Monthly Archive for March, 2008

Free Webcast: Monitoring Watershed Program Effective

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Free Webcast: Monitoring Watershed Program Effective

Monitoring Watershed Program Effectiveness
Thursday April 10, 2:00 – 4:00 p.m. Eastern

This EPA sponsored Watershed Academy webcast will address evaluating the
results of our efforts to control nonpoint source pollution on a
watershed basis.

Three types of data are needed to evaluate watershed management
projects: administrative, social, and environmental. Effectiveness
monitoring is designed to measure the actual impact of management
decisions, such as implementation of nutrient management practies
(administrative, social) and resulting impacts of nutrient levels
(environmental) in the waterbody. Instructors will preesent an overview
of watershed monitoring, three watershed effectiveness monitoring
designs, and identify issues to be considered when developing
effectiveness monitoring programs.

Instructors: Steven A. Dressing and Donald W. Meals, senior scientists,
Tetra Tech, inc.

Registration opens April 3. You must register in advance to
participate. To register, visit www.clu-in.org/live. Upon
registration, you will receive complete participation instructions.

After the webcast, an audio version will be available; visit
www.epa.gov/watershedwebcasts for more information.

This message was forwarded by:

Erick Burres
Citizen Monitoring Coordinator
SWRCB- Clean Water Team

Visit the Clean Water Team at:
http://www.waterboards.ca.gov/nps/volunteer.html

You can self-subscribe to the Clean Water Team’s E-Mailing List. To subscribe visit
http://www.waterboards.ca.gov/lyrisforms/swrcb_subscribe.html and check the box marked
Citizen Monitoring Program/Clean Water Team.

Contact me at:
Desk (213) 576-6788
Cell (213) 712-6862
Fax (213) 576-6686

LA-RWQCB
320 West 4th Street, Suite 200
Los Angeles, CA

IRWP NOTICE OF PUBLIC HEARINGS AND AVAILABILITY OF DRAFT EIRs

Just in case you did not receive this here you go.

Have a wonderful weekend,
Rue

Incremental Recycled Water Program (IRWP) Update
March 14, 2007

As of today, the City of Santa Rosa has made available for public review a
Draft Environmental Impact Report (EIR) for the Incremental Recycled Water
Program¹s (IRWP) Discharge Compliance Project (DCP). On March 25th the Seasonal Storage Project _reports.aspx> (SSP) Draft EIR will also be available. Information about
the DCP and SSP, and the availability of their Draft EIRs follows below.
These documents are being provided within a close time frame to allow for
the opportunity to cross reference them, in response to input we have
received from the public.

Key Dates in the Process Discharge Compliance Project Seasonal Storage Project:
Release of Draft EIR March 14, 2008 March 25, 2008 Draft EIR Public Review Period March 14 – May 6 March 25 – May 14 Draft EIR Public Hearing Date April 3, 2008 April 17, 2008

Each of the public hearings will be held before the Board of Public Utilities (BPU) at 5:00 PM in the Santa Rosa Council Chamber, 100 Santa Rosa Avenue, Santa Rosa. Oral and/or written comments on the Draft EIRs can be made or submitted to the BPU at that time. All interested persons are invited to appear at the hearings and be heard on the proposed Draft EIRs.

Written comments on the Draft EIRs will be accepted by the City until 5:00 PM on the final dates of their respective public review periods, as noted above. All written comments should be sent to: Glen Wright, City of Santa Rosa, 69 Stony Circle, Santa Rosa, CA 95401, Fax: 707-543-3936, E-Mail:
irwp@SRCity.org.

COPIES OF THE DCP and SSP DRAFT EIRs WILL BE AVAILABLE Both Draft EIRs are available for review at Sonoma County Branch Libraries in Santa Rosa, Rohnert Park/Cotati, Sebastopol, and Windsor and on the project Web site at www.SRCity.org/IRWP . The DCP Draft EIR is also available at the libraries in Cloverdale, Guerneville, Healdsburg, Occidental, Petaluma, Forestville and Lakeport. The Draft EIRs, appendices and reference material cited in the Draft EIRs will also be available for review at the Laguna Plant Library, located at 4300 Llano Road, Santa Rosa. Draft EIR hard copies, summary hard copies, and CDs of the Draft EIRs will be available for purchase by calling ARC at 707-579-9096.

Please contact our office if you have any questions. Additional information is also available at: IRWP (http://www.SRCity.org/IRWP).

Mark Millan
Public Information Coordinator
www.SRCity.org/IRWP
707.836.0300

Wetland and Riparian Resolution Change

I thought this might be of interest. I’ll let you know when Bruce Ho is going to make his Water Quality Control Boards’ (Districts I and II) presentation on riparian studies – if you are interested. It should be sometime in April, before he leaves us for the east coast.

Have a wonderful St. Patrick’s Day,
Rue

———-
The attached Changed Wetland and Riparian Area Resolution will be presented as item 11 on the State Water Board’s March 18th Agenda. This item will not be heard until after 1 PM. The resolution was changed in response to comments received.

Bill Orme
Senior Environmental Scientist
401 Certification and Wetlands Unit
Division of Water Quality
State Water Resources Control Board
1001 I Street
Sacramento, CA. 95814
Voice 916-341-5464
Fax 916-341-5470
Email
borme@waterboards.ca.gov

Healdsburg Wastewater Ruling Could Have Statewide Impact

By BOB NORBERG
THE PRESS DEMOCRAT

Following a loss in the U.S. Supreme Court, Healdsburg must stop discharging wastewater year-round into an old quarry pit next to the Russian River.

Arial photo

“It was a victory for the environment,” said Charles Tebbutt of Eugene, Ore., an attorney for Northern California River Watch, which brought suit against Healdsburg in 2001.

The decision, described by city officials as potentially precedent-setting, establishes that the Healdsburg quarry pits are subject to the federal Clean Water Act because of their proximity to the Russian River.

“From a legal perspective, it is very important; from an environmental perspective, it is very important,” Tebbutt said.

The Supreme Court on Tuesday declined to review decisions by federal courts in San Francisco that said Healdsburg’s discharges into Basalt Pond are subject to the Clean Water Act.

“That ruling, although specific for Healdsburg, is precedent-setting,” said Mike Kirn, the city’s public works director, who added that it could become the basis for decisions about wastewater storage by regional water quality control boards across the state.

“It would not surprise me if that becomes the barometer for the other regional boards to prepare waste discharge requirements and conditions,” he said.

It’s an important decision, said David Leland, the chief of watershed protection for the North Coast Water Quality Control Board, a state agency with regulatory oversight authority of wastewater discharges.

“It interprets a piece of the law that has been under challenge,” he said. “What are the waters of the United States? Is the Basalt Pond, which Healdsburg was arguing was separate from the river, part of the Russian River? The court ruled it was functionally part of the river.”

Leland said the ruling means the city has to comply with regulations of the Clean Water Act, which require a higher standard of treatment to discharge into the Basalt Pond and will eliminate summer discharges.

Healdsburg already was on track to meet water treatment requirements. The city is finishing a $32 million treatment plant and has received permits from the water board. The plant will be operating by May 1, the deadline to increase its level of treatment.

To eliminate summer discharges into the pond, the city is planning to spend $10 million to $14 million to irrigate city parks, playgrounds and the city golf course, Kirn said. That program needs to be in place by the summer of 2010.

That raises the possibility of sewage rate hikes, Kirn said.

“The city and its ratepayers have taken on a tremendous fiscal responsibility to build a new plant, and our average users’ rates are among the highest in the state, $80 a month,” Kirn said. “The rates will probably have to go up another $20 a month . . . We could be over $100 a month for our users.”

Healdsburg also may be liable for about $900,000 in court costs and River Watch attorney fees, Kirn said.

“We are a small community, 12,000 residents. There is not much economy of scale to spread those costs over,” Kirn said.

At issue in the lawsuit was the city’s practice of year-round discharges of treated wastewater into Basalt Pond, a 58-acre former quarry near the Russian River.

River Watch argued the wastewater eventually seeped into the river, requiring that the city get a permit to comply with the Clean Water Act.

The city contended it needed to meet state regulations, rather than those of the Clean Water Act, but federal courts in San Francisco ruled in 2006 and again in 2007 against the city.

The 2007 ruling, by the 9th U.S. Circuit Court of Appeals, was appealed by the city to the Supreme Court, which said it would not hear the case.

You can reach Staff Writer Bob Norberg at 521-5206 or bob.norberg @ pressdemocrat .com

U.S. Supreme Court Ends Healdsburg’s Appeals

BY LARRY HANSON
PRESS RELEASE

Tuesday, the Supreme Court of the United States decided to allow a lower court decision, involving Healdsburg’s disposal of secondarily treated sewage into an unlined pond adjacent to the Russian River, to stand without comment. The request for review brought by the City of Healdsburg was denied, and the original ruling handed down by the District court several years ago was allowed to stand essentially unchanged.

The United States Supreme Court issued it’s decision in Northern California River Watch vs. the City of Healdsburg. A petition for writ of Certiorari brought by the City of Healdsburg was denied without comment. The lower court ruling set out the principle that protection of water bodies adjacent to waters of the United States is necessary to the protection of the biological integrity of U.S. waters.

This is important news if you like clean water. The Clean Water Act was passed in 1972 to eliminate pollution to the nations waters. Over 30 years later, the public, agencies, and some politicians are still working to make the law a reality. During the history of the Act, pollution has been regulated but instead of water pollution having been eliminated, permits are issued to allow it. “We have a long way to go,” expressed Jack Silver lead attorney for River Watch the plaintiff in this precedent setting case involving the Russian River. “Today is a very good day for the nations waters,” observed Silver.

River Watch filed suit in Federal District Court seven years ago to protect a pond next to and biologically connected to the Russian River from discharges of unpermitted pollution. The City of Healdsburg utilized a long and expensive appeal process to challenge the claim that secondarily treated sewage needed to be permitted, monitored, and tested when discharged to this pond that is captured by the river in high flows.

The Ninth Circuit Court of Appeal upheld the District court’s view that these ponds are important waters of the United States and individuals or municipalities that wish to discharge pollutants into such ponds must first obtain a permit to do so. A permit allows the North Coast Regional Quality Control Board (NCRWQCB) the opportunity to oversee the effectiveness of the discharge proposal over time and to protect water quality. “I feel strongly that the Court’s decision was appropriate and that it supports the goals of the Clean Water Act in protecting our nations valuable wetlands and waterways,” commented John Short, Senior Water Resources Engineer in the office of the NCRWQCB in Santa Rosa.

During the appeal process, the City of Healdsburg has been building a new sewage treatment plant to better treat sewage. Despite the new capitol improvement plans, the city continued with the expensive legal appeals.

Some industries have come to rely on the nation’s waters as dumping grounds and as a means to dilute pollutants which stay in the environment. They are often represented by anti-environmental organizations like the Pacific Legal Foundation and would like a narrow definition of what constitutes the nation’s waters. The effect of such a narrow view is that important wetlands, tributaries, and isolated lakes and ponds will not be protected.

Clean fresh water is important. It is the mission of River Watch to protect the nation’s waters as the Clean Water Act intended. The Supreme Court’s lack of interest in overturning the Ninth Circuit and the San Francisco District court judge’s ruling may be a sign that there is agreement at the highest levels that we as a nation still place a high value on clean water.

Incremental Recycled Water Program (IRWP) Update

Just in case you did not receive this – here you go.

Have a wonderful weekend,
Rue

Incremental Recycled Water Program (IRWP) Update
March 14, 2007

As of today, the City of Santa Rosa has made available for public review a Draft Environmental Impact Report (EIR) for the Incremental Recycled Water Program’s (IRWP) Discharge Compliance Project (DCP). On March 25th the Seasonal Storage Project (SSP) Draft EIR will also be available. Information about the DCP and SSP, and the availability of their Draft EIRs follows below. These documents are being provided within a close time frame to allow for the opportunity to cross reference them, in response to input we have received from the public.

Key Dates in the Process Discharge Compliance Project Seasonal Storage Project
Release of Draft EIR March 14, 2008 March 25, 2008
Draft EIR Public Review Period March 14 – May 6 March 25 – May 14
Draft EIR Public Hearing Date April 3, 2008 April 17, 2008

Each of the public hearings will be held before the Board of Public Utilities (BPU) at 5:00 PM in the Santa Rosa Council Chamber, 100 Santa Rosa Avenue, Santa Rosa. Oral and/or written comments on the Draft EIRs can be made or submitted to the BPU at that time. All interested persons are invited to appear at the hearings and be heard on the proposed Draft EIRs.

Written comments on the Draft EIRs will be accepted by the City until 5:00 PM on the final dates of their respective public review periods, as noted above. All written comments should be sent to: Glen Wright, City of Santa Rosa, 69 Stony Circle, Santa Rosa, CA 95401, Fax: 707-543-3936, E-Mail: irwp@SRCity.org.

COPIES OF THE DCP and SSP DRAFT EIRs WILL BE AVAILABLE

Both Draft EIRs are available for review at Sonoma County Branch Libraries in Santa Rosa, Rohnert Park/Cotati, Sebastopol, and Windsor and on the project Web site at http://www.SRCity.org/IRWP . The DCP Draft EIR is also available at the libraries in Cloverdale, Guerneville, Healdsburg, Occidental, Petaluma, Forestville and Lakeport. The Draft EIRs, appendices and reference material cited in the Draft EIRs will also be available for review at the Laguna Plant Library, located at 4300 Llano Road, Santa Rosa. Draft EIR hard copies, summary hard copies, and CDs of the Draft EIRs will be available for purchase by calling ARC at 707-579-9096.

Please contact our office if you have any questions. Additional information is also available at: http://www.recycledwaterprogram.com

Mark Millan
Public Information Coordinator
www.SRCity.org/IRWP
707.836.0300

Water Board’s NPDES Compliance Changes

Attached is a Revised Resolution-Staff Change#1 for Compliance Schedules in NPDES.

Thank you,
Jeanine Townsend
Clerk to the Board
State Water Resources Control Board
1001 I Street. 24th Floor
Sacramento, CA 95814
Phone: (916) 341-5600
Fax: (916) 341-5620
E-mail: jtownsend@waterboards.ca.gov

http://www.ncriverwatch.org/wordpress/wp-content/uploads/2008/03/npdesstaff-change1.pdf

Update on Instream Flow Policy

To All,

Instream flow comments still being accepted Comment period extended on coastal stream flow proposals

A public comment period that was supposed to close this week has been extended to May 1 regarding a state policy for maintaining instream flows in Northern California coastal streams.

The State Water Resources Control Board in December released a draft of the new policy that if implemented could affect municipalities and landowners from the Sonoma County Water Agency to small winegrowers who divert water from the Russian River and its tributaries.

New and not-yet-permitted but existing stream diversions (dams) could be restricted or banned by the state policy that is looking at ways to ensure there is sufficient water flowing in North Coast waterways to support a healthy native salmon and steelhead fishery that is now on the federal endangered species list as threatened with extinction.

Some recently built agricultural dams may not be allowed and older existing dams may need improvements to aid fish passage, according to the draft policy that is being closely watched by local winegrowers, some of whom are diverting stream water for irrigation and other agricultural uses without a required state permit.

State water officials acknowledge there is some uncertainty in exactly ‘Äúhow much water can be diverted without adversely affecting fish habitat,’Äù said the draft policy released in december.

There are now more than 300 applications to take surface water in the policy area that includes five counties ‘Äî Marin, Sonoma, and parts of Mendocino, Napa and Humboldt counties. A draft of the policy and other information on efforts to maintain instream flows are available online by Googling the state Water Resources Control Board.

–Larry

Update on POLICY TO PROTECT WETLANDS AND RIPARIAN AREAS

From the State Water Resources Control Board:

–Larry

** High Priority **

Attached is a Revised Resolution – Staff Change#1 for the Wetlands & Riparian Areas.

Thank you,
Jeanine Townsend
Clerk to the Board
State Water Resources Control Board
1001 I Street. 24th Floor
Sacramento, CA 95814
Phone: (916) 341-5600
Fax: (916) 341-5620
E-mail: jtownsend@waterboards.ca.gov

STATE WATER RESOURCES CONTROL BOARD RESOLUTION NO. 2008–DEVELOPMENT OF A POLICY TO PROTECT WETLANDS AND RIPARIAN AREAS IN ORDER TO RESTORE AND MAINTAIN THE WATER QUALITY AND BENEFICIAL USES OF THE WATERS OF THE STATE

WHEREAS:
1. Over 85 percent of historic wetland and riparian acreage in California has been lost according to published research estimates. Remaining resources continue to be vulnerable to future impacts from projected population growth, land development, sea level rise, and climate change in California.
2. Although physically occupying only a small percentage of California watersheds, wetlands and riparian areas provide valuable water quality functions such as flood control, pollutant filtration, water supply and replenishment, recreation, and habitat for a wide variety of plants and animals. Wetlands and riparian areas act to promote the health and existence of other vital natural resources, and provide significant economic benefits to California.
3. The value of wetlands and riparian areas has been recognized in California through the enactment of the California Wetlands Conservation Policy that sets a goal to “ensure no overall net loss and achieve a long-term net gain in the quantity, quality, and permanence of wetlands acreage and values in California in a manner that fosters creativity, stewardship, and respect for private property” (Executive Order W-59-93).
4. The State has relied primarily on requirements of the Federal Water Pollution Control Act (33 U.S.C. § 1251 et seq.) (Clean Water Act) to protect wetlands and riparian areas for water quality goals.
5. Recent U.S. Supreme Court rulings (Solid Waste Agency of Northern Cook County v. U.S. Army Corps of Engineers, 2001 and Rapanos v. United States, 2006) have reduced the jurisdiction of the Clean Water Act over wetland and riparian areas by limiting the definition of “waters of the United States.” These decisions necessitate the use of California’s independent authorities under the Porter-Cologne Water Quality Control Act (Wat. Code, § 13000 et seq.) to protect these vital resources.
6. In 2003, the State Water Resources Control Board (State Water Board) issued a report to the Legislature titled, Regulatory Steps Needed to Protect and Conserve Wetlands Not Subject to the Clean Water Act (Supplemental Report of the 2002 Budget Act Item 3940-001-0001). This report reviewed the critical role that wetlands and riparian areas have in protecting the beneficial uses of waters throughout the State. Consistent with the State Water Board and Regional Water Quality Control Boards’ (Regional Water Boards) (collectively California Water Boards) 2001 Watershed Management Initiative, this report further recognizes that a watershed-level approach is needed to protect wetlands and riparian areas and their associated water quality functions.
7. In 2004, State Water Board staff initiated a Workplan upon the California Environmental Protection Agency’s request (Workplan: Filling the Gaps in Wetland Protection) to address the waters of the State that are no longer protected under the Clean Water Act. This Workplan specified the need to adopt a State wetland definition to “provide a standard metric to help determine compensatory mitigation requirements and compliance with [the] ‘no net loss’ policy [Executive Order W-59-93].”

Assessing site specific and cumulative impacts on anadromous fishery resources

Stream Flow Folks:

For thought and discussion:

In my stream flow file I found a document, NMFS/James R. Bybee to Mr. Harry Schueller/SWRCB, dated April 18, 2001 (my how the years fly by – the SWRCB should have a copy of this letter and it should be included in the record). This letter, by NMFS, was written to address a SWRCB staff report “Assessing site specific and cumulative impacts on anadromous fishery resources in coastal watersheds in Northern California”, January 23, 2001.

This document was written to address issue using discussion of subjects and concerns that NMFS has regarding the SWRCB policy proposal – some of which were addressed by the Joint CDFG/NMFS Proposed Guidelines (2000 – and – fixed 2002). The discussion included (short summary): General Approach – Cumulative Impacts related to numbers of un-permitted/unauthorized diversions (numbers in the thousands), limitations for “new” (what time frame constitutes new ?) onstream storage reservoirs, limiting the season of diversion to winter period when stream flow is the highest (Dec. 15 to March 31), providing bypass flows for the purpose of maintaining (recovering) the quality of downstream habitat. In general, NMFS argues that the Joint CDFG/NMFS Proposed Guidelines provided better (more useable solutions) by, 1) allowing diversions only when stream flows are higher then the February median – maintaining some semblance of the natural hydrograph, 2) restricting diversions to a maximum instantaneous rate of withdrawal – also to maintain a near-natural hydrograph. NMFS is critical of the proposed SWRCB policy which, 1) allows diversion when flows are higher than an established minimum (in this case the February median), 2) would establish the max total cumulative volume diverted based on estimated surface runoff – in normal years (discounting dry years) – and during a season from October 1 to March 31 – which would allow interception of all early flows needed by salmon (i.e. the early withdrawal season should not occur to January).

Instream Flow Policy – Northern California Streams – Issues from the NMFS 2001 letter are being highlighted to assess sufficiency of the newly (2008) proposed SWRCB flow maintenance policy to addresses issue and to show differences and potential shortfalls in the proposed policy to address issue.

Other issues:

Migration Barriers – Limitations on new (again define new) onstream dams, solely on basis of migration barrier issues, fails to address the flow needs issue – where the these dams normally fill during the early rain season – limiting critical flows during that period. In this case NMFS speaks strongly against allowing new onstream dams – except on Class III streams and only if the cumulative reduction in stream flow is not seriously (10%) reduced in fish bearing reaches. In addition, existence of such barrier that would preclude fish migration also precludes consideration of the potential to restore salmonids upstream form these unlauthorized and illegal structures. This is in conflict with newly proposed policy.

Season of Diversion – NMFS and the SWRCB seem to agree that the season of withdrawal should be December 15 to March 31 – with instantaneous flows outside the diversion season to be bypassed. This is linked by NMFS to another argument for limiting onstream dams. This is in conflict with the newly proposed policy – allowing October through March diversion.

Bypass Flow – NMFS disagrees with a bypass flow based on the February median flow. Bypass flows must protect all stream functions. “Bypass flows should not be some minimum value that does not fulfill all stream functions; instead it should be a dynamic fluctuating flow that effectuates all needed steam functions and processes” (ref: need to protect the natural hydrograph) The new policy addresses aspects of the flow issue but in a seriously convoluted way. Allowing illegal/unauthorized onstream dams (and diversions) that restrict flows and block migration will preclude attainment of the desired goal – habitat maintenance. NMFS suggests that a depth criterion may be necessary on some streams. This is not considered in the new policy, exception assessment, or cumulative assessment process. NMFS suggests that, both, CDFG and NMFS be included in the depth criterion assessment process.

Cumulative Effects – NMFS agrues for the Joint CDFG/NMFS Guidelines to avoid the “flatlining” of stream flows. NMFS argues that cumulative assessment of diversion impacts should include diversions under riparian right (or estimates of diversion under riparian right) – and – should be included in CEQA based cumulative effects analysis. NMFS, again, argues that the proposed period of permitted diversion starts too early. NMFS argues that historic habitats are not protected – nor are stream flows protected above migration restrictions. NMFS argues that assessments should include representative dry years. Lastly – NMFS recomends that assessment, reports, and cumulative effects analysis be presented in understandable form (this can be said for the wording of the new policy – itself). There is a conflict in the new policy with every issue mentioned in this paragraph.

Stream Flow Estimation – NMFS has some issue with reliance on USGS stream flow data (being uneven and sparse), and the Rational Runoff method. How will the unimpaired flow numbers be derived? The precipitation-based hydrologic model is given more support – but accuracy is questioned. This is a problem acknowledged by the SWRCB – with the suggestion that enforcement may be the key to the issue; ” …. a vigorous program to identify unauthorized diversions and bring them into the water rights process would be an important step in the right direction. If the problem is ignored it will only get worse.” (SWRCB 2000). NMFS agreed with the preceding statement. NMFS recommends a monitoring and research program for developing stream flow estimates. To date (during the last 10 years when this policy was on the table) little progress has been made in this area.

Verification – Variability and uncertainty regarding the adequacy and implementation of any set of guidelines or preceedures for regulating stream flow diversions for the purpose of protecting anadromous salmonids – demands verification or adaptive management. A program validating adequacy of such program should be put in place.

Compliance Monitoring – Any policy or program for limiting environmental impacts of water diversions on coastal streams will contribute little protection of fish and wildlife resources if there is inadequate oversight and enforcement of those programs or policy. “SWRCB must develop a credible compliance, monitoring, and enforcement program to ensure that requirements for bypass flows, rates of withdrawal, and a limited diversion season are met. SWRCB must also bolster its enforcement capability to discourage illegal appropriations of water. “(NMFS)

Given the above – short – review of issue, can it be said that the some areas of the new proposed policy is not consistent with NMFS concerns voiced in the 2001 letter to the SWRCB? Or – that the policy meets the criteria of meeting basic standards of being Understandable (Interpretable), Implementable, Enforceable? The Answer is that the policy is not there – yet.

This discussion, above, related to proposed SWRCB on insteam flows from 2000 and NMFS response (2001) can be applied to the current proposed Stream Flow – Maintenance policy now on deck. There are many open issues that need fixing. This discussion can be applied to that task.

Many of these comments are likely to appear in CAG’s final comments on SWRCB Stream Flow Policy. There are many more questions to be answered; e.g. How does the proposed policy and project review, with exceptions, fit in with CEQA?, How are unauthorized water transfers to be handeled?

Alan Levine