CSPA and Tuolumne advocates answer San Francisco on water supply

CSPA, the Tuolumne River Trust, Golden West Women Flyfishers and two unaffiliated Bay Area advocates (“TRT et al.”) continue to make the case that the City of San Francisco and its wholesale agency can both protect their water supply and release more water to the lower Tuolumne River.

In a December 30, 2019 comment  letter to the Federal Energy Regulatory Commission, TRT et al. responded to recent comments by the City and by the Bay Area Water Supply and Conservation Agency (BAWSCA).  BAWSCA is a wholesale agency that distributes water from the City’s facilities to 26 local water agencies in the Bay Area.

For many years, the City and BAWSCA have sought to limit flow increases into the lower Tuolumne River.  TRT et al. write in response that the City and BAWSCA (and FERC) should evaluate lower demand scenarios, including modeling their demand at the highest level it has been over the last five years.  The City and BAWSCA insist on starting evaluation of the water supply effects of Tuolumne River flows water using a demand value 20% higher than recent demand.  The City and BAWSCA also evaluate projected future demand at a level that is over 30% higher than recent demand.

The letter disputes the value of the City’s very conservative drought scenario.  It also points out the failure of the City and BAWSCA to diversify their sources of supply at a scale commensurate with the risk their drought scenario assumes.  Finally, the letter uses recent economic growth during a drought to dispute the level of economic impact that the City alleges would occur during droughts if higher flows Tuolumne River were required.

All of the authors of the December 30 letter have sought for many years to find common ground with the City and BAWSCA on improving the Bay Area’s water supply reliability while making meaningful flow improvements in the lower Tuolumne River.

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