HomeMy WebLinkAboutStaff Report 2509-5258CITY OF PALO ALTO
CITY COUNCIL
Monday, October 20, 2025
Council Chambers & Hybrid
5:30 PM
Agenda Item
A.Informational Report on the City of Palo Alto One Water Plan and Associated Letter from
the Utilities Advisory Commission for Future Water Supply and Conservation Planning
Purposes; CEQA Status – Not a Project
City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Utilities
Meeting Date: October 20, 2025
Report #:2509-5258
TITLE
Informational Report on the City of Palo Alto One Water Plan and Associated Letter from the
Utilities Advisory Commission for Future Water Supply and Conservation Planning Purposes;
CEQA Status – Not a Project
RECOMMENDATION
This report is provided for information only and requires no Council action. This report was
reviewed by both the City Council Climate Action & Sustainability Ad Hoc Committee and
Utilities Advisory Commission.
EXECUTIVE SUMMARY
The One Water Plan 1 (OWP) presents a framework for evaluating water supply and water
conservation alternative portfolios that may mitigate the impact of future water supply
uncertainties such as severe multi-year drought, changes in climate, water demand, and
regulations. Transmission of the report completes a key action in the Sustainability and Climate
Action Plan (S/CAP) Update to develop a plan for implementing a One Water portfolio, a water
supply plan that will analyze the City’s potential water supply priorities and conservation
opportunities. Specifically, development of this report completed one goal and one key action
in the Council-approved 2022 Sustainability and Climate Action Plan.
• Goal: Develop a water supply portfolio which is resilient to droughts, changes in climate,
and water demand and regulations, that supports our urban canopy.
• Key Action W4: Develop a tool for dynamic water planning in the future.
The Utilities Advisory Commission (UAC) unanimously voted to forward a letter to the City
Council (Attachment A) offering additional context on water supply and conservation planning.
The letter was intended to accompany the transmittal of the plan—not as a request for
acceptance or approval, but for Council to receive it as informational. The Climate Action and
Sustainability Committee (CASC) received both the report and the UAC letter for staff’s use as a
1 One Water Plan https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=c42ee7f3-8caf-4c48-
99e3-57bb8e437775
framework for evaluating future projects considering, where appropriate, the opinions
expressed in the UAC’s letter. After discussing the plan and the UAC’s concerns, the CASC voted
unanimously to receive the One Water Plan and forward for City Council information. OWP
provides an adaptive tool to aid in evaluation of future projects or actions. Such future projects
or actions may be implemented by Palo Alto or, more likely, through regional partnerships.
One Water Plan Summary: The OWP compares potential water supply and conservation
portfolios using the City’s weighted criteria, offering an initial analysis of alternatives and a
framework to support future Council decisions on which project types to explore further. A key
product of the OWP effort is the excel-based tool which may be used to adjust its overall water
supply strategy as the future unfolds, conditions change, and uncertainties are resolved.
Assumptions that may be adjusted in the tool include water demand, project costs, and
expected supply reductions during droughts or other events. The weighting or scoring
methodology may be modified as well. The OWP water supply and conservation options and
the resulting portfolios that scored highest, given the rough cost estimates and evaluation
criteria, include:
• Portfolio A – Baseline: Existing potable water supply from the Hetch Hetchy Regional
Water System (RWS);
• Portfolio B: Baseline with enhanced water conservation;
• Portfolio C: Baseline with enhanced conservation plus desalinization;
• Portfolio D: Baseline with enhanced conservation plus groundwater;
• Portfolio E: Baseline with enhanced conservation plus Palo Alto-operated Direct Potable
Reuse (DPR);
• Portfolio F: Baseline with enhanced conservation plus Palo Alto-operated Indirect
Potable Reuse (IPR); and
• Portfolio G: Baseline with enhanced conservation Regional DPR.
Before the Council approves any water supply or conservation project, further project-specific
studies and analyses will be required to assess the need for additional supplies or conservation,
as well as to evaluate project feasibility, including detailed cost estimates and potential funding
sources. To support this future evaluation and refinement, the One Water Plan (OWP) includes
a comparative scoring of the portfolios.
BACKGROUND
In June 2022, Council approved a contract with Carollo Engineers to develop the OWP (Staff
Report 134342). City staff from the Public Works and Utilities Departments closely collaborated
and worked with the consulting team to develop the attached OWP.
One of the City Council’s priorities for 2024 was Climate Change and Natural Environment –
Protection and Adaptation. The attached OWP fulfills a key action in the City’s Sustainability
and Climate Action Plan (S/CAP) and identifies an evaluation framework for water supply and
conservation projects as well as possible project alternatives for meeting the community’s
water needs in the future.
Palo Alto’s Sustainability and Climate Action Plan (S/CAP) was completed in 2023, and it
includes two water-specific goals:
1. Reduce Palo Alto’s potable water consumption by 30% compared to a 1990 baseline
(subject to refinement based on forthcoming California water efficiency standards
expected in 2025).
2. Develop a water supply portfolio which is resilient to droughts, changes in climate, and
water demand and regulations, that supports the City’s urban canopy.
Two of the key actions supporting these goals are satisfied by the OWP: 1) Develop and
implement projects that result from a “One Water” portfolio of alternative water supply and
water conservation options for Palo Alto, including but not limited to: stormwater, recycled
water, on-site-reuse, conservation and groundwater, and 2) develop a tool for dynamic water
planning in the future.
“One Water" is an integrated approach to water management that views all forms of water –
imported water, groundwater, wastewater, stormwater, water conservation and efficiency and
more-- as interconnected resources. The primary purpose of the OWP for the City of Palo Alto is
to provide a 20-year adaptable roadmap of prioritized alternatives, organized into water supply
portfolios, and a project evaluation tool, to guide decision-making around the City’s water
supply and conservation goals.
ANALYSIS
The OWP provides a comprehensive list of water supply and water conservation options
(“options”) considered, including input from stakeholders. The list of 27 options was sorted into
three “buckets”.
Bucket 1 - Ongoing or Already Planned
• Planned/ongoing conservation
• Advanced metering program
• Distribution system water loss reduction
2 Staff Report 13434 https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=81683
Bucket 2 - Not Currently Feasible (due to cost or lack of partnership interest)
• Indirect potable reuse at Lake Lagunita (groundwater recharge using purified water)
• Blackwater capture and reuse
• Valley water treated water via a new pipeline
• Interagency transfer agreements
• Tuolumne River purchases
• Atmospheric water generators
• Local surface water reservoir
• Temporary dewatering sites (basement construction)
• Permanent dewatering (as a way to increase the volume of other reuse options)
Bucket 3 – Selected to be Included in the Screening Process
• Regional Water System supply (current potable water supply)
• Enhanced conservation
• Next-level enhanced conservation
• Groundwater
• City park irrigation with groundwater
• Direct potable reuse of purified water via a Palo Alto facility
• Direct potable reuse of purified water via a Palo Alto facility and utilizing the new salt
removal equipment at the Regional Water Quality Control Plant
• Direct potable reuse of purified water via a regional facility
• Indirect potable reuse via groundwater injection of purified water
• Expanded distribution of non-potable water (recycled water to Stanford Research Park
and customers in the foothills)
• Greywater capture and reuse
• Residential rainwater capture
• Green Stormwater Infrastructure
• Multi-source storage including stormwater detention
• Desalination of bay water
The OWP analyzed this initial list of options in a high-level pre-screening process that resulted in
15 remaining options. The One Water Plan (OWP) applied three initial screening criteria to the
15 options, narrowing the list to nine. For these nine options, the OWP developed planning-
level cost estimates and conducted a comprehensive evaluation using four criteria, which
included unit cost and several non-cost factors. The OWP then assembled seven water supply
and water conservation portfolios (“Portfolios”) named Portfolio A through Portfolio G that
include groups of top scoring options. The following is a list and a brief description of the seven
portfolios.
Portfolio Descriptions
• Portfolio A – Baseline: Portfolio A represents the baseline portfolio which is the City’s
existing potable water supply from the Hetch Hetchy Regional Water System (RWS) and
serves as the benchmark for comparing other potential portfolios.
• Portfolio B – Enhanced Conservation Phase 1 and 2: Portfolio B builds on Portfolio A with
the addition of Enhanced Conservation Phase 1 and Phase 2, each encompassing a
series of targeted water conservation measures. Enhanced Conservation Phase 1
includes measures that are easier and less costly to implement while Enhanced
Conservation Phase 2 consists of more challenging and more costly measures. Table 1
shows the difference between conservation measures already planned for
implementation and the Enhanced Conservation measures contemplated in this OWP.
Table 1: Ongoing and Planned Conservation versus Enhanced Conservation Phases 1 and 2
Each portfolio C through G includes Enhanced Conservation Phase 1 and Phase 2 measures, plus
one local water supply infrastructure project, with the remainder of the water supplied by the
RWS.
• Portfolio C adds a Bay Water Desalination plant that would supply 4,480 acre feet per
year of water during a normal year.
• Portfolio D adds groundwater. Under this portfolio, the City would equip two of the
existing emergency groundwater supply wells with treatment facilities and convert these
from emergency supply to regular potable use. The wells would provide 2,250 acre feet
(af) per year of water supply during a normal year. Notably, Valley Water’s 10-year
projection anticipates that the groundwater production charge will more than double
from the 2023 rate of $1,724/af to $4,147/af by 2032, reflecting approximately 9.5
percent annual escalation. Valley Water expects this increase to primarily pay for critical
capital program needs including water treatment plant upgrades and dam seismic
retrofit work. For reference, SFPUC’s expected rate in 2032, assumed in the OWP, is
$2,630/af.
• Portfolio E adds a Palo Alto Direct Potable Reuse (DPR) facility that would supply 4,723
acre feet per year of water during a normal year.
• Portfolio F adds a Palo Alto Indirect Potable Reuse (IPR) water purification facility with
groundwater injection wells. This Indirect Potable Reuse facility would supply 5,150 acre
feet per year of water supply during a normal year.
• Portfolio G adds a Regional DPR water purification facility constructed by Valley Water
and located in Palo Alto instead of a dedicated Palo Alto DPR facility. The estimated
water supply from this facility for Palo Alto is 1,769 acre feet per year during a normal
year.
Figure 1 illustrates the water supply and demand for each portfolio during a normal year in
2045.
Figure 1: Normal Year Supply and Demand Analysis by Portfolio in 2045
The OWP calculates a weighted average unit cost for each portfolio considering the volume of supply
from each water supply source during a normal year. Table 1 shows the weighted average unit cost for
each portfolio in 2023 dollars and 2045 dollars. The cost estimates are planning-level or order-of-
magnitude cost estimates with a typical estimating accuracy of -50% to +100% due to limited level of
project information often coupled with significant uncertainties at this planning stage. The weighted
average unit costs are calculated based upon these cost estimates and are not rounded for consistency
across the OWP and appendices.
Table 2 – Estimated Weighted Average Unit Cost of Water for Portfolio A through Portfolio G
Portfolio Name Est. Weighted Avg Unit Cost
($/Acre Foot)
2023 Dollars 2045 Dollars
Portfolio A – Baseline $2,210 $4,088
Portfolio B – Enhanced Conservation Phase 1 and 2 $2,075 $3,093
Portfolio C – Enhanced Conservation Phase 1 and 2 with Bay Water
Desalination
$3,854 $6,663
Portfolio D – Enhanced Conservation Phase 1 and 2 with
Groundwater
$2,556 $5,330
Portfolio E – Enhanced Conservation Phase 1 and 2 with Palo Alto
DPR
$2,645 $4,938
Portfolio F – Enhanced Conservation Phase 1 and 2 with Palo Alto IPR $3,323 $6,440
Portfolio G – Enhanced Conservation Phase 1 and 2 with Regional
DPR
$2,355 $4,552
Effluent Transfer Agreement
In 2019, Council approved an Effluent Transfer Agreement with Valley Water and the City of
Mountain View Staff Report #10627.3 This 76-year agreement enables an effluent transfer from
the Regional Water Quality Control Plant (RWQCP) to Valley Water to be reused in Santa Clara
County, likely south of Mountain View. Valley Water has the option to exercise an effluent
transfer within 13 years. A Council study session with Valley Water on September 12, 2022
provides updated information Staff Report #14650.4 The governing bodies of Palo Alto,
Mountain View and Valley Water have established policy goals for long-term sustainability,
including expanding use of recycled water. The RWQCP is a local source of drought-proof,
sustainable water. This agreement aims to promote regional collaboration to advance resilient
water reuse programs in Santa Clara County.
Some of the OWP portfolios depend on Valley Water not exercising the effluent transfer option,
which would ensure there is sufficient treated effluent volume available for constructing local
reuse facilities in Palo Alto. Those portfolios are Portfolio E – Enhanced Conservation Phase 1
and 2 with Palo Alto DPR, and Portfolio F – Enhanced Conservation Phase 1 and 2 with Palo Alto
IPR. Portfolio G is only feasible if Valley Water exercises the effluent transfer option and decides
to build a Regional DPR facility located in Palo Alto. Figure 2 summarizes the dependencies of
OWP portfolios on the effluent transfer decision.
Weighted Evaluation Criteria Portfolio Scores
Unit cost was only one of several evaluation criteria used. The One Water Plan (OWP) also
scored the options based on factors such as reliability, environmental benefits, and ease of
implementation. Table 2 presents the rankings for each portfolio, reflecting the weighted results
3 Staff Report 10627 https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-
reports/reports/city-manager-reports-cmrs/year-archive/2019/id-10627-mini-packet-11182019.pdf?t=60382.02
4Staff Report 14650 https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=82012
of both cost and non-cost criteria. If Valley Water does not exercise its option to transfer a
portion of RWQCP treated effluent, the most cost effective and beneficial option to add to the
enhanced water conservation options is the Palo Alto DPR Facility, in Portfolio E. This portfolio’s
overall weighted criteria score is 3.43, the highest score of any portfolio, as shown in Table 2. If
Valley Water exercises its option to transfer a portion of RWQCP treated effluent, the most cost-
effective and beneficial option to add to the enhanced water conservation options is the
Regional DPR facility as combined in Portfolio G. The overall weighted criteria score of this
portfolio is 3.06 as shown in Table 2. The baseline portfolio scores the lowest of all the
portfolios using the weighted criteria
Table 3 - Evaluation Results - Weighted Criteria Scores By Portfolio
Weight Baseline Conservation
Phase 1 and 2
Conservation
with Bay Water
Desalination
Conservation
with
Groundwater
Conservation
with Palo Alto
DPR
Conservation
with Palo Alto
IPR
Conservation
with Regional
DPR
Portfolio Weighted
Unit Cost in 2045
($/AF)
- - $4,088 $3,903 $6,663 $5,330 $4,938 $6,440 $4,552
Year
- - 2025 2025 2035 2025/2030 2035 2030 2040
Unit Cost 20% 0.95 1.00 0.20 0.59 0.70 0.26 0.81
Reliability 35% 0.35 0.60 1.43 0.85 1.39 1.37 0.90
Benefits
Efficient Use of
Water
Tuolumne
Ease of
Implementation
Implementation
Timeline
Acceptance
Total 100% 2.55 2.91 2.91 2.78 3.43 2.99 3.06
Notes:
(1) Based on estimated year 2045.
(2) Portfolio G (Enhanced Conservation with Regional DPR) assumes that Valley Water does exercise its option to transfer a portion of RWQCP
treated effluent (selected “Yes” in the Tool). All other portfolios assume that Valley Water does not exercise its option (selected “No” in the Tool).
(3) The weighted criteria scores are normalized to a scale of 1-5.
Portfolio Evaluation Summary
Figure 2 compares the portfolios’ dependency on the Valley Water Transfer option decision.
Figure 2. Portfolio Results and Dependence on Valley Water Option to Transfer Decision
Sensitivity Analysis
The One Water Plan (OWP) includes a sensitivity analysis to assess how the findings might
change under different weightings of the evaluation criteria. The flexibility of the tool enables
staff to perform additional sensitivity analyses to assess how findings change as cutback and
demand assumptions are adjusted in the future.
Key findings from the sensitivity analysis are:
• Portfolio E (Enhanced Conservation + Palo Alto DPR) is the top-performing option if
Valley Water does not exercise its effluent transfer option, even when evaluation
criteria weights (cost, reliability, etc.) are adjusted. The only exception is when unit cost
is heavily prioritized, in which case Portfolio B (Enhanced Conservation only) ranks
highest.
• If Valley Water does exercise the effluent transfer option, Portfolio G (Enhanced
Conservation + Regional DPR) becomes the highest-scoring infrastructure portfolio.
However, Portfolio B or Portfolio C (with Bay Water Desalination) may outperform it
depending on how cost or reliability are weighted.
Events that May Trigger Revisiting One Water Planning in the Future
While staff is not recommending any action or decision at this time, revisiting the One Water
planning framework may be appropriate in the future. Some of the conditions that may warrant
a re-evaluation of the City’s water supply portfolio include the following.
• 2027: SFPUC updated Alternative Water Supply Plan
• 2032: Valley Water decision regarding option to transfer effluent from RWQCP for south
Santa Clara County uses
• State decision regarding Bay Delta Plan implementation
• Other events or conditions affecting water supply reliability or cost
• New water supply technologies or regional partnership opportunities
FISCAL/RESOURCE IMPACT
This report is informational only with no financial resource impact .
The OWP, cost estimates, and Evaluation Tool along with considerations raised in the UAC’s
letter provide an adaptable roadmap for the City’s water strategy. To illustrate the potential
rate impacts for water utility customers stemming from the various portfolios in the OWP, staff
utilized the projected weighted unit costs for each portfolio in FY 2045 as the basis for Palo
Alto's water purchase costs. This was coupled with an assumed average annual rate increase of
6% for the distribution system. All other assumptions are the same as outlined in the OWP. This
analysis does not take into consideration other unexpected costs that may impact the cost of
water and does not consider sensitivities to demand changes. This analysis is for illustration
purposes only, and provides an approximation of the relative rate impact of different portfolio
average unit costs (from Table 1) under the assumptions stated in the OWP. For reference,
under Palo Alto’s current rates in FY 2025, a residential monthly bill at 9 CCF of water usage
costs $113.47. Also shown is the capital cost associated with each portfolio.
Table 4 – Residential Monthly Bills in FY 2045 for Each OWP Portfolio
This analysis indicates that the difference in residential bills across the portfolios relative to the
baseline Portfolio A ranges from negative 1% for the least expensive Portfolio B (Enhanced
Conservation Phase 1 and 2) to 17% for the most expensive Portfolio C – Enhanced
Conservation with Bay Water Desalination. Note that capital costs are planning level and actual
costs are -50% to +100% of estimated.
STAKEHOLDER ENGAGEMENT
The following is a timeline of public meetings and community workshops on the OWP to date:
- July 7, 2021 - the Utilities Advisory Commission (UAC) reviewed a draft objectives, scope,
and community engagement plan for the OWP (Staff Report #12332)5
- November 2021 - Palo Alto Utilities Department in collaboration with the Public Works
Department issued OWP Request For Proposals
- June 2022 - Council approved the contract with Carollo Engineers to develop the OWP
(Staff Report 13434)6
- September 28, 2022 - First Community Workshop, Community Needs and Priorities7
- December 6, 2022 - Second Community Workshop Exploring Water Supply and Water
Conservation Options8
- February 1, 2023 - staff provided an update to the UAC on the development of the OWP
(Staff Report 14974)9
- June 3, 2024 - staff provided an update to the UAC on the OWP background, goals,
approach, overview and initial results (Staff Report 2404-2968)10
- January 7, 2025 – staff provided the final One Water Plan to the UAC (Staff Report 2407-
3234)11
- September 19, 2025 – the CASC received the final One Water Plan and the related
letter from the UAC (Staff Report 2505-469712)
Utilities Advisory Commission Review: At the UAC meeting on November 6, 2024, the SFPUC
(Palo Alto’s water supplier) through its Assistant General Manager of the Water Enterprise,
Steve Ritchie, provided an overview of the RWS and SFPUC’s planning efforts including drought
planning and Alternative Water Supply Program. At the same UAC meeting, the Bay Area Water
5 Staff Report 12332: https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-
minutes/utilities-advisory-commission/archived-agenda-and-minutes/agendas-and-minutes-2021/07-07-2021-
special/id-12332-item-1.pdf
6 Staff Report 13434: https://www.cityofpaloalto.org/files/assets/public/v/11/agendas-minutes-reports/agendas-
minutes/city-council-agendas-minutes/2022/20220620/20220620pccsm-amended-final-final.pdf
7 Presentation and results from the live polling:
https://www.cityofpaloalto.org/files/assets/public/v/1/utilities/water-drought/stakeholder-mtg-1-community-
meeting.pdf
8 Slides: https://www.cityofpaloalto.org/files/assets/public/v/1/utilities/water-drought/stakeholder-workshop-
2_community.pdf Recording: https://youtu.be/YEguKgxzRNY
9 Staff Report 14974: https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/agendas-
minutes/utilities-advisory-commission/archived-agenda-and-minutes/agendas-and-minutes-2023/02-feb-2023/02-
01-2023-uac-agenda-and-packet.pdf
10 Staff Report 2404-2968 https://www.cityofpaloalto.org/files/assets/public/v/2/agendas-minutes-
reports/agendas-minutes/utilities-advisory-commission/archived-agenda-and-minutes/agendas-and-minutes-
2024/06-jun-2024/06-03-2024-packet-v2.pdf
11 Staff Report 2407-3234 https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=5b035426-3a84-
4050-84eb-a2d44ebdb28f
12 Staff Report 2505-4697 https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=dd0a3d30-
3782-42d4-b2df-20a7389a196f
Supply and Conservation Agency (BAWSCA), through its CEO/General Manager, Nicole
Sandkulla, also presented additional information on water supply, water conservation and
reliability regionally, pertaining to the 26 wholesale customers (including Palo Alto) of the
SFPUC comprising BAWSCA’s membership. This provides additional regional context for the Palo
Alto OWP, which focuses on the local area within the Palo Alto city limits.
At the January 7, 2025 UAC meeting, staff recommended that the UAC advise the City Council
to accept the One Water Plan. The UAC did not take any action. The UAC expressed a desire to
provide additional information to the City Council regarding water supply and conservation
planning. As a result, as discussed by the Commission, three commissioners (Gupta, Mauter and
Phillips) were appointed to draft the letter for the full Commission’s consideration. The letter
contents fall into three main categories. First, it outlines concerns about the portfolio scoring
methodology. Second, it questions the worst-case water supply shortage scenario which was
provided by the SFPUC, the City’s water supplier and the owner and operator of the Regional
Water System. Third, the letter promotes regional collaboration, a practice that staff routinely
engages in as part of their ongoing responsibilities. At the March 5, 2025, UAC meeting, the
commission voted unanimously to send the letter (Attachment A) to Council.
Climate Action & Sustainability Ad Hoc Committee: On September 19, 2025, staff
recommended the CASC receive both the report and the UAC letter for staff’s use as a
framework for evaluating future projects if so directed by Council, considering, where
appropriate, the opinions expressed in the UAC’s letter. After discussing the Plan and the UAC’s
concerns, the CASC voted unanimously to receive the One Water Plan. Potential future
direction to staff related to the OWP will require separate Council action.
ENVIRONMENTAL REVIEW
The informational report including the OWP and UAC letter on water supply and conservation
planning is not a project requiring California Environmental Quality Act review, because it is an
administrative governmental activity which will not cause a direct or indirect physical change in
the environment. Any future proposals to implement the OWP would be subject to CEQA
analysis at that time.
ATTACHMENTS/LINKS
Attachment A: UAC letter to Council
Link: One Water Plan https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=c42ee7f3-8caf-
4c48-99e3-57bb8e437775
APPROVED BY:
Alan Kurotori, Director of Utilities
Staff: Karla Dailey, Assistant Director of Utilities, Resource Management
Memorandum: One Water Plan Review and Recommendations March 5, 2025
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MEMORANDUM
TO: City Council, City of Palo Alto
FROM: Utilities Advisory Commission
DATE: March 5, 2025
SUBJECT:One Water Plan Review and Recommendations
The Utilities Advisory Commission (UAC) has completed its review of the One Water Plan (OWP) and
recommends against acceptance of the plan at this time. The following sections outline our key concerns
and recommendations for moving forward.
The UAC’s decision not to approve the study, despite acknowledging the considerable staff time and
resources invested, stems from fundamental concerns about its analytical framework. Specifically, the
methodology and assumptions used in the plan could lead to potentially misleading conclusions about
Palo Alto’s water security options. The UAC is happy to meet with Council to discuss its concerns in more
detail, which are various. However, to help guide future water planning efforts, this memo focuses on our
most critical concerns, which we believe must be addressed to develop a robust and actionable water
security framework for Palo Alto: (1) the premise of the report and its recommendations relies on a 50%
cut back scenario that seems highly unlikely and must be validated, particularly by engagement with
BAWSCA and SFPUC; and (2) the conclusions are based on a weighted scoring scheme that is potentially
misleading—instead, the underlying metrics, such as dollar cost per acre-foot, should be directly
presented to decision-makers. In addition, the UAC provides several strategic recommendations for the
city’s future planning efforts.
Staff has reviewed this letter and agrees that investments in local water supply alternatives are not
prudent nor recommended at this time. Staff agrees that evolving demand projects and SFPUC supply
reliability assessments will be critical for continued water planning efforts and that regional partnership
may, indeed, prove to be most cost-effective if water supply reliability becomes an issue. The tool
developed as part of the OWP effort may be modified in subsequent analysis to address the UAC’s
concerns regarding the scoring methodology.
REPORT ISSUES
In this memo, the UAC focuses on two critical issues with the OWP report: (1) the 50% cutback scenario
underlies the premise and recommendations of the report, but this scenario seems unlikely and should
be validated before using it for water supply planning; and (2) the weighted scoring scheme for the
alternatives is potentially misleading.
First, the OWP report plans for a case in which there is a 50% reduction in regional water supply, and it
uses this scenario as a key metric in its portfolio evaluation.1 This assumption warrants further scrutiny
1 E.g., OWP Report at ES-8 (“Reliability is scored based on results of the dry year supply analysis for
each portfolio using the supply gap expressed in afy during a 50 percent reduction in water deliveries to
Memorandum: One Water Plan Review and Recommendations March 5, 2025
Page 2 of 4
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and validation, particularly concerning demand across the broader system, implementation of Bay Delta
Plan regulations, and policy and management decisions about storage. Members of the public have noted
that historical analysis of Tuolumne River flows over the past 1100 years using tree ring data suggests that
the level of drought and demand growth that would require this level of cutback is extremely improbable.
During the recent 2001-2022 California mega-drought, SFPUC was able to add to its reservoirs in 15 of the
22 years due to its robust water rights. Second, the Long Term Vulnerability Assessment (LTVA)
cosponsored by the SFPUC found no drought in 25,000 years of stochastic modeling that approached the
severity of the design drought scenario, and the assessment found no clear adverse impacts from climate
change through 2070. Third, the longest historical drought (1471-1483) would have left 40% of system
storage remaining at current demand levels. Fourth, probability analysis suggests the design drought
scenario has an exceptionally rare return period—potentially one in several hundred thousand years. The
UAC also has concerns with the demand forecasts, noting that BAWSCA’s forecasts have consistently over-
estimated future regional water demand, often by substantial amounts. Given that this 50% cut back
assumption during drought drives many of the report’s conclusions about needed infrastructure
investments and policy changes, a validated and nuanced analysis of potential supply scenarios
informed by better planning targets from BAWSCA and SFPUC would significantly strengthen the plan’s
utility for decision-making.2
While we understand Staff’s desire to ensure planning processes align with SFPUC’s policies and forecasts,
the 50% cutback scenario should not be used in the City’s planning framework without further validation.
We recommend that the City engage with SFPUC and BAWSCA to refine supply and demand projections
so that Palo Alto’s water planning incorporates realistic cutback assumptions. Better cutback assumptions
will provide actional guidance for both near-term and long-term decision-making.
Second, the OWP’s evaluation methodology also raises significant technical concerns about how different
water supply options are compared and ranked. The plan uses a weighting scheme that normalizes various
criteria (like unit cost, reliability, and environmental benefits) to a 1-5 scale and then applies weighted
scoring to compare portfolios. This approach, however, violates the Independence of Irrelevant
Alternatives principle—meaning that the relative ranking between two options can change based solely
on the characteristics of an unrelated third option, even when nothing about the two options being
compared has changed. For example, changes in the cost of one portfolio could artificially alter the scoring
and perceived relative merits of other portfolios, even though their underlying costs and benefits remain
exactly the same. Instead of using this potentially misleading scoring system, we recommend that future
evaluations present the actual underlying metrics (such as dollar cost per acre-foot) directly to decision-
makers, allowing for transparent analysis of tradeoffs between different options.
* * *
Palo Alto from the RWS.”), at 2-8 (“Based upon the City’s forecasted water demand presented in the
City’s 2020 UWMP and projections of water supply availability provided by SFPUC at the time, the City
anticipates the need to implement water use reductions of approximately 50 percent from pre-drought
usage levels in dry years post Bay-Delta Plan implementation.”).
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Overall, while the OWP found that some alternatives were infeasible, helping save the city analysis time
in the future, adopting the OWP appears premature given current regional developments. SFPUC is just
beginning its own alternative water supply planning process, with a focus on purified water projects.
SFPUC’s recently approved 10-year capital improvement plan includes $260 million for alternative water
supply programs within its $3.16 billion total budget, and much of this planning remains in early stages.
Furthermore, public comment indicates that even under a worst-case scenario combining the Bay-Delta
Plan flows with the worst recorded drought, SFPUC could manage without requiring rationing or new
water supplies, which requires further study. More fundamentally, as highlighted in recent Commission
discussions, while no investments are being recommended at this time, Palo Alto should avoid rushing
into major alternative water supply planning and investments without first having robust data,
transparent and robust modeling, and clear understanding of assumptions. This is particularly important
given historical patterns of overestimating water demand and the need to carefully evaluate the policy,
affordability, and regional growth implications of various supply options. The city should instead focus on
supporting and engaging with regional efforts through SFPUC and BAWSCA to comprehensively assess
future water supply needs and approaches.
STRATEGIC CONSIDERATIONS
Memorandum: One Water Plan Review and Recommendations March 5, 2025
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lower. This creates a challenging communication issue, as customers find it counterintuitive that rates
continue to rise faster than inflation despite increased conservation efforts.
C ONCLUSION