HomeMy WebLinkAbout2026-05-06 Utilities Advisory Commission Agenda PacketUTILITIES ADVISORY COMMISSION
Regular Meeting
Wednesday, May 06, 2026
Council Chambers & Hybrid
6:00 PM
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1 Regular Meeting May 06, 2026
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
CALL TO ORDER 6:00PM - 6:05PM
AGENDA CHANGES, ADDITIONS AND DELETIONS 6:05PM - 6:10PM
The Chair or Board majority may modify the agenda order to improve meeting management.
PUBLIC COMMENT 6:10PM - 6:25 PM
Members of the public may speak to any item NOT on the agenda.
APPROVAL OF MINUTES 6:25PM - 6:30PM
1.Approval of the Minutes of the Utilities Advisory Commission Meeting Held on March 31,
2026
UTILITIES DIRECTOR REPORT 6:30PM - 6:35PM
NEW BUSINESS
2.Approval of Chair and Vice Chair to Serve a One-Year Term beginning May 6,
2026 (ACTION: 6:35PM – 6:55PM)
3.Recommendation to the City Council to Adopt the Proposed Operating and Capital
Budgets for the Utilities Department for Fiscal Year 2027 (ACTION: 6:55PM – 7:40PM)
Supplemental Report Added
4.Recommendation to the City Council to Adopt a Resolution Adopting the 2025 Urban
Water Management Plan, a Resolution Adopting the 2025 Water Shortage Contingency
Plan, and an Ordinance to amend the City’s Water Use Ordinance (ACTION: 7:40PM –
8:30PM)
5.2026 Annual Water Shortage Assessment Report (ACTION: 8:30PM – 8:50PM)
FUTURE TOPICS FOR UPCOMING MEETINGS
COMMISSIONER COMMENTS AND REPORTS FROM MEETINGS/EVENTS
ADJOURNMENT
OTHER INFORMATION
The materials below are provided for informational purposes, not for action or discussion during this meeting’s agenda. Written
public comments may be submitted in advance and will be provided to the Board and available for public inspection on the
City’s website three days before the meeting.
2 Regular Meeting May 06, 2026
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
A.12 Month Rolling Calendar
B.Public Comments
3 Regular Meeting May 06, 2026
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
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4 Regular Meeting May 06, 2026
Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for
public inspection at www.paloalto.gov/agendas
Item No. 1 Page 1 of 1
Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: May 6, 2026
Report #: 2604-6230
TITLE
Approval of the Minutes of the Utilities Advisory Commission Meeting Held on March 31, 2026
RECOMMENDATION
Staff recommends that the Utility Advisory Commission review and approve the March 31,
2026 minutes.
Commissioner ______ moved to approve the draft minutes of the March 31, 2026 meeting as
submitted/amended.
Commissioner ____ seconded the motion.
ATTACHMENTS
Attachment A: March 31, 2026 Draft Minutes
AUTHOR/TITLE:
Alan Kurotori, Director of Utilities
Staff: Belle Farias, Administrative Associate III
Item #1
Packet Pg. 5
Utilities Advisory Commission Summary Minutes – March 31, 2026 Page 1 of 14
UTILITIES ADVISORY COMMISSION MEETING
SUMMARY MINUTES OF MARCH 31, 2026 SPECIAL MEETING
CALL TO ORDER
Chair Scharff called the meeting of the Utilities Advisory Commission (UAC) to order at 6:00
p.m. The clerk called roll with seven present.
Present: Chair Scharff, Vice Chair Mauter, Commissioners Croft, Gupta, Metz, Phillips, and
Tucher
Absent: None
AGENDA REVIEW AND REVISIONS
None.
ORAL COMMUNICATIONS
1. Sven T. asked the Commission to use words like oxides of nitrogen, benzene, and
formaldehyde regarding clean energy and air education and encouraged the members
to convert to induction.
2. Avroh S. urged the Commission to collaborate with utilities and community
organizations to communicate the health risks when using natural gas stoves.
3. Peter D. congratulated the Commission for having influenced BAWSCA.
APPROVAL OF THE MINUTES
ITEM 1: ACTION: Approval of the Minutes of the Utilities Advisory Commission Meeting Held on
March 4, 2026
MOTION: Commissioner Phillips moved, seconded by Commissioner Metz, to approve the
minutes of the March 4, 2026 meeting.
Item #1
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Utilities Advisory Commission Summary Minutes – March 31, 2026 Page 2 of 14
MOTION PASSED: 7-0
UNFINISHED BUSINESS
None.
UTILITIES DIRECTOR REPORT
Alan Kurotori, Utilities Director described the induction cooktop rebates that are currently
active on the portal. The Finance Committee voted unanimously to recommend City Council
approve the Wastewater Utility rate increases as presented by Staff at the March 17 meeting.
Staff is working on a rate assistance program. It was taken to a UAC subcommittee talking
about affordability and will be brought back to City Council as part of the Rules and Regulations
update. Staff are evaluating increasing the discount rate from 25 to 35 percent and applying the
low income threshold to other programs for the gas utility. Discussions are being held with
other departments on the storm drain fee and other fees to see if it can be done across the
board. That will be brought back to the UAC for future Council action. A contract amendment
with Smart Energy Water went to Council in March. That is the upgrade to the MyCPAU
customer portal. That will include a dedicated mobile app. The user interface will be updated.
Two new electric supply contracts will be brought to the UAC in the next couple of months for
solar and battery projects. Staff can walk the Commission through the power purchase
agreement contracts if needed.
Commissioner Croft inquired if submittals were requested as an initiating power purchase
agreements rather than the other way around. Director Kurotori confirmed this stating the
City's standard process is an open procurement with a request for proposals for developers to
provide their products. The City works through Northern California Power Agency, a consortium
of 16 utilities looking for the same types of projects. Commissioner Croft wanted to know a
timeline of when more information would be expected. Director Kurotori replied Staff wants to
bring back some terms for the Commission to consider as early as May.
Commissioner Tucher wanted to talk about the new solar and storage deal including what is
new and how it ties into peak load demands in a bigger context. Director Kurotori responded
Staff will be bringing forward the graphs brought in the past showing how these projects may
fill those gaps in context of the overall supply. The larger conversation on resources is on the
top of their mind. That will be added as a layer as part of the presentation to the UAC.
NEW BUSINESS
ITEM 2: ACTION: Staff Recommends the Utilities Advisory Commission Recommend that the
City Council Adopt a Resolution Approving the Fiscal Year 2027 Gas Utility Financial Forecast,
Reserve Transfer, General Fund Transfer, and Amending Rate Schedules G-1 (Residential Gas
Service), G-2 (Residential Master-Metered and Commercial Gas Service), and G-3 (Large
Commercial Gas Service) ; CEQA Status: Not a project under CEQA Guidelines Section
15378(b)(5)
Item #1
Packet Pg. 7
Utilities Advisory Commission Summary Minutes – March 31, 2026 Page 3 of 14
Director Kurotori started the slide presentation including a baseline of the gas utility and rate
increases, purpose of rate adjustments, and the value of Utility Services and how funds are
used. Eric Wong, Utilities Resource Planner, joined the presentation including gas cost structure
and rate design, gas cost and revenue projections, gas bill comparisons for residential and
commercial customers, FY 2027 rate increase drivers, gas supply load forecast, gas operations
reserve projections, summary of gas rate proposal, residential median bill projections, and
recommendation.
Commissioner Gupta indicated a summation of forecast tables would be helpful and wanted to
know if the forecasts in this Staff report are understating what the expected rate increases
might look like because the additional analysis from the consultant is no longer being included.
Lisa Bilir, Assistant Utilities Director, confirmed and explained the decommissioning cost has
been removed from the forecast. It is characterized as an area of uncertainty. The
decommissioning cost will need to be added to the forecast in the future. Commissioner Gupta
queried if there is a sense of what percentage impact that had on the forecast. Assistant
Director Bilir responded if the gas utility rate is increased by 1 percent, it will result in $700,000
per year. It would take 4 percent one time to recover $3 million every year in the future.
Commissioner Gupta asked if money is being spent to maintain something that is actively being
studied for decommissioning. Assistant Director Bilir indicated the team was not prepared to
answer that question but would convey the information to the team working on that. Director
Kurotori stated they are federally regulated to actively manage, invest, and maintain the gas
system to provide that service to customers and will continue to do so. The Sustainability and
Climate Action team has worked up an initial look at a gas transition study. The distribution
models have been updated for the gas utility. More work needs to be done. Looking at the gas
transition study, a reduction in terms of the distribution system was not seen until more
customers left the system. There are active conversations with Sustainability and Climate
Action programs in terms of how fast the customers electrify. The California Public Utilities
Commission is looking at potential pilots in the investor-owned utilities. As public-owned
utilities, they are monitoring, commenting on, and getting feedback on what the private
investor-owned utilities are doing.
Commissioner Gupta questioned if obsolescence can be planned if investments are not made
required to maintain the system and plan end of life for the system. Chair Scharff thought that
was a good question to ask the consultant. Commissioner Tucher observed they were investing
more in a business that is in decline and with considerations of decommissioning it.
Commissioner Gupta asked for an explanation of CIP salaries and benefits on packet page 15 in
the table for projected CIP spending. Assistant Director Bilir explained the City has made a
budget decision to move toward splitting out salaries and benefits. It is a fluctuation as a result
of the transition. Director Kurotori added it acknowledges there are staff working on capital
projects.
Item #1
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Utilities Advisory Commission Summary Minutes – March 31, 2026 Page 4 of 14
Commissioner Metz suggested it would be helpful to see all the gas reserves on one chart
showing the minimum, maximum, and target levels and queried if the expectation was still for
the gas commodity costs to decline 4 percent. Assistant Director Bilir stated that is a
combination of the price and quantity. Analysists looking at this information have not seen a
large fluctuation for what is expected. Commissioner Metz advised to consider recommending
City Council reduce the CPA payout in order to get the target increase more in the 5 to 6
percent range.
Chair Scharff thought it would be helpful for Staff to summarize what is driving the different
increases and decreases. Assistant Director Bilir said one thing driving the increase is the lower
gas quantities of sales that are anticipated relative to the previous forecast. There is a
construction year coming up for CIP increasing costs.
Commissioner Phillips asked if the assumption in the forecast is that gas unit prices are going
down 3 percent and consumption is going down 1 percent so total commodity expenditure is
being reduced by 4 percent per year. Assistant Director Bilir replied the sales are forecasted to
decline about 4 percent over the total period. The price is expected to decline on average by 2
percent per year. In the recent price spikes seen in the broader markets for gas have not yet
affected Palo Alto. What is seen on a national level is not always what is seen in Palo Alto but
price projections are monitored for the best forecast. Commissioner Phillips observed the U.S.
gas market is detached from the world market. Director Kurotori confirmed that to be correct.
Vice Chair Mauter mentioned a grant that represents about 27 percent of annual gas utility
expenditure and commented it would not be good to curtail any of the CIP investment. There is
a regulatory commitment to maintaining gas safety. These are large gas mains going through
the city, not individual service lines to individual houses that are being upgraded. Even if a gas
decommissioning plan was to be adopted in the future, the large gas mains in the City will not
be decommissioned within the useful lifespan of the infrastructure that is currently being
proposed. Director Kurotori stated it is a fair assessment that this grant will be used to replace
the aging infrastructure that provides gas service to a bulk of the community. There are not
excess reserves in the capital program. They are trying to build those reserves up. The reason
for the lumpy changes in terms of the rate requests to the Commission and City Council is
because there are not reserves to rely on.
Commissioner Tucher asked if taking or safeguarding the $16 million grant has any bearing on
that fact they are investing expense and CapEx in this utility that is in decline. Chair Scharff
stated it requires them to do the CIP. Vice Chair Mauter explained the typical CIP expenditure is
less than $16.5 million a year on average. This is an entire year's worth of CIP expenditure that
will have to be done anyway in order to maintain safety of the system. When City Council
makes decisions about a gas decommissioning, there will be a separate conversation. Director
Kurotori stated grant funding projects are projects that had been submitted and would need to
be done in the future anyway. The grants are valuable to the rate payers in terms of that
reinvestment. It shows a spike in terms of the revenues. That could be misinterpreted so that
Item #1
Packet Pg. 9
Utilities Advisory Commission Summary Minutes – March 31, 2026 Page 5 of 14
bump in increase on the graph is taking that into account. Vice Chair Mauter said it also
requires they continue to spend on capital at the same rate which means the rates cannot be
decreased. Director Kurotori replied there is a baseline commitment being held to as part of
that grant. The grant is on top. It is not a substitute.
Vice Chair Mauter queried if the Crossbore inspection program is finished. Aaron Perkins,
Principal Engineer – WGW Utilities, responded out of the 995 addresses brought to the UAC in
the past, Operations has been going around and inspecting those in-house. About 50 percent
have been cleared with operational staff which means any of the remaining ones that required
work they were not able to perform will go out to a contract. Vice Chair Mauter asked about
the annual cost. Mr. Perkins answered it is in the operating budget.
Commissioner Phillips was uncomfortable with the 14.5 percent increase on distribution costs.
CIP and reserves are potential levers. The 18 percent should be discussed. The Staff
recommendation is so open ended it should not be included in the resolution. Councilmember
Lauing wanted feedback on the 18 percent transfer. It is $5 million that cannot be put into
other services in the City. If it is put into utilities to keep the rates down, it does not go
anywhere else. It is a valid discussion for Council to have.
Commissioner Croft asked if the effect of the heat wave on the gas revenue has been taken into
account. Assistant Director Bilir replied the most recent information is based on a weather
normalized forecast using a statistically adjusted end use model provided by the consultant.
The month of March and the impact the heat wave may have had has not been incorporated
that in this forecast. Commissioner Croft would rather push people on the prices of the electric
side and water than gas.
Chair Scharff found the load forecast difficult to process and wanted to see the difference
between the weather and how many people are switching broken out. The downward trend on
the chart looks made up. Assistant Director Bilir explained weather normalization looks at
individual years where the temperature was known and then adjust what the sales would have
been for a longer time period. Attaching memos describing the full analytical analysis and
regression equation that shows what those coefficients are for each of the things are might be
helpful for the next year. Chair Scharff asked about the decline and what drives it. Assistant
Director Bilir is about 1.1 percent per year. When working with the consultant, there were two
scenarios. One without the high level of electrification and one with. The scenario selected was
with the higher level of electrification assumed. Chair Scharff queried if the low level of
electrification would change the suggestion on where rates should be for 2026. Assistant
Director Bilir replied it would not affect the rate proposal in the short term. The trajectory
might change in the more cumulative longer time period.
Chair Scharff asked how much lower the rate increase would be if building up the reserves was
emphasized less. Assistant Director Bilir pointed out a table on packet page 20 that gives a full
picture of the funds available for other purposes.
Item #1
Packet Pg. 10
Utilities Advisory Commission Summary Minutes – March 31, 2026 Page 6 of 14
Commissioner Phillips wanted to know what will happen to the rest of the operations reserve
that is not moved to the distribution rate stabilization. Assistant Director Bilir answered 2027 is
a construction year for CIP. CIP is spread over different years and can be lumpy in terms of the
investment. Commissioner Phillips asked how the level of CIP impacts the money in the reserve
at the beginning and end of the year. Assistant Director Bilir stated the change in the reserve
from the beginning to the end of the year has to do with the amount of revenue and expenses
Utility experiences during the year including the revenue and expenses and the investment that
Utility makes in capital assets. All of the costs and revenues go through the operations reserve.
The CIP reserve requires Council approval to move funds in or out of the reserve. From one year
to the next, there is not enough to put into the CIP reserve. It will be spent in 2027. As a
cleanup item, there could be a recommendation to transfer some of the operating dollars into
the CIP reserve in 2026 and take them out in 2027 for the purpose of CIP.
Commissioner Gupta queried how much wiggle room there is on timing of these projects. Vice
Director Kurotori stated they have to maintain the same level of commitment to get the $16.5
million. There is no wiggle room past the current commitment which is the current
expenditures for the gas main replacement. Mr. Perkins added the GMR 25 original budget was
$9.8 million. The grant is specific to GMR 25. The original budget for the original GMR 25 was
split in half and applied to GMR 26 and 27.
Chair Scharff asked if there was a spike in the general transfer fund last year. Assistant Director
Bilir stated it spiked up in 2025 based on the actual revenue in 2023, which was the gas price
spike year. Kiely Nose, Assistant City Manager, stated there are general fund transfers from the
electric and gas utilities. The gas utility was affirmed by the voters and is based on a gross
percentage of revenues. The electric transfer is based on a formula that was established many
years ago and ultimately was upheld when we went through the recent litigation that changed
the gas transfer. That is a transfer made from the electric utility to the general fund annually.
These transfers are about $27 million combined. It is based on asset values, rate of return from
other utilities, and available revenues eligible to be transferred under this formula.
Commissioner Croft inquired if there is any discretion to change the electric transfer. Assistant
City Manager Nose replied the Council can do a change in policy at its pleasure. There is high
risk for litigation so they would want to look at that in greater detail before relooking at the
structure of that. The structure of the electric one was upheld in recent litigation.
Assistant City Manager Nose reminded the Commission that the general fund is looking at
about a $15 million deficit this year. As part of the budget proposals, they will come back with
service cuts. Any additional reduction in this transfer will mean additional service cuts. Chair
Scharff wanted to know why they were not getting rid of the meter reader positions. Assistant
City Manager Nose responded AMI is not fully rolled out yet. They are making the eliminations
as that transition is being made. Once that is fully rolled out, further staffing adjustments will
be made. Director Kurotori added there will still be needs for meter techs so there will still be
some staff for that.
Item #1
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Utilities Advisory Commission Summary Minutes – March 31, 2026 Page 7 of 14
Commissioner Croft did not support the resolution believing there may be less demand.
Commissioner Tucher on the basis that it is a business in decline. Vice Chair Mauter recalled
being conscientious about not doing any CIP because commodity charges were peaking over
the past couple of years and focused on keeping rates low. Those were charges they did not
have control over because they were pass-through charges. They under-invested in reserves
and CIP. This is the implication of that and the receipt of an external grant to support this. A
transition toward electrification is desirable but not at the expense of safety. Chair Scharff
added it is a minor decline. It is not leading to decommissioning or shutting down the utility by
2040. It depends on where it goes beyond that. Commissioner Gupta indicated the City was
about to spend hundreds of millions of dollars in order to electrify the City and transition away
from gas and ultimately decommission it. There is a lot of work going on in the City on planning
around sustainability goals. The $16.5 million tied to the federal grant is fine but would
alternatively propose pushing CIP except just one year except for that. The 18 percent transfer
is one of the few levers to disincentivize gas and recommended studying reducing transfers
from the electric utility further.
MOTION: Commissioner Phillips moved, seconded by Vice Chair Mauter, to recommend that
the City Council adopt a resolution (Attachment A):
1. Approving the Fiscal Year 2027 Gas Utility Financial Forecast shown in this staff report
and attachments, which includes amending the Gas Utility Reserve Management
Practices; and
2. Approving the transfer of up to $1.5 million from the Gas Utility Operations Reserve to
the Distribution Rate Stabilization Reserve at the end of FY 2026; and
3. Maintain a rate increase of no more than 7% through a combination of reducing the
General Fund Transfer and potentially using other levers such as reserve levels; and
4. Amending Rate Schedules (Attachment A, Exhibit 1) effective July 1, 2026 (FY2027) by
7%.
a. G-1 (Residential Gas Service)
b. G-2 (Residential Master-Metered and Commercial Gas Service)
c. G-3 (Large Commercial Gas Service)
MOTION PASSED: 4-3, Croft, Gupta, Tucher no
ITEM 3: ACTION: Staff Recommends the Utilities Advisory Commission Recommend that the
City Council Adopt a Resolution Approving the FY 2027 Electric Financial Forecast, including
Approving a Reserve Transfers, and Amending Electric Rate Schedules E-1 (Residential Electric
Service), E-1 TOU (Residential Time of Use Electric Service), E-2 (Residential Master-Metered
and Small Non-Residential Electric Service), E-2-G (Residential Master-Metered and Small Non-
Residential Green Power Electric Service), E-4 (Medium Non-Residential Electric Service), E-4-G
(Medium Non-Residential Green Power Electric Service), E-4 TOU (Medium Non-Residential
Time of Use Electric Service), E-7 (Large Non-Residential Electric Service), E-7-G (Large Non-
Residential Green Power Electric Service), E-7 TOU (Large Non-Residential Time of Use Electric
Item #1
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Utilities Advisory Commission Summary Minutes – March 31, 2026 Page 8 of 14
Service), E-14 (Street Lights), E-16 (Unmetered Electric Service), E-EEC-1 (Export Electricity
Compensation), and E-NSE-1 (Net Metering Net Surplus Electricity Compensation); CEQA Status:
Not a project. under CEQA Guidelines Section 15378(b)(5)
Terry Crowley, Utilities Chief Operating Officer, provided a slide presentation including electric
utility at a glance, purpose of rate adjustments, and value of utility services and how funds are
used. Assistant Director Bilir joined the presentation including electric utility cost structure:
Average FY 2024-2025, electric cost and revenue projections, electric bill comparisons, electric
operations reserve projection, electric utility CIP spending, electric bill impact, communication
and outreach summary, recently implemented cost containment, summary of electric rate
proposal, residential median bill projections, and electric recommendation.
Chair Scharff asked about determining a median residential customer. Assistant Director Bilir
replied it is calculated based on the median usage of all residential customers. Chair Scharff
requested to see a breakdown in terms of distribution curve on a chart. Commissioner Croft
suggested using a histogram of usage brackets with the effect of the change. Mr. Crowley
pointed out table 11 in the staff report that shows residential rates and various usages ranging
from 300 kilowatt hours per month. Director Kurotori clarified the request is for a histogram of
the distribution of customers.
Commissioner Croft wanted to know how hydro versus renewable versus the market rate
compares to each other. Lena Perkins, Utilities Strategic Business Manager, replied there is no
short answer because hydro variability is basically a market mover across the whole west. In a
big hydro year, all of California's electricity is cheaper. About 50 percent of the portfolio is
hydro and about 20 percent of California's supply is hydro. That is why the hydro rate
stabilization reserve exists. The overall supply, including transmission, is around $95 million a
year. If transmission is $35 million of that, then dollars per kilowatt for supply is around six and
a half cents currently. Commissioner Croft asked if excluding hydro and looking at renewables
versus market was easier to talk about. Ms. Perkins answered renewables are required by the
state. They are no longer trying to have a higher renewable percentage than the state but the
required renewable percentage is like 52 percent. That requirement drives a price premium for
renewables versus market. That is what a renewable can be purchased for on the open market.
Commissioner Croft queried if they are required to get the power purchase agreements
because of the state requirement. Ms. Perkins stated there is a carbon neutral plan on top of
that. Given it is about 50 percent hydro in an average hydro year and sometimes below,
eventually renewables will be required to be 60 percent. In a wet year, there is an exemption to
go below that. One of the ways that exemption has been preserved is by being a good actor in
the renewable space. Hydro overall lowers the cost from market and renewables. The power
purchase agreements have a little bit of the investment tax credit baked in and look to be some
of the most affordable. There were a number of responses last year. They got a battery but no
power.
Item #1
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Utilities Advisory Commission Summary Minutes – March 31, 2026 Page 9 of 14
Commissioner Croft asked about the time of use rate increase. Assistant Director Bilir explained
there was not a new time of use cost of service analysis. It was increased by the appropriate
rate increase. Commissioner Croft asked if the 6 percent increase is warranted. Assistant
Director Bilir responded the rate increase for all rates is approached through an across the
board rate increase when there is not a cost of service study. The cost of service study was last
done in July or August 2025. It will be revisited soon. Director Kurotori added the time of use
rates are supposed to be revenue neutral in theory. There is no cross subsidy. It is appropriate
to raise them up at the same time as other rates.
Commissioner Phillips referred to packet page 130 and asked for explanation of rising
administration costs. Director Kurotori said when cost increases are done, they are
acknowledging other departments are being used. There is a cost allocation study in terms of
the support provided to the utilities. There are significant efficiencies in use of public works for
the line clearing program. The same staff manages the tree trimming program for street trees
and line clearing.
Commissioner Gupta inquired if the City is doing a cost of service type of study on allocated
charges for the citywide level. Assistant City Manager Nose will check with the administrative
services team. Cost allocation is looked at annually as part of the budget process.
Vice Chair Mauter wanted to be cognizant of presenting rates in the absence of presenting
inflation. Policies could be changed in order to talk about rate increases relative to the
appropriate metric for Santa Clara County.
Vice Chair Mauter wanted to be sure there is a way to translate between gas decline and the
impact on increase in electric power consumption. Assistant Director Bilir explained when gas
regression is forecast, it is not known if those units are one to one because of electrification. In
the load forecast for the electric utility, that has been considered and taken into account. Vice
Chair Mauter wanted to ensure there is a formalized process for making when looking at
declines in gas, the implications of increase in electric are being accounted for. Ms. Perkins
clarified because heat pumps get three to one, one unit of gas saved only gets a third of a unit
of additional electricity. It is baked in. It is linear at this point in the training period. Vice Chair
Mauter observed that recent discussions on data centers and the potential projected new load
growth will not significantly increase the marginal cost of power production. These projections
are insensitive to what might happen over the next year or two on that front. Commissioner
Phillips stated this was discussed in the subcommittee and small increases would not increase
the marginal cost and decrease residential rates. Vice Chair Mauter opined they should start
with the subcommittee report in the future.
Chair Scharff asked if there is a sense of the hydro for next year. Ms. Perkins replied the
upcoming year will not be as good as the past year. There has been some load growth. There is
instability in the market. Reservoirs have a design storage of a three to five year drought. Some
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of the worst parts of hydroelectric generation are after three years of a drought when a big
reservoir is sitting empty and it is filled instead of releasing anything.
Commissioner Gupta had questions about grid mod and debt service. Assistant Director Bilir
said the pink and red sections identify the magnitude of the grid modernization debt.
Commissioner Gupta queried if they are being targeted on investments on grid mod. Mr.
Crowley answered this plan represents what was presented to UAC a month or two ago. It
spreads those expenditures out over time and trying to meet the customer's pace for
electrification. There is focus on some of the legacy equipment in service right now. One
challenge is that while there are plans to do some work, material lead times are planned at
three to four years out resulting in a spike in expenditures in 2030. They will continue to revise
and optimize this number for cost savings.
Commissioners Phillips and Croft covered the subcommittee's discussions about rates in
general, data centers, and rebates to relatively low income customers. Vice Chair Mauter asked
if there is broad support of the subcommittee for the proposed rate increases. Commissioner
Croft supported the 1 year 6 percent increase for 2027. Commissioner Phillips was convinced
the 6 percent is right. Commissioner Tucher was in support of the 6 percent but would like
more analysis.
Commissioner Metz asked for the analysis about the future rate impacts of data centers.
Director Kurotori replied a presentation with that information had been brought to this body.
There will be more discussions moving forward. Commissioner Metz inquired what happens to
rates if the future load is greater than the FY27 expected forecast. Director Kurotori explained
industrial or commercial is 80 percent of the service. A larger customer has a benefit to all
customers because of where they are sited and capacity of the system. Palo Alto has plans of
looking at the costs associated with a data center coming in so there is some insulation with
that in existing customers. There are models other cities are using on capacity fees that have
been discussed with this Commission to look at. They can also bring in their own energy
contracts. This forecast is used for infrastructure. Commissioner Metz wanted to see an analysis
of the rate impact at the standard forecast and at the high end of the envelope.
Chair Scharff requested agendizing understanding how reserves are done in the City and
utilities. Director Kurotori indicated the Policy and Services Committee will hear the report from
Baker Tilly on the reserve on April 14th. It will be made public.
Assistant City Manager Nose requested the Commission choose someone to represent them at
the Finance Committee when these items move forward on April 21. Commissioner Phillips
agreed to attend.
MOTION: Vice Chair Mauter moved, seconded by Commissioner Croft, to recommend that the
City Council adopt a resolution (Attachment A):
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1. Approving the Fiscal Year 2027 Electric Utility Financial Forecast shown in this staff
report and attachments,; and
2. Approving the transfer at the end of FY 2026 of up to $5 million from the Electric Utility
Distribution Operations Reserve to the Electric Utility Capital Reserve; and Amending
Electric Rate Schedules (Attachment A, Exhibit 1) effective July 1, 2026 (FY 2027):
a. E-1 (Residential Electric Service)
b. E-1 TOU (Residential Time of Use Electric Service)
c. E-2 (Residential Master-Metered and Small Non-Residential Electric Service)
d. E-2-G (Residential Master-Metered and Small Non-Residential Green Power
Electric Service
e. E-4 (Medium Non-Residential Electric Service)
f. E-4-G (Medium Non-Residential Green Power Electric Service)
g. E-4 TOU (Medium Non-Residential Time of Use Electric Service)
h. E-7 (Large Non-Residential Electric Service)
i. E-7-G (Large Non-Residential Green Power Electric Service)
j. E-7 TOU (Large Non-Residential Time of Use Electric Service)
k. E-14 (Street Lights)
l. E-EEC-1 (Export Electricity Compensation) to reflect forecasted avoided cost for FY
2027, and
m. E-NSE-1 (Net Metering Net Surplus Electricity Compensation) to reflect avoided
cost for CY 2025.
MOTION PASSED: 6-1, Metz no
ITEM 4: DISCUSSION: Preliminary Information on the City of Palo Alto's (City) 2025 Urban Water
Management Plan (2025 UWMP)
Adriana Artola, Utilities Senior Resources Planner, provided a slide presentation including the
purpose and agenda, background, required inputs, long-term water demand projections,
historical and projected demand comparisons, water reliability assessment, water use
restrictions, recycled water and alternative water supplies, and stakeholder engagement/next
steps.
Public Comment
1. Peter D. mentioned the SFPUC's design drought, encouraged Palo Alto to create their
own table for the five-year dry year sequence and incorporate it into the Urban Water
Management Plan, and indicated it is time to move on from the design drought.
2. Dave W. echoed the previous public speaker's comments. The SFPUC, water
management representative, and City Council should be pressed to do a risk analysis.
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Chair Scharff asked what leeway there is in the City doing their own design drought. Assistant
Director Bilir understood the code requires them to use the information from SFPUC and Urban
Water Management Plan. They may be able to include information from Peter Drekmeier or
someone else if Council directs. The information would need to be vetted and brought to the
SFPUC to ask them to provide different information. Director Kurotori stated they would create
another alternate analysis that would stand alone from the Urban Water Management Plan
knowing there are guidelines and thresholds that have to be provided. The other 26 BAWSCA
agencies used San Francisco's information in the Urban Water Management Plan. Chair Scharff
wanted to understand where alternative scenarios go. Assistant Director Bilir stated there is not
staff or knowledge to come up with a different scenario. There would be need to hire a
consultant or put together a budget to figure out how to vet the information provided. The next
step after vetting would be to bring it to SFPUC to see if they can revise their forecast. Chair
Scharff asked if Staff is suggesting recommending the City hire a consultant to vet what Mr.
Drekmeier says. Director Kurotori indicated if they were to run the analysis given the provided
information by the Yosemite Rivers Alliance, that analysis could be done. It would be separate
from the Urban Water Management Plan.
Commissioner Phillips and Chair Scharff questioned what feedback is being requested. Ms.
Artola said the intention is to provide the opportunity for questions and concerns because this
has been a big topic with a lot of public interest. Commissioner Phillips inquired if the
Commission could use different assumptions for internal planning. Assistant Director Bilir
answered there have historically been integrated water resources plans in the utilities
department. Those have been done periodically. Before doing any alternative water supply
investments, they would look at an integrated water resources plan in addition to capital
planning. The regional level with SFPUC is going through their alternative water supply planning
and will be relying on additional analyses in order to do that. Although the Urban Water
Management Plans are useful in terms of their statewide requirements and being able to look
at information statewide across urban water suppliers, they will not rely on this for any
investment type decisions.
Commissioner Metz asked if this is viewed as a regulatory requirement or a plan. Ms. Artola
replied it is viewed as a regulatory requirement. The Urban Water Management Plan includes
the Water Shortage Contingency Plan. It outlines the actions the City will take during different
drought stages. The updated plan will be presented at the May meeting.
Commissioner Croft commented the forecast seemed reasonable, urged to do the non-
functional turf ban in 2027, and asked if it would be reasonable to come up with an alternative
design drought.
Vice Chair Mauter wanted to see more detail in the new demand study and have it linked in the
final packet and wanted to know why the numbers provided by Casey Brown are not being
used. Director Kurotori stated there was an update in 2025. The research partner was SFPUC.
Chair Scharff requested Staff be familiarized with this before it comes back in May.
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Vice Chair Mauter wanted to see clear relationship in the demand study to how temperature is
changing. It would be helpful to have the rate of demand increase and rebound validated by
AMI data specific to Palo Alto and snowmelt data. Vice Chair Mauter wanted to ensure Council
and the Commission is being educated about what is happening around the Bay.
Commissioner Phillips suggested they could change the tone of the Urban Water Management
Plan. A second plan not dependent on the same assumptions is desired looking at the
alternatives within the market and region that could ameliorate the risk by using different
forecasting methodologies, etc. The Commissioner wanted to see the demand model that was
used in detail and run it.
Commissioner Gupta thought there is a broad support in developing their own numbers with
the help of academics. They should approach SFPUC with the alternative numbers and ask them
to show the work on the numbers they have. Commissioner Gupta requested to have the
SFPUC's design drought code sent and wanted to know what alternative water supplies are
being built by other BAWSC members and if those plans are incorporated in SFPUC's plans.
They should be looking at other agencies who are not using SFPUC's plans in their Urban Water
Management Plans. The Commissioner wanted to confirm there is no one water planning or
alternative water investments being planned or approved through this process. Ms. Artola
confirmed that to be correct.
Chair Scharff asked about the distinction of non-functional turf and about delaying the non-
functional turf ban. Ms. Artola responded it is state law. The City must adopt an updated
ordinance by January 1, 2027. The implementation is phased. The City could adopt a more
aggressive timeline if directed by Council. Director Kurotori explained there have been a lot of
conversations and consistency with state law and the rollout. Government sites are first then
commercial and then the HOAs. Going faster than that would require more outreach. They are
actively engaging in those conversations with other water retailers. Assistant Director Bilir
explained non-functional turf is defined by the state. If used for recreation, it is considered
functional. If it is next to certain distance of trees and providing tree health it is considered
functional.
Chair Scharff asked about Mr. Drekmeier's thoughts on the Urban Water Management Plan.
Mr. Drekmeier stated everyone is going to pass their plans. It is an opportunity to make a
statement and get answers to their questions. Chair Scharff supported Vice Chair Mauter's
point with using Casey Brown and was not in favor of spending huge amounts on a consultant
to vet this.
Commissioner Tucher was not proposing any outside study. The only constructive thing to do is
come up with a plan to persuade SFPUC to come to the table and show its work, share its
assumptions, and engage in a more collaborative approach to drought planning. Vice Chair
Mauter understood that Casey was the source of a lot of information for SFPUC in those
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projections. There is documentation they have not been able to review. They can highlight
things they disagree with. They could approach SFPUC more collaboratively with specific asks of
value judgments baked in and specific questions about technical assumptions that would
kickstart constructive dialogue. They need to work collaboratively with SFPUC and BAWCA
member agencies to come up with an affordable and resilient water supply plan.
NO ACTION TAKEN
COMMISSIONER COMMENTS AND REPORTS FROM MEETINGS/EVENTS
None.
ADJOURNMENT
Adjournment: The meeting was adjourned at 10:06 p.m.
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Item No. 2 Page 1 of 1
Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: May 6, 2026
Report #: 2601-5818
TITLE
Approval of Chair and Vice Chair to Serve a One-Year Term beginning May 6, 2026
RECOMMENDATION
Commissioner ____ moved to approve Commissioner ____ as Chair.
Motion seconded by Commissioner ___.
Commissioner ___ moved to approve Commissioner ___ as Vice Chair.
Motion seconded by Commissioner ___.
BACKGROUND
This item is included in the agenda in alignment with the bylaws section 2.23 for the purpose of
Commissioners selecting a Chair and Vice Chair. Per section 2.23.040, “The commission shall
elect one of its members chairperson. The chairperson shall hold office for one year and until
his or her successor is elected, unless his or her term as a member of the commission expired
earlier.” The selected chair and vice chair will serve in accordance with this term.
AUTHOR/TITLE:
Alan Kurotori, Director of Utilities
Staff: Belle Farias, Administrative Associate III
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8
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7
Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: May 6, 2026
Report #: 2512-5645
TITLE
Recommendation to the City Council to Adopt the Proposed Operating and Capital Budgets for
the Utilities Department for Fiscal Year 2027
RECOMMENDATION
Staff recommends the Utilities Advisory Commission (UAC) recommend that the City Council
adopt the proposed operating and capital budgets for the Utilities Department for Fiscal Year
2027
SUMMARY
Staffing Highlights of the FY 2027 Utilities Budget
No new Full-Time Employees (FTEs) being requested
Elimination of 5 full-time and 3 part-time positions due to Advanced Metering
Infrastructure program
Freeze of 3 full-time FTEs in the Fiber Utility pending results of Fiber-to-the-Premises
pilot
CIP Highlights
Wastewater has three new projects
Project Title Proj. No. 5 Year Budget
Sewer Master Plan WC-30001 $0.4M
Wastewater Line Replacement at Arastradero Creek WC-27002 $2.4M
Wastewater Pump Station Retrofit WC-28000 $3.8M
Total $6.6M
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7
Electric Grid Modernization has become a project category encompassing 12 distinct
projects rather than a single project. This allows staff to better track project costs,
dependencies, priorities and progress within the Grid Modernization effort
Water has three new projects
Will be released on April 24, 2026 on the City’s Budget webpage:
https://www.paloalto.gov/Departments/Administrative-Services/City-Budget
FY 2027 Proposed Operating Budget
FY 2027 Proposed Capital Budget
AUTHOR/TITLE:
Alan Kurotori, Director of Utilities
Staff: Anna Vuong, Senior Business Analyst
Project Title Proj. No. 5 Year Budget
Adobe Creek Substation Reconstruction EL-27006 $3.8M
Alma Junction to Quarry 60kV T-Line Reconductor EL-27002 $1.2M
Colorado 60/12kV Banks Relocation & Rebuild EL-27007 $30.6M
Colorado 60kV Bus Rebuild EL-17002 $11.6M
Colorado to Adobe Creek 60kV T-Line Reconductor EL-27003 $1.4M
East Meadow Substation 4 to 12kV Conversion EL-27004 $29.2M
East Meadow to Maybell 60kV T-Line Reconductor EL-27001 $2.6M
GM 12kV Distribution Feeder Ties EL-27010 $23.1M
GM Hopkins Distribution 4 to 12kV Conversion EL-27009 $29.9M
GM 12kV Distribution Residential Rebuild EL-24000 $62.5M
Hopkins Substation 4 to 12kV Conversion EL-27005 $3.8M
Park Blvd 60kV Breaker Replacements EL-27008 $6.4M
Total $206.1M
Project Title Proj. No. 5 Year Budget
Water Main Replacement - Project 33 WS-20001 $0.6M
Water Line Replacement at Arastradero Creek WS-27001 $2.9M
Water System Master Plan WS-27000 $0.8M
Total $4.2M
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Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: May 6, 2026
Report #: 2512-5652
TITLE
Recommendation to the City Council to Adopt a Resolution Adopting the 2025 Urban Water
Management Plan, a Resolution Adopting the 2025 Water Shortage Contingency Plan, and an
Ordinance to amend the City’s Water Use Ordinance.
RECOMMENDATION
Staff recommend the Utilities Advisory Commission (UAC) recommend the City Council adopt a
resolution adopting the 2025 Urban Water Management Plan, a resolution adopting the 2025
Water Shortage Contingency Plan, and an Ordinance Amending Municipal Code Chapter 12.32
(Water Use Regulations).
EXECUTIVE SUMMARY
Every urban water supplier in California is required to submit an Urban Water Management
Plan (UWMP), which includes a Water Shortage Contingency Plan (WSCP), every five years.
UWMPs must include information about water demand, water supply, demand management
activities, alternative water supplies, anticipated shortages during dry periods, and contingency
plans for addressing those shortages. The actions recommended in this report, if approved,
would satisfy this requirement for the City of Palo Alto. The 2025 UWMP must be adopted by
City Council and submitted to the Department of Water Resources (DWR) to meet the state-
required deadline of July 1, 2026.
The City’s demand for water is expected to decrease by about 5% over the next 25 years,
inclusive of savings from passive and active conservation. Potable water supply from the City’s
supplier, the San Francisco Public Utilities Commission (SFPUC), is projected to be adequate
during normal years, but significant shortfalls are expected during droughts.
Palo Alto, in collaboration with its partners, continues to seek to maximize water conservation
to reduce the impact of dry years. When water supply shortages do occur, Palo Alto’s WSCP
provides for increasingly aggressive steps to reduce water use including public outreach and
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education, rebate programs, water use restrictions, and water allocations. The City’s Water Use
Ordinance outlines permanent water use restrictions.
BACKGROUND
ANALYSIS
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Element and the City’s current and planned participation in water conservation programs. More
information about the inputs and methodology for the 2025 Demand Study can be found in the
2025 Regional Demand Study Report1.
Figure 1: SFPUC Purchases - Actual and Forecast
the projections use population
data from the Association of Bay Area Governments (ABAG) Plan Bay Area 2040 projections,
together with the assumption that the City will meet its RHNA targets by 2031. Under this
assumption, all population growth occurs through 2031 as those units are added, and
population levels remain flat after 2031.
1 2025 Regional Water Demand and Conservation Study: https://bawsca.org/water/use/2025_Demand_Study
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Table 1: Population - Current and Projected
Water demand and population are described in “Section 4 – Water Demand” and “Section 2 –
Service Area” of the UWMP.
2. Water Supply Adequacy
The City receives 100% of its potable water from the SFPUC through the Regional Water System
(RWS). The City also uses some recycled water produced at the Palo Alto-operated Regional
Water Quality Control Plant (RWQCP) for irrigation of the municipal golf course, a park, and
some other minor applications. A system of local groundwater wells and storage provide
emergency water supply service.
The SFPUC has a perpetual commitment (Supply Assurance) to deliver 184 MGD to the 24
permanent Wholesale Customers collectively. Palo Alto’s allocation, or Individual Supply
Guarantee, is 16.575 MGD, or approximately 18,579 acre feet per year. In normal years, the
Palo Alto’s potable water demand is not expected to exceed supply as shown in Table 2.
3. Water Conservation
The 2025 UWMP highlights the water conservation programs and the important role they play
in the City’s water supply planning. The City partners with the Santa Clara Valley Water District
(Valley Water) to offer a wide range of water conservation programs to our residential and
commercial customers. The City pursues innovative technologies and cost-effective programs
to implement and best utilize the annual water conservation operating budget. These programs
include free outdoor water audits, rebates for upgrading a wide range of high water-using
fixtures to high efficiency models, low water use landscapes, laundry to landscape graywater
systems, irrigation hardware, commercial food service and other process equipment. Water
conservation resources available to Palo Alto customers can be found on the City’s website3
and Valley Water’s website4. Water conservation is described in “Section 5 – Demand
Management Measures” of the UWMP.
4. Recycled Water and Alternative Water Supplies
3 https://www.paloalto.gov/Departments/Utilities/Ways-to-Save
4 https://www.valleywater.org/watersavingsorg
2025 2030 2035 2040 2045 2050
Service Area Population 67,231 88,509 91,532 91,532 91,532 91,532
2025 2030 2035 2040 2045 2050
Palo Alto Demand for SFPUC Water 9,836 9,783 9,677 9,634 9,635 9,680
Individual Supply Guarantee 18,579 18,579 18,579 18,579 18,579 18,579
Difference 8,743 8,796 8,901 8,945 8,943 8,898
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The 2025 UWMP is required to describe planned recycled water use and alternative water
supply projects. The 2025 UWMP does not identify any recycled water or alternative water
supply projects planned by the City. It does include descriptions of regional projects and supply
planning projects by the SFPUC and BAWSCA.
7. The amount of water available to San Francisco’s
Retail Customers (the residential and commercial customers in the City of San Francisco) and
Wholesale Customers (the 26 agencies, including Palo Alto, that purchase water from the
SFPUC) will be impacted by the outcome of the Water Quality Control Plan for the San Francisco
Bay/Sacramento-San Joaquin Delta Estuary (Bay-Delta Plan Amendment or Bay Delta Plan). This
2025 UWMP assumes implementation of the Bay Delta Plan and associated unimpaired flow
requirements for the Tuolumne River. In August 2018, City Council voted to support the Bay
Delta Plan8.
7 The Tier 2 Drought Response Implementation Plan, which allocates the collective wholesale customers’ share of
available RWS supplies among each of the 26 wholesale customers during dry years, only applies during system-
wide shortages of 20% or less. Because the projected wholesale cutbacks range from 31% to 48%, the Tier 2 Plan
cannot be applied. Therefore, the 2025 UWMP cutback projections are assumed to apply to each wholesale
customer equally.
8 See Council meeting minutes: https://www.cityofpaloalto.org/civicax/filebank/documents/66831
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Table 3: Projected RWS Supply Available to Palo Alto for 5-year Drought Assessment (AFY)
The potable water supply shortfall for Palo Alto for multiple dry years is shown below in Table
4. The Multiple Dry Year projections assume implementation of the Bay Delta Plan in 2030.
Under these conditions, Palo Altans will be asked to reduce water usage by up to 48%.
See “Section 8 – Supply and Demand Comparison Provisions” in the UWMP for more details.
Climate change was considered as part of SFPUC’s water supply reliability assessment, and as
required by Water Code. The City’s 2025 UWMP includes a description of actions the SFPUC has
taken to assess the effects of climate change, including its partnership with the Water Research
Foundation to develop the Long-Term Vulnerability Assessment (LTVA) of the RWS11. See
UWMP “Section 6 – Water Supply Reliability – SFPUC Climate Change Studies”.
The 2025 UWMP also includes descriptions of regional efforts facilitated by BAWSCA to address
water supply reliability, including the development of its Long-Term Reliable Water Supply
Strategy 2050 (Strategy 2050), a regional assessment of Member Agencies’ water supply needs.
See “Section 6 – Water Supply Reliability – Regional Plans to Ensure a Reliable Water Supply”.
6. Water Shortage Contingency Planning
During the most recent drought, the City was able to reduce water use by 15% in response to
voluntary reduction measures and during the 2015 drought the City reduced water use by 31%.
The City’s proposed Water Shortage Contingency Plan (WSCP) includes actions to achieve water
use reductions above 40% and above 50%, but the City does not have actual experience in
implementing such drastic measures. With each progressive stage, enforcement, rate
strategies, and water use restrictions will be increased while putting in place mitigation
measures to maintain the health of the City’s tree canopy.
11 Long Term Vulnerability Assessment: https://www.sfpuc.gov/about-us/reports/long-term-vulnerability-
assessment
Year 2026 2027 2028 2029 2030
Palo Alto Demand 9,339 9,194 9,193 9,080 9,011
Cutback 0.0%0.0%0.0%0.0%0.0%
Available Supply 9,339 9,194 9,193 9,080 9,011
2030 2035 2040 2045 2050
First Year 31.1%33.0%35.2%36.8%38.4%
Second Year 42.2%42.9%45.1%46.8%48.4%
Third Year 42.2%42.9%45.1%46.8%48.4%
Fourth Year 42.2%42.9%45.1%46.8%48.4%
Fifth Year 42.2%42.9%45.1%46.8%48.4%
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Short-term emergency water needs will be met with the City’s groundwater wells and storage
system. The system was designed to provide adequate fire protection following a disaster such
as a major earthquake. Groundwater may also be available during drought periods although
pumping restrictions may be in place, and the City’s wells are currently restricted to 1,500 AFY,
5 consecutive days of pumping, and 15 days of pumping per year.
Table 5: Summary of Proposed Water Shortage Contingency Plan
Stage I Stage II Stage III Stage IV Stage V Stage VI
Target Water
Savings Up to 10%10% -20%20% -30%30% - 40%40%- 50%Above 50%
Information
Outreach
and Audit
Program
Low level
outreach
Increase advertising, social media
campaigns and direct communication with
customers targeting highest users and
increasing water use auditing
Escalate
outreach
efforts and
media
campaign
with focus
on water use
prioritization
Highest
outreach
effort level
with focus
on health
and safety
Demand-Side
Management
Programs
Continuation
of existing
programs,
evaluation of
new programs
Augment programs and incentive levels as necessary to achieve
reduction targets
Rate
Structures
Standard
rates already
encourage
conservation
Drought rate
structures may be
implemented to
secure needed
revenue
Water allocations or allotments may be
implemented
Water Use
Restrictions
Only
permanent
water use
ordinance –
no new
restrictions
apply
Water use restrictions become more severe with each stage and
enforcement is enacted more strongly with each stage. With each stage,
efforts made to ensure tree canopy is protected as much as possible.
Recycled
Water Use
Business as
usual use
Water use restrictions require use of recycled water for specific
purposes, advertise availability of recycled water for trucked delivery,
use recycled water for City facilities and street trees as much as
possible.
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7. Permanent Water Use Ordinance
Prohibition on irrigation of turf or ornamental landscape between 9:00 a.m. and 6:00 p.m:
This update revises the existing prohibition on the use of potable water for turf or ornamental
landscapes between 10:00 a.m. and 6:00 p.m to be between 9:00 a.m. and 6:00 p.m. This is for
consistency with Santa Clara Valley Water District. The ordinance amendment is stated below:
The irrigation of turf or ornamental landscapes, which serve purely decorative purposes, and are
distinguished from trees, edible gardens or landscapes that provide more than a purely
aesthetic function, with potable water shall not be allowed between 910:00 a.m. and 6:00 p.m.,
except via hand watering with a bucket or a hose with an operating shutoff valve.
Prohibition on the use of potable water for irrigating nonfunctional turf, as required by AB
1572: The proposed updates incorporate the commercial nonfunctional turf (decorative grass)
watering ban established under California Assembly Bill 1572 (2023) to ensure the City remains
consistent with state law. AB 1572 prohibits the use of potable water for irrigating
nonfunctional turf at government and CII properties, including HOA common areas, statewide.
AB 1572 features a phased implementation timeline and requires local governments to adopt
or revise ordinances by January 1, 2027. Staff recommends following the phased timeline
outlined in the state mandate. The ordinance amendment is stated below:
The use of potable water for the irrigation of nonfunctional turf located on commercial,
industrial, and institutional properties, other than a cemetery, and on properties of
homeowners’ associations, common interest developments, and community service
organizations or similar entities is prohibited as of the following dates:
(i) All properties owned by local governments, local or regional public agencies, and
public water systems, beginning January 1, 2027.
(ii) All other institutional properties and all commercial and industrial properties,
beginning January 1, 2028.
(iii) All common areas of properties of homeowners’ associations, common interest
developments, and community service organizations or similar entities, beginning
January 1, 2029.
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Item No. 4 Page 9 of 10
See Attachment D for the Draft Ordinance.
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
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Item No. 4 Page 10 of 10
One Commissioner expressed interest in accelerating the implementation timeline for AB 1572
(Nonfunctional Turf Ban) by fully implementing it in 2027 rather than using a phased approach
and clarifying the meaning of non-functional turf, particularly to make the distinction between
decorative turf and turf that is used for recreation when applying the policy to Homeowner
Associations (HOA)s. Staff explained that the proposal follows the State’s phased
implementation timeline, which allows for more time to communicate with customers and to
reduce confusion.
ENVIRONMENTAL REVIEW
ATTACHMENTS
AUTHOR/TITLE:
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2025
URBAN WATER MANAGEMENT PLAN
AND WATER SHORTAGE CONTINGENCY
PLAN
JUNE 2026
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City of Palo Alto Utilities
2025
Urban Water Management Plan and Water
Shortage Contingency Plan
June 2026
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Table of Contents
List of Tables ....................................................................................................................... vii
List of Figures ...................................................................................................................... viii
List of Acronyms .................................................................................................................. viii
Contact Sheet ...................................................................................................................... 10
Section 1 – Plan Development and Adoption ....................................................................... 11
Lay Description ........................................................................................................................ 11
Plan Structure ......................................................................................................................... 12
Plan Adoption.......................................................................................................................... 13
Public Participation ................................................................................................................. 13
Agency Coordination ............................................................................................................... 15
Internal City Coordination ................................................................................................ 15
Interagency Coordination ................................................................................................. 16
BAWSCA and Its Role ........................................................................................................ 16
Integrated Regional Water Management Plan ................................................................. 17
Palo Alto Regional Water Quality Control Plant Long Range Facilities Plan ..................... 18
Northwest County Recycled Water Strategic Plan ........................................................... 18
Valley Water Countywide Water Reuse Master Plan ....................................................... 18
Urban Water Management Plan ....................................................................................... 18
Section 2 – Service Area ....................................................................................................... 19
Demographics ......................................................................................................................... 20
Climate Characteristics ........................................................................................................... 21
Section 3 – System Supplies ................................................................................................. 21
Historical Background ............................................................................................................. 21
Water Integrated Resource Planning................................................................................ 22
Sustainability and Climate Action Plan ............................................................................. 23
Northwest County Recycled Water Strategic Plan ........................................................... 24
Effluent Transfer Agreement ............................................................................................ 24
One Water Plan ................................................................................................................. 24
Current and Planned Water Supply Sources .................................................................... 26
SFPUC Supply .......................................................................................................................... 26
Description of SFPUC Regional Water System .................................................................. 26
Wholesale Water Contractual Obligations ....................................................................... 31
Future Water Supply Decisions ......................................................................................... 32
Climate Change Impacts on Demand ................................................................................ 32
Alternative Water Supply Analysis .......................................................................................... 33
Transfer or Exchange Opportunities ....................................................................................... 33
Groundwater ........................................................................................................................... 34
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Deep Aquifer Groundwater .............................................................................................. 34
Shallow Aquifer Groundwater .......................................................................................... 38
Water Recycling ...................................................................................................................... 39
Wastewater Collection and Treatment in Palo Alto ......................................................... 39
Palo Alto Recycled Water Production ............................................................................... 41
Recycled Water Current and Potential Use ...................................................................... 41
Current Recycled Water Use ............................................................................................. 42
Potential Recycled Water Use .......................................................................................... 42
Regional Collaboration ...................................................................................................... 44
Encouraging and Optimizing Recycled Water Use............................................................ 46
Desalinated Water .................................................................................................................. 48
Energy Intensity ...................................................................................................................... 48
Section 4 – Water Demand .................................................................................................. 50
Water Usage ........................................................................................................................... 50
Lay Description .................................................................................................................. 50
Regional Water Demand and Conservation Projections .................................................. 51
Historical and Projected Demand ..................................................................................... 51
Water Sales ....................................................................................................................... 52
Share of Total Consumption by Customer Type ............................................................... 54
Sales to Other Agencies .................................................................................................... 54
Additional Water Uses ‐ Recycled Water Use ................................................................... 55
Non‐Revenue Water/Water Loss ...................................................................................... 55
Total Water Use ................................................................................................................ 55
Projected Lower Income Water Use ................................................................................. 55
Water Conservation Bill of 2009 ............................................................................................. 56
Measures, Programs and Policies that Achieved SBx7‐7 Water Targets .......................... 57
Economic Impacts of SBx7‐7 Compliance ......................................................................... 58
Making Conservation a Way of Life ........................................................................................ 58
Section 5 – Demand Management Measures ....................................................................... 59
Water Waste Prevention Ordinance ....................................................................................... 60
Green Building Ordinance and Model Efficient Landscape Ordinance .................................. 60
Metering ................................................................................................................................. 60
Conservation Pricing ............................................................................................................... 61
Public Education and Outreach .............................................................................................. 61
Programs to Assess and Manage Distribution Systems Real Loss .......................................... 62
Water Conservation Program Coordination and Staffing Support ......................................... 62
Water Conservation Programs ......................................................................................... 62
Do‐it‐Yourself Water Wise Indoor Survey Kits .................................................................. 63
Water Wise Outdoor Survey ............................................................................................. 63
Landscape Rebate Program .............................................................................................. 63
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Home Water Report and Customer Portal Program ........................................................ 63
Water Efficient Technology Rebate Program ................................................................... 63
Submeter Rebate Program ............................................................................................... 64
Water Conservation Coordinator ..................................................................................... 64
Water Waste Coordinator................................................................................................. 64
Large Landscape Survey and Water Budget Program ...................................................... 64
BAWSCA Conservation Programs ........................................................................................... 64
Section 6 – Water Supply Reliability ..................................................................................... 65
Constraints of Water Sources Considerations ........................................................................ 66
Water Supply – All Year Types .......................................................................................... 66
Reliability of the RWS ........................................................................................................ 68
Bay‐Delta Plan Amendment Updates ............................................................................... 69
Tier One Drought Allocations............................................................................................ 71
Water Supply Reliability Assessment Year‐Type Characterization (for RWS) .................... 73
SFPUC Supply Modeled RWS Dry Year Supply Availability ............................................... 73
Regional Plans to Ensure a Reliable Water Supply ................................................................. 73
Strategy 2050 Future Water Supply Projects and Programs ............................................ 74
WSIP Dry Year Water Supply Projects .............................................................................. 74
Alternative Water Supply Program ................................................................................... 76
Drought Risk Assessment ........................................................................................................ 77
Data, Methods, and Basis for Water Shortage Condition ................................................ 77
Individual Water Source Reliability ................................................................................... 78
Climate Change ....................................................................................................................... 78
Local Plans to Ensure a Reliable Water Supply ....................................................................... 80
Section 7 – Water Shortage Contingency Plan ...................................................................... 81
Background ............................................................................................................................. 82
Preparation for Catastrophic Supply Interruption ................................................................... 83
Emergency Preparedness Plans ........................................................................................ 83
Emergency Drinking Water Planning ................................................................................ 84
Power Outage Preparedness and Response ..................................................................... 85
Seismic Risk Assessment and Mitigation Plan .................................................................. 85
Local Distribution System Reliability ................................................................................. 87
Emergency Operations Plan .............................................................................................. 87
Water Supply and Demand Assessment ................................................................................. 89
Decision‐Making Process to Determine Water Supply Availability .................................. 89
Data and Methodologies .................................................................................................. 89
Notification and Approval of Response Actions ............................................................... 90
SFPUC Annual Water Supply and Demand Assessment Procedures ...................................... 91
Demand Assessment ......................................................................................................... 91
Supply Assessment ............................................................................................................ 91
Infrastructure Considerations ........................................................................................... 94
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System Modeling .............................................................................................................. 94
Decision‐Making Process .................................................................................................. 95
Water Shortage Contingency Plan .......................................................................................... 96
Palo Alto’s Experience with Drought Management ......................................................... 97
Water Shortage Mitigation Options ....................................................................................... 97
Supply Side Options .......................................................................................................... 98
Demand Side Options ....................................................................................................... 98
Water Shortage Contingency Plan Stages of Action ............................................................. 104
STAGE I – Minimum Water Supply Shortage: Up to 10% target water savings ............. 104
STAGE II – Moderate Water Supply Shortage: 10% to 20% target water savings .......... 105
STAGE III – Severe Water Supply Shortage: 20% to 30% target water savings .............. 106
STAGE IV – Severe to Critical Water Supply Shortage: 30% to 40% target water savings
......................................................................................................................................... 107
STAGE V – Critical Water Supply Shortage: 40% to 50% target water savings .............. 107
STAGE VI – Water Emergency: Greater than 50% target water savings ........................ 108
Alternative Water Supplies During a Water Shortage .......................................................... 110
Revenue and Expenditure Impacts and Measures to Overcome Impacts ........................... 111
Revenue Reductions, Expense Increases, and Cost of Compliance ................................ 111
Mitigation Actions ........................................................................................................... 112
Monitoring Customer Compliance and Reporting ................................................................ 112
Water Shortage Contingency Legal Authority ...................................................................... 113
Reevaluation and Improvement of Procedures.................................................................... 114
Section 8 – Supply and Demand Comparison Provisions ..................................................... 114
Supply and Demand Comparison ......................................................................................... 115
Normal Year Supply and Demand ................................................................................... 115
Dry Year Scenarios .......................................................................................................... 116
APPENDIX A ‐ Resolutions Adopting Urban Water Management Plan and Water Shortage
Contingency Plan ............................................................................................................... 122
APPENDIX B ‐ Public Participation Notices.......................................................................... 127
APPENDIX C – DWR Standardized Tables ............................................................................ 129
APPENDIX D ‐ Water Shortage Contingency Plan Draft Ordinance ...................................... 130
APPENDIX E ‐ Water Shortage Contingency Plan Evaluation Criteria ................................... 131
APPENDIX F ‐ Water Shortage Contingency Plan Use Restrictions ....................................... 133
APPENDIX G ‐ Water Supply And Demand Comparisons, Without Bay Delta Plan Amendment
......................................................................................................................................... 137
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List of Tables
Table 1: Calendar for Adoption ..................................................................................................... 13
Table 2: Coordination with Appropriate Agencies ....................................................................... 19
Table 3: Population – Current and Projected ............................................................................... 20
Table 4: Climate ............................................................................................................................ 21
Table 5: Current and Planned Water Supply Sources (AFY) ......................................................... 26
Table 6: Regional Water System Storage Capacity ....................................................................... 30
Table 7: Average Annual Maximum Temperature Increases in 2050 (Relative to 2025) Derived
from CalAdapt CMIP5 RCP 4.5 and RCP 8.5 .................................................................................. 33
Table 8: Wastewater Treatment ................................................................................................... 41
Table 9: Wastewater Collected and Treated and Method of Disposal – AFY ............................... 41
Table 10: Historical and Projected Water Sales – by Customer Type (Fiscal Years) ..................... 53
Table 11: Historical and Projected Water Accounts – by Customer Type (Fiscal Years) .............. 53
Table 12: Historical and Projected Water Sales per Account (AF) (Fiscal Years) .......................... 53
Table 13: Recycled Water Use (AFY) ............................................................................................. 55
Table 14: Non‐Revenue Water (AFY) ............................................................................................ 55
Table 15: Total Water Use (AFY) ................................................................................................... 55
Table 16: Baseline Daily Per Capita Water Use for 10‐year period (1995 through 2004) ............ 57
Table 17: 2015 UWMP SBx7‐7 Performance Metrics (gallons per capita per day) ...................... 57
Table 18: Interties with other Agencies ....................................................................................... 87
Table 19: Regional Water System Supply Availability in Normal Years (mgd) ............................. 93
Table 20: Regional Water System Supply Utilized in Normal Years (mgd) ................................... 93
Table 21: WSCP Summary ........................................................................................................... 110
Table 22: Projected Total Regional Water System Supply Utilized and Portion of Regional Water
System Supply Utilized by Wholesale Customers in Normal Years (AFY) ................................... 115
Table 23: City of Palo Alto Supply/Demand Balance (AFY) ......................................................... 116
Table 24: SFPUC Water System Improvement Program Project Assumptions for RWS Supply
Modeling ..................................................................................................................................... 116
Table 25: Projected Multiple Dry Years Wholesale Supply from RWS, With Bay Delta Plan
Amendment (AFY) ....................................................................................................................... 117
Table 26: Single Dry Year Potable Water Supply Shortfall for Palo Alto (AFY) ........................... 117
Table 27: Projected Potable Water Use Reductions in Multiple Dry Year Scenario for Palo Alto
..................................................................................................................................................... 117
Table 28: Wholesale Supply and Demand Comparison for Projected Normal and Dry Year
Scenarios (AFY) ............................................................................................................................ 118
Table 29: Palo Alto Supply and Demand Comparison for Projected Normal and Dry Year
Scenarios (AFY) ............................................................................................................................ 119
Table 30: Projected RWS Supply for 5‐Year Drought Assessment (AFY) .................................... 119
Table 31: Projected RWS Supply Available to Palo Alto for 5‐year Drought Assessment (AFY) 119
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List of Figures
Figure 1: Regional Water System and Main Facilities................................................................... 28
Figure 2: Potential Groundwater Use Area .................................................................................. 36
Figure 3: City of Palo Alto Water Supply Purchases – Actual and Forecast ................................. 52
Figure 4: FY 2020 Water Sales by Customer Class ........................................................................ 54
Figure 5: FY 2025 Water Sales by Customer Class ........................................................................ 54
Figure 6: Water Supply and Demand Assessment Process.......................................................... 96
List of Acronyms
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City of Palo Alto Utilities
2025 Urban Water Management Plan and
Water Shortage Contingency Plan
Contact Sheet
Date plan submitted to the Department of Water Resources: June XX, 2026
Name of persons preparing this plan:
Adriana Artola, Senior Resource Planner
Linda Grand, Sustainability Programs Administrator
Phone:
(650) 329‐2680; (650) 838‐2702
Fax: (650) 326‐1507
E‐mail address: adriana.artola@paloalto.gov, linda.grand@paloalto.gov
Utility services provided by the City include: electric, natural gas, commercial fiber, refuse,
recycled water, storm drain, wastewater collection, treatment and disposal.
Is This Agency a Bureau of Reclamation Contractor? No Is This Agency a State Water Project
Contractor? No
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Section 1 – Plan Development and Adoption
Lay Description
Law (see note)
California Water Code section 10620 1 (a)
Every urban water supplier shall prepare and adopt an urban water management plan in the manner set
forth in Article 3 (commencing with Section 10640).
10630.5.
Each plan shall include a simple lay description of how much water the agency has on a reliable
basis, how much it needs for the foreseeable future, what the agency’s strategy is for meeting its
water needs, the challenges facing the agency, and any other information necessary to provide a
general understanding of the agency’s plan.
The City of Palo Alto (City) is located in northern Santa Clara County approximately 35 miles
south of the City of San Francisco. In addition to serving about 20,000 residential and
commercial water customers, the City operates electric, gas, wastewater, and fiber utilities.
The City receives 100% of its potable water from the San Francisco Public Utilities Commission
(SFPUC) through the Regional Water System (RWS). Palo Alto’s Individual Supply Guarantee
(ISG) is 16.575 million gallons per day (MGD), or about 18,579 acre‐feet per year (AFY),
representing the City’s perpetual dedicated share of the SFPUC’s 184 mgd Supply Assurance.
The City also uses some recycled water produced at the Palo Alto‐operated Regional Water
Quality Control Plant (RWQCP) for irrigation of the municipal golf course, a park, and some
other minor applications. A system of local groundwater wells and storage provide emergency
water supply service.
Since the City relies on the SFPUC RWS for its potable water supplies, the City’s water supply
reliability mirrors that of the RWS. The RWS is anticipated to have sufficient supplies to meet
the projected water demands in normal years. During single dry years and multiple dry years,
the amount of water available to San Francisco’s Retail Customers (the residential and
commercial customers in the City of San Francisco) and Wholesale Customers (the 26 agencies,
including Palo Alto, that purchase water from the SFPUC) will be impacted by the outcome of
the Water Quality Control Plan for the San Francisco Bay/Sacramento‐San Joaquin Delta Estuary
(Bay Delta Plan Amendment or Bay Delta Plan). This 2025 UWMP assumes the Bay Delta Plan
and associated unimpaired flow requirements for the Tuolumne River will be implemented as
adopted by the state.
1 Unless noted, all statutory references herein are to the California Water Code. Relevant sections and/or subparts
or portions of the California Water Code are set forth at the beginning of each Section to provide the statutory
context for the discussion.
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Given the City’s forecasted water demand and projections of water supply availability provided
by the SFPUC, the City anticipates the need to implement water use reductions of up to 48% in
consecutive dry year scenarios post implementation of the Bay Delta Plan Amendment. During
the drought that occurred in 2012‐2016 (2015 drought), the City was able to reduce water use
by 31% by restricting landscape irrigation to two times per week as well as a number of other
measures. This was followed by the drought that occurred in 2020‐2023 (2021 drought) during
which the City reduced water use by 15% in response to voluntary water reductions measures.
The City’s proposed Water Shortage Contingency Plan (WSCP) includes actions to achieve water
use reductions above 40% and above 50%, but the City does not have actual experience in
implementing such drastic measures. With each progressive stage, enforcement, rate
strategies, and water use restrictions will be increased while putting in place mitigation
measures to maintain the health of the City’s tree canopy.
In August 2018, City Council voted to support the Bay Delta Plan to have 40 percent of natural
water in the Central Valley to enter the Delta from February to June and associated Southern
Delta salinity objectives; and sent a letter expressing this policy position to Bay Area Water
Supply and Conservation Agency (BAWSCA), California State Water Resources Control Board,
San Francisco Public Utilities Commission (SFPUC), and other stakeholders Staff believed should
receive the letter2.
Short‐term emergency water needs can be met with the City’s groundwater wells and storage
system. The system was designed to provide adequate fire protection following a disaster such
as a major earthquake.
The City partners with the Santa Clara Valley Water District (Valley Water) to offer a wide‐range
of water conservation programs to our residential and commercial customers. In 2024, the City
completed its One Water Plan 3 which evaluates water supply alternatives for the City that, if
implemented, may mitigate the impact of future water supply uncertainties such as severe
multi‐year drought, changes in climate, water demand, and regulations. The City is also active in
several regional efforts to address long‐term water supply issues.
Plan Structure
The City has not experienced significant changes in the water supply distribution system and
reliability since the preparation of the 2020 Urban Water Management Plan (2020 UWMP). For
the 2025 UWMP report, the City has updated the 2020 UWMP and addressed any changes to
the UWMP Act since 2020 as outlined in Appendix B of the Department of Water Resources
(DWR) UWMP Guidebook.
2 See Council meeting minutes: https://www.paloalto.gov/files/assets/public/v/1/agendas‐minutes‐
reports/agendas‐minutes/city‐council‐agendas‐minutes/00‐archive/2018/08‐20‐2018‐final‐ccm‐minutes.pdf
3 One Water Plan https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=c42ee7f3‐8caf‐4c48‐
99e3‐57bb8e437775
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Plan Adoption
The City began preparing this update of its UWMP in late 2025. The updated plan will be
considered by City Council before June 30, 2026 and submitted to the California Department of
Water Resources within 30 days of Council adoption. This plan includes all information
necessary to meet the requirements of California Water Code Division 6, Part 2.6 (Urban Water
Management Planning) as well as requirements of the California Water Code Division 6, Part
2.55 (Water Conservation Bill of 2009).
Public Participation
The City actively encourages community participation in its urban water management planning
efforts. The City held public hearings before the Utilities Advisory Commission (UAC) and City
Council prior to adoption. Table 1 shows the key dates. An UWMP webpage
(https://www.paloalto.gov/Departments/Utilities/Water/Water‐Resources/Urban‐Water‐
Management‐Plan) was created to educate the public about the UWMP process, provide
outreach for public meetings and opportunities to participate, as well as to make available
background materials on the City’s urban water management planning activities.
Table 1: Calendar for Adoption
March 31, 2026
and WSCP
June 1, 2026 Hearing and WSCP
Resolution
Resolution
Appendix B contains samples of the public participation notices the City sent in compliance with
Water Code 10621(b), 10620(d)(2), and 10642. A sample notice of the City Council meeting will
be added to the Final Draft 2025 UWMP that will be presented to Council for approval.
The City’s Utilities Advisory Commission (UAC) provides advice to the City Council on:
• The acquisition and development of electric, gas and water resources;
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• Joint action projects with other public or private entities which involve electric, gas or
water resources; wastewater collection and fiber optic issues;
• Environmental implications of electric, gas or water utility projects; and
• Resource conservation and demand management.
The UAC meets monthly and reviews the activities of the various utility services. One of the
primary tasks of the UAC is to assist with the review and development of long‐term plans for
the City’s utilities. The UAC meetings are open to the public and agendas are posted for public
review prior to each meeting. The schedule for approval of the 2025 UWMP provides the
opportunity for the UAC to review and comment on the Draft UWMP prior to submittal to the
City Council for final approval.
Since adoption of the 2020 UWMP, the UAC and Council have been active in the review of
water supply and water management activities.
The One Water Plan (OWP) was discussed at the following meetings:
• July 2021: UAC reviewed draft objectives, scope, and community engagement plan
• November 2021: CPAU in collaboration with the Public Works issued request for
comment
• June 2022: Council approved contract with Carollo Engineers
• September 2022: Community Workshop regarding Community Needs and Priorities
• December 2022: Community Workshop Exploring Water Supply and Water Conservation
Options
• February 2023: UAC update regarding OWP development
• June 2024: UAC update regarding background, goals, approach, overview and initial
results
• November 2024: SFPUC and BAWSCA overview of drought planning and Alternative
Water Supply Program to the UAC
• January 2025: Final One Water Plan to the UAC, UAC did not take action
• September 2025: Final One Water Plan to the Climate Action & Sustainability Ad Hoc
Committee (CASC), along with letter from UAC regarding OWP
• October 2025: Final One Water Plan received by City Council, along with letter from UAC
regarding OWP
The Water Supply Agreement (WSA) and Tier 2 Amendments were discussed at the following
meetings:
• June 2025: UAC did not provide a recommendation
• August 2025: Council approved the WSA and Tier 2 amendments
Water is the subject of one of seven chapters in the City’s Sustainability and Climate Action Plan
(S/CAP) discussed publicly at the following meetings:
• May 2020: Council discussion of Goals and Key Actions for 2020 S/CAP
• October 2022: Council approved the updated S/CAP Goals and Key Actions
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• June 2023: Council adopted the 2022 Sustainability and Climate Action Plan and
accepted the 2023‐2025 S/CAP Work Plan
• March 2026: Council approved the 2026‐2027 S/CAP Work Plan
Local Advanced Water Purification System was discussed at the following meetings:
• November 2019: Council approved Addendum to Environmental Impact Report
• March 2021: Council approved the design contract
• October 2023: Council approved a financing plan for the project
• May 2024: Council approved an application for a Site and Design Review and Design
Enhancement Exception to allow construction of the project
Agency Coordination
Law
10620 (a) Every urban water supplier shall prepare and adopt an urban water management plan in
the manner set forth in Article 3 (commencing with Section 10640).
10620(d) (1) An urban water supplier may satisfy the requirement of this part by participation in
area wide regional, watershed, or basinwide urban water management planning where those
plans will reduce preparation costs and contribute to the achievement of conservation, efficient
water use, and improved local drought resilience.
10620(d)(3) Each urban water supplier shall coordinate the preparation of its plan with other
appropriate agencies in the area, including other water suppliers that share a common source,
water management agencies, and relevant public agencies, to the extent practicable.
10642 (excerpt)
Each urban water supplier shall encourage the active involvement of diverse social, cultural, and
economic elements of the population within the service area prior to and during the preparation
of both the plan and the water shortage contingency plan.
Internal City Coordination
Many members of City staff collaborated in the development of this plan, including
representatives from all divisions of the City of Palo Alto Utilities Department (CPAU) and other
City departments including Planning and Development Services, the City Manager’s Office, the
City Attorney’s Office, the City Clerk’s office, and Public Works. The UWMP is coordinated with
other City planning and policy level documents to ensure the water policy direction in the
UWMP informs future decisions within the City of Palo Alto, including the 2030 Comprehensive
Plan, the 2023‐2031 Housing Element, and the Urban Forest Master Plan.
Since completion of the 2020 UWMP, CPAU has completed the One Water Plan, a 20‐year,
adaptable roadmap of prioritized water supply alternatives, aggregated into water supply
portfolios, that establishes a vision and achievable path toward meeting the City’s water supply
and water conservation goals. The completion of the plan required the cooperation of all
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divisions within the CPAU and several other departments within the City. Data and information
from the One Water Plan was used in the preparation of the 2025 UWMP.
Interagency Coordination
The City is an active member of the California water community and coordinated with a
number of agencies in preparation of its 2025 UWMP. The City is particularly active in the
following organizations:
• The City is an active member of the Bay Area Water Supply and Conservation Agency
(BAWSCA). The BAWSCA members, including the City, receive water from the City and
County of San Francisco through a contract that is administered by the SFPUC.
• The City is represented on the Valley Water Commission, the Joint Recycled Water
Committee, the Valley Water Retailers Group, the Valley Water Recycled Water
Subcommittee, the Valley Water Communication Subcommittee, the Valley Water
Conservation Subcommittee, and the Joint Water Supply & Groundwater
Subcommittee.
• The City is a member of the California Water Efficiency Partnership (CalWEP), the
WateReuse Association, Alliance for Water Efficiency, the Bay Area Clean Water
Agencies (BACWA), and the Western Recycled Water Coalition. It is also a partner in the
Environmental Protection Agency’s (EPA) WaterSense program.
The City continually coordinates water‐planning activities that support and inform the City’s
creation of this UWMP with neighboring communities and water agencies.
BAWSCA and Its Role
BAWSCA provides regional water reliability planning and conservation programming for the
benefit of its 26 member agencies (collectively the “Wholesale Customers” or “BAWSCA
Member Agencies”) that purchase wholesale water supplies from the SFPUC. Collectively, the
Wholesale Customers deliver water to over 1.8 million residents and nearly 40,000 commercial,
industrial and institutional accounts in Alameda, San Mateo and Santa Clara Counties.
BAWSCA also represents the collective interests of the Wholesale Customers on all significant
technical, financial, and policy matters related to the operation and improvement of the
SFPUC’s RWS.
BAWSCA’s role in the development of the 2025 UWMP updates is to work with its Member
Agencies and the SFPUC to seek consistency among UWMP documents.
As a member of BAWSCA, the City is formally represented on the BAWSCA Board of Directors
on matters involving decision‐making, policy setting and issues of interest to the BAWSCA
members. Staff also represents the City with the other BAWSCA members on other issues that
may arise from time to time.
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BAWSCA Long‐Term Reliable Water Supply Strategy 2050
The City is supporting BAWSCA in the development of its Long‐Term Reliable Water Supply
Strategy 2050 (Strategy 2050), a regional assessment of Member Agencies’ water supply needs.
Strategy 2050 will identify the water supply and demand management needs and opportunities
for the BAWSCA region and establish a framework to collectively support water reliability and
resilience. The main objectives of Strategy 2050 include:
• Providing a comprehensive picture of the region's supply and demand management
needs and options;
• Establishing a framework for collectively maintaining and improving regional water
supply reliability and resilience;
• Elevating awareness of and supporting the region’s interests in new and emerging
regulations that impact water supply and demand management;
• Expanding regional dialogue and collaboration to collectively address common needs;
• Closing the gap on funding needed for water supply resilience and reliability; and
• Supporting availability of affordable water supplies and demand management strategies
to all customers.
Strategy 2050 is actively evaluating opportunities to enhance water supply reliability in the
BAWSCA region, including projects involving physical infrastructure and actions involving non‐
infrastructure interventions, such as policies, programs, and/or contractual agreements. A total
of 70 local and regional projects and actions (P&As) will be considered, including stormwater
capture projects, technical assistance programs for onsite reuse, groundwater banking
partnerships, new and replacement well projects, and interties development and optimization,
among others. Strategy 2050 will evaluate the water reliability under the range of potential
future conditions and make recommendations on priorities and next steps for implementation.
Strategy 2050 plan is anticipated to be completed by 2027. From 2027 onward, the Strategy
2050 effort is anticipated to involve implementing the actions identified in the plan, tracking
and reporting on the progress, and incorporating the findings from the implementation
activities into BAWSCA’s following fiscal year Work Plan.
Integrated Regional Water Management Plan
The Association of Bay Area Governments (ABAG) convened a broad‐based group of
stakeholders to develop an Integrated Regional Water Management Plan (IRWMP) for the Bay
Area. The Bay Area IRWMP facilitates regional cooperation on issues of water supply, quality
and reliability, water recycling and conservation, storm water and flood water management,
wetlands and habitat restoration and creation, recreation and access.
The City was involved in the development of the Bay Area IRWMP on the water supply and
reliability areas through BAWSCA’s representation in the Bay Area Water Agencies Coalition
(BAWAC). In addition, the City also coordinates water recycling and wastewater for the IRWMP
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implementation through the City’s membership in the Bay Area Clean Water Agencies
(BACWA). The City adopted the 2019 Bay Area IRWMP in May 2019 4.
Palo Alto Regional Water Quality Control Plant Long Range Facilities Plan
The RWQCP has been in operation since 1934 and now serves the six communities of Palo Alto,
East Palo Alto, Mountain View, Stanford, Los Altos and Los Altos Hills. Aging equipment, new
regulatory requirements, and the movement to full sustainability will require rehabilitation,
replacement and new processes. The Long‐Range Facilities Plan (LRFP) was completed in
October 2012. Major recommendations in the plan were modeling influent sewer flows,
continuing source control and flow reduction efforts, rehabilitating and replacing critical
infrastructure, and preparing for regulatory action. In addition, the plan recommended the
RWQCP be positioned for a possible increase in recycled water demand by reserving space on
site for reverse osmosis facilities and being prepared to implement additional storage and
pumping capabilities.
In 2023, the City identified the need to perform an update to the 2012 LRFP (LRFP‐Update). The
LRFP‐Update began in August 2024 and is expected to be completed in 2027. It will incorporate
an evaluation of regulatory and emerging contaminant issues as they relate to capital
infrastructure, update to the Biosolids Facilities Plan, condition and capacity assessment,
development of re‐prioritized capital improvement program needs over the next 50 years, and
cost of service analysis.
Northwest County Recycled Water Strategic Plan
The Northwest County Recycled Water Strategic Plan represented a collaboration between the
City of Palo Alto and Valley Water that seeks to identify the most appropriate ways to expand
the City of Palo Alto’s Recycled Water Program. The plan evaluated the potential expansion of
the recycled water pipeline to the Stanford Research Park area as well as potable water reuse.
The final plan was accepted by City Council in March 20205.
Valley Water Countywide Water Reuse Master Plan
The collaboration between Valley Water and the Partner Agencies, including Palo Alto, builds
on existing partnerships, plans, and infrastructure; explores a wide range of reuse opportunities
that support Valley Water’s goals and yields multiple benefits for the collective region.
Urban Water Management Plan
The City coordinated the 2025 update of the UWMP with the following agencies:
4 See Staff Report 10243: https://www.paloalto.gov/files/assets/public/v/1/agendas‐minutes‐reports/reports/city‐
manager‐reports‐cmrs/year‐archive/2019/id‐10243‐mini‐packet‐050819.pdf
5 See Staff Report 10319: https://www.paloalto.gov/files/assets/public/v/1/agendas‐minutes‐reports/reports/city‐
manager‐reports‐cmrs/year‐archive/2020/id‐10913‐mini‐packet‐03022020.pdf?t=59282.96
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Table 2: Coordination with Appropriate Agencies
AGENCIES in Plan
development
of Plan
preparation
on the draft public
meetings
for
assistance
copy of
draft
of public
hearing
/ No
information
Alto
Mountain View
Park
District
University
BAWSCA
agencies
Clara
Section 2 – Service Area
Law
10631
(a) Describe the service area of the supplier, including current and projected population, climate,
and other social, economic, and demographic factors affecting the supplier’s water
management planning. The projected population estimates shall be based upon data from the
state, regional, or local service agency population projections within the service area of the
urban water supplier and shall be in five‐year increments to 20 years or as far as data is
available. The description shall include the current and projected land uses within the existing
or anticipated service area affecting the supplier’s water management planning. Urban water
suppliers shall coordinate with local or regional land use authorities to determine the most
appropriate land use information, including, where appropriate, land use information
obtained from local or regional land use authorities, as developed pursuant to Article 5
(commencing with Section 65300) of Chapter 3 of Division 1 of Title 7 of the Government Code.
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Demographics
Palo Alto is located in northern Santa Clara County approximately 35 miles south of the City of
San Francisco. The City’s population in 2025 was approximately 67,0006. The City is roughly 26
square miles in area and is a part of the San Francisco Bay metropolitan area. The City is one of
the area's most desirable residential communities with approximately 29,000 7 housing units.
The City’s desirability is partly due to the excellent public schools, comprehensive municipal
services, shopping, restaurants and the community's aesthetics.
Palo Alto, known as the “Birthplace of Silicon Valley,” is located directly adjacent to Stanford
University, which attracts major corporations from around the world. The City's 630‐acre
Stanford Research Park includes among its tenants such prestigious and innovative high‐tech
leaders as Hewlett‐Packard, Varian, Tesla Motors, and VMware. The City has 36 parks and
preserves (comprising 175 acres of urban parks and 4,018 acres of open space), tennis courts
(50), community centers (4), theaters (3), swimming pools (1), nature centers (3), athletic
centers (4), a golf course, an art center, and a junior museum and zoo8.
The City’s historical and current service area population is sourced from the US Census Bureau
American Community Survey. In fiscal year 2020, the City’s estimated service area population
was 67,019. It is estimated that the City’s service area population was 67,231 in fiscal year
2025, an increase of 0.3%.
Table 3 shows current and projected population from 2025 to 2050. Population projections for
2030–2050 are based on the 2025 BAWSCA Regional Water Demand and Conservation
Projections Report (Demand Study; described in further detail in Section 4 – Water Demand),
which incorporated inputs from the City’s 2023–2031 Housing Element as directed by City staff.
Specifically, the projections use population data from the Association of Bay Area Governments
(ABAG) Plan Bay Area 2040 projections, together with the assumption that the City will meet
its Regional Housing Needs Allocation (RHNA) target of 6,086 housing units by 2031. Under this
assumption, all population growth occurs through 2031 as those units are added, and
population levels remain flat after 2031. By 2050, the total population within the City’s service
area is expected to be 91,532, which represents a 1.4% annual growth rate compared to the
2025 population. For the 2020 UWMP, the City relied on its 2030 Comprehensive Plan through
2030 and extrapolated using the same growth rates through 2045.
Table 3: Population – Current and Projected
6 City of Palo Alto Official Data Set
7 City of Palo Alto 2023‐2031 Housing Element
8 City of Palo Alto 2024‐2025 Annual Comprehensive Financial Report (ACFR)
2025 2030 2035 2040 2045 2050
Service Area Population 67,231 88,509 91,532 91,532 91,532 91,532
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Climate Characteristics
The City enjoys a mild climate surrounded by the San Francisco Bay on the east, and coastal
mountains on the west. The monthly average temperature, rainfall and ETO (Reference
Evapotranspiration) for the area are presented in Table 4 below.
Table 4: Climate
Climate
Standard Monthly
9
Average
Rainfall
(inches)10
Average Max
Temperature
(degrees F)11
Temperature
(degrees F)
Section 3 – System Supplies
Law
10631 (b) (excerpt)
Identify and quantify, to the extent practicable, the existing and planned sources of water available
to the supplier over the same five year increments described in subdivision (a)…..
Historical Background
The water utility was established on May 9, 1896, two years after the City was incorporated.
Local water companies were bought out at that time with a $40,000 bond approved by the
9 Average ETO data for closest active station (Union city) reported by CIMIS website
http://www.cimis.water.ca.gov/
10 Average rainfall data for Palo Alto reported by NOAA website http://www.wrcc.dri.edu/
11 Average temperature data for Palo Alto reported by NOAA website http://www.wrcc.dri.edu/
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voters of the 750‐person community. These private water companies operated one or more
shallow wells to serve the nearby residents. The City grew, and the well system expanded until
nine wells were in operation in 1932.
In December 1937, the City signed a 20‐year contract with the City and County of San Francisco,
administered by the San Francisco Water Department (SFWD), for water deliveries from the
newly constructed pipeline bringing Hetch Hetchy water from Yosemite to the Bay Area. Water
deliveries from San Francisco commenced in 1938, and well production declined to less than
half of the total citywide water demand.
A 1950 engineering report noted, "the capricious alternation of well waters and the SFWD
water . . . has made satisfactory service to the average consumer practically impossible."
However, groundwater production increased in the 1950s, leading to lower groundwater tables
and water quality concerns. In 1962, a survey of water softening costs to City customers
determined that the City should purchase 100% of its water supply needs from the SFWD. A 20‐
year contract was signed with San Francisco, and the City’s wells were placed in a standby
condition. The SFWD later became known as the SFPUC. Since 1962 (except for some very short
periods) the City’s entire supply of potable water has come from the SFPUC.
BAWSCA is comprised of SFPUC’s 26 Wholesale Customers. The City largely works through
BAWSCA to manage its SFPUC contract and to interact with the SFPUC.
Water Integrated Resource Planning
The City prepared its first Water Integrated Resources Plan (WIRP) in 1993 when the City was
faced with a decision to participate in a regional recycled water expansion program. The 1993
WIRP assessed the costs and benefits of the recycled water project compared to other supply
alternatives and ultimately concluded that recycled water was not cost effective relative to
existing supply. In 2003, the City updated the WIRP. The 2003 WIRP indicated that supplies
from the SFPUC were adequate during normal years, but additional supplies were needed in dry
years to avoid shortages.
In 2017 the WIRP was updated again. Unprecedented drought conditions and regulatory action
by the State Water Resource Control Board (SWRCB), including the first‐ever mandatory
potable water use reductions, in addition to Palo Alto’s S/CAP, renewed the focus on water
supply sustainability. The 2003 WIRP Guidelines served as a roadmap for evaluating the
following potable water supply alternatives: 1) water from the SFPUC; 2) groundwater (with or
without groundwater recharge); 3) treated water from the Valley Water; and 4) Demand Side
Management (DSM). Recycled water was being evaluated outside of the WIRP in a recycled
water strategic planning process.
The evaluation concluded that DSM was the best resource, but could not significantly displace
potable water supplies. While SFPUC water was found to be the most expensive, it has higher
water quality than groundwater or treated water from the Valley Water. In addition,
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groundwater and Valley Water treated water supplies may increase in cost and aren’t likely to
offer additional protection in droughts.
Council adopted the following 2017 WIRP Guidelines in March 2017 12:
1. Pursue all cost‐effective water efficiency and conservation;
2. Continue to investigate the technical feasibility and financial impact of increasing the
use of non‐traditional, non‐potable sources such as black water, storm water, and water
incidentally produced in an excavating project;
3. Proceed with the Recycled Water Strategic Plan to determine how to reduce the
demand for imported water; and
4. Survey potentially impacted customers about their preference for SFPUC water versus
blended water.
Sustainability and Climate Action Plan
In November 2016 Council adopted the Sustainability and Climate Action Plan (S/CAP)
Framework 13 including four water‐specific goals, all of which have implications for water reuse:
1. Utilize the right water supply for the right use;
2. Ensure sufficient water quantity and quality;
3. Protect the Bay, other surface waters, and groundwater; and
4. Lead in sustainable water management.
In December 2017, Council adopted the S/CAP Sustainability Implementation Plan (SIP)14. The
SIP identified the following Key Actions:
1. Develop programs and ordinances to maximize water efficiency;
2. Develop programs and ordinances to facilitate the use of non‐traditional, non‐potable
water sources (e.g. graywater, storm water, black water, etc.);
3. Develop Recycled Water Strategic Plan and explore the most effective uses of recycled
water, both inside and outside Palo Alto;
4. Develop a Green Storm Water Infrastructure Plan to better capture and infiltrate storm
water back into the hydrologic cycle; and
5. Reduce salinity of Palo Alto’s recycled water to increase desirability of use.
In June 2023, Council adopted the 2022 Sustainability and Climate Action Plan (S/CAP)15. The
plan includes two water‐specific goals:
1. Reduce Palo Alto’s potable water consumption by 30 percent compared to a 1990
baseline.
12 See Staff Report #7634:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=76822&dbid=0&repo=PaloAlto
13 See Staff Report #7304:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=79931&dbid=0&repo=PaloAlto
14 See Staff Report #8487:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=78307&dbid=0&repo=PaloAlto
15 2022 Sustainability And Climate Action Plan:
https://www.paloalto.gov/files/assets/public/v/1/sustainability/reports/2022‐scap‐report_final.pdf
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2. Develop a water supply portfolio which is resilient to droughts, changes in climate, and
water demand and regulations, and which supports the City’s urban canopy.
These goals are supported by the following four key actions:
1. Maximize cost‐effective water conservation and efficiency through incentives,
outreach/education, and other programs.
2. Design and build a salt removal facility for the Regional Water Quality Control Plant to
improve the quality of recycled water.
3. Develop and implement projects that result from a "One Water" Portfolio of alternative
water supply and water conservation options (“Options”) for Palo Alto, including but not
limited to stormwater, recycled water, on‐site reuse, conservation, groundwater.
4. Develop a tool for dynamic water planning in the future.
Northwest County Recycled Water Strategic Plan
Palo Alto Utilities and Public Works staff collaborated with Valley Water to evaluate the most
effective water reuse options within Palo Alto as well as within the RWQCP service area. The
resulting Northwest County Recycled Water Strategic Plan Report and Appendices16 contains a
summary and ranking of the water reuse alternatives or “Concept Options” based on cost and
non‐cost criteria.
Effluent Transfer Agreement
A Council‐approved agreement with Valley Water and the City of Mountain View 17 gives Valley
Water an option to acquire about half of the treated wastewater produced by the RWQCP,
which would render some local water reuse options infeasible. The Agreement Between and
Among Palo Alto, Mountain View, and the Santa Clara Valley Water District to Advance Resilient
Water Reuse Programs in Santa Clara County is referred to as the Partnership Agreement.
Valley Water has paused consideration of building a Regional Plant in Palo Alto. The effluent
transfer option expires in 2033.
One Water Plan
In June 2022, Council approved a contract with Carollo Engineers to develop the One Water
Plan. City staff from the Public Works and Utilities Departments closely collaborated and
worked with the consulting team to develop the plan. The One Water Plan 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. The plan completes a key action in the
Sustainability and Climate Action Plan (S/CAP) Update to develop a plan for implementing a
16 See Staff Report #10913:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=87065&dbid=0&repo=PaloAlto&cr=1
17 See Staff Report #10627:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=80525&dbid=0&repo=PaloAlto
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One Water portfolio, a water supply plan that will analyze the City’s potential water supply
priorities and conservation opportunities.
The One Water Plan 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. The plan 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.
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 concerns
about the portfolio scoring methodology, the worst‐case water supply shortage scenario which
was provided by the SFPUC, and that the plan did not take more of a regional approach.
Members of the UAC outlined these concerns in a letter 18 addressed to the City Council. Staff
presented these concerns and the letter, along with the OWP, to the CASC on September 19,
2025, after which these items were presented to the City Council on October 20, 2025 as an
informational report.
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.
18 UAC Letter to Council: https://cityofpaloalto.primegov.com/viewer/preview?id=0&type=8&uid=8cbaaaad‐bf2a‐
4f91‐8d84‐d4be6c86e13b
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Current and Planned Water Supply Sources
Table 5 below shows the current and planned water supply sources for the City for normal
years. As required by Section 10631(j), this information has been provided to the SFPUC, the
City’s wholesale supplier.
Table 5: Current and Planned Water Supply Sources (AFY)19
SFPUC Supply
Description of SFPUC Regional Water System
Palo Alto receives water from the City and County of San Francisco’s RWS, operated by the
SFPUC. Approximately 85% of this supply is from the Sierra Nevada, delivered through the
Hetch Hetchy aqueducts, and approximately 15% is treated water produced by the SFPUC from
its local watersheds and facilities in Alameda and San Mateo Counties.
Over 2.7 million people and thousands of businesses in the San Francisco Bay Area rely on
water supplied by the SFPUC, a department of the City and County of San Francisco, to meet
their daily water needs. The San Francisco‐owned and operated RWS, which serves both retail
and wholesale customers, supplies high‐quality drinking water from the Tuolumne River
watershed and from the local Alameda and Peninsula watersheds. The RWS draws an average
of 85% of its supply from the Tuolumne River watershed, collected in Hetch Hetchy Reservoir in
Yosemite National Park. This water feeds into an aqueduct system delivering water 167 miles
by gravity to Bay Area reservoirs and customers. The remaining 15% of the RWS supply is drawn
from local surface waters in the Alameda and Peninsula watersheds. The percentage split
between these water sources varies from year to year depending on the water year hydrology
and operational circumstances.
RWS Distribution
The RWS, shown in Figure 1, consists of more than 280 miles of pipelines, 60 miles of tunnels,
11 reservoirs, five pump stations, two water filtration plants, and two treatment facilities for pH
adjustment and/or disinfection. It includes the Hetch Hetchy Water and Power (HHWP) Project
and the Bay Area water system facilities. The HHWP Project is generally composed of
reservoirs, hydroelectric generation and transmission facilities, and water transmission facilities
19 2025 Demand Study Model and 2025 Actual Usage Data
2025 2030 2035 2040 2045 2050
SFPUC 9,836 9,783 9,677 9,634 9,635 9,680
Local Groundwater - - - - - -
Local Surface Water - - - - - -
Recycled Water 196 250 250 250 250 250
Transfers In or Out - - - - - -
Exchanges In or Out - - - - - -
Desalinization - - - - - -
Other Sources - - - - - -
Total 10,032 10,033 9,928 9,884 9,886 9,931
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from the Hetch Hetchy Valley west to the Alameda East Portal of the Coast Range Tunnel in
Sunol Valley. Water system components of the HHWP Project are also referred to as the Hetch
Hetchy System. The local Bay Area water system is comprised of two parts—the Alameda
System and the Peninsula System—generally consisting of the facilities west of the Alameda
East Portal of the Coast Range Tunnel, including the 63,000‐acre Alameda and Peninsula
watersheds, storage reservoirs, two water filtration plants, and the distribution system that
delivers water to both retail and wholesale customers. The Hetch Hetchy, Alameda, and
Peninsula Systems are described in more detail below.
• Hetch Hetchy System: In the Hetch Hetchy System, water is diverted from the Tuolumne
River watershed into the Hetch Hetchy Reservoir and is then transported in a series of
tunnels and aqueducts from the Sierra Nevada to the San Joaquin Pipelines that cross the
San Joaquin Valley to the Coast Range Tunnel, which connects to the Alameda System at
the Alameda East Portal. Hetch Hetchy System water is disinfected at the Tesla Treatment
Facility.
• Alameda System: The Alameda System includes two reservoirs, San Antonio Reservoir
and Calaveras Reservoir, which collect water from the San Antonio Creek, Upper Alameda
Creek, and Arroyo Hondo watersheds in Alameda County. San Antonio Reservoir also
receives water from the Hetch Hetchy System. Conveyance facilities in the Alameda
System connect the Hetch Hetchy System and Alameda System to the Peninsula System.
The Bay Division Pipelines cross the South Bay to the Peninsula System delivering water
to customers along the pipeline route. The Sunol Valley Water Treatment Plant (SVWTP)
filters and disinfects water supplied from San Antonio Reservoir and Calaveras Reservoir.
The Sunol Valley Chloramination Facility treats Hetch Hetchy supplies with aqueous
ammonia to form chloramines and with sodium hydroxide to adjust pH, then blended in
the Alameda Siphons for delivery to Bay Area customers via the Irvington Tunnels.
• Peninsula System: The Peninsula System includes conveyance facilities connecting the
Bay Division Pipelines to the distribution system in San Francisco and to other customers
on the Peninsula. Two reservoirs, Crystal Springs Reservoir and San Andreas Reservoir,
collect runoff from the San Mateo Creek watershed. Crystal Springs Reservoir also
receives water from the Hetch Hetchy System. A third reservoir, Pilarcitos Reservoir,
collects runoff from the Pilarcitos Creek watershed and directly serves one of SFPUC’s
Wholesale Customers, the Coastside County Water District (which includes the City of Half
Moon Bay), along with delivering water to Crystal Springs and San Andreas Reservoirs.
The Harry Tracy Water Treatment Plant (HTWTP) filters and disinfects water supplied
from Crystal Springs Reservoir and San Andreas Reservoir before it is delivered to
customers on the Peninsula and in San Francisco.
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Figure 1: Regional Water System and Main Facilities
Water Treatment
The Hetch Hetchy Reservoir is the largest unfiltered water supply on the West Coast and one of
only a few large unfiltered municipal water supplies in the nation. The water originates from
well‐protected wilderness areas in Yosemite National Park and flows down the Tuolumne River
to Hetch Hetchy Reservoir. This water meets or exceeds all federal and State of California
(State) criteria for watershed protection. Water from Hetch Hetchy Reservoir, which is
protected in pipes and tunnels as it is conveyed to the Bay Area, requires pH adjustment to
control pipeline corrosion and disinfection for bacteria control. Based on the SFPUC’s
disinfection treatment practice, extensive bacteriological quality monitoring, and high
operational standards, the U.S. Environmental Protection Agency (USEPA) and the SWRCB
Division of Drinking Water (DDW) determined that the Hetch Hetchy water source meets
federal and State drinking water quality requirements without the need for filtration.
The Tesla Treatment Facility was a key component of the SFPUC’s Water System Improvement
Program and enhances the high‐quality water from the RWS. The facility has a capacity of 315
mgd, making it the third largest ultraviolet drinking water disinfection facility in the United
States.
The SFPUC treats all water derived from sources other than Hetch Hetchy Reservoir at one of
two water filtration facilities: the SVWTP or the HTWTP. The SVWTP primarily treats water from
the Alameda System reservoirs and has a design capacity of 160 mgd. Treatment processes
include powder activated carbon treatment for taste and odor control, coagulation,
flocculation, sedimentation, filtration, disinfection, fluoridation, corrosion control treatment,
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and chloramination. The nearby Sunol Valley Chloramination Facility can also provide
fluoridation, chloramination, and corrosion control treatment for Hetch Hetchy System and
blending with water treated from the SVWTP. The HTWTP treats water from the Peninsula
System reservoirs and has a design capacity of 140 mgd. Treatment processes at SVWTP include
ozonation, coagulation, flocculation, filtration, disinfection, fluoridation, corrosion control
treatment, and chloramination. The SFPUC completed major upgrades to the SVWTP in 2013
and to the HTWTP in 2015.
Water Storage
Most of the water delivered by the SFPUC is supplied by runoff from the upper Tuolumne River
watershed on the western slope of the central Sierra Nevada. Three major reservoirs collect
runoff: Hetch Hetchy, Cherry (also known as Lake Lloyd), and Lake Eleanor. The storage capacity
of these three reservoirs is included in Table 6. A “water bank” in Don Pedro Reservoir is also
integrated into RWS operations.20 Don Pedro Reservoir, which is jointly owned and operated by
Modesto Irrigation District and Turlock Irrigation District (the Districts), is located on the
Tuolumne River downstream of the Hetch Hetchy System.
San Francisco generates hydroelectric power through the HHWP Project as a by‐product of
water delivery and water supply management. Water released from Hetch Hetchy Reservoir is
used for hydroelectric generation and provides instream flows when released downstream.
Normally, only Hetch Hetchy Reservoir water supplies are exported to the Bay Area, while
releases from Lake Eleanor and Cherry Reservoir are used to provide instream flows, satisfy the
Districts’ Raker Act allocations, and produce hydroelectric power. The HHWP Project includes
four hydroelectric powerhouses along the Tuolumne River—Holm, Kirkwood, Moccasin, and
Moccasin Low Head—that have a collective generating capacity of nearly 400 megawatts.
In the Bay Area, the SFPUC utilizes the local Peninsula and Alameda watersheds. Crystal Springs,
San Andreas, and Pilarcitos Reservoirs, located in San Mateo County, capture local runoff in the
Peninsula watershed, and Calaveras and San Antonio Reservoirs, located in Alameda County,
capture local runoff in the Alameda watershed. In addition to capturing local runoff, San
Andreas, San Antonio, and Crystal Springs Reservoirs provide storage for water conveyed to the
Bay Area from the Hetch Hetchy System. These five local reservoirs are an important water
supply source in the event there is an interruption to Hetch Hetchy System deliveries. The
storage capacity of each of these Bay Area reservoirs is included in Table 6.
Prior to 2019, Calaveras Reservoir had been operating at one‐third of its capacity due to
restrictions imposed by the California Department of Water Resources Division of Safety of
Dams (DSOD). The Calaveras Dam Replacement Project, which took place from 2011 to 2019,
20 The Turlock Irrigation District and Modesto Irrigation District (the Districts) have senior water rights compared to those held
by the City and County of San Francisco for the Tuolumne River water diversions and are provided the first increment of flow in
the Upper Tuolumne River watershed according to the apportionment set forth in the Raker Act of 1913 (38 Stat. 242). The
water bank at Don Pedro Reservoir provides a credit and debit system, which allows the City and County of San Francisco to
divert water upstream while meeting its obligations to the Districts. Through this agreement, the SFPUC may pre‐deliver the
Districts’ Raker Act and contractual allocations and credit the water bank so that at other times the SFPUC may retain water
upstream that would otherwise be allocated to the Districts while the Districts debit the water bank.
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involved the construction of a new dam downstream of the then‐existing dam. The DSOD
restrictions on filling Calaveras Reservoir to full capacity have since been removed, and
Calaveras Reservoir reached full capacity during the 2022‐2023 winter season when it was
refilled completely in January 2023 following the dam replacement project.
Table 6: Regional Water System Storage Capacity
RWS Reservoir Acre‐Feet (AF) Billions of Gallons (BG)
Upcountry (a)
Hetch Hetchy 360,360 117.4
Cherry (b) 273,500 89.1
Lake Eleanor 27,100 8.8
Water Bank (c) 570,000 185.7
Local
Calaveras (Alameda) 96,800 31.5
San Antonio (Alameda) 50,500 16.5
Crystal Springs (Peninsula) (d) 69,300 22.6
San Andreas (Peninsula) (e) 19,000 6.2
Pilarcitos (Peninsula) (f) 3,100 1.0
a) Three other regulating reservoirs are also part of the RWS: Early Intake, Priest, and
Moccasin Reservoirs.
b) Storage capacity shown includes flashboards, which are structures placed in a spillway
to increase the capacity of a reservoir.
c) The SFPUC may draw against a credit of up to 740,000 AF in storage in a water bank
account in Don Pedro Reservoir; 170,000 AF of this water bank storage is only
available under certain circumstances and for a limited time. For this reason, the
SFPUC considers 570,000 AF in contributing to total storage for planning purposes.
d) Crystal Springs Reservoir has a maximum storage capacity of 22.6 BG (at 294.6 feet).
Based on permit conditions, the reservoir is currently operated at 286.6 feet (8 feet
below capacity).
e) San Andreas Reservoir has a maximum storage capacity of 6.2 BG (at 451.8 feet). Since
August 2020, in response to safety concerns about the seismic stability of the dam and
a directive from the Division of Safety of Dams, the SFPUC has held the maximum
water level at approximately 447.8 feet (4 feet below capacity).
f) Pilarcitos Reservoir has a maximum storage capacity of 1.0 BG (at 696.5 feet). Since
April 2025, in response to safety concerns about the seismic stability of the dam and a
directive from the Division of Safety of Dams, the SFPUC has held the maximum water
level at approximately 681.5 feet (15 feet below capacity).
g) For planning purposes, the total RWS storage is 1,469,660 AF. This includes 63,700 AF
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Wholesale Water Contractual Obligations
Under the terms of a 25‐year contract known as the Water Supply Agreement between the City
and County of San Francisco and Wholesale Customers in Alameda County, San Mateo County,
and Santa Clara County (WSA), the SFPUC sells water to 26 wholesale customers (collectively
referred to as the Wholesale Customers). The SFPUC has associated individual water sales
contracts with each Wholesale Customer, as well. Collectively, the Wholesale Customers
receive over two‐thirds of the RWS’s annual deliveries, with the remaining approximately one‐
third provided to the SFPUC’s retail customers located inside and outside of San Francisco
(collectively referred to as the Retail Customers). Of the 26 Wholesale Customers, 10 rely on
the SFPUC for 100% of their total supply. The remaining 16 Wholesale Customers rely on the
SFPUC for a significant portion of their water supply needs, but also use other local and
imported supplies to meet their retail water customers’ demands, including, but not limited to,
local groundwater and surface water, recycled water, and, in some cases, purchases from the
Santa Clara Valley Water District and the State Water Project.
The WSA became effective on July 1, 2009, as its predecessor agreement, the 1984 Settlement
Agreement and Master Water Sales Contract between the SFPUC and the Wholesale Customers
(1984 Agreement), expired. The WSA, as amended and restated in 2025, describes the current
contractual relationship between the SFPUC and the Wholesale Customers.
The WSA carries forward many components of the 1984 Agreement, including the SFPUC’s
“Supply Assurance” of 184 mgd to the Wholesale Customers. The SFPUC has agreed to deliver
water to the Wholesale Customers up to the amount of the Supply Assurance, and this
agreement is perpetual and survives the expiration of the WSA. The Supply Assurance is,
however, subject to reduction due to water shortage, drought, scheduled RWS maintenance
activities, and emergencies.
The Supply Assurance is shared among 24 of the 26 Wholesale Customers (all Wholesale
Customers, which have “permanent” status, except the cities of San Jose and Santa Clara, which
are “temporary, interruptible” customers). Twenty‐three of these 24 Wholesale Customers
have an “Individual Supply Guarantee” (ISG), which represents their dedicated individual share
of the 184 mgd Supply Assurance. The ISGs are also perpetual and survive the expiration of the
WSA. The City of Hayward is the 24th Wholesale Customer that shares in the Supply Assurance,
but it does not have an ISG due to the terms of its 1962 individual water supply contract with
the SFPUC that did not contain a fixed allocation of water. The City of Hayward’s unspecified
water supply allocation is included in the Supply Assurance as the difference between 184 mgd
and the sum of the other 23 permanent Wholesale Customers’ ISGs (22.1 mgd). If Hayward’s
water purchases from the RWS exceed 22.1 mgd over a period of three consecutive fiscal years
(an event that has not occurred to date and is not projected to occur before 2050), the 23
Wholesale Customers with ISGs would be required to reduce their individual ISGs to
accommodate the demands of Hayward.
Each Wholesale Customer also has an individual water sales contract with the SFPUC that
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describes the service area of the customer, identifies the location and size of service
connections between the RWS and the customer’s distribution systems, and in some instances
contains additional specific provisions unique to the customer. The individual water sales
contracts may be amended from time to time by the SFPUC and the applicable Wholesale
Customer pursuant to the terms of the WSA.
Palo Alto’s ISG is 16.575 MGD, or approximately 18,579 acre feet per year. The City’s ISG was
reduced to this level in May 2018 upon a permanent ISG transfer of 0.5 MGD to the City of East
Palo Alto 21.
Future Water Supply Decisions
In the 2009 WSA, the SFPUC committed to make two decisions before the end of 2018
regarding future water supplies, with the prerequisite of the SFPUC having completed any
necessary California Environmental Quality Act (CEQA) review relevant to those decisions:
• Whether or not to make the cities of San Jose and Santa Clara permanent customers of
the RWS, if the SFPUC determines that RWS long‐term water supplies are available to
support their permanent status, and
• Whether or not to increase the Supply Assurance above 184 mgd to meet future
Wholesale Customer demands.
Prior to 2018, the SFPUC determined that it was prudent to defer these decisions due to
uncertainty about water supply availability and future growth patterns in the Bay Area, as well
as unprecedented reductions in demands on the RWS, which indicated that total Wholesale
Customer demands (including the demands of San Jose and Santa Clara, who do not share in
the 184 mgd Supply Assurance) would be 173.9 mgd in 2040. Accordingly, the SFPUC and the
Wholesale Customers amended the WSA in 2018, deferring the future water supply decisions to
the end of 2028 to allow the SFPUC to conduct further water supply planning, including a
reevaluation of RWS demands and supply options, and any necessary CEQA analysis. Based on
current projections, Wholesale Customer demands (including the demands of San Jose and
Santa Clara) will continue to be less than the 184 mgd Supply Assurance through the year 2050.
The SFPUC’s planning efforts to support its decision regarding the status of San Jose and Santa
Clara are a part of the SFPUC’s Alternative Water Supply Program (see Section 6 – Water Supply
Reliability for more details).
Climate Change Impacts on Demand
Hotter and drier weather may lead to an increased demand in landscape irrigation. The City’s
Demand Study demand model reflects the historical relationship of the City’s water demand
with weather and then incorporates modeled weather under future climate change conditions
into the Demand Study demand projections. Therefore, the demand projections presented in
Section 4 – Water Demand include considerations of climate change. A description of the
weather and climate change data incorporated into the City’s demand model is provided in
21 See Staff Report #9041: https://www.cityofpaloalto.org/civicax/filebank/documents/64801
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Section 5.4 of the BAWSCA Demand Study (BAWSCA, 2025)22. Downscaled CMIP5 data were
obtained from CalAdapt’s Local Climate Change Snapshot tool. Climate projection data,
including annual precipitation and maximum temperature, was collected for the three counties
that overlay BAWSCA’s member agencies, including Alameda, San Mateo, and Santa Clara
counties. Modeled temperatures from the CalAdapt CMIP5 RCP 4.5 and RCP 8.5 datasets were
processed annually for 2025 – 2050 and included as potential inputs to the demand model.
Table 7 summarizes the estimated increases in temperature between 2025 and 2050.
Table 7: Average Annual Maximum Temperature Increases in 2050 (Relative to 2025) Derived
from CalAdapt CMIP5 RCP 4.5 and RCP 8.5
Alameda 1.20 °F 2.03 °F
Santa Clara 1.25 °F 2.05 °F
San Mateo 1.06 °F 1.77 °F
Alternative Water Supply Analysis
In anticipation of extended periods of drought and possible regulatory changes by the State,
the City is evaluating a wide range of alternative water supplies. The Northwest County
Recycled Water Strategic Plan, completed in collaboration with Valley Water, identified and
evaluated a number of potable and non‐potable water reuse concept options using effluent
from the RWQCP in Palo Alto. The City’s One Water Plan, received by City Council on October
20, 2025, is 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. The One Water Plan
included concept options identified in the Northwest County Recycled Water Strategic Plan. In
addition, the City, through BAWSCA, has additional water supply management opportunities.
Each is discussed in more detail below.
Transfer or Exchange Opportunities
Law
10631 (c) Describe the opportunities for exchanges or transfers of water on a short‐term or long‐
term basis.
22 https://bawsca.org/water/use/2025_Demand_Study
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The Tier 1 Shortage Plan23 allows for voluntary transfers of shortage allocations between the
SFPUC and any Wholesale Customer as well as between Wholesale Customers themselves. In
addition, voluntary transfers of water “banked” by the SFPUC or a Wholesale Customer,
through reductions in usage greater than required, may occur.
BAWSCA investigated water transfer opportunities as part of the Long Term Reliable Water
Supply Strategy discussed above. The recent historic drought led to capacity and regulatory
issues that made pilot transfers infeasible.
Groundwater
Law
10631 (b)(4) (excerpts)
If groundwater is identified as an existing or planned source of water available to the supplier, all
of the following information:
(A) The current version of any groundwater sustainability plan or alternative adopted…
(B) A description of any groundwater basin or basins from which the urban water supplier pumps
groundwater….
(C) A detailed description and analysis of the location, amount, and sufficiency of groundwater
pumped by the urban water supplier for the past five years….
(D) A detailed description and analysis of the amount and location of groundwater that is
projected to be pumped by the urban water supplier….
Deep Aquifer Groundwater
The City is located in Santa Clara County. Valley Water is the groundwater management agency
in Santa Clara County as authorized by the California legislature under the Santa Clara Valley
Water District Act, California Water Code Appendix, Chapter 60.
In September 2014, Governor Brown signed the Sustainable Groundwater Management Act
(SGMA) to promote the local, sustainable management of groundwater supplies. SGMA
requires sustainable groundwater management for all medium and high priority basins in
California. SGMA identifies Valley Water24 as the exclusive groundwater management agency
for Santa Clara County. The District actively manages the Santa Clara sub‐basin, designated as
high priority by the California Department of Water Resources. The groundwater basins in
Santa Clara County are not adjudicated nor have the basins been identified by the Department
of Water Resources as being in overdraft.
23 The Tier 1 Shortage Plan refers to the Water Shortage Allocation Plan (WSAP), which describes the method for
allocating water from the RWS between the SFPUC’s Retail Customers, on the one hand, and the Wholesale
Customers collectively, on the other, during system‐wide shortages caused by drought.
24 Valley Water Groundwater Sustainability Plan: https://www.valleywater.org/your‐water/where‐your‐water‐
comes‐from/groundwater/sustainable‐groundwater‐management
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In 2019, DWR approved Valley Water’s 2016 Groundwater Management Plan (GWMP) for the
Santa Clara and Llagas Subbasins as an Alternative, determining it satisfies the objectives of
SGMA. Periodic evaluations of approved plans are required at least every five years, so Valley
Water submitted the Board‐adopted 2021 GWMP to the DWR in December 2021. In June 2024,
DWR approved the 2021 GWMP confirming the Alternative satisfies the objectives of SGMA
and complies with related regulations. Valley Water is currently in the process of developing
the 2026 GWMP, which is the second periodic evaluation to the approved Alternative and due
to DWR in December 2026.
Although groundwater resources, including in South Santa Clara County, were heavily relied
upon in previous droughts, groundwater levels throughout the county are generally good, as
potable water demand has been reduced and as Valley Water efforts to prevent groundwater
basin overdraft, curb land surface subsidence, and protect water quality have been largely
successful.
The groundwater quality of the City’s wells is considered fair to good quality, though
significantly less desirable in comparison to SFPUC’s supplies. The groundwater is
approximately six times higher in total dissolved solids (TDS) and hardness than SFPUC’s
supplies. The City has not used groundwater as a water supply, since 1991;, groundwater is an
available alternative that is evaluated and reviewed on a regular basis. Figure 2 shows the
potential groundwater use area in the City’s service territory.
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Figure 2: Potential Groundwater Use Area
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The City maintains groundwater wells at sites El Camino, Fernando, Hale, Matadero, Peers Park,
Rinconada, Eleanor Pardee, and Library. The city has identified the wells as a potential supply
source for use during an emergency situation or a prolonged drought. Seven of the wells are
designated as standby or emergency sources, and the eighth (El Camino Park) is permitted as an
active, production well. These wells are not used for regular supply and are kept offline under
normal conditions. The City has chlorine injection systems at each well, and could supply
chlorination treatment to every well in an emergency.
The well system can support a minimum of eight hours of normal water use during a water
supply emergency at the maximum day demand level and four hours of fire suppression at the
design fire duration level. Up to 11,000 gpm of well capacity is available for emergency use. The
groundwater system may also be used to a limited extent for water supply during drought
conditions and is capable of providing normal wintertime supply needs during extended
shutdowns of the SFPUC system. The wells can only be used for 5 consecutive days up to 15
days in a year and the wells may collectively supply up to 1,500 AFY during a drought 25.
Activation of the wells for normal water use would require permitting, sampling, and
confirmation of water quality compliance under Title 22 standards before distribution.The
pumping restrictions for the well system are mitigation measures in the EIR prepared for the
Emergency Water Supply and Storage Project. Any increase in the current restriction could
require new or supplemental environmental review. The process to increase the current
limitation will require supporting information on the sustainable yield of the groundwater basin
in order to demonstrate increased pumping by the City will not have significant impacts.
Groundwater may hold some advantages in the long term for the City and may be useful during
water supply shortage events. However, a water supply portfolio that includes potable
groundwater does not benefit the City under the type of potable water reductions mandated
by the State Water Resources Control Board (SWRCB) during the 2015 drought. Under those
regulations, the City was required to reduce potable water consumption by 24% regardless of
the supply source. Likewise, Valley Water requests reductions in groundwater pumping during
dry periods. During the 2021 drought, Valley Water called for a 15% mandatory reduction,
compared to SFPUC’s 16% voluntary reduction measure for wholesale customers.
One of the Northwest County Recycled Water Strategic Plan objectives was to gain a better
understanding of the hydrology in northwest Santa Clara County. To that end, the Groundwater
Use Assessment (GUA)28 was completed including the development of a robust model of the
shallow and deep aquifers, particularly focusing on potential recharge zones and the
connectivity between the aquifers. The study concluded that Palo Alto could sustainably rely
on groundwater at a rate of approximately 3,000 AFY, or for about 30% of 2050 potable water
demands. Results of this effort were also used to evaluate the potential for Indirect Potable
25 Final EIR, City of Palo Alto Emergency Water Supply and Storage Project, SCH #2006022038
28 See full GUA report: https://www.cityofpaloalto.org/files/assets/public/v/1/utilities/water‐quality/rwqcp/task‐3‐
final‐report‐reduced.pdf?t=64573.3
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Reuse and may be used to demonstrate sustainable yield for a supplemental environmental
review to pump more than 1,500 AFY should Palo Alto plan to incorporate groundwater into its
supply portfolio.
Shallow Aquifer Groundwater
The shallow and deep aquifer research included in the GUA provided valuable insight into the
relationship between the aquifers in the northwest part of Santa Clara County. The study found
that, near the bay, a confining layer separates the deep and shallow aquifers. Further west,
toward the foothills, the two aquifers exhibit connectivity.
Basement construction is often required for non‐residential, mixed use and multifamily
residential buildings, particularly if underground parking is involved. Additionally, the high
value of land and housing in the City has resulted in more residential property owners seeking
to increase the size of their single family homes by constructing basements. Basement
construction groundwater pumping occurs when a basement is constructed in areas of shallow
groundwater, typically in the neighborhoods closer to the bay or near current or former creek
beds. Dewatering continues until enough of the house has been constructed to keep the
basement in place, typically 10 weeks. Longer term pumping removes seepage for older
underground structures such as the CalTrain underpass on Oregon Expressway.
Temporary groundwater dewatering from July 2019 to August 2020 produced over 461 AF.
When discharged to the City’s storm drain system, groundwater from dewatering activities
enters one of four creeks that discharges to the Bay. Most dewatering sites discharge to creeks
that have been channelized and offer negligible groundwater recharge opportunities. San
Francisquito Creek is the only creek in the City with potential to recharge the shallow
groundwater basin because it is not channelized within the City boundaries.
The City of Palo Alto issues permits for temporary and long‐term (greater than 1 year)
dewatering. The drought and resulting water use restriction increased public concern over
basement construction groundwater pumping in Palo Alto. Concerns range from the apparent
wasting of water by discharging to storm drains, to potential impacts on groundwater elevation
and flow volume, to potential impacts on neighboring properties, such as subsidence and
structure cracks, and impacts on trees and other landscaping.
The City has long regulated several aspects of basement groundwater pumping for both
residential and commercial sites. Public concerns regarding dewatering prompted City Council
to approve several enhancements to the dewatering policy that were codified in the Palo Alto
Municipal Code and went into effect in May 2017. Another iteration of requirements went into
effect in February 201829.
29 See Staff Report 8580:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=78367&dbid=0&repo=PaloAlto
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The goals of the construction dewatering requirements are improving the prediction of the
amount of pumped groundwater, decreasing impacts to surrounding structures and
infrastructure, addressing traffic impacts during the construction period, and minimizing
impacts to the area’s groundwater quantity and quality as well as the quality of downstream
water bodies. A summary of the requirements is listed below:
1. Fill stations are required so that others may fill water trucks or connect garden hoses for
irrigation;
2. Use plans are required to demonstrate that the applicant/builder is arranging for use of
as much of the pumped water as possible and minimizing storm drain discharge;
3. A Geotechnical Study is required to determine any potential effects and needed
avoidance measures; and
4. Street Work/Dewatering permits are required (and are issued after requirements #1, #2
and #3 are completed).
In November 2020, a technical memo 30 evaluating the reuse of dewatering water was
completed. While groundwater pumped from the basement dewatering is, in general, of
suitable quality to be used for irrigation after treatment in a settling tank and is equivalent to
about 12% of irrigation needs in Palo Alto in a typical year, the study identified limitations to
reusing large volumes of dewatering water. The study found it is not feasible to use all of the
groundwater for irrigation due to the high number of daily truck trips that would be required to
haul it to irrigation sites. If an average of 15 dewatering sites haul water to City irrigation sites
twice per week over a 12‐week dewatering period, approximately 900,000 gallons (2.8 AF) of
groundwater could potentially be reused for irrigation each year, which is less than 1% of the
groundwater produced by temporary dewatering.
Water Recycling
Wastewater Collection and Treatment in Palo Alto
Law
10633. (excerpts)
The plan shall provide, to the extent available, information on recycled water and its potential for
use as a water source in the service area of the urban water supplier. The preparation of the plan
shall be coordinated with local water, wastewater, groundwater, and planning agencies that
operate within the supplier’s service area, and shall include all of the following:
(a) A description of the wastewater collection and treatment systems in the supplier’s service
area, including a quantification of the amount of wastewater collected and treated…
(b) A description of the quantity of treated wastewater that meets recycled water standards, is
being discharged, and is otherwise available for use in a recycled water project.
30 See Technical Memo: https://www.paloalto.gov/files/assets/public/v/1/utilities/water‐drought/using‐
groundwater‐from‐temporary‐dewatering‐systems‐for‐irrigation‐technical‐memorandum‐task‐6.3.pdf?t=64014.74
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The City operates the RWQCP, a wastewater treatment plant, for the East Palo Alto Sanitary
District, Los Altos, Los Altos Hills, Mountain View, Palo Alto, and Stanford University.
Wastewater from these communities is treated by the RWQCP prior to discharge to the Bay.
Approximately 250,000 people live in the RWQCP service area. Of the wastewater flow to the
RWQCP, about 65 percent is estimated to come from residences, 5 percent from industries, and
30 percent from commercial businesses and institutions.
The RWQCP is a tertiary treatment facility featuring preliminary treatment (barscreens and grit
removal), primary treatment (sedimentation settling), secondary treatment (fixed film reactors,
nitrifying activated sludge soon to be converted to full biological nutrient removal, and
clarification), and tertiary treatment (filtration through a sand and coal filter), and UV
disinfection. After tertiary treatment, nonpotable recycled water is produced through further
filtration of tertiary effluent through sand filters at low loading rates and then disinfected with
sodium hypochlorite (instead of UV disinfection). Through these treatments, 99% of ammonia,
organic pollutants, and solid pollutants are removed.
The RWQCP has an average dry weather flow design capacity of 39 MGD (43,680 AF/Y) with full
tertiary treatment, and a peak wet weather flow capacity of 80 MGD (89,600 AF/Y) with full
secondary treatment. Current 2025 average flows are approximately 18 MGD (20 176 AF/Y).
The plant capacity is sufficient for current dry and wet weather loads and for future load
projections. There are no plans for expansion of the plant or to “build‐out” the plant. New
treatment technologies that will add nitrogen removing capabilities are being installed with full
availability by approximately 2028 as part of a new Secondary Treatment Upgrades project that
will address anticipated nitrogen limits on regional effluent discharges. In any case, the total
hydraulic capacity of the plant should remain unchanged after completion of the Secondary
Treatment Upgrades project.
The plant's discharge meets very high standards to protect South San Francisco Bay. The quality
of the water leaving the plant approaches the standards for drinking water. Table 8 provides
flow data for the RWQCP. A full description of the treatment facility is included in the 1992
Water Reclamation Master Plan and the 2012 Long Range Facilities Plan 31. An update to the
Long Range Facility Plan is expected to be completed in 2027.
31 See document: https://www.paloalto.gov/files/assets/public/v/1/public‐works/water‐quality‐control‐plant/lrfp‐
final‐report‐08‐2012.pdf
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Table 8: Wastewater Treatment
Treatment
Plant Name
Location
(City)
Average
Daily Flow
Daily Flow
(2025)
Year of
Planned
Build‐out
Planned Maximum Daily
RWQCP City of
Palo Alto AF/year
18.2 MGD
AF/year out Design Daily Flow
44,000 AF/year = Average Design
Daily Flow (Dry weather capacity)
Palo Alto Recycled Water Production
As shown in Table 9, the plant has capacity to produce approximately 4.5 MGD of recycled
water. Current annual production is about 15% of capacity while peak summer monthly
production is about 30% of capacity; peak hour summer demand uses nearly 100% of
production capacity in conjunction with storage tanks to address limitations in the 4.5 MGD
production capacity.
Wastewater projections are sourced from the City’s Long Range Facility Plan Update.
Table 9: Wastewater Collected and Treated and Method of Disposal – AFY
Recycled Water Current and Potential Use
Law
10633. (excerpts)
The plan shall provide, to the extent available, information on recycled water and its potential for
use as a water source in the service area of the urban water supplier. The preparation of the plan
shall be coordinated with local water, wastewater, groundwater, and planning agencies that
operate within the supplier’s service area, and shall include all of the following:
…(c) A description of the recycled water currently being used in the supplier's service area,
including but not limited to, the type, place and quantity of use.
Volume
Method of Disposal Treatment Level Volume
Collected and Treated
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(d) A description and quantification of the potential uses of recycled water, including, but not
limited to, agricultural irrigation, landscape irrigation, wildlife habitat enhancement, wetlands,
industrial reuse, groundwater recharge, and other appropriate uses, and a determination with
regard to the technical and economic feasibility of serving those uses.
(e) The projected use of recycled water within the supplier's service area at the end of 5, 10, 15,
and 20 years and a description of the actual use of recycled water in comparison to uses previously
projected pursuant to this subdivision.
Current Recycled Water Use
Phase 1 of the RWQCP’s regional recycled water system has been in operation since 1980. It
serves the Palo Alto Golf Course, Greer Park, Animal Services Center, and the RWQCP. In 2009
the City completed a project to replace an aging pipeline to Shoreline Golf Course in Mountain
View and to extend the pipeline to the Mountain View‐Moffett area. The pipeline replacement
restored the golf course connection and provides recycled water services to the Mountain View
Shoreline community.
The recycled water produced by the RWQCP in FY 2025 was used for the following:
• Trucked water mostly for irrigation with some construction dust control (4 AF)
• Irrigation water for Palo Alto Parks (48 AF)
• Irrigation water for the Palo Alto Municipal Golf Course (121 AF)
• Irrigation water for the RWQCP (2 AF)32
• Water for the Duck Pond (22 AF)
• Irrigation water for CalTrans freeway landscape medians (<1 AF)
In addition:
• Treated wastewater is used for industrial processes at the plant itself using final plant
effluent. The amount of effluent that replaces potable water for this use is estimated to
be about 800 AF.
• The pipeline serving Shoreline Park and other customers in Mountain View (632 AF)
Actual recycled water use in Palo Alto in 2025 was lower than the projection in the 2020 UWMP
(196 AF versus 316 AF). This is primarily due to decreased recycled water use by the Palo Alto
Municipal Golf Course for that year.
Potential Recycled Water Use
Palo Alto completed a Water Reclamation Master Plan (Master Plan) for the Palo Alto RWQCP
in 1992 (Brown and Caldwell 1992) and the accompanying Final Program Environmental Impact
Report (EIR) in 1995 (CH2MHill 1995). The Master Plan and program‐level EIR evaluated the
development of a regional water reuse system that could ultimately provide service to the
entire RWQCP service area. The Master Plan includes a phased approach to the expansion of
32 This is an estimated unmetered amount for landscaping inside the Palo Alto RWQCP and for that reason is
excluded from actual and projected recycled water estimates in this UWMP.
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treatment, distribution, storage, and use of recycled water. The City did not pursue any of the
recommended expansion stages of a water recycling system as the cost of the projects could
not be justified. In December 2008, the City completed the Recycled Water Facility Plan investigating the
expansion of the regional recycled water system to serve areas in Palo Alto 34. On September 28,
2015 the Palo Alto City Council adopted a resolution certifying the EIR for an expansion of the
existing recycled water distribution system 35. The primary objectives of extending the recycled
water pipeline would be:
1. To allow the City to maximize recycled water as a supplemental water source, thereby
improving potable water supply reliability by conserving drinking water, which is
currently used for irrigation and other non‐potable uses;
2. To provide a dependable, drought‐proof locally controlled non‐potable water source;
3. To increase recycled water use from the RWQCP and reduce discharge to San Francisco
Bay; and
4. To reduce reliance on imported water.
In 2019, the Northwest County Recycled Water Strategic Plan was undertaken in collaboration
with Valley Water to assess drought‐proof recycled water expansion opportunities throughout
the RWQCP service territory. One element was a business plan for the Phase 3 Expansion
Project. Phase 3 is a non‐potable water pipeline extending the current recycled water
distribution system to the Stanford Research Park. The Business Plan 36 presented the costs,
benefits and budgetary impacts of the project. The need for external funding was identified as a
key component of making the project economically feasible. Phase 3 and variations of it were
included in the larger strategic plan.
The Northwest County Recycled Water Strategic Plan identified, summarized and ranked water
reuse alternatives or “Concept Options” based on cost and non‐cost criteria. Selected recycled
water concept options from the Northwest County Recycled Water Strategic Plan were used as
the basis for developing the reuse options in the One Water Plan 37, including:
• Direct potable reuse of purified water via a Palo Alto facility;
34 Report provided to the UAC in March 2009: https://www.paloalto.gov/files/assets/public/v/1/agendas‐minutes‐
reports/agendas‐minutes/utilities‐advisory‐commission/archived‐agenda‐and‐minutes/agendas‐and‐minutes‐
2009/03‐04‐2009‐meeting/item‐7_att‐final_palo_alto_rwmp_dec08.pdf. The executive summary of the report
provided to Council in April 2009 in informational Staff Report 203:09:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=69775&dbid=0&repo=PaloAlto
35 See Staff Report 6071: https://www.paloalto.gov/files/assets/public/v/1/agendas‐minutes‐reports/reports/city‐
manager‐reports‐cmrs/year‐archive/2015/final‐staff‐report‐id‐6071_utilities‐program‐for‐emerging‐technologies‐
update.pdf
36 See Utilities Advisory Commission Report: https://www.paloalto.gov/files/assets/public/v/1/agendas‐minutes‐
reports/agendas‐minutes/utilities‐advisory‐commission/archived‐agenda‐and‐minutes/agendas‐and‐minutes‐
2018/08‐01‐2018‐meeting/item‐3_recycled‐water‐distribution‐system‐business‐plan.pdf
37 Staff Report 2509‐5258 provided to City Council October 20, 2025:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83667&dbid=0&repo=PaloAlto
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• 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; and
• Expanded distribution of non‐potable water (recycled water to Stanford Research Park
and customers in the foothills).
After applying initial screening criteria, these options were narrowed down and assembled into
the following recycled water portfolios:
• Portfolio E: Enhanced Conservation with 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: Enhanced Conservation with 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: Enhanced Conservation with 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.
The Phase 3 Expansion Project was not included in the One Water Plan’s portfolio evaluation
due to high unit costs and lower yield compared to other recycled water options. Moreover, it
does not substantially increase water supply reliability given non‐potable reuse water is used
primarily for irrigation which is likely to be restricted in drought years.
Portfolios E and F 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. 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. 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.
Regional Collaboration
The Partnership Agreement between the City of Palo Alto, City of Mountain View, and Valley
Water, approved by Palo Alto’s Council on November 18, 2019 38, addresses multiple objectives
including diverting treated wastewater discharge from the Bay, increasing the use of treated
wastewater from the RWQCP, and displacing potable imported water where appropriate and
feasible. The Partnership Agreement is comprised of three main elements:
38 Staff Report and Partnership Agreement to Advance Resilient Water Reuse Programs in Santa Clara County:
https://www.paloalto.gov/files/assets/public/v/1/agendas‐minutes‐reports/reports/city‐manager‐reports‐
cmrs/year‐archive/2019/11‐18‐2019‐item‐17‐utilities.pdf?t=68162.48
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1. Valley Water is contributing $16 million, of an approximately $60 million total cost, to
design and construct a 1.125 MGD salt removal facility at the RWQCP in Palo Alto to
improve the quality of non‐potable recycled water used in Palo Alto and Mountain View.
The improved water will be better for salt‐sensitive plants and will, in the short‐term,
enable Mountain View to connect around 60 new customers to the distribution system;
2. About half the treated wastewater produced by the RWQCP will be transferred to Valley
Water for use in the county south of Mountain View. Valley Water will pay $1 million
per year to be allocated between all the wastewater agencies that commit treated
effluent to the transfer; and
3. Palo Alto and Mountain View will have a future option to request a new potable or non‐
potable water supply from Valley Water if needed. Any new water resource will be
supplied by Valley Water at cost.
On June 7, 2021, City Council approved the Effluent Transfer Agreement between the City of
Palo Alto and the City of Los Altos, authorizing Palo Alto to pass‐through a portion of funding
from Valley Water39. On April 7, 2025, City Council additionally approved the Effluent Transfer
Agreement between the City of Palo Alto and the Town of Los Altos Hills, authorizing Palo Alto
to pass‐through a portion of funding from Valley Water40.
Valley Water has paused consideration of building an Indirect Potable Reuse Regional Plant in
Palo Alto. The effluent transfer option expires in 2033.
The City has participated in other various regional recycled water planning initiatives.
• The City is a stakeholder in the ABAG‐led effort to secure grant funding for a Bay Area
Integrated Regional Water Management Plan (IRWMP) and for projects identified in
that IRWMP.
• CPAU and the partners of the RWQCP assisted in the funding of a project to build a new
recycled water pipeline from the RWQCP to Mountain View. The project was completed
in summer 2009. This project does not have new connections to end uses in the City,
but the pipeline is sized to accommodate future expansion of recycled water use in the
City.
• The City is a member of the California WateReuse Association, which helps promote and
implement water recycling in California.
• The City is a member of the Bay Area Recycled Water Coalition, a group of regional
recycled water project proponents that advocate for and seek funding from the Federal
39 Staff Report #11773: https://www.cityofpaloalto.org/files/assets/public/v/1/agendas‐minutes‐
reports/reports/city‐manager‐reports‐cmrs/year‐archive/2021/id‐
11773.pdf#:~:text=The.%20Partnership%20Agreement%20includes%20an%20option%20for%20the%20Santa%20C
lara%20Valley%20Water%20District%20(Valley.
40 Staff Report #2501‐4068:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83328&dbid=0&repo=PaloAlto
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Bureau of Reclamation under Title XVI of the Reclamation Projects Authorization and
Adjustment Act of 1992 (P.L. 102‐575).
• The City is a member of Bay Area Clean Water Agencies, a group of wastewater
treatment plants that advocate and seek funding from State propositions and State
Revolving Fund loans.
• The City is a member on the Valley Water Recycled Water Subcommittee. The
Committee is a group of recycled water retailers and wholesalers that meets bimonthly
to discuss issues and challenges surrounding the use and promotion of recycled water.
• The City of Palo Alto is currently a member of the Joint Recycled Water Task Force with
Valley Water which seeks future recycled water expansion projects.
Encouraging and Optimizing Recycled Water Use
Law
10633. (excerpts)
The plan shall provide, to the extent available, information on recycled water and its potential for
use as a water source in the service area of the urban water supplier. The preparation of the plan
shall be coordinated with local water, wastewater, groundwater, and planning agencies that
operate within the supplier’s service area, and shall include all of the following:
…(f) A description of actions, including financial incentives, which may be taken to encourage the
use of recycled water, and the projected results of these actions in terms of acre‐feet of recycled
water used per year.
(g) A plan for optimizing the use of recycled water in the supplier's service area, including actions
to facilitate the installation of dual distribution systems and to promote recirculating uses, to
facilitate the increased use of treated wastewater that meets recycled water standards, and to
overcome obstacles to achieving that increased use.
The City has engaged in a variety of activities to advance water reuse. Regional coordination as
well as state and federal matching funds will be critical to successful implementation.
The City encourages Recycled Water usage in the following ways:
• Participating in the Integrated Regional Water Management Plan process
• Encouraging businesses and City departments to utilize the existing recycled water
capability within the City
• Participating as an active member of the WateReuse Association, including hosting
meetings of the Northern California Chapter of the Association
• Offering recycled water for a minimal permit‐processing fee to users willing to pick it up
at the RWQCP by truck
• Adoption of the Recycled Water Mandatory Use Ordinance
• Adoption of the Salinity Reduction Policy
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In May 2008, the City approved a Mandatory Use Ordinance to require customers within the
boundaries of any recycled water project area to prepare for recycled water delivery 41. In 2019,
the City updated the Green Building Ordinance 42. The threshold for dual plumbing in new
construction was lowered from 100,000 sf (square feet) to 50,000 sf or 50 or more toilets and
urinals (formerly 100 toilets and urinals). Compliance with the ordinance is administered
through the permit process with the Building Department.
The City Council approved a Salinity Reduction Policy 43 in January 2010 to address the elevated
salinity levels in the recycled water. The policy identified inflow and infiltration as a likely
contributor to the elevated salinity levels, and provided a target salinity level based on
minimum inflow and infiltration into the wastewater collection system. As a result, several
steps were implemented to lower the TDS levels in the recycled water:
• The RWQCP continues to monitor potential saltwater intrusion "hotspots" and
communicate the results to the RWQCP partners;
• The RWQCP tracks salinity data and performs other investigative work to support the
effort;
• CPAU coordinated implementation of the Sanitary Sewer Management Plan to manage
the Palo Alto wastewater collection system and identify inflow and infiltration reduction
actions; and
• The RWQCP developed a plan to coordinate salinity reduction activities with the RWQCP
partners and prepare for expanded recycled water applications. This plan was
coordinated with the Valley Water, which has jurisdiction over the groundwater basins
in Santa Clara County.
In September 2015, the City of Palo Alto City Council certified an Environmental Impact Report
(EIR) for the Palo Alto Recycled Water Project (SCH #2011062037). The EIR included Mitigation
Measure HYD‐3d, which requires the City to consider treatment options, such as reverse
osmosis, to reduce the salinity of its recycled water and thus making its recycled water useable
for irrigation of salt‐sensitive species.
Following adoption of the Palo Alto Recycled Water Project EIR, Council directed staff to
coordinate with Valley Water and Mountain View to prepare a feasibility study and preliminary
design report for a local advanced water purification system (Local AWPS), which was
completed in 2017. The Local AWPS project improves recycled water quality by reducing its
average concentration of total dissolved solids (TDS) through the blending of reverse osmosis
permeate with tertiary‐treated recycled water. It responds to Council’s expressed goal, as set
forth in the Recycled Water Salinity Reduction Policy adopted in 2010, to reduce the TDS level
of recycled water to 600 parts per million.
41 City of Palo Alto Municipal Code, Title 16, Chapter 16.12. The Ordinance applies to non‐residential customers.
The City has no plans to provide recycled water to residential customers.
42 See PAMC section 18.24: https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0‐0‐0‐85864
43 City Council Resolution 9035:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=53257&dbid=0&repo=PaloAlto
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In 2019 the City Council approved an agreement with Valley Water to advance recycled water
projects in the region; one of them is the Local AWPS. Construction on the Local AWPS began in
2025 and is scheduled for completion in spring of 2028. Phase I of the project will produce
1.125 MGD of permeate that will then be blended with the RWQCP’s current tertiary treated
recycled water for an overall 2.25 MGD of blended recycled water with a lower TDS content of
about 450 mg/L. This is anticipated to improve and increase the overall use of non‐potable
recycled water in the RWQCP service area. The improved recycled water quality could allow for
increased use within the City’s existing recycled water system. Mountain View plans to increase
its use of recycled water treated by the RWQCP and expand its recycled water system. To
account for that expansion, a future Phase II was incorporated in the original design to increase
permeate production to 2.25 MGD for a total delivery of blended recycled water of 4.5 MGD.
Desalinated Water
Law
10631 (excerpts)
A plan shall be adopted . . . that shall do all of the following:
…(g) Describe the opportunities for development of desalinated water, including, but not limited
to, ocean water, brackish water, and groundwater, as a long‐term supply.
Development of desalinated water is not feasible at this time. Desalination projects have
previously been considered on a regional level as part of BAWSCA’s Long Term Reliable Water
Supply Strategy and SFPUC’s Alternative Water Supply Plan, but the City is not aware of any
projects being considered at this time.
Energy Intensity
Law
10631.2 (a) In addition to the requirements of Section 10631, an urban water management plan
shall include any of the following information that the urban water supplier can readily obtain:
(1) An estimate of the amount of energy used to extract or divert water supplies.
(2) An estimate of the amount of energy used to convey water supplies to the water treatment
plants or distribution systems.
(3) An estimate of the amount of energy used to treat water supplies.
(4) An estimate of the amount of energy used to distribute water supplies through its distribution
systems.
(5) An estimate of the amount of energy used for treated water supplies in comparison to the
amount used for nontreated water supplies.
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(6) An estimate of the amount of energy used to place water into or withdraw from storage.
(7) Any other energy‐related information the urban water supplier deems appropriate.
The RWS is mostly gravity‐fed, and therefore, has relatively low energy intensity. More
information is provided in SFPUC’s 2025 UWMP.
The City’s local distribution system operates mostly by taking advantage of the gravity‐fed RWS
with two exceptions: water pumped to storage and customers in the foothills and the
production of recycled water. An estimated 535,400 kwh per year is required to produce the
Regional Water Quality Control Plant’s 828 AFY recycled water supply making the energy
intensity 647 kwh/AF in fiscal year 2025. Moving water to the foothills required approximately
1,300,000 kwh per year in fiscal year 2025. Spreading the energy use over Palo Alto’s total
potable demand of 10,431 AF yields an energy intensity of 125 kwh/AF. Since 2013 the City’s
electric supply has been carbon neutral44, making the greenhouse gas footprint negligible.
44 Palo Alto Carbon Neutral Plan:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=80024&dbid=0&repo=PaloAlto
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Section 4 – Water Demand
Law
10631 (excerpts)
A plan shall be adopted in accordance with this chapter that shall do all of the following:
…(d) (1) For an urban retail water supplier, quantify, to the extent records are available, past and
current water use, over the same five‐year increments described in subdivision (a), and projected
water use, based upon information developed pursuant to subdivision (a), identifying the uses
among water use sectors including, but not necessarily limited to, all of the following uses:
(A) Single‐family residential. (B) Multifamily. (C) Commercial. (D) Industrial. (E) Institutional and
governmental. (F) Landscape. (G) Sales to other agencies. (H) Saline water intrusion barriers,
groundwater recharge, or conjunctive use, or any combination thereof. (I) Agricultural. (J)
Distribution system water loss.
(d) (2) The water use projections shall be in the same five year increments described in subdivision
(a).
…(d) (4) (A) Water use projections, where available, shall display and account for the water savings
estimated to result from adopted codes, standards, ordinances, or transportation and land use
plans identified by the urban water supplier, as applicable to the service area.
(B) To the extent that an urban water supplier reports the information described in subparagraph
(A), an urban water supplier shall do both of the following:
(i) Provide citations of the various codes, standards, ordinances, or transportation and land use
plans utilized in making the projections.
(ii) Indicate the extent that the water use projections consider savings from codes, standards,
ordinances, or transportation and land use plans. Water use projections that do not account for
these water savings shall be noted of that fact.
10631.1 (a) The water use projections shall include projected water use for single‐family and multi‐
family residential housing needed for lower income households, as defined in Section 50079.5 of
the Health and Safety Code, as identified in the housing element of any city, county, or city and
county in the service area of the supplier.
10608.20(e) An urban retail water supplier shall include in its urban water management plan due
in 2010 pursuant to Part 2.6 (commencing with Section 10610) the baseline daily per capita water
use target, interim urban water use target, and compliance daily per capita water use, along with
the bases for determining those estimates, including references to supporting data.
Water Usage
Lay Description
Although the City has experienced several drought periods since 1975, the 2015 drought had a
particularly profound effect on City and customer attitudes regarding water. The state‐
mandated water use reductions in the 2015 drought resulted in large numbers of landscape
conversion projects as well as a dramatic shift in customer behavior regarding water use.
Voluntary reductions during the 2021 drought also produced a sustained decrease in demand,
though to a smaller degree. In addition, new construction in every sector is subject to
increasingly stringent regulations regarding water‐using appliances and fixtures.
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Regional Water Demand and Conservation Projections
In December 2025, BAWSCA completed the Regional Water Demand and Conservation
Projections Report (Demand Study)45. The goal of the Demand Study was to develop
transparent, defensible, and uniform demand and conservation savings projections for each
Wholesale Customer using a common methodology to support both regional and individual
agency planning efforts and compliance with the new statewide water efficiency targets
required by Assembly Bill (AB) 1668 (2018) and Senate Bill (SB) 606 (2018).
Through the Demand Study process, BAWSCA and the Wholesale Customers (1) quantified the
total average‐year water demand for each Wholesale Customer through 2050, (2) quantified
passive and active conservation water savings potential for each individual Wholesale Customer
through 2050, and (3) identified conservation programs with high water savings potential
and/or BAWSCA Member Agency interest. Implementation of these conservation measures,
along with passive conservation, is anticipated to yield an additional 16.14 million gallons per
day (mgd) of water savings by 2050. Based on the revised water demand projections, the
identified water conservation savings, increased development and use of other local supplies by
the Wholesale Customers, and other actions, the collective purchases of the BAWSCA Member
Agencies from the SFPUC are projected to stay below 184 mgd through 2050.
As part of the Demand Study, each Wholesale Customer was provided with a demand model
that can be used to support ongoing demand and conservation planning efforts, including
UWMP preparation.
Historical and Projected Demand
The City’s 2025 UWMP uses the demand projections produced as part of the Demand Study
discussed in the section above.
Figure 3 below shows the City’s potable water use since 1988 and a projection of water supplies
through 2050. Water consumption in the 2015 drought reached its lowest level in more than
25‐years due to state mandated water reductions combined with permanent water
conservation measures. This was followed by the 2021 drought during which demand declined
by 15% in response to voluntary water reductions measures.
Following a slight rebound in water demand after the 2021 drought, the City’s baseline demand
forecast reflects a 5% total decline in water demand over the 25‐year forecast period, inclusive
of savings from passive and active conservation.
45 https://bawsca.org/water/use/2025_Demand_Study
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Figure 3: City of Palo Alto Water Supply Purchases – Actual and Forecast
Water Sales
Table 10 shows historical and projected sales by customer type before and after incorporating
the impact of planned DMMs discussed in Section 5 – Demand Management Measures.
Planned DMMs are included as an estimate, however, actual conservation programs are subject
to approval by Palo Alto’s City Council. Table 11 shows the number of accounts in each
category, and Table 12 shows the sales per account for each customer type. The City does not
have sales to other agencies, agricultural use, or saline water intrusion barriers, groundwater
recharge, or conjunctive use, or any combination thereof.
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Table 10: Historical and Projected Water Sales – by Customer Type (Fiscal Years)
Table 11: Historical and Projected Water Accounts – by Customer Type (Fiscal Years)
Table 12: Historical and Projected Water Sales per Account (AF) (Fiscal Years)
Use per account declined from FY 2020 to FY 2025 due to voluntary water use reductions
adopted during the 2021 drought. Overall water use per account decreased by 10%. During this
period, water use per account decreased by 15% for single family residences, 18% for
multifamily, 1% for industrial, 6% for public facilities, 17% for City facilities, and 9% for
landscape irrigation customers. Water use per account increased 9% for commercial customers.
These changes in water use by sectors likely also reflect, to a smaller degree, the effects of the
COVID‐19 pandemic during this period.
AF/Y 2020 2025 2030 2035 2040 2045 2050
Single Family 4,967 4,347 4,112 4,144 4,170 4,187 4,215
Multifamily 1,797 1,340 1,795 1,874 1,884 1,887 1,896
Commercial 1,628 2,035 1,764 1,831 1,864 1,891 1,922
Industrial 295 241 235 244 248 252 256
Institutional 435 391 354 367 374 379 386
Other 3 11 2 2 2 2 2
Landscape 1,278 1,211 1,118 1,129 1,137 1,146 1,157
Government 319 258 236 244 249 252 257
Total Water Sales 10,722 9,836 9,617 9,835 9,928 9,998 10,091
Passive Water Savings 209 369 451 510 553
Active Water Savings 397 576 639 654 666
Net Water Sales 10,722 9,836 9,011 8,889 8,838 8,835 8,872
2020 2025 2030 2035 2040 2045 2050
Single Family 15,026 15,517 15,783 15,821 15,821 15,821 15,821
Multifamily 2,162 1,965 2,659 2,761 2,761 2,761 2,761
Commercial 1,352 1,544 1,493 1,554 1,580 1,606 1,632
Industrial 62 52 54 56 57 58 59
Institutional 47 45 45 45 45 45 45
Other 707 668 669 669 669 669 669
Landscape 433 451 453 453 453 453 453
Government 228 222 222 222 222 222 222
Total Water Accounts 20,016 20,463 21,377 21,581 21,607 21,634 21,661
2020 2025 2030 2035 2040 2045 2050
Single Family 0.331 0.280 0.261 0.262 0.264 0.265 0.266
Multifamily 0.831 0.682 0.675 0.679 0.682 0.684 0.687
Commercial 1.204 1.318 1.182 1.178 1.180 1.177 1.178
Industrial 4.749 4.680 4.335 4.321 4.327 4.319 4.321
Institutional 9.214 8.699 7.867 8.163 8.312 8.432 8.572
Other 0.004 0.017 0.004 0.004 0.004 0.004 0.004
Landscape 2.956 2.686 2.468 2.491 2.509 2.530 2.554
Government 1.401 1.167 1.063 1.103 1.124 1.140 1.159
Total Use per Account 0.536 0.481 0.450 0.456 0.459 0.462 0.466
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Share of Total Consumption by Customer Type
In FY 2025 single‐family and multi‐family water sales were responsible for 58% of total water
consumption in the City. The business sectors including commercial and industrial customers
consume 23%, while irrigation customers consumed 12%. Government and institutional
facilities consume the remaining 7%. The relative share of water consumed by residential
customers has decreased since FY 2020 by 5% while the share of water consumed by business
sectors (other than irrigation) has increased by 5% since FY 2020. Figure 4 and Figure 5 below
show the breakdown of consumption by customer type for FY 2020 and FY 2025.
Figure 4: FY 2020 Water Sales by Customer Class
Figure 5: FY 2025 Water Sales by Customer Class
Sales to Other Agencies
The City has not, and does not plan to, sell water supplies to other agencies.
Single Family
46%
Multifamily
17%
Commercial
15%
Industrial
3%
Institutional
4%
Landscape
12%
Government
3%
Single Family
44%
Multifamily
14%
Commercial
21%
Industrial
2%
Institutional
4%
Landscape
12%
Government
3%
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Additional Water Uses ‐ Recycled Water Use
Past use and future recycled water use projections are presented in Table 13 below. Actual use
in 2025 was 196 AF. Currently, there are no plans to expand the recycled water system within
the City’s service area. Recycled water demand projections represent a return to historical
levels (compared to relatively low usage in 2025) and a flat trend.
Table 13: Recycled Water Use (AFY)
Non‐Revenue Water/Water Loss
Non‐Revenue water, or unaccounted‐for water, is the difference between the amount of water
purchased and the amount sold to customers. Non‐revenue water has averaged about 6% of
total purchases during the past five years. Standardized table 4‐5 (Appendix C) contains a link to
the City’s water loss audit reports for years 2020 ‐ 2024. Real losses in 2024 year, as per the
audit, were 294 AFY.
Table 14 presents the historical and projected non‐revenue water volumes for the City’s water
system.
Table 14: Non‐Revenue Water (AFY)
Total Water Use
Table 15 shows total water use in the City.
Table 15: Total Water Use (AFY)
Projected Lower Income Water Use
All of the City's residential customers, regardless of income level, are metered and thus the
demands of residential customers with lower incomes are part of the single‐ and multi‐family
Treatment
Total 196 250 250 250 250 250
20502045Type of Use 2025
(Actual)2030 2035 2040
2025 2030 2035 2040 2045 2050
Non‐Revenue Water 595 771 788 795 801 808
2025 2030 2035 2040 2045 2050
Retail Sales 9,836 9,011 8,889 8,838 8,835 8,872
Non‐Revenue Water 595 771 788 795 801 808
Recycled Water 196 250 250 250 250 250
Total 10,626 10,033 9,928 9,884 9,886 9,931
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water uses shown in Tables 10‐12 and in DWR Table 4‐1 and DWR Table 4‐2 (See Appendix D –
DWR Standardized Tables). The City’s long‐term water demand projections are based on the
housing growth assumptions of City’s 2023‐2031 Housing Element, which includes the City’s
low‐income RHNA allocation of 2,452 lower‐income units, all of which are planned multi‐family
units. Based on the City’s demand model, the average multi‐family household is projected to
use 0.089 AFY per unit in 2030. At this rate, an additional 2,452 lower‐income housing units
would increase demand by 218 AFY.
Based on future projected demand forecasts shown in Table 10, the City expects to have ample
water supplies to meet all customers’ demands during a normal year. During a drought, the City
will follow the steps outlined in Section 8 ‐ Water Shortage Contingency Plan. The WSCP
addresses the City’s response depending on the severity of the drought. The City will
implement measures to maximize potential savings while at the same time minimizing the
impact to the wellbeing of the citizens and businesses in Palo Alto. As part of this process, the
City Council will have an opportunity to balance the needs of different customer classes with
the need to achieve meaningful reductions46.
Water Conservation Bill of 2009
The Water Conservation Bill of 2009 (SBx7‐7) was enacted in November 2009. It required water
suppliers to reduce the statewide average per capita daily water consumption by 20% by
December 31, 2020. To monitor the progress towards achieving the 20% by 2020 target, the bill
also required urban retail water providers to reduce per capita water consumption 10% by
2015. Water agencies that are not in compliance with the provisions of the bill could be
ineligible for State grants and/or a low‐cost financing program.
The City Council, by Resolution 9174 47, adopted a compliance methodology based on 80% of an
urban water user’s baseline gallons per capita per day (GPCD), in accordance with the Water
Conservation Act of 2009 and DWR’s Methodologies for Calculating Baseline and Compliance
Urban Per Capita Water Use (For the Consistent Implementation of the Water Conservation Act
of 2009). Under this methodology, the City was required to prepare the following calculations for
compliance purposes:
• Baseline daily per capita water use — The City must determine for baseline purposes how
much water is used within an urban water supplier’s distribution system area on a per
capita basis. It is determined using water use and population estimates from a defined
range of years. For the City, the range selected was from fiscal year 1995 to 2004 (Table 16).
46 Water Utilities typically do not possess income information for their customers and are limited in their ability to
offer differential rate treatment for low income customers due to Proposition 218 restrictions. During a drought, it
is more common for water utilities to differentiate between customers in a Class based on water usage patterns
and relative efficiency. For example, accounts with extremely low water use could be exempted from penalty rate
treatment.
47 Resolution 9174:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=53430&dbid=0&repo=PaloAlto&searchid=a8e79332
‐0f7c‐4fbe‐ae08‐18550ad91cfa
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• Urban water use target — The value is equal to 80% of the baseline daily per capita water
use value.
• Interim urban water use target — The planned daily per capita water use in 2015 is halfway
between the baseline daily per capita water use and the urban water use target.
• Compliance daily per capita water use – The gross water use during the final year of the
reporting period, reported in gallons per capita per day. This value was adjusted during the
2015 and 2020 compliance period based on actual usage data.
Table 16 illustrates the methodology to calculate the 10‐year average baseline per capita 48
water use.
Table 16: Baseline Daily Per Capita Water Use for 10‐year period (1995 through 2004)
Based on future water use and population growth projections, Table 17 summarizes Palo Alto’s
2020 UWMP SBx7‐7 target and compliance goals.
Table 17: 2015 UWMP SBx7‐7 Performance Metrics (gallons per capita per day)
The City met the 2020 SBx7‐7 target and the 2015 target. The City did not adjust the
compliance original target.
Measures, Programs and Policies that Achieved SBx7‐7 Water Targets
The City is committed to promoting all cost‐effective conservation programs that meet both the
City’s water reduction goals and community interest. Palo Alto shifts emphasis between
48 Population data is sourced from the US Census
Fiscal Year Distribution System Population Daily System Gross Water Use (MG)
1995 56,647 203.8
1996 56,885 220.8
1997 57,420 203.8
1998 57,868 203.8
1999 58,136 198.2
2000 58,467 203.7
2001 59,334 199.6
2002 60,028 209.1
2003 59,930 202.5
2004 59,894 251.1
225.3Baseline Daily Per Capita Water Use
2015 2020
Baseline GPCD 225.3 225.3
Target GPCD 202.8 180.3
Actual GPCD 142.0 141.7
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different conservation programs depending on various factors, including community
acceptance.
Economic Impacts of SBx7‐7 Compliance
There were no incremental economic impacts associated with SBx7‐7 compliance.
Implementation of conservation measures was not driven by SBx7‐7. Palo Alto deploys all
measures that are cost effective compared to the incremental cost of purchasing additional
water supplies from the SFPUC system 49.
Making Conservation a Way of Life
In July 2024, California enacted the Making Conservation a California Way of Life (MCCWL)
regulation (implementing SB 606 and AB 1668) to support long‐term water conservation and
drought resilience. MCCWL established annual Urban Water Use Objectives (UWUO) for water
suppliers and introduced Performance Measures for commercial, industrial, and institutional
(CII) water users.
The UWUO is a water‐budget‐based framework tailored to each supplier. It consists of the
following components:
1. Residential indoor water use standard,
2. Residential outdoor water budget,
3. CII landscape outdoor water use standard (for landscapes with dedicated irrigation
meters),
4. Water loss standard,
5. Variance, and
6. Potable reuse bonus.
Beginning in 2027, suppliers must annually assess whether the sum of their regulated water
uses (i.e., residential indoor and outdoor, dedicated irrigation meter use, and water loss) is at
or below their UWUO. The state standards for residential indoor and outdoor water use and for
CII outdoor use will become increasingly stringent over time, potentially requiring additional
conservation efforts to achieve compliance.
Urban retail water suppliers must report annually to the state on their water use relative to
their UWUOs. Because compliance with the UWUO requirements falls under the authority of
the State Water Resources Control Board (SWRCB), UWUO compliance projections are not
required as part of an UWMP per the 2025 UWMP Guidebook. Therefore, UWUO projections
are not included herein.
49 DMMs discussed in Section 5
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Section 5 – Demand Management Measures
Law
10631 (e) (excerpts)
Provide a description of the supplier’s water demand management measures. This description
shall include all of the following:
(1) (A) For an urban retail water supplier, as defined in Section 10608.12, a narrative
description that addresses the nature and extent of each water demand management measure
implemented over the past five years. The narrative shall describe the water demand management
measures that the supplier plans to implement to achieve its water use targets pursuant to Section
10608.20.
(B) The narrative pursuant to this paragraph shall include descriptions of the following water
demand management measures: (i) Water waste prevention ordinances. (ii) Metering. (iii)
Conservation pricing. (iv) Public education and outreach. (v) Programs to assess and manage
distribution system real loss. (vi) Water conservation program coordination and staffing support.
(vii) Other demand management measures that have a significant impact on water use as
measured in gallons per capita per day, including innovative measures, if implemented.
10620 (f) An urban water supplier shall describe in the plan water management tools and options
used by that entity that will maximize resources and minimize the need to import water from other
regions.
The City is committed to support conservation and efficient use of its water supply. It is the goal
of the City to continue to look for opportunities, innovative technologies, and cost‐effective
programs that best utilize the City’s water conservation budget. The City works with BAWSCA
and Valley Water to implement Best Management Practices water conservation programs.
The California Water Code Section 10631 (e) requires that an urban retail water supplier
provide descriptions that address the nature and extent of the following Demand Management
Measures (DMMs) that have been implemented over the past five years and/or will be
implemented to achieve its water use target pursuant to SBx7‐7:
A. Water waste prevention ordinance;
B. Metering;
C. Conservation pricing;
D. Public education and outreach;
E. Programs to assess and manage distribution system real loss;
F. Water conservation program coordination and staff support; and
G. Other demand management measures that have a significant impact on water use as
measured in gallons per capita per day, including innovative measures, if implemented.
In addition, the DMMs described below are water management tools and options used by the
City that maximize resources and minimize the need to import water from other regions.
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Water Waste Prevention Ordinance
The City has enforced water waste prevention as part of the City’s Municipal Code since 1989
(Palo Alto Municipal Code Chapter 12.32). Enforcement includes written warning notices to
violators and may result in fines and installation of a flow restrictor on the service connection of
the customer or purchaser of water whose service connection was used in the violations
observed or established, and billing the costs of such installation to said customer or purchaser.
Green Building Ordinance and Model Efficient Landscape Ordinance
In 2015, Palo Alto City Council approved an updated Green Building Ordinance (Palo Alto
Municipal Code Chapter 16.14) that incorporates the state’s 2013 Green Building Standards
Code (CALGreen), which sets permit requirements for water efficiency design, including
irrigation systems, in new development. In addition to the CALGreen standards, the City
requires the installation of a “laundry to landscape ready” irrigation system for all residential
new construction projects. Also, the City’s Green Building Ordinance has a lower square footage
trigger for irrigation efficiency than the state’s Model Water Efficient Landscape Ordinance
(MWELO). The 2019 Green Building Ordinance50 update lowered the threshold for dual
plumbing in new commercial construction to 50,000 sf and 50 toilets or urinals.
For non‐residential projects, MWELO requires compliance for landscapes of any size associated
with new construction and landscapes of 1,000 square feet for renovation projects. Under the
City’s current Green Building Ordinance, compliance with MWELO is required for landscapes of
any size on all non‐residential construction projects, as well as for landscaped areas of 1,000
square feet or more for residential projects. Palo Alto adopted the State Water Efficient
Landscape Ordinance per Governor Brown’s Drought Executive Order EO‐29‐15. The new
ordinance went into effect February 1, 2016.
Metering
The City has approximately 20,500 water service connections in its service territory. The system
is fully metered. In 2025, irrigation meters accounted for 2% of the total installed meters,
whereas water consumption from irrigation meters accounted for 12% of the City’s total
metered water consumption.
The City is upgrading its utility metering system with Advanced Metering Infrastructure (AMI).
As of March 2026, the City has converted 19,362 or 93% of water meters to AMI. Staff is
expecting completion of the water meters by June 2027. The system gives customers the ability
to track ongoing utility consumption data to make informed decisions about water use and
enables the timely detection of water leaks through access to WaterSmart, an online water
50 See Green Building Ordinance:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=47138&dbid=0&repo=PaloAlto
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management tool.
Conservation Pricing
The City’s residential water rates use a tiered structure to recover the cost of service based on
peaking factors, which represent the amount of extra capacity needed on the system to serve
customers within the customer class. Residential water usage is thus billed as a two‐tiered
volumetric charge that increases as monthly water consumption exceeds a threshold level. Tier
2 rates are based on the higher peaks observed in that customer class, largely due to irrigation
use in the summer. For non‐residential customers, water usage is billed on a uniform
volumetric charge. All customers are also billed a monthly service charge that varies depending
on the meter size. This cost‐based structure, where prices increase with consumption,
incentivizes conservation as well.
The City conducted a water cost of service and rate study51 in 2019 with the assistance of an
independent consultant, to ensure continued compliance with the California Constitution’s cost
of service requirements for water rates. As a result, the water rate structure was evaluated and
updated. The City plans to conduct a new water cost of service and rate study in 2027. On an
annual basis, City staff reviews and updates the City’s water rates for both residential and
nonresidential water customers.
Public Education and Outreach
Since 2006, the City has partnered with BAWSCA to offer free workshops on water efficient
landscaping, irrigation and water conservation. See the Regional Water Conservation – BAWSCA
Conservation Programs section below for more details. In addition to public workshops, City of
Palo Alto Utilities (CPAU) staff attends community, corporate and school events to promote
water conservation programs and practices, in addition to energy efficiency, waste reduction
and other sustainability practices.
The City carries out various seasonal and general water conservation campaigns via the use of
print and digital advertisements, utility bill inserts, social media, email newsletters, and
dynamic content such as through videos. Palo Alto also regularly updates the City’s website on
water conservation programs and public workshops.
The City has a web and mobile application known as PaloAlto311 to allow residents and
businesses to report incidents of leaks or other water waste issues.
During the last major drought affecting California, the City expanded its outreach to customers
about free and easy water use efficiency tips and access to resources such as rebates for
upgrading landscapes to water‐wise plants.
51 See consultant memo: https://www.paloalto.gov/files/assets/public/v/1/agendas‐minutes‐reports/reports/city‐
manager‐reports‐cmrs/attachments/attachment‐q‐6055187‐water‐cosa.pdf?t=48180.98
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Programs to Assess and Manage Distribution Systems Real Loss
The real losses of non‐revenue water is a combination of inaccurate water meters and water
system leakage from pipes in the public water distribution system. The City’s utilities meter
shop tests and replaces meters on a continuous and on‐going basis. The meter shop also
monitors meter data for unusual flow patterns to target individual meters for maintenance or
replacement. Every year, the Water, Gas, and Wastewater Division of the Utilities Department
calculates the statistical inaccuracy of all water meters and estimates the total volume and
percentage of real water loss. The Water, Gas, and Wastewater Division of the Utilities
Department contracts for acoustical leak detection services and locates leaks for repair. The
City’s Utility operators monitor streets for visible water leaks and respond to all phone calls
from the general public regarding potential leaks. The City funds and replaces pipes, with high
leak rates, on a biennial basis.
Water Conservation Program Coordination and Staffing Support
To achieve the water conservation and efficiency objectives of state and local mandates, Palo
Alto partners with agencies, such as Valley Water and BAWSCA, to offer many conservation
programs and services to Palo Alto residential and commercial water customers. City Council
has adopted several policies that support increased goals for energy and water efficiency
efforts as well as sustainability goals for the City.
Water Conservation Programs
For over a decade Palo Alto has partnered with Valley Water to administer water efficiency
programs to meet the City’s water reduction goals. This partnership between Valley Water and
the City is currently formalized through a cost‐sharing agreement under which Valley Water
and the City co‐fund various programs and partner to promote residential and commercial
landscape upgrades, free conservation devices, outdoor water efficiency surveys, irrigation
hardware upgrades, and educational workshops. Over time, the water efficiency programs
provided under the agreement have evolved or expanded concurrently with advancements in
water‐saving technologies and best practices for water‐efficient program delivery.
The City pursues innovative technologies and cost‐effective programs to implement and best
utilize the annual water conservation operating budget. These programs include free outdoor
water audits, rebates for upgrading landscapes to drought‐tolerant plants, irrigation
equipment, and commercial equipment. Water conservation resources available to Palo Alto
customers can be found on the City’s website 52 and Valley Water’s website53.
52 See website: https://www.paloalto.gov/Departments/Utilities/Ways‐to‐Save
53 See Valley Water’s website: https://www.valleywater.org/water‐conservation‐programs
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Do‐it‐Yourself Water Wise Indoor Survey Kits
This program enables customers to independently check their homes for leaks and identify
opportunities for water use efficiency improvements. Kits include a step‐by‐step guide to
evaluate water use (in English, Chinese, Spanish, and Vietnamese), a flow rate bag for testing
shower and sink flow rates, and dye tablets for testing toilets for leaks. Customers can request
free water conservation items for their homes, such as low flow faucet aerators, showerheads
and toilet flappers.
Water Wise Outdoor Survey
Through this program, customers receive a free, comprehensive, landscape consultation from a
trained irrigation professional. The consultation includes an irrigation system evaluation to
identify efficiency opportunities, rebate qualification for landscape and irrigation hardware
upgrades, and a custom report detailing the survey findings. The service is offered to single‐
family and small multi‐family sites (under 1/2 acre of landscape area) in Palo Alto with a
working irrigation system.
Landscape Rebate Program
The Landscape Rebate Program (LRP) provides rebates for Palo Alto residents and businesses to
convert approved high water‐using landscapes (i.e. irrigated turf or functional swimming pools)
with a qualifying low water‐using landscape, retrofit existing irrigation equipment (including
rain sensors, high efficiency nozzles, dedicated landscape meters, and weather‐based irrigation
controllers), and rain gardens, rain barrels, and cisterns.
Home Water Report and Customer Portal Program
In November 2022, the City launched an online water management tool, WaterSmart, to all
customers. The tool provides information on water consumption and personalized water
conservation recommendations. On a monthly basis, all single‐family customers receive home
water reports via email or regular mail if an email is not on file. The Home Water Report
compares a household’s water usage to neighbors with similar lot sizes, landscape area, and
household size. The reports rank a household for how water efficient it is compared to homes
with similar demographics to encourage more water‐efficient behaviors and participation in
conservation programs. Home water reports result in residential water savings of
approximately 26.2 MG (3% savings) annually. Through the portal, all CPAU customers also
receive emails alerting them of unusual usage, which could indicate a leak. The alerts include
resources on how to find and fix common leaks. Leak alerts result in water savings of
approximately 12.1 MG annually.
Water Efficient Technology Rebate Program
Through Valley Water, the City offers the Water Efficient Technology (WET) Rebate Program.
Commercial, industrial, and institutional customers such as schools and hospitals may receive a
rebate to replace or update equipment that results in a measurable water use reduction.
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Submeter Rebate Program
Through Valley Water, the City offers the Submeter Rebate Program to help mobile home
parks, apartments and condominium complexes in Palo Alto convert from a master water
meter to individual water submeters.
Water Conservation Coordinator
The City has maintained a full‐time Water Conservation Coordinator position for more than 20
years and expects to maintain the position indefinitely. Duties of the Water Conservation
Coordinator include water conservation program planning, implementation, management,
reporting, and representing Palo Alto at various water conservation committees and meetings.
The current Water Conservation Coordinator is Linda Grand (Linda.Grand@paloalto.gov)
Water Waste Coordinator
The City created a Water Waste Coordinator position in 2014. The Water Waste Coordinator
performs a wide range of functions associated with the City’s drought response program,
including investigating incidents of water waste, enforcing the City’s water use restrictions, and
responding to customer inquiries about drought regulations and water conservation programs.
The current coordinator is Kirk Gharda (Kirk.Gharda@paloalto.gov)
Large Landscape Survey and Water Budget Program
Through Valley Water, the City offers a program in which a trained irrigation professional will
perform a free landscape irrigation survey and provide water budgets and customized water
usage reports for commercial, industrial, institutional, and multi‐family complex customers with
over 1/2 acre of landscape area. The water budget for each landscape site is calculated based
on the area of irrigated landscape, type of plants, irrigation system and real‐time weather
monitoring. Through a web portal, customers can access site‐specific recommendations, view
trends in water use, verify water budget assumptions and request a free landscape field survey
from an irrigation expert. This program has been in place since 2012 and to date, there are 303
large landscape sites covered under this program.
BAWSCA Conservation Programs
BAWSCA manages a Regional Water Conservation Program comprised of several programs and
initiatives that support and augment Member Agencies’ and customers’ efforts to use water
more efficiently. These efforts extend limited water supplies that are available to meet both
current and future water needs; increase drought reliability of the existing water system; and
save money for both the Member Agencies and their customers.
The implementation of the Regional Water Conservation Program builds upon the Demand
Study (completed in December of 2025). These efforts include both Core Programs,
implemented regionally throughout the BAWSCA service area, and Subscription Programs,
which are funded by individual Member Agencies that elect to participate and implement them
within their respective service areas.
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BAWSCA’s Core Conservation Programs include organizing classes focused on sustainable and
water‐efficient landscape design, assistance for automated metering infrastructure, and other
associated programs that work to promote smart water use and practices. BAWSCA’s
Subscription Programs include rebates, educational services for schools, technical assistance to
Member Agencies in evaluating water loss, and data analytics tools to provide customized
water‐saving recommendations to customers. In total, BAWSCA offers 24 programs to its
Member Agencies and that number continues to grow over time.
Each fiscal year, BAWSCA prepares an Annual Water Conservation Report that documents
several conservation program metrics exemplifying the benefits of the Regional Water
Conservation Program to all 26 of BAWSCA Member Agencies. Additionally, the report
highlights how all 26 Member Agencies participate in one or more of the Subscription Programs
offered by BAWSCA, such as rebates, water loss management and large landscape audits. The
Demand Study indicates that through a combination of active and passive conservation, 16.14
million gallons per day (MGD) will be saved by BAWSCA Member Agencies by 2050.
The Core Programs provided as a part of the Regional Water Conservation Program include
conservation measures that yield benefits through regional implementation and are funded
through the annual BAWSCA budget. The Subscription Programs are conservation measures
that individual agencies must elect to participate in and whose benefits are primarily realized
within an individual water agency’s service area. As such, the Subscription Programs are funded
by individual member agencies, based on their participation level. The City is actively
participating in the following Subscription Programs:
• Water Loss Management Program
• Customer Meter Testing Program
• Landscape Workshop Program
Section 6 – Water Supply Reliability
Law
10631 (excerpts)
A plan shall be adopted in accordance with this chapter that shall do all of the following:
…(b) Identify and quantify, to the extent practicable, the existing and planned sources of water
available to the supplier over the same five‐year increments described in subdivision (a), providing
supporting and related information, including:
(1) A detailed discussion of anticipated supply availability under a normal water year, single dry
year, and droughts lasting at least five years, as well as more frequent and severe periods of
drought, as described in the drought risk assessment. For each source of water supply, consider
any information pertinent to the reliability analysis conducted pursuant to Section 10635,
including changes in supply due to climate change.
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…(f) Include a description of all water supply projects and water supply programs that may be
undertaken by the urban water supplier to meet the total projected water use, as established
pursuant to subdivision (a) of Section 10635. The urban water supplier shall include a detailed
description of expected future projects and programs that the urban water supplier may
implement to increase the amount of the water supply available to the urban water supplier in
normal and single‐dry water years and for a period of drought lasting five consecutive water years.
The description shall identify specific projects and include a description of the increase in water
supply that is expected to be available from each project. The description shall include an estimate
with regard to the implementation timeline for each project or program.
…(h) An urban water supplier that relies upon a wholesale agency for a source of water shall
provide the wholesale agency with water use projections from that agency for that source of water
in five‐year increments to 20 years or as far as data is available. The wholesale agency shall provide
information to the urban water supplier for inclusion in the urban water supplier’s plan that
identifies and quantifies, to the extent practicable, the existing and planned sources of water as
required by subdivision (b), available from the wholesale agency to the urban water supplier over
the same five‐year increments, and during various water‐year types in accordance with subdivision
(f). An urban water supplier may rely upon water supply information provided by the wholesale
agency in fulfilling the plan informational requirements of subdivisions (b) and (f).
The City’s potable water supply is dependent upon the reliability of SFPUC’s RWS. The SFPUC
defines reliability by the amount and frequency of water delivery reductions (deficiencies)
required to balance customer demands with available supplies in droughts. This section
discusses these potential system‐wide deficiencies.
Constraints of Water Sources Considerations
Water Supply – All Year Types
Constraints on Supplies
The SFPUC has identified potential constraints on its water supplies. The list below summarizes
the legal, environmental, water quality, climatic, and other factors potentially resulting in
inconsistent supply.
• RWS: There may be shortfalls of RWS supplies in dry years as a result of several factors,
including required instream flow releases (further discussed in the “Bay‐Delta Plan
Amendment Updates” section below) as well as climate change (see “Climate Change”
section).
The 2018 adoption of the Bay‐Delta Plan Amendment may significantly impact the supply
available from the RWS. The SFPUC recognizes that the Bay‐Delta Plan Amendment has been
adopted and that, given that it is now state law, the SFPUC must plan for a future in which it is
fully implemented. The SFPUC also acknowledges that the plan is not self‐implementing and
therefore does not automatically go into effect. Similarly, there is active litigation at the
appellate level regarding the Bay‐Delta Plan Amendment. The SFPUC is also pursuing a
voluntary agreement, known as the Healthy Rivers and Landscapes Program (HRL). The HRL is
currently undergoing evaluation at the SWRCB. In fall of 2025, the SWRCB released a Scientific
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Basis Report evaluating the biological benefits of the Tuolumne River component of the HRL.
The next step is for SWRCB to finalize this report including scientific peer review. At the same
time, the SWRCB is undergoing CEQA evaluation of the Tuolumne HRL. No timeline has been
provided for when the HRL will be considered for adoption by the SWRCB.
Because of the uncertainty surrounding implementation of the Bay‐Delta Plan Amendment, the
following water supply reliability assessment includes a set of tables for two future supply
scenarios: (1) a scenario in which the Bay‐Delta Plan Amendment is implemented and (2) a
scenario that considers the SFPUC system’s current conditions without implementation of the
Bay‐Delta Plan Amendment. The two scenarios provide a bookend for the possible future
scenarios regarding RWS supplies. The Bay‐Delta Plan Amendment implementation start date is
unknown, for the purposes of the supply reliability analysis, it is included in the 2030 modeling
scenarios. The standardized tables associated with this UWMP contain the future scenario that
assumes implementation of the Bay‐Delta Plan Amendment.
There are additional factors that could affect the availability of water supply regarding the
SWRCB curtailments and agreements with Turlock and Modesto Irrigation Districts pertaining
to instream flow obligations on the Tuolumne River. The following describes these and how
they were incorporated into the water supply reliability analysis.
• During the last two drought periods, 2013‐2016 and 2021‐2023, the SWRCB implemented
curtailments through emergency regulations and curtailment orders that attempted to
limit diversions from Central Valley watersheds including the Tuolumne River at certain
times. Due to the uncertain legality of the SWRCB’s curtailment actions as well as the
uncertainties regarding any potential future curtailment actions against San Francisco,
the SFPUC’s RWS supply reliability analyses do not assume curtailments are in effect.
• Through a 1966 agreement with the Modesto and Turlock Irrigation Districts (Districts),
who are more senior downstream appropriative water rights holders on the Tuolumne
River, San Francisco may become responsible for up to approximately 51.7% of any flow
releases the Federal Energy Regulatory Commission (FERC) may require through issuance
of a new license for the Districts’ Don Pedro Hydropower Project. The exact flow
contribution for which San Francisco may become responsible is highly uncertain and may
depend on multiple currently unknown factors, including an anticipated Endangered
Species Act biological opinion from the National Marine Fisheries Service and a Clean
Water Act section 401 water quality certification from the SWRCB. San Francisco’s
potential responsibility for FERC‐ordered flows may further depend on San Francisco’s
ability to enter into a new or extended agreement with the Districts to offset a portion of
San Francisco’s flow contributions in exchange for payment. Due to the high levels of
uncertainty surrounding the Districts’ FERC‐relicensing process, as well as the unknown
timing for license issuance, the SFPUC’s RWS water supply reliability analyses do not
assume additional water supply losses from any potential new FERC‐ordered flow
releases.
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• The simulation of the Bay‐Delta Plan Amendment scenario assumes that a 1996
agreement between San Francisco and the Districts (the Side Agreement), which allows
San Francisco to pay the Districts in lieu of contributing a portion of current FERC‐ordered
flow releases, remains in effect, and that the San Francisco share of flows in excess of and
not covered by the Side Agreement is approximately 51.7%. These assumptions were
made for the purpose of completing the modeling for the UWMP update, and they do not
represent a commitment by San Francisco or the Districts to any future agreement or of
San Francisco accepting responsibility for any future FERC‐ordered flow releases.
Water Quality of RWS Supplies
Surface water supplies available to the RWS include the Tuolumne River and local Bay Area
reservoirs. Most of the water supply originates in the upper Tuolumne River watershed high in
the Sierra Nevada, where the watershed is protected from development and pollution. Water
from Hetch Hetchy Reservoir is conveyed to the Bay Area through a system of pipes and tunnels
and requires only primary disinfection, ultraviolet light disinfection at the Tesla Treatment
Facility, and pH adjustment for corrosion control.
The USEPA and SWRCB Division of Drinking Water have approved the use of this drinking water
source without filtration. In contrast, water from the SFPUC’s local watersheds requires
filtration to meet drinking water quality standards. The SFPUC blends filtered and treated local
water with water from Hetch Hetchy Reservoir, and most customers receive this blended
supply. The SFPUC continuously monitors and tests both raw and treated water to ensure that
water delivered to customers meets or exceeds federal and state drinking water and public
health requirements. The SFPUC expects to continue relying on these high‐quality water
sources and does not anticipate future degradation of water quality.
Each spring, the SFPUC publishes an annual water quality report (Consumer Confidence
Report), available at www.sfpuc.gov/waterqualityreport.
Reliability of the RWS
Initiated in 2008, SFPUC’s Water System Improvement Program (WSIP) is a $4.8 billion, multi‐
year capital program to upgrade the RWS as well as the SFPUC’s local water system. The
program is delivering capital improvements that enhance the SFPUC’s ability to provide reliable,
affordable, high quality drinking water in an environmentally sustainable manner to its Retail
and Wholesale Customers. The SFPUC structured WSIP to cost‐effectively meet water quality
requirements, improve seismic and delivery reliability goals through the year 2030, and fulfill
water supply objectives through the year 2018. The SFPUC completed the San Francisco portion
of WSIP in October 2020. As of June 30, 2025, the regional portion of WSIP was 99.3%
complete, having repaired, replaced, and seismically upgraded crucial portions of the RWS; only
two regional projects remain in planning and construction, while 49 regional projects have been
completed or are in close‐out. The SFPUC forecasts that the overall WSIP will be complete in
June 2032.
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The SFPUC undertook the WSIP to ensure the ability of the RWS to meet Level of Service (LOS)
Goals and Objectives for water quality, seismic reliability, delivery reliability, and water supply.
The Water Supply LOS goal, stated in the WSIP and adopted in 2008, is to meet customer water
needs in non‐drought and drought periods. The SFPUC amended and updated the LOS Goals
and Objectives in November 2023. The SFPUC’s current LOS Goals and Objectives related to
water supply include the following:
• Meet an average annual water demand of 265 mgd from the SFPUC watersheds for Retail
and Wholesale Customers during non‐drought years consistent with the Water Supply
Agreement between San Francisco and its Wholesale Customers in Alameda, San Mateo,
and Santa Clara Counties.
• Meet dry‐year delivery needs while limiting rationing to a maximum 20 percent system‐
wide reduction in water service during extended droughts.
• Diversify and improve use of new water sources and drought management, including
groundwater, recycled water, conservation, transfers, storage expansion, purified water,
desalinated water, and technological innovations that can increase supply and/or water
use efficiency.
• Maintain San Francisco retail residential potable water use below 45 gallons per capita
per day.
• Realize annual Real Water Losses of less than 10% of water supplied to San Francisco.
• Meet 80% of San Francisco’s Recreation and Parks Department irrigation demands with
recycled water by December 31, 2025.
Bay‐Delta Plan Amendment Updates
In December 2018, the SWRCB adopted amendments to the Water Quality Control Plan for the
San Francisco Bay/Sacramento‐San Joaquin Delta Estuary (Bay‐Delta Plan Amendment) to
establish water quality objectives for the San Francisco Bay‐Delta watershed. The SWRCB is
required by law to regularly review this plan. The adopted Bay‐Delta Plan Amendment was
developed with the stated goal of increasing salmonid populations in three San Joaquin River
tributaries (the Stanislaus, Merced, and Tuolumne Rivers) and the San Francisco Bay‐Delta. The
Bay‐Delta Plan Amendment requires the release of 30‐50% of the “unimpaired flow”54 on the
three tributaries from February through June in every year type. In SFPUC modeling of the flow
standard, it is assumed that the required release is 40% of unimpaired flow.
If the Bay‐Delta Plan Amendment is implemented, the SFPUC will be able to meet the projected
water demands presented in this 2025 UWMP in normal years but is expected to experience
supply shortages in single dry years or multiple dry years. Implementation of the Bay‐Delta Plan
54 "Unimpaired flow represents the natural water production of a river basin, unaltered by upstream diversions,
storage, or by export or import of water to or from other watersheds." (Water Quality Control Plan for the San
Francisco Bay/Sacramento‐San Joaquin Delta Estuary (Dec. 12, 2018) p.17, fn. 14, available at
https://www.waterboards.ca.gov/plans_policies/docs/2018wqcp.pdf.)
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Amendment could require rationing in all single dry years and multiple dry years.
Implementation of the Bay‐Delta Plan Amendment remains uncertain for multiple reasons,
including:
• Over a dozen lawsuits have been filed in both state and federal courts challenging the
SWRCB’s adoption of the Bay‐Delta Plan Amendment, including a legal challenge filed by
the federal government at the request of the U.S. Department of Interior, Bureau of
Reclamation. This litigation is currently at the appellate level.
• The Bay‐Delta Plan Amendment is not self‐implementing and does not automatically
allocate responsibility for meeting its flow requirements to San Francisco or any other
water rights holders. Rather, the Bay‐Delta Plan Amendment provides a regulatory
framework for implementing water quality objectives, which must be accomplished by
other regulatory and/or adjudicatory proceedings, such as a comprehensive water rights
adjudication or, in the case of the Tuolumne River, implementation may be through the
water quality certification process set forth in section 401 of the Clean Water Act as part
of the Federal Energy Regulatory Commission’s licensing proceedings for the Don Pedro
and La Grange hydroelectric projects. It is currently unclear when the license amendment
process is expected to be completed. This process and the other regulatory and/or
adjudicatory proceedings may face legal challenges and have lengthy timelines, and quite
possibly could result in a different assignment of flow responsibility (and therefore a
different water supply impact on the RWS).
In recognition of the obstacles to implementation of the Bay‐Delta Plan Amendment, the
SWRCB Resolution No. 2018‐0059 adopting the Bay‐Delta Plan Amendment directed staff to
help complete a “Delta watershed‐wide agreement, including potential flow measures for the
Tuolumne River,” and to incorporate such agreements as an “alternative” for a future
amendment to the Bay‐Delta Plan to be presented to the SWRCB “as early as possible after
December 1, 2019.” On March 26, 2019, the SFPUC adopted Resolution No. 19‐0057 to support
the SFPUC’s participation in the Voluntary Agreement negotiation process. To date, those
negotiations are ongoing under the California Natural Resources Agency and the leadership of
the Newsom administration.55 On November 10, 2022, the SFPUC along with the Modesto and
Turlock Irrigation Districts signed a Memorandum of Understanding Advancing the Term Sheet
for the Voluntary Agreements to Update and Implement the Bay‐Delta Water Quality Control
Plan and Other Actions. Voluntary Agreements are now referred to as the Agreements to
Support Healthy Rivers and Landscapes and negotiations remain ongoing.
Because of the uncertainty surrounding implementation of the Bay‐Delta Plan Amendment, the
water service reliability assessment in the 2025 UWMP looks at two future supply scenarios: (1)
implementation of the Bay‐Delta Plan Amendment and (2) SFPUC system’s current conditions
without implementation of the Bay‐Delta Plan Amendment.
55 California Natural Resources Agency, “Voluntary Agreements to Improve Habitat and Flow in the Delta and its
Watersheds,” available at https://files.resources.ca.gov/voluntary‐agreements/.
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Tier One Drought Allocations
Tier One Drought Allocations
The WSA between the SFPUC and the Wholesale Customers, discussed above, includes as
“Attachment H” a Water Shortage Allocation Plan (WSAP), also known as the Tier 1 Shortage
Plan. This plan describes the method for allocating water from the RWS between the SFPUC’s
Retail Customers, on the one hand, and the Wholesale Customers collectively, on the other,
during system‐wide shortages caused by drought. The Tier 1 Shortage Plan applies only when
the SFPUC determines that a system‐wide water shortage due to drought exists, as set forth in
a declaration of water shortage emergency by the SFPUC Commission. In the absence of such a
declaration, the SFPUC also may opt to request voluntary cutbacks from its Retail and
Wholesale Customers to achieve water use reductions. The SFPUC and the Wholesale
Customers most recently amended the Tier 1 Shortage Plan in 2025.
The SFPUC allocates water under the Tier 1 Shortage Plan when it determines that the
projected available water supply is less than projected system‐wide water purchases for the
upcoming Supply Year, defined as the period from July 1 through June 30. The following table
shows the Retail Customers’ share and the Wholesale Customers’ share of the annual water
supply available during shortages depending on the level of system‐wide reduction in water use
that is required. If the SFPUC determines that the level of system‐wide reduction required
during a shortage is greater than 20 percent, the SFPUC and the Wholesale Customers will meet
to discuss the appropriate Retail and Wholesale Customers’ shares of available water. The
Retail and Wholesale Customers’ shares of available water are also known as the Retail and
Wholesale Customers’ Tier 1 Allocations. The Wholesale Customers’ Tier 1 Allocation will be
apportioned among the individual Wholesale Customers based on a separate methodology,
known as the Tier 2 Drought Response Implementation Plan (Tier 2 Plan), which is separately
adopted by all the Wholesale Customers without the SFPUC’s involvement as discussed further
below.
Level of System‐Wide
Reduction in Water Use Share of Available Water
5% or less
6% through 10%
11% through 15%
16% through 20%
35.5%
36.0%
37.0%
37.5%
64.5%
64.0%
63.0%
62.5%
The Tier 1 Shortage Plan allows for voluntary transfers of shortage allocations between the
SFPUC and any Wholesale Customer as well as between Wholesale Customers themselves. In
addition, voluntary transfers of water “banked” by the SFPUC or a Wholesale Customer,
through reductions in usage greater than required, may occur.
Under the Tier 1 Shortage Plan, as amended in 2018, if the Retail Customers’ Tier 1 Allocation
results in the Retail Customers receiving a “positive allocation” (i.e., a supply of additional
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water rather than a required reduction in water use), then the excess percentage for Retail is
re‐allocated to the Wholesale Customers’ Tier 1 Allocation. The Retail Customers are also
required to conserve a minimum of 5% for any level of reduction in system‐wide water use. The
additional water conserved by Retail Customers up to the minimum 5% level is deemed as
remaining in RWS storage for inclusion in the calculation of projected available water in future
successive dry years.
The Tier 1 Shortage Plan will expire at the end of the term of the WSA in 2034, unless the SFPUC
and the Wholesale Customers mutually agree to revise or terminate it prior to that date.
Tier Two Drought Allocations
The Wholesale Customers have negotiated and adopted the latest Tier 2 Plan , in 2025, which
allocates the Wholesale Customers’ Tier 1 Allocations from the Tier 1 Shortage Plan among
each of the 26 Wholesale Customers. These Tier 2 Allocations are based on a formula that takes
into account multiple factors for each Wholesale Customer including:
• Residential population;
• Non‐residential “base” (i.e., indoor) use;
• Seasonal uses;
• Total RWS purchases in recent non‐drought years; and
• Individual Supply Guarantee.
The Tier 2 Plan employs a structured, sequential, five‐step method to allocate water to each
Wholesale Customer. The allocations are constrained by minimum and maximum cutbacks,
which establish the maximum final allocation and minimum guaranteed final allocation,
respectively. No agency's final allocation can fall outside of these bounds. The allocation then
proceeds by prioritizing indoor uses.
The subsequent steps systematically allocate the remaining available water based on different
customer demands. First focusing on indoor demand, water is allocated based on an agency’s
residential population and the State residential efficient indoor standard (47 gallons per person
per day (GPCD) in 2025), followed by an allocation based on non‐residential “base” (i.e., indoor)
use. A limited amount of water is allocated based on seasonal use (e.g., cooling towers and
irrigation). Finally, the remaining supply is allocated based on a weighted share of two‐thirds
RWS purchases in the recent non‐drought years and one‐third ISG.
The result of the Tier 2 Plan is each Wholesale Customers’ proportion, expressed as a
percentage, of the available Tier 1 Allocation (Allocation Factor).
The Tier 2 Plan requires that the Allocation Factors be calculated by BAWSCA each year in
preparation for a potential water shortage emergency. As the Wholesale Customers change
their water use characteristics (e.g., increases or decreases in RWS purchases and use of other
water sources, changes in monthly water use patterns, or changes in population), the Allocation
Factor for each Wholesale Customer will also change. However, for long‐term planning
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purposes, each Wholesale Customer may use as its Allocation Factor, the value identified in the
Tier 2 Plan.
Water Supply Reliability Assessment Year‐Type Characterization (for RWS)
SFPUC Supply Modeled RWS Dry Year Supply Availability
The SFPUC used its Hetch Hetchy and Local Simulation Model (HHLSM) to perform the water
supply analyses for the supply reliability assessment and the drought risk assessment within the
2025 UWMP. HHLSM combines a historical record of hydrology from 1920 through 2025 with a
current representation of RWS infrastructure and operations. The simulated operations include
decisions on water supply rationing during droughts. The use of those results is described
below.
A key input for the HHLSM model is the anticipated level of demand on the RWS. Supply
modeling results presented in the 2025 UWMP reflect an input of projected demands on the
RWS consisting of (1) projected Retail Customer demands on the RWS (total Retail Customer
demands minus local groundwater and recycled water supplies), and (2) projected Wholesale
Customer purchases. The SFPUC has estimated total RWS demands for 2030 through 2050 and
used these estimates in HHLSM simulations of RWS water supply reliability. The SFPUC has a
Level of Service objective of meeting an average annual water demand of 265 mgd from the
SFPUC watersheds for Retail and Wholesale Customers during non‐drought years consistent
with the WSA, under which the SFPUC has a contractual obligation to supply up to 184 mgd to
the Wholesale Customers. Therefore, the SFPUC has also conducted modeling that assumes
Wholesale Customer demand is 184 mgd to facilitate planning that supports meeting this Level
of Service objective and contractual obligation.
In a normal year the SFPUC can provide up to 265 mgd of supply from the RWS. However,
within the context of this document, normal year RWS supply is defined as the supply that will
be used to meet the full demands on the RWS in a non‐drought year.
Regional Plans to Ensure a Reliable Water Supply
The City has also been implementing, and plans to continue to implement, the demand
management measures described in Section 5 – Demand Management Measures. Further, to
address potential future dry year supply shortfalls, the City has developed a robust WSCP that
systematically identifies ways the City can reduce water demands.
At a regional level, the City maintains active involvement in the efforts led by SFPUC and
BAWSCA to optimize the use of regional water supplies and pursue additional supplies.
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Strategy 2050 Future Water Supply Projects and Programs
The City is supporting BAWSCA in the development of its Long‐Term Reliable Water Supply
Strategy 2050 (Strategy 2050), a regional assessment of Member Agencies’ water supply needs.
Strategy 2050 will identify the water supply and demand management needs and opportunities
for the BAWSCA region and establish a framework to collectively support water reliability and
resilience. The main objectives of Strategy 2050 include:
• Providing a comprehensive picture of the region's supply and demand management
needs and options;
• Establishing a framework for collectively maintaining and improving regional water
supply reliability and resilience;
Elevating awareness of and supporting the region’s interests in new and emerging
regulations that impact water supply and demand management;
• Expanding regional dialogue and collaboration to collectively address common needs;
• Closing the gap on funding needed for water supply resilience and reliability; and
• Supporting availability of affordable water supplies and demand management strategies
to all customers.
Strategy 2050 is actively evaluating opportunities to enhance water supply reliability in the
BAWSCA region, including projects involving physical infrastructure and actions involving non‐
infrastructure interventions, such as policies, programs, and/or contractual agreements. A total
of 70 local and regional projects and actions (P&As) will be considered, including stormwater
capture projects, technical assistance programs for onsite reuse, groundwater banking
partnerships, new and replacement well projects, and interties development and optimization,
among others. Strategy 2050 will evaluate the impacts of these P&As on the water supply
reliability under the range of potential future conditions and make recommendations on
priorities and next steps for implementation.
Strategy 2050 plan is anticipated to be completed by 2027. From 2027 onward, the Strategy
2050 effort is anticipated to involve implementing the actions identified in the plan, tracking
and reporting on the progress, and incorporating the findings from the implementation
activities into BAWSCA’s following fiscal year Work Plan.
WSIP Dry Year Water Supply Projects
With WSIP, the SFPUC has undertaken several water supply projects to meet dry‐year demands.
Those projects include the following:
• Calaveras Dam Replacement Project. Calaveras Dam is in the East Bay near a seismically
active fault zone, and following the Loma Prieta earthquake in 1989, it was determined
to be seismically vulnerable. To address the dam’s vulnerability, the SFPUC constructed a
new dam of equal height downstream of the existing dam. This project was completed in
2022. Calaveras Reservoir was completely refilled in 2023 and is now operating at full
capacity.
• Alameda Creek Recapture Project. The Alameda Creek Recapture Project includes new
facilities in and around an existing quarry pit in Sunol Valley to recover the loss of water
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supply associated with instream flow release and bypass requirements related to the
Calaveras Dam Replacement Project. The project is anticipated to be completed in 2032.
• Lower Crystal Springs Dam Improvements. The Lower Crystal Springs Dam Improvements
Project was completed in May 2012. The related joint San Mateo County/SFPUC Bridge
Replacement Project to replace the bridge across the Lower Crystal Springs Dam was
completed in January 2019.
• Regional Groundwater Storage and Recovery Project. The Regional Groundwater
Storage and Recovery (RGSR) Project is a strategic partnership between the SFPUC and
three Wholesale Customers in San Mateo County: the California Water Service Company
(serving South San Francisco and Colma), the City of Daly City, and the City of San Bruno.
The project sustainably manages groundwater and surface water resources to provide the
RWS with additional supplies during times of drought. During years of normal or heavy
rainfall, the SFPUC provides additional surface water from the RWS to the three agencies
in northern San Mateo County, allowing them to reduce the amount of groundwater that
they pump from the southern Westside Groundwater Basin. Over time, the reduced
pumping allows the aquifer to naturally recharge and result in increased groundwater
storage of up to 61,000 acre‐feet of new water supply available during dry years. As of
December 2025, the SFPUC had accumulated approximately 14 billion gallons of
groundwater storage credits (about 43,093 acre‐feet) through the project.
The RGSR project has two phases. Phase 1, which included building thirteen production
wells and treatment facilities, is complete. Phase 2 design began in early 2020 and
covers rehabilitating and reinstalling well pumps, installing two new variable frequency
drivers, and conducting start‐up testing and well disinfection. Pumps at the Hickey,
Southwood Drive, and Mission well were rehabilitated, packed, and stored due to staff
shortages, operational challenges, and elevated ammonia levels at the Southwood Drive
well; they may be reinstalled later. Construction on Phase 2B began in 2024 and would
transport groundwater from SFPUC South San Francisco Main Well to California Water
Service Company Treatment Station in South San Francisco. The project will make
improvements at the existing well site which includes mechanical, electrical, structural,
and corrosion protection upgrades. The SFPUC also prepared a conceptual engineering
report and initiated design work for additional treatment to address the high ammonia
levels at the South Spruce Lane Well and Treatment Facility. Minor amounts of
groundwater pumping from RGSR wells have occurred during start‐up testing and
monthly maintenance.
• Regional Groundwater Treatment Improvements Project. The SFPUC approved this new
project in the 10‐Year Water Enterprise Capital Improvement Program for FY 2021‐2030.
The project includes treatment facilities for several of the RGSR project wells to address
groundwater quality issues that have emerged since the wells were constructed.
• Water Transfers. During the planning and implementation of the WSIP, the SFPUC
pursued a long‐term agreement to transfer 2 mgd from Modesto irrigation District to the
SFPUC in drought years. Negotiations with Modesto Irrigation District ended in 2012
when an agreement could not be reached. The dry‐year transfer project is now being
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included as part of the new SFPUC Alternative Water Supply Program and is described in
further detail below.
Alternative Water Supply Program
In 2019, the SFPUC established the Alternative Water Supply (AWS) Program to identify and
plan water supply and storage projects and actions that increase the dry‐year reliability of the
RWS. Based on the 2045 planning horizon that the SFPUC applied in its February 2024 AWS
Plan, the SFPUC anticipates a water supply gap will occur in future dry years. The AWS Program
aims to help fill the gap through local and regional capital projects. The February 2024 AWS
Plan identified six regional projects that might partially address the future water supply gap and
the priorities for this planning effort. Since the development of that plan, three projects have
been deferred (Daly City Recycled Water Expansion, Alameda County Water District‐Union
Sanitary District Purified Water, and Calaveras Reservoir Expansion) and one project has been
canceled (Los Vaqueros Reservoir Expansion). The AWS Program is continuing to pursue the
following two projects:
• PureWater Peninsula. PureWater Peninsula (formerly known as the Crystal Springs
Purified Water Project) is a purified water project that could provide 6 mgd of additional
potable water supply to the RWS through surface water augmentation at the SFPUC’s
Crystal Springs Reservoir. The currently proposed project involves treating wastewater
effluent from Silicon Valley Clean Water at a new advanced purified water facility located
on the Peninsula and transmitting that purified water to Crystal Springs Reservoir, where
it would blend with RWS surface water supplies before the SFPUC treats it again at Harry
Tracy Water Treatment Plant. A future phase could provide an additional 6 mgd of
additional potable water supply to the RWS. Project partners include the SFPUC, Silicon
Valley Clean Water, BAWSCA, Mid‐Peninsula Water District, California Water Service
Company, City of Redwood City, City of Foster City, and City of San Mateo.
• South Bay Purified Water. In 2023, the SFPUC, the City of San Jose, and the City of Santa
Clara completed an initial feasibility study for the South Bay Purified Water project,
envisioned as a 10 mgd purified water project that would serve the local demands of San
Jose and Santa Clara during all types of water years and deliver an additional volume of
water supply to the RWS in dry years. Currently, Santa Clara Valley Water District (Valley
Water) is working with San Jose and Santa Clara to design a larger project to meet broader
regional needs. The SFPUC’s participation in this project will be based on the regional
benefits to the RWS customers. This project may also assist the SFPUC with its decision
regarding San Jose and Santa Clara’s status as RWS customers, discussed above.
If both AWS projects that SFPUC staff has identified through the current planning process can
be implemented, there would still be a supply shortfall to meet projected needs associated with
implementation of the Bay‐Delta Plan Amendment. Furthermore, both alternative water supply
options are in the planning phase and are subject to changes in institutional structure and
design. Given the limited availability of water supply alternatives, unless the supply risks are
significantly reduced, the SFPUC will continue to plan, develop, and implement all potential
projects that can help bridge the anticipated water supply gap during droughts.
Outside of the AWS Program, the following additional regional projects are included in the
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Agreements to Support Healthy Rivers and Landscapes discussed in the Bay‐Delta Plan
Amendment section above. Progress on these water supply options will be guided by scientific
monitoring and collaborative decision making.
• Groundwater Banking. Groundwater banking projects in the Modesto Irrigation District
and Turlock Irrigation District service areas could provide the SFPUC with some additional
water supply to meet instream flow releases in dry years, reducing water supply impacts
on the RWS. A feasibility study of this option is included in the Agreements to Support
Healthy Rivers and Landscapes.
• Inter‐Basin Collaborations. Inter‐Basin Collaborations could include establishing a
partnership between interests on the Tuolumne River (such as the SFPUC) and those on
the Stanislaus River, which would allow responsibility for streamflow to be assigned
variably based on the annual hydrology. The Tuolumne system tends to spill more excess
flow in wetter years than the Stanislaus system, and this excess flow could be shaped and
credited to meet Stanislaus system requirements, while New Melones Reservoir in the
Stanislaus system is refilling. Then the stored water could be partially used to provide
required streamflow to meet Stanislaus and Tuolumne requirements in future dry years.
• Dry‐Year Transfers. The SFPUC initiated discussions with irrigation districts under WSIP
to secure a dry‐year transfer (see WSIP Dry‐Year Water Supply Projects section above).
While no transfer was secured, the SFPUC continues to engage in discussions with
irrigation districts to explore potential transfer opportunities.
The SFPUC’s AWS Plan published in February 2024 included a planning framework for the
SFPUC to consider water supply needs and related tradeoffs; guide the decisions to proceed
with environmental review; and continue the development of projects that can best meet
anticipated water supply needs. In June 2025, the SFPUC prepared a progress report that
provided status updates on the AWS projects. In 2027, the SFPUC plans to review and revise its
Alternative Water Supply Plan based on updated information.
Drought Risk Assessment
In addition to the long‐term water service reliability assessment presented above, the Drought
Risk Assessment (DRA) evaluates the City’s supply risks under a severe drought period lasting
for the next five consecutive years after the assessment is completed (i.e., from 2026 through
2030). The DRA is intended to inform the demand management measures and water supply
projects and programs to be included in the UWMP (see DWR Sections 6 and 9). Suppliers may
conduct an interim update or updates to this DRA within the five‐year cycle of its UWMP
update (i.e., before the 2030 UWMP).
Data, Methods, and Basis for Water Shortage Condition
As a first step to the DRA, the City estimated unconstrained water demand for the next five
years. Unconstrained water demand is the expected water use in the absence of drought water
use restrictions. The characteristic five‐year water demand is from the 2025 Demand Study, a
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uniform demand and conservation savings projection for each Member Agency developed by
BAWSCA and further described in Section 4 – Water Demand.
Individual Water Source Reliability
The available water supplies assumed in the DRA are based upon the same methodology and
assumptions used for the long‐term water service reliability assessment, provided in
DWR Section 7.2, and relies on information provided by SFPUC and BAWSCA.
The data and methods used to determine the RWS supply for the DRA dry‐year sequence are
the same as those described in the “SFPUC Supply Modeled RWS Dry Year Supply Availability”
section. The SFPUC used the HHLSM with the design drought sequence to perform the water
supply analyses and simulate the water supply shortage conditions over the five‐year drought
period.
Because the start date of the implementation of the Bay‐Delta Plan Amendment is unknown,
the DRA considers the supply scenario without the implementation of the Bay‐Delta Plan
Amendment.
Climate Change
Climate change has become an important factor in water resources planning in California and is
frequently considered in urban water management planning, although the extent and precise
effects of climate change remain uncertain. Increasing concentrations of greenhouse gases
have caused and will likely continue to cause a rise in temperatures around the world, which
will result in a wide range of changes in climate patterns. Moreover, observational data show
that a warming trend occurred during the latter part of the 20th century, the first quarter of the
21st century, and will likely continue through the end of the 21st century. Numerous studies
have been conducted to determine the potential impacts of climate change on water resources.
These climate change impacts are likely to affect both the Tuolumne River watershed and local
watersheds in the Bay Area and include the following:
• Reductions in the average Sierra Nevada annual snowpack due to a rise in the snowline
elevation and a shallower snowpack at lower elevations, and a shift in snowmelt runoff
to earlier in the year;
• Changes in the timing, annual average, intensity, and variability of precipitation, and an
increased amount of precipitation falling as rain instead of as snow;
• Long‐term changes in watershed vegetation and increased incidence of wildfires that
could affect water quality and quantity;
• Sea level rise and an increase in saltwater intrusion;
• Increase in water temperatures with accompanying potential adverse effects on some
fisheries and water quality;
• Increases in evaporation and concomitant increase in irrigation need; and
• Changes in urban and agricultural water demand.
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SFPUC Climate Change Studies
The SFPUC views assessment of the effects of climate change as an ongoing need that requires
regular updating to reflect improvements in climate science, atmospheric/ocean modeling,
observations, and human response to the threat of greenhouse gas emissions. Climate change
research by the SFPUC began in 2009 and continues to be refined.
The SFPUC partnered with The Water Research Foundation to develop the Long Term
Vulnerability Assessment (LTVA) of the RWS. The study was conducted by the University of
Massachusetts Amherst Hydrosystems Research Group with input from National Center for
Atmospheric Research, other climate scientists, and Deltares. The goal of the LTVA is to help
quantitatively and qualitatively assess to what extent climate change will be a threat to the
RWS in comparison to, or in combination with, other external drivers of change over the 50
year period, 2020‐2070. The LTVA assessed the potential effects of climate change on RWS
water supply using a wide range of plausible increases in temperature and changes in
precipitation to address the wide uncertainty in climate projections over the planning horizon.
There are many uncertain factors, such as climate change, changing regulations, water quality,
growth and economic cycles, that may create vulnerabilities for the RWS’s ability to meet Levels
of Service. The uncertainties associated with the degree to which these factors will occur and
how much risk they present to the water system are difficult to predict but were considered in
this study. To address this planning challenge, the LTVA used a vulnerability‐based planning
approach to explore a range of future conditions to identify vulnerabilities, and to assess the
risks associated with these vulnerabilities, that could lead to developing an adaptation plan that
is flexible and robust to a wide range of future outcomes. The LTVA was completed in 2021 and
the University of Massachusetts Amherst and The Water Research Foundation amended it in
2024.
The key findings of the LTVA are:
• Climate change exacerbates impacts from other external drivers of change and is not
the single most important driver of vulnerability for the RWS.
• The RWS at a baseline demand of 227 MGD is resilient to changes in climate and other
external drivers.
• The RWS water supply performance declines with reductions in mean precipitation but
is mostly insensitive to increases in temperature.
• The RWS is more vulnerable to changes in demand and instream flow requirements
than changes in mean annual temperature and precipitation.
• The RWS is vulnerable to changes to mean climate when demand or regulatory instream
flow requirements increase.
Further results and conclusions from the LTVA and its amendment are provided below:
• According to climate projections and expert elicitations, there is a central tendency of
warming of +2°C and +4°C by 2040 and 2070 (Representative Concentration Pathway
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[RCP] 8.5), respectively, with no clear direction of change in mean annual precipitation
over the planning horizon.
• In the upcountry region, by 2040, most projections and elicitations of warming estimate
between +1°C and +4°C, and precipitation changes range between ‐5% and +5%,
compared to historical baseline; and by 2070, estimates of warming range between +3°C
and +6°C, and precipitation changes range between ‐15% and +15% (RCP8.5).
• Changes in hydrology due to climate change affect the RWS’s ability to meet water
supply targets. At 227 MGD baseline demand, the RWS can sustain up to +4°C and ‐5%
precipitation change before failing to meet targets for delivery reliability, frequency of
20% rationing, storage reliability, and duration of rationing.
• Precipitation change is an important driver for RWS performance. A decrease by 10% or
more will cause RWS water supply targets to be missed. The climate projections and
expert elicitations show that such a change in precipitation is possible by 2040, although
unlikely. The likelihood of this change increases toward 2070.
• The RWS shows minor sensitivity to temperature change for the metrics evaluated in
this study. Most metrics stay above target under warming conditions. However,
warming conditions often magnify the loss in system performance if precipitation or
demand change.
• Demand change appears to be a major driver of future RWS performance. An increase in
demand by 15% (265 MGD) will lead to failure to meet rationing frequency targets
under current climate conditions. At 265 MGD demand, the rationing frequency targets
would be met if there is an increase in precipitation of 10%. If demand increases by 30%,
the rationing target cannot be met even when precipitation increases by 40%, which is
believed plausible but unlikely over the planning horizon.
• The RWS is particularly vulnerable to the state‐amended new instream flow
requirements below Don Pedro Dam, which represents a huge reduction in water
available. Under all demand and climate scenarios, the system reliability, defined as
frequency of years without rationing, remains below 5%.
• The RWS is also vulnerable to the draft Tuolumne voluntary agreement new instream
flow requirements below Don Pedro Dam, which represents a large reduction in water
available, although significantly less than for the state‐amended new instream flow
releases. The implementation of the draft Tuolumne voluntary agreement under current
climate and demand conditions would reduce the system reliability to 75%, which
corresponds to the effects of a reduction in average rainfall by 20% under the current
Federal Energy Regulatory Commission agreement.
Local Plans to Ensure a Reliable Water Supply
The City has been a leader in combating climate change while recognizing that its impact will
not be avoided and mitigation measures will be needed. To that end, the City adopted a Sea
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Level Rise Adaptation Policy in March 2019 56. In June 2022, the City completed a Sea Level Rise
Vulnerability Assessment, which documents potential sea level rise hazards to the City and
community assets. It will inform subsequent development of a Sea Level Rise Adaptation Plan
that will address the identified flood susceptibilities caused by sea level rise and rising shallow
groundwater levels. In September 2025, construction began on the Palo Alto Horizontal Levee
Pilot Project. It is the first horizontal levee to be built in the San Francisco Bay that beneficially
reuses treated wastewater for irrigation and helps the marsh adapt as sea level rises.
The City has completed several studies and projects regarding water supply reliability. In 2024,
the City completed its One Water Plan which presents a vision and achievable path toward
meeting the City’s long‐term water supply and water conservation goals by identifying
alternatives for the City that, if implemented, may mitigate the impact of future water supply
uncertainties such as severe multi‐year drought, changes in climate, water demand, and
regulations. The One Water Plan includes a comparative scoring of seven water supply and
conservation portfolios to support future evaluation and refinement. 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.
The City has also been implementing, and plans to continue to implement, the demand
management measures described in Section 5 – Demand Management Measures. Further, to
address potential future dry year supply shortfalls, the City has developed a robust WSCP that
systematically identifies ways in which the City can reduce water demands.
At a regional level, the City maintains active involvement in the efforts led by SFPUC and
BAWSCA to optimize the use of regional water supplies and pursue additional supplies.
Section 7 – Water Shortage Contingency Plan
Law
10632. (excerpts)
(a) Every urban water supplier shall prepare and adopt a water shortage contingency plan as part
of its urban water management plan that consists of each of the following elements:
(1) The analysis of water supply reliability conducted pursuant to Section 10635.
(2) The procedures used in conducting an annual water supply and demand assessment....
(3) (A) Six standard water shortage levels corresponding to progressive ranges of up to 10, 20, 30,
40, and 50 percent shortages and greater than 50 percent shortage….
56 See Palo Alto’s Seas Level Rise Adaptation Policy:
https://www.paloalto.gov/files/assets/public/v/1/sustainability/sea‐level‐rise/slr‐adaptation‐
policy_web.pdf?t=71340.78
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(4) Shortage response actions that align with the defined shortage levels….
(5) Communication protocols and procedures to inform customers, the public, interested parties,
and local, regional, and state governments regarding, at a minimum, all of the following:
(A) Any current or predicted shortages as determined by the annual water supply and demand
assessment described pursuant to Section 10632.1. (B) Any shortage response actions triggered
or anticipated to be triggered by the annual water supply and demand assessment described
pursuant to Section 10632.1. (C) Any other relevant communications.
(6) For an urban retail water supplier, customer compliance, enforcement, appeal, and
exemption procedures for triggered shortage response actions….
(7) (A) A description of the legal authorities that empower the urban water supplier to
implement and enforce its shortage response actions specified in paragraph (4) that may include,
but are not limited to, statutory authorities, ordinances, resolutions, and contract provisions.
(B) A statement that an urban water supplier shall declare a water shortage emergency in
accordance with Chapter 3 (commencing with Section 350) of Division 1. (C) A statement that an
urban water supplier shall coordinate with any city or county within which it provides water
supply services for the possible proclamation of a local emergency, as defined in Section 8558 of
the Government Code.
(8) A description of the financial consequences of, and responses for, drought conditions….
(9) For an urban retail water supplier, monitoring and reporting requirements and procedures
that ensure appropriate data is collected, tracked, and analyzed for purposes of monitoring
customer compliance and to meet state reporting requirements.
(10) Reevaluation and improvement procedures for systematically monitoring and evaluating the
functionality of the water shortage contingency plan in order to ensure shortage risk tolerance is
adequate and appropriate water shortage mitigation strategies are implemented as needed.
Background
Except for recycled water, the City does not currently produce any of its own water supplies,
but is dependent upon its suppliers. The City’s primary supplier is the SFPUC. The SFPUC is the
only supplier in normal years. The City’s five older wells have been refurbished and the City
completed construction of three new wells to remain in standby for use during emergencies
and potentially to supplement the SFPUC supply during a severe drought. Valley Water
manages the county’s groundwater and levies a groundwater extraction fee for all water
produced by the wells within its jurisdictions.
To meet the requirements of the Urban Water Management Planning Act and for the purposes
of this document, a distinction will be made between a catastrophic interruption of water
supplies and a water shortage due to drought. A catastrophic interruption of water supplies
may occur due to natural disasters such as an earthquake or due to a sudden problem with
water quality, or because of sabotage or terrorism. A water shortage due to drought is a more
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likely occurrence. The City has experienced four drought water shortages in the past 35 years,
in 1976‐1977, from 1987‐1993, 2014‐2016, and 2020‐2023.
Preparation for Catastrophic Supply Interruption
The SFPUC maintains various planning documents and strategies that collectively address its
emergency preparedness and planned response in the event of a catastrophic interruption of
water supplies due to power outages, earthquakes, or other disasters. These plans are
described in the following subsections: (1) Emergency Preparedness Plans, (2) Emergency
Drinking Water Planning, and (3) Power Outage Preparedness and Response. The Seismic Risk
Assessment and Mitigation Plan section that follows this section addresses the seismic risk
assessment and mitigation plan required by California Water Code Section 10632.5(a). Should a
catastrophic interruption occur, the SFPUC will coordinate with any city or county within which
it provides water for the possible proclamation of a local emergency (California Government
Code, California Emergency Services Act Article 2, Section 8558).
Emergency Preparedness Plans
Following the 1989 Loma Prieta earthquake, the SFPUC created a departmental Emergency
Operations Plan (EOP). The SFPUC EOP was originally released in 1992 and has since been
updated as necessary. The SFPUC EOP addresses a broad range of potential emergency
situations that may affect the SFPUC and supplements the City and County of San Francisco’s
Emergency Response Plan, which was prepared by the SF Department of Emergency
Management and most recently updated in 2017. Specifically, the purpose of the SFPUC EOP is
to describe the SFPUC’s emergency management organization, roles and responsibilities, and
emergency policies and procedures. In 2025, the SFPUC developed a Water Emergency
Operations Plan (Water EOP) to comply with the America’s Water Infrastructure Act passed in
2018. The Water EOP integrates directly into, and functions as an annex to, the SFPUC EOP. The
Water EOP addresses SFPUC water transmission and distribution systems and identifies the
agency’s enterprises, divisions, and bureaus with direct roles and responsibilities for those
systems.
In addition, the SFPUC’s enterprises each have their own emergency plans (in alignment with the
SFPUC EOP), which detail that entity’s specific emergency management organization, roles and
responsibilities, and emergency policies and procedures. The SFPUC EOP functions as a front end
for the SFPUC’s enterprise EOPs, covering emergency response at the department level; while
each EOP covers enterprise‐specific information on the enterprise’s emergency organization
and response procedures specific to enterprise responsibilities, assets, technical scope, and
operations. The SFPUC exercises its EOPs on a regular basis by conducting emergency exercises
and through real‐world responses. Through these exercises and activations, the SFPUC learns
how well the plans and procedures will or will not work in response to an emergency. EOP
improvements are based on the results of these exercises and real‐world event response and
evaluation. The SFPUC also has an emergency response training plan that is based on federal,
State, and local standards and exercise and incident improvement plans. SFPUC employees have
emergency training assignments based on their emergency response roles, as identified in the
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EOPs.
The types of events affecting the SFPUC that require emergency plans include but are not limited
to:
• Major earthquake
• Loss of power
• Loss of water supply
• Major fire
• Hazardous material release that threatens water supply or environment
• Major pipeline breaks
• Dam incident
• Significant outage of SFPUC services
• Man‐made or intentional acts of terrorism resulting in damage to the system or
interruption in service
In addition to the documents described above, the SFPUC also maintains various plans and
procedures that deal with the possibility of alternate supply schemes and options. These plans
and procedures include:
• Emergency Disinfection and Recovery Plan
• Emergency Response Action Plan
• Emergency Drinking Water Equipment and Alternatives Report
• Disinfection of SFPUC Water Trailers Procedure
• San Francisco Water Division Hydrant Manifold Standard Operating Procedure
Emergency Drinking Water Planning
The SFPUC has implemented several projects to increase its capability to provide emergency
drinking water during an emergency. These projects include:
• Completion of many WSIP projects and other capital upgrades to improve security,
detection, and communication (see the Seismic Risk Assessment and Mitigation Plan
section);
• Development of public information and educational materials for residents and
businesses;
• Construction of six wells as part of the San Francisco Groundwater Supply Project, two
of which also serve as emergency drinking water supplies, including a distribution
system to fill emergency water tankers;
• Purchase and engineering of emergency‐related equipment, including water tanker
trucks and water distribution manifolds, to help with distribution post‐disaster; and
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• Coordination of planning with other City and County of San Francisco departments,
neighboring jurisdictions, and other public and private partners to maximize resources
and supplies for emergency response.
The SFPUC also maintains a Water Quality Notifications and Communications Plan. Initially
prepared in 1996 and most recently updated in 2022, this plan provides contact information
and guidelines on notifications that the SFPUC staff will issue in the event of water quality
impacts that warrant communications internally and externally with the State, the Wholesale
Customers, and/or public. The plan treats water quality issues as potential or actual supply
problems, which fall under the emergency response structure of the SFPUC EOP.
Power Outage Preparedness and Response
The SFPUC’s water transmission system is primarily gravity fed from Hetch Hetchy Reservoir to
San Francisco. Within San Francisco’s distribution system, key pump stations have generators
on site, and all others have connections in place that would allow the use of portable
generators.
Although power outages would not greatly impact water conveyance throughout the RWS
because it is gravity fed, the SFPUC has prepared for potential regional power outages as
follows:
• The Tesla Treatment Facility, the SVWTP, the Sunol Valley Chloramination Facility (SVCF),
and the San Antonio Pump Station (SAPS) have back‐up power on site in the form of
generators. Additionally, SVWTP, SVCF, and SAPS would not be impacted by a failure of
the regional power grid because these facilities are powered by hydropower generated
by Hetch Hetchy Water and Power via the Calaveras Substation.
• Both the HTWTP and the Baden Pump Station (part of the Peninsula System) have back‐
up generators in place.
• Administrative facilities that may act as emergency operation centers also have back‐up
power.
• The SFPUC has an emergency water supply connection with Valley Water, known as the
Valley Water intertie, which also has back‐up generators in place.
• Additionally, as described in the next section, various WSIP projects expanded the
SFPUC’s ability to remain in operation during power outages and other emergency
situations.
Seismic Risk Assessment and Mitigation Plan
As part of the SFPUC’s Facilities Reliability Program and WSIP, the SFPUC performed an
extensive multi‐year evaluation of seismic risks to its water system that resulted in major
capital improvements to increase seismic reliability. The goals of WSIP include enhancing the
ability of the SFPUC water system to meet identified levels of service goals for water quality,
seismic reliability, delivery reliability, and water supply. One of the reasons the SFPUC
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developed WSIP was to reduce the likelihood of shortages, thereby reducing the likelihood of
needing to implement the WSCP. Several WSIP projects located in San Francisco improved the
seismic reliability of the in‐City distribution system, such as additional wells that can be used as
emergency drinking water sources. Many WSIP projects related to the RWS outside of San
Francisco, the majority of which are now complete, addressed both seismic reliability and
overall system reliability. The SFPUC completed the San Francisco portion of WSIP as of October
2020 and forecasts that the overall WSIP will be complete in June 2032.
The Levels of Service (LOS) Goals and Objectives for seismic reliability informed development of
WSIP capital projects and guided program implementation. The LOS established post‐
earthquake delivery and recovery objectives under the following seismic scenarios:
• Magnitude 7.9 event on the San Andreas fault
• Magnitude 7.3 event on the Hayward fault
• Magnitude 6.9 event on the Calaveras fault
An assessment of seismic risk and resilience is contained in the body of analysis performed to
support the WSIP. The risks associated with the seismic scenarios considered are reflected in
the delivery objectives established in the LOS, specifically:
• Delivery of winter month demand 24 hours after a major earthquake, and
• Delivery of average day demand 30 days after a major earthquake
In addition to the improvements that have or will come from the WSIP, the SFPUC has already
constructed system interties for use during catastrophic emergencies, short‐term facility
maintenance and upgrade activities, and times of water shortages. These are listed below:
• An intertie that may transfer up to 30 mgd between the SFPUC and East Bay Municipal
Utilities District (EBMUD) systems, allowing EBMUD to serve the City of Hayward (an
SFPUC Wholesale Customer) and/or supply the SFPUC directly (and vice versa);
• An intertie that may transfer up to 40 mgd between the SFPUC and Valley Water systems;
and,
• An intertie between the SFPUC the South Bay Aqueduct that the SFPUC used in 1991‐1992
and may upgrade to enable the SFPUC to receive State Water Project water in the event
of a future emergency.
The WSIP also includes projects related to standby power facilities at various locations. These
projects provide for standby electrical power at six critical facilities to keep them in operation
during power outages and other emergency situations. Permanent engine generators are
located at four locations (San Pedro Valve Lot, Millbrae Facility, Alameda West, and Harry Tracy
Water Treatment Plant), while hookups for portable engine generators are at two locations
(San Antonio Reservoir and Calaveras Reservoir).
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The City and County of San Francisco also has a Hazards and Climate Resilience Plan 57 which
was last updated in July 2025. This plan is a roadmap to minimizing the impacts of natural
hazards and climate change on buildings, infrastructure, and communities. The plan also serves
as San Francisco’s Local Hazard Mitigation Plan which it updates every five years to include the
latest understanding of natural hazards and climate change impacts, local risks, and community
priorities. Examples of hazards analyzed in the plan include dam or reservoir failure, flooding,
drought, and wildfire.
Local Distribution System Reliability
The City has improved its emergency supply preparedness by rehabilitating five existing wells,
drilling three new wells, and building an additional water storage reservoir.
The City also maintains several critical interconnections with neighboring water utilities as shown
in Table 18. These interties can be activated during critical events to ensure water supplies are
not impacted and also to provide mutual aid to neighboring communities.
Table 18: Interties with other Agencies
Name Number Diameter (inches)
East Palo Alto 1 6
Mountain 2 6
Stanford 2 8
Purissima Hills WD 2 8,12
Emergency Operations Plan
Response to a catastrophic interruption of supply is handled through a series of interconnected
plans. All Disaster or Act of War Plans, from the state to local levels, use the Federal Civil
Defense and Emergency Planning systems as role models with additions that take into
consideration any unique conditions or situations that may exist within their jurisdictions.
At the national level, the Federal Emergency Management Agency (FEMA) controls all functions
of Civil Defense or Emergency Planning for the Federal Government. FEMA will not assume
control of an emergency until the President declares a State of Emergency or an Act of War
occurs. At that point FEMA will assume control through the State of California Office of
Emergency Services (State OES) and make available all of its resources.
At the state level, the State OES will control any disaster within the state and make its resources
available after a State of Disaster has been declared by the governor. The State OES further
controls the Master Mutual Aid Agreement that can also be used in a local disaster (the City is a
57 The 2025 Hazards and Climate Resilience Plan may be accessed at https://www.onesanfrancisco.org/hazards‐
and‐climate‐resilience‐plan.
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member of California’s Water Agency Response Network, Region 2, a mutual aid system for
water utilities, in accordance with State requirements).
At the county level, the Santa Clara County OES will control the unincorporated areas of the
County. It will coordinate mutual aid within the County and act as an intermediary between local
governments or utilities and the State mutual aid office.
On the city level, the City will control all emergencies according to its Emergency Operations
Plan 58. The Mayor, City Council or City Manager may declare an emergency at which time
representatives of all City departments will report to the Emergency Operations Center. The
roles and responsibilities of the Utilities Department for water supply is listed in the Emergency
Operations Plan.
The City of Palo Alto Utilities Department Emergency Operations Plan (the Utilities EOP) covers
any emergency curtailment of water supplies. The Utilities EOP contains a detailed outline of
actions to be taken and procedures to be followed by utility personnel in event of a water
emergency. This plan is maintained by the Utilities Department.
The Utilities EOP Plan is designed as both an outline and a procedures manual. It covers the
following primary functions:
1) Notification Procedures;
2) Water Mutual Aid Agreement;
3) Radio/Telephone /Communications;
4) Water Receiving Station and Reservoir Check List;
5) Boil Water Notifications;
6) Highest Water Use Customer Load Reduction List;
7) Water Interconnect Locations; and
8) Disinfecting of Water Mains.
58 Staff Report #2510‐5338:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=83775&dbid=0&repo=PaloAlto&searchid=7afecf90‐
52e8‐4cef‐9406‐83e090f7f4ae&cr=1
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Water Supply and Demand Assessment
Law
10632. (excerpts)
(a) Every urban water supplier shall prepare and adopt a water shortage contingency plan as
part of its urban water management plan that consists of each of the following elements:
…(2) The procedures used in conducting an annual water supply and demand assessment that
include, at a minimum, both of the following:
(A) The written decision‐making process that an urban water supplier will use each year to
determine its water supply reliability.
(B) The key data inputs and assessment methodology used to evaluate the urban water supplier’s
water supply reliability for the current year and one dry year, including all of the following: (i)
Current year unconstrained demand, considering weather, growth, and other influencing factors,
such as policies to manage current supplies to meet demand objectives in future years, as
applicable. (ii) Current year available supply, considering hydrological and regulatory conditions
in the current year and one dry year. The annual supply and demand assessment may consider
more than one dry year solely at the discretion of the urban water supplier. (iii) Existing
infrastructure capabilities and plausible constraints. (iv) A defined set of locally applicable
evaluation criteria that are consistently relied upon for each annual water supply and demand
assessment. (v) A description and quantification of each source of water supply.
Decision‐Making Process to Determine Water Supply Availability
In June 2020, Palo Alto provided an example of an annual Water Supply and Demand
Assessment (Annual Assessment) report to support DWR in the development of guidelines for
AB 1668 and SB 606 implementation. To support this process, Palo Alto worked with the SFPUC
and BAWSCA to review existing water supply report processes and evaluate options to meet
the requirements of the legislation.
Palo Alto receives approximately 93% of its total water supply and 100% of its potable water
supply from SFPUC. The WSA between SFPUC and its Wholesale Customers requires SFPUC to
provide its Wholesale Customers with an initial assessment of water supply availability in each
February, followed by an update in March and a final assessment by April 15th of each calendar
year. These letters document whether SFPUC can provide full supplies for the coming water
year or whether rationing will be implemented. The determination of projected available water
supply considers, among other things, stored water, projected runoff, water acquired by the
SFPUC from non‐SFPUC sources, inactive storage, reservoir losses, allowance for carryover
storage, and water bank balances.
Data and Methodologies
Because Palo Alto relies on only one potable water supply source, SFPUC RWS water, the
Annual Assessment will rely on key data inputs from the SFPUC.
1. Evaluation Criteria
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In April of each year, the SFPUC provides an assessment of the water supply situation
and alerts the Wholesale Customers of any voluntary or mandatory water use reduction
requirements. The SFPUC’s assessment of the water supply situation will serve as the
City’s evaluation criteria.
2. Water Supply
Palo Alto relies on RWS water for 100% of its potable water supply. Recycled water is
used on a limited basis for irrigation and industrial uses and cannot replace potable
water supplies in any significant way. Groundwater may be available to supplement
potable water needs in extreme circumstances.
3. Unconstrained Customer Demand
Palo Alto will utilize the best available information to date, typically including the
previous year’s demands as well as consideration of current demand use patterns or
other conditions impacting demands, to determine unconstrained demand. If significant
land use or customer water use changes have occurred, the input data will be updated
to reflect those changes.
4. Planned Water Use for Current Year Considering Dry Subsequent Year
Evaluation of how anticipated supplies for the particular coming year will be used, while
anticipating that the following year will be dry. Each year’s assessment is informed by
the characterizations in Section 6 – Water Supply Reliability and other current pertinent
factors and considerations.
5. Infrastructure Considerations
Any local Palo Alto capital projects that may impact delivery capacity such as main
replacements or emergency groundwater well work will be considered. The SFPUC’s
water supply assessment will take into consideration capacity constraints on the RWS.
6. Other factors
Because groundwater in Santa Clara County is managed by Valley Water, Palo Alto will
take into consideration any water use reductions anticipated to be implemented by
Valley Water for the coming year when deciding whether or not to incorporate
groundwater into the City’s supply for the following year.
Notification and Approval of Response Actions
If the Annual Assessment anticipates a water shortage for the following year, the results of the
Annual Assessment will be presented and discussed at a UAC meeting along with information
and staff recommendations regarding specific WSCP response actions triggered by the Annual
Assessment results. City Council will then be notified of the Annual Assessment results and
staff will request Council approval to implement the WSCP response actions triggered.
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SFPUC Annual Water Supply and Demand Assessment Procedures
The SFPUC has a robust process for assessing its annual water supply and demand. This process
involves considering a range of input factors unique to the SFPUC’s water supplies and system
configuration and provides the SFPUC with flexibility to consider new factors. The SFPUC
reports on an assessment of its system’s water supply and demand to the State through the
following methods:
• On or before July 1 of each year, the SFPUC prepares a Water Supply and Demand
Assessment (WSDA), consistent with California Water Code Section 10632.1
requirements, by evaluating the total amount of water it expects to be in storage within
the RWS that year and comparing that amount to expected Retail and Wholesale
Customer demands. The following subsections outline the SFPUC’s procedures for
preparing the annual WSDA.
• Every month, the SFPUC completes the SWRCB’s Drought and Conservation Reporting
on the SAFER Clearinghouse online portal.
Demand Assessment
To calculate unconstrained customer demand on the RWS for the purpose of its annual WSDA,
the SFPUC collects information on the demands of both the retail and wholesale customers.
The SFPUC estimates Retail Customer demand based on the best available information to date,
typically including the previous year’s demands as well as consideration of current demand use
patterns or other conditions impacting demands, such as weather and growth. For estimated
wholesale demands, each February, the SFPUC receives from BAWSCA a report of estimated
Wholesale Customer demands on the RWS for the upcoming year. BAWSCA compiles this
report based on demand estimates it receives from each of its 26 Member Agencies. The SFPUC
estimates the relatively small demands of Cordilleras Mutual Water Company and Groveland
Community Services District, its other two wholesale customers for the purposes of its UWMP,
that are not parties to the WSA and are not BAWSCA Member Agencies as it does the demands
of its Retail Customers: based on the best available information to date, typically including the
previous year’s demands as well as consideration of current demand use patterns or other
conditions impacting demands, such as weather and growth.
Supply Assessment
The RWS collects water from the Upper Tuolumne River watershed in the Sierra Nevada and
from the local Alameda and Peninsula watersheds. The RWS draws an average of 85% of its
supply from the Tuolumne River watershed. This water feeds into an aqueduct system
delivering water 167 miles by gravity to Bay Area reservoirs and customers. The remaining 15%
of the RWS supply is drawn from local surface waters in the Alameda and Peninsula
watersheds. The percentage split between the Upper Tuolumne River and Bay Area watersheds
varies from year to year depending on the water year hydrology and operational circumstances.
To evaluate water supply conditions each year, the SFPUC uses measurements of precipitation
and snowpack in the watersheds above Hetch Hetchy, Cherry, and Eleanor Reservoirs. The
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Cooperative Snow Survey (conducted by the SFPUC in partnership with state and federal
agencies) evaluates snowpack conditions every year beginning in late January. The SFPUC also
estimates snowpack conditions using information from the Airborne Snow Observatory, which
is a developing technology that uses aerial surveys to quantify snowpack, along with other
sources. The SFPUC maintains a hydrologic model of the upcountry watersheds that uses this
information to project runoff for the coming year. This process also includes a statistical
analysis of additional expected precipitation. In addition to projected runoff, the determination
of projected available water supply also considers stored water throughout the RWS, water
acquired by the SFPUC from non‐SFPUC sources, reservoir losses, and allowances for carryover
storage.
Additionally, the SFPUC accounts for groundwater provided by the San Francisco Groundwater
Supply Project for the San Francisco retail system and recycled water provided for irrigation at
Harding Park, Fleming, and Sharp Park Golf Courses.
The RWS relies on precipitation and snowmelt captured and stored in its reservoirs. During
droughts, water supply deliveries can exceed inflows, requiring the use of water stored in
previous years to meet demands. Because of the importance of carry‐over storage, the SFPUC
constantly monitors and evaluates water supply conditions in the RWS, updating look‐ahead
forecasts as a year’s hydrology and operations change. Generally, in early winter of any year,
SFPUC staff can begin providing a forecast of water supply conditions for the upcoming year
based on known and anticipated winter and spring precipitation and snowpack. The predictive
power of this forecast improves greatly through the spring. The annual precipitation, snowmelt,
and carry‐over storage together constitute the SFPUC’s reservoir storage condition. Using data
for each of these factors, the SFPUC can determine whether the reservoir system will be
capable of serving full deliveries to its customers.
The SFPUC sells water to 26 wholesale customers (collectively referred to as the Wholesale
Customers) under the terms of a 25‐year contract known as the Water Supply Agreement
between the City and County of San Francisco and Wholesale Customers in Alameda County,
San Mateo County, and Santa Clara County (WSA) and associated individual water sales
contracts with each Wholesale Customer. Collectively, the Wholesale Customers on average
receive over two thirds of the RWS’s annual deliveries, with the remaining approximately one
third provided to the SFPUC’s Retail Customers.
The WSA carries forward many components of its predecessor agreement, including the
SFPUC’s “Supply Assurance” of 184 mgd to the Wholesale Customers. The SFPUC has agreed to
deliver water to the Wholesale Customers up to the amount of the Supply Assurance, and this
agreement is perpetual and survives the expiration of the WSA. The Supply Assurance is,
however, subject to reduction due to water shortage, drought, scheduled RWS maintenance
activities, and emergencies. As part of the Phased Water System Improvement Plan (WSIP) in
2008, the SFPUC established a temporary 265 mgd annual average limitation on water
deliveries from RWS watersheds, the “Interim Supply Limitation” (ISL). The SFPUC has allocated
the ISL between the Retail Customers and Wholesale Customers as follows:
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• Retail supply allocation: 81 mgd
• Wholesale supply allocation: 184 mgd
Table 19 shows the availability of RWS supplies for the SFPUC’s retail Customers and wholesale
customers in normal years. Table 20 shows the current and projected RWS supply needs to
meet retail and wholesale customer demands based on information and projections presented
in the SFPUC’s 2025 UWMP.
Table 19: Regional Water System Supply Availability in Normal Years (mgd)
RWS Supply Allocation Projected
Retail Customers (a)(b) 81 81 81 81 81
Total RWS Supplies 265 265 265 265 265
(a) Groundwater and recycled water are assumed to be used before RWS supplies to meet retail
demand. However, if these alternative supplies are not available, up to 81 mgd of RWS supply could
be used in normal years.
(b) The SFPUC reports Groveland Community Services District (GCSD) as a wholesale customer in its
UWMP, but the SFPUC otherwise considers GCSD a Retail Customer and includes GCSD’s demands
(approximately 0.3 mgd) within the Retail supply allocation of 81 mgd.
(c) Projected Wholesale Customer deliveries are limited to 184 mgd, including the demands of the
cities of San Jose and Santa Clara, which are supplied on a temporary and interruptible basis.
(d) Cordilleras Mutual Water Company is a wholesale customer of the SFPUC, but it is not a party to
the WSA or a BAWSCA Member Agency, and it is not included in the Wholesale Customer supply
allocation of 184 mgd. The demands of Cordilleras Mutual Water Company are minor (projected to
Table 20: Regional Water System Supply Utilized in Normal Years (mgd)
RWS Supply Allocation Projected
Retail Customers (a)(b) 62.7 61.2 61.9 64.0 66.7
Total RWS Supplies 196.62 197.52 202.43 208.12 215.1
(a) Groundwater and recycled water are assumed to be used before RWS supplies to meet retail
demand. However, if these alternative supplies are not available, up to 81 mgd of RWS supply may
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UWMP, but the SFPUC otherwise considers GCSD a Retail Customer and includes GCSD’s demands
(approximately 0.3 mgd) within the Retail supply allocation of 81 mgd.
(c) Projected Wholesale Customer deliveries are limited to 184 mgd, including the demands of the
cities of San Jose and Santa Clara, which are supplied on a temporary and interruptible basis.
(d) Cordilleras Mutual Water Company is a wholesale customer of the SFPUC, but it is not a party to
the WSA or a BAWSCA Member Agency, and it is not included in the Wholesale Customer supply
allocation of 184 mgd. The demands of Cordilleras Mutual Water Company are minor (projected to
Infrastructure Considerations
On an ongoing basis, three groups with the SFPUC’s Water Enterprise – Hetch Hetchy Water
and Power, Water Supply and Treatment Division, and Hydrology and Water Systems – conduct
analyses of the RWS that incorporate planned facility outages and multiple levels of projected
system demands to evaluate operational capabilities and plan for potential water delivery
constraints. These three groups meet quarterly to share plans and coordinate how facility
outages, changes in service area demand, wet or dry weather, and other variables shape the
operating plans each year. Facility outages due to maintenance or upgrades are coordinated in
an adaptive manner to respond to changes as they occur. For new water supplies or new capital
projects related to supply distribution, impacts on the RWS are evaluated extensively prior to
initiation of any changes. Results from these modeling efforts are considered in the annual
WSDA.
System Modeling
To proactively plan for conditions that would result in a shortage of water supplies, the SFPUC
models conditions using a hypothetical drought that is more severe than what the RWS has
historically experienced. This drought sequence is referred to as the “design drought” and
serves as the basis for planning and modeling of future scenarios. The design drought consists
of an 8.5‐year sequence of dry conditions.
In applying its water supply planning methodology, the SFPUC performs an initial model
simulation of the system for the design drought sequence and then reviews the ability of the
system to deliver water to the service area through the entire design drought sequence. If the
projected water supply runs out before the end of the design drought sequence in the initial
model run, system‐wide water use is reduced by applying water supply reductions and the
scenario is re‐run. This process continues iteratively until a model simulation of the system is
achieved in which the water supply in storage at the end of the design drought sequence is
brought to the system “dead pool,” where no additional storage is available for delivery
(currently simulated as 96,775 acre‐feet). Drawing system storage down to the dead pool
without going below it indicates that water supply delivery, including the adjusted amount of
water use, is maintained through the design drought sequence.
Estimated levels of water supply reduction and corresponding storage threshold values that
initiate each level of supply reduction can then be used to simulate the operation of the system
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through the historical record of hydrology, or to evaluate system water supply conditions
during an ongoing drought. While the design drought sequence does not occur in the historical
hydrology, the reduced water use and storage threshold values that are adjusted to allow a
system configuration to maintain water delivery through the design drought sequence can be
used to evaluate system performance in the historical record, or as a basis for comparing with
real‐time system conditions. Through use of this planning method, the SFPUC can simulate a
response to declining water supply in storage that is appropriate for the system conditions
being evaluated.
The SFPUC plans its water deliveries using indicators for demand reduction that are developed
through analysis with the design drought sequence. As a result, the SFPUC system operations
are designed to provide sufficient carry‐over water in SFPUC reservoirs to continue delivering
water, although at reduced levels, during multiple‐year droughts.
Decision‐Making Process
Regardless of the expectation of shortage conditions, as part of the normal course of business,
the SFPUC provides a water supply condition update to its executive team every two weeks
throughout the year. Pursuant to the Water Shortage Allocation Plan (WSAP), also known as the
Tier 1 Shortage Plan, that is incorporated in the WSA and described further previously, the
SFPUC also provides an initial estimate of available water supply for the upcoming Supply Year
(defined as the period between July 1 through June 30) to its Wholesale Customers on February
1 every year. A Wholesale Customer Annual Meeting is held in February at which the SFPUC
makes a presentation on current water supply conditions and forecasts. The SFPUC issues a
revised estimate of available water supply for the upcoming Supply Year on March 1 and uses
the snow survey that occurs in the first week of April and an associated runoff forecast to refine
an estimated total system storage expected on July 1. By the middle of April, the SFPUC issues a
final estimate of available water supply and determines whether there will be a system‐wide
shortage for the coming Supply Year.
If the SFPUC determines that a water shortage exists, the SFPUC may call for voluntary demand
reductions among its customers or issue a declaration of water shortage emergency pursuant
to California Water Code Section 350 et seq. In support of a declaration of water shortage
emergency, SFPUC staff will deliver a presentation to the Commission with information that
explains the basis for the shortage conditions, such as conditions of precipitation to date,
snowpack, and storage levels with more information as necessary depending on the particulars
of the supply forecast. Depending on the level of shortage, the SFPUC may determine that
voluntary actions by its Retail and Wholesale Customers will be sufficient to accomplish the
necessary reduction in water use throughout its service area or that mandatory actions will be
required. Water demand reductions that are applicable to Wholesale Customers will be
formally communicated following the Commission’s declaration of a water shortage emergency
under Section 350 of the California Water Code.
An example of the general WSDA process for water shortages caused by a drought is presented
in Figure 6 for illustrative purposes. Other non‐drought water shortages may not trigger the
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WSAP and therefore would not follow the same process shown below. For more information
about procedures in response to non‐drought water shortages, such as those caused by a
catastrophic supply interruption, see the next section.
Figure 6: Water Supply and Demand Assessment Process
Water Shortage Contingency Plan
Law
10632 (excerpts)
(a) Every urban water supplier shall prepare and adopt a water shortage contingency plan as part
of its urban water management plan…
…(3)(A) Six standard water shortage levels corresponding to progressive ranges of up to 10, 20, 30,
40, and 50 percent shortages and greater than 50 percent shortage….
(4) Shortage response actions that align with the defined shortage levels and include, at a
minimum, all of the following: (A) Locally appropriate supply augmentation actions. (B) Locally
appropriate demand reduction actions to adequately respond to shortages. (C) Locally
appropriate operational changes. (D) Additional, mandatory prohibitions against specific water
use practices that are in addition to state‐mandated prohibitions and appropriate to the local
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conditions. (E) For each action, an estimate of the extent to which the gap between supplies and
demand will be reduced by implementation of the action.
Palo Alto’s Experience with Drought Management
The City has had considerable experience implementing action plans during a period of water
shortage, such as a drought. The City has always been able to comply with any rationing
requirement imposed by SFPUC. During the 1976/77 drought period, the City achieved
reductions in citywide consumption of 16% in FY 1977 and 37% in FY 1978 compared to
consumption in FY 1976. In the 1987‐1993 drought period, the City’s consumption was lower
than consumption in 1987, the year just before SFPUC instituted mandatory rationing, from
19% (in FY 1989) to over 35% (in FY 1992). In response to the voluntary 10% call for rationing in
2008‐2009, the City responded with reductions of approximately 18% relative to 2004
consumption. In 2015, the City responded to state‐mandated potable water use reductions by
implementing the water restrictions in Stage II of its WSCP. The City exceeded the 24%
cumulative reduction target for the June 1, 2015 through May 31, 2016 compliance period
compared to calendar year 2013; the City’s usage was 31% below usage during the same period
in 2013. During the 2021 drought, City water use declined by 15% in response to SFPUC’s
system‐wide voluntary water reduction measure.
The community has responded exceedingly well to requests to use water in the most efficient
way possible. As a result of experiencing these drought‐time water supply shortages, many
residents and businesses have implemented permanent improvements in water use efficiency.
During a water shortage period, the Director of Utilities is responsible for executing the WSCP.
Representatives from appropriate City Departments and Utilities Divisions are involved to
oversee outreach and monitoring efforts. Additional resources are dedicated to this effort both
for internal and external execution of the plan.
A key element to developing WSCPs for the City is close coordination and cooperation with
SFPUC, BAWSCA, and the Valley Water. It is critical to develop a coherent and coordinated
regional response to water shortages in order to provide a consistent message to customers.
Water Shortage Mitigation Options
Water shortage mitigation options can be classified under two categories: Supply Side Options
and Demand Side Options. This section provides descriptions of many different actions and
activities that are possible in reaction to a water supply shortage situation. The City’s response
to drought‐time shortages depends upon the severity of the shortage. Following this section,
specific actions are outlined for the various stages of a potential shortage.
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Supply Side Options
The City’s options to increase its short‐term water supply are limited. The City’s long‐term supply
options are discussed in Section 3, “System Supplies.” The section below discusses short‐term
alternatives to increase supply in the event of a water supply shortage.
City Wells
The status of the City’s emergency wells is discussed in the Groundwater subsection of Section
3, “System Supplies.” During a drought period, it may be possible to use some water from the
wells to supplement the supply from the SFPUC, depending on the groundwater situation in the
Santa Clara Basin. Valley Water, the groundwater manager in Santa Clara County, may place
drought restrictions on that resource as well.
Recycled Water
During a drought or a short‐term water emergency, recycled water would be available to the
City, however, a wide distribution of recycled water would require substantial infrastructure
that would be difficult to construct in a short period of time. The City or private companies with
tanker trucks can obtain permits to utilize recycled water from the RWQCP. These companies
can pick up recycled water and deliver it to customers who will pay for this service. During the
summer of 2015, the City increased the use of water trucks to irrigate City trees on City‐owned
medians and several private companies utilized recycled water to deliver water to private
citizens. Public awareness is enhanced by greater publicity of the availability of this alternative
to customers. Trucking recycled water may displace about 1% of potable water demand.
Recycled water is available except in a catastrophic disaster (severe earthquake) that severs all
sources of water (SFPUC, wells and storage) to the system thereby eliminating the source of
water to the RWQCP. However, in the event of a severe earthquake the delivery of recycled
water will be a low priority.
Water Purchases from Other Suppliers
The City could conceivably purchase water from a new supplier in an extreme water supply
shortage situation. However, any such purchase would have to be consistent with the
requirements specified in the WSA 59 and be coordinated with all other jurisdictions between
the source and the City to ensure the supply meets deliverability requirements. The SFPUC has
made such purchases of water from various suppliers in times of water shortages. The City and
all other BAWSCA member agencies have received this water through the SFPUC delivery
systems. It is unlikely that the City could negotiate a better deal than the SFPUC or BAWSCA in
these extremely complicated short‐term arrangements, and therefore it is unlikely that the City
would seek to purchase water on its own.
Demand Side Options
In droughts, the City expects to achieve significant amounts of demand reduction through its
use of DMMs, as that term is used in the California Water Code. (See, for example, §§ 371,
59 WSA, Section 3.12
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10631.) These options include a combination of information outreach programs, drought rate
schedules, demand side programs and water use restrictions.
Defining Water Features
The City owns and operates several un‐metered water features including two recirculating
fountains and one recreational water feature. A small number of commercial customers have
recirculating fountains. The City’s Water Use Restrictions ordinance prohibits non‐recirculating
fountains. The City is not aware of any non‐recirculating, privately‐owned water features.
Boronda Lake, which uses about 250 AF over the 5‐month period from mid‐May through mid‐
October, is used for recreation and education and is habitat for several species of fish, other
aquatic life and birds. The lake is also a water source for many different types of mammals.
Demand Side Management Programs:
Demand side management programs can be offered using many different program design
options and delivery mechanisms. Some examples are listed below.
A. Home Water Use Reports
Home Water Reports will be used to encourage customers to save water. The Home Water
Report compares a household’s water usage to neighbors with similar lot sizes, landscape area,
and number of occupants. The reports ranks a household for how water efficient it is compared
to homes with similar demographics, in an attempt to encourage more water‐efficient
behaviors and participation in conservation programs.
B. Information Outreach Programs
Customers will be provided with information on ways to achieve needed water use reductions.
The City will communicate to the customers how best to prioritize their water use needs and
how to implement alternative ways to receive the same level of service while using less water.
Information and public outreach programs include utility bill inserts, information on CPAU’s
website, local print media campaigns, a social media presence, commercial targeted mailings,
workshops and demonstrations, fact sheets on conservation technologies and practices, and
coordination with product manufacturers and suppliers.
C. Incentive‐based Demand Side Management Programs
In a persistent water shortage or required water use reduction, most customers will take the
quick and easy actions first. More complex and expensive incentive programs to provide
demand side management may be needed to achieve additional results. Although incentive
programs require time to develop and promote, significant water savings can be achieved.
Depending upon market saturation, some programs such as delivery of relatively inexpensive
hardware (e.g. low‐flow faucet aerators and showerheads) and services such as leak detection
and irrigation system audits can offer quick drought‐time savings. Other programs may include
increased incentives to replace high water use landscapes with water efficient landscape
designs and installation of efficient irrigation hardware.
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D. Customer Water Use Audit Programs
Water audits are provided as an informational service to customers and typically include an
individualized, one‐on‐one analysis and site‐specific recommendations for both indoor and
outdoor water efficiency improvements. Audits can be enhanced by the delivery of relevant,
action‐oriented information the customer can use to change behavioral practices or participate
in additional audit or rebate programs. In a water emergency or shortage, additional staff may
be needed to provide water audits, rebate program administration, and outreach assistance to
residential and commercial customers.
Drought Rate Schedules
Pricing is one of the most powerful tools that a utility can use to promote its conservation
goals. The overarching criteria for constitutionally compliant water rate structures—for use in
droughts or not—is that all rates must be based on the cost to serve customers. Both tiered
water rates and volumetric‐based rates can provide an incentive to conserve. CPAU has had
tiered water rates for some time, and the bulk of water revenues are from volumetric rates and
not the fixed monthly meter charge. This rate design encourages efficient use of water
whether in a drought or not. However, when water use declines in droughts, revenue recovery
may become a problem.
In September 2015, drought surcharges were developed so that, upon Council action,
additional charges could be applied to ensure the financial health of the Water Fund. The
drought surcharges were imposed effective September 1, 2015 to recover (via a tiered
volumetric charge) the cost of operating the distribution system. The drought surcharge may
be re‐instated in response to future water supply shortages.
Customer Class Targets
In many water shortage situations, no rationing of water is required – ample communication of
the water shortage coupled with drought surcharges, if needed, have been sufficient to meet
the City’s water reduction targets in the prior and current drought. If rationing of water is
required to meet a water reduction requirement in a drought, customer class targets should
mirror the required indoor/outdoor water reduction goals that may be established during a
drought. Whether there will be different rate schedules (consistent with the cost of service
requirement) for each customer class will be determined by: (a) the severity of the water
shortage, and (b) the capabilities and limitations of the utility billing system. Experience has
shown that separating the single‐ family residential customers—which are more homogeneous
than any other customer group—from all other customer groups is generally the only
distinction needed.
Allocation Methods
Any allocation plan would take into consideration the criteria listed in Appendix G. These criteria
will be a guide to selecting the most efficient and effective water use reduction method under
the particular circumstances of a specific drought situation.
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1. Allocations Based on Percentage of Past Use
Plans that base a customer’s allocation on a percentage of past use are sometimes
perceived as fair and easy to administer. However, these plans have three significant
shortcomings. First, selection of a base year is problematic. It is difficult to pick a base
year unaffected by shortage year programs on the one hand, or gradually increasing
water use after a drought (the “rebound effect”) on the other. The second problem is
that each year the turnover of new accounts is approximately 20 to 30% (mostly multi‐
family residents). In addition, many businesses have changed their practices to some
extent over the years. Therefore to use this plan would mean that a large percentage of
water customers would have an allocation based on a previous occupant’s usage, a
previous operation, or some alternative situation. The third major flaw in the “percent
of past use” concept is that, regardless of base year selected, historically conservation‐
minded customers may feel penalized for their past efforts while profligate users may
have too large an allocation.
2. Equal Allocation for Each Home (for single‐family residential)
This plan would set an identical allocation for each home designed to meet the target
reduction for the class. The first tier in the rate structure 60 would be set at this target
amount. The second tier would be a “buffer” tier designed to accommodate seasonal
water needs. The third and last tier would be a penalty rate block price considerably
higher than the first two tiers.
All homes would be treated the same under this plan. In addition, it would be
inexpensive to administer and easy to understand and implement. However, it could be
perceived as unfair by relatively large families or customers with large lots.
Under this plan, hardship exemptions would be limited to those who require more
water for health or safety reasons. No additional allowances would be provided for the
number of persons living in the household or the landscaping requirements of the
particular size lot. Enforcement of this plan would involve installing a flow restrictor on
those customers who continue to exceed the allocation beyond a two‐month period.
3. Complete Per Capita Allocation Plan (for single‐family residential)
Under this plan each person would be allocated a certain amount of water per month.
In addition, each household would be allotted a certain amount of water per month for
other essential needs, including a base minimum amount for outdoor watering of shrubs
and trees. Per capita information would be based on information supplied by the
customers through a special mailing. The strength of this plan is that it would probably
be more acceptable to the community than the equal allocation per household plan
because it takes into account the relationship between water usage and the number of
persons living in a household. Its weaknesses are the inability of the current Utilities
billing system to record or manage “per capita” data and verification of per capita
60 Any rate design must be consistent with “cost of service” principles embedded within the California constitution.
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information. This method is consistent with the state’s Making Conservation a California
Way of Life Principles.
4. Default Per Capita Allocation Plan (for single‐family residential)
Under this plan each household would receive an allocation sufficient for families of a
default size. For households over that size, an additional amount would be allocated per
month for the number of people over the default size. This plan is easier to administer
than a complete per capita plan since the number of data entries is significantly
reduced. The plan’s weakness is its lack of detail or fine‐tuning for households under the
default size, which may be perceived as unfair by larger households.
Mandatory Water Rationing Plans Applicable to Multi‐Family Accounts, Business, and City
Departments
Due to the differences between customer classes, it is difficult to construct rationing plans that
meet all the criteria listed in Appendix G. During the 1987‐1993 drought period, the City
introduced Baseline Consumption Allowances (BCAs) for all customer classes except single‐
family residential accounts. This includes multi‐family residential, commercial, industrial,
institutional, and city facilities accounts. The BCA was intended to represent the indoor
consumption of each customer.
It is important for any allocation plan to take into account the specific needs of these customer
classes because of their diversity and unique requirements. The BCA does this. Rate structures
using the BCAs can be constructed as appropriate to meet the reduction targets required and to
provide the economic incentive necessary to prompt customer action. Furthermore, the targets
and the associated rate block prices could be changed as the reduction requirement changes.
Weaknesses of this method are that it may not accurately represent indoor water use. For
example, exemptions would have to be considered for customers with cooling towers, since
lack of water for cooling towers would effectively end the customers’ ability to cool their
building interiors, resulting in possible health and safety impacts of employees. Another
alternative in extreme cases (Stage 3 or higher) could be an allocation per fixture plus a cooling
tower credit, which is similar to the per capita method for residences.
Excessive Use Penalties for All Allocation Methods
Penalties for excessive use are expected to vary according to the customer class. For single‐
family residential customers exceeding percent‐of‐past‐use, equal‐allocation‐per‐home, or per
capita water use, the penalty could be installation of a flow restrictor when usage continued to
exceed the allocation beyond a 2‐month period. Enforcement of this penalty would only occur
after customers were notified and any reasonable appeals had been processed.
For customers under a BCA (all classes except single family residential), the primary penalty is in
the rate structure itself.
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Water Use Prohibitions, Mandatory Restrictions
Adopting water use restrictions is another way to manage how customers use a limited
resource. Restrictions can be classified as those preventing water waste, those “setting a tone”,
and those that prohibit low priority use in times of severe shortages.
In the case of a system‐wide water shortage, close coordination with SFPUC is necessary. One
of the considerations for selecting which water use restriction ordinances to adopt is what the
City’s suppliers recommend for the region. Both the SFPUC and Valley Water provide
recommendations, and the City will attempt to follow those recommendations so that regional
consistency is achieved.
The City’s ability to enforce restrictions is also a critical variable in the selection of water use
regulations. For restrictions to be credible and obeyed they must be enforceable and enforced.
Therefore certain restrictions, such as limits on indoor uses such as showering, are not
practical.
Water use restrictions are achieved by using the methods, prohibitions and penalties described
in the sections below. Appendix H lists permanent water use restrictions that the City currently
has in place and those that may be adopted on an emergency basis in times of state‐mandated
reductions or water shortage 61.
61 Section 12.32.015 of the Palo Alto Municipal Code, pertaining to emergency water use regulations, previously
codified and containing portions of Ordinance Nos. 3960, 3984 and 4038, was suspended, but specifically not
repealed, by Ordinance No. 4150, § 2. In pertinent part, Section 2 of Ordinance No. 4150 states that Section
12.32.015 is "suspended until such time as water shortage emergency conditions shall be subsequently found,
determined, and declared by the Council to exist."
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Water Shortage Contingency Plan Stages of Action
Actions to be taken in response to a water shortage or state‐mandated reduction depend on
the severity of the shortage or the magnitude of the required reduction. The staged responses
(Stage I to Stage IV) depend to some extent upon the local conditions and the length of time
that customers have had to focus their attention on the water shortage. For each stage noted
below, activity levels in several key areas are described. Appendix H, the Water Shortage
Contingency Plan, details the planned water use restrictions for each reduction level. Reduction
targets will be based on the most recent non‐drought year. If a different base year were to be
selected, the programs might require modification. In all stages, action will be taken to ensure
City facility water use is reduced by the appropriate amount.
Some factors which influence the effectiveness of any water management plan include: (1) the
customer’s behavior and perception of the need to conserve; (2) weather; (3) the duration of
the shortage or mandate; (4) the customer’s economic situation; (5) the extent to which the
City achieves its utility revenue targets; (6) the percentage of exemptions or variances granted;
(7) the role of the media; and (8) the customer’s acceptance of the need for water use
reduction.
Because each water shortage situation is unique in duration, in breadth and in involvement by
the state, there is a need for some flexibility in selecting the exact response strategy. Even with
the same reduction target, the strategy in the first year of a drought may be different than that
recommended for an additional year of a long running drought. It is very important early in a
drought period to develop outreach messages and policy directions using a longer‐term
perspective. In this way, communications with customers throughout the drought period will be
consistent and appropriate.
STAGE I – Minimum Water Supply Shortage: Up to 10% target water savings
The SFPUC requested voluntary reductions in this range in 1987, 2009, 2014, 2016 and 2021
which the City was able to achieve.
Information Outreach and Audit Programs
The City provides ongoing informational outreach and audit programs. At this water shortage
stage, the focus of these programs would be on water saving information. A low level media
information campaign would begin with the emphasis on reducing waste. As water
consumption is monitored, the level of emphasis would be adjusted in order to meet the
reduction goal.
The City has permanent ordinances in place that prohibit the waste of water. These ordinances
are sufficient for this stage of water shortage. Enforcement would be on an “as reported” basis
and mostly via reminder notices.
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Incentive‐based Demand Side Management Programs
Programs designed to assist customers in demand side management would be continued and
augmented, to the extent necessary to provide the savings required. These programs may
include rebate programs for indoor fixtures or incentives to remove lawn turf for less water‐
thirsty landscaping or to install advanced irrigation controllers. The City would continue to
monitor programs being developed by other utilities in order to take advantage of regional
momentum and shorten internal development time.
Drought Rate Structures
No special drought rate structure is needed at this water shortage stage. The City’s standard
single‐family rate structure already encourages conservation by having a relatively small fixed
charge and tiered rates.
STAGE II – Moderate Water Supply Shortage: 10% to 20% target water savings
The City was able to achieve this level of water reduction (19.1%) when rationing was imposed
by the SFPUC in FY 1989. The program used at that time is similar to the one outlined below.
Information Outreach and Audit Programs
The frequency of advertising and events comprising the information campaign would be
increased. Water kits with low‐cost conservation devices will be available to customers.
Incentive‐based Demand Side Management Programs
Programs designed to assist customers in demand side management would be continued and
augmented to the extent necessary to provide the savings required. These programs may
include incentives for replacing high water using fixtures such as toilets, clothes washers, and
irrigation devices, as well as incentives to retrofit landscapes for a low water use, drought
tolerant design. The City would continue to monitor programs being developed by other
utilities in order to take advantage of regional momentum and shorten internal development
time.
Drought Rate Structures
In response to water shortage conditions in the 1987‐1992 drought, the City established
separate drought rate schedules for single‐family residential and all other customers and
increased the price difference between lower and higher consumption tiers. For all customers
except single‐ family residential customers, the consumption tiers were based on a Baseline
Consumption Allowance (BCA) concept. This concept is described in the section, Water
Shortage Mitigation Options, as applicable to multi‐family, commercial, industrial, public
facilities and City facilities accounts.
Water Use Restrictions
The City would actively enforce the water use restrictions with an emphasis on education. A
system of warnings leading to possible fines and installation of a flow restrictor would be
followed. During the summer of 2015, the City developed a mobile application (311) for
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members of the community to report wasted water. This technology allowed for much wider
enforcement by City staff. A small number of emergency water use restrictions would be added
including restrictions of the number of days per week irrigation is permitted. Alternative
Irrigation Plans will be established for golf courses, parks, and schools with specific water use
reduction targets.
Drought Rate Structures
Drought surcharges may be imposed.
If reduction goals were not being met, reduction targets may need to be developed for each
customer class. Potential strategies for allocation plans are discussed above.
The exact rates and rate structures would be established upon receipt of information regarding
both the reduction requirement and applicable penalties and based on the utility’s overall
revenue requirements.
STAGE III – Severe Water Supply Shortage: 20% to 30% target water savings
The state‐mandated water use reduction for Palo Alto in 2015/2016 was 24% which the City
exceeded. The program outlined below was implemented to achieve those results. The water
use restrictions for this stage have been modified slightly to accommodate the increase in the
number of stages in the proposed 2020 WSCP.
Information Outreach and Audit Programs
All activities from Stage II would continue at escalated levels. In addition, emphasis would be
put on targeted outreach to high water users and special categories of water users (e.g., car
washes, restaurants, etc.).
Incentive‐based Demand Side Management Programs
Existing demand side management programs would be continued. Staff would continue to
closely monitor overall water savings in order to determine if additional levels of rebate
amounts would provide additional savings, or whether other programs would be necessary.
Drought Rate Structures
Drought surcharges may be imposed.
If reduction goals were not being met, reduction targets may need to be developed for each
customer class. Potential strategies for allocation plans are discussed above.
The exact rates and rate structures would be established upon receipt of information regarding
both the reduction requirement and applicable penalties and based on the utility’s overall
revenue requirements.
Water Use Restrictions
Additional “emergency” water use restrictions would be added to the existing permanent
restrictions including further restrictions of the number of days per week irrigation is permitted.
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Alternative Irrigation Plans will be established for golf courses, parks, and schools with specific
water use reduction targets.
The amount of staff time dedicated to enforcement would be increased with an emphasis on
education.
STAGE IV – Severe to Critical Water Supply Shortage: 30% to 40% target water savings
The City achieved usage reductions of 31.5%, 35.4%, and 32.7% in FY 1991, FY 1992, FY 1993
respectively, in response to SFPUC water rationing. In response to the state‐mandated water
use reductions in 2015/2016, the City achieved a 31% water use reduction. The program
outlined below was implemented to achieve those results, with some modifications.
Information Outreach and Audit Programs
All activities from Stage III would continue at escalated levels. In addition, emphasis would be
put on targeted outreach to high water users and special categories of water users (e.g., car
washes, restaurants, etc.).
Incentive‐based Demand Side Management Programs
Existing demand side management programs would be continued. Staff would continue to
closely monitor overall water savings in order to determine if additional levels of rebate
amounts would provide additional savings, or whether other programs would be necessary.
Drought Rate Structures
To achieve these reduction goals in past droughts, rationing was not implemented. Instead,
along with an extensive information outreach effort, drought surcharges may be imposed.
The exact rates and rate structures would be established upon receipt of information regarding
both the reduction requirement and applicable penalties and based on the utility’s overall
revenue requirements.
Water Use Restrictions
Additional “emergency” water use restrictions would be added to the existing permanent
restrictions including further restrictions on the number of days per week irrigation is
permitted. Alternative Irrigation Plans will be established for gold courses, parks, and schools
with specific water use reduction targets.
The amount of staff time dedicated to enforcement would be increased with an increase in
levying fines.
STAGE V – Critical Water Supply Shortage: 40% to 50% target water savings
A program to meet this level of water use reduction has not yet been implemented in the City.
However, in the spring of 1991, the SFPUC adopted a program calling for reductions in this
range. Although ultimately replaced with a less restrictive program, the City discussed what
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actions would be taken to meet the critical reduction targets. The program below outlines the
major components of the plan to meet such a target.
Information Outreach and Audit Programs
All activities from Stage IV would continue at further escalated levels. A greater focus will be
placed on survival strategies and prioritization assistance for all customer classes.
Incentive‐based Demand Side Management Programs
Depending on what programs have been implemented prior to this stage, or current market
saturations for certain devices, a selected number of indoor conservation incentives will be
offered. These may include rebates for and/or free distribution of showerheads and faucet
aerators, toilet modifications or retrofits, process water use modifications and use of recycled
water.
Drought Rate Structures
At this level of reduction, an allocation method would be considered for each customer. The
allocations would be sufficient for the most critical, high priority uses of water and the
availability of water for outside use would be dramatically reduced. Various allocation methods
are discussed in the previous section, Allocation Methods.
Water Use Restrictions
Severe “emergency” water use restrictions, many of which will supersede less stringent
restrictions imposed in a less critical phase, will be added. Enforcement will be more rigorous in
terms of hours of enforcement, number of staff involved, and the speed with which penalties
are applied.
STAGE VI – Water Emergency: Greater than 50% target water savings
A program to meet this level of water use reduction will have major economic and aesthetic
impacts on the City. Water use will be restricted to health and safety needs, possibly with some
allocation for the tree canopy maintenance.
Information Outreach and Audit Programs
All activities from Stage V would continue at further escalated levels. A greater focus will be
placed on survival strategies and prioritization assistance for all customer classes.
Incentive‐based Demand Side Management Programs
Depending on what programs have been implemented prior to this stage, or current market
saturations for certain devices, a selected number of indoor conservation incentives will be
offered. These may include rebates for and/or free distribution of showerheads and faucet
aerators, toilet modifications or retrofits, process water use modifications and use of recycled
water.
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Drought Rate Structures
At this level of reduction, an allotment method would be considered for each customer. The
allocations would be sufficient for health and safety and the availability of water for outside use
would be eliminated with some exception for keeping the tree canopy alive. Various allotment
methods are discussed in the previous section, Allocation Methods.
Water Use Restrictions
Severe “emergency” water use restrictions, many of which will supersede less stringent
restrictions imposed in a less critical phase, will be added. Enforcement will be at the highest
possible level terms of hours of enforcement, number of staff involved, and the speed with
which penalties are applied.
Table 21 summarizes the WSCP.
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Table 21: WSCP Summary
Up to 10% 10% ‐20% 20% ‐30% 30% ‐ 40% 40%‐ 50% Above 50%
Information
Outreach
and Audit
Program
Low level
outreach campaigns and direct communication with
customers targeting highest users and
increasing water use auditing
outreach
efforts and
media
campaign
with focus
outreach
effort level
with focus
on health
and safety
Demand‐Side
Management
Programs
Continuation
of existing
programs,
evaluation of
reduction targets
Rate
Structures
Standard
rates already
encourage
conservation
implemented to
secure needed
implemented
Water Use
Restrictions
Only
permanent
water use
ordinance –
no new
restrictions
efforts made to ensure tree canopy is protected as much as possible.
Recycled
Water Use
Business as
usual use purposes, advertise availability of recycled water for trucked delivery,
use recycled water for City facilities and street trees as much as
possible.
Alternative Water Supplies During a Water Shortage
Recycled Water Use
Recycled water offers an alternative source of water to those customers with valuable
landscaping. The availability of contractors who can haul recycled water will be advertised. In
addition, the City may rent tanker trucks to irrigate valuable City landscaping and street trees
that will undoubtedly be stressed by a long‐term drought, the likely precursor to this stage of a
water shortage. The City used trucked recycled water in this manner during the recent drought.
Some customers have continued to use local contractors to irrigate with recycled water.
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Groundwater
The City’s eight emergency groundwater wells are permitted for an annual production of 1,500
AFY. Staff will evaluate required wellhead treatment modifications needed to safely blend
groundwater with SFPUC water and will potentially update the WSCP incorporating
groundwater as an additional supply during severe droughts or water emergencies. The volume
of groundwater available may be subject to pumping restrictions determined by Valley Water,
the Groundwater Manager in Santa Clara County. In the event of a severe water supply
shortage, Valley Water will work with stakeholders to determine the best use for groundwater
resources.
Revenue and Expenditure Impacts and Measures to Overcome Impacts
Law
10632. (excerpts)
(a) Every urban water supplier shall prepare and adopt a water shortage contingency plan as part
of its urban water management plan that consists of each of the following elements:
…(8) A description of the financial consequences of, and responses for, drought conditions,
including, but not limited to, all of the following:
(A) A description of potential revenue reductions and expense increases associated with
activated shortage response actions….
(B) A description of mitigation actions needed to address revenue reductions and expense
increases associated with activated shortage response actions....
(C) A description of the cost of compliance….
Revenue Reductions, Expense Increases, and Cost of Compliance
Water utility expenditures can be generally categorized as fixed or variable expenses. The
variable costs are almost entirely related to the costs of purchasing water supplies. Although
the SFPUC supply costs are expressed as a variable commodity rate, the SFPUC system, like
many water delivery systems, is almost exclusively a fixed‐cost conveyance and treatment
system. Therefore, during a water supply shortage, the City’s cost of purchasing water from the
SFPUC may go down in the short‐term, but SFPUC rates will be raised to make up for the
revenue shortfall in the long‐term.
As a retail provider, the City’s fixed costs primarily relate to the cost of operating and
maintaining the City’s distribution system. Due to the City’s volumetric rate structure, decline in
sales revenue will exceed the decline in expenses. For each stage in the WSCP and assuming
2025 rate schedules, the revenue shortfall, net of the decline in expenses and based on FY 2025
costs and revenues, is calculated to be:
Stage 1: Up to 10% target water savings results in $1.8 million shortfall
Stage 2: 10% ‐ 20% target water savings results in $3.5 million shortfall
Stage 3: 20% ‐ 30% target water savings results in $5.3 million shortfall
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Stage 4: 30% ‐ 40% target water savings results in $7.0 million shortfall
Stage 5: 40% ‐ 50% target water savings results in $8.8 million shortfall
Stage 6: Greater than 50% target water savings results in greater than $8.8 million shortfall
Moreover, implementation costs for the informational outreach programs, monitoring, and
reporting during a water shortage increase during periods of voluntary and mandatory water
use reductions. For example, the 2015 state‐mandated potable water use reductions cost the
City an estimated $400,000.
Excessive use penalties may be associated with certain drought rate structures described
above. Additional staff resources would be needed to monitor customer use and install flow
restrictors on excessive water users.
For SFPUC wholesale rates, the rate‐setting process is governed by the terms of the WSA,
which provides that, in the event of a water shortage emergency, the SFPUC may adjust
wholesale rates in an expedited way concurrently with the imposition of drought surcharges
on its retail customers. Beyond drought rate setting and emergency rate setting, rates are set
annually in coordination with the SFPUC annual budget process and are based on the
forecasted wholesale share of RWS expenditures and total purchases. If Wholesale Customer
usage is expected to decrease – either voluntarily, or due to shortages – this would be
incorporated into the wholesale rate forecast, and rates may increase.
Mitigation Actions
From a utility perspective, there is a downside to water conservation: the erosion of sales
revenue. As consumers reduce their usage in response to the drought, the utility will
experience a decline in sales. Both the magnitude of the water use reduction and the duration
of such reductions will influence which mitigation measures are needed.
An approach for short‐term revenue shortfalls caused by decreased revenue and increased
expenses is to draw upon the utility’s cash reserves, if they are sufficient, to cover the financial
obligations of the utility. Other options include short‐term borrowing, financing long‐term
capital projects through revenue bonds rather than through current rates, or the
implementation of drought surcharges to address the loss in sales revenue. Each of these
approaches has its advantages and disadvantages. The appropriate response will depend upon
the specific circumstances facing the utility.
Monitoring Customer Compliance and Reporting
Law
10632. (a) The plan shall provide an urban water shortage contingency analysis that includes each
of the following elements that are within the authority of the urban water supplier:
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…(9) For an urban retail water supplier, monitoring and reporting requirements and procedures
that ensure appropriate data is collected, tracked, and analyzed for purposes of monitoring
customer compliance and to meet state reporting requirements.
Under normal water supply conditions, the amount of water coming into the City from the
SFPUC regional supply line is metered at the Arastradero, California, Page Mill, Sand Hill and
Lytton turnouts. The daily meter readings are maintained at the Utility Control Center. Totals
are reported monthly to CPAU for comparison to the billing amounts from the SFPUC.
In water shortage periods, the mechanism for determining actual reductions in water use
remains largely the same. The Director of Utilities would form an ad hoc Water Committee
with representatives of all divisions to oversee outreach and monitoring efforts. During
curtailment stages in a water shortage, supply figures are reported on a daily basis. The Water
Committee would provide timely reports to the City Council on the shortage and success of
measures taken. Such a committee was formed during the 2015‐2016 drought and during the
2021‐2023 drought.
If curtailment reaches Stage III or higher, daily supply figures are reported to the Director of
Utilities and the Water Committee. The Water Committee would report monthly to City Council
or as frequently as information is requested by the City Council.
If Alternative Irrigation Plans are put in place for golf courses, schools, and parks, usage reports
will be generated at the close of each monthly billing cycle to monitor compliance. The City will
work closely with those customers through the Utilities Key Account Customer Representatives,
to ensure compliance and collaborate on any operational adjustments needed to achieve the
targeted reductions.
Water Shortage Contingency Legal Authority
Law
10632. (excerpts)
(a) The plan shall provide an urban water shortage contingency analysis that includes each of the
following elements that are within the authority of the urban water supplier:
…(7) (A) A description of the legal authorities that empower the urban water supplier to
implement and enforce its shortage response actions... that may include, but are not limited to,
statutory authorities, ordinances, resolutions, and contract provisions.
(B) A statement that an urban water supplier shall declare a water shortage emergency….
(C) A statement that an urban water supplier shall coordinate with any city or county within
which it provides water supply services for the possible proclamation of a local emergency, as
defined in Section 8558 of the Government Code.
The City has experienced four instances of water shortage due to drought in the last 35 years. A
shorter duration drought occurred in 1976‐77, a water supply deficit occurred between 1987
and 1993, the drought of 2015‐2016 brought unprecedented state‐mandated reductions, and
the most recent 2021‐2023 drought resulted in voluntary water use reductions.
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Under Water Code Section 350, the Council may declare a water shortage emergency condition
within the City’s service territory, whenever it finds and determines that the ordinary demands
and requirements of water consumers cannot be satisfied without depleting the water supply
of the distributor to the extent that there would be insufficient water for human consumption,
sanitation, and fire protection. The City will declare a water shortage if the SFPUC or the state
declares a water shortage. The City will coordinate such a declaration with Valley Water and
Santa Clara County.
Appendix F provides a draft model ordinance that could be implemented during a water
shortage emergency.
Reevaluation and Improvement of Procedures
Law
10632. (a) The plan shall provide an urban water shortage contingency analysis that includes each
of the following elements that are within the authority of the urban water supplier:
…(10) Reevaluation and improvement procedures for systematically monitoring and evaluating
the functionality of the water shortage contingency plan in order to ensure shortage risk
tolerance is adequate and appropriate water shortage mitigation strategies are implemented as
needed.
At the end of each water shortage period, the City will conduct a review and evaluation of
savings achieved, expenditures, revenue losses and other impacts on the water customers and
on the City as a whole. Adjustments to the WSCP will be proposed and recommended for
Council approval as needed.
Section 8 – Supply and Demand Comparison Provisions
Law
10635. (a) Every urban water supplier shall include, as part of its urban water management plan,
an assessment of the reliability of its water service to its customers during normal, dry, and
multiple dry water years. This water supply and demand assessment shall compare the total
water supply sources available to the water supplier with the long‐term total projected water use
over the next 20 years, in five‐year increments, for a normal water year, a single dry water year,
and a drought lasting five consecutive water years. The water service reliability assessment shall
be based upon the information compiled pursuant to Section 10631, including available data
from state, regional, or local agency population projections within the service area of the urban
water supplier.
(b) Every urban water supplier shall include, as part of its urban water management plan, a
drought risk assessment for its water service to its customers as part of information considered
in developing the demand management measures and water supply projects and programs to be
included in the urban water management plan. The urban water supplier may conduct an interim
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update or updates to this drought risk assessment within the five‐year cycle of its urban water
management plan update. The drought risk assessment shall include each of the following:
(1) A description of the data, methodology, and basis for one or more supply shortage conditions
that are necessary to conduct a drought risk assessment for a drought period that lasts five
consecutive water years, starting from the year following when the assessment is conducted.
(2) A determination of the reliability of each source of supply under a variety of water shortage
conditions. This may include a determination that a particular source of water supply is fully
reliable under most, if not all, conditions.
(3) A comparison of the total water supply sources available to the water supplier with the total
projected water use for the drought period.
(4) Considerations of the historical drought hydrology, plausible changes on projected supplies
and demands under climate change conditions, anticipated regulatory changes, and other locally
applicable criteria.
Supply and Demand Comparison
Normal Year Supply and Demand
Since the City’s primary water supply is from the SFPUC, it is useful to examine the supply‐
demand comparison for the entire SFPUC system. SFPUC, in their 2025 UWMP, provides more
detail regarding available water supply for normal and drought scenarios.
Table 22 illustrates total system deliveries for both the Retail and Wholesale SFPUC customers.
During normal precipitation years, the SFPUC has adequate supplies to meet projected
Wholesale Customer purchases through 2050.
Table 22: Projected Total Regional Water System Supply Utilized and Portion of Regional
Water System Supply Utilized by Wholesale Customers in Normal Years (AFY)
1. RWS supply utilized by Wholesale Customers from 2030 through 2050 is equivalent to Wholesale Customer
purchase projections provided to the SFPUC by BAWSCA on March 4, 2026, and includes demands for the cities
of San Jose and Santa Clara.
The City has an ISG of 16.575 MGD (or 18,579 AFY) and projects demands will remain below the
City’s ISG through the 2025 UWMP planning horizon. Table 23 represents the City’s Supply and
Demand balance for the 2025 planning horizon based on the City’s contractual entitlement with
the SFPUC and normal precipitation.
2030 2035 2040 2045 2050
RWS Supply Utilized 220,366 221,375 226,980 233,257 241,103
RWS Supply Utilized by Wholesale Customers1 150,087 152,777 157,597 161,520 166,340
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Table 23: City of Palo Alto Supply/Demand Balance (AFY)
As previously discussed, SFPUC’s WSIP is nearly complete. For this 2025 UWMP, the WSIP‐
related water supply sources assumed to be available are summarized in Table 24. The
following assumptions regarding the SFPUC’s WSIP apply to all normal and dry year water
availability forecasts.
Table 24: SFPUC Water System Improvement Program Project Assumptions for RWS Supply
Modeling
1. The GSR Project was intended to provide 7.2 MGD over 7.5 years, however current limitations on the number
of wells available will result in deliveries less than 7.2 MGD over 7.5 years.
Dry Year Scenarios
Palo Alto’s recycled water supply is 100% reliable to meet the City’s demand for non‐potable
water. The dry‐year analysis that follows pertains only to potable water purchased from the
SFPUC.
For water shortages up to 20%, the Tier One water shortage plan will be applied. The Tier One
plan does not apply to system‐wide shortages greater than 20%. Implementing water use
reduction greater than 20% requires the SFPUC to meet and discuss with Wholesale Customers
a strategy for meeting incremental reductions above the Tier One plan. The SFPUC has the
authority to make final allocation decision for the portion above 20%, though the Wholesale
Customers have the contractual right to challenge the proposed approach.62 This analysis
assumes the relative split of available water between SFPUC Retail and Wholesale Customers
will be the same for shortages greater than 20% as shortages of 20%.
62 WSA, Section 3.11 (c )(3)
2025 2030 2035 2040 2045 2050
Palo Alto Demand for SFPUC Water 10,431 9,783 9,677 9,634 9,635 9,680
Individual Supply Guarantee 18,579 18,579 18,579 18,579 18,579 18,579
Difference 8,148 8,796 8,902 8,945 8,944 8,899
Projects Base Year 2025
Base Year 2030 and
Beyond
Base Year 2040 and
Beyond
Lower Crystal Springs
Dam Improvements
Crystal Springs storage
not fully restored
Crystal Springs storage
not fully restored
Crystal Springs storage
not fully restored
Regional Groundwater
Storage and Recovery
(GSR) Project
GSR account partially filled
at spring 2020 level of
43,000 AF; GSR recovery
rate of
5.2 MGD1
GSR account fully filled;
GSR recovery rate of
5.2 MGD1
GSR account fully filled;
GSR recovery rate of
6.2 MGD1
Alameda Creek
Recapture Project
Project not built Project built and
operating
Project built and
operating
Dry-Year Transfers Not in effect Not in effect Not in effect
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The following tables assume implementation of the Bay Delta Plan Amendment. It is unknown
when implementation may begin on the Bay Delta Plan Amendment; for the purposes of the
2025 UWMP analysis, unless noted otherwise, the SFPUC included it beginning in the 2030
modeling scenarios. Appendix G contains supply reliability analysis that assumes no
implementation of the Bay‐Delta Plan Amendment.
Under the condition of multiple dry years in a row and assuming implementation of the Bay
Delta Plan in 2030, Wholesale RWS available supply is greatly reduced as shown in Table 25.
Table 25: Projected Multiple Dry Years Wholesale Supply from RWS (AFY)
1. Projected supply reliability for 2050 assuming total demand is equivalent to the Wholesale Customer Supply
Assurance of 184 MGD, or 206,243 AFY.
The potable water supply shortfall for Palo Alto from a single dry year and for multiple dry years
is shown below in Table 26 and Table 27. Under these conditions, Palo Altans will be asked to
reduce water usage by up to 48%.
Table 26: Single Dry Year Potable Water Supply Shortfall for Palo Alto (AFY)
Table 27: Projected Potable Water Use Reductions in Multiple Dry Year Scenario for Palo Alto
A single dry year followed by 5 more consecutive dry years yields available water supply as
shown in Table 28 below using base years of 2030 ‐ 2050.
2030 2035 2040 2045 2050
2050 (with Supply
Assurance1)
First Year 103,346 102,337 102,113 102,001 102,449 101,889
Second Year 86,757 87,205 86,532 85,972 85,860 84,291
Third Year 86,757 87,205 86,532 85,972 85,860 84,291
Fourth Year 86,757 87,205 86,532 85,972 85,860 84,291
Fifth Year 86,757 87,205 86,532 85,972 85,860 84,291
2030 2035 2040 2045 2050
Supply Totals 6,736 6,482 6,242 6,085 5,962
Demand Totals 9,783 9,677 9,634 9,635 9,680
Difference (3,047) (3,195) (3,392) (3,551) (3,718)
2030 2035 2040 2045 2050
First Year 31.1%33.0%35.2%36.8%38.4%
Second Year 42.2%42.9%45.1%46.8%48.4%
Third Year 42.2%42.9%45.1%46.8%48.4%
Fourth Year 42.2%42.9%45.1%46.8%48.4%
Fifth Year 42.2%42.9%45.1%46.8%48.4%
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Table 28: Wholesale Supply and Demand Comparison for Projected Normal and Dry Year
Scenarios (AFY)
For Palo Alto, the consecutive dry year scenarios result in shortfalls ranging from 42% to 48% by
the 2rd consecutive dry year as shown in Table 29.
Year Wholesale Supply and
Demand
Normal
Year
Single
Dry Year
Dry Year
1
Dry Year
2
Dry Year
3
Dry Year
4
Dry Year
5
2030 Total Wholesale Demand 150,087 150,087 150,087 150,087 150,087 150,087 150,087
2030 Total Wholesale RWS Supply 150,087 103,346 103,346 86,757 86,757 86,757 86,757
2030 Difference (Surplus or Shortfall)- (46,741) (46,741) (63,330) (63,330) (63,330) (63,330)
2030 Difference (as % of Demand)0.0%-31.1%-31.1%-42.2%-42.2%-42.2%-42.2%
2035 Total Wholesale Demand 152,777 152,777 152,777 152,777 152,777 152,777 152,777
2035 Total Wholesale RWS Supply 152,777 102,337 102,337 87,205 87,205 87,205 87,205
2035 Difference (Surplus or Shortfall)- (50,440) (50,440) (65,572) (65,572) (65,572) (65,572)
2035 Difference (as % of Demand)0.0%-33.0%-33.0%-42.9%-42.9%-42.9%-42.9%
2040 Total Wholesale Demand 157,597 157,597 157,597 157,597 157,597 157,597 157,597
2040 Total Wholesale RWS Supply 157,597 102,113 102,113 86,532 86,532 86,532 86,532
2040 Difference (Surplus or Shortfall)- (55,484) (55,484) (71,064) (71,064) (71,064) (71,064)
2040 Difference (as % of Demand)0.0%-35.2%-35.2%-45.1%-45.1%-45.1%-45.1%
2045 Total Wholesale Demand 161,520 161,520 161,520 161,520 161,520 161,520 161,520
2045 Total Wholesale RWS Supply 161,520 102,001 102,001 85,972 85,972 85,972 85,972
2045 Difference (Surplus or Shortfall)- (59,519) (59,519) (75,548) (75,548) (75,548) (75,548)
2045 Difference (as % of Demand)0.0%-36.8%-36.8%-46.8%-46.8%-46.8%-46.8%
2050 Total Wholesale Demand 166,340 166,340 166,340 166,340 166,340 166,340 166,340
2050 Total Wholesale RWS Supply 166,340 102,449 102,449 85,860 85,860 85,860 85,860
2050 Difference (Surplus or Shortfall)- (63,891) (63,891) (80,480) (80,480) (80,480) (80,480)
2050 Difference (as % of Demand)0.0%-38.4%-38.4%-48.4%-48.4%-48.4%-48.4%
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Table 29: Palo Alto Supply and Demand Comparison for Projected Normal and Dry Year
Scenarios (AFY)
Table 30 shows the amount of water projected to be available to the RWS Wholesale
Customers if the next five years are dry, and Table 31 shows the available water to Palo Alto.
The five‐year drought assessment does not assume implementation of the Bay‐Delta Plan
Amendment because the start of implementation remains uncertain, and therefore reflects
100% supply for both RWS Wholesale Customers and the City.
Table 30: Projected RWS Supply for 5‐Year Drought Assessment (AFY)
1. Wholesale Purchase Projections for 2026‐2030 assume a linear growth between 2025 actual demands and 2030
projections, as calculated by BAWSCA.
Table 31: Projected RWS Supply Available to Palo Alto for 5‐year Drought Assessment (AFY)
Year Wholesale Supply and
Demand
Normal
Year
Single
Dry Year
Dry Year
1
Dry Year
2
Dry Year
3
Dry Year
4
Dry Year
5
2030 Total Demand 9,783 9,783 9,783 9,783 9,783 9,783 9,783
2030 Total RWS Supply 9,783 6,736 6,736 5,655 5,655 5,655 5,655
2030 Difference (Surplus or Shortfall)- (3,047) (3,047) (4,128) (4,128) (4,128) (4,128)
2030 Difference (as % of Demand)0.0%-31.1%-31.1%-42.2%-42.2%-42.2%-42.2%
2035 Total Demand 9,677 9,677 9,677 9,677 9,677 9,677 9,677
2035 Total RWS Supply 9,677 6,482 6,482 5,524 5,524 5,524 5,524
2035 Difference (Surplus or Shortfall)- (3,195) (3,195) (4,154) (4,154) (4,154) (4,154)
2035 Difference (as % of Demand)0.0%-33.0%-33.0%-42.9%-42.9%-42.9%-42.9%
2040 Total Demand 9,634 9,634 9,634 9,634 9,634 9,634 9,634
2040 Total RWS Supply 9,634 6,242 6,242 5,290 5,290 5,290 5,290
2040 Difference (Surplus or Shortfall)- (3,392) (3,392) (4,344) (4,344) (4,344) (4,344)
2040 Difference (as % of Demand)0.0%-35.2%-35.2%-45.1%-45.1%-45.1%-45.1%
2045 Total Demand 9,635 9,635 9,635 9,635 9,635 9,635 9,635
2045 Total RWS Supply 9,635 6,085 6,085 5,129 5,129 5,129 5,129
2045 Difference (Surplus or Shortfall)- (3,551) (3,551) (4,507) (4,507) (4,507) (4,507)
2045 Difference (as % of Demand)0.0%-36.8%-36.8%-46.8%-46.8%-46.8%-46.8%
2050 Total Demand 9,680 9,680 9,680 9,680 9,680 9,680 9,680
2050 Total RWS Supply 9,680 5,962 5,962 4,997 4,997 4,997 4,997
2050 Difference (Surplus or Shortfall)- (3,718) (3,718) (4,684) (4,684) (4,684) (4,684)
2050 Difference (as % of Demand)0.0%-38.4%-38.4%-48.4%-48.4%-48.4%-48.4%
Year 2026 2027 2028 2029 2030
Wholesale Purchase Projections1 146,724 147,509 148,405 149,302 150,087
RWS Supply Utilized by Wholesale Customers 146,724 147,509 148,405 149,302 150,087
Year 2026 2027 2028 2029 2030
Palo Alto Demand 10,112 9,961 9,966 9,851 9,783
Cutback 0.0%0.0%0.0%0.0%0.0%
Available Supply 10,112 9,961 9,966 9,851 9,783
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While the SFPUC has an adopted Level of Service goal of no more than a 20% system‐wide
shortfall, implementation of the Bay Delta Plan is projected to result in greater water supply
reductions if and until alternative supplies are developed. These anticipated dry‐year supply
reductions will be considered as Palo Alto plans for additional housing development.
In response to a severe drought the City will work with residents and businesses to significantly
reduce water use by implementing the WSCP. The WSCP contains provisions for shortages of
the magnitude shown in the tables in this section, however, the City does not have actual
experience in reducing water use to those levels.
In the 2015 drought, the City was able to achieve water use reductions of about 30%, but there
were significant impacts to the tree canopy. As a result, the City updated the permanent water
use regulations to allow irrigation practices that protect trees, despite certain restrictions on
watering decorative landscapes. The City also partners with community groups such as Canopy
on education for residents to encourage appropriate irrigation practices and selection of tree
species best suited for this microclimate to preserve the urban canopy.
Groundwater from City wells may be a supplemental resource, but it is probable that Valley
Water, the groundwater manager in Santa Clara County, will also require water use reductions,
and the wells are not permitted for sustained long‐term use. The City’s wells are restricted to
1,500 AFY, pumping for a maximum of five consecutive days and a maximum of 15 days per
year.
In response to the potential need for water supply in dry years in the long term, the SFPUC is
evaluating alternative water supplies and BAWSCA is seeking water supplies and solutions for
dry year events. See Section 6 – Water Supply Reliability.
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APPENDIX A ‐ Resolutions Adopting Urban Water
Management Plan and Water Shortage Contingency
Plan
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*NOT YET APPROVED*
1
027041426
Resolution No. XXXX
Resolution of the Council of the City of Palo Alto Adopting the 2025
Urban Water Management Plan to be Submitted to the California Department
of Water Resources
R E C I T A L S
A. The California Legislature has enacted the Urban Water Management
Planning Act, California Water Code Sections 10610 - 10656 and 10608, as amended, which
requires every urban water supplier providing water to more than 3,000 customers or supplying
more than 3,000 acre-feet of water annually to prepare an urban water management plan
("Plan") that has as its primary objective the conservation and efficient use of water.
B. The City of Palo Alto ("City"), a municipal utility and chartered city, is an
urban water supplier providing water to a population over 60,000.
C. The Plan must be reviewed at least once every five years by the City, which
must amend the Plan, as necessary, after it has conducted a review.
D. The preparation of the updated Plan has been coordinated with other
public agencies to the extent practicable, and staff has encouraged the active involvement of
diverse social, cultural and economic sectors of the population within the City's retail water
service area during preparation of the Plan.
E. The Plan must be adopted by July 1, 2026, after it is first made available for
public inspection and a public hearing is noticed and held, and it must be filed with the California
Department of Water Resources within thirty days of adoption.
F. After reviewing a draft Plan at their May 6, 2026 meeting, the Utilities
Advisory Commission recommended that the Council adopt the Plan as presented; and
G. A noticed public hearing on the draft Plan was held by the City Council on
June 8, 2026, at which time public comments were heard and considered.
NOW, THEREFORE, the Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Council hereby adopts the 2025 Urban Water Management Plan of the
City of Palo Alto, which shall be filed with the City Clerk. The City Manager is hereby authorized
and directed to file the 2025 Urban Water Management Plan of the City of Palo Alto with the
California Department of Water Resources and the State Library.
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*NOT YET APPROVED*
2
027041426
SECTION 2. The Council finds and determines that, under the California Water Code
Section 10652, the adoption of the Plan and the WSCP and this resolution does not constitute a
project under the California Environmental Quality Act, and no environmental assessment is
required.
AS TO FORM:
Director of Utilities
Director of Administrative Services
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*NOT YET APPROVED*
1
027041426
Resolution No. XXXX
Resolution of the Council of the City of Palo Alto Adopting the 2025 Water
Shortage Contingency Plan Included in the Urban Water Management Plan to be
Submitted to the California Department of Water Resources
R E C I T A L S
A. The California Legislature has enacted the Urban Water Management
Planning Act, California Water Code Sections 10610 - 10656 and 10608, as amended, which
requires every urban water supplier providing water to more than 3,000 customers or supplying
more than 3,000 acre-feet of water annually to prepare an urban water management plan
("UWMP") that has as its primary objective the conservation and efficient use of water.
B. The California Water Code requires urban water suppliers to prepare a
Water Shortage Contingency Plan (WSCP) to be included in its UWMP.
C. The WSCP must be adopted, along with the UWMP, by July 1, 2026, after it
is first made available for public inspection and a public hearing is noticed and held, and it must
be filed with the California Department of Water Resources within thirty days of adoption.
D. After reviewing a draft WSCP, which is included in the UWMP, at their May
6, 2026 meeting, the Utilities Advisory Commission recommended that the Council adopt the
WSCP as presented; and
E. A noticed public hearing on the WSCP, included in the UWMP, was held by
the City Council on June 8, 2026, at which time public comments were heard and considered.
NOW, THEREFORE, the Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Council hereby adopts the 2025 Water Shortage Contingency Plan of the
City of Palo Alto, included in its UWMP, which shall be filed with the City Clerk. The City Manager is
hereby authorized and directed to file the 2025 Water Shortage Contingency Plan of the City of
Palo Alto, included in the UWMP, with the California Department of Water Resources and the
State Library.
//
//
//
//
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*NOT YET APPROVED*
2
027041426
SECTION 2. The Council finds and determines that, under the California Water Code
Section 10652, the adoption of the Plan and the WSCP and this resolution does not constitute a
project under the California Environmental Quality Act, and no environmental assessment is
required.
AS TO FORM:
Director of Utilities
Director of Administrative Services
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APPENDIX B ‐ Public Participation Notices
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NOTICE OF PUBLIC HEARING
(FOR PUBLICATION ONCE A WEEK FOR TWO SUCCESSIVE WEEKS)
CITY OF PALO ALTO
NOTICE OF PUBLIC HEARING
NOTICE IS GIVEN, that the City Council of the City of Palo Alto will conduct a Public Hearing at
its meeting on Monday, June 8, 2026, at 5:30 p.m., or as soon thereafter as possible, via virtual
teleconference to consider: Update of the 2025 Urban Water Management Plan (UWMP) and
the Water Shortage Contingency Plan (WSCP). If you have any questions about Palo Alto’s
UWMP or WSCP, please contact Adriana Artola, Sr. Resource Planner, at
adriana.artola@paloalto.gov.
The City of Palo Alto’s Draft 2025 UWMP and WSCP can be viewed at:
https://www.paloalto.gov/Departments/Utilities/Water/Water-Resources/Urban-Water-
Management-Plan
Mahealani Ah Yun
City Clerk
PUBLISH ON:
May 25 and June 1, 2026
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APPENDIX C – DWR Standardized Tables
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CA431009 City of Palo Alto 20,463 10,626
20,463 10,626Total
Public Water System
Number
Public Water System
Name
Number of Municipal
Connections 2025
Submittal Table 2-1 Retail: Public Water Systems
Add additional rows as needed
NOTES:
Volume of Water
Supplied 2025 (AF)
DWR NOTES:
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in
Submittal Table 2-3. This table identifies the unit of measure selected in Submittal Table 2-3.
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Select
One
Name of Regional Alliance or
RUWMP (Drop Down List)
NOTES:
Submittal Table 2-2: Plan Identification
Type of Plan
If Water Supplier is also a member of a SB X7-7
Regional Alliance, select name from the drop-down.
Regional Urban Water Management Plan (RUWMP)
drop-down.
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Supplier is a wholesale supplier
Supplier is a retail supplier
UWMP Tables are in calendar years
UWMP Tables are in fiscal years
Unit AF
Submittal Table 2-3: Supplier Identification
If using fiscal years provide month and date that the fiscal year
begins (mm/dd)
(Select from the drop down list).
7/1
DWR NOTES:
Units of measure (AF, CCF, MG) must remain consistent
throughout the UWMP as reported in Submittal Table 2-3.
NOTES:
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Submittal Table 2-4 Retail: Water Supplier Information Exchange
Water Code Section 10631(h)
The retail Supplier has informed the following wholesale supplier(s) of projected
water use.
Wholesale Water Supplier Name
NOTES:
10631(h) An urban water supplier that relies upon a wholesale agency for a source of
water shall provide the wholesale agency with water use projections from that agency
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2025 2030 2035 2040 2045 2050(opt)
67,231 88,509 91,532 91,532 91,532 91,532
Submittal Table 3-1 Retail: Population - Current and Projected
Water Code Section 10631(a)
Population
Served
NOTES:
CWC 10631(a) describe the current and projected population of the service area including
current and projected population…
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Use Type
Drop down list
May select each use multiple times
These are the only use types that will be recognized by
the WUEdata online submittal tool
Potable or Non-Potable
(OPTIONAL)
Drop down list
Volume (AF)
10,626
(B) Multifamily.
(C) Commercial.
(D) Industrial.
(E) Institutional and governmental.
(F) Landscape.
(G) Sales to other agencies.
4 | Water Use Characterization
Draft | November 2025 4-10
(H) Saline water intrusion barriers,
groundwater recharge, or
conjunctive use, or any combination
thereof.
(I) Agricultural.
(J) Distribution system water loss
Total
Submittal Table 4-1 Retail: Total Uses for Potable and Non-Potable Water — Actual
Water Code Section 10631(d)(1)
For an urban retail water supplier, quantify, to the extent records are available, past and current water
use…identifying the uses among water use sectors including but not limited to:
must remain consistent throughout the UWMP as reported in Submittal Table 2-
3. This table identifies the unit of measure selected in Submittal Table 2-3.
2025 Actual Water Use
Additional Description
(as needed)
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Use Type
Drop down list
May select each use multiple times
These are the only Use Types that will be recognized
by the WUEdata online submittal tool
Potable or Non-Potable
(OPTIONAL)
Drop down list
2030 (AF)2035 (AF)2040 (AF)2045 (AF)2050 opt (AF)
Single Family Potable 3,785 3,726 3,710 3,699 3,706
Multi-Family Potable 1,674 1,631 1,603 1,585 1,579
Commercial Potable 1,719 1,757 1,769 1,779 1,797
Institutional/Governmental Potable 575 587 591 595 601
Other (optional)Potable 2 2 2 2 2
Distribution System Water Loss Potable 771 788 795 801 808
Total
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table identifies the unit of measure selected in
Submittal Table 2-3.
Add additional rows as needed.
Submittal Table 4-2 Retail: Total Uses for Potable, and Non-Potable Water — Projected
Water Code Section 10631(d)(1)
Projected Water Use
(Report To the Extent that Records are Available)
(as needed)
NOTES:
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Are Future Water Savings Included in Projections?
Drop down list (y/n) Yes
If "Yes" to above, state the section or page number, in the cell to the right, where
citations of the codes, ordinances, or otherwise are utilized in demand projections are
found.
Optional Suppliers may complete Optional Submittal Table 4-4 R to quantify the
Section 5 -
Demand
Management
Measures
Are Lower Income Residential Demands Included In Projections?
Drop down list (y/n)Yes
Optional If the method for accounting Lower Income Residential Demands has been
included, provide page number where this accounting can be found.
for water savings estimated to result from adopted codes, standards, ordinances, or
transpotation and land use plans identified by the urban water supplier, as applicable
to the service area.
information described in subparagraph (A), an urban water supplier shall do both of
the following: (i) Provide citations of the various codes, standards, ordinances or
transportation and land use plans utilized in making the projections.
(ii) Indicate the extent that the water use projections consider savings from codes,
standards, ordinances, or transportation and land use plans. Water use projections
that do not account for these water savings shall be noted of that fact.
water use for single-family and multifamily residential housing needed for lower
Submittal Table 4-3 Retail: Inclusion in Water Use Projections
Water Code Section 10631 (a), 10631 (d)(4)(A), and 10631 (d)(4)(B)
All of the City’s residential customers, regardless of income level, are metered and thus the
demands of residential customers with lower incomes are part of the single- and multi-family water
uses shown in DWR Table 4-2 and DWR Table 4-6.
DWR NOTES: Additional guidance is provided in Appendix K.
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2030 (AF)2035 (AF)2040 (AF)2045 (AF)2050 opt (AF)
209 369 451 510 553
397 576 639 654 666
Optional Submittal Table 4-4 Retail: Passive Water Savings Projections
Water Code Section 10631(d)(4)(A)
Passive savings
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in
Submittal Table 2-3. This table identifies the unit of measure selected in Submittal Table 2-3.
Description
(Codes, Standards, Ordinances, or Plans)
Water Code Section 10631(d)(4)(A) Water use projections, where available, shall display and account for the
water savings estimated to result from adopted codes, standards, ordinances, or transportation and land use
plans identified by the urban water supplier, as applicable to the service area.
NOTES:
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Public Water System ID # Reported
in Table 2-1 R Reporting Period Submitted to DWR Water
Loss Audit Program (yes/no)
2020 Yes
2021 Yes
2022 Yes
2023 Yes
2024 Yes
CWC 10631(d)(3) (A) The distribution system water loss shall be quantified for each of the five
years preceding the plan update, in accordance with rules adopted pursuant to Section
10608.34.
Submittal Table 4-5 Retail: Water Loss Audit Reporting
Water Code Section 10631(d)(3)(A)
CA4310009
DWR NOTES: Suppliers will provide a link to the WUEdata submittals of their Water
Loss Audit Reports.
NOTES: Links to the City's water loss reports can be found at
https://wuedata.water.ca.gov/awwa_plans
Report submittal status for all five years for each Public Water System as available.
Add rows as needed
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2028 Real Water Loss
Standard per Unit per
day
Units for Real
Water Loss
Drop down list
Number of Units
corresponding with
units selected)
Volume of Total Real
Loss
(from AWWA Water
Loss Audit)
(AF)
2028 Apparent
Water Loss Standard
per Unit per Day
Units for
Apparent Water
Loss
Number of
Connections
Volume of Total
Apparent Loss
(from AWWA Water
Loss Audit)
(AF)
CA431009 Yes 23.6
Gallons per
Service
Connection per
Day (GPSCD)
24,023 183.51 6.8 5.7
Gallons per
Service
Connection per
Day (GPSCD)
24,023 310.9 11.6
Gallons per
Service
Connection per
Day (GPSCD)
Gallons per
Service
Connection per
Day (GPSCD)
Submittal Table 4-6 Retail: Progress Towards 2028 Water Loss Standard
Water Code Section 10631(d)(3)(C)
Did the Water Board Calculate a
Water Loss Standard for this
Public Water System? (y/n)
If no, Supplier will not complete
this row.
Real Water Loss
DWR NOTES: Units of measure (AF, CCF, MG) for Water Loss MUST remain consistent with units reported in Submittal Table 2-3. The units reported in Submittal Table 2-3 are used in this table's calculations.
Public Water
System ID #
Reported in
R
Most Recent AWWA Water Loss Audit
Real Water
Loss Per Unit
per Day
Most Recent AWWA Water Loss Audit
Apparent Water
Loss Per Unit per
Day
State Water Board Standard State Water Board Standard
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Actual 2025 GPCD
(From SB X7-7
Compliance Form)
Did Supplier meet
the 2020 Target in
2025?
No Individual Target 180 142 Yes NA
10608.40 Urban water retail suppliers shall report to the department on their progress in meeting their urban water use targets as part of their
urban water management plans submitted pursuant to Section 10631.
Submittal Table 5-1 Retail: SB X7-7 2020 Target Progress
Water Code Section 10608.40
Did Supplier
Achieve Targeted
Reduction for
2020?
Actual 2020 GPCD2020 Target
Target or
Individual
Target?
Drop down list
DWR NOTES:
Suppliers calculating a 2025 GPCD will need to complete and submit SB X 7-7 Compliance Tables to verify the use of SB X7-7 Methodologies.
Suppliers that were part of a merger or consolidation since 2020 see Chapter 5 and Appendix P for guidance.
NA=Not Applicable
Check the box if the Supplier was not an Urban Water Supplier during or before the 2020 UWMP reporting cycle.
Proceed to the next table.
Only for suppliers that did not meet the
Target in 2020
See DWR NOTES below. Was Supplier part of a
merger or
consolidation since
2020?
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Groundwater Type
Drop Down List
May use each category
multiple times
Potable or
Non-Potable
(OPTIONAL)
Drop down list
Location or Basin Name 2021 (AF)2022 (AF)2023 (AF)2024 (AF)2025 (AF)
0 0 0 0 0
Add additional rows as needed
10631(4) If groundwater is identified as an existing or planned source of water available to the supplier, all of the following
information:
(C) A detailed description and analysis of the location, amount, and sufficiency of groundwater pumped by the urban water
supplier for the past five years. The description and analysis shall be based on information that is reasonably available,
including, but not limited to, historic use records.
Submittal Table 6-1 Retail: Groundwater Volume Pumped
Water Code Section 10631(4) and 10631(4)(c)
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table identifies the
unit of measure selected in Submittal Table 2-3.
NOTES
Total
Proceed to the next table.
Check the box if all or part of the groundwater described below is desalinated. (OPTIONAL)
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99E%
99E%
Name of Wastewater
Wastewater
or Estimated?
OPTIONAL
Drop Down List
Volume of Wastewater
Collected from UWMP
Service Area 2025 (AF)
Name of Wastewater
Treatment Plant (WWTP) and
Place ID Number
Drop down list
Is WWTP Located
Within UWMP
Area?
Drop Down List
City of Palo Alto Metered 10,563 ID 247457 Yes
10,563
CWC 10633(a) A description of the wastewater collection and treatment systems in the supplier’s service area, including a
quantification of the amount of wastewater collected and treated and the methods of wastewater disposal.
Proceed to the next table.
NOTES:
Submittal Table 6-2 Retail: Wastewater Collected Within Service Area
Water Code Section 10633(a)
Percentage of 2025 service area population served by wastewater collection system
(OPTIONAL)
Percentage of 2025 service area served by wastewater collection system (OPTIONAL)
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal
Table 2-3. This table identifies the unit of measure selected in Submittal Table 2-3.
Additional Guidance: See Appendix M, Section M.21 for detailed guidance on this table.
Wastewater Collection Recipient of Collected Wastewater
Total Wastewater Received from UWMP
Service Area in 2025:
Add additional rows as needed
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Treatment Level
Drop down list
Volume
(AF)
Treatment Level
Drop down list
Volume
(AF)
Treatment Level
Drop down list
Volume
(AF)
Treatment Level
Drop down list
Volume
(AF)
Treatment Level
Drop down list
Volume
(AF)
Name of other
entity
Yes 10,563 26,652 Tertiary 196 Tertiary 632 Tertiary 25,824
10,563 26,652 196 632 25,824 0 0
10633. The plan shall provide, to the extent available, information on recycled water and its potential for use as a water source in the service area of the urban water supplier...and shall include all of the following:
(b) A description of the quantity of treated wastewater that meets recycled water standards, is being discharged, and is otherwise available for use in a recycled water project.
Check the box if no wastewater is treated or disposed of within the UWMP service area.
Proceed to the next table.
Does This Plant
Treat
Wastewater
Generated
Outside the
UWMP Service
Area?
(OPTIONAL)
Drop down list
Wastewater Treatment
Number
Drop down list
Total 2025
Volume of
Water
Treated (AF)
NOTES:
Total
2025 Volume of
Wastewater
Received from
UWMP Service
Area
(As Reported in
Submittal Table
6-2 R) (AF)
Water Recycled Within
UWMP Service Area
(enter data as applicable)
Submittal Table 6-3 Retail: Wastewater Treatment and Outcomes Within UWMP Service Area
Water Code Section 10633(b)
DWR NOTES:
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table identifies the unit of measure selected in Submittal Table 2-3.
IPR: Indirect Potable Reuse would have the treatment level of its end use requirement in the Level of Treatment drop-down.
Additional Guidance: See Appendix M, Section M.21 for detailed guidance on this table.
Water Recycled Outside of
UWMP Service Area
(enter data as applicable)
Effluent Discharge that is
not a Permitted Recycled
Water Use
(enter data as applicable)
Required Discharge for
Instream Flow
(enter data as applicable)
Delivered to Another Entity for Additional
Treatment
(enter data as applicable)
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Volume Narrative page number
(OPTIONAL)
0 0 0 0 0 0 0Subtotal Potable
Water Use" and submit an accompanying narrative on the feasibility of that potential recycled water use.
Submittal Table 6-4 Retail: Recycled Water Direct Beneficial Uses Within Service Area
Water Code Section 10633 (c),(d),(e)
Potential Recycled Water Use
Name(s) of Facility/ies Producing (Treating) the Recycled Water (OPTIONAL) :Palo Alto Regional WQCP
Name of Supplier Operating the Recycled Water Distribution System (OPTIONAL) :City of Palo Alto
Volume of Supplemental Water Added in 2025 (OPTIONAL) :
Source of 2025 Supplemental Water (OPTIONAL) :
Subtotal Non-Potable
(c) A description of the recycled water currently being used in the supplier’s service area, including, but not limited to, the type, place, and quantity of use
d) A description and quantification of the potential uses of recycled water, including, but not limited to, agricultural irrigation, landscape irrigation, wildlife habitat
enhancement, wetlands, industrial reuse, groundwater recharge, indirect potable reuse, and other appropriate uses, and a determination with regard to the technical
and economic feasibility of serving those uses.
(e) The projected use of recycled water within the supplier’s service area at the end of 5, 10, 15, and 20 years, and a description of the actual use of recycled water in
comparison to uses previously projected pursuant to this subdivision.
Total
Use Type
Drop down list
Potable or Non-Potable
(after treatment if treated)
(OPTIONAL)
Drop down list
Additional Information
(as needed)
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table identifies the unit of measure selected in Submittal Table 2-3.
Additional Guidance: See Appendix M, Section M.21 for detailed guidance on this table.
Potential recycled water use: a description of the feasibility of these uses must be included in the narrative.
Multiple Producers: If you have multiple recycled water producers, submit a separate table for each.
NOTES:
2050 (AF)2025 (AF)2030 (AF)2035 (AF)2040 (AF)2045 (AF)
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2020 Projection
for 2025 (AF)
2025 Actual
Use (AF)
Submittal Table 6-5 Retail: 2020 UWMP Recycled Water Use Projection
Compared to 2025 Actual
Water Code Section 10633(e)
Check the box if recycled water was not used in 2025 nor previously
projected for use in 2020.
Proceed to the next table.
Add additional rows as needed
NOTES:
Total
DWR NOTES:
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in
Submittal Table 2-3. This table identifies the unit of measure reported in Submittal Table 2-3
Additional Guidance: See Appendix M, Section M.21 for detailed guidance on this table.
Use Type
Drop Down list
10633. The plan shall provide, to the extent available, information on recycled water and
its potential for use as a water source in the service area of the urban water supplier. The
preparation of the plan shall be coordinated with local water, wastewater, groundwater,
and planning agencies that operate within the supplier’s service area, and shall include all
of the following: (e) ...a description of the actual use of recycled water in comparison to
uses previously projected pursuant to this subdivision
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pg 42
Name of Action Description Expected Increase in Recycled Water
Use (AF)
Total (AF)
urban water supplier. The preparation of the plan shall be coordinated with local water, wastewater, groundwater, and planning agencies that operate within
(f) a description of actions, including financial incentives, which may be taken to encourage the use of recycled water, and the projected results of these
DWR NOTES:
Units of measure (AF, CCF, MG) MUST remain consistent with units reported in Submittal Table 2-3. This table identifies the unit of measure selected in
Submittal Table 2-3.
The unit conversion to Acre Feet addresses the Water Code's requirement that this value be provided in acre-feet.
NOTES:
Submittal Table 6-6 Retail: Methods to Encourage Future Recycled Water Use
Water Code Section 10633(f)
Check the box if the Supplier does not plan to expand recycled water use in the future. Supplier will not complete the table
below but will provide narrative explanation.
Provide page location of narrative in the UWMP
Unit Conversion to AF
Planned Implementation Year
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Drop Down
List
(yes/no)
If Yes, Supplier Name
10631 (f) Include a description of all water supply projects and water supply programs that may be undertaken by the urban water supplier to meet the total projected water
use, as established pursuant to subdivision (a) of Section 10635. The urban water supplier shall include a detailed description of expected future projects and programs that
the urban water supplier may implement to increase the amount of the water supply available to the urban water supplier in normal and single-dry water years and for a
period of drought lasting five consecutive water years. The description shall identify specific projects and include a description of the increase in water supply that is expected
to be available from each project. The description shall include an estimate with regard to the implementation timeline for each project or program.
Year Type
Drop Down List
Submittal Table 6-7 Retail: Expected Future Water Supply Projects or Programs
Water Code Section 10631(f)
DWR NOTES:
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table identifies the unit of measure reported in
Submittal Table 2-3.
Check the box if some or all of the supplier's future water supply projects or programs are not compatible with this table and are described in a
narrative format.
Check the box if there are no expected future water supply projects or programs that provide a quantifiable increase to the agency's water supply.
Proceed to the next table.
Planned
Implementation
Year
Add additional rows as needed
Joint Project with other suppliers?Expected
Increase in
Water Supply
to Supplier
(This may be a
range) (AF)
Provide page location of narrative in the UWMP
or Programs
Additional Description
(as needed)
Potable or Non-Potable
(after treatment if treated)
(OPTIONAL)
Drop Down list
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Water Supply
Drop down list
May use each category multiple times.
These are the only water supply
WUEdata online submittal tool
Potable or Non-Potable
(after treatment if treated)
(OPTIONAL)
Drop Down list
Actual Volume
(AF)
Total Entitlement
(OPTIONAL)
See 'DWR Notes' below
(AF)
Recycled Water Non-Potable 196
10631. A plan shall be adopted in accordance with this chapter that shall do all of the following... (b) Identify and quantify, to the extent practicable,
the existing and planned sources of water available to the supplier over the same five-year increments described in subdivision (a), providing
supporting and related information...
Submittal Table 6-8 Retail: Water Supplies — Actual
Water Code Section 10631(b)
2025
Palo Alto’s Individual Supply Guarantee (ISG) is 16.575 million gallons per day (MGD), or about 18,579 acre-feet per year (AFY), representing
the City’s perpetual dedicated share of the SFPUC’s 184 mgd Supply Assurance.
DWR NOTES:
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table identifies the unit of
measure selected in Submittal Table 2-3.
Total Entitlement: e.g. Water Right, Groundwater Allocation, Contracted Amount.
Total
Additional Description
(as needed)
Item #4
Packet Pg. 181
Water Supply
Reasonably
Available
Volume (AF)
Total Entitlement
(OPTIONAL)
See 'DWR Notes'
below (AF)
Reasonably
Available
Volume (AF)
Total Entitlement
(OPTIONAL)
See 'DWR Notes'
below (AF)
Reasonably
Available
Volume (AF)
Total Entitlement
(OPTIONAL)
See 'DWR Notes'
below (AF)
Reasonably
Available
Volume (AF)
Total Entitlement
(OPTIONAL)
See 'DWR Notes'
below (AF)
Reasonably
Available
Volume (AF)
Total Entitlement
(OPTIONAL)
See 'DWR Notes'
below (AF)
Potable 9,783 18,579 9,677 18,579 9,634 18,579 9,635 18,579 9,680 18,579
Recycled Water
From
Regional
Quality
Water
Control Plant
Non-Potable 250 250 250 250 250
2050 (opt)
Add additional rows as needed
Total
NOTES: Palo Alto’s Individual Supply Guarantee (ISG) is 16.575 million gallons per day (MGD), or about 18,579 acre-feet per year (AFY), representing the City’s perpetual dedicated share of the SFPUC’s 184 mgd Supply Assurance.
2030 2035 2040 2045
DWR NOTES:
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.
Total Entitlement: e.g. Water Right, Groundwater Allocation, Contracted Amount.
Submittal Table 6-9 Retail: Water Supplies — Projected
Water Code Section 10631 (b)
Projected Water Supply (Report to the Extent Practicable)
Drop down list
May use each category multiple
times. These are the only water
supply categories that will be
recognized by the WUEdata online
submittal tool
Additional
Detail on
Water
Supply
Potable or Non-Potable
(after treatment if treated)
(OPTIONAL)
Drop Down list
Item #4
Packet Pg. 182
Units for
Water
Volume
Extract and
Divert
Place
into
Storage
Conveyance Treatment Distribution Total Utility
See DWR NOTES Hydropower Net Utility
AF 10,431 0
1,301,901 1301901 1301901
N/A 0.0 0.0 0.0 0.0 383.0 0.0 0.0 0.00
Quantity of Self-Generated Renewable Energy
0 kWh
Data Quality (Estimate, Metered Data, Combination of Estimates and Metered Data)
Metered Data
Data Quality Narrative:
Narrative:
(1) An estimate of the amount of energy used to extract or divert water supplies.
NOTES:
10631.2. (a) In addition to the requirements of Section 10631, an urban water management plan shall include any of the following information that the urban
water supplier can readily obtain:
(2) An estimate of the amount of energy used to convey water supplies to the water treatment plants or distribution systems.
(3) An estimate of the amount of energy used to treat water supplies.
Energy Intensity (kWh/vol. converted to MG)
DWR NOTES: Total Utility:The volume of water entered in the “Total Utility” column should equal the volume of water entering the distribution system (excluding recycled water); in most cases, this is the total volume calculated in UWMP
Table 4-1: 2025 Actual Total Uses for Potable and Non-Potable Water. Note if recycled water is included in your Submittal Table 4-1, you must exclude it from your volume in this table.
Optional Submittal Table O-1A: Recommended Energy Reporting - SINGLE DELIVERY PRODUCT - WATER SUPPLY PROCESS APPROACH
Water Delivery Product
drop down list
(If delivering more than one type of product recommend using Table O-
1C)
Only for Water Delivery Products Under the Urban Water Supplier's Operational Control
Start Date of Reporting Period
Water Management Process Non-Consequential Hydropower
(if applicable)End Date of Reporting Period
Is upstream embedded energy included in the values reported?
Item #4
Packet Pg. 183
Start Date of Reporting Period 7/1/2024
End Date of Reporting Period 6/30/2025
Is upstream embedded energy in the values reported?No
Units of Measure for Water AF Collection /
Conveyance Treatment Discharge /
Distribution Total
26,652 26652
17,234,400 17234400
0.0 1984.5 0.0 1984.5
828 828
535,422 535422
0.0 1984.5 0.0 1984.5
kWh
Data Quality (drop down)
Combination of Estimates and Metered Data
Data Quality Narrative:
Narrative:
Volume of Wastewater Entering Process (volume units selected above)
Wastewater Energy Consumed (kWh)
Volume of Recycled Water Entering Process (volume units selected above)
Recycled Water Energy Consumed (kWh)
Wastewater Energy Intensity (kWh/volume converted to MG)
Recycled Water Energy Intensity (kWh/volume converted to MG)
Optional Submittal Table O-2: Recommended Energy Reporting - WASTEWATER AND RECYCLED WATER
Supplier's Operational Control
Wastewater Energy Consumed is sourced from billing data for the Water Quality Control Plant. Recycled Water Energy Consumed is estimated based
on kWh/AF of Wastewater Energy.
with two exceptions: water pumped to storage and customers in the foothills and the production of recycled water.
Item #4
Packet Pg. 184
% of Average Supply
Average Year 2030 100%
NOTES: Potable water supply
DWR NOTES: Supplier may use multiple versions of Submittal Table 7-1 R if different water sources have different base years and
the supplier chooses to report the base years for each water source separately. If a Supplier uses multiple versions of Submittal
Table 7-1 R, in the "Note" section of each submittal table, state that multiple versions of Submittal Table 7-1 R are being used and
identify the particular water source that is being reported in each submittal table.
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table
reports the units of measure reported in Submittal Table 2-3.
6,736
Year Type
If not using a calendar
year, type in the last
year of the fiscal,
water year, or range
of years, for example,
use 2025
Optional Submittal Table 7-1 Retail: Basis of Water Year Data (Reliability Assessment)
Available Supplies if
Year Type Repeats
Check the box if quantification of available supplies is not
compatible with this table and is provided elsewhere in
the UWMP.
Location: [insert location from UWMP]
Volume Available (AF)
Quantification of available supplies is provided in this table as
either volume only, percent only, or both.
Item #4
Packet Pg. 185
% of Average Supply
Average Year 2035 100%
DWR NOTES: Supplier may use multiple versions of Submittal Table 7-1 R if different water sources have different base years and
the supplier chooses to report the base years for each water source separately. If a Supplier uses multiple versions of Submittal
Table 7-1 R, in the "Note" section of each submittal table, state that multiple versions of Submittal Table 7-1 R are being used and
identify the particular water source that is being reported in each submittal table.
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table
reports the units of measure reported in Submittal Table 2-3.
NOTES: Potable water supply
6,482
Optional Submittal Table 7-1 Retail: Basis of Water Year Data (Reliability Assessment)
Year Type
If not using a calendar
year, type in the last
year of the fiscal,
water year, or range
of years, for example,
use 2025
Available Supplies if
Year Type Repeats
Check the box if quantification of available supplies is not
compatible with this table and is provided elsewhere in
the UWMP.
Location: [insert location from UWMP]
Quantification of available supplies is provided in this table as
either volume only, percent only, or both.
Volume Available (AF)
Item #4
Packet Pg. 186
% of Average Supply
Average Year 2040 100%
DWR NOTES: Supplier may use multiple versions of Submittal Table 7-1 R if different water sources have different base years and
the supplier chooses to report the base years for each water source separately. If a Supplier uses multiple versions of Submittal
Table 7-1 R, in the "Note" section of each submittal table, state that multiple versions of Submittal Table 7-1 R are being used and
identify the particular water source that is being reported in each submittal table.
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table
reports the units of measure reported in Submittal Table 2-3.
NOTES: Potable water supply
6,242
Optional Submittal Table 7-1 Retail: Basis of Water Year Data (Reliability Assessment)
Year Type
If not using a calendar
year, type in the last
year of the fiscal,
water year, or range
of years, for example,
use 2025
Available Supplies if
Year Type Repeats
Check the box if quantification of available supplies is not
compatible with this table and is provided elsewhere in
the UWMP.
Location: [insert location from UWMP]
Quantification of available supplies is provided in this table as
either volume only, percent only, or both.
Volume Available (AF)
Item #4
Packet Pg. 187
% of Average Supply
Average Year 2045 100%
DWR NOTES: Supplier may use multiple versions of Submittal Table 7-1 R if different water sources have different base years and
the supplier chooses to report the base years for each water source separately. If a Supplier uses multiple versions of Submittal
Table 7-1 R, in the "Note" section of each submittal table, state that multiple versions of Submittal Table 7-1 R are being used and
identify the particular water source that is being reported in each submittal table.
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table
reports the units of measure reported in Submittal Table 2-3.
NOTES: Potable water supply
6,085
Optional Submittal Table 7-1 Retail: Basis of Water Year Data (Reliability Assessment)
Year Type
If not using a calendar
year, type in the last
year of the fiscal,
water year, or range
of years, for example,
use 2025
Available Supplies if
Year Type Repeats
Check the box if quantification of available supplies is not
compatible with this table and is provided elsewhere in
the UWMP.
Location: [insert location from UWMP]
Quantification of available supplies is provided in this table as
either volume only, percent only, or both.
Volume Available (AF)
Item #4
Packet Pg. 188
% of Average Supply
Average Year 2050 100%
DWR NOTES: Supplier may use multiple versions of Submittal Table 7-1 R if different water sources have different base years and
the supplier chooses to report the base years for each water source separately. If a Supplier uses multiple versions of Submittal
Table 7-1 R, in the "Note" section of each submittal table, state that multiple versions of Submittal Table 7-1 R are being used and
identify the particular water source that is being reported in each submittal table.
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table
reports the units of measure reported in Submittal Table 2-3.
NOTES: Potable water supply
5,962
Optional Submittal Table 7-1 Retail: Basis of Water Year Data (Reliability Assessment)
Year Type
If not using a calendar
year, type in the last
year of the fiscal,
water year, or range
of years, for example,
use 2025
Available Supplies if
Year Type Repeats
Check the box if quantification of available supplies is not
compatible with this table and is provided elsewhere in
the UWMP.
Location: [insert location from UWMP]
Quantification of available supplies is provided in this table as
either volume only, percent only, or both.
Volume Available (AF)
Item #4
Packet Pg. 189
% of Average Supply
Average Year 2030 100%
DWR NOTES: Supplier may use multiple versions of Submittal Table 7-1 R if different water sources have different base years and
the supplier chooses to report the base years for each water source separately. If a Supplier uses multiple versions of Submittal
Table 7-1 R, in the "Note" section of each submittal table, state that multiple versions of Submittal Table 7-1 R are being used and
identify the particular water source that is being reported in each submittal table.
Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. This table
reports the units of measure reported in Submittal Table 2-3.
NOTES: Non-Potable Water Supply
Optional Submittal Table 7-1 Retail: Basis of Water Year Data (Reliability Assessment)
Year Type
If not using a calendar
year, type in the last
year of the fiscal,
water year, or range
of years, for example,
use 2025
Available Supplies if
Year Type Repeats
Check the box if quantification of available supplies is not
compatible with this table and is provided elsewhere in
the UWMP.
Location: [insert location from UWMP]
Quantification of available supplies is provided in this table as
either volume only, percent only, or both.
Volume Available (AF)
Item #4
Packet Pg. 190
2030 (AF)2035 (AF)2040 (AF)2045 (AF)2050 (AF)
Supply totals
(autofill from Submittal Table 6-
9 R)
10,033 9,927 9,884 9,885 9,930
Use totals
2 R)
10,033 9,927 9,884 9,885 9,930
Surplus/(shortfall)0 0 0 0 0
WSCP - use reduction savings
benefit
Revised Surplus/(shortfall)
of the reliability of its water service to its customers during normal, dry, and multiple dry water years. This water
supply and demand assessment shall compare the total water supply sources available to the water supplier
with the long-term total projected water use over the next 20 years, in five-year increments, for a normal
water year, a single dry water year, and a drought lasting five consecutive water years.
OPTIONAL Planned WSCP Actions
Submittal Table 7-2 Retail: Normal Year Supply and Use Comparison
Water Code Section 10635 (a)
must remain consistent throughout the UWMP as reported in
Submittal Table 2-3.
Item #4
Packet Pg. 191
2030 (AF)2035 (AF)2040 (AF)2045 (AF)2050 (AF)
Supply totals
6-9 R)
9,783 9,677 9,634 9,635 9,680
9,783 9,677 9,634 9,635 9,680
Surplus/(shortfall)0 0 0 0 0
Revised Surplus/(shortfall)
OPTIONAL Submittal Table 7-2 Retail: Normal Year Supply and Use Comparison - POTABLE
NOTES:
Item #4
Packet Pg. 192
2030 (AF)2035 (AF)2040 (AF)2045 (AF)2050 (AF)
Supply totals
6-9 R)
250 250 250 250 250
250 250 250 250 250
Surplus/(shortfall)(0)(0)(0)(0)(0)
Revised Surplus/(shortfall)
OPTIONAL Submittal Table 7-2 Retail: Normal Year Supply and Use Comparison -
NON-POTABLE
NOTES:
Item #4
Packet Pg. 193
Supply totals 6,986 6,732 6,492 6,335 6,212
Use totals 10,033 9,927 9,884 9,885 9,930
Surplus/(shortfall)(3,047)(3,195)(3,392)(3,551)(3,718)
Revised Surplus/(shortfall)
Submittal Table 7-3 Retail: Single Dry Year Supply and Use Comparison
Water Code Section 10635(a)
OPTIONAL Planned WSCP Actions
2030 (AF)2035 (AF)2040 (AF)2045 (AF)
10635. (a) Every urban water supplier shall include, as part of its urban water
management plan, an assessment of the reliability of its water service to its customers
during normal, dry, and multiple dry water years. This water supply and demand
assessment shall compare the total water supply sources available to the water
supplier with the long-term total projected water use over the next 20 years, in five-
year increments, for a normal water year, a single dry water year, and a drought
lasting five consecutive water years.
DWR NOTES : Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP
as reported in Submittal Table 2-3.
2050 (AF)
Item #4
Packet Pg. 194
Supply totals 6,736 6,482 6,242 6,085 5,962
Use totals 9,783 9,677 9,634 9,635 9,680
Surplus/(shortfall)(3,047)(3,195)(3,392)(3,551)(3,718)
Revised Surplus/(shortfall)
OPTIONAL Submittal Table 7-3 Retail: Single Dry Year Supply and Use
Comparison - POTABLE
OPTIONAL Planned WSCP Actions
2030 (AF)
must remain consistent throughout the UWMP as
reported in Submittal Table 2-3.
2035 (AF)2040 (AF)2045 (AF)2050 (AF)
Item #4
Packet Pg. 195
Supply totals 250 250 250 250 250
Use totals 250 250 250 250 250
Surplus/(shortfall)0 0 0 0 0
Revised Surplus/(shortfall)
OPTIONAL Submittal Table 7-3 Retail: Single Dry Year Supply and Use
Comparison - NON-POTABLE
OPTIONAL Planned WSCP Actions
2030 (AF)
must remain consistent throughout the UWMP as
reported in Submittal Table 2-3.
2035 (AF)2040 (AF)2045 (AF)2050 (AF)
Item #4
Packet Pg. 196
2030 (AF)2035 (AF)2040 (AF)2045 (AF)2050 (AF)
Supply totals 6,987 6,733 6,492 6,335 6,213
Use totals
Use totals
Use totals
Use totals
Use totals
NOTES: This table assumes the implementation of the Bay-Delta Plan Amendment.
10635. (a) Every urban water supplier shall include, as part of its urban water management plan, an assessment of the
reliability of its water service to its customers during normal, dry, and multiple dry water years. This water supply and
demand assessment shall compare the total water supply sources available to the water supplier with the long-term
total projected water use over the next 20 years, in five-year increments, for a normal water year, a single dry water
rought lasting five consecutive water years.
First year
Second year
Third year
Fifth year
must remain consistent throughout the UWMP as reported in Submittal Table 2-3.
Fourth year
Submittal Table 7-4 Retail: Multiple Dry Years Supply and Use Comparison
Water Code Section 10635(a)
Item #4
Packet Pg. 197
2030 (AF)2035 (AF)2040 (AF)2045 (AF)2050 (AF)
Supply totals
Supply totals
Supply totals
Supply totals
Supply totals
Revised Surplus/(shortfall)
OPTIONAL Submittal Table 7-4 Retail: Multiple Dry Years Supply and Use Comparison - POTABLE
Second
year
Third
year
Fourth
year
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.
Item #4
Packet Pg. 198
2030 (AF)2035 (AF)2040 (AF)2045 (AF)2050 (AF)
Supply totals
Supply totals
Supply totals
Supply totals
Supply totals
Revised Surplus/(shortfall)
OPTIONAL Submittal Table 7-4 Retail: Multiple Dry Years Supply and Use Comparison - NON-POTABLE
Second
year
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table
2-3.
Third
year
Fourth
year
Item #4
Packet Pg. 199
2026 Total
Total Water Use (AF)
2027 Total
Total Water Use (AF)
Total Supplies (AF)
Surplus/Shortfall w/o WSCP Action 0
WSCP - supply augmentation benefit (AF)
WSCP - use reduction savings benefit (AF)
Revised Surplus/(shortfall)
2028 Total
Total Water Use (AF)
2029 Total
Total Water Use (AF)
2030 Total
Total Water Use (AF)
Submittal Table 7-5 Retail: Five-Year Drought Risk Assessment
Water Code Section 10635(b)(3)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
Item #4
Packet Pg. 200
WSCP - supply augmentation benefit (AF)
WSCP - use reduction savings benefit (AF)
Revised Surplus/(shortfall)
10635 (b) Every urban water supplier shall
include, as part of its urban water management
plan, a drought risk assessment for its water
service... The drought risk assessment shall
include each of the following:
(1) A description of the data, methodology, and
basis for one or more supply shortage conditions
that are necessary to conduct a drought risk
assessment for a drought period that lasts five
consecutive water years, starting from the year
following when the assessment is conducted.
(2) A determination of the reliability of each source
of supply under a variety of water shortage
conditions. This may include a determination that a
particular source of water supply is fully reliable
under most, if not all, conditions.
(3) A comparison of the total water supply sources
available to the water supplier with the total
projected water use for the drought period.
(4) Considerations of the historical drought
NOTES: This Table assumes the current regulatory context is in effect
(and assumes that the Bay Delta Plan would not get implemented
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent
throughout the UWMP as reported in Submittal Table 2-3.
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
Item #4
Packet Pg. 201
2026 Total
Total Water Use (AF)
Total Supplies (AF)
Surplus/Shortfall w/o WSCP Action 0
Revised Surplus/(shortfall)
2027 Total
Total Water Use (AF)
Total Supplies (AF)
Surplus/Shortfall w/o WSCP Action 0
WSCP - supply augmentation benefit (AF)
WSCP - use reduction savings benefit (AF)
Revised Surplus/(shortfall)
2028 Total
Surplus/Shortfall w/o WSCP Action 0
Revised Surplus/(shortfall)
2029 Total
Surplus/Shortfall w/o WSCP Action 0
Revised Surplus/(shortfall)
2030 Total
Surplus/Shortfall w/o WSCP Action 0
OPTIONAL Submittal Table 7-5 Retail: Five-Year Drought Risk Assessment -
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
Item #4
Packet Pg. 202
WSCP - use reduction savings benefit (AF)
Revised Surplus/(shortfall)
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout
the UWMP as reported in Submittal Table 2-3.
Item #4
Packet Pg. 203
2026 Total
Total Water Use (AF)
Total Supplies (AF)
Surplus/Shortfall w/o WSCP Action 0
Revised Surplus/(shortfall)
2027 Total
Total Water Use (AF)
Total Supplies (AF)
Surplus/Shortfall w/o WSCP Action 0
WSCP - supply augmentation benefit (AF)
WSCP - use reduction savings benefit (AF)
Revised Surplus/(shortfall)
2028 Total
Surplus/Shortfall w/o WSCP Action 0
Revised Surplus/(shortfall)
2029 Total
Surplus/Shortfall w/o WSCP Action 0
Revised Surplus/(shortfall)
2030 Total
Surplus/Shortfall w/o WSCP Action 0
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Submittal Table 7-5 Retail: Five-Year Drought Risk Assessment -
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
OPTIONAL Planned WSCP Actions (use reduction and supply augmentation)
Item #4
Packet Pg. 204
WSCP - use reduction savings benefit (AF)
Revised Surplus/(shortfall)
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout
the UWMP as reported in Submittal Table 2-3.
Item #4
Packet Pg. 205
Standard
Shortage
Levels Range
Suppliers
Shortage
Levels
Percent
1 Up to 10%
2 Up to 20%
3 Up to 30%
4 Up to 40%
5 Up to 50%
6 >50%
Submittal Table 8-1: Cross-reference for Standard vs
Supplier Shortage Levels
Water Code Section 10632(a)(3)(B)
Check the box if the Supplier uses the Standard
six levels of water shortage.
Proceed to the next table.
NOTES:
water shortage contingency plan as part of its urban water
management plan that consists of each of the following elements:
Item #4
Packet Pg. 206
(B) An urban water supplier with an existing water shortage
contingency plan that uses different water shortage levels may
comply with the requirement in subparagaph (A) by developing
and including a cross-reference relating its existing categores to
the six standard water shortage levels.
progressive ranges of up to 10, 20, 30, 40, and 50 percent
shortages and greater than 50 percent shortage. Urban water
suppliers shall define these shortage levels based on the
suppliers’ water supply conditions, including percentage
reductions in water supply, changes in groundwater levels,
changes in surface elevation or level of subsidence, or other
changes in hydrological or other local conditions indicative of the
water supply available for use. Shortage levels shall also apply to
catastrophic interruption of water supplies, including, but not
limited to, a regional power outage, an earthquake, and other
potential emergency events.
Item #4
Packet Pg. 207
Yes
Volume or
Percentage
Drop down
Shortage Gap
Reduction Value
(May be a range) (AF)
Submittal Table 8-2 Retail: Supply Augmentation and Other Actions
Water Code Section 10632(a)(4)(A),(C) and (E)
Add additional rows as needed
NOTES: The City’s options to augment its watery supply during a drought are limited. See Section 7 - Water Shortage Contingency Plan - Water
Shortage Mitigation Options.
Is the Supplier completing this table using the standard six levels? (yes/no)
How much is this going to reduce the
shortage gap?
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.
Shortage
Level
Supply Augmentation Methods and
Other Actions by Water Supplier
Drop down list
These are the only categories that will be
accepted by the WUEdata online submittal tool
Additional Explanation or Reference
(OPTIONAL)
Item #4
Packet Pg. 208
Yes
Volume or Percentage
Drop down
Shortage Gap
Reduction Value
(May be a range) (AF)
Expand Public Information Campaign Percentage 0%-1%No
Other Percentage 0%-5%Permanent Ordinances Prohibiting Water Waste Yes
Other Percentage 0%-5%No
Percentage 1%-5%Yes
Percentage 1%-5%Yes
Percentage 1%-5%Drought rate structures may be implemented No
20%)
CII - Restaurants may only serve water
upon request Percentage 0%-1%serve water to customers only upon Yes
20%)
CII - Lodging establishment must offer
opt out of linen service Percentage 0%-1%
with the option of choosing not to have
towels and linens laundered daily. The hotel or
motel shall prominently display notice of this
option in each guestroom using clear and easily
Yes
20%)
Landscape - Limit landscape irrigation
to specific days Percentage 5%-10%
potable water more than three days
per week is prohibited during the months of April
through October. The irrigation of ornamental
day per week is prohibited during the months of
Yes
Percentage 0%-1%Yes
Percentage 5%-10%Water allocations may be imposed.No
Stage III
(20%-30%)
Landscape - Limit landscape irrigation
to specific days Percentage 10%-25%potable water more than two days per
week is prohibited during the months of April Yes
Stage III
(20%-30%)
Landscape - Prohibit certain types of
landscape irrigation Percentage 0%-1%
Golf courses, schools, and parks have the option to
be placed on Alternative Irrigation Plans
with targets established by the Director of Utilities.
Yes
Stage IV
(30%-40%)Expand Public Information Campaign Percentage 1%-5%direct communication with customers targeting No
Percentage 5%-10%Drought rate structures may be implemented No
Stage IV
(30%-40%)
Landscape - Limit landscape irrigation
to specific days Percentage 10% to 20%potable water more than one day per Yes
Stage IV
(30%-40%)
Other water feature or swimming pool
restriction Percentage 0%-1%potable water unless required for Yes
Stage IV
(30%-40%)
Landscape - Other landscape
restriction or prohibition Percentage 0%-5%irrigation and runoff is required at new
construction sites, and non-drought tolerant Yes
Other Percentage 5%-10%No
50%)
Moratorium or Net Zero Demand
Increase on New Connections Percentage 0%-5%
No new water service connections unless the
customer pays for sufficient conservation measures
elsewhere in the city to offset water use.
Yes
Shortage
Level
Demand Reduction Actions
Drop down list
These are the only categories that will be
tool. Select those that apply.
Additional Explanation or Reference
(OPTIONAL)
Penalty, Charge, or
Other
Enforcement?
For Retail Suppliers Only
Drop Down List
Is the Supplier completing this table using the standard six levels? (yes/no)
Submittal Table 8-3 Retail: Demand Reduction Actions
Water Code Section 10632(a)(4)(B),(D), and (E)
Add additional rows as needed
How much is this going to reduce the shortage
gap?
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Stage V(40%-
50%)Expand Public Information Campaign Percentage 5%-10%No
Other Percentage 0%-5%No
Percentage 10%-15%No
Percentage 10%-20%Yes
50%)at facilities using recycled or Percentage 0%-1%commercial washing facility that Yes
Percentage 5%-10%Sprinkler irrigation is prohibited Yes
Expand Public Information Campaign Percentage 10%-15%No
Other Percentage 0%-5%No
Percentage 10%-15%No
Stage VI
(>50%)
Landscape - Prohibit all landscape
irrigation Percentage 20%-30%possibly with some allocation for the tree canopy Yes
(D) Additional, mandatory prohibitions against specific water use practices that are in addition to state-mandated prohibitions and appropriate to the local conditions.
(E) For each action, an estimate of the extent to which the gap between supplies and demand will be reduced by implementation of the action.
conditions, feasibility, and consumption trends. Water use restrictions are maintained from one stage to the next: Stage III has all the water use restrictions for Stage II as well
as the restrictions listed for Stage III, Stage IV has all the water use restrictions for Stages II and III as well as the restrictions listed for Stage IV; Stage V has all the water use
restrictions for Stages II, III, and IV as well as the restrictions listed for Stage V, and Stage VI has all the water use restrictions for Stages II, III, IV and V as well as the restrictions
listed for Stage VI. Stages III through V will include Alternative Irrigation Plans with specific water use reduction targets for high-value landscapes such as playing fields and golf
courses.
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.
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City Name 60 Day Notice
Drop Down (yes/no)
Notice of Public
Hearing
Drop Down (yes/no)
Brisbane Yes Yes
Burlingame Yes Yes
Daly City Yes Yes
East Palo Alto Yes Yes
Foster City Yes Yes
Hayward Yes Yes
Hillsborough Yes Yes
Menlo Park Yes Yes
Millbrae Yes Yes
Milpitas Yes Yes
Mountain View Yes Yes
Redwood City Yes Yes
San Bruno Yes Yes
San Jose Yes Yes
Santa Clara Yes Yes
Sunnyvale Yes Yes
County Name
Drop Down List
60 Day Notice
Drop Down (yes/no)
Notice of Public
Hearing
Drop Down (yes/no)
Santa Clara County Yes Yes
San Francisco County Yes Yes
provides water that the urban water supplier will be reviewing the plan and considering amendments or
changes to the plan.
Submittal Table 10-1 Retail: Notification to Cities and Counties
Water Code Section 10621(b) and 10642
Add additional rows as needed
Add additional rows as needed
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CWC 10642 The water supplier is to provide the time and place of the hearing to any city or county within which
the supplier provides water.
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APPENDIX D ‐ Draft Permanent Water Use Ordinance
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Ordinance No.
Ordinance of the Council of the City of Palo Alto Amending Chapter 12.32
(Water Use Regulations) of the Palo Alto Municipal Code to Incorporate
Additional Water Use Regulations
The Council of the City of Palo Alto ORDAINS as follows:
SECTION 1. Findings and Declarations. The City Council finds and declares as follows:
A. Article 10, Section 2 of the California Constitution declares that waters of the State are to
be put to beneficial use, that waste, unreasonable use, or unreasonable method of use of
water be prevented, and that water be conserved for the public welfare.
B. The State of California is prone to drought conditions, which result in water supply
shortages.
C. The City of Palo Alto recognizes the continuing need to manage water resources under its
jurisdiction and control in a constitutionally compliant manner.
D. Section 12.32.010 of the Palo Alto Municipal Code sets forth permanent water use
restrictions applicable to all City water customers in order to responsibly manage the
City’s water resources.
E. City regulation of the time and manner of water use, rate design, the method of
application of water for certain uses, and establishment of enforcement procedures in
support of water use management is an effective and immediately available means of
conserving water and is authorized by Palo Alto Municipal Code Section 12.20.010.
F. California Assembly Bill (AB) 1572 (2023) prohibits the use of potable water to irrigate
nonfunctional turf at most commercial, industrial, and institutional properties, including
common areas managed by homeowner associations, and requires the City of Palo Alto
to update its regulations to enforce the State-mandated prohibitions.
G. In 2024, the State Water Resources Control Board adopted the “Making Conservation as
a Way of Life” regulation (23 CCR § 965 et seq.), which establishes urban water use
objectives and performance measures for retail water suppliers like the City.
H. The Council wishes to make minor changes to existing water use restrictions and adopt
additional permanent water use restrictions in order to responsibly manage the City’s
water resources, meet its urban water use objectives, and comply with AB 1572.
SECTION 2. Section 12.32.010 (Water Use Regulations) of Chapter 12.32 (Water Use
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Regulations) of the Palo Alto Municipal Code is hereby amended as follows (additions
underlined, deletions struck through):
12.32.010 Water use regulations.
No purchaser of water from the city of Palo Alto, nor any customers of the water utility of the
city of Palo Alto, shall use water or allow any other person to use water under the control of
such customer or purchaser in the following ways:
(a) Potable water shall not be allowed to flood or run off into gutters: driveways, sidewalks,
streets or other unlandscaped areas.
(b) By means of a hose to wash cars, boats, trailers, buses or other vehicles or to wash
sidewalks, building structures, other hard-surfaced areas or parts thereof without an
operating automatic shut-off valve. Use of a hose for such purposes should be avoided
whenever possible.
(c) Potable water for consolidation of backfill and other nondomestic uses in construction
shall not be used if other water sources such as reclaimed water are available, as
determined by the director of utilities or his or her designee. Applicants for hydrant
permits from the city of Palo Alto shall be deemed to have consented to restrictions on
water use which may be imposed by the director of utilities or his or her designee.
(d) Any broken or defective plumbing, sprinklers, watering or irrigation systems which
permit the escape or leakage of water shall be repaired or replaced as soon as possible,
but no later than the date established by the director of utilities, or his or her designee,
as reasonable after observation of the broken or defective system.
(e) The irrigation of turf or ornamental landscapes, which serve purely decorative purposes,
and are distinguished from trees, edible gardens or landscapes that provide more than a
purely aesthetic function, with potable water shall not be allowed between 910:00 a.m.
and 6:00 p.m., except via hand watering with a bucket or a hose with an operating shut-
off valve.
(f) The use of potable water in a fountain or other decorative water feature is prohibited,
except where the water is part of a recirculating system.
(g) The use of potable water for street sweepers and washers is prohibited if non-potable
water is available, as determined by the Director of Utilities, or his or her designee.
(h) Commercial car washes must use recycled water systems, if recycled water is available,
as determined by the Director of Utilities, or his or her designee, and economically
feasible.
(i) The use of potable water for the irrigation of nonfunctional turf located on commercial,
industrial, and institutional properties, other than a cemetery, and on properties of
homeowners’ associations, common interest developments, and community service
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organizations or similar entities is prohibited as of the following dates:
(i) All properties owned by local governments, local or regional public agencies, and
public water systems, beginning January 1, 2027.
(ii) All other institutional properties and all commercial and industrial properties,
beginning January 1, 2028.
(iii) All common areas of properties of homeowners’ associations, common interest
developments, and community service organizations or similar entities,
beginning January 1, 2029.
Notwithstanding the provisions of this subdivision (i), the use of potable water is not
prohibited to the extent necessary to ensure the health of trees and other perennial
nonturf plantings, or to the extent necessary to address an immediate health and safety
need. For the purposes of this subdivision (i), relevant terms have the same meaning as
in Section 10608.12 of the Water Code.
SECTION 3. If any section, subsection, clause or phrase of this Ordinance is for any
reason held to be invalid, such decision shall not affect the validity of the remaining portion or
sections of the Ordinance. The Council hereby declares that it would have adopted the
Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the
fact that any one or more sections, subsections, sentences, clauses or phrases be declared
invalid.
SECTION 4. The Council finds that this ordinance is categorically exempt from review
under the California Environmental Quality Act (CEQA) pursuant to Section 15307 and 15308 of
the CEQA Guidelines (actions taken by regulatory agencies for the protection of natural
resources and the environment).
//
//
//
//
//
//
//
//
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SECTION 5. This ordinance shall be effective on the thirty-first day after the date of
its adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
City Clerk Mayor
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
City Attorney or Designee City Manager
Director of Utilities
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APPENDIX E ‐ Water Shortage Contingency Plan Evaluation
Criteria
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CRITERIA TO EVALUATE WATER SHORTAGE RESPONSE PLAN
This appendix lists criteria expected to guide the selection of allocation/allotment strategies
whenever water use reductions are needed. Not all of them may be applicable to every strategy
but customer perception of equity is important in achieving the necessary reductions.
1. Reduce overall City consumption by reduction target required – this is the effective goal of
any plan. To accomplish this goal the percentage reduction for the various customer
classes will necessarily vary because their ratios of indoor/outdoor use varies.
2. Sufficient water available for personal use – the most important use of water is for basic
drinking, health, and sanitary uses, and therefore, this is given the highest priority of use.
This prioritization will drive both rate schedules and water use restrictions. However,
within allowed limits (i.e., water use restriction ordinances), customers will be able to
choose how they use their allotment between indoor and outdoor uses.
3. Acceptance by the community – many people tend to evaluate or accept a particular
water- rationing plan in terms of how it would directly affect them. It is this aspect which
makes it difficult to gain a popular consensus on any one plan. However, any plan must be
generally accepted by the community to be successful. One important aspect of
acceptance is the public’s understanding of the program; thus, it is viewed as important to
make the plan as uncomplicated as possible.
4. Minimize unemployment or business loss – water is extensively used in both commercial
and industrial functions. If water is severely limited to these consumers, increased
unemployment and business losses could result. Staff intends that, wherever possible, this
should be avoided. Still, outside water use must be sacrificed greatly if only minimal indoor
reductions are required. Cooling tower use for air conditioning must also be considered.
5. Landscaping investment losses – in cases of critical or severe shortage of water, it is
expected that significant landscaping losses may arise. The use of recycled water should be
encouraged for certain applications. In some cases, using the City’s well system to
augment the SFPUC supply will be an option to provide a minimum amount of water for
landscaping. In this case, the goal should be to keep valuable and mature trees and
plantings alive. Shrubs and lawns will be considered a lower priority.
6. Workable plan – the plan must be workable in order to accomplish its goal. It must take
the following factors into account:
a. Cost - the cost of any water plan to the public should be minimized.
b. Enforcement - enforcement is viewed as a key component of any plan. Those plans
requiring fewer resources for enforcement would be preferable. However, the success
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of a plan is contingent upon effective enforcement and the utility must be provided the
resources to meet the enforcement objective. The current staff can only absorb a
certain level of additional responsibilities without unreasonably impacting service to
the customer.
c. The plan must be practical and feasible from a data processing viewpoint and not
subject to erroneous results due to incomplete or inaccurate databases. A realistic
timeframe must be allowed to perform any necessary data entry or customer
programming functions.
9. Flexibility – the water shortage is a dynamic situation and may get better or worse. Thus, it
is necessary that any plan be adaptable to changes in targets or adjustable if original
expectations are not being met.
10. Allowance for new services – some provision must be made in any plan to serve new
establishments or those under construction.
12. Recover penalties applied by suppliers – revenue should be collected to the extent
necessary to recover any penalties that may be charged by suppliers.
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APPENDIX F ‐ Water Shortage Contingency Plan Use
Restrictions
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WATER USE RESTRICTIONS
Water use restrictions will depend on local conditions and on the length of the water shortage or
drought. The City’s Water Shortage Contingency Plan identifies measures appropriate for various
stages of action, based on reduction targets for each stage. Section A of this Appendix describes
the City’s existing water use regulations. The restrictions in Section B are additional restrictions
that could be applied in various stages or a drought or other water supply shortage. These staged
restrictions are intended to serve as tools within the broader framework of the Urban Water
Shortage Contingency Plan, to help the City reduce potable water consumption.
Implementation of individual restrictions within each stage shall be carried out at the direction
of the City Council, in response to its assessment of local water supply conditions, feasibility, and
consumption trends. The Council may, in its discretion, opt to revise, delete or include different
elements than those described below, so long as the restrictions implemented serve the overall
purpose of reducing local consumption.
A. Permanent Water Use Regulations (See Palo Alto Municipal Code Section 12.32.010)
1. Flooding or runoff of potable water into gutters, driveways, sidewalks, streets or other
unlandscaped areas is prohibited.
2. An operating shut-off valve is required for hoses used to wash cars, boats, trailers, buses or
other vehicles, or to wash sidewalks, building structures, other hard -surfaced areas or parts
thereof. Use of a hose for such purposes should be avoided whenever possible.
3. Potable water for consolidation of backfill and other nondomestic uses in construction shall
not be used if other water sources, such as reclaimed water, are available, as determined
by the Director of Utilities or his or her designee. Applicants for hydrant permits from th e
city of Palo Alto shall be deemed to have consented to restrictions on water use which may
be imposed by the Director of Utilities or his or her designee.
5. Any broken or defective plumbing, sprinklers, watering or irrigation systems which permit
the escape or leakage of water shall be repaired or replaced as soon as possible, but no later
than the date established by the Director of Utilities, or his or her d esignee, as reasonable
after observation of the broken or defective system.
6. Ornamental landscape1 or turf irrigation with potable water shall not be allowed between
9:00 a.m. and 6:00 p.m., except via hand watering with a bucket or a hose with an operating
shut-off valve.
7. The use of potable water in a fountain or other decorative water feature is prohibited,
except where the water is part of a recirculating system.
8. The use of potable water for street sweepers/washers is prohibited if non -potable water is
available, as determined by the Director of Utilities, or his or her designee.
9. Commercial car washes must use recycled water systems, if economically feasible.
10. The use of potable water for the irrigation of nonfunctional turf located on commercial,
industrial, and institutional properties, other than a cemetery, and on properties of
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homeowners’ associations, common interest developments, and community service
organizations or similar entities is prohibited as of the following dates: (1) All properties
owned by local governments, local or regional public agencies, and public water systems,
beginning January 1, 2027. (2) All other institutional properties and all commercial and
industrial properties, beginning January 1, 2028. (3) All common areas of properties of
homeowners’ associations, common interest developments, and community service
organizations or similar entities, beginning January 1, 2029.
a. The use of potable water is not prohibited to the extent necessary to ensure the
health of trees and other perennial nonturf plantings, or to the extent necessary to
address an immediate health and safety need.
B. Additional Restrictions Available for Council’s Consideration in Droughts or Other Water
Supply Shortages
Stage I – Minimum Water Supply Shortage: Up to 10% Target Water Savings
1. Irrigation with potable water during and within 48 hours after a measurable rainfall of at
least one fourth of one inch of rain, as determined by the Director of Utilities, or his or her
designee, and posted on the Palo Alto website, is prohibited.
2. The application of potable water to driveways, sidewalks, buildings, structures, patios,
parking lots, or other hard surfaced areas is prohibited, except where necessary to address
an immediate health and safety need or to comply with a term or condition in a permit issued
by a state or federal agency.
Stage II – Moderate Water Supply Shortage: 10% - 20% Target Water Savings
1. Restaurants and other food service operations shall serve water to customers only upon
request.
2. Operators of hotels and motels shall provide guests with the option of choosing not to have
towels and linens laundered daily. The hotel or motel shall prominently display notice of this
option in each guestroom using clear and easily understood language.
3. The irrigation of ornamental landscapes or turf with potable water more than three days
per week is prohibited during the months of April through October.2
4. The irrigation of ornamental landscapes or turf with potable water more than one day per
week is prohibited during the months of November through March.
Stage III – Severe Water Supply Shortage: 20% - 30% Target Water Savings
All water use restrictions for Stage II, and the following:
1. The filling of newly constructed pools, spas and hot tubs is prohibited.
2. Water allocations may be imposed.
4. Golf courses, schools, and parks have the option to be placed on Alternative Irrigation Plans
with targets established by the Director of Utilities.
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5. The irrigation of ornamental landscapes or turf with potable water more than two days per
week is prohibited during the months of April through October.
Stage IV – Severe to Critical Water Supply Shortage: 30% - 40% Target Water Savings
All water use restrictions for Stages II, and III, and the following:
1. Drought tolerant landscaping that minimizes irrigation and runoff is required at new
construction sites, and non-drought tolerant landscaping is prohibited.
2. The irrigation of ornamental landscapes or turf with potable water more than one day per
week is prohibited.
3. Existing pools shall not be emptied and refilled using potable water unless required for
public health and safety purposes.
Stage V – Critical Water Supply Shortage: 40% - 50% Target Water Savings
All water use restrictions for Stages II, III and IV, and the following:
1. No new water service connections are permitted unless the customer pays for sufficient
conservation measures to be applied elsewhere in the City, to offset anticipated water use
at the site to be served by the new water service, as determined by the City o f Palo Alto.
2. Ornamental landscape and turf irrigation with potable water is prohibited.
3. The washing of all vehicles is prohibited except for at commercial washing facility that
recirculates its water or uses recycled water.
4. Sprinkler irrigation is prohibited.
Stage VI – Water Emergency: Greater than 50% Target Water Savings
All water use restrictions for Stages II, III, IV, and V and the following:
1. Some targeted water use to keep trees alive may be permitted.
2. Water use for public health and safety purposes only.
1 “Ornamental landscapes” serve purely decorative purposes, and are distinguished from trees, edible gardens or
landscapes that provide more than a purely aesthetic function.
2 Customers with a public or private non-residential facility containing ornamental landscapes or turf which
supports a demonstrable business necessity or public benefit may apply for City approval of an alternative
irrigation schedule.
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APPENDIX G ‐ Water Supply And Demand Comparisons,
Without Bay Delta Plan Amendment
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Year Wholesale Supply and Demand Normal
ea
Single
Dry Yea
Dry Year
1
Dry Year
2
Dry Year
3
Dry Year
4
Dry Year
5
2030 Total Wholesale Demand 150,087 150,087 150,087 150,087 150,087 150,087 150,087
2030 Total Wholesale RWS Supply 150,087 150,087 150,087 150,087 150,087 150,087 150,087
2030 Difference (Surplus or Shortfall) - - - - - - -
2030 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
2035 Total Wholesale Demand 152,777 152,777 152,777 152,777 152,777 152,777 152,777
2035 Total Wholesale RWS Supply 152,777 152,777 152,777 152,777 152,777 152,777 152,777
2035 Difference (Surplus or Shortfall) - - - - - - -
2035 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
2040 Total Wholesale Demand 157,597 157,597 157,597 157,597 157,597 157,597 157,597
2040 Total Wholesale RWS Supply 157,597 157,597 157,597 157,597 157,597 157,597 157,597
2040 Difference (Surplus or Shortfall) - - - - - - -
2040 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
2045 Total Wholesale Demand 161,520 161,520 161,520 161,520 161,520 161,520 161,520
2045 Total Wholesale RWS Supply 161,520 161,520 161,520 161,520 161,520 161,520 161,520
2045 Difference (Surplus or Shortfall) - - - - - - -
2045 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
2050 Total Wholesale Demand 166,340 166,340 166,340 166,340 166,340 166,340 166,340
2050 Total Wholesale RWS Supply 166,340 166,340 166,340 166,340 166,340 166,340 166,340
2050 Difference (Surplus or Shortfall) - - - - - - -
2050 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Year Wholesale Supply and Demand Normal
ea
Single
Dry Yea
Dry Year
1
Dry Year
2
Dry Year
3
Dry Year
4
Dry Year
5
2030 Total Demand 9,783 9,783 9,783 9,783 9,783 9,783 9,783
2030 Total RWS Supply 9,783 9,783 9,783 9,783 9,783 9,783 9,783
2030 Difference (Surplus or Shortfall) - - - - - - -
2030 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
2035 Total Demand 9,677 9,677 9,677 9,677 9,677 9,677 9,677
2035 Total RWS Supply 9,677 9,677 9,677 9,677 9,677 9,677 9,677
2035 Difference (Surplus or Shortfall) - - - - - - -
2035 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
2040 Total Demand 9,634 9,634 9,634 9,634 9,634 9,634 9,634
2040 Total RWS Supply 9,634 9,634 9,634 9,634 9,634 9,634 9,634
2040 Difference (Surplus or Shortfall) - - - - - - -
2040 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
2045 Total Demand 9,635 9,635 9,635 9,635 9,635 9,635 9,635
2045 Total RWS Supply 9,635 9,635 9,635 9,635 9,635 9,635 9,635
2045 Difference (Surplus or Shortfall) - - - - - - -
2045 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
2050 Total Demand 9,680 9,680 9,680 9,680 9,680 9,680 9,680
2050 Total RWS Supply 9,680 9,680 9,680 9,680 9,680 9,680 9,680
2050 Difference (Surplus or Shortfall) - - - - - - -
2050 Difference (as % of Demand) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Table 1: Wholesale Supply and Demand Comparison for Projected Normal and Dry Year Scenarios
Without Bay-Delta Plan Amendment (AFY)
Table 2: Palo Alto Supply and Demand Comparison for Projected Normal and Dry Year Scenarios
Without Bay-Delta Plan Amendment (AFY)
WATER SUPPLY AND DEMAND COMPARISONS, WITHOUT BAY DELTA PLAN AMENDMENT
The following tables represent the projected supplies and demands during normal, single dry, and multiple dry
years (on a water year basis) for the scenario Without Implementation of the Bay-Delta Plan Amendment, for
both the Wholesale Regional Water System (RWS) and the City of Palo Alto. Under this scenario, the SFPUC
will have sufficient supplies to meet its projected wholesale demands. Refer to Table 28 and Table 29 in
Section 8 - Supply and Demand Comparison Provisions for the scenario With Implementation of the Bay-Dela
Plan Amendment.
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027041426
Resolution No. XXXX
Resolution of the Council of the City of Palo Alto Adopting the 2025
Urban Water Management Plan to be Submitted to the California Department
of Water Resources
R E C I T A L S
A. The California Legislature has enacted the Urban Water Management
Planning Act, California Water Code Sections 10610 - 10656 and 10608, as amended, which
requires every urban water supplier providing water to more than 3,000 customers or supplying
more than 3,000 acre-feet of water annually to prepare an urban water management plan
("Plan") that has as its primary objective the conservation and efficient use of water.
B. The City of Palo Alto ("City"), a municipal utility and chartered city, is an
urban water supplier providing water to a population over 60,000.
C. The Plan must be reviewed at least once every five years by the City, which
must amend the Plan, as necessary, after it has conducted a review.
D. The preparation of the updated Plan has been coordinated with other
public agencies to the extent practicable, and staff has encouraged the active involvement of
diverse social, cultural and economic sectors of the population within the City's retail water
service area during preparation of the Plan.
E. The Plan must be adopted by July 1, 2026, after it is first made available for
public inspection and a public hearing is noticed and held, and it must be filed with the California
Department of Water Resources within thirty days of adoption.
F. After reviewing a draft Plan at their May 6, 2026 meeting, the Utilities
Advisory Commission recommended that the Council adopt the Plan as presented; and
G. A noticed public hearing on the draft Plan was held by the City Council on
June 8, 2026, at which time public comments were heard and considered.
NOW, THEREFORE, the Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Council hereby adopts the 2025 Urban Water Management Plan of the
City of Palo Alto, which shall be filed with the City Clerk. The City Manager is hereby authorized
and directed to file the 2025 Urban Water Management Plan of the City of Palo Alto with the
California Department of Water Resources and the State Library.
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SECTION 2. The Council finds and determines that, under the California Water Code
Section 10652, the adoption of the Plan and the WSCP and this resolution does not constitute a
project under the California Environmental Quality Act, and no environmental assessment is
required.
AS TO FORM:
Director of Utilities
Director of Administrative Services
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Resolution No. XXXX
Resolution of the Council of the City of Palo Alto Adopting the 2025 Water
Shortage Contingency Plan Included in the Urban Water Management Plan to be
Submitted to the California Department of Water Resources
R E C I T A L S
A. The California Legislature has enacted the Urban Water Management
Planning Act, California Water Code Sections 10610 - 10656 and 10608, as amended, which
requires every urban water supplier providing water to more than 3,000 customers or supplying
more than 3,000 acre-feet of water annually to prepare an urban water management plan
("UWMP") that has as its primary objective the conservation and efficient use of water.
B. The California Water Code requires urban water suppliers to prepare a
Water Shortage Contingency Plan (WSCP) to be included in its UWMP.
C. The WSCP must be adopted, along with the UWMP, by July 1, 2026, after it
is first made available for public inspection and a public hearing is noticed and held, and it must
be filed with the California Department of Water Resources within thirty days of adoption.
D. After reviewing a draft WSCP, which is included in the UWMP, at their May
6, 2026 meeting, the Utilities Advisory Commission recommended that the Council adopt the
WSCP as presented; and
E. A noticed public hearing on the WSCP, included in the UWMP, was held by
the City Council on June 8, 2026, at which time public comments were heard and considered.
NOW, THEREFORE, the Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Council hereby adopts the 2025 Water Shortage Contingency Plan of the
City of Palo Alto, included in its UWMP, which shall be filed with the City Clerk. The City Manager is
hereby authorized and directed to file the 2025 Water Shortage Contingency Plan of the City of
Palo Alto, included in the UWMP, with the California Department of Water Resources and the
State Library.
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027041426
SECTION 2. The Council finds and determines that, under the California Water Code
Section 10652, the adoption of the Plan and the WSCP and this resolution does not constitute a
project under the California Environmental Quality Act, and no environmental assessment is
required.
AS TO FORM:
Director of Utilities
Director of Administrative Services
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0290193_20260422_ms29
Ordinance No.
Ordinance of the Council of the City of Palo Alto Amending Chapter 12.32
(Water Use Regulations) of the Palo Alto Municipal Code to Incorporate
Additional Water Use Regulations
The Council of the City of Palo Alto ORDAINS as follows:
SECTION 1. Findings and Declarations. The City Council finds and declares as follows:
A. Article 10, Section 2 of the California Constitution declares that waters of the State are to
be put to beneficial use, that waste, unreasonable use, or unreasonable method of use of
water be prevented, and that water be conserved for the public welfare.
B. The State of California is prone to drought conditions, which result in water supply
shortages.
C. The City of Palo Alto recognizes the continuing need to manage water resources under its
jurisdiction and control in a constitutionally compliant manner.
D. Section 12.32.010 of the Palo Alto Municipal Code sets forth permanent water use
restrictions applicable to all City water customers in order to responsibly manage the
City’s water resources.
E. City regulation of the time and manner of water use, rate design, the method of
application of water for certain uses, and establishment of enforcement procedures in
support of water use management is an effective and immediately available means of
conserving water and is authorized by Palo Alto Municipal Code Section 12.20.010.
F. California Assembly Bill (AB) 1572 (2023) prohibits the use of potable water to irrigate
nonfunctional turf at most commercial, industrial, and institutional properties, including
common areas managed by homeowner associations, and requires the City of Palo Alto
to update its regulations to enforce the State-mandated prohibitions.
G. In 2024, the State Water Resources Control Board adopted the “Making Conservation as
a Way of Life” regulation (23 CCR § 965 et seq.), which establishes urban water use
objectives and performance measures for retail water suppliers like the City.
H. The Council wishes to make minor changes to existing water use restrictions and adopt
additional permanent water use restrictions in order to responsibly manage the City’s
water resources, meet its urban water use objectives, and comply with AB 1572.
SECTION 2. Section 12.32.010 (Water Use Regulations) of Chapter 12.32 (Water Use
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0290193_20260422_ms29
Regulations) of the Palo Alto Municipal Code is hereby amended as follows (additions
underlined, deletions struck through):
12.32.010 Water use regulations.
No purchaser of water from the city of Palo Alto, nor any customers of the water utility of the
city of Palo Alto, shall use water or allow any other person to use water under the control of
such customer or purchaser in the following ways:
(a) Potable water shall not be allowed to flood or run off into gutters: driveways, sidewalks,
streets or other unlandscaped areas.
(b) By means of a hose to wash cars, boats, trailers, buses or other vehicles or to wash
sidewalks, building structures, other hard-surfaced areas or parts thereof without an
operating automatic shut-off valve. Use of a hose for such purposes should be avoided
whenever possible.
(c) Potable water for consolidation of backfill and other nondomestic uses in construction
shall not be used if other water sources such as reclaimed water are available, as
determined by the director of utilities or his or her designee. Applicants for hydrant
permits from the city of Palo Alto shall be deemed to have consented to restrictions on
water use which may be imposed by the director of utilities or his or her designee.
(d) Any broken or defective plumbing, sprinklers, watering or irrigation systems which
permit the escape or leakage of water shall be repaired or replaced as soon as possible,
but no later than the date established by the director of utilities, or his or her designee,
as reasonable after observation of the broken or defective system.
(e) The irrigation of turf or ornamental landscapes, which serve purely decorative purposes,
and are distinguished from trees, edible gardens or landscapes that provide more than a
purely aesthetic function, with potable water shall not be allowed between 910:00 a.m.
and 6:00 p.m., except via hand watering with a bucket or a hose with an operating shut-
off valve.
(f) The use of potable water in a fountain or other decorative water feature is prohibited,
except where the water is part of a recirculating system.
(g) The use of potable water for street sweepers and washers is prohibited if non-potable
water is available, as determined by the Director of Utilities, or his or her designee.
(h) Commercial car washes must use recycled water systems, if recycled water is available,
as determined by the Director of Utilities, or his or her designee, and economically
feasible.
(i) The use of potable water for the irrigation of nonfunctional turf located on commercial,
industrial, and institutional properties, other than a cemetery, and on properties of
homeowners’ associations, common interest developments, and community service
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0290193_20260422_ms29
organizations or similar entities is prohibited as of the following dates:
(i) All properties owned by local governments, local or regional public agencies, and
public water systems, beginning January 1, 2027.
(ii) All other institutional properties and all commercial and industrial properties,
beginning January 1, 2028.
(iii) All common areas of properties of homeowners’ associations, common interest
developments, and community service organizations or similar entities,
beginning January 1, 2029.
Notwithstanding the provisions of this subdivision (i), the use of potable water is not
prohibited to the extent necessary to ensure the health of trees and other perennial
nonturf plantings, or to the extent necessary to address an immediate health and safety
need. For the purposes of this subdivision (i), relevant terms have the same meaning as
in Section 10608.12 of the Water Code.
SECTION 3. If any section, subsection, clause or phrase of this Ordinance is for any
reason held to be invalid, such decision shall not affect the validity of the remaining portion or
sections of the Ordinance. The Council hereby declares that it would have adopted the
Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the
fact that any one or more sections, subsections, sentences, clauses or phrases be declared
invalid.
SECTION 4. The Council finds that this ordinance is categorically exempt from review
under the California Environmental Quality Act (CEQA) pursuant to Section 15307 and 15308 of
the CEQA Guidelines (actions taken by regulatory agencies for the protection of natural
resources and the environment).
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0290193_20260422_ms29
SECTION 5. This ordinance shall be effective on the thirty-first day after the date of
its adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
City Clerk Mayor
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
City Attorney or Designee City Manager
Director of Utilities
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Item No. 5 Page 1 of 3
Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: May 6, 2026
Report #: 2601-5794
TITLE
2026 Annual Water Shortage Assessment Report
RECOMMENDATION
Staff recommends the Utilities Advisory Commission (UAC) recommend City Council adopt the
2026 Annual Water Shortage Assessment Report
EXECUTIVE SUMMARY
Beginning in 2022, every urban water supplier in California must conduct an Annual Water
Supply and Demand Assessment as required by California Water Code Section 10632 (a). Each
urban water supplier must also submit an Annual Water Shortage Assessment Report to the
Department of Water Resources (DWR) on or before July 1, as required by California Water
Code Section 10632.1. The City’s Annual Water Shortage Assessment Report (Attachment A,
Tables 1-5) show that there is no water shortage anticipated for Fiscal Year 2027.
On April 14, 2026, the San Francisco Public Utilities Commission (SFPUC), Palo Alto’s water
supplier, provided Palo Alto with the Water Supply Availability Update for the current year.
Although precipitation at Hetch Hetchy has been near median, snowpack in the upper
watersheds is only 25% of the April 1 median. Even with these historic conditions, the entire
water system is expected to be filled by the end of May 2026. SFPUC’s Water Bank is full and
will continue to support deliveries throughout the year, while reservoir storage as of April 13,
2026 remains well above typical levels for this time of year. The City of Palo Alto encourages
continued water conservation efforts and the City’s website contains more information about
available water conservation programs.1
1 https://www.paloalto.gov/Departments/Utilities/Ways-to-Save
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Item No. 5 Page 2 of 3
DISCUSSION
To prepare the 2026 Annual Water Shortage Assessment Report, staff followed the procedures
outlined in its Water Shortage Contingency Plan, contained in Section 7 of the City’s 2020 Urban
Water Management Plan (UWMP).3 Palo Alto’s 2026 Annual Water Shortage Assessment
Report uses the DWR-developed Optional Annual Assessment Tool format. This format includes
the 5 tables shown in Attachment A. Staff will submit the standard tables to DWR by July 1,
2026. “Table 1. Annual Assessment Information” (Table 1) provides required overview
information. The remaining tables project water supply and demand for FY 2027 under dry
conditions, as required, and finds that there is no projected water shortage.
Upon Council adoption, staff will submit the 2026 Annual Water Shortage Assessment Report to
the Department of Water Resources. After Palo Alto and other urban water suppliers report to
DWR on the 2026 Annual Water Shortage Assessment Reports, DWR will prepare a summary
report on its review of the Annual Water Supply and Demand Assessment results and provide it
to the State Water Resources Control Board (State Board) by September 30, 2026. The DWR
report will include water shortage information at the supplier level, as well as regional and
statewide analysis of water conditions as required by California Water Code Section 10644
(c)(1)(B).
Potable Water
Palo Alto receives 100% of its potable water supply from the SFPUC Regional Water System and
staff used the SFPUC's April 14, 2026 Water Supply Availability Update to determine water
supply.
• “Table 2: Water Demands” (Table 2) provides a demand projection for each month of
FY 2027;
• “Table 3: Water Supplies” (Table 3) notes that there is sufficient supply to meet Palo
Alto’s demand and projects supply equal to the demand projection since there is no
projected water shortage in FY 2027;
• “Table 4(P): Potable Water Shortage Assessment” (Table 4(P)) compares projected FY
2026 demand with supply and illustrates that there is no shortage projected for FY 2027;
• “Table 5: Planned Water Shortage Response Actions” (Table 5) shows no triggered
water shortage actions.
Palo Alto’s eight permanent water use regulations remain in effect (see Palo Alto Municipal
Code Section 12.32.010).
Non-Potable Water
For non-potable recycled water, Table 2 provides the demand projection and Table 3 notes that
there is sufficient supply to meet Palo Alto’s non-potable recycled water demand in FY 2026.
3 https://www.paloalto.gov/files/assets/public/v/1/utilities/uwmp/2020-uwmp_final-submission-to-dwr.pdf
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Item No. 5 Page 3 of 3
For that reason, the supply is set to equal demand and there is no shortage of non-potable
water projected in Table 4(NP), “Non Potable Water Shortage Assessment”.
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
AUTHOR/TITLE:
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Attachment A: 2026 Annual Water Shortage Assessment Report Tables
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= From prior tables
= Auto calculated
Use Type Start Year: 2026 Volumetric Unit Used2:AF
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Total by Water
Demand Type
All Demands 1313 1287 1309 1090 931 687 655 576 661 699 971 1137 11316
0
0
0
0
0
0
0
0
0
1313 1287 1309 1090 931 687 655 576 661 699 971 1137 11316
All Demands Tertiary 54 53 35 22 11 2 2 11 9 24 42 50 315
0
0
0
0
54 53 35 22 11 2 2 11 9 24 42 50 315
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Total
0
0
0
0
Table 2: Water Demands1
Projected Water Demands - Volume3
Total by Month (Non-Potable)
1Projections are based on best available data at time of submitting the report and actual demand volumes could be different due to many factors.
2Units of measure (AF, CCF, MG) must remain consistent.
3When opting to provide other than monthly volumes (bi-monthly, quarterly, or annual), please see directions on entering data for Projected Water Demand in the Table Instructions.
Notes: Potable unconstrained customer demand determined using the end-use model described in the 2020 UWMP Section 4. Non-potable unconstrained customer demand determined based on 2020 UWMP projection.
Total by Month (Potable)
Additional
Description
(as needed)
Level of
Treatment
for Non-
Potable
Supplies
Drop-down
list
Drop-down list
May select each use multiple times
These are the only Use Types that will
be recognized by the WUEdata online
submittal tool
(Add additional rows as needed)
Demands Served by Potable Supplies
Demands Served by Non-Potable Supplies
Three years ago total demand
Four years ago total demand
Optional (for comparison purposes)
Last year's total demand
Two years ago total demand
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= From prior tables
= Auto calculated
Use Type Start Year: 2025 Volumetric Unit Used2:AF
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Total by Water
Demand Type
All Demands 1310 1285 1307 1088 929 686 654 575 660 697 969 1135 11295
0
0
0
0
0
0
0
0
0
1310 1285 1307 1088 929 686 654 575 660 697 969 1135 11295
All Demands Tertiary 54 53 35 22 11 2 2 11 9 24 42 50 315
0
0
0
0
54 53 35 22 11 2 2 11 9 24 42 50 315
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Total
0
0
0
0
Table 2: Water Demands1
Projected Water Demands - Volume3
Total by Month (Non-Potable)
1Projections are based on best available data at time of submitting the report and actual demand volumes could be different due to many factors.
2Units of measure (AF, CCF, MG) must remain consistent.
3When opting to provide other than monthly volumes (bi-monthly, quarterly, or annual), please see directions on entering data for Projected Water Demand in the Table Instructions.
Notes: Potable unconstrained customer demand determined using the end-use model described in the 2020 UWMP Section 4. Non-potable unconstrained customer demand determined based on 2020 UWMP projection.
Total by Month (Potable)
Additional
Description
(as needed)
Level of
Treatment
for Non-
Potable
Supplies
Drop-down
list
Drop-down list
May select each use multiple times
These are the only Use Types that
will be recognized by the WUEdata
online submittal tool
(Add additional rows as needed)
Demands Served by Potable Supplies
Demands Served by Non-Potable Supplies
Three years ago total demand
Four years ago total demand
Optional (for comparison purposes)
Last year's total demand
Two years ago total demand
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= From prior tables
= Auto calculated
Water Supply Start Year: 2026 Volumetric Unit Used2:AF
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun
Total by
Water
Supply Type
Purchased/Imported Water
San Francisco
Public Utilities
Commission
Regional
Water Supply
System
1313 1287 1309 1090 931 687 655 576 661 699 971 1137 11316
0
0
0
0
0
0
0
0
0
1313 1287 1309 1090 931 687 655 576 661 699 971 1137 11316 0
Recycled Water
Recycled
Water from
the Regional
Water Quality
Control Plant
54 53 35 22 11 2 2 11 9 24 42 50 315
0
0
0
0
54 53 35 22 11 2 2 11 9 24 42 50 315 0
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Total
0
Table 3: Water Supplies1
Projected Water Supplies - Volume3
Water
Quality
Drop-down
List
Total Right
or Safe
Yield*
(optional)
Additional
Detail on
Water Supply
Drop-down List
May use each category multiple
times.These are the only water
supply categories that will be
recognized by the WUEdata online
submittal tool
(Add additional rows as needed)
Potable Supplies
Non-Potable Supplies
eAR Reported Total Water Supplies
Optional (for comparison purposes)
1Projections are based on best available data at time of submitting the report and actual supply volumes could be different due to many factors.
2Units of measure (AF, CCF, MG) must remain consistent.
3When opting to provide other than monthly volumes (bi-monthly, quarterly, or annual), please see directions on entering data for Projected Water Supplies in the Table Instructions.
Notes: Palo Alto purchases 100% of its potable water from SFPUC; Palo Alto used the SFPUC's March 1, 2024 Water Supply Availability Update to determine water supply. Palo Alto supplies recycled water for irrigation of the municipal golf course,
a park and some other minor applications. There is sufficient supply of both potable and recycled water to meet demand.
Total by Month (Potable)
Total by Month (Non-Potable)
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= From prior tables
= Auto calculated
Water Supply Start Year: 2025 Volumetric Unit Used2:AF
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun
Total by
Water
Supply Type
Purchased/Imported Water
San Francisco
Public
Utilities
Commission
Regional
Water
Supply
System
1310 1285 1307 1088 929 686 654 575 660 697 969 1135 11295
0
0
0
0
0
0
0
0
0
1310 1285 1307 1088 929 686 654 575 660 697 969 1135 11295 0
Recycled Water
Recycled
Water from
the Regional
Water
Quality
Control Plant
54 53 35 22 11 2 2 11 9 24 42 50 315
0
0
0
0
54 53 35 22 11 2 2 11 9 24 42 50 315 0
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Total
0
Table 3: Water Supplies1
Projected Water Supplies - Volume3
Water
Quality
Drop-down
List
Total Right
or Safe
Yield*
(optional)
Additional
Detail on
Water
Supply
Drop-down List
May use each category multiple
times.These are the only water
supply categories that will be
recognized by the WUEdata
online submittal tool
(Add additional rows as needed)
Potable Supplies
Non-Potable Supplies
eAR Reported Total Water Supplies
Optional (for comparison purposes)
1Projections are based on best available data at time of submitting the report and actual supply volumes could be different due to many factors.
2Units of measure (AF, CCF, MG) must remain consistent.
3When opting to provide other than monthly volumes (bi-monthly, quarterly, or annual), please see directions on entering data for Projected Water Supplies in the Table Instructions.
Notes: Palo Alto purchases 100% of its potable water from SFPUC; Palo Alto used the SFPUC's March 1, 2024 Water Supply Availability Update to determine water supply. Palo Alto supplies recycled water for irrigation of the
municipal golf course, a park and some other minor applications. There is sufficient supply of both potable and recycled water to meet demand.
Total by Month (Potable)
Total by Month (Non-Potable)
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= Auto calculated
= For manual input
Table 4(P): Potable Water Shortage Assessment1 Start Year: 2026 Volumetric Unit Used2:AF
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun3 Total
Anticipated Unconstrained Demand 1313 1287 1309 1090 931 687 655 576 661 699 971 1137 11316
Anticipated Total Water Supply 1313 1287 1309 1090 931 687 655 576 661 699 971 1137 11316
Surplus/Shortage w/o WSCP Action 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
% Surplus/Shortage w/o WSCP Action 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
State Standard Shortage Level 0 0 0 0 0 0 0 0 0 0 0 0 0
Benefit from WSCP: Supply Augmentation 0.0
Benefit from WSCP: Demand Reduction 0.0
Revised Surplus/Shortage with WSCP 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
% Revised Surplus/Shortage with WSCP 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
= From prior tables
Planned WSCP Actions4
1Assessments are based on best available data at time of submitting the report and actual volumes could be different due to many factors.
2Units of measure (AF, CCF, MG) must remain consistent.
3When optional monthly volumes aren't provided, verify Tables 2 and 3 use the same columns for data entry and are reflected properly in Table 4 and make sure to use those same columns to enter the benefits from Planned WSCP Actions. Please see directions
on the shortage balancing exercise in the Table Instructions. If a shortage is projected, the supplier is highly recommended to perform a monthly analysis to more accurately identify the time of shortage.
4If you enter any WSCP Benefits, then you must enter the corresponding planned Actions into Table 5.
= Auto calculated
= For manual input
Table 4(NP): Non-Potable Water Shortage Assessment1 Start Year: 2026 Volumetric Unit Used2:AF
Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun3 Total
Anticipated Unconstrained Demand: Non-Potable 54 53 35 22 11 2 2 11 9 24 42 50 315
Anticipated Total Water Supply: Non-Potable 54 53 35 22 11 2 2 11 9 24 42 50 315
Surplus/Shortage w/o WSCP Action: Non-Potable 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
% Surplus/Shortage w/o WSCP Action: Non-Potable 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
Benefit from WSCP: Supply Augmentation 0.0
Benefit from WSCP: Demand Reduction 0.0
Revised Surplus/Shortage with WSCP 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
% Revised Surplus/Shortage with WSCP 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
1Assessments are based on best available data at time of submitting the report and actual volumes could be different due to many factors.
2Units of measure (AF, CCF, MG) must remain consistent.
3When optional monthly volumes aren't provided, verify Tables 2 and 3 use the same columns for data entry and are reflected properly in Table 4 and make sure to use those same columns to enter the benefits from Planned WSCP Actions. Please see directions
on the shortage balancing exercise in the Table Instructions. If a shortage is projected, the supplier is highly recommended to perform a monthly analysis to more accurately identify the time of shortage.
4If you enter any WSCP Benefits, then you must enter the corresponding planned Actions into Table 5.
= From prior tables
Planned WSCP Actions4
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July 1, 2026 to June 30, 2027
Enter Amount
(Drop-down
List)
Select % or
Volume Unit
Start Month End Month
NOTES:
Notes Section to be used
only for clarifying details, and
not for listing specific
actions. Actions must be
entred into table rows
1If you plan Supply Augmentation Actions then you must enter WSCP Benefits from Supply Augmentation Actions into Table 4. If you plan Demand Reduction
Actions then you must enter WSCP Benefits from Demand Reduction Actions into Table 4.
2If an Action is planned to be implemented in multiple non-contiguous periods of the year, please make separate entries on multiple rows for the same action
spanning the different implementation periods.
Table 5: Planned Water Shortage Response Actions
Add additional rows as needed
How much is action going to
reduce the shortage gap?
(Optional)
When is shortage response
action anticipated to be
implemented2?Is action
already being
implemented?
(Y/N)
ACTIONS1: Demand Reduction, Supply
Augmentation, and Other Actions.
(Drop-down List)
These are the only categories that will be
accepted by the WUEdata online
submittal tool. Select those that apply.
Anticipated Shortage
Level
Drop-down List of
State Standard Levels (1 -
6) and Level 0 (No
Shortage)
Palo Alto currently inplements permanent water use restrictions according to the Palo Alto Municipal Code Section
12.32.010 https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-69362#JD_Chapter12.32. There is
currently no water shortage projected for FY 2027 in Table 4(P).
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Date: May 6, 2026
12-MONTH ROLLING CALENDAR
FORECAST
CCM – City Council Meeting
FCM – Finance Committee Meeting PS – Policy and Services
May 2026
FY 2027 Utilities Operating and CIP Budget
Urban Water Management Plan
Water Supply and Demand Assessment
Election of UAC Chair and Vice Chair
FY 2027 Utilities Operating and CIP Budget (FCM)
Updates to Utilities Rules and Regulations
Fiber-to-the-Premise Update Informational Report
Grid Modernization FY 2026 Update Informational
Report
VertexOne/WaterSmart Contract Amendment
June 2026
FY 2026 - Q3 Report, Informational
Commission Norms
UAC Work Plan
Approval of Third Phase Agreement with
Northern California Power Agency
FY 2027 Utility Rates and 5-year Forecasts
(ACTION)
FY 2027 Utilities Operating and CIP Budget
Commercial Efficiency and Electrification Program
Commercial Customer Characterization Tool &
Commercial Electrification Technical Assistance
Programs
Urban Water Management Plan (ACTION)
Permanent Water Use Ordinance
Sanitary Sewer CCTV
Approval to Extend Existing Contract Number
C24185875 with Woodard and Curran, Inc. for
Hydraulic Modeling Support for Wastewater
Engineering Services
Utility Underground Box Manufacturer
Prequalification Process and Authorization with
Jensen Precast and Oldcastle Infrastructure
Recommended Changes to Purchasing Thresholds
and Muni Code Changes
July 2026
FTTP Pilot Report Out
Grid Mod Project Update
Long Duration Resiliency
Status Update on Gas Transition Study
GoGreen Business Energy Financing Program
Time of Use Update
August 2026 FTTP Pilot Report Out (FCM & CCM)
GoGreen Business Energy Financing Program
Sewer Lateral Replacement Project
CLEAResult for Residential Energy Efficiency and
Electrification
Approval of Bond Financing for Grid
Modernization Project (FCM)
Refinancing of the 2009A Water Revenue Bonds
(FCM)
North American Energy Standards Board (NAESB)
Agreement with JPMorgan Chase Bank, N.A
Approval of Third Phase Agreement with
Northern California Power Agency (FCM &CCM)
Fiber Mat'l Contract 4352F Reel & Fiber Const &
Contract On-Call Trench Substructure
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September 2026 September 2, 2026 Substations’ Electric Equipment and Structures
Painting Contract
Approval of Bond Financing for Grid
Modernization Project
Refinancing of the 2009A Water Revenue Bonds
October 2026 October 7, 2026
FY 2026 – Q4 Report, Discussion
November 2026 November 4, 2026
FY 2028 Preliminary Rates
Long Duration Resiliency
December 2026 December 2, 2026 FY 2028 Preliminary Rates (FCM)
January 2027 January 6, 2027
February 2027 February 3, 2027
March 2027 March 3, 2027
April 2027 April 7, 2027
Council Recap on Utilities Items – April 2026
Approved By Council & Finance Committee:
Duke’s Root Control for Root Foaming Contract
Utilities Reserves Advisory Report (P&S)
Legislative Update (P&S)
Amendment No 3 with Larratt Brother Plumbing
FY 2027 Electric Rates and 5-Year Forecasts (FCM)
FY 2027 Gas Rates and 5-year Forecasts (FCM)
Recurring Items Items to Be Scheduled
Educational Update on any Type of New Technology or Terminology
Projects with a Resiliency Component
Quarterly Reports (Q1-3 Info Rpts)(Q4 Discussion Summary of the year)
o Financial Report
o Utilities Programs Update
Informational EV Charger Installation Updates
Informational Bucket 1 REC Sales Updates
Informational Fiber Updates
Rates and Financial Forecast
Utilities Budget
Utilities Quarterly Informational Report – Council
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Item No. 3 Page 1 of 2
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Utilities Advisory Commission
Supplemental Memo
From: Alan Kurotori, Director of Utilities
Meeting Date: May 6, 2026
Item Number: 3
Report #:2604-6310
TITLE
SUPPLEMENTAL REPORT: Recommendation to the City Council to Adopt the Proposed
Operating and Capital Budgets for the Utilities Department for Fiscal Year 2027
BACKGROUND
Linked and referenced below are the FY 2027 Proposed Operating and Capital budgets for the
Utilities Department.
The entire Utilities Operating budget for FY 2027 can be downloaded and viewed in full from
the link below:
Proposed Utilities Operating Budget for FY 20271
Utilities Department - Pages 445 - 515
The entire Utilities CIP budget for FY 2027 – FY 2031 with the individual project pages can be
downloaded and viewed in full from the link below:
Proposed Utilities Capital Budgets for FY 2027 – FY 20312
Electric CIP – Pages 417 – 495
Fiber Optic CIP – Pages 497 - 517
Gas CIP – Pages 519 – 553
Wastewater Collection CIP – Pages 587 - 625
1 Proposed Utilities Operating Budget for FY 2027
https://www.paloalto.gov/files/assets/public/v/1/administrative-services/city-budgets/fy-2027-city-
budget/proposed/fy-2027-proposed-operating-budget-book_online.pdf
2 Proposed Utilities Capital Budgets for FY 2027 – FY 2031
https://www.paloalto.gov/files/assets/public/v/1/administrative-services/city-budgets/fy-2027-city-
budget/proposed/fy-2027-proposed-capital-budget-book_online.pdf
Item #3
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Item No. 3 Page 2 of 2
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Water CIP – Pages 667 – 711
APPROVED BY:
Alan Kurotori, Director of Utilities
Staff: Dave Yuan, Strategic Business Manager
Item #3
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