Hi Alan–
Do you have more info on this for the SCWC Agenda — place, time??
Thanks,
Jane
Please Review this message to the SWRCB on the above subject
Reminder – Workshop on this in Ukiah on June 26
Contact Gita Kapahi to reserve a spot.
The contact for signing up for the workshop on listings of rivers
should be:
gkapahi@waterboards.ca.gov
916 341-5501
————– This message sent to the SWRCB on the above subject
Dear Board Members:
The following is a inside view of the Stillwater Temperature Potential "Model" (idea) that will be presented and considered in a Workshop in the near future. This is a good short synopsis of the issue for your reference to consider for he Board Workshop on this issue.
Temperature Potential Model – History and Analysis
As a reaction to the listing of Ten Mile River (and other North Coast Rivers) for the pollutant, Temperature, and the listing procedure, science, and number of hits showing instances (MWAT – Mean Weakly Average Temperature) of severe temperature loading (detrimental/stressful and/or near lethal to coho) incidence, Campbell Hawthorne commissioned Stillwater Sciences to develop a model the would indicate "alternative" listing criteria (alternative meaning changing WQS).
The Model
Campbell/Hawthorne and Stillwater argue that new "reach specific" standards should be adopted. These new Water Quality Standards would reflect existing conditions, they say more accurately, and these new WQS would be more capable of attainment and thus delisting for temperature impairment (or not being listed temperature impaired in the first place).
As noted above, new site specific Water Quality Standards would need to be adopted by the Regional Board (and SWRCB). This is problematic as the existing standards have a well grounded science base (more on this below).
The Stillwater model is proprietary. There is no public, or agency input. Availability of date is limited from public and agency review.
The Stillwater model only works with huge amounts of data. In part, the Stillwater Temperature Potential model needs would include the necessity for data on flow levels, an a large temporal scale, for every reach considered – inclusive of upstream and down stream date at the junction of all tributaries.
Changing Water Quality Standards
Campbell/Hawthorne may be right. It may, now, be impossible to attain the current water quality standards. This may be good logic, you do not like the current WQS so you hire out some science to come up with new standards. This is happening all over the State in the form of Use Attainability Analysis. You don’t like the Water Quality Standards, so you fix it by changing the WQS.
It is not like the elevated temperature hits throughout the watershed were borderline. The great preponderance of elevated hits, spatially and temporally, were well above the concern level and the coho absence level.
Argument for and/or Against Use of the Stillwater Model
In the not to distant past the current WQS were being met on Ten Mile River. Stream Temperatures were lower (way lower) and salmon, including coho, were abundant. What happened? Land use, logging, has altered stream temperatures. The riparian climate zones (that have big responsibility for temperature control) are vastly diminished. And, up slope conditions have changed. Forests that were occupied with in excess of 100,000 board feet of standing merchantable conifers now have about 10,000 board feet of the same. Weather conditions and the ability to hold moisture have been changed by land use.
The EPA has a very good paper on Temperature standards and needs to support north coast rivers – cold water fisheries.
Is this a reasonable argument for changing Water Quality Standards? I hope not.
Get on with TMDLs and fixing the rivers – Check out the Garcia !!!!!!!
Alan Levine