COMMITTEE TO SAVE LAKE MERCED

215 STUYVESANT DRIVE
SAN ANSELMO CA 94960
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COMMENTS ON EDAW TASK 3 TECHNICAL MEMORANDUM RE: INITIATIVE TO RAISE AND MAINTAIN LAKE LEVEL AND IMPROVE WATER QUALITY – LAKE MERCED

INTRODUCTION.   A fundamental backdrop on these comments necessarily includes consideration of the schedule proposed by the San Francisco Public Utilities Commission (SFPUC) for completion of the initiative.  At a public meeting on August 20,2003 SFPUC proposed a schedule that calls for a Commission update and finalization of the plan in January 2004. That is about four to five months, or  80 to 100 working days from now.  Yet, as is clear from the Task 3 Memo there are major unresolved problems and issues with respect to all of the four major components of the proposed initiative.  It is highly problematical whether any or all of these problems and issues can be finally resolved by year end 2003.

Moreover, an alternative to raising the lake level and improving water quality that may very well be more feasible, more environmentally benign, and less costly to taxpayers and ratepayers apparently remains off the table.  That alternative should be considered on its merits as a stand alone alternative and as an alternative to be considered in combination with one or more of the four alternatives currently on the table.  That alternative is to continue the efforts to reduce aquifer pumping in the Westside Basin and to continually monitor the effects that recent reductions and additional reductions have on lake level and water quality.

Additionally, nothing that has been made public to date takes into consideration the pending CalTrout petition and the ongoing confidential mediated negotiations relating to the petition.  Are we expected to assume that those negotiations will be completed by January 2004 and that all parties thereto will be satisfied with the “finalized” plan contemplated for January 2004?

SPECIFIC COMMENTS.  Each comment will reference the applicable page number in Task 3 Memo .

    p. iv –  There does not appear to be a clear explanation as to why one year and three year periods were selected for proposed water additions to attain the four alternative lake levels.  

    p. v – The second paragraph starts with the sentence, “Recycled water from either the City of Daly City or the SFPUC’s Oceanside Plant could provide a nearby abundant source.”  No supporting evidence is provided either here or on page 39 (where the recycled water alternative is discussed in more detail) to justify saying that Daly City could provide an “abundant” amount of water.  The contract between Daly City and its three golf course customers gives the golf courses considerable flexibility in how much of Daly City’s capacity they might take. Task 3 Memo  should be revised to show the specific amount of water potentially available from Daly City, assuming the golf courses took the maximum allowable amount of water.

    p. v – The paragraph relating to storm water acknowledges that there is a problem with coliform and that to date the source of coliform has not been identified.  Given the fact that SFPUC proposes to finalize its plans in January 2004, some indication of how long Daly City has been trying to identify the source should be spelled out and some knowledgeable expert should be asked to predict the likelihood that the source will be identified, and eliminated, before January 2004.  Likewise, more detail is needed immediately on the “separate pilot project….underway” to deal with the coliform problem if the source cannot be identified and eliminated.  Will this separate project be completed prior to January 2004?

    p. v – The paragraph relating to SFPUC system water states that a dechloramination process will be “cost and space prohibitive”.  This caution is repeated on pages 42 and 56.  Yet, the table on page 58 characterizes the cost as being “low/medium”.  Clarification is needed.

    p. v – The paragraph relating to Groundwater, characterizes addition of groundwater as being “easy-to-implement” while acknowledging that conveyance issues could be costly and “need to be addressed.” It is not clear whether the “easy-to-implement” conclusion relates solely to the following tentative conclusion that  treatment would “likely” not be required because groundwater around the lake is “assumed” to be similar in quality to water already discharging into the lake. The more detailed discussion on pages 44 and 45 suggest that there is limited data to support the conclusion that groundwater quality will not be an issue if it is to be added to the lake. Additionally, it is not clear why the discussion on pages 44 and 45 includes wells in the shallow aquifer, as there has not been serious consideration given to pumping from the shallow aquifer to replenish the lake.  Finally, any pumping of groundwater for lake additions presents an issue not explicitly mentioned in Task Memo 3.  The 1993 GeoResources study (at page 54) points out that addition of groundwater does not increase lake levels as much as addition of an equal amount of water from another source due to the increased seepage resulting from the groundwater pumping.  Task 3 Memo implicitly acknowledges this by saying that the effects of groundwater extraction on the lake-aquifer system “will need to be reviewed in greater detail”.  No hint is given as to when this needed review might occur; before or after January 2004.  Finally, similar to the inconsistency in projected costs for SFPUC system water, Task 3 Memo gives conflicting conclusions here.  On p. vi it said that if the wells are not located adjacent to Lake Merced conveyance costs “could” be costly.  Yet, p. 58 shows the cost of the groundwater option to be “low”.

    p. 2 – The middle paragraph acknowledges that the 1993 GeoResources report recommends an optimal lake level of 26 feet on the gage board.  This paragraph should be expanded to also point out that SFPUC resolution 10,435 (1950) mandates that in no instance should the lake level be drawn down below 27 feet on the gage board.  There may be some uncertainty as to the meaning of “drawn down”, but the resolution certainly indicates that in 1950 the SFPUC believed 27 feet was an appropriate or optimal level.

    p. 4 – Here and elsewhere (pages 5, 6 and 31) Task 3 Memo cites with seeming approval the 1993 GeoResources study.  The relevance of this will be discussed in the Summary and Conclusions section of these comments.

    p. 7.  Here, at the conclusion of its history of Lake Merced, Task 3 Memo states that, “Ground-water pumping for irrigation purposes was confined to the San Francisco Zoo, and Golden Gate Park until it ceased in the early 1990’s.”  This statement is confusing and potentially misleading in at least three respects: (1) does the sentence only relate to pumping by Spring Valley Water Company? (2) the sentence leaves the potential implication that there is no longer pumping going on at the Zoo and Golden Gate Park; (3) the sentence implies by silence that there was never pumping or direct withdrawal from Lake Merced at Harding Park; the GeoResources report at page 56 indicates that in 1990 Harding Park switched from direct pumping out of the lake to municipal water.

    p. 15 – Here, in its conclusion to the Hydrology section, Task 3 Memo acknowledges and confirms what activists and independent hydrologists have maintained all along: that “[l]ocal pumping by municipalities, cemeteries and golf courses, as well as surface water diversion and lack of natural recharge….has led to declining water levels in the lake.” Yet, as has been discussed above and in the Summary and Conclusions section of these comments, the current proposal does not in any way address the merits of continued curtailment of pumping as an alternative to dealing with lake level and water quality issues.

    p. 17 – In the interest of accuracy, the statement in the middle of the page that the boat hoists are “currently inoperable” ought to be amended to reflect the reality that the hoists are unusable because they are many feet removed from the lake’s shoreline.  

    p. 20 – There are seven conditions listed which Task 3 Memo says are presumed to contribute to low dissolved oxygen conditions.  Would it not be more to the point to simply say that a lack of an adequate level and volume of water is the true casual connection to the low dissolved oxygen situation?

    p. 30 – As an introduction to the section on options for raising the lake, Task 3 Memo says that eight options have been considered.  To even the careful reader it is probably not clear what eight options are intended.  If the “eight” is derived by using the one and three year periods mentioned on page iv multiplied by the four (2, 4, 6 and 8 feet) water level increases being considered, then that ought to be spelled out in so many words.  As mentioned above, an explanation is needed as to why one and three year periods were selected.

    pp. 42& 43 – Passing reference is made to an analysis that is “underway” in an attempt to find a cost effective solution to deal with the fact that shortly SFPUC system water will not be available for addition to the lake because of chloramines.  Analogous to the efforts to detect the source of coliform in storm water, some indication should be given in Task 3 Memo as to how long SFPUC has known that chloramine would be added to system water in late 2003, and how long have studies and analysis been going on in an effort to find a cost effective way to make system water acceptable for addition to the lake after late 2003.  Like the coliform situation, at this point (not a few days before a final plan is submitted to the public) an expert ought to render an opinion as to the likelihood that the issue can be favorably resolved.

SUMMARY AND CONCLUSIONS

    Task 3 Memo reflects SFPUC’s apparent intent to deal with lake level and water quality problems utilizing one or some combination of four sources of water for addition to the lake.  There are serious unresolved problems with each of the four that are summarized as follows:

Recycled Water.  It is not clear whether there is currently an adequate quantity of recycled water. (Putting reliance on the possibility of additional recycled water from SFPUC’s Oceanside plant should not even be considered unless and until SFPUC is prepared to put forth a legally enforceable commitment that an appropriate quantity of water will be available by a specific date.)  Even if an adequate quantity of recycled water is available,  Task 3 Memo acknowledges that “significant permitting and treatment requirements” need to be addressed (p. v).  There is limited precedent in California for discharge of recycled water into sources (or potential sources) of drinking water.  Some very worthwhile programs have gone down in the face of public opposition, which admittedly may have not always been rationale.  Nonetheless, the reality is that there are no assurances currently available that introduction of recycled water to Lake Merced will be blessed by applicable regulatory agencies or the public.  Finally, the chart on page 58 confirms that the cost of recycled water will be “high”.  Who will pay these costs?  Can all these questions be answered by January 2004?

Stormwater.  Suffice it to say that this option should not be seriously considered until the coliform problem has been diagnosed and a cost effective and assured solution has been presented to the public.  Based on what little information is currently available, it seems highly problematical whether this will happen prior to January 2004.

SFPUC System Water.   Little more can be said than what was said above because of the sparseness and inconsistencies in what currently appears in Task 3 Memo.  In one place the cost is “prohibitive” and in another it is “low/medium”.  The Memo acknowledges (p.v) that there are other potential problems – concerns using city water to fill the lake and unreliability (i.e. unavailability) in times of drought.  Will the cost issue and the other concerns be any closer to being resolved prior to January 2004?

Groundwater.   While possibly the theoretically best of the four alternatives presented, this appears to have the most question marks.  Is it really contemplated to pump from the shallow aquifer?  What would be the costs, including conveyance costs?  What would the effect be on the aquifer-lake system?  When will these questions be answered?

Task 3 Memo seems to approve the 1993 GeoResources report.  The GeoResources report gives quite specific projections regarding lake level increases that will result from pumping reductions, both in terms of number of feet in increase and time to attain the increases.  (See pages 51, 52, 56 and 57 of the GeoResources report).  Rates of increase in level range from 4 to 10 feet depending on the scenario used, and time to attain those rates ranged from 15 to 30 years depending upon the scenario used.  The March 2002 Luhdorff and Scalmanini report, Conceptualization of the Lake-Aquifer System etc, at page 46 is much less specific in saying that it “would likely take a combination of widespread pumping reductions, of at least decades, to return the basin to sufficiently high ground-water levels that would cause Lake Merced to rise.”  How many decades?

This discussion necessarily involves mention of the appropriate rate of lake level increase.  The Committee to Save Lake Merced is not aware of any lake advocate who has insisted, or even suggested, that the lake level be increased a significant amount in 2, 3, 4 or any other single digit number of years.  Although Task Memo 3 is virtually silent on the issue, common sense tells most that a relatively slow rate of increase would be the most environmentally benign in terms of potential adverse effects on wildlife and habitat.

So, why is the proposal before us limited to options that don’t call for continued and further curtailment of pumping, while calling for rapid increases in lake levels over a one or three year period?  Because there may be a final plan adopted within the next four to five months, it is now time to address this question head on.

Occasional mention has been made of San Francisco’s interest in managing the Westside Basin “conjunctively” in coordination with San Francisco’s existing Hetch Hetchy water delivery system.  In simplified terms this would involve injecting SFPUC system water into the aquifer in wet years and withdrawing it in years of need.  One has to ask if San Francisco has not concluded that such a scheme would likely be incompatible with managing the aquifer in a fashion that would gradually restore the aquifer and the lake to acceptable historical levels.  That would lead one to conclude that San Francisco would be tempted to put forth a set of alternatives such as are described in Task 3 Memo in order to divert attention from the idea of putting a high priority on managing the aquifer primarily for the benefit of Lake Merced.

If that is what is happening, it would be unfair for the Committee to Save Lake Merced or others to criticize San Francisco’s motives regarding the aquifer if the current proposal included one or more sound, cost-effective, scientifically proven alternatives that would assure beyond a doubt the restoration of the lake.  The current proposal, most recently articulated in Task 3 Memo, does not include sound, cost-effective, scientifically proven alternatives.  It primarily just enumerates numerous unresolved issues of science, cost, and regulatory and public approval.  Thus, the proposal should be broadened to include adding management of the aquifer as one of the options for raising and maintaining lake levels and improving water quality.  At the same time, after coordination with the mediated negotiations, a more realistic date for approval of a plan should be established.  That date should be one that will allow most, if not all, of the numerous unresolved issues to be resolved.

Respectfully Submitted,

Committee to Save Lake Merced
September 4, 2003