Comments on the Recycled Water Master Plan (Draft), September 2005

prepared for the Recycled Water Master Plan
Public Review, 10/18/2005

&

WSIP PEIR Scoping Meeting, 10/19/2005

It is time now to set aside the Recycled Water Master Plan (Draft), and to begin anew, with a new planning framework, new goals, and new determination.  The good news is that this does not need to lead to delays in the development of a significant recycled water program in San Francisco, and in fact could speed that up.  More important, a new approach, considering the regional potential and not limiting the planning horizon to the City and County of San Francisco, can substantially increase the productivity of the intended investment in recycling and other conservation steps.

In earlier comments (see Goals for a Recycled Water Program in San Francisco, July 14, 2005, available at http://www.lakemerced.org/recycling/Recycled_water_program_objectives.html) we pointed out that the current proposals submitted by the San Francisco Public Utilities Commission (SF-PUC) are unduly modest and far from cost effective.  To summarize:

·    A targeted production of just 4.1 million gallons of recycled water per day (mg/d) is just 22.5% of the SF-PUC’s own estimated demand potential for recycled water in 2030.

·    The state of California Department of Water Resources has set a statewide goal of 23% of available municipal wastewater.  4.1 mg/d represents less than 5% of available resource, less than one-fourth of the statewide goal.

·    At an estimated $125 million for 4.1 mg/d of recycling capacity the required investment is approximately four times the state-wide average, and more than ten times the Daly City actual for the plant built just two years ago.

·    The SF-PUC proposal suggests that seven years will be required to build the first facility; Daly City completed their plant in just two years.

Since those comments were published other programs have been presented, with varying costs and varying estimates of the amount of recycled water to be produced.  None of these, however, contradicts the conclusions reached above.  In fact, the current report increases the estimated output of recycled water by just 10%, from 4.1 mg/d to 4.5 mg/d, while increasing the cost estimate by nearly one-third, from $125 million to $165 million.  This is clearly an even less viable proposal.

In our testimony to the Water System Improvement Program (WSIP) Scoping Meeting, held in Sonora October 5, we suggested that the SF-PUC scan the regional horizon for additional opportunities for investment in recycled water that might prove to be more productive.

The Water System Improvement Program Assessment conducted by Parsons and CH2MHill, program management consultants to the SF-PUC, has confirmed these observations:

The cost of local recycled water projects identified tend to be relatively high compared to other recycled water projects in California, when evaluated on a unit cost basis (dollars per million gallons or dollars per acre-foot of water).

They then propose the following program:

1)    Locate a satellite membrane bioremediation plant in Golden Gate Park at the site of the McQueen Water Reclamation Plant . . . The plant requires less space than older treatment technologies and can be architecturally designed to be consistent with the goals of the Golden Gate Park Master Plan . . . This alternative would require little construction of additional distribution pipelines or storage.

2)    Estimates of irrigation demand were made using the best available information.  Not all City irrigation sites have water meters, and not all meters are read.  The review team recommends that meters be installed on all irrigation users, including telemetry to remotely read and record water use.

3)    There is significant potential recycled water demand among the wholesale customers.  (The assessment team estimates this potential at 20,000 acre-feet per year, compared with a local potential of just 4,200 to 4,800 acre-feet per year.)  Although there are many challenges to implementing these projects, . . . the review team believes the local and regional projects should be developed and ranked together on the same basis of unit cost and total quantity used.  The review team further recommends that the projects be benchmarked against both the cost of SF-PUC water and the cost of seawater desalination.

4)    Recycled water also need(s) to be reviewed in the context of all alternative water supplies because of their inter-relationship.  These include regional recycled water supplies (not in the WSIP), desalination (not in the WSIP), and conservation (funded separately from the WSIP), as well as local and regional groundwater (both included in the WSIP).

5)    Rank potential projects of wholesale customers according to the size of the potential offset (to demand on system water), the readiness of the customer to proceed, the unit cost for reclaimed water, and the willingness of the customer to negotiate a mutually satisfactory agreement.

Obviously, implementing these recommendations requires a fundamental shift in emphasis and approach from that taken in preparing the current draft Recycled Water Master Plan.  This shift is so great as to make impractical any attempt to edit and modify the current plan to meet these recommendations.

Finally, it was recently pointed out that a reading of the Raker Act prescribes the approach suggested by the assessment team:

Sec.8. That the word “grantee” as used herein shall be understood as meaning the city and county of San Francisco and such other municipalities or water district or water districts as may, with the consent of the city and county of San Francisco or in accordance with the laws of the State of California, hereafter participate in or succeed to the beneficial rights and privileges granted by this act.

Sec. 9. That this grant is made to the said grantee subject to the observance on the part of the grantee of all the conditions hereinbefore and hereinafter enumerated;
(h) That the said grantee shall not divert beyond the limits of the San Joaqin Valley and more of the waters from the Tuolumne watershed than, together with the waters which it now has or may hereafter acquire, shall be necessary for its beneficial use for domestic and other municipal purposes.  (Emphasis added.)

Not being an attorney, I do not know if this term is or is not enforceable.  However, in a memorandum prepared for Environmental Defense (July 2004) by Stuart L. Somach of the firm Somach, Simmons & Dunn states:

“Congress may constitutionally limit the disposition of the public domain in a manner consistent with its views of public policy.”   Just as Congress “clearly intended to require - as a condition of its grant” that San Francisco sell its power solely to municipal agencies, or that CCSF honor the Districts’ water rights under California law, it is reasonable to conclude that Congress also intended for CCSF to rely on Tuolumne River water only to the extent it had fully developed its other resources. Nothing in the language of the statute fixes this limitation as of a particular time; accordingly, CCSF is arguably under a continuing obligation to develop its own resources, as by recycling, conservation, desalinization, and other available means, in order to relieve the pressure of its exports from the Tuolumne River and the Hetch Hetchy Valley.

The drafters of this Act could not, in 1913, anticipate the water quality requirements, or the water reclamation technologies, that would exist one hundred years later.  But it seems clearly to be the intent of those drafting this Act that the regional customers would work together to minimize their dependency on imported water, and to maximize the potential of the Tuolumne River to be maintained as a natural and environmentally sound resource.

To summarize, implementing the recommendations of the Parsons / CH2Mhill assessment team can and will lead to an expedited implementation of recycled water in Golden Gate Park, with possible extensions to Lincoln Park and other locations as well, while providing in the long term a much more viable recycled water program, from both the perspective of effectiveness and cost.

John Plummer
October 13, 2005

Notes from the Parsons/CH2MHill assessment:

4.0 MAJOR PROJECT REVIEWS

After discussions with staff, the review team recommended that recycled water also needed to be reviewed in the context of all alternative water supplies because of their inter-relationship. These include regional recycled water supplies (not in the WSIP), desalination (not in the WSIP), and conservation (funded separately from the WSIP), as well as local and regional groundwater (both included in the WSIP). The regional recycled water projects are also the subject of a master plan, but the regional projects developed to the same level of detail as the local projects.

Observation: Though progress has been made in creation of the new natural resources unit in the Water Division and in hiring of lead staff, activities reflecting the SFPUC’s commitment to integrate the Stewardship Policy and Principles into the WSSIP have not been made explicit.

Recommendation: Describe activities that reflect the SFPUC’s commitment to integrate the Stewardship Policy and Principles into WSIP projects. Prepare an overall summary of the approach to this integration.

Observation: There is no overall system-wide strategy to guide implementation of projects such as reclamation and groundwater.  Therefore, the projects proposed for implementation in San Francisco may be less cost-effective than those that might be implemented by wholesale customers.  Additionally, these projects should be benchmarked against the cost benefits for desalination projects.