“There is more than enough information available for the Board to adopt scientifically justified, more protective new standards,” the letters state
Wednesday, 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
