HomeMy WebLinkAboutStaff Report 4.A Late Document 1 06/06/2011RECEIVED
CITY OF PETALUMA, CALIFORNIA JUN o 6 2011
C MEMORANDUM CITY MANAGER
"'later Resources`and Conservation Department 202 McDowell Blvd North, Petaluma, CA 94954
(707) 778 -4546 Fax (707) 778 -4508 Email-- dwrc9ci-petaluma. ca. us
DATE: June 3, 2011
TO: John Brown, City Manager
FROM: Pamela Tuft, Interim Direc
SUBJECT: Council Agenda Item 94.A.
Resolution Adopting the Urban Water Management Plan 2010 and SBx707, 20%
by 2020 Water U "se Reduction Requirements
Sonoma County Water Agency submitted comments to our UWMP 2010 late. We have
reviewed their comments, land in the interest of accommodation,''made adjustments to our
document where we felt they were appropriate.
Attached is SCWA's letter -and our response letter. We, have lalso;provided the pages with the
adjustments highlighted. We will update the plan withtheseTages and the Resolution, and then
submit the plan to the State.
S:\WATER RESOURCES & CONSERVATIOMUWMP\2010 \City CouncilWdopl UWMP \UWMP'Corrmlion 060611.Doc
SONOMA
C 0 U N T Y
WATER
,C''Y
June'2, 2011
Ms. Pamela Tuft
City of 'Petaluma
E-mail:, ptuft @ci.petaluma ca.us
202 North McDowell Blvd.
Petaluma, CA 949.54,
RE: Review of "Urban Water Management Plan,
.Dear Ms. Tuft.
File' CFl40 -0 -1 Urban Water Management Plan'- 2010
The Sonorna County Water Agency (Water, Agency) has reviewed the City of Petaluma s (City.) draft
Urban Water Management Plan (Plan). The Water Agency engaged in extensive discussions with
each, of 'its water contractors in order to coordinate. preparation. of our respective, plans. However,
because. the City, submitted its plan prior to the Water Agency's draft, plan, there. are several .
inconsistencies between the Water Agency's Plan and the City's Plan'.. We offer the following,
comments and encourage 'the, City to revise its' draft plan so that It is 'consistent with the Water
Agency's ,plan..
General Coimments
The City's draft ,Plan provides inconsistent and potentially misleading information. about the respective
.rights and obligations of the, City and the -Water Agency ° under the Restructured' Agreement -for Water
Supply. The, figure of 1'3,.400 acre - feet per year is referred; to throughout the; draft as an "'entitlement"
or a "contracted'' volume" that the City is assured of receiving from the'Water Agency in all, years,
regardless of clirnatic This is inaccurate for two reasons.
First, the 13,400' acre; foot per year figure is a, limitation on the amount of water Water Agency can
deliver to the City, not a guaranteed amount. 'The Water Agency's delivery obligations under `the
Restructured Agreement are subject to numerous conditions; many of Which currently impact the
Water Agency's ability :to deliver water.. The draft Plan's statements that- the City will receive:13,400
acre =foot per year from the 'Water -Agency ignores the language of the Restructured Agreement- and
the express conditions placed upon theNVOterAgericy's,delivery obligations.
Second, under Section 3.5 of the Restructured Agreement, deliveries to- all contractors may be,
curtailed during drought conditions. The City's draft Plan does not consider Section 3:5, and states
that the Citywill receive 13,400 acre -feet of-water from the Water Agency' during every year, including
severe drought years like 1;977. This is incorrect; the City's deliveries during any specific drought year
would be determined in accordance. with the allocation provisions of Section 3.5 and any specific
allocation plan then in:effect.
Water Agency staff, provided. City staff with projections of the amounts of water thatwould�be available
to• the, City during normal water years through 2035. 'These should' be used instead of the 13 .
acre =foot per year figure. Specific instances are discussed' below.
404 Aviation3oulevard - Santa Rosa, CA 95403 -9019 (707) 526 - 5370• - Faz (707) 544 -6M - www.sonomacountywater.org/
I
Ms. Pamela Tuft
City of Petaluma
June 2, 2011
Page 2 of 3
Table 3 -14
Table 3 =14 contains a heading titled "Contracted Volume" which lists a volume of 13,400 acre -feet.
This is incorrect: The Water. Agency recommends that the column titled Contracted Volume be
deleted. In addition, projected demands should be° revised for 2015 -2035 so that they are consistent
with Table 3 -2 of the Water Agency's draft 2010 Urban Water Management Plan
Section 4.1.1_
This section provides a discussion of the Water Supply and Transmission System Project. The
discussion is inaccurate and confuses that project with the subsequent Water Supply and
Transmission' System Reliability Project. Further, neither of these former - projects are relevant in
regards to the Water Agency's current water supply planning strategies. Consequently, the Water
Agency recommends that the section bel revised so that it is - consistent with the future water supply
projects described in the Water Agency's draft 2010 Urban Water Management Plan.
Section 4.1.3
The discussion of the, Water Agency's inflatable dam is inaccurate: The Water Agency recommends
that this section be revised so that it is consistent with the discussion of diversion facilities described
in the Water Agency's draft 2010 Urban Water Management Plan (Section 2.0).
Section 4.1.5
This section is inaccurate for the reasons described in the "General Comments" section above. In
particular the comment that the Water;Agency has overcommitted the available supply through the
2006 Restructured Agreement is inaccurate and should be deleted.
Table 4 -1
Table
table should beped eed to bee consistent availability from the Water Agency of 13,400 acre -feet.
This
with Table 3 -2' "of the'Water Agency's draft 2010 Urban
Water Management Plan.
Table 4 -12
As indicated above, water,supply available to the City from the Water Agency is identified in Table 3 -2
of the Water Agency's draft 2010 Urban Water Management Plan. Based on the Water Agency's
Russian River water supply modeling,rthis water could be provided to the City in normal and likely in
multiple dry year scenarios. However,. as noted in the Water Agency's plan, it is likely that there
would be demand management measures implemented (similar to 2007 and 2009) to preserve
reservoir storage in Lake Mendocino. For a single dry year scenario, water available to the City from
the Water Agency would be: less than a ;normal year as described in the Water.Agency's plan. Total
water supply available from the Water Agency for a single dry-year is indicated in Table 6 -2 the Water.
Agency's draft,20.10, UWMP. This would then be allocated based. on'Section 3.5 of the Restructured
Agreement. Consequently, Table 4 -12 should be revised so that it is consistent, with the Water
Agency's 2010 draft UWMR.
Section 6
Section 6 needs to be revised based on the comments provided above regarding water supply
available to the City from the; Water Agency. The section should also. include a discussion of Section
3.5 of the Restructured'Agreement.
Ms. Pamela Tuft
City of Petaluma
June 2, 2011
Page 3 of 3
Please call me at 707- 547 -1959 if you have any questions regarding the comments provided by the
Water Agency.
Sincerely
Jay I P E.
Y
Wat r'_ y Chief Engineer
c: Remleh-Scherzinger PO Box 61,=:Petaluma, CX94953 -0061
Mike Healy, PO`Box 61, Petaluma, CA 94953 -006.1
David Rabbitt — SCWA Board of Directors
Steve Shupe— Sonoma County Counsel
Grant Davis., Don Seymour, George Lincoln— SCWA
ep \ \fileserver\data \cl \pinks \week 05 -30 -11 \city of Petaluma commnet letter sss djs- jlj.docx
IT'S' OF PETALUMA
POST OFFICE BOX 61
PETALUMA, CA 94953 -0061
David Glass
Mayor
Jay Jasperse, P.E.
Sonoma County Water Agency
Chris Albertson
404 Aviation Blvd.
Teresa Barrett
Mike Harris
Santa Rosa„ CA 95403
Mike Healy
Gabe Kearney
Tiffany Ren&
Councilinenabers.
RE: Comments Regarding the Water Management Plan 2010
Mr. Jasperse,
We have received your comments dated June 2, 2011 regarding the City's UWMP 2010.
As you know our document was released on April 21S and our Public Hearing closed on
the 16 of May. In an effort to address your concerns, we will pull the final copies already
released to our City Council and suggest some modifications prior to adoption.
To address your General .comment, we are fully aware - of the contractual allocation limits
that the restructured Agreement for Water Supply places upon the City. We do not feel
that the comments in the UWMP regarding the "entitlement" and or "contracted volume"
are misleading. In fact, the usage is consistent with the title. of Section 3.1 of the
agreement "Delivery Entitlements of Water Contractors " and the 13,400 Ac /ft is a
contracted volume. We understand that it is a maximum allocation, but a volume none -
the -less.
With regard to Section 3.15 and the Agency's selection of 1977 as the single drought year.
In your own words, the assumptions that the,Agency made were "very conservative ".
With only the draft results made available to us, and no further knowledge of all the
modeling assumptions, we are not prepared to include the Agency's results for the
following reasons:,
6 1977 was the second of two back -to -back drought years and so is not
representative of a single year drought event with respect.to the Agency's
Water Resources &
assumptions regarding Lake Sonoma volume at the beginning the year.
Conservation
202 N. McDowell Boulevard
, The assumption that Lake Sonoma would start at 100,000 Ac /ft and trip the June
p
Pelalumo, CA 94954
15 requirement forcing a 30% diversion reduction is unfounded and appears
Phone (707) 778 -4546
overly conservative in that the Lake has never been at this level after a normal
Fax (707) 778 -4508
E-A- fail:
Y ear and the Lake did not exist in 1977. We would like to further understand the
dtivrc@ci.2ela
Agency's assumptions for the lake and watershed operational baselines during
the modeling period.
Ellis Creek !cater
Recycling Facility
e We would like to see modeli results when the single dry year is receded by a
g g Y Y p
3890 Cypress Drive
normal year with normal storage.
Petaluma, CA 94954
Phone (707) 776 -3777
Fax (707) 776 -3746
SCWA — Response Letter June 3, 2011
Jaylasperese. 3
We do however recognize Section 3.15 of.the Restructured Agreement which is addressed in
Section 6.1 of our Plan.
Thank you for taking the time'to carefully review our document and provide these comments.. We
would also like to extend our thanks to you and your staff for meeting with us over the last few months
and helping us shape the collective responses to DWR. We look forward to working' collaboratively with
Agency staff on future regional initiatives.
Regards,__ -
R"eml h S�l erzinger P.E.
WR &C Engineering Manaer'
CC Pamela Tuft
Grant Davis
David Rabbitt
Steve Shupe
George Lincoln
Don Seymour
City of Petaluma 2010 Urban Water Management Plan
and 16596). The permits authorize the Agency to store water in Lake Mendocino
(122,500 ac -ft) and Lake Sonoma (245,000 ac -ft) and to divert and re -divert 180 cubic
feet per second '(cfs) (116.3 MGD) of water from the Russian River and Dry Creek, up to
75,000 ac-ft /yr.
The permits also establish minimum instream flow requirements for-fish and wildlife
protection and Russian :River recreational,considerations. These rninimum instream flow
requirements vary according, W. the hydrologic cycle (i:e: water years versus normal
water years) as defined: by the;SWRCB's Decision 1610. Recent studies discussed below
suggest the minimum flows required. by D1610 may negatively impact the fishery habitat.
In addition, other issues impact the management of the Russian River system. SCWA is
working to improve its :supply reliability through multiple efforts. The following
describes each issue and current status.
4.1.1 Water Supply Projects
SCWA is currently plan'n'ing multiple supply and reliability projects, in response to the
issues as described in thesesections. Projects include effortsto:`implement the Biological
Opinion, improve supply reliability,. improve infrastructure.r'eliability, and enhance in-
stream conditions. Detailed information regarding SCWA's water supply projects is
presented. in SCWA!s UWMP. The City understands that SC VA's supply projects will
not provide any new supply to current volumes, but ma increase reliability or modify
operations of SCWA's Tacilities.__ At this time, the City does not expect these future
supply projects to impact its current contract supply upper limit of 13,400 iacre -feet per
year
4.1.2 Russian River: ESA Section 7 and. Biological Opinion
The Central California coast steelhead, California Coast Coho salmon, and California.
Coast Chinook salmon were listed as threatened under the federal Endangered Species
Act (ESA),. This,, listing'began a process of investigation and review as -part of the ESA
Section 7 consultation requirements. The National Marine Fisheries Service (NMFS)
issued its 15 -year Biological Opinion for Water-Supply Flood Control'Operations, and
Channel Maintenance conducted by,the U.S. Army corps of Engineers; the Sonoma
County. Water Agency, and the Mendocino County Russian River Flood Control and
Water Conservation Improvement District (MCRRFCWCID) in the Russian River
Watershed (Russian 'River Biological Opinion) on September 24 2008. In.summary, the
Biological Opinion concluded that the elevated river flows by Decision 1610
were adversely affecting the fish habitat.
The Biological Opinion. (BO) lists Reasonable and Prudent Alternatives (RPAs) to reduce
the affects to fishhabitat from the SCWA, Army Corps, and 1VICRRFCWCID operations.
The BO identifies RPAs for the next 15 years that address SCWA operations and water
supply impacts and include:
• Reducing summertime flows in the Russian River and Dry Creek
• Enhancing six:miles of habitat in Dry Creek
• Creating a,freshwater lagoon in the estuary during summer months
CoP %20UWMP %20Final[l] 17
City of Petaluma 2010 Urban Water Management Plan
® Monitoring both habitat and fish in Dry Creek, the estuary, and- Russian River
o Elirriinating impediments to fish spawning or improving habitat in' several
streams.
The BO concludes that reducing the minimum instream flow requirements will assist
implementation of other RPAs. SCWA filed a petition in September 2009 to the
SWRCB requesting permanent changes to Decision, 1,610 minimum flow;requirements in
line with the Biological Opinion. ,.S WRCB will act on the petition upon completion of the
EIR for Fish Habitat Flows and Water Rights Project as described below. Until thaftime,
SCWA must request temporary changes to the Decisions 1610 minimum flows annually
per the .BO recommendations. SCWA received its, first temporary flow reduction petition
under the BO recommendations for 20 -10.
SCWA developed the Fish Habitat. Flows and Water Rights Project to addressthe'BO
RPAs and improve supply reliability. The project includes updating, the Decision 1610
- minimum flow requirements per the'BO, modifying reservoir release schedules and
volumes, petitioning SWRCB to change the methodology used to define hydrologic; year
types to include parameters in the Russian River watershed, and to. rnodify `SCWA's
Water rights to reflect current conditions, possibly modify place of'use,, and' make .other
clarif cations: A .Notice of Preparation for the EIR was - posted on Sepfember 1 29,, 2010.
4.1.3 Seasonal hydrologic constraints on the Russian River diversion
facilities
The ability of SCWA to divert water from the Russian River can be limited. by the rate of
recharge to the aquifer through the streambed. To augment this recharge capacity, the
Agency has constructed several infiltration ponds , that surround the Agency collector
wells. Diversions, and infiltration operations are also assisted by an inflatable: dam. The
Agency's water production capacity is complex andvill vary, from year to year based on
a number of factors: In any given year, Agency production needs depend on demands;
Which iare is function of temperature, 'precipitation; growth, and hydrologic conditions:
The hydrologic'conditions are in turn a!functibm of groundwater levels and the
permeability of the riverbed, which in turn `impacts whether or,not supply is.,groundwater
or considered underflow from the river..: An Agency analysis of wate.rtrends from 1.997
to 1999 concludedT that stressed hydrologic conditions occurred in the fall /early winter,
followedby non-stressed conditions in the winter; and stressed conditions again in the
spring, prior to the rubber darn being, raised:. Stressed hydrologic conditions -Eire
determined by monitoring groundwater levels and noting the decline in water levels as.
the Agency pumps water'to meet demands: Agency staff is continuing to analyze': the
seasonatcohAraint and`its potential "impact on the :ability to provide water to 'its
customers: As non =peak, demands continue to rise,'the Agency will increasingly rely :on.
using, the inflatable dam more continuously throughout the year if conditionszllow use.
Should the Agency be precluded from using the dam due to mechanical or environmental
constraints, the production capacity of the Agency transmission system could be
temporarily impaired.
CoP %20UWMP %20Final[1] 18
City of Petaluma 2010 Urban Water Management Plan
r ,
4.1:4 SCWA Water. Supply Strategy Action Plan
SCWA developed the Water Supply Strategy. Action Plan in 2010. The action plan
addresses strategies and goals to improve supply reliability, implement the BO
requirements, and other.issues. The City,of Petalunta is collaboratively working with
SCWA and the other contractors to address the regional Water supply and demand issues.
4.1.5 SCWA Water Supply Reliability
With SCWA's diversions,.are .currently limited to 75,000 AFY. The Restructured
Agreement lists a total :of 77 .AFY to the Water Contractor's under Section 3.1
Delivery Entitlements of'Water Contractors. The Restructured Agreement states SCWA
is not obligated to provide the City of Petaluma more than 13,400 acre -feet per year and
21.8 mgd average dailyrate during any month. Until modified'through an updated
contract or other means, the City assumes its reliable supply has not changed from the
Restructured Agreement. The Agreement acknowledges supply shortages, but leaves
actual allocation values to be 'determined depending on, the specifics of the shortage
situation. Table 4-1 lists;the projected surface water supply expected through 2035. Dry -
year supply reliability analysis and summary is presented in =S'ection 4.6.
Table 4 -L Surface Water Supplies (DWR Table 17)
Note. 2010 value actual volume delivered; delivered; volume available w as 13,400' AF per Restructured
Agreement
4.2 Groundwater
WR &C maintains wells that pump from the Petaluma Valley Basin. The California
Department of Water Resources Bulletin 118, 2003 Update id'ent'ifies the Petaluma
Valley Basin as Basin Number 2.1. The total basin acreage, is listed' at acres. The
groundwater basin 'is defined Eby Bulletin 118 and is generally`the Petaluma River Valley
starting at Penngrove, on the north and following-the valley south to San Pablo Bay, as
shown in Figure 4 -1.
CoP %20UWMP %o20Final[1] 19
Pro'ected.Su 1 Availabilif
-,;;acre =feet. er ear
2010
actual
2015
2020
2025
. 2030
2035
SCWA
_ 6,993
13,400
13;400
13;40.0
13;400
13;400
Note. 2010 value actual volume delivered; delivered; volume available w as 13,400' AF per Restructured
Agreement
4.2 Groundwater
WR &C maintains wells that pump from the Petaluma Valley Basin. The California
Department of Water Resources Bulletin 118, 2003 Update id'ent'ifies the Petaluma
Valley Basin as Basin Number 2.1. The total basin acreage, is listed' at acres. The
groundwater basin 'is defined Eby Bulletin 118 and is generally`the Petaluma River Valley
starting at Penngrove, on the north and following-the valley south to San Pablo Bay, as
shown in Figure 4 -1.
CoP %20UWMP %o20Final[1] 19