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Indybay Feature

Broad Coalition Urges State, Feds to Update Bay-Delta Water Quality Plan

by Dan Bacher
The coalition wrote, "The Board is required under federal and state law to review the WQCP every three years. The latest delay would in essence start the 3-year clock ticking again, after six years of work. Water quality conditions in the estuary are simply too urgent to allow for such a delay. There is more than enough information available for the Board to adopt scientifically justified, more protective new standards in the next twelve to twenty-one months. We are united in urging you to take the information before you and make a decision as soon as possible."

Photo of State Water Resources Control Board Members. From left to right: Dorene D'Adamo; Vice Chair Frances Spivy-Weber; Chair Felicia Marcus; Steven Moore, and Tam Doduc.
wb_group2013sept.jpg
A large coalition of over 150 conservation, fishing, recreational, and tribal organizations on April 5 sent letters to the California State Water Resources Control Board and to the U.S. Environmental Protection Agency regarding California’s failure to update Bay-Delta Water Quality Standards.

The letter was sent as Governor Jerry Brown’s California Water Fix plan to build the massive Delta Tunnels is in complete chaos while the economic, scientific and financial justifications for the project become increasingly untenable.

The San Francisco Bay Delta ecosystem is now in an unprecedented crisis as winter-run Chinook salmon, Delta and longfin smelt, and other fish species draw closer and closer to the abyss of extinction under the current water quality standards.

The letter states, “There is no dispute in the scientific or resource management communities that the current water quality standards are failing to protect fish and wildlife and other beneficial uses of the estuary’s water. The record is strong and clear that insufficient freshwater flows and inadequate water quality are primary drivers of the long-term degradation of ecological conditions for the public trust resources of the Bay-Delta estuary, and this state of affairs is only growing worse. The decline of pelagic organisms that was first detected in the early 2000s has accelerated, with many native fish species at record or near-record low population levels in recent surveys.”

Below are the two letters:

April 5, 2016

Felicia Marcus, Chair State Water Resources Control Board P.O. Box 2000 Sacramento, CA 95812-2000

RE: ADOPT NEW BAY-DELTA STANDARDS IN NEXT 12-21 MONTHS

Dear Chairwoman Marcus:

Our organizations are writing to urge the State Water Resources Control Board to complete its update of the 2006 Water Quality Control Plan (WQCP) for the San Francisco Bay-Delta Estuary and adopt new water quality standards in the next twelve to twenty-one months.

There is no dispute in the scientific or resource management communities that the current water quality standards are failing to protect fish and wildlife and other beneficial uses of the estuary’s water. The record is strong and clear that insufficient freshwater flows and inadequate water quality are primary drivers of the long-term degradation of ecological conditions for the public trust resources of the Bay-Delta estuary, and this state of affairs is only growing worse. The decline of pelagic organisms that was first detected in the early 2000s has accelerated, with many native fish species at record or near-record low population levels in recent surveys.

Yet the Board has not substantively or comprehensively updated the current water quality standards for the Bay-Delta estuary since 1995. The Board initiated its current review of the standards in 2009, but six years later has yet to adopt any amendments to the WQCP. Instead of adopting new protections, in fact, the Board relaxed standards over the last two years, completely devastating several year classes of multiple Chinook salmon runs, risking extinction of some native fish species, and causing significant injury to other fish and wildlife beneficial uses. Recently, the Board again revised its schedule for completing the WQCP update, this latest delay to mid-2018.

The Board is required under federal and state law to review the WQCP every three years. The latest delay would in essence start the 3-year clock ticking again, after six years of work. Water quality conditions in the estuary are simply too urgent to allow for such a delay. There is more than enough information available for the Board to adopt scientifically justified, more protective new standards in the next twelve to twenty-one months. We are united in urging you to take the information before you and make a decision as soon as possible.

Sincerely,

(see list below)

---

April 5, 2016

Jared Blumenfeld, Regional Administrator Region IX, U.S. Environmental Protection Agency 75 Hawthorne Street San Francisco, CA 94105

RE: STATE OF CALIFORNIA’S FAILURE TO REVIEW AND AMEND BAY-DELTA WATER QUALITY STANDARDS

Dear Regional Administrator Blumenfeld:

Our organizations are writing to urge the U.S. Environmental Protection Agency to initiate proceedings to develop and adopt sufficiently protective new water quality standards for the San Francisco Bay-Delta Estuary, in light of the continuing failure of the California State Water Resources Control Board to do so, as required under the Clean Water Act.

There is no dispute in the scientific or resource management communities that the current water quality standards in the 2006 Bay-Delta Water Quality Control Plan (WQCP) are failing to protect fish and wildlife and other beneficial uses of the estuary’s water. The record is strong and clear that insufficient freshwater flows and inadequate water quality are primary drivers of the long-term degradation of ecological conditions for the public trust resources of the Bay-Delta estuary, and this state of affairs is only growing worse. The decline of pelagic organisms that was first detected in the early 2000s has accelerated, with many native fish species at record or near- record low population levels in recent surveys.

Yet the State of California has not substantively or comprehensively updated the current water quality standards for the Bay-Delta estuary since 1995. The Board initiated its current review of the standards in 2009, but six years later has yet to adopt any amendments to the WQCP. Instead of adopting new protections, in fact, the Board relaxed standards over the last two years, completely devastating several year classes of multiple Chinook salmon runs, risking extinction of some native fish species, and causing significant injury to other fish and wildlife beneficial uses. Recently, the Board again revised its schedule for completing the WQCP update, this latest delay to mid-to-late 2018.

The Board is required under federal and state law to review the WQCP every three years. The latest delay would in essence start the 3-year clock ticking again, after six years of work. Water quality conditions in the estuary are simply too urgent to allow for such a delay. Given the existence of an extensive record on which to base action and the State of California’s continuing failure to use that information to take action, we are writing to urge US EPA to initiate the process of adopting scientifically justified, more protective new standards, with an end-date of final action by the end of 2017.

Sincerely,

Adam Stern Executive Director Acterra: Action for a Healthy Planet

Jeff Miller Director Alameda Creek Alliance

Lynette Kofinow SF Chapter Representative American Cetacean Society, SF Bay Chapter

Dave Steindorf California Stewardship Director American Whitewater

Steve Welch General Manager ARTA River Trips

Marily Woodhouse Director Battle Creek Alliance

Gary Bobker Program Director The Bay Institute

Carol Perkins Water Policy Advocate Butte Environmental Council

Bill Wells Executive Director California Delta Chambers & Visitors Bureau

Bill Jennings Executive Director California Sportfishing Protection Alliance

David Shugar Development Committee Chair California Student Sustainability Coalition

Patty Clary Executive Director Californians for Alternatives to Toxics

Katelyn Roedner Sutter San Joaquin Regional Director Catholic Charities, Diocese of Stockton

Steve Rothert California Director American Rivers

Barbara Vlamis Executive Director AquAlliance

Hengsothea Ung Program Manager Asian Pacific Self Development and Residential Association (APSARA)

David Loeb Executive Director Bay Nature

Joan Herskowtz Conservation Chair Buena Vista Audubon Society

Keith Miller President California Canoe & Kayak

Lloyd Carter President California Save Our Streams Council

Jim Cox President California Striped Bass Association

Carolee Krieger Executive Director California Water Impact Network

Sarah Aird Acting Executive Director Californians for Pesticide Reform

Jeff Miller Conservation Advocate Center for Biological Diversity

Christopher Lim Executive Director Central Coast Salmon Enhancement

John Buckley Executive Director Central Sierra Environmental Resource Center

Florence LaRiviere Chairperson Citizens Committee to Complete the Refuge

Jennifer Clary Water Program Manager Clean Water Action

Bill Loyko President Concerned Citizens Coalition of Stockton

Dan Randall Owner Current Adventures

Ken Scheiddeger Owner Delta Boat Works

Siobahn Dolan Director Desal Response Group

Linda Sheehan Executive Director Earth Law Center

Melinda DeVincenzi Advisor East County Student Anglers

Fred Evanson Director Ecological Rights Foundation

Tom Parrington President Central Sierra Audubon Society

Chris Conrad President Central Valley Bird Club

Jeff Kellogg President Clavey Paddlesports

Alan Levine Director Coast Action Group

Eddie Kurtz Executive Director Courage Campaign

Rachel Zwillinger Water Policy Director Defenders of Wildlife

Ron Forbes Conservation Chair Delta Fly Fishers

Nate Knodt Facilitator Downtown Comeback Club of Stockton

Trent W. Orr Staff Attorney Earthjustice

Susan Robinson Vice Chairperson Ebbetts Pass Forest Watch

Dan Silver Executive Director Endangered Habitats League

Mark Rockwell California State Representative Endangered Species Coalition

Colin Bailey Executive Director Environmental Justice Coalition for Water

Connor Everts Facilitator Environmental Water Caucus

Dan Bacher Managing Editor Fish Sniffer

Lowell Asbaugh Conservation VP Fly Fishers of Davis

Adam Scow California Director Food & Water Watch

Paul Hughes Executive Director Forests Forever

Alan Harthorn Executive Director Friends of Butte Creek

Michael Garabedian President Friends of the North Fork American River

Mitch Avalon President Friends of the San Francisco Estuary

Roger Thomas President Golden Gate Fisherman’s Association

Caryn Mandelbaum Freshwater Program Director Environment Now

Natalynne DeLapp Executive Director Environmental Protection Information Center

Crystal Sanders Founder Fish Revolution

Trevor Kennedy President Fishery Foundation of California

Chuck Hammerstad Conservation Chair Flycasters of San Jose

Cecily Smith Executive Director Foothill Conservancy

Jim Linburg Legislative Director Friends Committee on Legislation of California

Scott Greacen Executive Director Friends of the Eel River

Eric Wesselman Executive Director Friends of the River

Les McCabe President Global Green USA

John McManus Executive Director Golden Gate Salmon Association

Cindy Charles Conservation Director Golden West Women Flyfishers

Douglas Wilhoit President & CEO Greater Stockton Chamber of Commerce

John Hocevar Ocean Team Leader Greenpeace

Pennie Opal Plant Co-Founder Idle No More SF Bay

Peter Bosshard Executive Director International Rivers

Ger Vang Executive Director Lao Family Community Empowerment, Inc.

Helen Hutchison President League of Women Voters of California

Bruce Reznik Executive Director Los Angeles Waterkeeper

Gordon Beebe President Madrone Audubon Society

Kate Powers President Marin Conservation League

Jefferson Greywolf-Kelly Chief Modoc Nation

Mel Odemar Vice President, Conservation Chair Granite Bay Flycasters

Constance Higdon Gannon Executive Director Green Space

Jennifer Kalt Director Humboldt Baykeeper

Pietro Parravano President Institute for Fisheries Resources

Konrad Fisher Riverkeeper Klamath Riverkeeper

Daniel Cooper Co-Founder & Attorney Lawyers for Clean Water

Osha Meserve General Counsel Local Agencies of the North Delta

Roger Mammon President Lower Sherman Island Duck Hunters Association

Barbara Salzman President Marin Audubon Society

Michael Martin, Ph.D. Director Merced River Conservation Committee

Steve Shimek Coastkeeper Monterey Coastkeeper

Jim Edgar President Mount Diablo Audubon Society

Doug Obegi Staff Attorney Natural Resource Defense Council

Anna Swenson Action Committee North Delta CARES

Larry Glass President Northcoast Environmental Center

Larry Hanson Manager Northern California River Watch

Tim Sloane Executive Director Pacific Coast Federation of Fisherman’s Associations

John Tobin Conservation Chair Pasadena Casting Club

David Keller Executive Director Petaluma River Council

John Hooper Co-Founder Protect Our Water

Roberta Lyons President Redbud Audubon Society

Ken Scheiddeger Owner River Boat Marina

Melissa Samet Senior Water Resources Counsel National Wildlife Federation

Jay Ziegler Director of External Affairs and Policy The Nature Conservancy

Jim Ricker President North Fork American River Alliance

Lowell Asbaugh Conservation Vice President Northern California Council International Federation of Fly Fishers

Steve Shimek Executive Director The Otter Project

Greg Haller Conservation Director Pacific Rivers Council

Jack Ellwanger President Pelican Network

Jonas Minton Water Policy Advisor Planning and Conservation League

Michael Warburton Executive Director Public Trust Alliance

Barbara Barrigan-Parrilla Executive Director Restore the Delta

Katherine Baer Director of Science and Policy River Network

Megan Isadore Executive Director River Otter Ecology Project

Tim Little Executive Director The Rose Foundation

Lucas Ray RossMerz Executive Director Sacramento River Preservation Trust

Todd Steiner Executive Director Salmon Protection and Watershed Network

David S. Kossack, Ph.D. President San Andreas Land Conservancy

Larry Collins President San Francisco Crab Boat Owners Association

Steve Mayo Project Manager San Joaquin Council of Governments

Sally Shanks Treasurer Sandhill Crane Festival

Stephen Green President Save the American River

Janet McCleery President Save the California Delta Alliance

Ara Marderrosian Forestkeeper Sequoia Forestkeeper

Dan Randall Owner The River Store

Don McEnhill Executive Director Russian Riverkeeper

Larry Glass Executive Director Safe Alternatives for our Forest Environment

Jessie Raeder Board President SalmonAID

Sejal Choski Executive Director San Francisco Baykeeper

Matt Ryan President San Francisco Herring Association

Lynn Plambeck President Santa Clarita Organization for Planning and the Environment

Jack Sanchez President Save Auburn Ravine Salmon & Steelhead

David Lewis Executive Director Save the Bay

Katherine O’Dea Executive Director Save Our Shores

Kyle Jones Policy Advocate Sierra Club California

Marty McDonnell President Sierra Mac River Trips

Greg King Executive Director Siskiyou Land Conservancy

David Keller Board Chair Sonoma County Conservation Action

John Herrick General Counsel South Delta Water Agency

Caleb Dardick Executive Director South Yuba River Citizens League

Jennifer Savage California Policy Manager Surfrider Foundation

Chandra Ferrari Water Policy Advisor/Staff Attorney Trout Unlimited

Jason Weiner Coastkeeper Ventura Coastkeeper

Brent Plater Executive Director Wild Equity Institute

Mati Waiya Executive Director Wishtoyo Foundation

Elizabeth Lasensky Council Co-Chair Yolo MoveOn

Peter Van Zant Executive Director Sierra Nevada Alliance

Don Marshall President Small Boat Commercial Salmon Fisherman’s Association

Richard Dale Executive Director Sonoma Ecology Center

Michael Schweit President Southwest Council, International Federation of Fly Fishers

Conner Everts Executive Director Southern California Watershed Alliance

Donna Olsen Chair Tri-City Ecology Center

Peter Drekmeier Policy Director Tuolumne River Trust

Dick Pool President Water4Fish

Caleen Sisk Spiritual Leader & Tribal Chief Winnemen Wintu Tribe

Heidi Perryman, Ph.D. President Worth a Dam
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