San Francisco's Green Credentials in Question when it comes to Water Efficiency

San Francisco has a reputation as one of the most environmentally progressive cities in the country, if not the world, and in many respects that assertion is correct.  According to, which named San Francisco one of the 5 Most Sustainable Cities in the World in 2011, the City recycles 77 percent of its waste, reserves nearly 20 percent of its land to green spaces, and has more than 497 LEED-certified green building projects.  But when it comes to water stewardship, San Francisco might not be leading the way.

In my last blog I talked about California’s progress in meeting the 20x2020 water use reduction goals contained in the state’s Water Conservation Act of 2009.  In addition to looking at the state as a whole, NRDC also reviewed 2010 Urban Water Management Plans for a select group of water suppliers.  We evaluated the calculation of baseline and target water use for measuring compliance with the state’s requirement to reduce urban water use by 2020, and we summarized our reviews in letters to the suppliers and a report to the Department of Water Resources (DWR).  One of those plans was prepared for San Francisco Public Utility Commission (SFPUC), the city’s retail water supplier. I always think of San Francisco as a leader in all things green, so I was really surprised to see the shortcuts SFPUC included in its Plan:

  1. SFPUC excluded ALL its retail water service connections located outside of the City of San Francisco, including out-of-city residential customers, San Francisco Airport, the prison, and Lawrence Livermore and Sandia National Laboratories from its baseline water use calculation despite the fact that DWR requires that the calculation be based on total gross produced water and total retail service area population. By excluding several of these sites with high water use but low resident population, SFPUC’s action makes its per capita water use appear lower than it really is.

    In a letter to NRDC, SFPUC stated that for the purposes of water billing and accounting, In-City Retail and Suburban Retail are considered separately and chose to only consider In-City Retail for compliance with the Water Conservation Act.  The DWR Guidebook (page D-3) provides options for public water suppliers that have multiple service areas - none of these options includes a provision allowing a water supplier to exclude a portion of its retail service area.
  2. SFPUC reported a 2020 Target water use that is 28% HIGHER than its Baseline.  Per the DWR Guidebook, any supplier with a 5-year baseline below 100 gallons per capita per day (gpcd) is exempt from further water use reduction requirements but is obligated to document and maintain water use at or below 100 gpcd in 2015 and 2020.  SFPUC reported a 5-year Baseline Water Use of 92.2 gpcd but set its 2020 target at 124.5 gpcd.  Setting a target allowing for increased water use, as SFPUC has done, certainly does not follow the intent of the Water Conservation Act. SFPUC is simply exploiting some ambiguity in the language of the DWR Guidebook to allow its per capita water consumption to increase dramatically without fear of penalty for failing to achieve its 2020 target.  NRDC has brought this to the attention of DWR and it will be addressed in an upcoming series of Urban Stakeholder Committee meetings later this fall.
  3. 2010 Census population data shows in-city populations significantly lower than the values reported in SFPUC’s plan.  Higher population data, such as that used in the SFPUC Plan, has the impact of lowering the baseline per capita water use  - so the reported SFPUC baseline water use of 92 gpcd is very likely understated.  This casts further doubt on SFPUC’s eligibility for the 100-gpcd exemption.  [Note: 2010 Census data was not available at the time SFPUC prepared its UWMP, but will likely be required to be used in the 2015 Plan update. If SFPUC no longer qualifies for the exemption when the 2015 UWMP is prepared, they may only have a few years to implement policies that will allow them to meet required demand reductions.]
  4. SFPUC’s Plan did not include complete water use and demographic data because it chose to exclude key water use data that is required to be included under the law. Because of this, the Plan does not provide sufficient information to verify SFPUC’s eligibility for the exemption from further water use reductions based on documented water use at or below 100 gpcd during the base period.

Does SFPUC have some useful water conservation and efficiency programs?  Undoubtedly.  That is part of the reason I was so surprised to see that SFPUC chose not to play by the rules.  Some may look at SFPUC’s baseline water use and think, “wow, that’s really low!”  And compared to other cities around the state it is, but the low per capita water use is largely due to the fact that few households in San Francisco have sizeable yards.  Landscaping often uses 50% of the water in a typical single-family home in California.  The dense, compact urban form of San Francisco is one of its greatest assets, but without an accurate measure of per capita water use, we can’t know for sure how much more water-efficient the city could become.

It is well known that nearly a century ago, San Francisco sought special approval to flood Hetch Hetchy Valley, a pristine glacial valley in Yosemite National Park, to create a reservoir for the City of San Francisco.  To this day, SFPUC diverts this supply from the Tuolumne River and from the struggling Bay-Delta estuary where such flows would otherwise be headed, delivering extremely high quality water to the city and numerous suburbs.  Given the controversial history of its primary water supply as context, I would have expected SFPUC to pay more attention to the rules for good stewardship and conservation of this supply. What’s more, current supplies may be reduced in the near future due to a State Water Board process that includes plans to take water from the Tuolumne to buffer salinity and flow issues in the Delta.  We think SFPUC can and should be doing more to reduce unnecessary water consumption, and the place to start is more complete documentation of all current water uses, as required by the state.