Comments on Task 3 Report by EDAW
by Dick Morten
September 7, 2003

Greg, Please review my EDAW report comments.  I have pasted the comments below as well as inclusding them as an attachment.  If you have any questions please give me a call.

I appreciate your personal commitment to improve the SFPUC’s public involvement processes.  My comments concerning community involvement are not directed at your efforts to date because they represent a breath of fresh air.  

Dick Morten

INTRODUCTION: To date, the public has been largely excluded from the development of the EDAW plan alternatives and analysis, leaving development and analysis totally to PUC staff and its consultants.

Only one introductory meeting was held with the PUC staff and EDAW consultants prior to issuance of EDAW’s report.  At the initial meeting, the community participants were assured by the PUC staff and EDAW that periodic progress meetings would be held.  In fact, a PUC consultant contracted for ensuring adequate public involvement was introduced.  No meetings were held.  I certainly hope that the PUC did not pay the public involvement consultant because there is not apparent work completed.

The plan for Lake Merced cannot be allowed to follow the PUC’s typical public involvement pattern – announce plan, advocate plan, defend plan, and adopt plan (frequently over public objectiions).    

There are a number of potentially volatile issues that deserve thorough public involvement from the beginning, not when the plan alternatives are announced.  Continuation of this pattern could increase the potential for acrimonious public debate and conflict, costly delays and worst of all, defeat of the positive goals we share for improving Lake Merced’s lake level, water quality and restoring its beneficial uses.

The proposed schedule (corresponding to the holiday season) will certainly provide inadequate opportunity for the public to become actively involved in unresolved problems.   Beginning today, the PUC should actively involve the community in the development of the plan.

SPECIFIC COMMENTS.  Comments correspond to the applicable page number in Task 3 Memorandum .

Page iv EDAW describes one year and three year periods for proposed water additions to attain the four alternative lake levels. A fifth alternative should be considered: Gradual annual water additions and maintenance level water additions, consistent with habitat, wildlife and environmental considerations and timing for water additions.

Page v.  EDAW states, “Recycled water from either the City of Daly City or the SFPUC’s Oceanside Plant could provide a nearby abundant source” of water for raising Lake Merced’s water level.  No supporting evidence is provided.  In fact, at a recent PUC/LMTF meeting, Daly City seemed to indicate that there would be insufficient recycled water from their plant for additions to Lake Merced.  No public discussion of the quality of Daly City or Oceanside recycled water and related issues has been provided.  The Task 3 Memorandum should be revised to identify the specific amount of recycled water potentially available from Daly City, assuming the golf courses took the maximum allowable amount of water allowed under their contracts with Daly City.

I am unaware of any details concerning the potential quantity or quality of Oceanside recycled water.  The possible uses of the Oceanside recycled water source are not known.  

The regulatory issues concerning recycled water and the additional cost of possibly treating recycled water in a potable water resource have not been publicly explored.  Until these details are provided it is presumptuous to assume that recycled water could be available for Lake Merced.

Page v  EDAW and Daly City acknowledge that there is a problem with coliform in the Vista Grande stormwater. To date, the source of coliform has not been identified. Due to pilot stormwater separator construction problems and the timing and amount of rainfall there may be insufficient data to determine the quality of stormwater proposed for addition into the lake. Only sketchy reference has been made about piping the stormwater into wetlands for additional natural purification.  Will the coliform,  wetlands purification concept, and insufficient data be resolved prior to January 2004?

Pages v, 42 and 56 Indicate that a dechloramination water will be costly and space prohibitive. Yet, the table on page 58 characterizes the cost as low/medium. In conversations with PUC staff, they indicate there may be a range of dechloramination processes that might be used to make Hetch Hetchy water available for raising lake level and improving water quality.  If Hetch Hetchy water is to be considered then clarification is needed as to the options, initial and operational costs,  plant requirements, etc. of the potential dechloramination processes.

Page 2 EDAW acknowledges that the 1993 GeoResources report recommends an optimal lake level of 26 feet on the gage board. This paragraph should be expanded to include the 1950 SFPUC resolution where the commission believed 27 feet at the gage board was an appropriate optimal level for Lake Merced.  Clear acknowledgment of the historic public policy optimal level should incorporated into EDAW’s report.

Page 15 EDAW’s Hydrology section acknowledges and confirms what activists and independent hydrologists have maintained that local pumping by municipalities, cemeteries and golf courses, as well as surface water diversion and lack of natural recharge has led to declining water levels and quality in the lake. Yet, the plan alternatives does not in any way address the merits of continued curtailment of pumping (e.g., San Francisco Zoo) as an alternative to dealing with lake level and water quality issues.   Perhaps, this acknowledgment should be included in the introduction where more people are likely to read it.  

Could EDAW estimate the percentage of the lake’s degradation attributable to local pumping, surface water diversion, and lack of natural recharge?

Page 17 EDAW states that the boat hoists are currently inoperable.   Was this statement for comic relief? The hoists probably are operable.  The reality is that the hoists are “inoperable” because the lake has been allowed to decline so that the hoists are stranded far from the lake’s current shoreline. The lake’s shoreline has moved but the hoists cannot chase the lake’s declining level.  Please correct this statement indicating why the hoists cannot be used.

Pages 44 and 45  Additionally, it is not clear why the discussion includes wells in the shallow aquifer, as there has been no public been consideration given to pumping from the shallow aquifer to replenish the lake. Previous discussions have focused on pumping from the deep aquifer.   Shallow aquifer pumping needs thorough analysis regarding its impact on the lake’s hydrology.  There are also conflicting cost conclusions related to the location, depth and treatment of groundwater, etc. that need to be resolved.  

SUMMARY AND CONCLUSIONS

Recycled Water. It is not clear whether there is currently an adequate quantity of recycled water. Before adoption of the plan, preferably during its development, extensive discussions with the regulatory authorities conducted to determine whether recycled water could be added to Lake Merced. Secondly, is further treatment of recycled water required to pass regulatory hurdles?

SFPUC System Water.  Occasional mention has been made of San Francisco’s interest in managing the Westside Basin conjunctively.  If the PUC intends to manage the Westside Basin as part of the overall Hetch Hetchy water delivery system then specific details of this management plan need to be communicated to the public. A whole range of issues including development of an aquifer water budget for various uses and users, detailing an ongoing aquifer monitoring and hydrological model, binding conservation and recycling program agreements by users of the aquifer, using the rate structure to manage the aquifer, etc. Over the years, PUC staff and legal advisors have hinted that this is the direction that they are moving. While this approach may have substantial merit it should be acknowledged and a specific proposal developed with full public involvement at the onset.   

What would be the impact on Lake Merced if the aquifer is managed as part of the region’s delivery system and the basin is managed conjunctively?  

This should not be a stealth Westside Basin Management plan.