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Home My WebLink About12 ADOPTION OF 2025 WATER SHORTAGE CONTINGENCY PLANDocusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 MEETING DATE TO: FROM: SUBJECT: SUMMARY: Agenda Item AGENDA REPORT Reviewed: City Manager Finance Director JUNE 16, 2026 ALDO E. SCHINDLER, CITY MANAGER MICHAEL GRISSO, DIRECTOR OF PUBLIC WORKS ADOPTION OF 2025 WATER SHORTAGE CONTINGENCY PLAN The California Urban Water Management Planning Act requires the City to develop and adopt a Water Shortage Contingency Plan as part of the Urban Water Management Plan update process. The plan establishes the City's response framework for water shortages and drought conditions, demand reduction actions, water use restrictions, and operational responses necessary to maintain water supply reliability. RECOMMENDATION: Recommend the City Council: 1. Conduct a public hearing for the 2025 Water Shortage Contingency Plan; and 2. Adopt Resolution No. 26-33 approving the City's 2025 Water Shortage Contingency Plan. a 6Y97_1IIIIIIIIII 1►yi l :7_[I& 6 Sufficient funds were appropriated in the 2025-26 Water Enterprise Operating Budget to complete the 2025 Water Shortage Contingency Plan. There are no additional fiscal impacts associated with plan adoption. CORRELATION TO THE STRATEGIC PLAN: This effort contributes to the fulfillment of the City's Strategic Plan Goal D: Strong Community and Regional Relationships. Specifically, the action implements Strategy 2, which, among other things, is to enhance collaboration efforts with agencies within and outside Tustin on issues of mutual interest and concern. 12 afs Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 City Council Agenda Report Adoption of 2025 Water Shortage Contingency Plan June 16, 2026 Page 2 BACKGROUND AND DISCUSSION: California Water Code Section 10632 requires urban water suppliers to prepare, adopt, and file a Water Shortage Contingency Plan (WSCP) with the California Department of Water Resources (DWR) as part of its Urban Water Management Plan (UWMP) update. While the WSCP is developed in conjunction with the UWMP, the WSCP is a standalone document and is required to be approved independently of the UWMP. The 2025 WSCP has been prepared in compliance with the requirements of the Act and, as amended, revises the adopted 2020 UWMP. Staff partnered with Municipal Water District of Orange County (MWDOC) and Carollo Engineers, Inc. to update and develop the 2025 WSCP in coordination with regional and wholesale water agencies, aligning with the Metropolitan Water District of Southern California, Water Surplus and Drought Management Plan and Water Supply Allocation Plan, as well as MWDOC's Water Supply Allocation Plan. The 2025 WSCP framework remains consistent with the City's 2020 WSCP while updating revised demand projections, regulatory references, current regional supply planning information, coordination procedures with regional water agencies, and current water reliability analyses as required under State law. The WSCP also evaluates water supply reliability and concludes that the City is projected to meet anticipated customer demands through 2050 under normal, single dry -year, and multiple dry -year conditions through a combination of groundwater supplies, imported water supplies, storage reserves, and ongoing conservation efforts. The 2025 WSCP further incorporates established emergency response coordination procedures, including those from the Water Emergency Response Organization of Orange County and the City's Local Hazard Mitigation Plan. The attached 2025 WSCP was made available for public review prior to the public hearing in accordance with State law and is recommended for City Council adoption. Michael Grisso Director of Public Works Attachments: 1. 2025 Water Shortage Contingency Plan 2. Resolution 26-33 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 ATTACHMENT 1 2025 Water Shortage Contingency Plan Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 1V�J11� Remembe ri ng ,..a+at co n nec t s us. 2025 Water Shortage Contingency Plan FINAL DRAFT / May 2026 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 Remembering what connects us. 2025 Water Shortage Contingency Plan May 2026 / FINAL DRAFT Prepared By: Carollo Engineers, Inc. 707 Wilshire Boulevard, Suite 3920 Los Angeles, California 90017 Phone: 213.489.1587 https://www.carollo.com In collaboration with: Prepared For: City of Tustin 300 Centennial Way Tustin, California 92780 Phone: 714.573.3350 https://www.tustinca.org C MADDAUS WATER MANAGEMENT Smith Making a Difference in the World of WaterTM listen, think. deliver. Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Contents SECTION 1 INTRODUCTION AND WSCP OVERVIEW 1.1 Water Shortage Contingency Plan Requirements and Organization 1.2 Integration with Other Planning Efforts SECTION 2 BACKGROUND INFORMATION 2.1 City Service Area 2.2 Relationship to Wholesalers 2.3 Relationship with Wholesaler Water Shortage Planning 2.3.1 MET Water Surplus and Drought Management Plan 2.3.2 MET Water Supply Allocation Plan 2.3.3 MWDOC Water Supply Allocation Plan SECTION 3 WATER SHORTAGE CONTINGENCY PREPAREDNESS AND RESPONSE PLANNING 1 1 2 3 3 5 6 6 8 9 10 3.1 Water Supply Reliability Analysis 11 3.2 Annual Water Supply and Demand Assessment Procedures 11 3.2.1 Decision -Making Process 11 3.2.2 Data and Methodologies 13 3.3 Six Standard Water Shortage Levels 17 3.4 Shortage Response Actions 17 3.4.1 Supply Augmentation 17 3.4.2 Demand Reduction 18 3.4.3 Operational Changes 18 3.4.4 Additional Mandatory Restrictions 18 3.4.5 Emergency Response Plan (Hazard Mitigation Plan) 18 3.4.6 Seismic Risk Assessment and Mitigation Plan 20 3.4.7 Shortage Response Action Effectiveness 21 3.5 Communication Protocols 21 3.6 Compliance and Enforcement 22 3.7 Legal Authorities 22 3.8 Financial Consequences of WSCP 23 3.9 Monitoring and Reporting 24 3.10 WSCP Refinement Procedures 24 3.11 Special Water Feature Distinction 25 3.12 Plan Adoption, Submittal, and Availability 25 SECTION 4 REFERENCES 26 CITY OF TUSTIN pw://Carollo/CA/MWDOC/204447-000000/03 Reports and Studies/02 Deliverables/Grp2_Tustin UWMP/Tustin_2025 WSCP.docx Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Appendices APPENDIX A DWR SUBMITTAL TABLES APPENDIX B TUSTIN MUNICIPAL CODE CHAPTER 10 WATER MANAGEMENT PLAN APPENDIX C NOTICE OF PUBLIC HEARING (PENDING) APPENDIX D ADOPTED WSCP RESOLUTION (PENDING) Tables Table 1 Cross -Reference for Standard vs Supplier Shortage Levels Table 2 Communication Objectives and Tools During a Water Shortage Table 3 Agency Contacts and Coordination Protocols Figures Figure 1 City Service Area Figure 2 Regional Location of City and Other MWDOC Member Agencies Figure 3 Resource Stages, Anticipated Actions, and Supply Declarations Figure 4 AWSDA Reporting Timeline Figure 5 Water Shortage Contingency Plan AWSDA Framework 17 22 23 4 6 7 12 13 CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Abbreviations % Percent AF Acre -Feet AWSDA Annual Water Supply and Demand Assessment BPP Basin Production Percentage City City of Tustin DDW Division of Drinking Water DRA Drought Risk Assessment DVL Diamond Valley Lake DWR California Department of Water Resources EOC Emergency Operations Center EOCWD East Orange County Water District EOP Emergency Operations Plan FY Fiscal Year GRP OCWD's Groundwater Resilience Plan GSP Groundwater Sustainability Plan GSWC Golden State Water Company IAWP Interim Agricultural Water Program LHMP Local Hazard Mitigation Plan M&I Municipal and Industrial MCL Maximum Contaminant Level MET Metropolitan Water District of Southern California MWDOC Municipal Water District of Orange County NIMS National Incident Management System OC Basin Orange County Groundwater Basin OCWD Orange County Water District PFAS Per- and Polyfluoroalkyl Substances PFOA Perfluorooctanoic Acid PFOS Perfluorooctane Sulfanate PPT Parts Per Trillion Producers Groundwater Producers RL Response Level SEMS California Standardized Emergency Management System Supplier Urban Water Supplier SWP State Water Project SWRCB California State Water Resources Control Board UWMP Urban Water Management Plan Water Code California Water Code CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO WEROC Water Emergency Response Organization of Orange County WSAP Water Supply Allocation Plan WSCP Water Shortage Contingency Plan WSDM Water Surplus and Drought Management Plan CITY OF TUSTIN Iv Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO SECTION 1 INTRODUCTION AND WSCP OVERVIEW The Water Shortage Contingency Plan (WSCP) is a strategic planning document designed to prepare for and respond to water shortages. This WSCP complies with California Water Code (Water Code) Section 10632, which requires that every Urban Water Supplier (Supplier) shall prepare and adopt a WSCP as part of its Urban Water Management Plan (UWMP). This level of detailed planning and preparation is intended to help maintain reliable supplies and reduce the impacts of supply interruptions. The WSCP is the City of Tustin (City)'s operating manual that is used to prevent catastrophic service disruptions through proactive, rather than reactive, management. A water shortage, when the water supply available is insufficient to meet the normally expected customer water use at a given point in time, may occur due to a number of reasons, such as drought, climate change, and catastrophic events. This plan provides a structured guide for the City to deal with water shortages, incorporating prescriptive information and standardized action levels, along with implementation actions in the event of a catastrophic supply interruption. This way, if and when shortage conditions arise, the City's governing body, its staff, and the public can easily identify and efficiently implement pre -determined steps to manage a water shortage. A well -structured WSCP allows real-time water supply availability assessment and structured steps designed to respond to actual conditions, enabling efficient management of any shortage with predictability and accountability. The WSCP also describes the City's procedures for conducting an Annual Water Supply and Demand Assessment (AWSDA) that is required by Water Code Section 10632.1 and is to be submitted to the California Department of Water Resources (DWR) on or before July 1 of each year, or within 14 days of receiving final allocations from the State Water Project (SWP), whichever is later. The City's 2025 WSCP is included as an appendix to its 2025 UWMP, which will be submitted to DWR by July 1, 2026. However, while developed in conjunction with the UWMP, this WSCP is a standalone document and can be amended, as needed, without amending the UWMP. Furthermore, the Water Code does not prohibit a Supplier from taking actions not specified in its WSCP, if needed, without having to formally amend its UWMP or WSCP. 1.1 Water Shortage Contingency Plan Requirements and Organization The WSCP provides the steps and water shortage response actions to be taken in times of water shortage conditions. The WSCP has prescriptive elements, such as an analysis of water supply reliability; the water shortage response actions for each of the six standard water shortage levels that correspond to water shortage percentages ranging from 10 percent to greater than 50 percent; an estimate of potential to close supply gap for each measure; protocols and procedures to communicate identified actions for any current or predicted water shortage conditions; procedures for an AWSDA; monitoring and reporting requirements to determine customer compliance; and reevaluation and improvement procedures for evaluating the WSCP. CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO This WSCP is organized into three main sections, with Section 3 aligned with Water Code Section 16032 requirements: ■ Section 1 Introduction and WSCP Overview gives an overview of the WSCP fundamentals. ■ Section 2 Background Information provides a background on the City's water service area. ■ Section 3 Water Shortage Contingency Preparedness and Response Planning. >> Section 3.1 Water Supply Reliability Analysis provides a summary of the water supply analysis and water reliability findings from the 2025 UWMP. Section 3.2 Annual Water Supply and Demand Assessment Procedures provides a description of procedures to conduct and approve the AWSDA. » Section 3.3 Six Standard Water Shortage Stages explains the WSCP's six standard water shortage levels corresponding to progressive ranges of up to 10, 20, 30, 40, 50, and more than 50 percent shortages. Section 3.4 Shortage Response Actions describes the WSCP's shortage response actions that align with the defined shortage levels. Section 3.5 Communication Protocols addresses communication protocols and procedures to inform customers, the public, interested parties, and local, regional, and state governments, regarding any current or predicted shortages and any resulting shortage response actions. Section 3.6 Compliance and Enforcement describes customer compliance, enforcement, appeal, and exemption procedures for triggered shortage response actions. Section 3.7 Legal Authorities describes the legal authorities that enable the City to implement and enforce its shortage response actions. Section 3.8 Financial Consequences of the WSCP provides a description of the financial consequences of and responses for drought conditions. Section 3.9 Monitoring and Reporting describes monitoring and reporting requirements and procedures that ensure appropriate data is collected, tracked, and analyzed for purposes of monitoring customer compliance and to meet state reporting requirements. Section 3.10 WSCP Refinement Procedures addresses reevaluation and improvement procedures for monitoring and evaluating the functionality of the WSCP. Section 3.11 Special Water Feature Distinction provides a required definition for inclusion in a WSCP per the Water Code. Section 3.12 Plan Adoption, Submittal, Availability describes the process the City followed to adopt its WSCP. 1.2 Integration with Other Planning Efforts As a retail water supplier in Orange County, the City considered other key entities in the development of this WSCP, including East Orange County Water District (EOCWD), wholesale zone of the District and supplier of imported water to the City; the Municipal Water District of Orange County (MWDOC), regional wholesale supplier and the direct supplier of imported water to EOCWD; the Metropolitan Water District of Southern California (MET), regional wholesaler for Southern California and the direct supplier of imported water to MWDOC; and Orange County Water District (OCWD), Orange County Groundwater Basin (OC Basin) manager and provider of recycled water in North Orange County. As a MWDOC member agency, the City also developed this WSCP with input from several coordination efforts led by MWDOC. CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Some of the key planning and reporting documents that were used to develop this WSCP are: ■ MWDOC's 2025 UWMP provides the basis for the projections of the imported supply availability over the next 25 years for the City's service area. ■ MWDOC's 2025 WSCP provides a water supply availability assessment and structured steps designed to respond to actual conditions that will help maintain reliable supplies and reduce the impacts of supply interruptions. • MWDOC's 2023 Orange County Water Reliability Study is a planning document to help guide planning for future water supply reliability for water providers in Orange County and provide input on regional water supply issues for MET. • 2025 Orange County Water Demand Projection Model Technical Memorandum is a collaborative effort amongst MWDOC, OCWD, and all retail water suppliers in Orange County that developed water demand projections to produce regionally consistent forecasts across all Orange County water agencies. • OCWD's 2025 Groundwater Resilience Plan (GRP) is an adaptive strategies management plan outlining strategic projects to secure reliable future water supplies in the OC Basin. ■ MET's 2025 UWMP uses assumptions that fall within the plausible futures contemplated in MET's Integrated Water Resources Plan to evaluate MET's future imported water supply reliability. ■ MET's 2025 WSCP provides a water supply availability assessment and guide for MET's intended actions during water shortage conditions. ■ OCWD's 2023-24 Engineer's Report provides information on the groundwater conditions, water supply, and basin utilization of the OC Basin. ■ OCWD's 2022 Basin 8-1 Alternative is an alternative to the Groundwater Sustainability Plan (GSP) for the OC Basin, provides significant information related to sustainable management of the basin in the past and hydrogeology of the basin, including groundwater quality and basin characteristics, and addresses DWR's recommendations to ensure long-term basin sustainability. ■ City of Tustin's 2019 Local Hazard Mitigation Plan (LHMP) provides the basis for the seismic and other natural and natural disaster risk analysis of the water system facilities. SECTION 2 BACKGROUND INFORMATION Incorporated in 1927, the City is a General Law City and has a Council -Manager form of government which consists of an elected City Council responsible for policy making, and a professional City Manager, appointed by the Council. The City purchases imported water from EOCWD, who purchases the water from MWDOC (Orange County's wholesale water supplier and a member agency of MET). 2.1 City Service Area The City is located in central east Orange County. The City is bounded by the City of Orange to the north, the City of Santa Ana to the west, the City of Irvine to the south, and unincorporated areas of Orange County to the east. The City is approximately 35 miles south of Los Angeles and 10 miles inland from the CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Pacific Ocean. The City's water service area has an area of 8.4-square-miles and an elevation of about 210 feet above sea level. The topography of the City combines generally flat areas with gradual rolling hills. The City provides potable water service to most of the incorporated area of the City and also to unincorporated county areas north of the City. A map of the City's water service area is shown in Figure 1. I � � TUSTIN ru.swwuw StwWa A"Lw Q +r "s flrWAM AM& r Figure 1 City Service Area CITY OF TUSTIN 4 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO 2.2 Relationship to Wholesalers The Metropolitan Water District of Southern California: MET is the largest water wholesaler for domestic and municipal uses in California, serving approximately 19 million customers. MET wholesales imported water supplies to 26 member cities and water districts in six Southern California counties. Its service area covers the Southern California coastal plain, extending approximately 200 miles along the Pacific Ocean from the City of Oxnard in the north to the international boundary with Mexico in the south. This encompasses 5,200 square miles and includes portions of Los Angeles, Orange, Riverside, San Bernardino, San Diego, and Ventura counties. Approximately 85 percent of the population from the aforementioned counties reside within MET's boundaries. MET is governed by a Board of Directors comprised of 38 appointed individuals with a minimum of one representative from each of MET's 26 member agencies. The allocation of directors and voting rights are determined by each agency's assessed valuation. Each member of the Board shall be entitled to cast one vote for each ten million dollars ($10,000,000) of assessed valuation of property taxable for district purposes, in accordance with Section 55 of the Metropolitan Water District Act. Directors can be appointed through the chief executive officer of the member agency or by a majority vote of the governing board of the agency. Directors are not compensated by MET for their service. MET is responsible for importing water into the region through its operation of the Colorado River Aqueduct (CRA) and its contract with the State of California for SWP supplies. Member agencies receive water from MET through various delivery points and pay for service through a rate structure made up of volumetric rates, capacity charges, and readiness to serve charges. Member agencies provide estimates of imported water demand to MET annually in April regarding the amount of water they anticipate they will need to meet their demands for the next five years. The Municipal Water District of Orange County: In Orange County, MWDOC and the cities of Anaheim, Fullerton, and Santa Ana are MET member agencies that purchase imported water directly from MET. Furthermore, MWDOC purchases both treated potable and untreated water from MET to supplement its retail agencies' local supplies. The city is one of MWDOC's 27 member agencies, although it purchases imported water from EOCWD who acts as the wholesale provided directly to the City. The City's location within MWDOC's service area is shown in Figure 2. CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO f� ... o .......in" cowry j ros Angeles rounty Go�tlen Sere yor6a Linda `�®water D'mdrr 27 to r`I"'s ' orange cow y r water Dharlct u�cra Serrano water District Riverside Cvunry t� O Golden sere umryc�w wTrerco.-oc ® West n J sealaaa.n I'ennreln Valley © ® Irv_ Trshuco � ne Panrh � Cenyvn Wa[er HunnnFtOn e53 Water DlarrIn MDatr [t dfach ram, El Toro 1 olsafee ''AA�� warer Dlnria E®®ay r lutaulrnn Laguna Beach Niguel Water Santa saorga.' cnnnty dsaiice water LSArla water Dlsnrlat MWDOC San 5v�eh coast Cements Water District MWDOC Service Area inn Neg. Cvunry More is a wholesale watersupplier that serves Orange County through 27 memberagentiee. The 29 water providers identified in the legend bya cirele provide retail water sewicesto the public. Figure 2 Regional Location of City and Other MWDOC Member Agencies City of Brea City of Buena Park City of Fountain Valley OCity of Garden Grove Cj City of Huntington Beach O City of La Habra O City of La Palma QCity of Newport Beach OCity of Orange 1p City of San Clemente 40 City of Seal Beach ® City of Tustin City of Westminster East Orange County Water District ® El Toro Water District 0 Emerald Bay Service District 4) Golden State Water Co. - OC 1$ Irvine Ranch Water District 0 Laguna Beach County Water District 0 Mesa Water District 0 Moulton Niguel Water District Santa Margarita Water District is Serrano Water District 24 South Coast Water District ® Trabuco Canyon Water District 2fi Yorba Linda Water District Orange County Water District (Groundwater Wholesaler) 2.3 Relationship with Wholesaler Water Shortage Planning The WSCP is designed to be consistent with MET's Water Surplus and Drought Management (WSDM) Plan, MWDOC's Water Supply Allocation Plan (WSAP), and other emergency planning efforts as described below. MWDOC's WSAP is integral to the WSCP's shortage response strategy in the event that MET or MWDOC determines that supply augmentation (including storage) and lesser demand reduction measures would not be sufficient to meet a projected shortage levels needed to meet demands. 2.3.1 MET Water Surplus and Drought Management Plan MET evaluates the level of supplies available and existing levels of water in storage to determine the appropriate management stage annually. Each stage is associated with specific resource management actions to avoid extreme shortages to the extent possible and minimize adverse impacts to retail customers should an extreme shortage occur. The sequencing outlined in the WSDM Plan reflects anticipated responses towards MET's existing and expected resource mix. CITY OF TUSTIN 6 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Surplus stages occur when net annual deliveries can be made to water storage programs. Under the WSDM Plan, there are four surplus management stages that provides a framework for actions to take for surplus supplies. Deliveries in Diamond Valley Lake (DVL) and in SWP terminal reservoirs continue through each surplus stage provided there is available storage capacity. Withdrawals from DVL for regulatory purposes or to meet seasonal demands may occur in any stage. The WSDM Plan distinguishes between shortages, severe shortages, and extreme shortages. The differences between each term are listed below: Shortage: MET can meet full -service demands and partially meet or fully meet interruptible demands using stored water or water transfers as necessary (Stages 1-3). ■ Severe Shortage: MET can meet full -service demands only by making withdrawals from storage, calling on its water transfers, and possibly calling for extraordinary conservation and reducing deliveries under the Interim Agricultural Water Program (IAWP) (Stages 4-5). ■ Extreme Shortage: MET must allocate available imported supplies to full -service customers (Stage 6). There are six shortage management stages to guide resource management activities. These stages are defined by shortfalls in imported supply and water balances in MET's storage programs. When MET must make net withdrawals from storage to meet demands, it is considered to be in a shortage condition. Figure 3 gives a summary of actions under each surplus and shortage stages when an allocation plan is necessary to enforce mandatory cutbacks. The goal of the WSDM plan is to avoid Stage 6, an extreme shortage (MET, 2026b). Surplus Stages Actions Shortage Stages 4 3 2 1 1 2 3 4 5 6 Put to SWP & CRA G rou ndwater Storage Put to SWP & CRA Surface Storage Put to Conjunctive Use Groundwater Put to DWR Flexible Storage Put to Metropolitan Surface Storage Public Outreach Take from Metropolitan Surface Storage Take from SWP Groundwater Storage Takefrom Conjunctive Use Storage Takefrom SWP & CRA Surface Storage Take from DWR Flexible Storage Extraordinary Conservation Reduce IAWP Deliveries Call Options Contracts Buy Spot Transfers Implement Water SupplyAllocation Plan Potential Simultaneous Actions Source: MET, 2026. Figure 3 Resource Stages, Anticipated Actions, and Supply Declarations CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO MET's Board of Directors adopted a Water Supply Condition Framework in June 2008 to communicate the urgency of the region's water supply situation and the need for further water conservation practices. The framework has four conditions, each calling increasing levels of conservation. Descriptions for each of the four conditions are listed below: • Baseline Water Use Efficiency: Ongoing conservation, outreach, and recycling programs to achieve permanent reductions in water use and build storage reserves. ■ Condition 1 Water Supply Watch: Local agency voluntary dry -year conservation measures and use of regional storage reserves. ■ Condition 2 Water Supply Alert: Regional call for cities, counties, member agencies, and retail water agencies to implement extraordinary conservation through drought ordinances and other measures to mitigate use of storage reserves. ■ Condition 3 Water Supply Allocation: Implement MET's WSAP. As noted in Condition 3, should supplies become limited to the point where imported water demands cannot be met, MET will allocate water through the WSAP (MET, 2026a). 2.3.2 MET Water Supply Allocation Plan MET's imported supplies have been impacted by a number of water supply challenges as noted earlier. In case of extreme water shortage within the MET service area is the implementation of its WSAP. MET's Board of Directors adopted the WSAP in February 2008 to fairly distribute a limited amount of water supply and applies it through a detailed methodology to reflect a range of local conditions and needs of the region's retail water consumers (MET, 2026a). The WSAP includes the specific formula for calculating member agency supply allocations and the key implementation elements needed for administering an allocation. MET's WSAP is the foundation for the urban water shortage contingency analysis required under Water Code Section 10632 and is part of MET's 2025 UWMP. MET's WSAP was developed in consideration of the principles and guidelines in MET's 1999 WSDM Plan with the core objective of creating an equitable "needs -based allocation." The WSAP's formula seeks to balance the impacts of a shortage at the retail level while maintaining equity on the wholesale level for shortages of MET supplies of greater than 50 percent cutbacks. The formula takes into account a number of factors, such as the impact on retail customers, growth in population, changes in supply conditions, investments in local resources, demand hardening aspects of water conservation savings, recycled water, extraordinary storage and transfer actions, and groundwater imported water needs. The formula is calculated in three steps: (1) base period calculations; (2) allocation year calculations; and (3) supply allocation calculations. The first two steps involve standard computations, while the third step contains specific methodology developed for the WSAP. Step 1: Base Period Calculations - The first step in calculating a member agency's water supply allocation is to estimate their water supply and demand using a historical base period with established water supply and delivery data. The base period for each of the different categories of supply and demand is calculated using data from the two most recent non -shortage years. CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Step 2: Allocation Year Calculations - The next step in calculating the member agency's water supply allocation is estimating water needs in the allocation year. This is done by adjusting the base period estimates of retail demand for population growth and changes in local supplies. Step 3: Supply Allocation Calculations - The final step is calculating the water supply allocation for each member agency based on the allocation year water needs identified in Step 2. In order to implement the WSAP, MET's Board of Directors makes a determination on the level of the regional shortage, based on specific criteria, typically in April. The criteria used by MET includes current levels of storage, estimated water supplies conditions, and projected imported water demands. The allocations, if deemed necessary, go into effect in July of the same year and remain in effect for a 12-month period. The schedule is made at the discretion of the Board of Directors (MET, 2026b). As demonstrated by the findings in MET's 2025 UWMP, both the Water Reliability Assessment and the Drought Risk Assessment (DRA) demonstrate that MET is projecting to be able to mitigate the challenges posed by hydrologic variability, potential climate change, and regulatory risk on its imported supply sources through the significant storage capabilities it has developed over the last two decades, both dry -year and emergency storage (MET, 2026b). Although MET's 2025 UWMP forecasts that MET will be able to meet projected imported demands throughout the projected period from 2026 to 2050, uncertainty in supply conditions can result in MET needing to implement its WSAP to preserve dry -year storage and curtail demands (MET, 2026b). 2.3.3 MWDOC Water Supply Allocation Plan To prepare for the potential allocation of imported water supplies from MET, MWDOC worked collaboratively with its 27 retail agencies to develop its own WSAP that was adopted in January 2009 and amended in 2016. The MWDOC WSAP outlines how MWDOC will determine and implement each of its retail agency's allocation during a time of shortage. The MWDOC WSAP uses a similar method and approach, when reasonable, as that of the MET's WSAP. However, MWDOC's plan remains flexible to use an alternative approach when MET's method produces a significant unintended result for the member agencies. The MWDOC WSAP model follows five basic steps to determine a retail agency's imported supply allocation: Step 1: Determine Baseline Information - The first step in calculating a water supply allocation is to estimate water supply and demand using a historical base period with established water supply and delivery data. The base period for each of the different categories of demand and supply is calculated using data from the last two non -shortage years. Step 2: Establish Allocation Year Information - In this step, the model adjusts for each retail agency's water need in the allocation year. This is done by adjusting the base period estimates for increased retail water demand based on population growth and changes in local supplies. Step 3: Calculate Initial Minimum Allocation Based on MET's Declared Shortage Level - This step sets the initial water supply allocation for each retail agency. After a regional shortage level is established, MWDOC will calculate the initial allocation as a percentage of adjusted base period imported water needs within the model for each retail agency. CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Step 4: Apply Allocation Adjustments and Credits in the Areas of Retail Impacts and Conservation - In this step, the model assigns additional water to address disparate impacts at the retail level caused by an across-the-board cut of imported supplies. It also applies a conservation credit given to those agencies that have achieved additional water savings at the retail level as a result of successful implementation of water conservation devices, programs, and rate structures. Step S: Sum Total Allocations and Determine Retail Reliability - This is the final step in calculating a retail agency's total allocation for imported supplies. The model sums an agency's total imported allocation with all of the adjustments and credits and then calculates each agency's retail reliability compared to its Allocation Year Retail Demand. The MWDOC WSAP includes additional measures for plan implementation, including the following (MWDOC, 2016): Appeal Process - An appeal process to provide retail agencies the opportunity to request a change to their allocation based on new or corrected information. MWDOC anticipates that under most circumstances, a retail agency's appeal will be the basis for an appeal to MET by MWDOC. ■ Melded Allocation Surcharge Structure - At the end of the allocation year, MWDOC would only charge an allocation surcharge to each retail agency that exceeded their allocation if MWDOC exceeds its total allocation and is required to pay a surcharge to MET. MET enforces allocations to retail agencies through an allocation surcharge to a retail agency that exceeds its total annual allocation at the end of the 12-month allocation period. MWDOC's surcharge would be assessed according to the retail agency's prorated share (acre-feet [AF] over usage) of MWDOC amount with MET. Surcharge funds collected by MET will be invested in its Water Management Fund, which is used in part to fund expenditures in dry -year conservation and local resource development. ■ Tracking and Reporting Water Usage - MWDOC will provide each retail agency with water use monthly reports that will compare each retail agency's current cumulative retail usage to their allocation baseline. MWDOC will also provide quarterly reports on its cumulative retail usage versus its allocation baseline. ■ Timeline and Option to Revisit the Plan - The allocation period will cover 12 consecutive months and the Regional Shortage Level will be set for the entire allocation period. MWDOC only anticipates calling for allocation when MET declares a shortage; and no later than 30 days from MET's declaration will MWDOC announce allocation to its retail agencies. SECTION 3 WATER SHORTAGE CONTINGENCY PREPAREDNESS AND RESPONSE PLANNING The City's WSCP is a detailed guide of how the City intends to act in the case of an actual water shortage condition. The WSCP anticipates a water supply shortage and provides pre -planned guidance for managing and mitigating a shortage. Regardless of the reason for the shortage, the WSCP is based on adequate details of demand reduction and supply augmentation measures that are structured to match varying degrees of shortage to ensure the relevant stakeholders understand what to expect during a water shortage situation. CITY OF TUSTIN 10 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO 3.1 Water Supply Reliability Analysis Per Water Code Section 10632 (a)(1), the WSCP shall provide an analysis of water supply reliability conducted pursuant to Water Code Section 10635, and the key issues that may create a shortage condition when looking at the City's water asset portfolio. Understanding water supply reliability, factors that could contribute to water supply constraints, availability of alternative supplies, and what effect these have on meeting customer demands provides the City with a solid basis on which to develop appropriate and feasible response actions in the event of a water shortage. For the 2025 UWMP, the City worked collaboratively with MWDOC, OCWD, EOCWD, and MWDOC's other retail water agencies to produce long-term projected water use over the next 25 years, in five-year increments, for each agency (MWDOC, 2025). The City also conducted a DRA to evaluate a drought period that lasts five consecutive water years starting from the year following when the assessment is conducted (2026-2030). An analysis of both assessments determined that the City is capable of meeting all customers' demands from 2025 through 2050 for a normal year, a single dry year, and a drought lasting five consecutive years with significant imported water supplemental drought supplies from EOCWD/MWDOC/MET and ongoing conservation program efforts. The City has also added reliability through receiving the majority of its water supply from groundwater from the OC Basin and supplemental supplies from EOCWD/MWDOC/MET. As a result, there is no projected shortage condition due to drought that will trigger customer demand reduction actions until MWDOC and/or EOCWD notifies the City of insufficient imported supplies. More information is available in the City's 2025 UWMP (Tustin, 2026). 3.2 Annual Water Supply and Demand Assessment Procedures Per Water Code Section 10632.1, the City will conduct an AWSDA pursuant to subdivision (a) of Section 10632 and by July 1 st of each year, beginning in 2022, submit an AWSDA with information for anticipated shortage, triggered shortage response actions, compliance and enforcement actions, and communication actions consistent with the Supplier's WSCP. The City must include in its WSCP the procedures used for conducting an AWSDA. The AWSDA is a determination of the near -term outlook for supplies and demands and how a perceived shortage may relate to WSCP shortage stage response actions in the current calendar year. This determination is based on information available to the City at the time of the analysis. Starting in 2022, the AWSDA will is due by July 1 of every year. This section documents the decision -making process required for formal approval of the City's AWSDA determination of water supply reliability each year, the key data inputs and the methodologies used to evaluate the water system reliability for the coming year, while considering that the year to follow would be considered dry. 3.2.1 Decision -Making Process The following decision -making process describes the functional steps that the City will take to formally approve the AWSDA determination of water supply reliability each year. CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO 3.2.1.1 City Steps to Approve the AWSDA Determination The AWSDA will be predicated on the OCWD Basin Production Percentage (BPP) and on MWDOCs AWSDA outcomes. Figure 4 shows the AWSDA reporting timeline for the City. April/May May/June MWDOC MET WSAP WSAP & determination Annual & Assessment Annual approval Assessment approval EOCWD Annual Assessment approval OCWD BPP Projection City of Tustin Annual Assessment approval Figure 4 AWSDA Reporting Timeline July 1 July June O O Annual Implement Annual Assessment Outcomes: Assessment submission to 1.Shortage Identified: Implement WSCP DWR 2. No Shortage Identified: No action needed The City produces local groundwater from the OC Basin managed by OCWD. The OC Basin is not adjudicated and as such, pumping from the OC Basin is managed through a process that uses financial incentives to encourage Groundwater Producers (Producers) to pump a sustainable amount of water. The framework for the financial incentives is based on establishing the BPP, the percentage of each Producer's total water supply that comes from groundwater pumped from the OC Basin. The BPP is set uniformly for all Producers by the OCWD Board of Directors on an annual. Based on the projected water demand and modeled water supply, over the long-term, OCWD anticipates sustainably supporting a BPP of 85 percent; however, volumes of groundwater and imported water may vary depending on OCWD's actual BPP projections. A supply reduction that may result from the annual BPP projection will be included in the AWSDA. While the City's primary source of water is OCWD groundwater, any remaining source to meet retail demands comes from the purchase of imported water from EOCWD/MWDOC. MWDOC surveys its member agencies annually for anticipated water demands and supplies for the upcoming year. MWDOC utilizes this information to plan for the anticipated imported water supplies for the MWDOC service area. This information is then shared and coordinated with MET and is incorporated into their analysis of their service area's annual imported water needs. Based on the year's supply conditions and WSDM actions, MET will present a completed AWSDA for its member agencies' review from which they will then seek CITY OF TUSTIN 12 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Board approval in April of each year. Additionally, MET expects that any triggers or specific shortage response actions that result from the AWSDA will be approved by their Board at that time. Based upon MET's Assessment and taking into consideration information provided to MWDOC through the annual survey, MWDOC will provide an anticipated estimate of imported supplies for City to incorporate into the AWSDA. The City Manager and/or his or her designated representative shall review the AWSDAs from MET, MWDOC, and OCWD and incorporate the finding into the City's assessment. The City Manager and/or his or her designee will authorize the City's AWSDA determining specific shortage response action necessary to prudently plan for water supply needs to its customers, and/or or comply with regulations and/or restrictions implemented by the State Water Resources Control Board (SWRCB), MET, MWDOC, or OCWD. The City will formally submit assessment findings to DWR prior to the July 1 deadline. 3.2.2 Data and Methodologies The following paragraphs document the key data inputs and methodologies that are used to evaluate the water system reliability for the coming year, while considering that the year to follow would be considered d ry. 3.2.2.1 Assessment Methodology The City will evaluate water supply reliability for the current year and one dry year for the purpose of the AWSDA. The AWSDA determination will be based on considerations of unconstrained water demand, local water supplies, EOCWD/MWDOC imported water supplies, planned water use, and infrastructure considerations. The balance between projected local supplies coupled with MET imported supplies and anticipated unconstrained demand will be used to determine what, if any, shortage level is expected under the WSCP framework as presented in Figure 5. The WSCP's standard shortage levels are defined in terms of shortage percentages. Shortage percentages will be calculated by dividing the difference between water supplies and unconstrained demand by total unconstrained demand. This calculation will be performed separately for anticipated current year conditions and for assumed dry year conditions. �A Develop Water Shortage Conduct annual Contingency Plan water supply and concurrently with updated demand assessment Ordinance (to be periodically revised) Shortage identified in annual assessment t1111� �~l 001, No shortage identified in annual assessment Figure 5 Water Shortage Contingency Plan AWSDA Framework Implement- 1. Shortage response actions in WSCP 2. Compliance and enforcement actions in line with Ordinance 3. Communication actions in WSCP No further action needed that year CITY OF TUSTIN 13 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO 3.2.2.2 Locally Applicable Evaluation Criteria Within Orange County, there are no significant local applicable criteria that directly affect reliability. Through the years, the water agencies in Orange County have made tremendous efforts to integrate their systems to provide flexibility to interchange with different sources of supplies. There are emergency agreements in place to ensure all parts of the County have an adequate supply of water. In the northern part of the County, agencies have the ability to meet a majority of their demands through groundwater with very little limitation, except for the OCWD BPP. The City will also continue to monitor emerging supply and demand conditions related to supplemental imported water from MWDOC/MET and take appropriate actions consistent with the flexibility and adaptiveness inherent to the WSCP. The City's AWSDA was based on the City's service area, water sources, water supply reliability, and water use as described in Water Code Section 10631, including available data from state, regional, or local agency population, land use development, and climate change projections within the service area of the City. Some conditions that affect MWDOC's wholesale supply and demand, such as groundwater replenishment, surface water and local supply production, can differ significantly from earlier projections throughout the year. If a major earthquake on the San Andreas Fault occurs, it has the potential to damage all three key regional water aqueducts and disrupt imported supplies for up to six months. The region would likely impose a water use reduction ranging from 25-35% until the system is repaired. However, MET has taken proactive steps to handle such disruption, such as constructing DVL, and prepositioning necessary reconstruction resources to quickly recover from such a seismic event, which mitigates potential impacts. DVL, along with other local reservoirs, can store a six to twelve-month supply of emergency water (MET, 2026a). 3.2.2.3 Water Supply As detailed in the City's 2025 UWMP, the City meets its customers' demands with a combination of local groundwater from the OC Basin and imported water from EOCWD. The City's main source of water supply is groundwater, with imported water making up the rest of the City's water supply portfolio. In fiscal year (FY) 2024-25, the City relied on approximately 68 percent groundwater and 32 percent imported water. It is projected that by 2050, the City's water portfolio will change to approximately 85 percent groundwater (consistent with OCWD's long-term 85 percent BPP projection) and 15 percent imported water, and the City can purchase more MET imported water through MWDOC/OCWD should the need arise (Tustin, 2026). 3.2.2.4 Unconstrained Customer Demand The WSCP and AWSDA define unconstrained demand as expected water use prior to any projected shortage response actions that may be taken under the WSCP. Unconstrained demand is distinguished from observed demand, which may be constrained by preceding, ongoing, or future actions, such as emergency supply allocations during a multi -year drought. WSCP shortage response actions to constrain demand are inherently extraordinary; routine activities such as ongoing conservation programs and regular operational adjustments are not considered as constraints on demands. The City's DRA reveals that its supply capabilities are expected to balance anticipated total water use and supply, assuming a five-year consecutive drought from FY 2025-26 through FY 2029-30 (Tustin, 2026). CITY OF TUSTIN 14 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO This is based on the water demand projection model, in a single dry year, demand is expected to increase by 6 percent above a normal year (MWDOC, 2025). For the City, the five consecutive dry year demand scenario is based on the demand model's multiple dry year methodology. In accordance with the econometric demand model approach used to develop UWMP demand projections, a single hot/dry year was first identified based on weather conditions that produced the greatest demand response. Consecutive dry years were then represented by applying incremental scaling factors to this single hot/dry year demand to account for the compounding effects of persistent warm and dry conditions over time. These scaling factors show long-term relationships between regional water use and multi -year temperature and precipitation deficits and are applied sequentially to simulate second through fifth consecutive dry years. This approach is consistent with the demand modeling framework summarized in Chapter 7 of the City's UWMP. 3.2.2.5 Planned Water Use for Current Year Considering Dry Subsequent Year Water Code Section 10632(a)(2)(B)(ii) requires the AWSDA to determine "current year available supply, considering hydrological and regulatory conditions in the current year and one dry year." The AWSDA will include two separate estimates of City's annual water supply and unconstrained demand using: (1) current year conditions; and (2) assumed dry year conditions. Accordingly, the AWSDA's shortage analysis will present separate sets of findings for the current year and dry year scenarios. The Water Code does not specify the characteristics of a dry year, allowing discretion to the Supplier. The City will use its discretion to refine and update its assumptions for a dry year scenario in each AWSDA as information becomes available and in accordance with best management practices. Supply and demand analyses for the single -dry year case were based on conditions affecting the SWP as this supply availability fluctuates the most among MET's, and therefore MWDOC and the City's, sources of supply. Severe drought conditions in 2021-2022 affected must of the Western United States, including the Colorado River system, which caused its water supply decrease. As conditions worsened, Lake Mead and Lake Powell (the largest storage units in the system), had a combined total storage capacity of 25 percent in 2022, a significant decrease from 39 percent in 2021 (MWDOC, 2024). The Orange County Water Demand Projection Model isolated the impacts that weather and future climate can have on water demand through the use of a statistical model. The impacts of hot/dry weather conditions are reflected as a percentage increase in water demands from the normal year condition. For a single dry year condition (FY 2013-14), the model projects a 6 percent increase in demand for the OC Basin area where the City's service area is located (MWDOC, 2025). Detailed information of the model is included in the City's 2025 UWMP. The City has documented that it is 100 percent reliable for single dry year demands from 2025 through 2050 with a demand increase of 6 percent from normal demand with significant reserves held by MET, local groundwater supplies, and conservation (Tustin, 2026). 3.2.2.6 Infrastructure Considerations The AWSDA will include consideration of any infrastructure issues that may pertain to near -term water supply reliability, including repairs, construction, and environmental mitigation measures that may temporarily constrain capabilities, as well as any new projects that may add to system capacity. MWDOC closely coordinates with MET and its member agencies, including the City, on any planned infrastructure CITY OF TUSTIN 15 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO work that may impact water supply availability. Throughout each year, MET regularly carries out preventive and corrective maintenance of its facilities within the MWDOC service area that may require shutdowns to inspect and repair pipelines and facilities and support capital improvement projects. These shutdowns involve a high level of planning and coordination between MWDOC, MWDOC's member agencies, and MET to ensure that major portions of the distribution system are not out of service at the same time. Operational flexibility within MET's system and the cooperation of member agencies allow shutdowns to be successfully completed while continuing to meet all system demands. Specifically for the City, as of March 2026 there are no foreseen near -term infrastructure issues that would impact supply. 3.2.2.7 Other Factors For the AWSDA, any known issues related to water quality would be considered for their potential effects on water supply reliability. Per- and polyfluoroalkyl substances (PFAS) are a group of thousands of manmade chemicals that includes perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). PFAS compounds were once commonly used in many products including, among many others, stain- and water-repellent fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning products, and fire -fighting foams. Beginning in the summer of 2019, the California State Division of Drinking Water (DDW) began requiring testing for PFAS compounds in some groundwater production wells in the OCWD area. MET has voluntarily monitored PFAS in its source and treated waters since 2017. Most samples have shown non detect (ND) for all tested PFAS, including PFOA and PFOS. A limited number of other PFAS— such as PFHxA, PFBA, PFPeA, PFDoA, PFTA, and PFBS, have been detected only at trace levels below their method detection limits. PFOA and PFOS have not been detected in MET's imported or treated water supplies. Some member agencies, however, have detected these compounds in local groundwater wells, which may require treatment or source management to comply with emerging Division of Drinking Water (DDW) regulations. As DDW and U.S. Environmental Protection Agency (EPA) establish enforceable maximum contaminant levels (MCLs) for PFOA and PFOS, some agencies may supplement their local supplies with increased purchases of MET water (MET, 2025). EPA finalized the first national drinking water standards for six PFAS compounds in April 2024. These standards include enforceable MCLs for PFOA and PFOS set at 4 parts per trillion (ppt). In May 2025 the EPA announced that it would extend the compliance deadline for PFOA and PFOS from 2029 to 2031 to provide additional time for testing, planning, and installation of treatment technologies. While MET and its member agencies continue to monitor and test PFAS in imported and local sources, the delay in the federal compliance date allows additional time to evaluate treatment options, coordinate funding, and plan system upgrades necessary to meet forthcoming federal PFAS standards. PFAS have been detected in the OC Basin in very small amounts (parts per trillion), entering primarily via the Santa Ana River whose flows infiltrate into the basin. Despite playing no role in releasing PFAS into the environment, OCWD is working with its cities and retail water districts to remove it from local water supplies in order to comply with new state and federal regulations. More than 100 wells have been impacted due to various state and federal regulations. Fifteen impacted agencies will have to temporarily purchase more costly imported water to replace PFAS contaminated supplies. As of 2025, 53 impacted wells are back online due to close to a billion dollars being spent on state-of-the-art testing, research and CITY OF TUSTIN 16 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO piloting of different treatment systems, and design and construction of treatment plants that are now operational. 3.3 Six Standard Water Shortage Levels Per Water Code Section 10632 (a)(3)(A), the City must include the six standard water shortage levels that represent shortages from the normal reliability as determined in the AWSDA. The shortage levels have been standardized to provide a consistent regional and statewide approach to conveying the relative severity of water supply shortage conditions. This is an outgrowth of the severe statewide drought of 2012-2016, and the widely recognized public communication and state policy uncertainty associated with the many different local definitions of water shortage Levels. The six standard water shortage levels correspond to progressively increasing estimated shortage conditions (up to 10 percent, 20 percent, 30 percent, 40 percent, 50 percent, and greater than 50 percent shortage compared to the normal reliability condition) and align with the response actions the Supplier would implement to meet the severity of the impending shortages. Table 1 Cross -Reference for Standard vs Supplier Shortage Levels Submittal Table 8-1: Cross-reference for Standard vs Supplier Shortage Levels Water Code Section 10632(a)(3)(B) _ MCheck the box if the Supplier uses the Standard six levels of water shortage. Proceed to the next table. Standa d Shortage Percent Shortage Suppliers Shortage Percent Shortage evels Range Levels Range 3.4 Shortage Response Actions Water Code Section 10632 (a)(4) requires the WSCP to specify shortage response actions that align with the defined shortage levels. The City has defined specific shortage response actions that align with the defined shortage levels in DWR Tables 8-2 and 8-3 (Appendix A). These shortage response actions were developed with consideration to the system infrastructure and operations changes, supply augmentation responses, customer -class or water use -specific demand reduction initiatives, and increasingly stringent water use prohibitions. 3.4.1 Supply Augmentation The supply augmentation actions are described in DWR Table 8-3 (Appendix A). These augmentations represent short-term management objectives triggered by the MET'S WSDM Plan and do not overlap with the long-term new water supply development or supply reliability enhancement projects. Supply CITY OF TUSTIN 17 3.4 Shortage Response Actions Water Code Section 10632 (a)(4) requires the WSCP to specify shortage response actions that align with the defined shortage levels. The City has defined specific shortage response actions that align with the defined shortage levels in DWR Tables 8-2 and 8-3 (Appendix A). These shortage response actions were developed with consideration to the system infrastructure and operations changes, supply augmentation responses, customer -class or water use -specific demand reduction initiatives, and increasingly stringent water use prohibitions. 3.4.1 Supply Augmentation The supply augmentation actions are described in DWR Table 8-3 (Appendix A). These augmentations represent short-term management objectives triggered by the MET'S WSDM Plan and do not overlap with the long-term new water supply development or supply reliability enhancement projects. Supply CITY OF TUSTIN 17 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Augmentation is made available to the City through MWDOC and MET. The City relies on MET's reliability portfolio of water supply programs including existing water transfers, storage, and exchange agreements to supplement gaps in the City's supply/demand balance. MET has developed significant storage capacity (over 5 million AF) in reservoirs and groundwater banking programs both within and outside of the Southern California region. Additionally, MET can pursue additional water transfer and exchange programs with other water agencies to help mitigate supply/demand imbalances and provide additional dry -year supply sources. MWDOC, and in turn its retail agencies, including the City, has access to supply augmentation actions through MET. MET may exercise these actions based on regional need, and in accordance with their WSCP, and may include the use of supplies and storage programs within the Colorado River, SWP, and in -region storage. The City has the ability to augment its supply to reduce the shortage gap by up to 100 percent by purchasing additional imported water through MWDOC or pumping additional groundwater in the OC Basin; however, both are subject to rate penalties from MWDOC and OCWD, respectively. 3.4.2 Demand Reduction The demand reduction measures that would be implemented to address shortage levels are described in DWR Table 8-2 (Appendix A). This table indicates which actions align with specific defined shortage levels and estimates the extent to which the actions will reduce the gap between supplies and demands to deliver the outcomes necessary to meet the requirements of a given shortage level. This table also identifies the enforcement action, if any, associated with each demand reduction measure. 3.4.3 Operational Changes During shortage conditions, operations may be affected by supply augmentation or demand reduction responses. The City will consider their operational procedures when it completes its AWSDA or as needed to identify changes that can be implemented to address water shortage on a short-term basis. The City can alter maintenance cycles, such as system flushing, and defer planned construction activities and capital improvement projects to limit or defer planned system outages; however the City is limited by groundwater pumping approvals. 3.4.4 Additional Mandatory Restrictions Water Code Section 10632(a)(4)(D) calls for "additional, mandatory prohibitions against specific water use practices that are in addition to state -mandated prohibitions and appropriate to the local conditions" to be included among the WSCP's shortage response actions. The City will identify additional mandatory restrictions as needed based on the existing Tustin Municipal Code Chapter 10 Water Management Plan (Appendix B). The City intends to update any mandatory restrictions in a subsequently adopted ordinance which will supersede the existing ordinance. 3.4.5 Emergency Response Plan (Hazard Mitigation Plan) A catastrophic water shortage would be addressed according to the appropriate water shortage level and response actions. It is likely that a catastrophic shortage would immediately trigger Shortage Level 6 and response actions have been put in place to mitigate a catastrophic shortage. In addition, there are several CITY OF TUSTIN 18 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Plans that address catastrophic failures and align with the WSCP, including MET's WDSM and WSAP, the City's Local Hazard Mitigation Plan (LHMP), and the Water Emergency Response Organization of Orange County (WEROC)'s Emergency Operations Plan (EOP). 3.4.5.1 MET's WSDM and WSAP MET has comprehensive plans for stages of actions it would undertake to address a catastrophic interruption in water supplies through its WSDM and WSAP. MET also developed an Emergency Storage Requirement to mitigate against potential interruption in water supplies resulting from catastrophic occurrences within the Southern California region, including seismic events along the San Andreas Fault. In addition, MET is working with the state to implement a comprehensive improvement plan to address catastrophic occurrences outside of the Southern California region, such as a maximum probable seismic event in the Sacramento -San Joaquin River Delta that would cause levee failure and disruption of SWP deliveries. 3.4.5.2 Water Emergency Response Organization of Orange County Emergency Operations Plan In 1983, the Orange County water community identified a need to develop a plan on how agencies would respond effectively to disasters impacting the regional water distribution system. The collective efforts of these agencies resulted in the formation of WEROC to coordinate emergency response on behalf of all Orange County water and wastewater agencies, develop an emergency plan to respond to disasters, and conduct disaster training exercises for the Orange County water community. WEROC, administered by MWDOC, was established through the creation of an indemnification agreement among its member agencies to protect each other against civil liabilities and to facilitate the exchange of resources. WEROC is unique in its ability to provide a single point of contact for the representation of all water and wastewater utilities in Orange County during a disaster. This representation is to the county, state, and federal disaster coordination agencies. Within the Orange County Operational Area, WEROC is the recognized contact for emergency response for the water community, including the City. As a member of WEROC, the City will follow WEROC's EOP in the event of an emergency and coordinate with WEROC to assess damage, initiate repairs, and request and coordinate mutual aid resources in the event that the City is unable to provide the level of emergency response support required by the situation. The EOP defines the actions to be taken by WEROC Emergency Operations Center (EOC) staff to reduce the loss of water and wastewater infrastructure; to respond effectively to a disaster; and to coordinate recovery operations in the aftermath of any emergency involving extensive damage to Orange County water and wastewater utilities. The EOP includes activation notification protocol that will be used to contact partner agencies to inform them of the situation, activation status of the EOC, known damage or impacts, or resource needs. The EOP is a standalone document that is reviewed annually and approved by the MWDOC Board every three years. WEROC is organized on the basis that each member agency is responsible for developing its own EOP in accordance with the California Standardized Emergency Management System (SEMS), National Incident Management System (NIMS), and Public Health Security and Bioterrorism Preparedness and Response Act of 2002 to meet specific emergency needs within its service area. CITY OF TUSTIN 19 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO The WEROC EOC is responsible for assessing the overall condition and status of the Orange County regional water distribution and wastewater collection systems including MET facilities that serve Orange County. The EOC can be activated during an emergency situation resulting from both natural and man- made causes, and can be activated through automatic, manual, or standby for activation. WEROC recognizes four primary phases of emergency management, which include: ■ Preparedness: Planning, training, and exercises that are conducted prior to an emergency to support and enhance response to an emergency or disaster. • Response: Activities and programs designed to address the immediate and short-term effects of the onset of an emergency or disaster that helps to reduce effects on water infrastructure and speed recovery. This includes alert and notification, EOC activation, direction and control, and mutual aid. ■ Recovery: This phase involved restoring systems to normal, in which short-term recovery actions are taken to assess the damage and return vital life-support systems to minimum operating standards, while long-term recovery actions have the potential to continue for many years. ■ Mitigation/Prevention: These actions prevent the occurrence of an emergency or reduce the area's vulnerability in ways that minimize the adverse impacts of a disaster or emergency. The EOC Action Plans provide frameworks for EOC staff to respond to different situations with the objectives and steps required to complete them, which will in turn serve the WEROC member agencies. In the event of an emergency that results in a catastrophic water shortage, the City will declare a water shortage condition of up to Level 3 for the impacted area depending on the severity of the event, and coordination with WEROC is anticipated to begin at Level 4 or greater (WEROC, 2021). 3.4.5.3 City of Tustin's Emergency Response Plan The City will also refer to its current American Water Infrastructure Act Risk and Resilience Assessment and Emergency Response Plan in the event of a catastrophic supply interruption (Tustin, 2025). 3.4.6 Seismic Risk Assessment and Mitigation Plan Per the Water Code Section 10632.5, Suppliers are required to assess seismic risk to water supplies as part of their WSCP. The plan also must include the mitigation plan for the seismic risk(s). Given the great distances that imported supplies travel to reach Orange County, the region is vulnerable to interruptions along hundreds of miles of aqueducts, pipelines and other facilities associated with delivering the supplies to the region. Additionally, the infrastructure in place to deliver supplies is susceptible to damage from earthquakes and other disasters. In lieu of conducting a seismic risk assessment specific to the City's 2025 UWMP, the City has included their LHMP, as required under the federal Disaster Mitigation Act of 2000 (Public Law 106-390). The LHMP describes the City's approach to proactively decreasing threats before disaster occurs, including water supply specific mitigation actions such as improving security and alert systems, upgrading back-up power systems, and retrofitting existing flood control infrastructure. (Tustin, 2019). CITY OF TUSTIN 20 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO 3.4.7 Shortage Response Action Effectiveness For each specific Shortage Response Action identified in the plan, the WSCP also estimates the extent to which that action will reduce the gap between supplies and demands identified in DWR Tables 8-2 and 8-3 (Appendix A). To the extent feasible, the City has estimated percentage savings for the chosen suite of shortage response actions, which can be anticipated to deliver the expected outcomes necessary to meet the requirements of a given shortage level. 3.5 Communication Protocols Timely and effective communication is a key element of the WSCP implementation. In the context of water shortage response, the purpose may be an emergency water shortage situation, such as may result from an earthquake, or a longer -term, non -emergency, shortage condition, such as may result from a drought. In an emergency, the City will activate the communication protocol detailed in the Emergency Response Plan. In a non -emergency water shortage situation, the City will implement the communication protocols described below. Per the Water Code Section 10632 (a)(5), the City has established communication protocols and procedures to inform customers, the public, interested parties, and local, regional, and state governments regarding any current or predicted shortages as determined by the AWSDA described pursuant to Section 10632.1; any shortage response actions triggered or anticipated to be triggered by the annual water supply and demand assessment described pursuant to Section 10632.1; and any other relevant communications. Non -emergency water shortage communication protocols are focused on communicating the water shortage contingency planning actions that can be derived from the results of the AWSDA, and it would likely trigger based upon the decision -making process in Section 3.2. Prior to water shortage level declaration, the City will pursue outreach to inform customers of water shortage levels and definitions, targeted water savings for each drought stage, guidelines that customers are to follow during each stage, and sources of current information on the City's supply and demand response status. The type and degree of communication will vary with each shortage level in order to inform stakeholders of the current water shortage level status and associated shortage response actions, as defined in Section 3.4.1. Predefined communication objectives and tools will ensure the City's ability to message necessary events and information to ensure compliance with shortage response actions. These communication objectives and tools are summarized in Table 2. The City's Public Relations department will lead public information and outreach efforts in close coordination with other MWDOC and MET. The City will share information and provide guidance to its customers as well as monitor the customer response and attitude toward both voluntary and mandatory customer response guidelines. The City's customer outreach is required to successfully achieve targeted water savings during each shortage level. CITY OF TUSTIN 21 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Table 2 Communication Objectives and Tools During a Water Shortage Compliance with response actions, Social media outreach, water billing inserts, City webpage, 10% reduction in water use wastewater patrols, partnership supporting regional outreach messaging. Compliance with response actions, ■ Social media outreach, water billing inserts, City webpage, 20% reduction in water use wastewater patrols, partnership supporting regional outreach messaging. Compliance with response actions, ■ Social media outreach, direct mail communications, City 30% reduction in water use webpage, wastewater patrols, partnership supporting regional outreach through MWDOC and MET. Direct communication with higher water users, and CII customers. Compliance with response actions, ■ Social media outreach, direct mail communications, City 40% reduction in water use webpage, wastewater patrols, partnership supporting regional outreach through MWDOC and MET. Direct communication with higher water users, and CII customers. Compliance with response actions, ■ Social media outreach, direct mail communications, City 50% reduction in water use webpage, wastewater patrols, partnership supporting regional outreach through MWDOC and MET. Direct communication with higher water users, and CII customers. Compliance with response actions, ■ Social media outreach, direct mail communications, City >50% reduction in water use webpage, wastewater patrols, partnership supporting regional outreach through MWDOC and MET. Direct communication with higher water users, and CII customers. 3.6 Compliance and Enforcement Per the Water Code Section 10632 (a)(6), the City has defined customer compliance, enforcement, appeal, and exemption procedures for triggered shortage response actions. Communication procedures to ensure customer compliance are described in Section 3.5 Communication Protocols and customer enforcement, appeal, and exemption procedures are defined in the existing Tustin Municipal Code Chapter 10 Water Management Plan (Appendix B). The City intends to update any enforcement procedures in a subsequently adopted ordinance which will supersede the existing ordinance. 3.7 Legal Authorities Per Water Code Section 10632 (a)(7)(A), the City has provided a description of the legal authorities that empower the City to implement and enforce its shortage response in the Tustin Municipal Code Chapter 10 Water Management Plan (Appendix B). The City intends to update any legal authorities in a subsequently adopted ordinance which will supersede the existing ordinance. Per Water Code Section 10632 (a)(7) (B), the City shall declare a water shortage emergency condition to prevail within the area served by such wholesaler whenever it finds and determines that the ordinary demands and requirements of water consumers cannot be satisfied without depleting the water supply of the distributor to the extent that there would be insufficient water for human consumption, sanitation, and fire protection. CITY OF TUSTIN 22 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Per Water Code Section 10632 (a)(7)(C), the City shall coordinate with any agency or county within which it provides water supply services for the possible proclamation of a local emergency under California Government Code, California Emergency Services Act (Article 2, Section 8558). Table 3 identifies the contacts for all cities or counties for which the Supplier provides service in the WSCP, along with developed coordination protocols, can facilitate compliance with this section of the Water Code in the event of a local emergency as defined in subpart (c) of Government Code Section 8558. Table 3 Agency Contacts and Coordination Protocols ContactA•- Board of Supervisors County of Orange City Manager City of Tustin City Council City of Tustin 3.8 Financial Consequences of WSCP Memo In Person/Call/Email Memo/Council Meeting Per Water Code Section 10632(a)(8), Suppliers must include a description of the overall anticipated financial consequences to the Supplier of implementing the WSCP. This description must include potential reductions in revenue and increased expenses associated with implementation of the shortage response actions. This should be coupled with an identification of the anticipated mitigation actions needed to address these financial impacts. During a catastrophic interruption of water supplies, prolonged drought, or water shortage of any kind, the City will experience a reduction in revenue due to reduced water sales. Throughout this period of time, expenditures may increase or decrease with varying circumstances. Expenditures may increase in the event of significant damage to the water system, resulting in emergency repairs. Expenditures may also decrease as less water is pumped through the system, resulting in lower power costs. Water shortage mitigation actions will also impact revenues and require additional costs for drought response activities such as increased staff costs for tracking, reporting, and communications. The City receives water revenue from a service charge and a commodity charge based on consumption. The service charge recovers costs associated with providing water to the serviced property. The service charge does not vary with consumption and the commodity charge is based on water usage. Rates have been designed to recover the full cost of water service in the charges. Therefore, the total cost of purchasing water would decrease as the usage or sale of water decreases. In the event of a drought emergency, the City will impose excessive water use penalties on its customers, which may include additional costs associated with reduced water revenue, staff time taken for penalty enforcement, and advertising the excessive use penalties. The excessive water use penalties are further described in the City's Municipal Code Chapter 10 Water Management Plan (Appendix B). However, there are significant fixed costs associated with maintaining a minimal level of service. The City will monitor projected revenues and expenditures should an extreme shortage and a large reduction in water sales occur for an extended period of time. To overcome these potential revenue losses and/or expenditure impacts, the City may use reserves. If necessary, the City may reduce expenditures by delaying implementation of its Capital Improvement Program and equipment purchases to reallocate funds to cover the cost of operations and critical maintenance, adjust the work force, implement a drought surcharge, and/or make adjustments to its water rate structure. CITY OF TUSTIN 23 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Based on current water rates, a volumetric cutback of 50 percent and above of water sales may lead to a range of reduction in revenues. The impacts to revenues will depend on a proportionate reduction in variable costs related to supply, pumping, and treatment for the specific shortage event. The City has set aside reserve funding to mitigate a short-term water shortage situation. 3.9 Monitoring and Reporting Per Water Code Section 10632(a)(9), the City is required to provide a description of the monitoring and reporting requirements and procedures that have been implemented to ensure appropriate data is collected, tracked, and analyzed for purposes of monitoring customer compliance and to meet state reporting requirements. Monitoring and reporting key water use metrics is fundamental to water supply planning and management. Monitoring is also essential in times of water shortage to ensure that the response actions are achieving their intended water use reduction purposes, or if improvements or new actions need to be considered (see Section 3.10). Monitoring for customer compliance tracking is also useful in enforcement actions. Under normal water supply conditions, potable water production figures are recorded daily, and monthly reports are prepared and monitored. This data will be used to measure the effectiveness of any water shortage contingency level that may be implemented. As levels of water shortage are declared by MET and MWDOC, the City will follow implementation of those levels as appropriate based on the City's risk profile provided in UWMP Chapter 6 and continue to monitor water demand levels. When MET calls for extraordinary conservation, MET's Drought Program Officer will coordinate public information activities with MWDOC and monitor the effectiveness of ongoing conservation programs. The City will participate in monthly member agency manager meetings with both MWDOC and OCWD to monitor and discuss monthly water allocation charts. This will enable the City to be aware of imported and groundwater use on a timely basis as a result of specific actions taken responding to the City's WSCP. 3.10 WSCP Refinement Procedures Per Water Code Section 10632 (a)(10), the City must provide reevaluation and improvement procedures for systematically monitoring and evaluating the functionality of the water shortage contingency plan in order to ensure shortage risk tolerance is adequate and appropriate water shortage mitigation strategies are implemented as needed. The City's WSCP is prepared and implemented as an adaptive management plan. The City will use the monitoring and reporting process defined in Section 3.9 to refine the WSCP. In addition, if certain procedural refinements or new actions are identified by City staff, or suggested by customers or other interested parties, the City will evaluate their effectiveness, incorporate them into the WSCP, and implement them quickly at the appropriate water shortage level. It is envisioned that the WSCP will be periodically re-evaluated to ensure that its shortage risk tolerance is adequate and the shortage response actions are effective and up to date based on lessons learned from implementing the WSCP. The WSCP will be revised and updated during the UWMP update cycle to incorporate updated and new information. For example, new supply augmentation actions will be added, and actions that are no longer applicable for reasons such as program expiration will be removed. CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO However, if revisions to the WSCP are warranted before the UWMP is updated, the WSCP will be updated outside of the UWMP update cycle. In the course of preparing the AWSDA each year, City staff will routinely consider the functionality of the overall WSCP and will prepare recommendations for City Council if changes are found to be needed. 3.11 Special Water Feature Distinction Per Water Code Section 10632 (b), the City has defined water features in that are artificially supplied with water, including ponds, lakes, waterfalls, and fountains, separately from swimming pools and spas, as defined in subdivision (a) of Section 115921 of the Health and Safety Code, in the Tustin Municipal Code Chapter 10 Water Management Plan (Appendix B). 3.12 Plan Adoption, Submittal, and Availability Per Water Code Section 10632 (a)(c), the City provided notice of the availability of the Public Review Draft 2025 UWMP and 2025 WSCP and notice of the public hearing to consider adoption of the WSCP. The Public Review Drafts of the 2025 UWMP and the 2025 WSCP were posted prominently on the City's website in advance of the public hearing on June 16, 2026. Copies of the Draft WSCP were also made available for public inspection at the City Clerk's and Utilities Department offices and public hearing notifications were published in local newspapers. A copy of the published Notice of Public Hearing is included in Appendix D. The City held the public hearing for the Draft 2025 UWMP and Draft WSCP on June 16, 2026, at the City Council meeting. The City Council reviewed and approved the 2025 UWMP and the WSCP at its June 16, 2026 meeting after the public hearing. See Appendix E for the resolution approving the WSCP. By July 1, 2026, the City's adopted 2025 UWMP and WSCP was filed with DWR, California State Library, and the County of Orange. The City will make the WSCP available for public review on its website no later than 30 days after filing with DWR. Based on DWR's review of the WSCP, the City will make any amendments to its adopted WSCP, as required and directed by DWR. If the City revises its WSCP after the UWMP is approved by DWR, then an electronic copy of the revised WSCP will be submitted to DWR within 30 days of its adoption. CITY OF TUSTIN 25 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO SECTION 4 REFERENCES City of Tustin. (2026). 2025 Urban Water Management Plan. City of Tustin. (2019). City of Tustin Local Hazard Mitigation Plan. Metropolitan Water District of Southern California (MET). (2026a). 2025 Water Shortage Contingency Plan. Metropolitan Water District of Southern California (MET). (2026b). 2025 Urban Water Management Plan. Municipal Water District of Orange County. (2023, July). 2023 Orange County Water Reliability Study. Municipal Water District of Orange County. (2024). Multi -Jurisdictional Hazard Mitigation Plan. Municipal Water District of Orange County. (2025, December 30). Orange County Water Demand Projection Model Technical Memorandum. Water Emergency Response Organization of Orange County (WEROC). (2025). WEROC 2025 Annual Report. CITY OF TUSTIN 26 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO APPENDIX DWR SUBMITTAL TABLES CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Submittal Table 8-1: Cross Reference for Standard vs Supplier Shortage Level Submittal Table 8-1: Cross-reference for Standard vs Supplier Shortage Levels Water Code Section 10632(a)(3)(B) Check the boxes if the Supplier uses the Standard six levels of water shortage. Proceed to the next table. Standard Shortage Percent Shortage I Suppliers Shortage Percent Shortage Levels Range Levels Range Submittal Table 8-2: Supply Augmentation and Other Actions Submittal Table Submittal Table 8-2: Supply Augmentation and Other Actions Submittal Table 8-2 Retail: Supply Augmentation and Other Actionsmp 0 Water Code Section 10632(a)(4)(A),(C) YesIs the Suppliercompleting . Supply Augmentation Methods b- using the standard six levels? (yes/no) I How much ii0o and Other Actions by Water s Shortage Supplier Additional Explanation or Level Drop down list . - . Reference These are the only categories - - (OPTIONAL) that will be accepted by the WUEdata online submittal tool Add additional rows as needed 1 through 6 Other Purchases Percentage 0 -100% Additional imported water purchases through MWDOC Additional groundwater pumping 1 through 6 Other Purchases Percentage 0 -100% in the Orange County Groundwater Basin DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. NOTES: Additional imported water and groundwater pumping may be subject to rate penalties from MWDOC and OCWD, respectively. CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Submittal Table 8-3: Demand Reduction Actions Submittal Table 8-3 Retail: Demand Reduction Actions Water ••- Section 10632(a)(4)(B)and YesIs the Supplier• • - • this table using the standard • Demand Reduction Actions How much is this going to reduce the shortage gap? Penalty, Charge, or Drop down list . - Other Enforcement? Shortage These are the only categories that will be ' -' •- Additional ExplanationReference For Retail Suppliers - - - , • - - • - - - • - Level (OPTIONAL)) accepted by the WUEdata online submittal Only tool. Select those that apply. " " (AF) Drop Down List Add additional rows as needed 0 Other water feature or swimming pool Statewide Prohibition is Required The operation of any ornamental fountain or similar structure is prohibited unless the foundation or structure internally Yes restriction recycles the water it uses. 0 Other - Prohibit vehicle washing except at Statewide Prohibition is Required Washing or hosing down vehicles is prohibited except by use of a handheld container, hand hose equipped with a positive Yes facilities using recycled or recirculating water shut off nozzle, or at a commercial car wash. Further, such washing is exempted from these regulations where health, safety, and welfare of the public is contingent upon frequent vehicle cleaning such as a garbage truck and vehicles used to transport food and perishables. 0 Other - Prohibit use of potable water for Statewide Prohibition is Required Washing hard or paved surfaces is prohibited except to alleviate safety or sanitary hazards using a handheld container, Yes washing hard surfaces hose with an automatic shut off device, or a low -volume high pressure cleaning machine that recycles used water. 0 Landscape - Restrict or prohibit runoff from Statewide Prohibition is Required Watering vegetated areas in a manner that causes excessive water flow or runoff onto an adjoining sidewalk, driveway, Yes landscape irrigation street, alley, gutter, or ditch is prohibited. 0 Landscape - Other landscape restriction or Statewide Prohibition is Required No landscape watering shall occur within 48 hours after measurable precipitation. "Measurable precipitation" shall mean a Yes prohibition one -quarter inch or more of rainfall within the City of Tustin within a twenty -four-hour period. 0 Landscape - Limit landscape irrigation to On -going Long -Term Conservation Savings Measure. Between April 1 and October 31, lawn watering and landscape irrigation will be limited to 4 days per week. Watering and Yes specific days Not applicable to Water Shortage Contingency Plan irrigation may only occur on Sunday, Tuesday, Thursday, and Saturday. Between November 1 and March 31, lawn quantifiable savings. watering and landscape irrigation will be further limited to 3 days per week. Watering and irrigation may only occur on Tuesday, Thursday, and Saturday. 0 Landscape - Limit landscape irrigation to On -going Long -Term Conservation Savings Measure. Watering or irrigation with a device that is not continuously attended to is limited to 5 minutes per valve, per irrigation day. Yes specific times Not applicable to Water Shortage Contingency Plan Low flow drip type systems, water efficient stream rotor systems, and sensor/weather-controlled systems shall be limited to quantifiable savings. 15 minutes per valve, per irrigation day. 0 Landscape - Limit landscape irrigation to On -going Long -Term Conservation Savings Measure. Watering or irrigation of vegetated areas is prohibited between 8:00 a.m. and 4:00 p.m. except for when adjusting or Yes specific times Not applicable to Water Shortage Contingency Plan repairing an irrigation system for short periods of time. quantifiable savings. 0 Other - Customers must repair leaks, breaks, On -going Long -Term Conservation Savings Measure. Fix all water leaks or faulty sprinklers immediately upon notification. Yes and malfunctions in a timely manner Not applicable to Water Shortage Contingency Plan quantifiable savings. 0 CII - Restaurants may only serve water upon On -going Long -Term Conservation Savings Measure. CII - Restaurants may only serve water upon request Yes request Not applicable to Water Shortage Contingency Plan quantifiable savings. 0 CII - Lodging establishment must offer opt out On -going Long -Term Conservation Savings Measure. CII - Lodging establishment must offer opt out of linen service and shall prominently display notice of this options in each Yes of linen service Not applicable to Water Shortage Contingency Plan guestroom quantifiable savings. 0 CII - Other CII restriction or prohibition On -going Long -Term Conservation Savings Measure. CII - Watering parks, school grounds, public facilities, and recreational fields are not permitted between the hours of 8:00 Yes Not applicable to Water Shortage Contingency Plan a.m. and 4:00 p.m. quantifiable savings. CITY OF TUSTIN A-2 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Submittal Table 8-3 Retail: Demand Reduction Actions Water ••- Section 10632(a)(4)(B)and YesIs the Supplier• • - • this table using the standard • Demand Reduction Actions How much is this going to reduce the shortage gap? Penalty, Charge, or Shortage Drop down list These are the only categories that will be • - • • , • Reduction Additional Explanation or Reference Other Enforcement? For Retail Suppliers Level accepted by the WUEdata online submittal � . , range) (OPTIONAL) Only tool. Select those that apply. Drop down (AF) Drop Down List 0 Landscape - Other landscape restriction or On -going Long -Term Conservation Savings Measure. Customers that utilize turf for beneficial public use may apply for an exemption from the permanent water restriction Yes prohibition Not applicable to Water Shortage Contingency Plan schedule. A Water Management Plan shall be provided that demonstrates specific actions that will be taken to manage quantifiable savings. potable water use within the guidelines, requirements, and conservation standards set by the State Water Resources Control Board or City. Designated irrigation schedules shall remain in effect until the City has reviewed and approved the customers' water management plan. Exemptions may be revoked if customer does not comply or meet their defined conservation goals within the approved plan. 1 Expand Public Information Campaign Percentage 0-1% Community Outreach and Messaging (Expand Public Information Campaign) 1 Expand Public Information Campaign Percentage 0-1 % Encourage customers to wash only full loads when washing dishes or clothes. 1 Expand Public Information Campaign Percentage 0-1 % Encourage customers to use pool covers to minimize evaporation. 1 Landscape - Limit landscape irrigation to Percentage 5-10% Between April 1 and October 31, lawn watering and landscape irrigation will be limited to 4 days per week. Watering and Yes specific days irrigation may only occur on Sunday, Tuesday, Thursday, and Saturday. Between November 1 and March 31, lawn watering and landscape irrigation will be further limited to 3 days per week. Watering and irrigation may only occur on Tuesday, Thursday, and Saturday. 1 Landscape - Limit landscape irrigation to Percentage 0-5% Watering or irrigation with a device that is not continuously attended to is limited to 5 minutes per valve, per irrigation day. Yes specific times Low flow drip type systems, water efficient stream rotor systems, and sensor/weather-controlled systems shall be limited to 15 minutes per valve, per irrigation day. 1 Provide Rebates for Landscape Irrigation Percentage 0-1 % Expanded/Enhanced Rebate Programs offered through Municipal Water District of Orange County Efficiency 1 Offer Water Use Surveys Percentage 0-1 % Offer Water Use Surveys 1 Provide Rebates on Plumbing Fixtures and Percentage 0-1 % Rebates on Plumbing Fixtures and Devices may be offered through Municipal Water District of Orange County Devices 1 Provide Rebates for Turf Replacement Percentage 0-1 % Rebates for Turf Replacement may be offered through Municipal Water District of Orange County 1 Increase Water Waste Patrols Percentage 0-1 % Increase Water Waste Patrols 2 Landscape - Limit landscape irrigation to Percentage 5-10% Between April 1 and October 31, lawn watering and landscape irrigation will be limited to 3 days per week. Watering and Yes specific days irrigation may only occur on Tuesday, Thursday, and Saturday. Between November 1 and March 31, lawn watering and landscape irrigation will be further limited to 2 days per week. Watering and irrigation may only occur on Tuesday and Saturday. 2 Water Features - Restrict water use for Percentage 0-1 % Filling or refilling ornamental lakes and ponds with potable water is prohibited. Ornamental lakes and ponds that sustain decorative water features, such as fountains aquatic life of significant value and were actively managed prior to the storage declaration are exempt. 2 Decrease Line Flushing Percentage 0-1 % Decrease distribution system flushing 2 Pools - Allow filling of swimming pools only Percentage 0-1 % Swimming pools may only be filled when an appropriate cover is in place. when an appropriate cover is in place. 2 Increase Water Waste Patrols Percentage 0-1 % Increase Water Waste Patrols 3 Pools - Allow filling of swimming pools only Percentage 0-1 % Existing pools shall not be emptied and refilled using potable water unless required for public health and safety purposes. Yes when an appropriate cover is in place. Swimming pools utilizing a cover may be topped off to prevent damage to pump and filter equipment. 3 Other water feature or swimming pool Percentage 0-1 % Decorative water features that use potable water must be drained and kept dry. restriction CITY OF TUSTIN A-3 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Submittal Table 8-3 Retail: Demand Reduction Actions Water ••- Section 10632(a)(4)(B)and YesIs the Supplier• • - • this table using the standard • Demand Reduction Actions How much is this going to reduce the shortage gap? Penalty, Charge, or Shortage Drop down list Volume ,g. ,, -.dAdditional Explanation or Reference Other Enforcement? Level These are the only categories that will be ___ . ,range) (OPTIONAL) For Retail Suppliers accepted by the WUEdata online submittal Only tool. Select those that apply. Drop " (AF) Drop Down List 3 Other - Prohibit vehicle washing except at Percentage 0-1 % Car washing is only permitted using a commercial carwash that recirculates water or by high pressure/low volume wash facilities using recycled or recirculating water systems. 3 Landscape - Limit landscape irrigation to Percentage 5-10% Between April 1 and October 31, lawn watering and landscape irrigation will be limited to 2 days per week. Watering and Yes specific days irrigation may only occur on Tuesday and Saturday. Between November 1 and March 31, lawn watering and landscape irrigation will be further limited to 1 day per week. Watering and irrigation may only occur on Tuesday. 3 Increase Water Waste Patrols Percentage 0-1 % Increase Water Waste Patrols 4 Other water feature or swimming pool Percentage 0-1 % Pools shall not be emptied and refilled using potable water unless required for public health and safety purposes. Yes restriction 4 Landscape - Limit landscape irrigation to Percentage 5-10% Lawn watering and landscape irrigation will be limited to 1 day per week. Watering and irrigation may only occur on Yes specific days Tuesday. 4 Other - Prohibit vehicle washing except at Percentage 0-1 % Washing of autos, trucks, mobile homes, buses, trailers, boats, airplanes, and any other type of mobile equipment is Yes facilities using recycled or recirculating water prohibited. Washing is permitted at any time on the immediate premise of a commercial car wash. The use of water by all types of commercial car washes not using partially reclaimed or recycled water shall reduce water use in volume by twenty percent. 4 Landscape - Limit landscape irrigation to Percentage 0-1 % Agriculture users and commercial nurseries shall use water only between hours of 6:00 p.m. and 6:00 a.m. and may be Yes specific times subject to additional restrictions if the state, regional, or city jurisdiction deems necessary. The City will make good faith efforts to inform agricultural users and commercial nurseries of any such restrictions. Monetary penalties will be passed through to agricultural and commercial nursery customers, if assessed by the State Water Resources Control Board, Metropolitan Water District of Southern California, or Municipal Water District of Orange County. 4 Water Features - Restrict water use for Percentage 0-1 % The operation of any ornamental fountain or similar structure is prohibited, even when recycled water is used. Yes decorative water features, such as fountains 4 Other - Prohibit use of potable water for Percentage 0-1 % Construction water shall not be used for earthwork or road construction purposes unless authorized as a mitigation, erosion Yes construction and dust control control, compaction, or backfilling work or as required by the Air Quality Management Plan Control Measure F-4. 4 CII - Other CI I restriction or prohibition Percentage 0-1 % The use of water for commercial, industrial, institutional, manufacturing, or processing purposes shall be essential use only. Yes All outdoor irrigation is prohibited. 4 Increase Water Waste Patrols Percentage 0-1 % Increase Water Waste Patrols 5 Other Percentage 0-1 % Water for agricultural or commercial nursery purposes, except for livestock watering, is prohibited. Yes 5 Landscape - Prohibit all landscape irrigation Percentage 5-10% All outdoor irrigation is prohibited. Yes 5 Landscape - Prohibit certain types of Percentage 0-1 % Watering of all golf course areas is prohibited with the exception of plant material, or turf classified to be rare or Yes landscape irrigation exceptionally valuable. 5 Landscape - Prohibit certain types of Percentage 0-1 % Watering of parks, school grounds, public facilities, and recreation fields is prohibited with the exception of plant material Yes landscape irrigation classified to be rare, exceptionally valuable, or essential to the wellbeing of rare animals. 5 Moratorium or Net Zero Demand Increase on Percentage 0-1 % Moratorium or Net Zero Demand Increase on New Connections. Construction meters or permits for new water service Yes New Connections connections will not be issued. 5 Other Percentage 0-1 % Water use from fire hydrants shall be limited to firefighting or related activities necessary to maintain public health, safety, Yes and welfare of the public. CITY OF TUSTIN A-4 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO Submittal Table 8-3 Retail: Demand Reduction Actions Water ••- Section 10632(a)(4)(B)and YesIs the Supplier• • - • this table using the standard • Demand Reduction Actions How much is this going to reduce the shortage gap? Penalty, Charge, or Shortage Drop down list Volume ' Shortage ' • Reduction Additional Explanation or Reference Other Enforcement? Level These are the only categories that will be Percentage _ range) � � � (OPTIONAL) For Retail Suppliers accepted by the WUEdata online submittal Only tool. Select those that apply. Drop down (AF) Drop Down List 5 Other - Prohibit vehicle washing except at Percentage 0-1 % Commercial car washing facilities shall reduce water usage by a volume of fifty percent. Yes facilities using recycled or recirculating water 5 Increase Water Waste Patrols Percentage 0-1 % Increase Water Waste Patrols Yes 6 Other Percentage 0-1 % Water for air conditioning is prohibited Yes 6 Landscape - Prohibit all landscape irrigation Percentage 0-5% All irrigation is prohibited. The City may shut off all non -essential water services. Yes 6 CII - Other CII restriction or prohibition Percentage 0-15% Water for commercial, manufacturing, or processing purposes shall be reduced in volume by up to 50% or exceeded if Yes necessary for public health and safety purposes. 6 Other Percentage 0-70% Water use for public health and safety purposes only. Customer rationing may be implemented. Yes DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3. NOTES: CITY OF TUSTIN A-5 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO APPENDIX TUSTIN MUNICIPAL CODE CHAPTER 10 WATER MANAGEMENT PLAN Below is the weblink to the current ordinance (last accessed on May 12, 2026): https:Hlibrary.municode.com/ca/tustin/codes/code of ordinances?nodeld=ART4HESA CH10WAMAPL CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO APPENDIX NOTICE OF PUBLIC HEARING (PENDING) CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 2025 WATER SHORTAGE CONTINGENCY PLAN MAY 2026 / FINAL DRAFT / CAROLLO APPENDIX ADOPTED WSCP RESOLUTION (PENDING) CITY OF TUSTIN Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 ATTACHMENT 2 Resolution No. 26-33 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 RESOLUTION NO. 26-33 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF TUSTIN, CALIFORNIA ADOPTING THE 2025 WATER SHORTAGE CONTINGENCY PLAN WHEREAS, the California Urban Water Management Planning Act (California Water Code Sections 10610 et seq.) requires urban water suppliers to prepare and adopt an Urban Water Management Plan and Water Shortage Contingency Plan every five years; and WHEREAS, California Water Code Section 10632 specifically requires urban water suppliers to adopt a Water Shortage Contingency Plan that establishes response actions and planning procedures for water shortage conditions; and WHEREAS, the City of Tustin ("City") has prepared the 2025 Water Shortage Contingency Plan ("WSCP") in compliance with the requirements of California Water Code Section 10632; and WHEREAS, the 2025 WSCP establishes procedures for conducting Annual Water Supply and Demand Assessments, identifies six standard water shortage levels, and outlines shortage response actions, communication procedures, enforcement provisions, monitoring requirements, and emergency response coordination measures; and WHEREAS, the 2025 WSCP was developed in coordination with regional water agencies, including the Metropolitan Water District of Southern California, Municipal Water District of Orange County, East Orange County Water District, and Orange County Water District; and WHEREAS, the City Council conducted a duly noticed public hearing regarding the proposed 2025 Water Shortage Contingency Plan on June 16, 2026, in accordance with California Water Code requirements; and WHEREAS, the City Council has reviewed and considered the 2025 Water Shortage Contingency Plan and all testimony and information presented at the public hearing. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF TUSTIN DOES RESOLVE AS FOLLOWS: SECTION 1. The City Council hereby finds that the foregoing recitals are true and correct and are incorporated herein by this reference. SECTION 2. The City Council hereby adopts the City of Tustin 2025 Water Shortage Contingency Plan attached hereto and incorporated herein by reference. Resolution 26-33 Page 1 of 3 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 SECTION 3. The City Council authorizes the City Manager, or designee, to make non -substantive corrections, revisions, or formatting changes to the Plan as necessary for final publication and submittal to the California Department of Water Resources. SECTION 4. The City Clerk shall certify as to the adoption of this Resolution. PASSED AND ADOPTED at a regular meeting of the City Council of the City of Tustin held on the 16t" day of June 2026. AUSTIN LUMBARD, Mayor ATTEST: ERICA N. YASUDA, City Clerk APPROVED AS TO FORM: `31-kc DAVID E. KENDIG, City Attorney /msd/ Resolution 26-33 Page 2 of 3 Docusign Envelope ID: 358C2907-8737-8327-823E-C74D6AE09DF2 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) SS CITY OF TUSTIN ) I, Erica N. Yasuda, City Clerk and ex-officio Clerk of the City Council of the City of Tustin, California, do hereby certify that the whole number of the members of the City Council is five; that the above and foregoing Resolution No. 26-33 was duly and regularly passed and adopted at a regular meeting of the City Council held on the 16t" day of June, 2026 by the following vote: COUNCILMEMBER AYES: COUNCILMEMBER NOES: COUNCILMEMBER ABSTAINED: COUNCILMEMBER ABSENT: ERICA N. YASUDA City Clerk Resolution 26-33 Page 3 of 3