[env-trinity] ACTION ALERT! - Tell the North Coast Regional Water Quality Control Board to Amend its Trinity River Temperature Objectives

Tue May 2 12:22:54 PDT 2023

ACTION ALERT! - Tell theNorth Coast Regional Water Quality Control Board to Amend its Trinity RiverTemperature Objectives by May 5!

Contact: Tom Stokely, tgstoked at gmail.com

530-524-0315

Background

The North Coast Regional Water Quality Control Board(NCRWQCB) is in the process of updating its “Water Quality Control Plan (BasinPlan) and requests input from the public on its priorities through the“Triennial Basin Plan Review.”  Pleasefill out the onlinesurvey and ask them to make updating Trinity River temperature objectivesto reflect current science and protect spawning Chinook and Coho salmon apriority project.

The current Basin Plan contains the following temperatureobjectives for the Trinity River:

RiverReach                                         Daily Average Not to Exceed  Period

Lewistonto Douglas City Bridge         60 Degrees                              July 1 - September15

Lewistonto Douglas City Bridge         56 Degrees                              September 15 -October 1

Lewiston to North Fork confluence    56Degrees                              October 1 - December 31

However, the most up to date science indicates that Chinooksalmon need 53.5F to successfully spawn and hatch eggs, and Coho salmon need48-50F to successfully spawn and hatch eggs. In 2021, a significant amount of Coho eggs died due to warm water.

Therefore, Save California Salmon, PCFFA and IFR recommendthat the existing temperature objectives for the Trinity River be retained, andthe following temperature objectives be added:

LewistonDam 

July1-Sept 14: 56 degrees 

Sept.15- Oct 31: 53.5 degrees 

Nov.1-Dec. 31: 50 degrees 

Jan. 1-March 1: 48 degrees

Please fill out the onlinesurvey by May 5, 2023, and let the NCRWQCB know it should make updatingTrinity Temperature objectives a high priority. See the attached sample answers to the questionnaire.

SaveCalifornia Salmon (SCS) is dedicated topolicy change and community advocacy for Northern California’s salmon and fishdependent people. We support the fisheries and water protection work of thelocal communities, and advocate effective policy change for clean water,restored fisheries and vibrant communities.

We aim to help to support Tribes and thegeneral public in engaging with public
comments related to water pollution, fisheries, and beneficial use issues.

Pacific Coast Federation of Fishermen’s Associations(PCFFA) and its sister organization, Institute for Fisheries Resources (IFR)represent the interests of coastal salmon-dependent commercial fishing familiescoastwide and are working with SCS and the Tribes to protect and improve salmonhabitat to assure that salmon – and salmon-dependent communities, have afuture.

###

SAMPLE RESPONSES TO NCRWQCBQUESTIONNAIRE ON THE 2023 

TRIENNIAL BASIN PLAN REVIEW

Questionnaireaddress: https://forms.microsoft.com/Pages/ResponsePage.aspx?id=JWoY_kl95kGZQQXSKB02wSD44qwt2IVNog-9A610oJdUMVpKUEo0WUpNQTJQRTNIRFBKWks3MjRPTiQlQCN0PWcu 

SubmissionDetails

1.SubmittingEntity

Pleasechoose from the following that describes your organization or your submitterstatus.

Answer:Self-Explanatory

2-7.Contact Information 

Answer:Self-Explanatory

8.EditorialAmendments

Isthe proposed amendment editorial or otherwise improves clarity or consistencywithin the Basin Plan?

Answer:No

9.ExistingTriennial Review Projects

Isthe proposed amendment related to projects from the 2018 Triennial Review?Information on the 2018 Triennial Review can be found in the link below:
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/triennial_review/

Answer:No

10.NarrativeDescription of Proposed Amendment

Pleaseprovide a clear and complete narrative description of the proposed amendment.

Answer:

Table3-1b in the North Coast Basin Plan should be amended by adding the following toprotect Chinook and Coho salmon in the Trinity River, while maintaining theexisting temperature objectives:

Lewiston Dam 

July 1-Sept 14: 56 degrees 

Sept. 15- Oct 31: 53.5 degrees 

Nov. 1-Dec. 31: 50 degrees 

Jan. 1-March 1: 48 degrees

11.BeneficialUses Definitions and/or Designations

Please selectany Beneficial Uses (BU) affected by the proposed amendment.Alternatively, or additionally, if the information relates to a BU notcurrently designated in the Basin Plan, please describe the proposed new BUunder "Other." If the proposed amendment affects all BUs, pleaserespond with "ALL" under "Other." For the full definition ofeach BU, please see Chapter 2 of the Basin Plan, which can be found in thelink below: 
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/180710/BPChapter2BeneficialUses.pdf

Answers(check these boxes) 

COMM -Commercial and Sport Fishing

COLD -Cold Freshwater Habitat

RARE -Rare, Threatened, or Endangered Species

MIGR -Migration of Aquatic Organisms

SPWN -Spawning, Reproduction, and/or Early Development

WQE -Water Quality Enhancement

CUL -Native American Culture

FISH -Subsistence Fishing

12.WaterQuality Objectives

Doesthe proposed amendment change the Water Quality Objectives as described inChapter 3 of the Basin Plan? Chapter 3 can be found in the link below:
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/180710/BPChapter3WaterQualityObjectives.pdf

Answer:Yes

13.WaterQuality Objectives - Details

Pleasedescribe any applicable Water Quality Objectives (WQO) related to the proposedamendment. Some WQOs are linked to specific Beneficial Uses; please include theexact wording from the Basin Plan when responding. WQOs are described inChapter 3 of the Basin Plan. Chapter 3 can be found in the link below:
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/180710/BPChapter3WaterQualityObjectives.pdf

Answer:

Table3-1b in the North Coast Basin Plan should be amended as follows to protectChinook and Coho salmon in the Trinity River while keeping the existingtemperature objectives as well:

Lewiston Dam 

July 1-Sept 14: 56 degrees 

Sept. 15- Oct 31: 53.5 degrees 

Nov. 1-Dec. 31: 50 degrees 

Jan. 1-March 1: 48 degrees

14.AntidegradationPolicy

Doesthe proposed amendment affect the Antidegradation Policy in Chapter 3 of theBasin Plan? The Antidegradation Policy is in section 3.1.2, Chapter 3 of theBasin Plan. Chapter 3 can be found in the link below:
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/180710/BPChapter3WaterQualityObjectives.pdf

Answer:Unknown

15.Implementationand Action Plans

Doesthe proposed amendment make any changes to implementation and action plans asfound in Chapter 4 of the Basin Plan? Chapter 4 can be found in the linkbelow:
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/190204/Chapter4Implementation_lmb.pdf

Answer:Yes

16.Implementationand Action Plans - Details

Pleasedescribe how the proposed amendment changes existing or adds new implementationplans to Chapter 4. Chapter 4 can be found in the link below:
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/190204/Chapter4Implementation_lmb.pdf

Answer:

TheTrinity River Implementation Plan, 4.1.5 is grossly outdated and should beamended to include the current situation with the Trinity ROD and the fact thatthe SWRCB promised a Trinity specific water right hearing in 1990 that has notyet occurred.  The temperature objectivein the interim action plan also needs to be amended per item 13, above.

17.Monitoring

Doesthe proposed amendment affect the monitoring programs as described in Chapter 6of the Basin Plan? Chapter 6 can be found in the link below:
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/180710/BPChapter6SurveillanceAndMonitoring.pdf

Answer:No

18.Partnersand Proponents

Pleaselist any partner organizations or additional proponents of the proposedamendment. When listing multiple partners, please separate each entry with a semicolon.For example: 
Partner A; Partner B; Partner C.

Answer:Save California Salmon; Trinity River Restoration Program; Trinity County Boardof Supervisors; Pacific Coast Federation of Fishermen’s Associations; Institutefor Fisheries Resources

19.Funding,Staffing, or Other Resources

Doesyour organization and/or partners have funds, staff, or resources to supportthe proposed amendment?

Answer:Maybe

Impactsfrom Proposed Amendment

Responsesin this section should describe the effects of the proposed amendment should itbe considered and adopted into the Basin Plan.

20.RegulatoryImplications

Pleasedescribe the regulatory need, impact, and scale of the proposed amendment onthe regulated community.

Answer:Existing temperature objectives for the Trinity River do not reflect currentscience.  Chinook salmon eggs need to beno warmer than 53.5F to successfully hatch and Coho salmon eggs need 50F tosuccessfully hatch.  Significantmortality of Coho eggs occurred in 2021. Water Right Order 90-5 by the SWRCB does not adequately protect thesefish, nor does it include summer temperature objectives for SpringChinook.  All of California’s salmonfishing is shut down in 2023, partially as a result of inadequate populations,and poor water quality protections, of Klamath-Trinity salmon.

21.Waterbodiesand Watersheds

Please identify the specific waterbody(ies) andwatershed(s) affected by the proposed amendment. Please use the nomenclaturefound in Chapter 2, Table 2-1 of the Basin Plan relating to hydrologic units,areas and subareas. If the response is a list, please separate each waterbodyname with a semicolon. For example: 
Smith River Hydrologic Unit; Klamath River Hydrologic Unit; Lower Eel RiverHydrologic Area.

Chapter 2 can be found in the link below:
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/180710/BPChapter2BeneficialUses.pdf

Answer: Trinity River Hydrologic Unit

22.Impactsto Beneficial Uses

Please describeany foreseeable impacts to Beneficial Uses due to this proposed amendment.Please see Chapter 2 of the Basin Plan for the definitions of each BU.Chapter 2 can be found in the link below: 
https://www.waterboards.ca.gov/northcoast/water_issues/programs/basin_plan/180710/BPChapter2BeneficialUses.pdf

Answer:Implementation of revised Trinity River Temperature objectives should improveTrinity River Chinook and Coho salmon populations.

23.Implementation

Pleasedescribe any actions necessary to meet the proposed amendment's regulatoryimpact. For example: planning, permitting, management practices, coordination,infrastructure, etc.

Answer:SWRCB Water Right Order 90-5 should be amended because of these proposed BasinPlan amendments, or a separate Trinity River Water Right Hearing should becompleted, as promised in SWRCB Water Right Order 90-5 and Water Quality Order89-18.

24.Data,Information, or Evidence Submission

Doyou or does your organization have references, data, information, or evidencesupporting the proposed amendment? If so, Regional Water Board staff will reachout via your preferred method of communication to coordinate any datatransfers.

Answer:No (unless you have something to add)

Tom Stokely Salmon and Water Policy Consultant530-524-0315 tstokely at att.net 
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