2084 -- 16th Avenue
San Francisco, CA 94116
August 16, 2004
Ms. Cheryl Davis
Acting General Manager
San Francisco Public Utilities Commission
1155 Market St., 11th Floor
San Francisco, CA 94103
I am writing in response to an exchange of memoranda between John
Plummer and Alex Lantsberg, members of the community, and Joe
Scalmanini, principal of the consulting firm Luhdorff and Scalmanini,
the firm retained by the City Attorney’s office in response to the
petition filed some years ago by CalTrout. It seems that although
that petition has been inactive for at least a year now, the firm
Luhdorff and Scalmanini continues as a general consultant to the City,
including the Public Utilities Commission, on a variety of issues,
particularly as they affect Lake Merced.
I should make it clear that I am not technically qualified to comment
on the scientific merit of the points made on either side.
Rather, I would like to observe on the process these memoranda
represent, and the failure, in my view, of Joe Scalmanini to
participate in a constructive discussion of those issues, a discussion
intended to produce a beneficial result for the lake and for the
Before I begin may I observe that I have known and worked with John
Plummer for the past five years. John has consistently brought a
level of intelligent analysis to bear on issues at Lake Merced that the
City should be happy to incorporate into their plans and
programs. Instead, as Joe Scalmanini’s memorandum illustrates, an
effort has been made to denigrate John’s work and to attack him
personally. John demonstrates incredible patience as he continues
his efforts on behalf of Lake Merced; I have never known him to have
any other motive.
Joe’s memorandum makes clear his extensive capability as a litigant; in
fact his reputation precedes him on this point. It is equally
clear why the City Attorney’s office has chosen Joe’s firm to represent
the City in actions of this sort. We are not, however, involved
in litigation at this time. Needed now are good science and a
constructive dialog with the community. Joe Scalmanini has
Joe claims that “the draft plan . . . was discussed at several public
meetings prior to being circulated as a draft.” We have asked
Greg Bartow to provide copies of the public notice of these
meetings. Greg has provided two, one in May and the other in June
of this year, both after the release of the draft plan. Greg
describes several other contacts, including web postings, all but one
post-publication. That one exception was a meeting of
hydrologists in April 2003 to discuss the development of a computer
model of the Westside Basin and its relationship to Lake Merced.
The groundwater plan was not on the agenda, was not discussed in any
detail, and in fact this was not a public meeting, the attendance
limited to those technically qualified.
There have been a series of meetings to discuss Lake Merced, potential
sources of imported water to control lake level, and the impact of
various lake levels on beneficial uses. None of these meetings
discussed either the maintenance of the aquifer or increased withdrawal
of water for domestic use, the subject of the groundwater plan. I
am sure that Joe is well acquainted with this history. Why, then,
did he make this claim?
The community has for some time supported the use of models being
developed by Gus Yates and John Fio, under a contract with the City of
Daly City Department of Water and Wastewater Resources, to evaluate
various strategies for management of the Westside Basin aquifer.
Joe argues that this is not appropriate: “The commentors (sic) also
fail to recognize that plans are not based on output or other use of a
model.” I believe that few if any scientists would agree with
that statement. It is my understanding that effective use of
models for prediction is a hallmark of good science.
Joe has consistently promoted the use of a “conceptual model” rather
than the development of an enhanced computer model such as that being
developed by Yates and Fio. Joe now states, “The commentors (sic)
fail to recognize that a conceptual model is an essential primary step
in the development of a numerical groundwater flow model.” It
would seem to a casual observer, based upon this statement, that Joe
has been supportive of this effort all along, that his main goal has
been to provide support for the numerical modeling effort. In
fact, in public statements Joe has been openly critical and dismissive
of this modeling effort.
Earlier work, by the consulting firm Geo/Resource Consultants, Inc.
(1993), indicated that the use of recycled water to build a barrier
between the ocean and Lake Merced would lead to an increase of lake
level of an estimated seven feet. No other single action had such
a large impact. John has on several occasions requested that this
option be evaluated using the improved groundwater flow models.
In his comments John had observed:
The conclusion is accepted without support that Lake Merced can be
maintained much in the manner of a reservoir, ignoring its natural
relationship to the aquifer. This completely ignores repeated
requests both by Friends of Lake Merced and the Water Committee of the
Lake Merced Task Force, that the lake be considered in conjunction with
programs to restore the aquifer itself. One example: the only
consideration of recycled water is its use for direct input into the
lake; using recycled water to buttress the aquifer is off the table.
Joe responds first with a dismissive exposition on the failure of the
“commentors” to define what they mean by “restored”. He then
repeats the claim that there is to date no evidence of seawater
intrusion, a claim not in dispute; neither is it relevant to the
discussion. He then directs the reader to Elements 3 and 6 of the
groundwater management plan. We took a look. Element 3
discusses basin yield, but does not mention recycled water.
Element 6 discusses recycled water, but only for the purpose of
irrigation and direct input into Lake Merced. Neither element
discusses the potential benefit, either for lake level or increased
sustainable yield, of groundwater recharge using recycled water.
More important, the recently released Recycled Water Market Assessment
reports that using recycled water for Westside Basin aquifer recharge
has a “low priority.” Potential impact on Lake Merced from such
an action is not discussed. The only reference to Lake Merced in
this Assessment is the potential for addition of recycled water
directly to the lake. Whatever the groundwater plan reports, if
those actions don’t make it into the recycled water plan there has been
no effective coordination; there is little likelihood that the best
solution will be found.
Joe observes that “attacks on the process not helpful.” John and
Alex have not attacked anyone, or anything. They have, however,
suggested that better coordination between plan elements is needed, and
that a “Comprehensive Water Management Planning Team” should be formed
to bring all water management elements, local domestic water supply,
groundwater management, stormwater management, the clean water program
and recycled water under a single planning team, distinct from the
larger capital planning effort, and reporting separately to the General
Manager. I am sure that the community would enthusiastically
support such an effort.
I hope that you will carefully consider this realignment of the Public
Utilities Commission’s planning effort. I firmly believe that
working together, the PUC and the community can and will develop
constructive and sustainable solutions to the preservation of Lake
Merced. I fail to see, however, how the contentious attitude
expressed in Joe Scalmanini’s comments contributes to the achievement
of this goal.
c.c.: Dennis Normandy, President
San Francisco Public
Alliance for a Clean Waterfront
Friends of Lake Merced
San Francisco Public Utilities