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Home My WebLink About07.a.1) Draft comment letter on Bay-Delta Conservation Plan (BDCP) and associated EIR/EIS[IRY1121 June _, 2014 BDCP Comments Ryan Wulff, NMFS 650 Capitol Mall, Suite 5 -100 Sacramento, CA 95814 Sent via Email Dear Mr. Wulff: DRAFT DRAFT 7, PHONE: (925) 228 -9500 FAX: (925) 372 -0192 www.centralsaii.org ROGER S. BAILEY General Manager KENTON L. ALM Counsel for the District (510) 808 -2000 ELAINE R. BOEHME Secretcay of the District Subject: Comments on Bay -Delta Conservation Plan (BDCP) and Associated Environmental Impact Report/Environmental Impact Statement (EIR /EIS) We appreciate the opportunity to provide comments on the subject documents. Central Contra Costa Sanitary District ( CCCSD) provides wastewater collection and treatment for approximately 467,500 residents in central Contra Costa County. On a typical day we treat approximately 40 million gallons and discharge most of that freshwater to Suisun Bay, where it ultimately flows to the San Francisco Bay and the Pacific Ocean. CCCSD also has a relatively small recycled water program that delivers 200 million gallons per year of recycled water to customers near our treatment plant primarily for landscape irrigation, but the potential exists for much more water recycling. Recycled Water Should Be Included In BDCP The BDCP and the EIR /EIS should consider recycled water as an alternative water supply to the proposed project. Locally - available, drought -proof supplies of treated wastewater effluent represent a large, significantly underutilized source of freshwater throughout California. It is critical for California to continue developing local and regional recycled water supplies for use in landscape irrigation, industrial process water, indirect potable reuse and ultimately direct potable reuse when feasible. If fully developed, the availability of a large supply of recycled water in northern, central valley and southern regions of California could potentially mitigate the need to build such an extensive north Delta diversion facility as proposed in the BDCP. California's response to the water supply challenges posed by severe droughts, climate change impacts, and population growth requires the investment in a portfolio of options that will best serve the water demands of the state. Recycled water should be appropriately considered in long -term planning decisions to develop sustainable water supplies for California. Limited Plan Area The area studied for impacts by the project stops short at the western -most boundary of Delta (station D10A) in the BDCP and at the Carquinez Strait (Station D6) in the BDCP EIR /EIS (See DRAFT DRAFT DRAFT map below). Since the San Francisco Bay is hydraulically connected to the Sacramento -San Joaquin Delta (Delta), the BDCP should evaluate impacts to the entire San Francisco Bay. A��v' -1 7i r� Jrr.'r taotiato San Raphael i r j 'yr. .� " tip• • ';� .�' a /�� Vacaville '�` `. ? • � Fairfield $a.o Pab'o Boy e ..w� Al; DavisI v Sacramento l 4•. irtii yAO Z � • ix�a Bfpass Ya i c', t d 3 3 C3A D FiiO; .IV: ' Lodi t �3 D6A gartinez D1 rra S•o �►} `cr's Concord Anboclt ✓o c' cou chrr.ond ' F: Oakland CPAZ-, Fac.�c San Ocean Fra ^asco - y ' c.+arx Lm OA � D11 R; Outdated Standard Used for Ammonia Caner Tracy Lr:ermore - '�- I.l 'mss The standard used to evaluate ammonia throughout both the BDCP and EIR /EIS which were released in November 2013 was the standard established in 1999 (1999 Update of Ambient Water Quality Criteria for Ammonia, EPA 822 -R -99 -014). EPA published the updated ammonia standards on August 22, 2013 (EPA 822 -R -13 -001 Aquatic life Ambient Water quality Criteria for Ammonia — Freshwater 2013). The BDCP and EIR /EIS identified the updated ammonia standard (0.26 ppm ammonia when mussels are present and 1.8 ppm ammonia when mussels are not present) when it was in draft form but the final evaluation of these documents used the 1999 ammonia standard. The 2013 ammonia standard should be used to evaluate the project's potential impacts related to ammonia. . Studies have linked ammonia to the decline of pelagic organisms in the Delta and Suisun Bay. Based on this linkage, a quantitative assessment in both the BDCP and the EIR /EIS is warranted. Using the 2013 ammonia criteria would trigger inclusion of ammonia for quantitative analysis, which differs from the result achieved in EIR /EIS Appendix 8C Constituent Screening DRAFT DRAFT DRAFT Analysis, page 8C -28. The qualitative assessments performed in Step 6 of the Appendix 8C Screening Analysis appears to be inadequate considering these important issues. The Sacramento Regional wastewater treatment plant is required in its current NPDES Permit to invest significant funds to upgrade treatment processes to achieve significant reductions of effluent ammonia. These requirements were to protect water quality in the Delta and Suisun Bay downstream of the Delta[MLEil. The BDCP document states on page 5.d -41, "By 2021, effluent (sac) must be below 1.5 and 2.4 ppm ammonia on a seasonal basis, an 18 -fold decrease in ammonia concentrations. It would take a similar decrease in Sacramento River flow to achieve the current conditions and few to no effects are expected from covered activities on ammonia/um." The water quality improvements for the Delta and downstream water bodies achieved by Sacramento Regional's facility improvements should not be used to justify projects that may have an adverse effect on water quality due to ammonia. The statement extracted from the BDCP was based on application of the 1999 ammonia standard. The statement may need further modification if the 2013 standard is applied. No Agricultural Contribution to Ammonia in the Delta The evaluation does not include agricultural input ammonia[MLE2] into the Sacramento River so the potential impacts may be underestimated. It is counterintuitive that a highly - agricultural area that uses urea -based fertilizers would result in no ammonia contributions to the Delta when urea undergoes hydrolysis to ammonia in the water column. BDCP Section 5.D.4.4 only evaluates ammonia /um impacts in the Sacramento River rather than considering the entire Plan Area. As a result, this section does not fully evaluate agricultural inputs of ammonia. The low- outflow scenario (LOS) and high - outflow scenario (HOS) need to be run against existing conditions with agricultural inputs to check if the current 2013 ammonia standard is met. Although there is no current accurate model for ammonia in the Delta, the BDCP should evaluate the potential impacts of ammonia from both point sources (POTWs) and non -point sources (agricultural) as they relate to the proposed project. Insufficient Evaluation of Selenium Water quality impairment resulting from selenium in the Suisun Bay has been studied for many years. The Delta contribution of selenium to Suisun Bay, in particular from the San Joaquin River, is well documented. Implementing the BDCP project would result in the contributory flow from the San Joaquin River to Suisun Bay increasing which could increase the source of selenium to Suisun Bay. A Total Maximum Daily Load (TMDL) for selenium in Suisun Bay (referred to in studies as North San Francisco Bay) is being developed. The District and other dischargers to Suisun Bay could be adversely affected if the BDCP project's impact on selenium loading is not properly evaluated. CCCSD requests the BDCP EIR /EIS be modified to consider the following: More current data from Tetra Tech's 2012 North San Francisco Bay Selenium Characterization Study should be used to evaluate modeling of Current Operations against Alternate Scenarios. DRAFT DRAFT DRAFT Historical selenium measurements for the San Joaquin River are identified in EIR /EIS Chapter 8, Appendix C (Screening Analysis) Table 8C -22 to be 2.0 ppb. However, the selenium concentration used for the modeling was 0.31 ppb resulting in lower fish tissue values reported by the model. The historic selenium concentrations should be used in the BDCP modeling. The evaluation uses modeled concentrations from the San Joaquin River at Antioch station and the Sacramento River at Mallard Island station which are tidally influenced. Model stations further upstream should be used to understand the relative contribution from each river and to avoid confounding the results from tidally - influenced stations. The Tetra Tech 2012 report supports this objective, "Given the importance of the riverine sources of selenium on bioaccumulation and the potential changes in the riverine inputs associated with Delta conveyance proposals, better characterization of the magnitude of the Se sources and transformations within the Delta are warranted." The EIR /EIS proposes on page 8M -5 Lines 19 -36 that selenium in Suisun Bay will be controlled by the TMDL under development by the San Francisco Regional Water Quality Control Board in addition to the nonpoint source TMDL that the Central Valley Regional Water Quality Control Board will be putting into place. This assessment increases the burden of mitigating the environmental impacts of selenium from the proposed BDCP project to dischargers downstream from the project and other regulatory mechanisms. [MLE3] Further, implementing the selenium TMDL to control sources would have significant challenges using historic selenium loadings. It seems unlikely that the selenium TMDL in North San Francisco Bay will be able to mitigate the impact of an additional 3 -10% increase in selenium concentrations as noted in the EIR /EIS on page 8M -5 line 4 -6. Additionally, the current modeled baseline conditions exceed the range for sturgeon whole -body fish tissue of 6.0 -8.1 ug /g dry weight according to the 2004 Preliminary Project Report for the TMDL Selenium in North San Francisco Bay. The selenium impacts from the project should be mitigated by the project proponents and not passed on to other dischargers via other regulatory processes.[MLE4] We appreciate the opportunity to provide these comments. If you have any questions or need further clarification on the comments in this letter, please contact me at (925) 229 -7386 or rbailey@centralsan.org. Sincerely, Roger S. Bailey General Manager