HomeMy WebLinkAboutStaff Report 417-08City of Palo Alto
City Manager’s Summary Report
TO:HONORABLE CITY COUNCIL
FROM:
DATE:
REPORT TYPE:
CITY MANAGER
OCTOBER 20, 2008
INFORMATIONAL
Department: UTILITIES
CMR: 417:08
SUBJECT:San Francisco Planning Commission’s Release of the Final Program
Environmental Impact Report on the San Francisco Public Utilities
Commission’s Water System Improvement Program
This is an informational report and no Council action is required. This item is provided as
background information in conjunction with the study session on October 20, 2008.
BACKGROUND
The San Francisco Public Utilities Commission (SFPUC) operates the regional water system,
which supplies water to Palo Alto and the 26 other member agencies of the Bay Area Water
Supply and Conservation Agency (BAWSCA). The regional water system is in need of repairs
and upgrades to ensure that it can reliably deliver high quality water to meet the region’s water
supply needs. A report released in January 2000 indicated that the regional water system could
suffer damage from a large earthquake so severe that water supplies would be cut off for up to
two months. In response, the SFPUC developed the Water System Improvement Program
(WSIP) comprised of 37 capital improvement projects to address the deficiencies of the regional
water system.
Palo Alto and the other BAWSCA agencies have worked with the SFPUC since early 2003 to
prepare for the environmental review phase of the WSIP. Since the environmental review would
evaluate the impact of delivering additional water supplies to San Francisco and the BAWSCA
agencies, BAWSCA and the SFPUC coordinated on the establishment of the future water
supplies needs for the region. Water supply demands for 2030 were calculated for each agency
after incorporating cost-effective water conservation measures. The BAWSCA agencies
committed to a total of 15 million gallons per day (MGD) of conservation, groundwater and
recycled water to meet future water supply needs. Palo Alto’s long-term demand projections
incorporated a savings of 4% from all measures found to be feasible and cost-effective at the
time. These measures and natural conservation from improved efficiency standards for water-
CMR: 417:08 Page 1 of 5
using fixtures and appliances resulted in no increased demand for water from the regional system
for Palo Alto.
Despite the 15 MGD committed to by the BAWSCA agencies, San Francisco and the BAWSCA
agencies indicated a need for 35 MGD of additional water by 2030 from the regional water
system. On June 27, 2007, the San Francisco Planning Department released the Draft Program
Environmental Impact Report (PEIR) on the SFPUC’s WSIP for public review and comment.
The WSIP proposed that the additional water supply needs for 2030 be met with 10 MGD of
additional conservation, water recycling and groundwater supply programs in the City and
County of San Francisco and 25 MGD from increased use of Tuolumne River water.
The Draft PEIR described the proposed WSIP, identified the environmental consequences
associated with implementation of the WSIP, specified mitigation measures to reduce significant
and potentially significant impacts, and analyzed and compared the environmental effects of
alternatives to the proposed program as required by the California Environmental Quality Act.
The Draft PEIR also included an analysis of three variants to the WSIP as requested by the
SFPUC.
On September 24, 2007, the Council considered comments on the Draft PEIR (Attachment B,
CMR: 370:07). On September 25, 2007, the City of Palo Alto submitted comments on the draft
PEIR to the San Francisco Planning Department (Attachment C).
DISCUSSION
On September 30, 2008, the San Francisco Planning Department released the Final PEIR on the
SFPUC’s WSIP. The Final PEIR consists of the Draft PEIR, comments and recommendations
received on the Draft PEIR, the responses of the lead agency to significant environmental points
raised in the review and consultation process and any other information added by the lead
agency.
Since publication Of the Draft PEIR in June 2007, the SFPUC has proposed revisions to the
WSIP in three areas, either in response to comments received on the Draft PEIR or as part of its
ongoing system operations and planning. These revisions include: (1) changes in the project
descriptions of two WSIP facility improvement projects (both of which help reduce impacts
associated with the projects as originally proposed) which affect overall system operations; (2)
updated water system assumptions and corresponding updates in the system modeling and
results; and (3) development of the Phased WSIP Variant, a "hybrid" program that is a
combination of the proposed program and one of the alternatives analyzed in the Draft PEIR.
The "Phased WSIP Variant" was developed by the SFPUC as an option that would involve full
implementation of the proposed WSIP facility improvement projects to ensure that the public
health, water quality, seismic safety, and delivery reliability goals are achieved as soon as
possible, but a phased implementation of water supply delivery through 2030. Phasing the water
supply element of the WSIP would allow the SFPUC and its wholesale customers to focus first
on implementing additional local recycled water, groundwater, and demand management actions
while minimizing additional diversions from the Tuolumne River. Under this variant, the
SFPUC would establish an interim, mid-term planning horizon--the year 2018. If the SFPUC
CMR: 417:08 Page 2 of 5
adopts this variant, it would make a decision about future water supply for its customers through
2018 only and defer a decision regarding long-term water supply until after 2018.
Under this variant, the SFPUC would limit average annual water deliveries supplied from its
watersheds to 265 million gallons per day (mgd), which represents the base-year level of supply
delivered from the SFPUC watersheds through the regional water system to both the retail and
wholesale customers analyzed in the Draft PEIR. The SFPUC would maintain the 265 mgd
average annual delivery of surface water from the SFPUC watersheds to existing levels through
2018. At the same time, through 2018, the SFPUC would implement the delivery and drought
reliability element of the WSIP, which would increase average annual diversions from the
Tuolumne River by about 2 mgd over the existing conditions.
By 2018, the demand on the SFPUC regional water system is projected to be 285 mgd,
consisting of 91 mgd for San Francisco and 194 mgd for the BAWSCA agencies. To satisfy the
remaining 20 mgd of demand on the regional system through2018 while holding deliveries from
the SFPUC watersheds to 265 mgd, the SFPUC proposes development of local conservation,
recycled water, and groundwater projects within its service area. As proposed under the WSIP,
the Phased WSIP Variant would develop 10 mgd of local supply and supply offsets through
conservation, recycled water and groundwater projects in San Francisco. The SFPUC also
proposes to develop an additional 10 mgd of local conservation, recycled water, and groundwater
within the service area.
By 2018, the SFPUC would reevaluate the delivery amount and consider whether to maintain
these delivery limitations from the SFPUC watersheds through 2030 or increase them, and
whether and how to provide additional supply to the BAWSCA agencies.
The Final PEIR determines that the potential environmental effects of the Phased WSIP Variant
fall within the range of impacts already evaluated in the Draft PEIR for the WSIP and-the
alternatives. Although the Phased WSIP Variant does not include a specific water supply
proposal beyond 2018, for purposes of environmental impact analysis and comparison to the
proposed WSIP and other alternatives evaluated in the PEIR, the PEIR does assess the range of
water supply that could be provided under this variant through 2030.
Table 13.1 in the Final PEIR, reproduced below, summarizes the SFPUC average annual water
deliveries to its retail (San Francisco) and wholesale (BAWSCA agencies) customers under the
Phased WSIP Variant. In that variant, the SFPUC proposes to establish an interim delivery
amount through the year 2018, and then to either maintain this same delivery amount through
2030 or increase it, possibly up to the. level proposed under the WSIP.
CMR: 417:08 Page 3 of 5
(SFPUC, WSIP, PEIR)
TABLE 13.1
SFPUC AVERAGE ANNUAL WATER DELIVERIES UNDER THE PHASED WSlP VARIANT
Supply Source
SFPUC Regional System Average Annual Water Deliveries (mgd)
WSIPExist|rig Condition (Proposed Program}Phased WSIP Variant200520302018
SFPUC Watersheds
Retail customersa 91 81 81
Wholesale customers 174 209 184
Total 265 290 265
Local Conservation. Recycled Water,
and Groundwater (not included inpurchase requests)
Retail customers
Wholesale customers
Total
0
0
10 10
0 0 -- 10b
10 10 - 20
Total from all sources 265 300 275 - 285
a The SFPUC retai~ customer deliveries include I n’.<jd de!ivered to Castie,^~<>d in the Pleasanton area that ~s supplied by local
groundwater rather than from the regional system. Thus, although this detivep.# amount is included ~n the SFPUC retail customer delivery
total. 90 mgd represents the current and future de:i’~eries to re[ai! customers that are and will continue to be made from Ihe regk>nal
s~tem.b A range ;s provided because 10 mgd may be provided by SFPUC in partnership with B~WSCA and wholesale customers or BAWSCA
and ~,~otesate customers may choose to seoarateiy deve;;op this 10 rngd.
As explained in the Final PEIR, although the SFPUC would only make a decision regarding
water supply through 2018 under the Phased WSIP Variant, after 2018 and through 2030 it is
possible that average annual deliveries to the wholesale customers could range from 184 mgd to
209 mgd, as shown in Table 13.1 (or 199 mgd, on the high end if it is an assumed additional 10
mgd of local conservation, recycled water and groundwater programs is implemented by 2018).
If, after 2018, the SFPUC decides to maintain the 184 mgd average annual limit on SFPUC
watershed deliveries to the wholesale customers, then by 2030 the SFPUC regional water system
deliveries to the wholesale customers could be up to 25 mgd less than their 209 mgd purchase
request amount. It is possible that, in combination with the additional local conservation,
recycled water, and groundwater already developed during the first phase of this variant, the
wholesale customers could receive up to their full 2030 purchase request amount of 209 mgd
with no shortfall.
Impact on Palo Alto
The impact on Palo Alto of the Phased WSIP Variant is not completely clear. Since Palo Alto
did not project and does not anticipate growth in water supply needs, the stricture to limit future
water deliveries from the regional water system of the variant may not negatively impact Palo
Alto. However, Palo Alto will need to re-examine its water needs and potential to implement
additional water efficiency programs along with all the BAWSCA agencies to ensure that all
CMR: 417:08 Page 4 of 5
water supplies are used as efficiently as possible. It is also true that Palo Alto residents use more
water per capita than most of the BAWSCA agencies. Additional efficiency programs, perhaps
related to water used on landscaping, may need to be evaluated. In addition, Palo Alto will need
to seriously evaluate expanding the recycled water distribution system to new users in the search
for solutions to the regional water supply issues.
The Final PEIR contains responses to Palo Alto’s comments on the Draft PEIR (Attachment D).
Many of the comments were acknowledged and additional information was provided as
appropriate. On the request for the PEIR to address the concept of an intertie with the Santa
Clara Valley Water District (SCVWD) the response was that the SCVWD does not have excess
water to transfer and, therefore, would not be a dependable future water source for the regional
water system. The Final PEIR also revised a paragraph describing Palo Alto’s parklands.
NEXT STEPS
The San Francisco Planning Commission is scheduled to certify the Final PEIR (if it is
determined to fulfill all requirements under the California Environmental Quality Act) on
October 30, 2008. On that same day, the SFPUC is expected to adopt the WSIP, including the
Phased WSIP Variant.
BAWSCA and its member agencies have already begun a study to update the estimates for future
water demand and the potential for efficiency measures that were developed in 2003 and 2004
for the Draft PEIR. This study is expected to identify additional water efficiency programs and
recycled water projects that can be completed to meet the water supply restrictions that are
expected to be adopted. One part of the study is the development of a plan to implement the
identified programs and projects.
ATTACHMENTS
A. September 30, 2008
go
C°
D.
PREPARED BY:
Memorandum from Ed Harrington, SFPUC General Manager
regarding Staff Recommendation for WSIP Adoption
CMR: 370:07 - Approval of Palo Alto’s Comments on Draft Program Environmental
Impact Report Concerning San Francisco Public Utilities Commission’s Water System
Improvement (Hetch-Hetchy) Program (without attachment)
September 25, 2007 Letter from the City of Palo Alto Mayor to San Francisco Planning
Department Regarding Comments on the Draft PEIR for SFPUC’s WSIP
Response in the Final PEIR to City of Palo Alto Comments on Draft PEIR
DEPARTMENT APPROVAL:
CITY MANAGER APPROVAL:
~uANE RATCHYE
tilities Assistant Director, Resource Management
Director, Utilities
KEENI~/~- ~¢
~Manager
CMR: 417:08 Page 5 of 5
ATTACHMENT A
WATER
POWER
GAVIN NEWSOM
MAYOR
ANN MOLLER CAEN
PRESIDENT
F,X, CROWLEYCOMMISS!ONER
FRANCESCA VIETOR
COMMISSIONER
ED HARRINGTON
GENERAL MANAGER
SAN FRANCISCO PUBLIC UTILITIES COMMISSION
OFFICE OF THE GENERAL MANAGER
1155 Market St., 1 lt~ Floor, San Francis~.o, CA 94103 ¯ Tel. (415) 554~1600. Fax (415) 554-3161. l-P( (415] 554.3488
DATE:
TO:
FROM:
SUBJECT:
September 30, 2008
Ann Moller Caen, SFPUC President
F.X. Crowley, SFPUC Commissioner
Francesca Viewer, SF2UC Commissioner
Ed Harrington, t_reneral Manager
Staff Recommendation for WSIP Adoption
Recommendation
Staff recommends that the San Francisco Public Utilities Commission (SFPUC) adopt
the Phased Water System Improvement Program (WSIP) Variant based on the
determinations and findings of the Final Programmatic Environmental Impact Report
(FPEIR) for the WSIP and other policy considerations.
Description
In March 2008, SFPUC staff requested the San Francisco Planning Department to
consider a variation of the WSIP called the Phased WSIP Variant. The SFPUC
identified this Variant in order to consider a program scenario that involves full
implementation o fall proposed WSIP facility improvement projects to insure that the
public health, seismic safety and delivery reliability goals are achieved as soon
possible but phased implementation of a water supply program to meet projected
water purchases through 2030. Deferring the 2030 water supply element of the
WSIP until 2018 would allow the SFPUC and its wholesale customers to focus first
on inaplementing additional local recycled water, groundwater and demand
management actions while minimizing additional diversions fromthe Tuolumne
River. Under the Phased WSIP Variant, the SFPUC would establish an interim mid-
term planning horizon - 2018. If the SFPUC adopts this Variant, it would make a
decision about future water supply to its customers through 2018 only, and would
defer a decision regarding long-term water supply until after 2018 in light of then-
current information and updated analysis. All non-water supply related WSIP goals
and level of service objectives would be achieved under this Variant and all
individual WSIP facility improvement projects proposed in the original WSIP would
be constructed.
Under the Phased WSIP Variant, the SFPUC would construct and operate all the
regional water system WSIP facility projects while (1) limiting water sales to an
average annual of 265 million gallons per day (mgd) from the watersheds through
2018; and (2) improving water supply reliability to meet the goals and objectives of
the WSIP including no greater than 20 percent rationing in any one year of a drought.
The Phased WSIP Variant would not provide water supply to meet 300 mgd average
SFPUC Staff Recommendation for WSIP Adoption
September 30, 2008
Page 2
amaual water sales in 2030 as proposed under the WSIP. Rather, the SFPUC would
supply no more than 265 mgd from the watersheds through 2018, and the SFPUC and
wholesale customers would collectively develop 20 mgd in conservation, recycled
water, and groundwater to meet or offset the regional water system purchase request
of 285 mgd in 2018. This 20 mgd of conservation, recycled water, and groundwater
includes development of 10 mgd of conservation, recycled water and groundwater in
San Francisco as proposed under the WSIP and 10 mgd of conservation, recycled
water and groundwater developed by the wholesale customers, which is in addition to
15 mgd of conservation, recycled water and groundwater already assumed by the
wholesale customers in preparing their regional water system purchase requests. The
SFPUC would also implement the delivery and drought reliability elemelats of the WSIP,
which would increase average annual diversions fi’om the Tuolumne River by about 2
mgd over existing base-year conditions.
Before 2018, the SFPUC would engage in a flew planning process to re-evaluate
water system demands and water supply options. As part of the process, the San
Francisco would conduct additional environmental studies and CEQA review as
appropriate to address the SFPUC’s recommendation regarding water supply and
proposed water system deliveries after 2018.
Background
The Water System Improvement Program (WSIP) is a multi-billion dollar, multi-year
capital program to upgrade the San Francisco’s regional and local drinking water
systems. The program will deliver improvements that enhance the San Francisco’s
ability to provide reliable, affordable, high quality drinking water to its 27 wholesale
customers and regional retail customers in Alameda, Santa Clara, and San Mateo
Counties, and to 800,000 retail customers in San Francisco, in an environmentally
sustainable manner.
Propositions A and E, passed in November 2002 by San Francisco voters, approved
financing for San Francisco’s portion of the water system improvements. Assembly
Bill No. 1823 (AB 1823); the Wholesale Regional Water System Security and
Reliability Act, also approved in 2002, required the City and County of San Francisco
to adopt a capital improvement program designed to restore and improve the regional
water system and to review and update the program as necessary.
Program Need
The need for the WSIP is predicated on the basic mission of the SFPUC, which is in
part:
To serve San Francisco and its Bay Area customers with reliable, high-quality and
affordable water, while maximizing benefits from power operations and
responsibly managing the resources to its care (SFPUC, 2002)
There are numerous factors contributing to the need for a comprehensive, systemwide
program such as the WSIP. In order to continue to reliably meet this mission in the
future, the SFPUC must plan for future needs as well as address existing, known
SFPUC Staff Recommendation for WSIP Adoption
September 30, 2008
Page 3
deficiencies. The proposed program addresses these needs and deficiencies,
including: ..
¯ Aging Infrastructure. The SFPUC regional water system is old. Many of its
components were built in the 1800s and early 1900s; parts of the regional water
system were built using now-outdated construction materials and/or methods and are
currently in need of major repair. As the system ages, its reliability decreases and the
risk of failure increases.
¯ Exposure to Seismic and Other Hazards. The 167-mile-long system crosses five
active earthquake faults. Many of the SFPUC regional water system components are
located on or in the immediate vicinity of maj or earthquake faults. Due to the age of
the system, many facilities do not meet modern seismic standards. To protect public
safety, the California Department of Water Resources, Division of Safety of Dams
has imposed operating restrictions on Calaveras and Crystal Springs Reservoirs,
reducing the local storage capacity and impairing normal system operations; this
storage capacity needs to be restored.
~o Maintain Water Quality. The regional water system currently meets or exceeds
existing water quality standards. However, system upgrades are needed to improve
the SFPUC’s ability to continue to maintain compliance with current water quality
standards and to meet anticipated future water quality standards under a range of
operating conditions, including such events as a major earthquake, without reducing
system reliability.
¯ Improve Asset Management and Delivery Reliability. In order to implement a
feasible asset management program in the future that will provide continuous
maintenance and repairs to facilities, the regional water system requires redundancy
(i.e., backup) of some critical facilities necessary to meeting day-tO-day customer
water supply needs. Without adequate redundancy of critical facilities, the SFPUC
has limited operational flexibility in’the event of an emergency or a system failure, as
well as constraints on conducting adequate system inspection and maintenance.
° Meet Customer Water Demands. Water demand among SFPUC customers is
predicted to increase over the next 25 years. Additional supplies are needed to satisfy
current demand in drought years and projected 2030 demand in all years. The
experience of the last 150 years of record as well as recent studies on California’s
climate show the region is susceptible to droughts. Two of the most severe droughts
occurred during the past 30 years. The regional water system currently has
insufficient water supply to meet customer demand during a prolonged drought, and
this situation will worsen in the future.
To address these challenges to the reliability of the regional water system, the SFPUC
must replace or upgrade numerous components of the system and add some new
components--thus the need for the WSIP and its associated facility improvement
projects.
SFPUC Staff Recommendation for WSIP Adoption
September 30, 2008
Page 4
Program Goals and Ob/ectives
The WSIP goals and objectives were developed based on a planning horizon through
2030. The SFPUC selected the year 2030 because published population projections
generally do not extend beyond 20 to 25 years, and the agency determined the 2030
forecasts to be the most reasonably foreseeable future condition. The goals and
objectives are founded ontwo fundamental principles pertaining to the existing
regional water system: (1) maintaining a clean, unfiltered water source from the
Hetch Hetchy system, and (2) maintaining a gravity-driven system.
The overall goals of the WSIP for the regional water system are to: .
¯ Maintain high-quality water and a gravity-driven system
¯ Reduce vulnerability to earthquakes
¯ Increase delivery reliability
¯ Meet customer water supply needs
¯ Enhance sustainability
¯ Achieve a cost-effective, fully operational system
To further these program goals, the WSIP includes objectives that address regional
water system performance. The following table presents these objectives as they
relate to the WSIP goals. The system performance objectives describe and, in many
cases, more specifically quantify, what the regional water system proposes to achieve
under the WSIP, and thereby guide the water supply actions, facility improvements,
operations, and maintenance requirements included in the WSIP.
WSIP GOALS AND OBJECTIVES
Program Goal System Performance Objective
Water Quality- o
maintain high water
quality
Design improvements to meet current and foreseeable future federal and
state water quality requirements.
Provide clean, unfiltered water originating from Hetch Hetchy Reservoir
and filtered water from local watersheds.
Seismic Reliability - ¯
reduce vulnerability to
earthquakes ~
Continue to implement watershed protection measures.
Design improvements to meet current seismic standards.
Deliver basic service to the three regions in the service area (E~st/South
Bay, Peninsula, and San Francisco) within 24 hours after a major
earthquake. Basic service is defined as average winter-month usage, and the
performance objective for the regional system is 215 mgd. The performance
objective is to provide delivery to at least 70 percent of the turnouts in each
region, with 96, 37, and 82 mgd delivered to the East/South Bay, Peninsula,
and San Francisco, respectively.
Restore facilities to meet average-day demand within 30 days after a major
earthquake,
SFPUC Staff Recommendation for WSIP Adoption
September 30, 2008
Page 5
Program !~oal
Delivery Reliability-
increase delivery
reliability and intprove
ability to maintain the
system
System Performance Objective
Provide operational flexibility to allow planned maintenance shutdown of
individual facilities without interrupting customer service.
o Provide operational flexibility to minimize the risk of service interruption
due to unplanned facility upsets or outages.
Provide operational flexibility and system capacity to replenish local
reservoirs as needed.
Water Supply - meet
customer water needs in
non-drought and drought
peri~Ms
Sustainability - enhance
sustainability in all
8yslem activities
Cost-effectiveness -
achieve a cost-effective,
fully operational system
Meet the estimated average annual demand of 300 mgd for 2030 under the
conditions of one planned shutdown of a maj or facility for maintenance
concurrent with one unplanned facility outage due to a natural disaster,
emergency, or facility failure/upset. -
Meet average annual water purchase requirements of 300 mgd from retail
and wholesale customers during non -drought years for system demands
through 2030
Meet dry-year delivery needs through 2030 while limiting rationing to a
m~.,dmum 20 percent system-wide reduction in water service during
extended droughts.
Diversify water supply options during non-drought and drought periods.
Improve use of new water sources and drought management, including
groundwater, recycled water, conservation, and transfers.
Manage natural resources and physical systems to protect watershed
ecosystems.
Meet, at a minimum, all current and anticipated legal requirements for
protection offish and wildlife habitat,
Manage natural resources and physical systems to protect public health and
safety.
Ensure cost-effective use of funds~
Maintain gravity-driven system.
Implen~ent regular inspection and maintenance program for all facilities.
The Phased WSIP Variant
The Phased WSIP Variant achieves the original WSIP goals and objectives as
outlined above with one exception: the Phased WSIP Variant does not propose to
mee~ the projected wholesale and retail needs for 300 mgd water purchases in 2030.
Instead, the Variant establishes an interim mid-term planning horizon of 2018, and
focuses on meeting the projected wholesale and retail purchase needs through 2018
only. Any decision regarding long-term water supply beyond the interim planning
horizon would be deferred until 2018 based on additional information and updated
analysis.
As described in the FPEIR, purchases in 2018 are projected to be 285 mgd (this
:includes 15 mgd of conservation, recycled water, and groundwater already factored in
the purchase requests for the wholesale customers). The Phased WSIP Variant would
meet only 265 mgd of retail and wholesale customer purchases from the SFPUC
watersheds, and meet or offset the remaining 20 mgd through conservation, recycled
SFPUC Staff Recommendation for WSIP Adoption
September 30, 2008
Page 6
water, arid groundwater in the retail and wholesale service areas. Ten mgd of this
would be met, as proposed under the WSIP, through conservation, recycled water,
and ~roundwater projects in San Francisco. The FPEIR analyzed the following three
options to meet the remaining 10 mgd:
The SFPUC, wholesale customers and BAWSCA partner to develop an
additional 10 mgd in local conservation, recycled water, and groundwater in
the service area; or
BAWSCA and the wholesale customers develop an additional 10 mgd in local
conservation, recycled water, and groundwater within the wholesale customer
service area independent of the SFPUC; or
Individual wholesale customers develop 10 mgd of additional conservation,
recycled water, and groundwater on their own within their individual service
area.
The SFPUC and BAWSCA staffhave worked together to ensure demand in 2018 is
met. The following describes total demand in the regional water system service area
in 2018 and the proposal for meeting demand.
Total demand in the regional water system service area is projected to be 417.4 mgd
in 2018. As presented in the table below, plumbing code savings, coupled with the
use of other sources by retail and wholesale customers, result in purchases from the
regional water system of 299.2 mgd in 2018 (91 mgd retail; 208.2 mgd wholesale).
The wholesale customers assumed 15 mgd of conservation, recycled water and
groundwater in preparing the purchase requests to be analyzed in the PEIR. Thus,
total purchase requests, as considered in ,the FPEIR, from the regional water system in
2018 are estimated at 284.2 mgd (91 mgd retail; 193.2 mgd wholesale),a In an effort
to limit sales from the SFPUC watersbeds to 265 mgd, additional development of
conservation, groundwater, and recycled water in the service area is necessary to
reduce total purchases from the regional water system even further.
Ten ,mgd of conservation, recycled water and groundwater is planned under the
proposed .WSIP in the retail service area by 2018, while an additional 10 mgd of
conservation, recycled water, and groundwater is proposed to be developed in the
wholesale service area. As presented in the table below, the development of a total of
35 mgd of conservation, recycled water, and groundwater in the service area, within
the next decade, will reduce demand on the Tuolumne River and local watersheds,
bringing the projected total regional water system purchases down to 264.2 in 2018
(81 mgd retail; 183.2 wholesale, including 9 mgd for the cities of San Jose and Santa
Clara).
~ The FPEIR uses rotmded values in developing purchase requests from the regional water system. In
2018, purchase requests in the FPEIR are estimated at 285 mgd (91 mgd retail; 194 mgd wholesale).
SFPUC Staff Recommendation for WSIP Adoption
September 30, 2008
Page 7
2018 Demand and Projected Purchases from the Regional Water System (all
aumbers in MGD) "
Total Demand (including Plumbing Code Savings)
- minus plumbing code savings
- minus base use of other sources2
- minus additional supply from other sources2
Total Regional Water System Purchases Before
Conservation/Recycled Water/Groundwater
- minus planned conservation, groundwater, recycled
water reflected in Regional Water System purchase
requests (increase from 2002-2018)
Total Regional Water System Purchase Request
- minus additional conservation, groundwater, recycled
water not reflected in Regional Water System Ptirchase
requests (increase from 2002-2018)
Total Purchases from Regional Water System after
Conservation/Recycled Water/Groundwater After
Recommended SFPUC Action on WSIP
Total Conservation/Recycled Water/Groundwater
Retail
98.8
6.8
1.0
91.0
91.0
10.0
81.0
10.0
Wholesale
318.6
16.7
84.5
9.2
208.2
15.0
193.2
10.0
183.2
25.0
Total
417.4
23.5
85.5
9.2
299.2
15.0
284.2
20.0
264.2
35.0
The Phased WSIP Variant includes the following key program elements:
¯Full implementation of all WSIP facility improvement projects.
¯Water supply delivery to regional water system customers through 2018 only
of 265 mgd average annual target delivery originating from the watersheds.
This includes 183.2 mgd for the wholesale customers (including 9 mgd for the
cities of San Jose and Santa Clara), and 81 mgd for the retail customers.
Water supply sources include: 265 mgd average annual from the Tuolurrme
River and local watersheds plus 20 mgd of conservation, recycled water and
groundwater developed within the service area (10 mgd retail; 10 mgd
wholesale; in addition 15 mgd of conservation, recycled water and groundwater
assumed as part of the wholesale customers purchase requests).
Dry-year water transfers coupled with the Westside Groundwater Basin
Conjunctive Use Project.
Re-evaluation of 2030 demand projections, potential regional water system ¯
purchase requests, and water supply options by 2018 and a separate SFPUC
decision in 2018 regarding regional water system water deliveries after 2018.
Financial incentives to limit water sales to an average annual of 265 mgd from
the watersheds.
To summarize, the SFPUC will deIiver 265 mgd from the SFPUC watersheds. By
limiting sales to 265 mgd average annual from the watersheds, the SFPUC will not
increase average annual Tuolumne River diversions from base-year conditions to
meet non-drought year needs. To meet the delivery reliability goals of the WSIP,
z Examples of other sources include State Water Project water, Santa Clara Valley Water District
supplies, groundwater, and local surface water.
SFPUC Staff Recommendation for WSIP Adoption
September 30, 2008
Page 8
includin~ drought reliability, the SFPUC would need to divert an additional 2 mgd
aver.age annual from ~he Tuolumne River. As part of adoption of this program, the
SFPUC will implement the mitigation measures identified for this Variant in the
FPEIR.
The SFPUC must maintain water deliveries to all its customers for the protection of
public health and safety. Therefore, the SFPUC will develop f’mancial incentives to
limit water sales to an average annual of 265 mgd from the watersheds through 2018.
Additionally, in the event that sales to all its customers exceed 265 mgd average
annual prior to the implementation of the conservation, recycled water and
groundwater projects, the SFPUC would implement the applicable miligation
measures set forth in the FPEIR.
Sumtnary
To accomplish all of its objectives, the SFPUC must move forward with the WSIP
facilities as proposed to improve seismic and water delivery reliability, meet current
and future water quality regulations, provide for additional regional water system
conveyance for maintenance, and meet water supply reliability goals. Like all water
utilities, the SFPUC must consider current needs as well as possible future changes
and unplanned outages, and design a system that achieves a balance anaong the
numerous objectives, functions and risks a water supply must face. Approval of the
Phased WSIP Variant will allow the SFPUC to accomplish these many goals.
ATTACHMENT B
TO:HONORABLE CITY COUNCIL
FROM:CITY MANAGER DEPARTMENT: UTILITIES
DATE:SEPTEMBER 24, 2007 CMR:370:07
SUBJECT:APPROVAL OF PALO ALTO’S COMMENTS ON DRAFT PROGRAM
ENVIRONMENTAL IMPACT REPORT CONCERNING SAN
FRANCISCO PUBLIC UTILITIES COMMISSION’SWATER SYSTEM
IMPROVEMENT (HETCH-HETCHY) PROGRAM
RECOMMENDATION
Staff recommends that the City Council approve Palo Alto’s comments on the Draft Program
Environmental Impact Report concerning the San Francisco Public Utilities Commission’s Water
System Improvement Program, including informing San Francisco of Palo Alto’s expectations
and wish to be consulted on any projects being constructed in and around Palo Alto and on the
use of any of the water resource options that Palo Alto controls, such as recycled water,
groundwater, or water efficiency programs.
BACKGROUND
In January 2000, the City’s primary water supplier, the San Francisco Public Utilities
Commission (SFPUC), released a report indicating that its regional water system is vulnerable to
damage from a large earthquake and that water supplies could be cut off to the users, including
Palo Alto, for up to 60 days. On July 10, 2000, the City Council adopted a resolution
recommending that the SFPUC take prompt action to improve regional water supply reliability
and quality [CMR:311:00].
The SFPUC proposes to implement the Water System Improvement Program (WSIP) to repair
and replace aging portions of its water delivery system. The system currently serves 2.4 million
people inSan Francisco, San Mateo, Santa Clara, Alameda and Tuolumne counties. The WSIP is
a program to implement the service goals and system performance objectives established by the
SFPUC for the regional water system in the areas of water quality, seismic reliability, delivery
reliability and water supply through the year 2030. The SFPUC approved the WSIP in
November 2005.
CMR:370:07 Page 1 of 11
Palo Alto is a member of the Bay Area Water Supply and Conservation Agency (BAWSCA).
BAWSCA is a special district that represents the interests of 25 cities and water districts, and two
private utilities that purchase water wholesale from the San Francisco regional water system.
These agencies, in turn, provide water to 1.7 million people, businesses and community
organizations in Alameda, Santa Clara and San Mateo counties. Palo Alto and the other
BAWSCA member agencies are on record in support of the SFPUC’s program to improve the
regional water system. The environmental review process is a major step in receiving approvals
to proceed towards implementation of the WSIR
Since early 2003, in preparation for the environmental review phase of the WSIP, BAWSCA and
SFPUC have coordinated on completing the foundational work of establishing the water supply
needs for the BAWSCA agencies and San Francisco through 2030. As part of this effort, San
Francisco obtained copies of each land use planning agency’s adopted general or comprehensive
plan. The long-term demands were calculated for each agency using a detailed end-use
forecasting model. The result of those calculations, Palo Alto’s long-term water demands, were
provided to the City Council on March 15, 2004 [CMR:106:04]. These demand projections
included the natural efficiency improvements that would take place as a result of changes in the
pl,umbing codes since 1992 requiring new fixtures to be water conserving.
After establishing the long-term demands for each BAWSCA agency, SFPUC conducted an
analysis of thirty-two water conservation measures to determine which measures would be
effective in each agency’s service area. On September 13, 2004, the Council received an
information report [CMR:395:04] on this evaluation. That report concluded that the long-term
conservation savings potential for Palo Alto is between 1.6% and 4% of the water demands in
2030. Palo Alto selected the high end of this range as the basis to determine how much water
Palo Alto plans to purchase from San Francisco. A report to the City Council on October 25,
2004 [CMR:449:04] provided Palo Alto’s estimate of water purchases from San Francisco by
2030.
These water purchase estimates for Palo Alto, the other BAWSCA agencies, and San Francisco
provide the basis for the water supply needs expected to be placed on the regional water system.
The SFPUC provided these estimates to the San Francisco Planning Department to use in its
preparation of the PElR for the WSIR
The California Environmental Quality Act (CEQA) requires that the public be informed about
the significant environmental effects of a project or program, and ways to avoid or reduce those
~nvironmental effects, before that project or program is approved. In accordance with the
requirements of CEQA, the San Francisco Planning Department issued a Notice of Preparation
(NOP) of the Program Environmental Impact Report (PEIR) for the WSIP on September 6, 2005.
On June 29, 2007, the San Francisco Planning Department issued a public notice announcing the
availability of the Draft PEIR for the SFPUC’s WSIP. The public notice provided the following
Program Description: "The San Francisco Public Utilities Commission (SFPUC) proposes to
adopt and implement the WSIP to increase the reliability of the regional water system, which
provides drinking water to 2.4 million people in San Francisco, San Mateo, Santa Clara,
Alameda, and Tuolumne Counties. WSIP implementation would involve using additional water
CMR:370:07 Page 2 of 11
supplies to serve customer needs through 2030 as well as construction of repairs and/or
improvements to many facilities within the existing system located in Tuolumne, Stanislaus, San
Joaquin, Alameda, Santa Clara, San Mateo, and San Francisco Counties."
On July 23, 2007, the Mayor appointed an ad-hoc subcommittee of the Council to work with
staff to craft the proposed Council comments to the PEIR. The subcommittee consisted of Vice
Mayor Klein and Council Members Mossar and Beecham. The subcommittee met three times to
review the Draft PEIR and to develop comments for Council consideration.
DISCUSSION
San Francisco’s Public Notice announcing the availability of the draft PEIR provided the
following Summary of Impact Analysis:
"The Draft PEIR evaluates the environmental effects of the proposed changes in
water supply, including growth-inducing impacts, as well as the general
environmental effects of implementing 22 facility projects. The analysis in the
Draft PEIR finds that the WSIP would support planned growth in the existing
SFPUC service area and indirect effects of growth are significant and
unavoidable. All other impacts resulting from water supply changes could be
mitigated to a less-than-significant level, with the exception of an unavoidable
impact on streamflow for about two miles in Alameda Creek and a potentially
significant and unavoidable fisheries impact in Crystal Springs Reservoir. Other
potentially significant but mitigable impacts as a result of water supply changes
include: impacts on water quality, fishery resources, terrestrial biological
resources, recreation and visual resources in the watersheds of either the
Tuolumne River, Alameda Creek, San Mateo Creek, or Pilarcitos Creek; and
impacts on groundwater and related resources in the Westside Groundwater
Basin.
"The environmental analysis also determined that most of the impacts associated
with implementing facility projects could be mitigated to a less-than significant
level, although some impacts in the areas of land use, visual resources, cultural
resources, biological resources, noise, vibration, air quality, and traffic were
conservatively identified as potentially significant and unavoidable at the
programmatic level. These impact determinations may be revised during
subsequent environmental review of individual facility improvement projects. The
Draft PEIR identifies potentially significant, but mitigable impacts from
construction and operation of 22 facility projects in the areas of land use~ visual
quality, geology, hydrology/water quality, biological resources, cultural resources,
traffic, air quality, noise, vibration, public services, utilities, recreational
resources, agricultural resources, hazards, and energy.
"The Draft PEIR also evaluates the environmental effects of variations of and
alternatives to the WSIP."
CMR:370:07 Page 3 of 11
Level of Service Goals
The service goals and performance objectives, established by SFPUC, include:
Water Quality - meet or exceed all current and anticipated water quality requirements
Seismic Reliability - restore basic service (wintertime usage) within 24 hours after a major
earthquake and full service within 30 days
Delivery reliability - allow for system redundancy so that there will be no disruption of
service in the event of one planned and one unplanned outage of major facilities.
Water Supply fully meet customer purchase requests through the year 2030 in non-drought
years.
Drought Protection - partially meet customer demands in drought years so the maximum
amount of rationing in any year of the design drought does not result in more than a 20
percent system wide reduction in delivery of the 2030 purchase requests
Environmental stewardship - enhance sustainability in all system activities
Water Supply
Regarding water supply, the Draft PEIR notes that the proposed program, the WSIP, would serve
the average annual retail and wholesale customer purchase request of 300 million gallons per day
(MGD) from SFPUC in the year 2030. This is 35 MGD more than current annual average
delivery of 265 MGD from the regional system. The water supply to meet the 35 MGD of
increased demand includes 25 MGD of increased use of Tuolumne River water under San
Francisco’s existing water rights and 10 MGD of increased conservation, water recycling and
groundwater supply programs in the City and County of San Francisco.
The proposed WSIP’s drought year water supply includes: (1) reduced supplies from local
sources and the Tuolumne River; (2) restoring historic storage capacities in Calaveras and
Crystal Springs Reservoirs; (3) acquiring 23 MGD of water though transfer agreements with the
Modesto Irrigation District and the Turlock Irrigation District; (4) implementing a groundwater
program to store water for recharge in non-drought years; and (5) requiring up to 20% system-
wide rationing in any year of a drought:
Environmental Impacts of WSIP ~
The evaluation of environmental impacts of the WSIP in the Draft PEIR include: (1) impacts
associated with facility improvement projects; (2) impacts associated with water supply and
system operations; and (3) growth-inducement potential and indirect effects of growth.
1. Impacts associated with facility improvement projects
¯ The Draft PEIR indicates that most of the impacts associated with the WSIP projects occur
during the construction phase and can be mitigated to less than significant. Some impacts were
determined to be potentially significant and unavoidable and mitigations were identified in the
PEIR. Impacts from implementation of WSIP projects exist, but implementation of the identified
mitigation measures would reduce these impacts to less than significant levels.
2.Impacts associated with water supply and system operations
The Draft PEIR evaluates the impacts of the WSIP water supply and system operations on the
watersheds which are the supply sources of the regional water system. The Draft PEIR notes that
CMR:370:07 Page 4 of 11
the impacts can be less than significant with proposed mitigation measures, except for the
following: a) a significant and unavoidable impact in the Alameda Creek watershed below the
Alameda Creek Diversion Dam; and b) a potential significant and unavoidable impact in the San
Mateo creek watershed on fishery resources in Crystal Springs Reservoir.
Impacts on the upper Tuolumne River meadow habitat are mitigable with controlled releases.
Impacts on fishery resources on the lower Tuolumne River below La Grange Dam are significant
and include a listed species. Mitigation measures identified include water transfers from
MID/TID or enhanced fishery protection projects.
3. Growth-inducement potential and indirect effects of growth.
According to the Draft PEIR, the WSIP would support planned growth in the SFPUC service
area and growth inducement impacts cannot be entirely mitigated. The Draft PEIR states that the
WSIP supports planned growth in the area served by the regional water system. Most of the
growth is infill, or "smart growth" in existing developed areas: Most of the growth identified has
been addressed in adopted general plans, but the planning horizons for many general plans do not
extend to 2030, the planning horizon for the WSIP. Palo Alto’s comprehensive plan, adopted in
1998, has a planning horizon of 2010.
Alternatives to the Proposed Program
The Draft PEIR evaluated seven alternatives to the proposed WSIP:
1. No Program Alternative
Only projects that are required by regulations would be completed in this alternative. Seismic
and delivery reliability goals would not be achieved. Although in normal and wet years
additional water would be diverted from the Tuolumne River under San Francisco’s water rights,
more severe rationing would be required in droughts since the transfers with MID/TID would not
be effected and the additional conservation, recycled water, and groundwater projects would not
be completed. The Draft PEIR concludes that the regional water system would be placed at
significant risk due to seismic events under this alternative.
2. No Purchase Request Increase Alternative
Under this alternative, SFPUC’s wholesale customers would receive additional water up to the
amount required under the existing Master Water Contract between San Francisco and the
SFPUC’s wholesale customers, including Palo Alto. Currently, the wholesale customers
purchase about 170 MGD and the Master Water Contract requires that San Francisco deliver up
to 184 MGD. However, the projected wholesale customer’s purchase requests in 2030 of 209
MDG are not served under this alternative. The Draft PEIR notes that the wholesale customers
may seek supplemental supplies to meet their long-term demands, but impacts from those
potential actions are not analyzed. In droughts, water transfers from MID/TID would total 1
MGD, instead of the 23 MGD in the Proposed WSIE
The Draft PEIR notes that additional development in the SFPUC service area might be slowed
somewhat, but it is likely that growth would occur elsewhere in the Bay Area or in the Central
Valley. Growth in these outlying areas could have more severe environmental impacts due to the
CMR:370:07 Page 5 of 11
effects of new development versus infill that would occur in the communities served by the
regional system.
3. Aggressive Conservation/Water Recycling and Local Groundwater Alternative
All WSIP facilities would be constructed in this alternative, but the additional 25 MGD of water
purchase requests through 2030 would be met by about 19 MGD of aggressive conservation,
water recycling, and local groundwater projects. The additional water purchase requests would
be either: 1) additional 6 MGD of Tuolumne River diversions; or 2) not be met. If the additional
purchase requests are not met, then the maximum rationing amount would increase to 25%,
rather than the 20% maximum under the WSIE
SFPUC worked with BAWSCA to identify potential additional conservation, water recycling and
local groundwater projects that were not included in the demand projections. Projects were
classified into three categories: (1) projects likely to be implemented; (2) projects in early
planning stages; and (3) potential projects for future consideration.
There were two projects in Category 1, projects likely to be implemented, that were not included
in the 10 MGD of recycled water, conservation, and groundwater projects included inthe WSIE
Ten projects in Category 2, projects in early planning stages, were identified. Expanding the
recycled water distribution system in Palo Alto was included in this category of projects with a
maximum yield of 1 MGD. The range of yield for all Category 2 projects was 5.1 to 15.2 MGD.
Category 3 projects identified are conceptual in nature and have not yet been determined to be
feasible. The five projects in this category could yield between 0.5 and 2.23 MGD. The total
amount of conservation or new water supply from the projects totals up to 19 MGD if all the
projects are completed, including those for which no planning or feasibility studies have been
done. The Draft PEIR calls the 19 MGD "an optimistic, high-end estimate based on very
preliminary studies."
The Draft PEIR states that this alternative may not meet the seismic objectives and could
partially, but not fully, meet the delivery reliability and water supply performance objectives. In
addition, this alternative would provide less drought year supply reliability than the WSIR
Additional environmental impacts from development of recycled water and groundwater projects
would occur under this scenario, but these would be mostly related to construction, water quality,
and use of energy. The growth inducement potential would be similar to that for the No Program
Alternative.
4.Lower Tuolumne River Diversion Alternative
In this alternative, all WSIP facilities would be implemented and increased customer purchase
requests would be served from diversions from the lower Tuolumne River near its confluence
with the San Joaquin River. This alternative wou~d result in additional environmental impacts
from construction and operation of additional conveyance and treatment facilities to divert,
transport, and treat the new regional system supply.
This alternative would only partially meet the water quality goal and it is uncertain that the
seismic and delivery reliability goals would be met. The water supply reliability goal would be
CMR:370:07 Page 6 of 11
met, but the sustainability objectives may not be met due to the need to resolve numerous
regulatory and permitting issues, including the effects on fisheries in the lower Tuolumne. Due
to significant increases in energy use, the cost-effectiveness goal would not be achieved.
The additional flows on the lower Tuolumne River above the diversion point near the confluence
with the San Joaquin River would benefit fisheries, habitat, and recreation. However, operation
of the intake structures is critical as they could result in trapping of certain critical fish species.
Additional environmental impacts include greater energy use and impacts from construction and
operation of the conveyance, pumping, and treatment facilities.
5.Year-Round Desalination at Oceanside Alternative
All WSIP facilities would be implemented in this alternative. This alternative does not include
any increased diversions from the Tuolumne River since a new 25 MGD desalination plant in
San Francisco would be constructed and operated year-round to serve additional customer
purchase requests.
Most of the service objectives are met for this alternative with the possible exception of the
sustainability goal due to the regulatory and permitting issues related to building a desalination
facility. Additionally, the cost-effectiveness goal is not met due to increased energy use and the
cost for the new facilities.
Increased environmental impacts would occur due to the construction and operation of the
additional facilities, which include an intake structure, pipelines, pump stations, and the
desalination plant. This alternative would not result in changes in average annual releases to the
upper Tuolumne River, but changes could occur due to operational changes. Occasional
differences in releases in the lower Tuolumne River could occur, but no changes in average
annual releases.
6. Regional Desalination for Drought Alternative
sFPUc is currently investigating the construction of a regional desalination plant with other
regional water supply agencies in the Bay Area. This alternative would implement all the WSIP
projects and operate this regional plant to provide the SFPUC with supplemental water supplies
in dry years. This alternative is the same as Variant 2 described below.
7.Modified WSIP Alternative
The Draft PEIR identified this alternative as the "environmentally superior alterative." All the
WSIP facilities would be constructed, but system operations would be modified to minimize
environmental impacts. Key features of this alterative include:
¯Transfer of conserved water from MID and TID.
¯Implementation of minimum stream flow requirements in a portion of Alameda Creek.
o Modification of operations at Pilarcitos Creek to accommodate increased demands from
Coastside County Water District, a wholesale water customer;
-Management of the levels at Crystal Springs Reservoir to preserve upland habitat; and
o Implementation of 5-10 MGD of additional conservation, water recycling, and local
groundwater projects in the service areas of the wholesale customers.
CMR:370:07 Page 7 of 11
This concept requires the implementation of water conservation measures in the MID and TID
service areas with the freed up water being used by SFPUC for delivery into the regional water
system. The transfer of conserved water would be implemented every year, not only as a dry-
year supplement, so that WSIP impacts on the lower Tuolumne River could be avoided.
The additional 5-10 MGD of conservation, water recycling and local groundwater projects would
likely be a subset of the most feasible of those identified in the Aggressive Conservation/Water
Recycling and Local Groundwater Alternative (see #3 above).
The Modified WSIP Alternative would reduce impacts on natural resources along the lower
Tuolumne River, parts of Alameda Creek, l:’ilarcitos Creek and Reservoir, and Crystal Springs
Reservoir. The additional conservation, water recycling, and local groundwater projects would
cause construction impacts, but they are minor compared to the fewer and less severe
environmental impacts on the Tuolumne River for this alternative.
The ad-hoc Council subcommittee supported the Modified WSIP Alternative.
Water Supply Variants
The Draft PEIR evaluated three water supply variants to the proposed WSIP, which differ from
the proposed WSIP in water supply sources or rationing limits, but are identical in terms of
meeting water quality, seismic reliability, and delivery reliability goals. These variants are not
complete alternatives, but could be substituted for the water supply component of some of the
alternatives described above.
I.Variant 1 -All Tuolumne
This variant would accommodate the entire 35 MGD of additional water supply needs from the
Tuolumne River and would not include the 10 MGD of recycled water, conservation, and
groundwater projects that the WSIP includes. Modeling of historic hydrologic years indicates
that the system under this variant would require increased diversions from the Tuolumne River. of
32 MGD compared to existing conditions and 5 MGD compared to the proposed WSIR
Rationing in droughts would be both more frequent and more severe compared to the proposed
WSIR This variant would have slightly more severe impacts on the Tuolumne River resources
compared to the WSIP, although no additional mitigations measures would be required.
2. Variant 2 - Regional Desalination for Drought
This variant differs from the WSIP in that supplemental dry-year supplies would come from a
regional desalination plant instead of from drought-time water transfers from MID and TID.
This variant would result in slightly reduced impacts on the Tuolumne River resources due to the
absence of transfers from MID and TID. However, environmental impacts from the desalination
plant and conveyance facilities would be substantial due to the increased energy consumption
and impacts related to seawater intake structures and brine disposal.
3.Variant 3 - 10% Rationing
Under this variant, the maximum rationing during droughts would be reduced to 10%, compared
to the WSIP maximum rationing of 20%. This would be accomplished by increasing dry-year
transfers from MID and TID, thereby increasing average annual diversions from the Tuolumne
CMR:370:07 Page 8 of I 1
River (35 MGD compared to 23 MGD under the WSIP). These increased dry-year diversions
would result in somewhat more severe impacts on Tuolumne River resources, but not enough to
trigger additional mitigation measures. Overall, this variant and the WSIP would result in an
increase of average annual diversion from the Tuolumne River over current conditions of about
27 MGD over the 82-year hydrologic record.
Proposed Comments
The attached letter contains proposed comments on the Draft PEIR on SFPUC’s WSIP that were
developed by the Council ad-hoc subcommittee. The major comments summarized in the first
part of the letter are repeated below:
Palo Alto commends the City of San Francisco for completing the very comprehensive PEIR
for the WSIP. Preparing the Draft PEIR is a major undertaking and Palo Alto commends San
Francisco on its substantial effort. Overall, Palo Alto would support a finding that the Draft
PEIR on SFPUC’s WSIP is adequate and, therefore, satisfies CEQA requirements.
Palo Alto appreciates the precious nature of the water supplies delivered to it in a manner that
utilizes a well-engineered system designed to flow by gravity from the pristine mountain
source to end users in the Bay Area, and knows that the aging system of pipes, tunnels, dams
and water treatment plants is in dire need of upgrades.
Palo Alto urges San Francisco to move expeditiously to implement the seismic improvement
projects contained in the WSIP as they are urgent for earthquake reliability. Palo Alto’s City
Council has named emergency preparedness as one of its top three priorities.
Palo Alto supports the environmentally superior alternative identified in the Draft PEIR, the
"Modified WSIP" alternative. This alternative would result in less severe environmental
impacts, particularly on the lower Tuolumne River. Palo Alto supports reducing diversions
from the lower Tuolumne River as it believes that there is significant potential to conserve or
recycle water rather than diverting more water from the river.
¯Palo Alto is aware of other diverters of Tuolumne River water with significant potential for
implementing conservation measures. Palo Alto would support and commit to pay its share
for aggressive conservation measures in these areas as well as in the SFPUC’s service area.
Palo Alto is committed to implementing cost-effective conservation and water recycling
projects in Palo Alto itself.
¯The WSIP should limit drought year reductions to no more than 10% per year. Palo Alto is
concerned that a plan that incorporates up to 20% cutbacks in drought years discourages
long-term investments in conservation measures by providing what amounts to a "penalty"
for maximizing conservation in non-drought years.
The PEIR should clarify how the 2030 water demand projections were developed using Palo
Alto’s Comprehensive Plan, which incorporates populationand employment figures only
through 2010. Further, the PEIR should explain the inconsistency between ABAG’s 2030
population projections for Palo Alto and the population forecast used in the PEIR. Palo Alto
considers the PEIR estimates to be reasonable and realistic based on anticipated development
and historic growth rates for the City.
The WSIP project schedule should be coordinated with Palo Alto’s Gunn High School to
minimize construction impacts of Project BD-2 on the school, its students, and any other
users of the facilities.
CMR:370:07 Page 9 of 11
COMMISSION REVIEW AND RECOMMENDATIONS
The Utilities Advisory Commission (UAC) received a presentation on the Draft PEIR at its
September 5, 2007 meeting. The UAC unanimously recommended that the Council:
(1) Strongly support completion of the WSIP project to seismically improve the water system;
(2) Support the following activities recommended by BAWSCA:
¯Agencies should review PEIR for overall accuracy in describing retail agency activities
¯Agencies should review how their own systems and growth plans are described
¯Make sure comments do not unintentionally conflict with other wholesale customers
(intentional conflicts may exist)
¯Convey the urgency of the seismic improvements needed for the system - water supply
decisions are not urgent; and
(3)Include a cost effectiveness measure such as a cost not to exceed more than 10% of the
projected water rate of $1600/acre-ft for any conservation measures pursued within TID or
MID.
NEXT STEPS
Written comments on the Draft PEIR for SFPUC’s WSIP will be accepted by the San Francisco
Planning Department until close-of-business on October 1, 2007. Itis anticipated that the Final
PEIR will be certified in May 2008.
RESOURCE IMPACT
The estimated cost for SFPUC’s WSIP is incorporated into long-term cost projections. Any
alternatives that are identified in the PEIR will need to be evaluated as to the cost impact. City
Staff resources to monitor and participate in this project are budgeted. The cost for BAWSCA,
which is deeply involved in the process to represent its member agencies, is also included in the
water fund budget.
POLICY IMPLICATIONS
Comments submitted to San Francisco on the PEIR are in conformance with Council-approved
policy.
ENVIRONMENTAL REVIEW
Submitting comments on the Draft PEIR for SFPUC’s WSIP does not constitute a project under
the California Environmental Quality Act; therefore, no environmental assessment is required.
ATTACHMENT
A.Proposed Comments of the Council of the City of Palo Alto on the Draft PEIR for SFPUC’s
WSIP
CMR:370:07 Page l0 of ll
PREPARED BY:
JANE O. RATCHYE
Assistant Director of Utilities, Resource Management
DEPARTMENT APPROVAL:
VALERIE O. FONG
Director of Utilities
CITY MANAGER APPROVAL:
EMILY HARRISON
Assistant City Manager
CMR:370:07 Page 11 of 11
ATTACHMENT C
L PaloAIto
City of Palo Alto
Office of the Mayor and City Council
Scptd,nher 25.2{ff;?
Paul Mall×or. E~vironmenlal Review Officer, WSIP PEIR
Sun Francisco Phmning L)cpartment
1650 Missitm Slrcct. Suile 400
San Francisco. CA 94103
RECEIVED
SEP 2 6 2OO7
(;~ ry & COUNTY OF S.F.
¯., ~ ;q~,,,l~.tG OEPARI’MEN1
Re:Draft Program Environmental Impact Report for the San Francisco Public Utilities
Commission’s Water System Improvement Program
Dear Mr. Maltzer. "
The City ol’Palo Alto receives all.ol’its potable water supplies from the regional water system
operated by Ihc San Francisco Public Utilities Commission (SFPU(’). Palo Alto has great
interest in the Water System Improvement Program (WSIP) that aims to repair and upgrade the
regional water system to increase its reliability. Palo Alto undcrsllmds that the completion oflhc
Drali Program Environmental Impact Report (PEIR) lbr the WSIP is a sigrtilican! slep towards
timely COml)lcticm of the urgent seismic mlprovement projecls needed Ibr improved earthquake
reliability.
~ummarv of (~omments
Palo Alto commends Ihe City of San Francisco Ibr completing the very comprehensive PEIR
Ibr Ihe WSIP. Preparing lbc Draft PEIR is a-mqor unde~aking and Palo Alto commends San
Francisco on its substantial effort. Overall, Palo Alto would support a finding ll~al the Draft
PEIR on SFPUC’s WSI~ is adequate and, theref6re, salisfies CEQA requirements.
Palo Alto appmctates the precious nature and high quality of flat water supplies delivered ~o
it in a rammer that utilizes a well-engineered system designed to flow by gravity from the
prislmc motmlain source to end users in the Bay Area, and knows thal the aging system of
pipes, lunnels, dams and wuler lrcalmcnt phmts is in dire need of upgrades.
Palo Alto urges San Francisco to move cxpediliously to implement lhe seismic improvement
projccls contained in the WSIP as they are urgent tbr earthquake reliabilily. Palo Allo’s City
Council has named emergency preparedness as one of its toD priorities.
Palo Alto supports the environmentally superior allernalive identilqed in the Dra~i PEIR, the
"Modified WSIP" alternative. This alternative wotlld result in less severe environmental
impacts, Imrticuhtrly on the lower q’uohmme River. Palo Aim supports reducing diversions
fi’om the lower Tuohtnme River as it believes that there is s~gnificant potential to conse~e or
recycle xvamr ralher than di vetting more waler l~om ll~e river.
Palo Alto believes there is a significanl opportunity ~or impleme~ting conservalion measures
through cooperative efforl betxvcela lhe Bay Area’s wholesale water pttrchascrs mad other
divctters of Tuolumne River waler. Pa]o Alto would support and commil to pay its share tbt
aggressive conservation measures in these areas as well as in the SFPUC service area Palo
Alto is also committed to m~plemenling cost-effective conservation and water recycling ¯
i)rojccts in I’alo Alto itself. P.O. Box I02~P~lo Alto, CA ~3650.329.2477650.328.3631 fax
01
L PaloAIto
The WSIP should limit drought ycar rcductions to no more than 10% per ycar, Palo Alto is
concerned tha~ a plan that incorporates up to 20% cutbacks in drought years discourages
long-term investments in conscrvmion measures by providing wha( amounts to a "pcnaltf’
Ibr maximizing conservation in non-drought years.
The PEIR should clari[~ how dao 2030 water demand projections were developed using Palo
Aho’s (’omprehensive Plan, which incorporates population and employment figures only
through 2010. Further, II~e PEI R slmuld explain the inconsistency between ABAG’s 2030
populalion projeciio~3s for Palo Alto and the population tbrecast used in the PEIR. Palo Alto
considers the PEIR estimates to be reasonable and realistic based on anticipated development
and historic growth rates tbr the City.
The WSIP project schedule should be coordinalcd wilh Palo Alio’s Gunn High School to
minimize construction impacts of Project BD-2 on the school, its students, and any other
users o I" the Ihcilities.
The City of Pulo Alto rcspectf’ully submits the tbllowing more detailed comments on the subject
Drafl PEIR:
Palo Alto strongly soppo,-ts ~imely completion of the seismic improvement projects
contai~led in the WSIP. Palo Alto has understood since 1999 that a large earthquake in
the Bay Area could result in parts of the SFPUC service area being without water for up
to 60 days. The Palo Alto City Council adopted Resolution//7986 (Attachment A) io
July 2000 urg{tlg the SFPUC to take immediatc steps to safeguard the regional water
system [’tom earthquakes ;.|l’~d to secure water supplies lbr dry years. Subsequcndy, City
(’ouncil adopted Resolutions 08135 and #8136 (Attachments B and C) in support of bills
in Ihe state legislature that would form cntitics that could provide funding for the projects
to upgrade and repair tile regional water system.
The Palo Alto City Council has delermincd that emergency preparedness is lhe first o f its
top [’our priorities and strongly SUl~ports projects such as tbc WSIP that wot, ld increase
the seismic preparedness [br the community and better ensure its health and safety. Palo
Alto has also supported major local capital projects to in]prove the reliability of the Palo
Alto water distribution system.
Palo Alto st~pports the "Modified WSIP" alternative, which is identified as the
eaviroumentally superior alternative. Palo Alto believes that completing the seismic
upgrades and repairs of the regional water systcm arc critical. While ensurtng adequate
water supply tbr tile future ~s impo~lant, it is not nearly as urgent as completing the
se’sm~c improvements to tile regional system. Since water tlSC by San Francisco’s
wholesale customers remains below the anqount co~almitted il~ the existing Master Water
(’ontract. th,Src is time to e~plore lhe development of alter~late resources, including
recycled water and more aggressive conservation measures. Palo Alto slrongly supports
the development o f these allernate resources and is especial l y supportive of searching for
ware," conservatio~ opporhmities wherever they make the mosl sense, h~cluding in the
smwice ureas of Modesto and Turlock Irrigation Districts (M ID and TID).
T01
cont.
O2
I 03
O4
O5
L PaloAlto
Palo Alto believes that the transfers of conserved water from MI D and TID tha! are
part ol’O~e Modified WSIP alternative should be aggressively pursued, as this may
be potentially the least expensive and most effective "new" wa~er supply available
for the regional water system. Because MID and TID are by fi~r ll~c largest divc~ers of
w:uer []’om the Tuolumnc River, they are an obvious source o~conservalion opportunities
~ ~al would resull in minimizing ~olal river diversions. Pale Abe advocales fl~at SFPUC’s
wholesale customers pay For the best conservation measures, wherever [hey exist, to
improv~ environmental conditions on lhe Tuolumnc River. Pale Alto supports aggressive
i~ursuil ofconservalion opportunities in the MID and TID service areas and would
support creating a ~e[ increase to flows in the lower Tuolumnc River Io improve
cnvironmcntal conditions. Pale Alto is concerned about the environmental impacls
identified on the lower Tuolumnc River and supports significant improvements.
Polo Allo strongly supports efficieul use of natural resources, including water.
AllachlllCnt D conlains ordinances, resolutions, guidelines, policies, and reports that
document lhat support. For example, Polo Alto adopted enlbrceablc water use
regulations in 1989 that made certain wasteful practices illegal, such as landscape runoff
and using potable water to wash vehicles. In March 1991. Polo AIIo produced a booklet
¯ "Using the Pulo Alto Landscape Guidelines" to educate the public and developers on how
to use effective xvater management melhods such as automatic controller use, adjusting
~rrlgation lbr cvapotranspu’ation rates, zone planting For water needs, water budgeting,
separating irrigation meters, etc, to limit water used for landscape irrigation. Polo Alto
cn£orccs landscape water efficiency slzndards thal are in compliance with the State of ’
Calilbrnia’s Water Conservation in Landscaping Act (AB 325).
Polo Alto also strongly supports stewardship of tthe ~alural envirooment, iacluding
responsible managemeut of waler resources and smart growth practices. In October
2005, Polo Alto adopted modified Ahwahnee Water Principles. These principles address
isst~es such as water contamination, slorm water runoft~ flood damage, and reliabilily of
water supply. The principles promote compact community design, prcservation of
natural habitats, reduction of runoff, appropriate landscaping, use of permeable surfaces,
dual plumbing lbr nonpotablc water uses, and use O~ waler conservation technologies.
Polo Alto understands the relationship bclwccn land use practices and nalural resource
stewaMship. Many oflhe Ah~vabnee Water Principles arc roflcctcd in Polo Alto’s land
ttsc ordinances and practices. ~or example, in 2005, Polo Alto’s application ~ora Priority
Development Area designation near a transit station with the potential tbr in-fill growll~
was approved. In 2006, Polo Alto adopted an ordi]mnccamcndin~ its Municipul Code in
support of pcdcslrim~ and transit oriented development combining district, to implement
Polo Alto’s Housing Element and Comprehensive Plan policies in support of resource
con~ervalion. An amendnacnl to the Municipal Code in 2007 promotes snstainable
landscaping (Chapter 18.40.130), strema~ corridor protection (Chapter 18.40.140), and
storm wutcr qualily prolcction (Chapter 18.40.150). AIso, in 2007, Polo AIIo adopted an
ordinance amending Municipal Code Chapters 18.76 and 18.77, which address Polo
Alto’~ Sustaimd)ility Policy and Green Building practices.
06
07
O8
L PaloAIto
Pale Alto has long offered robust energy and water conservation programs, services
and technica! support, to its residential and business customers. As a provider of
natural gas and electricity as well as water, the Cfly of Pale Alto Utilities can effectively
promote cftlcicncy improvements by informing customers through its Utilities bill
inserts, Attachment E contains pasl bill inserts specifically related to water ei’ficicncy.
Along with bill inscms, City of Pale Alto Utilities has produced and/or distributed
marketing materials to its customers to promote e/’ficiency Attachment F contains a
sampling of marketing materials speci tic to water cfftcicnt programs and practices. C.ity
of Pale Alto Utilities also makes extensive use of’advertisements in print media to get out
the message on e fficiency. Attachment G contains copies o~’ads and articles promoting
water efficiency. City o1" Pale Alto Utilities also has an active school education program
to encourage efficient use of resources. Attachment H is a collection of’materials,
ir~cluding workbooks, flyers, and brochures used in school water efficiency education
programs.
Pale Alto’s efforts to manage demand citywide are effectively illustrated in the
grat}hic showing actual water consumption since 1965 in Attachment 1. Pale Alto’s
wa(cr usage peaked in 1976 at almost 20,000 acre-feet per year (AFY). After lowered
consunq)ti~,~n during the 1976-1977 drought period, usage rebounded to almost 19,000
AFY in 1988. EITorts to curb consumption during the extended drought period
]9~8 to 1992 were successful with consumptior~ since the drought ranging between
14,00(~ AF-Y and 15,000 AFY. Consumption projections lbr the future are flal at about
15,0()0 AF¥, I~u" lower than actual usage in 1976 despite increases in popuh~tion mad
economic activity in Pale Alto over tile last 30 years.
Du ring both tile 1976-77 and the ] 988-1992 drought periods, Pale Alto implemented
an extensive public educatian program on water conservation. Pale Alto produced
many materials designed to educate the public about the drought and promole waler
efficiency. A sampling of these materials is found in Attachment J.
Pale Alto has long struelured its residenlial retail water rates to promote efficient
use of water. Since July 1976, Pale Alto has had an "increasing block rate structure" for
residents. Increasing block rates increase as the quantity used increases. This rate
structure is considered by the Cali fomia Urban Water Conservation Council to be water
conserving pricing. Attachment K contains Pale Alto’s residential water rates since J uty
1976. During the 1988-1992 drought, Pale Alto was able to achieve the goals for water
use cutbacks by increasing the differential between the rates in lower and higher use tiers.
Because the conservation pricing, extensive public education, conservation programs, use
restrictions and related enforcement practices that wcrc nscd wcrc so cffcctive, Pale Alto
did not need to implement rations or limits for residenlial cuslomcrs during that drought.
Pale Alto’s ongoing efforts to encourage and invest in conservation are not well "[
served by the proposed drought-time rationing goal of cutbacks of up to 20%. With
tb¢ Ibl’¢al of a prc-dcternaincd rationing goal, Pale Alto and other wholesale cttstomers
may huve difficulty continning to invest in conservation measures and recycled walcr
projects. To the extcnt that demands are limited and wasles are elin’fim~ted, getting an
09
10
L PaloAIto
II.
additional 20% reduction in usage is and will bc difficuh. The Drall PEIR evaluated a
"’water supply variant" with 10% maximum drought reduclion and dclem~ined thai the
environn]enlal impacts of such an option were similar to the impacts ol’d]c proposed
program anti that the average annual diversions fiom the Tuolumne River would bc thc
same over a long period of time. Besides increasing supply reliability, the 10% ralioning
option would reduce the inevitable economic impact resulting from lhe extended
reduction of water supplies, Palo Alto supports thc 10% m aximum drought reduction
"’water supply wwianl" and encourages San Francisco to selecl that option. [n concert
wdh tim pursuit of additional conserved wa~er flom MID and TID, lllis option could
resull in no additional diversions from Ihe Tuolunme River in droughts than the proposed
program.
The Draft PEIR addresses the concept of an additional intertie with the Santa Clara
Vnllev Wnler District (SCVWD), but presents it only as a strategy that affects water
supply sources. This concept, which Palo Alto raised in its written commenls regarding
the Notice of Prcparatim~ of Ihe PE[R, would increase desirable redundancy and
operational flcxihility for both regional systems (SFPUC and SCVWD) and offers
improved emergency response. The concept could help meet or exceed the Level of
Service goals for the pro.leer relating to seismic reliability and deliverability. The PEIR
t[iscosscs a dry year transfer concept and a [’uture water supply source for the SFPUC
regional systcm and rejects those ideas with good reasons. However, the concept of
using ancw intcrtic for emergencies is nol given adequate discuss,on. Such an intertie
would be created by extending SCVWD’s West Pipeline from the point where it
currently ctads at Foothill Expressway and Fremont Avcrmc in Mountain View to Foothill
Expressway and Page Mill 1o Bay Division Pipelines 3&4. Alternately, the West
Pipeline couht be paralleled back to SCVWD’s Rinconada Water Treatmcnt Plant to
tmprove reliability tbr both rcgiomd systems.
Palo Alto understands that one ofthe crossovers between Bay Division Pipelines
3&4 for WSIP Project BD-2 is located in Palo Alto. The site for the crossover in Palo
Alto is it!entitled in the Draft PEIR is "near Barr0n Creek, adjacent to the running-track
and sports fields at Gunn High School." According to the Draft PEIR, the project
includes a valve vault of app,’oximately 3,750 square feet with the drainage outfall
located on the site and that piping to connect the [’acility to outfalls would be required. [n
addition, a control building (3 to 8 feet high) tot" electrical anti mechanical equipment at
the valve vault is required Section 4.3 ofthe PEIR should include an
clcvation/schemalic oflhe control buildin,g aud/or vault so the reader has an
understanding ofwhal the racilily will look like and how it may visually impact sensitive
areas, Ma~ly of the mitigation measures for WSIP project impacts located within Palo
Alto involve constructton. The PEIR should state lhal mitigatmn measures may not
violate City ordinances, including, but not limited to, noise and nuisance ordinances. In
addition. Palo Alto expects to be involved in and consulted at an early stage m this
project
10
:ont.
11
12
L PaloAlto
The City of Palo Aim rcspectfldly submits the tbllowing comments with rc[’c,cnccto specific
sections and pages on the subject Draft PEIR:
Pages 4.3-17 and 6-4 lisl scveral mitigations for construction impacts. The first measure
listed on page 6-4, Neighborhood Notice, in and of itself is not mitigation. This measure
may m,,ke it more palatable to neighboring residents because they will know when
construction will occur, but it doesn’t reduce the impact. As a substitute mitigation, Palo
Alto suggests coordinating with Gunn High School in order to limit construction of the
crossover to times during the school year that would be least likely to result in noise and
other construction impacts on school activities.
14.Page 4.3-22 mentions that additional right of way/easement cot,[d be needed for the
crossover outfal} at the Ounn/Veteran’s Administration hospital location. The PEIR
should identify how much additional landwill be required, when thai will be determined
and where it will be located.
15.Page 4.3-,-10 of the PEIR is ambiguous as to whethcr thc control building and/or vault will
be visible frorn Foothill Blvd. [fit will not Io be visiblc, then no mitigalion is needed. If"
it is going to be visible, then il should be so stated in the PEIR.
16.On page 4.12-10, the firsl two sentences ol’tl~e City of Patio Alto section should read:
"’Palo Alto has a Iotal o1"4,358 acres of parkland and open space areas irmluding 32 City
t~rban parks encompassing approximately 200 acres and several large open space and
nature preserves. Foothills Park is af~proximately 1400 acres and the Arastradero
Preserve is approximalcly 610 acres." Many of the City parks are dedicated parks,
crealed by ordinance. The City Charter bans substantial building, construction,
reconstruction, or development upon or with respect to any dedicated park lands except
pursuant to ordinance subject to referendum.
17.Page 6-6 in the last paragraph under the Cultural Resources section should clarify that it "l-
is San F,’ancisco’s Planning Department and Environmental Review O{’ficer that will be
responsible for these actions.
18.Section 7.3 needs to be clarilied regarding the population and employmenl forecasts used
Ibr the water dcmand projections and assumptions. The discussion should be clear that
. lhe City’s projecled population and employment forecasts in dm PEIR for lhe year 2030
are assumed to be extrapolated from the Palo Alto 2010 Comprehensive Plan; the
Ibrecasls used in the analysis are within I0% and 16% of |he 2010 Comprehcnsivc Plan
population and employment figures, respcctivcly. ABAG’s projected 2030 population
growth cited in the PEIR for Palo Alto’s Sphere of Influence is over 33% higher than the
2030 population pro.iection for Palo Alto used in lhe PEIR. The PEIR does not explain
why ABAG’s population projections are signiticantly higher than the population
projections used tbr thc water demand plan given that both arc for a 2030 horizon. The
PEIR should explain that the City considers the forecast uscd in the PEIR to be a
rcasonable and realistic projection of Palo Alto’s anticipated growth through 2030,
I lislodcally, Palo Alto has grown very slowly; the 2000 census showed a 5% increase in
13
16
L PaloAIto
population over a lhirty year period from 1970. Although in tile last seven years, Pale
Alto has experienced tmprecedented new honsing develop~rmnl resulting in an 8%
increase in population (still l’ar below the A BAG projections), this growth cannot be
sustained given Pale Alto’s limited land availability and redevelopment potential:
thcrctbrc, the City considers the PEIR 2030 population Forecast, which is approximately a
I0% growth increase from our 2010 Comprehensive Plan projected population, to be a
reasonable increase.
Pale Alto commends tim City of San Francisco rot completing the very comprehensive PE[R for
the WGIP. especially in ll~e context that the WSIP is a significant step towards timely completion
oFthc urgent seismic improvement projects needed [’or tmproved earthquake reliability.
Sinccrely,
16
cont.
Kishimom
lyOl"
AtlaChl~lCnls:
A.Resohition No 7986
D,
E.
F.
G.
H.
Resolution of the Council of the City of Pale Alto Recommending
that Ihe San Francisco Public Utililies Commission Take Prompt Action to Improve
~eg[onal Water Supply Rcliabilily and Quality.
Resolution No. 8135 - Resolution of the Cotmcil of the Cily of Pale A Ire in Suppml of
Legislalion Allowing the Formation era Regional Water Agency, Specifically Senate
Bill 1870, the Bay Area Waler Reliability Financing Authority Acl
Resolulion No. 8136 - Resolution of the Council of l!)e City of Pale Alto in Support of
Legislation Allowing the Formation era Regional Water Agency, Specifically Assembly
Bill 2058, ~l~e Bay Area Water Regional Water Supply and Conservation Agency Acl
Water Policies and Reports Regarding Water
City of Pale Alto Utililies Bill luserts
City o~" Pale A]lo Utilities Marketiog Material
Advertisements and Articles relating to Water Efficiency
City o(" Palo Alto Utilities School Education Program Materials
Cily of Pale A)lo Annual Water Supply Purchases Since 1965 and Long-Term Purchase
Forecast
Cily o~" f’alo Alto Ulilities School Special Orought Materials
Cily of Pale Alto Utilities Residential Water Rate Schedules (since July 1976)
cc:Art .lensen, General Manager of the Bay Area Water Supply and Conscrvalion Agency
15. Responses to Individual Comments
Local and Regional Agencies
ATTACHMENT D
City of Palo Alto, Yoriko Kishimoto, Mayor, 9/25/07
L PaloAlto-01
L PaloAlto-02
L PaloAlto-03
L PaloAlt0-04
This comment expresses support for the WSIP and the adequacy of the Draft
PEIR in satisfying CEQA requirements. It summarizes the more detailed
comments presented in Comments L_PaloAlto-04 through L_PaloAlto-06;
refer to Responses L_PaloAlto-04 through L_PaloAlto-06 for the specific
responses.
This comment requests clarification on the development of the water demand
projections. The Draft PEIR (Vol. 1, Chapter 3, pp. 3-16 to 3-22) describes the
methodology used to develop the 2030 water demand projections; more
detailed information is provided in Draft PEIR Appendix E.2 (Vol. 5). As
described on p. 3-21, each wholesale customer selected the source of the
demographic projections to be used in the development of the water demand
projections for its service area. According to the SFPUC Wholesale Customer
Water Demand Projections Technical Memorandum (Table 4-1 of that report,
p. 4-5; UP, S, 2004a), the Association of Bay Area Governments’ (ABAG)
Projections 2002 was used to develop water demand for Palo Alto, not the
comprehensive plan (as implied in this comment). The "Wholesale Customer
Population Selection Form" submitted by the City of Palo Alto to the SFPUC
also indicates that Projections 2002 was the City’s choice of projections for use
in the demand model. The inconsistency between ABAG’s 2030 projections
and the population forecast used is discussed in the customer summary
presented in Draft PEIR Chapter 7 (Vol. 4, pp. 7-51 and 7-52). The comment
that the Draft PEIR demand estimates for Palo Alto are realistic is
acknowledged.
The commenter’s request for coordination of the construction schedule for the
BDPL Nos. 3 and 4 Crossovers project (BD-2) with Palo Alto’s Gunn High
School is addressed by SFPUC Construction Measure #1, Neighborhood
Notice (Draft PEIR, Vol. 4, Chapter 6, p. 6-4), which states, "Where schools
would be affected, the SFPUC will coordinate with school facility managers to
schedule construction for time periods with the least impact on school activities
to ensure student safety and to minimize disruption to educational and
recreational uses of the school property."
The comment stressing support for the timely completion the seismic
improvement projects contained in the WSIP is acknowledged. The
information related to Palo Alto City Council Resolution #7986 is also noted.
Please refer to Section 14.1, Master Response on WSIP Purpose and Need
(Vol. 7, Chapter 14, Section 14.1.2) for more discussion.
PEIR on SFPUC Water System Improvement Program 1 5.3-1 4z~ESA+Odon ! 203287
Comments and Responses Seotember 2008
15. Responses to Individual Comments
Ci~ of Palo Alto, Yodko Kishimoto, Mayor. 9/25/07
L PaloAlto-05
L PaloAlto-06
L PaloAlto-07
L PaloAlto-08
L PaloAlto-09
L PaloAlto-10
L PaloAlto-11
This comment expressing Palo Alto’s support for the Modified WSIP
Alternative is acknowledged. Please see Section 14.10, Master Response on
Modified WS1P Alternative (Vol. 7, Chapter 14) for additional discussion and
analysis of this alternative. In addition, this comment noting the critical need
for completing the seismic upgrades and repairs of the regional system is also
acknowledged. Please see Section 14.1, Master Response on WSIP Purpose
and Need (Vol. 7, Chapter 14, Sections 14.1.2 and 14.1.3) for further
discussion.
This comment expressing Palo Alto’s support for the transfers of conserved
water as a component of the Modified WSIP Alternative is acknowledged. The
commenter also expresses support for the following: wholesale customers
paying for the best conservation measures; aggressive pursuit of conservation
opportunities in the Modesto and Turlock Irrigation District service areas; and
creating a net increase in flows in the lower Tuolumne River to improve
environmental conditions. These comments are acknowledged. See Response
L-BAWSCA1-47.
This information related to the City of Palo Alto’s support for the efficient use
of natural resources, including water supplies, is noted. Please see
Section 14.2, Master Response on Demand Projections, Conservation, and
Recycling (Vol. 7, Chapter 14), for more discussion on assumptions regarding
conservation and recycling used in the development of the WSIP. Please also
refer to Section 14.3, Master Response on Proposed Dry-Year Water
Transfer (Vol. 7, Chapter 14, Section 14.3.2) for additional discussion
regarding the proposed dry-year transfer under the WSIP.
This comment, which describes Palo Alto’s commitment to stewardship of the
natural environment and smart growth practices, is acknowledged. As it does
not address the adequacy or accuracy of the PEIR, no response is provided.
This comment, which describes Palo Alto’s energy and water conservation
programs, water consumption patterns, and water rates, is acknowledged. This
information is conceptually included in the PEIR by virtue of its inclusion in
this comment letter.
The opinion of the commenter supporting WSIP Variant 3 - 10% Rationing is
acknowledged See Response L_Burlgme-02 for clarification of the difference
between the proposed program and Vari,ant 3.
As described in the Draft PEIR (VoI. 4, Chapter 9, pp. 9-116 and 9-122 to
9-123), the SFPUC investigated several alternatives for an exchange or transfer
with the Santa Clara Valley Water District (SCVWD) as part of the WSIP
background studies exploring regional water supply opportunities. The SFPUC
and SCVWD explored options using the existing intertie or a new intertie, as
P~IR o~ SFPUC Water System Improvemenl Program 15, 3-145 ESA+Odon / 203287
Comments and Resporlses September 2008
15. Responses to Individual Comments
Local and Regional Agencies
L PaloAlto-12
L PaloAlto-13
well as exchanges through delivery to the eight customers in common to both
the SCVWD and SFPUC. In general, an exchange would involve the SFPUC
advancing water in wet years to the SCVWD in exchange for supplies from the
SCVWD in dry years. However, the SCVWD does not have the capacity or
need for additional water supplies during wet years. At times when the SFPUC
has addi.tional supplies available for delivery to the SCVWD, the SCVWD
cannot use the water directly or store it. Additionally, the SCVWD does not
have excess water to transfer to the SFPUC in normal or dry years. Therefore,
this concept was eliminated from further consideration because it would not
provide a dependable future water source for the SFPUC regional system.
The commenter requests that the PEIR include an elevation/schematic of the
control building and/or vault associated with the BDPL Nos. 3 and 4
Crossovers project (BD-2). Please refer to Section 14.4, Master Response on
PEIR Appropriate Level of Analysis (Vol. 7, Chapter 14, Section 14.4.2) for
detailed discussion of the issues raised by this comment. This master response
provides information on the appropriate level of detail of an impact analysis at
the program level versus the project level. Atthe programmatic level, design
details for individual WSIP projects are not presented or evaluated in the Draft
PEIR. The City will have the opportunity to review and comment on the design
details of this project during project-level CEQA review~
The commenter states that the mitigation measures should not allow WSIP
projects to violate city ordinances (including but not limited to noise and
nuisance ordinances), and that the City should be consulted at an early stage in
this project. The Draft PEIR (Vol. 2, Chapter 4, p. 4.2-9) states that the SFPUC
is exempt from complying with the building and zoning ordinances of other
cities. However, project consistency with the provisions of other local
ordinances (including noise and tree ordinances) wilt be determined during the
preparation of project-level CEQA documentation. The Palo Alto tree,
vegetation, and noise ordinances are identified in Tables 4.6-1 and 4.10-2
(Vol. 2, Chapter 4, pp. 4.6-34 and 4.10-7). As stated in the Draft PEIR (Vol. 2,
Chapter 4, p. 4.10-6), time and noise limits prescribed in local noise ordinances
were used in the PEIR as criteria to determine the gignificance of project
impacts under CEQA. Please refer to Section14.4, Master Response on
PEIR Appropriate Level of Analysis (Vol. 7, Chapter 14, Section 14.4.3)
regarding the City’s request for early consultation. This request for early
consultation has been noted in Draft PEIR Table C.6 (Vol. 5, Appendix C,
p. C-26).
The commenter requests substitution of SFPUC Construction Measure #t with
specific language requiring coordination with Gunn High School, but such
coordination is already required, as described in Response L_PaloAlto-03.
PEIR dn SFPUC Water System Improvement Program ’15,3-146 ESA+Odon / 203287
Comments and Responses September 2008
15. Resoonses to Individual Comments
City of Pale Alto, Yoriko Kishimoto, Mayor. 9/25/07
L PaloAlto-14
L PaloAlto- 15
L PaloAlto-16
The commenter also mentions that additional right-of-way/easement could be
needed for the BDPL Nos. 3 and 4 Crossovers project (BD-2), and also
questions the visibility of the control building/vault from Foothill Boulevard.
Please refer to Section 14.4, Master Response on PEIR Appropriate Level
of Analysis (Vol. 7, Chapter 14, Section 14.4.2) for information on the
appropriate level of detail of an impact analysis at the program level versus the
project level. As a program-level document, the Draft PEIR does not present or
evaluate the design details for the individual WSIP projects. The City will have
the opportunity to review and comment on the design details of this project
during project-level CEQA review.
The commenter requests that information on the city’s parks and open space be
updated. The number of parks and total urban park acreage presented in the
Draft PEIR (Vol. 2, Chapter 4, p. 4.12-10) are based on information cited in the
City of Pale Alto Comprehensive Plan (1998) and subsequent revisions to the
plan made in July 2007. In response to this comment, the Draft PEIR (Vol. 2,
Chapter 4, p. 4.12-10, fourth full paragraph) has been revised as follows:
City of Palo Alto
According to the Cits, of Palo Alto, the city has a total of 4,358 acres of
parkland and open space areas, including 32 urban parks encompassing
approximately 200 acres and several large open-space and nature
preserves. Foothill Park is approximately 1,400 acres and the Arastradero
Preserve is approximately 610 acres (City of Palo Alto, 2007). Pale Alto
Preserve, ape, pular ........ s .................. ~, .......
£an Ff"~ncio°cc Bay, encompasses !,940 acres and contains !5 miles of
facilities, " ...... ~...a .~ ~.?,~.~a~ Nature Inte~retive ~"-t~* The
CiW of Pale Alto owns the wetl~ds south of Cooley Landing (in E~t
Pale Alto) in the vicini~ of the BDPL ReliabiliV Upgrade (BD-1)
pipeline alignment (Ci~ of Pale Alto, 1998). A BDPL Nos. 3 and 4
Crossovers (BD-2) crossover Ncili~ would be adjacent to the spo~s
fields N G~n High School.
The following reference has been added to the Draft PEIR (Vol. 2, Chapter 4,
p. 4.12-29):
_City of Pate Alto, Yoriko Kishimoto, Mayor, letter communication,
September 25, 2007.
The commenter’s recommendation to correct the last paragraph under the
Cultural Resources section (Vol. 4, Chapter 6, p. 6-6) is not necessary. The
Environmental Review Officer represents the Planning Department.
This comment repeats points made in Comment L_Palo Alto-02 about the
projections source used in the demand model and differences between ABAG
PEIR on SFPUC Water System Improvement Program
Comments and Responses
15.3-147 ESA+ eden / 203~87
September 2008
15. Responses to Individual Comments
Local and Regional Agencies
projections and those used in the demand model. Please refer to Response
L PaloAlto-02. The Draft PEIR (Vol. 4, Chapter 7, p. 7-52) indicates that the
population and employment projections used for Palo Alto in the demand study
are about 10 percent and 16 percent higher, respectively, than those shown for
2010 in the comprehensive plan (referred to as the general plan), consistent
with this comment’s request. The comment that the City considers the forecast
shown in the PEIR to be reasonable is acknowledged.
PEIR on SFPUC Water System Improvement Program 15.3-148 ESA÷Odon / 203287
Commen~s and Responses September 2008