Public Utilities Department

December 20, 2023

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460

Re: Request for Information Regarding Products and Categories of Products Used in Water
Infrastructure Programs - Docket ID EPA-HQ-OW-2023-0396

The City of San Diego Public Utilities Department appreciates the opportunity to provide our
insights on water infrastructure projects, aiming to support the successful implementation
of the Build America Buy America Act (BABA) and facilitate streamlined water infrastructure
development.

The City of San Diego Public Utilities Department (City) provides water services for 1.4
million customers and wastewater services for 2.2 million customers. The City owns and
operates three drinking water treatment plants, three wastewater treatment plants, and one
biosolids facility.

The City is currently constructing California’s first indirect potable reuse reservoir
augmentation project, Pure Water San Diego (Pure Water). Pure Water is a phased, multi-
year program that will provide nearly half of San Diego's water supply locally (83 million
gallons per day) by the end of 2035.

Drawing from our experience in Phase 1 of Pure Water, we have identified a list of products
that may pose challenges for future water infrastructure projects due to the BABA domestic
sourcing requirements. The products listed below were not manufactured in the United
States and/or are steel products that we have received American Iron and Steel waivers for:

• Key Adjustable Speed Drives

• Submersible horizontal axial flow pumps
• Master Control Stations
• Ozone Equipment
• UV Equipment
• Electrical Steel
• Small Bore stainless steel tubing and various fittings
• Small Diameter SST valves
• Dewatering Centrifuges
• Blowers
• Aeration Equipment
• Swing Check Valves
• Globe Valves (4”)
• Pressure release valves
• 60” DI flanges
• 4” Backflow Preventor

9192 Topaz Way, M.S. 901A

San Diego, CA 92123
www.sandiego.gov/publicutilities 858-292-6436
sandiego.gov
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RFI Regarding Products and Categories of Products Used in Water Infrastructure Programs
Docket ID EPA–HQ–OW–2023–0396
December 20, 2023

• Stainless Steel Wedge Anchors

• Pressure Reducer valves
• Manual ball valves
• C900 Bell Restraints
• Compressor Motors

We value the opportunity to share our insights to support BABA domestic sourcing eforts
and inform EPA’s interim waiver process as domestic production continues to expand.

Sincerely,

Juan Guerreiro
Director
City of San Diego
Public Utilities Department

cc: Kris McFadden, Deputy Chief Operating O�cer, City of San Diego
Adrian Granda, Director, Government Afairs
Walter Bishop, Deputy Director, Government Afairs
Randy Wilde, Senior Policy Advisor, O�ce of the Mayor
Lisa Celaya, Executive Assistant Director, Public Utilities Department
Ally Berenter, Program Manager, Public Utilities Department
Katie Keach, Program Coordinator, Public Utilities Department