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