November 15, 2004
Ms. Susan Leal, General Manager
San Francisco Public Utilities Commission
1155 Market Street, 11th Floor
San Francisco, California 94103
The staff of the PUC Planning Bureau recently released a document entitled “Response to Comments on May 2004 Draft North Westside Groundwater Basin Management Plan.” This contained responses to points raised by Friends of Lake Merced together with the Alliance for a Clean Waterfront, California Trout, and a number of other organizations and individuals.
As is often the case, this is another example of what Dick Morten has referred to as “the PUC’s
3-Ds, Decide, Describe, and Defend.” I do not believe that there is even one suggestion from the community that has been incorporated into this response.
There are other problems as well:
Perhaps most important, this plan has undergone at least two years of development without any pubic input or review. The PUC’s first response was to deny this fact, claiming that several public meetings had been held for this purpose. Of course there were none, and this was well known, as the entire proceeding was cloistered in the mediated negotiations discussing the CalTrout complaint. However, I requested copies of the notices for these public meetings. That request was referred to Dianna Parker, the PUC’s Sunshine Request Coordinator, who assured me that she would provide that information. I have not heard from Dianna again. Now a series of community workshops is proposed, after the fact, intended to take the place of full community participation. An inclusive process involves the community in the development of the plan; it does not wait until the plan is completed to solicit input. Before this process goes any further, the SF PUC must develop appropriate outreach mechanisms.
Second, this statement raises the lack of coordination between the various planning elements within the PUC from practice to policy. Referring to the just-mentioned community workshops, the statement is made that “These groundwater workshops will feed into an integrated water resources planning initiative that the Planning Bureau will begin by late fall of this year. The intent of this plan is to coordinate and comprehensively manage, all the water resource issues in San Francisco (e.g., system surface water, recycled water, groundwater, conservation.) [emphasis added] The omission of the Clean Water Program, including stormwater, from this statement is alarming. Clearly, we have a different definition of integration. . The SF PUC must pursue a integrated plan that actually considers all available water sources
When we suggested that attention should be paid recommendations made by the PUC’s Technical Advisory Committee the Planning Bureau responded, “As regards the comment that such an injection effort would increase the sustainable yield of the aquifer, and that such an option was considered to have high potential by the PUC’s TAC, there is no record of such a conclusion or recommendation by the TAC, which is constituted to advise the PUC on wastewater-related matters, and not on groundwater basin management.” The Planning Bureau did not record this recommendation for the simple reason that no one representing the Planning Bureau attended the TAC’s most recent meeting. We recommend that, if they are unable to find this reference, SFPUC staff ask the question again of the TAC members, and record the response.
The Planning Bureau staff selects answers that meet their current need whether or not those answers are consistent. For example, in response to one set of comments they observe, "Interestingly, there is no mention of using recycled water for direct input to any lake; the comment that such a use is the 'only consideration' is incorrect." In response to comments by Dick Morten they observe, "Particularly if recycled water is selected as a component of purposeful augmentation of the lake, San Francisco will pursue an appropriate modification of the emergency potable water designation for Lake Merced." There are more, but this illustrates the need to review the responses in this report for both accuracy and consistency.
What action is needed? Certainly better community relations and improved planning coordination are two goals that remain high on the Things-Left-To-Do list. Specifically, how can those be achieved? At a Commission meeting some months ago President Dennis Normandy suggested that for each planning project a specific budget be set aside to support community involvement, and that the community should be included when deciding how that budget would be allocated. To date nothing of the sort has occurred, yet it remains a good idea in our view.
I regret that I do not have any additional recommendations. I do, however, appreciate your support on behalf of those goals.
cc.: Dennis Normandy, President, PUC
Members of the Public Utilities Commission