Light at the End of the Trail

As far as back as I can remember, I’ve never enjoyed being outdoors. My childhood choices of sports ranged from soaking in the four-color pages of The Uncanny X-Men to studying every single Bruce Lee move in Enter the Dragon. Whether it was reading, watching, or even drawing my favorite fictional heroes, I spent more of those times envying the athletic around me, rather than indulging in aerobics for myself.

Twenty years later, I’m an AmeriCorps member of the National Civilian Community Corps (NCCC). Considering how most manual labor happens outside, I’ve spent more of my time tending to the Tuolumne area than I do catching subsequent viewings of Days of Future Past. So what could have possibly transformed a nerdy Texan into someone willing to apply civic responsibilities through physically demanding service?

Taken in 2014, Preston chose to get in shape about three years later. Facebook

From that point, I made the goal of losing fifty pounds by the following year — igniting my desire to eat healthier and exercise regularly. Within a month into AmeriCorps, living on my new regimen, I took this rare opportunity to see what I was really made of. Without Southern culture. Without popular culture. Without anything resembling my comfort zone of old.

In October, I was welcomed into NCCC by a team of thirteen incredibly supportive people and a friendly campus. Since I’m the only person on my team from the land of George Strait and plateaus, several teammates delighted in introducing me to the wonders of beaches, Cuban cuisine, and the Golden Gate Bridge. But one common tradition I still couldn’t ascertain was the outdoorsiest of them all: camping. A few days of our training at Camp Lodestar, where I slept only 90 minutes on our first night, gave me reason enough to keep hating living in a tent.

However, my team’s Round 2 assignment necessitated putting such misgivings aside since we would spend three months deployed in the wilderness near the Tuolumne River. Although we planned to live at the luxurious Rush Creek Lodge, much of our manual labor would put us in direct contact with dehydrating elevations, poison oak, and parasitic ticks. Not exactly ideal compared to my usual activities.

Learning about the Tuolumne River’s importance to its community was enough of a reason to stick around. I found it difficult to pass up the chance to help an entire area by clearing its mountains of precarious debris and inspiring the youth to take action long after we left. We have recently begun planting trees, which my team loved doing for Luther Burbank High School last October.

If I could make the life-changing decision to leave everything I knew for ten months – forcing myself to adapt to new communities – who was I to dismiss the notion of facing some of my strongest grievances to help others in need?

I’ve found that a month into our project has done wonders for my health, my team, and the area we occupy. Although I’ve never been much of a runner, jogging distances over 4,500 feet above sea level has vastly improved my endurance and physicality. Taking into account how the only things in Texas rivaling elevation are the sizes of our bargains, hiking recreationally has allowed me to surprise myself and find gratifying incentives within the service we’re undertaking.

Preston digging for weeds at the San Jose Family Camp in Tuolumne County, California. Laura Schneider.
Preston digging for weeds at the San Jose Family Camp in Tuolumne County, California. Laura Schneider.

While there are certainly times I succumb to homesickness or Whataburger cravings, I wouldn’t trade these new experiences for the world. As I continue to explore the West Coast wilderness, mainly everything around the Stanislaus National Forest and Yosemite National Park, I learn and grow every day. Instead of reading about fictional heroes, I’m surrounded by real heroes who don’t need an Indiana Jones fedora to survive rattlesnake confrontations. When all else fails, I’m reminded that even on the gloomiest days or the darkest hours, there’s still light to be found at the end of the trail.

EDITOR’S NOTE: Preston Mitchell is a media representative and member of Team Blue 4. He plans to pursue a journalism career after his NCCC program ends in July. Feel free to follow him on Twitter and LinkedIn.

How can fire promote forest health?

We firmly believe that, in addition to proper planning and management, controlled burns can greatly reduce the risk of large, dangerous wildfires in California’s forests. A recent report by the Little Hoover Commission details the changes that they believe should be made to make this strategy happen. The Sacramento Bee has done a fantastic job of summarizing the debate in their article Future Forest Health Needs Fire to Fight Fire.

More background about this issue can be found here:

Special thanks to TRT advisor John Amodio for working with the Little Hoover Commission and the Sacramento Bee’s editorial staff to raise awareness of the changes that need to be made in forest management!

TRT Responds to SFPUC Misinformation

The State Water Resources Control Board is in the process of updating the Bay Delta Water Quality Control Plan to help restore the estuary and rivers that feed it, including the Tuolumne.

Comments submitted by the City and County of San Francisco, the Bay Area Water Supply and Conservation Agency (BAWSCA), many of BAWSCA’s 26 member agencies, and several other entities exhibited a number of misconceptions about potential impacts of the Plan. Many of the figures cited were based on misleading information provided by the San Francisco Public Utilities Commission (SFPUC).

For example, eight members of the Bay Area Legislative Caucus wrote, “If approved, the SWRCB’s current plan would substantially cut water supplies to 2.6 million Bay Area residents in San Francisco, Silicon Valley and the East Bay by up to 50% at the first sign of any future drought.”

Comment letters from 16 of BAWSCA’s member agencies were virtually the same. The agencies were provided with a form letter and encouraged to fill in a few blanks. Among other things, these letters stated, “As a wholesale customer of SFPUC … water supply available to (city or agency) under the SED proposal could be reduced more than 50% under drought conditions for multiple consecutive years.”

Objective modeling demonstrates the SFPUC could manage a reoccurrence of the drought of record, even with the 40% unimpaired flow requirement in place.

TRT has modeled the impact of a reoccurrence of the 1987-92 drought under the SFPUC’s current baseline demand – 223 million gallons per day (MGD) or 250,000 acre feet/year (AF/Y) – and 40% unimpaired flow between February and June. We found that the SFPUC would not run out of water under such a scenario. We based our model on a modest average of 10% rationing during the six-year period. We assumed there would be no rationing in the first two years of the drought, 10% rationing in years three and four, and 20% rationing in years five and six. For comparison, water demand in FY 2015/16 was 175 MGD – 21.5% below the 223 MGD baseline. Demand in FY 2016/17 was 180 MGD – 20% below the baseline.

The SFPUC has not challenged our model, and in fact, their own modeling demonstrates they would not run out of water if the drought of record were to reoccur and the SED were in place. However, they base their planning on a “Design Drought” (see below).

During the height of the recent 4-year drought (2012-2015), the SFPUC had enough water in storage to last more than three years. Had the Bay Delta Plan’s 40% unimpaired flow between February and June been in place during the drought, the SFPUC still would have had at least 2-years-worth of water in storage at any given point.

Following the normal water year in 2016, the SFPUC’s Tuolumne River storage rebounded to 85% of capacity by December 11. By early January of 2017, it was clear that all the reservoirs on the Tuolumne would easily fill, so water had to be released from Don Pedro Reservoir at the maximum amount allowed by flood control rules for months. Had the SED been in place during the drought, all of the Tuolumne’s reservoirs would still have filled in January, and any previous storage deficit would have been erased.

SFPUC figures are based on an arbitrary 8.5-year “Design Drought.”

While the SFPUC has not challenged our modeling, they assert that their much more extreme rationing scenario is based on an 8.5-year “Design Drought,” which includes the 1987-92 drought of record, followed immediately by the driest 2-year period on record – 1976/77. They assume every year is either the beginning of, or middle of, this Design Drought, and thus factor in much higher levels of rationing than would have been required at any time in the past.

The SFPUC does not explain its Design Drought when sharing information with others, leaving the impression that impacts would be much greater than should be reasonably expected. Furthermore, the scenario they share is based on Plan Bay Area 2040 demand projections (265 MGD) vs. the current baseline (223 MGD) or internal SFPUC 2040 demand projections (250 MGD).

The SFPUC model assumes rationing would begin in the first year of drought, and would be 39% for the first three years (under 223 MGD demand) and 49% for the remaining years. This policy would leave 576,000 acre-feet remaining in storage at the end of the six-year drought of record if it were to reoccur. This is enough water to last more than two years at pre-drought demand, and almost three years at FY 2015/16 demand. All of the projected job losses and socioeconomic impacts associated with excessive rationing would have been unnecessary, making the Design Drought a very expensive insurance policy.

The SFPUC has projected jobs and economic losses from such a conservative rationing scenario to be 445,905 annual full-time equivalents and more than $116 billion. Again, these impacts would have been unnecessary. These socioeconomic impacts are based on a 2017 Brattle Group report commissioned by the SFPUC.

The 2017 Brattle Group report is flawed.

Along with its SED comments, the SFPUC submitted a document entitled, Bay Area Socioeconomic Impacts Resulting from Instream Flow Requirements for the Tuolumne River, prepared by The Brattle Group. This report states, “The method used to estimate these impacts is described in the report Socioeconomic Impacts of Water Shortages within the Hetch Hetchy Regional Water System Service Area, prepared by The Brattle Group in 2014.”

Shortly after the 2014 report was issued, a coalition of NGOs submitted extensive comments that identified a number of flaws in the Brattle Group analysis.

The recent drought proved that prior Brattle Group studies were seriously flawed (see TRT presentation). For example, their 2014 report projected that 30% rationing would result in the loss of 25,000 jobs and $7 billion. However, between 2006 and 2016, water demand in the SFPUC service territory decreased by 30%, with no job losses and no negative economic impacts. In fact, 125,000 jobs were added in San Francisco alone between 2010 and 2015, and the regional economy improved to its strongest position ever.

SFPUC drought planning harms the Tuolumne River ecosystem unnecessarily.

During the recent drought, releases into the lower Tuolumne were critically low, and fish and wildlife suffered. Had the SED been in place, river conditions would have been improved, and SFPUC storage would currently be the same as it is today. This graph shows that under the current flow regime, the SFPUC needed to capture 373,000 acre-feet coming into Water Year 2017 to fill its reservoirs on the Tuolumne. Actual water available to San Francisco was 3.1 million acre-feet – enough water to fill all of the SFPUC’s reservoirs, including those in the Bay Area, more than twice. In other words, during Water Year 2017, the SFPUC had the right to capture enough water from the Tuolumne (if storage were available) to last more than 12 years.

Click here for a series of graphs that compare unimpaired flow, actual flow, and 40% unimpaired flow between February and June between 2012 and 2017. The difference between 40% unimpaired and actual flow is additional water that would have benefited the Tuolumne River ecosystem had the SED been in place. Rather than releasing this water during the drought, it all (and much more) got dumped in 2017, providing much less benefit to the river ecosystem than had it been apportioned over the dry years of the drought.

TRT has attempted to correct the record.

The Tuolumne River Trust and other NGOs have attempted to convince the SFPUC to correct the record, with limited success. The SFPUC issued a brief, to which we responded with our critique, and finally the SFPUC responded to our critique. We believe these documents make it clear that information distributed by the SFPUC has been extremely misleading.


The Delta Reform Act of 2009 established a State policy aimed at achieving the co-equal goals of ensuring water supply reliability and restoring the Bay-Delta ecosystem. Unfortunately, many water agencies have chosen to ignore the second of the goals. This is unfortunate, because under a reasonable scenario, both objectives could be achieved.

A Salmon-eye View of the River

Despite having been with the Tuolumne River Trust for over 10 years and having spent much of that time on the Tuolumne River or in its watershed, I still get excited every time I head to the river, wondering what will amaze me this time. And the river never disappoints. In the heat of the Central Valley summer, the lower Tuolumne greets me with cooling shade, inviting swimming holes and lush green tangles of riparian habitat surrounded by an otherwise dried up landscape. Winter fills the sky with welcoming rains and thousands of migrating birds, many of which stop to refuel or winter over at places like our Dos Rios Ranch restoration site at the confluence of the Tuolumne and San Joaquin rivers. In the spring the river bursts with new life from snow-fed flows to wildflowers to wildlife. But what happens in the river this time of year, often while we are sleeping or simply caught up in our busy human world, is a wonder of nature that blows my mind every time I experience it – the return of the Chinook salmon.

Beginning as early as September, mature Chinook salmon that have spent several years out in the ocean gorging themselves (and growing to a size they could never achieve in the freshwater rivers where they are born) begin to gather in the brackish waters of the Sacramento – San Joaquin Delta waiting for signs to begin their journey back to their natal rivers to spawn. Between October and December, hundreds, even thousands, of Chinook salmon make their way from the Delta, up the San Joaquin River to the Tuolumne where they will continue their journey as far upstream as La Grange before being stopped by one of many human-made barriers, in this case the La Grange Dam. In the gravel beds of this reach of the Tuolumne, female salmon will use their broad strong tails to dig out gravel nests called redds in the rocky riverbed. Each female will make several redds and lay anywhere from 1,000 to 8,000 eggs before she is done. Brightly colored males hang out at the river’s edge, jockeying for position to be the first to reach a redd to fertilize the eggs. Battered and exhausted from their long journey back from the ocean and from the energy expended during spawning, these powerful fish spend their last 24 to 48 hours protecting the redds that hold their future offspring before giving them one final gift by dying and releasing a plethora of rich nutrients and energy from the ocean into the waters and soils of the Tuolumne River – a gift which sustains the ecosystem and, in turn, the juvenile Chinook salmon.

One of my first, and still most memorable, experiences with the Tuolumne River Trust was a staff canoe trip during the salmon spawning season. The day started with me arriving about 30 minutes early to our take-out for that day, the Turlock Lake Recreation Area. Within minutes of walking over to the river the show began with my first sighting of river otters frolicking in the water and chasing each other over fallen trees. I remember looking around to see if anyone else was witnessing this amazing sight, sure that nobody would believe me if I didn’t have backup. The second act was headed by a bald eagle keeping watch on an old snag a few hundred feet downstream. Again, I felt a wave of excitement and disbelief travel through my body at seeing such an iconic bird overlooking the river I had recently signed on to steward through education and outreach. I remember the beauty of that stretch of the river between Old La Grange Bridge and the Turlock Lake Recreation Area as being intoxicating and so different from the stretches in and around Modesto that I was familiar with. It’s hard to put into words the thrill of seeing that first salmon, for me, a female “working a riffle”, her arched back exposed as she fought her way upstream then flipped onto her side and pumped her tail up and down to remove a little more gravel from the redd until satisfied that it is ready to receive her eggs. I remember jumping when taken by surprise by a male Chinook shooting out from his hiding place in a shaded spot near a bank in an effort to “win” a redd to fertilize. Finally, I remember seeing my first carcass, not washed up on shore by the current or dragged out by a lucky predator but lying on the river bottom like a white ghost, giving itself up to the river and associated ecosystems.

For two weekends in November (11/4, 11/5 and 11/12) the public has the opportunity to join the Tuolumne River Trust for our annual Paddle with the Salmon canoe trips. This is one of those once-in-a-lifetime experiences that never gets old. Our trips are led by experienced river guides and knowledgeable staff who know how to share this amazing natural event while taking precautions to keep the salmon and the redds safe. These half day paddles are leisurely, perfect for beginners, and take participants through the heart of the Chinook salmon spawning grounds as well as some of the most scenic stretches of the lower Tuolumne River. While viewing a salmon is not guaranteed, gaining new knowledge, insight and appreciation for this amazing resource is! I hope you will consider joining us for this amazing event, the return of the Chinook salmon to the Tuolumne River.

  • Sunday November 12th –  Half day – Space Available!

For full details on each trip, including start time, meeting location, what to bring, what to expect, etc, please visit the registration site by clicking the button below. Register to reserve your spot today – space is limited.We look forward to seeing you on the river!

Register Now



If a pop-up window doesn’t open upon clicking the “Register Now” button above, please complete your registration here (you will be redirected to Flipcause, a secure platform).


September 7, 2017

For more information, contact:
Patrick Koepele
Executive Director

The Tuolumne River Trust issued the following statement:

As a nonprofit conservation organization, we work tirelessly to ensure we have a healthy and safe environment for current and future generations. Much of our work is focused on clean and safe water, land, and air so that people of all races, cultures, ethnicities and income levels have the best chance to live a healthy and prosperous life so that they may best contribute to a vibrant American society.

Much of our work is conducted by, and directly benefits, those who immigrated to the United States as children and have grown up in this country as Americans. The Deferred Action for Childhood Arrivals- DACA- program has allowed them to remain in this country without fear of deportation, until now.

The Tuolumne River Trust stands with these young people whose parents brought them here to pursue the American dream. They were granted permission to live and work legally in America. They have passed background checks. They are our neighbors and co-workers, our friends and family.

We are a country of people who help one another in crisis. We don’t turn our backs. We don’t close our doors. We need Congress to stand up to the president and do the same.

To our Congressional leaders we say that DACA should be upheld, continued, and expanded. This is both a moral imperative and a national necessity. America needs talent – and these people, who have been raised and educated in the United States, are already part of our national community and are American in every way except on paper. They represent what is best about America, and they are essential to our future.

Groundwater recharge – solution for both farmers and fish

If every year were an average water year, the Tuolumne River could provide enough water to sustain a vibrant agricultural economy as well as a healthy river ecosystem. The problem is there are good years and bad years, and when a number of dry years line up we experience water shortages, often pitting economic interests against the environment.

This year we experienced the opposite, as torrential storms dumped near-record precipitation on the Tuolumne River watershed. The reservoirs filled quickly and, beginning in January, maximum allowable releases from Don Pedro Dam were required to prevent future flooding downstream.

More water in excess of flow requirements was released into the Tuolumne River than what the three water agencies operating on the Tuolumne – the Modesto and Turlock irrigation districts and the San Francisco Public Utilities Commission (SFPUC) – use in about two years.

While it’s likely there will always be a debate over how much water should flow down the river to protect fish and wildlife and maintain water quality, few would argue that there wasn’t a considerable excess of water this year.

So, what could be done to capture and store some of the excess water in wet years for future use during dry years?

The answer lies right under our feet.

Stanislaus County is blessed with excellent soils for groundwater recharge, and sits upon two large groundwater sub-basins – Modesto and Turlock, on either side of the river – with many times the storage capacity of Don Pedro Reservoir. While neither sub-basin is classified as over-drafted, there are concerns that pumping could increase as a result of higher in-stream flows required by the State Water Resources Control Board to help revive the San Francisco Bay-Delta and rivers that feed it. Over-pumping of the aquifer could reduce its reliability and possibly lead to land subsidence, threatening important infrastructure.

It would be prudent to explore potential new recharge opportunities to ensure the continued viability of groundwater pumping without causing harm to the aquifer. Such a program would help meet the Sustainable Groundwater Management Act (passed in 2014) requirement that levels of pumping and recharge be in balance.

The Stanislaus and Tuolumne Rivers Groundwater Basin Association and Turlock Groundwater Basin Association have done a good job establishing Groundwater Sustainability Agencies, as required by SGMA. The next step is to create Groundwater Sustainability Plans. We are hopeful these plans will include active recharge programs during wet years, and look forward to engaging in the process.

The viability of recharge programs has already been demonstrated. For example, a 20-acre recharge basin managed by the Merced Irrigation District replenishes 25 acre-feet of groundwater per day. The State is eager to support similar projects, as funding for earthwork and infrastructure is available through the California Water Bond, which allocated $2.7 billion for water storage projects.

Another option is for the Irrigation Districts to partner with the SFPUC, which might be interested in establishing a groundwater bank similar to its water bank in Don Pedro Reservoir.

With further study and implementation of groundwater recharge, we could capture more water during wet years, improve in-stream river flows every year, and continue to support a prosperous agricultural economy during dry years.

Peter Drekmeier is Policy Director and Zarine Kakalia is a Summer Fellow with the Tuolumne River Trust.


This article appeared in the Modesto Bee. See the original post at

Building Bay Area Drought Resilience

On Tuesday, July 18th, the Public Policy Institute of California (PPIC) hosted leaders from local water resource management and conservation organizations for a discussion about building drought resilience in the Bay Area.  Our Policy Director, Peter Drekmeier, was featured on the discussion panel as the voice of the environmental perspective on these issues for a diverse audience of elected officials, policy experts, NGOs, college students, and interested citizens. Their discussion centered around the findings published in PPIC’s new report which reviewed water usage and conservation efforts during the recent drought, including lessons learned and potential courses of action for the future.

According to PPIC, the “essential takeaways” from the panel discussion included:

  • Regional diversification of water supply is key to getting through dry times.
  • Mandated conservation from the state was a blunt instrument; targets based on utilities’ local water conservation plans are more appropriate for such decisions.
  • Planning for “conservation rates” is essential for water districts’ fiscal resilience and maintenance of reserves to pay for fixed costs.
  • Aquatic ecosystems took a hit during the drought. Even though Bay Area cities embraced water conservation throughout the drought, flows to the Tuolumne River and Delta were inadequate. Addressing this before the next drought hits is key to maintain ecosystem health and at-risk species.

You can watch the entire panel discussion here:

For more resources and information, please visit

TRT Critique of SFPUC Brief

Response to the SFPUC’s Document Titled: “State Water Resources Control Board (SWRCB) Revised Substitute Environmental Document (SED): Potential Impact on San Francisco Bay Area”

Response prepared by the Tuolumne River Trust
Contact: Peter Drekmeier, Policy Director,, (415) 882-7252
Date: February 2, 2017

We believe that increasing unimpaired flows on the Tuolumne River to help revive the San Francisco Bay-Delta can be achieved without negatively impacting the Bay Area economy.  The point-by-point critique below will show that the SFPUC’s claims of potential economic impacts are based on a seriously flawed analysis, and did not come to pass during the drought.  Instead, at the height of the drought, the SFPUC had multiple years of water left in storage, and the Bay Area economy grew, both in jobs and economic prosperity.

We encourage the SFPUC to follow the best-available science and play a leadership role in balancing environmental needs with a reliable water supply.  Bay Area residents have repeatedly demonstrated their concern for the San Francisco Bay-Delta, with 70% voting to tax themselves in June (Measure AA) to restore the Bay’s wetlands.

SFPUC Statement:
Our analysis of the 2012 recommendation (35% unimpaired flows) shows a significant economic hit to our service area:

  • 50% shortage of water due to rationing during droughts.
  • Economic impact of 188,000 jobs lost.
  • $49 billion annual cost to the local economy.

TRT Response:
Please view a brief video slideshow about the SFPUC’s socioeconomics analysis at

The figures cited above were produced by economist David Sunding in 2009.  In 2014 he produced an updated draft study with much more detail.  It reduced the worst-case scenario for projected economic impacts significantly, yet the SFPUC continues to cite the 2009 figures.

Even the 2014 figures are extremely inflated.  Had they been correct, we should have seen a loss of $6.5 billion in sales and 25,000 jobs last year when rationing was at 30%.  On the contrary, the economy grew and jobs were created.  According to the CA Employment Development Department, San Francisco added more than 125,000 jobs between 2010 and 2015, despite the drought.

In reality, it is unlikely the SFPUC service territory will ever suffer economic losses as a result of releasing more water into the Tuolumne River to restore the ecosystem.  This is because the SFPUC has so much storage (almost 1.5 million acre-feet) that it buffers the system from extended droughts.  For example, after the recent four-year drought, the SFPUC still had enough water in storage to last three years.  During water year 2016, which was a normal water year, the SFPUC captured enough water to last two-and-a-half years, and the system filled to 80% of capacity.  This January, the Tuolumne reservoirs were so full that water had to be released into the River to create space in the reservoirs for flood control, and the entire system will fill this year.  There will be enough water in storage to last six years.

While providing some environmental benefit, excess water released into the Tuolumne could have benefited the ecosystem over the past few years.  Furthermore, it would have offset any water supply deficit that might have occurred during those years had the Bay Delta Plan been in effect.

Regarding the SFPUC’s claim that the Bay Delta Plan could result in a 50% shortage in water, please see our response below.

Again, please view our much more thorough analysis at:

SFPUC Statement:
Without a predictable water supply, we are jeopardizing growth and development across the Bay Area including much needed housing projects from San Francisco to San Jose.

  • East Palo Alto has already halted 11 development projects because the city cannot guarantee water supplies.

TRT Response:
This statement suggests that East Palo Alto’s water shortage is a result of limited water supply, which is not the case.  East Palo Alto’s shortage is a result of an unfair water allocation.

Individual Supply Guarantees (permanent water supply allocations) for the SFPUC’s wholesale customers (represented by BAWSCA) were first established in 1984.  The SFPUC allocated a perpetual supply assurance of 184 million gallons of water per day (mgd) to its wholesale customers, and those customers together determined how the water would be allocated amongst themselves.  East Palo Alto’s allocation was set at a ridiculously low 1.96 mgd.

During the 2015/16 fiscal year, BAWSCA’s member agencies used 126 mgd, far below their 184 mgd cap.  There’s plenty of water available, it just isn’t allocated equitably.

The Cities of Palo Alto and Mountain View are currently exploring transfers of some of their excess water allocations to East Palo Alto, and these are likely to happen this year.

SFPUC Statement:

  • For example, if San Francisco had to reduce water use by 40%, that would limit us to 25 gallons per person, per day.

TRT Response:
This statement suggests that San Francisco might have to reduce its water use by 40%, which is not the case.  According to the SFPUC’s Water System Allocation Plan, the SFPUC would be entitled to 98.1% of its water allocation during multiple dry years.[1]

SFPUC Statement:
The 2016 SED concludes incorrectly that San Francisco would not have major impacts because we could obtain additional water through other means:

  • Water transfers: Especially during times of drought, it is unrealistic to expect other parties who need the water themselves would sell us their water.

TRT Response:
As explained above, it is unlikely the SFPUC would need to purchase water from other agencies because it has enough storage to buffer the system against droughts.

The alleged $49 billion figure for economic impacts cited by the SFPUC suggests that for every acre-foot of water lost, the economy would lose more than $400,000.  SFPUC customers currently pay about $1,500 per acre-foot, and the Modesto Irrigation District charges farmers about $15 per acre-foot.  It’s ludicrous to suggest there wouldn’t be a willing seller for less than $400,000 per acre-foot, or even a small fraction of that amount.  For comparison, recycled water costs a little more than $2,000 per acre-foot.

SFPUC Statement:
Solutions must include both flow and non-flow measures to improve habitat conditions on the Tuolumne River while providing customers with reliable water supply.

TRT Response:
For more than two years the environmental community has attempted to engage the Tuolumne River water diverters in a Scientific Evaluation Process (SEP) that would bring together biologists from water agencies, state and federal fish and wildlife agencies and non-governmental organization to assess biological goals and objectives for the Tuolumne and establish a roadmap to achieve them.  We’re still waiting for a response.

The State Water Resources Control Board has clear jurisdiction over instream flows.  It’s jurisdiction over non-flow measures, such as habitat restoration and controlling non-native predators, is less clear.  Habitat restoration, for example, depends on willing land owners, so the State Water Board has not included non-flow measures in the Bay Delta Plan.

However, the Bay Delta Plan does acknowledge that non-flow measures could play a role in the recovery of native fish species, and a key component of the Plan is an adaptive management framework.  Phase 1 of the Plan proposes starting with 40% of unimpaired flow on the San Joaquin River’s three major tributaries between February and June, but allows flexibility to go as low as 30% or as high as 50%, depending on whether biological goals and objectives are met.

The challenge with non-flow measure alone is that water diversions on the Tuolumne River have reduced the actual flow on average to just 21% of annual unimpaired flow, dramatically altering the ecosystem.  The lower Tuolumne is now slow-moving and warm, creating ideal habitat for non-native species, such as bass and water hyacinth, that thrive under such conditions.  Native species, which evolved with faster-moving, colder water, are now at a competitive disadvantage.  Without addressing the altered ecosystem, recovery of fish species with non-flow measures alone is not possible.

SFPUC Statement:
Instead of adopting a flawed plan, we believe the best solution is a voluntary agreement with the SFPUC and other affected stakeholders including the Turlock and Modesto Irrigation Districts.

TRT Response:
Pursuing a voluntary agreement is fine, as long as it’s not just a stall tactic.  In fact, settlement negotiations for the Tuolumne have been underway for two-and-a-half years.  The reality is that any solution must include higher flows.  The best available science makes it clear that flows are the most important factor in reviving the Bay-Delta and rivers that feed it.  Flows affect fish migration, water temperature, dissolved oxygen, water quality, floodplain inundation (critical habitat for juvenile fish rearing) and even predator avoidance.

Please view a video slideshow at

SFPUC Statement:
Our analysis of the 2012 recommendation (35% unimpaired flows) shows a significant economic hit to our service area:

  • 50% shortage of water due to rationing during droughts.

TRT Response:
This statement is false.  According to the Bay Delta Water Quality Control Plan environmental document:

“The 1922-2003 average calculated volume of water potentially available to CCSF under the Raker Act was about 750 TAF/y (thousand acre-feet per year, or 670 mgd)…According to a SFPUC planning document, an average of 244 TAF/y (218 mgd) is diverted from the Tuolumne River…based on data from 1989-2005.”[2]

The amount of water potentially available to the SFPUC on the Tuolumne is three times the amount it has diverted historically.  Last year water use was 30% lower than in 2005.  15% of the SFPUC’s water comes from the Bay Area – a supply that will not be affected by the Bay Delta Plan.  Between 2010 and 2014, the SFPUC’s 2.6 million customers used between 220 and 225 mgd.  In 2015 they used 195 mgd.  In 2016, they used 180 mgd.  During droughts SFPUC customers step up and conserve.

As explained above, the SFPUC has enough storage to last six years.  Right now, even after the recent drought, the SFPUC has enough water in storage to last longer than 1987-1992 drought.

The SFPUC’s basis for analysis since 2009 has been to assume a worst-case economic scenario during droughts and argue that this is the only possible outcome.  A contract between the SFPUC and the Modesto and Turlock Irrigation Districts, known as the Fourth Agreement, obligates the SFPUC to produce 51.7% of any increase in Tuolumne River flows required by the Federal Energy Regulatory Commission (FERC).  However, the State Water Board is not a party to the Fourth Agreement, and has no authority to enforce it.  The Fourth Agreement is silent on flow increases that might be required by the State Water Board, but each iteration of the SFPUC socioeconomics analysis is founded on the assumption that the SFPUC will be responsible for 51.7% of increased flows, and that SFPUC will find no replacement water if needed.

In testimony to the State Water Board, the SFPUC stated, “In presenting potential water supply and socioeconomic effects from certain interpretations of the Raker Act and the Fourth Agreement, San Francisco does not thereby waive arguments it may have about how the Raker Act or Fourth Agreement should or will be interpreted in future proceedings.”  Obviously, the SFPUC intends to challenge any application of the Fourth Agreement if necessary.

[1] SFPUC Urban Water Management Plan, Table 8-2 —

[2] Bay Delta Water Quality Control Plan, Substitute Environmental Document, Appendix L, Page L-4.

The SFPUC’s Socioeconomics Study Is Flawed

The Bay Delta Water Quality Control Plan aims to achieve the co-equal goals of protecting fish and wildlife and ensuring a reliable water supply. Phase 1 of the Plan proposes to require 40% of unimpaired flow (what would naturally occur in the absence of dams and diversions) to be released into the Stanislaus, Tuolumne and Merced Rivers, down into the lower San Joaquin River and out to the San Francisco Bay-Delta between February and June. Adaptive management would allow flows to be increased or decreased by up to 10% depending on whether biological goals and objectives are met.

In an OpEd published in the San Francisco Chronicle on October 9, 2016, the General Managers of the San Francisco Public Utilities Commission (SFPUC) and the Bay Area Water Supply and Conservation Agency (BAWSCA) stated, “Our initial economic analysis of the first iteration of this plan forecast up to 51 percent rationing, resulting in 140,000 to 188,000 jobs lost in the Bay Area. These same forecasts also show between $37 billion and $49 billion in decreased sales transactions.”

The Socioeconomics Study referenced in the above quote was seriously flawed. Had it been accurate, we should have expected to see a loss of $7 billion and 24,510 jobs during the last fiscal year when water use in the SFPUC service territory was 32% below the SFPUC’s average year water supply. Obviously, that did not happen.


On March 13, 2014, the SFPUC released its draft Socioeconomics Study, and on April 9, 2014 a coalition of environmental groups submitted comments that pointed out a number of flaws in the Study. To date, the SFPUC has yet to respond, but continues to cite the Study.

We found the following flaws:

  • The Study confused water demand with supply. Instead of calculating reduction percentages based on supply, it worked off of demand. This failed to credit the role conservation plays in allowing demand to be met when supply is reduced. Reductions would come from supply, not demand.
  • The Study assumed reductions in water supply would be imposed on the SFPUC’s entire Regional Water System, and not just the Tuolumne portion of supply. In an average year, 15% of the SFPUC’s water supply comes from Bay Area sources. The Bay Delta Plan will not affect this portion.
  • The Study failed to sufficiently analyze the important role storage carryover and replenishment play in the SFPUC’s water supply. For example, after five years of drought, with the Tuolumne watershed receiving normal precipitation last year, total SFPUC storage is currently at 80% of capacity. We have enough water in storage to last four-and-a-half years at pre-drought levels of use.

Furthermore, after the Socioeconomics Study was released, BAWSCA (which accounts for two-thirds of system demand) revised its 2040 demand projections downward by 20%. Therefore, future demand projections cited in the Study are no longer accurate.

Water Use Was 32% Below Supply in FY 2015/16

During the 2015/16 fiscal year, water demand in the SFPUC service territory was 180 million gallons per day (mgd) – 32% below the average year supply of 265 mgd. The following charts from the SFPUC’s Socioeconomics Study suggest that a 30% reduction in supply would have resulted in $6.5 billion in sales losses, $570 million in welfare losses, and 24,510 lost jobs. This did not happen. In fact, our economy was stronger than ever.




Even before the drought kicked in, water demand was down around 225 mgd. The graph below shows that water use in FY2015/16 was lower (180 mgd) than during the 1997/98 drought, despite a large increase in population and jobs in the SFPUC service territory.


Source: SFPUC

Future Demand Projections Have Decreased

The top chart below from the Socioeconomics Study suggests water demand from the SFPUC’s wholesale customers in San Mateo, Santa Clara and Alameda Counties (represented by BAWSCA) would be 212 mgd in 2035/36. The bottom graph shows BAWSCA’s revised demand projections reduced by 20%. They now expect to need only 168 mgd from the SFPUC by 2040. The Socioeconomics Study is obviously stale, and should no longer be referenced.


Source: SFPUC Socioeconomics Study


Source: BAWSCA

Water Supply Carryover and Replenishment

The SFPUC owns several reservoirs in addition to Hetch Hetchy and has a water bank at Don Pedro Reservoir that allows them to capture and store water when there’s excess in the system and then borrow off of it in dry years. Total storage equals 1.458 million acre-feet (an acre-foot is 326,000 gallons). After five years of drought, with last year being a normal precipitation year, the system held 1.144 million acre-feet of water on October 2, 2016, and the rainy season had just begun.

Before the drought kicked in, the SFPUC service area used about 250,000 acre-feet of water per year. At 80% capacity, there’s currently enough water in storage to last 4.5 years.


Source: SFPUC

According to the Substitute Environmental Document (SED) prepared by the State Water Board for the Bay Delta Plan: “The 1922-2003 average calculated volume of water potentially available to CCSF under the Raker Act was about 750 TAF/y [thousand acre-feet per year]…According to a SFPUC planning document, an average of 244 TAF/y is diverted from the Tuolumne River…based on data from 1989-2005…” The SFPUC is not short on water.

The SFPUC’s Obligation Under the Bay Delta Plan

At this point it is unclear what portion of increased flow the SFPUC will be responsible for. A contract (known as the Fourth Agreement) between the SFPUC and the Modesto and Turlock Irrigation Districts (which own and operate Don Pedro Reservoir) obligates the SFPUC to provide 51.7% of any increase in flow required by the Federal Energy Regulatory Commission (FERC). However, the State Water Board is not a party to the Fourth Agreement, and has no authority to enforce it. The Fourth Agreement explicitly addresses flow increases pursuant to a “Federal Power Commission license requirement” and is silent on flow increases that may be required by the State Water Board.

In its Socioeconomic Study, the SFPUC worked off of the assumption it would be responsible for 51.7% of increased flow, making the economic impacts appear much larger than they will likely be. However, in testimony to the State Water Board, the SFPUC stated, “In presenting potential water supply and socioeconomic effects from certain interpretations of the Raker Act and the Fourth Agreement, San Francisco does not thereby waive arguments it may have about how the Raker Act or Fourth Agreement should or will be interpreted in future proceedings.” Obviously, they intend to argue against being responsible for 51.7% of increased flow.

The Bay Delta Plan SED states, “The State Water Board may assign responsibility for meeting the flow objectives through a proceeding amending the agency’s water rights to require compliance with the objectives. In a water right proceeding amending water users’ rights, the State Water Board generally would assign responsibility for meeting the objectives in accordance with the rule of priority and other applicable law. At this time, it cannot be predicted how such responsibility would be allocated in a future proceeding among the water right holders on the Tuolumne River.”

If the SFPUC’s responsibility ends up being proportional to its percentage of diversions from the Tuolumne, it would be obligated to produce 20% of the increase in flow (80% of diversions are carried out by the Irrigation Districts in Stanislaus County). This would amount to about 45 mgd. Subtracted from its average supply from the Tuolumne (225 mgd), and then adding in 40 mgd of Bay Area water supply, the SFPUC would still have access to 220 mgd.

It’s interesting to note that over the past seven years, the SFPUC service area has averaged less than 220 mgd in water demand. And again, for real impact one must consider carryover and replenishment storage.

Prepared by the Tuolumne River Trust on October 20, 2016.