IL98.

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Elissa Callman (ECallman(Qcityofsacramento.orgJMonday, September 27, 2010 3:00 PMILRP CommentsMarty Hanneman; Grace Garcia; Dave Brent; Mike Vee; Roland Pang; 'Forrest Williams';'Vicki Butler'; de la Salle. Amy; Fields. Myra (MSA); Sheri II Huun; Bonny StarrSacramento River Source Water Protection Program's Comments on Draft PublicEnvironmental Impact Report for a Waste Discharge Regulatory Program for Irrigated Landswithin the Central ValleySacramento River Source Water Protection Program Comments on ILP Draft PEIR - Sept 272010.pdf

Subject:

Attachments:

Dear Ms. Smith:

The Sacramento River Source Water Protection Program appreciates the opportunity to provide comments onthe Draft Public Environmental Impact Report for a Waste Discharge Regulatory Program for Irrigated Landswithin the Central Valley (Draft PEIR). Please find attached our comments.

If you have any questions, please do not hesitate to contact me at 916-808-1424.

Thank you for your efforts.

Sincerely,

Elissa CallmanCity of Sacramento Dept of UtilitiesProgram Manager of the Sacramento River Source Water Protection Program916-808-1424ecallma ncmcityofsacramento .org.

Note: The FY11 Sacramento River Source Water Protection Program is sponsored by the City of SacramentoDept of Utilities and the Sacramento County Dept of Water Resources.

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DEPAUTMENTOF UTILITIES

CALIFOHNIA

35thSACRAMENTO, CA

916.808-1400916.808- 1497/ 1498

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ILRP CommentsSeptember 27,2010Page 2 of 3

standards and those with treatment technology requirements. This would includeherbicides, pesticides, total organic carbon, bromide, and microbiological constituents.

"' We support the coordination with other federal and state regulatory programs to ensurethat issues are being addressed comprehensively, without duplication or conflict.

Specifically, we have several concerns related to protection of the drinking water beneficial use.

.. Page 3-7, Alternative 1 Monitoring Requirements (Table 3-2): We believe that totalorganic carbon and bromide need to be specifically listed, given the special studyconducted by the California Rice Commission indicating large amounts of carbon in ricedrainage. Also, the note indicates that the current program provides flexibilty to reducemonitoring. We believe this note should be expanded to allow for flexibility to expand aswell if conditions change and require addition of new constituents.

.. Page 3-8, Alternative 2 Optional Watershed or Area Management Objectives Plan: It isindicated that areas implementing management objective plans would be allowed toreduce surface water monitoring. We do not support the reduction of monitoring untilthere has been documentation of success of the management program and sufficientverification procedures have been put in place to confirm that the management practicesare being successfully implemented. Without monitoring data, it wil be impossible todetermine whether the practices are effective. We strongly recommend that somemonitoring continue as verification.

.. Page 3-16, Alternative 3 Monitoring Provisions: This alternative does not include a

water quality monitoring component. We strongly disagree with this philosophy as itdoes not allow for identification in changes to source water qualiy conditions, whetherimprovements or degradation, and does nqt allow for assessment of managementpractices. We recommend that the Regional Board modify this alternative to include atleast some form of monitoring designed to assess overall watershed conditions and

effectiveness of management practices.

.. Page 3-17, Alternative 4 Criteria for Tier System: The criteria outlined here appear toapply to Alternatives 2 and 5 as welL. Our major concern is with understanding when theRegional Board wìi be conducting the tier ranking and how frequently it wil be updated.Agricultural use patterns (i.e. crop types, pesticides applied, fertilizer use) can varysignificantly and therefore field rankings could change. It seems that there is a largediscretionary interpretation on this item which could significantly affect the managementof the fields. We strongly encourage the Regional Board to provide more specific

information on the criteria for tier ranking and the procedures for triggering a revisedranking.

.. Page 3-24, Alternative 4 Surface Water Monitoring: The individual monitoringrequirements have been laid out quite specifically based on timing of discharges andstorm events. We are concerned that this concise timing may reduce or eliminate thepotential to capture periods of peak pesticide application with relation to discharge. Ourexperience with the Rice Pesticide Program strongly supports timing sampling to periodsof peak pesticide use. We recommend that there should be program flexibility to allow

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09/27/2010 15: 14 9158081497 DOU PAGE 01/04

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09/27/2010 15: 14 9158081497 DOU PAGE 02/04

DEPARTMNTOFf.mirmS CITY OF SACRAMENTO

CAfORN1395 %," AVENUESAÇRAMFNTO. CA9')822.2911

ENGINEERINGSERVCES DIVISION PH 916-800-1-00

FAX 916-80S.149i/1498

September 27,2010101789:EC

ILRP CommentsMs. Megan SmithCentral Valley Regional Water Quality Control Board630 K Street, Suite 400Sacramento, CA 95814

VIA EMAIL: ILRPcommentstäicfi.com

Subject: Comments on Draft Publie Environmental Impact Report for a Waste DischargeRegulatory Program for Irrigated Lands within the Central Valley

Dear Ms. Smith:

The Sacramento River Source Water Protection Program appreciates the opportunity to providecomments on the Draft Public Environmental Impact Report for a Waste Discharge RegulatoryProgram for Irrigated Lands within the Central Valley (Oraft PEIR). We are providing severalgeneral comments regarding the overall development of the Waste Discharge RegulatoryProgram as well as several specific comments on the published documents.

Overall, we continue to support the acknowledgment of the need to protect beneficial uses.Protection of public health and safety through protection of the quality of sources of drinkingwater should remain one of the State's highest priorities.

· We support the continuation of watershed groups as the primary mechanism forimplementing the long term program and believe that significant progress has beenmade under the current Conditional Waiver Program.

· We support a reasonable monitoring program designed to continue to identify wherethere are problem areas, what corrective actíons are needed, and to ascertain that theremedies are successfuL. We believe that these programs need to be f1exíble in natureto adjust for changes in conditions, such as agricultural management practìces,

regulatory standards, and identification of new constituents of interest. We belíeve thatthese monitoring programs need to include drinking water constituents of interest relatedto agriculture, including constituents with primary and secondary drinking water

................~..~.¡.'i.....

~.E,;ARTMËÑ';:OF UTIL1Tl ES

Malttifl a D(ffer(mæ it, Your Ne1JlbIJorhood

09/27/2010 15: 14 9158081497 DOU PAGE 03/04

ILRP CommentsSeptember 27,2010Page 2 of 3

standards and those with treatment technology requirements. This would includeherbicides, pesticides. total organic carbon, bromide, and microbiological constituents.

· We support the coordination with other federal and state regulatory programs to ensurethat issues are being addressed comprehensively, without duplication or conflict.

Specifically, we have several concerns related to protection of the drinking water beneficial use.

· Page 3-7, Alternative 1 Monitoring Requirements (Table 3-2): We believe that totalorganic carbon and bromide need to be specificaHy listed, given the special studyconducted by the California Rice Commission indicating large amounts of carbon În ricedrainage. Also, the note indicates that the current program provides flexibilty to reducemonitoring. We believe this note should be expanded to allow for flexibility to expand aswell if conditions change and require addition of new constItuents.

. Page 3-8, Alternative 2 Optional Watershed or Area Management Objectives Plan: It is

indicated that. areas implementing management objective plans would be allowed toreduce surface water monftorìng. We do not support the reduction of monitoring untilthere has been documentatíon of success of the management program and sufficientverification procedures have been put in place to confirm that the management practicesare being successfully ímplemented. Without monitoring data, it will be impossible todetermine whether the practices are effective, We strongly recommend that somemonítoríng continue as veiifîcatíon.

. Page 3-16j Alternative 3 Monitoring Provisions: This alternative does not include awater quality monitoring component. We strongly disagree with thÎs philosophy as itdoes not allow for ìdentificatìon in changes to source water quality conditions, whetherimprovements or degradation, and does not allow for assessment of managementpractices. We recommend that the Regional Board modify this alternative to include atleast some form of monitoring designed to assess overall watershed conditions and

effectiveness of management practices.

. Page 3-17, Alternative 4 Criteria for Tier System: The crìteria outlined here appear toapply to Alternatives 2 and 5 as welL. Our major concern ís with understanding when theRegional Board will be conducting the tier ranking and how frequently it wil be updated.Agricultural use patterns (Le. crop types, pesticides applied, fertilzer use) can varysignificantly and therefore field rankings could change. It seems that there is a largediscretionary interpretatîon on this item which could significantly affect the managementof the fields. We strongly encourage the Regional Board to provide more specific

information on the critería for tier ranking and the procedures for triggering a revisedranking.

. Page 3-24, Alternative 4 Surface Water Monitoring: The individual monitoringrequirements have been laid out quite specifically based on timing of discharges andstorm events. We are concerned that this concise timing may reduce or eliminate thepotential to capture periods of peak pesticide application with relation to discharge. Ourexperience with the Rice Pesticide Program strongly support timing sampling to periodsof peak pesticide use. We recommend that there should be program flexíbîlty to allow

09/27/2010 15: 14 9158081497 DOU PAGE 04/04

ILRP CommentsSeptember 27, 2010Page 3 of 3

for determining which sample timing method is more appropriate based on crop type,irrigation practices and pesticide application practices.

· Page 3~28, Alternative 5 Monitoring Provisions: We have the same comment as abovefor Alternative 4.

· Appendix A, Page 31 - Malathion and Thiobencarb Evaluation: The concludingparagraph of this discussion states that malathion and thiobencarb exceedances causedby rice applications În the Sacramento River Basin are addressed through the CentralValley Water Boards Rice Pesticide Program, rather than the Irrigated Lands RegulatoryProgram (ILRP). Please provide clarification regarding coverage of malathion use onwild rice under the ILRP through the Sacramento Valley Water Quality Coalítíon.

We appreciate the opportunity to provide comments on the Draft PEIR We sincerely believethat development of this long-term program wil continue the improvements in water quafity andprotection of beneficial uses that have begun under the Conditíonal Waiver Program. Pleasecall Elissa Callman at (916) 808-1424 if you have any questions on our comments or needadditional information.

Sincerely,

h_ '.,. ~~.- ..

Sherill HuunSupervising Engineer

cc: Marty Hanneman, City of Sacramento Dept of UtiltiesDave Brent, City of Sacramento Dept of UtiltiesMike Vee. City of Saoramento Dept of Utilities .Roland Pang, City of Sacramento, Dept of UtiltiesForrest Williams, Sacramento County DWRVicki Butler, Sacramento County DWRAmy de la Salle, Sacramento County DWR

09/27/2010 15: 18 9158081497 DOU PAGE 01/04

e.1TY ot' ':ACRAMENTCl

DEPARTMENTOF UTILlTJES

1395 35th AvenueS:'(:rimento, CA 95822(916) 808-1400

Fs~: (916) 808-1497OR 808-1498

DATE:

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09/27/2010 15: 18 9158081497 DOU PAGE 02/04

DEPARTMEJIOF irr,rrmS CITY OF SACRAMENTO

ÇALTrORNlA

1395 35'" AVENUESACRAMENTO. CA95822-2911ENGINEERING

SERVlf:F.S l)VISrON PH 916-808-1400PAX '.16-R08-1497!149R

September 27,2010101789:EC

ILRP CommentsMs. Megan SmithCentral Valley Regional Water Quality Control Board630 K Street, Suite 400Sacramento, CA 95814

VIA EMAIL: IlRPcommentsØlicfi.com

Subject; Comments on Draft Public Environmental Impact Report for a Waste DischargeRegulatory Program for Irrigated Lands within the Central Valley

Dear Ms. Smith:

The Sacramento River Source Water Protection Program appreciates the opportunity to providecomments on the Draft Public Environmental Impact Report for a Waste Discharge RegulatoryProgram for Irrigated Lands within the Central Valley (Draft PEIR). We are providing severalgeneral comments regarding the overall development of the Waste Discharge RegulatoryProgram as well as several specific comments on the published documents.

Overall, we continue to support the aCknowledgment of the need to protect beneficial uses.Protection of public health and safety through protection of the quality of sources of drinkingwater should remain one of the State's highest priorities.

· We support the continuation of watershed groups as the primary mechanism forimplementing the long term program and believe that significant progress has beenmade under the current Conditional Waiver Program.

· We support a reasonable monitoring program designed to continue to identify wherethere are problem areas, what corrective actions are needed, and to ascertain that theremedies are successfuL. We believe that these programs need to be flexible in natureto adjust for changes in conditions, such as agricultural management practices,

regulatory standards, and identification of new constituents of interest. We believe thatthese monitoring programs need to include drinking water constituents of interest relatedto agriculture, including constituents with primary and secondary drinking water

................~.'I.'i."'I.'i

~I''' ~r "l!.r.n",,,rwT'''oi:p.."TMF'.NTOF UTILITIES

MakiltJl a LlIr¡¿'ttltlæ 111 YOUI' Nl!iibborhoo

09/27/2010 15: 18 9158081497 DOU PAGE 03/04

ILRP CommentsSeptember 27,2010Page 2 of 3

standards and those with treatment technology requirements, This would includeherbicides, pesticides, total organic carbon, bromide, and microbiologicai constituents.

· We support the coordination with other federal and state regulatory programs to ensurethat issues are being addressed comprehensively, without duplication or conflict.

Specifically, we have several concerns related to protection of the drìnking water beneficial use.

.. Page 3-7, Alternative 1 Monitoring' Requirements (Table 3-2): We believe that totalorganic carbon and bromide need to be specificalfy listed, given the special studyconducted by the California Rice Commission indicating large amounts of carbon in ricedrainage. Also, the note indicates that the current program provides flexibility to reducemonitoring. We believe this note should be expanded to allow for flexìbilty to expand aswell if conditions change and require addition of new constituents.

.. Page 3-8, Alternative 2 Optional Watershed or Area Management Objectives Plan: It isindicated that areas implementing management objective plans would be allowed toreduce surface water monitoring. We do not support the reduction of monitoring untìlthere has been documentation of success of the management program and suffcientverification procedures have been put in place to confirm that the management practicesare being successfully implemented. Without monitoring data, it wil be impossible todetermine whether the practices are effective, We strongly recommend that somemonitoring continue as verification.

.. Page 3-16, Alternative 3 Monitorìng Provisions: This alternative does not include a

water quality monitoring component. We strongly disagree with this philosophy as itdoes not aHow for identification in changes to source water quality conditions, whetherimprovements or degradation, and does not allow for assessment of managementpractices. We recommend that the Regiona! Board modify this alternative to include atleast some form of monitoring designed to assess overall watershed conditions and

effectiveness of management practices.

. Page 3-17, Alternative 4 Criteria for Tier System: The criteria outlined here appear toapply to Alternatives 2 and 5 as welL. Our major Concern is with understandîng when theRegional Board will be conducting the tier ranking and how frequently it wil be updated.Agricultural use patterns (Le. crop types, pesticides applied, fertilizer use) can varysignificantly and therefore field rankings could change. It seems that there is a largediscretionary interpretation on this item which could significantly affect the managementof the fields. We strongly encourage the Regional Board to provide more specific

information on the criteria for tier ranking and the procedures for triggering a revisedranking.

. Page 3-24, Alternative 4 Surface Water Monitoring: The individual monitoringrequirements have been laid out quite specifically based on timing of discharges andstorm events. We are concerned that this concise timing may reduce or eliminate thepotential to capture periods of peak pesticide application with relation to discharge. Ourexperience with the Rice Pesticide Program strongly supports timing sampling to períodsof peak pesticide use. We recommend that there should be program flexibilty to allow

09/27/2010 15: 18 9158081497 DOU PAGE 04/04

ILRP CommentsSeptember 27,2010Page 3 of 3

for determining which sample timing method is more appropriate based on crop type,irrigation practices and pesticide application practices.

· Page 3-28, Alternative 5 Monitoring Provisions: We have the same comment as abovefor Alternative 4.

· Appendix A, Page 31 - Malathion and Thiobencarb Evaluation: The concludingparagraph of this discussion states that malathion and thiobencarb exceedances'causedby rice applícatrons in the Sacramento River Basin are addressed through the CentralValley Water Board's Rice Pesticide Program, rather than the Irrigated Lands RegulatoryProgram (lLRP). Please provide clarification regarding coverage of malathion use onwíld rice under the ILRP through the Sacramento Valley Water Quality Coalition.

We appreciate the opportunity to provide comments on the Draft PEIR. We sincerely believethat development of this fang-term program will continue the improvements in water quality andprotection of beneficíal uses that have begun under the Conditional Waiver Program. Pleasecall Elissa Callman at (916) 808-1424 if you have any questìons on our comments or needadditìonal information.

Sincerely,~~ ..Sheríl HuunSupervising Engineer

ec: Marty Hanneman, City of Sacramento Dept of UtilitiesDave Brent, City of Sacramento Dept of UtilitiesMike Yes, City of Sacramento Dept of UtiltiesRoland Pang, City of Sacramento, Dept of UtiltiesForrest Willams, Sacramento County DWRVicki Butler, Sacramento County DWRAmy de fa Salle, Sacramento County DWR