and other
programs to increase the reliability of the water supplies.
ACTION:
Chair Cook made a motion that the UAC recommend that Council raise the Palo Alto CLEAN
program price for local non-solar eligible renewable energy resources to the updated avoided
cost of such energy (8.4 ¢/kWh for a 20-year contract term, or 8.5 ¢/kWh for a 25-year contract
Utilities Advisory Commission Minutes Approved on: Page 7 of 13
term), from the prior price (8.1 ¢/kWh for a 20-year contract term, or 8.2 ¢/kWh for a 25-year
contract term), and to remove the program limit of 3 MW for local non -solar eligible renewable
resources. Commissioner Trumbull seconded the motion. The motion carried unanimously (5-0)
with Chair Cook, Vice Chair Danaher, and Commissioners Forssell, Johnston, and Trumbull
voting yes and Commissioners Ballantine and Schwartz absent.
Commissioner Forssell made a motion that the UAC recommend that Council maintain the
current CLEAN price of 16.5 cents per kilowatt-hour (¢/kWh) for a 20-year or 25-year contract
term for a maximum of 3 MW of capacity and, for any capacity over 3 MW, reduce the price to
the avoided cost of such energy (8.9 ¢/kWh for a 20-year contract term, or 9.1 ¢/kWh for a 25-
year contract term) and remove the program limit of 3 MW for local solar resources. Chair Cook
seconded the motion. The motion carried (4-1) with Chair Cook, Vice Chair Danaher, and
Commissioners Forssell and Trumbull voting yes, Commissioner Johnston voting no and
Commissioners Ballantine and Schwartz absent. Commissioner Johnston said he voted no as he
supported the staff recommendation of reducing the price in tiers until 6 MW of capacity was
reached before moving to a price based on the avoided cost.
ITEM 2. DISCUSSION: Utilities Advisory Commission Review and Discussion of the Draft 2017
Water Integrated Resource Plan Guidelines
Senior Resource Planner Karla Dailey provided a presentation summarizing the written report.
She said that the Water Integrated Resources Plan (WIRP) was ready to be updated since the
recent drought has reinforced that there is a need for water in water shortages and there is
regulatory risk since the State Water Resources Control Board showed a willingness to regulate
water use by mandating water use reduction. In addition, there are ongoing cost increases from
both the City’s potable water supplier, the San Francisco Public Utilities Commission (SFPUC),
and for the Santa Clara Valley Water District’s (SCVWD) supplies. The City effort to develop a
comprehensive strategic plan for recycled water, the Council’s dedication to water
sustainability through the Sustainability and Climate Action Plan process and the community’s
interest in water are all also driving the need for a WIRP.
Dailey listed the water supply options evaluated in the WIRP and the attributes considered. She
noted that the WIRP did not evaluate recycled water (since it is being evaluated separately in
the Recycled Water Strategic Plan), desalination, a sale of the City’s excess water allocation of
SFPUC water, small-scale irrigation wells, the use of treated, contaminated water, “nuisance”
groundwater from the Oregon Expressway underpass or basement dewatering, graywater,
black (i.e. sewer) water, and stormwater.
Dailey said that, after looking at all the attributes, staff concluded that SFPUC water is more
expensive but has highest water quality, the cost of SCVWD supplies may increase dramatically
and SCVWD does not have excess treated water to sell, groundwater is susceptible to
mandated water use reductions like imported supplies, blending groundwater with SFPUC
water at El Camino is the least expensive, most sustainable alternative to 100% SFPUC supplies,
but water quality may be an issue, reliability and sustainability can be achieved by reducing
potable water demand through expanding use of recycled water.
The recommended guidelines include:
Pursue all cost-effective water efficiency and conservation;
Utilities Advisory Commission Minutes Approved on: Page 8 of 13
Survey potentially impacted customers about their preference for SFPUC water versus blended
water;
Proceed with the Recycled Water Strategic Plan to determine how to reduce the demand for
imported water; and
Continue to investigate ways to increase the use of non-traditional, non-potable sources such as
black water, storm water, and nuisance water from basement construction.
Public comment
Keith Bennet, Save Palo Alto Groundwater, said that he wanted to talk about water pumped
out from basement construction and groundwater protection. He said that 200 million gallons
was dumped into the Bay from 8 residential basements in 2016, equal to 7% the amount the
City buys from the SFPUC and 100% of the recharge of the aquifer from precipitation for a
normal rain year. In 2015 there were 13 or 14 basements constructed in Palo Alto and the
allowed pumping time was longer so he assumes the amount of water discharged to the Bay
was greater than in 2016. He said discharging freshwater to the Bay according to the WIRP is to
be discouraged. He said that the water moving through the soil instead of the storm drain is
valuable for pushing saltwater out of the groundwater. He said shallow groundwater is of very
high quality and can be used for irrigation, including irrigation of Redwoods. He said the water
is usually at 10 feet or less and easily accessible. He said the San Mateo Basin study shows the
shallow and deep aquifers are connected. Proven alternative construction methods exist and
are used in the Netherlands. This is a valuable resource and pumping and dumping the water is
not sustainable. Pumping for basements contradicts the desire to protect groundwater. Utilities
should change the WIRP to recognize the value of the shallow aquifer. He wants Utilities to ask
Council to protect groundwater and restrict pumping and dumping from basement
construction.
Commissioner Trumbull said the report was excellent. He urged the City to investigate the
items that are recommended in the guidelines.
Commissioner Johnston asked how we would do a survey to evaluate whether people would
prefer Hetch Hetchy to Groundwater. Dailey said she had considered blind tastings but said
Utilities would have to consult a survey expert.
Commissioner Danaher said his wife doesn’t want water that tastes like Los Altos water. He
suggested online surveys won’t be valuable but taste test might. It’s staggering that basement
dewatering uses so much water and that alternative construction methods and/or more use of
the water should be investigated. He wondered about how easily Palo Alto’s groundwater is
recharged and was heartened that more studies on groundwater will be done and that more
work will be done on recycling and grey water. Building codes should be examined to include
more grey water. He said the assumed availability of SFPUC water is too rosy. Looking at last 80
years is not a good baseline to predict the impact of climate change. The plan should have
different scenarios showing different assumptions regarding the future availability of Hetch
Hetchy water. He asked if the plan will be updated after the Recycled Water Strategic plan is
finished. Dailey confirmed that it would.
Commissioner Forssell said she appreciated the report and public comment. We switched water
supplies in the past and the change was noticeable. So that could be used to determine
people’s attitude about water quality. Dailey said the SFPUC switches water supplies a couple of
Utilities Advisory Commission Minutes Approved on: Page 9 of 13
times a year, and customers always notice. Assistant Director Ratchye clarified that the water is
still SFPUC water not groundwater. She is interested in the Recycled Water Strategic Plan.
Chair Cook said he agreed with Danaher and that Palo Alto needs to be prepared for more dire
cuts in water supply in the future. He said the public comment was compelling and that the
scale is mind boggling. We recognize that groundwater is a shared resource. He pondered a
temporary halt on dewatering may be in order while more studies are done. He said the way
we source and use our water is very important.
ITEM 3. ACTION: Selection of Potential Topic(s) for Discussion at Future UAC Meeting
Commissioner Forssell said that she would like to hear about electrification and also about the
City’s carbon accounting.
Vice Chair Danaher suggested that the General Manager could provide a top -down overview of
the Utilities Department indicating where the challenges are and the outlook and focus areas
for the future.
General Manager Shikada indicated that those two issues could be discussed as they relate to
upcoming issues. He said that electrification could be discussed when the UAC reviews the
related sustainability implementation plans. Also, the Utilities top-down view could be
discussed in the context of the Utilities Strategic Plan.
Commissioner Trumbull suggested that educational briefings on various could be provided
along the year so that the Commission would be better informed when decisions on those
topics arise.
Chair Cook advised that the December UAC meeting should be cancelled if there are no items
other than the updated legislative guidelines. General Manager Shikada agreed.
ACTION:
None.
ITEM 4. DISCUSSION: Fiber and Wireless Update
Chief Information Office Jonathan Reichental and Utilities Senior Management Analyst Jim
Fleming provided an update regarding Fiber-to-the-Premises (FTTP) and wireless activities,
including Google Fiber, AT&T Fiber, Comcast, a summary of the public-private partnership
Request for Information, and potential recommendations for discussion.
Reichental reported that Google Fiber is “pausing” its plan to build in the San Jose area,
including in Palo Alto. The delay is indefinite and no target date has been provided by Google
senior personnel. This indefinite delay also applies to a potential “co-build” agreement. AT&T
has rebranded its “GigaPower” high-speed Internet service and it is now called AT&T Fiber. City
staff is currently processing permits for two cabinets submitted by AT&T. AT&T plans to submit
more permits for cabinets in 2017. AT&T has also committed to engaging in continuing
discussions with the City to explore creative and innovative ideas for fiber and wireless.
Comcast is targeting a citywide DOCSIS 3.1 launch starting in the second quarter of 2017.
DOCSIS 3.1 supports Internet speeds of 10 Gigabits per second for downloads downstream and
Utilities Advisory Commission Minutes Approved on: Page 10 of 13
1Gbps upstream - the level of speeds typically only available with a fiber optic connection.
Comcast informed the City that it has no interest in a co-build partnership.
Fleming provided the highlights of the Request for Information (RFI) issued to determine if
there is any interest from the private sector in partnering with the City t o build a citywide FTTP
network. The RFI was distributed to approximately 40 vendors in May 2016 and the City
received eight responses. Two responses were deemed to be incomplete and the other six
responses generally did not align with the City’s objective laid out in the RFI, including City
ownership of the network, ubiquitous service and open access. Based on a recommendation by
the City’s consultant, CTC Technology & Energy, interviews were conducted with three
companies for information collection purposes. The status of Google Fiber at the time the RFI
was issued may have discouraged more responses.
The firms interviewed were Comcast, Axia and N1/UTOPIA:
Comcast’s response was focused on pointing out to the City that they currently offer
advanced telecom services, with plans to upgrade their voice, video and data
products in the near future, including the launch of DOCSIS 3.1 for gigabit Internet.
Axia was closest to the City’s expectations, but largely did not align with the City’s
objective to own the network. Axia’s approach for FTTP entails minimal financial risk
for the City. Axia would finance, build and own the network based on attaining a 40
percent “expression of interest” in the community. Axia is also interested in
acquiring the City’s dark fiber network. Axia has no interest in a co -build agreement
with the City.
N1/UTOPIA’s model would require the City to finance and build an open access FTTP
network, while they would provide design and engineering services under a
consulting agreement. N1/UTOPIA would help the City to operate the network and
facilitate interconnection with Internet Service Providers (ISPs) who would provision
voice, video and data services on the network. N1/UTOPIA’s operational services
would be provided under a revenue sharing agreement with the CIty. The City
would be required to handle customer billing and colle ction of the transport fees
that would be paid by the ISPs to provide services over the open access network.
Reichental and Fleming reviewed the following potential recommendations for the City Council:
• Explore and identify appropriate funding models to build and operate a municipally-
owned ubiquitous fiber-to-the-premises network;
• Concurrently issue a solicitation to design a Fiber-to-the-Node network, and include
an option for respondents to also quote for building last mile or incentivize market
to build the last mile;
• Proceed with expanding Wi-Fi deployments for unserved City facilities (e.g. portions
of Lucie Stern and Cubberley);
• Not proceed with Wi-Fi deployments in high traffic retail areas which are already
being served;
• Reevaluate the approach to an implementation of a “Dig Once” ordinance.
City Manager James Keene noted that we have been working on fiber sin ce he arrived eight
years ago. Since the market is constantly changing and Google Fiber has gone dormant, t he
Council, UAC and the community need to align their policy and demand for fiber. The
Utilities Advisory Commission Minutes Approved on: Page 11 of 13
incumbents will continue to compete and upgrade their networks based on customer demand.
If the City goes out again with another partnership RFI, it still may not yield a viable solution.
Should the City figure out how to fund the $77M network? The Fiber-to-the-Node concept
could be funded by existing Fiber reserves, but that doesn’t mean it’s a wise decision. It’s time
to have a discussion with Council and UAC to refocus the objectives in the new market
environment.
Vice Chair Danaher asked about AT&T’s willingness to discuss creative ideas. Reichental replied
that Council asked staff to explore with AT&T and Google Fiber ways to incentivize ubiquitous
service. AT&T asked for more clarification about potential scenarios. AT&T is enthusiastic
about their new gigabit offering; they are open to creative discussions with the City. Even
though there aren’t any substantive ideas at this point from either side, AT&T has not closed
the discussion.
Vice Chair Danaher asked what the City wouldn’t get if AT&T didn’t deploy its upgrade.
Reichental replied that deployment is market driven and AT&T will only build cabinets where
there is consumer interest. The current U-verse service does not reach every home in Palo
Alto.
Vice Chair Danaher asked about competition and rates. Fleming replied there are markets
where open access networks create competition and reasonable rates, but the Bay Area market
isn’t one of them. Google Fiber was successful in getting the incumbents to up their game and
accelerate network upgrades. Vice Chair Danaher added that if open access isn’t practical, then
the City’s goal should be ubiquity and to provide incentives for network upgrades. The City
should focus on incentives and actions to accelerate upgrades and take focus off owning its
own network. Fleming added that the incumbents’ upgrades are easier because it’s more
about upgrading their network equipment and electronics, rather than installing more fiber.
City Manager Keene stated that the City has a propensity for study related to fiber . The UAC
should move with dispatch to give Council its perspective. It is not practical for staff to
continue evaluating several options simultaneously. What content will the City provide with a
city owned network? UAC should let the Council know from a policy perspective about its
current thinking.
Vice Chair Danaher stated that from his point of view spending $77 million to build a city owned
network was never a great proposition if there is already competitive services available; co-
building or co-owning the network should not be a priority. We should look at what we can do
administratively and logistically to speed upgrades to ensure ubiquity. The RFI was never
compelling and is not surprised by the lack of responses. Instead we should look for speed and
support for the incumbent upgrades.
Commissioner Johnston stated that technology is changing and it may leapfrog whatever we
do. He agrees with Vice Chair Danaher that the incumbents have commercial incentives to
upgrade and the City should press them for speed and to cover everyone.
Commissioner Forssell asked what leverage we have to press AT&T to provide citywide
coverage.
Utilities Advisory Commission Minutes Approved on: Page 12 of 13
Senior Deputy City Attorney Jessica Mullan responded that it depends on the particular
application that comes before the City and the conditions of approval we can impose at the
time. This is a challenging space for telecom companies in that what the City offers to one
company we have to offer to all companies across the board due to federal law. The City
Attorney’s office will have to analyze this in terms of looking at it on a contractual basis.
Reichental added that when the City speaks to AT&T and Comcast they certainly want revenue
and the market, but they also want support from the City for fast er permitting. Additionally,
some customers may be satisfied with the current level of service they receive. AT&T will
market heavily throughout the City and people can go onli ne or to one of their storefront
locations to express interest; if there’s a critical mass of interest in an area then they will
deploy.
City Manager Keene noted that in trying to negotiate there are usually “no deal” or “walk -
away” options. The challenge in attaining leverage is that there are conditions when the
provider will say they’ll do the best they can to get 100 percent coverage, but if there are other
conditions from the City, they may not come at all. It’s important at this point that the UAC
provide Council with their thoughts from a policy standpoint.
Senior Deputy City Attorney noted that telecom companies have access to the City’s public
rights-of-way, but under State and federal law, the City has the right to regulate “time, place
and manner” of the placement of their facilities in the rights -of-way. The City can only regulate
certain aspects, but we can encourage them to expand to underserved areas.
Commissioner Forssell observed that both AT&T and Comcast are profit -making institutions
beholden to their shareholders. We have an opportunity to look out for all residents, but she is
skeptical that unless we have tangible leverage, she is unconvinced that AT&T and Comcast will
deploy ubiquitously if that’s the Council’s policy goal.
Commissioner Forssell asked to clarify that if we are mulling over the idea of issuing a bond for
$77 million, what services will we provide and do we have a sense of what citizens want? Is it
bundled entertainment, Internet and voice services similar to what AT&T and Comcast offer
and the prices change depending on what bundle you sign-up for? City Manager Keene
responded that even if the City in in this business, it doesn’t preclude the incumbents and
others from competing against the City. Even after capi talizing the expense to build the
network we’d have to get enough customers to get the 72 percent market uptake and the
incumbents in response may be willing to provide more services at a better price. The City
Manager added that we’re not advocating for AT&T and Comcast as the solution, but the
comment Commissioner Forssell’s made about shareholders is an appropriate one since if a City
network is run as a utility the shareholders are the citizens and customers and we need to
acknowledge that relationship, especially if it involves a public-private partnership and the
potential benefits that would be provided to the shareholders.
Chair Cook recognized the market is moving quickly and how much things change each time the
fiber item is reviewed by the UAC and expressed frustration on the lack of progress. Chair Cook
also noted that he has been skeptical of the cost to build and he has heard different cost
numbers. The decision would vary based on a cost of $20 million vs. $70 million; Fiber-to-the-
Node approach may be an idea. Chair Cook asked if there is the potential to expand the
existing fiber backbone infrastructure to increase revenue, but he has a concern about getting
Utilities Advisory Commission Minutes Approved on: Page 13 of 13
away from the City’s goals for network ownership, ubiquity and open access. Perh aps the
question to the Council is what is the public benefit of fiber for the community in terms of local
control and lower costs (similar to the public benefit of achieving carbon neutrality)? We need
to determine the public benefit aspect of fiber for the community.
Commissioner Trumbull noted that we may have to give up on the notion of fiber a as public
utility due to federal law.
City Manager Keene noted that the Fiber-to-the-Node (FTTN) approach has potential because
of the need to reinvest in the fiber network and the cost is manageable. The fiber ring could be
expanded in a way to stay competitive. For example, the fiber network was extended to the
school district and there may be other opportunistic expansions. Also, since we don’t know
now where the technology is headed for fiber and wireless, FTTN may be back -filler for fiber
backhaul opportunities, ubiquity and support of 5G in the future.
The City Manager added that General Manager of Utilities/Assistant City Manager Ed Shikada,
CIO Jonathan Reichental and the Fiber/Wireless Team will have to further flesh out the se
concepts for future discussions.
ACTION:
None.
Meeting adjourned at 9:38 p.m.
Respectfully Submitted,
Marites Ward
City of Palo Alto Utilities
Page 1 of 3
1
MEMORANDUM
TO: UTILITIES ADVISORY COMMISSION
FROM: UTILITIES DEPARTMENT
DATE: JANUARY 11, 2017
SUBJECT: Staff Recommendation that the Utilities Advisory Commission Recommend
that the City Council Adopt a Resolution Approving the Updated City of Palo
Alto Utilities Legislative Policy Guidelines
______________________________________________________________________________
REQUEST
Staff requests that the Utilities Advisory Commission (UAC) recommend that the City Council
adopt the attached resolution approving amendments to the Utilities Legislative Policy
Guidelines.
BACKGROUND
The utility industry is a high-profile and heavily regulated industry subject to continuous
legislative action at both the state and federal levels. Such legislation can influence, among
other things, the reliability and security of the supply and distribution infrastructure,
commodity procurement practices, customer service and billing, program design, rate design,
and activities and costs associated with climate protection. City appointed and elected officials
and staff participate in Federal and State legislative forums to advocate positions on issues
facilitating the City’s current strategic objectives, as adopted in the 2011 Utilities Strategic Plan
and modified in the 2013 Utilities Strategic Plan update: ensuring a reliable and safe supply of
utility resources, providing customer service excellence, managing costs, and ensuring
environmental sustainability. The City also participates in joint action efforts to advocate for
goals and objectives shared by other publicly-owned utilities.
The Utilities Legislative Guidelines were drafted parallel to the City’s Legislative Priorities and
Legislative Program Manual (2017 update), as approved by the Policy and Services Committee
on November 29, 2016. For example, the City Legislative Program Manual highlights general
priorities that speak to protecting local revenue sources, funding for programs and services,
and protecting local government discretion on how best to operate local programs.
The Utilities Legislative Policies Guidelines contains complementary goals such as preserving
and enhancing local accountability and oversight, ensuring system/program reliability, and
preserving reasonable rates. These department-specific priorities are intended to operate in
conjunction with the City’s priorities, and are consistent with the City’s overarching legislative
principles.
Page 2 of 3
At the state level, hundreds of bills focused on the utility industry can be introduced each year.
The number of bills introduced and the pace at which bills change and new language is
negotiated, requires staff and elected officials to respond quickly if the City is to have any
influence on the resulting legislation. Often, a response to an amended bill is required in a
matter of a day or two. These timing constraints preclude a return to the UAC and Council for
approval each time a response is required. Therefore, a set of policy guidelines is developed
each year that identifies the goals and priorities for the City to be applied by staff when
evaluating and responding to legislation. While the guidelines are used by staff for evaluating
legislation, any advocacy positions taken in alignment with these guidelines will be subject to
the approval of the Assistant City Manager/ Utilities General Manager or City Manager per the
City’s legislative advocacy process. Although it is impractical to return for approval each time a
letter is sent in response to a bill amendment, the issues under debate are known to the UAC
and Council through their participation in legislative committee meetings, and updates from
the City Manager, the Assistant City Manager/ Utilities General Manager and City staff. Formal
letters responding to legislative bills or amendments will be distributed to the UAC and Council.
DISCUSSION
The proposed Utilities Legislative Policy Guidelines have been updated to respond to recent
legislative and regulatory trends. Exhibit 1, attached to the resolution (Attachment A), shows
the proposed revised guidelines; Attachment B shows changes from the last approved set of
guidelines. The priorities are grouped in six sections: the first listing goals, trends and priorities
that are common to all utilities, and the following five sections identifying goals, trends and
priorities that are specific to electric, fiber optic, natural gas, wastewater collection and water
services.
Attachment C provides a summary of key legislative action from 2016 and a look forward at
anticipated issues that have a good chance of reappearing in the second year of California’s
2017/2018 legislative session. Staff returns every year with an update to the guidelines and is
proposing the guidelines, if adopted by Council, remain in effect from February XX, 2016 until
the next approved update.
RESOURCE IMPACT
There is no direct resource impact associated with adoption of the proposed legislative policy
guidelines. However, actions taken that support the efficient use of the City’s assets and
resources will help control costs, implement the Council’s policies and goals, and protect the
interests of utility customers.
ENVIRONMENTAL REVIEW
Adoption of a resolution approving the updated City of Palo Alto Utilities’ Legislative Policy
Guidelines does not constitute a project under Section 21065 of the California Environmental
Quality Act (CEQA) and the CEQA Guidelines, and therefore, no environmental assessment is
required.
ATTACHMENTS
• Attachment A: Draft Resolution with Exhibit 1,. Update to the. Utifitles Legislative ·PoJicy
Guidelines
• Att~thment S: 40l7' Updt:)te tp th~ Utilitie$. legisfa!tivf;? Pqlicy GvideUnes -Red.line ver~ion
showing changes from th~ 2016 Guidelines
•.. Attachment C: Review of Legislative~~~ \OA6 rf .
PREPARED -BY: . ~~nior ·Resource Planner
REVIEWED BY: C!YD, utlUtles~mplian~e Manag~
DEPARTMENT HEAD: .... ~-. . . .. . ....
-=osHU<ADA
Utilities General Manag~r
.Page3ot3
NOT YET APPROVED
161228 jm/UTL/UAC 20161228 January 2017 Update
Resolution No. _________
Resolution of the Council of the City of Palo Alto Approving the City of
Palo Alto Utilities’ Legislative Policy Guidelines
A. The City of Palo Alto Utilities Strategic Plan (“Strategic Plan”), approved by the Palo
Alto City Council on July 18, 2011, [Staff Report #1880], and amended on August 5, 2013 (Staff
Report #3950), provides a set of Strategic Objectives for the City of Palo Alto Utilities
Department (CPAU) to follow in ensuring a reliable and safe supply of utility resources,
providing customer service excellence, managing costs, and ensuring environmental
sustainability.
B. CPAU annually identifies Utilities’ Legislative Policy Guidelines that facilitate the
Strategic Plan’s Strategic Objectives, and advocates for utility-related issues at Federal and
State legislative forums in furtherance of those objectives.
C. Action on some of these issues may require active involvement of Palo Alto elected
and appointed officials.
D. The Utilities’ Legislative Policy Guidelines were presented to the UAC at its January
11, 2017 meeting, and the UAC voted _______ to recommend that the City Council approve the
Utilities’ Legislative Policy Guidelines.
The Council of the City of Palo Alto does hereby RESOLVE as follows:
SECTION 1. The Council hereby adopts the resolution approving the Utilities
Legislative Policy Guidelines, effective February XX, 2017. All prior versions of the City of Palo
Alto Utilities Legislative Policy Guidelines are hereby repealed and replaced in their entirety by
the Utilities Legislative Policy Guidelines, attached to this Resolution as Exhibit 1.
SECTION 2. Staff will review the Guidelines annually and any proposed changes will
be approved by City Council.
/ /
/ /
/ /
/ /
ATTACHMENT A
NOT YET APPROVED
161228 jm/UTL/UAC 20161228 January 2017 Update
SECTION 2. The Council finds that the adoption of this resolution does not constitute
a project under Section 21065 of the California Environmental Quality Act (CEQA) and the CEQA
Guidelines, and therefore, no environmental assessment is required.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
___________________________ ___________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
___________________________ ___________________________
Senior Deputy City Attorney City Manager
___________________________
Asst. City Manager/Utilities General Manger
___________________________
Director of Administrative Services
Utilities Legislative Policy Guidelines January 2017 Update
Page 1 of 16
EXHIBIT 1
Approved by City Council on January XX, 2017; Resolution #---
Utilities’ Legislative Policy Guidelines
Formal advocacy positions taken in alignment with these guidelines will be subject to the
approval of the Utilities General Manager or City Manager.
ALL UTILITES
Goals
1.Preserve/enhance local accountability in the control and oversight of matters impacting utility
programs and rates for our customers while balancing statewide climate protection goals.
2.Support efforts to maintain or improve the reliability of the supply, transmission, storage and
distribution/collection infrastructures.
3.Support government action that makes bold progress in cost effectively reducing greenhouse gas
(GHG) emissions, supporting electrification efforts, and recognizes early voluntary action advancing
both.
4.Maintain the City of Palo Alto Utilities’ (CPAU’s) ability to provide safe, reliable, sustainable, and
competitively-priced utility services.
Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountabili
ty
2. Reliability
&
Infrastructure
3. Climate
Protection
4. Service &
Cost
Control
1.Advocate goals through active
participation in joint action
efforts, including supporting
the efforts of common goals
through external organizations
Federal,
State, and
Regional
2.Support legislation that results
in locally designed, cost-
effective and efficient solutions
to the goal of GHG emissions
reductions.
Federal,
State, and
Regional
3.Promote legislation and
regulations that have
undergone stakeholder review
and cost benefit analysis to
support effective and
consistent reporting
requirements, customer
communications, and program
results
Federal,
State, and
Regional
Reliability
Councils
Utilities Legislative Policy Guidelines January 2017 Update
Page 2 of 16
Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountabili
ty
2. Reliability
&
Infrastructure
3. Climate
Protection
4. Service &
Cost
Control
4.Oppose unreasonable and
inequitable financial burdens
and support policy changes that
assist customers through active
participation in the legislative
activities of the Northern
California Power Agency (NCPA)
and the California Municipal
Utilities Association (CMUA).
Federal,
State, and
CPUC
5.Advocate for state and federal
grants for local and regional
energy efficiency and
conservation measures,
renewable resources, fiber, fuel
switching, wastewater collection
systems and recycled water
projects.
Federal
and State
6. Maintain right of way access for
utility infrastructure.
Federal and
State
7.Protect the value of existing
assets and contracts and
local regulatory approvals of
same.
Federal
and State
8. Support government action
allowing CPAU to maintain
customer confidentiality.
State
9.Maintain existing low cost
municipal financing options for
infrastructure projects and
advocate for new federal and
state programs that recognize
critical infrastructure needs.
Federal
and State
10.Promote utility legislation and
regulations that support
reasonable and consistent
notification, compliance, and
reporting requirements for
operations, services,
communications, billing and
payments.
Federal
and State
Utilities Legislative Policy Guidelines January 2017 Update
Page 3 of 16
Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountabili
ty
2. Reliability
&
Infrastructure
3. Climate
Protection
4. Service &
Cost
Control
11. Through Account
Representatives, educate key
customer accounts about
significant policy actions that
could affect their business
Local
12. Oppose government action
that could adversely impact
our customers or that include
mandates we could not
reasonably achieve.
Federal
and State
13.Support cap-and-trade
market designs that:
protect consumers from
the exercise of market
power;
allocate allowances that
mitigate impacts to Palo Alto
customers while preserving
City environmental goals;
advocate for an allowance
allocation methodology that
provides flexibility for Palo
Alto to structure rates to
align GHG costs and
revenues;
provide flexible compliance
mechanisms such as
banking and borrowing of
allowances; and
allocate funds generated
from cap-and-trade
markets to GHG related
activities, not as a revenue
source for state or federal
general funds.
State
Utilities Legislative Policy Guidelines January 2017 Update
Page 4 of 16
ELECTRIC
Goals
1.Preserve/enhance the ability of municipal utilities to exercise local accountability and oversight over
matters impacting customer service, programs (such as demand side efficiency and conservation
programs), and rate structure.
2.Preserve/enhance the reliability, local oversight, and security of infrastructure.
3.Support legislation that recognizes early voluntary action to combat climate change including
initiatives to reduce GHG emissions and specifically exempts a municipality from
burdensome requirements in subsequent legislation that could result from the early action.
4.Preserve just and reasonable utility rates/bills established by local governing bodies.
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
1.Advocate goals through NCPA, CMUA,
American Public Power Association (APPA),
Transmission Agency of Northern California
(TANC), and the Bay Area Municipal
Transmission Group (BAMx) with support from
Palo Alto staff to speak with a coordinated
voice.
Federal and
State
2.Support NCPA in its continued efforts to
streamline state regulatory reporting
responsibilities, to eliminate duplicative data
and report submittals to multiple state
regulatory agencies, including the CEC, CARB,
and the California Independent System
Operator (CAISO).
State
3.Advocate for legislation/regulations that
provide local accountability and support for:
locally-designed and implemented solar
programs and rates
development of long-term plans and
reasonable and flexible integrated
resource planning requirements
development of distributed energy
resources and plans, and standards and
permitting requirements for connecting
such resources to the local distribution
system;
transparent and consistent accounting
and reporting of CHG emissions and
portfolio content;
balancing state and local policy
Federal and
State
Utilities Legislative Policy Guidelines January 2017 Update
Page 5 of 16
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
implementation and ratepayer equity;
equitable rate design and tariffs;
cost-effective electric efficiency and
demand-side management programs;
implementation of renewable portfolio
standards in a reasonable manner;
cost-effective and locally beneficial
storage;
direct access;
advanced meters and smart grid design and
implementation;
use of public benefit funds (as allowed in
AB 1890 (1996); and
Electrification, including electric vehicle
infrastructure
4.Support legislation for renewable portfolio
standards that:
maintain local compliance authority;
avoid mandates for technology or source
specific carve outs;
allow utilities to pursue the most cost
effective resources available to meet
portfolio needs including use
of Renewable Energy Certificates (RECs);
ensure fair application of RPS standards,
avoiding punitive and/or duplicative non-
compliance penalties;
restrict extension of CEC jurisdiction and
attempts of the CPUC to claim jurisdiction
or obtain de facto jurisdiction over
Publicly Owned Utilities;
allow local distributed generation to
count in full towards RPS; and
prioritize the use of the existing
transmission system over building new
transmission.
Local and
State
5.Support/encourage transmission, generation,
and demand-reduction projects and solutions
including advocating for financing or funding
solutions/options for projects that:
enhance/ensure reliability;
ensure equitable cost allocation following
beneficiary pays principles (including
protection against imposition of state-
Local, State,
and Federal
Utilities Legislative Policy Guidelines January 2017 Update
Page 6 of 16
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
owned electric contract costs on municipal
utility customers);
improve procurement flexibility (e.g.
resource adequacy rules that ensure
reliability and provide flexibility in meeting
operational requirements or flexibility in
meeting State renewable portfolio
standards);
support the continuation of federal and
state financial incentives that promote
increased renewable development;
improve market transparency (particularly
transparency of IOU’s transmission and
procurement planning and
implementation); and
reduce the environmental impact on
the Bay Area and the Peninsula.
6.Advocate for actions on matters impacting
the Western Area Power Administration
(Western) such as:
support Congressional hearings to explore
modernizing regulation and generation
strategies at Central Valley Project (CVP)
plants to enhance generation, water
delivery, flood control and fisheries;
protection of the status of Western Power
Marketing Administration and cost-based
rates;
provisions for preference customers’ first
take at land available with economic
potential for wind farms;
balancing efforts for competing
environmental improvements in rivers and
Delta conditions with water supply and
hydropower impacts without
compromising the primary mission of
Western and recognizing the achievements
already made in California without adding
duplicate costly efforts;
monitoring and evaluating impacts of Delta
conveyance proposals on Western Base
Resource allocation; and
advocating for an equitable distribution of
costs between water and power customers
of the Central Valley Project.
Federal,
State and
Regional
Utilities Legislative Policy Guidelines January 2017 Update
Page 7 of 16
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2.
Reliability
3. GHG
Reduction
4. Cost
Control
advocating for clear product provisions,
fair allocation of Base Resource Capacity
and fair contract terms under Western’s
2025 Power Marketing Plan and new
Western Base Resource contracts.
7.Advocate for actions on matters relating to
overly burdensome reporting and compliance
requirements established by the North
American Reliability Corporation (NERC), the
Federal Energy Regulatory Commission (FERC)
or the Western Electricity Coordinating
Council (WECC).
Federal,
State and
Regional
8.Support fair and reasonable application of grid
reliability requirements established by NERC,
WECC, or FERC and seek appropriate remedies
(if needed) for punitive application of fees and
fines.
Federal and
Regional
9.Work with CAISO and/or FERC:
to give buyers of renewable intermittent
resources relief from imbalance penalties;
to promote financial and operational
changes that result in timely and accurate
settlement and billing; and
to provide critical input on the need for
various transmission projects in light of the
escalating costs to the City to import power
using the bulk transmission system.
Federal and
State
10.Monitor cyber security issues to ensure that
CPAU, which currently does not have critical
cyber assets, retains local control over its
cyber security needs while remaining exempt
from NERC cyber security standards. Support
NCPA to protect it and its member agencies
from unnecessary cyber security regulations.
Federal and
Regional
Utilities Legislative Policy Guidelines January 2017 Update
Page 8 of 16
FIBER OPTIC
Goals
1.Preserve and enhance the authority of local government to (1) develop broadband solutions that align
with community needs and (2) expand consumer choice for competitive Internet connectivity and
other advanced services delivered over fiber-optic networks.
2.Encourage the competitive delivery of broadband services by permitting the use of public rights-of-
way and Utilities infrastructure in a responsible manner, provided that local rights of way authority
and management is preserved and the use does not compromise the City’s existing utility safety and
services obligations.
3.Support local government authority over zoning-related land use for communications infrastructure
in accordance with reasonable and non-discriminatory regulations.
4.Support the Council’s Technology and the Connected City initiative to fully leverage the City’s fiber-
optic asset to provide ubiquitous and reliable ultra-high-speed broadband connectivity
Goals
Legislative Policy Guidelines Venue
1.Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
1.Advocate for these goals through the
APPA, CMUA, National Association of
Telecommunications Officers and
Advisors (NATOA), National League of
Cities (NLC), and the Next Century
Cities initiative (NCC), with support
from City staff.
Federal
and State
2.Support legislation and regulations that
preserve and enhance municipal
delivery of conventional and advanced
telecommunication services as
prescribed by the Telecommunications
Act of 1996.
Federal
and State
3.Support the goals of the Federal
Communications Commission’s (FCC),
National Broadband Plan to improve
Internet access nationwide.
Federal
and State
4.Oppose legislation and regulations that
benefit the incumbent cable TV and
telephone companies at the expense of
community-owned fiber-optic and
wireless networks.
Federal
and State
5.Support legislation and regulations that
preserve and enhance consumer
protections related to the incumbent
providers of telecommunication
Federal
and State
Utilities Legislative Policy Guidelines January 2017 Update
Page 9 of 16
Goals
Legislative Policy Guidelines Venue
1.Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
services.
6.Continue to support the Council’s
municipal fiber and wireless
initiatives.
Local
7.Support legislation and regulations
that:
Permit the use of public right-of-
way and Utilities infrastructure
Preserve local rights-of-way
authority and management;
Preserve local government zoning
and siting authority for wireless
and wireline communication
facilities;
Support local “dig once” policies
to ensure conduit and fiber are
available for lease on reasonable
terms; and
Oppose legislation and regulations that
reduce compensation received by local
governments for the use of the public
rights-of-way and other public
properties that support communication
infrastructure
Federal,
State and
Local
Utilities Legislative Policy Guidelines January 2017 Update
Page 10 of 16
NATURAL GAS
Goals
1.Preserve/enhance the ability of municipal utilities to develop their own demand side efficiency and
conservation programs, alternative gas supplies, and rate structure.
2.Increase the security and reliability of the gas supply and transmission infrastructure. This includes
retaining access to intra- and interstate gas transmission systems to reliably serve customers.
3.Support efforts to reduce greenhouse gas emissions and protect the environment.
4.Preserve just and reasonable utility rates/bills established by local governing bodies.
Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environ-
ment
4. Cost
Control
1.Leverage the American Public Gas
Association (APGA) to assist in
natural gas goals .
Primarily
Federal with
minor
advocacy at
State level
2.Work with NCPA and CMUA to
the extent that the City’s goals as
a gas distributor align with
generators’ use of natural gas.
Federal and
State
3.Support cost effective renewable
gas supplies from in or out of state
sources. Advocate for locally
reasonable mandated renewable
portfolio standards.
Federal and
State
4.Advocate for financing or funding
for cost-effective natural gas
efficiency and solar water heating
end uses.
Federal and
State
5.Support market transparency and
efforts to eliminate market
manipulation through reasonable
oversight.
Federal
6.Support municipal utilities’ ability
to enter into pre-pay transactions
for gas supplies.
Federal
7.Support efforts to improve pipeline
safety.
Federal and
State
8.Work with partners to discourage
extension of CPUC regulatory
authority over municipal gas
operations.
State
Utilities Legislative Policy Guidelines January 2017 Update
Page 11 of 16
Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environ-
ment
4. Cost
Control
9.Oppose legislative proposals
resulting in unreasonable costs for
Palo Alto’s customers.
Federal
and State
10.Support legislation that aims to
protect public health and
encourages transparency
regarding hydraulic fracturing or
“fracking” for natural gas
development, while opposing
blanket moratoriums that aren’t
supported by science.
Federal
and State
Utilities Legislative Policy Guidelines January 2017 Update
Page 12 of 16
WASTEWATER COLLECTION
Goals
1.Support ability of municipal utilities to develop and manage their own conservation and efficiency
programs and retain authority over ratemaking, including the imposition of non-volumetric
customer meter or infrastructure charges for wastewater collection service.
2.Encourage efforts to increase the reliability of the local wastewater collection systems.
3.Maintain the provision of reliable and sustainable wastewater collection service at a fair price.
4.Support equal comparisons of wastewater collection systems by regulatory agencies in order to
minimize and reduce onerous, costly, time-intensive reporting requirements and improve value
and accuracy of information reported to the public.
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2. Reliable
Infrastructure
3. Maintain
service
4. Valuable
reporting
1.Advocate goals through active
participation in the Association of
Bay Area Governments (ABAG),
and CMUA.
Local,
Regional
& State
2.Support regulations of wastewater
collection systems that recognize:
local jurisdictions’ proactive
efforts to replace and maintain
wastewater collections
systems;
the need to provide affordable
and cost based collection
service; and
the unique characteristics of
each collection system.
Local,
Regional
& State
3.Support provision of sufficient
resources for regional agencies to
enable them to advocate for:
environmentally sustainable,
reliable wastewater collection
service at a fair price; and
regional comparisons of
wastewater collection projects
for future state grant funding.
Local and
Regional
4.Support infrastructure security and
reliability including equitable
allocation of funds for increasing
the security of infrastructure.
Regional,
and State
Utilities Legislative Policy Guidelines January 2017 Update
Page 13 of 16
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2. Reliable
Infrastructure
3. Maintain
service
4. Valuable
reporting
5.Advocate for funding and local
regulations for wastewater
collections system projects and
requirements that reduce
overflows and improve collection
system efficiency.
Regional,
State and
Federal
Utilities Legislative Policy Guidelines January 2017 Update
Page 14 of 16
WATER
Goals
1.Support ability of municipal utilities to develop and manage their own conservation and efficiency
programs and retain authority over ratemaking, including the ability to optimize volumetric and
fixed charges to balance the goals of revenue certainty and water use efficiency.
2.Increase the security and reliability of the regional water system owned and operated by the San
Francisco Public Utilities Commission (SFPUC).
3.Support efficiency and recycled water programs in order to minimize the use of imported supplies.
4.Maintain the provision of an environmentally sustainable, reliable supply of high quality water at a
fair price.
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
1.Advocate goals through active
participation in the Bay Area Water Supply
and Conservation Agency (BAWSCA) and
CMUA, with support from Palo Alto staff
for BAWSCA
Local,
Regional
and State
2.Advocate to ensure that legislative actions
regarding the Hetch Hetchy Regional
Water System include:
timely rebuilding of the regional water
system;
assurance that the SFPUC is
adequately assessing and
mitigating risks of infrastructure
failure;
maintenance of the quality of
delivered water;
minimization of any increase in the
cost of water;
no additional exposure to more
frequent or severe water
shortages;
support for the existing water system
and its operation.
Local,
Regional
and State
3.Advocate for interpretations or
implementation of Water Code provisions
that maintain or reinforce the authorities
and protections available to the City and
BAWSCA members outside of San
Francisco.
Local,
Regional
and State
Utilities Legislative Policy Guidelines January 2017 Update
Page 15 of 16
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
4 .Support BAWSCA in efforts to achieve:
an environmentally sustainable,
reliable supply of high quality water at
a fair price;
a SFPUC rate structure that is
consistent with the Water Supply
Agreement and is based on water
usage;
a contract amendment to modify the
drought time water allocation
between the SFPUC and the BAWSCA
agencies;
preservation of Palo Alto’s existing
contractual water allocation and
transportation rights on the SFPUC
Hetch Hetchy system; and
regional planning for conservation,
recycled water, and other water supply
projects.
Local and
Regional
5.Advocate for actions that:
preserve Palo Alto’s existing
contractual rights;
preserve local control over water
use; and
limit encroachment from outside
jurisdictions.
Local and
Regional
6.Support infrastructure security and
reliability including an interconnection
between the SCVWD West Pipeline with
the SFPUC’s Bay Division Pipelines 3 and 4.
Regional
and State
7.Support notification requirements that
inform residents/customers but do not
inflict undue or unobtainable requirements
on the utility.
State
8.Support local control of public benefit
funding levels and program design.
State
9.Support beneficiary pays methodologies to
prevent taxes or fees imposed on SFPUC
customers to fund infrastructure
improvements and costs of water sources
that do not serve Palo Alto customers.
State and
Regional
Utilities Legislative Policy Guidelines January 2017 Update
Page 16 of 16
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
10.Advocate for financing, funding, and,
where applicable, tax exemption, for water
conservation programs, water rebate
programs, and recycled water projects that
meet end-use needs and conserve potable
water; oppose legislation that would
reduce such funding.
State,
Regional
and
Federal
11.Support legislation that promotes
responsible groundwater management.
State
12.Support Proposition 218 reform efforts to
provide ratemaking flexibility to balance
conservation, revenue sustainability, and
low income programs.
State
13.Advocate for water conservation policies
(both drought response and long term)
that achieve water sustainability while
minimizing customer and commercial
impact, protecting the City’s urban
canopy and minimizing the City’s
enforcement costs.
Local and
State
14.Protect SFPUC’s water rights.Local and
State
15.Support legislation that would protect the
City’s infrastructure and treatment
investments from future state-wide cuts
in water use.
State
16. Oppose government action that creates
undue burdens on or unreasonably
expands the role and responsibility of
water suppliers
State
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EXHIBIT A
Approved by City Council on January XX, 2017; Resolution #---
Utilities’ Legislative Policy Guidelines
Formal advocacy positions taken in alignment with these guidelines will be subject to the approval
of the Utilities General Manager or City Manager as per the City’s Legislative Program Manual.
ALL UTILITES
Goals
1.Preserve/enhance local accountability in the control and oversight of matters impacting utility programs
and rates for our customers while balancing statewide climate protection goals.
2.Support efforts to maintain or improve the reliability and security of the supply, transmission, storage,
and distribution/collection, and data infrastructures.
3.Support legislationgovernment action that makes bold progress in cost effectively reducing greenhouse
gas (GHG) emissions, , supporting electrification efforts, and recognizes without penalizing early
voluntary action, and supports statewide climate protection goals advancing both.
4.Maintain the City of Palo Alto Utilities’ (CPAU’s) ability to provide safe, reliable, sustainable, and
competitively-priced utility services.
Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
1.Advocate goals through active
participation in joint action
efforts., including supporting
the efforts of common goals
through external
organizations
Federal,
State, and
Regional
2.Support legislation that allows
local evaluationresults in locally
designed, cost-effective and
design of more efficient energy
solutions, fuel switching, and
demand control programs to
the goal of GHG emissions
reductions.
Federal,
State, and
Regional
ATTACHMENT B
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Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
3. Promote utility legislation and
regulations that have
undergone stakeholder review
and cost benefit analysis to
support effective and
consistent compliance and
reporting requirements.
Ensure such legislation,
customer communications,
and regulations have received
stakeholder review and cost
benefit analysis.program
results
Federal,
State, and
Regional
Reliability
Councils
4. Oppose unreasonable and
inequitable financial burdens
and support policy changes
that assist customers through
active participation in CMUA
and NCPAthe legislative
activities. of the Northern
California Power Agency
(NCPA) and the California
Municipal Utilities Association
(CMUA).
Federal,
State, and
CPUC
5. Advocate for state and federal
grants for local and regional
energy efficiency and
conservation measures,
renewable resources, fiber
optic, fuel switching,
wastewater collection systems
and recycled water projects.
Federal
and State
6. Maintain right of way access for
utility infrastructure.
Federal and
State
7. Protect the financial and
operational value of
utilityexisting assets and
contracts; preserve and
local regulatory
controlapprovals of
bothsame.
Federal
and State
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Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
8. Enhance utilitySupport
government action allowing
CPAU to maintain customer
protections for data security
and confidentiality.
Federal
and State
9. Maintain existing low cost
municipal financing options for
infrastructure projects and
advocate for new federal and
state programs that recognize
critical infrastructure needs.
Federal
and State
10. Oppose government action
that could adversely impact
our customers or that include
mandates we could not
reasonably achieve.
Federal
and State
11. Promote utility legislation
and regulations
supportingthat support
reasonable and consistent
notification, compliance, and
reporting requirements for
utility notifications, ,
safetyoperations, services,
public communications,
billing, and payments, and
customer assistance.
Federal
and State
12. Through Account
Representatives, educate key
customer accounts about
significant policy actions that
could affect their business
Local
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Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
13. 11. Support Proposition 26
reform efforts to provide
ratemaking flexibility to
balance conservation,
revenue sustainability, and
low income assistance
programs.Oppose
government action that could
adversely impact our
customers or that include
mandates we could not
reasonably achieve.
Federal
and State
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Goals
Legislative Policy
Guidelines
Venue
1. Local
Accountability
2. Reliability,
Security
&
Infrastructure
3. Climate
Protection
4. Service & Cost
Control
14. Support cap-and-trade
market designs that:
• protect consumers from
the exercise of market
power;
• allocate allowances that
mitigate impacts to Palo
Alto customers while
preserving City
environmental goals;
• advocate for an allowance
allocation methodology that
provides flexibility for Palo
Alto to structure rates to
align GHG costs and
revenues;
• provide flexible
compliance mechanisms
such as banking and
borrowing of allowances;
and
• allocate funds generated
from cap-and-trade
markets to GHG related
activities, not as a revenue
source for state or federal
general funds.12. Seek
state and regional funding
to enhance the efficiency,
security, and reliability of
infrastructure that
maintains utility customer
data security and
confidentiality.
Federal
and State
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ELECTRIC
Goals
1. Preserve/enhance the ability of municipal utilities to exercise local accountability and oversight over
matters impacting customer service, programs (such as demand side efficiency and conservation
programs), and rate structure.
2. Preserve/enhance the reliability, local oversight, and security of infrastructure.
3. Support legislation that recognizes early voluntary action in reducingto combat climate change
including initiatives to reduce GHG emissions and specifically exempts a municipality from
burdensome requirements in subsequent legislation that could result from the early action.
4. Preserve just and reasonable utility rates/bills established by local governing bodies.
Goals
Legislative Policy Guidelines
Venue
1. Local
Accountability
2. Reliability 3. GHG
Reduction
4. Cost
Control
1. Advocate goals through Northern California
Power Agency (NCPA), California Municipal
Utilities Association (, CMUA),, American
Public Power Association (APPA), Transmission
Agency of Northern California (TANC), and the
Bay Area Municipal Transmission Group
(BAMx) with support from Palo Alto staff;
strive to present the same or substantially the
same messagespeak with a coordinated voice.
Federal and
State
2. Support NCPA in its continued efforts to
streamline the state regulatory reporting
responsibilities, to eliminate duplicative data
and report submittals to multiple state
regulatory agencies, including the CEC, CARB,
and the California Independent System
Operator (CAISO).
State
3. Advocate for legislation/regulations that
provide local accountability and design
ofsupport for:
• Net Energy Metering (NEM) successor
programs designed to fit local conditions
and priorities;
• Electric Integrated Resource Plans
• cost-effective renewablelocally-designed
and implemented solar programs and
rates
• development of long-term plans and
reasonable and flexible integrated
resource planning requirements
• development of distributed
Federal and
State
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Goals
Legislative Policy Guidelines
Venue
1. Local
Accountability
2. Reliability 3. GHG
Reduction
4. Cost
Control
generationenergy resources and
cogeneration projectsplans, and standards
and permitting requirements for
connecting such resources to the local
distribution system;
• transparent and consistent accounting
and reporting of GHG emissions and
portfolio content;
• balancing state and local policy
implementation and ratepayer equity;
• equitable rate design and tariffs;
• cost-effective electric efficiency and
demand-side management programs;
• implementation of renewable portfolio
standards in a reasonable manner;
• cost-effective and locally beneficial storage
integration;
• direct access requirements;
• smartadvanced meters and smart grid
design and implementation; and
• use of public benefit funds (as allowed in
AB 1890 (1996)); and
• Electrification, including electric vehicle
infrastructure
4. Support cap-and-trade market designs that:
• protect consumers from the exercise of
market power;
• allocate allowances that help mitigate
impacts to Palo Alto customers while
providing incentives for utilities to lower
GHG emission portfolios;
• provide flexible compliance mechanisms
such as banking and borrowing of
allowances; and
• allocate funds generated from cap-and-
trade markets to cost-effective GHG-
reduction related activities, not as a
revenue source for state or federal general
funds.
Federal and
State
5.4. Support legislation for renewable portfolio
standards that:
• maintain local compliance authority;
• avoid mandates for technology or source
specific carve outs, and minimum term
Local and
State
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Goals
Legislative Policy Guidelines
Venue
1. Local
Accountability
2. Reliability 3. GHG
Reduction
4. Cost
Control
requirements;
• allow utilities to pursue allthe most cost-
effective resources available to meet
portfolio needs including use
• of Renewable Energy Certificates
(RECs);
• ensure uniformfair application of RPS
standards, avoiding punitive and/or
duplicative non-compliance penalties;
• restrict new regulations
expandingextension of CEC jurisdiction
and attempts of the CPUC to claim
jurisdiction or obtain de facto jurisdiction
over publicly owned utilitiesPublicly
Owned Utilities;
• allow local distributed generation to
count in full towards RPS; and
• prioritize the use of the existing
transmission system assets over
building new transmission.
5. Support/encourage transmission, generation,
and demand-reduction projects and solutions
including advocating for financing or funding
6.solutions/options for projects that:
• enhance/ensure reliability;
• ensure equitable cost allocation following
beneficiary pays principles (including
protection against imposition of state-
owned electric contract costs on municipal
utility customers);
• improve procurement flexibility (e.g.
resource adequacy rules that ensure
reliability and provide flexibility in meeting
operational requirements or flexibility in
meeting State renewable portfolio
standards);
• support the continuation of federal and
state financial incentives that promote
increased renewable development;
• improve market transparency (particularly
transparency of IOU’s transmission and
procurement planning and implementation
activities); and
• reduce negative the environmental
impactsimpact on the Bay Area and the
Local, State, and
Federal
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Goals
Legislative Policy Guidelines
Venue
1. Local
Accountability
2. Reliability 3. GHG
Reduction
4. Cost
Control
Peninsula.
7.6. Advocate for Congressional, legislative, or
administrative actions on matters impacting
costs or operations of the Western Area
Power Administration (Western) such as:
• support of Congressional Field
Hearingshearings to explore modernizing
flood control strategies, river regulation
and generation strategies at Central
Valley Project (CVP) plants to enhance
generation, water delivery, flood control
and fisheries;
• protection of the status of Western Power
Marketing Administration and cost-based
rates;
• provisions for preference customers’ first
take at land available land with economic
potential for wind farms;
• balancing efforts for competing
environmental improvements in rivers and
Delta conditions with water supply and
hydropower impacts;
• support grid modernization without
compromising the primary mission of
Western and recognizing the
achievements already made in California
without adding duplicate costly efforts;
• monitoring and evaluating impacts of
Delta conveyance proposals on Western
Base Resource allocation; and
• advocating for an equitable distribution
of costs between water and power
customers of the Central Valley Project;
and
• advocating for clear product provisions,
fair allocation of Base Resource Capacity
and fair contract terms under Western’s
2025 Power Marketing Plan and new
Western Base Resource contracts.
Federal,
State and
Regional
8.7. Advocate for Congressional or
administrative actions on matters relating to
overly burdensome reporting and compliance
requirements established by the North
American Reliability Corporation (NERC), the
Federal Energy Regulatory Commission (FERC)
Federal, State
and Regional
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Goals
Legislative Policy Guidelines
Venue
1. Local
Accountability
2. Reliability 3. GHG
Reduction
4. Cost
Control
or the Western Electricity Coordinating
Council (WECC).
9.8. Support fair and reasonable application of
grid reliability requirements established by
NERC, WECC, or FERC and seek appropriate
remedies (if needed) for inequitable or
punitive application of fees and fines.
Federal and
Regional
10.9. Work with CAISO and/or FERC:
• to give buyers of renewable intermittent
resources relief from imbalance penalties;
• to promote financial and operational
changes that result in timely and accurate
settlement and billing; and
• to provide critical input on the need for
various transmission projects in light of the
escalating costs to the City to import power
using the bulk transmission system.
Federal and
State
10. Work with NCPA, CMUA and NERC 10.
Monitor cyber security issues to ensure that:
• Federal, state and regional designations
of “ CPAU, which currently does not have
critical cyber assets” are appropriately
applied to only truly critical local
distribution infrastructure; and
• CPAU, retains local control over
implementation of utility industryits cyber
security needs while remaining exempt from
NERC cyber security standards, policies.
Support NCPA to protect it and procedures.
its member agencies from unnecessary cyber
security regulations.
Federal and
Regional
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FIBER OPTIC
Goals
1. Preserve and enhance the authority of local government to (1) develop broadband solutions that
align with community needs and (2) expand consumer choice for competitive Internet connectivity
and other advanced services delivered over fiber-optic networks.
2. Encourage the competitive delivery of broadband services by permitting the use of public rights-of-
way and Utilities infrastructure in a responsible manner, provided that local rights of way authority
and management is preserved and contractual or otherthe use does not compromise the City’s
existing utility safety, service, and operational sservices obligations.
3. Support local government authority over zoning-related land use for communications infrastructure
in accordance with reasonable and non-discriminatory regulations.
4. Support the Council’s Technology and the Connected City initiative of 2013, to fully leverage the
City’s fiber- optic asset to provide ubiquitous and infrastructure assets such as public rights-of-
way, utility poles and conduit for thereliable ultra-high-speed broadband expansion.connectivity
Goals
Legislative Policy Guidelines
Venue
1. Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
1. Advocate for these goals through the
American Public Power Association
(APPA), California Municipal Utilities
Association (, CMUA),, National
Association of Telecommunications
Officers and Advisors (NATOA),
National League of Cities (NLC), and the
Next Century Cities initiative (NCC),
with support from City staff.
Federal
and
State
2. Support legislation and regulations that
preserve and enhance municipal
delivery of conventional and advanced
telecommunication services as
prescribed by the Telecommunications
Act of 1996.
Federal
and
State
3. Support the goals of the Federal
Communications Commission’s (FCC),
National Broadband Plan to improve
Internet access nationwide.
Federal
and
State
4. Oppose legislation and regulations that
benefit the incumbent cable TV, and
telephone, and telecommunications
companies at the expense of
community-owned fiber-optic and
wireless networks.
Federal
and
State
5. Support legislation and regulations that Federal
and
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Goals
Legislative Policy Guidelines
Venue
1. Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
preserve and enhance utility customer
data security and
confidentialityconsumer protections
byrelated to the incumbent providers
of telecommunication services.
State
6. Continue to sSupport the Council’s
municipal fiber and wireless initiatives.
directive to concurrently pursue the
findings and recommendations in the
Fiber-to-the-Premises Master Plan and
Wireless Network Plan and continue
discussions and negotiations with third
parties considering new service
deployments in Palo Alto.
Local
7.6. Support legislation and regulations
that:::
• Permit the contractual use of
public right-of- way and Utilities
infrastructure;
• Preserve local rights-of-way
authority and management;
• Preserve local government zoning
and siting authority for wireless
and wireline communication
facilities;
• Support local “dig once” policies
to deploy infrastructure such as
communications conduit for
future fiber and wireless networks
capable of delivering next-
generation broadband services.
• ensure conduit and fiber are
available for lease on reasonable
terms; and
• Oppose legislation and regulations
that arbitrarily reduce
compensation received by local
governments from other entities
for the economic use of the public
rights-of-way and other public
properties required for that
support communication
infrastructure (e.g., utility poles,
Federal,
State and
Local
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Goals
Legislative Policy Guidelines
Venue
1. Support
Municipal
Delivery
2. Competitive
Delivery
3. Local
Authority
over Land
Use
4. Support
Council
Initiatives
streetlight poles, ducts and
conduits).
NATURAL GAS
Goals
1. Preserve/enhance the ability of municipal utilities to develop and implement their own demand
side efficiency and conservation programs, alternative gas supplies, and rate structuresstructure.
2. Increase the security and reliability of the gas supply and transmission infrastructure. This includes
retaining access to intra- and interstate gas transmission systems to reliably serve customers.
3. Support efforts to reduce greenhouse gas emissions and protect the environment.
4. Preserve just and reasonable utility rates/bills established by local governing bodies.
Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environment 4. Cost Control
1. Advocate most of these goals
mainly throughLeverage the
American Public Gas Association
(APGA) with minor support from
Palo Alto staffto assist in natural
gas goals .
Primarily
Federal with
minor
advocacy at
State level
2. Work with Northern California
Power Agency (NCPA) and
California Municipal Utilities
Association (CMUA) to the extent
that the City’s goals as a gas
distributor align with generators’
use of natural gas.
Federal and
State
3. Support cost effective renewable
gas supplies from in or out of state
sources. In case ofAdvocate for
locally reasonable mandated
renewable portfolio standards,
advocate for controls and off-
ramps similar to the electric RPS
that minimize customer cost
impact.
Federal and
State
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Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environment 4. Cost Control
4. Advocate for financing or funding
for cost-effective natural gas
efficiency and solar water heating
end uses.
Federal and
State
5. Support market transparency and
efforts to eliminate market
manipulation through reasonable
oversight.
Federal
6. Support municipal utilities’ ability
to enter into pre-pay transactions
for gas supplies.
Federal
7. Support efforts to improve pipeline
safety.
Federal and
State
8. Work with partners to discourage
extension of CPUC regulatory
authority over municipal gas
operations.
State
10. 9. Oppose legislative
proposals resulting in
unreasonable costs for
Support cap-and-trade market
designs that:
• protect consumers from the
exercise of market power;
• allocate allowances that
mitigate impacts to Palo
AltoAlto’s customers while
preserving City environmental
goals;
• advocate for an allowance
allocation methodology that
provides flexibility for Palo Alto
to structure rates to align GHG
costs and revenues;
• provide flexible compliance
mechanisms such as banking
and borrowing of allowances;
and
• allocate funds generated from cap-
and-trade markets to GHG related
activities, not as a revenue source
for state or federal general funds.
Federal and
State
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Goals
Legislative Policy Guidelines Venue 1. Local
Accountability
2. Reliability of
Infrastructure
3. Environment 4. Cost Control
11. 10. Support legislation that
aims to protect public health and
encourages transparency regarding
the practice of hydraulic fracturing
or “fracking” for natural gas
development, while opposing
blanket moratoriums that aren’t
supported by science.
Federal and
State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 16 of 22
WASTEWATER COLLECTION
Goals
1. Support ability of municipal utilities to develop and manage their own conservation and efficiency
programs and retain authority over ratemaking, including the imposition of non-volumetric
customer meter or infrastructure charges for wastewater collection service.
2. Encourage efforts to increase the reliability of the local wastewater collection systems.
3. Maintain the provision of reliable and sustainable wastewater collection service at a fair price.
4. Support equal comparisons of wastewater collection systems by regulatory agencies in order to
minimize and reduce onerous, costly, time-intensive reporting requirements and improve value
and accuracy of information reported to the public.
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2. Reliable
Infrastructure
3. Maintain
service
4. Valuable
reporting
1. Advocate goals through active
participation in the Association of
Bay Area Governments (ABAG).),
and CMUA.
Local,
Regional
& State
2. Support regulations of wastewater
collection systems that recognize:
• local jurisdictions’ proactive
efforts to replace and maintain
wastewater collections
systems;
• the need to provide affordable
and cost based collection
service; and
• the unique characteristics of
each collection system.
Local,
Regional
& State
3. Support provision of sufficient
resources for regional agencies in
their pursuit ofto enable them to
advocate for:
• environmentally sustainable,
reliable wastewater collection
service at a fair price; and
• regional comparisons of
wastewater collection projects
for future state grant funding.
Local and
Regional
4. Support infrastructure security and
reliability including equitable
allocation of funds for increasing
the security of infrastructure.
Regional,
and State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 17 of 22
Goals
Legislative Policy Guidelines Venue
1. Local
Accountability
2. Reliable
Infrastructure
3. Maintain
service
4. Valuable
reporting
5. Advocate for funding and local
regulations for wastewater
collectioncollections system
projects and requirements that
reduce overflows and improve
collection system efficiency.
Regional,
State and
Federal
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 18 of 22
WATER
Goals
1. Support the ability of publicmunicipal utilities and districts to develop and implementmanage
their own water efficiency and conservation and efficiency programs while retainingand retain
authority over ratemaking, including the ability to optimize volumetric, and fixed, and drought-
related pricing and charges to balance the goals of revenue certainty and water use efficiency.
2. Increase the security and reliability of the regional water system owned and operated by the San
Francisco Public Utilities Commission (SFPUC).
3. Support efficiency and recycled water programs in order to minimize the use of imported supplies.
4. ProvideMaintain the provision of an environmentally sustainable and, reliable suppliessupply of
high quality water. at a fair price.
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
1. Advocate goals through active
participation in the Bay Area Water Supply
and Conservation Agency (BAWSCA),
California Urban Water Conservation
Council (CUWCC),) and California
Municipal Utilities Association (CMUA),,
with support from Palo Alto staff for
BAWSCA
Local,
Regional
and State
2. Participate in CUWCC Best Management
Practice (BMP) revisions and development
to ensure that aggressive and cost-
effective efficiency goals are incorporated
and operating proposals are reasonable,
achievable, and cost-effective.
State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 19 of 22
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
3.2. Advocate to ensure that legislative actions
regarding the Hetch Hetchy Regional
Water System include:
• timely rebuilding of the regional water
system;
• assurance that the SFPUC is
adequately assessing and
mitigating risks of infrastructure
failure;
• maintenance of the quality of
delivered water;
• minimization of any increase in the
cost of water;
• no additional exposure to more
frequent or severe water
shortages;
• increased real-time monitoring
data availability to ensure water
quality;
• support for the existing water system
and its operation;
• SWRCB responsiveness to SFPUC water
quality issues;.
Local,
Regional
and State
3. 4. Advocate for interpretations or
implementation of Water Code provisions
that maintain or reinforce the authorities
and protections available to the City and
BAWSCA members outside of San
Francisco.
Local,
Regional
and State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 20 of 22
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
5. 4. Support BAWSCA in efforts to enable
it to advocate forachieve:
• an environmentally sustainable,
reliable supply of high quality water at
a fair price;
• for Wholesale Customers’ rights
under the Water Supply Agreement
for water from SFPUC that meets
quality standards;
• a SFPUC rate structure that is
consistent with the Water Supply
Agreement and is based on water
usage;
• a contract amendment to modify the
drought time water allocation
between the SFPUC and the BAWSCA
agencies;
• preservation of Palo Alto’s existing
contractual water allocation and
transportation rights on the SFPUC
Hetch Hetchy system; and
• regional planning for conservation,
recycled water, and other water supply
projects.
Local and
Regional
6. 5. Advocate for actions that:
• preserve Palo Alto’s existing
contractual rights; and
• preserve local control over water
use; and
• limit encroachment from outside
jurisdictions.
Local and
Regional
67. Support infrastructure security and
reliability including an interconnection
between the SCVWD West Pipeline with
the SFPUC’s Bay Division Pipelines 3 and 4.
Regional
and State
78. Support notification requirements that
inform residents/customers but do not
inflict undue or unobtainable requirements
on the utility.
State
89. Support local control of public benefit
funds, funding levels and program
design.
State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 21 of 22
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
910. Support beneficiary pays methodologies
to prevent taxes or fees imposed on
SFPUC customers to fund infrastructure
improvements and costs of water sources
that do not serve Palo Alto customers.
State and
Regional
101. Advocate for financing or, funding, and,
where applicable, tax exemption, for water
conservation programs, water rebate
programs, and recycled water projects that
meet end-use needs and conserve potable
water and; oppose legislation that would
reduce such funding.
State,
Regional
and
Federal
11.12. Support infrastructure security and
reliability that includes equitable
allocation of funds for increasing the
security of infrastructure and that
protects the City from unnecessary
regulations. Support legislation that
promotes responsible groundwater
management.
Local,
State and
Federal
123. Support legislation that promotes
responsible groundwater management
while recognizing Palo Alto’s existing and
historical groundwater extraction
practices. Support Proposition 218
reform efforts to provide ratemaking
flexibility to balance conservation,
revenue sustainability, and low income
programs.
State
134. Support Proposition 218 reform efforts
to provide ratemaking flexibility to
balance conservation, revenue
sustainability, and low income assistance
programs.Advocate for water
conservation policies (both drought
response and long term) that achieve
water sustainability while minimizing
customer and commercial impact,
protecting the City’s urban canopy and
minimizing the City’s enforcement costs.
Local and
State
Utilities Legislative Policy Guidelines January 2017 Update AAA
Page 22 of 22
Goals
Legislative Policy Guidelines Venue 1. Local
Authority
2. Reliable
Infrastructure
3. Minimize
imports
4. Supplies
at fair cost
145. Advocate for reasonable statewide
water conservation efforts (both drought
response and long term) that achieve
required water savings while minimizing
customer and commercial impact,
protecting the City’s urban canopy and
minimizing the City’s enforcement
costs.Protect SFPUC’s water rights.
Local and
State
156. ProtectSupport legislation that would
protect the CityCity’s infrastructure and
County of San Francisco’streatment
investments from future state-wide cuts
in water rights as well as those of the co-
grantees of the Raker Actuse.
State
167. Support legislationOppose government
action that would protectcreates undue
burdens on or unreasonably expands the
City’s infrastructurerole and treatment
investments from future state-wide cuts
inresponsibility of water use.suppliers
State
ATTACHMENT C
1
Review of Select Legislative Activities in 2016
While 2016 was a one-year legislative session, there was no shortage of water and energy bills.
City of Palo Alto Utilities (CPAU) staff tracked eighteen bills in 2016; seven passed the
legislature and became law 1. Following is a summary of the state legislation and federal issues
CPAU staff followed in 2016.
State Legislation
Energy Related Bills
AB 2339 (Irwin): Net energy metering (NEM). This bill would have extended the current NEM
program, causing Palo Alto to expend resources while jeopardizing the implementation of the
approved NEM Successor Program. CPAU staff was very active on this bill, and engaged heavily
with NCPA and CMUA to meet with many legislators and provide testimony during committee
hearings.
Outcome: Failed
AB 2163 (Wlliams): NEM: Imperial Irrigation District. A bill appearing for the first time days
before the end of session, AB 2163 would have required the Imperial Irrigation District to renew
its former NEM program for the benefit of certain customers, some of whom do not have PV
instillations. The bill would have taken effect immediately when signed into law. As this bill
represented a slippery slope that could impact Palo Alto’s NEM program, CPAU staff worked
with CMUA and NCPA to oppose the bill.
Outcome: Failed
AB 2699 (Gonzales): Department of Consumer Affairs: Contractor's State License Board: Solar
energy systems companies: Regulations. Otherwise known as the solar customer consumer
protection bill, this bill would have protected customers against perceived inappropriate
actions of the solar industry.
Outcome: Failed
SB 1393 (De Leon): Energy efficiency and pollution reduction (SB 350 clean-up bill). States that
POUs do not have to notify the Energy Commission when they consider renewable energy
procurement, and if a POU receives a certain portion of its sales from hydroelectric generation,
it may not have to also procure eligible renewable resources in certain circumstances. This bill
attempted to go farther by inserting language from various agencies; however, the many
interested stakeholders could not agree to the proposed amendments and the language did not
appear in the final bill. NCPA and CMUA were two of those stakeholders.
Outcome: Signed into law
1 For the purpose of brevity, only the most viable and/or potentially impactful bills are noted here.
ATTACHMENT C
2
SB 32 (Pavley): California Global Warming Solutions Act of 2006. Requires the Air Resources
Board to adopt rules and regulations to ensure statewide GHG emissions limits are reduced to
at least 40% below the 1990 level by December 2030.
Outcome: Signed into law
AB 197 (Garcia, E): State Air Resources Board: greenhouse gases: regulations. Tied to SB 32,
this new statute adds two members of the legislature to the Air Resources Board (ARB) as non-
voting members and creates the Joint Legislative Committee on Climate Change Policies. AB
197 also increases ARB’s reporting on GHG sources.
Outcome: Signed into law
SB 1028 (Hill): Electric Utilities: Wildfire mitigation plans. Requires electrical corporations and
local POUs to maintain and operate their electrical lines and equipment in a manner that
minimizes the risk of catastrophic wildfire posed by such electrical lines and equipment. Palo
Alto’s City Council will be required to determine whether any portion of the geographical area
where our utility’s overhead electrical lines and equipment are located has a significant risk of
catastrophic wildfire. If such a finding is made, Council must approve wildfire mitigation
measures the utility intends to undertake to minimize the risk of its overhead electrical lines
and equipment causing a catastrophic wildfire.
Outcome: Signed into law
Water Legislation
SB 814 (Hill): Drought: excessive water use: urban retail water suppliers. Enforceable only
during a state or locally declared drought, SB 814 states that excessive water use by a
residential customer is prohibited. Urban retail water suppliers must establish a method to
identify and restrict excessive water use. CPAU and CMUA staff actively engaged with Senator
Hill’s office before the bill was introduced to express concerns with earlier language related to
public requests; that language was stricken.
Outcome: Signed into law
AB 2594 (Gordon): Stormwater resources: use of captured water. Currently, the Stormwater
Resource Planning Act authorizes public agencies to develop a stormwater resource plan. This
statute authorizes a public entity that captures stormwater from urban areas, to use the water
before it reaches a natural channel.
Outcome: Signed into law
SB 1398 (Leyva): Public water systems: lead user service lines. Requires public water systems,
such as CPAU, to compile an inventory of known lead user service lines in use in its distribution
system and identify areas that may have lead user service lines by July 1, 2018. After
completing the inventory, the utility is required to provide a timeline for replacement of known
lead user service lines in the distribution system to the State Water Resources Control Board
(SWRCB). If a public water system identifies areas in the distribution system that may have lead
user service lines then, by July 1, 2020, the public water system must either verify the existence
ATTACHMENT C
3
or absence of lead user service lines in these areas or provide a timeline for replacement of the
user service lines whose content cannot be determined.
Outcome: Signed into law
Natural Gas Legislation
AB 2460 (Irwin). Solar Thermal Systems. This bill would have revised the current Solar Water
Heating and Efficiency program to promote the installation of solar water systems and set the
funding cap between January 1, 2017, and July 31, 2027, at $1 billion.
Outcome: Failed
Federal Legislation
Senator Murkowski’s S.2012, the Energy Policy Modernization Act of 2015, included language
that would have eased the hydropower relicensing process, and was supported by NCPA. While
the bill went far enough to go to conference between the House and Senate, it ultimately failed
to pass.
A bill that did pass and was signed by the President is the Water Infrastructure Improvements
for the Nation Act. This bill contains provisions regarding California drought conditions and the
Western states, and will assist public water agencies provide safe reliable water.
Looking forward
In 2017, we expect Governor Brown to put forth legislation regarding regionalization, the effort
to fundamentally change the state’s energy market by joining with other entities. Last year,
such legislation was promised, but did not materialize, in part due to efforts of agencies like
NCPA, CMUA, CPAU, and many other stakeholders cautioning policymakers of moving too
quickly on such a significant issue. Stakeholders continue to meet with state and CAISO
representatives to discuss issues from governance to costs to operations. In 2017, we also
expect to see legislation regarding energy storage, a repeat of last year’s solar consumer
protection bill, cap and trade, energy efficiency, and electric vehicles.
Federally, CPAU joins other local governments and associations in waiting to see what
President-elect Trump has in store for renewable energy and environmental issues. CPAU staff
will pay close attention as Mr. Perry and Mr. Pruitt undergo confirmation hearings for Energy
Secretary and EPA Administrator, and as new Federal Energy Regulatory Commission
appointments are made.
2
MEMORANDUM
TO: UTILITIES ADVISORY COMMISSION
FROM: UTILITIES DEPARTMENT
DATE: JANUARY 11, 2017
SUBJECT: Recommendation that Council Approve the 2017 Water Integrated Resource
Plan Guidelines
RECOMMENDATION
Staff requests that the Utilities Advisory Commission (UAC) recommend that Council approve
the updated 2017 Water Integrated Resource Plan (WIRP) Guidelines.
EXECUTIVE SUMMARY
The past several years have brought unprecedented drought conditions and regulatory action
by the State Water Resource Control Board (SWRCB), including the first-ever mandatory
potable water use reductions. During this time, much focus has been placed on the
sustainability of water supply in California. The WIRP Guidelines, which were last updated in
2003, are a roadmap for the City of Palo Alto’s future potable water supply.
In this WIRP, the following potable water supply alternatives were evaluated: 1) water from the
San Francisco Public Utilities Commission (SFPUC); 2) groundwater (with or without
groundwater recharge); 3) treated water from the Santa Clara Valley Water District (SCVWD);
and 4) Demand Side Management (DSM). Recycled water is being evaluated outside of the
WIRP in the Recycled Water Strategic Plan process that will include an evaluation of direct and
indirect potable reuse as well as the feasibility and advisability of expanding the existing non-
potable recycled water distribution system.
The evaluation concluded that DSM is the best resource, but potable water supplies are still
needed. While SFPUC water is more expensive, it has higher water quality than groundwater or
treated water from the SCVWD. In addition, groundwater and SCVWD treated water supplies
may increase in cost and aren’t likely to offer additional protection in droughts.
In summary, the proposed 2017 WIRP Guidelines are:
1. Pursue all cost-effective water efficiency and conservation;
2. Survey potentially impacted customers about their preference for SFPUC water versus
blended water;
3. Proceed with the Recycled Water Strategic Plan to determine how to reduce the
demand for imported water; and
4. Continue to investigate the technical feasibility and financial impact of increasing the
use of non-traditional, non-potable sources such as black water, storm water, and
nuisance water from basement construction.
The WIRP Guidelines will need to be revisited after the Recycled Water Strategic Plan is
completed so that a comprehensive, regional water strategy can be developed.
BACKGROUND
The City prepared its first WIRP in 1993 when the City was faced with a decision to participate
in a regional recycled water expansion program. The 1993 WIRP assessed the costs and benefits
of the recycled water project compared to other supply alternatives, and ultimately concluded
that recycled water was not cost effective relative to existing supply.
In 2003, the City updated the WIRP. The 2003 WIRP indicated that supplies from the SFPUC
were adequate during normal years, but additional supplies were needed in dry years to avoid
shortages. The key conclusions from the 2003 WIRP analysis were:
• The City’s existing contractual entitlement with the SFPUC provides adequate supplies;
• The cost to connect to the SCVWD treated water pipeline was prohibitive;
• Continuous use of groundwater is not recommended;
• The City should continue to evaluate recycled water; and
• Continue the current Demand Side Management programs and explore additional
measures.
In December 2003, Council adopted WIRP Guidelines (Attachment B) for the development of
new water resources and the preservation of existing supplies, which are summarized below:
1. Preserve and enhance SFPUC supplies
2. Continue to advocate for an interconnection between SFPUC and SCVWD
3. Participate in the development of cost effective regional recycled water programs
4. Scope water conservation programs to comply with Best Management Practices (BMPs)
5. Maintain emergency water conservation measures to be activated in case of droughts
6. Retain groundwater supply options in case of changed future conditions
7. Survey community to determine its preferences regarding the best water resource
portfolio
As a first step toward updating the 2003 WIRP, a Preliminary Assessment (Attachment C) was
completed and provided to the UAC in February 2013. The Preliminary Assessment provided a
general evaluation of the following water resources: 1) water from the SFPUC; 2) groundwater;
3) treated water from the SCVWD; 4) recycled water; 5) DSM; and 6) sale of the City’s Individual
Supply Guarantee. No recommendations were made based on the Preliminary Assessment,
although staff found that groundwater, SCVWD treated water, recycled water and the sale of
the City’s Individual Supply Guarantee merited further evaluation.
At its November 2, 2016 meeting, the UAC reviewed the draft 2017 WRIP guidelines. The UAC
was generally pleased with the report, but expressed a desire to represent more scenarios
regarding the availability of SFPUC supplies in the future. The plan has been updated with an
expanded description of the short and long term threats to SFPUC water supply availability.
The minutes from the UAC’s November 2, 2016 meeting are provided as Attachment D.
DISCUSSION
For the current analysis, each potable water supply alternative was evaluated for normal and
dry year availability, water quality, cost, sustainability, emergency robustness, and sensitivity to
regulations and environmental review. For each alternative, the following attributes were
considered:
1. Normal and dry year availability;
2. Water quality;
3. Cost;
4. Sustainability;
5. Emergency robustness; and
6. Sensitivity to regulations and environmental review.
The current analysis made the following conclusions:
1. Cost-effective DSM is the superior resource, but DSM alone can’t eliminate the City’s need
for potable water.
2. While SFPUC water is expected to be slightly more expensive than other potable water
alternatives, it has the highest water quality.
3. The cost of SCVWD supplies—both groundwater and treated water—may increase
dramatically if purified water is fully developed and/or if the California Water Fix (“twin
tunnels”) project is constructed. However, SCVWD does not have excess treated water to
sell.
4. Groundwater in the county is susceptible to mandated water use reductions just like
imported supplies.
5. Blending groundwater with SFPUC water at only the El Camino well is the least expensive,
most sustainable alternative to 100% SFPUC supplies. Whether the residents and businesses
that would receive the water would consider the tradeoff between cost and quality to be
acceptable is worth investigating.
6. The most promising way to increase reliability and increase sustainability is to reduce the
demand for potable water by expanding the use of recycled water. The Recycled Water
Strategic Plan will provide valuable analysis and information to help the City and SCVWD
formulate a comprehensive strategy for the future.
Table 1 shows a summary of the WIRP analysis.
Table 1: Summary Comparison of Potable Water Supply Alternatives
Water
Resource
Normal Year
Availability
Dry Year
Availability
Quality Cost Emergency
Robustness
Sustainability Sensitivity to
Regulations and
Environmental
Review
SFPUC
Groundwater
Groundwater
(w/recharge)
?
SCVWD
Treated Water
Demand Side
Management
On December 7, 2017, the Utilities Risk Oversight and Coordinating Committee reviewed the
proposed 2017 WIRP and suggested one clarifying change to Guideline 4. The proposed 2017
WIRP Guidelines now read:
1. Pursue all cost-effective water efficiency and conservation;
2. Survey potentially impacted customers about their preference for SFPUC water versus
blended water;
3. Proceed with the Recycled Water Strategic Plan to determine how to reduce the
demand for imported water; and
4. Continue to investigate the technical feasibility and financial impact of increasing the
use of non-traditional, non-potable sources such as black water, storm water, and
nuisance water from basement construction.
NEXT STEPS
If recommended by the UAC, the 2017 WIRP Guidelines will be presented to City Council for
approval in early 2017. The WIRP Guidelines will be updated after the completion of the
Recycled Water Strategic Plan.
POLICY IMPLICATIONS
Adoption of the proposed WIRP Guidelines will replace the 2003 Guidelines and will determine
the water resource planning activities for the next three years. The proposed 2017 WIRP
Guidelines are consistent with the City’s Urban Water Management Plan, the Utilities Strategic
Plan, and the City’s Sustainability and Climate Action Plan.
ENVIRONMENTAL REV IEW
The UAC's recommendation that Council approve the 2017 Water Integrated Resources Plan
Guidelines does not require California Environmental Quality Act review, because the plan does
not meet the definition of a project under Public Resources Code Section 21065 and CEQA
Guidelines Section 15378(b}{S), as an administrative governmental activity which will not cause
a direct or indirect physical change in the environment.
ATTACHMENTS
A. Final 2017 Water Integrated Resource Plan
B. Council-approved Water Integrated Resource Plan Guidelines (2003)
C. 2013 Preliminary Assessment of Water Resource Alternatives
D. Excerpted minutes from the UAC's November 2016 meeting
PREPARED BY : Karla Dailey, Senior Resource Planner ~
DEPARTMENT HEAD:
Jan~. B'hye, Assistant Director, Resource Management
) ( 7
(._~ c.-.
REVIEWED BY:
Ed Shikada
Utilities General Manager
Attachment A
2017 Water Integrated Resources Plan
January 2017
i
2017 Water Integrated Resources Plan
Table of Contents
List of Figures ___________________________________________________________ iii
List of Tables ___________________________________________________________ iii
List of Acronyms _________________________________________________________ iii
I. Executive Summary ____________________________________________________ 1
II. WIRP Drivers _________________________________________________________ 2
III. Background __________________________________________________________ 3
IV. Water Supply History ________________________________________________ 6
V. Water Use Projections __________________________________________________ 7
Urban Water Management Plan (UWMP) ________________________________________ 8
Summary Water Resource Mix _________________________________________________ 8
VI. Attributes Evaluated and Water Resource Alternatives Examined ____________ 9
Attributes Evaluated for each Water Resource Alternative ___________________________ 9
Water Resource Alternatives Examined __________________________________________ 9
Water Resource Alternatives NOT Examined _____________________________________ 10
VII. Water from the SFPUC ______________________________________________ 13
Availability ________________________________________________________________ 13
Water Quality ______________________________________________________________ 15
Cost ______________________________________________________________________ 16
Sustainability ______________________________________________________________ 17
Emergency Robustness ______________________________________________________ 18
Sensitivity to Regulations and Environmental Review ______________________________ 19
VIII. Potable Groundwater _______________________________________________ 19
Availability ________________________________________________________________ 21
Water Quality ______________________________________________________________ 22
Cost ______________________________________________________________________ 23
Sustainability ______________________________________________________________ 25
Emergency Robustness ______________________________________________________ 26
Sensitivity to Regulations and Environmental Review ______________________________ 26
ii
IX. Treated Water from the SCVWD _________________________________________ 27
Availability ________________________________________________________________ 29
Water Quality ______________________________________________________________ 29
Cost ______________________________________________________________________ 30
Emergency Robustness ______________________________________________________ 31
Sustainability ______________________________________________________________ 32
Sensitivity to Regulations and Environmental Review ______________________________ 32
X. Demand Side Management ____________________________________________ 33
Availability ________________________________________________________________ 34
Water Quality ______________________________________________________________ 35
Cost ______________________________________________________________________ 35
Emergency Robustness ______________________________________________________ 37
Sustainability ______________________________________________________________ 37
Sensitivity to Regulations and Environmental Review ______________________________ 37
XI. Comparison of Water Supply Alternatives _________________________________ 38
Availability ________________________________________________________________ 38
Water Quality ______________________________________________________________ 38
Cost ______________________________________________________________________ 39
Emergency Robustness ______________________________________________________ 41
Sustainability ______________________________________________________________ 41
Sensitivity to Regulations and Environmental Review ______________________________ 41
XII. Conclusions _______________________________________________________ 41
iii
List of Figures
Figure 1: Historic Water Use (1988-2016) ...................................................................................... 7
Figure 2: 2010 and 2015 UWMP Demand Forecast Projection Comparison ................................. 8
Figure 3: Summary of 2015 UWMP Water Resource Composition ................................................ 9
Figure 4: Projected Frequency of Shortage for RWS Based on 91-Year Historical Hydrologic
Record and Estimated Demand .................................................................................................... 15
Figure 5: SFPUC Actual and Projected Cost of Water ................................................................... 16
Figure 6: Map of SFPUC Regional Water System .......................................................................... 18
Figure 7: Estimated Well Production for Various Treatment Options ......................................... 23
Figure 8: Cost at Each Well for Each Treatment Option ............................................................... 24
Figure 9: Unit cost of Various Treatment Options ........................................................................ 25
Figure 10: West Pipeline Extension Map ...................................................................................... 28
Figure 11: SBx7X7 Targets, Results, and Projections .................................................................... 34
Figure 12: Monthly Potable Water Consumption......................................................................... 35
Figure 13: Water Demand Forecast with Future Water Efficiency .............................................. 37
Figure 14: Commodity Cost Comparison of Water Supply Alternatives ...................................... 40
Figure 15: Present Value Unit Cost Comparison of Water Supply Alternatives ........................... 40
List of Tables
Table 1: Estimated Well Capacity ................................................................................................. 21
Table 2: Water Quality Resulting from Various Treatment Options ............................................ 23
Table 3: SCVWD Treated Water Connection Cost Summary ........................................................ 30
Table 4: Water Efficiency Costs ($/AF) ......................................................................................... 36
Table 5: Water Quality Parameters for Water Resource Alternatives ......................................... 39
Table 6: Summary Comparison of Potable Water Resource Alternatives .................................... 42
List of Acronyms
AFY Acre Feet per Year
AMI Advanced Metering Infrastructure
BAWSCA Bay Area Water Supply and Conservation Agency
BMP Best Management Practice
CCF One hundred cubic feet
CDPH California Department of Public Health
CEQA California Environmental Quality Act
CPAU City of Palo Alto Utilities
CVP Central Valley Project
DPR Direct Potable Reuse
iv
DSM Demand Side Management
EIR Environmental Impact Report
ESA Endangered Species Act
FERC Federal Energy Regulatory Commission
GHG Greenhouse gas
GPCD Gallons per capita per day
GWMP Groundwater Management Plan
IPR Indirect Potable Reuse
ISA Interim Supply Allocation
ISG Individual Supply Guarantee
ISL Interim Supply Limitation
MGD Million gallons per day
PPM Parts per Million
RWQCP Regional Water Quality Control Plant
RWS Regional Water System (refers to SFPUC’s Hetch Hetchy system)
SBx7-7 Water Conservation Bill
SCVWD Santa Clara Valley Water District
S/CAP Sustainability and Climate Action Plan
SFPUC San Francisco Public Utilities Commission
SGMA Sustainable Groundwater Management Act
SWP State Water Project
SWRCB State Water Resources Control Board
TDS Total Dissolved Solids
UAC Utilities Advisory Commission
UWMP Urban Water Management Plan
WIRP Water Integrated Resource Plan
WSA Water Supply Agreement
WSIP Water System Improvement Program
Page 1
I. Executive Summary
The past several years have brought unprecedented drought conditions and regulatory action
by the State Water Resource Control Board (SWRCB) including the first-ever mandatory potable
water use reductions. During this time, much focus has been placed on the sustainability of
water supply in California. The Water Integrated Resource Plan (WIRP) Guidelines, which were
last updated in 2003, are a roadmap for the City of Palo Alto’s future potable water supply.
In this WIRP, the following potable water supply alternatives were evaluated: 1) water from the
San Francisco Public Utilities Commission (SFPUC); 2) groundwater (with or without
groundwater recharge); 3) treated water from the Santa Clara Valley Water District (SCVWD);
and 4) Demand Side Management (DSM). Recycled water is being evaluated outside of the
WIRP in the Recycled Water Strategic Plan process that will include an evaluation of direct and
indirect potable reuse as well as the feasibility and advisability of expanding the existing non-
potable recycled water distribution system.
For each alternative, the following attributes were considered:
1. Normal and dry year availability;
2. Water quality;
3. Cost;
4. Sustainability;
5. Emergency robustness; and
6. Sensitivity to regulations and environmental review.
Major findings of the evaluation are:
1. Cost-effective DSM is the superior resource, but DSM can’t eliminate the City’s need for
potable water.
2. While SFPUC water is slightly more expensive than groundwater and SCVWD treated
water, it has the highest water quality.
3. The cost of SCVWD supplies may increase dramatically if purified water is fully
developed and/or if the “twin tunnels” project in the Delta is constructed.
4. SCVWD does not have excess treated water available to sell.
5. Like other potable water supplies, groundwater in the county is susceptible to
mandated water use reductions.
6. Blending groundwater with SFPUC water at only the El Camino well is the least
expensive, most sustainable alternative to 100% SFPUC supplies. It is unclear whether
the customers that would receive the water would consider the tradeoff between cost
and quality to be acceptable.
7. Expanding the use of recycled water and other non-potable sources will reduce the
reliance on potable water, but more work needs to be done and no conclusions about
the cost-effectiveness of those resources can be drawn from this study.
Page 2
In summary, the recommended 2017 WIRP Guidelines are:
1. Pursue all cost-effective water efficiency and conservation;
2. Survey potentially impacted customers about their preference for SFPUC water versus
blended water;
3. Proceed with the Recycled Water Strategic Plan to determine how to reduce the
demand for imported water; and
4. Continue to investigate the technical feasibility and financial impact of increasing the
use of non-traditional, non-potable sources such as black water, storm water, and
nuisance water from basement construction.
II. WIRP Drivers
There are several drivers for updating the WIRP Guidelines at this time.
a) Dry year need – The City has an Individual Supply Guarantee of 17.07 million gallons per
day (MGD) from the regional water system operated by the SFPUC. The City has no
foreseeable supply deficiency in normal years, but SFPUC supplies will likely be inadequate
during dry years. Many of the supply alternatives available to the City are also subject to
drought shortfalls. A critical question to address is the level of reliability the City will
provide to residents and businesses and at what cost.
b) Legislative & Regulatory Risks – In 2015, the SWRCB overrode individual supplier water
shortage assessments and mandated potable water use reduction targets. It is prudent to
evaluate Palo Alto’s water supply alternatives relative to this new regulatory risk.
c) Cost Increases – The SFPUC’s Water System Improvement Program (WSIP) is 90% complete.
The WSIP included 81 projects for a cost of $4.8 billion (including $1.6 billion for projects
within, and completely paid for by ratepayers within, the City and County of San Francisco).
The largest project remaining is the re-build of the Calaveras Dam which has encountered
unexpected geological challenges. As a result of the WSIP and other capital projects, the
cost of SFPUC water has risen dramatically and is projected to continue to increase in the
future. With the increase in costs, other alternatives are increasingly competitive with
SFPUC supplies, although other supply alternatives such as groundwater from the SCVWD
and treated water from the SCVWD have also increased in cost and are expected to
continue on that trajectory.
d) Recycled Water and the Nexus with Potable Supplies - Recycled water from the Regional
Water Quality Control Plant (RWQCP) is an available local supply source with the potential
to reduce the City’s demand for SFPUC water. Recycled water could be deployed for non-
potable uses or converted to potable water through Indirect Potable Reuse (IPR or
recharging the deep aquifer followed by groundwater pumping) or Direct Potable Reuse
(DPR or highly purified water that can be injected directly to the potable water distribution
system). A renewed commitment at the State level may change the viability of recycled
Page 3
water projects. There is also regulatory pressure to reduce the amount of water discharged
to the San Francisco Bay.
e) Council Commitment to Sustainability - The issue of climate change has become an
important factor in water resources planning in the State, though the extent and precise
effects of climate change remain uncertain. There is convincing evidence that increasing
concentrations of greenhouse gasses have caused, and will continue to cause, a rise in
temperatures around the world, which will result in a wide range of changes in climate
patterns. Moreover, observational data show that a warming trend occurred during the
latter part of the 20th century and virtually all projections indicate this will continue
through the 21st century. Climate change could result in the following types of water
resource impacts, including impacts on the watersheds in the Bay Area:
• Reductions in the average annual snowpack due to a rise in the snowline and a
shallower snowpack in the low and medium elevation zones, such as in the Tuolumne
River basin (the primary source of SFPUC’s regional water system), and a shift in
snowmelt runoff to earlier in the year;
• Changes in the timing, intensity and variability of precipitation, and an increased
amount of precipitation falling as rain instead of as snow;
• Long-term changes in watershed vegetation and increased incidence of wildfires that
could affect water quality and quantity;
• Sea level rise and an increase in saltwater intrusion;
• Increased water temperatures with accompanying potential adverse effects on some
fisheries and water quality;
• Increases in evaporation and concomitant increased irrigation need; and
• Changes in urban and agricultural water demand.
The updated Sustainability and Climate Action Plan (S/CAP) will include aggressive goals
and robust strategies for ensuring Palo Alto has a sustainable long-term water supply. In
particular, local water sources need to be considered with this new focus in mind.
f) Community Engagement on All Things Water Related – The current drought shined a
spotlight on the lack of adequate water supplies for the state as a whole. Media attention
and actions by the Governor raised awareness among Palo Alto’s educated, engaged
community resulting in a need to provide to the public more information on the City’s
water supply planning efforts.
III. Background
The first WIRP was prepared largely because the City was faced with a decision regarding
participation in a regional recycled water program. This 1993 WIRP assessed the costs and
benefits of a recycled water project compared to other supply alternatives, and ultimately
determined that recycled water was not cost effective relative to existing supplies. In 1999, the
Page 4
City began working on a new WIRP, and completed the effort with approval by the City Council
of seven WIRP Guidelines in December 2003 1:
1. Preserve and enhance SFPUC supplies.
2. Advocate for an interconnection between SFPUC and the District
3. Actively participate in development of cost-effective regional recycled water plans
4. Focus water DSM programs to comply with BMPs
5. Maintain emergency water conservation measures to be activated in case of droughts
6. Retain groundwater supply options in case of changed future conditions
7. Survey community to determine its preferences regarding the best water resource portfolio
During the process to prepare the 2003 WIRP, several studies were conducted to inform the
effort:
1. Water, Wells, Regional Storage, and Distribution System Study, 1999, Carollo
Engineers 2 – This study identified system improvements to the distribution system to
meet water demands and fire flows following a catastrophic interruption of service on
the SFPUC system. Among the recommendations was to refurbish the 5 existing wells
and construct three new wells and a new water storage tank.
2. Long Term Water Supply Study, 2000, Carollo Engineers – The report examined the
issues and costs of using new or rehabilitated wells as active sources of supply. The
alternatives examined in the report included: (1) Using the wells for active supply either
on a long term basis or during droughts; (2) using groundwater for irrigation; and (3)
connecting to the SCVWD treated water pipeline.
3. Groundwater Supply Feasibility Study, 2002, Carollo Engineers – The report evaluated
whether operating one or two of the City’s water wells as active supplies would cause
significant decrease in groundwater levels or deterioration in groundwater quality.
4. Santa Clara Valley Water District’s West Pipeline Extension Conceptual Evaluation
Final Report, 2003, SCVWD. – The report evaluated an extension of the existing SCVWD
West Pipeline to enable an interconnection of the Palo Alto and SCVWD systems at Page
Mill turnout.
The 2003 WIRP analysis indicated that SFPUC supplies were adequate during normal years, but
additional supplies were needed in dry years to avoid shortages. Since SFPUC supplies were
adequate in normal years, the following conclusions were drawn:
1. The City’s existing ISG through its water supply contract with San Francisco provides
adequate supplies;
1 CMR:547:03: https://www.cityofpaloalto.org/civicax/filebank/documents/51715
2 See Executive Summary here: http://www.cityofpaloalto.org/civicax/filebank/documents/25618
Page 5
2. The cost to connect to the SCVWD treated water pipeline is prohibitive assuming that
Palo Alto would bear the entire project cost;
3. Continuous use of groundwater was not recommended;
4. The City should continue to evaluate recycled water;
5. Continue the current DSM programs and explore additional measures; and
6. Additional supplies are needed in a drought if water use restrictions are to be avoided.
Following Council approval of the 2003 WIRP Guidelines, staff surveyed residential customers
to gain a sense of community preferences on the use of groundwater during a drought. The
survey asked respondents to rank several options for water supply during a drought: (A) blend
groundwater with existing SFPUC supplies; (B) use no groundwater; and (C) treat groundwater
at the well location prior to introduction to the distribution system.
Survey respondents generally preferred Options B (no groundwater) and C (treat groundwater),
but Option A (blend groundwater) was not soundly rejected. The results of the survey were
presented to the Utilities Advisory Commission (UAC) in June 2004 3. Based on the results staff
made the following recommendations:
1. Do not install advanced treatment systems for the groundwater at this time. This option
is expensive, both in terms of capital and operating costs.
2. Blending at an SFPUC turnout is the best way to use ground water as a supplemental
drought time supply while maintaining good water quality.
3. Staff should await the conclusion of the environmental review process before
proceeding with any site selections for wells to be used in dry years.
4. Actively participate in the development of long term supply plans with the Bay Area
Water Supply and Conservation Agency (BAWSCA) and/or SCVWD.
5. Continue efforts identified in the Council-approved WIRP guidelines:
a. Evaluate a range of demand side management options to reduce long term
water demands.
b. Evaluate feasibility of expanding recycled water.
c. Maintain emergency water conservation measures to be activities in case of
droughts.
In 2013, a Preliminary Assessment of Water Resource Alternatives was prepared and presented
to the UAC 4 as a first step toward updating the WIRP. Other high-priority tasks, such as drought
management and completion of the 2015 Urban Water Management Plan, delayed work on the
WIRP until now.
The City has several policies embodied in the Comprehensive Plan that relate to groundwater
and water supplies. The relevant policies are listed below, with program elements, if
applicable. An update of the Comprehensive Plan is underway.
3 http://www.cityofpaloalto.org/cityagenda/publish/uac-meetings/3354.pdf
4 http://www.cityofpaloalto.org/civicax/filebank/documents/33029
Page 6
1. POLICY N-51: Minimize exposure to geologic hazards, including slope stability,
subsidence, and expansive soils, and to seismic hazards including ground shaking, fault
rupture, liquefaction, and land sliding.
2. POLICY N-18: Protect Palo Alto’s groundwater from the adverse impacts of urban uses.
a. PROGRAM N-22: Work with the SCVWD to identify and map key Groundwater
recharge areas for use in land use planning and permitting and the protection of
groundwater resources.
3. POLICY N-19: Secure a reliable, long-term supply of water for Palo Alto.
In April 2016 5, Council approved the framework of the City’s Sustainability and Climate Action
Plan. The section, “Getting Smart about Water” included two goals: (1) Reduce consumption of
potable water and (2) Supplement existing water supplies. As part of the S/CAP Implementation
Plan process, a revised set of goals and strategies will be presented to Council for approval.
IV. Water Supply History
The water utility was established on May 9, 1896, two years after the City was incorporated.
Local water companies were purchased at that time with a $40,000 bond approved by the
voters of the 750-person community. These private water companies operated one or more
shallow wells to serve the nearby residents. The city grew and the well system expanded until
nine (9) wells were in operation by 1932.
In December 1937, the City signed a 20-year contract with the City and County of San Francisco
for water deliveries from the newly constructed pipeline bringing Hetch Hetchy water from
Yosemite to the Bay Area. Water deliveries from San Francisco commenced in 1938 and well
production declined to less than half of the total citywide water demand.
A 1950 engineering report noted, "The capricious alternation of well waters and the [San
Francisco] water...has made satisfactory service to the average consumer practically
impossible." Groundwater production increased in the 1950s leading to lower groundwater
tables and increasing water quality concerns.
In 1962, a survey of water softening costs to City customers determined that the City should
purchase 100% of its water supply needs from San Francisco. A 20-year contract was signed
with San Francisco and the City’s wells were placed in a standby condition. Since 1962 (except
for some very short periods) the City’s entire potable water has come from San Francisco’s
Hetch Hetchy regional water system administered by the SFPUC.
In 1974, several wholesale customers joined Palo Alto and filed a lawsuit against San Francisco
in protest of an increase in water rates that was higher for wholesale customers than it was for
5 Staff Report 6754: http://www.cityofpaloalto.org/civicax/filebank/documents/51856
Page 7
direct retail customers. In 1984, settlement negotiations resulted in the “Settlement
Agreement and Master Water Sales Contract between the City and County of San Francisco and
Certain Suburban Purchasers in San Mateo, Santa Clara and Alameda Counties”. The 25-year
agreement was approved in 1984. The 1984 agreement included the creation of a “Supply
Assurance” equal to 184 million gallons of water per day (MGD) for the benefit of the wholesale
customers.6 The agreement included a mechanism to allocate the 184 Supply Assurance
between the wholesale agencies. The City’s allocation, its “Individual Supply Guarantee” or ISG,
is 17.07 MGD. Each agency’s ISG is perpetual in nature and survives termination or expiration
of the water supply contract with San Francisco.
In 2009, a new 25-year Water Supply Agreement (WSA) was executed between San Francisco
and the City7. The City’s historical water use and supply sources are illustrated in Figure 1.
Figure 1: Historic Water Use (1988-2016)
V. Water Use Projections
The City of Palo Alto Utilities (CPAU) regularly prepares water supply and demand forecasts to
prepare financial forecasts, to meet regulatory requirements, or as part of ongoing regional
planning efforts. Like many water agencies in California, the City has experienced a significant
6 The Supply Assurance is expressed as an annual average and does not constitute an obligation on the part of the
SFPUC to meet daily or hourly peak demands.
7 CMR: 269:09: http://www.cityofpaloalto.org/civicax/filebank/documents/15985
Page 8
drop in water use since 2007, which is largely attributable to the 2008 economic recession and
the recent drought and resulting water conservation.
Urban Water Management Plan (UWMP)
The UWMP is submitted to the Department of Water Resources every five years; the City
Council approved the most recent 2015 UWMP in June 20158. Water demand forecast for the
2015 UWMP are shown in Figure 2. For comparison purposes, the forecast from the 2010
UWMP is also included in Figure 2. The water use projection results are revealing in that the
City, along with most water agencies in California, did not anticipate the dramatic drop in water
demand from 2007 to 2009. Potable water demands from 2009 to the present appear to have
leveled off and have begun to trend upwards again, albeit slowly, and it remains to be seen if
water demands will follow the increase forecasted in the 2010 UWMP.
Figure 2: 2010 and 2015 UWMP Demand Forecast Projection Comparison
Summary Water Resource Mix
The 2015 UWMP provided detailed information on baseline water resources through 2040.
SFPUC supplies were assumed to remain the primary potable supply for the foreseeable future.
Recycled water consumption was projected to continue at current levels and no expansion was
assumed in the 2015 UWMP. Finally, demand side management and conservation program
penetration and savings were projected contribute to a modest decrease in potable water use.
A representation of the future water resource mix is provided in Figure 3.
8 Staff Report 6851: http://www.cityofpaloalto.org/civicax/filebank/documents/52272, Resolution 9589:
http://www.cityofpaloalto.org/civicax/filebank/documents/53456
Page 9
Figure 3: Summary of 2015 UWMP Water Resource Composition
VI. Attributes Evaluated and Water Resource Alternatives Examined
Attributes Evaluated for each Water Resource Alternative
In this section, each potential water resource option is evaluated and compared based on the
following attributes:
1. Normal and Dry Year Availability – The quantity, timing, peak flow or capacity, and any
expected changes over time during normal years and during dry years.
2. Water Quality – All options must meet water quality regulations, but supply resources
may differ in their relative water qualities (i.e. taste, odor, color, hardness, mineral
content, trace levels of contaminants, etc.).
3. Cost – The capital and operating and maintenance (O&M) costs of the resource.
4. Sustainability – The long-term outlook for the supply source given climate change, sea
level rise, and the Council preference for local resources.
5. Emergency Robustness – The availability of the resource under various emergency
scenarios.
6. Sensitivity to Regulations and Environmental Review – Vulnerability to existing or
potential federal, state, or local regulations and required environmental review.
Water Resource Alternatives Examined
The potable water resource alternatives evaluated in this 2017 WIRP process include:
1. Water from the SFPUC
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2. Groundwater (with or without groundwater recharge)
3. Treated Water from the SCVWD
4. Demand side Management
Water Resource Alternatives NOT Examined
The WIRP is an analysis of potable water resource alternatives. However, non-potable water
sources can both satisfy unmet water needs and reduce dependence on potable water. The City
is moving forward on several fronts regarding recycled water and other non-potable supplies,
but an evaluation of those supplies is not included in this analysis.
The following is a summary of the water resources not included in WIRP due to cost, technical
obstacles, or regulatory restrictions. A number of non-potable water sources are under
development or are being studied in parallel with the WIRP effort.
1. Recycled Water – The City of Palo Alto operates the Regional Water Quality Control
Plant (RWQCP), a wastewater treatment plant, for the East Palo Alto Sanitary District,
Los Altos, Los Altos Hills, Mountain View, Palo Alto, and Stanford University. The City, in
partnership with the SCVWD, is embarking on a Recycled Water Strategic Plan that will
include a holistic evaluation of this important resource. The costs and benefits of
expanding the current recycled water distribution system will be re-examined. The study
will include an analysis of the nexus between recycled water and potable water through
Indirect Potable Reuse (IPR), whereby highly purified wastewater in used to recharge
the groundwater for future potable use, and Direct Potable Reuse (DPR), whereby highly
purified wastewater is injected directly into the potable water distribution system.
a. Non-potable Recycled Water - In September 20159, Council certified the
Environmental Impact Report (EIR) for a project that includes capital
improvements to the existing distribution system needed to increase deliveries
to the Stanford Research Park. The Recycled Water Strategic Plan will re-
evaluate the cost effectiveness of this project given an updated demand
assessment for non-potable water, current cost estimates including potential
outside funding sources. The potential impact on potable water demand of
expanding the use of non-potable recycled water is considered in this analysis.
b. IPR and the Nexus with Groundwater – State regulations allow recharging
groundwater with purified water, and projects are in operation in other parts of
the state. A project in Palo Alto would include a pipeline to a suitable site where
a facility could be constructed to successfully recharge the aquifer. Because
understanding the hydrology is such an important aspect of successful recharge
and because data for this part of the county is incomplete, the Recycled Water
9 Staff Report 5962: http://www.cityofpaloalto.org/civicax/filebank/documents/49079, Resolution 9548:
http://www.cityofpaloalto.org/civicax/filebank/documents/49865, and Resolution 9549:
http://www.cityofpaloalto.org/civicax/filebank/documents/49866
Page 11
Strategic Plan includes a study of the upper and lower aquifers and the
connectivity between the two and they relate to the water balance. The WIRP
does include an analysis of groundwater as an alternative resource but does not
include a cost estimate to recharge groundwater with purified water from the
RWQCP.
c. DPR – While it is technically possible, as evidenced by the new SCVWD Advanced
Water Purification Plant, to produce recycled water that meets all drinking water
requirements, state law still prohibits injecting purified recycled water directly
into drinking water distribution systems. In addition, the cost of treating
recycled water to this degree is not yet cost-competitive. State lawmakers,
however, are embarking on a process to establish the regulations for DPR, and
since the supply is drought-proof, it will likely be a viable alternative in the
future.
2. Desalination – BAWSCA is evaluating a desalination project as part of its long-term
water supply plan. The demand analysis, however, revealed that current water
resources are adequate in normal water years through 2040. Less expensive, more
flexible alternatives such as water transfers are more suited to filling the supply gaps
during dry years. Because the projected timeline for completing any desalinization
project is very long, BAWSCA intends to continue studying this resource and seeking
alternate funding for such projects.
3. Sale of the City’s Individual Supply Guarantee (ISG) - The City’s access to water from
the SFPUC Regional Water System is embodied in the 2009 WSA. The City’s ISG of 17.07
MGD is a perpetual guarantee, but the delivery of water is subject to interruption for
reason of water shortage, drought, or emergency. The City’s average year water needs,
after consumption bounces back from the recent drought, are projected to be about 9.5
MGD. The City of East Palo Alto (EPA) lacks adequate long-term water supplies for
development and is interested in increasing its ISG. Any transfer of Palo Alto’s ISG would
be permanent and may impact the percentage Palo Alto would be required to cutback in
a water shortage. Discussions between the City and EPA are underway and are separate
from this analysis.
4. Small scale irrigation wells - Individuals may drill their own wells without City review or
permits, but are subject to SCVWD’s rules, restrictions, and permitting requirements.
The City does have the option of using small wells for irrigation of large landscapes, such
as for City parks. However, locating, maintaining, and operating small wells is cost-
prohibitive and operationally problematic.
5. Treated Contaminated Groundwater – There are several entities in the City that treat
contaminated groundwater and discharge the groundwater to the storm drain system
and, to a lesser extent, the sanitary sewer system. The primary purpose of these
Page 12
facilities is to remediate contaminated groundwater with finite operations. The
potential end uses for this water are limited due to its very low quality.
6. Nuisance Groundwater from the Oregon Expressway Underpass - The Santa Clara
County Oregon Expressway dewatering pumps discharge significant amounts of
nuisance groundwater to the storm drain system to keep the underpass dry. The City
evaluated the capture and conveyance of the Oregon Expressway groundwater for
irrigation purposes and determined the effort would require significant conveyance and
storage infrastructure investments that are not cost effective.
7. Nuisance Groundwater from Basement Dewatering - Basement construction
groundwater pumping occurs when a basement is constructed in areas of shallow
groundwater, typically in the neighborhoods closer to the bay or near current or former
creek beds. Dewatering continues until enough of the house has been constructed to
keep the basement in place. The shallow and deep aquifer research to be undertaken by
the City in coordination with the SCVWD in the Recycled Water Strategic Plan will
provide valuable insight to the relationship between the aquifers in the north part of
Santa Clara County.
While the City has long regulated several aspects of basement groundwater pumping for
both residential and commercial sites, recent public concern over the appearance of
wasted water prompted Council’s adoption of several new requirements for builders.
Where groundwater pumping is needed, builders must install a fill station and submit a
Groundwater Use Plan describing how use of the pumped groundwater will be
maximized.
On February 1, 2016 10, Council approved the following additional requirements and
actions:
• Public outreach to encourage greater fill station use;
• Increased outreach on the water cycle and value of fresh water flows to storm
drains, creeks and bay;
• Additional requirements for Groundwater Use Plans such as maximizing on-site
water reuse (e.g. watering on-site and nearby vegetation), providing water truck
hauling service for neighbor and City landscaping, and piping to nearby parks or
major users where feasible;
• Expansion of fill station specifications to address water pressure issues from multiple
concurrent users, including separate pumps for neighbors where needed and
sidewalk bridges for hoses to reduce tripping hazards; and
• Submission of a determination of the effects of groundwater pumping on nearby
buildings, infrastructure, trees, or landscaping.
10 See Staff Report 6478: http://www.cityofpaloalto.org/civicax/filebank/documents/50690
Page 13
8. Graywater and Black Water – Graywater is relatively clean waste water from baths,
sinks, washing machines, and other kitchen appliances while black water is waste water
from toilets. Treating and reusing both types of water at the building level can decrease
the demand for potable water. The City’s draft Sustainability Implementation Plan
includes designing programs for cost-effective incentives for grey water and black water
systems and developing a local ordinance that facilitates the use of non-traditional
water sources such as grey water and black water.
9. Storm water – Storm water is precipitation that can soak into the soil (infiltrate), be held
on the surface and evaporate, or run off and end up in nearby streams etc. Capturing
and using storm water in Palo Alto can reduce the demand for potable water, help to
recharge the aquifer, and prevent pollutants from entering the San Francisco Bay. Storm
water can be a useful resource for keeping Palo Alto’s urban canopy well-watered.
The draft Sustainability Implementation Plan includes developing a Storm Water
Infrastructure Plan by 2019 to include design guidelines, funding sources, and prioritized
projects. The draft plan also includes promoting permeable paving material through
mandates and rebates and incentives and exploring new applications for permeable
paving.
VII. Water from the SFPUC
The City currently purchases 100% of its potable supplies from the SFPUC under the 2009 WSA.
The WSA is administered for the City by BAWSCA which represents the interests of 24 cities and
water districts and two private utilities that purchase wholesale water from the San Francisco
regional water system. These entities provide water to 1.7 million people, businesses and
community organizations in Alameda, Santa Clara and San Mateo counties. The City of Palo
Alto is a member of BAWSCA and has a Council-appointed representative on the BAWSCA
Board of Directors.
Availability
The City’s right to water from the SFPUC system is embodied in the 2009 WSA. The City’s ISG of
17.07 MGD is a perpetual right, but the delivery of water is subject to interruption for reason of
water shortage, drought, or emergency.
Normal Year SFPUC Water Availability
While the City’s ISG is 17.07 MGD, the City’s long-term projected potable water demand
forecast is only about 9.5 MGD. The WSA includes an interim water delivery limitation 11 from
the SFPUC system of 265 MGD until its expiration in 2018. The City’s share of the interim
11 This limitation applies to all users of the San Francisco regional water supply system, the City of San Francisco
and all the BAWSCA member agencies.
Page 14
limitation, or its Interim Supply Allocation (ISA), is 14.70 MGD 12. Based on the water demand
forecast from the 2015 UWMP, there is no foreseeable need for additional supply beyond the
City’s ISG, or the ISA.
There is one situation where the City’s ISG could be involuntarily reduced. Under the terms of
the 1962 contract between the City of Hayward and San Francisco, the City of Hayward’s
contractual entitlement from the SFPUC system essentially equals its water demand. In theory,
since the collective Supply Assurance of the wholesale customers cannot exceed 184 MGD, if
Hayward’s water usage increases substantially, the other wholesale agencies could experience
a proportional ISG reduction to ensure the 184 MGD limit is not exceeded. However,
BAWSCA’s 2014 Regional Demand and Conservation Projections Project showed total agency
demand for SFPUC water to be 168 MGD in 2040, well below the 184 MGD limit.
Dry Year SFPUC Water Availability
SFPUC’s WSIP includes a level of service goal of no greater than a 20% system-wide supply
shortage during a drought. The 2009 WSA includes a water shortage allocation plan to share
water from the regional system between the SFPUC retail and group of BAWSCA agencies (also
known as the “wholesale customers”) during a shortage of up to 20% (Tier I plan). The
wholesale customers further divided the wholesale allocation based on a formula adopted by
all the wholesale customers (Tier II plan)13. The Tier II formula results in larger cutbacks from
the wholesale customers compared to SFPUC’s retail customers, however, the formula expires
in 2018, unless extended by mutual agreement of the BAWSCA members. This analysis
assumes that, in the future, any voluntary or mandatory water use reductions will be
commensurate with the needed system-wide reduction.
Based on the 2040 regional demand assumptions and using 91 years of historical hydrologic
data and the SFPUC’s Hetch Hetchy/Local Simulation Model, drought year supply shortages of
10 percent to 20 percent on SFPUC’s Regional Water System are estimated to occur up to 8
times during the 91-year historical hydrologic sequence (i.e., 1920 through 2011) that the
SFPUC uses for water supply planning purposes. This is the equivalent of a shortage event on
the Regional Water System approximately every 11 years. The estimated frequency of shortage
is conceptually illustrated Figure 4.
12 See informational Staff Report 1321: https://www.cityofpaloalto.org/civicax/filebank/documents/26211
13 Staff Report 1308: http://www.cityofpaloalto.org/civicax/filebank/documents/40970, Resolution 9141:
http://www.cityofpaloalto.org/civicax/filebank/documents/31879
Page 15
Figure 4: Projected Frequency of Shortage for RWS Based on 91-Year Historical Hydrologic
Record and Estimated Demand
As identified in the 2015 UWMP, the City has developed a Water Shortage Contingency Plan for
implementation during a drought. The Water Shortage Contingency Plan identifies several
stages of drought response, depending on the degree of supply reduction required. Responses
range from informational outreach to severe water use restrictions and modified rate
structures.
SFPUC supplies, like other imported supplies, are subject to a whole host of other short and
long term threats. The State is proposing to increase natural flow requirements on the
Tuolumne and other rivers which would result in significant shortfalls to the SFPUC and its
customers during water supply shortage periods. A lawsuit calling for the SFPUC to study
removal of the O’Shaughnessy dam is still pending. Finally, the SFPUC is studying the impact of
climate change on Sierra snowpack and the availability of water. Impacted agencies will have
time to adjust water supply strategies if significant changes to the availability of SFPUC supplies
are anticipated.
While the City has the option of pumping groundwater as supplemental supply in a water
supply shortage determined by the SFPUC, this may not be a viable option in a State-mandated
potable water reduction. This is discussed in more detail in the groundwater section below
(Section VII Potable Groundwater).
Water Quality
SFPUC supplies are of extremely high quality. See Table 2 (in Section VII Potable Groundwater)
which lists key water quality parameters for SFPUC water, SCVWD treated water and
Page 16
groundwater. Water provided by the SFPUC is a mix of Hetch Hetchy water and water from the
East Bay and Peninsula reservoirs. In a normal year, Hetch Hetchy water makes up 85% of the
mix. Due to maintenance requirements, the SFPUC typically will shut down the Hetch Hetchy
supply for a period during the low demand winter months and draw from the local reservoirs.
It is not unusual to experience temporary water quality changes due to these events, though
the water still meets all drinking water quality standards. The SFPUC uses chloramine as the
primary drinking water disinfectant and adds fluoride14.
Cost
The City purchases 100% of its potable water supply from the SFPUC, with the current cost
structure composed of a volumetric charge and a small fixed monthly meter charge. With the
$4.8 billion WSIP nearly complete, the cost of SFPUC water has increased significantly over the
past 10 years. The recent decline in region-wide water consumption has intensified the
problem since the cost, which is almost all fixed, is spread over fewer sales units. The historic
and projected wholesale volumetric rate for SFPUC water is illustrated in Figure 5.
Figure 5: SFPUC Actual and Projected Cost of Water
While the SFPUC charges wholesale customers based on how much water is used, the costs of
the SFPUC system are almost entirely fixed costs—in other words, even if usage drops the cost
to operate the system (O&M, debt service, etc.) remains essentially the same 15.
14 In 1957 the voters in Palo Alto adopted a measure that requires fluoride be added to the City’s water supply
(Palo Alto Municipal Code Section 12.24.010).
15 The SFPUC system is largely gravity fed, so little variable O&M is required for water deliveries.
Page 17
The SFPUC wholesale water rate projections in Figure 5 assume that the current rate structure
remains in place. However, the WSA provides some flexibility for the SFPUC to adjust rate
structures and the SFPUC has signaled an interest in exploring alternative rate structures16
including increasing the fixed charge component or allocating charges based on the ISG, rather
than actual water usage. The City’s ISG of 17.07 MGD is approximately 9.23% of the total
BAWSCA agencies’ Supply Assurance of 184 MGD. If collection of the Wholesale Revenue
Requirement is based on each agency’s ISG and if the City chose to not permanently transfer
any of its ISG, the City could pay 20-30% more for SFPUC water annually.
Sustainability
The SFPUC views assessment of the effects of climate change as an ongoing project requiring
periodic updates to reflect improvements in climate science, atmospheric/ocean modeling, and
human response to the threat of greenhouse gas emissions. Climate change research by the
SFPUC began in 2009 and continues to be refined. In its 2012 report “Sensitivity of Upper
Tuolumne River Flow to Climate Change Scenarios,”17 the SFPUC assessed the sensitivity of
runoff into Hetch Hetchy Reservoir to a range of changes in temperature and precipitation due
to climate change.
Key conclusions from the report include the following:
• With differing increases in temperature alone, the median annual runoff at Hetch
Hetchy would decrease by 0.7-2.1 percent from present-day conditions by 2040 and by
2.6-10.2 percent from present-day by 2100. Adding differing decreases in precipitation
on top of temperature increases, the median annual runoff at Hetch Hetchy would
decrease by 7.6-8.6 percent from present-day conditions by 2040 and by 24.7-29.4
percent from present-day conditions by 2100.
• In critically dry years, these reductions in annual runoff at Hetch Hetchy would be
significantly greater, with runoff decreasing by up to 46.5 percent from present-day
conditions by 2100 utilizing the same climate change scenarios. In addition to the total
change in runoff, there will be a shift in the annual distribution of runoff. Winter and
early spring runoff would increase and late spring and summer runoff would decrease.
Under all scenarios, snow accumulation would be reduced and snow would melt earlier
in the spring, with significant reductions in maximum peak snow water equivalent under
most scenarios.
Given the current regional system demand projection, the shorter-term effects of climate
change are not expected to be relevant. The potential impact of runoff decreasing by nearly
50% by the next century, however, represents a dramatic shift in the availability of water
sourced in the Sierra Nevada including water in the Hetch Hetchy system.
16 SFPUC Comments, July 2012 BAWSCA Board of Director’s meeting
17Accessed September 29, 2016: http://bairwmp.org/docs/climate-
change/Bay%20Area%20Impacts/Water%20Supply/SFPUC%202012%20Sensitivity%20of%20Upper%20Tuolumne%
20River%20Flow%20to%20Climate%20Change%20Scenarios.pdf/view
Page 18
The SFPUC is planning to conduct a comprehensive assessment of the potential effects of
climate change on water supply. The assessment will incorporate an investigation of new
research on the current drought and is anticipated to be completed in 2017.
Emergency Robustness
Since the SFPUC is the City’s primary potable supply source, the City is vulnerable to service
interruptions on the SFPUC system. One of the major drivers behind the WSIP was to address
reliability deficiencies, which under some circumstances could have resulted in an interruption
of SFPUC service for up to 60 days following a catastrophic event such as an earthquake. The
WSIP level of service objective for seismic reliability is to deliver basic service 18 within 24 hours
after a major earthquake. The performance objective is to provide delivery to at least 70 per
cent of the turnouts in each region, and full restoration to meet average day demand within 30
days after a major earthquake. Palo Alto may be better situated than other agencies in having
two distinct connection points to the SFPUC system: three SFPUC connections are served by the
Palo Alto Pipeline connection to Bay Division Pipelines 1 and 2, and two SFPUC connections are
served by Bay Division Pipelines 3 and 4. Figure 6 below is a schematic of the SFPUC Regional
Water System.
Figure 6: Map of SFPUC Regional Water System 19
18 Basic service is defined as average winter month usage.
19 Source: SFPUC: http://www.sfwater.org/index.aspx?page=355 accessed September 29, 2016.
Page 19
Sensitivity to Regulations and Environmental Review
The SFPUC supply is the current baseline supply source for the City. Subsequent sections
analyze several alternatives to the current and projected supply mix, and the resulting potential
environmental impacts. Increased water use within an agency’s ISG does not require any action
by an agency’s governing body, and therefore does not trigger any California Environmental
Quality Act (CEQA) review obligation.
For many water systems in California, the availability of water supplies depends on many
factors, including legislative and regulatory changes that may impact future supply conditions.
The SFPUC system is no different, and has several future regulatory risks that could impact
water supply reliability and/or cost 20:
1. Federal Energy Regulatory Commission (FERC) relicensing of the Don Pedro Project
a. State Water Resources Control Board (SWRCB) 401 Certification of FERC
relicense
b. Endangered Species Act (ESA) Section 7 consultation for FERC relicense
2. Central Valley Total Maximum Daily Load regulations
3. Bay-Delta proceedings (SWRCB, Legislative actions)
4. ESA Habitat Conservation Plans for SFPUC local watersheds
The SFPUC manages these risks, with support from BAWSCA and the wholesale customers.
VIII. Potable Groundwater
The SCVWD manages an integrated water resources system that includes the management of
groundwater, supply of potable water, flood protection and stewardship of streams on behalf
of Santa Clara County's 1.8 million residents. The SCVWD manages ten dams and surface water
reservoirs, three water treatment plants, nearly 400 acres of groundwater recharge ponds and
more than 275 miles of streams. The SCVWD provides wholesale water and groundwater
management services to municipalities, private water retailers, and individual property owners
operating groundwater wells in Santa Clara County.
In 2012, the SCVWD prepared a Groundwater Management Plan (GWMP)21 which provided
information regarding general groundwater conditions in the area and characterized the
SCVWD groundwater activities in terms of basin management objectives, strategies, and
outcome measures. The GWMP described the Santa Clara sub basin as being divided into upper
and lower aquifers separated by low permeability clays and silts. The SCVWD refers to these as
the shallow and principal aquifer, with the latter generally defined as 150 feet below ground
surface. The principal aquifer is the primary drinking water aquifer, and is the source for the
any increased reliance on groundwater to meet current or future potable water demands.
20 Source: SFPUC’s 2010 UWMP
21 See SCVWD website: http://www.valleywater.org/services/groundwater.aspx accessed September 26, 2016.
Page 20
The SCVWD is responsible for managing Santa Clara County’s groundwater basin to ensure
there is adequate supply and overdraft conditions are minimized. The SCVWD accomplishes
this goal by maximizing conjunctive use, the coordinated management of surface and
groundwater supplies, to enhance supply reliability. Programs to accomplish this goal include
the managed recharge of imported and local supplies, in-lieu groundwater recharge through
the delivery of treated surface water22 and acquisition of supplemental water supplies, and
programs to protect, manage and sustain water resources. The SCVWD adopted level of service
goals as part of its 2012 Water Supply and Infrastructure Master Plan 23 effort, including the
development of water supplies designed to meet at least 100% of average annual water
demand identified in the SCVWD 2010 UWMP during non-drought years and at least 90 percent
of average annual water demand in drought years24.
Managed and in lieu recharge programs are in balance with withdrawals. Groundwater levels
have dropped significantly over the past several years as a result of the drought conditions and
lack of State Water Project water imported to the county. The groundwater conditions in the
Santa Clara sub-basin vary, and groundwater pumping from different locations will have
different effects depending on location, elevation, recharge conditions, and pumping activity.
In September 2014, Governor Brown signed the Sustainable Groundwater Management Act
(SGMA) to promote the local, sustainable management of groundwater supplies. SGMA
requires sustainable groundwater management for all medium and high priority basins in
California. SGMA identifies the District as the exclusive groundwater management agency for
Santa Clara County.
The SCVWD’s 2012 Water Supply and Infrastructure Master Plan described how the SCVWD will
support future water supply needs and reliability. The adopted strategy identifies conservation,
increased recycled water use, indirect potable reuse, additional groundwater recharge ponds,
grey water, imported water reoperations, and dry year options as important components of the
plan.
The City maintains close involvement with the SCVWD as it is an important water wholesaler
and the steward of groundwater resources in Santa Clara County. The City also partners with
the SCVWD on conservation activities. The community is represented on the SCVWD Board of
Directors by the District 7 Director. The City’s mayor also appoints a representative to the
SCVWD Commission, an advisory body to the SCVWD Board of Directors.
In 2015, the City completed the Emergency Water Supply and Storage Project 25. The project
consisted of the repair and rehabilitation of five existing wells, construction of three new wells,
22 The SCVWD and the SFPUC wholesale customers in Santa Clara County are partners in conjunctively managing
the water resources in the county. The SFPUC customers in the county have contracts with the SFPUC.
23 See SCVWD website: http://www.valleywater.org/Services/WaterSupplyPlanning.aspx accessed Sept. 26, 2016
24 SCVWD Board Agenda Item 4.2, June 12, 2012
25 See more at: http://www.cityofpaloalto.org/gov/depts/utl/eng/water/emergency/default.asp
Page 21
and construction of a 2.5 million gallon storage reservoir and associated pump station, and
other upgrades to the water distribution system.
Availability
Normal Year Availability
As a city in Santa Clara County, Palo Alto has the ability to pump groundwater with the
understanding that SCVWD will appropriately manage the groundwater resources in the
county. If the basin has been drawn down to critical or severe levels over multiple years of
drought, it may take several years of normal or above-normal precipitation for the aquifer to
recover.
Assuming groundwater levels in the county are healthy, the City could use potable water from
some or all of its eight wells. As shown in Table 1, if all eight wells were used full time at full
capacity, they could produce more than 18,000 acre-feet per year (AFY). These well capacities26
compare to 11,000 AF/Y, the average forecasted demand for the 20-year WIRP planning. This
level of pumping, however, may be beyond the basin’s sustainable yield, estimated in the 2000
Carollo Study to be 3,500 to 6,100 AFY. The Recycled Water Strategic Plan will result in an
updated estimate of that yield.
Production levels will be impacted by the treatment options chosen as discussed in the section
regarding quality.
Table 1: Estimated Well Capacity
Dry Year Groundwater Availability
Because groundwater discharge and recharge happens at different rates, the available
groundwater supply may not coincide precisely with wet and dry years. During dry periods,
water users pump more groundwater and recharge is reduced or halted exacerbating the
situation. Even though the SCVWD may prudently manage local water supplies, the reliance on
imported water subjects water users in the county to potential water supply shortfalls.
26 Estimate provided by Utilities Engineering 2015
Well Capacity (AF/Y
Hale 2,340
Rinconada 5,326
Fernando 1,130
Peers 2,744
Matadero 1,130
El Camino 2,986
Eleanor 1,614
Library 968
Total 18,238
Page 22
In 2014 imported water from the State Water Project was reduced to almost zero, and the
SCVWD asked for voluntary reductions of 20%. In 2015, groundwater levels continued to drop
prompting the SCVWD to call for a 30% reduction in potable water use. This reduction was, in
many cases, more drastic than the targets imposed by the SWRCB imposed to meet the
Governor’s 25% state-wide water use reduction goal. Notwithstanding average precipitation
experienced in 2016, as of September 2016, the SCVWD continues to request a 20% reduction
while groundwater levels slowly recover. A prolonged drought could result in a request for cuts
of 40%.
Water Quality
The water quality of the groundwater is considered good, though historically the groundwater
in the area has had iron (Fe), manganese (Mn) and Total Dissolved Solids (TDS) levels that
exceed secondary27 drinking water quality standards.
All potable water scenarios must comply with water quality requirements. Wells are sampled
based in accordance with the SWRCB requirements. It is permissible to be out of compliance
with secondary standards on a short-term basis during emergencies, but for full-time operation
the City must be in compliance with secondary standards or apply for a waiver 28. The waiver
requires justification and includes a community survey demonstrating a high degree of
acceptance to establish support for the provision of water that exceeds secondary standards.
Several treatment and blending options for the wells were evaluated in 2000 in the “Long Term
Water Supply Study”, including:
1. Blend water with SFPUC water to meet water quality limits for manganese and iron. The
blended water will meet regulatory limits, but will have TDS levels 2-3 times the current
level in the distribution system29.
2. Provide iron and manganese treatment at each well site. The water will likely not
exceed TDS limits, but it will be 5-7 times the current TDS levels in the distribution
system.
3. Provide iron and manganese treatment at each well site and blend with SFPUC supplies
to reduce the well water TDS levels.
4. Provide iron, manganese and TDS treatment at each well site. The treated water at the
injection point will be comparable to SFPUC supplies.
The resulting water quality of each treatment option is provided in Table 2 30.
27 Primary drinking water quality standards apply to contaminants that affect health while secondary standards
apply to those constituents that affect aesthetics, taste and odor.
28 Title 17 Code of Regulations, Chapter 64449.2
29 Since completion of the Emergency Water Supply and Storage project, the El Camino Well water can be blended
with SFPUC water in the new 2.5 million gallon storage tank in El Camino Park in a similar manner to Option 1.
30 Estimate provided by Utilities Engineering 2015
Page 23
Table 2: Water Quality Resulting from Various Treatment Options
Water Quality
Parameter 31
Option 1
(blend)
Option 2 (treat
for Fe, Mn)
Option 3 (treat for
Fe, Mn and blend)
Option 4 (treat for
Fe, Mn and TDS)
TDS (500 ppm) 130-300 440-700 120 120
Manganese (<0.05 ppm) 0.04-0.05 <0.05 <0.01 <0.05
Iron (<0.3 ppm) 0.08-0.3 <0.3 0.05-0.06 <0.3
Treating and/or blending the groundwater affect the well production. Figure 7 shows the
production potential for all eight wells using each of the treatment options.
Figure 7: Estimated Well Production for Various Treatment Options
Cost
The SCVWD levies a groundwater extraction fee, or “pump tax”, on each acre-foot of water that
is pumped from the groundwater basin. The charge varies depending on a variety of factors,
including end use (agriculture vs. municipal) and geographic location in the County.
The new and refurbished wells were constructed with chlorine disinfection injection points and
the capability to accommodate fluoride and other needed chemical injection points. The use of
the wells on a regular basis will require a detailed operational plan and some or all of the sites
will need modifications to accommodate backup power, chemical storage, and any equipment
associated with the selected treatment option. Not all sites will have the space to
31 Manganese and Iron have single consumer acceptance contaminant levels, while TDS is a consumer acceptance
contaminant level range (recommended = 500; short term= 1000 and upper limit = 1500)
Page 24
accommodate these additional requirements, so an estimate of land acquisition needs was
included.
The total annualized unit cost in 2017 dollars including O&M and capital cost for each
treatment option at each well is shown in Figure 8 32. Capital costs include equipment, pipelines,
and land acquisition, if needed. O&M costs include the SCVWD groundwater production charge,
chemicals, replacement parts, personnel, and energy. The cost for the blending alternatives is
only for the groundwater and does not include the cost of SFPUC water.
Figure 8: Cost at Each Well for Each Treatment Option
The total annualized unit cost in 2017 dollars including O&M and capital cost for each
treatment option, assuming all wells are used, is shown in Figure 9. Because El Camino is
already configured to be a blending facility, the least cost option is blending at that site. If a
decision to use groundwater is made, a site-by-site evaluation of cost and operational
challenges will be needed, and it is likely that not all wells will be practical to use.
32 Costs are only those costs incurred by Water Utility. Customer costs, including water softening or filtration
devices will be additional costs borne by individual customers
Page 25
Figure 9: Unit cost of Various Treatment Options
The various treatment options will generate waste streams with elevated levels of iron,
manganese, TDS, and chemical residuals used in the treatment process. Due to regulatory
restrictions on the RWQCP and environmental protections for the San Francisco Bay,
discharging the raw waste stream to the storm water system or the wastewater collection
system for delivery to the Palo Alto RWQCP is not acceptable. Additional costs to manage this
waste stream are not included in this analysis.
Sustainability
Managing the groundwater resource in Santa Clara County is, ultimately, the SCVWD’s
responsibility. Palo Alto, however, would collaborate with SCVWD to ensure the basin remains
healthy. While the 2000 Carollo study estimated sustainable yield to be between 3,500 and
6,100 AFY, there are still unanswered questions regarding the hydrology in this part of the
county.
The Recycled Water Strategic Plan will shed more light on the water balance, the sustainable
yield, the interconnectivity between the shallow aquifer and the lower aquifer, and the
possibilities for groundwater recharge. Using the lower end of Carollo’s estimate, the City may
be able to safely rely on groundwater for about 30% of its potable water needs. In that case,
one or two high-production wells would likely be operated with treatment at those sites only.
Should the City chose to use groundwater on an ongoing basis for a significant amount of its
potable water needs, IPR may prove beneficial.
Since the City does not have land for percolation ponds, IPR would not only require advanced
treatment at the RWQCP, but a new pipeline to an injection facility as well. The cost of an IPR
Page 26
project is not included in the cost analysis of groundwater in this WIRP. If imported water
supplies are required to be delivered to the recharge facilities, those supplies need to be
identified.
Emergency Robustness
Refurbishing the five older wells and constructing three new wells and a 2.5 million gallon
storage reservoir and pump station was all part of the Emergency Water Supply and Storage
project, the primary goal of which was to maintain basic water service and fire flows in all
pressure zones in the City following a catastrophic interruption of SFPUC service. The City can
provide a minimum of eight hours of normal water use at the maximum day demand level and
four hours of fire suppression at the design fire duration level and will be capable of providing
normal wintertime supply needs during extended shutdowns of the SFPUC system.
The groundwater system may also be used to a limited extent during drought emergencies, but
is subject to the following mitigation measures, as stated in the Environmental Impact Report
(EIR) completed for the project 33:
1. An aquifer test shall be conducted following the City’s well construction and
rehabilitation efforts to verify the basin’s response to pumping; and
2. Emergency demand pumping shall be limited to 1,500 acre-feet (AF)34 in one year.
Following this level of pumpage, groundwater production shall be restricted until
groundwater levels recover to pre-pumping levels.
Sensitivity to Regulations and Environmental Review
All wells are currently permitted and designated by the California Department of Public Health
as “Standby” and, as such, can only be used for 5 consecutive days up to 15 days in a year35.
The wells may collectively supply up to 1,500 AF per year during a drought, with restrictions on
when the wells can resume pumping following that level of groundwater extraction. It is
important to note that the pumping restriction only applies to the project as defined in the EIR
prepared for the Emergency Water Supply and Storage Project. This includes the 5 existing
wells and 3 new wells. Individual property owners can install their own wells and pump
groundwater.
The SCVWD has indicated that the process to increase the current limitation will require
supporting information on the sustainable yield of the groundwater basin in order to
demonstrate increased pumping by the City will not have significant impacts36.
33 Environmental Impact Report, Emergency Water Supply and Storage project, Mitigation Measure 3.5-4(a) & 4(b).
See http://www.cityofpaloalto.org/civicax/filebank/documents/8372/ accessed September 29, 2016
34 1500 AF/Year is equal to 1.34 MGD, or approximately 12% of FY 2012 water consumption
35 California Code of Regulations, Title 22, Section 64414(c).
36 In summer 2012, staff met with SCVWD representatives to discuss the current limitation and the process to
increase/remove the limitation.
Page 27
With the current 1,500 AFY dry year groundwater extraction limitation, there is little risk any
dry year pumping program could result in significant impacts to the groundwater basin37.
The use of the wells to meet dry year needs is currently permitted subject to a pumping
limitation of 1,500 AF per year. A significant increase to this limitation could require
supplemental environmental review. Staff anticipates issues such as sustainable yield, dry year
availability, subsidence risk, saltwater intrusion, dewatering of local creeks and contaminated
plume migration, would be considered in such an environmental analysis.
The Sustainable Groundwater Management Act (SB 1168, SB 1319 and AB 1739) was a first step
toward more regulation of California’s groundwater resource. Santa Clara County, however, is
already managed by the SCVWD, an agency considered to be a model for the rest of the state.
It is very unlikely, therefore, that the new state regulations will have any impact on
groundwater activities in the county. The San Francisquito cone is the aquifer below the City,
and this formation includes part of San Mateo County. In general, more management of the
groundwater basin by the District in the north county would be beneficial for the City should
groundwater become a part of the City’s long-term water supply.
Potential State and Federal water quality regulations for potable water are a concern. Changes
in regulations could make the groundwater supply less attractive and more expensive due to
additional needed treatment.
IX. Treated Water from the SCVWD
In addition to managing the groundwater, the SCVWD produces and delivers treated drinking
water to water retail agencies in Santa Clara County. The existing treated water delivery
system does not serve the northwest portion of the county. A potential project known at the
SCVWD as the “West Pipeline Extension” involves extending the treated water pipeline from its
current terminus at Foothill Expressway and Miramonte Road to SFPUC’s Bay division Pipelines
3 and 4 at Foothills Expressway and Arastradero Road (a distance of about 4.5 miles). A map of
the potential project is provided in Figure 10.
37 The 1500 AFY limitation is a CEQA derived mitigation measure that has undergone the public review process.
Page 28
Figure 10: West Pipeline Extension Map
In 1999, the City sent a letter to the SCVWD advising it that information was needed to analyze
the City’s option to connect to the SCVWD West Pipeline. The SCVWD responded with an
estimated cost for the extension of the West Pipeline that would have to be fully borne by Palo
Alto. In February 2002, Palo Alto and four other county retailers requested that the SCVWD
conduct a feasibility study of a West Pipeline extension from both a supply perspective and the
additional reliability of having an additional interconnection with the SFPUC system. The
SCVWD prepared a report on extending the West Pipeline, entitled: “Santa Clara Valley Water
District’s West Pipeline Extension Conceptual Evaluation Final Report”38. The report evaluated
an extension of the existing SCVWD West Pipeline to enable an interconnection of the Palo Alto
and SCVWD systems at Page Mill turnout39.
38 The City of Palo Alto participated in the preparation of the 2012 Water Supply and Infrastructure Master Plan
(WSIMP). As part of that process, staff requested the SCVWD include the West Pipeline extension for project
consideration. The SCVWD noted in the Final 2012 WSIMP that the project is not recommended in the WSIMP
because it does not contribute to long-term supply reliability. However, the SCVWD stated that it would be
considered during a planned Infrastructure Reliability Master Plan.
39 The SFPUC and the SCVWD have an emergency interconnection near Milpitas that could theoretically be used to
wheel water to Palo Alto. Staff does not anticipate it will be feasible to wheel normal year supplies via the intertie,
but the use of the intertie during dry years may be possible. However, in general the SCVWD system is more dry
Page 29
Because the pipeline extension by itself would not increase water supply to the county, it is not
likely to be recommended in the SCVWD’s 2017 Water Supply Master Plan. The pipeline
combined with an SFPUC intertie is, however, one of 15 projects being considered in the Bay
Area Regional Reliability Project 40.
Availability
Normal Year Treated Water Availability
The SCVWD has a diverse water supply portfolio, including State Water Project, Central Valley
Project, and local reservoirs. SCVWD’s 2015 UWMP 41 indicated the SCVWD anticipates having
adequate supplies to meet future needs through 2040. As in other parts of the state, water
demand has decreased dramatically due to mandatory water use restrictions and usage
reduction targets. SCVWD’s water supply and demand projections do not assume any treated
water deliveries to Palo Alto or any other agency that does not currently receive treated water
from the SCVWD.
If the SCVWD extends the West Pipeline and the City negotiates a contract to receive water
from that pipeline, the terms of the treated water contract would determine the amount of
water delivered during normal years.
Dry Year Availability
It is unlikely treated water will be available during dry years. SCVWD’s 2015 UWMP showed an
adequate supply of available water to meet demands for one dry year, but multiple dry years
result in insufficient water supply to meet demand.
The water produced at SCVWD’s state-of-the-art purified water plant is currently blended with
recycled water for non-potable uses. Future plans include IPR and, possibly, DPR which could
increase SCVWD’s potable water supply availability. The cost of that water will also be impacted
and is not included in this analysis.
Water Quality
Carollo Engineers evaluated the SCVWD treated water line in the 2000 Long Term Supply Study
and provided information on the issues of blending SCVWD supplies with SFPUC supplies. In
general, SFPUC supplies are of superior quality to SCVWD supplies, but there were several
specific issues that were identified in the previous study. If the district decides to extend the
West Pipeline to achieve system reliability and if Palo Alto is interested in moving forward with
an interconnection with the SCVWD system, additional analysis will need to be performed to
determine if the previous issues still remain, and what additional issues have arisen.
year sensitive than the SFPUC system, so it is unclear whether supplies would be available to be wheeled to Palo
Alto via this mechanism.
40 http://www.bayareareliability.com/ accessed September 29, 2016
41 See SCVWD website: http://www.valleywater.org/Services/WaterSupplyPlanning.aspx accessed Sept. 29, 2016
Page 30
On the positive side, the SCVWD’s decision to include fluoridation at its treatment plants
removes the need to provide fluoridation at the interconnection points to ensure the water
supply complies with the municipal code. In a similar manner, the SFPUC uses chloramine for
residual disinfection. This removes some water quality related issues associated with blending
treated water from different sources that use different disinfectants. There may be other
issues related to water quality that could require the two water supplies to be isolated in the
distribution system. This would result in water from difference sources being provided to
customers depending on their location in the distribution system.
Cost
SCVWD’s West Pipeline Extension Report provided detailed cost estimates for several pipeline
configurations, which are summarized in Table 3. Both scenarios require a new parallel pipeline
from Rinconada Water Treatment plant to the current terminus of the West Pipeline at
Miramonte Road. From there, a new pipeline would be constructed to Page Mill Road. The
cost differential between the two scenarios is largely attributed to different pipe sizing
requirements and an intertie pump station.
Table 3: SCVWD Treated Water Connection Cost Summary 42
Alternative Assumptions Total Cost
of
Alternative
($million)
Cost to
SFPUC
($million)
Cost to
Palo Alto
($million)
Rate Increase
to SCVWD
Retailers
($/AF)
Parallel
and
Extension
• Existing treated water
contractors and new retailers
share cost of parallel pipe
• New retailers pay for extension
$160 N/A $64
$8
Parallel,
Extension
and
Intertie
• Existing treated water
contractors and new retailers
share cost of parallel pipe
• SFPUC pays for half of
incremental cost of intertie
• Existing and new retailers share
cost of extension and half of
incremental cost of intertie
$120 $23 $37
Pump Tax: $14
Treated
Water: $20
SCVWD’s West Pipeline Extension Report concluded that the City and neighboring jurisdictions
must pay for the costs of constructing the extension via a “take or pay” contract, which is a
common payment mechanism for all retail water agencies in the county that purchase SCVWD
treated water. The amount of the take or pay contract is determined by the amortized
42 Cost of additional supply is not included in project cost. Costs have been escalated 3% from 2003 dollars to
provide a representation of potential cost ranges.
Page 31
construction costs divided by the annual treated water rate. For example, if Palo Alto’s
obligation for a West Pipeline extension was $37 million, it would pay an annual cost of $2.5
million (assuming an interest rate of 3%/year for a 20-year financing period). Using a treated
water rate of $1,350 per AF 43, Palo Alto would be required to purchase about 2,000 AF/year
($2.5 million divided by $1,350/AF), or about 18% of the City’s expected average water usage
for the WIRP planning horizon.
During the term of the contract, the City would have limited ability to adjust its annual water
purchase from the SCVWD. There are several agencies in Santa Clara County that purchase
both SCVWD and SFPUC treated water, and they are subject to minimum “take or pay” contract
provisions from both providers. The City would receive similar treatment. The cost estimates
in Table 3 do not account for any distribution system improvements that may be required to
configure Palo Alto’s distribution system to receive SCVWD treated water.
If the pipeline extension came to fruition through a regional reliability implementation plan, the
terms of a potential treated water supply contract with Palo Alto may be adjusted to account
for the regional system reliability provided to all customers as a result of the project.
The California Water Fix (also known as the “Twin Tunnels”) is a proposal to address the co-
equal goals of water supply reliability and environmental sustainability. The proposed water
conveyance solution is a pair of tunnels underneath the Delta from an intake on the
Sacramento River to the South Delta Diversion/Pumping facilities. Such a facility will take
decades to build and the costs will likely be borne by State and Federal water contractors,
including the SCVWD. The SCVWD will likely continue to collect revenue for all SWP costs
through property taxes rather than through water rates. Palo Alto property owners will, thus,
bear those costs whether or not water is delivered to Palo Alto.
Emergency Robustness
The SCVWD’s Water Utility Infrastructure Reliability Plan was completed in in 2005. The project
measured the baseline performance of critical facilities in emergency events and identified
system vulnerabilities. The plan concluded that the water supply system could suffer up to a 60-
day outage if a major event, such as a 7.9 magnitude earthquake on the San Andreas Fault,
were to occur. A series of projects were implemented and the expected outage time in a major
event is now estimated to be 30 days.
The SCVWD is currently updating its Infrastructure Reliability Plan. The goal of the update is to
identify new reliability improvements that are more regional, less capital intensive alternatives
to the well fields. The updated plan and final recommendations will be complete in in the near
future.
43 This is SCVWD’s projected treated water rate for FY 2018
Page 32
If the West Pipeline was extended to provide potable water service to Palo Alto, the City would
have one connection to the SCVWD system44, compared to 5 connections to the SFPUC system.
It is unclear what level of reliability would be provided in the event of catastrophic event. The
SFPUC level of service goal following an earthquake is to provide for average wintertime
demands with delivery to 70% of the turnouts within 24 hours following a major earthquake.
The SCVWD level of service goal provides for service resumption to one turnout within 7 days of
a similar event, though the location of a Palo Alto interconnection at the end of the treated
water line may be a weak point, so it is unclear if there will be adequate supplies or system
pressures to provide meaningful service. In addition, the SCVWD plans on extracting
groundwater for raw water delivery to the treatment plants and on to the retailers during an
emergency. The Emergency Water Supply and Storage project was designed to serve this
purpose for Palo Alto.
Sustainability
Like all water suppliers in California that rely on imported water, the SCVWD’s ability to provide
a reliable, clean water supply is challenged by the potential of warmer temperatures, changing
precipitation and runoff patterns, reduced snow pack, and rising sea levels. The SCVWD’s water
supply vulnerabilities to climate change include a potential decrease in imported water supplies
as a result of a reduction in snow pack and a shift in the timing of runoff, a decrease in local
surface water supplies as result of reduced precipitation, more frequent and severe droughts,
changes in surface water quality associated with changes in flows and temperature, and
changes in imported water quality due to salinity intrusion in the Delta. Additional
vulnerabilities include infrastructure and water quality issues from more frequent algal blooms,
invasive and/or non-native species, and wildfire.
During the drought in the late 1980’s and again in recent years, SCVWD supplies from both the
state and federal sources were drastically reduced. Groundwater was relied upon heavily
causing levels to rapidly decrease. Sustainability will be improved if purified water from the
SCVWD’s plant is ultimately used for IPR or DPR in the county.
Sensitivity to Regulations and Environmental Review
A West Pipeline extension will require CEQA review. The SCVWD would be the lead agency for
the CEQA process.
Because the SCVWD imports water from both the State and Federal water projects, it is
vulnerable to actions that impact those sources. Since Council approved the 2003 WIRP,
federal and state water deliveries have been reduced on several occasions due to Delta related
issues. Most recently, state water deliveries were curtailed dramatically due to the drought.
44 There may be additional connection options to a new SCVWD treated water pipeline, such as a new extension to
the existing Arastradero SFPUC turnout. However, the cost of additional connections was not included in the initial
cost estimate and would likely be borne by the City. Additional connections may allow increased use of and more
efficient distribution of SCVWD treated water, though they may not provide any additional reliability assurances.
Page 33
X. Demand Side Management
The City is committed to support conservation and efficient use of its water supply. It is the goal
of the City to continue to look for opportunities, innovative technologies, and cost-effective
programs that best utilize the City’s water conservation budget. The City works with other
BAWSCA members, the SCVWD, and other water agencies in the Bay Area to implement Best
Management Practices (BMPs) related to water conservation programs.
The Water Conservation Bill of 2009 (SBx7-7) was enacted in November 2009. It requires water
suppliers to reduce the statewide average per capita daily water consumption by 20% by
December 31, 2020. To monitor the progress towards achieving the 20% by 2020 target, the bill
also requires urban retail water providers to reduce per capita water consumption 10% by
2015. The City met the interim 2015 SBx7-7 target and is projected to meet the 2020 target.
The following measures have been implemented over the past five years and/or will be
implemented to achieve the City’s water use target pursuant to SBx7-7:
1. Water Waste Prevention Ordinance: The City has enforced water waste prevention as
part of the City’s Municipal Code since 1989 (Palo Alto Municipal Code Chapter 12.32).
Enforcement includes written warning notices and may result in fines and installation of
a flow restrictors, and billing the costs of such installation to the responsible customer or
purchaser, as applicable.
2. Metering: The City is currently implementing a pilot program using advanced electric, gas
and water meters at 300 single-family homes. Customers with these advanced meters
can monitor their hourly water usage from a secured website. The City plans to deploy
advanced water meters to all customers by 2022.
3. Conservation Pricing: Since 1976, the City has implemented conservation-based pricing
for water usage, within an overall cost-based rate structure.
4. Public Education and Outreach: Since 2006, the City has partnered with BAWSCA to offer
free workshops on water efficient landscaping, irrigation and water conservation. In
addition to public workshops, CPAU staff attends community, corporate and school
events to promote water conservation programs and practices, in addition to energy
efficiency, waste reduction and other sustainability practices.
The City carries out various seasonal and general water conservation campaigns via the
use of television, online, social media and print advertisements. Palo Alto also regularly
updates the City’s website on water conservation programs and public workshops. The
City utilizes utility bill inserts, brochures and email newsletters to customers as part of its
outreach efforts.
5. Programs to Assess and Manage Distribution Systems Real Loss: For over two decades,
the City has pursued an aggressive Water Main Replacement Capital Improvement
Program. In addition, the City maintains a Water Meter Replacement Program that
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replaces 500 to 1,000 meters per year in accordance with American Water Works
Association (AWWA) standards.
6. Water Conservation Program Partnership with SCVWD: Since 2002, the City has
partnered with SCVWD to promote and cost-share a wide range of water conservation
programs to encourage residents and businesses to improve water use efficiency. These
programs include free indoor and outdoor water audits, as well as rebates for upgrading
a wide range of water-using fixtures to high efficiency models, including toilets, urinals,
clothes washers, laundry to landscape graywater systems, high water-using landscapes,
irrigation hardware, commercial food service and other process equipment.
7. Greywater Use: Laundry to Landscape Graywater rebates are available from the City and
SCVWD for residents who properly connect a clothes washer to a graywater irrigation
system following rebate program and California Plumbing Code guidelines.
Availability
Normal Year Availability
The SBx7-7 goal is consistent with the City’s longstanding policy of providing cost effective
conservation programs to the community. Figure 11 shows the targets, the City’s progress to
date, and a projection of the City’s future water demand.
Figure 11: SBx7X7 Targets, Results, and Projections
Dry Year Availability
Page 35
During SFPUC water shortage events or state-mandated potable water use reductions, the City
implements its Water Shortage Contingency Plan (WSCP) as outlined in the UWMP. The WSCP
included water use restrictions and other actions to be taken to achieve specific water use
reduction targets. The stages are:
Stage I: 5%-10% water use reduction
Stage II: 10%-20% water use reduction
Stage III: 20%-35% water use reduction
Stage IV: 35%-50% water use reduction
From June 1, 2015 until February 28, 2016, the City was subject to a mandatory 24% potable
water use reduction by the SWRCB using usage during calendar year 2013 as the baseline. All of
Stage II actions, a subset of Stage III actions and the additional State-mandated actions were
implemented. The City was able to achieve a 31.4% reduction in potable water use over the
compliance period, proving the WSCP is an effective means to reduce water demand when
needed. Figure 12 demonstrates the City’s successful drought response.
Figure 12: Monthly Potable Water Consumption
Water Quality
Demand side measures do not present any water quality issues.
Cost
The City takes advantage of opportunities, innovative technologies, and cost effective programs
that best utilize the water conservation budget. In FY 2011, the City dramatically increased
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conservation program savings goals to meet the requirements of SB7x-7, the Water
Conservation Bill of 2009 which required water suppliers to reduce the average per capita
water consumption in their service territories 20% by 2020.
Each demand side measure is assessed in terms of financial impact to the utility, which includes
rebate costs as well as any other administrative costs. Table 4 depicts the actual cost of water
efficiency to the utility for the past several years. For comparison, as shown in Figure 5 above,
the cost of SFPUC water is currently almost $2,000 per AF and is expected to increase to $2,800
per AF in 10 years.
Table 4: Water Efficiency Costs ($/AF)
FY 2013 FY 2014 FY 2015 3-Year Average
$1,294 $1,359 $2,008 $1,555
As the cost of potable water increases, some conservation programs become more cost
effective, though the easiest, most cost-effective measures have largely been deployed.
Adjustments are made to conservation programs depending on several factors, including
program penetration and community preferences.
The 2015 UWMP identified Advanced Metering Infrastructure (AMI) as the primary future
water efficiency program. Anticipated savings from AMI and other incremental water efficiency
activities are shown in Figure 13. New efficiency programs are projected to shave off about
1.2% from the expected demand forecast.
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Figure 13: Water Demand Forecast with Future Water Efficiency
Emergency Robustness
The 2015 UWMP contains a summary of demand side options that can be implemented under
various scenarios. During a catastrophic interruption of SFPUC supplies, the City will
immediately initiate emergency supply options to meet potable demands and fire flow
requirements. At the same time, the City will begin informational outreach programs to inform
the community that emergency conditions are in effect and water consumption behavioral
changes are required (i.e. no irrigation).
Sustainability
Demand side management is the most sustainable resource. Every cubic foot of water saved
can be put to some beneficial use. Measures that specifically target landscape conversions or
efficiency changes have been the subject of concern by tree advocacy groups who are
concerned about impacts on trees due to decreased landscape watering. The City includes
information on proper tree maintenance for those customers converting to drought resistant
landscapes.
Sensitivity to Regulations and Environmental Review
Demand side measures are not limited by any regulations. In light of the current drought, State
agencies are reviewing the existing long-term conservation targets and water shortage
contingency planning scenarios. It is likely that by the 2020 UWMP cycle, new conservation
Page 38
targets and new planning criteria will be in place. Additionally, requirements to implement
measures may be proposed, or compliance with certain efficiency standards (e.g. per capita
water use) may be required, especially if seeking State or Federal grant or loan assistance for a
project such as the recycled water project.
XI. Comparison of Water Supply Alternatives
Availability
Normal Year Availability
• SFPUC supplies are sufficient in normal years.
• Groundwater without recharge may not always be available depending on the amount
of water pumped by the City, the sustainable yield determined in the Recycled Water
Strategic Plan, and the groundwater levels throughout the county.
o A coincident recharge project with purified recycled water would improve the
availability of this resource.
o Using the El Camino well alone for blending will meet only about 15% of the
City’s demand.
• Treated water from the SCVWD is not in abundance.
• Demand side management is possible, but many of the easy cost-effective measures
have already been implemented.
Dry Year Availability
• All potable water supplies, including SFPUC supplies, are subject to 20% reductions or
more by the State.
• SFPUC supplies are subject to reductions in availability of up to 20% due to drought.
• Groundwater may be restricted up to 40% by the SCVWD or subject to State-mandated
reductions.
• Water deliveries from State and federal projects may impact the amount of treated
water available from the SCVWD requiring water use reductions of up to 40%.
• Demand side management is very effective during dry years.
Water Quality
Key water quality parameters for untreated groundwater, water from the SFPUC and treated
water from the SCVWD are compared in Table 5. All of these sources meet primary drinking
water standards. The table lists several secondary standards and a sampling of other
parameters. Groundwater used as a regular long-term supply source would require treatment
and/or blending to meet the secondary standards.
Page 39
Table 5: Water Quality Parameters for Water Resource Alternatives
Water Source Fe
(ppm)
Mn
(ppm)
TDS
(ppm)
Sodium
(ppm)
Hardness
(as CaCo3)
(ppm)
Turbidity
(NTU)
Drinking Water Quality Standard .300 .050 500 N/A N/A 5
SFPUC Water (1) ND ND 132 13.5 57 0.16
SCVWD Treated Water (2) ND ND 209 37 90 0.07
Groundwater (3) 0.25-1.3 0.13-0.31 440-710 75-170 - 0.33-7.7
(1) SFPUC values are average water quality values reported by the SFPUC in its 2011 Water Quality Report
(2) Average values from 2011 SCVWD Rinconada Water Treatment Plant Water Quality Data Summary
(3) Based on the City’s well water testing records
ND = non detect
Cost
Figure 14 shows projected commodity rates for SFPUC water and groundwater and treated
water from the SCVWD. In the near term, SFPUC water is expected to be more expensive. By
2037, even with SCVWD subsidizing the cost of its State Water Projects costs by collecting those
costs via property taxes, SCVWD and SFPUC rates are expected to converge.
These projected rates for the SCVWD do not include the cost of using the purified water plant
to supply potable water nor do these rates include the cost of the California Water Fix (the
“twin tunnels” project in the Delta). Both of those projects will cause steep increases for
SCVWD rates. The total groundwater rate does not include the cost of local treatment that may
be required to improve the water quality from that shown in Table 5 above. In addition, both
SFPUC and SCVWD rates are extremely sensitive to the volume of water sold as both systems’
costs are mostly fixed.
Cost-effective demand side management measures are, by definition, the lowest cost resource.
Costs of demand side measures were assumed to rise with inflation. The exhaustion of easy
measures may cause costs to be higher, but technology developments may result in lower
costs.
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Figure 14: Commodity Cost Comparison of Water Supply Alternatives
Figure 15 shows the present value unit cost over 20 years for each option including the cost of
groundwater treatment. The cost of blending at the El Camino well is shown as a separate
option because blending at that specific wellsite is the least cost groundwater alternative.
Figure 15: Present Value Unit Cost Comparison of Water Supply Alternatives
Page 41
Emergency Robustness
• The SFPUC has nearly completed a massive capital project to improve the reliability of
the regional water system, however some risks still exist.
• Groundwater is a reliable and available emergency resource.
• Treated water from the SCVWD may not be available in an emergency.
• Demand side management is very effective during emergencies.
Sustainability
• SFPUC supplies originate as snowpack in the Sierra and may be impacted by climate
change.
• Groundwater may be sustainable at lower pumping rates and sustainable at higher
pumping rates with a recharge project.
• Treated water available from the SCVWD originates as Sierra snowpack, which may be
impacted by climate change, and the Delta, which has already been determined to be
unsustainable in its current state.
• Demand side management is very sustainable as long as the urban canopy is properly
cared for.
Sensitivity to Regulations and Environmental Review
• SFPUC supplies may be sensitive to future regulations.
• Groundwater is managed by the SCVWD. A groundwater recharge project would be
subject to environmental review.
• Water deliveries from State and Federal projects may be sensitive to future regulations.
The Delta is experiencing environmental challenges now.
• Demand side management is not sensitive to regulations or environmental review.
XII. Conclusions
Table 6 is a side-by-side comparison of the potable water resource alternatives based on the
attributes considered in this WIRP.
Page 42
Table 6: Summary Comparison of Potable Water Resource Alternatives
Water
Resource
Alternative
Normal Year
Availability
Dry Year
Availability
Quality Cost Emergency
Robustness
Sustainability Sensitivity to
Regulations and
Environmental
Review
SFPUC
Groundwater
Groundwater
(w/recharge)
?
SCVWD
Treated Water
Demand Side
Management
Cost-effective demand side management is the superior resource and should be diligently
pursued but can’t eliminate the City’s need for potable water. While SFPUC water is slightly
more expensive, it has higher water quality. The cost of SCVWD supplies may increase
dramatically if purified water is fully developed and/or if the twin tunnels project is
constructed. However, SCVWD does not have excess treated water to sell and groundwater in
the county is susceptible to mandated water use reductions just like SFPUC supplies are,
arguably more so. Blending groundwater with SFPUC water at only the El Camino well is the
least expensive, most sustainable alternative to 100% SFPUC supplies. Whether the residents
and businesses that would receive the water would consider the tradeoff between cost and
quality to be acceptable is worth investigating.
The most promising way to increase reliability and increase sustainability is to reduce the
demand for potable water by expanding the use of recycled water. The Recycled Water
Strategic Plan will provide valuable analysis and information to help the City and SCVWD
formulate a strategy for the future.
In summary, the recommended 2017 WIRP Guidelines are:
1. Pursue all cost-effective water efficiency and conservation;
2. Survey potentially impacted customers about their preference for SFPUC water versus
blended water;
3. Proceed with the Recycled Water Strategic Plan to determine how to reduce the
demand for imported water; and
4. Continue to investigate the technical feasibility and financial impact of increasing the
use of non-traditional, non-potable sources such as black water, storm water, and
nuisance water from basement construction.
WIRP Guidelines
Adopted by Resolution by the City Council on December 8, 2003 [CMR:547:03]
Guideline 1 – Preserve and enhance SFPUC supplies: With respect to the City of Palo Alto
Utilities’ (CPAU’s) primary water supply source, the San Francisco Public Utilities Commission
(SFPUC), continue to actively participate in the Bay Area Water Supply and Conservation
Agency (BAWSCA) to assist in achieving BAWSCA’s stated goal: “A reliable supply of water,
with high quality, and at a fair price.” Objectives in support of that overall goal include:
A. That the regional water system gets rebuilt cost-effectively and that BAWSCA
monitor implementation of AB 1823 – San Francisco should safeguard the water
system against damage from earthquakes and other foreseeable hazards. BAWSCA
will monitor progress on the system repairs and on completing the requirements of
the legislation that the BAWSCA agencies supported to oblige San Francisco to
repair and rebuild the regional system.
B. That the cost of improvements is fairly allocated – San Francisco should commit to
maintaining cost-based pricing, with the costs of the wholesale water system shared
between the City and its wholesale customers based on their proportionate share.
C. That future water needs can be met – San Francisco must evaluate the ability of the
regional system to meet future supply and capacity requirements and must use the
BAWSCA agencies’ long-term water demand forecasts as the basis for regional water
demand projections.
D. That there are adequate supplies during droughts – San Francisco should arrange
back-up supplies for dry years and should “drought proof” the entire service area, not
just San Francisco itself. If rationing becomes necessary, San Francisco should use a
system that allocates available water between San Francisco and wholesale customers
in a way that (1) is fair and (2) avoids penalizing long-term conservation efforts
and/or development of alternative supplies, such as recycled water.
E. That communities prepare for potential water outages – San Francisco should
coordinate with the BAWSCA agencies to develop a crisis management plan.
F. That agencies implement cost-effective water conservation activities – San Francisco
should provide agencies enough information so that they can prepare for possible
outages, including the provision of conservation programs for their communities.
BAWSCA can act as coordinator for these programs to improve the cost-
effectiveness of agencies offering such programs.
G. That water received must meet drinking water standards – San Francisco should
continue to protect the purity of Hetch Hetchy water and commit to provide its
wholesale customers with water that meets EPA and California drinking water
standards.
H. That the Master Contract is properly implemented and a new Master Contract is in
place prior to 2009 – San Francisco should commit to maintaining cost-based pricing,
with the costs of the wholesale water system shared between the City and its
wholesale customers based on their proportionate share.
I. That there is ongoing support of efforts to protect health, safety and economic well
being of the water customers and communities – BAWSCA should maintain the
support of the many allies who supported the legislative effort to ensure San
Francisco repairs, rebuilds, and maintains the regional system.
Attachment B
Guideline 2 – Advocate for an interconnection between SFPUC and the District: Work with
the Santa Clara Valley Water District (District) and the SFPUC to pursue the extension of the
District’s West Pipeline to an interconnection with the SFPUC Bay Division Pipelines 3&4.
Continue to re-evaluate the attractiveness of a connection to an extension of the District’s West
Pipeline.
Guideline 3 – Actively participate in development of cost-effective regional recycled water
plans: Re-initiate discussions with the owners of the Palo Alto Regional Water Quality Control
Plant (PARWQCP) on recycled water development. In concert with the PARWQCP owners,
conduct a new feasibility study for recycled water development. Since the feasibility of a
recycled water system depends upon sufficient end-user interest, determine how much water
Stanford and the Stanford Research Park would take.
Guideline 4 – Focus water DSM programs to comply with BMPs: Continue implementation
of water efficiency programs with the primary focus to achieve compliance with the Best
Management Practices (BMPs) promoted by the California Urban Water Conservation Coalition.
Guideline 5 – Maintain emergency water conservation measures to be activated in case of
droughts: Review, retain, and prioritize CPAU’s emergency water conservation measures that
would be put into place in a drought time emergency.
Guideline 6 – Retain groundwater supply options in case of changed future conditions:
Using groundwater on a continuous basis does not appear to be attractive at this time due to the
availability of adequate, high quality supplies from the SFPUC in normal years. However,
SFPUC supplies are not adequate in drought years and circumstances could change in the future
such that groundwater supplies could become an attractive, cost-effective option. Examples of
changing circumstances could be that the amount of water available to CPAU from the SFPUC
for the long-term is reduced. This could occur if regulations or legislation require additional
water to be made available to the Tuolumne River fisheries. In addition, in the future allocations
or entitlements to SFPUC water may be developed. If those allocations are based on the dry-
year yield of the system, allocations to all the users of the system, including CPAU, could be
well below their current and projected future needs. CPAU should retain the option of using
groundwater in amounts that would not result in land surface subsidence, saltwater intrusion, or
migration of contaminated plumes.
Guideline 7 – Survey community to determine its preferences regarding the best water
resource portfolio: Seek feedback from all classes of water customers on the question of
whether to use groundwater during drought to improve drought year supply reliability. At the
same time, seek feedback on the appropriate level of water treatment for groundwater if it were
to be used in droughts. Survey all classes of water customers to determine their preferences as to
the appropriate balance between cost, quality, reliability, and environmental impact.
Attachment B
PRELIMINARY ASSESSMENT
OF WATER RESOURCE
ALTERNATIVES
February 2013
i
2013 Preliminary Assessment
Table of Contents
List of Figures ___________________________________________________________ iii
List of Tables ___________________________________________________________ iii
List of Acronyms _________________________________________________________ iii
I. Introduction __________________________________________________________ 1
II. Background __________________________________________________________ 2
III. Water Supply History __________________________________________________ 3
IV. Water Use Projections _______________________________________________ 6
Urban Water Management Plan (UWMP) _________________________________________ 6
Water Conservation Bill of 2009 _________________________________________________ 7
Summary Water Resource Mix __________________________________________________ 7
V. Attributes Evaluated and Water Resource Alternatives Examined ______________ 8
Attributes Evaluated for each Water Resource Alternative ___________________________ 8
Water Resource Alternatives Examined __________________________________________ 9
VI. Water from the SFPUC ______________________________________________ 10
Availability _________________________________________________________________ 10
Cost ______________________________________________________________________ 12
Water Quality ______________________________________________________________ 13
Long Term Reliability ________________________________________________________ 13
Emergency Robustness _______________________________________________________ 15
Environmental impacts _______________________________________________________ 16
Sensitivity to Regulations _____________________________________________________ 16
VII. Groundwater _____________________________________________________ 17
Availability _________________________________________________________________ 18
Cost ______________________________________________________________________ 20
Water Quality ______________________________________________________________ 21
Long Term Reliability ________________________________________________________ 24
Emergency Robustness _______________________________________________________ 24
Environmental impacts _______________________________________________________ 24
Sensitivity to Regulations _____________________________________________________ 24
VIII. SCVWD Treated Water ______________________________________________ 25
Availability _________________________________________________________________ 26
Cost ______________________________________________________________________ 26
Water Quality ______________________________________________________________ 28
Long Term Reliability ________________________________________________________ 28
Emergency Robustness _______________________________________________________ 28
Environmental Impacts _______________________________________________________ 30
ii
Sensitivity to Regulations _____________________________________________________ 30
IX. Recycled Water ______________________________________________________ 31
Availability _________________________________________________________________ 32
Cost ______________________________________________________________________ 35
Water Quality ______________________________________________________________ 36
Long Term Reliability ________________________________________________________ 37
Emergency Robustness _______________________________________________________ 37
Environmental Impacts _______________________________________________________ 37
Sensitivity to Regulations _____________________________________________________ 37
X. Demand‐Side Management ____________________________________________ 38
Availability _________________________________________________________________ 38
Cost ______________________________________________________________________ 40
Water Quality ______________________________________________________________ 40
Long Term Reliability ________________________________________________________ 41
Emergency Robustness _______________________________________________________ 41
Environmental Impacts _______________________________________________________ 41
Sensitivity to Regulations _____________________________________________________ 42
XI. Individual Supply Guarantee Sale ________________________________________ 42
Availability _________________________________________________________________ 42
Cost ______________________________________________________________________ 42
Water Quality ______________________________________________________________ 43
Long Term Reliability ________________________________________________________ 43
Emergency Robustness _______________________________________________________ 43
Environmental Impacts _______________________________________________________ 43
Sensitivity to Regulations _____________________________________________________ 44
iii
List of Figures
Figure 1: Historic Water Use ........................................................................................................... 5
Figure 2: 2005 and 2010 UWMP Demand Forecast Projection Comparison ................................. 6
Figure 3: 20% by 2020 Compliance Forecast .................................................................................. 7
Figure 4: Summary Water Resource Composition .......................................................................... 8
Figure 5: SFPUC Actual and Projected Cost of Water ................................................................... 12
Figure 6: Historic Water Shortages at Maximum Demand Level (265 MGD) ............................... 15
Figure 7: Map of SFPUC Regional Water System .......................................................................... 16
Figure 8: Projected SFPUC and SCVWD Water Rates ................................................................... 21
Figure 9: West Pipeline Extension Map ........................................................................................ 26
Figure 10: Proposed Recycled Water Project ............................................................................... 32
Figure 11: Palo Alto Existing Recycled Water Uses for FY 2004‐FY 2012 .................................... 34
Figure 12: Water Conservation Savings Goals .............................................................................. 39
List of Tables
Table 1: City Of Palo Alto Water Shortage Allocation .................................................................. 11
Table 2: Dry Year Shortfall under different demand scenarios .................................................... 14
Table 3: Projected Well Capacities ............................................................................................... 20
Table 4: Water Quality Parameters for Various Water Sources ................................................... 22
Table 5: Well Treatment Alternative Preliminary Cost Analysis ................................................... 23
Table 6: SCVWD Treated Water Connection Summary Costs ...................................................... 27
Table 7: Recycled Water Gross Cost Estimate .............................................................................. 35
Table 8: Water Savings vs. Goals .................................................................................................. 39
Table 9: Conservation Program Costs ........................................................................................... 40
List of Acronyms
AFY Acre Feet per Year
BAWSCA Bay Area Water Supply and Conservation Agency
BMP Best Management Practice
CDPH California Department of Public Health
CEQA California Environmental Quality Act
CUWCC California Urban Water Conservation Council
CVP Central Valley Project
DSM Demand Side Management
EIR Environmental Impact Report
ESA Endangered Species Act
FERC Federal Energy Regulatory Commission
iv
GWMP Groundwater Management Plan
ISA Interim Supply Allocation
ISG Individual Supply Guarantee
ISL Interim Supply Limitation
MGD Million gallons per day
MOU Memorandum of Understanding
NEPA National Environmental Policy Act
PEIR Program Environmental Impact Report
PPM Parts per Million
RWQCP Regional Water Quality Control Plant
SCVWD Santa Clara Valley Water District
SFPUC San Francisco Public Utilities Commission
SRF State Water Resources Control Board State Revolving Fund
SWP State Water Project
SWRCB State Water Resources Control Board
TDS Total Dissolved Solids
TRC Total Resource Cost
UAC Utilities Advisory Commission
UWMP Urban Water Management Plan
WIRP Water Integrated Resource Plan
WSA Water Supply Agreement
WSIP Water System Improvement Program
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I. Introduction
Preparation of a Preliminary Assessment of Water Resource Alternatives is the first step
towards development of a Water Integrated Resource Plan (WIRP). The Preliminary
Assessment collects the available information and data about all water resource alternatives
available to the City of Palo Alto. The following are a summary of the main drivers for updating
the WIRP at this time.
a) Cost Increases – The San Francisco Public Utilities Commission (SFPUC) is midway through
the $4.6 billion Water System Improvement Program (WISP), which includes an upgrade of
the regional water system. As a result of the WSIP, the cost of SFPUC water has risen
dramatically and will continue to do so. With the increase in costs, other alternatives are
increasingly competitive with SFPUC supplies.
b) SFPUC Wholesale Water Charge – The SFPUC currently collects the wholesale revenue
requirement primarily through a volumetric water rate. The SFPUC may propose changes
to the current wholesale rate structure that include a fixed charge based on the Individual
Supply Guarantee. Since the City has a relatively high Individual Supply Guarantee, this
could change the City’s cost dramatically and make other alternatives more cost‐effective.
c) Dry year need – The City has an Individual Supply Guarantee of 17.07 million gallons per
day (MGD) from the SFPUC system. The City has no foreseeable supply deficiency in
normal years, but SFPUC supplies are inadequate during dry years. A critical question to
address is the level of reliability the City will provide to residents and businesses and at
what cost.
d) Disposition of “Surplus” SFPUC Individual Supply Guarantee– The City currently uses
substantially less than its Individual Supply Guarantee. Considering long lead times to
execute water transfers, it may be the time for the City to proceed towards a sale of a
portion of the Individual Supply Guarantee. The sale could generate revenue for a variety
of options, including increased dry year reliability, conservation programs, a recycled water
project, or to reduce rates.
e) Alternative Supplies – The Santa Clara Valley Water District’s (SCVWD’s) groundwater and
treated water charges have historically been similar to the cost of SFPUC supplies. Over
the last few years, and for the foreseeable future, SCVWD water charges will be lower than
SFPUC charges, making groundwater or a connection to the SCVWD’s treated water system
potentially cost‐effective alternatives to SFPUC water.
f) Use of Palo Alto Groundwater System – The City has recently refurbished the five older
wells, developed two new wells and is completing another new well. One or more of the
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wells could be used to provide supplemental dry year supplies or as an alternative to
SFPUC supplies during normal years.
g) Legislative & Regulatory Risks – The City’s 2010 Urban Water Management Plan (UWMP)
incorporates recent and future legislative and regulatory requirements to provide a
comprehensive forward looking review of the water utility. A major new development is
Senate Bill 7x‐7 (2009), which requires a 20% reduction in per capita water use by 2020.
II. Background
The first WIRP was prepared largely because the City was faced with a decision to participate in
a regional recycled water program. This 1993 WIRP assessed the costs and benefits of a
recycled water project compared to other supply alternatives, and ultimately determined that
recycled water was not cost effective relative to existing supplies. In 1999, the City began
working on a new WIRP, and completed the effort with approval by the City Council of the
WIRP Guidelines in December 2003 (CMR 547:03). During the process to prepare the 2003
WIRP, several studies were conducted to inform the effort:
1. Water, Wells, Regional Storage, and Distribution System Study, 1999, Carollo Engineers –
This study identified system improvements to the distribution system to meet water
demands and fire flows following a catastrophic interruption of service on the SFPUC
system. Among the recommendations was to refurbish the 5 existing wells and construct
three new wells and a new water storage tank.
2. Long Term Water Supply Study, 2000, Carollo Engineers – The report examined the issues
and costs of using new or rehabilitated wells as active sources of supply. The alternatives
examined in the report included: (1) Using the wells for active supply either on a long term
basis or during droughts; (2) using groundwater for irrigation; and (3) connecting to the
SCVWD treated water pipeline.
3. Groundwater Supply Feasibility Study, 2002, Carollo Engineers – The report evaluated
whether operating one or two of the City’s water wells as active supplies would cause
significant decrease in groundwater levels or deterioration in groundwater quality”.
4. Santa Clara Valley Water District’s West Pipeline Extension Conceptual Evaluation Final
Report, 2003, SCVWD. – The report evaluated an extension of the existing SCVWD West
Pipeline to enable an interconnection of the Palo Alto and SCVWD systems at Page Mill
turnout.
The 2003 WIRP indicated that SFPUC supplies were adequate during normal years, but
additional supplies were needed in dry years to avoid shortages. Since SFPUC supplies were
adequate in normal years, the following conclusions were drawn:
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1. The City’s existing Individual Supply Guarantee provides adequate supplies;
2. The cost to connect to the SCVWD treated water pipeline was prohibitive;
3. Continuous use of groundwater is not recommended;
4. The City should continue to evaluate recycled water;
5. Continue the current Demand Side Management programs and explore additional
measures; and
6. Additional supplies are needed in a drought.
Following approval of the 2003 WIRP, staff surveyed residential customers to gain a sense of
community preferences on the use of groundwater during a drought. The survey asked
respondents to rank several options for water supply during a drought: (A) blend groundwater
with existing SFPUC supplies; (B) use no groundwater; and (C) treat groundwater at the well
location prior to introduction to the distribution system.
Survey respondents generally preferred Options B (no groundwater) and C (treat groundwater),
but Option A (blend groundwater) was not soundly rejected. The results of the survey were
presented to the UAC in June 2004. Based on the results staff made the following
recommendations:
1. Do not install advanced treatment systems for the groundwater at this time. This option
is expensive, both in terms of capital and operating costs.
2. Blending at an SFPUC turnout is the best way to use ground water as a supplemental
drought time supply while maintaining good water quality.
3. Staff should await the conclusion of the environmental review process before
proceeding with any site selections for wells to be used in dry years.
4. Actively participate in the development of long term supply plans with the Bay Area
Water Supply and Conservation Agency (BAWSCA) and/or SCVWD.
5. Continue efforts identified in the Council approved WIRP guidelines:
a. Evaluate a range of demand side management options to reduce long term
water demands.
b. Evaluate feasibility of expanding recycled water.
c. Maintain emergency water conservation measures to be activities in case of
droughts.
III. Water Supply History
The water utility was established on May 9, 1896, two years after the City was incorporated.
Local water companies were purchased at that time with a $40,000 bond approved by the
voters of the 750‐person community. These private water companies operated one or more
shallow wells to serve the nearby residents. The city grew and the well system expanded until
nine (9) wells were in operation by 1932.
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In December 1937, the City signed a 20‐year contract with the City and County of San Francisco
for water deliveries from the newly constructed pipeline bringing Hetch Hetchy water from
Yosemite to the Bay Area. Water deliveries from San Francisco commenced in 1938 and well
production declined to less than half of the total citywide water demand.
A 1950 engineering report noted, "The capricious alternation of well waters and the [San
Francisco] water...has made satisfactory service to the average consumer practically
impossible." Groundwater production increased in the 1950s leading to lower groundwater
tables and increasing water quality concerns.
In 1962, a survey of water softening costs to City customers determined that the City should
purchase 100% of its water supply needs from the San Francisco. A 20‐year contract was signed
with San Francisco and the City’s wells were placed in a standby condition. Since 1962 (except
for some very short periods) the City’s entire potable water has come from San Francisco’s
Hetch Hetchy regional water system administered by the SFPUC.
In 1974, several wholesale customers joined Palo Alto and filed a lawsuit against the San
Francisco in protest of an increase in water rates that was higher for wholesale customers than
it was for direct retail customers. In 1984, settlement negotiations resulted in the “Settlement
Agreement and Master Water Sales Contract between the City and County of San Francisco and
Certain Suburban Purchasers in San Mateo, Santa Clara and Alameda Counties”. The 25‐year
agreement was approved in 1984. The 1984 agreement included the creation of a “Supply
Assurance” equal to 184 million gallons of water per day (MGD) for the benefit of the wholesale
customers.1 The agreement included a mechanism to allocate the 184 Supply Assurance
between the wholesale agencies. The City’s allocation, or Individual Supply Guarantee (ISG), is
17.07 MGD. Each agency’s ISG is perpetual in nature and survives termination or expiration of
the water supply contract with San Francisco.
1 The Supply Assurance is expressed as an annual average and does not constitute an obligation on the part of the
SFPUC to meet daily or hourly peak demands.
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In 2009, a new 25‐year Water Supply Agreement (WSA) was executed between San Francisco
and the City. The City’s historical water use and supply sources are illustrated in Figure 1.
Figure 1: Historic Water Use
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IV. Water Use Projections
The City of Palo Alto Utilities (CPAU) regularly prepares water supply and demand forecasts to
prepare financial forecasts, to meet regulatory requirements, or as part of ongoing regional
planning efforts. Like many water agencies in California, the City has experienced a significant
drop in water use since 2006, which is largely attributable to weather, water conservation, and
the recent economic recession.
Urban Water Management Plan (UWMP)
The UWMP is submitted to the Department of Water Resources every five years, and City
Council approved the most recent 2010 UWMP in June 2011 (Staff Report 1688)2. Water
demands forecast for the 2010 UWMP are shown in Figure 2 below. For comparison purposes,
the forecast from the 2005 UWMP is also included in Figure 2. The water use projection results
are revealing in that the City, along with most water agencies in California, did not anticipate
the dramatic drop in water demand from 2007 to 2009. Potable water demands from 2009 to
the present appear to have leveled off and have begun to trend upwards again, albeit slowly,
and it remains to be seen if water demands will follow the increase forecasted in the 2010
UWMP.
Figure 2: 2005 and 2010 UWMP Demand Forecast Projection Comparison
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2005 UWMP Forecast
Individual Supply Guarantee
Actual Forecast
2 Typically, UWMPs are due December 31 of years ending in 0 and 5. However, a six‐month extension
was granted to allow suppliers to comply with new legislation (Senate Bill X7‐7).
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Water Conservation Bill of 2009
The City is subject to ongoing changes in the regulatory and legislative environment, though
few are as explicit as SB X7‐7, the Water Conservation Bill of 2009. SB X7‐7 was enacted in
November 2009 and requires water suppliers to reduce the average per capita daily water
consumption in their service territories 20% by 2020. To monitor the progress towards
achieving the 20% by 2020 target, the bill also requires urban water retail providers to reduce
per capita water consumption 10% by 2015. Figure 3 illustrates the projected 2015 and 2020
state‐mandated compliance targets and provides preliminary information on the City’s need for
future action to meet SB7x‐7 requirements.
Figure 3: 20% by 2020 Compliance Forecast
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Figure 3 indicates that the City is on track to meet both the 2015 and 2020 state‐mandated
compliance targets.
Summary Water Resource Mix
The 2010 UWMP provided detailed information on baseline water resources through 2030.
SFPUC supplies were assumed to remain the primary potable supply for the foreseeable future,
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but were not forecasted to increase dramatically over the 20‐year planning horizon. Recycled
water consumption was projected to continue at current levels and no expansion was assumed
in the 2010 UWMP. Finally, demand side management and conservation program penetration
and savings were projected to increase dramatically from the 2005 UWMP. A representation
of the future water resource mix is provided in Figure 4.
Figure 4: Summary Water Resource Composition
V. Attributes Evaluated and Water Resource Alternatives Examined
Attributes Evaluated for each Water Resource Alternative
In this section, each potential water resource option is evaluated to allow each alternative to be
compared to each other. The purpose of this evaluation is to provide the best available
information on each water resource alternative and to identify data deficiencies that need to
be addressed. The attributes evaluated for each alternative are listed below:
1. Availability – The quantity, timing, peak flow or capacity, and any expected changes
over time.
2. Cost – The capital and O&M costs of the proposed action (including system upgrades,
project lifetime, energy costs, chemicals, technical innovation, customer costs, etc.), the
manner which the cost is incurred (pay‐as‐you‐go, debt finance, etc.).
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3. Water Quality – All options must meet water quality regulations, but options may differ
in their relative water qualities (i.e. taste, odor, color, hardness, mineral content, trace
levels of contaminants, etc.).
4. Long Term Reliability – What is the reliability of the source under different conditions?
What future conditions could affect water deliveries?
5. Emergency Robustness – Will the resource perform under various scenarios, including
an interruption of SFPUC supplies?
6. Environmental impacts – Are there anticipated environmental impacts and what level
of environmental review is required?
7. Sensitivity to Regulations – Is the resource vulnerable or does it have strength in view
of existing or impending federal, state, or local regulations?
Water Resource Alternatives Examined
The water resource alternatives evaluated in this report include:
1. Water from the SFPUC
2. Groundwater
3. Treated Water from the SCVWD
4. Recycled Water
5. Demand‐Side Management
6. Sale of the City’s Individual Supply Guarantee
Water resources that were evaluated in the 2003 WIRP process, but are not included in this
Preliminary Assessment, include:
1. Desalination – BAWSCA is evaluating several desalination alternatives as part of recent
long range supply studies. When this effort is complete, this alternative can be
evaluated.
2. Small scale irrigation wells – The City is focusing its efforts on the capital program to
improve the municipal well system to meet the dual purpose of providing emergency
and supplemental potable supplies. Currently, individuals may drill their own wells
without City review or permits, but are subject to rules and restrictions of the Santa
Clara Valley Water District (SCVWD) and must obtain a permit from the SCVWD. The City
does have the option of using small wells for irrigation of large landscapes, such as for
City parks. However, the cost to maintain and operate small wells and locate a site for
such facilities is problematic.
3. Treated Contaminated Groundwater – There are several entities in the City that treat
contaminated groundwater and discharge the groundwater to the storm drain system
and, to a lesser extent, the sanitary sewer system. The primary purpose of these
facilities is to remediate contaminated groundwater with finite operations. The Santa
Clara County Oregon Expressway dewatering pumps are the exception, and they
discharge significant amounts of nuisance groundwater to the storm drain system to
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keep the underpass dry. The City evaluated the capture and conveyance of the Oregon
Expressway groundwater for irrigation purposes and determined the effort would
require significant conveyance and storage infrastructure investments that are not cost
effective.
VI. Water from the SFPUC
The City currently purchases 100% of its potable supplies from the SFPUC under the 2009
Water Supply Agreement (WSA). The WSA is administered for the City by the Bay Area Water
Supply and Conservation Agency (BAWSCA). BAWSCA represents the interests of 24 cities and
water districts and two private utilities that purchase wholesale water from the San Francisco
regional water system. These entities provide water to 1.7 million people, businesses and
community organizations in Alameda, Santa Clara and San Mateo counties. The City of Palo
Alto is a member of BAWSCA and has a City Council appointed representative on the BAWSCA
Board of Directors.
Availability
The City’s right to water from the SFPUC system is embodied in the 2009 WSA. The City’s
Individual Supply Guarantee (ISG) of 17.07 MGD is a perpetual right, but the delivery of water is
subject to interruption for reason of water shortage, drought, or emergency.
Normal Year SFPUC Supplies
While the City’s ISG is 17.07 MGD, the City’s water needs are currently only about 11.5 MGD.
The WSA includes an interim water delivery limitation3 from the SFPUC system of 265 MGD
until its expiration in 2018. The City’s share of the interim limitation, or its Interim Supply
Allocation (ISA), is 14.70 MGD. Based on the water demand forecast from the 2010 UWMP,
there is no foreseeable need for additional supply beyond the City’s Individual Supply
Guarantee, or the ISA.
Dry Year SFPUC Supplies
SFPUC’s WSIP includes a goal of no greater than a 20% system‐wide supply reduction on the
SFPUC system during a drought. The 2009 WSA includes a water shortage allocation plan to
share water from the regional system between the SFPUC retail and wholesale customers
during a shortage of up to 20% (Tier I plan). The wholesale customers further divided the
wholesale allocation based on a formula adopted by all the wholesale customers (Tier II plan).
The detail of the allocation methodology is included in the City’s 2010 UWMP (Section 7 –
Water Shortage Contingency Plan) and was approved by City Council in February 2011 (Staff
Report 1308). The Tier II formula expires in 2018, unless extended by mutual agreement of the
BAWSCA members. Table 1 summarizes the effect of the water shortage allocation formula on
3 This limitation applies to all users of the San Francisco regional water supply system, the City of San Francisco and
all the BAWSCA member agencies.
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Palo Alto during a 20% SFPUC system‐wide reduction under low demand and high demand
scenarios.4
Table 1: City Of Palo Alto Water Shortage Allocation
Palo Alto Allocation
(low demand)
Palo Alto Allocation
(High demand)
(a) Baseline Demand (MGD) 11.63 13.33
(b) Drought Allocation (MGD) 8.94 10.011
(c) Reduction from Baseline Demand (b‐a)
(MGD) ‐2.69 ‐3.32
(d) Percentage reduction from Baseline
Demand (c/a) ‐23.12% ‐24.90%
The results in Table 1 indicate that the City will experience a water supply deficit of 23‐25% in
the event of a 20% system‐wide water shortage on the SFPUC system.
4 In general, changes in Palo Alto demand patterns track many of the other BAWSCA members. However, the
ultimate allocation to each BAWSCA agency depends on many factors, including the water use of each agency
relative to each other. For these reasons, staff can only provide an approximation of the potential cutback.
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Cost
The City purchases 100% of its potable water supply from the SFPUC, with the current cost
structure composed of a volumetric charge and a small fixed monthly meter charge. With the
$4.6 billion WSIP well underway, the cost of SFPUC water has increased sharply. Recent region‐
wide water consumption declines have intensified the problem since the cost is spread over
fewer sales units. The historic and projected cost of SFPUC water is illustrated in Figure 5.
Figure 5: SFPUC Actual and Projected Cost of Water
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While the SFPUC charges wholesale customers based on how much water is used, the costs of
the SFPUC system are almost entirely fixed costs – in other words, even if usage drops the cost
to operate the system (O&M, debt service, etc.) remains essentially the same5.
The SFPUC water cost projections in Figure 5 assume that the current rate structure remains in
place. However, the WSA provides some flexibility for the SFPUC to adjust rate structures and
the SFPUC recently signaled an interest in exploring alternative rate structures6 including
increasing the fixed charge component and allocating charges based on the ISG, rather than
actual water usage. The City’s share of the costs paid by the BAWSCA agencies (the “Wholesale
Revenue Requirement”), steadily decreased from 8% in 1998 to 7.2% in 2010 as the City’s
proportional share of water purchases dropped relative to the other BAWSCA agencies. In
5 The SFPUC system is largely gravity fed, so little variable O&M is required for water deliveries.
6 SFPUC Comments, July 2012 BAWSCA Board of Director’s meeting
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recent years the City’s share of the Wholesale Revenue Requirement has increased slightly,
probably as a result of several SFPUC customers making economic decisions to reduce SFPUC
purchases to minimum amounts in favor of other, less costly supplies. The City’s ISG of 17.07
MGD is approximately 9.23% of the total BAWSCA agencies’ Supply Assurance of 184 MGD. If
collection of the Wholesale Revenue Requirement were to be based on each agency’s ISG, the
City could pay 20‐30% more for water annually, with little apparent increase in benefit.
Water Quality
SFPUC supplies are extremely high quality. See Table 4 which lists key water quality parameters
for SFPUC water, SCVWD treated water and groundwater. Water provided by the SFPUC is a
mix of Hetch Hetchy water and water from the East Bay and Peninsula reservoirs. In an average
year, Hetch Hetchy water makes up 85% of the mix. Due to maintenance requirements, the
SFPUC typically will shut down the Hetch Hetchy supply for a period during the low demand
winter months and draw from the local reservoirs. It is not unusual to experience temporary
water quality changes due to these events, though the water still meets all drinking water
quality standards.
Since completion of the 2003 WIRP, there were two noteworthy operational changes on the
SFPUC system that related to water quality: In 2004, the SFPUC starting using chloramine
instead of chlorine as the primary drinking water disinfectant. In 2005, San Francisco began
adding fluoride to the water supply. Up until then, the City introduced fluoride at the SFPUC
turnouts, but ceased to do so once the SFPUC began providing fluoridation from a centralized
facility7.
Long Term Reliability
Recent demand projections do not forecast a normal year supply deficiency, given the
perpetual nature of the City’s Individual Supply Guarantee. However there is one situation
where the City’s Individual Supply Guarantee could be reduced. Under the terms of the 1962
contract between it and San Francisco, the City of Hayward’s contractual entitlement from the
SFPUC system essentially equals its water demand. In theory, since the collective Supply
Assurance of the wholesale customers cannot exceed 184 MGD, if Hayward’s water usage
increases substantially, the other wholesale agencies could experience a proportional ISG
reduction to ensure the 184 MGD limit is not exceeded. The most recent water use projection
shows this will not be an issue until at least 2030, and it will proceed gradually in any event.
SFPUC’s level of service goal is to meet dry year delivery needs while limiting rationing to a
maximum 20% system wide reduction in water service during extended droughts. However,
7 In 1957 the voters in Palo Alto adopted a measure that requires fluoride be added to the City’s water supply (Palo
Alto Municipal Code Section 12.24.010).
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recent events have called into question the SFPUC’s ability to maintain a level of service of no
greater than 20% reduction8.
BAWSCA and its member agencies are developing the Long Term Reliable Water Supply
Strategy to quantify when, where, and how much additional supply reliability and new water
supplies are needed throughout the BAWSCA agencies’ service area through 2035. The report
revealed that several agencies have normal year needs in excess of their ISG and all agencies
have varying dry year deficiencies. The report also identified several potential resource
alternatives to address these shortfalls, including desalinization, recycled water, and water
transfers.
The BAWSCA report (Section 3.2 of the Phase IIA report) includes a representation of potential
dry year cutbacks based on historic hydrologic conditions for the period from 1920 through
2002. The analysis used the SFPUC hydrologic system’s operational model to evaluate the
frequency and magnitude of droughts on the system over the 83 years with all WSIP related
projects complete. The results, as shown in Table 2, indicate there is little supply cutback risk
under low demand scenarios, but the risk rises as demands increase.
Table 2: Dry Year Shortfall under different demand scenarios
Demand Scenario
Number of Years of Projected Supply Cutbacks to the Wholesale
Customers Over 83‐year history
18% Average Wholesale
Customer Supply Cutback
(10% System‐wide shortfall)
29% Wholesale Customer
Supply Cutback
(20% System‐wide Shortfall)
Minimum Demand
Scenario (224 MGD) 0 0
Intermediate Demand
Scenario (252 MGD) 7 1
Maximum Demand
Scenario (265 MGD) 6 2
8 Environmental flow requirements at Crystal Springs and Calaveras Dam were greater than anticipated. A 2 MGD
water transfer between the Modesto Irrigation District and SFPUC was also rejected recently by the MID Board.
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Figure 6 provides a representation of the supply cutbacks that would have been experienced
under the maximum demand scenario using historic hydrologic data with all WSIP projects
complete. The results provide an illustration of the frequency and magnitude of droughts in
the past under the high demand scenario, and are helpful in framing future dry year risks. As
shown, over the 83 year hydrologic period, there would have been 8 years with water
shortages – 6 years with a 10% system‐wide reduction and 2 years with a 20% system‐wide
reduction.
Figure 6: Historic Water Shortages at Maximum Demand Level (265 MGD)
Clearly there is a potential deficiency in SFPUC supplies during dry years, though the overall
impact and frequency will depend on decisions related to dry year contingency plans and future
portfolio adjustments that could be made to remedy the supply deficiency. As identified in the
2010 UWMP, the City has developed a Water Shortage Contingency Plan for implementation
during a drought. The Water Shortage Contingency Plan identifies several stages of drought
response, depending on the degree of supply reduction required. Responses range from
informational outreach to severe water use restrictions and modified rate structures. The City
also has the option of pumping groundwater as supplemental supply in water shortage
situations. This option is discussed in more detail in the section on groundwater.
Emergency Robustness
Since the SFPUC is the City’s only potable supply source, the City is vulnerable to service
interruptions on the SFPUC system. One of the major drivers behind the WSIP was to address
reliability deficiencies, which under some circumstances could have resulted in an interruption
of SFPUC service for up to 60 days following a catastrophic event such as an earthquake. The
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WSIP level of service objective for seismic reliability is to deliver basic service9 within 24 hours
after a major earthquake. The performance objective is to provide delivery to at least 70 per
cent of the turnouts in each region, and full restoration to meet average day demand within 30
days after a major earthquake. Palo Alto may be better situated than other agencies in having
two distinct connection points to the SFPUC system: three SFPUC connections are served by the
Palo Alto Pipeline connection to Bay Division Pipelines 1 and 2, and two SFPUC connections are
served by Bay Division Pipelines 3 and 4. Figure 7 below is a map of the SFPUC regional water
system.
Figure 7: Map of SFPUC Regional Water System
The City is currently completing the Emergency Water Supply and Storage project. The primary
goal of the project is to maintain basic water service and fire‐flows in all pressure zones in the
City following a catastrophic interruption of SFPUC service. The project allows the City to
maintain water supply in the event that the SFPUC supplies are disrupted.
Environmental impacts
The SFPUC supply is the current baseline supply source for the City of Palo Alto. Subsequent
sections analyze several alternatives to the current and projected supply mix, and the resulting
potential environmental impacts. Increased water use within an agency’s ISG does not require
any action by an agency’s governing body, and therefore does not trigger any California
Environmental Quality Act (CEQA) review obligation.
Sensitivity to Regulations
For many water systems in California, the availability of water supplies depends on many
factors, including legislative and regulatory changes that may impact future supply conditions.
9 Basic service is defined as average winter month usage.
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The SFPUC system is no different, and has several future regulatory risks that could impact
water supply reliability and/or cost10:
1. Federal Energy Regulatory Commission (FERC) relicensing of the Don Pedro Project
a. State Water Resources Control Board (SWRCB) 401 Certification of FERC
relicense
b. Endangered Species Act (ESA) Section 7 consultation for FERC relicense
2. Central Valley Total Maximum Daily Load regulations
3. Bay‐ Delta proceedings (SWRCB, Legislative actions)
4. ESA Habitat Conservation Plans for SFPUC local watersheds
The SFPUC manages these risks, with support from BAWSCA and the wholesale customers.
VII. Groundwater
The Santa Clara Valley Water District (SCVWD) manages an integrated water resources system
that includes the management of groundwater, supply of potable water, flood protection and
stewardship of streams on behalf of Santa Clara County's 1.8 million residents. The SCVWD
manages ten (10) dams and surface water reservoirs, three (3) water treatment plants, nearly
400 acres of groundwater recharge ponds and more than 275 miles of streams. The SCVWD
provides wholesale water and groundwater management services to municipalities, private
water retailers, and individual property owners operating groundwater wells in Santa Clara
County.
Although the City currently purchases all of its potable water from the SFPUC system, the City
maintains close involvement with the SCVWD as it is an important water wholesaler and the
steward of groundwater resources in Santa Clara County. The city also partners with the
SCVWD on conservation activities. The community is represented on the SCVWD Board of
Directors by the District 7 Director. The City’s mayor also appoints a representative to
represent the City on the SCVWD Commission, an advisory body to the SCVWD Board of
Directors.
The SCVWD’s 2012 Water Supply and Infrastructure Master Plan describes how the SCVWD will
support future water supply needs and reliability. The adopted strategy identifies conservation,
increased recycled water use, indirect potable reuse, additional groundwater recharge ponds,
grey water, imported water reoperations, and dry year options as important components of the
plan.
The City of Palo Alto has several policies embodied in the Comprehensive Plan that relate to
groundwater and water supplies. The policies don’t provide a preference for the use of
10 Source: SFPUC’s 2010 UWMP
Page 18
groundwater, but indicate preservation of groundwater conditions is of critical importance to
the City. The relevant policies are listed below, with program elements, if applicable:
1. POLICY N‐51: Minimize exposure to geologic hazards, including slope stability,
subsidence, and expansive soils, and to seismic hazards including ground shaking, fault
rupture, liquefaction, and land sliding.
2. POLICY N‐18: Protect Palo Alto’s groundwater from the adverse impacts of urban uses.
a. PROGRAM N‐22: Work with the SCVWD to identify and map key Groundwater
recharge areas for use in land use planning and permitting and the protection of
groundwater resources.
3. POLICY N‐19: Secure a reliable, long‐term supply of water for Palo Alto.
Availability
As a city in Santa Clara County, Palo Alto has the ability to pump groundwater with the
understanding that SCVWD will appropriately manage the groundwater resources in the
county. Groundwater conditions throughout the county are generally very good11.
Groundwater elevations have generally recovered from overdraft conditions throughout the
basin since the 1987‐1992 drought, inelastic land subsidence has been curtailed, and
groundwater quality supports beneficial uses.
Background
The SCVWD last published a Groundwater Management Plan (GWMP) in 2001. Since that time,
SB 1938 and other legislation have amended the requirements for groundwater management
plans. The 2012 GWMP was prepared under existing groundwater management authority
granted by the District Act. The purpose of the 2012 GWMP is to characterize the SCVWD
groundwater activities in terms of basin management objectives, strategies, and outcome
measures.
General groundwater conditions in the area are detailed in the SCVWD 2012 GWMP. The City
of Palo Alto overlies the Santa Clara sub basin. The Santa Clara sub basin is divided into upper
and lower aquifers, which are separated by low permeability clays and silts. The SCVWD refers
to these as the shallow and principal aquifer, with the latter generally defined as 150 feet below
ground surface. The principal aquifer is the primary drinking water aquifer, and is the source
for the any increased reliance on groundwater to meet current or future demands. The upper,
or shallow, aquifer is of poorer quality and has limited uses beyond small to medium size
distributed irrigation systems. The SCVWD is responsible for managing the groundwater basin
to ensure there is adequate supply and overdraft conditions are minimized.
The SCVWD accomplishes this goal by maximizing conjunctive use, the coordinated
management of surface and groundwater supplies, to enhance supply reliability. Programs to
accomplish this goal include the managed recharge of imported and local supplies, in‐lieu
11 SCVWD 2012 Groundwater Management Plan
Page 19
groundwater recharge through the delivery of treated surface water12 and acquisition of
supplemental water supplies, and programs to protect, manage and sustain water resources.
Managed and in lieu recharge programs are in balance with withdrawals and the basin is not
currently in overdraft conditions. The groundwater conditions in the Santa Clara sub‐basin
vary, and groundwater pumping from different locations will have different effects depending
on location, elevation, recharge conditions, and pumping activity.
Emergency Water Supply and Storage Project
As part of the Emergency Water Supply and Storage project, the City has refurbished five older
wells, constructed two new wells, and is constructing another new well and a new 2.5 million
gallon storage reservoir and pump station. The primary goal of the project is to improve the
City’s emergency water supply capability. Together with the City’s existing water storage
system, the project will support a minimum of eight hours of normal water use at the maximum
day demand level and four hours of fire suppression at the design fire duration level and will be
capable of providing normal wintertime supply needs during extended shutdowns of the SFPUC
system. The proposed project would provide up to 11,000 gallons per minute (gpm) of reliable
well capacity and an additional 2.5 million gallons of water storage for emergency use. The
groundwater system may also be used to a limited extent during drought emergencies, but is
subject to the following mitigation measures, as stated in the Environmental Impact report (EIR)
completed for the project13:
1. An aquifer test shall be conducted following the City’s well construction and
rehabilitation efforts to verify the basin’s response to pumping; and
2. Emergency demand pumpage shall be limited to 1,500 acre‐feet (AF)14 in one year.
Following this level of pumpage, groundwater production shall be restricted until
groundwater levels recover to pre‐pumping levels.
All wells are currently permitted and designated by the California Department of Public Health
as “Standby” and, as such, can only be used for 5 consecutive days up to 15 days in a year15.
Once the project is complete, the wells may collectively supply up to 1,500 AF per year during a
drought, with restrictions on when the wells can resume pumping following that level of
groundwater extraction. It is important to note that the pumping restriction only applies to the
project as defined in the CEQA documents. This includes the 5 existing wells and 3 new wells.
Individual property owners can install their own wells and pump groundwater.
12 The SCVWD and the Santa Clara County SFPUC customers are partners in conjunctively managing the water
resources in the county. The SFPUC customers in the county have contracts with the SFPUC. The SCVWD has no
contractual relationship with the SFPUC.
13 Environmental Impact Report, Emergency Water Supply and Storage project, Mitigation Measure 3.5‐4(a) & 4(b)
14 1500 AF/Year is equal to 1.34 MGD, or approximately 12% of FY 2012 water consumption
15 California Code of Regulations, Title 22, Section 64414(c).
Page 20
The pumping restrictions for the well system are mitigation measures in the EIR prepared for
the Emergency Water Supply and Storage project. Any increase in the current restriction could
require new or supplemental environmental review. The SCVWD has indicated that the process
to increase the current limitation will require supporting information on the sustainable yield of
the groundwater basin in order to demonstrate increased pumping by the City will not have
significant impacts16.
The capacities of the City’s wells are listed in Table 3. As shown in the table, if all 8 wells were
used full time, they could produce 13.3 MGD, which is equivalent to almost 15,000 AF per year.
Table 3: Projected Well Capacities
Name Capacity (MGD)Status
Fernando 0.5544 Refurbished Well/Fully Operational
Hale 1.8432 Refurbished Well/Fully Operational
Matadero 0.864 Refurbished Well/Fully Operational
Peers 1.872 Refurbished Well/Fully Operational
Rinconada 4.464 Refurbished Well/Fully Operational
Eleanor Pardee 1.296 New Well/Fully Operational
Library 1.008 New Well/Fully Operational
El Camino Park 1.44 New Well/Under Construction
Total 13.3
During the drought in the late 1980’s, substantial pumping by pumpers in the county and
neighboring jurisdictions resulted in a dramatic drop in the groundwater levels in the area. It is
possible that this scenario could happen again during a drought of similar magnitude if
imported water supplies were reduced. The SCVWD adopted level of service goals as part of its
2012 Water Supply and Infrastructure Master Plan effort, including the development of water
supplies designed to meet at least 100% of average annual water demand identified in the
SCVWD 2010 UWMP during non‐drought years and at least 90 percent of average annual water
demand in drought years17. This goal is a countywide goal and includes Palo Alto demands.
Cost
The SCVWD levies a groundwater extraction fee, or “pump tax”, on each acre‐foot of water that
is pumped from the groundwater basin. The charge varies depending on a variety of factors,
including pumpage type (agriculture vs. municipal) and geographic location in the County.
Historically, the cost of groundwater (including the pump tax and the O&M cost of operating a
well) has been comparable to the cost of SFPUC supplies. However, due to the increasing cost
of SFPUC water due to the WSIP, the cost to pump groundwater is projected to be less than the
cost of SFPUC supplies (Figure 8). While the costs of SCVWD groundwater and treated water
16 In summer 2012, staff met with SCVWD representatives to discuss the current limitation and the process to
increase/remove the limitation.
17 SCVWD Board Agenda Item 4.2, June 12, 2012
Page 21
are also projected to rise over the next decade due to capital investment requirements, the
cost of SCVWD water is likely to be less than SFPUC supplies. The vertical lines above the
groundwater and treated water bars in Figure 8 represent the SCVWD high cost scenario, and
reveal that the cost differential between SFFPUC and SCVWD water remains significant even
under a SCVWD high cost scenario.
Figure 8: Projected SFPUC and SCVWD18 Water Rates
0
200
400
600
800
1000
1200
1400
1600
1800
2000
2200
2400
$/
A
c
r
e
‐Fo
o
t
Fiscal Year
SFPUC vs. SCVWD
SCVWD ‐ Groundwater Rate
SCVWD Treated Water rate
SFPUC Treated Water Rate
ForecastActual
Water Quality
The water quality of the groundwater is considered good, though historically the groundwater
in the area has had iron (Fe), manganese (Mn) and Total Dissolved Solids (TDS) levels that
exceed secondary19 drinking water quality standards.
All potable water scenarios must comply with water quality requirements. Staff currently
samples the wells based on the conditions outlined in the California Department of Public
Health (CDPH) permit(s). The City may be out of compliance with secondary standards on a
18 The SCVWD sets groundwater and treated water rates according to water pricing policies and SCVWD Board
direction. In general, treated water charges are slightly higher than groundwater charges to account for O&M
costs to pump groundwater. However, at times, the SCVWD may adjust rates to encourage use of groundwater
instead of treated water, or vice versa depending on the health of the underground water supplies.
19 Primary drinking water quality standards apply to contaminants that affect health while secondary standards
apply to those constituents that affect aesthetics, taste and odor.
Page 22
short term basis during emergencies, but for full‐time operation the City must be in compliance
with secondary standards or apply for a waiver20. The waiver requires justification and includes
a community survey to establish support for the provision of water that exceeds secondary
standards. The community survey must demonstrate a high degree of acceptance to justify the
waiver.
Key water quality parameters for groundwater, water from the SFPUC and treated water from
the SCVWD are compared in Table 4. All of these sources meet primary drinking water
standards. The table lists several secondary standards and a sampling of other parameters.
Table 4: Water Quality Parameters for Various Water Sources
Water Source Fe
(ppm)
Mn
(ppm)
TDS
(ppm)
Sodium
(ppm)
Hardness
(as CaCo3)
(ppm)
Turbidity
(NTU)
Drinking Water Quality Standard .300 .050 500 N/A N/A 5
SFPUC Water (1) ND ND 132 13.5 57 0.16
SCVWD Treated Water (2) ND ND 209 37 90 0.07
Groundwater (3) 0.25‐1.3 0.13‐0.31 440‐710 75‐170 ‐ 0.33‐7.7
(1) SFPUC values are average water quality values reported by the SFPUC in its 2011 Water Quality Report
(2) Average values from 2011 SCVWD Rinconada Water Treatment Plant Water Quality Data Summary
(3) Based on the City’s well water testing records
ND = non detect
Normal Year Groundwater Supplies
Several treatment and blending options for the wells were evaluated in 2000 in the “Long Term
Water Supply Study”:
1. Blend water with SFPUC water to meet water quality limits for manganese and iron. The
blended water will meet regulatory limits, but will have TDS levels 2‐3 times the current
level in the distribution system21.
2. Provide iron and manganese treatment at each well site. The water will likely not
exceed TDS limits, but it will be 5‐7 times the current levels in the distribution system.
3. Provide iron and manganese treatment at each well site and blend with SFPUC supplies
to reduce the well water TDS levels.
4. Provide iron, manganese and TDS treatment at each well site. The treated water at the
injection point will be comparable to SFPUC supplies.
The estimated present dollar cost of each option is provided in Table 5 for information
purposes. The treatment options focus on the costs to address the elevated iron, manganese
and TDS levels under several water quality scenarios.
20 Title 17 Code of Regulations, Chapter 64449.2
21 Upon completion of the Emergency Water Supply and Storage project, the El Camino Well water can be blended
with SFPUC water in the new 2.5 million gallon storage tank in El Camino Park in a similar manner to Option 1.
Page 23
Table 5: Well Treatment Alternative Preliminary Cost Analysis
Treatment Options22
1 (blend) 2 (treat for
Fe, Mn)
3 (treat for Fe,
Mn and blend)
4 (treat for Fe,
Mn and TDS)
Capital Cost23 (Total for 5 wells) $8.5‐10.8 M $8.5‐10.8 M $9.4 ‐ 11.8 M $37.4 ‐ 46.7 M
Well production
Acre feet per year 6300 12800 2500 12800
% of total Potable Demands 50% 100% 25% 100%
Water Quality24
TDS (500 ppm) 130‐300 440‐700 120 120
Manganese (<0.05 ppm) 0.04‐0.05 <0.05 <0.01 <0.05
Iron (<0.3 ppm) 0.08‐0.3 <0.3 0.05‐0.06 <0.3
The new and refurbished wells are being constructed with chlorine disinfection injection points
and the capability to accommodate fluoride and other needed chemical injection points. The
use of the wells on a regular basis will require a detailed operational plan and some or all of the
sites will need modifications to accommodate backup power, chemical storage, and any
equipment associated with the selected treatment option. Not all sites will have the space to
accommodate these additional requirements. These and other additional operating and capital
costs will need to be incorporated as part of a future detailed cost‐benefit analysis.
The various treatment options will generate waste streams with elevated levels of iron,
manganese, TDS, and chemical residuals used in the treatment process. It is unknown if this
can be discharged to the storm drain system. Options to address this issue include onsite
treatment facilities at each site or discharging the raw waste stream to the wastewater
collection system for delivery to the Palo Alto RWQCP25. In addition to these unknown costs,
there may be several challenges that may need to be addressed related to wastewater
constituent changes from the RWQCP.
Dry Year Groundwater Supplies
The City’s new well and reservoir at El Camino Park is currently being configured to blend with
SFPUC supplies so the El Camino Well can be relied upon to provide groundwater during a
drought up to the 1500 AFY limitation. As a result of blending, the water will meet all
secondary water quality standards, but will be of lesser quality when compared to SFPUC
supplies. To bring the water quality to a level comparable to SFPUC supplies, the City will need
to install Iron, Manganese and TDS filtration at the new El Camino well site.
22 Costs are only those costs incurred by Water Utility. Customer costs, including water softening or filtration
devices will be additional costs borne by individual customers
23 All costs were adjusted from the estimates in the 2000 study to provide a likely cost range in 2012 dollars.
24 Manganese and Iron have single consumer acceptance contaminant levels, while TDS is a consumer acceptance
contaminant level range (recommended = 500; short term= 1000 and upper limit = 1500)
25 Discharges to the wastewater collection system for treatment at the RWQCP have associated costs that are not
included in the preliminary cost estimates.
Page 24
Long Term Reliability
The wells are an important resource during a drought and could be an important resource to
serve a portion of the normal year potable needs in the City. With the current 1500 AFY dry
year groundwater extraction limitation, there is little risk any dry year pumping program could
result in significant impacts to the groundwater basin26.
Since SCVWD manages the groundwater in Santa Clara County, any plans to increase Palo Alto’s
groundwater pumping would need to be discussed with the SCVWD.
Emergency Robustness
The City’s wells are being maintained to provide emergency service during a catastrophic
interruption of SFPUC supplies. If the portfolio changes in the future such that groundwater
becomes part of the normal year supply, emergency preparedness will need to be evaluated
further to ensure the resource can perform under various scenarios. Such an increase could
result in the need for the SCVWD to construct recharge facilities to ensure that the county’s
groundwater supplies are properly maintained. If imported water supplies are required to be
delivered to the recharge facilities, those supplies need to be identified.
Environmental impacts
The use of the wells to meet dry year needs is currently permitted subject to a pumping
limitation of 1500 AF per year. A significant increase to this limitation could require
supplemental environmental review. Staff anticipates issues such as sustainable yield, dry year
availability, subsidence risk, saltwater intrusion, dewatering of local creeks and contaminated
plume migration, would be considered in such an environmental analysis.
Sensitivity to Regulations
An area of concern is future State and Federal water quality regulations for potable water.
Changes in regulations could make the groundwater supply less attractive and more expensive
due to additional treatment. This becomes less of an issue depending on the level of treatment
that is chosen.
26 The 1500 AFY limitation is a CEQA derived mitigation measure that has undergone the public review process.
Page 25
VIII. SCVWD Treated Water
Besides being the manager of groundwater in Santa Clara County, the SCVWD also produces
and delivers treated drinking water to water retail agencies in the county. Long‐term plans of
the SCVWD include extending the treated water pipeline from its current terminus at Foothill
Expressway and Miramonte Road to a Palo Alto connection point at Foothills Expressway and
Arastradero Road (a distance of about 4.5 miles). The SCVWD calls this extension the “West
Pipeline Extension”. However, the project would only be constructed if the City requested
water supply from the SCVWD and signed a treated water contract.
Background
In 1999, the City sent a letter to the SCVWD advising it that information was needed to analyze
the City’s option to connect to the SCVWD treated water West Pipeline. The SCVWD responded
with an estimated cost for the extension of the West Pipeline that would have to be fully borne
by Palo Alto. In February 2002, Palo Alto and four other county retailers requested that the
SCVWD conduct a feasibility study of a West Pipeline extension from both a supply perspective
and the additional reliability of having an additional interconnection with the SFPUC system.
The SCVWD prepared a report on extending the West Pipeline, entitled: “Santa Clara Valley
Water District’s West Pipeline Extension Conceptual Evaluation Final Report”27. The report
evaluated an extension of the existing SCVWD West Pipeline to enable an interconnection of
the Palo Alto and SCVWD systems at Page Mill turnout28. A map of the potential project is
provided in Figure 9.
27 The City of Palo Alto participated in the preparation of the 2012 Water Supply and Infrastructure Master Plan
(WSIMP). As part of that process, staff requested the SCVWD include the West Pipeline extension for project
consideration. The SCVWD noted in the Final 2012 WSIMP that the project is not recommended in the WSIMP
because it does not contribute to long‐term supply reliability. However, the SCVWD stated that it would be
considered during a planned Infrastructure Reliability Master Plan.
28 The SFPUC and the SCVWD have an emergency interconnection near Milpitas that could theoretically be used to
wheel water to Palo Alto. Staff does not anticipate it will be feasible to wheel normal year supplies via the intertie,
but the use of the intertie during dry years may be possible. However, in general the SCVWD system is more dry
year sensitive than the SFPUC system, so it is unclear whether supplies would be available to be wheeled to Palo
Alto via this mechanism.
Page 26
Figure 9: West Pipeline Extension Map
Availability
If the City requested that the SCVWD extend the West Pipeline to serve the City, the terms of
the treated water contract would determine the availability and amount of water that would be
delivered during normal years. The SCVWD has a diverse water supply portfolio, including State
Water Project, Central Valley Project, and local reservoirs. SCVWD’s 2010 UWMP and its 2012
WSIMP indicated the SCVWD anticipates having adequate supplies to meet future needs until
2030 when minor deficits begin to materialize. However, those projections do not assume any
treated water deliveries to Palo Alto. In addition, there is no guarantee that the water will be
available during dry years.
Cost
SCVWD’s West Pipeline Extension Report provided detailed cost estimates for several pipeline
configurations, which are summarized in Table 6. Both scenarios require a new parallel pipeline
from Rinconada Water Treatment plant to the current terminus of the West Pipeline at
Miramonte Road. From there, a new pipeline would be constructed to Page Mill Road. The
cost differential between the two scenarios is largely attributed to different pipe sizing
requirements and an intertie pump station.
Page 27
Table 6: SCVWD Treated Water Connection Summary Costs29
Alternative Assumptions Total Cost
of
Alternative
($million)
Cost to
SFPUC
($million)
Cost to
New
Retailers
($million)
Rate
Increase
to SCVWD
Retailers
($/AF)
Parallel
and
Extension
Existing treated water
contractors and new retailers
share cost of parallel pipe
New retailers pay for extension
94‐114 N/A Palo Alto:
44‐67
Purissima
Hills: 5‐9
$5‐8
Parallel,
Extension
and
Intertie
Existing treated water
contractors and new retailers
share cost of parallel pipe
SFPUC pays for half of
incremental cost of intertie
Existing and new retailers share
cost of extension and half of
incremental cost of intertie
127‐154 18‐22 Palo Alto:
23‐41
Purissima
Hills: 4‐10
Stanford
University:
4‐8
Pump Tax:
11‐14
Treated
Water: 15‐
22
The report concluded that the City and neighboring jurisdictions must pay for the costs of
constructing the extension via a “take or pay” contract, which is a common payment
mechanism for all agencies in the county that purchase SCVWD treated water. The amount of
the take or pay contract is determined by the amortized construction costs divided by the
annual treated water rate. For example, if Palo Alto’s obligation for a West Pipeline extension
was $30 million with an annual cost of $2 million (using an interest rate of 3%/year for a 20‐
year financing period), and the treated water rate was $634.60 per AF30, then Palo Alto would
be required to purchase about 3,150 AF/year, or about 25% of the City’s water usage in FY
2012.
During the term of the contract, the City would have limited ability to adjust its annual water
purchase from the SCVWD. There are several agencies in Santa Clara County that purchase
both SCVWD and SFPUC treated water, and they are subject to minimum “take or pay” contract
provisions by both providers. The City would receive similar treatment. The cost estimates in
Table 6 do not account for any distribution system improvements that may be required to
configure Palo Alto’s distribution system to receive SCVWD treated water.
Recently, the City conducted an evaluation of property tax collected by SCVWD from Palo Alto
property owners. It is not uncommon for water districts to rely wholly, or in part, on property
related taxes to build water systems or for surplus capacity for future users. The SCVWD has
historically relied on taxes to some degree to purchase imported water and fund local
29 Cost of additional supply is not included in project cost. Costs have been escalated 3‐5% from 2003 dollars to
provide a representation of potential costs ranges.
30 This is SCVWD’s treated water rate for FY 2013
Page 28
groundwater and treated water programs, and continues to do so. The results of the property
tax evaluation revealed Palo Alto taxpayers have contributed to the development of the SCVWD
water supply, distribution and treatment system, and will likely continue to do so in the future.
This information could be helpful in determining an equitable sharing of the capital costs of an
extension to serve areas of the county that have historically supported the SCVWD system.
Water Quality
See Table 4 in the groundwater section for a comparison of certain water quality parameters of
SCVWD’s treated water, SFPUC water, and groundwater.
Carollo Engineers evaluated the SCVWD treated water line in the Long Term Supply Study and
provided information on the issues of blending SCVWD supplies with SFPUC supplies. In
general, SFPUC supplies are of superior quality to SCVWD supplies, but there were several
specific issues that were identified in the previous study. If there is interest in moving forward
with an interconnection with the SCVWD system, additional analysis will need to be performed
to determine if the previous issues still remain, and what additional issues have arisen. On the
positive side, the SCVWD’s recent decision to include fluoridation at their treatment plants
removes the need to provide fluoridation at the interconnection points to ensure the water
supply complies with the municipal code. In a similar manner, the SFPUC has completed the
transition to chloramine from chlorine for residual disinfection. This removes some water
quality related issues associated with blending treated water from different sources that use
different disinfectants. However, there may be other issues related to water quality that could
require the two water supplies to be isolated in the distribution system. This would result in
water from difference sources being provided to customers depending on their location in the
distribution system.
Long Term Reliability
It is likely the SCVWD has little surplus imported water to allocate to Palo Alto, so the details of
a potential supply arrangement will need to be evaluated further. During the drought in the
late 1980’s, SCVWD supplies from both the state and federal sources were significantly
reduced. It is not clear what level of drought protection would be provided, though the recent
level of service commitment by the SCVWD indicates that there would be no greater than 10%
reduction in supplies during dry years.
Emergency Robustness
In 2003, the SCVWD initiated the Water Utility Infrastructure Reliability Project to determine
the current reliability of its water supply infrastructure (pipes, pump stations, treatment plants)
and to appropriately balance level of service with cost. The project measured the baseline
performance of critical SCVWD facilities in emergency events and identified system
vulnerabilities. The study concluded that the SCVWD water supply system could suffer up to a
60‐day outage if a major event, such as a 7.9 magnitude earthquake on the San Andreas Fault,
Page 29
were to occur. Less severe hazards, such as other earthquakes, flooding and regional power
outages had less of an impact on the SCVWD, with outage times ranging from one to 45 days.
The level of service goal identified for the Infrastructure Reliability Project was “Potable water
service at average winter flow rates available to a minimum of one turnout per retailer within
seven days, with periodic one day interruptions for repairs.” In order to meet this level of
service goal, the project identified a recommended portfolio to mitigate the risks. The SCVWD
has been implementing the recommended portfolio. The project is expected to reduce the
post‐earthquake outage period from 45‐60 days to 7‐14 days.
In 2007, the SCVWD created a stockpile of emergency pipeline repair materials including large
diameter spare pipe, internal pipeline joint seals, valves, and appurtenances. The stockpile
marks a significant increase in reliability of the SCVWD water supply system, as it helps to
reduce outage time following a large earthquake from approximately 60 to 30 days. The
SCVWD still needs to complete several other emergency planning projects to meet the goal of
reducing outage time to 30 days. These include developing a post‐disaster recovery plan,
developing mutual aid agreements or expanding participation in the California Water/
Wastewater Agency Response Network , setting up contractor, welder, and equipment rental
company retainer agreements, and setting up post‐earthquake pipeline inspection teams. The
addition of groundwater wells and line valves to the SCVWD system will further reduce outage
time following a large earthquake from 30 days to 14 days. The wells will allow the SCVWD to
convey supplies from the groundwater basin to the treated water pipelines following a hazard
event to meet the project’s level of service goal. The line valves will allow the SCVWD to isolate
damaged portions of pipelines.
If the West Pipeline was extended to provide potable water service to Palo Alto, the City would
have one connection to the SCVWD system31, compared to 5 connections to the SFPUC system.
It is unclear what level of reliability would be provided in the event of catastrophic event. The
SFPUC level of service goal following an earthquake is to provide for average wintertime
demands with delivery to 70% of the turnouts within 24 hours following a major earthquake.
The SCVWD level of service goal provides for service resumption to one turnout within 7 days of
a similar event, though the location of a Palo Alto interconnection at the end of the treated
water line may be a weak point, so it is unclear if there will be adequate supplies or system
pressures to provide meaningful service. In addition, the SCVWD plans on extracting
groundwater for raw water delivery to the treatment plants and on to the retailers during an
emergency. The Emergency Water Supply and Storage project will serve this purpose for Palo
Alto.
31 There may be additional connection options to a new SCVWD treated water pipeline, such as a new extension to
the existing Arastradero SFPUC turnout. However, the cost of additional connections was not included in the initial
cost estimate and would likely be borne by the City. Additional connections may allow increased use of and more
efficient distribution of SCVWD treated water, though they may not provide any additional reliability assurances.
Page 30
Environmental Impacts
A West Pipeline extension will require CEQA review. The SCVWD would be the lead agency for
the CEQA process.
Sensitivity to Regulations
The SCVWD imports water from both the State and Federal water projects, and is vulnerable to
actions that impact those sources. Since publication of the 2003 WIRP, federal and state water
deliveries have been reduced on several occasions due to Delta related issues. The Bay Delta
Conservation Plan is currently underway to address the co‐equal goals of water supply
reliability and environmental sustainability. The most likely water conveyance solution will be a
tunnel underneath the Delta from an intake on the Sacramento River to the South Delta
Diversion/Pumping facilities. Such a facility will take decades to build and the costs will likely be
borne by State and Federal water contractors, including the SCVWD.
Page 31
IX. Recycled Water
The City of Palo Alto operates the Regional Water Quality Control Plant (RWQCP), a wastewater
treatment plant, for the East Palo Alto Sanitary District, Los Altos, Los Altos Hills, Mountain
View, Palo Alto, and Stanford University. Approximately 220,000 people live in the RWQCP
service area. Of the total plant flow, about 60 per cent is estimated to come from residences,
10 per cent from industries, and 30 per cent from commercial businesses and institutions.
In 1992, the City and the other RWQCP partners completed a Water Reclamation Master Plan
(Master Plan). The Master Plan identified a three stage implementation for recycled water in in
the RWQCP service area.
In 1995, City Council certified the Final Program Environmental Impact Report (PEIR) for the
Master Plan projects. At the same time, Council decided not to pursue any of the
recommended expansion stages of a water recycling system as the cost could not be justified.
Council adopted a water recycling policy, which included continuation of the existing programs
and monitoring of conditions that would trigger an evaluation of the Master Plan. The Water
Recycling Policy described five conditions that would trigger evaluation of the Master Plan
projects:
1) Changes in the RWQCP discharge requirements
2) Increased mass loading to the RWQCP
3) Requests from partner agencies or other local agencies
4) Availability of federal or other funds
5) Water supply issues:
a. Water shortages
b. Legislative or Regulatory Initiatives
c. Advanced treatment for potable reuse.
Since the Master Plan, the City prepared a recycled water survey in 2006 and a Facility Plan in
2009 for a project to deliver recycled water to the Stanford Research Park. The Facility Plan had
four goals:
1) Define recycled water alternatives and identify a recommended project;
2) Develop a realistic funding strategy
3) Develop an implementation strategy ; and
4) Provide a basis for any future state and federal grant requests for the Project.
Since completion of the Facility Plan, the City initiated the environmental review process for the
project and is currently working on an Environmental Impact Report (EIR) for the project. The
City is also focusing on outside funding sources to improve the project economics.
The Facility Plan provided a comprehensive overview of the proposed recycled water project to
serve the Stanford Research Park. The project would connect to the recently completed
Page 32
recycled water transmission line serving the Mountain View area and extend through the City
to serve the target area. A schematic of the proposed project including water demands and
pipe sizes is provided in Figure 10.
Figure 10: Proposed Recycled Water Project
Availability
The average dry weather flow capacity of the RWQCP is 38 MGD. The average treated
wastewater discharge to the San Francisco Bay is approximately 22 MGD. In theory, all of this
could be captured for reuse. Several RWQCP partners, including Palo Alto, have a contractual
entitlement to the treated wastewater in proportion to the amount of wastewater that is sent
to the RWQCP32. Palo Alto’s FY 2011 flow share to the plant was approximately 39.2%, or 8.624
32 Personal communication with James Allen, RWQCP Plant Manager, November 2012
Page 33
MGD. However, operational constraints and plant configuration limit the recycled water
production capability from the RWQCP.
The RWQCP collaborates with the partners to ensure needed capital improvements for future
recycled water expansion goals are incorporated into long range plans. Considering the
RWQCP’s primary role to provide wastewater treatment services for the partners and to ensure
the RWQCP meets all associated regulatory and permit limitations, the necessary
improvements to accommodate a substantial increase in recycled water deliveries are not a
priority for the foreseeable future. In the meantime, the RWQCP can deliver up to 4.5 MGD of
recycled water via coagulation and filtration through a multi‐layered filter and disinfection
process. This additionally treated effluent meets California Department of Health Services Title
22 requirements for “unrestricted reuse”. The new ultraviolet (UV) disinfection banks can add
6 MGD of recycled water production (8 MGD with an extra bank). The RWQCP plans to use UV
as backup to the filtration/chlorination recycled water treatment train. Future plans include
consolidating the systems into a 10.5 MGD recycled water facility, but this would require some
modifications in plant piping and storage tanks to get bottlenecks out of the system.
In constructing the project to extend the recycled water distribution system to serve the City of
Mountain View, the CPAU Water Fund paid $1 million and committed to pay an additional $1
million connection fee in the event the project to serve the Stanford Research Park was built.
By virtue of this arrangement, the CPAU Water Fund has secured capacity on the pipeline for
future use. The RWQCP cannot currently meet projected recycled water demands under peak
conditions, and additional pumping capacity and possibly storage is needed to accommodate all
project users. Palo Alto’s recycled water project capital costs include the cost of retrofitting the
RWQCP pump station to accommodate incremental recycled water deliveries to serve the
Stanford Research Park.
Page 34
The RWQCP has had a robust recycled water program for many years, including a substantial
amount for RWQCP onsite needs and irrigation at Greer Park, the Duck Pond and the Palo Alto
Municipal Golf Course. As shown in Figure 11, the RWWCP uses about 0.5 MGD annually
(about 560 AFY) for irrigation around the plant as well as some cleaning and treatment
processes. Greer Park and the Duck Pond have each used about 0.04 MGD (45 AFY) on average
over the past five years while the Palo Alto Municipal Golf Course has used about 0.2 MGD (230
AFY) on average over the past five years.
The 2009 Facility Plan identified about 0.8 MGD of new recycled water usage for the project to
expand the recycled water distribution system. The project would primarily serve the Stanford
Research Park area and the bulk (90%) of the recycled water would be used for irrigation
purposes.
Figure 11: Palo Alto Existing Recycled Water Uses for FY 2004‐FY 2012
Page 35
Cost
The Facility Plan included a detailed cost plan to build the project (Table 7). The gross project
cost is approximately $33 million, though this does not include potential outside funding
sources that could lower the project cost.
Table 7: Recycled Water Gross Cost Estimate 1,2
The cost estimates in Table 7 were developed for 2009 Facility Plan using March 2008 dollars
and will need to be updated to reflect current capital and O&M costs. Based on the 2008 data,
the recycled water cost is approximately $2,700/AF, compared to an SFPUC cost of $1260/AF
(2013) to $2240/AF (2020). However, these cost estimates do not reflect several grant and low
interest funding programs that the City has been pursuing that will help lower the unit cost of
the recycled water to a more competitive level with SFPUC costs. These funding options are
listed below:
1. Title 16 ‐ The Bureau of Reclamation's water reclamation and reuse program is
authorized by the Reclamation Wastewater and Groundwater Study and Facilities Act of
1992 (Title XVI of Public Law 102‐575). The City of Palo Alto is a member of the Bay Area
Recycled Water Coalition, a group of regional recycled water projects that collaborate to
pursue federal funding for recycled water projects. In order to receive federal funding,
all projects must receive federal authorization. The City is currently seeking
authorization in the House of Representatives for a federal award of $8.25 million (H.R.
3910). Obtaining authorization is a first step and subsequent steps include submittal of
Page 36
appropriation requests until the full authorized amount is received. While authorization
provides a degree of certainty on a grant award, receipt of the full grant amount will
depend on annual appropriations and the federal political process.
2. Proposition 84 through IRWMP – The City is pursuing Proposition 84 grant funds
through the Bay Area Integrated Regional Water Management Plan. The BAIRWMP
project list was recently updated and the City will have the option to submit funding
requests during future funding rounds.
3. State Revolving Fund Low Interest Loan – The City can apply for low interest
construction loans through the State Water Resources Control Board State Revolving
Fund (SRF) program. The program provides 20 year loans with an interest rate equal to
half of the most recent General Obligation bond interest rate. The most recent SRF
interest rate is 1.7%, though the historical rate is typically in the 2‐2.5% range. SRF
loans have several attractive features, including a payment plan that commences 1 year
after construction and the avoidance of bond issuance costs.
The Title 16 and SRF loan programs represent the best State and Federal funding opportunities
for the project at this time. The City’s recycled water project is on the SRF project list, and staff
does not anticipate that obtaining an SRF loan will be problematic. However, obtaining Title 16
authorization for the project will be critical to making the project economically viable. An SRF
loan and an $8.25 million federal grant would improve project economics such that recycled
water would become competitive with SFPUC potable water within 4‐6 years.
The City’s recycled water project was identified in BAWSCA’s Long‐term Regional Water Supply
Strategy as a project with near term development potential to meet future water supply needs.
Inclusion in the BAWSCA report does not change the project, but it does position the project for
innovative funding opportunities with another BAWSCA agency in exchange for some
equivalent benefit. Such a partnership could be combined with State and Federal funding
sources to further improve project economics.
Water Quality
The recycled water from the RWQCP meets Title 22 requirements for unrestricted reuse. The
main purpose of the Palo Alto recycled water project is to offset the use of high quality
imported SFPUC water for irrigation and cooling purposes. A major challenge for the project is
acceptance by the landscape community of using recycled water for irrigation purposes.
Certain landscapes are particularly vulnerable to the higher salinity that is present in recycled
water, especially those areas with poor drainage and clay soils.
The RWQCP and the plant partners are undertaking efforts to address the elevated salinity
levels in the recycled water by establishing the Salinity Reduction Policy and evaluating the
wastewater collection system for areas where elevated salinity levels indicate Inflow and
Infiltration may be an issue. For example, the City of Mountain View is currently spending $3‐4
Page 37
million to line a sewer trunk line that has indications of saline water intrusion. This large
project may yield a significant salinity reduction when complete in February 2013.
Long Term Reliability
Recycled water is one of the most reliable new water supply sources. As previously mentioned,
CPAU has paid for a future connection to the pipeline that extends from the RWQCP to serve
Mountain View, which has a maximum capacity of 21 MGD. With the addition of the UV banks,
the recycled water production train could provide up to 10.5 MGD of recycled water. As it is
local, it is more reliable than imported supplies, which rely on lengthy networks of pipes, pumps
and storage facilities. In droughts or other water shortage situations, landscape water use is
normally targeted for the largest reductions, but recycled water use would not be subject to
such reductions.
Additional recycled water use will increase the City’s allocations of SFPUC water in drought
times. Since the drought allocation formula is based on both a seasonal component and overall
water use, increased use of recycled water would provide a double benefit since it lowers
potable water use and also reduces the City’s potable usage during the peak irrigation season.
While it is difficult to assess future drought allocations since much depends on the actions of
other agencies, staff estimates the Stanford Research Park recycled water project could reduce
the dry year cutback by 10‐20%.
Emergency Robustness
Recycled water will be used for irrigation purposes and, to a lesser extent, cooling. During a
catastrophic emergency, CPAU will focus on operation of the emergency wells and the potable
distribution system to ensure potable requirements and fire flows are maintained. The RWQCP
will also focus its efforts on returning the RWQCP to normal operations. Recycled water does
not provide additional emergency preparedness improvements over the current situation.
Environmental Impacts
The City has been preparing the requisite National Environmental Policy Act (NEPA) and CEQA
documents for the project. The environmental review process has taken longer than
anticipated, largely due to additional study of the use of recycled water on plants in areas of
poor drainage and clay soils.
Sensitivity to Regulations
The recycled water supply is sensitive to regulations, but these can have both positive and
negative impacts due to the unique nature of the recycled water supply. The RWQCP is subject
to numerous regulatory requirements related to treated wastewater discharges to San
Francisco Bay. The use of recycled water is recognized as one method to reduce discharges to
the Bay and assists the RWQCP in complying with these requirements. For example, in March
2012, the Regional Water Board issued a Water Code Section 13267 Technical Report Order to
Page 38
Bay Area wastewater dischargers, including the RWQCP, requiring submittal of information on
nutrients in wastewater discharges (nitrogen and phosphorus). This information will be
compiled over the next few years and will likely result in the development of future water
quality objectives for the San Francisco Bay estuary. An increase in recycled water use would
decrease the total nitrogen and phosphorus discharge to the Bay. As the regulatory
environment for wastewater treatment plants becomes stricter, recycled water will become an
increasingly useful tool to assist wastewater treatment plants in complying with these new
regulations.
In February 2009, the State Water Resources Control Board adopted Resolution No. 2009‐0011,
which established a statewide Recycled Water Policy. This policy encourages increased use of
recycled water and local storm water. It also requires local water and wastewater entities,
together with local salt/nutrient contributing stakeholders to develop a Salt and Nutrient
Management Plan for each groundwater basin in California. The SCVWD is the lead agency for
this effort in Santa Clara County. Together with the benchmarks in the SCVWD 2012 GWMP,
recycled water impacts on the groundwater basin will likely be monitored and subject to
regulation in the event there are observed changes.
X. Demand‐Side Management
Demand‐side management measures and Best Management Practices (BMPs) are measures
that can be implemented to conserve water. The BMPs are included in the California Urban
Water Conservation Council (CUWCC) Memorandum of Understanding (MOU). Water agencies
that became signatories to the MOU pledged to implement the BMPs and to report progress
biannually to CUWCC.
Since becoming a signatory to the MOU in 1991, the City has saved an estimated 4,135 AF of
water through conservation program implementation. The 2010 UWMP contains the City’s
reports to the CUWCC, including compliance reports on the BMPs. The 2010 UWMP included
an increased conservation program commitment, in large part driven by the requirements of SB
X7‐7.
Availability
BAWSCA has assisted its members in assessing the potential for water efficiency measures. In
October 2008, as part of the adoption of the Water System Improvement Program (WSIP)
Program Environmental Impact Report, BAWSCA coordinated the completion of the Water
Conservation Implementation Plan, which provided a comprehensive analysis of cost effective
conservation measures to identify additional programs that could assist the BAWSCA agencies
in meeting future purchase limitations. Results from the Water Conservation Implementation
Plan were also used to prepare the City’s 2010 UWMP. Figure 12 shows the water conservation
goals Council adopted when it approved the 2010 UWMP. Figure 12 also compares the
Page 39
conservation program commitment in the 2005 UWMP to the new commitments in the 2010
UWMP.
Figure 12: Water Conservation Savings Goals
0
500
1000
1500
2000
2500
2005 2010 2015 2020 2025 2030
Cu
m
u
l
a
t
i
v
e
W
a
t
e
r
S
a
v
i
n
g
s
(
A
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r
e
-
F
e
e
t
)
Fiscal Year
Actual Savings 2005-2010
Projected Savings from 2005 UWMP
Projected Savings from 2010 UWMP
13% of Water
Demand
4% of Water
Demand
The annual report to City Council on efficiency goals and achievements includes a summary for
water demand side management goals and achievements as illustrated in Table 8.
Table 8: Water Savings vs. Goals
Note that the savings goal increased threefold starting in FY 2011. The increase is primarily a
result of legislative requirements (SB 7x‐7) that were captured in the 2010 UWMP. This
aggressive goal is consistent with the City’s longstanding policy of providing cost effective
conservation programs to the community. Staff will monitor conservation program
effectiveness and make necessary adjustments if it appears the current program is not meeting
established targets.
Page 40
Cost
It is the goal of the City to look for opportunities, innovative technologies, and cost effective
programs that best utilize the water conservation budget. In FY 2011, the City dramatically
increased conservation program savings goals to meet the requirements of SB7x‐7. The 2010
UWMP contains a detailed analysis of the current suite of conservation measures that are
offered by the City. For each program, the benefit/cost ratio from the Total Resource Cost
(TRC) perspective is shown. The TRC cost‐effectiveness test compares the total cost of
implementing a measure, regardless of who pays. The costs include the cost of the device, any
installation costs, and the implementation costs of the program (advertising, tracking,
performance monitoring, rebate processing, etc.). The benefits include the avoided costs of
water purchases. The Water Utility assesses each measure in terms of financial impact to the
utility, which includes rebate costs as well as any other administrative costs borne by the Water
Utility. The water savings summary through 2030 is provided in Table 9, including cost to the
utility.
Table 9: Conservation Program Costs33
2015 2020 2025 2030
Total Savings (Acre‐feet) 672 560 168 448
Total Wastewater Savings (Acre‐feet) 403 314 67 157
Total Outdoor Savings (Acre‐feet) 269 246 101 291
Utility Implementation Cost ($2010) $754,058 $370,843 $364,762 $387,604
Cost/Acre‐feet $1,122 $662 $2,171 $865
Table 9 illustrates that the aggregate conservation program is cost effective when compared to
SFPUC supply alternatives.
As the cost of SFPUC water increases, many conservation programs become more cost
effective, though the Water Utility adjusts conservation programs depending on several factors,
including program penetration, community preferences and the TRC. Despite the very
aggressive targets in the 2010 UWMP, it may be possible to further increase conservation
program utilization to achieve additional savings.
Water Quality
Demand side measures do not present any water quality issues.
33 The large increase in cost per acre foot in 2025 reflects regular captured savings less a drop off of savings from
those measures initiated in the 2012‐2020 time frame that begin to reach maturity. Water agencies offer rebates
to make it more attractive for customers to install more efficient, and potentially costlier, measures. At some
point in the future the measure reaches the end of its useful life and must be replaced. For some measures, the
models assume the consumer will only have the choice of the more efficient model in the future and therefore no
rebate is needed anymore. Absent a rebate, the Water Utility does not account for the savings anymore.
Page 41
Long Term Reliability
Staff forecasts and tracks DSM program effectiveness, but the ultimate effectiveness for
different programs varies substantially depending on many factors, including individual
behavioral patterns. Much research has gone into evaluating the reliability of DSM, and some
of that research could be useful to the City in future efforts to plan and evaluate program
effectiveness. Due to the large differential between water demand and the City’s Individual
Supply Guarantee, there is no pressing need to strictly monitor DSM program effectiveness like
there may be for an agency that is at risk of exceeding its Individual Supply Guarantee
Water efficiency during a drought is a more complicated issue. One issue is the concept of
“demand hardening”, which is the assumed loss of demand elasticity during a drought that
results from water conservation programs implemented before the drought. In other words,
the community may have little flexibility to reduce demand further if conservation programs
have been truly effective. At the same time, there are certain DSM measures that are not
suitable during normal years that can be implemented during dry years and achieve desired
savings (i.e ‐ steep rate increases, irrigation restrictions).
Emergency Robustness
The 2010 UWMP contains a summary of demand side options that can be implemented under
various scenarios (Section 7 – Water Shortage Contingency Plan). During a catastrophic
interruption of SFPUC supplies, the City will immediately initiate emergency supply options to
meet potable demands and fireflow requirements. At the same time, the City will begin
informational outreach programs to inform the community that emergency conditions are in
effect and water consumption behavioral changes are required (i.e no irrigation).
For dry year scenarios, the City will implement informational outreach programs, incentive
based demand‐side management programs, and water audits. In addition, rate schedules may
be modified, as appropriate, to reflect the water shortage conditions. Due to the
SFPUC/BAWSCA drought allocation formula, conservation programs provide a benefit in
reducing dry year cutback requirements. Conservation programs that specifically target
irrigation demands will provide an additional benefit because of the seasonal component of the
drought allocation formula.
Environmental Impacts
For the most part, demand side measures do not present any environmental issues. Measures
that specifically target landscape conversions or efficiency changes have occasionally been the
subject of concern by tree advocacy groups who are concerned about impacts on trees due to
decreased landscape watering. The City includes information on proper tree maintenance for
those customers converting to drought resistant landscapes.
Page 42
Sensitivity to Regulations
Demand side measures are not limited by any regulations. However, additional requirements
to implement measures may be proposed, or compliance with certain efficiency standards (e.g.
per capita water use) may be required, especially if seeking State or Federal grant or loan
assistance for a project such as the recycled water project.
XI. Individual Supply Guarantee Sale
Availability
The City currently purchases approximately 12 MGD of potable water from the SFPUC and has
an Individual Supply Guarantee (ISG), of 17.07 MGD. A sale of surplus ISG could generate
income for a variety of potential purposes. Over the past several years there has been
increased interest in an ISG transaction, but the mechanism and value of the ISG has been
difficult to establish, and this has hindered movement on this issue.
The City’s current water use is approximately 12 MGD, and the recent 2010 UWMP forecasted
the City’s water use would increase slightly in the next few years, and then remain flat around
13.6 MGD through 2030. In the event the City transferred 1‐2 MGD of its ISG to another party,
recent forecasts do not anticipate this will impact the City’s ability to meet normal year potable
demands.
The SFPUC/BAWSCA (Tier II) drought formula is based on the weighted average of two
components, the smaller of which is the ISG34. This is beneficial to the City since current
consumption is well below the City’s ISG. An ISG transfer would reduce that benefit and result
in an increased dry year reduction requirement by the City. At the same time, this aspect of the
role of the ISG in the drought formula would be viewed favorably by a purchasing entity as it
would be acquiring normal year supply and improving its dry year allocation.
There are several possible uses for the funds from an ISG transaction, including increasing dry
year supply reliability. Examples of potential projects that could reduce the dry year supply
deficiency include retrofitting the City’s wells to provide high quality groundwater, arranging a
dry year water transfer arrangement that could be wheeled via the SFPUC system, or providing
the funds necessary to complete the recycled water project, which is a “drought‐proof” water
supply resource.
Cost
In May 2010, the Purissima Hills Water District indicated an interest in purchasing 0.5 MGD of
the City’s ISG for a one‐time payment of $1 million. The City declined the offer, citing several
34 It is important to emphasize the Tier II formula expires in 2018, unless extended by mutual agreement of the
Wholesale customers. It is possible the successor agreement to the current Tier II formula could be quite
different, including a larger or smaller role for the ISG.
Page 43
policy issues that needed resolution prior to any action to initiate an ISG transaction. With
completion of the Tier II drought allocation process and the Interim Supply Limitation allocation
process, the major policy obstacles have been addressed.
In September 2012, the City of Brisbane executed a term sheet with the Oakdale Irrigation
District to transfer water to Brisbane. The transaction will require additional agreements with
the Modesto Irrigation District and the SFPUC as intermediate parties. As is the case with
PHWD, Brisbane’s water use is close to its ISG and it needs additional supplies to meet
anticipated needs. The term sheet is a preliminary step, but it provides a starting point to
establish a proxy value for an ISG transaction. The term sheet contemplates a sale of up to
2,400 AFY, with a price of $500/AF for any delivered water and a price of $100 for any water
not delivered (i.e, the difference between 2,400 AF and the delivered quantity). After five
years, Brisbane must notify Oakdale Irrigation District how much water will be taken during the
remainder of the agreement. All of that water is paid for at $500/AF, regardless of whether or
not it is actually taken. If the City were to execute an agreement similar to the
Brisbane/Oakdale transaction, a 2 MGD transfer might generate revenues of $224,000 to $1.1
million per year for the first five years, followed by up to $1.1 million per year for the duration
of the transaction. Of course, such a transfer would also reduce the City’s ISG from 17.07 MGD
to 15.07 MGD.
Water Quality
A water transfer does not present any water quality issues.
Long Term Reliability
A 2 MGD water transfer would reduce the City’s ISG from 17.07 MGD to 15.07 MGD. The City’s
current normal year water use is well below 15.07 MGD, and recent forecasts indicate that the
City’s usage will exceed 15.07 MGD for the foreseeable future. For dry years, a reduction in the
City’s ISG will result in an increased water reduction requirement. For dry years, the Tier II
drought allocation formula has an ISG component so a reduction in ISG will negatively impact
the City’s allocation during a drought. Staff estimates a 2 MGD sale would require an additional
5‐7% dry year cutback from the City or could increase reliance on groundwater. A thorough
evaluation of such a sale is necessary to provide a more detailed assessment.
Emergency Robustness
A nominal ISG transfer would not impact the City’s access to SFPUC supplies following a
catastrophic interruption of SFPUC supplies.
Environmental Impacts
Staff anticipates that the receiving party will initiate any required environmental review under
CEQA.
Page 44
Sensitivity to Regulations
An ISG transaction is subject to Section 3.04 of the WSA. The SFPUC review is limited to
determining if the proposed transfer complies with the Raker Act and whether the affected
facilities in the Regional Water System have sufficient capacity to accommodate delivery of the
increased amount of water to the proposed transferee. Section 3.04(a) of the WSA also
specifies the City may “transfer a portion….to one or more other Wholesale Customers...”, thus
indicating an ISG transaction will likely be limited to another Wholesale Customer, or a third
party that plans on receiving the water within the service territory of another Wholesale
Customer.
EXCERPTED DRAFT MINUTES OF THE NOVEMBER 2, 2016
UTILITIES ADVISORY COMMISSION
ITEM 2. DISCUSSION: Utilities Advisory Commission Review and Discussion of the Draft 2017
Water Integrated Resource Plan Guidelines
Senior Resource Planner Karla Dailey provided a presentation summarizing the written report.
She said that the Water Integrated Resources Plan (WIRP) was ready to be updated since the
recent drought has reinforced that there is a need for water in water shortages and there is
regulatory risk since the State Water Resources Control Board showed a willingness to regulate
water use by mandating water use reduction. In addition, there are ongoing cost increases from
both the City’s potable water supplier, the San Francisco Public Utilities Commission (SFPUC),
and for the Santa Clara Valley Water District’s (SCVWD) supplies. The City effort to develop a
comprehensive strategic plan for recycled water, the Council’s dedication to water
sustainability through the Sustainability and Climate Action Plan process and the community’s
interest in water are all also driving the need for a WIRP.
Dailey listed the water supply options evaluated in the WIRP and the attributes considered. She
noted that the WIRP did not evaluate recycled water (since it is being evaluated separately in
the Recycled Water Strategic Plan), desalination, a sale of the City’s excess water allocation of
SFPUC water, small-scale irrigation wells, the use of treated, contaminated water, “nuisance”
groundwater from the Oregon Expressway underpass or basement dewatering, graywater,
black (i.e. sewer) water, and stormwater.
Dailey said that, after looking at all the attributes, staff concluded that SFPUC water is more
expensive but has highest water quality, the cost of SCVWD supplies may increase dramatically
and SCVWD does not have excess treated water to sell, groundwater is susceptible to
mandated water use reductions like imported supplies, blending groundwater with SFPUC
water at El Camino is the least expensive, most sustainable alternative to 100% SFPUC supplies,
but water quality may be an issue, reliability and sustainability can be achieved by reducing
potable water demand through expanding use of recycled water.
The recommended guidelines include:
Pursue all cost-effective water efficiency and conservation;
Survey potentially impacted customers about their preference for SFPUC water versus blended
water;
Proceed with the Recycled Water Strategic Plan to determine how to reduce the demand for
imported water; and
ATTACHMENT D
Continue to investigate ways to increase the use of non-traditional, non-potable sources such as
black water, storm water, and nuisance water from basement construction.
Public comment
Keith Bennet, Save Palo Alto Groundwater, said that he wanted to talk about water pumped
out from basement construction and groundwater protection. He said that 200 million gallons
was dumped into the Bay from 8 residential basements in 2016, equal to 7% the amount the
City buys from the SFPUC and 100% of the recharge of the aquifer from precipitation for a
normal rain year. In 2015 there were 13 or 14 basements constructed in Palo Alto and the
allowed pumping time was longer so he assumes the amount of water discharged to the Bay
was greater than in 2016. He said discharging freshwater to the Bay according to the WIRP is to
be discouraged. He said that the water moving through the soil instead of the storm drain is
valuable for pushing saltwater out of the groundwater. He said shallow groundwater is of very
high quality and can be used for irrigation, including irrigation of Redwoods. He said the water
is usually at 10 feet or less and easily accessible. He said the San Mateo Basin study shows the
shallow and deep aquifers are connected. Proven alternative construction methods exist and
are used in the Netherlands. This is a valuable resource and pumping and dumping the water is
not sustainable. Pumping for basements contradicts the desire to protect groundwater. Utilities
should change the WIRP to recognize the value of the shallow aquifer. He wants Utilities to ask
Council to protect groundwater and restrict pumping and dumping from basement
construction.
Commissioner Trumbull said the report was excellent. He urged the City to investigate the
items that are recommended in the guidelines.
Commissioner Johnston asked how we would do a survey to evaluate whether people would
prefer Hetch Hetchy to Groundwater. Dailey said she had considered blind tastings but said
Utilities would have to consult a survey expert.
Commissioner Danaher said his wife doesn’t want water that tastes like Los Altos water. He
suggested online surveys won’t be valuable but taste test might. It’s staggering that basement
dewatering uses so much water and that alternative construction methods and/or more use of
the water should be investigated. He wondered about how easily Palo Alto’s groundwater is
recharged and was heartened that more studies on groundwater will be done and that more
work will be done on recycling and grey water. Building codes should be examined to include
more grey water. He said the assumed availability of SFPUC water is too rosy. Looking at last 80
years is not a good baseline to predict the impact of climate change. The plan should have
different scenarios showing different assumptions regarding the future availability of Hetch
Hetchy water. He asked if the plan will be updated after the Recycled Water Strategic plan is
finished. Dailey confirmed that it would.
Commissioner Forssell said she appreciated the report and public comment. We switched water
supplies in the past and the change was noticeable. So that could be used to determine
people’s attitude about water quality. Dailey said the SFPUC switches water supplies a couple of
times a year, and customers always notice. Assistant Director Ratchye clarified that the water is
still SFPUC water not groundwater. She is interested in the Recycled Water Strategic Plan.
Chair Cook said he agreed with Danaher and that Palo Alto needs to be prepared for more dire
cuts in water supply in the future. He said the public comment was compelling and that the
scale is mind boggling. We recognize that groundwater is a shared resource. He pondered a
temporary halt on dewatering may be in order while more studies are done. He said the way
we source and use our water is very important.
. '
....
MEMORANDUM
3
TO: UTILITIES ADVISORY COMMISSION
FROM: UTILITIES DEPARTMENT
DATE:
SUBJECT:
JANUARY 11, 2017
Amendment to Utilities Rule and Regulation 27, Generating
Facility Interconnections
Attached is the staff report describing the amendment to Utilities Rule and Regulation 27,
Generating Facility Interconnections, including the resolution Council adopted on December 12,
2016.
The main changes to Rules and Regulation 27 include
o Restructuring of Section C, Application and Interconnection Process, to clarify the
interconnection review process and the time line r equirements for the interconnection
of a generating facility.
o Addition of Section 0.3, Technology Specific Requirements~ to explain the requirements
for different generating technologies.
o Addition of Section D.5, Smart Inverter Generating Facility Design and Operating
Requirements, to keep pace with changing inverter technology.
o General modifications to several sections to ensure the Rule conforms to current
technology, helps staff meet customer expectations1 and is clear and easy to
understand.
AITACHMENT
A. Council Staff Report #7435 -Amendment to Utilities Rule and Regu l ation 271
Generating Facility Interconnections
PREPARED BY: DEAN BAT~t}ti!.lti es Chief Operating Officer J2.o.8l~~/ .
,,,,..,-}~j ~ / ; . ~ e:S"---..., DEPARTMENT HEAD:
EDSHIKADA ......
Utilities General Manager
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City of Palo Alto (ID # 7435)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 12/12/2016
City of Palo Alto Page 1
Summary Title: Amendment to Utilities Rule and Regulation 27, Generating
Facility Interconnection
Title: Adoption of a Resolution Amending Utilities Rule and Regulation 27,
Generating Facility Interconnections
From: City Manager
Lead Department: Utilities
Recommendation
Staff recommends that Council adopt a resolution amending City of Palo Alto Utilities
(“Utilities”) Rule and Regulation 27 Generating Facility Interconnections (Attachment B).
Executive Summary
Utilities’ Rules and Regulations govern utility services in the city and the fees charged for those
services. They are updated as needed to ensure Utilities’ procedures meet industry practices,
standards, and requirements. The recommended amendment adds practices and procedures
to Rule and Regulation 27 for the definition, installation, and interconnection of generating
facilities that are connected to Utilities’ electric distribution system.
Background
There are twenty-nine Utilities Rules and Regulations (Rules) which set forth the conditions
under which the City provides utility services from both the Utilities Department (electric,
natural gas, water, wastewater, fiber optic) and the Public Works Department (refuse, storm
drain). Rule and Regulation 27, Generating Facility Interconnections, describes the
Interconnection, operating and metering requirements for Generating Facilities connected to
the electric distribution system. It was last updated and issued by Council in April 2012.
Discussion
The proposed changes to Rule and Regulation 27 include:
Addition of a “Table of Contents”
Restructuring of Section C, Application and Interconnection Process, to clarify the
interconnection review process and the time line requirements for the interconnection
of a generating facility
ATTACHMENT A
City of Palo Alto Page 2
Addition of Section D.3, Technology Specific Requirements, to explain the requirements
for different generating technologies.
Addition of Section D.5, Smart Inverter Generating Facility Design and Operating
Requirements, to keep pace with changing inverter technology
General modifications to several sections to ensure the Rule conforms to current
technology, helps staff meet customer expectations, and is clear and easy to
understand.
Resource Impact
Approval of changes to Utilities Rule and Regulation 27 will not result in a significant change in
net operating revenues or expenses.
Policy Implications
This recommendation does not represent a change to current City policies.
Environmental Review
The adoption of a resolution amending Utility Rule and Regulation 27 does not constitute a
project requiring review under the California Environmental Quality Act (CEQA) under Public
Resources Code Section 21065 and CEQA Guidelines Section 15378(b)(5), because it is an
administrative governmental activity which will not cause a direct or indirect physical change in
the environment.
Attachments:
Attachment A: Resolution Amending Rule and Reg 27 (PDF)
Attachment B: Amended Rule 27 effective December 12, 2016 (PDF)
Attachment C: Rule 27 Redlines (PDF)
Attachment A
NOT YET APPROVED
161108 jb 6053873 1
Resolution No.
Resolution of the Council of the City of Palo Alto Amending Utilities Rule
and Regulation 27 (Generating Facility Interconnections)
R E C I T A L S
A. Pursuant to Chapter 12.20.010 of the Palo Alto Municipal Code, the Council of the City of
Palo Alto may by resolution adopt rules and regulations governing utility services, fees and charges.
The Council of the City of Palo Alto hereby RESOLVES as follows:
SECTION 1. Pursuant to Section 12.20.010 of the Palo Alto Municipal Code, Utilities Rule and
Regulation 27 (Generating Facility Interconnections) is hereby amended as attached and
incorporated. Utility Rule and Regulation 27, as amended, shall become effective December 12,
2016.
SECTION 2. The adoption of this resolution amending Utilities Rule and Regulation 27 (Generating
Facility Interconnections) is not a project requiring California Environmental Quality Act (CEQA) review,
under California Public Resources Code Sec. 21065, 21080(b)(8), and CEQA Guidelines Section
15378(b)(5), because it is an administrative governmental activity which will not cause a direct or indirect
physical change in the environment.
INTRODUCED AND PASSED: AYES:
NOES: ABSENT:
ABSTENTIONS:
ATTEST:
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
Senior Deputy City Attorney City Manager
Director of Utilities
Director of Administrative Services
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 1
TABLE OF CONTENTS:
A. APPLICABILITY ......................................................................................................................................................... 2
B. GENERAL RULES, RIGHTS AND OBLIGATIONS ................................................................................................. 2
C. APPLICATION AND INTERCONNECTION PROCESS ........................................................................................... 5
1. APPLICATION PROCESS ............................................................................................................................ 5
2. OVERVIEW OF THE INTERCONNECTION REVIEW PROCESS............................................................ 5
3. COMMISSIONING TESTING AND PARALLEL OPERATION............................................................... 10
4. WITHDRAWAL / CANCELLATION ......................................................................................................... 11
D. GENERATING FACILITY DESIGN AND OPERATING REQUIREMENTS ........................................................ 11
1. GENERAL INTERCONNECTION AND PROTECTION FUNCTION REQUIREMENTS ...................... 12
2. PREVENTION OF INTERFERENCE ......................................................................................................... 14
3. TECHNOLOGY SPECIFIC REQUIREMENTS .......................................................................................... 19
4. SUPPLEMENTAL GENERATING FACILITY REQUIREMENTS ........................................................... 20
5. SMART INVERTER GENERATING FACILITY DESIGN AND OPERATING REQUIREMENTS ....... 21
E. INTERCONNECTION FACILITIES AND DISTRIBUTION SYSTEM MODIFICATIONS OWNERSHIP AND
COST ALLOCATION ................................................................................................................................................ 31
1. SCOPE AND OWNERSHIP OF INTERCONNECTION FACILITIES AND DISTRIBUTION SYSTEM
MODIFICATIONS ....................................................................................................................................... 31
2. RESPONSIBILITY OF COSTS OF INTERCONNECTING A GENERATING FACILITY...................... 32
3. INSTALLATION AND FINANCING OF INTERCONNECTION FACILITIES AND DISTRIBUTION
SYSTEM MODIFICATIONS ....................................................................................................................... 32
F. METERING, MONITORING AND TELEMETRY ................................................................................................... 33
1. GENERAL REQUIREMENTS..................................................................................................................... 33
2. METERING BY CPAU ................................................................................................................................ 33
3. NET GENERATION METERING ............................................................................................................... 34
4. POINT OF COMMON COUPLING METERING ....................................................................................... 34
5. TELEMETERING ........................................................................................................................................ 34
6. LOCATION .................................................................................................................................................. 35
7. COSTS OF METERING ............................................................................................................................... 35
ATTACHMENT B
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 2
A. APPLICABILITY
This Rule describes the Interconnection, Metering and operating requirements for Generating
Facilities to be connected to the City of Palo Alto Utilities (CPAU) Electric Distribution System.
In order to provide for uniformity and to encourage the Interconnection of renewable energy
generation, this Rule is intended to be generally consistent with the technical requirements of
California Public Utilities Commission Rule 21 and IEEE 1547, as amended.
Language from IEEE 1547 that has been adopted directly (as opposed to paraphrased) is followed by
a citation that lists the clause from which the language derived. For example, IEEE 1547-4.1.1 is a
reference to Clause 4.1.1.
In the event of any conflict between this Rule and any of the CPUC Rule 21 and IEEE 1547
standards listed herein, the requirements of this Rule shall take precedence.
B. GENERAL RULES, RIGHTS AND OBLIGATIONS
1. Prior Authorization Required to Interconnect and Operate. An executed Interconnection
Agreement or Net Energy Metering and Interconnection Agreement, as applicable, is
required in addition to receiving CPAU’s express written permission before Parallel
Operation of a Generating Facility with CPAU’s Distribution System. CPAU shall apply this
Rule in a non-discriminatory manner and shall not unreasonably withhold its permission for
Parallel Operation of Generating Facilities with CPAU’s Distribution System.
2. Separate Agreements Required for Other Services. Separate Agreements are required for the
provision of other Electric Services from CPAU including, but not limited to, Distribution
Service provided by CPAU during periods of Curtailment or interruption of a Generating
Facility, in accordance with CPAU’s Rules & Regulations.
3. Service Not Provided With Interconnection. Interconnection with CPAU's Distribution
System under this Rule provides no rights to utilize CPAU's Distribution System for the
transmission, distribution, or wheeling of electric power.
4. Compliance with Laws, Rules & Regulations and Utility Rates. Applicants shall ascertain
and comply with applicable CPAU Rules & Regulations and Utility Rates; applicable Federal
Energy Regulatory Commission (FERC) approved rules, tariffs and regulations; and any
local, state or federal Law, statute or regulation which applies to the design, siting,
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 3
construction, installation, operation, or any other aspect of the Applicant’s Generating
Facility and Interconnection Facilities.
5. Design Reviews and Inspections. CPAU has the right to review the design of an Applicant’s
Generating Facility and Interconnection Facilities and to inspect the Generating Facility
and/or Interconnection Facilities prior to the commencement of Parallel Operation with
CPAU’s Distribution System. CPAU may require Applicants to make modifications as
necessary to comply with the requirements of CPAU Rules and Regulations or other
reasonable requirements. CPAU’s review and authorization for Parallel Operation shall not
be construed as confirming or endorsing the Applicant’s design or as warranting the
Generating Facility and/or Interconnection Facilities’ safety, durability or reliability. CPAU
is not responsible for the adequacy or capacity of such Facilities.
6. Right to Access. Customer Generating and Interconnection Facilities shall be accessible to
CPAU personnel whenever necessary for CPAU to perform its duties and exercise its rights
under its Rules and Regulations and any Interconnection Agreement, including the Net
Energy Metering and Interconnection Agreement.
7. Prudent Operation and Maintenance Required. The Customer shall operate and maintain its
Generating Facility and Interconnection Facilities in accordance with Prudent Electrical
Practices and shall maintain compliance with CPAU Rules and Regulations.
8. Curtailment and Disconnection. CPAU may limit the operation, disconnect or require the
disconnection of a Customer’s Generating Facility from CPAU’s Distribution System at any
time, with or without notice, in the event of an Emergency, or to correct Unsafe Operating
Conditions. CPAU may also limit the operation, disconnect or require the disconnection of a
Customer’s Generating Facility from CPAU’s Distribution System with reasonable written
notice: (1) to allow for routine maintenance, repairs or modifications to CPAU’s
Distribution System; (2) upon CPAU’s determination that a Customer’s Generating Facility
is not in compliance with any CPAU Rules and Regulations; or (3) upon termination of the
applicable Interconnection Agreement or Net Energy Metering and Interconnection
Agreement. Within a reasonable period after the Customer’s written request, CPAU will
provide a written explanation of the reason for such Curtailment or disconnection.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 4
9. Coordination with Affected Systems. CPAU will notify the Affected System Operators that
are potentially affected by an Applicant’s Interconnection Request(s). CPAU will coordinate
the conduct of any studies required to determine the impact of the Interconnection Request
on Affected Systems with Affected System Operators and, if possible, include those results
in its Interconnection Study. CPAU will invite such Affected System Operators to all
meetings held with Applicant as required by this Rule. Applicants and transmission providers
which may be an Affected System shall cooperate with CPAU in all matters related to the
conduct of relevant studies and the determination of modifications to Affected Systems.
Applicant shall enter into an agreement with the owner of the Affected System, as applicable
and upon request by CPAU. The agreement will specify the terms governing payments to be
made by Applicant to the owner of the Affected System as well as the repayment, if
applicable, by the owner of the Affected System.
10. Transferability of Interconnection Request. An Applicant may transfer its Interconnection
Request to another entity only if such entity acquires the proposed Generating Facility
identified in the Interconnection Request and the Point of Interconnection and operating
parameters do not change. CPAU at its discretion may deny such requests if CPAU
determines applicable requirements will not be met as a result of the transfer.
11. Special Provisions Applicable to Net Energy Metering Applicants (NEM). Notwithstanding
any other provision in this Rule:
a. For Generating Facilities qualifying for service under PUC Sections 2827, 2827.8
and 2827.10, as amended, the Applicant is not responsible for payment of study
costs.
b. For Generating Facilities qualifying for service under PUC Sections 2827 and
2827.8, as amended, CPAU’s approval for Interconnection will normally be
processed not later than thirty (30) Business Days following CPAU’s receipt of:
i. a completed Net Energy Metering Interconnection Request including all
supporting documents and required payments;
ii. a completed signed Net Energy Metering Generator Interconnection
Agreement; and
iii. evidence of Applicant’s final electric inspection clearance from the Palo Alto
Building Department.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 5
If the 30-day period cannot be met, CPAU will notify Applicant of the reason for the
inability to process the Interconnection Request and the expected completion date.
Applicants with PUC Section 2827 Generating Facilities that include non-inverter
based Generators and/or Generators with non-Certified Equipment should submit a
completed Net Energy Metering Interconnection Request, including all supporting
documents sufficient for CPAU to start the review process, without waiting for the
final inspection clearance. Applicants with such Generating Facilities are advised to
submit their Interconnection Request at least six (6) months in advance of their
planned Commercial Operation Date. Depending on the size and location of these
Generating Facilities, additional time for review and study may be required.
C. APPLICATION AND INTERCONNECTION PROCESS
1. APPLICATION PROCESS
a. Utility Service Application (Application). All Applicants must complete and submit
the Application and three (3) sets of plan drawings at the Development Center
located at 285 Hamilton Avenue.
2. OVERVIEW OF THE INTERCONNECTION REVIEW PROCESS
a. Valid Interconnection Request. After an Application is received and deemed
complete and valid, CPAU will start the interconnection review process. See Section
B.11 for special provisions related to the timeframe and costs applicable to NEM
Applicants.
b. Initial Review. Upon receipt of a complete and valid Application and plans, CPAU
shall perform an Initial Review. The Initial Review determines if (i) the Generating
Facility qualifies for a Simplified Interconnection, or (ii) the Generating Facility
requires a Supplemental Review. Absent extraordinary circumstances, CPAU shall
notify Applicant in writing of the results of Initial Review within ten (10) Business
Days following validation of an Interconnection Request.
i. Passage of Initial Review. For Interconnection Requests that pass the Initial
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 6
Review and do not require Interconnection Facilities or Distribution
Upgrades, CPAU will provide the Applicant with a Generator
Interconnection Agreement or Generator Interconnection Agreement and Net
Energy Metering Agreement, if applicable, within fifteen (15) Business Days
of providing notice of Initial Review results. For Interconnection Requests
that pass the Initial Review but also require Interconnection Facilities or
Distribution upgrades, CPAU will provide Applicant with a non-binding cost
estimate of the Interconnection Facilities or Distribution upgrades within
thirty (30) Business Days of providing notice of Initial Review results. These
facilities may be treated as Special Facilities (depending on circumstance) for
the purpose of determining Applicant costs. The applicant can then proceed
with executing an Interconnection Agreement in accordance with Section
C.1.e below.
ii. Failure of Initial Review. For Interconnection Requests that fail Initial
Review, CPAU will provide the technical reason, data and analysis
supporting the Initial Review results in writing and provide Applicant the
option to proceed directly to a Supplemental Review. The Applicant shall
notify CPAU within ten (10) Business Days following such notification
whether to (i) proceed to a Supplemental Review, or (ii) withdraw the
Interconnection Request. Applicants that elect to proceed to a Supplemental
Review shall provide a nonrefundable Advance Engineering Fee set forth in
Rate Schedule E-15 with their response. CPAU will proceed with the
Supplemental Review once payment of the required Advance Engineering
Fee has been received. If Applicant fails to notify CPAU within ten (10)
Business Days of such notification, the Interconnection Request will be
deemed withdrawn.
iii. Additional Initial Review Information. No changes may be made to the
planned Point of Interconnection or Generating Facility size included in the
Interconnection Request during the review process, unless such changes are
agreed to by CPAU. Where agreement has not been reached, Applicants
choosing to change the Point of Interconnection or Generating Facility size
must reapply and submit a new Interconnection Request.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 7
c. Supplemental Review.
If Applicant requests a Supplemental Review and submits an Advance
Engineering Fee as described in Rate Schedule E-15, if required, CPAU will
perform the Supplemental Review using the review process in Section H.2., and
complete the Supplemental Review within twenty (20) Business Days, absent
extraordinary circumstances, following authorization and receipt of the fee. The
Supplemental Review will determine if (i) the Generating Facility qualifies for
interconnection, or interconnection with additional requirements, or (ii) the
Generating Facility requires a Detailed Study.
The Applicant must provide the following data to CPAU when requesting a
Supplemental Review:
Generator:
1. MVA Rating
2. kV Rating
3. Base MVA
4. Base kV
5. Xd" (direct axis subtransient reactance)
6. Xd' (direct axis transient reactance)
7. Xd (Synchronous reactance)
8. X2 (Negative Sequence reactance)
9. X0 (Zero Sequence reactance)
Generating Facility Transformer Data:
1. Winding configuration (delta-Wye gnd or Wye gnd-Delta)
2. MVA Rating
3. KV Rating
4. Base MVA
5. Base KV
6. Z1 HV-LV
7. Z0 HV-LV
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 8
Line Data:
1. Impedance data for line from Transformer to POI (if applicable)
2. Z1
3. Z0
4. Point of Interconnection (POI) Location
i. Passage of Supplemental Review. For Interconnection Requests that pass a
Supplemental Review and do not require Interconnection Facilities or
Distribution Upgrades, CPAU will provide Applicant with a Generator
Interconnection Agreement within fifteen (15) Business Days of providing
notice of the Supplemental Review results. For Interconnection Requests
that pass a Supplemental Review but also require Interconnection
Facilities or Distribution upgrades, CPAU will provide Applicant with a
non-binding cost estimate of the Interconnection Facilities or Distribution
upgrades within thirty (30) Business Days of providing notice of the
Supplemental Review results. These facilities may be treated as Special
Facilities (depending on circumstance) for the purpose of determining
Applicant costs. The Applicant can then proceed with executing an
Interconnection Agreement in accordance with Section C.1.e below.
ii. Failure of Supplemental Review. For Interconnection Requests that fail a
Supplemental Review, CPAU will provide the technical reason, data and
analysis supporting the Supplemental Review results in writing and
provide Applicant the option to proceed directly to a cost estimate and
schedule for a Detailed Study. The Applicant shall notify CPAU within
fifteen (15) Business Days following such notification whether to (i)
proceed to a cost estimate and schedule for a Detailed Study, or (ii)
withdraw the Interconnection Request. If the Applicant elects to proceed
with the cost estimate and schedule for a Detailed Study, CPAU shall
provide Applicant with a non-binding cost estimate and schedule within
thirty (30) Business Days of the Applicant providing notice to proceed. If
Applicant fails to notify CPAU within fifteen (15) Business Days of such
notification, the Interconnection Request shall be deemed withdrawn.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 9
d. Detailed Study.
If the Applicant requests to proceed with the cost estimate and schedule for a
Detailed Study as provided by CPAU in Section C.1.c.ii above, CPAU and the
Applicant may enter into a Detailed Study agreement that provides for CPAU to
perform additional studies, facility design and engineering, and to provide an
estimate for the actual cost of CPAU provided Interconnection Facilities or
Distribution Upgrades as required to allow for the interconnection of the
generating facility at the Applicant’s expense. The Detailed Study agreement shall
set forth CPAU’s estimated time schedule and charges for completing such work.
Note: the Detailed Study fee shall be waived for NEM applicants meeting the
requirements of Section B.11. Following payment of the cost estimate by the
Applicant, CPAU will proceed with the Detail Study in accordance with the
agreed upon time schedule, and upon completion of the Detailed Study, CPAU
will provide the results in writing to the Applicant along with the final cost
estimate of any required Interconnection or Distribution Facilities. These facilities
may be treated as Special Facilities (depending on circumstance) for the purpose
of determining Applicant costs. The applicant can then proceed with executing an
Interconnection Agreement in accordance with Section C.1.e below.
e. Execution of the Generator Interconnection Agreement.
i. Following the receipt of a cost estimate for any Distribution Upgrades
and/or Interconnection Facilities that have been identified (Applicants that
did not require a cost estimate may proceed to Section C.1.e.ii below),
Applicant shall notify CPAU within fifteen (15) Business Days whether
Applicant: (i) requests a Generator Interconnection Agreement, or (ii)
withdraws its Interconnection Request. If Applicant fails to notify CPAU
within fifteen (15) Business Days, the Interconnection Request shall be
deemed withdrawn. If Applicant elects to proceed to a Generator
Interconnection Agreement, CPAU will provide Applicant with a
Generator Interconnection Agreement for Applicant’s signature within
fifteen (15) Business Days of Applicant’s request.
ii. Upon receipt of a draft Generator Interconnection Agreement, Applicant
has ninety (90) Calendar Days to sign and return the Generator
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 10
Interconnection Agreement. Applicant shall provide to CPAU written
comments, or notification of a lack of any comments, on the draft
Generator Interconnection Agreement and appendices within thirty (30)
Calendar Days. At the request of Applicant, CPAU shall begin
negotiations with Applicant at any time after CPAU provides Applicant
with the draft Generator Interconnection Agreement, which contains in its
appendices the cost estimate for any Distribution Upgrades and/or
Interconnection Facilities that have been identified by CPAU. If Applicant
fails to execute the Generator Interconnection Agreement within the ninety
(90) Calendar Days described in this section, the Interconnection Request
shall be deemed withdrawn.
iii. After Applicant has executed the Generator Interconnection Agreement
and paid the final invoice for estimated cost of Distribution Upgrades
and/or Interconnection Facilities, CPAU will commence with the design,
procurement, construction and installation of required facilities identified
in the Generator Interconnection Agreement. (Note: once the Applicant
executes the agreement, the Applicant is thereafter referred to as a
Producer) CPAU and Producer will use good faith efforts to meet
schedules and estimated costs in accordance with the requirements of the
Generator Interconnection Agreement. Producer is responsible for all costs
associated with Parallel Operation to support the safe and reliable
operation of the Distribution System and Transmission System.
3. COMMISSIONING TESTING AND PARALLEL OPERATION
a. Commissioning Testing. Producer is responsible for commissioning and testing
new Generating Facilities and associated Interconnection Facilities to ensure
compliance with the safety and reliability provisions of this Rule prior to being
operated in parallel with CPAU’s Distribution or Transmission System. For non-
Certified Equipment, Producer shall develop a written testing plan to be submitted
to CPAU for its review and acceptance. Where applicable, the testing plan shall
include the installation test procedures published by the manufacturer of the
Generating Facility or Interconnection Facilities. Facility testing shall be
conducted at a mutually agreeable time, and CPAU shall be given the opportunity
to witness the tests.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 11
b. Parallel Operation or Momentary Parallel Operation. Producer shall not
commence Parallel Operation of its Generating Facility with CPAU’s system
unless it has received CPAU’s express written permission to do so. CPAU will
authorize Producer’s Generating Facility for Parallel Operation or momentary
Parallel Operation with CPAU’s Distribution or Transmission System, in writing,
within five (5) Calendar Days of satisfactory compliance with the terms of all
applicable agreements.
4. WITHDRAWAL / CANCELLATION
Applicant may withdraw its Interconnection Request at any time by written notice of such
withdrawal to CPAU. In addition, after receipt of the Interconnection Request, if
Applicant fails to adhere to the requirements and timelines of this rule, CPAU shall deem
the Interconnection Request to be withdrawn and shall provide written notice to
Applicant of the deemed withdrawal within five (5) Business Days and an explanation of
the reasons for such deemed withdrawal. Upon receipt of such written notice, Applicant
shall have five (5) Business Days in which to either respond with information or action
that either cures the deficiency or supports its position that the deemed withdrawal was
erroneous.
Applications that are over one year old (from the date of CPAU’s receipt) without resulting
in a signed Interconnection Agreement or Net Energy Metering and Interconnection
Agreement, or approval for Parallel Operation of a Generating Facility within one year of
completion of all applicable review and/or studies, are subject to cancellation by CPAU.
D. GENERATING FACILITY DESIGN AND OPERATING REQUIREMENTS
This section D. has been revised to be consistent with the requirements of ANSI/IEEE 1547-2003
Standard for Interconnecting Distributed Resources with Electric Power Systems (IEEE 1547).
Exceptions are taken to IEEE 1547 Clauses 4.1.4.2 Distribution Secondary Spot Networks and
Clauses 4.1.8.1 or 5.1.3.1, which address Protection from Electromagnetic Interference. Note
that this Rule and Regulation 27 does not adopt the Generating Facility power limitation of 10
MW incorporated in IEEE 1547.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 12
1. GENERAL INTERCONNECTION AND PROTECTION FUNCTION
REQUIREMENTS
The Protective Functions and requirements of this Rule are designed to protect CPAU’s
Distribution System and not the Generating Facility. Customer shall be solely responsible
for providing adequate protection for its Generating Facility and Interconnection Facilities.
The Customer’s Protective Functions shall not impact the operation of other Protective
Functions utilized on CPAU’s Distribution System in a manner that would affect CPAU’s
capability of providing reliable service to its Customers.
a. Protective Functions Required. A Generating Facility operating in parallel with
CPAU’s Distribution System shall be equipped with the following Protective
Functions to sense abnormal conditions on CPAU’s Distribution System and cause
the Generating Facility to be automatically disconnected from CPAU’s Distribution
System or to prevent the Generating Facility from being connected to CPAU’s
Distribution System inappropriately:
i. Over and under voltage trip functions and over and under frequency trip
functions;
ii. A voltage and frequency sensing and time-delay Function to prevent the
Generating Facility from energizing a de-energized Distribution System
circuit and to prevent the Generating Facility from reconnecting with CPAU’s
Distribution System unless CPAU’s Distribution System service voltage and
frequency is within the ANSI C84.1-1995 Table 1 Range B Voltage Range of
106V to 127V on a 120V basis, inclusive, and a frequency range of 59.3 Hz
to 60.5 Hz, inclusive, and are stable for at least 60 seconds, and;
iii. A Function to prevent the Generating Facility from contributing to the
formation of an Unintended Island, and cease to energize the CPAU system
within two seconds of the formation of an Unintended Island.
The Generating Facility shall cease to energize CPAU’s Distribution System
for faults on CPAU’s Distribution System circuit to which it is connected
(IEEE1547-4.2.1). The Generating Facility shall cease to energize CPAU’s
Distribution circuit prior to re-closure by CPAU’s Distribution System
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 13
equipment (IEEE1547-4.2.2).
b. Momentary Paralleling Generating Facilities. With CPAU’s approval, the transfer
switch or scheme used to transfer the Producer’s Loads from CPAU’s Distribution
System to Producer’s Generating Facility may be used in lieu of the Protective
Functions required for Parallel Operation.
c. Suitable Equipment Required. Circuit breakers or other interrupting devices located
at the Point of Common Coupling must be Certified or "Listed" (as defined in
Article 100, the Definitions Section of the National Electrical Code) as suitable for
their intended application. This includes being capable of interrupting the maximum
available fault current expected at their location. Producer’s Generating Facility and
Interconnection Facilities shall be designed so that the failure of any one device shall
not potentially compromise the safety and reliability of CPAU’s Distribution System.
The Generating Facility’s paralleling-device shall be capable of withstanding 220%
of the Interconnection Facilities’ rated voltage (IEEE 1547-4.1.8.3). The
Interconnection Facilities shall have the capability to withstand voltage and current
surges in accordance with the environments defined in IEEE Std C62.41.2-2002 or
IEEE Std C37.90.1-2002 as applicable and as described in IEEE 1547-4.1.8.2.
d. Visible Disconnect Required: The Producer shall furnish and install a ganged,
manually-operated isolating switch (or a comparable device mutually agreed upon by
CPAU and the Producer) near the Point of Interconnection to isolate the Generating
Facility from CPAU’s Distribution System. The device does not have to provide
overcurrent protection.
The device must:
i. Allow visible verification that separation has been accomplished. (This
requirement may be met by opening the enclosure to observe contact
separation.) Molded case circuit breakers do not meet the visible contact
requirement and are not acceptable as a Visible Disconnect device.
ii. Include markings or signage that clearly indicates open and closed positions.
iii. Be capable of being reached quickly and conveniently 24 hours a day by
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 14
CPAU personnel for construction, maintenance, inspection, testing or
reading, without obstacles or requiring those seeking access to obtain keys,
special permission, or security clearances.
iv. Be capable of being locked in the open position.
v. Be clearly marked on the submitted Single Line Diagram and its type and
location approved by CPAU prior to installation. If the device is not adjacent
to the Point of Common Coupling (PCC), permanent signage must be
installed at a CPAU-approved location providing a clear description of the
location of the device. Generating Facilities with Non-Islanding inverters
totaling one (1) kilovolt-ampere (kVA) or less are exempt from this
requirement.
e. Drawings Required. Prior to Parallel Operation or Momentary Parallel Operation of
the Generating Facility, CPAU shall approve the Producer's Protective Function and
control diagrams. A Generating Facility equipped with a Protective Function and
control scheme previously approved by CPAU for system-wide application or only
Certified Equipment may satisfy this requirement by reference to previously
approved drawings and diagrams.
f. Generating Facility Conditions Not Identified. In the event this Rule does not
address the Interconnection conditions for a particular Generating Facility, CPAU
and Producer may agree upon other arrangements, to be approved by CPAU.
2. PREVENTION OF INTERFERENCE
The Producer shall not operate a Generating Facility or Interconnection Facilities that
superimpose a voltage or current upon CPAU’s Distribution System that interferes with
CPAU operations, service to CPAU Customers, or communication facilities. If such
interference occurs, the Producer must diligently pursue and take corrective action at its
own expense after being given notice and reasonable time to do so by CPAU. If the
Producer does not take corrective action in a timely manner, or continues to operate the
facilities causing interference without restriction or limit, CPAU may, without liability,
disconnect the Producer's facilities from CPAU’s Distribution System, in accordance with
Section B.8 of this Rule. To eliminate undesirable interference caused by its operation,
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 15
each Generating Facility shall meet the following criteria:
a. Voltage Regulation. The Generating Facility shall not actively regulate the voltage at
the PCC while in parallel with CPAU’s Distribution System. The Generating Facility
shall not cause the service voltage at other Customers to go outside the requirements
of ANSI C84.1-1995, Range A (IEEE 1547-4.1.1).
b. Operating Voltage Range. The voltage ranges in Table D.1 define protective trip
limits for the Protective Function and are not intended to define or imply a voltage
regulation Function. A Generating Facility shall cease to energize CPAU’s
Distribution System within the prescribed trip time whenever the voltage at the PCC
deviates from the allowable voltage operating range. The Protective Function shall
detect and respond to voltage on all phases to which the Generating Facility is
connected.
i. Generating Facilities. Generating Facilities shall be capable of operating
within the voltage range normally experienced on CPAU’s Distribution
System from plus to minus 5% of the nominal voltage (e.g. 114 volts to 126
volts on a 120 volt base), at the service panel or PCC. The trip settings at the
generator terminals shall be selected in a manner that minimizes nuisance
tripping between 106 volts and 132 volts on a 120-volt base (88-110% of
nominal voltage) to compensate for voltage drop between the generator
terminals and the PCC. Voltage shall be detected at either the PCC or the
Point of Interconnection. However, the voltage range at the PCC with the
generator on-line shall stay within +/-5% of nominal.
ii. Voltage Disturbances. Whenever CPAU’s Distribution System voltage at the
PCC varies from and remains outside normal (nominally 120 volts) by the
predetermined amounts set forth in Table D.1, the Generating Facility’s
Protective Functions shall cause the Generator(s) to become isolated from
CPAU’s Distribution System.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 16
TABLE D.1: Voltage Trip Settings
Voltage at Point of Common Coupling Maximum Trip Time(1)
Assuming 120 V Base % of Nominal Voltage
# of Cycles
(Assuming 60 Hz
Nominal)
Seconds
Less than 60 Volts Less than 50% 10 Cycles 0.16 Seconds
Greater than or equal to
60 Volts but less than
106 Volts
Greater than or equal to
50% but less than 88% 120 Cycles 2 Seconds
Greater than or equal to
106 Volts but less than or
equal to 132 Volts
Greater than or equal to
88% but less than or
equal to 110%
Normal Operation
Greater than 132 Volts
but less than or
equal to 144 Volts
Greater than 110% but
less than or equal to
120%
60 Cycles 1 Second
Greater than 144 Volts Greater than 120% 10 Cycles 0.16 Seconds
(1) “Maximum Trip time” refers to the time between the onset of the abnormal condition and the
Generating Facility ceasing to energize CPAU’s Distribution System. Protective Function sensing
equipment and circuits may remain connected to CPAU’s Distribution S ystem to allow sensing of
electrical conditions for use by the “reconnect” feature. The purpose of the allowed time delay is to
allow a Generating Facility to “ride through” short-term disturbances to avoid nuisance tripping. Set
points shall not be user adjustable (though they may be field adjustable by qualified personnel).
c. Paralleling. The Generating Facility shall parallel with CPAU’s Distribution System
without causing a voltage fluctuation at the PCC greater than ±5% of the prevailing
voltage level of CPAU’s Distribution System at the PCC, and meet the flicker
requirements of D.2.d.
d. Flicker. The Generating Facility shall not create objectionable flicker for other
Customers on CPAU’s Distribution System. To minimize the adverse voltage effects
experienced by other Customers (IEEE 1547-4.3.2), flicker at the PCC caused by the
Generating Facility should not exceed the limits defined by the “Maximum
Borderline of Irritation Curve” identified in IEEE 519-1992 (IEEE Recommended
Practices and Requirements for Harmonic Control in Electric Power Systems, IEEE
STD 519-1992). This requirement is necessary to minimize the adverse voltage
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 17
affects experienced by others Customers on CPAU’s Distribution System.
Generators may be connected and brought up to synchronous speed (as an induction
motor) provided these flicker limits are not exceeded.
e. Integration with CPAU’s Distribution System Grounding. The grounding scheme of
the Generating Facility shall not cause over-voltages that exceed the rating of the
equipment connected to CPAU’s Distribution System and shall not disrupt the
coordination of the ground fault protection on CPAU’s Distribution System (IEEE
1547-4.1.2).
f. Frequency. The Generating Facility shall operate in synchronism with CPAU’s
Distribution System. Whenever CPAU’s Distribution System Frequency at the PCC
varies from and remains outside normal (nominally 60 Hz) by the predetermined
amounts set forth in Table D.2, the Generating Facility’s Protective Functions shall
cease to energize CPAU’s Distribution System within the stated maximum trip time.
TABLE D.2: Frequency Trip Settings
Generating Facility Rating Frequency Range
(Assuming 60 Hz Nominal)
Maximum Trip Time (1)
(Assuming 60 Cycles per
Second
Less or equal to 30 kW
Less than 59.3 Hz 10 Cycles
Greater than 60.5 Hz 10 Cycles
Greater than 30 kW
Less than 57 Hz 10 Cycles
Less than an adjustable value
between 59.8 Hz and 57 Hz
but greater than 57 Hz (2)
Adjustable between 10 and
18,000 Cycles (2),(3)
Greater than 60.5 Hz 10 Cycles
1) “Maximum Trip time” refers to the time between the onset of the abnormal condition and the
Generating Facility ceasing to energize CPAU’s Distribution System. Protective Function sensing
equipment and circuits may remain connected to CPAU’s Distribution System to allow sensing of
electrical conditions for use by the “reconnect” feature. The purpose of the allowed time delay is
to allow a Generating Facility to “ride through” short-term disturbances to avoid nuisance tripping.
Set points shall not be user adjustable (though they may be field adjustable by qualified
personnel).
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 18
(2) Unless otherwise required by CPAU, a trip frequency of 59.3 Hz and a maximum trip time of 10
cycles shall be used.
(3) When a 10-cycle maximum trip time is used, a second under frequency trip setting is not required.
g. Harmonics. When the Generating Facility is serving balanced linear Loads, harmonic
current injection into CPAU’s Distribution System at the PCC shall not exceed the
limits stated below in Table D.3. The harmonic current injections shall be exclusive
of any harmonic currents due to harmonic voltage distortion present in CPAU’s
Distribution System without the Generating Facility connected (IEEE 1547-4.3.3).
The harmonic distortion of a Generating Facility located at a Customer’s site shall be
evaluated using the same criteria as for the Host Loads.
Table D.3 Maximum Harmonic Current Distortion in Percent of Current (I)(1,2)
Individual
Harmonic Order h,
(odd harmonics) (3)
h<11 11 ≤ h < 17 17 ≤ h < 23 23 ≤ h < 35 35 ≤ h
Total
Demand
distortion
(TDD)
Max Distortion (%) 4.0 2.0 1.5 0.6 0.3 5.0
(1) IEEE 1547-4.3.3
(2) I = the greater of the maximum Host Load current average Demand over 15 or 30 minutes without the GF, or the GF rated current capacity (transformed to the PCC when a transformer exists between the GF and the PCC).
(3) Even harmonics are limited to 25% of the odd harmonic limits above.
h. Direct Current Injection. Generating Facilities should not inject direct current greater
than 0.5% of rated output current into CPAU’s Distribution System.
i. Power Factor. Each Generator in a Generating Facility shall be capable of operating
at some point within a Power Factor range from 0.9 leading to 0.9 lagging. Operation
outside this range is acceptable provided the reactive power of the Generating
Facility is used to meet the reactive power needs of the Host Loads or that reactive
power is otherwise provided under tariff by CPAU. The Producer shall notify CPAU
if it is using the Generating Facility for Power Factor correction. Unless otherwise
agreed upon by the Producer and CPAU, Generating Facilities shall automatically
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 19
regulate Power Factor, not voltage, while operating in parallel with CPAU’s
Distribution System.
3. TECHNOLOGY SPECIFIC REQUIREMENTS
a. Three-Phase Synchronous Generators. For three-phase Generators, the Generating
Facility circuit breakers shall be three-phase devices with electronic or
electromechanical control. The Producer shall be responsible for properly
synchronizing its Generating Facility with CPAU’s Distribution System by means of
either manual or automatic synchronizing equipment. Automatic synchronizing is
required for all synchronous Generators that have a Short Circuit Contribution Ratio
(SCCR) exceeding 0.05. Loss of synchronism protection is not required except as
may be necessary to meet D.2.d (Flicker) (IEEE 1547-4.2.5). Unless otherwise
agreed upon by the Producer and CPAU, synchronous Generators shall automatically
regulate Power Factor, not voltage, while operating in parallel with CPAU’s
Distribution System. A power system stabilization function is specifically not
required for Generating Facilities under 10 MW Net Nameplate Rating. Ground Fault
Protection is required for generators > 40 kW. Voltage Restraint Overcurrent or
Voltage Controlled Overcurrent relays are required for generators or a group of
generators > 400 kW.
b. Induction Generators. Induction Generators (except self-excited Induction
Generators) do not require a synchronizing Function. Starting or rapid Load
fluctuations on induction Generators can adversely impact CPAU’s Distribution
System's voltage. Corrective step-switched capacitors or other techniques may be
necessary and may cause undesirable ferroresonance. When these counter measures
(e.g. additional capacitors) are installed on the Producer's side of the Point of
Common Coupling, CPAU must review these measures. Additional equipment may
be required as determined in a Supplemental Review or a Detailed Study.
Ground Fault Protection is required for generators > 40 kW. Voltage Restraint
Overcurrent or Voltage Controlled Overcurrent relays are required for generators or a
group of generators > 400 kW.
c. Inverters. Only Certified inverters are approved for interconnection. Utility-
interactive inverters do not require separate synchronizing equipment. Non-utility-
interactive or “stand-alone” inverters shall not be used for Parallel Operation with
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 20
CPAU’s Distribution System. Inverters or a group of inverters > 400 kW require
Ground Fault Protection.
Inverter based systems not classified as “Smart Inverters” may continue to be
installed per Section D.3.c until September 8, 2017, which is twelve (12) months
after the date the Supplement SA of UL-1741 (with California requirements) was
approved. Section D.5 may be used in all or in part, for inverter based technologies
by mutual agreement of CPAU and the Applicant.
The replacement of an existing inverter to an inverter that is of equal or greater
ability than the original is allowed per Section D.3.c. Section D.5 may be used in all
or in part, for replacement inverter based technologies by mutual agreement of CPAU
and the Applicant.
d. Single-Phase Generators. For single-phase Generators connected to a shared
single-phase secondary system, the maximum Net Nameplate Rating of the
Generating Facilities shall be 20 kVA. Generators connected to a center-tapped
service neutral must be installed such that no more than 6 kVA of unbalanced power
is applied to the two “legs” of the service. The current in the most heavily loaded leg
must not exceed twice that of the other leg. For Dedicated Distribution Transformer
Services, the maximum Net Nameplate Rating of a single-phase Generating Facility
shall be the transformer nameplate rating.
4. SUPPLEMENTAL GENERATING FACILITY REQUIREMENTS
a. Fault Detection. A Generating Facility with an SCCR exceeding 0.1 or one that does
not cease to energize CPAU’s Distribution System within two seconds of the
formation of an Unintended Island shall be equipped with Protective Functions
designed to detect Distribution System faults, both line-to-line and line-to-ground,
and shall cease to energize CPAU’s Distribution System within two seconds of the
initiation of a fault.
b. Transfer Trip. For a Generating Facility that cannot detect Distribution System faults
(both line-to-line and line-to-ground) or the formation of an Unintended Island, and
cease to energize CPAU’s Distribution System within two seconds, CPAU may
require a Transfer Trip system or an equivalent Protective Function. For net metered
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 21
or non-net metered Generating Facilities, the Facility will be considered capable of
supporting an Unintended Island if the aggregate distributed generation output is 80%
or more of the Distribution System real-time load kW seen at CPAU’s source-side
Distribution Protection Device.
c. Reclose Blocking. Where the aggregate Generating Facility capacity exceeds 15% of
the peak Load on any automatic reclosing device, CPAU may require additional
Protective Functions, including, but not limited to reclose-blocking on some of the
automatic reclosing devices.
5. SMART INVERTER GENERATING FACILITY DESIGN AND OPERATING
REQUIREMENTS
Section D.3.c shall continue to be used for interconnection of inverter based technologies
until September 8, 2017, twelve (12) months after the date the Supplement SA of UL-1741
(with CA requirements) was approved by the full UL-1741 Standards Technical Panel (STP).
Following such date, Section D.5 shall apply for interconnection of inverter based
technologies. Until such date, Section D.5 may be used in all or in part, for inverter based
technologies by mutual agreement of the CPAU and the Applicant.
The inverter requirements are intended to be consistent with ANSI/IEEE 1547- 2003 and
1547a Standard for Interconnecting Distributed Resources with Electric Power Systems
(IEEE 1547 including amendment 1547a). In the event of conflict between this Rule and
IEEE 1547-2003, this Rule shall take precedence. Exceptions are taken to IEEE 1547
Clauses 4.1.4.2 Distribution Secondary Spot Networks and Clauses 4.1.8.1 or 5.1.3.1, which
address Protection from Electromagnetic Interference. Rule 27 does not adopt the Generating
Facility power limitation of 10 MW incorporated in IEEE1547.
a. Protective Functions Required. Smart Inverters operating in parallel with CPAU’s
Distribution System shall be equipped with the following Protective Functions to
sense abnormal conditions on CPAU’s Distribution System and cause the Smart
Inverter to be automatically disconnected from CPAU’s Distribution System or to
prevent the Smart Inverter from being connected to CPAU’s Distribution System
inappropriately:
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 22
i. Over and under voltage trip functions and over and under frequency trip
functions;
ii. A voltage and frequency sensing and time-delay function to prevent the Smart
Inverter from energizing a de-energized Distribution System circuit and to
prevent the Smart Inverter from reconnecting with CPAU’s System unless
CPAU’s Distribution System service voltage and frequency is within the
ANSI C84.1-1995 Table 1 Range B voltage Range of 106 volts to 127 volts
(on a 120 volt basis), inclusive, and a frequency range of 59.3 Hz to 60.5 Hz,
inclusive, and are stable for at least 15 seconds; and
iii. A function to prevent the Smart Inverter from contributing to the formation of
an Unintended Island, and cease to energize CPAU’s Distribution System
within two seconds of the formation of an Unintended Island.
iv. Only Certified Smart Inverters are approved for interconnection. Smart
Inverters or a group of Smart Inverters > 400 kW require Ground Fault
Protection.
The Smart Inverter shall cease to energize CPAU’s Distribution System for
faults on CPAU’s Distribution System circuit to which it is connected (IEEE
1547-4.2.1). The Smart Inverter shall cease to energize CPAU’s Distribution
circuit prior to reclosing by CPAU’s Distribution System equipment (IEEE
1547-4.2.2).
b. Momentary Paralleling Generating Facilities. With CPAU’s approval, the transfer
switch or scheme used to transfer Producer’s loads from CPAU’s Distribution
System to Producer’s Generating Facility may be used in lieu of the Protective
Functions required for Parallel Operation.
c. Suitable Equipment Required. Circuit breakers or other interrupting equipment
located at the PCC must be Certified or “Listed” (as defined in Article 100, the
Definitions Section of the National Electrical Code) as suitable for their intended
application. This includes being capable of interrupting the maximum available fault
current expected at their location. Producer’s Smart Inverter and Interconnection
Facilities shall be designed so that the failure of any single device or component shall
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 23
not potentially compromise the safety and reliability of CPAU’s Distribution System.
The Smart Inverter paralleling-device shall be capable of withstanding 220% of the
Interconnection Facility rated voltage (IEEE 1547- 4.1.8.3). The Interconnection
Facility shall have the capability to withstand voltage and current surges in
accordance with the environments defined in IEEE Std. C62.41.2-2002 or IEEE Std.
C37.90.1-2002 as applicable and as described in L.3.e (IEEE 1547- 4.1.8.2).
d. Visible Disconnect Required. Producer shall furnish and install a ganged, manually-
operated isolating switch (or a comparable device mutually agreed upon by CPAU
and Producer) near the Point of Common Coupling to isolate the Smart Inverter from
CPAU’s Distribution System. The device does not have to provide over-current
protection.
The device must:
i. Allow visible verification that separation has been accomplished. (This
requirement may be met by opening the enclosure to observe contact
separation.) Molded case circuit breakers do not meet the visible contact
requirement and are not acceptable as a Visible Disconnect device.
ii. Include markings or signage that clearly indicates open and closed positions.
iii. Be capable of being reached quickly and conveniently 24 hours a day by
CPAU personnel for construction, maintenance, inspection, testing or
reading, without obstacles or requiring those seeking access to obtain keys,
special permission, or security clearances.
iv. Be capable of being locked in the open position.
v. Be clearly marked on the submitted single line diagram and its type and
location approved by CPAU prior to installation. If the device is not adjacent
to the PCC, permanent signage must be installed at a CPAU approved
location providing a clear description of the location of the device. If the
switch is not accessible outside the locked premises, signage with contact
information and a CPAU approved locking device for the premises shall be
installed. Generating Facilities with Non-Islanding inverters totaling one (1)
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 24
kilovolt-ampere (kVA) or less are exempt from this requirement.
e. Drawings Required. Prior to Parallel Operation or Momentary Parallel Operation of
the Smart Inverter, CPAU shall approve Producer’s Protective Function and control
diagrams. Generating Facilities equipped with Protective Functions and a control
scheme previously approved by CPAU for system-wide application or only
Certified Equipment may satisfy this requirement by reference to previously
approved drawings and diagrams.
f. Generating Facility Conditions Not Identified. In the event this Rule does not address
the Interconnection conditions for a particular Smart Inverter, CPAU and Producer
may agree upon other arrangements, to be approved by CPAU.
g. Prevention of Interference. Producer shall not operate Smart Inverters that
superimpose a voltage or current upon CPAU’s Distribution System that interferes
with CPAU operations, service to CPAU Customers or communication facilities. If
such interference occurs, Producer must diligently pursue and take corrective action
at its own expense after being given notice and reasonable time to do so by CPAU. If
Producer does not take corrective action in a timely manner, or continues to operate
the facilities causing interference without restriction or limit, CPAU may, without
liability, disconnect Producer's facilities from CPAU’s Distribution System, in
accordance with Section B.8 of this Rule.
h. Voltage Regulation. If approved by CPAU, the Smart Inverter may actively regulate
the voltage at the Point of Common Coupling (PCC) while in parallel with CPAU’s
Distribution System. The Smart Inverter shall not cause the service voltage at other
customers to go outside the requirements of ANSI C84.1-1995, Range A (IEEE
1547-4.1.1).
i. Voltage Trip and Ride-Through Settings. The voltage ranges in Table D.4 define
protective trip limits for the Protective Function and are not intended to define or
imply a voltage regulation Function. Generating Facilities shall cease to energize
CPAU’s Distribution System within the prescribed trip time whenever the voltage at
the PCC deviates from the allowable voltage operating range. The Protection
Function shall detect and respond to voltage on all phases to which the Generating
Facility is connected.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 25
j. Smart Inverters. Smart Inverters shall be capable of operating within the voltage
range normally experienced on CPAU’s Distribution System from plus to minus 5%
of the nominal voltage (e.g. 114 volts to 126 volts, on a 120 volt base), at the service
panel or PCC. The trip settings at the generator terminals may be selected in a
manner that minimizes nuisance tripping in accordance with Table D.4 to
compensate for voltage drop between the generator terminals and the PCC. Voltage
may be detected at either the PCC or the Point of Interconnection. However, the
voltage range at the PCC, with the generator on-line, shall stay within +/-5% of
nominal.
k. Voltage Disturbances. Whenever CPAU’s Distribution System voltage at the PCC
varies from and remains outside Near Nominal voltage for the predetermined
parameters set forth in Table D.4, the Smart Inverter’s Protective Functions shall
cause the Smart Inverter(s) to become isolated from CPAU’s Distribution System:
i. The Smart Inverter shall stay connected to CPAU’s Distribution System
while the grid remains within the “Ride-Through Until” voltage-time range
and must stay connected in the corresponding “Operating Mode”.
ii. For voltage excursions beyond the near Nominal (NN) magnitude range and
within the range of the HV1 or LV3 regions, the Smart Inverter shall
momentarily cease to energize within 0.16 seconds.
iii. In the HV1 region, the Smart Inverter is permitted to reduce power output as
a function of voltage under mutual agreement between the Producer and
CPAU.
iv. If the distribution system voltage does not exit the ride-through region and
recovers to normal system voltage, the Smart Inverter shall restore continuous
operation within 2 seconds.
v. If the CPAU’s Distribution System voltage does not exit the ride-through
region and returns from the LV3 region to the LV2 or LV1 region, the Smart
Inverter shall restore available current within 2 seconds.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 26
vi. Different voltage-time settings could be permitted by CPAU.
Table D.4: Voltage Ride-Through Table
Region Voltage at Point
of Common
Coupling (%
Nominal Volts)
Ride-Through
Until
Operating Mode Maximum Trip
Time
High Voltage 2
(HV2)
V > 120 0.16 seconds
High Voltage 1
(HV1)
110 < V < 120 12 seconds Momentary
Cessation
13 seconds
Near Nominal
(NN)
88 < V < 110 Indefinite Continuous
Operation
Not Applicable
Low Voltage 1
(LV1)
70 < V < 88 20 seconds Mandatory
Operation
21 seconds
Low Voltage 2
(LV2)
50 < V < 70 10 seconds Mandatory
Operation
11 seconds
Low Voltage 3
(LV3)
V < 50 1 second Momentary
Cessation
1.5 seconds
l. Paralleling. The Generating Facility shall parallel with CPAU’s Distribution System
without causing a voltage fluctuation at the PCC greater than plus/minus 5% of the
prevailing voltage level of CPAU’s Distribution System at the PCC, and meet the
flicker requirements of Section D.5.m below.
m. Flicker. The Generating Facility shall not create objectionable flicker for other
customers on CPAU’s Distribution System. To minimize the adverse voltage effects
experienced by other customers (IEEE 1547-4.3.2), flicker at the PCC caused by the
Generating Facility should not exceed the limits defined by the "Maximum
Borderline of Irritation Curve" identified in IEEE 519-1992 (IEEE Recommended
Practices and Requirements for Harmonic Control in Electric Power Systems, IEEE
STD 519-1992). This requirement is necessary to minimize the adverse voltage
affects experienced by other Customers on CPAU’s Distribution System. Generators
may be connected and brought up to synchronous speed (as an induction motor)
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 27
provided these flicker limits are not exceeded.
n. Integration with CPAU’s Distribution System Grounding. The grounding scheme of
the Generating Facility shall not cause over-voltages that exceed the rating of the
equipment connected to CPAU’s Distribution System and shall not disrupt the
coordination of the ground fault protection on CPAU’s Distribution System (IEEE
1547-4.1.2).
o. Frequency. CPAU controls system frequency, and the Generating Facility shall
operate in synchronism with CPAU’s Distribution System. Whenever CPAU’s
Distribution System frequency at the PCC varies from and remains outside normal
(nominally 60 Hz) by the predetermined amounts set forth in Table D.2, the
Generating Facility’s Protective Functions shall cease to energize CPAU’s
Distribution System within the stated maximum trip time.
p. Frequency Ride-Through Requirements. Smart Inverter based systems shall remain
connected to CPAU’s Distribution System while the grid is within the frequency-time
range indicated in Table D.5, and shall disconnect from the electric grid during a high
or low frequency event that is outside that frequency-time range. The frequency
values are shown in Table D.5. These values provide default interconnection system
response to abnormal frequencies. The inverter shall disconnect by the default
clearing times. In the high frequency range between 60.2 Hz and 61.5 Hz, or some
other mutually agreed range, the Smart Inverter is permitted to reduce real power
output until it ceases to export power by 61.5 Hz, or other frequency value mutually
agreed between the generating facility operator and CPAU. Islands and microgrids
may need different default frequency settings.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 28
Table D.5: Frequency Ride-Through and Trip Settings Table
System
Frequency
Default Settings
(Hz)
Minimum Range
of Adjustability
(Hz)
Ride-Through
Until
Ride –Through
Operational
Mode
Maximum Trip
Time
f > 62 62 – 64 No Ride Through Not Applicable 0.16 seconds
60.5 < f < 62 60.1 – 62 299 seconds Mandatory
Operation
300 seconds
58.5 < f < 60.5 Not Applicable Indefinite Continuous
Operation
Not Applicable
57.0 < f < 58.5 57 – 59.9 299 seconds Mandatory
Operation
300 seconds
f < 57.0 53 – 57 No Ride Through Not Applicable 0.16 seconds
q. Harmonics. When the Smart Inverter is serving balanced linear loads, harmonic
current injection into CPAU’s Distribution System at the PCC shall not exceed the
limits stated in Table D.3. The harmonic current injections shall be exclusive of any
harmonic currents due to harmonic voltage distortion present in
CPAU’s Distribution System without the Smart Inverter connected (IEEE 1547-
4.3.3.). The harmonic distortion of a Smart Inverter shall be evaluated using the same
criteria as for the Host Loads.
r. Direct Current Injection. Smart Inverter should not inject direct current greater than
0.5% of rated output current into CPAU’s Distribution System.
s. Power Factor. Producer shall provide adequate reactive power compensation on site
to maintain the Smart Inverter power factor near unity at rated output or a CPAU
specified power factor in accordance with the following requirements:
i. Default Power Factor setting: 1.0 +/- 0.01 (0.99 Lagging to 0.99 Leading).
ii. Aggregate generating facility is greater than 15 kW: 1.0 +/- 0.15 (0.85
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 29
Lagging to 0.85 Leading) down to 20% rated power based on available
reactive power.
iii. Aggregate generating facility is less than or equal to 15 kW: 1.0 +/- 0.10
(0.90 Lagging to 0.90 Leading) down to 20% rated power based on available
reactive power.
t. Dynamic Volt/VAR Operations. The Smart Inverter shall be capable of operating
dynamically within a power factor range of +/- 0.85 PF for larger (>15 kW) systems,
down to 20% of rated power, and +/- 0.9 PF for smaller systems (≤15 kW), down to
20% of rated power, based on available reactive power. This dynamic Volt/VAR
capability shall be able to be activated or deactivated in accordance with CPAU
requirements.
CPAU may permit or require the Smart Inverter systems to operate in larger power
factor ranges, including in 4-quadrant operations for storage systems with the
implementation of additional anti-islanding protection as determined by CPAU.
The Smart Inverter shall be capable of providing dynamic reactive power
compensation (dynamic Volt/VAR operation) within the following constraints:
The Smart Inverter shall not cause the line voltage at the point of common
coupling to go outside the requirements of the latest version of ANSI C84.1,
Range A.
The Smart Inverter shall be able to consume reactive power in response to an
increase in line voltage, and produce reactive power in response to a decrease
in line voltage.
The reactive power provided shall be based on available reactive power, but
the maximum reactive power provided to the system shall be as directed by
CPAU.
u. Ramp Rate Requirements. The Smart Inverter is required to have the following ramp
controls for at least the following two conditions. These functions can be established
by multiple control functions or by one general ramp rate control function. Ramp
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 30
rates are contingent upon sufficient energy available from the Smart Inverter.
Normal ramp-up rate: For transitions between energy output levels over the
normal course of operation. The default value is 100% of maximum current
output per second with a range of adjustment between 1% to 100%, with
specific settings as mutually agreed by the CPAU and the Producer.
Connect/Reconnect Ramp-up rate: Upon starting to inject power into the grid,
following a period of inactivity or a disconnection, the inverter shall be able
to control its rate of increase of power from 1 to 100% maximum current per
second, with specific settings as mutually agreed upon by CPAU and the
Producer.
v. Default Activation States for Phase 1 Functions. Unless otherwise provided by
CPAU, the default settings will be as follows:
Anti-islanding – activated
Low/High Voltage Ride-Through – activated
Low/High Frequency Ride-Through – activated
Dynamic Volt/VAR operations – deactivated
Ramp rates – activated
Fixed power factor – activated
Reconnect by “soft-start” methods – activated
These default activation states may be modified by mutual agreement between CPAU
and Producer.
w. Automatic Transfer (Load Shedding or Transfer). The voltage and frequency ride-
through requirements of D.5.i and D.5.m shall not apply if either: a) The real power
across the Point of Common Coupling is continuously maintained at a value less than
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 31
10% of the aggregate rating of the Smart Inverters connected to the Generation
Facility prior to any voltage disturbance, and the Generation Facility disconnects
from CPAU’s distribution system, along with Generation Facility load, such that the
net change in real power flow from or to CPAU is less than 10% of the aggregate
Smart Inverter capacity; or b) Generation Facility load real power demand equal to
90% to 120% of the pre-disturbance aggregate Smart Inverter real power output is
shed within 0.1 seconds of Smart Inverter disconnection.
x. Fault Detection. A Smart Inverter with an SCCR exceeding 0.1 or one that does not
cease to energize CPAU’s Distribution System within two seconds of the formation
of an Unintended Island shall be equipped with Protective Functions designed to
detect Distribution System faults, both line-to-line and line-to-ground, and cease to
energize CPAU’s Distribution System within two seconds of the initiation of a fault.
y. Transfer Trip. For a Generating Facility that cannot detect Distribution System faults
(both line-to-line and line-to-ground) or the formation of an Unintended Island, and
cease to energize CPAU’s Distribution System within two seconds, CPAU may
require a Transfer Trip system or an equivalent Protective Function.
z. Reclose Blocking. Where the aggregate Generating Facility capacity exceeds 15% of
the peak load on any automatic reclosing device, CPAU may require additional
Protective Functions, including, but not limited to reclose-blocking on some of the
automatic reclosing devices.
E. INTERCONNECTION FACILITIES AND DISTRIBUTION SYSTEM
MODIFICATIONS OWNERSHIP AND COST ALLOCATION
1. SCOPE AND OWNERSHIP OF INTERCONNECTION FACILITIES AND
DISTRIBUTION SYSTEM MODIFICATIONS
a. Scope. Parallel Operation of Generating Facilities may require Interconnection
Facilities or modifications to CPAU’s Distribution System (“Distribution System
modifications”). The type, extent and costs of Interconnection Facilities and
Distribution System modifications shall be consistent with this Rule and determined
through the Supplemental Review and/or Interconnection Studies described in
Section C.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 32
b. Ownership. Interconnection Facilities installed on Producer’s side of the PCC may
be owned, operated and maintained by the Producer or CPAU. Interconnection
Facilities installed on CPAU’s side of the PCC and Distribution System
modifications shall be owned, operated and maintained only by CPAU.
2. RESPONSIBILITY OF COSTS OF INTERCONNECTING A GENERATING
FACILITY
a. Study and Review Costs. A Producer shall be responsible for the reasonably incurred
costs of the reviews and studies conducted pursuant to Section C.1 of this Rule.
b. Facility Costs. A Producer shall be responsible for all costs associated with
Interconnection Facilities owned by the Producer. The Producer shall also be
responsible for any costs reasonably incurred by CPAU in providing, operating, or
maintaining the Interconnection Facilities and Distribution System modifications
required for the Interconnection of the Producer’s Generating Facility with CPAU’s
Distribution System.
c. Separation of Costs. Should CPAU combine the installation of Interconnection
Facilities or Distribution System modifications required for the Interconnection of a
Generating Facility with modifications to CPAU’s Distribution System to serve other
Customers or Producers, CPAU shall not include the costs of such separate or
incremental facilities in the amounts billed to the Producer.
d. Payments. The Producer must pay applicable costs prior to the scheduling of any
engineering reviews and studies; construction of distribution system modifications; or
interconnection of generating facilities to CPAU’s Distribution System.
3. INSTALLATION AND FINANCING OF INTERCONNECTION FACILITIES AND
DISTRIBUTION SYSTEM MODIFICATIONS
a. Agreement Required. The costs for Interconnection Facilities and Distribution
System modifications shall be paid by the Producer pursuant to the Provisions
contained in the Special Facilities Agreement. Where the type and extent of the
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 33
Interconnection Facilities or Distribution System modifications warrant additional
detail, Producer and CPAU shall execute separate agreement(s) to more fully
describe and allocate the parties’ responsibilities for installing, owning, operating and
maintaining the Interconnection Facilities and Distribution System modifications.
b. Interconnection Facilities and Distribution System Modifications. Interconnection
Facilities connected to CPAU’s side of the Point of Common Coupling and
Distribution System modifications shall be provided, installed, owned and
maintained by CPAU at Producer’s expense.
c. Reservation of Unused Facilities. When a Producer wishes to reserve CPAU-owned
Interconnection Facilities or Distribution System modifications installed and operated
as Special Facilities for the Producer at Producer’s expense, but idled by a change in
the operation of the Producer's Generating Facility or otherwise, Producer may elect
to abandon or reserve such facilities consistent with the terms of its agreement with
CPAU. If Producer elects to reserve idle Interconnection Facilities or Distribution
System modifications, CPAU shall be entitled to continue to Charge Producer for the
costs related to the ongoing operation and maintenance of the Special Facilities.
d. Refund of Salvage Value. When a Producer elects to abandon the Special Facilities
for which it has either advanced the installed costs or constructed and transferred to
CPAU, the Producer shall not receive a credit for the net salvage value of the Special
Facilities.
F. METERING, MONITORING AND TELEMETRY
1. GENERAL REQUIREMENTS
All Generating Facilities shall be metered in accordance with this Section F and shall
meet all applicable standards of CPAU contained in CPAU’s applicable rules and
published CPAU manuals dealing with Metering specifications. For general metering
requirements, see CPAU Rule and Regulation 15. For net metering requirements, see
CPAU Rule and Regulation 29.
2. METERING BY CPAU
The ownership, installation, operation, reading and testing of revenue Metering Equipment
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 34
for Generating Facilities shall be by CPAU only.
3. NET GENERATION METERING
For purposes of monitoring Generating Facility operation to determine standby Charges and
applicable non-bypassable Charges as defined in CPAU’s tariffs, and for Distribution System
planning and operations, consistent with Section B.4 of this Rule, CPAU shall have the right
to specify the type, and require the installation of Net Generation Metering equipment.
CPAU shall only require Net Generation Metering to the extent that less intrusive and/or
more cost effective options for providing the necessary Generating Facility output data are
not available. In exercising its discretion to require Net Generation Metering, CPAU shall
consider all relevant factors, including but not limited to:
a. Data requirements in proportion to need for information;
b. Producer’s election to install equipment that adequately addresses CPAU’s
operational requirements;
c. Accuracy and type of required Metering consistent with purposes of collecting data;
d. Cost of Metering relative to the need for and accuracy of the data;
e. The Generating Facility’s size relative to the cost of the Metering/monitoring;
f. Other means of obtaining the data (e.g., Generating Facility logs, proxy data etc.);
and
g. Requirements under any Interconnection Agreement with the Producer.
4. POINT OF COMMON COUPLING METERING
For purposes of assessing CPAU Charges for retail service, the Producer’s PCC Metering
shall be reviewed by CPAU, and if required, replaced to ensure that it will appropriately
measure Electric power according to the Provisions of the Customer’s Electric Service tariff.
Where required, the Customer’s existing Meter may be replaced with a bi-directional meter
so that power deliveries to and from the Producer’s site can be separately recorded.
Alternately, the Producer may, at its sole option and cost, require CPAU to install Multi-
Metering Equipment to separately record power deliveries to CPAU’s Distribution System
and retail purchases from CPAU. Where necessary, such PCC Metering shall be designed to
prevent reverse registration.
5. TELEMETERING
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 12-12-2016
Sheet No. 35
If the nameplate rating of the Generating Facility is 1 MW or greater, telemetering equipment
at the Net Generator Metering location may be required at the Producer's expense. If the
Generating Facility is interconnected to a portion of CPAU’s Distribution System operating
at a voltage below 10 kV, then Telemetering equipment may be required on Generating
Facilities 250 kW or greater. CPAU shall only require Telemetering to the extent that less
intrusive and/or more cost effective options for providing the necessary data in real time are
not available
6. LOCATION
Where CPAU-owned Metering is located on the Producer’s Premises, Producer shall
provide, at no expense to CPAU, a suitable location for all such Metering Equipment as set
forth in CPAU Rule and Regulation 15.
7. COSTS OF METERING
The Producer will bear all costs of the Metering required by this Rule, including the
incremental costs of operating and maintaining the Metering Equipment.
(END)
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 12
TABLE OF CONTENTS:
A. APPLICABILITY ......................................................................................................................................................... 2
B. GENERAL RULES, RIGHTS AND OBLIGATIONS ................................................................................................. 2
C. APPLICATION AND INTERCONNECTION PROCESS......................................................................................... 65
1. APPLICATION PROCESS .......................................................................................................................... 65
2. OVERVIEW OF THE INTERCONNECTION REVIEW PROCESS.......................................................... 75
3. COMMISSIONING TESTING AND PARALLEL OPERATION .......................................................... 1510
4. WITHDRAWAL / CANCELLATION ..................................................................................................... 1711
D. GENERATING FACILITY DESIGN AND OPERATING REQUIREMENTS .................................................... 1811
1. GENERAL INTERCONNECTION AND PROTECTION FUNCTION REQUIREMENTS .............. 181112
2. PREVENTION OF INTERFERENCE ..................................................................................................... 2114
3. TECHNOLOGY SPECIFIC REQUIREMENTS ...................................................................................... 2819
4. SUPPLEMENTAL GENERATING FACILITY REQUIREMENTS ...................................................... 3020
5. SMART INVERTER GENERATING FACILITY DESIGN AND OPERATING REQUIREMENTS .. 3221
E. INTERCONNECTION FACILITIES AND DISTRIBUTION SYSTEM MODIFICATIONS OWNERSHIP AND
COST ALLOCATION ............................................................................................................................................ 4231
1. SCOPE AND OWNERSHIP OF INTERCONNECTION FACILITIES AND DISTRIBUTION SYSTEM
MODIFICATIONS ................................................................................................................................... 4231
2. RESPONSIBILITY OF COSTS OF INTERCONNECTING A GENERATING FACILITY ............. 423132
3. INSTALLATION AND FINANCING OF INTERCONNECTION FACILITIES AND DISTRIBUTION
SYSTEM MODIFICATIONS ............................................................................................................... 443233
F. METERING, MONITORING AND TELEMETRY ............................................................................................... 4533
1. GENERAL REQUIREMENTS ................................................................................................................ 4533
2. METERING BY CPAU ........................................................................................................................ 453334
3. NET GENERATION METERING ....................................................................................................... 453334
4. POINT OF COMMON COUPLING METERING ................................................................................... 4634
5. TELEMETERING ................................................................................................................................ 463435
6. LOCATION .............................................................................................................................................. 4635
7. COSTS OF METERING ........................................................................................................................... 4735
ATTACHMENT C
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 22
A. APPLICABILITY
This Rule describes the Interconnection, Operating and Metering and operating requirements for
Generating Facilities to be connected to the City of Palo Alto Utilities (CPAU) Electric
Distribution System. Subject to the requirements of this Rule, CPAU will allow the
Interconnection of Generating Facilities with its Distribution System.
In order to provide for uniformity and to encourage the Interconnection of renewable energy
generation, this Rule has been writtenis intended to be generally consistent with the technical
requirements of CPUCCalifornia Public Utilities Commission Rule 21 and IEEE 1547, as
amended.
Language from IEEE 1547 that has been adopted directly (as opposed to paraphrased language
or previous language that was determined to be consistent with IEEE 1547) is followed by a
citation that lists the clause from which the language derived. For example, IEEE 1547-4.1.1 is a
reference to Clause 4.1.1.
In the event of any conflict between this Rule and any of the CPUC Rule 21 and IEEE 1547
standards listed herein, the requirements of this Rule shall take precedence.
B. GENERAL RULES, RIGHTS AND OBLIGATIONS
1. Prior Authorization Required to Interconnect and Operate. A Producer must comply with
this Rule, execute anAn executed Interconnection Agreement or, if a Producer is a
customer-generator, as that term is used in Rule and Regulation 29, a Net Energy
Metering and Interconnection Agreement with CPAU, and receive, as applicable, is
required in addition to receiving CPAU’s express written permission before Parallel
Operation of itsa Generating Facility with CPAU’s Distribution System. CPAU shall
apply this Rule in a non-discriminatory manner and shall not unreasonably withhold its
permission for Parallel Operation of Producer’s Generating FacilityFacilities with
CPAU’s Distribution System.
2. Separate Agreements Required for Other Services. A Producer requiringSeparate
Agreements are required for the provision of other Electric Services from CPAU
including, but not limited to, Distribution Service provided by CPAU during periods of
Curtailment or interruption of the Producer’sa Generating Facility, will enter into
agreements with CPAU for such Services in accordance with CPAU’s Rules &
Regulations and Utility Rates.
3. Service Not Provided With Interconnection. Interconnection with CPAU's Distribution
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 32
System under this Rule does not provide a Producer anyprovides no rights to utilize
CPAU's Distribution System for the transmission, distribution, or wheeling of
Electricelectric power.
4. Compliance Withwith Laws, Rules & Regulations and Utility Rates. A
ProducerApplicants shall ascertain and comply with applicable CPAU Rules &
Regulations and Utility Rates; applicable Federal Energy Regulatory Commission
(FERC) approved rules, tariffs and regulations; and any local, state or federal Law,
statute or regulation which applies to the design, siting, construction, installation,
operation, or any other aspect of the Producer’sApplicant’s Generating Facility and
Interconnection Facilities.
5. Design Reviews and Inspections. CPAU shall havehas the right to review the design of a
Producer’san Applicant’s Generating Facility and Interconnection Facilities and to
inspect a Producer’sthe Generating Facility and/or Interconnection Facilities prior to the
commencement of Parallel Operation with CPAU’s Distribution System. CPAU may
require a ProducerApplicants to make modifications as necessary to comply with the
requirements of this RuleCPAU Rules and Regulations or other reasonable requirements.
CPAU’s review and authorization for Parallel Operation shall not be construed as
confirming or endorsing the Producer’sApplicant’s design or as warranting the
Generating Facility and/or Interconnection Facilities’ safety, durability or reliability.
CPAU shallis not, by reason of such review or lack of review, be responsible for the
adequacy or capacity of such equipmentFacilities.
6. Right to Access. A Producer’sCustomer Generating Facility and Interconnection
Facilities shall be accessible to CPAU personnel whenever necessary for CPAU to
perform its duties and exercise its rights under its Rules &and Regulations and Utility
Rates and any Interconnection Agreement, including the Net Energy Metering and
Interconnection Agreement, between CPAU and the Producer.
7. Confidentiality of Information. Any information pertaining to Generating Facility and/or
Interconnection Facilities provided to CPAU by a Producer shall be treated by CPAU in a
confidential manner. CPAU shall not use information contained in the Application to
propose discounted rates to the Customer unless authorized to do so by the Customer or
the information is provided to CPAU by the Customer through other means.
7. 8. Prudent Operation and Maintenance Required. A ProducerThe Customer shall
operate and maintain its Generating Facility and Interconnection Facilities in accordance
with Prudent Electrical Practices and shall maintain compliance with this RuleCPAU
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 42
Rules and Regulations.
9. Curtailment and Disconnection. CPAU may limit the operation or, disconnect or require
the disconnection of a Producer’sCustomer’s Generating Facility from CPAU’s
Distribution System at any time, with or without notice, in the event of an Emergency, or
to correct Unsafe Operating Conditions. CPAU may also limit the operation or,
disconnect or require the disconnection of
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 5
8. a Producer’sCustomer’s Generating Facility from CPAU’s Distribution System upon the
Provision ofwith reasonable written notice: (1) to allow for routine maintenance, repairs
or modifications to CPAU’s Distribution System; (2) upon CPAU’s determination that a
Producer’sCustomer’s Generating Facility is not in compliance with this Ruleany CPAU
Rules and Regulations; or (3) upon termination of the applicable Interconnection
Agreement or the Net Energy Metering and Interconnection Agreement. Upon the
Producer’sWithin a reasonable period after the Customer’s written request, CPAU
shallwill provide a written explanation of the reason for such Curtailment or
disconnection.
9. Coordination with Affected Systems. CPAU will notify the Affected System Operators
that are potentially affected by an Applicant’s Interconnection Request(s). CPAU will
coordinate the conduct of any studies required to determine the impact of the
Interconnection Request on Affected Systems with Affected System Operators and, if
possible, include those results in its Interconnection Study. CPAU will invite such
Affected System Operators to all meetings held with Applicant as required by this Rule.
Applicants and transmission providers which may be an Affected System shall cooperate
with CPAU in all matters related to the conduct of relevant studies and the determination
of modifications to Affected Systems. Applicant shall enter into an agreement with the
owner of the Affected System, as applicable and upon request by CPAU. The agreement
will specify the terms governing payments to be made by Applicant to the owner of the
Affected System as well as the repayment, if applicable, by the owner of the Affected
System.
10. Transferability of Interconnection Request. An Applicant may transfer its Interconnection
Request to another entity only if such entity acquires the proposed Generating Facility
identified in the Interconnection Request and the Point of Interconnection and operating
parameters do not change. CPAU at its discretion may deny such requests if CPAU
determines applicable requirements will not be met as a result of the transfer.
11. Special Provisions Applicable to Net Energy Metering Applicants (NEM).
Notwithstanding any other provision in this Rule:
a. For Generating Facilities qualifying for service under PUC Sections 2827, 2827.8
and 2827.10, as amended, the Applicant is not responsible for payment of study
costs.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 6
b. For Generating Facilities qualifying for service under PUC Sections 2827 and
2827.8, as amended, CPAU’s approval for Interconnection will normally be
processed not later than thirty (30) Business Days following CPAU’s receipt of:
i. a completed Net Energy Metering Interconnection Request including all
supporting documents and required payments;
ii. a completed signed Net Energy Metering Generator Interconnection
Agreement; and
iii. evidence of Applicant’s final electric inspection clearance from the Palo
Alto Building Department.
If the 30-day period cannot be met, CPAU will notify Applicant of the reason for
the inability to process the Interconnection Request and the expected completion
date.
Applicants with PUC Section 2827 Generating Facilities that include non-inverter
based Generators and/or Generators with non-Certified Equipment should submit
a completed Net Energy Metering Interconnection Request, including all
supporting documents sufficient for CPAU to start the review process, without
waiting for the final inspection clearance. Applicants with such Generating
Facilities are advised to submit their Interconnection Request at least six (6)
months in advance of their planned Commercial Operation Date. Depending on
the size and location of these Generating Facilities, additional time for review and
study may be required.
C. APPLICATION AND INTERCONNECTION PROCESS
1. APPLICATION PROCESS
a. a. Applicant initiates contact with CPAU. Upon request, CPAU will provide
information and documents (such as sample agreements, Load Sheets, technical
information, listing of Certified Equipment, applicable Rate Schedules and
Metering requirements) to a potential Applicant. Unless otherwise agreed upon,
all such information shall normally be sent to the Applicant within three
(3) Business Days following the initial request from the Applicant.a. Utility
Service Application (Application).
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 7
b. Applicant Completes a Load Sheet. All Applicants shallmust complete and
submit a Load Sheetthe Application and three (3) sets of plan drawings for
review. Load Sheets and plans may be dropped off at the Development Center
located at 285 Hamilton Avenue, or Utilities Engineering at 1007 Elwell Court..
1. CPAU shall complete the Initial Review, absent any extraordinary
circumstances, within 10 Business Days of receiving the Load Sheet and
plans. If defects are noted, CPAU and Applicant shall cooperate to
establish a satisfactory Application.
2. Applications that are over one year old (from the date of CPAU’s
acknowledgement) without a signed Interconnection Agreement or Net
Energy Metering and Interconnection Agreement, or a Generating Facility
that has not been approved for Parallel Operation within one year of
completion of all applicable review and/or studies are subject to
cancellation by CPAU; however, CPAU may not cancel an Application if
the Producer provides reasonable evidence that the project is still active.
c. CPAU Performs an Initial and Supplemental Review and Develops Preliminary
Cost Estimates and Interconnection Requirements.
2. 1. UPON RECEIPT OF A SATISFACTORILY COMPLETED
APPLICATION AND ANY ADDITIONAL INFORMATION NECESSARY TO
EVALUATE THE INTERCONNECTION OF A GENERATING
FACILITYOVERVIEW OF THE INTERCONNECTION REVIEW PROCESS
a. Valid Interconnection Request. After an Application is received and deemed
complete and valid, CPAU will start the interconnection review process. See
Section B.11 for special provisions related to the timeframe and costs applicable
to NEM Applicants.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 8
a.b. Initial Review. Upon receipt of a complete and valid Application and plans,
CPAU shall perform an Initial Review using the process defined in Section G. .
The Initial Review determines if: (a) (i) the Generating Facility qualifies for a
Simplified Interconnection;, or (bii) the Generating Facility requires a
Supplemental Review. Absent extraordinary circumstances, CPAU shall notify
Applicant in writing of the results of Initial Review within ten (10) Business Days
following validation of an Interconnection Request.
2. CPAU shall complete its Passage of Initial Review, absent any
extraordinary circumstances, within 10 Business Days after receipt of a
completed Application including Load Sheet and plan drawings. If the
Initial Review determines the proposed Generating Facility can be
Interconnected by means of a Simplified. For Interconnection, CPAU will
provide the Applicant with an Interconnection Agreement for Applicant’s
signature.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 9
3. If the Generating Facility does not Requests that pass the Initial Review
for Simplifiedand do not require Interconnection as proposedFacilities or
Distribution Upgrades, CPAU will notifyprovide the Applicant and performwith a
Supplemental Review. Applicant shall pay the applicable Advance Engineering
Fee described in Rate Schedule E-15 unless the Application is withdrawn. The
Supplemental Review will result in CPAU providing either: (a)Generator
Interconnection requirements beyond those for a Simplified Interconnection, and
anAgreement or Generator Interconnection Agreement or theand Net Energy
Metering and Interconnection Agreement for Applicant’s signature; or (b) a cost
estimate and schedule for an Interconnection Study. The Supplemental Review
shall be completed, absent any extraordinary circumstances, within 20 Business
Days of receipt of a completed Application and fees. The Interconnection Study
may require additional fees and more time to complete, depending on the
complexity of the project to be studied. If the Supplemental Review determines
that new or modified Utility-owned distribution and/or protection facilities are
required, the Applicant will be charged the estimated cost of any Utility-owned
facilities determined to be required by the Review. These facilities will be treated
as Special Facilities for the purpose of determining Applicant costs. , if
applicable, within fifteen (15) Business Days of providing notice of Initial Review
results. For Interconnection Requests
d. When Required, Applicant and CPAU Commit to Additional Interconnection
Study Steps.
When a Supplemental Review reveals that the proposed Generating Facility
cannot be Interconnected to CPAU’s Distribution System by means of a
Simplified Interconnection, or that significantpass the Initial Review but also
require Interconnection Facilities installed on CPAU’s system or Distribution
System modifications will be needed to accommodate an Applicant’s Generating
Facility, CPAU and Applicant shall enter into an agreement that provides for
CPAU to perform additional studies, facility design and engineering, and to
provide an estimate for actual cost billing to the Applicant, at the Applicant’s
expense (the Advanced Engineering Fee). The Interconnection Study agreement
shall set forth CPAU’s estimated schedule and Charges for completing such work.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 10
2. INTERCONNECTION PROCESS
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 11
i. a. Applicant and CPAU enter into an Interconnection Agreement or a
New Energy Metering and Interconnection Agreement and, where
required, a Special Facilities Agreement forupgrades, CPAU will provide
Applicant with a non-binding cost estimate of the Interconnection
Facilities or Distribution System Modifications. upgrades within thirty
(30) Business Days of providing notice of Initial Review results. These
facilities may be treated as Special Facilities (depending on circumstance)
for the purpose of determining Applicant costs. The applicant can then
proceed with executing an Interconnection Agreement in accordance with
Section C.1.e below.
ii. Failure of Initial Review. For Interconnection Requests that fail Initial
Review, CPAU shallwill provide the technical reason, data and analysis
supporting the Initial Review results in writing and provide Applicant the
option to proceed directly to a Supplemental Review. The Applicant shall
notify CPAU within ten (10) Business Days following such notification
whether to (i) proceed to a Supplemental Review, or (ii) withdraw the
Interconnection Request. Applicants that elect to proceed to a
Supplemental Review shall provide a nonrefundable Advance Engineering
Fee set forth in Rate Schedule E-15 with their response. CPAU will
proceed with the Supplemental Review once payment of the required
Advance Engineering Fee has been received. If Applicant fails to notify
CPAU within ten (10) Business Days of such notification, the
Interconnection Request will be deemed withdrawn.
iii. Additional Initial Review Information. No changes may be made to the
planned Point of Interconnection or Generating Facility size included in
the Interconnection Request during the review process, unless such
changes are agreed to by CPAU. Where agreement has not been reached,
Applicants choosing to change the Point of Interconnection or Generating
Facility size must reapply and submit a new Interconnection Request.
c. Supplemental Review.
If Applicant requests a Supplemental Review and submits an Advance
Engineering Fee as described in Rate Schedule E-15, if required, CPAU will
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 12
perform the Supplemental Review using the review process in Section H.2., and
complete the Supplemental Review within twenty (20) Business Days, absent
extraordinary circumstances, following authorization and receipt of the fee. The
Supplemental Review will determine if (i) the Generating Facility qualifies for
interconnection, or interconnection with additional requirements, or (ii) the
Generating Facility requires a Detailed Study.
Theexecutable version of the Applicant must provide the following data to CPAU
when requesting a Supplemental Review:
Generator:
1. MVA Rating
2. kV Rating
3. Base MVA
4. Base kV
5. Xd" (direct axis subtransient reactance)
6. Xd' (direct axis transient reactance)
7. Xd (Synchronous reactance)
8. X2 (Negative Sequence reactance)
9. X0 (Zero Sequence reactance)
Generating Facility Transformer Data:
1. Winding configuration (delta-Wye gnd or Wye gnd-Delta)
2. MVA Rating
3. KV Rating
4. Base MVA
5. Base KV
6. Z1 HV-LV
7. Z0 HV-LV
Line Data:
1. Impedance data for line from Transformer to POI (if applicable)
2. Z1
3. Z0
4. Point of Interconnection (POI) Location
i. Passage of Supplemental Review. For Interconnection Requests that pass a
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 13
Supplemental Review and do not require Interconnection Facilities or
Distribution Upgrades, CPAU will provide Applicant with a Generator
Interconnection Agreement or the Net Energy Metering and within fifteen
(15) Business Days of providing notice of the Supplemental Review
results. For Interconnection Requests that pass a Supplemental Review but
also require Interconnection Facilities or Distribution upgrades, CPAU
will provide Applicant with a non-binding cost estimate of the
Interconnection Facilities or Distribution upgrades within thirty (30)
Business Days of providing notice of the Supplemental Review results.
These facilities may be treated as Special Facilities (depending on
circumstance) for the purpose of determining Applicant costs. The
Applicant can then proceed with executing an Interconnection Agreement
in accordance with Section C.1.e below.
ii. Failure of Supplemental Review. For Interconnection Requests that fail a
Supplemental Review, CPAU will provide the technical reason, data and
analysis supporting the Supplemental Review results in writing and
provide Applicant the option to proceed directly to a cost estimate and
schedule for a Detailed Study. The Applicant shall notify CPAU within
fifteen (15) Business Days following such notification whether to (i)
proceed to a cost estimate and schedule for a Detailed Study, or (ii)
withdraw the Interconnection Request. If the Applicant elects to proceed
with the cost estimate and schedule for a Detailed Study, CPAU shall
provide Applicant with a non-binding cost estimate and schedule within
thirty (30) Business Days of the Applicant providing notice to proceed. If
Applicant fails to notify CPAU within fifteen (15) Business Days of such
notification, the Interconnection Request shall be deemed withdrawn.
d.as appropriate, for Detailed Study.
If the Applicant requests to proceed with the cost estimate and schedule for a
Detailed Study as provided by CPAU in Section C.1.c.ii above, CPAU and the
Applicant may enter into a Detailed Study agreement that provides for CPAU to
perform additional studies, facility design and engineering, and to provide an
estimate for the actual cost of CPAU provided Interconnection Facilities or
Distribution Upgrades as required to allow for the interconnection of the
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 14
generating facility at the Applicant’s Generating Facility and desired mode of
operation. Where the Supplemental Review or Interconnection Study performed
by CPAU has determined that modifications or additions to expense. The Detailed
Study agreement shall set forth CPAU’s estimated time schedule and charges for
completing such work. Note: the Detailed Study fee shall be waived for NEM
applicants meeting the requirements of Section B.11. Following payment of the
cost estimate by the Applicant, CPAU will proceed with the Detail Study in
accordance with the agreed upon time schedule, and upon completion of the
Detailed Study, CPAU will provide the results in writing to the Applicant along
with the final cost estimate of any required Interconnection or Distribution
Facilities. These facilities may be treated as Special Facilities (depending on
circumstance) for the purpose of determining Applicant costs. The applicant can
then proceed with executing an Interconnection Agreement in accordance with
Section C.1.e below.
e. Execution of the Generator Interconnection Agreement.
i. Following the receipt of a cost estimate for any Distribution Upgrades
and/or Interconnection Facilities that have been identified (Applicants that
did not require a cost estimate may proceed to Section C.1.e.ii below),
Applicant shall notify CPAU within fifteen (15) Business Days whether
Applicant: (i) requests a Generator Interconnection Agreement, or (ii)
withdraws its Distribution System are required, or that additional
Interconnection Facilities will be necessary to accommodate an
Interconnection Request. If Applicant fails to notify CPAU within fifteen
(15) Business Days, the Interconnection Request shall be deemed
withdrawn. If Applicant elects to proceed to a Generator Interconnection
Agreement, CPAU will provide Applicant with a Generator
Interconnection Agreement for Applicant’s Generating Facility, CPAU
may also provide the Applicant with a Special Facilities Agreement. This
agreement shall set forth CPAU and the signature within fifteen (15)
Business Days of Applicant’s responsibilities, completion schedules, and
estimated costs for the required workrequest.
b. Where applicable, CPAU installs required Interconnection Facilities or modifies
CPAU’s Distribution System.
ii. After executing the applicable agreementsUpon receipt of a draft
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 15
Generator Interconnection Agreement, Applicant has ninety (90) Calendar
Days to sign and return the Generator Interconnection Agreement.
Applicant shall provide to CPAU written comments, or notification of a
lack of any comments, on the draft Generator Interconnection Agreement
and appendices within thirty (30) Calendar Days. At the request of
Applicant, CPAU shall begin negotiations with Applicant at any time after
CPAU provides Applicant with the draft Generator Interconnection
Agreement, which contains in its appendices the cost estimate for any
Distribution Upgrades and/or Interconnection Facilities that have been
identified by CPAU. If Applicant fails to execute the Generator
Interconnection Agreement within the ninety (90) Calendar Days
described in this section, the Interconnection Request shall be deemed
withdrawn.
ii.iii. After Applicant has executed the Generator Interconnection Agreement
and paid the final invoice for estimated cost of Distribution Upgrades
and/or Interconnection Facilities, CPAU will commence with the design,
procurement, construction/ and installation of CPAU’s Distribution
System modifications or Interconnection Facilities which have been
identified in the agreements. The parties required facilities identified in
the Generator Interconnection Agreement. (Note: once the Applicant
executes the agreement, the Applicant is thereafter referred to as a
Producer) CPAU and Producer will use good faith efforts to meet
schedules and estimated costs as appropriatein accordance with the
requirements of the Generator Interconnection Agreement. Producer is
responsible for all costs associated with Parallel Operation to support the
safe and reliable operation of the Distribution System and Transmission
System.
3. C. PRODUCER ARRANGES FOR AND COMPLETES PRE-
PARALLELCOMMISSIONING TESTING AND PARALLEL OPERATION
a. Commissioning Testing of Generating Facility and Producer’s Interconnection
Facilities.
.
The Producer is responsible for commissioning and testing new Generating Facilities and
associated Interconnection Facilities to ensure compliance with the safety and
reliability Provisionsprovisions of this Rule prior to being operated in parallel
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 16
with CPAU’s Distribution or Transmission System. For non-Certified
Equipment, Producer shall develop a written testing plan to be submitted to
CPAU for its review and acceptance. Where applicable, the testing plan shall
include the installation test procedures published by the manufacturer of the
Generating Facility or Interconnection Facilities. Facility testing shall be
conducted at a mutually agreeable time, and CPAU shall be given the opportunity
to witness the tests.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 17
Where applicable, the test plan shall include the installation test procedures
published by the manufacturer of the generation or Interconnection equipment.
Facility testing shall be conducted at a mutually agreeable time, and CPAU and
Producer shall be given the opportunity to witness the tests.
d. CPAU Authorizes
b. Parallel Operation or Momentary Parallel Operation.
CPAU shall authorize the Producer’s Generating Facility for Parallel Operation or
Momentary Parallel Operation with CPAU’s Distribution System, in writing,
within 5 days of satisfactory compliance with the terms of all applicable
agreements. Compliance may include, but not be limited to, Provision of any
required documentation and satisfactorily completing any required inspections or
tests as described herein or in the agreements formed between the Producer and
CPAU. A Producer shall not commence Parallel Operation of its Generating
Facility with CPAU’s system unless it has received CPAU’s express written
permission to do so. CPAU will authorize Producer’s Generating Facility for
Parallel Operation or momentary Parallel Operation with CPAU’s Distribution or
Transmission System, in writing, within five (5) Calendar Days of satisfactory
compliance with the terms of all applicable agreements.
4. D. WITHDRAWAL / CANCELLATION
Applicant may withdraw its Interconnection Request at any time by written notice of
such withdrawal to CPAU. In addition, after receipt of the Interconnection Request, if
Applicant fails to adhere to the requirements and timelines of this rule, CPAU shall deem
the Interconnection Request to be withdrawn and shall provide written notice to
Applicant of the deemed withdrawal within five (5) Business Days and an explanation of
the reasons for such deemed withdrawal. Upon receipt of such written notice, Applicant
shall have five (5) Business Days in which to either respond with information or action
that either cures the deficiency or supports its position that the deemed withdrawal was
erroneous.
Applications that are over one year old (from the date of CPAU’s receipt) without
resulting in a signed Interconnection Agreement or Net Energy Metering and
Interconnection Agreement, or approval for Parallel Operation of a Generating Facility
within one year of completion of all applicable review and/or studies, are subject to
cancellation by CPAU.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 18
D. GENERATING FACILITY DESIGN AND OPERATING REQUIREMENTS
This section D. has been revised to be consistent with the requirements of ANSI/IEEE 1547-
2003 Standard for Interconnecting Distributed Resources with Electric Power Systems (IEEE
1547). Exceptions are taken to IEEE 1547 Clauses 4.1.4.2 Distribution Secondary Spot
Networks and Clauses 4.1.8.1 or 5.1.3.1, which address Protection from Electromagnetic
Interference. Also, RULE AND REGULATIONNote that this Rule and Regulation 27 does not
adopt the Generating Facility power limitation of 10 MW incorporated in IEEE 1547.
1.
1. GENERAL INTERCONNECTION AND PROTECTION FUNCTION
REQUIREMENTS
The Protective Functions and requirements of this Rule are designed to protect CPAU’s
Distribution System and not the Generating Facility. A ProducerCustomer shall be solely
responsible for providing adequate protection for its Generating Facility and
Interconnection Facilities. The Producer’sCustomer’s Protective Functions shall not
impact the operation of other Protective Functions utilized on CPAU’s Distribution
System in a manner that would affect CPAU’s capability of providing reliable service to
its Customers.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 19
a. Protective Functions Required. A Generating Facility operating in parallel with
CPAU’s Distribution System shall be equipped with the following Protective
Functions to sense abnormal conditions on CPAU’s Distribution System and
cause the Generating Facility to be automatically disconnected from CPAU’s
Distribution System or to prevent the Generating Facility from being connected to
CPAU’s Distribution System inappropriately:
1i. Over and under voltage trip functions and over and under frequency trip
functions;
2ii. A voltage and frequency sensing and time-delay Function to prevent the
Generating Facility from energizing a de-energized Distribution System
circuit and to prevent the Generating Facility from reconnecting with
CPAU’s Distribution System unless CPAU’s Distribution System service
voltage and frequency is within the ANSI C84.1-1995 Table 1 Range B
Voltage Range of 106V to 127V on a 120V basis, inclusive, and a
frequency range of 59.3 Hz to 60.5 Hz, inclusive, and are stable for at least
60 seconds, and;
3iii. A Function to prevent the Generating Facility from contributing to the
formation of an Unintended Island, and cease to energize the CPAU
system within two seconds of the formation of an Unintended Island.
The Generating Facility shall cease to energize CPAU’s Distribution
System for faults on CPAU’s Distribution System circuit to which it is
connected (IEEE1547-4.2.1). The Generating Facility shall cease to
energize CPAU’s Distribution circuit prior to re-closure by CPAU’s
Distribution System equipment (IEEE1547-4.2.2).
b. Momentary Paralleling Generating Facilities. With CPAU’s approval, the
transfer switch or scheme used to transfer the Producer’s Loads from CPAU’s
Distribution System to Producer’s Generating Facility may be used in lieu of the
Protective Functions required for Parallel Operation.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 20
c. Suitable Equipment Required. Circuit breakers or other interrupting devices
located at the Point of Common Coupling must be Certified or "Listed" (as
defined in Article 100, the Definitions Section of the National Electrical Code) as
suitable for their intended application. This includes being capable of interrupting
the maximum available fault current expected at their location. Producer’s
Generating Facility and Interconnection Facilities shall be designed so that the
failure of any one device shall not potentially compromise the safety and
reliability of CPAU’s Distribution System.
The Generating Facility’s paralleling-device shall be capable of withstanding
220% of the Interconnection Facilities’ rated voltage (IEEE 1547-4.1.8.3). The
Interconnection Facilities shall have the capability to withstand voltage and
current surges in accordance with the environments defined in IEEE Std
C62.41.2-2002 or IEEE Std C37.90.1-2002 as applicable and as described in
IEEE 1547-4.1.8.2.
d. Visible Disconnect Required: The Producer shall furnish and install a ganged,
manually-operated isolating switch (or a comparable device mutually agreed upon
by CPAU and the Producer) near the Point of Interconnection to isolate the
Generating Facility from CPAU’s Distribution System. The device does not have
to be rated for Load break nor provide over-currentovercurrent protection.
The device must:
1i. Allow visible verification that separation has been accomplished. (This
requirement may be met by opening the enclosure to observe contact
separation.) Molded case circuit breakers do not meet the visible contact
requirement and are not acceptable as a Visible Disconnect device.
2ii. Include markings or signage that clearly indicates open and closed
positions.
3iii. Be capable of being reached quickly and conveniently 24 hours a day by
CPAU personnel for construction, maintenance, inspection, testing or
reading, without obstacles or requiring those seeking access to obtain
keys, special permission, or security clearances.
4iv. Be capable of being locked in the open position.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 21
5v. Be clearly marked on the submitted Single Line Diagram and its type and
location approved by the CPAU prior to installation. If the device is not
adjacent to the Point of Common Coupling (PCC,), permanent signage
must be installed at a CPAU-approved location providing a clear
description of the location of the device.
Generating Facilities with Non-Islanding inverters totaling one (1) kilovolt-
ampere (kVA) or less are exempt from this requirement.
e. Drawings Required. Prior to Parallel Operation or Momentary Parallel Operation
of the Generating Facility, CPAU shall approve the Producer's Protective
Function and control diagrams. A Generating Facility equipped with a Protective
Function and control scheme previously approved by CPAU for system-wide
application or only Certified Equipment may satisfy this requirement by reference
to previously approved drawings and diagrams.
f. Generating Facility Conditions Not Identified. In the event this Rule does not
address the Interconnection conditions for a particular Generating Facility, CPAU
and Producer may agree upon other arrangements, to be approved by CPAU.
2. 2. PREVENTION OF INTERFERENCE
The Producer shall not operate a Generating Facility or Interconnection Facilities that
superimpose a voltage or current upon CPAU’s Distribution System that interferes with
CPAU operations, service to CPAU Customers, or communication facilities. If such
interference occurs, the Producer must diligently pursue and take corrective action at its
own expense after being given notice and reasonable time to do so by CPAU. If the
Producer does not take corrective action in a timely manner, or continues to operate the
facilities causing interference without restriction or limit, CPAU may, without liability,
disconnect the Producer's facilities from CPAU’s Distribution System, in accordance
with Section B.98 of this Rule. To eliminate undesirable interference caused by its
operation, each Generating Facility shall meet the following criteria:
a. Voltage Regulation. The Generating Facility shall not actively regulate the
voltage at the PCC while in parallel with CPAU’s Distribution System. The
Generating Facility shall not cause the service voltage at other Customers to go
outside the requirements of ANSI C84.1-1995, Range A (IEEE 1547-4.1.1).
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 22
b.
b. Operating Voltage Range. The voltage ranges in Table D.1 define protective trip
limits for the Protective Function and are not intended to define or imply a voltage
regulation Function. A Generating Facility shall cease to energize CPAU’s
Distribution System within the prescribed trip time whenever the voltage at the
PCC deviates from the allowable voltage operating range. The Protective
Function shall detect and respond to voltage on all phases to which the Generating
Facility is connected.
1i. Generating Facilities (30 kVA or less).. Generating Facilities with a Gross
Nameplate Rating of 30 kVA or less shall be capable of operating within
the voltage range normally experienced on CPAU’s Distribution System.
The operating range from plus to minus 5% of the nominal voltage (e.g.
114 volts to 126 volts on a 120 volt base), at the service panel or PCC.
The trip settings at the generator terminals shall be selected in a manner
that minimizes nuisance tripping between 106 volts and 132 volts on a
120-volt base (88-110% of nominal voltage). ) to compensate for voltage
drop between the generator terminals and the PCC. Voltage shall be
detected at either the PCC or the Point of Interconnection. However, the
voltage range at the PCC with the generator on-line shall stay within +/-
5% of nominal.
2. Generating Facilities (greater than 30 kVA). CPAU may have specific
operating voltage ranges for a Generating Facility with a Gross Nameplate
Rating greater than 30 kVA, and may require adjustable operating voltage
settings. In the absence of such requirements, the Generating Facility
shall operate at a range between 88% and 110% of the applicable
Interconnection voltage. Voltage shall be detected at either the PCC or the
Point of Interconnection, with settings compensated to account for the
voltage at the PCC. Generating Facilities that are Certified Non-Islanding
or that meet one of the options of the Export Screen (Section l.3.b) may
detect voltage at the Point of Interconnection without compensation.
3
ii. Voltage Disturbances. Whenever CPAU’s Distribution System voltage at
the PCC varies from and remains outside normal (nominally 120 volts) by
the predetermined amounts set forth in Table D-.1, the Generating
Facility’s Protective Functions shall cause the Generator(s) to become
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 23
isolated from CPAU’s Distribution System:.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 24
TABLE D.1: Voltage Trip Settings
Voltage at Point of Common Coupling Maximum Trip Time(1)
Assuming 120 V Base % of Nominal Voltage
# of Cycles
(Assuming 60 Hz
Nominal)
Seconds
Less than 60 Volts Less than 50% 10 Cycles 0.16 Seconds
Greater than or equal to
60 Volts but less than
106 Volts
Greater than or equal to
50% but less than 88% 120 Cycles 2 Seconds
Greater than or equal to
106 Volts but less than or
equal to 132 Volts
Greater than or equal to
88% but less than or
equal to 110%
Normal Operation
Greater than 132 Volts
but less than or
equal to 144 Volts
Greater than 110% but
less than or equal to
120%
60 Cycles 1 Second
Greater than 144 Volts Greater than 120% 10 Cycles 0.16 Seconds
(1) “Maximum Trip time” refers to the time between the onset of the abnormal condition and the
Generating Facility ceasing to energize CPAU’s Distribution System. Protective Function
sensing equipment and circuits may remain connected to CPAU’s Distribution System to allow
sensing of electrical conditions for use by the “reconnect” feature. The purpose of the allowed
time delay is to allow a Generating Facility to “ride through” short-term disturbances to avoid
nuisance tripping. Set points shall not be user adjustable (though they may be field adjustable by
qualified personnel). For Generating Facilities with a Gross Nameplate Rating greater than 30
kVA, set points shall be field adjustable and different voltage set points and trip times from those
in Table D.1 may be negotiated with CPAU.
c. Paralleling. The Generating Facility shall parallel with CPAU’s Distribution
System without causing a voltage fluctuation at the PCC greater than ±5% of the
prevailing voltage level of CPAU’s Distribution System at the PCC, and meet the
flicker requirements of D.2.d.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 25
d. Flicker. The Generating Facility shall not create objectionable flicker for other
Customers on CPAU’s Distribution System. To minimize the adverse voltage
effects experienced by other Customers (IEEE 1547-4.3.2), flicker at the PCC
caused by the Generating Facility should not exceed the limits defined by the
“Maximum Borderline of Irritation Curve” identified in IEEE 519-1992 (IEEE
Recommended Practices and Requirements for Harmonic Control in Electric
Power Systems, IEEE STD 519-1992, Institute of Electrical and Electronic
Engineers, Piscataway, NJ). ). This requirement is necessary to minimize the
adverse voltage affects experienced by others Customers on CPAU’s Distribution
System. Generators may be connected and brought up to synchronous speed (as
an induction motor) provided these flicker limits are not exceeded.
e. Integration with CPAU’s Distribution System Grounding. The grounding scheme
of the Generating Facility Interconnection shall not cause over-voltages that
exceed the rating of the equipment connected to CPAUCPAU’s Distribution
System and shall not disrupt the coordination of the ground fault protection on
CPAU’s Distribution System (IEEE 1547-4.1.2). Also see Section F.
f. Frequency. CPAU’s controls system frequency, and theThe Generating Facility
shall operate in synchronism with CPAU’s Distribution System. Whenever
CPAU’s Distribution System Frequency at the PCC varies from and remains
outside normal (nominally 60 Hz) by the predetermined amounts set forth in
Table D.2, the Generating Facility’s Protective Functions shall cease to energize
CPAU’s Distribution System within the stated maximum trip time.
TABLE D.2: Frequency Trip Settings
Generating Facility Rating Frequency Range
(Assuming 60 Hz Nominal)
Maximum Trip Time (1)
(Assuming 60 Cycles per
Second
Less or equal to 30 kW
Less than 59.3 Hz 10 Cycles
Greater than 60.5 Hz 10 Cycles
Greater than 30 kW
Less than 57 Hz 10 Cycles
Less than an adjustable value
between 59.8 Hz and 57 Hz
but greater than 57 Hz (2)
Adjustable between 10 and
18,000 Cycles (2),(3)
Greater than 60.5 Hz 10 Cycles
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 26
(
1) “Maximum Trip time” refers to the time between the onset of the abnormal condition and the
Generating Facility ceasing to energize CPAU’s Distribution System. Protective Function
sensing equipment and circuits may remain connected to CPAU’s Distribution System to allow
sensing of electrical conditions for use by the “reconnect” feature. The purpose of the allowed
time delay is to allow a Generating Facility to “ride through” short-term disturbances to avoid
nuisance tripping. Set points shall not be user adjustable (though they may be field adjustable by
qualified personnel). For Generating Facilities with a Gross Nameplate Rating greater than
30 kVA, set points shall be field adjustable and different voltage set points and trip times from
those in Table D.2 may be negotiated with CPAU.
(2) Unless otherwise required by CPAU, a trip frequency of 59.3 Hz and a maximum trip time of 10
cycles shall be used.
(3) When a 10-cycle maximum trip time is used, a second under frequency trip setting is not
required.
g. Harmonics. When the Generating Facility is serving balanced linear Loads,
harmonic current injection into CPAU’s Distribution System at the PCC shall not
exceed the limits stated below in Table D.3. The harmonic current injections
shall be exclusive of any harmonic currents due to harmonic voltage distortion
present in CPAU’s Distribution System without the Generating Facility connected
(IEEE 1547-4.3.3). The harmonic distortion of a Generating Facility located at a
Customer’s site shall be evaluated using the same criteria as for the Host Loads.
Table D.3 Maximum Harmonic Current Distortion in Percent of Current (I)(1,2)
Individual
Harmonic Order h,
(odd harmonics) (3)
h<11 11 ≤ h < 17 17 ≤ h < 23 23 ≤ h < 35 35 ≤ h
Total
Demand
distortion
(TDD)
Max Distortion (%) 4.0 2.0 1.5 0.6 0.3 5.0
(1) IEEE 1547-4.3.3
(2) I = the greater of the maximum Host Load current average Demand over 15 or 30 minutes without the GF, or the GF rated current capacity (transformed to the PCC when a transformer exists between the GF and the PCC).
(3) Even harmonics are limited to 25% of the odd harmonic limits above.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 27
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 28
h. Direct Current Injection. Generating Facilities should not inject direct current
greater than 0.5% of rated output current into CPAU’s Distribution System.
i. Power Factor. Each Generator in a Generating Facility shall be capable of
operating at some point within a Power Factor range from 0.9 leading to
0.9 lagging. Operation outside this range is acceptable provided the reactive
power of the Generating Facility is used to meet the reactive power needs of the
Host Loads or that reactive power is otherwise provided under tariff by CPAU.
The Producer shall notify CPAU if it is using the Generating Facility for Power
Factor correction. Unless otherwise agreed upon by the Producer and CPAU,
Generating Facilities shall automatically regulate Power Factor, not voltage, while
operating in parallel with CPAU’s Distribution System.
3. 3. TECHNOLOGY SPECIFIC REQUIREMENTS
a. Three-Phase Synchronous Generators. For three-phase Generators, the
Generating Facility circuit breakers shall be three-phase devices with electronic or
electromechanical control. The Producer shall be responsible for properly
synchronizing its Generating Facility with CPAU’s Distribution System by means
of either manual or automatic synchronizing equipment. Automatic
synchronizing is required for all synchronous Generators that have a Short Circuit
Contribution Ratio (SCCR) exceeding 0.05. Loss of synchronism protection is
not required except as may be necessary to meet D.2.d (Flicker) (IEEE 1547 -
4.2.5). Unless otherwise agreed upon by the Producer and CPAU, synchronous
Generators shall automatically regulate Power Factor, not voltage, while
operating in parallel with CPAU’s Distribution System. A power system
stabilization function is specifically not required for Generating Facilities under
10 MW Net Nameplate Rating. Ground Fault Protection is required for generators
> 40 kW. Voltage Restraint Overcurrent or Voltage Controlled Overcurrent relays
are required for generators or a group of generators > 400 kW.
b. Induction Generators. Induction Generators (except self-excited Induction
Generators) do not require a synchronizing Function. Starting or rapid Load
fluctuations on induction Generators can adversely impact CPAU’s Distribution
System's voltage. Corrective step-switched capacitors or other techniques may be
necessary and may cause undesirable ferro-resonance.ferroresonance. When
these counter measures (e.g.,. additional capacitors) are installed on the Producer's
side of the Point of Common Coupling, CPAU must review these measures.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 29
Additional equipment may be required as determined in a Supplemental Review
or an Interconnectiona Detailed Study.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 30
Ground Fault Protection is required for generators > 40 kW. Voltage Restraint
Overcurrent or Voltage Controlled Overcurrent relays are required for generators
or a group of generators > 400 kW.
c. Inverters. Only Certified inverters are approved for interconnection. Utility-
interactive inverters do not require separate synchronizing equipment. Non-
utility-interactive or “stand-alone” inverters shall not be used for Parallel
Operation with CPAU’s Distribution System. Inverters or a group of inverters >
400 kW require Ground Fault Protection.
Inverter based systems not classified as “Smart Inverters” may continue to be
installed per Section D.3.c until the later of either (1) December 31, 2015 or (2)
September 8, 2017, which is twelve (12) months after the date the Supplement SA
of UL-1741 (with California requirements) is approved. Section D.5 may be used
in all or in part, for inverter based technologies by mutual agreement of CPAU
and the Applicant.
The replacement of an existing inverter to an inverter that is of equal or greater
ability than the original is allowed per Section D.3.c. Section D.5 may be used in
all or in part, for replacement inverter based technologies by mutual agreement of
CPAU and the Applicant.
d. Single-Phase Generators. For single-phase Generators connected to a shared
single-phase secondary system, the maximum Net Nameplate Rating of the
Generating Facilities shall be 20 kVA. Generators connected to a center-tapped
service neutral 240-volt service must be installed such that no more than 6 kVA of
unbalanced power is applied to the two “legs” of the 240-volt service.service. The
current in the most heavily loaded leg must not exceed twice that of the other leg.
For Dedicated Distribution Transformer Services, the maximum Net Nameplate
Rating of a single-phase Generating Facility shall be the transformer nameplate
rating.
4. 4. SUPPLEMENTAL GENERATING FACILITY REQUIREMENTS
a. Fault Detection. A Generating Facility with an SCCR exceeding 0.1 or one that
does not cease to energize CPAU’s Distribution System within two seconds of the
formation of an Unintended Island shall be equipped with Protective Functions
designed to detect Distribution System faults, both line-to-line and line-to-ground,
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 31
and shall cease to energize CPAU’s Distribution System within two seconds of
the initiation of a fault.
b. Transfer Trip. For a Generating Facility that cannot detect Distribution System
faults (both line-to-line and line-to-ground) or the formation of an Unintended
Island, and cease to energize CPAU’s Distribution System within two seconds,
CPAU may require a Transfer Trip system or an equivalent Protective Function.
For net metered or non-net metered Generating Facilities, the Facility will be
considered capable of supporting an Unintended Island if the aggregate
distributed generation output is 80% or more of the Distribution System real -time
load kW seen at CPAU’s source-side Distribution Protection Device.
c. Reclose Blocking. Where the aggregate Generating Facility capacity exceeds
15% of the peak Load on any automatic reclosing device, CPAU may require
additional Protective Functions, including, but not limited to reclose-blocking on
some of the automatic reclosing devices.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 32
E.
5. SMART INVERTER GENERATING FACILITY DESIGN AND OPERATING
REQUIREMENTS
Section D.3.c shall continue to be used for interconnection of inverter based technologies
until September 8, 2017, twelve (12) months after the date the Supplement SA of UL-
1741 (with CA requirements) is approved by the full UL-1741 Standards Technical Panel
(STP). Following such date, Section D.5 shall apply for interconnection of inverter based
technologies. Until such date, Section D.5 may be used in all or in part, for inverter based
technologies by mutual agreement of the CPAU and the Applicant.
The inverter requirements are intended to be consistent with ANSI/IEEE 1547- 2003 and
1547a Standard for Interconnecting Distributed Resources with Electric Power Systems
(IEEE 1547 including amendment 1547a). In the event of conflict between this Rule and
IEEE 1547-2003, this Rule shall take precedence. Exceptions are taken to IEEE 1547
Clauses 4.1.4.2 Distribution Secondary Spot Networks and Clauses 4.1.8.1 or 5.1.3.1,
which address Protection from Electromagnetic Interference. Rule 27 does not adopt the
Generating Facility power limitation of 10 MW incorporated in IEEE1547.
a. Protective Functions Required. Smart Inverters operating in parallel with CPAU’s
Distribution System shall be equipped with the following Protective Functions to
sense abnormal conditions on CPAU’s Distribution System and cause the Smart
Inverter to be automatically disconnected from CPAU’s Distribution System or to
prevent the Smart Inverter from being connected to CPAU’s Distribution System
inappropriately:
i. Over and under voltage trip functions and over and under frequency trip
functions;
ii. A voltage and frequency sensing and time-delay function to prevent the
Smart Inverter from energizing a de-energized Distribution System circuit
and to prevent the Smart Inverter from reconnecting with CPAU’s System
unless CPAU’s Distribution System service voltage and frequency is
within the ANSI C84.1-1995 Table 1 Range B voltage Range of 106 volts
to 127 volts (on a 120 volt basis), inclusive, and a frequency range of 59.3
Hz to 60.5 Hz, inclusive, and are stable for at least 15 seconds; and
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 33
iii. A function to prevent the Smart Inverter from contributing to the
formation of an Unintended Island, and cease to energize CPAU’s
Distribution System within two seconds of the formation of an Unintended
Island.
iv. Only Certified Smart Inverters are approved for interconnection. Smart
Inverters or a group of Smart Inverters > 400 kW require Ground Fault
Protection.
The Smart Inverter shall cease to energize CPAU’s Distribution System
for faults on CPAU’s Distribution System circuit to which it is connected
(IEEE 1547-4.2.1). The Smart Inverter shall cease to energize CPAU’s
Distribution circuit prior to reclosing by CPAU’s Distribution System
equipment (IEEE 1547-4.2.2).
b. Momentary Paralleling Generating Facilities. With CPAU’s approval, the transfer
switch or scheme used to transfer Producer’s loads from CPAU’s Distribution
System to Producer’s Generating Facility may be used in lieu of the Protective
Functions required for Parallel Operation.
c. Suitable Equipment Required. Circuit breakers or other interrupting equipment
located at the PCC must be Certified or “Listed” (as defined in Article 100, the
Definitions Section of the National Electrical Code) as suitable for their intended
application. This includes being capable of interrupting the maximum available
fault current expected at their location. Producer’s Smart Inverter and
Interconnection Facilities shall be designed so that the failure of any single device
or component shall not potentially compromise the safety and reliability of
CPAU’s Distribution System. The Smart Inverter paralleling-device shall be
capable of withstanding 220% of the Interconnection Facility rated voltage (IEEE
1547- 4.1.8.3). The Interconnection Facility shall have the capability to withstand
voltage and current surges in accordance with the environments defined in IEEE
Std. C62.41.2-2002 or IEEE Std. C37.90.1-2002 as applicable and as described in
L.3.e (IEEE 1547- 4.1.8.2).
d. Visible Disconnect Required. Producer shall furnish and install a ganged,
manually-operated isolating switch (or a comparable device mutually agreed upon
by CPAU and Producer) near the Point of Common Coupling to isolate the Smart
Inverter from CPAU’s Distribution System. The device does not have to provide
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 34
over-current protection.
The device must:
i. Allow visible verification that separation has been accomplished. (This
requirement may be met by opening the enclosure to observe contact
separation.) Molded case circuit breakers do not meet the visible contact
requirement and are not acceptable as a Visible Disconnect device.
ii. Include markings or signage that clearly indicates open and closed
positions.
iii. Be capable of being reached quickly and conveniently 24 hours a day by
CPAU personnel for construction, maintenance, inspection, testing or
reading, without obstacles or requiring those seeking access to obtain
keys, special permission, or security clearances.
iv. Be capable of being locked in the open position.
v. Be clearly marked on the submitted single line diagram and its type and
location approved by CPAU prior to installation. If the device is not
adjacent to the PCC, permanent signage must be installed at a CPAU
approved location providing a clear description of the location of the
device. If the switch is not accessible outside the locked premises, signage
with contact information and a CPAU approved locking device for the
premises shall be installed. Generating Facilities with Non-Islanding
inverters totaling one (1) kilovolt-ampere (kVA) or less are exempt from
this requirement.
e. Drawings Required. Prior to Parallel Operation or Momentary Parallel Operation
of the Smart Inverter, CPAU shall approve Producer’s Protective Function and
control diagrams. Generating Facilities equipped with Protective Functions and a
control scheme previously approved by CPAU for system-wide application or
only
Certified Equipment may satisfy this requirement by reference to previously
approved drawings and diagrams.
f. Generating Facility Conditions Not Identified. In the event this Rule does not
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 35
address the Interconnection conditions for a particular Smart Inverter, CPAU and
Producer may agree upon other arrangements, to be approved by CPAU.
g. Prevention of Interference. Producer shall not operate Smart Inverters that
superimpose a voltage or current upon CPAU’s Distribution System that
interferes with CPAU operations, service to CPAU Customers or communication
facilities. If such interference occurs, Producer must diligently pursue and take
corrective action at its own expense after being given notice and reasonable time
to do so by CPAU. If Producer does not take corrective action in a timely manner,
or continues to operate the facilities causing interference without restriction or
limit, CPAU may, without liability, disconnect Producer's facilities from CPAU’s
Distribution System, in accordance with Section B.8 of this Rule.
h. Voltage Regulation. If approved by CPAU, the Smart Inverter may actively
regulate the voltage at the Point of Common Coupling (PCC) while in parallel
with CPAU’s Distribution System. The Smart Inverter shall not cause the service
voltage at other customers to go outside the requirements of ANSI C84.1-1995,
Range A (IEEE 1547-4.1.1).
i. Voltage Trip and Ride-Through Settings. The voltage ranges in Table D.4 define
protective trip limits for the Protective Function and are not intended to define or
imply a voltage regulation Function. Generating Facilities shall cease to energize
CPAU’s Distribution System within the prescribed trip time whenever the voltage
at the PCC deviates from the allowable voltage operating range. The Protection
Function shall detect and respond to voltage on all phases to which the Generating
Facility is connected.
j. Smart Inverters. Smart Inverters shall be capable of operating within the voltage
range normally experienced on CPAU’s Distribution System from plus to minus
5% of the nominal voltage (e.g. 114 volts to 126 volts, on a 120 volt base), at the
service panel or PCC. The trip settings at the generator terminals may be selected
in a manner that minimizes nuisance tripping in accordance with Table D.4 to
compensate for voltage drop between the generator terminals and the PCC.
Voltage may be detected at either the PCC or the Point of Interconnection.
However, the voltage range at the PCC, with the generator on-line, shall stay
within +/-5% of nominal.
k. Voltage Disturbances. Whenever CPAU’s Distribution System voltage at the PCC
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 36
varies from and remains outside Near Nominal voltage for the predetermined
parameters set forth in Table D.4, the Smart Inverter’s Protective Functions shall
cause the Smart Inverter(s) to become isolated from CPAU’s Distribution System:
i. The Smart Inverter shall stay connected to CPAU’s Distribution System
while the grid remains within the “Ride-Through Until” voltage-time
range and must stay connected in the corresponding “Operating Mode”.
ii. For voltage excursions beyond the near Nominal (NN) magnitude range
and within the range of the HV1 or LV3 regions, the Smart Inverter shall
momentarily cease to energize within 0.16 seconds.
iii. In the HV1 region, the Smart Inverter is permitted to reduce power output
as a function of voltage under mutual agreement between the Producer and
CPAU.
iv. If the distribution system voltage does not exit the ride-through region and
recovers to normal system voltage, the Smart Inverter shall restore
continuous operation within 2 seconds.
v. If the CPAU’s Distribution System voltage does not exit the ride-through
region and returns from the LV3 region to the LV2 or LV1 region, the
Smart Inverter shall restore available current within 2 seconds.
vi. Different voltage-time settings could be permitted by CPAU.
Table D.4: Voltage Ride-Through Table
Region Voltage at Point
of Common
Coupling (%
Nominal Volts)
Ride-Through
Until
Operating Mode Maximum Trip
Time
High Voltage 2
(HV2)
V > 120 0.16 seconds
High Voltage 1
(HV1)
110 < V < 120 12 seconds Momentary
Cessation
13 seconds
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 37
Near Nominal
(NN)
88 < V < 110 Indefinite Continuous
Operation
Not Applicable
Low Voltage 1
(LV1)
70 < V < 88 20 seconds Mandatory
Operation
21 seconds
Low Voltage 2
(LV2)
50 < V < 70 10 seconds Mandatory
Operation
11 seconds
Low Voltage 3
(LV3)
V < 50 1 second Momentary
Cessation
1.5 seconds
l. Paralleling. The Generating Facility shall parallel with CPAU’s Distribution
System without causing a voltage fluctuation at the PCC greater than plus/minus
5% of the prevailing voltage level of CPAU’s Distribution System at the PCC,
and meet the flicker requirements of Section D.5.m below.
m. Flicker. The Generating Facility shall not create objectionable flicker for other
customers on CPAU’s Distribution System. To minimize the adverse voltage
effects experienced by other customers (IEEE 1547-4.3.2), flicker at the PCC
caused by the Generating Facility should not exceed the limits defined by the
"Maximum Borderline of Irritation Curve" identified in IEEE 519-1992 (IEEE
Recommended Practices and Requirements for Harmonic Control in Electric
Power Systems, IEEE STD 519-1992). This requirement is necessary to minimize
the adverse voltage affects experienced by other Customers on CPAU’s
Distribution System. Generators may be connected and brought up to
synchronous speed (as an induction motor) provided these flicker limits are not
exceeded.
n. Integration with CPAU’s Distribution System Grounding. The grounding scheme
of the Generating Facility shall not cause over-voltages that exceed the rating of
the equipment connected to CPAU’s Distribution System and shall not disrupt the
coordination of the ground fault protection on CPAU’s Distribution System (IEEE
1547-4.1.2).
o. Frequency. CPAU controls system frequency, and the Generating Facility shall
operate in synchronism with CPAU’s Distribution System. Whenever CPAU’s
Distribution System frequency at the PCC varies from and remains outside
normal (nominally 60 Hz) by the predetermined amounts set forth in Table D.2,
the Generating Facility’s Protective Functions shall cease to energize CPAU’s
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 38
Distribution System within the stated maximum trip time.
p. Frequency Ride-Through Requirements. Smart Inverter based systems shall
remain connected to CPAU’s Distribution System while the grid is within the
frequency-time range indicated in Table D.5, and shall disconnect from the
electric grid during a high or low frequency event that is outside that frequency-
time range. The frequency values are shown in Table D.5. These values provide
default interconnection system response to abnormal frequencies. The inverter
shall disconnect by the default clearing times. In the high frequency range
between 60.2 Hz and 61.5 Hz, or some other mutually agreed range, the Smart
Inverter is permitted to reduce real power output until it ceases to export power by
61.5 Hz, or other frequency value mutually agreed between the generating facility
operator and CPAU. Islands and microgrids may need different default frequency
settings.
Table D.5: Frequency Ride-Through and Trip Settings Table
System
Frequency
Default Settings
(Hz)
Minimum Range
of Adjustability
(Hz)
Ride-Through
Until
Ride –Through
Operational
Mode
Maximum Trip
Time
f > 62 62 – 64 No Ride Through Not Applicable 0.16 seconds
60.5 < f < 62 60.1 – 62 299 seconds Mandatory
Operation
300 seconds
58.5 < f < 60.5 Not Applicable Indefinite Continuous
Operation
Not Applicable
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 39
57.0 < f < 58.5 57 – 59.9 299 seconds Mandatory
Operation
300 seconds
f < 57.0 53 – 57 No Ride Through Not Applicable 0.16 seconds
q. Harmonics. When the Smart Inverter is serving balanced linear loads, harmonic
current injection into CPAU’s Distribution System at the PCC shall not exceed
the limits stated in Table D.3. The harmonic current injections shall be exclusive
of any harmonic currents due to harmonic voltage distortion present in
CPAU’s Distribution System without the Smart Inverter connected (IEEE 1547-
4.3.3.). The harmonic distortion of a Smart Inverter shall be evaluated using the
same criteria as for the Host Loads.
r. Direct Current Injection. Smart Inverter should not inject direct current greater
than 0.5% of rated output current into CPAU’s Distribution System.
s. Power Factor. Producer shall provide adequate reactive power compensation on
site to maintain the Smart Inverter power factor near unity at rated output or a
CPAU specified power factor in accordance with the following requirements:
i. Default Power Factor setting: 1.0 +/- 0.01 (0.99 Lagging to 0.99 Leading).
ii. Aggregate generating facility is greater than 15 kW: 1.0 +/- 0.15 (0.85
Lagging to 0.85 Leading) down to 20% rated power based on available
reactive power.
iii. Aggregate generating facility is less than or equal to 15 kW: 1.0 +/- 0.10
(0.90 Lagging to 0.90 Leading) down to 20% rated power based on
available reactive power.
t. Dynamic Volt/VAR Operations. The Smart Inverter shall be capable of operating
dynamically within a power factor range of +/- 0.85 PF for larger (>15 kW)
systems, down to 20% of rated power, and +/- 0.9 PF for smaller systems (≤15
kW), down to 20% of rated power, based on available reactive power. This
dynamic Volt/VAR capability shall be able to be activated or deactivated in
accordance with CPAU requirements.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 40
CPAU may permit or require the Smart Inverter systems to operate in larger
power factor ranges, including in 4-quadrant operations for storage systems with
the implementation of additional anti-islanding protection as determined by
CPAU.
The Smart Inverter shall be capable of providing dynamic reactive power
compensation (dynamic Volt/VAR operation) within the following constraints:
The Smart Inverter shall not cause the line voltage at the point of common
coupling to go outside the requirements of the latest version of ANSI
C84.1, Range A.
The Smart Inverter shall be able to consume reactive power in response to
an increase in line voltage, and produce reactive power in response to a
decrease in line voltage.
The reactive power provided shall be based on available reactive power,
but the maximum reactive power provided to the system shall be as
directed by CPAU.
u. Ramp Rate Requirements. The Smart Inverter is required to have the following
ramp controls for at least the following two conditions. These functions can be
established by multiple control functions or by one general ramp rate control
function. Ramp rates are contingent upon sufficient energy available from the
Smart Inverter.
Normal ramp-up rate: For transitions between energy output levels over
the normal course of operation. The default value is 100% of maximum
current output per second with a range of adjustment between 1% to
100%, with specific settings as mutually agreed by the CPAU and the
Producer.
Connect/Reconnect Ramp-up rate: Upon starting to inject power into the
grid, following a period of inactivity or a disconnection, the inverter shall
be able to control its rate of increase of power from 1 to 100% maximum
current per second, with specific settings as mutually agreed upon by
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 41
CPAU and the Producer.
v. Default Activation States for Phase 1 Functions. Unless otherwise provided by
CPAU, the default settings will be as follows:
Anti-islanding – activated
Low/High Voltage Ride-Through – activated
Low/High Frequency Ride-Through – activated
Dynamic Volt/VAR operations – deactivated
Ramp rates – activated
Fixed power factor – activated
Reconnect by “soft-start” methods – activated
These default activation states may be modified by mutual agreement between
CPAU and Producer.
w. Automatic Transfer (Load Shedding or Transfer). The voltage and frequency ride-
through requirements of D.5.i and D.5.m shall not apply if either: a) The real
power across the Point of Common Coupling is continuously maintained at a
value less than 10% of the aggregate rating of the Smart Inverters connected to
the Generation Facility prior to any voltage disturbance, and the Generation
Facility disconnects from CPAU’s distribution system, along with Generation
Facility load, such that the net change in real power flow from or to CPAU is less
than 10% of the aggregate Smart Inverter capacity; or b) Generation Facility load
real power demand equal to 90% to 120% of the pre-disturbance aggregate Smart
Inverter real power output is shed within 0.1 seconds of Smart Inverter
disconnection.
x. Fault Detection. A Smart Inverter with an SCCR exceeding 0.1 or one that does
not cease to energize CPAU’s Distribution System within two seconds of the
formation of an Unintended Island shall be equipped with Protective Functions
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 42
designed to detect Distribution System faults, both line-to-line and line-to-ground,
and cease to energize CPAU’s Distribution System within two seconds of the
initiation of a fault.
y. Transfer Trip. For a Generating Facility that cannot detect Distribution System
faults (both line-to-line and line-to-ground) or the formation of an Unintended
Island, and cease to energize CPAU’s Distribution System within two seconds,
CPAU may require a Transfer Trip system or an equivalent Protective Function.
z. Reclose Blocking. Where the aggregate Generating Facility capacity exceeds 15%
of the peak load on any automatic reclosing device, CPAU may require additional
Protective Functions, including, but not limited to reclose-blocking on some of
the automatic reclosing devices.
E. INTERCONNECTION FACILITIES AND DISTRIBUTION SYSTEM
MODIFICATIONS OWNERSHIP AND FINANCING COST ALLOCATION
1.
1. SCOPE AND OWNERSHIP OF INTERCONNECTION FACILITIES AND
DISTRIBUTION SYSTEM MODIFICATIONS
a. Scope. Parallel Operation of Generating Facilities may require Interconnection
Facilities or modifications to CPAU’s Distribution System (“Distribution System
modifications”). The type, extent and costs of Interconnection Facilities and
Distribution System modifications shall be consistent with this Rule and
determined through the Supplemental Review and/or Interconnection Studies
described in Section C.
b. Ownership. Interconnection Facilities installed on Producer’s side of the Point of
Common Coupling (PCC) may be owned, operated and maintained by the
Producer or CPAU. Interconnection Facilities installed on CPAU’s side of the
PCC and Distribution System modifications shall be owned, operated and
maintained only by CPAU.
2. 2. RESPONSIBILITY OF COSTS OF
INTERCONNECTING A GENERATING FACILITY
a. Study and Review Costs. A Producer shall be responsible for the reasonably
incurred costs of the reviews and studies conducted pursuant to Section C.1 of this
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RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-2012
Sheet No. 43
Rule.
b. Facility Costs. A Producer shall be responsible for all costs associated with
Interconnection Facilities owned by the Producer. The Producer shall also be
responsible for any costs reasonably incurred by CPAU in providing, operating,
or maintaining the Interconnection Facilities and Distribution System
modifications required solely for the Interconnection of the Producer’s Generating
Facility with CPAU’s Distribution System.
c. Separation of Costs. Should CPAU combine the installation of Interconnection
Facilities or Distribution System modifications required for the Interconnection of
a Generating Facility with modifications to CPAU’s Distribution System to serve
other Customers or Producers, CPAU shall not include the costs of such separate
or incremental facilities in the amounts billed to the Producer.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-201212-12-2016
Sheet No. 2044
d.
b.d. Reconciliation of Costs and Payments. The Producer must pay applicable costs
prior to the scheduling of any engineering reviews and studies; construction of
distribution system modifications; or interconnection of generating facilities to
CPAU’s Distribution SystemIf the Producer selected a fixed price billing for the
Interconnection Facilities or Distribution System modifications, no reconciliation
will be necessary. If the Producer selected actual cost billing, a true-up will be
required. Within a reasonable time after the Interconnection of a Producer’s
Generating Facility, CPAU will reconcile its actual costs related to the Generating
Facility against any advance payments made by the Producer. The Producer wi ll
receive either a bill for any balance due or a reimbursement for overpayment as
determined by CPAU’s reconciliation. The Producer shall be entitled to a
reasonably detailed and understandable accounting for the payments.
3.
3. INSTALLATION AND FINANCING OF INTERCONNECTION FACILITIES
AND DISTRIBUTION SYSTEM MODIFICATIONS
a. a. Agreement Required. The costs for Interconnection Facilities and
Distribution System modifications shall be paid by the Producer pursuant to the
Provisions contained in the Special Facilities Agreement. Where the type and
extent of the Interconnection Facilities or Distribution System modifications
warrant additional detail, Producer and CPAU shall execute separate agreement(s)
to more fully describe and allocate the parties’ responsibilities for installing,
owning, operating and maintaining the Interconnection Facilities and Distribution
System modifications.
b. b. Interconnection Facilities and Distribution System Modifications.
Interconnection Facilities connected to CPAU’s side of the Point of Common
Coupling and Distribution System modifications shall be provided, installed,
owned and maintained by CPAU at Producer’s expense.
c. c. Reservation of Unused Facilities. When a Producer wishes to reserve
CPAU-owned Interconnection Facilities or Distribution System modifications
installed and operated as Special Facilities for the Producer at Producer’s expense,
but idled by a change in the operation of the Producer's Generating Facility or
otherwise, Producer may elect to abandon or reserve such facilities consistent
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RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-201212-12-2016
Sheet No. 2045
with the terms of its agreement with CPAU. If Producer elects to reserve idle
Interconnection Facilities or Distribution System modifications, CPAU shall be
entitled to continue to Charge Producer for the costs related to the ongoing
operation and maintenance of the Special Facilities.
d. Refund of Salvage Value. When a Producer elects to abandon the Special
Facilities for which it has either advanced the installed costs or constructed and
transferred to CPAU, the Producer shall, at a minimum, not receive from CPAU a
credit for the net salvage value of the Special Facilities.
F. METERING, MONITORING AND TELEMETRY
1. GENERAL REQUIREMENTS
All Generating Facilities shall be metered in accordance with this Section F and shall
meet all applicable standards of CPAU contained in CPAU’s applicable rules and
published CPAU manuals dealing with Metering specifications. For general metering
requirements, see CPAU Rule and Regulation 15. For net metering requirements, see
CPAU Rule and Regulation 29.
2. METERING BY CPAU
The ownership, installation, operation, reading and testing of revenue Metering
Equipment for Generating Facilities shall be by CPAU only.
3. NET GENERATION METERING
For purposes of monitoring Generating Facility operation to determine standby Charges
and applicable non-bypassable Charges as defined in CPAU’s tariffs, and for Distribution
System planning and operations, consistent with Section B.4 of this Rule, CPAU shall
have the right to specify the type, and require the installation of Net Generation Metering
equipment. CPAU shall only require Net Generation Metering to the extent that less
intrusive and/or more cost effective options for providing the necessary Gen erating
Facility output data are not available. In exercising its discretion to require Net
Generation Metering, CPAU shall consider all relevant factors, including but not limited
to:
a. Data requirements in proportion to need for information;
b. Producer’s election to install equipment that adequately addresses CPAU’s
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-201212-12-2016
Sheet No. 2046
operational requirements;
c. Accuracy and type of required Metering consistent with purposes of collecting
data;
d. Cost of Metering relative to the need for and accuracy of the data;
e. The Generating Facility’s size relative to the cost of the Metering/monitoring;
f. Other means of obtaining the data (e.g., Generating Facility logs, proxy data etc.);
and
g. Requirements under any Interconnection Agreement with the Producer.
4. POINT OF COMMON COUPLING METERING
For purposes of assessing CPAU Charges for retail service, the Producer’s PCC Metering
shall be reviewed by CPAU, and if required, replaced to ensure that it will appropriately
measure Electric power according to the Provisions of the Customer’s Electric Service
tariff. Where required, the Customer’s existing Meter may be replaced with a bi-
directional meter so that power deliveries to and from the Producer’s site can be
separately recorded. Alternately, the Producer may, at its sole option and cost, require
CPAU to install Multi-Metering Equipment to separately record power deliveries to
CPAU’s Distribution System and retail purchases from CPAU. Where necessary, such
PCC Metering shall be designed to prevent reverse registration.
5. TELEMETERING
If the nameplate rating of the Generating Facility is 1 MW or greater,
Telemeteringtelemetering equipment at the Net Generator Metering location may be
required at the Producer's expense. If the Generating Facility is
Interconnectedinterconnected to a portion of CPAU’s Distribution System operating at a
voltage below 10 kV, then Telemetering equipment may be required on Generating
Facilities 250 kW or greater. CPAU shall only require Telemetering to the extent that
less intrusive and/or more cost effective options for providing the necessary data in real
time are not available
6. LOCATION
Where CPAU-owned Metering is located on the Producer’s Premises, Producer shall
provide, at no expense to CPAU, a suitable location for all such Metering Equipment as
set forth in CPAU Rule and Regulation 15.
GENERATING FACILITY INTERCONNECTIONS
RULE AND REGULATION 27
CITY OF PALO ALTO
UTILITIES RULES AND REGULATIONS
Issued by the City Council
Effective 4-2-201212-12-2016
Sheet No. 2047
7. COSTS OF METERING
The Producer will bear all costs of the Metering required by this Rule, including the
incremental costs of operating and maintaining the Metering Equipment.
G. SUPPLEMENTAL REVIEW
If the Generating Facility meets any of the following criteria, the Facility does not qualify for
Simplified Interconnection Review and must undergo a Supplemental Review:
1. Output from the Generating Facility at any time will be equal to or greater than 15% of
the load on the distribution line section.
2. The aggregate distributed generation on the distribution line section exceeds 80% of the
real-time peak load kW.
3. Startup, shutdown or other operating characteristics of the Generating Facility cause
voltage drop or flicker to exceed CPAU’s allowable limits as specified in Section D.
4. The Generating Facility is connected to a 4kV distribution feeder which has line-to –
neutral connected load and the Generating Facility nameplate rating exceeds 10% of the
line section peak load.
5. The Generating Facility, in aggregate with other generation, shall not contribute more
than 10% to the circuit’s maximum fault current
(END)