January 5, 2024
Board of Directors
Santa Clara Valley Water District
5750 Almaden Expressway
San Jose, CA 95118
Via email to:
Clerk of the Board <clerkoftheboard@valleywater.org>
Board of Directors <Board@valleywater.org>
John Varela <jvarela@valleywater.org>
Tony Estremera <testremera@valleywater.org>
Barbara Keegan <bkeegan@valleywater.org>
Richard Santos <rsantos@valleywater.org>
Jim Beall <jbeall@valleywater.org>
Nai Hsueh <nhsueh@valleywater.org>
Rebecca Eisenberg <reisenberg@valleywater.org>
Re: Agenda Item 3.8. Receive an Informational Update and Provide Feedback on the Development of Valley Water’s Water Supply Master Plan 2050.
Dear Valley Water Board of Directors,
The Sierra Club appreciates any opportunity to provide input on the Water Supply Master Plan (WSMP) update, especially early in the process. Please consider the following comments and suggestions based on the information provided about the Plan update so far.
- Portfolio Analysis Under Alternative Futures. (Staff report pg. 3)
- Portfolio #2 is the most environmentally friendly option of the example portfolios while achieving water supply needs in multiple future scenarios. Valley Water should analyze a portfolio that incorporates both Palo Alto recycled water and the refinery recycled project to Portfolio #2 in an effort to evaluate whether it meets the needs of a “high demand and severely impacted imports” future scenario. All portfolio analyses should include both the Palo Alto and San Jose potable reuse projects as it becomes increasingly important to secure a resilient local water supply given the uncertainties of climate change.
- The staff report finds that "Some projects work better when paired with other projects." This seems especially true for the Pacheco Reservoir Project and the Delta Conveyance Project (DCP). Pacheco makes even less sense without the DCP. Therefore, any scenario with Pacheco should also include the DCP.
- Cost Analysis (staff report pg. 5). "For supply projects, the unit cost is calculated using present values of lifecycle cost relative to the proposed annual supply benefit, while for storage projects, a "storage capacity cost" or cost per acre-foot of storage capacity is calculated."
Using storage capacity cost for storage projects would substantially under-calculate unit costs because storage projects will rarely be at capacity. To objectively compare these projects, the work needs to be done to project future water storage levels in reservoirs and realistically calculate unit costs in a comparable manner. - Attachment 1 Demand Memo (pdf pg. 518)
- Demand projections in this memo are much higher than demand projections used for rate-setting. The rate-setting projection for water usage is 202-207 thousand acre-feet (TAF) for 2024-25. This memo projects 330 TAF in 2025. It appears at least 2025 projection for the Water Supply Master Plan should be adjusted. In general, the water usage projection methodologies should be compared and brought into greater alignment.
- Is CALSIM II used in any of the demand analysis? If so, this is out of date and modeling needs to be updated to use CALSIM III as soon as possible. Valley Water should not be making decisions based on such out-of-date modeling.
- Next Steps (Slide 18). "Provide update to support upcoming project decisions."
If the next update is provided in Spring 2024, that will not help with decisions for this year’s Capital Improvement Program. How will the Spring update on the WSMP support specific upcoming project decisions? - Feedback Requested (Slide 20)
- Any specific portfolios. See comment #1 above.
- Overall evaluation framework. The Sierra Club is disappointed that environmental impacts barely factor into the evaluation framework.
- Information to help inform decisions. Take/put information for out-of-county storage projects would be useful to understand how different portfolios meet take/put criteria. Also, information about the water demand drought rebound in 2023 would be useful to see how demand is progressing towards the assumption of 330 TAF in 2025.
We look forward to seeing an in-depth analysis of all project evaluation criteria for all projects/portfolios. The sooner additional opportunities for public input can be provided the better.
Thank you for your consideration.
Sincerely,
Katja Irvin, AICP
Guadalupe Group Conservation Chair
Sierra Club Loma Prieta Chapter
Molly Culton
Chapter Organizing Manager
Sierra Club California