Large coalition of interest groups send letters to State Water Board and US EPA urging the feds to step in and set new Bay-Delta water quality standards by the end of 2017

Delta generic header water quality
“There is more than enough information available for the Board to adopt scientifically justified, more protective new standards,” the letters state

open_letter_with_arrow_around_it_9212Wednesday, a large coalition of conservation, fishing, recreational, and tribal organizations sent letters to the State Water Resources Control Board and to the U.S. Environmental Protection Agency, urging completion of the Bay Delta’s water quality control plan by the end of 2017, and asking the feds to step in should the state fail to do so.

Signatories to the letters are too numerous to list here (full list is below), but include AquAlliance, the Bay Institute, CSPA, C-WIN, Clean Water Action, Environmental Water Caucus, Friends of the SF Estuary, Environment Now, Friends of the River, NRDC, the Nature Conservancy, Planning and Conservation League, Restore the Delta, and Trout Unlimited, as well as numerous tribes, fishermen’s associations, and conservation organizations.

The letter points out that the State Water Board is required under federal and state law to review the Bay-Delta’s water quality control plan every three years, yet despite worsening conditions, the State Water Board has not updated the water quality standards for the Bay-Delta since 1995.

The letters state:

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.”

The latest review of the water quality control plan was initiated in 2009, but the Board has yet to adopt any amendments, and in fact, has relaxed the standards over the last two years to the detriment of the Bay-Delta’s endangered and other native species; now with the latest timeline for completion of the water quality control plan extending in mid-2018, water quality conditions in the estuary are simply too urgent to allow for such a delay, the letters state.

The coalition writes in their letter to Felicia Marcus at the State Water Board that there is more than enough information available for the Board to adopt scientifically justified, more protective new standards and they urge the Board to complete their work by the end of 2017.

To Jared Blumenfeld with the US EPA, they ask the US EPA to initiate the process of adopting new protective standards for the Bay-Delta by the end of 2017.

Read the letters below:

April 5, 2016

Felicia Marcus, Chair
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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