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).


Sharon’s Guide to Understanding Scientific Papers: I. Querying the Abstract

In the spirit of teaching a person to fish, I’ll explain my own process for reviewing scientific papers. Because I’ve been in the forest biology/forest ecology biz for almost 50 years, it may be easier for me. But I’m hoping that curious TSW readers will be able to adapt these steps for your own use, and I’ll give you some hints to make things easier. Along the way, you’ll also find out what peer reviewers may look at, and what they don’t or can’t. I hope others will share their own methods and shortcuts.

We’ll start with the paper Jon posted here:

1. Get a copy of the paper. Some may be open-source (yay!). The next step is to go to Google Scholar and look it up. Often you will find a copy for free there. The last step is to write the corresponding author (there’s usually an envelope and an email if you hover over the list of authors) and ask for a reprint. Back in the day, we would send each other postcards and slip copies in the surface mail. This is pretty much the modern equivalent of that process. So far, no one has turned me down or not replied to an email. That’s how I got the copy I am posting so thanks to author Thom Thom et al (2019) – The climate sensitivity of carbon, timber, and species richness co-varies with forest age in boreal-temperate North America

2. Look at the abstract with an eye to data sources, methods and conclusions. What are they measuring?
(one of the most difficult things to wade through is terminology, but it has to be done).

We focused on a number of ESB indicators to (a) analyze associations among carbon storage, timber growth rate, and species richness along a forest development gradient; (b) test the sensitivity of these associations to climatic changes; and (c) identify hotspots of climate sensitivity across
the boreal–temperate forests of eastern North America.

What is “ESB”? It’s some combination of ecosystem services and biodiversity. There are many indicators of those (e.g. genetic diversity of amphibians, species diversity of insects, and so on for biodiversity). So to relate what they measured to what we know, we’ll have to dive deeper into the methods section. We may have our own experiences with carbon measurements, but not so much with species richness.

The data used was FIA and other plot information, and they used modeling to test the sensitivity to climate change. By now, you may be curious and ask “how can you tell what climate change will do? how can you tell what aspects will be sensitive?” That again, will have to wait for methods section.

Next, I look for the conclusions in the abstract:

While regions with a currently low combined ESB performance benefited from climate change, regions with a high ESB performance were particularly vulnerable to climate change. In particular, climate sensitivity was highest east and southeast of the Great Lakes, signaling potential priority areas for adaptive management. Our findings suggest that strategies aimed at enhancing the representation of older forest conditions at landscape scales will help sustain ESB in a changing world.

Then I try to paraphrase it in my own words. I came up with “if you combine indicators, the regions with low marks get higher marks after climate change and regions that have high marks now will go down, that would be east and SE of the Great Lakes.” A natural question would be “do all indicators go the same way?” “How sensitive are these findings to the way you combine them and which ones you include?”

And how does the above relate to “old forest conditions” that strategies should enhance?

3. Write down your questions. This is particularly helpful if you can’t get back to this for a day or so. In this case, my questions would be:
a) what ESB indicators did they use? It sounds like carbon, timber and species richness, but it could be others as well.
b) how did they figure out what changes would occur due to climate change?
c) how did they figure out whether an indicator was sensitive to climate change?
d) do all indicators change in the same direction and/or how sensitive are the findings to the way they are combined and which ones are in and out?
e) how does all this relate to “old forest conditions?


Action for Clean Water: Tell Your Senator to support AB 756

To All,

According to a federal study, California has the most known detections of toxic PFAS chemicals in the nation. But that study only looked for very high levels of a mere six chemicals in a family of 5000.

Protecting the public from toxic PFAS chemicals will require having a true understanding of PFAS in our water supplies. AB 756 is a commonsense bill that clarifies the State Water Board’s role in requiring public water systems to monitor for any PFAS with a verified testing method. This would help reveal the true scope of the problem by monitoring for more chemicals than the federal government has looked for. It also requires that the public be notified when PFAS are found.

Please take a moment to tell your senator to vote for AB 756 (C. Garcia) when it comes up in the Senate Environmental Quality Committee on June 19th.

The Association of California Water Agencies (ACWA) is opposing the bill; they want the state to limit monitoring to a weak federal plan that focuses on only two PFAS chemicals. They also claim that notifying the public about these chemicals would be burdensome. In other words, they want to keep you in the dark about chemicals that have been linked to cancer, liver toxicity, disruption of the immune and endocrine systems, neonatal toxicity, and environmental damage.

We need you to counter ACWA’s position by telling your senator that you have the right to know what’s in your water.

Several states are way ahead of California in trying to find out how much PFAS is in their environment and regulating those chemicals in drinking water. Tell your senator today to make sure our safety doesn’t lag behind. Request that your senator vote yes on AB 756.

For Clean Water,
Andria Ventura
Toxics Program Manager