New Fully Appropriated Stream Systems (FASS) Web Map Tool

The State Water Resources Control Board, Division of Water Rights (Division) has released an interactive GIS web map for representing Fully Appropriated Stream Systems (FASS) in California. The web map provides access to FASS and related information, including seasonal limitations, court references, and Board decisions all in one place and within a geospatial context. The web map can be found at the following web address:

The Division is planning to host a webinar on the new tool in mid-December, and will follow up with additional information on the time and date of that webinar in the near future. More information can be found on the Division’s Fully Appropriated Stream Systems webpage.

Action: Send Letter to Maui County for polluting Groundwater and Ocean Beaches

Below is a sample letter to send to the Environmental Program of Maui County expressing outrage for continuing to pollute or simply a statement of not visiting until pollution of groundwater and ocean is stopped and the Clean Water Act is followed.

Dear Environmental Coordinator: I am outraged by the continued pollution from treated wastewater that is impacting groundwater and ocean beaches in your area. You need to adhere to the lower and appeal’s court decision to require a permit that would regulate this activity to safeguard water and its environment. Furthermore, any future plans to visit this area would be avoided and spent elsewhere. Pollution of waters in its jurisdiction is not something a tourist destination like Maui County wants visitors to be thinking about never mind spending time there. Get the “paradise” back into Maui County. Thank you.

Use the above sample language to modify your own message and copy and paste to send via your email program to the Environmental Coodinator:

Protecting Species under Groundwater Management

Dear Groundwater Colleagues,

The Nature Conservancy is pleased to announce the release of the Critical Species LookBook (the LookBook) which may be found on the Groundwater Resource Hub. The LookBook is a compendium of 84 state and federally listed species likely to be affected by groundwater management and merit consideration by Groundwater Sustainability Agencies (GSAs) under the Sustainable Groundwater Management Act (SGMA). Consistent with SGMA’s emphasis on local control, the LookBook is designed to inform local planning and decision-making.

The goal of the LookBook is to synthesize the best available groundwater-relevant information for each species to ensure that their water needs are adequately considered when developing Groundwater Sustainability Plans (GSPs). The LookBook was developed with expert opinion and review from more than 90 professionals at federal and state agencies, academia, technical consultancy firms, NGOs, and local water agencies with either an expertise in a particular species or in water management.

Please download the PDF version of the LookBook. Should you have any questions regarding information in the LookBook, please contact Ruthie Redmond (

TNC wishes to thank the California Department of Fish and Wildlife, UC Davis, the National Marine Fisheries Service, and Audubon for their invaluable contributions to the LookBook.

Thank you,

Sandi Matsumoto

Associate Director

California Water Program

Public Comment and Board Workshop on Safe and Affordable Drinking Water

There is an opportunity for Public Comment and Board Workshop on the Draft Administrator Policy Handbook for Safe and Affordable Drinking Water.

This on Russian River Watershed Pathogen Total Maximum Daily Load (TMDL) & Prohibition against the Discharge of Fecal Waste Materials

The Board Workshop is scheduled for August 21, 2019

Comment Deadline is September 4, 2019 by 12 noon.

Russian River TMDLs

Russian River Watershed Pathogen Prohibition of Discharge of Fecal Waste Materials

AUGUST 14, 2019 BEGINNING SOON AFTER 8:30 AM. 5550 Skylane Blvd., Santa Rosa, near the Sonoma County Airport.

This action will provide the basis for new septic management requirements. For instance:
Septic inspections by a qualified expert will need to take place every five years.

Cesspools will no longer be allowed, although if use is not expanded, low income people can put off changes for up to 15 years. Etc.
Most lower river septic owners will be affected by this new regulation, especially in Monte Rio and Villa Grande.
More stringent rules will apply to properties within 600’ of the Russian River or blue stream tributaries (even if only part of your property is within 600’). This may include supplementary treatment if soils are found to be inadequate at filtering pathogens.

The approved documents are subject to review by other State Agencies and nothing will be considered final all approvals are received, which is expected to be about a year from now. Timelines will kick in at that point.

Thanks for supporting the lower Russian River and RRWPC’s work.

There is information on live-streaming this meeting if you can’t attend in person in the Regional Board notice.

Brenda Adelman
Russian River Watershed Protection Committee

Newly Appointed Coastal Commissioner

Very good news. Kevin de Leon did make some very good appointments.


From Annie Notthof on the NRDC Web Site:

“Congratulations to my friend and colleague Linda Escalante, NRDC’s Southern California Legislative Director, for being appointed to the California Coastal Commission by Assembly Speaker Anthony Rendon. Linda has been standing up for clean water, clean air and environmental justice for over a decade. As an alternate Commissioner, appointed by former CA Senate President pro Tem Kevin de Le??n, for the past year, she has been a standout bridge builder and has a clear vision of the next era of coastal protection.”

Commissioner Escalante replaces outgoing Commissioner Mark Vargas.


About TMDLs

Russian River Interested Parties

Included (below) are some ideas and thoughts regarding the regulatory structure and review standards for this project.,

The Russian River TMDL and Implementation Plan is a CEQA based process. The Regional and State Board process is a Certified Regulatory Program (no full EIR is necessary – though compliance with CEQA standards are mandated by State Resources Code. Thus, there must be a full description of the project (environmental setting), potential impacts and outcomes, discussion of remedies to limit impacts provided – including the full range of feasible alternatives (the argument that some CEQA responsibilities can be ignored – as this project is improving environmental outcomes – does not stand) – and findings that logically support conclusions must be presented. Additionally, the agency must respond to all reasonable comments.

In my review of previous TMDLs and Implementation (Action) Plans – the RB does not always comply with the CEQA mandates – nor does the RB meet all requirement of Cal Water Code.

Not only is the TMDL and Implementation Plan a project under CEQA, it is a Water Quality Control Plan (and must meet the requirements of same under Cal Water Code 13242).

Cal Water Code (Section 13242) – Requirements of a Water Quality Control Plan (summarized):

Note: Impairment by listed pollutants – means – not meeting Water Quality Objectives (in the Basin Plan) + not meeting Beneficial Uses (= Water Quality Standards are not being met).
Thus – TMDL must identify sources of pollutants (and attach weighted responsibility to the sources), TMDL must establish acceptable levels of pollutants and the amount of specific pollutant reduction from the various sources need to attain Water Quality Standards (WQS).

A Water Quality Control Plan must:

1.) Describe all actions necessary to attain WQS

2). Have an Implementation Schedule for the employment of the noted actions (this schedule must be sufficient to attain WQS in a reasonable period of time)

3) There must be monitoring and adaptive feedback mechanism in place to assure effectiveness and compliance.

Thus all sources must be noted and controlled to the extent the reasonable progress of attainment of WQS will occur (and demonstrated by monitoring results – and – must be reasonably capable of attainment of acceptable results).

Review State Non-Point Source Policy for other requirements (that may apply) Note: NPS Policy is in the Basin Plan and, thus, enforceable.

If the above is not extant – and – the TMDL and Implementation Plan does not meet the above noted requirements – it must be noted in comments to the RB (to preserve legal standing).

Reliance on actions as yet to be defined or described (differred mitigations) are not acceptable under Cal Water Code and/or CEQA.

It is best to have some expert opinion in the file supporting your arguments on issues – and/or – peer review.

The EPA must approve the TMDL

The State Board must approve the TMDL and Implementation Plan (thus two shots at making your point – so – you may get a chance of going to Sacramento)

Finally – if there are issues – they must be submitted to the State Board – prior to any potential litigation (exhaust administrative remedies). If the State Board does not act in 180 days – then you have 30 days (I think) to file litigation.

Hopefully there will not be any problems (though I have seen that to occur).