San Francisco Public Utilities Commission Meeting - September 9, 2025
And Stacy?
Here.
Vice President Arce.
Absent.
Commissioner Jamdar.
Absent.
Commissioner Leveroni.
Here.
Commissioner Thurlow.
Here, you have a quorum.
And I think Commissioner Jamdar is expected momentarily and hopefully Vice President Arce will be here later in the meeting.
Thanks.
Before calling the first item, I'd like to announce that the San Francisco Public Utilities Commission acknowledges that it owns and are stewards of the unceded lands located within the ethnohistoric territory of the Mawekma Alone tribe and other familial descendants of the historic federally recognized Mission San Jose Verona Band of Alameda County.
The SFPUC also recognizes that every citizen residing within the Greater Bay Area has and continues to benefit from the use and occupation of the Mawekma Alone tribes aboriginal lands since before and after the San Francisco Public Utilities Commission's founding in 1932.
It is vitally important that we not only recognize the history of the tribal lands on which we reside, but also that we acknowledge and honor the fact that the Mawekma Alone people have established a working partnership with the SFPUC and our productive and flourishing members within the many greater San Francisco Bay Area communities today.
Item three, approval of the minutes of July 22nd, 2025.
Commissioners, are there any comments or corrections to the minutes?
No.
Seeing none, let's take public comment.
Remote callers, please raise your hand if you wish to provide comment on item three.
Are there any members of the public present who wish to comment on this item?
This is for the minutes.
Commissioners, uh, it's been some time since I've come here.
I'm busy on some other fronts facing our nation.
I'm sorry, Mr.
DeCosta.
Are you commenting on the minutes?
Yes, please.
Okay, thank you.
So from time to time, I have to prioritize what's important to San Francisco, and what's important to our citizens.
Early today, I was at a meeting at 525 on the third floor, 525 Golden Gate, on the rate board, listening to them very intently.
And they kind of refer to the commission as to what is happening with energy, our source system, our clean water system, back and forth, back and forth.
We have issues with PGE, we have issues with our program, the clean program, and we need to pay attention to those who are who need help most, our seniors, and those who need uh, you know, people who are challenged and need and have to have certain um instruments and certain applications so that health can be addressed, and we need to have those who are suffering here in San Francisco.
Uh lots of charts, I'm going to review them.
Uh, a lot of statistics, but very few solutions, and PGN PGN is still in the cockpit.
As long as they're in the cockpit, it's going to be a tough fight.
Thank you very much.
Are there any other members of the public who would like to speak on item three?
Minutes for July 22nd, 2025.
Moderator, are there any callers who would like to speak?
Ms.
Lanyard, there are two callers that wish to be recognized.
Thank you.
We wanted a gentleman.
Caller, you're you can unmute it.
You have two minutes.
I want to make a comment.
General comment.
The general public comment is the next item.
We're just talking about the minutes now on item three.
Okay.
Caller, your mind has been unmuted.
You have two minutes.
Ms.
Lennier, there are no callers that wish to be recognized.
Thank you.
Thank you.
Commissioners, could I have a motion and a second to approve the minutes of July 22nd?
Seconded.
Thank you.
President Stacey?
Aye.
Vice President Arce absent.
Commissioner Jamdar.
Absent.
Commissioner Laverone.
Yes.
Commissioner Thurlow.
Aye.
The item passes.
Item four.
General public comment.
Members of the public may address the commission on matters that are within the commission's jurisdiction and are not on today's agenda.
Just a note, the commission values civic engagement and encourages respectful communication at the public meeting.
We ask that all public comment be made in a civil and courteous manner, and that you refrain from the use of profanity.
Thank you.
Remote callers, please raise your hand if you wish to provide comment on item number four.
Are there any members of the public present who wish to comment on this item?
If so, and you have not already done so, please complete a speaker's card.
Mr.
DeCosta.
My name is Francisco de Costa.
I'm going to speak on general public comment.
And I'm going to speak on how the Bayview Hunters Point is looking forward to the SFUC and to a few of those in the SFPUC to have the community.
So for the last two and a half years, we have been meeting every Wednesday to address chronologically from 1950 to now what is happening in our community.
And commissioners, you have to find out who is working with us from the SFPUC.
And try to find out a solution.
So when there is no accountability and transparency, there's going to be a problem.
So I want you to hear to the people from the Bayview.
We already had three meetings with the controller's office.
Greg Wagner, who's a good friend of mine, and Todd, you know, Todd was an institution, but he left us.
But he knew more.
We cannot look away from the Bayview Hunters Point community.
Thank you very much.
Mr.
Spreck Rose Grills?
Thank you.
I don't know if it's operating.
It's not working.
Okay.
Thank you.
Uh Spreck Rosecrans.
Oh, there it is.
Okay.
A little fuzzy.
Um, restore a chesty.
Thank you for the opportunity to speak today.
I want to talk a little bit about water quality.
And the commission uh does a great job providing high-quality, reliable water, as do many other water agencies.
We do hear from time to time that it's the best.
And uh frankly, we've always wondered if that's true.
Uh so last summer we engaged graduate students from the University of Colorado to design and initiate a double-blind water taste test.
And they compared uh water from the BUC with water from East Bay Mud and water from the Marin Municipal Water District.
And we tested people uh throughout the summer at various locations and asked for first place boats, and it turned out it was fairly close, but East Bay MUD came out first, Marin came out second, and San Francisco came out third.
Um, so in a sense it's good news because you've at times it gotten heat from your customers when you've introduced a little groundwater here and there, and to introduce a little bit of something with some minerals doesn't necessarily turn off customers from what we've seen.
Um, and if anybody wants to question these findings or the way we did the testing and wants to work with us on further testing and a more publicly designed experiment, we'd be happy to cooperate.
Thank you very much.
Thank you.
Mr.
Rosecrans, that document that you had on the overhead was also part of your letter that you sent to the Commission.
Thank you.
Thank you.
Nancy Arbuckle.
Good afternoon, Commissioners.
My name is Nancy Arbuckle.
I live in San Francisco.
I'm a resident and a ratepayer.
There are just two points I want to make today.
The first one is that the SFPUC is basing their decisions about our water on flawed data.
And number two, uh, taxpayers, excuse me, ratepayers in the environment are being harmed as a result.
So regarding number one, the flawed data, this starts with flawed demand projections.
Demand projections should be based on actual usage.
The SFPUCs are not.
Demand for water has declined drastically and dramatically over the past 30 years.
This should be reflected in the demand projections.
San Franciscans are conservers.
We value our environment and we don't want to throw our money away.
Now, regarding point two, which is the harm to ratepayers in the environment, uh, the SFPUC's own reports show that half of every bill, every bill we pay goes to paying off debt.
We already pay the highest water rates in the state.
Rates keep increasing.
Ratepayers respond to this by using less water.
Fixed costs stay the same, so rates increase even further.
So rather than directly dealing with number one above, which was the flawed data, resulting in number two, which I was just talking about, the rate payer and environmental harm, the SFPUC has taken an anti-science and anti-data approach and resorted to voluntary agreements, which we all know don't begin to address the real problem.
The science supports the Bay Delta Plan, rate payers support the science, rate payers support the Bay Delta plan, ratepayers demand accountability.
Thank you very much.
Thank you.
Bill Clark?
Good afternoon, Commissioners.
My name is Bill Clark, and I'm here today to express concerns regarding the direction of today's PUC.
With limited knowledge of the full scope of PUC purview, I am versed enough to know that the basic needs of citizens affected by deferred maintenance of sewer infrastructure is threatened with public health at a crossroads.
Upstream sewer drainage issues during winter storms and flooding from overwhelmed overwhelmed outfalls have become more alarming as systemic problems are ignored.
There appears to be a focus on big budget projects and operational approach of legal maneuvering to divert, deflect, and delay from maintaining current infrastructure that directly affects day-to-day public health.
By avoiding the integration of current facilities through upgrades, maximizing sewer system strengths, fine-tuning poorly functioning outfalls and gates into a comprehensive, holistic concept of modernization.
San Francisco's sewer network falls short of functioning optimally for its citizens.
The Bayside's Biosolids Digester and Headworks project alone has diverted valuable budgetary resources to the tune of four billion that could have been implemented in stages to avoid the ensuing deferred maintenance of other vital infrastructure.
The PUC has allowed a number of outfall gates, including Brandon Street Gate, Sansome Street, 5th and 6th Street, Mission Creek, et cetera, to degrade and fail, leading to both an increase in combined sewer discharges into sensitive Bay Recreating Areas, as well as amplifying the threat of upstream flooding in Soma, the mission, and marina neighborhoods.
The closure of the Pierce Street outfall specifically is offlined an integral piece of marine area flood control.
Modernizing and integrating the infrastructure we have is paramount to the future of the SF sewer system and public health.
Thank you.
Thank you.
Demetrius Williams.
Good afternoon, Commissioners.
My name is Demetrius Williams.
I'm the president of the San Francisco Hyperlocal Building Trades Contractors Collective.
We're a group of contractors that meet in the Bayview every Tuesday at 8 a.m.
at the 1550 Evans site.
There was resources that were supposed to come to the Bayview that was not allocated to the Bay View.
I don't know where those resources went, but um the people who were in charge eventually got indicted and the resources was taken from them.
Now we build in this state of the art uh sewer treatment plant without no community contractors that's able to, in case of a national disaster, able to fix something that goes on wrong there.
We need the training to train some of the community contractors, especially the plumbing contractors that live in the Bayview, dwell in the Bayview, bank in the Bayview, that's able to come out and fix the Bayview state of the art uh sewer treatment plant that's uh being built out there.
So I think we need to find out, like Francisco say, where those resources are uh and where they're allocated, and train the community contractors on how to fix that sewer treatment plant and be prepared for a national disaster or anything else that might come up, changing out a uh eight-inch butterfly valve or whatever it might be.
But that's those are my concerns, and I hope that we can find some type of resources to train some of us out there in the community to help out.
Thank you.
Thank you.
Moderator, are there any callers who have their hand raised?
Thank you.
Caller, I have a mute at your line.
You have two minutes.
Thank you.
We are here on Ohlone.
I am Alone.
Oce.
I know, I norma wallet Galvan.
The ACMA is weak.
Normal Uyakish, Uyakish, Yakish.
Makam Rote Ohloni Warep.
Good day.
My name is Norma Wallace Galvan.
My family has been born here for many, many years.
I am Oloney and Bay Miwok and Potlin.
I own our family home on Quintara next to Old Tank Hill.
It is all unseeded stolen land.
I am a lonely.
That San Francisco sued to destroy the Clean Water Act is to our everlasting shame.
I knock Alone.
The ancestors sought consensus before the captain decided.
After years of attending SFTUC meeting, testifying, seeing the public ignored, watching a well-known, deeply respected, dedicated community member resigned out of frustration.
I am confused.
I am a looney.
There are at least four new commissioners here.
You need to ramp up, and I do not envy you one IOTA.
Ga nakolone.
As was done in the past, hold a workshop to receive an update.
Let staff share why they ignored two commission directives to work with the irrigation districts to include biological goals and adaptive management in the TRBA.
I am Olone.
I also want to underscore that I completely agree with the prior comments related to voluntary agreements, deferred maintenance.
And when I was told to save water, I got down to 13 gallons a month.
Please.
Thank you, caller.
Your time has expired.
Caller, I'm unmuted your mic.
You have two minutes.
Yes, can you hear me?
Yes, we can hear you.
Hi, my name is uh John Rose the Pepe.
Um former uh fisheries biologists uh former Mitchell fisherman and angler and care about our water in the river.
And I want to echo um the previous caller's call to have some workshops.
I mean, for if you are new back in uh 2022 and 2023, um, there was a series of workshops.
I think there were five and uh several of them uh focused, one of them focused especially on the fish biology and and the uh how badly they're doing and why they're doing and how the voluntary agreement doesn't work.
Again, uh so um thank you very much.
And the other thing is um it would be nice if you had a workshop on the design drought.
Thank you for your time and um I look forward to uh having uh workshops where you invite uh not only the staff but also uh people from outside either uh agency biologists and NGOs.
Thank you very much.
Good day.
Thank you, caller, for your comments.
Caller, I'm a muted line.
You have two minutes.
Good afternoon, President Stacey and Commissioners.
This is Peter Dreckmeier, policy director for the Tualomee River Trust.
The Tualamy River Volunteer Agreement has been extremely controversial for years.
The science tells us it would fail, but there's no backup plan.
Following extensive criticism from conservation and fishing groups in 2019, the commission adopted a resolution directing staff to work with the irrigation districts to incorporate biological goals and adaptive management into the TRVA.
A similar resolution was adopted in 2020.
Staff has clearly ignored these directives.
A public records act request I filed in May of 2024, seeking evidence of discussions with the irrigation districts, was illegally denied based on attorney client communications.
Explain that one to me.
A year later, this past May, I sent a follow-up letter to President Stacey but never received a response.
In the fall of 2024, General Manager Herrera made a statement that the SFPUC was communicating with the state on biological goals and adaptive management, but we've heard nothing since.
And now Governor Newsom is threatening to introduce a trailer bill that would exempt water quality control plans from CEQA review.
This is clearly an admission that the volunteer agreements cannot hold up to environmental review.
The SFPC does not need to fight the Bay Delta water quality control plan.
Did you know that Valley Water, the SFPC's closest neighbor, is planning for a drought comparable to the 1987-92 drought?
The design drought is 72% more severe and could cost 17 billion dollars to fund alternative water supplies to meet the drought needs.
So is Valley Water's planning not conservative enough, or is SFPUC planning way too conservative, harming both the environment and ratepayers?
Please schedule workshops to answer pressing questions about the TRVA and the design drought.
We haven't had any workship shops since then.
Thank you, Coller.
Your time has expired.
Caller, I've unmuted your line.
You have two minutes.
This is Ben from Friends of Mission Creek.
I'd like to thank the Commission for the opportunity to speak today.
We at Friends of Mission Creek have grown increasingly concerned about the lack of regard for public health and safety shown by PUC's management and commission.
San Francisco sewers frequently back up onto the streets and into homes and businesses.
The BACU's discharge raw and treated sewage, which in most of the United States is considered a public health hazard, not in San Francisco.
This lack of concern seems to have been formalized in the 2010 sewer system master plan tech memo 405 regulatory considerations for wet weather collection systems backups.
This document clearly points out that there is no regulatory reason to prevent sewer backups or spills.
Based on this finding in 2010, the PUC general manager Ed Harrington, who was appointed by then mayor Gavin Newsom, dictated to this commission that the only storms San Francisco PUC would concern itself with was a very small five-year storm.
Then in July 2012, Commission meeting, he then dictated to this commission that PUC would remove all funding for flooding projects recommended by the 22 2010 sewer system master plan.
Oddly enough, they did not, they did continue several projects already to improve upstream flooding, bringing even more sewage down in the PUCs to areas where the sewers were already too small to carry the flow from sewers upstream with no sewage back and forth.
This decision took PUC into a down or spiral from which it has yet to find its way out of.
In 2021, after pressure from the US EPA to the state of California, the regional board worked out the cleanup and abatement order requiring San Francisco to fix the undersized sewers in three areas.
Since only three areas were included, San Francisco leaders must have decided they can continue to dump sewage into our homes and businesses while working on the caller, your time has expired.
Caller, I've unmuted your mic.
You have two minutes.
Um decisions.
And I'd like to support what some other of the callers have said.
The problem is twofold.
So they can understand what's wrong with the design drought, why the demand projections are off, and why not uh why the commission should adopt and support uh Bay Delta plan?
If we don't do that, the long and short will be, I'm afraid to say, the uh station of the bay, the delta, and all you need to do is look around places like the Sultan Sea and the Aeral Sea to see the horrible consequences that might result.
Thank you.
Thank you, Coller, for your comments.
Caller, I have a mute your mind.
You have two minutes.
Hi, welcome new commissioners, and thank you for all your time.
My name is Martin Gothberg and I'm a consumer of Tuoline River Water.
First of all, I agree with the prior comments.
I'd like to add that the SFPUC water management planning process is really part of the problem.
SFPUC and that design drought, an imaginary eight-year drought that has never happened in history.
Models tell us it's beyond conservative, unlikely to occur within 8,000 years or greater.
Why should SFPUC be different from water agencies that plan for six years?
Mashing together two different drought year periods is completely arbitrary and unscientific.
We will always be in drought planning mode facing extreme rationing and cost implications.
Accounting methods under the current iteration of TRVA have been shown to be riddled with double counting, and it's the very definition of using smoke and mirrors to further restrict unimpaired flow.
Furthermore, claiming that we just don't know how long a drought can be, especially with climate change.
That's a problem because you can review video from workshops with extensive citations from the long-term vulnerability assessment, the climate change study.
SFPUC staff essentially ignored the study because it didn't support their narrative, apparently.
The report concluded that climate change doesn't pose a risk with the earlier runoff actually helping SFPUC.
It's been well documented.
So ignoring data and evidence because it's contrary to your narrative means that you might have a corrupted decision-making process.
It is at least a red flag, and please look into that.
Please make sure staff has clearly addressed the likelihood of occurrence and that they respond to alternatives that were presented.
Really, this needs to change.
Thank you again for your time.
Thank you, Coller, for your comments.
Coller, I've unmuted your line.
You have two minutes.
Can you hear me?
Yes, we can hear you.
Okay, great.
Um, good afternoon.
My name is Mary Butterwick.
A longtime resident of San Francisco.
I have a personal connection to the Tuolamee River, the source in my drinking water, and a responsibility to do what I can to advocate for functioning aquatic ecosystem in the Tuolamy.
Since 2019, when I learned that San Francisco and others joined a lawsuit against the state water board's Bay Delta Plan update, I and other members of the public have attended and testified at numerous SFPOC meetings, the mission, visit its extremely conservative 8.5-year design drought and related water demand projections.
Thus far, the commission has been unresponsive to our concerns.
Costs associated with the developing alternative water supplies would add 17 to 25 billion to the budget.
Reduce the design drought year, apply realistic demand projection, and one can reduce the amount of alternative water supplies needed by two-thirds.
This approach could ensure instrumental flows are consistent with the state's adopted flow standards for me.
The fall run Chinook salmon are in desperate need of increased flows.
I urge the commission to workshop on the design drought and invite the to have a panel as has been done in the past.
It is time for an update on the proposed Guilamee River Voluntary Agreement.
I'm very concerned that this VA will not work because it provides little in the way of new protective water that is needed to sustain this based aquatic ecosystem.
This VA is no substitute for forceable flow-based water quality standards.
Thank you.
Thank you, Coller, for your comments.
Caller, I'm a mute your line.
You have two minutes.
Good afternoon, members of the PUC.
Uh, my name is Steven Rosenrum.
I'd like to uh thank you for the opportunity to speak and align myself with many of the prior comments on from Nancy Arbuckle, Peter Brick Meyer, Rush Ran, and Mary Bunrick, going to name a few.
Due to climate change, California is facing continuing cycles of drought and flooding.
The task of the SFPUC is to plan for reliable and cost-effective supply of drinking water for its customers.
The way to do this is to make a plan that tries to address the likely scenarios the SFPUC will face.
Disaster just the design drought is not a likely scenario.
No, commit the SFPUC to disastrous increases in cost to rate periods that are required to develop new water supply and storage capacity.
Yes, the SFPC should also not support any budget trailer bills that ignore environmental costs that are trying to increase supply by reducing pressure water flows to fishing wildlife.
The SFPC should commit itself to abiding by the state water boards regulation requiring 30 to 50% minimum flows on Tuolamy River and not accept the bogus idea that voluntary agreements by stakeholders can substitute for the problem of cold clean water for salmon and truck.
Thank you.
Thank you, Colin, for your comments.
Caller at a mute at your line, you have two minutes.
Hi, can you hear me?
Yes, we can hear you.
Hi there.
My name is Sonica Hummer, and I have a professional background in the fisheries consideration from the federal government and on the nonprofit side.
And thank you, Commissioners, for having us and to the opportunity to comment today.
I wanted to mention that in 2009, the state legislature adopted the Belgian reform establishing co-equal goals and reliable water supply.
And the SSPC is better positioned compared to any other water agency to support those police for goals, given their expensive water rights and reservoir storage.
And also wanted to take the opportunity to remind everyone that in 2010, the water court released a flow criteria report that it determines the lower San Joaquin River and its three main tributaries.
We mean 60% of the pair flow between February and June for the ecosystem.
However, phase one of the Bay Adult Plan, which only require 40% of unimpaired flow compared to that 60% identified in the report.
And so I wanted to support several of the comments made already and encouraged SF to hold a session to answer the question of if they could really meet the 40% unimpaired flow requirement without risking running out of water.
Thank you.
Thank you, Coller, for your comments.
Ms.
Lanier, there are no more callers that wish to be recognized.
Thank you.
Thank you to all the commenters.
Please call the next item.
Item five report of the general manager.
Thank you, Miss Lanier.
Uh, item 5A is a quarterly audit and performance review report.
Nancy Hum will be presenting.
Good afternoon, President Stacey and Commissioners.
My name is Nancy Hom, Chief Financial Officer and Assistant General Manager for Business Services.
I'm here on behalf of Irella Blackwood Audit Director to present the Audit Bureau's quarterly audit and performance review report for the fourth quarter ending June 30th, 2025.
May I have the slides, please?
Thank you.
At the end of the fourth quarter, the PUC completed a total of 23 audits, which includes 16 financial audits and seven performance audits.
There are currently 14 audits in progress as of June 30th.
Six are scheduled for the current first quarter of the current fiscal year 25-26, with the majority being financial and related to the fiscal year end.
The four audits completed in quarter four are listed here in this table, highlighting the individual audit, oversight body, and the report issuance date.
They are the fiscal year 2324 single audit, oversighted by the controller's office, the 2024 Clean Power SF privacy audit, the interdepartmental services management performance audit performed by the Board of Supervisors Budget and Legislative Analysts, and the fiscal year 2324 wholesale revenue requirement statement of changes in the balancing account financial audit for the Bay Area Water Supply and Conservation Agency.
Each quarter, the audit bureau highlights one noteworthy completed audit to the commission, and we've chosen to spotlight the be at the budget and legislative analysts' citywide um audit uh for the performance management of interdepartmental services.
The audit was in response to the Board of Supervisors' November 2023 motion to initiate a performance audit of citywide interdepartmental service work order agreements.
As the BLA reviewed these transactions, they included a four-year audit scope period from fiscal year 2018-19 through fiscal year 2022-23, focusing on the areas of budget, expense documentation, billing and carry forwards, performance management of services delivered, and adherence to contract requirements, comparison to best practices, and then also agreed upon procedures to resolve overbilling and other disputes between departments.
The audit focused on three key areas of deficiency within work orders and interpart departmental services where the city could improve.
This included inadequate planning, which created surplus and deficits between city departments, insufficient oversight and tracking of expenditures and carry forwards, as well as performance management and disputes.
Oversight departments providing citywide services were highlighted for their centrally loaded work orders.
These included the controller's office, Department of Technology, and the Office of Contract Administration.
Internal control deficiencies were attributed to a lack of standardized procedures and templates for cost-sharing models and inadequate reviews of cost justifications.
And then lastly, inefficient administrative processes that did create billing delays and other issues such as accounting errors, non-sufficient funds, and lack of support and documentation.
Our agency did participate in this audit as part of surveys and interviews along with other city departments.
The positive highlight is that the PUC had no findings.
These four recommendations focused on areas of standardizing policies, templates, and reporting, monitoring departments' work orders performance via timely review of justifications and supporting documentation, as well as detailing performance monitoring and dispute resolution in MOU agreements.
They also highlighted the requirement to have timely billing and enforcing that, as well as codifying the prohibited use on delegated authority on any new projects.
This slide highlights our department's audits that have audit recommendations as are current.
The audit bureau actively monitors all open recommendations agency-wide and ensures that they're implemented within a six-month time frame as agreed upon by management.
As of June 30th, the PUC has 16 open audit recommendations across two open audits.
Staff are currently working to implement these and close these as soon as possible.
Looking into quarter one of the current fiscal year, we anticipate completing these five audits listed here that include the Mission Valley Rock Revenue Lease Audit, the Revenue Bond Audit Phase 3, the Controllers Single Audit for Fiscal Year 23-24, excuse me, the controller's calendar year 2024 post-audit, as well as the 14B LBE compliance audit, and also the annual warehouse physical inventory counts for fiscal year 24-25.
Upcoming audits are we're expecting this quarter that have already begun or anticipated, include the fiscal year 24-25 audited financial statements for each of the enterprises of water, wastewater, and the Hedgehogi Water and Power and Clean Power SF, information technologies network penetration and vulnerability assessment, as well as a reconciliation of costs between the Treasury Island Development Authority and the SFPUC.
And then lastly, the City Services Auditors Citywide Assessment for Compliance of the City's Digital Accessibility and Inclusion Standard.
This concludes my report to the Commission.
I'm glad to answer any questions you might have.
Thank you for that presentation.
Commissioners, comments or questions.
Seeing none, let's take public comment.
Thank you.
Remote callers, please raise your hand if you wish to provide comment on this item.
Are there any members of the public present who wish to comment on this item?
If so, please approach the podium.
I commend the chief financial officer always for doing a good job.
That's what it takes to guide the commission.
You hear what she has to say.
Not only today, but in the past.
But y'all don't do anything viable and sustainable.
To respect the report.
Um I know the general manager very well for a very long time.
Because when you listen to the people, you give them only two minutes.
At least allow them to make the point.
If you do not listen to the people, you will not go anywhere.
You'll fall flat on your face, just like the Democratic Party.
This nonsense that we are having in Washington, DC, and I know every aspect of it, is because we have not been listening to the people.
They complain to me.
Because they are suffering.
Why should they suffer?
Commissioners, please do due diligence.
Thank you very much.
Thank you.
Moderator, are there any callers who have their hand raised?
Ms.
Linair, there are no callers in the queue.
Thank you.
Thank you for the presentation and the materials to support it.
Madam President, that concludes my report.
Thank you.
Item six, consent calendar.
Commissioners, any comments or questions on the consent calendar?
No.
Seeing none, let's take public comment.
Remote callers, please raise your hand if you wish to provide comment on item six, the consent calendar.
Are there any members of the public present who wish to comment on this item?
Seeing none, moderator.
Do we have any members pre with their hand raised?
Ms.
Lanier, there are no callers in the queue.
Thank you.
Commissioners, could I have a motion and a second to approve the consent calendar item six?
Motion to approve.
Seconded.
Thank you.
President Stacey?
Aye.
Vice President Arcee absent.
Commissioner Jamdar.
Aye.
Commissioner Leveroni?
Aye.
Commissioner Thurlow.
Aye.
Item six passes.
Thank you.
Item seven.
Public hearing on the San Francisco Water System 2025 Public Health Goal Report for the purpose of accepting and responding to public comment and directing the San Francisco Public Utilities Commission, General Manager, or the General Manager's designee to submit a letter to the State Water Resources Control Board documenting that such a hearing has been held.
Great.
Next slide, please.
Oh, I got advanced, okay.
Yeah.
So the public health goal report has to be done every three years.
This is our 10th edition of the public health goal report.
Thank you.
We have to compare the last three years of compliance data against the public health call report.
And this actual public health goals.
If there's no California public health goal, we have to use the federal maximum contaminant level goal.
We have to identify the health risks associated with the contaminant, identify the best available technology, which is the treatment, and the cost.
We prepare a brief written report, which we sent to you in June, and we're holding this hearing right now to accept comments on the report.
Public health goals are not enforceable standards.
That are as maximum contaminant levels.
We produce an annual water quality report that's sent out.
So that's a different report.
There is no guidance from the state on how to produce this.
So we use the Association of California Water Agency's guidance.
Basically, what they say is look and see if there is a regular decontaminant, compare that result against the public health goal.
We use the data that comes out of the treatment plants basically, except for lead, which we use the customers' faucet where we collect the sample.
We use the same statistical analysis.
So if you use averages, use averages, you use a 90th percentile, like with lead, you use that 90th percentile to base the comparison.
We exclude caninates that doesn't have a public health goal or an MCL, and the process is that if you have a non-detect, that is treated as zero.
So this chart here provides a rough estimation of what the different levels are.
So for the MCLs, that's the highest level.
Then we have an operational goal, so we want to be comfortably below.
So generally speaking, for example, disinfection by products, we send it at 80%.
So we want to have that buffer so we're not coming up against the regulatory limit.
The MCLs in most cases are much lower.
So for the three that we're going to talk about in a few minutes, they're about at 1% of the MCL, so much lower level than the actual regulatory requirement.
So there are three contaminants who are exceeded the public health goal.
The first is bromate.
The regulatory limit is 10.
The DLR, which is the analytical method where we can see it, is one.
The public health goal is 0.1.
So 1% of the MCL.
The next is hexavalent chromium.
The MCL is 10.
The analytical detection level is 0.1, and the public health goal is 0.02.
And the final one is lead.
It's not actually MCL, it's a treatment technique.
It's 15.
We can see it at five.
Actually, our laboratory can see it down to one.
And the public health goal is 0.2.
So in terms of bromate again, the regulatory limit is 10.
The PHT is 0.1% of the MCL.
We see this coming out of the Harry Tracy water treatment plant.
We ozonate there, so the ozone reacts with bromide, which is naturally in the water, and that forms bromate.
It's a probable hard humid carcinogen.
The best available treatment, which is the treatment, is to optimize ozone dosage control at treatment plant, which we practice.
We also maintain our watershed.
So again, bromite comes out of the watershed, some of the soils.
So as you saw in the report, when the levels get a little bit too low, there's a higher level of bromide at that particular level.
We think the wave action causes more bromide to come out of the water.
So keeping it at a higher level, which we typically do, uh helps minimize the level of bromate coming out of that particular treatment plant.
So we continue to do that, watershed protection, and we do monthly monitoring just to see what the bromide levels are.
So if we have to tweak our ozone dose, we make sure that we tweak it to minimize bromate.
The next one is hexavalent chromium.
The MCL is 10.
The public health goal is 0.02.
It's a carcinogen.
We had to do initial compliance monitoring in October 2024.
Potential sources is basically the soil.
So whether it's the groundwater basin soil or the watershed in terms of the surface waters that you see.
So there isn't one for the particularly low levels for PHG.
We blend sources of water, particularly groundwater, to make sure that we get comfortably below the MCL and as close as possible to the PHG.
We maintain watershed protection.
We also have a chemical quality control program.
So we get treatment chemicals, and the treatment chemicals also have contaminants inside them.
So we want to make sure that those treatment chemicals are not adding any additional contaminants to our drinking water supply.
The final one is lead.
Uh the treatment uh level is 15 parts per million.
That's the action level, so there isn't an actual limit that we can't go above.
The PHG is 0.2.
Uh, lead is a little bit different than that.
The other contaminants, there are carcinogens.
This one is different in terms of the concerns about IQ loss if you have lead to too high.
Uh we've not detected it in our distribution system.
Basically, you're picking it up from the plumbing from the pipes in the street or service lines to the pipes that are in people's homes on their fixtures and faucets.
Um, so there is no uh identified best available treatment for that.
But we have a number of programs in terms of reducing lead or controlling it.
The first is lead component uh replacement.
In the 1980s, um, the city and this commission directed the removal of all the lead service lines, so there was about 7,000 in San Francisco.
So we're decades ahead of the regulations that are currently in place that tell uh utilities that they have to remove uh lead service lines.
We discontinued uh leaded joints in '83.
We've worked about curb stops, which are the valves uh in the sidewalk controlling the water flow.
So those have been lead-free versions of that.
We've also replaced meters, we're at 99 plus percent of meters that have a lead-free version, so we're getting close to having all of those replaced.
Uh basically our control is optimized corrosion control, and so we've been practicing that for a long period of time.
Next is uh lead user service lines.
So those are the service lines from the street to our meter.
So those are what the utility actually owns.
Uh we've had to do surveys, and this is required by the state.
So the first one was in 2018, and then we did a second one in 2020.
Uh, we identified about 1,578 galvanized service lines that had to be replaced.
So those are service lines that had a potential of having a couple of foot of lead connected from the main in the street to the pipe.
So sometimes uh you have very rigid connections, so you need that soft lead that you can kind of connect to the main of the street as well to that surface line.
So we developed a plan to replace those, um, the 10-year replacement plan starting in June of 2020, and we need to complete that by June of 2030.
We've also created a lookup map for customers, so if they go to our website, they can see whether or not they potentially had a lead user service line.
We anticipate completion uh for this particular project to be done by mid-2026.
So our San Francisco Water Division has done a great job.
They're gonna be four years ahead of schedule in terms of removing the lead user service line in our distribution system.
So looking at the data for the actual replacements, on this chart here, we talk about uh what was replaced and saying it was 81%.
Actually, as of June 1st, we're up to 90%, so we're making uh a lot of great progress still.
When you look at the service lines that we replaced, which is blue, roughly 20% of them actually had a lead connector.
So 80% of them didn't.
But what has to happen is we have to dig up the street to figure out what's there or not, and so since we've dug up the street, we've decided to replace that very old service line at the same time.
We've also done a lot of effort in terms of public uh outreach, and this goes back to 1980.
The first time was unified school district having some concern about lead in their fixtures.
Uh, we began uh lead test for free for customers in uh 1994.
We've offered testing to the San Francisco Department of Public Health Childhood Lead Protection or LED Prevention Program since 1996.
We've offered free less testing for uh WIC program participants uh starting in 19 uh 98, and we've continued to do so.
We also have offered uh lead-free faucets for child care centers and public schools at no cost, and we did a minor version where we charge $10 for customers, and that went on for a while.
Um, since then there's new requirements to say all faucets sold in California have to be lead-free.
So we stopped the program when all the faucets had to be lead-free.
A lot of public education, so we have our annual consumer conference report as well as bill inserts.
We also have a bunch of fact sheets on our website translated into multiple languages to try to make that information accessible.
We've also done monitoring at schools and daycares.
Uh there was a requirement from the state from 2017 to 2019 to do a lot of school testing.
Uh, so we did approximately 200 schools.
Um there's also some new requirements uh with the lead and copper rule improvements where we're gonna have to do the school monitoring all over again.
So from 2028 uh over a five-year cycle, we're gonna have to monitor all the schools.
So we're gearing up, try to get a list of all the schools and start doing that outreach.
It's interesting in that you think schools say the same, but it's amazing how schools come in and out of business.
So you have to kind of keep on top of that to figure out who's around.
Uh on the customer side, we've now looked at their service lines.
Um, so we did an initial report in October.
We found that there was no lead service lines, there was 650 feet galvanized uh requirement replacement.
So if we had a lead service line and we replaced 7,000 of them, and if there's a galvanized iron on the other side, then there's a believed risk that there could be some lead particles on that line.
So EPA set the rule-up saying that if you ever had that line, you have to replace it.
What is interesting is there's been some more research by some utilities basically saying that after 40 years, the lead that may have been on that galvanized side is gone.
So there's ongoing discussions about potentially seeing how this rule might be changed, and maybe there will be an out in terms of us not having to do this.
So we're waiting to see if there's gonna be some change in the science uh for all of that.
We uh also have 407 unknowns, and with the rule, if you have an unknown, that's treated the same as a lead service line.
So it's really, really important to get rid of all of those unknowns.
And so we found initially 407.
We're continuing the process of trying to identify what those lines are to make sure that we get that down to zero.
We think at the end of the day, we're gonna have about 700 galvanized requirement replacement lines when we've completed uh the additional excuse me survey work.
We have a lookup map for people, so if they're interested, they can take a look on a website and see whether or not they potentially have that.
Uh again, we we hope to complete the surveys uh hopefully in the end of this year.
Um, in terms of uh the public health response actions, um, we believe that what we're doing uh makes sense.
If we were to put in treatment, it'd be incredibly expensive, and we wouldn't necessarily even know if we're doing anything.
We don't have detection methods to go that low to figure out what is or isn't working.
Uh we are gonna have to look at new tier three sites as part of the lead and copper rule.
And so those are the GRR sites that we talked about.
So it could be ironic, and that these new tier three sites could have actually less copper than our historical sites, but that's the way the federal government wrote the new regulation.
So uh we'll complete that monitoring.
The general trend though is that the lead levels are going down, so it's a very good story in terms of the PUC.
The PUC has been very active in terms of replacing leader components.
Uh, basically, as the plumbing stock in homes gets replaced, you know, the lead problem should go away.
It'll take a few decades.
But at least on the utility side, we've done a very good job in terms of managing our lead issues.
Um I think that is basically uh it.
So, any questions?
Commissioners questions or comments.
Commissioner Leveroni.
Thank you very much for the report, very thorough.
Um, just more curiosity on to understand.
So, the lead that was say our responsibility or that was say in the street and coming in to our lines, uh, looks like very much um ahead of schedule and on top of that.
So then what happens is you then have once it goes into a building or into a home or into that, that's where we stop, or or does your report, was it touching on the fact that we do know what might be in homes or buildings?
I mean, we sort of know in terms of when we do monitoring, whether it be a school at the homes, we can kind of see what is or isn't going on.
And so when we do this lead and copper rule monitoring, the vast majority is non-detect.
So, as part of the rule, we have to pick the worst possible locations.
And so you're looking for places that were downstream of lead service line, uh galvanized required replacement.
The next category would be whether you had homes built around 1986 and had uh potentially lead solder, and then you have all the regular homes.
So the rule is set up to try to find out the worst possible locations, but again, we're not going through the buildings to try to look at that.
For some of the schools where you found some high lead, we've done what we call sequential sampling.
So instead of collecting a one liter sample, we've collected 21 liter samples, you know, right after each other.
And so that's an attempt to try to figure out where that lead might be coming from.
Is it coming from the fixture?
Is it coming from the pipes in the wall?
Maybe there's some lead solder there.
So we do that, but we've only done that, it's kind of big and expensive for some of the schools.
So for the average person out there, you know, if you do an initial sample, uh looking at your fixture, which is really the basic main risk for somebody at their home, um, that should probably tell you whether or not you have a lead problem.
But you could do more complicated, a lot more monitoring, it's just that that's not typically done.
And the solder then used starting to be used after 86, was it?
It was banned.
So at some point all the lead was banned.
And so you're kind of looking at all of the homes that had the construction that allowed lead solder.
You know, after that, you don't consider that to be a problem or a concern.
Okay.
And is there you mentioned also that the lead after so many years does go away or is is no longer uh, that that's our belief.
It just makes sense.
If you have an iron pipe and it's you know sat there for 40 years with water flowing because we replaced some other utilities that also replaced you know their lead service line many decades ago, there's not a risk, but EPA didn't consider that.
There were some people that commented it's like, let us do some testing to see if there really is a risk or not before we go out there and have to replace because none of the stuff is cheap.
And so having some sanity, having some data would have made more sense, but that was not the way they constructed the rule.
Okay.
Thank you very much.
Thank you.
Commissioner Jandar.
Thank you, President Stacey, and thank you for that presentation.
Um my questions are along the lines of uh Commissioner Leveroni's.
Uh, is there a list of SFUCD or other school buildings that have had high lead uh values?
Because I I heard of some last year, and uh just curious if uh the map that you uh sort of identified as that by property, or is it just by the So the map that we have is looking at the customer service lines, and so our side and their side.
On our website, uh we have data when we've done school monitoring, so it's all out there.
And so for most of the cases, there isn't really like a school that has lots of problems.
It's generally like a fixture here or there, and so in most cases, um the school could either shut off that fixture or replace it.
And so we give them the data for them to decide what they think is appropriate, but that's as far as we go in terms of here's the information, then you guys have to decide what you consider to be important or not.
Thank you.
Commissioner Thurlow.
Thank you so much for the presentation.
It was really helpful and answered a lot of the questions that I had.
One residual question that you may have covered.
Um, is how do you design the it's the 90th percentile for lead of your samples?
Is it just every fixture that you sample on the customer side?
Um, or are they specifically targeted, and you're thinking about 90% of that subsample?
So the way the rule is constructed is that we have to go out there and find those high risk sites, and so that becomes our sample pool.
Then you get all the data in and then just figure out where that 90th percentile is, and that is your regulatory compliance value.
So there's an art, you know, getting people to volunteer.
We try to stick with the same sites because we want to have like a baseline to kind of see if things were improving or not.
There's, you know, different homes that come in and out, but we try to stay with the people that we've been working with over time, but that becomes more and more of a challenge.
Okay.
So PUC selects the sample.
Uh, yes, we we do a whole bunch of solicitations, like there's broad, anybody interested, we'll put it in our consumer conference report.
Anyone interested in getting their house tested, obviously they have to fit the category.
So we get a lot of people that may apply that don't meet the criteria, but we do try to solicit and get people to participate.
Okay, that's really helpful.
I have one additional question about hexavalent chromium.
It seemed like that was more sort of universally present.
And one thing that I note in general is that it seems like the detection limit for these methods are all quite a bit above these um sort of optimal um public health levels.
Um so it's not really achievable to see us being um better than the guidance is recommended.
But for hexavalent chromium, it seems like it's distributed across more sites, and then I wondered about whether or not we've tested source water.
So we look at all of our source waters and chromium is interesting in that it's the 21st most abundant element, and it averages 100 uh parts per million.
So when you look at our groundwater and our groundwater levels, which are about 25 parts per billion, it's 4,000 times higher, you know, in the average soil.
So in San Francisco, the groundwater soil we have obviously has some chromium, and so we see it and we have to blend down.
But you look at Het Chechi, and there's none.
There's not a tech.
And so there's a range.
We're starting to see uh tweaking at the detection level, a few cases in the local watersheds, which is a little bit surprising, but again, these numbers are so low.
You know, I think our sources as surface water are great.
It's in this case the groundwater that we have to pay attention to, and that's why we have to blend it down to make sure that we meet the compliance levels.
Okay, that's super helpful.
Thank you so much.
Thank you for the presentation.
I had um a couple of clarification questions back on lead.
It from your report, there are both PUC assets that may contain lead.
It looked like maybe there were 8,000 unknowns that you are still investigating.
Is that right?
No, we've we completed the investigation for that, yes.
Okay.
And then there's also the potential for lead that are not PUC assets, what we've been talking about.
So you've been doing a lot of customer outreach testing and working with homeowners, schools, various um institutions to make to help them sort of get on top of either replacing or looking for improvement in the lead content of their water, correct.
Okay.
And then on the bromate at um Harry Tracy, you mentioned with hexavalent chromium that there was some dilution through blending, but you didn't you the report doesn't mention that for bromate.
So does that mean that there may be no dilution?
Um, there is dilution.
Um what happens is that we have to use the compliance data, which is the point of entry.
So basically you're taking the water coming out of that particular treatment plan.
So if we got to pick some place in San Francisco, you'd be blending with Het Chechi and be lower, but by the way the rules are set up, we have to report it that way.
Okay, thank you.
We also um received uh an email from Mission Creek with some comments uh about the west side of the city that there were um some sewer overflows um on the west side that may implicate um the west side aquifer, groundwater on the west side, and maybe the lobos creek water that goes to the presidio.
Could you comment on those concerns that the mission creek raised with the commission?
Sure.
Um obviously we believe in source water protection, we don't want any of these incidents to occur, but you know, stuff does happen.
When we look at this, first of all, uh groundwater was less than 0.1% of San Francisco supply in San Francisco.
So it's a very small overall supply.
But if there's some sort of discharge events, first of all, it has to get in some place either water body or ground, right?
If it lands in the street and it flows back into the sewer, you know, it's not going to cause a problem.
Then if it gets in for the sake of argument, a water body, you've got a huge amount of dilution just in that water body.
And so that's one factor.
Then it goes through the groundwater basin, you know, thousands of feet, if not miles, and there's natural filtration.
So that's one of the things about groundwater is that if you're concerned about microbes, it's all going to be filtered out as it goes through the groundwater.
There's also then dilution just because you have native groundwater that's already there.
When it comes out, we treat it.
So there's also disinfection in terms of a strength air and groundwater.
Then on top of that, we blend it with our high-quality surface waters.
So we don't want to see this happen, but if I look at all the water quality issues that we're facing and the new ones like microplastics and PFOS and whatnot, you know, this just honestly doesn't rise to a high level of concern given how much is produced and like said natural barriers and treatment barriers that we have.
Thank you for that explanation.
I also really appreciated um the inclusion in our packet this week of the um the report on the contaminants of emerging concerns.
I think it's a it's a really um good combination at looking at what what we might not know about yet, but we may have concerns about future concerns potentially, yes.
And another piece of correspondence, maybe more than one, um, that the commission had this week were concerns about artificial turf and the tire rubber that's um often used as part of that artificial turf.
I I I wonder if you are looking at that, because as water again, you know, maybe it's the same comment on the sewer system overflows that as water flows through that those tire, those artificial turf, the t the crumbled tire rubber.
Are you are you looking at or is this um something that is of concern in the future?
It is not bubbled up to the top.
Um, you know, we look at the stuff, we bring in the health department, we bring in some outside consultants just so that we have some um broader eyes on the stuff.
But this is the importance of having these types of meetings just to get these issues put in front of us.
You know, I'll definitely put a note down.
These are living documents, these plans, you know, we update them every three to six years, and so sometimes issues bubble up, sometimes it bubble down.
Um if it's a concern, it's important, right?
Whether it's a real water quality issue or not, if there is a public concern about that, we need to address it.
So that is something that I'll make sure that you know we put it down.
Thank you.
Uh Mr.
Richie, you had something to add.
Uh yeah.
So you would chief assistant general manager for water.
Uh actually uh relative to artificial turf.
Uh we do have uh best practices we use over the West Side Groundwater Basin.
That is the one groundwater basin we do utilize in San Francisco.
Uh so if you recall, there was uh a lot of concern about the uh soccer fields uh at uh uh at BCLA.
Uh and so we worked with Reckon Park uh on having uh a protocol in place to actually capture the drainage water from there uh and test it uh and and treat it uh to the extent it needs to be.
But that's for the groundwater basin where there actually is you know uh utilization of the groundwater basin.
So when you look at other parts of the city, we we don't have a particular concern about those because those are not used for drinking water uh in the little pockets that do have groundwater.
So there's not as direct a connection between the use of the turf and the drinking water.
Yeah, but definitely on the west side we are concerned about it.
Well that's really great to know.
Thank you.
I suppose the um artificial turf could also be a concern for our wastewater system and what we emit, but I know that's not before us today, but it is um it seems like something to pay attention to as well.
One other um issue that uh at least was implicit implicit in the mission creek comments was a concern that there wasn't much notice about this report.
And it was it was in our packets, the commission's packets for the June 24th hearing, um, because I remember reading it this summer.
I wonder if um there was public notice given of the report at that time or if there's a way to provide in the future some earlier public notice when that draft is published so that um interested groups and individuals have more access to that information.
So what we've historically done is that we've given you the report in Gina, we've purposely have delayed it uh to September just to allow you and others to have time to look at that.
But what we can do, because we've held back publishing the final report.
So if you go to our website, you see the 2022.
So we kind of go through this hearing before we publish it.
But what we can do moving forward, if you would like, is that we could publish this at the same time we said it to you, we could put it on our website.
So if that would make sense, then that would just make it a little bit more accessible.
That would be great.
So you would publish it as a draft rather than a final, and that way people would have access to it who might be interested in reviewing it.
Yeah, we'll we'll just put it out there.
I mean, honestly, there's never been any real changes to the stuff because it's more of a factual here's your data, here's the PhDs, and so there's not anything potentially really controversial just because it's looking at your data and saying how you compare it to a standard.
So what we submit to you, we've never changed it.
We could if you decide that there's some problem with it in the future, but this is our tenth version, so there hasn't been any changes.
But we will put it out there as soon as we send it to you.
We'll put on our website so that three years from now people have an opportunity, they will be able to look at it, and they can come here.
So it just makes it a little bit more accessible.
Yeah.
Thank you.
It seemed like the concerns were not with the science of the PUC, but rather what we might be missing or what other issues might exist out there.
Yeah, yeah.
No, uh it's good to share all the information, allow you know all of our stakeholders to see what it is and give them opportunity to digest it and comment on it.
Yeah, I think that's important.
And as you mentioned earlier, that it might also cause the PUC to focus on an issue that in a way that we might not have done so.
Yeah, and it again CECs is a process.
Um we share it with our citizens advisory committee.
We talk to them, but again, the more stakeholders reach the better our we are.
Great.
Thank you so much.
Really important report.
Uh commissioners.
Any further questions or comments?
Uh let's take public comment.
Remote callers.
Please raise your hand if you wish to provide comment on item number seven.
Are there any members of the public present who wish to comment on this item?
Is Francisco da Costa here?
No.
Moderator, seeing none.
Are there any members with their hand raised?
Ms.
Lanier, there's one caller that wish to be recognized.
Thank you.
Excuse me, I meant to ask you this at the beginning of public comment.
I'd like to provide three minutes for um individuals to comment if that's okay with the commission.
Thanks.
Please continue.
Call it out of unit your line.
You have three minutes.
Thank you.
Uh Commissioners, we have friends of Mission Creek concerned about the PUC's insistence on ignoring obvious public health concerns.
Dilution is not the solution to pollution of our drinking waters.
But not addressing the concerns about sewage contamination, not only of our waters and our home, but also of the watershed of the Western Aquiber, where we get our blended water.
PC is risking not only its own compliance with the Safe Drinking Water Act, but also California's enforcement agencies.
In 2019, EPA administrator Andrew Wheeler, in a letter to Governor Gavin Newsom, pointed out the problems California was having in meeting its duties to adequately enforce the federal safe drinking water act.
San Francisco is very prominent and powerful legislative, as well as San Franciscans in executive offices have been mostly immune to attempts to address it blatantly ignoring federal law.
California regulators allow San Francisco to ignore state and federal law.
It is now putting the state regulatory agencies at increased risk of losing the state's authority to enforce the state drinking water act as well as the Clean Water Act.
Please refrain from accepting this report today.
Ask the staff to address all known risks for placing San Francisco's permits at risk as well as the state regulatory authority.
Thank you.
Thank you, Colleen, for your comments.
There are no more callers that wish to be recognized.
Thank you.
Did I hear there's one more caller?
Oh, no more callers.
Okay.
Thank you.
Uh Commissioners.
Um.
Could I have a motion and a second to approve item seven?
Motion to approve item seven.
Second.
Thank you.
President Stacey.
Aye.
Vice President Arcee absent.
Commissioner Jamdar.
Hi.
Commissioner Leverone.
Aye.
Commissioner Thurlow.
Aye.
The item passes.
Item eight.
Thank you very much for the report and all the information.
Item eight.
Approve the draft San Francisco Public Utilities Commission Cross Connection Control Plan and Program Manual, which documents SFPUC compliance with the California State Water Resources Control Board Cross Connection Control Policy Handbook, Standards and Principles for California's Public Water Systems.
Good afternoon, Commissioners.
Andrew Grosso, Water Quality Division Director.
I'm here to talk about our cross-connecontrol program.
Slides, please.
So we're going to cover what is a cross-connection.
I'm sure that is not something that everybody's familiar with.
Talk about our historical program, new regulations, the plan that's in front of you right now, and the schedule to move forward with that.
So a cross connection is an interconnection between a potable water supply and a known potable source via any actual potential connection or structural arrangement to meet a public water system, any source or distribution system containing a liquid gas or other substances not from an approved water supply.
So the approved water supply is our system.
So everything up to the meter is approved.
When it goes to the other side of the meter, it's not approved.
So you don't want any of the water going back, particularly because we don't control that system, but there's also potentially other hazards in that water besides just being water in their system.
So this is a diagram that kind of looks at a building.
And typically in the building, uh the two most common areas of risk are the HPA system, sort of at the top of the roof and the boilers at the bottom.
They will put biosized corrosion chemicals and other stuff inside that water supply.
So you obviously don't want that to come back into the building, let alone back into our distributed system.
There's other hazards depending if you have laboratories or sewage or whatnot.
So there's a lot of different potential hazards in a building.
So there's two ways the water, then if you have the hazard gets picked in the system.
So this picture here shows a back siphonage.
So if there is some sort of uh hydrant use, it gets run over, the fire department's out there, there's big main break, you could have back siphonage so it can basically suck the water in.
You can also have big buildings where they actually have to pump the water up.
So if you think of Salesforce, there's multiple pumping stations in that building to pump it to higher, higher levels.
So if all of a sudden those valves were to not work, you could have all that water at high pressure come back into our distribution system.
So we have devices to make sure that doesn't occur.
These devices are backflow professional assemblies, and you typically have them at the base of buildings.
So you probably walk by a whole bunch of them, never paid attention.
If you see some, you know, plumbing, some pipes come out of the ground, there's a cage around it, that's a backflow prevention device.
The keys that allows water only go in one direction into the building, it doesn't allow the water to come back into the distribution system.
So our program was established in 1984 by the Board of Supervisors.
There is the Health Safety Code Article 12A.
We're basically required to make sure that we have the appropriate backflow devices out there, that all of these devices, which is now 35,000 plus, are tested every year.
We've been growing those devices over the past few decades at 6% a year.
So it's just continual growth in backflow uh devices.
We also respond to all two plus alarm fires.
In San Francisco, we have a non-potable fire and a potable firing.
So sometimes it's a big fire, you have all kinds of hoses in the street if there's a potential having those two things.
The non-potables at higher pressure, so we're required to go out there with inspector just to make sure that uh it's not uh connected in properly.
Uh, we also, with consumer complaints, go out there so if somebody complains, try to figure out what is going on.
Um, and so in case there's something going on, our customer with a complaint could be the indication that there's an issue.
We've not found any, but we get about 500 complaints a year that we respond to.
So, in terms of the new regulations, the state water board came up with this cross-connection uh policy handbook that was effective in July 1st, 2027.
It basically replaced regulations that were started in 1987.
Uh the policy handput is required.
We have to basically say how we have a plan to comply with all the components, as well as have an outreach.
Um, so a lot of new regulations we have how outreach requirements, so whether it's the Lenin Copper rule or the cross-connection policy handbook.
So there's a lot of stuff now that are embedded in regulations in terms of making sure that we make our customers aware of some of the issues that are out there.
Um there are gonna be several new requirements that are gonna be challenging for us to meet.
The first one is a hazard assessment.
Uh, we have 182,000 services in San Francisco.
Our program where we talk about those 35,000 devices are 18,000 services, so 10% of the system.
So we're gonna go from 10% of high risk to all of them.
So that's gonna be very complex in terms of just getting hold of people, getting information.
So that's gonna be a definite challenge.
We also have to have improved fire services, and I apologize, just gone through the slides.
Uh, hazard assessment.
Um, basically, we have to tell them how frequently we're gonna do this or what time frame.
Uh we've had initial discussions, and they've agreed that we can do this over a 25-year period.
So uh a lot of stuff over 25 years.
Um we also uh need to excuse me, um, make sure that in some cases customers will have to install new devices.
So when we go out there and do a hazard assessment, there may be some problem that we found out that we were not aware of.
And so then that customer is going to have to be able to put in a new device.
So we're hoping that's going to be minimal, but with 182,000 services, we expect there's going to be a few, hopefully, not too many, but there will be some.
So what we typically have right now for fire services is a single swing check.
And so that doesn't meet the current requirement.
The current requirement says that you have to have bigger backflow device and RP.
So we're going to have to work with customers, and there's over 4,000 services for them to upgrade those services.
Some of these devices, the swing checks have been in the ground for a long very long period of time.
You can see kind of that big spike over to the right, that's around the 1906 earthquake period of time.
The more recent stuff is to the left.
Each one of those little bars represents 20 years, and so for the average swing check, their life is 15 to 20 years.
So each one of those kind of lines that go vertically is kind of a lifetime.
So you can see we have some fairly old devices out there.
Some of the other issues concerned about them is that some of them have big lead weights in them.
So that's what keeps them closed.
And so when the water is flowing, it pushes it up, but when it's not, that lead weight pushes back down.
So there's another reason why getting rid of these things would be good for us.
So in terms of upgrading them, again, the existing swing checks are our asset.
That's what we put on the ground, and we're going to need to remove those.
There's gonna have to be installation of a backflow assembly on the customer side.
That's not gonna be cheap.
You know, we're estimating the range of 10,000 to 100,000 depending on how big, how complex uh the installation is gonna be.
We have to work with the fire department and DBI to get the permitting process, so we're gonna have to create a process.
Try to stream like and make it as simple as possible.
We know anytime you deal with permits, it's not a fun issue.
So we're gonna try to work with the uh fire department and DBI.
We have long-term good relationships with both of them.
We actually have monthly cross-connection meetings with them going back for many years.
So they're aware of this.
But again, the devil's in the details.
Um, outreach is also gonna be critically important.
All those customers out there, uh, so we've discarded discussions with our communications, we've had discussion with external affairs.
We need to let the elected other officials know that this is out there, and obviously it could be a concern to uh our customers.
Um swing check removals need to be timed such that uh when we replace it, they're also replacing at the same time because you want to maintain that fire protection.
So there's that timing aspect which uh makes this a little bit more complicated.
So there's a lot of things we have to go on.
We're talking about a 20-year replacement cycle.
So one of the things I'll note is that in the report we talked about 15 years, but since we produced this, we've had ongoing discussions with the state, and so they've allowed us another five years to make this a 20-year program.
Um, we've told them that it's a major startup cost, you know, creating all these programs, getting them running.
You know, once we get them running, let our lead user service line, we can be pretty good, but that whole startup uh takes a bit of effort to try to figure out uh what's going on.
So we plan to do a pilot program.
Um, a lot of the stuff is new, we don't have cost estimates, we don't have time estimates, so doing a pilot program will give us some better information uh to estimate the resource needs.
Uh the next area is hydrant connections.
Um, so right now we have hydrants that are used for temporary services, construction, street fairs, and whatnot.
So that is regularly used in the city.
We've used the swing checks as our base, we're gonna have to put in the RP devices, and so there's about 300 of them.
Uh, there's gonna need to be some time to procure all those devices.
Our water uh division, you know, has a meter shop, they'll be able to handle all this stuff, do all of the testing, but it'll take us a while to actually purchase all these things and get them deployed in the field.
So, in summary, um, in terms of the hazard assessments, that's something that we're gonna have to do for all the services, and that's gonna take 25 years.
Uh, the fire services is about 4200.
Um, we've got 20 years to do all that stuff.
Uh we need to take care of the swing check on our side, and the customers will need to do the new device on their side, and then in terms of hydro connections, we'll obviously uh purchase those devices and issue those when we issue meters for temporary connections.
Uh, this doesn't come without a cost.
Um, we're gonna need some new staffing.
Uh, we're gonna have our other bureaus within the PC that are gonna need it to provide support.
We talked about the fire department, DBI.
Uh, we're gonna need contractual professional services, uh purchasing hydrogen assembly, and then unfortunately, uh the end of the day enforcement is our issue, and so we're gonna have to kind of formally develop an enforcement program for the people that um decide not to cooperate.
So that's our last option.
We want to do that, but we're gonna have to build that program just to make sure that there's a process.
If there's a problem that we have a way to deal with all of that on the capital side, we'll need money to remove all of the single checks, and then the customers obviously are gonna have to spend some money to install devices on their side.
Again, we talked about the pilot.
We're looking at maybe a hundred of the fire service replacements and doing about a thousand of the hazard assessments to hopefully give us a rough idea of what this will cost us.
So the schedule for the past six months, we've worked on this draft plan and manual.
Um, it's been a bit of a challenge just because there is no guidance, there's no standard out there.
Uh the state board has uh worked with us, at least the local staff, and they agreed to the schedule and the high-level concepts.
Um, what will happen is that this will go to the Sacramento Office of the State Board, and they'll do the final review and all the stuff.
And so, what we mentioned in the resolution is to give the general manager authority if we get some minor feedback from the state to be able to you know tweak this to make sure it's in alignment with whatever the final agreements are.
Uh if you approve this, uh we will submit this to the state formally uh by the end of this week, and then uh we'll wait for them to get the final comments and then finalize this plan.
So thank you very much for your attention.
Thank you.
Commissioners, comments or questions?
Commissioner Leverone.
For your report.
Um on the uh swing checks, um, is there a correlation with the lead swing checks to our previous report?
With the uh with your testing and saying there's might be lead in this, no, there isn't anything.
I mean, we've done some monitoring of the distribution system, like the pipes, you don't see anything.
So if these devices are working, and then there should really be no water flowing anyway.
If anything, maybe there's a water flowing in that direction towards a building because somehow they're testing sprinklers or something like that.
But no, there's no definitive monitoring results downstream of any of these devices to see if there's any lead or not coming back into our system.
Is there an um in looking at the replacement, especially when it's with the sprinkler system in a building?
Is there an average time frame that that would be able to be serviced and changed?
And if it's more than, you know, a certain amount of time with would we then provide a fire uh check for that building during the time that the sprinkler system is down?
Um yeah, that's gonna be part of the more detailed discussion with the fire department because they don't like that.
And so they want fire watches, which means you know, I don't know if they'll charge you, have a truck out there maybe for big buildings, but other than that, they have a program to train people, and somebody's gonna have to be watching you know the building if they don't have that fire service in operation.
So that's gonna be a very important detail for us to work out with them.
And if if um when the change out does come from the PUC side, is it gonna be cost-effective and more appropriate also to handle it on the building side, the building owner or the property owner side at this to try to coordinate that?
So that that's clearly one of the very important details.
And so one of our discussions is um if the PC is gonna be a replacement for our side, we're talking about hiring an outside contractor because our San Francisco water division, there's all kinds of emergence other stuff like that.
So we need to be lined up, ready to go for those customers.
If they're saying we're ready to go next Tuesday and we agree we can't say sorry on Tuesday, we can't show up because he had a big main break or something like that.
So we're looking at that.
There's also discussions about whether the contractor hired by the customer could potentially do some of the stuff.
So you saw a picture where that device is there.
So maybe we create the program where their contractors are placeable or replaces it or removes it, and we pay them some money for whatever that work is.
So these are all the details that have to be worked out in the program just to make sure that we have something that works and makes sense.
No, it's very rare.
So that's the big change in this regulation.
Before we were focused on the big buildings with the big risks, now they've thrown all the residential stuff in there.
And so that to me is going to be the test of this regulation.
If we start seeing a whole bunch of residential people having to put backflow devices, then there's something wrong with this regulation, as far as I'm concerned, given our our past history.
So we're hoping that's going to be a very small number.
But you know, we're dealing with a regulatory agency, it's a new rule.
So hopefully that's going to be a minimum level that we go there once and the level of effort to do hazard assessments, you know, first time as well as the future is not going to be a major production.
Could you imagine us trying to contact all these customers?
You know, none of us wants to get, you know, we're here from the government utility, we need a bunch of information.
So we're gonna try to figure out a way to minimize this as much as possible.
That is our goal to make it as accessible as possible.
But this is a brand new program, and I'm sure we're gonna learn along the way, and we'll probably have to make a little corrections here and there because you know something didn't work as well as we hoped it would.
Thank you very much.
Uh Commissioner Thurlow.
Um my questions are kind of a follow-on to Commissioner LeBroni's.
Um, one thing that I'm wondering about is to what extent do we have the ability to measure whether or not backflow issues are a problem in residential um homes?
And how will we know, you know, like what is the problem that we're fixing and have we been able to measure it to date?
And then secondarily, what is the experience going to be like for these 180,000 residential service units?
Is it does it involve a home inspection?
Is it just at the meter?
Um, how do we think about what that will be like?
Um we're gonna try to minimize it, and if we see the rich up in the sunset, we're everything looks cookie-cutter, uh, unless we see something that looks funny, and so that's a question about what do we do?
Do we have some sort of satellite view?
And if we see funny tanks on tops of buildings, we say, uh oh, there's maybe an issue with those.
But we're hoping that as much as possible, if we can cookie cut or say, look, this is our experience, these are all similar homes.
There's nothing exciting that we see from the outside or from the roof or in the backyard, um, that we don't think there needs to be anything detailed.
Part of the pilot we may issue like a survey and set it out to customers, just see what their response rate is.
You know, so if we get some data from them, that would be great.
And if that knocks out 10%, that would be wonderful.
So part of this is the communications and the outreach.
You know, we've seen sometimes you have to take multiple times reaching out, we'll probably put stuff on our consumer confidence report, other things.
So we're gonna try to bring that up as much as possible.
But again, this is gonna be the art, right?
It's not a science, and it's gonna be things that we learn along the way to try to figure out what's going on.
In terms of your first part of the question, there are backflow events.
Um they do happen.
Before we had AMI, uh, you wouldn't know, right?
Because you'd read the meter once or twice, you know, once a month, once every two months, and you just see there's always some water use.
We have AMI now, but there's noise in that AMI data, and we can't ping it all the time because if you ping it all the time, we want it every minute, we wear out the batteries.
So the technology is not there right now for us to see what's going on, at least you know, small little problems.
We're working with our customer service bureau, and so if they see a service that has like a big negative read over an extended period of time, okay, we see a what we call a reverse flow situation, and we send people out there.
And we're resolving a couple right now in the city.
So it does occur.
Um, does it occur often?
No, and do I think it's gonna occur residential?
Unlikely, because there's not situations where they got pump or high rise or whatnot that's gonna create that particular problem.
But we've seen it in the city, we've seen internal cross-connection issues, um, particularly like with HVAC, where somebody within a building has a hose that's connected to that somehow get next to the water supply, and we get a complaint and we respond.
So it's infrequent, it does occur, and really, from my perspective, how far this moves from where we are right now into residential is gonna be kind of the test in terms of is this a reasonable or not change in the regulations, and then just a quick follow-up.
Are there other jurisdictions that have these types of requirements that we can learn from, or is this really really the frontier?
This is the California special, and because there is no guidance and no history, all the utilities are doing their own thing.
We've talked to our peers that are out there and gotten some information.
So for example, like the 25 years, is because we heard from utilities that had 20 years and 30 years.
So we said, okay, great, let's just put us in the middle, not too much, not too little.
So where we've gotten some information, we've tried to, like I said, post us out there.
We're, I think, somewhat unique in that we have the dual fighter firing distribution.
Um we may be somewhat unique in that we've got those 4,000 plus fire services, so it's kind of an old urban area.
And so I think that LA may be parts of sacrament.
We may have some peers like that.
There's other utilities that have a lot of wells within the system.
So they've got that other potential uh cross connection issue, and so they have devices on those.
So we will have commonality with I think some of the big systems.
One of our other concerns is that you'll see a lot of like suburban areas that they have plenty of space between the street and their property to put on a backflow device, right?
It's just, you know, part of the landscaping issue.
In San Francisco, we have a lot of the properties that built out, you know, right to the sidewalk.
And so these are real issues that we're gonna have to be working with to try to figure out what we can do.
Um, so I wish there was um some past history and standard, but there's not.
And like I said, we will learn and have to make corrections along the way.
Uh Commissioner John Dyer.
Thank you.
I'm just curious.
Uh so this does include even single family residential homes.
The hazard assessments, yeah, we're gonna have to do for all of them.
Wow, that's impressive.
So is there a cost associated on the customer side for going through this kind of uh, well, certainly through the rates, right?
I mean, all the work that we do, uh, they're gonna have to pay for.
Um certainly if they have to put on a backflow device, then there's a very big clear cost associated with that particular customer.
So again, you know, we're hoping for little as possible.
The other thing is that if this doesn't make sense, you know, you know, we have to maybe push back to the state and just saying, is this reasonable?
What is the cost benefit of all the stuff, you know?
Uh it's something that they didn't do with the regulation.
This was a policy handbook.
It didn't go through the formal regulatory process where you generally look at the cost-benefit implementation issues.
So they deal with this and then say come up with a plan, and then people start looking in details, like, oh no, what about this?
What about that?
Here's a real world situation, and this was not fact into that thought process.
So, from my perspective, it's not the way we should be developing regulations, but you know, the legislator passes a bill, these are the rules, and then we deal with the best way we possibly can.
But again, that's one of our options to talk to the utilities, see what it looks like for them.
This becomes a big problem, you know, maybe we have to figure out some ways to push back.
Okay.
Commissioner Leveroni.
Just a follow-up on the communication, which you know you're gonna, I'm sure spend a lot of time in coming out.
But there seems when we start to talk about water and water issues, no matter what level, there is pushback a lot from people like feeling you know, you're coming in and testing my water, looking at the water, and and be somewhat reticent of that, not maybe from a safety but from a cost situation.
That you know, if you find something, it's gonna come back at me.
Is that not that I need an answer, but I I would think that that's gonna be part of the process of the communication.
Uh you know, it's a real issue.
You know, if it's just providing information, that's you know, not something people want to do or they're busy, they have their lives.
Uh that's one thing.
But if it's, you know, we're from the utility of the government, and by the way, you may have to spend a lot of money, um, you know, you're not gonna be necessarily welcome to to come or they may not want to participate.
So again, it's just something we're gonna have to learn.
Uh I think, as we go through the process.
And you know, our goal is clearly to minimize the impact, particularly the unnecessary impact to our customers.
Um, this is gonna be an expensive program, um, and like I said, not fun, and we know that there are people who are not gonna be happy with us coming in there, and it's sort of you know, again, life in the big city.
It's what we expect, and we'll try to do our best.
Good communication, outreach, you know, trying to talk to people.
We have discussions about maybe we go to BOMA, some other groups and give presentations and say this is going on.
We're gonna want to work with them, it costs money, and so if we can provide some float and schedules, we're gonna try to provide float and schedules for people.
We understand that people have real economic issues, so we're not saying do it tomorrow.
And so when we run into customers with issues like that, we're gonna try to be as responsive as we reasonably can be and work with them.
If I may add, and I think a s if a sense of the costs that could be incurred would be good to have in your outreach.
Uh yeah, so hopefully, as we do the pilot of the next couple of years, we'll have better cost estimates.
You know, right now the cost we talk about is like more of order of magnitude, you know, uh it kind of gives us a rough idea, but until we actually develop the program and all the rules and how we deal with the fire department and DBI and all the rest of that, where they have to do fire watch or whatnot.
Uh there's gonna be a lot of different wrinkles in terms of what it's gonna cost and what needs to be done.
So uh we'll be learning a lot over the next uh several years.
So I um think all of my questions were answered.
It's unfortunate that the state water board did not work with utilities um up front to really think through some of these very detailed practicalities.
I they they work with trade groups, but they worked with trade groups in terms of just the idea.
So I I can't say they didn't have outreach, but when you do regulations to the level that you should, you look at the cost-benefit, you talk about implementation, all these issues that we're identifying right now.
Right.
That there's no setback, you're building right on top, people have to put stuff in basements, you know, what does that mean and whatnot?
That's the shame in all the stuff.
You know, that should have been done as a normal regulatory process.
And I think utilities are gonna comment more and more about you know, not allowing policy handbooks, not lying emergency regulations, because that's been the trend lately, and I think you end up with bad regulations and you don't have the true cost benefit.
And I believe every regulation should have a cost benefit.
You should believe that you're getting more benefits for the cost, otherwise we shouldn't be making that investment.
Well, and I think in the manual itself, what's before us today, your approach makes a lot of sense.
Um the way that you've set up the priorities for the hazardous assessments, seems um very rational.
I appreciate that.
I think uh it's hard not to think about the potential costs, both for the PUC and for the individual um property owners, especially if there are costs for homeowners.
Yes, and of no daunting, you know, we've put residential people at the very end of this assessment.
Right.
And because we think it's also the lowest risk.
Right.
And so there'll be a delay before you know we're talking to people and whether it's a potential for you know a typical single family home or whatnot, to consider you know, worry about this issue.
So, again, hopefully we'll do a good job and show there's no risk or minimize the risk and we won't have a bunch of people that uh have to deal with that at their the residence.
Yeah.
Thank you.
Commissioner Leveroni.
Yes, but uh um currently, uh, you know, just driving around the city seeing all the remodeling that's going on in the different things and residential side.
Um, is there something now that is out, say with knowledge of the say the plumbers or the plumbers union that that would suggest that we're doing this major remodel to your home.
This might be something that we should look at right now to um change uh as opposed to waiting a couple of years.
Yeah, that's part of the discussion I've had with staff in terms of we want to take advantage of any property that has major remodeling because if you've got a contract and you're spending millions of millions of dollars, you've already got your your plumbing contractor there, much easier just to do it at the same time.
So this again is part of the outreach.
You know, we meet again with the fire department and DBI every month, have discussions with them.
Um maybe there's more communication outreach material that we developed and try to put some places.
Uh but you know, it's a small world, the plumbing community.
Um, you know, our inspectors are part of 38, you know, they all know each other, they all uh talk, and so I think some of that is getting out there in terms of you know, there's a potential change in terms of what is going on.
Um so I think that's good, but it doesn't mean that we can't do more and try to get that information out there.
So again, if we could take advantage of someone doing a major remodel and they need to do something in terms of upgrading their devices, they do it at the same time versus us coming back.
And that's part of the reason why part of this we didn't maybe mention is that when we go and look at a fire service, we're also gonna look at the domestic service for those buildings.
Because we don't want to come back and say here you have to spend say $50,000 in your fire service, and two years later, oh, time for you to do the domestic service hazard.
Here's another $50,000 thing.
So uh I hate to say we want to give them all the bad news at once versus just kind of come back and then you can say when are these people going to leave me alone type of thing?
So these are the little details that we're trying to work out.
Bad news doesn't get better with time.
No, and twice as less welcome than one time.
Uh thank you very much for the report.
If no further questions or comments, let's take public comment.
Remote college, please raise your hand if you wish to provide comment on item eight.
Are there any members of the public present who wish to comment on this item?
Seeing none, moderator, are there any college who have their hand raised?
Ms.
Linier, there are no callers that wish to be recognized.
Thank you.
Thank you.
Uh Commissioners, could I have a motion and a second to approve item eight?
Motion to approve.
Seconded.
Thank you.
President Stacy?
Aye.
Vice President Arcee absent.
Commissioner Jamdar.
Aye.
Commissioner Leveroni.
Aye.
Commissioner Thurlow?
Aye.
Item eight passes.
Item nine.
Public hearing to consider and possible action to adopt.
Amended Section G, cross connection control of the San Francisco Public Utilities Commission's rules and regulations governing water service to customers.
So it's my last time, I promise.
So basically, we're trying to uh tweak Section G, which is our rules and regulations to implement the cross connection control program.
Um I think they're relatively minor, um, some simple things in terms of how long we keep records.
Uh just reminded that we want licensed plumbers involved.
That's always been a citizen policy we did include it in there.
So uh hopefully minor uh changes and here to answer any questions you may have.
Thank you.
It's very self-explanatory.
You've had a busy time.
Uh commissioners, any comments or questions?
No.
Seeing none, let's take public comment.
Remote college, please raise your hand if you wish to provide comment on item nine.
Are there any members of the public present who wish to comment on this item?
Seeing none, moderator, are there any college who have their hand raised?
Lanyard, there are no callers in the queue.
Thank you.
Commissioners, could I have a motion and a second to approve item nine?
Motion to approve.
Seconded.
Thanks.
President Stacy.
Aye.
Vice President RC is absent.
Commissioner Jamdar.
Aye.
Commissioner Leveroni.
Aye.
Commissioner Thurlow.
Aye.
Item 10 passes.
Thank you.
Item nine.
I apologize.
Item 10.
Approve amendment number two.
It's a contract numbers, PRO.0188 A through D for as needed specialized and technical services water enterprise with Kennedy Jenks Consultants Incorporated and Applied Technology and Science Joint Venture, ACOM Technical Services Incorporated, and Water Resources Engineering Incorporated joint venture.
Woodard and Curran Incorporated and SRT Consultants Joint Venture and Brown and Caldwell and Lotus Joint Venture.
Good afternoon again, Commissioners.
Uh Steve Ritchie, Assistant General Manager for Water.
These are a set of professional services contracts that we use for basically specialized work related to the operations and management of the water enterprise.
This is the second amendment.
The first amendment was uh to insert some terms from reimbursable costs that were originally left out of the contracts.
But what we're doing today is increasing the each contract amount from five million dollars to $7.5 million per contract.
This means a total increase from $20 million to $30 million, but there's no change in duration.
Basically, we have used these for a lot of significant work that we've done on the regulatory front, uh in planning for our capital improvement programs, our asset management program, uh, and other activities.
Excuse me, uh, as of uh August 27th, we had actually expended through these contracts or actually the amount encumbered, I should say, it's not totally expended yet.
Uh it's been about 16.2 million dollars.
Uh so we're already, you know, well on our way to expending the 20 million dollars uh that's in the uh currently authorized amount.
So this would uh expand that a bit more uh to carry on for another couple of years uh within the contract.
These were being used at a higher rate than we originally planned, uh, but there are good reasons for all of the work that we've been doing under these contracts, and so I recommend uh your approval of the amendments to the contracts.
Thank you.
Commissioners' comments or questions.
No, no, Commissioner Leverone, no.
All right, thanks for the report.
Um let's take public comment.
Remote college, please raise your hand if you wish to provide comment on item number 10.
Are there any members of the public present who wish to comment on this item?
Seeing none, moderator, are there any calls who have their hand raised?
Mr.
There are no callers that wish to be recognized.
Thank you.
Commissioners, could I have a motion and a second to approve item 10?
Motion to approve item 10.
Second.
President Stacy.
Aye.
Vice President Arceus is absent.
Commissioner Jamdar.
Aye.
Commissioner Leveroni.
Aye.
Commissioner Thurlow.
Aye.
Item 10 passes.
Item 11.
The published version of item 11 contained the contractor's name listed once when it should have been listed twice.
Item 11 is accept work performed by precision engineering incorporated under contract number WW-736, Cash Joe and Mission District's sewer improvements.
Approved modification number three, final and authorized final payment to the contractor.
Good afternoon, Commissioners.
Mary Tinkin, project manager with the infrastructure division.
I am here today to ask you to accept the work performed by precision engineering, authorize the modification, and go ahead and approve payment.
And the reason why this is for structural rehabilitation of sewers and the mission district along with the Castro District.
The reason why I'm here today before you rather than on the consent calendar is because the modification is to change the duration of the contract from 425 days to 712 days.
There are two reasons for that change.
One was the addition of approximately 1,400 linear feet of brick sewer to the contract.
And then the other change, another 187 days resulted from just the slow work to complete the punch list item items which required CCTV throughout our brick sewers.
So there was like punch list work, getting the CCTV to meet the requirements of the wastewater enterprise, not with so lengthy or a lengthy process.
And so I ask your authorization to close out the contract.
Thank you.
Commissioner Levroni.
This is just a length of time, not a change in the contract dollar amount.
So back in May of 2024, the commission authorized the scope change that added 1,400 linear feet of additional sewer rehabilitation along with 22.5 million dollars and 100 additional contract days.
At this point, we're reducing the contract value and adding contract duration.
Thank you.
Seeing no further questions, let's take public comment.
Remote callers, please raise your hand if you wish to provide comment on this item.
There are any members of the public present who wish to comment on item 11.
Seeing none, moderator, are there any callers who have their hand raised?
There are no callers in the queue.
Thank you.
Commissioners, could I have a motion and a second to approve item 11?
Motion to approve.
Seconded.
Thank you.
President Stacey?
Aye.
Vice President Arceus Abson.
Commissioner Janjar.
Aye.
Commissioner Leveroni.
Aye.
Commissioner Thurlow.
Aye.
Item 11 passes.
Item 12.
Approve an increase of $5 million to the cost contingency for contract number WD-2776, San Francisco West Side Recycled Water Treatment Facility at Oceanside Plant with SJ Amoroso Construction Company Incorporated.
Good afternoon, Commissioners.
Barbara Palacios, Project Manager for the Westside Enhanced Water Recycling Project.
The agenda item before you today is requesting your approval to increase the cost contingency on Contract WD 2776, West Side Recycled Water Treatment Facility at Oceanside Plant.
I have a brief presentation to provide an overview of the project as a whole, some key challenges encountered, and the request in front of you today.
May I please have the slides.
The Westside Enhanced Water Recycling Project has the objective of producing and delivering an annual average of two million gallons per day of highly treated recycled water for non-drinking uses such as irrigation.
Recycled water is highly treated wastewater that has undergone multiple levels of treatment.
This project is part of the SFP's SFPUC's commitment to diversify its water supply portfolio by developing alternative water supplies.
The project includes the construction of an advanced treatment facility at the oceanside plant, a new pump station and reservoir in Golden Gate Park, and approximately eight miles of recycled water pipeline.
The project's primary customers will be Golden Gate Park and Lincoln Park golf course.
And we are also working on projects to connect the San Francisco Zoo and Lower Great Highway and Sunset Boulevard Medians.
In terms of construction contract status, contract WD 2776, which is the subject of today's agenda item, construction is complete and the administrative closeout work is in progress.
The other three contracts that constructed recycled water infrastructure have already been completed.
These include the reservoir and pump station in Golden Gate Park, the updating of the irrigation systems in Golden Gate Park and Lincoln Park to be compliant with recycled water regulations, and the recycled water pipeline, which were completed in 2018.
And the final bullet here, while it's not a contract, it's an important milestone for the project, and that was we have secured the permit to operate the recycled water system from the state water resources control board, and we received that permit in 2023.
Now I want to briefly describe a specific challenge encountered at the treatment facility.
In 2023, just as we were preparing to begin the commissioning of the treatment system, we discovered that the reverse osmosis system, variable frequency drives, this is equipment that controls the flow of water through the system, had failed due to corrosion.
The equipment failure was determined to be due to the ventilation design, which allowed for outside moist air to enter the electrical cabinets.
In this photo, you could see the electrical cabinets with ventilation ductwork connected at the top.
The concept is that a fan inside of that duct exhausts the heat produced by the equipment and sends it outside.
But that same ductwork also allowed for the entry and condensation of moist air to enter and fall onto the electrical components.
Both the ventilation systems and the electrical equipment have been redesigned and we have new contracts in place to replace that equipment and construct the required modifications.
Since most of the major contract construction work under contract WD 2776 had already been completed, we decided against having the contractor complete this repair work as it would further extend the contract and we would incur additional costs related to construction delay.
The as I mentioned, the replacement of the equipment is in progress, and we are planning to resume the commissioning process in mid-2026 once that equipment is installed and tested, and we are using the job order contracting process to get that work done.
Now I want to focus on the broader context of delays and the current status of contract WD 2776.
The project incurred delays over the course of construction, including those related to COVID and the related supply chain issues.
We had many miscellaneous changes to the electrical and mechanical systems, which were often further impacted if the changes required parts that had long lead times.
Substantial completion was established as February 4th, 2025 as the date that marked the completion of all physical work.
We continue to work with the contractor on the administrative closeout items.
This brings me to the request under this agenda item requesting this commission's approval to increase the cost contingency by five million dollars to allow for payment of the extended overhead costs related to delays and for the miscellaneous electrical and mechanical changes.
Thank you, Ms.
Palacios.
Commissioners.
Questions or comments?
Oh, Commissioner Leverone.
I'm just trying to get my arms a lot as gone on here, and it sounds like a lot of negotiation has taken place to get to this point and that you're comfortable with the five million dollar figure.
But just to get curious here is so June 30, 2023, was there at that time determined that there was a design defect?
Um with what has caused the damage?
Because it looks like only two years and we had a lot of corrosion take place.
Yeah.
Well, the equipment had been sitting there for a bit of time.
Um those components had been installed.
I don't I don't have the exact date that that those VFDs were in place, but they had been sitting idle for a bit of time because there were other change order work that needed to be done until we could get to the commissioning process.
And it was at that point when we went to fire up the equipment that we discovered the corroded components.
Okay.
And it is, I guess with the I'm not going to get into latent and patent defect claims or anything like that.
Was that ever in the discussed in the settle or it arrive into the five million dollar figure?
Is that something that was a possibility or maybe it wasn't even applicable?
It was uh pretty apparent that it was a design.
Okay, we had workshops internally.
Uh we had an outside consultant come in and and help us evaluate what happened, and and the conclusion was that the ventilation design was not appropriate for this installation.
Okay, and then getting to the five million dollars, was there I'm gonna think the figures must have started off a lot higher or higher.
I don't know, need I don't need to know the exact figure, but how did we get to five million?
The five million is actually it's it's um it's composed of of two major components.
One is the um the negotiation of time, the delays, um, and uh the actual change order work related to um mechanical and electrical components that um took some time to negotiate the cost of those changes, um, but the time is the is the bigger component of of that five million dollars.
If I if I might uh commissioner maybe I think you're getting it I just I just want to be clear the design it was designed by DPW.
So I I think you're you were focusing on defects and whatnot.
The design that we determined was the issue was a design by DPW by the city.
I didn't realize that.
Thank you.
That answers that I think that clarifies, that clarifies it.
Thank you.
Thank you very much.
No more questions.
Uh commissioners, any other uh commissioner thurlow?
Um, can I just get a sense of scale for how much um how much we will pay through the jock to do the repair work and replacement, I guess like redesign and replacement of the of the variable frequency drives?
The replacement of the VFDs themselves is about 1.5 million dollars.
Uh there's also modifications to the to the ductwork itself, the HVAC system, and that's about half a million dollars.
Okay, great.
And then the idea is that they'll be finished and ready for commissioning, you said um next year, is that right?
Yes.
Okay, great.
Thank you so much.
Thank you.
This project has been uh troublesome for a few years.
I I remember the the ventilation issue came before the commission a while ago, and that it was a city, um, city sort of owned that problem, and as uh general manager indicated, it was a city designed ventilation system that just didn't work out at the ocean.
It's really it's hard to hear this.
Um it's an important project and it's been significantly delayed.
And I I think Commissioner Leveroni got at this question the five million dollars is a negotiated number with the contractor to sort of allocate responsibility for who caused what delays.
Which delays correct the what was negotiated were um the days of delay.
The contract itself stipulated a five thousand dollar per day of compensable time.
Yeah, and is that part of the reason why you decided to move on with a correct different contractor rather than continue with this contract?
Yes, yeah.
Okay, thank you for the presentation.
Uh let's take public comment.
Remote collars, please raise your hand if you wish to provide comment on item 12.
Are there any members of the public present who wish to comment on this item?
Seeing none, moderator.
Are there any callers who have their hand raised?
Ms.
Lamier, there are no callers in the queue.
Thank you.
Thank you.
Uh Commissioners, could I have a motion and a second to approve item 12?
A motion to approve item 10.
12.
Second.
Thank you.
President Stacey?
Aye.
Vice President Arce?
Aye.
Commissioner Jamzar?
Aye.
Commissioner Leveroni?
Aye.
Commissioner Thurlow.
Aye.
Item 12 passes.
Item 13.
Approve amendments number one to contract numbers CS-1231.
A, D, and E.
Municipal Advisory Services with Baxstrom, McCarley, Barry, and Company LLC, Montesquieu de Rose and Associates, PFM Financial Advisors LLC.
Good afternoon, President Stacey and Commissioners.
Commissioner RC, I hope this last agenda item is worth your trip.
This will be a very brief item.
As you know from our July 22nd presentation on the capital financing plan, one of the first items we promised to come back to you with is an expansion of our municipal advisor agreements.
As you know, we provide financing for four separate rated entities.
Prior to my joining the PUC in 2021, a new pool of municipal advisors was selected, including these contracts that we are amending today.
In the last few years, you've approved larger capital financing plans, which have required additional borrowing.
We have also been doing a number of new things, including uh innovative refinancings like the two tender refinancings that we've done for the water enterprise.
We have also been mitigating risks due to changes in Washington DC around our build America bonds.
We've taken advantage of tax credits approved by the prior administration.
All of these things were not anticipated when we form that pool.
And so we've been exhausting our approved amounts for our advisors.
As you know, when we do any financing, we have a number of trusted advisors, the most important ones being our city attorney's office, the uh outside attorneys hired by the city attorney's office.
We have access to the premier investment banks and commercial banks who are working with us.
But the one party who sits by us and has a fiduciary responsibility to us, in other words, they are obligated to put our interests ahead of even their own interests, are our uh financial advisors, and in particular the securities exchange commission in the wake of the financial crisis, uh, and the passage of Dodd Frank created a new designation called municipal advisors.
So our independent municipal advisors are the ones who sit by us and guide us through our transactions.
They serve as an extension of staff, they they help provide us independent advice, they help us in our negotiation with those various external parties, the investment banks, the commercial banks, they help us to achieve the lowest borrowing costs and uh minimize the impacts on our ratepayers.
So it is our intention um to accelerate uh replacement of our pool uh which is due to expire in 207.
But in order to bridge that period, we are requesting additional funds on these contracts to ensure that we always have those trusted advisors by us with whatever uh requests come our way.
Uh we have been asked to take a look at additional financing options that have not yet uh ripened to the point of being presented to you, but we are constantly looking at additional uh financing opportunities.
So with that, um we would ask for uh the extension of 700,000 to each of these three contracts, and we look forward to uh continuing to work with them.
Thank you.
Commissioners, comments or questions?
Commissioner Leverone, just a question in general had nothing to do with the this, but uh since you're here, do we ever avail ourselves or do we have an opportunity for carbon credits with our forest programs?
We we are looking at various credits on different projects.
Um our team hasn't been involved with uh carbon credits, but we are looking at other types of uh credit opportunities, uh, and our advisors help us explore those.
The um the tax credits specifically are things that we have filed for.
Um that program unfortunately is being diminished this year, uh, but uh we continue to pursue those.
Thank you.
If I might, I I should also add that one of the things important things that these advisors do is advise us on our ratings.
Um, in our previous presentations, we told you about our power rating that in the wake of the uh wildfires in Southern California.
Excuse me.
Uh the rating agencies had reached out to us um to um both express concerns about wildfires, SP took the extraordinary action of putting a number of Northern California utilities on negative outlook.
Um so we uh from the entire team um uh including uh AGMs, uh, uh cross section of staff, uh city attorney's office have been meeting with them over a number of months.
We had our first presentation in May, and uh just before the holiday we received the very exciting news that SP had revised the negative outlook back to a stable outlook and affirmed our rating, and Fitch also affirmed our rating.
So I'm pleased to be able to share that news in connection with this.
Good news.
That's that's great.
Congratulations.
And um I just uh wanted to comment that it's been a complicated couple of years and understandable that we continue to need more services to work with us, and that the continuity of those services is really important.
So these amendments make sense to me.
Uh, could we take public comment?
Remote callers, please raise your hand if you wish to provide comment on item 13.
Are there any members of the public present who wish to comment on this item?
Seeing none, moderator, are there any callers who have their hand raised?
Ms.
Lanyette, no callers in the queue.
Thank you.
Commissioners, could I have a motion and a second to approve item 13?
I move to approve item 13.
Second.
Thank you.
President Stacey?
Aye.
Vice President Arce?
Aye.
Commissioner Jandar?
Aye.
Commissioner Leveroni.
Aye.
Commissioner Thurlow.
Aye.
Item 13 passes.
Thank you.
Item 14, communications.
Commissioners, any comments or questions on the communications calendar?
No.
Seeing none.
Item 15.
I just had a quick question.
Commissioner Jamdar short comments.
Reacted a little late.
I did read the Clean Power SF quarterly report and excited to see some new programs coming online.
So excited to see them on unfold and roll out.
Thank you.
Item 15.
Item 15, items initiated by commissioners.
Commissioners, are there any items to initiate for future discussion?
Vice President Arcei.
Um thank you, President Stacey.
I want to bring up a topic I brought up earlier in the year.
Am I off?
Oh, I'm on the wrong mic, so you come in late to get the wrong mic.
Uh, wanna bring up a topic I I brought up at an earlier meeting and was really grateful to staff to get some information about the Hummingbird Farm uh collaboration and partnership we have in the Southeast for folks that know.
I got a really great presentation from the team.
It's a really important resource for Southeast residents, a collaboration, and real, I think, win for the agency for so many years.
I've been there tons of times myself, been there to participate in food and plant workshops, there's field trips, there's volunteer experiences, they have an apprenticeship program, they do water and land conservation program.
I bring all that up because I think probably due to the fact that I I mentioned it uh at a previous meeting.
I've had some of the ratepayers in that area ask me what current plans are because again, this is just what I understand the our uh agreement there expires soon, maybe the end of the month.
So I thought I would just um kind of ask that question on behalf of number of folks in the neighborhood who've reached out to me.
Um, what's our plans are for the future?
Um I'm guessing it's it's already there, and I'll probably learn pretty darn quick what it is.
But I think it's a great uh really great win for this agency, and that's something I'd um love to kind of either offline or online or whatever it is, love to be able to be uh cognizant about when I'm asked because I expect to be asked again kind of what our thinking is there.
So thanks everybody.
Thank you.
Should we take public comment on Hummingburg Farm?
Yes, let's take public comment.
Remote college, please raise your hand if you wish to provide public comment on item 15.
Are there any members of the public present who wish to comment on this item?
Seeing none, moderator, are there any calls who have their hand raised?
Thank you.
Thank you.
This meeting is adjourned.
Discussion Breakdown
Summary
San Francisco Public Utilities Commission Meeting - September 9, 2025
The San Francisco Public Utilities Commission (SFPUC) convened a meeting addressing routine approvals, extensive public testimony on water management and infrastructure concerns, staff reports on audits and public health goals, regulatory updates for cross-connection control, and several contract amendments. Commissioners discussed these items with a focus on accountability and public engagement.
Consent Calendar
- The consent calendar (Item 6) was approved unanimously.
- Minutes from July 22, 2025 (Item 3) were approved unanimously after brief public comment.
Public Comments & Testimony
- Francisco de Costa expressed concerns about lack of accountability and transparency in the Bayview Hunters Point community, urging the commission to find solutions with community members.
- Spreck Rosecrans presented results from a double-blind water taste test, indicating East Bay MUD ranked first, Marin Municipal Water District second, and San Francisco third, and offered to cooperate on further testing.
- Nancy Arbuckle criticized the SFPUC for using flawed demand projections, argued this harms ratepayers and the environment, and expressed support for the Bay Delta Plan.
- Bill Clark raised concerns about deferred maintenance of sewer infrastructure, emphasizing that big budget projects divert resources from essential upgrades, increasing flooding and public health risks.
- Demetrius Williams requested training for local contractors in the Bayview to maintain the sewer treatment plant, highlighting a need for community involvement.
- Norma Wallace Galvan (Ohlone representative) called for workshops to address ignored commission directives and agreed with prior comments on voluntary agreements and deferred maintenance.
- John Rose echoed calls for workshops on fish biology and the design drought.
- Peter Dreckmeier (Tuolumne River Trust) argued that the Tuolumne River Voluntary Agreement is flawed, staff ignored commission resolutions, and urged scheduling workshops on the agreement and design drought.
- Ben from Friends of Mission Creek expressed concerns about sewer backups and public health hazards, criticizing the PUC's management decisions.
- Other callers including Martin Gothberg, Mary Butterwick, Steven Rosenrum, and Sonica Hummer criticized the design drought as overly conservative, supported the Bay Delta Plan, and called for more transparency and workshops.
Discussion Items
- Quarterly Audit Report (Item 5): Nancy Hom presented the audit bureau's report, highlighting no findings for the PUC in a citywide interdepartmental services audit. Commissioners had no questions, and the report was accepted.
- Public Health Goal Report (Item 7): Staff presented the 2025 report, identifying three contaminants exceeding public health goals: bromate, hexavalent chromium, and lead. Discussions focused on lead replacement programs, outreach, and concerns about groundwater contamination from sewer overflows. The commission directed staff to publish draft reports earlier for public access.
- Cross Connection Control Plan (Item 8): Andrew Grosso presented the draft plan to comply with new state regulations, requiring hazard assessments for all 182,000 services and upgrades to fire services. Commissioners discussed challenges, costs, and outreach strategies.
- Contract Amendments and Project Updates:
- Item 10: Approved increased funding for specialized technical services contracts.
- Item 11: Accepted work for sewer improvements with a duration extension.
- Item 12: Approved a $5 million cost contingency increase for the West Side Recycled Water Treatment Facility due to delays from a ventilation design issue.
- Item 13: Approved amendments to municipal advisory services contracts.
- Hummingbird Farm Inquiry (Item 15): Vice President Arce inquired about future plans for the Hummingbird Farm partnership, noting community interest.
Key Outcomes
- All items brought to a vote were approved unanimously:
- Item 3: Minutes approved.
- Item 6: Consent calendar approved.
- Item 7: Public Health Goal Report approved.
- Item 8: Cross Connection Control Plan approved.
- Item 9: Amended Section G rules approved.
- Item 10: Contract amendments approved.
- Item 11: Work acceptance and payment approved.
- Item 12: Cost contingency increase approved.
- Item 13: Municipal advisor contract amendments approved.
- The commission directed staff to improve public notice for draft reports and acknowledged calls to schedule workshops on the Tuolumne River Voluntary Agreement and design drought.
Meeting Transcript
And Stacy? Here. Vice President Arce. Absent. Commissioner Jamdar. Absent. Commissioner Leveroni. Here. Commissioner Thurlow. Here, you have a quorum. And I think Commissioner Jamdar is expected momentarily and hopefully Vice President Arce will be here later in the meeting. Thanks. Before calling the first item, I'd like to announce that the San Francisco Public Utilities Commission acknowledges that it owns and are stewards of the unceded lands located within the ethnohistoric territory of the Mawekma Alone tribe and other familial descendants of the historic federally recognized Mission San Jose Verona Band of Alameda County. The SFPUC also recognizes that every citizen residing within the Greater Bay Area has and continues to benefit from the use and occupation of the Mawekma Alone tribes aboriginal lands since before and after the San Francisco Public Utilities Commission's founding in 1932. It is vitally important that we not only recognize the history of the tribal lands on which we reside, but also that we acknowledge and honor the fact that the Mawekma Alone people have established a working partnership with the SFPUC and our productive and flourishing members within the many greater San Francisco Bay Area communities today. Item three, approval of the minutes of July 22nd, 2025. Commissioners, are there any comments or corrections to the minutes? No. Seeing none, let's take public comment. Remote callers, please raise your hand if you wish to provide comment on item three. Are there any members of the public present who wish to comment on this item? This is for the minutes. Commissioners, uh, it's been some time since I've come here. I'm busy on some other fronts facing our nation. I'm sorry, Mr. DeCosta. Are you commenting on the minutes? Yes, please. Okay, thank you. So from time to time, I have to prioritize what's important to San Francisco, and what's important to our citizens. Early today, I was at a meeting at 525 on the third floor, 525 Golden Gate, on the rate board, listening to them very intently. And they kind of refer to the commission as to what is happening with energy, our source system, our clean water system, back and forth, back and forth. We have issues with PGE, we have issues with our program, the clean program, and we need to pay attention to those who are who need help most, our seniors, and those who need uh, you know, people who are challenged and need and have to have certain um instruments and certain applications so that health can be addressed, and we need to have those who are suffering here in San Francisco. Uh lots of charts, I'm going to review them. Uh, a lot of statistics, but very few solutions, and PGN PGN is still in the cockpit. As long as they're in the cockpit, it's going to be a tough fight. Thank you very much. Are there any other members of the public who would like to speak on item three? Minutes for July 22nd, 2025. Moderator, are there any callers who would like to speak? Ms. Lanyard, there are two callers that wish to be recognized. Thank you. We wanted a gentleman. Caller, you're you can unmute it. You have two minutes. I want to make a comment. General comment. The general public comment is the next item. We're just talking about the minutes now on item three.