Comments on Regional Water Board’s Integrated Plan


At the last Regional Water Board meeting – when Flow Impairment was being considered as part of the listing process – the Board recognized that there was a serious problem with flow impairment with our surfaces waters – but – could not justify allowing for Flow Impairment to be a factor necessitating such listing.

The basic argument was  that  “Listing….seems a clunky way to get at the issue.”

The following poses the question of “Clunky-ness” as an inherent aspect of all Regional and State Board programs and policies.

Glunky?  What program do they have that is not “Clunky”?

Dealing with the subject of Low Flows via a listing might seem “clunky” – what other avenue are they suggesting we use.

Are listings for Temperature, Sediment, Nutrients, Pathogens not “clunky”

Are ineffectual Implementing Programs, that lack enforceability (due to lack of clearly stated operational standards – Dairy WDR, Timber WDR, still to be developed WDRs) not “clunky”.

What can be clunkier than a bunch of rivers with no water in them?

Everything is “clunky” – as we are dealing with messy situations.

Listing merely points to the problem the needs attention and remedy.  How you deal with the problem may or may not be “clunky”. – depending on authority and design.

Listing  merely tells responsible agencies and planning authorities that they must look at issue and address it.

When a program or policy to deal with flow issues is derived that is not “Clunky” –  I will eat my hat.



To All,

I want to support Alan’s concerns about the flippant use of the word ‘clunky’ to describe your decision to NOT list flow as a water quality impairment.  The use of that word totally lacks credibility, scientific basis, and does nothing to ameliorate our extraordinary water crisis taking place in all our rivers.  The use of the word ‘clunky’ is of particular concern since Matt himself talked about the causal role of flow in the extensive nutrient impairment of the Klamath River earlier in the meeting on the day you made your determination.  We have three endangered fish species at risk here, the livelihoods of major agricultural operations, a very popular recreation area, all of which represent huge amounts of tax revenue for the State, not to mention the incredible environmental values that living in our area brings to all of us.  We need a much more serious justification for NOT listing this critical element as an impairment.

I want to acknowledge that this is a very thorny and controversial issue. You have limited resources to address flow impairments, but that has never been a cause to stop critical listings before, that I am aware of.  In fact, how many of the listed impairments were supported by past Boards, in spite of complaints they would be too costly for regulated entities to comply with?

Those of you who are current members of this very important Board are intelligent and knowledgable people who were placed in your position because you know far more than the general public about technical and legal aspects of water quality and river functioning.  Your justification for not listing flow as an impairment is very disappointing.  We request that you provide a scientific basis for why it is NOT necessary to place ‘flow’ on the 303(d) list.

Finally, justifications provided thus far are not consistent with many other impairments listed in the past, as Alan points out.  Unless and until the listing occurs, you would be under no obligation to fully address its impacts let alone how you will protect beneficial uses without it.


Brenda Adelman