One or more Central Valley Regional Water Quality Board members may attend.

CV-SALTS Executive Committee Meeting Thursday, October 20, 2016 – 9:00 AM to 4:00 PM Valley Oak Room

Sacramento Regional Sanitation District Offices 10060 Goethe Rd, Sacramento 95827

Teleconference (641) 715-3580 Code: 279295#

Go-To-Meeting Link: https://global.gotomeeting.com/join/407357133

Posted 10-11-16 – Revised 10-19-16

1) Welcome and Introductions – Chair (15 mins)

a) Committee Roll Call and Membership Roster b) Approve Aug-Sep Meeting Notes

2) CEQA/Economics/Antidegradation Analyses – Tess Dunham, Consultant Teams (2 hrs. 15)

− Overview and discussion of submitted documents (Consultant Teams) Link to CV-SALTS CEQA/ECON/ANTIDEGRADATION web page Link to Aggressive Restoration Scenario Report Section 6.1 Antideg SED Impacts Overview

− Next steps, as needed, to complete regulatory analyses (Tess Dunham)

11:30 am to 1:00 pm - Lunch on Your Own

3) Prioritization for Implementation of Nitrate Permitting Strategy – Richard Meyerhoff and Joe LeClaire (1 hr. 30 min)

− Discussion of proposed strawman approach - (Link to PowerPoint version)

4) SNMP Glossary – Tim Moore (1 hr. 15 min)

5) Antidegradation Report Finalization – Daniel Cozad/Richard Meyerhoff (15 mins)

− Consider Consider Cleanup and Abatement funding authorization for additional work by LWA to Finalize the Antidegradation Report with direction from Legal Counsels

Schedule Budget

6) Review Meeting Schedule/Location

− November 4th – Admin Meeting – 1:00-2:30 − November 10th - Executive Committee Policy Session @ Sac Regional – 9:00-3:00

CV-SALTS meetings are held in compliance with the Bagley-Keene Open Meeting Act set forth in Government Code sections 11120-11132 (§ 11121(d). The public is entitled to have access to the records of the body which are posted at http://www.cvsalinity.orgA

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Last First Organization 6-May 11-May 12-May 10-Jun 15-Jun 16-Jun 8-Jul 1-Aug 5-Aug 10-Aug 11-Aug 14-Sep 15-Sep 16-Sep 14-Oct 20-Oct

Laputz Adam CVRWQCB ✔ ✔Larson Bobbi CASA ✔ ✔ ✔LeClaire Joe CDM Smith ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Lilien Jonathan Chevron ✔Link Adam CASA ✔Longley Karl CVRWQCB ✔ ✔ ✔ ✔ ✔ ✔McGahan Joe SJVDA ✔ ✔McLellan Laura SWRCB ✔Meeks Glenn CVRWQCB ✔ ✔ ✔ ✔ ✔ ✔ ✔Meyerhoff Richard CDM Smith ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Moore Tim Risk-Sciences ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Nasaei Elnaz SWRCB ✔Okita David CWC ✔ ✔Ores Debi CWC ✔ ✔ ✔ ✔Peschel Paul KRCD ✔Pritchett Gregory ChevronPulupa Patrick CVRWQCB ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Pitcher Jennifer West. States PetroleumRempel Jenny CWCRodgers Clay CVRWQCB ✔ ✔ ✔ ✔ ✔ ✔Savage Chris Gallo ✔Schultz Paul CDM Smith ✔ ✔ ✔ ✔Seaton Phoebe CRLA ✔ ✔Segal Daniel ChevronStamps Alicia Kennedy/JenksThomas Bill KRCD ✔ ✔ ✔ ✔ ✔Tillman Stephanie LANDIQ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Tristao Dennis J.G. BoswellTrouchon Mike LWA ✔Wackman Mike ✔ ✔ ✔Zimmerman Christie Valley Water Mgmt. ✔ ✔ ✔ ✔ ✔ ✔ ✔

ADDITIONAL PARTICIPANTS:

Participant Names CV-SALTS Executive Committee Meetings -2016

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CV-SALTS Committee Rosters

Voters Category/Stakeholder Group Name 6-May 11-May 12-May 10-Jun 15-Jun 16-Jun 8-Jul 1-Aug 5-Aug 10-Aug 11-Aug 14-Sep 15-Sep 16-Sep 14-Oct 20-Oct

1 Central Valley Water Board Pamela Creedon ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Alt Central Valley Water Board Jeanne Chilcott ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔2 State Water Resources Control Bd. Darrin Polhemus ✔ ✔ ✔ ✔ ✔ ✔3 Department of Water Resources Jose Faria

Alt Department of Water Resources4 US Bureau of Reclamation Kirk Nelson ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔5 Environmental Justice Laurel Firestone ✔ ✔ ✔ ✔ ✔ ✔6 Environmental Water Quality TBD

CV Salinity Coalition1 So. San Joaquin WQC Casey Creamer ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔2 City of Stockton Robert Granberg ✔ ✔ ✔3 California Cotton Growers Chris McGlothlin ✔ ✔ ✔ ✔ ✔4 City of Fresno Rosa Lau-Staggs ✔ ✔ ✔5 CA Leaque of Food Processors Trudi Hughes

Alt CA Leaque of Food Processors Rob Neenan ✔ ✔ ✔ ✔ ✔ ✔ ✔6 NCWA/SVWQC Bruce Houdesheldt ✔ ✔ ✔ ✔ ✔ ✔ ✔7 City of Tracy Erich Delmas ✔ ✔

Alt City of Tracy Dale Klever8 Sacramento Regional CSD Lysa Voight ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔

Alt Sacramento Regional CSD Sam Safi9 San Joaquin Tributaries Authority Dennis Westcot ✔ ✔

10 Valley Water Management Jim Waldron ✔ ✔ ✔ ✔ ✔ ✔Alt Valley Water Management Melissa Thorme ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔11 California Rice Commission Tim Johnson ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔12 City of Davis Josie Tellers ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔13 Tulare Lake Drainage/Storage District Mike Nordstrom ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔14 Western Plant Health Assoc. Renee Pinel ✔ ✔ ✔15 City of Vacaville Steve Sawyer ✔Alt City of Vacaville Tony Pirondini ✔ ✔ ✔ ✔ ✔ ✔ ✔16 Dairy Cares J.P. Cativiela ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Alt Dairy Cares Paul Sousa ✔ ✔ ✔ ✔17 Westlands Water District Jose Guiterrez ✔Alt Westlands Water District Charlotte Gallock ✔ ✔ ✔ ✔ ✔ ✔ ✔

Comm. Chairs/Co-chairs 1 Chair Executive Committee Parry Klassen, ESJWQC ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔2 Vice Chair Executive Committee Debbie Webster CVCWA ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔

Technical Advisory Committee Roger Reynolds, S Engr. ✔ ✔ ✔ ✔ ✔ ✔Technical Advisory Committee Nigel Quinn, LBL ✔ ✔ ✔

4 Public Education and Outreach Joe DiGiorgio ✔ ✔ ✔ ✔ ✔ ✔5 Economic and Social Cost Committee David Cory, SJVDA ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔6 Lower San Joaquin River Committee Karna Harrigfeld, SEWD ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔

CV-SALTS Executive Committee Meetings - 2016Executive Committee Membership

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CV-SALTS Committee Rosters

Last First Organization 6-May 11-May 12-May 10-Jun 15-Jun 16-Jun 8-Jul 1-Aug 5-Aug 10-Aug 11-Aug 14-Sep 15-Sep 16-Sep 14-Oct 20-Oct

Archibald Elaine CUWA ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Ashby Karen LWA ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Barclay Diane SWRCB ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Bell Nicole KRWCA ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Brown Michelle RBI ✔Bryant Mike RBI ✔Buford Pam CVRWQCB ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Carlo Penny Carollo Engineers ✔ ✔Cady Mark CDFA ✔ ✔ ✔ ✔ ✔ ✔Cehrs David KRCDClary Jennifer CWA ✔D'Adamo Dee Dee SWRCB ✔Deeringer Andrew SWRCB ✔Delehant GailDickey John Plantierra ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Doduc Tam SWRCB ✔ ✔Dunham Tess Somach Simmons ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Escobar Juan DWR ✔ ✔ ✔ ✔ ✔ ✔ ✔Fink Cody LANDIQ ✔ ✔Fuentes Robert Leadership Counsel ✔ ✔Gallock Charlotte WWD ✔ ✔ ✔ ✔ ✔Garcia Rick CRCGonzalez Armando Occidental Oil & GasGosling DougGrovhoug Tom LWA ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔Jensen Ryan CWCJohnson Alex Freshwater TrustJohnson Michael LSJRC ✔ ✔ ✔ ✔ ✔Kihara Annalisa SWRCBKimmelshue Joel LANDIQKretsinger Grabert Vicki LSCE ✔ ✔ ✔ ✔ ✔ ✔ ✔Kubiak Rachel Western Plant Health Assoc. ✔ ✔ ✔Kuzelka Timothy CWC

ADDITIONAL PARTICIPANTS:

Participant Names CV-SALTS Executive Committee Meetings -2016

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CV-SALTS Executive Committee Meeting - Summary Action Notes

For August 1, 2016 – 1:00 PM to 4:00 PM

Attendees are listed on the Membership Roster

AGENDA 1) Welcome and Introductions

a) Executive Committee Chair Parry Klassen brought the meeting to order, and roll call was completed. b) SNMP & Policy Schedule Richard Meyerhoff presented the Proposed Schedule to Finalize CV-SALTS Policy Documents and

Incorporate into SNMP. o Goal is to make final decisions on policies by August 11th. o Committee members were asked to advise Richard if they were still working on any policy

comments. o Two small group meetings were scheduled for further in-depth policy discussion:

August 4th for Nitrate/Salinity/AGR/Mgmt Zone from 9-1 August 8th for Exceptions/Offsets/SMCLS/Drought from 9-12

• 8/8 Participants: Debbie Webster, Tess Dunham, Jeanne Chilcott, Elaine Archibald, Richard Meyerhoff, Nigel Quinn

o The 8/4 LSJRC meeting was rescheduled to start at 1:15 to accommodate the small group participants.

o Due to anticipated workload a second policy meeting was added for 9/14 from 1:00-4:00 PM.

2) Salinity Management Strategy Discussion (AM) 3) Salinity Management Strategy Discussion (PM) Tess Dunham presented the Draft Salinity Management Strategy. Some of the feedback offered by the

committee: − Should address both groundwater and surface water; region-wide. − There should be zones where there is no opting out. − Develop criteria for opting out. What kind of demonstration is needed to opt out? − In lieu approach for Phase 1 should also analyze the change in salt looking at annual input into

the system. − Set clear milestones for first 10 years. Need to extend the current exceptions and variance

policies. − Do not remove managed degradation and effluent limitations from Tulare Lake Basin Plan while

in the study period. − Does a separate section need to be added to adequately address surface water?

Richard Meyerhoff and Joe LeClaire presented the Concept Level Tasks and Costs for Phase 1-Salinity Prioritization and Optimization Study. Some of the feedback offered by the committee:

− Add a new task at end of Phase 1, what changes to basin plan need to be done? − Include importance of salt management plans in areas of good water quality. − Include importance for environmental review in description of Task 9. − Delete Task 13 “Well Head Treatment for Nitrate”

4) Review Meeting Schedule/Location Next Admin Meeting is 8/5 Small Group Meetings 8/4 & 8/8 8/10 Policy Meeting 1-4, 8/11 Policy Meeting 9:00 – 3:00 8:30-4:00

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CV-SALTS Executive Committee Meeting - Summary Action Notes

For August 10, 2016 – 1:00 PM to 4:00 PM

Attendees are listed on the Membership Roster

AGENDA 1) Welcome and Introductions

a) Executive Committee Chair Parry Klassen brought the meeting to order, and roll call was completed. b) SNMP & Policy Schedule Richard Meyerhoff summarized the meeting and policy discussion schedule for the remainder of

August-September. September 15th will be a key meeting for discussion of the draft SNMP, with a focus on the implementation section.

c) Standing Rules Amendment Daniel Cozad presented the revised CV-SALTS Standing Rules. After discussion Rob Neenan moved

approval, and David Cory seconded, and by general acclamation the CV-SALTS Standing Rules, Version 10, dated 8/1/16, were approved.

2) CV-SALTS Policy Documents and Comments Tess Dunham led the discussion of key proposed options and alternatives for the SMCL, and Drought

and Conservation policies, and committee decisions for moving forward. − SMCL Policy

Add a paragraph explaining problems for discharges to surface water Need an analysis of the cost impact if a surface water monitoring program is necessary Clarify that if guidance is developed it will be in “consultation with” DDW. Inclusion of reference Tables in the Basin Plan to be included on future agenda, does not

affect CEQA. Maintain the policy of filtered sample, have CEQA look at unfiltered option. For point of compliance in receiving water evaluate all options, for both surface and

groundwater, and adjust the policy based upon CEQA results • The proposal of “trigger of 80%” will also be reviewed at a later date.

Clarification: change “public water supplies” to “community water systems” − Drought Policy

Keep salinity as the recommended, with boron as an option. Consider amending the policy to include a paragraph on what are the triggers;

Governor’s Drought Emergency-Extended Dry Period(LSJR)-Local State of Emergency. Other triggers would have to undergo a separate CEQA analysis later.

Tess Dunham asked the committee to weigh in on the decisions that were talked about on August 1st on the Draft Salinity Management Strategy. Some feedback from the committee:

P&O Study should be region-wide. Include both surface and groundwater The issue of forward modeling will be referred to the CEQA Project Committee for

discussion. Bracket interim permitting approach under Option 1 at 15-20 years. Richard Meyerhoff will develop the written criteria for an opt-out pathway. No decision was reached on the Tulare Lake Basin deletions.

3) Review Meeting Schedule/Location 8/11 Policy Meeting and Board Workshop 8/17 9/14 Policy Meeting 1-4, 9/15 Policy Meeting 9:00 – 3:00 Next Admin Meeting is 9/16

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CV-SALTS Executive Committee Meeting - Summary Action Notes

For August 11, 2016 – 9:00 AM to 4:00 PM

Attendees are listed on the Membership Roster

AGENDA

1) Welcome and Introductions a) Executive Committee Chair Parry Klassen brought the meeting to order, and roll call was completed. b) David Cory moved, and J.P. Cativiela seconded, and by general acclimation the May and June meeting

notes were approved.

2) CV-SALTS Policy Documents and Comments 3) Continuation of Morning Discussion Tess Dunham led the discussion of key proposed options and alternatives for the SMCL, and Drought

and Conservation policies, and committee decisions for moving forward. − Exceptions

Both proposals for term of an exception will be analyzed as options for CEQA; board discretion and term limitation of 10 years.

• Must be conditions that would pull the exception if milestones not achieved per plan.

Mitigation fund not a CEQA alternative, but can be included in the SNMP. − Offsets

Clarification needed in documents regarding offsets vs. exceptions. Offsets for surface water not an option for CEQA, consider for evaluation in Phase 1

of the Salinity Management Strategy. − Nitrate Permitting Strategy

Expansion to include surface waters not included as an option, but recognize there may be future consideration.

Cannot wait until “groundwater is greater than 75% of the objective.” Need trend analysis on watersheds that have reached 50%.

Consider the term “First Encountered Usable” in allocation of assimilative capacity. − Management Zone

Participation in an existing management zone should be subject to board review. EJ does not support the volume weighted average in the production zone.

− Salinity Management Strategy Recommend deleting Tulare Lake Basin Plan “managed degradation objectives,’ and

“salinity-related limitations…”

4) Review Meeting Schedule/Location CV-SALTS Workshop – August 17th September 14th 1:00-4:00 & 15th 9:00-3:00 @ SacRegional Next Admin Meeting is 9/16

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CV-SALTS Executive Committee Meeting - Summary Action Notes

For September 14, 2016 – 1:00 PM to 4:00 PM

Attendees are listed on the Membership Roster

AGENDA 1) Welcome and Introductions

a) Executive Committee Chair Parry Klassen brought the meeting to order, and roll call was completed.

2) CV-SALTS Policy Documents and Comments Tess Dunham presented the Revised Salinity Management Strategy, highlighting the changes made

based upon the August Meeting. Some of feedback from the committee: − Brine line development section should be broader. Identify areas not connected to the brine

line project. − Include a project schedule. − Document seems groundwater centric, how will surface water be integrated? − Page 16, second bullet, delete last sentence:

In particular, individual discharge efforts would have little impact on CentralValley salinity management as a whole, and as such they are not reasonable, feasible or practicable.

− For dischargers opting out, what are the appropriate criteria for that pathway? How to interpret the narrative objective?

− Tess will incorporate this and other comments from today’s discussion and distribute next week.

Tess also presented the new Salinity Variance Policy which proposes to amend the current basin plan to extend the sunset date on the Salinity Variance Program by an additional 15 years.

3) Review Meeting Schedule/Location 9/15 Policy Meeting 9:00 – 3:00 Next Admin Meeting is 9/16

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CV-SALTS Executive Committee Meeting - Summary Action Notes

For September 15, 2016 – 9:00 AM to 3:00 PM

Attendees are listed on the Membership Roster

AGENDA

1) Welcome and Introductions a) Executive Committee Chair Parry Klassen brought the meeting to order, and roll call was completed.

2) CV-SALTS Policy Documents and Comments 3) Continuation of Morning Discussion The following policy documents & SNMP sections had been distributed to the committee:

SNMP Implementation Section • Front Material (TOC, Abbreviations) • Section 1 – Introduction • Section 2 – CV Region Description • Section 4 - Implementation • Section 5 - References

Updated Policy Documents A1 Groundwater Management Zone A2 Nitrate Permitting Strategy A3 Salinity Management Strategy A4 Exceptions Policy A5 AGR Policy A6 Salinity Variance Policy A7 Offsets Policy A8 Drought and Water Conservation Policy A9 SMCL Policy A10 ACP Guidelines A11 Maximum Benefit Findings

Richard Meyerhoff summarized the contents of the agenda and noted the focus of discussion for the meeting would be Section 4 of the SNMP, Implementation. The committee was asked to provide written comments no later than October 3rd. The final SNMP and CEQA findings will be the focus of the October policy meeting. • During the initial discussion of Section 4.3.2 Nitrate Management, Laurel Firestone expressed

concern that she felt none of the EJ community comments had been incorporated. Two significant issues being, the provision of assimilative capacity up to 10, and private wells not being included. Tess Dunham advised that the written comments were incorporated as an alternate to be analyzed in CEQA. Pamela Creedon also noted that the Permitting Strategy incorporates both the trigger that had been requested, and a trend, to address the assimilative capacity concern. Laurel indicated they would no longer be participating in the meetings and would provide any future comments in written form only.

− Richard summarized each section of the Section 4-Implementation chapter. Some observations from the committee:

• Several sections seemed to be focusing only on groundwater.

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• Similarly, sections of the Drought and Conservation policy indicated it only applied in a drought situation.

• Richard asked committee members to identify areas of inconsistency and provide alternative text if possible. Members were also asked to note and forward any disconnects between Section 4 and the policy documents.

Tess Dunham highlighted changes made to the Exceptions and Management Zone Policies since the August meetings.

• Tess will incorporate additional steps in the management zone approval process to reflect the committee input on whether approval of the management zone is an Executive Officer authority, or a required Board approval.

• After a discussion on allocation of assimilative capacity and triggers, Tess indicated she will draft two options, with and without a trigger, and bring back to the October meeting. A decision must be made at the October meeting.

• Patrick Pulupa advised that when using assimilative capacity, the management zone must have some concept of how assimilative capacity numbers are changing for the portion of the basin not carved out in the zone.

• In response to Parry Klassen’s question on “dueling databases,” Richard noted that Section 4.3.4 of the Implementation Chapter talks about alternative data and could be revised to address Parry’s concern regarding the use of alternative data.

Richard Meyerhoff will develop a strawman proposal for the Nitrate Permitting Strategy prioritization approach and bring to the October meeting for discussion.

4) Workshop Glossary Tim Moore asked committee members to review the current glossary and email him with any additions

or comments.

5) Review Meeting Schedule/Location Next Admin Meeting is 10/14 October 20th Policy meeting has been extended one hour: 9:00-4:00 @ SacRegional

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Section 6.1 Groundwater Management Zone Policy

The proposed Groundwater Management Zone Policy would enhance the Central Valley Water Board’s authority to issue waste discharge requirements to groups of dischargers that have contributed or are contributing to nitrate impairments in groundwater, and who are willing to work collaboratively to address those impairments. The Groundwater Management Zone Policy would establish the process by which participating dischargers would define areas of the aquifer that have been adversely impacted by nitrate discharges, develop plans to address impairments in these areas (Management Zone Implementation Plans), and obtain the Central Valley Water Board’s approval of Implementation Plans.1

In addition to establishing this process, the Groundwater Management Zone Policy will set the minimum requirements that must be met for the Central Valley Water Board to approve Management Zone Implementation Plans. For example, the proposed Groundwater Management Zone Policy will require that Implementation Plans establish a governance structure for participating dischargers, ensure that the needs of individuals and communities that depend on the aquifer as their source of drinking water are met, and, where feasible, balance nitrate inputs and implement long-term projects to rectify groundwater impairments. Lastly, the proposed Groundwater Management Zone Policy would alter how the Central Valley Water Board would account for and allocate assimilative capacity amongst dischargers participating in a management zone.

Though the Central Valley Water Board’s adoption of the Groundwater Management Zone Policy itself will not authorize or cause any degradation of high-quality waters, implementation of the Policy through the Board’s issuance of waste discharge requirements, conditional waivers, and other permits and orders pursuant to the Policy may result in water quality degradation over and above that which the Central Valley Water Board could authorize pursuant to currently applicable Basin Plan provisions. This analysis discusses how the Central Valley Water Board’s implementation of the proposed Groundwater Management Zone Policy will nonetheless be consistent with State Water Board Resolution 68-16, the Statement of Policy with Respect to Maintaining High Quality of Waters in California (State Antidegradation Policy). In addition, this analysis considers two alternate approaches proposed by stakeholders.

The three approaches considered in this analysis include:

Proposed Policy Option – Dischargers may propose a Management Zone Implementation Plan to the Central Valley Water Board. The Management Zone Implementation Plan, once approved by the Board, would become enforceable through the Board’s reissuance or modification of waste discharge requirements. Assimilative capacity would be defined as the additional nitrate loading that could occur up until the volume-weighted average of nitrate concentrations measured in the upper zone reached 75% of the water quality objective. Management Zone participants could therefore request that the Board authorize assimilative capacity collectively to participants on this basis.

No-Average Option – Identical to the Proposed Policy Option with the exception that the Board could not allocate assimilative capacity collectively to dischargers based on a volume-weighted

1 With respect to salinity, management zones may be a future tool, but the proposed Policy does not include criteria and requirements for development of a salinity based management zone.

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average of nitrate concentrations measured in the upper zone. Management Zone Implementation Plans would primarily function as a means of collaboratively prioritizing and addressing water quality impairments within the management zone.

Evaluation-Only Option – The Board would continue to regulate nitrate discharges in the traditional manner (i.e., by issuing waste discharge requirements on a permit-by-permit basis, where the waste discharge requirements would require compliance with applicable water quality objectives in shallow groundwater). The concept of a “management zone” would only be used as a mechanism for evaluating regional nitrate concentration trends.

As described below, should the Central Valley Water Board approve either the Proposed Policy Option or the No-Average Option, the Board would be authorized to allow additional degradation beyond that which the Basin Plan currently allows through the issuance of waste discharge requirements, conditional waivers, and other permits. Furthermore, some of this degradation would likely occur in areas currently considered “high-quality waters” as that term is defined in the State Antidegradation Policy.

Under the Evaluation-Only Option, Management Zones would solely function to coordinate monitoring and modeling efforts, and would not be an alternative path towards regulatory compliance for collective groups of dischargers. Under this option, the Board would not be authorized to allow additional degradation beyond that which the Basin Plan currently allows; should the Board adopt the Evaluation-Only Option, the Board’s current process for evaluating compliance with the State Antidegradation Policy would remain the same. Therefore, no further analysis of this option is required.

Defining the Process by which the Board will ensure that any change to high quality waters will not unreasonably affect present and anticipated beneficial uses of such water or result in water quality less than water quality objectives following adoption of the Proposed Policy Option or the No-Average Option

Proposed Policy Option –The Board currently requires that dischargers that discharge nitrates comply with a water quality objective of 10 ug/L in the shallow aquifer underlying their discharge. Compliance with the water quality objective may currently be assured through the adoption of effluent limitations, or through the adoption of receiving water limits that limit discharges from causing or contributing to a violation of the water quality objective in the shallow aquifer. The nitrate water quality objective of 10 mg/L correlates to the drinking water maximum contaminant level (MCL), which is designed to protect the beneficial use most sensitive to nitrate impacts, which is the municipal and domestic drinking water (MUN) beneficial use.

The Proposed Policy Option would significantly change how the Board will determine compliance with the water quality objective during the time when the dischargers are implementing their Management Zone Implementation Plans – a time period which could span decades. Instead of determining compliance with applicable water quality objectives in shallow groundwater, the Board could authorize dischargers participating in a management zone to not cause groundwater to exceed 75% of the MCL, using a volume-weighted average in the upper portion of the groundwater aquifer. (Following implementation of the Implementation Plan, groundwater is expected to meet the drinking water MCL, or the highest quality water technically and economically achievable.)

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This method of evaluating compliance with the water quality objective will nonetheless ensure the reasonable protection of beneficial uses, as long as the dischargers take responsibility for ensuring that all groundwater users affected by nitrate dischargers in the management zone are made whole through the provision of replacement drinking water supplies. This is the first priority for those participating in a management zone, and the needs of the water users must be provided for both the short and long-term. These provisions of the Groundwater Management Zone Policy are designed to ensure that, regardless of whether groundwater is considered high-quality or not, beneficial uses will be protected by providing robust protection for groundwater users.

More importantly, the Groundwater Management Zone Policy has an overarching goal at achieving nitrate balance within the affected aquifer and restoring water quality within that aquifer where restoration is reasonable and feasible, resulting in protection of existing and probable future beneficial uses. This begins with an initial assessment of groundwater conditions as part of the management zone’s preliminary proposal, as well as a characterization of nitrate conditions as a minimum requirement for the Management Zone proposal and its subsequent Implementation Plan. The characterization of conditions as part of the Management Zone Implementation Plan will be the basis for demonstrating how nitrate in the zone will be managed over the short and long-term to meet the SNMP management goals.

In cases where balance and/or restoration is not reasonable or feasible, the Central Valley Water Board may need to evaluate the need to alter beneficial uses. However, such a consideration is a last resort, and only after it has been demonstrated that restoration of the basin in question to meeting water quality objectives is in fact not reasonable or feasible. Otherwise, all management zone proposals need to include long-term implementation plans for moving towards restoration of the aquifer in question. For example, a minimum requirement of a management zone implementation plan is identification of “short (≤ 20 years) and long-term (≥ 20 years) projects and/or planning activities that will be implemented within the management zone, and in particular within prioritized areas (if such areas are identified in the implementation plan) to make progress towards attaining each of the management goals established by the Central Valley SNMP.”

Further, any request for allocation of assimilative capacity from high quality waters (which, in this circumstance, would be defined as management zones where a volume-weighted average of water within the upper aquifer does not exceed 75% of the nitrate MCL) must be supported by a comprehensive antidegradation analysis for that zone, which must include demonstration that “there is sufficient assimilative capacity to ensure that the proposed discharge, together with discharges from participants to the same management zone, including discharges to recharge projects, will not cause the volume-weighted average water quality in the appropriate zone underlying the management zone to exceed the applicable Basin Plan objective(s) (upper zone for nitrate and production zone for salt).” Pursuant to the Groundwater Management Zone Policy, the Central Valley Water Board must evaluate and approve a finding ratifying this analysis before issuing revised waste discharge requirements or conditional waivers to effectuate the Management Zone Implementation Plan. Accordingly, the minimum requirements in the Groundwater Management Zone Policy ensure that any changes to high quality waters will not result in water quality less than water quality objectives when evaluated and considered over the long-term.

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Other policy elements, which are minimum requirements for a Management Zone Implementation Plan, also ensure that changes to high quality waters will not be unreasonable affected:

• Consistency with the management goals of the SNMP, including plan for achieving balance and establishing a managed aquifer restoration program;

• Need for short and long-term projects and/or planning activities to make progress towards meeting the SNMP management goals;

• Milestones for achievement of the SNMP management goals, including a schedule of implementation; and,

• Surveillance and monitoring program adequate to assure that the plan, when implemented, is achieving the expected progress towards attainment of the SNMP management goals.

These provisions, taken collectively with the provisions of the Groundwater Management Zone Policy described above, will ensure that any change to high quality waters authorized by the Board pursuant to any waste discharge requirement, conditional waiver, or other order issued following the adoption of the Groundwater Management Zone Policy will not unreasonably affect present and anticipated beneficial uses of such water or result in water quality less than water quality objectives.

No-Average Option – As with option 1, option 2 is more restrictive and thus provides further protection for present and anticipated beneficial uses of water.

Defining the Process by which the Board will ensure that discharges to existing high quality waters will be regulated under waste discharge requirements that will result in best practicable treatment or control necessary to ensure (a) that pollution or nuisance will not occur and (b) that the highest water quality consistent with maximum benefit to the people of the state will be maintained

Proposed Policy Option – The Groundwater Management Zone Policy anticipates that the Central Valley Water Board will revise waste discharge requirements to incorporate requirements from the approved Management Zone Implementation Plans. When approving the Management Zone Implementation Plans, the Board must find that the treatment or control methods that will be employed by the dischargers while they implement the Management Zone Implementation Plans will result in “best practicable treatment or control” of the wastes in their discharges.

The Groundwater Management Zone Policy differs from the Board’s current permitting approach in that it would allow the Board to consider the “practicability” of the collective actions of the dischargers participating in the management zone, rather than the practicability of individual treatment or control methodologies on a case-by-case basis. In other words, if the Board was considering waste discharge requirements for two individual facilities on a permit-by-permit basis, it would need to evaluate whether each individual facility was implementing pollution or control methods that were “best practicable treatment or control” based on the financial and technical capacities of each of the facilities on its own. Under the traditional permitting approach, if the two facilities found that it might be practicable for them to collectively finance a pollution treatment methodology that would reduce pollutant loadings to a greater degree than each could individually afford on their own, there would still be some ambiguity as to whether the Board could consider this alternative the “best practicable treatment or control” alternative. However, under the proposed Groundwater Management Zone Policy, the Board would be afforded the ability to take a broader view of practicability on the scale of the management zone.

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5 | P a g e

Even though the Board could take a broader view of “best practicable treatment or control” when evaluating treatment or control methodologies proposed in the Management Zone Implementation Plans (as well as any waste discharge requirement amendments adopted to effectuate the Implementation Plans), the Groundwater Management Zone Policy would not obviate the need for the Central Valley Water Board to hold a public hearing and carefully consider whether the Implementation Plan actually describes actions, infrastructure, and methodologies that would be considered the best practicable treatment or control of nitrates.

The Groundwater Management Zone Policy will also not eliminate the need for the Central Valley Water Board to conduct hearings and make findings regarding whether or not the Management Zone Implementation Plans and waste discharge requirements adopted thereunder will ensure that pollution or nuisance will not occur and that the highest water quality consistent with maximum benefit to people of the state will be maintained. Furthermore, the Board will ensure that pollution or nuisance will not occur via the process outlined in the response above, and that any degradation will inhere to the maximum benefit to the people of the state as described in the response below.

The Groundwater Management Zone Policy will ensure that the Board has the ability to take a broader view of what can be considered “best practicable treatment or control” of nitrate discharges, which is not inconsistent with the State Antidegradation Policy. Following adoption of the Groundwater Management Zone Policy, the Board will still be required to ensure that any degradation authorized by the Board pursuant to any waste discharge requirement, conditional waiver, or other order that effectuates a Management Zone Implementation Plan will result in best practicable treatment or control necessary to ensure that pollution or nuisance will not occur and that the highest water quality consistent with maximum benefit to the people of the state will be maintained.

No-Average Option – Like with option 1, option 2 is more restrictive and thus provides further protection for ensuring that waste discharge requirements assure that pollution or nuisance will not occur.

Defining the Process by which the Board will ensure that any degradation to high quality waters is consistent with the “maximum benefit to the people of the state” following adoption of the Proposed Policy Option or the No-Average Option

Proposed Policy Option – Following adoption of the Groundwater Management Zone Policy, dischargers may propose Management Zone Implementation Plans to the Central Valley Water Board that, if incorporated into waste discharge requirements, conditional waivers, or other orders, would result in water quality degradation over the short-term. As described above, the Groundwater Management Zone Policy would authorize the Board to implement such Management Zone Implementation Plans provided that the plans would ultimately result in nitrogen balance and aquifer restoration, where feasible. However, the Management Zone Implementation Plans may propose that the Board allow current nitrate impairments to persist for years in order to prioritize projects that would ultimately result in nitrate load reductions, and could also propose that the Board allow limited areas of high-quality waters to be further degraded while dischargers plan, propose, and identify projects to restore impacted aquifers. Furthermore, under the volume-weighted averaging concept, the Board could authorize the allocation of assimilative capacity that could result in areas of the aquifer degrading beyond applicable water quality objectives while the dischargers participating in the Management Zone implement their Implementation Plan.

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Authorizing such degradation would grant dischargers the latitude to develop long-term implementation plans that are both cost-effective and that can prioritize compliance alternatives that will have a greater net effect on nitrate reduction. Though these measures will ultimately require that dischargers make substantial and meaningful investments in nitrate reduction strategies and control measures, granting extended compliance timelines helps ensure that regulatory measures do unreasonably affect the economic vitality of the Central Valley’s communities. This is certainly a benefit to those dischargers that will be granted the flexibility to develop Management Zone Implementation Plans that address their specific economic and technical capacities.

However, any analysis of whether or not degradation authorized by the Board inheres to the maximum benefit to the people of the State must not only consider the benefits enjoyed by dischargers, but also any negative effects borne by those individuals that may be adversely affected by the degradation. In this case, because the beneficial use most sensitive to nitrate impacts is the MUN beneficial use, those most affected by any increased nitrate degradation are those who depend on the aquifer as their source of drinking water. In order to address the needs of these populations, the Groundwater Management Zone Policy is specifically structured to require, as a condition of the Board’s approval of a Management Zone Implementation Plan, that participants of the Management Zone provide alternate water supplies for nitrate-affected individuals and communities while long-term strategies are being implemented. In addition, even before the Central Water Water Board would need to approve the Management Zone Implementation Plan, participants of the management zone must collectively develop Early Action Plans to address immediate drinking water needs for those that rely on groundwater within the tentative management zone boundary.

Because the Groundwater Management Zone Policy both addresses the economic well-being of dischargers in the Central Valley and mandates that the Board require that Management Zone Implementation Plans assure that all affected users will be provided a safe drinking water supply, any degradation that the Board may authorize pursuant to the Groundwater Management Zone Policy is expected to be consistent with the maximum benefit of the people of the state.

No-Average Option – For the same reasons provided above, any revision to the Groundwater Management Zone Policy to implement the No-Average Option would be the maximum benefit to the people of the state. Providing safe drinking water remains the highest priority for a nitrate management zone and thus is to the maximum benefit to the people of the state.

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SUMMARY OF CENTRAL VALLEY SALT & NITRATE MANAGEMENT PLAN SUPPLEMENTAL ENVIRONMENTAL DOCUMENT

IMPACT DETERMINATIONS

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Resource Categories other than Water Quality No Impact Less-than-Significant Impact

• Aesthetics • Agriculture and Forestry Resources • Air Quality • Biological Resources • Cultural Resources • Geology, Soils, and Seismicity • Hazards and Hazardous Materials • Hydrology • Land Use and Planning • Mineral Resources • Noise • Public Services • Recreation • Transportation/Traffic • Utilities and Service Systems

• Greenhouse Gas Emissions (p. 83 of SED) – Less than significant to formation of nitrous oxide gas from nitrate in soil.

• Population and Housing (p. 106 of SED) – Less than significant to displacement of people due to impairment of groundwater nitrate, because of requirement for alternative, safe, reliable drinking water supply.

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SUMMARY OF CENTRAL VALLEY SALT & NITRATE MANAGEMENT PLAN SUPPLEMENTAL ENVIRONMENTAL DOCUMENT

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SNMP Policy / Strategy / Guidance

Description of Element Impact Determination Basis

WATER QUALITY Default Groundwater Management Areas (p. 88 of SED)

Amend Basin Plans to make definitions of groundwater basins/subbasins consistent with 2003 DWR Bulletin 118

No impact Not an action that involves changes in WQOs or beneficial uses; rather provides a framework for groundwater quality management.

Option: None N/A N/A Groundwater Management Zone Policy (p. 89 of SED)

Establishes criteria for the formation of management zones (MZs) that would be subject to Central Valley Water Board approval. May be a regulated entity for compliance with WDRs.

No impact The formation of a management zone, itself, would not result in water quality degradation, as this action is the establishment of a management structure to address degradation through the other SNMP strategies and policies. The potential for substantial water quality degradation associated with implementing the other SNMP strategies through a management zone (e.g., Nitrate Permitting Strategy, Exceptions Policy) is addressed in assessments of those policies/strategies.

Options: Include not allowing MZs to be used for compliance with WDRs, time to restoration of 50 yrs, determine assimilative capacity at first encountered groundwater

Same Same as above. The specific impacts to water quality would occur through implementation of other policies (e.g., Nitrate Permitting Strategy).

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SUMMARY OF CENTRAL VALLEY SALT & NITRATE MANAGEMENT PLAN SUPPLEMENTAL ENVIRONMENTAL DOCUMENT

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SNMP Policy / Strategy / Guidance

Description of Element Impact Determination Basis

Nitrate Permitting Strategy (p. 89 of SED)

Regulates degradation of nitrate in groundwater according to nitrate concentrations in discharge and underlying groundwater.

Potentially significant; less than significant at full implementation

Permitting discharges that fall into Category 5 (already degraded in groundwater and above objective in discharge) could contribute to substantial degradation of groundwater quality for nitrate in basins/subbasins where nitrate levels are already above the applicable objective, thereby making adverse nitrate conditions worse, which would adversely affect the beneficial uses of groundwater. With implementation of short-term, intermediate, and long-term compliance projects, would see improvement in groundwater basins.

Option: Provides alternative structure, information requirements and timelines.

Same As with the proposed strategy, there still could be substantial degradation in regard to nitrate for a period of time (years to decades) until projects are ultimately implemented that achieve nitrate loading balance and improved (reduced) nitrate concentrations, relative to existing conditions.

Salinity Management Strategy (p. 91 of SED)

Regulates degradation of salts in surface water and groundwater.

Less than significant – surface water Potentially significant – groundwater

Surface water: Not much degradation expected given that salts would be controlled at existing levels, flows, and receiving water conditions, and not a parameter that is being treated for now. Groundwater: In groundwater basins or portions of basins where levels of salinity constituents are near or above applicable objectives and the discharge levels are above groundwater levels, there is the potential for water quality degradation to occur that results in groundwater concentrations being increased above applicable objectives, or results in groundwater quality that is already exceeding objectives being further degraded.

Option: None N/A N/A

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SUMMARY OF CENTRAL VALLEY SALT & NITRATE MANAGEMENT PLAN SUPPLEMENTAL ENVIRONMENTAL DOCUMENT

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SNMP Policy / Strategy / Guidance

Description of Element Impact Determination Basis

Exceptions Policy (p. 92 of SED)

Grants exceptions to meeting groundwater objectives for salt and nitrate in WDRs

Potentially significant; less than significant at full implementation of other regulatory tools

Because the exception allows discharges and groundwater to exceed water quality objectives for salt and nitrate, there would be the potential to adversely affect MUN and/or AGR beneficial uses in some areas of the Central Valley. Exceptions would be part of “toolbox” with other policies to temporarily allow degradation with the ultimate long-term plan to improve groundwater quality (or develop SSO, if appropriate).

Option: Add in boron Other Options: Address conditions under which an exception would be granted, incorporation of performance measures, and restricting use of exceptions to a permit-by-permit basis.

Same Same

Same While these other options incorporate additional conditions and restriction on the use of exceptions, there would still be the potential for substantial adverse water quality degradation for the term of the exception. Thus, the same impact determinations also would apply with the options.

AGR Policy (p. 94 of SED)

Establishes four classes of groundwater basins based on existing EC/TDS to interpret Chemical Constituents objective; allows for development of site-specific objectives

Less than significant To address situations where localized EC/TDS may differ from the AGR class assigned to the basin, the Central Valley Water Board would manage the EC/TDS in the groundwater through application of the state Antidegradation Policy and Central Valley SNMP, or potentially through site-specific objectives. Thus, while there could be degradation of EC/TDS through the assignment and management of EC/TDS through the proposed AGR classes, that degradation would be managed and limited such that it would not adversely affect the AGR beneficial uses that rely on groundwater in the Central Valley Region.

Option: None N/A N/A

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SNMP Policy / Strategy / Guidance

Description of Element Impact Determination Basis

Salinity Variance Policy (p. 94 of SED)

Grants variance to meeting surface water objectives for salinity discharges

Less than significant Permittees applying for a variance would be required to demonstrate how their discharge situation is similar or comparable to the case studies evaluated for the current Salinity Variance Program, which consisted of three municipal wastewater treatment facilities that discharge to surface waters (City of Tracy, City of Stockton, and City of Manteca). Modeling conducted for original Variance Program showed little to no impact to EC.

Option: None. N/A N/A Offsets Policy (p. 95 of SED)

Allows use of offsets toward compliance with WDRs

Potentially significant

There is the potential for long-term degradation of water quality, relative to existing conditions, on a localized basis within groundwater basins, subbasins, and management zones, on a long-term average basis, that could adversely affect the direct use of the degraded water for MUN or AGR uses within the local area.

Option: Allow use of offsets across MZs, basins/subbasins. Option: Allow use of offsets only in area where impact is occurring that would result in water quality objectives being attained

Same No impact

Same This situation is more restrictive in its implementation than the proposed policy. Because attainment of water quality objectives is a condition of this option, which would require an improvement over the existing conditions.

Drought and Water Conservation Policy (p. 96 of SED)

Modifications to how compliance with salinity objectives is assessed to facilitate recycled water use and compliance with WDRs, particularly during drought periods

Less than significant Degradation to salinity would be temporary and, thus, not expected to result in substantial adverse effects to beneficial uses.

Option: Include boron Same Same

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SNMP Policy / Strategy / Guidance

Description of Element Impact Determination Basis

Secondary MCL Guidance (p. 98 of SED)

Modifies how SMCL constituents are regulated in WDRs for surface water and groundwater discharges

Less than significant SMCLs for EC/TDS/chloride/sulfate: clarifies use of recommended, upper, and short-term objectives. No change from existing anticipated because salts are being regulated now. The following applies to applies to compliance with secondary MCLs for Aluminum, Color, Copper, Iron, Manganese, Silver, Turbidity, Zinc Measuring compliance using filtered sample: no substantial change in environment anticipated because quality of discharges now a function of controls (i.e., BMPs, wastewater processes) in place that would remain in place in the future. Consideration of Natural Background: Make clear that where the natural background is greater than secondary MCLs, including the “Upper” levels, that the water body shall not exceed the natural background concentration due to controllable anthropogenic sources. By definition, controllable anthropogenic sources could not cause water quality degradation. Consideration of Dilution/Attenuation: For surface water, mixing zones must be as small as practicable and not adversely affect aquatic life and drinking water uses, so this would not result in appreciable change in regulation of surface water discharges. For groundwater discharges, water quality would continue to be regulated to protect MUN, so would not adversely affect beneficial uses. Compliance assessment time period as an annual average: Consistent with current implementation in many WDRs. Not expected to result in appreciable change to wastewater, storm water, or agricultural discharge quality.

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SNMP Policy / Strategy / Guidance

Description of Element Impact Determination Basis

Option re. Consideration of Dilution/Attenuation: a) compliance determined at point of discharge b)compliance determined at edge of mixing zone

Same Would result in lesser degradation, because more stringent than proposed guidance. Nevertheless, the options to the guidance would not lessen or eliminate a significant water quality impact caused by implementing the guidance because no significant impact to water quality would occur from implementing the Secondary MCL Guidance.

Alternative Compliance Project Guidelines (p. 102 of SED)

The Alternative Compliance Project Guidelines establish the components of an Alternative Compliance Project.

No impact These guidelines do not establish new water quality standards or implementation of water quality standards. To the extent that an Alternative Compliance Project would involve construction of new facilities, that project would undergo separate environmental review to identify project-specific environmental impacts and to incorporate any necessary measures to avoid, reduce, or mitigate for any identified significant environmental impacts.

Option: None N/A N/A Maximum Benefit Guidance (p. 102 of SED)

The Maximum Benefit Guidance provides a list of water quality degradation and socioeconomic factors for the Central Valley Water Board to consider when making a determination whether WDRs are “consistent with the maximum benefit to the people of the State” portion of the state Antidegradation Policy.

No impact Within the existing regulatory framework, the Central Valley Water Board considers water quality degradation and socioeconomics factors when making findings in WDRs regarding consistency with the state Antidegradation Policy. The proposed guidance simply provides further definition to what those factors can be.

Option: None N/A N/A

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MANDATORY FINDINGS OF SIGNIFICANCE (p. 112) Fish and Wildlife Populations Cumulative Impacts Adverse Effects to Human Beings

- No Impact Surface Water - Salinity Parameters: would not have

considerable contribution to any significant adverse cumulative condition

- Nitrate: would not have considerable contribution

- Additional Secondary MCL Parameters: would not have considerable contribution

Groundwater

- Salinity Parameters and Nitrate: beneficial impact on basin/subbasin level. Would contribute considerably to adverse condition on local level. Potentially significant and unavoidable.

- Additional Secondary MCL Parameters: would not have considerable contribution

- Less than significant

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October 20, 2016Nitrate Permitting Strategy

Joe LeClaire, PhDRichard Meyerhoff, PhDHannah Erbele

Implementation Prioritization Approach - Strawman Proposal

CV-SALTS Executive Committee Meeting

Prioritization Approach

• Objective is to determine a prioritization approach for implementing the Nitrate Permitting Strategy for Central Valley floor groundwater basins

• Priority factors in Nitrate Permitting Strategy:1. Current ambient groundwater quality (nitrate-N)2. Trends in nitrate concentrations in groundwater3. Number of individuals or community systems that are

being impacted by groundwater that exceeds nitrate drinking water standards

• Can apply approach to both Upper Zone and Production Zone – This presentation based on Upper Zone

2

Priority Factors 1 and 2

• Ambient groundwater quality and trends in nitrate concentrations– Current ambient groundwater quality (nitrate-N) from LSCE

and LWA, 2016*.– Trends in nitrate concentrations in groundwater from LSCE

and LWA, 2016*.

*Luhdorff & Scalmanini Consulting Engineers and Larry Walker Associates. 2016. High Resolution WQ Analysis: Central Valley Salinity Alternatives for Long Term Sustainability (CV-SALTS) Region 5: updated Groundwater Quality Analysis and High Resolution Mapping for Central Valley Salt and Nitrate Management Plan. June 2016. Prepared for: San Joaquin Valley Drainage Authority, Submitted by: Luhdorff and Scalmanini Consulting Engineers In association with: Larry Walker Associates, Inc.

3

Priority Factor 1

• Ambient Nitrate in Groundwater in Upper Zone (volume-weighted data)

4

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Priority Factor 2

• Predicted Nitrate Water Quality Groundwater in the Upper Zone in 50 Years (volume-weighted data)

5

Priority Factor 3 – Impacts to Users

• Reviewed surrogate criteria for individuals and communities at risk from nitrate contamination in groundwater:– Population density– Median household income– Wells serving 25 people or fewer– California Communities Environmental Health Screening Tool

(Cal EnviroScreen 3.0 Draft)

6

Priority Factor 3

• Population Density• (Census Block Group

2011)

7

Priority Factor 3

• Median Household Income

• (CA 2011 Median: $60,000)

8

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Priority Factor 3

• Community Water System (CWD) Wells Serving a Population Served (25 or fewer)

• CV-SALTS Database

9

Priority Factor 3

• CalEnviro Screen 3.0 Draft

• 20 indicators of environmental conditions and population vulnerability

• CalEnviroScreenScore = Pollution Burden (10) X Population Characteristics (10)

10

Calculation of Prioritization Score for Each Groundwater Basin

• Initial Prioritization Score

Nscore = Nambient + Nprojected + Cal EnviroScreen

11

Priority Ranking 1 Square Mile

• Nambient +• Nprojected +• Cal EnviroScreen

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Initial Priority Ranking GW Basins• Nambient +• Nprojected +• Cal EnviroScreen

13

Prioritization Score: Additional Criterion

• Initial criteria did not result in adequate parsing of groundwater basins

• Lack of data/spatial coverage in some groundwater basins

• Did not highlight well enough areas where we know there are significant nitrate concerns in groundwater

• Added average nitrate concentration in each groundwater basin to mitigate basins where data were sparse

Nscore = Nambient + Nprojected + Cal EnviroScreen + Nwell average

14

Priority Ranking GW Basins

• Nambient +• Nprojected +• Cal EnviroScreen +• Nwell average

15

Priority 1 & 2

16

Priority Ranking Basin Number Basin Name Score

Priority 1

5-22.11 Kaweah 4.655-22.03 Turlock 4.325-22.08 Kings 4.245-22.04 Merced 4.105-22.05 Chowchilla 4.025-22.12 Tulare Lake 4.01

Priority 2

5-22.07 Delta-Mendota 3.995-22.13 Tule 3.965-22.14 Kern County 3.775-22.01 Eastern San Joaquin 3.755-22.02 Modesto 3.695-21.67 Yolo 3.695-21.66 Solano 3.625-22.06 Madera 3.56

2-4 Pittsburg Plain 3.545-21.64 North American 3.17

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Priority 3 & 4

17

Priority Ranking Basin Number Basin Name Score

Priority 3

5-22.15 Tracy 2.915-21.62 Sutter 2.89

2-5 Clayton Valley 2.792-6 Ygnacio Valley 2.43

5-6.02 Rosewood 2.422-3 Suisun-Fairfield Valley 2.33

5-21.52 Colusa 2.275-21.68 Capay Valley 2.275-21.61 South Yuba 2.165-21.50 Red Bluff 2.085-21.65 South American 2.085-22.16 Cosumnes 2.045-21.57 Vina 2.02

Priority 4

5-21.58 West Butte 1.945-21.55 Dye Creek 1.865-21.53 Bend 1.845-22.09 Westside 1.825-22.10 Pleasant Valley 1.785-21.56 Los Molinos 1.735-21.51 Corning 1.735-21.60 North Yuba 1.665-21.54 Antelope 1.635-21.59 East Butte 1.625-6.01 Bowman 1.605-6.03 Anderson 1.485-6.06 South Battle Creek 1.405-6.05 Millville 1.325-6.04 Enterprise 1.21 18

Questions?

Cal EnviroScreen 3.0 Draft

19

Priority Factor X

• CASGEM

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SNMP GLOSSARY Draft for Discussion on 10/20/16 Pg. 1 of 9

SNMP GLOSSARY (not in alphabetical order)

Spatial Terms

AQUIFER: A body of rock or sediment that is sufficiently porous and permeable to store, transmit and yield significant or economic quantities of groundwater to wells or springs. (DWR)

BASIN: A groundwater basin is an alluvial aquifer comprised of soils and sediments that are

sufficiently porous and permeable to store, transmit and yield significant or economic quantifies of water to wells or springs. Groundwater basins have a definable bottom and well-defined lateral boundaries that are usually characterized by impermeable formations of rock or clay or by subsurface gradients that physically constrain subsurface flows to a limited direction. The California DWR has identified XX groundwater basins or sub-basins in the Central Valley Region (see SNMP Appendix XX).

SUB-BASIN: A sub-basin is a smaller, but contiguous, area of the aquifer within a larger

groundwater basin. The sub-basin boundaries can be defined both vertically and horizontally by a number of factors including, but not limited to: mineral or chemical concentrations, pumping practices, porosity, ownership, overlying land uses, jurisdictional oversight, flow gradients, tributary relationships, or other variables that merit the sub-basin be managed differently from adjacent areas in the same larger groundwater basin. The California DWR has identified XX groundwater basins or sub-basins in the Central Valley Region (see SNMP Appendix XX).

SATURATED ZONE: The area, below the land surface, in which all pore space between soil,

sand and rock particles is filled with water. The Saturated Zone is below the Unsaturated Zone and excludes areas of soil moisture where water is held by capillary action in the upper unsaturated soil or rock.

UNSATURATED ZONE: The area, below the land surface, in which the pore space between soil,

sand and rock particles contains varying degrees of both air and water in ratios that inhibit extraction of significant or economic quantities of groundwater extraction. The term "Unsaturated Zone" is generally considered to be synonymous with the term "Vadose Zone."

PERCHED GROUNDWATER: Groundwater that is supported by a zone of material of low

permeability located above an underlying main body of groundwater with little or no hydrologic connectivity to the underlying main aquifer. In most cases, Perched Groundwater is excluded when characterizing the Production Zone, Upper Zone or Shallow Zone of the main Aquifer which makes up a given DWR Basin or Sub-basin.

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Spatial Terms (cont.)

PRODUCTION ZONE: The portion of a basin or sub-basin from which the vast majority (≈90%) of groundwater being pumped and utilized. It generally extends from the top of the saturated zone to the bottom of the lowest screened production well. The production zone may be further subdivided into the Upper Zone and the Lower Zone. Groundwater in storage below the Lower Zone is not included when describing or characterizing the Production Zone. (see Fig. 1)

UPPER ZONE: The portion of a groundwater basin or sub-basin from which most domestic

wells draw water. It generally extends from the top of the saturated zone to the bottom of the lowest screened domestic wells or to the top of the Corcoran Clay layer where this layer exists. The lower boundary of the upper zone varies based on well construction information for a given basin or sub-basin (as described in Section 2 of LWA/LSCE; Region 5: Updated Groundwater Quality Analysis and High Resolution Mapping for Central Valley Salt and Nitrate Management Plan; June, 2016).

LOWER ZONE: The remaining portion of a groundwater basin or sub-basin's Production Zone

excluding the Upper Zone. Wells located in the Lower Zone are generally used for crop irrigation although some wells in the lower zone are also used for municipal supply. The upper boundary of the Lower Zone varies based on well construction information for a given basin or sub-basin (see reference citation in the definition of Upper Zone. Where it exists, the Corcoran Clay layer defines that upper boundary of the Lower Zone.

SHALLOW ZONE: The uppermost portion of the Upper Zone where viable production wells first

begin to support beneficial use of groundwater from a given basin or sub-basin. For regulatory purposes, the term "Shallow Zone" should be used in lieu of the phrase "first-Encountered Groundwater."

RECEIVING WATER(S): A surface waterbody (lake or stream) or a groundwater Basin or Sub-

basin into which pollutants are discharged. AREA-OF-INFLUENCE: The portion(s) of Basin or Sub-basin where a discharge or discharges will

co-mingle with the receiving water and where the presence of such discharge(s) would likely be detected in a subsequent tracer study.

MANAGEMENT ZONE: A discrete and contiguous subdivision of a larger groundwater basin or

sub-basin for which compliance with water quality standards is regulated and evaluated separately. Management Zones, which must be approved by the Regional Board, are intended to encourage permitted dischargers within the zone to protect beneficial uses and meet water quality standards by implementing more effective and efficient collective action strategies. By definition, a Management Zone must include the Area of Influence for all dischargers participating in the Management Zone.

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Concentration Terms

CURRENT GROUNDWATER QUALITY: The volume-weighted Average Concentration of a chemical constituent in a given Basin or Sub-basin. Current water quality can be computed separately for the Production Zone, Upper Zone, Lower Zone, Shallow Zone, Management Zone.

EXISTING GROUNDWATER QUALITY: The lowest volume-weighted average (mean)

concentration of a chemical constituent consistently attained in a given groundwater Basin or Sub-basin since the relevant water quality objective for that same constituent was establish or since October 28, 1968, whichever is later, unless the Regional Board has subsequently authorized a different water quality baseline consistent with the state Antidegradation Policy (Resolution No. 68-16).

AVERAGE CONCENTRATION: The mean concentration of a chemical constituent computed

using all reasonably available, representative and reliable well data collected in a given Basin or Sub-basin during the most recent 10 year sampling period. The Regional Board may authorize longer or shorter averaging periods where necessary and appropriate. Statistical tools and transformations may be used to identify and disqualify outliers, to normalize data, or to spatially and temporally de-cluster well data to reduce the potential for sampling bias when estimating a mean concentration. See [INSERT SNMP CITATION HERE] for a more detailed description of technical methods previously accepted for use in estimating average chemical concentrations in groundwater.

ASSIMILATIVE CAPACITY: The difference between the average concentration of a chemical

constituent in a given groundwater Basin or Sub-basin and the relevant water quality objective for the same chemical constituent. For the purpose of calculating available assimilative capacity, and in accordance with §9(c)(1) of the Recycled Water Policy (Res. No. 2009-0011), the most recent 5 years of available data should be used unless a different data set is approved by the Regional Board's Executive Officer.

NATURALLY-OCCURRING BACKGROUND CONCENTRATION: The average concentration of a

chemical constituent that is likely to be present a given groundwater Basin or Sub-basin without the influence of any anthropogenic activities that may have occurred over time. Acceptable methods for estimating the naturally-occurring background concentration are described in [INSERT SNMP CITATION HERE]. Other scientifically-defensible methods for estimating the naturally occurring background concentration may also be approved by the Regional Board's Executive Officer.

IMPERCEPTIBLE IMPROVEMENT IN WATER QUALITY: A calculable but relatively insignificant

reduction in pollutant concentration that does not materially alter a typical person's willingness or ability to make beneficial use of the receiving water or substantially change the risk of doing so.

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Use Impairment Terms

POLLUTION: Per CWC §13050(l), an alteration of the quality of the waters of the state by waste to a degree which unreasonably affects the waters for beneficial uses or the facilities which serve these beneficial uses. Pollution may include contamination. Naturally-occurring background concentrations are not considered a pollution.

NUISANCE: Per CWC §13050(m), anything which meets all of the following requirements: 1] Is

injurious to health, or is indecent or offensive to the senses, or an obstruction to the free use of property, so as to interfere with the comfortable enjoyment of life or property; 2] Affects at the same time an entire community or neighborhood, or any considerable number of persons, although the extent of the annoyance or damage inflicted upon individual may be unequal; 3] Occurs during, or as the result of, the treatment or disposal of wastes.

CONTAMINATION: Per CWC §13050(k), an impairment of the quality of the waters of the state

by waste to a degree which creates a hazard to public health through poisoning or through the spread of disease. Contamination includes any equivalent effect resulting from the disposal of waste, whether or not waters of the state are affected.

THREATENING TO BE EXCEEDED: For a given groundwater Basin, Sub-basin, or Management

Zone, water quality objectives are threatening to be exceeded when: 1) the volume-weighted average concentration of a chemical constituent is greater than 50% of the relevant water quality objective and long-term monitoring data confirms that there is a clear rising trend in the average concentration for that constituent; or 2) the volume weighted average concentration of a chemical constituent is greater than 75% of the relevant water quality objective unless long-term monitoring data confirms that there is a clear declining trend in the average concentration for that constituent. For individual wells, water quality objectives are threatening to be exceeded when: 1) the average concentration of a chemical constituent in recent and representative samples is greater than 50% of the relevant water quality objective and long-term monitoring data confirms that there is a rising trend in the measured concentrations of that constituent; or 2) the average concentration of a chemical constituent in recent and representative samples is greater than 75% of the relevant water quality objective.

WILL NOT UNREASONABLY AFFECT BENEFICIAL USES: Discharges shall be initially presumed to

not unreasonably affect beneficial uses of water provided that: 1) the discharge does not cause the average concentration of a given chemical constituent in a groundwater Basin or Sub-basin to exceed 75% of the relevant water quality objective; or 2) the discharge does not cause the concentration of a given chemical constituent to exceed 50% of the relevant water quality objective at any individual well where the beneficial use is likely to occur. These are rebuttable presumptions with the burden of proof on those seeking to make such a rebuttal.

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SNMP GLOSSARY Draft for Discussion on 10/20/16 Pg. 5 of 9

Implementation Terms BEST PRACTICABLE TREATMENT OR CONTROL (BPTC): Proven, cost-effective and reliable

methods for reducing the mass or concentration of potential pollutants in the discharge or the receiving water. BPTC may be discerned by evaluating performance data from a range of alternative pollutant reduction technologies/techniques, particularly those strategies successfully implemented by similarly-situated dischargers. BPTC is conceptually comparable (but not legally synonymous) with other similar phrases commonly used to proscribe the most effective, efficient and affordable means for minimizing pollution, such as: Best Available Technology Economically Achievable (BATEA), Best Practicable Control Technology (BPT), Best Conventional Pollution Control Technology (BCT), Best Efforts, and Best Management Practices (BMP). However, the phrase BPTC applies exclusively to situations where receiving water quality is better than relevant water quality objectives and an Antidegradation Analysis is being performed as required by Res. No. 68-16.

BEST EFFORTS: The highest level of water quality that can be reliably achieved using the most

effective and affordable methods generally available to reduce the discharge of pollutants or mitigate potential adverse effects of such discharges on the receiving waters. The term "Best Efforts" has historically been used to: 1) establish more stringent waste discharge requirements than necessary to meet water quality objectives where such limits can be met without undue hardship to the discharger, or 2) assure the lowest pollutant concentrations reasonably achievable, in conjunction with authorizing an exception or variance from water quality standards, where a discharge is unable to otherwise assure compliance with relevant water quality objectives. Best Efforts is conceptually comparable (but not legally synonymous) with other similar phrases commonly used to proscribe the most effective, efficient and affordable means for minimizing pollution, such as: Best Available Technology Economically Achievable (BATEA), Best Practicable Control Technology (BPT), Best Conventional Pollution Control Technology (BCT), and Best Management Practices (BMP). However, unlike the phrase BPTC, use of the term Best Efforts is not confined to situations where receiving water quality is better than relevant water quality objectives. Factors that should be considered when ascertaining what constitutes "Best Efforts" include, but are not limited to: the water supply available to the discharger, past discharge quality, quality of discharge achieved by other similarly-situated dischargers, good faith efforts by the discharger to limit the discharge of the relevant chemical constituent, the measures necessary to achieve compliance and the cost of such measures, and the feasibility and effect of prohibiting a discharge which is unable to demonstrate compliance with applicable water quality objectives.

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SNMP GLOSSARY Draft for Discussion on 10/20/16 Pg. 6 of 9

Implementation Terms (cont). BEST MANAGEMENT PRACTICES (BMP): Structural or non-structural (operational) control

techniques designed to reduce the discharge of pollutants into receiving waters, especially for non-point sources where conventional wastewater treatment technologies are not a feasible or practicable compliance option. First applied to stormwater discharges to surface waters [CWA §319(a)(1)(C)], the obligation to implement BMPs has since been cross-applied to various non-point discharges to groundwater in lieu of imposing numeric effluent limitations. Waste discharge requirements requiring BMPs also obligate dischargers to: 1) adopt practices adapted to site-specific or regional-specific conditions; 2) monitor to assure that these practices are properly applied and are effective; 3) immediately mitigate problems where monitoring indicates that BMPs are not effective; and 4) improve existing BMPs or implement additional BMPs as needed to attain and maintain water quality standards. The BMP approach is an iterative and adaptive process designed to make reasonable progress toward eventual attainment of water quality standards where immediate compliance is not generally feasible or practicable. According to the SWRCB (WQ 2000-11) factors that should be considered when determining if a BMP will reduce pollutants to the maximum extent practicable include, but are not limited to: 1) technical feasibility, 2) effectiveness, 3) public acceptance, 4) the economic and social costs (tangible and intangible) to both the discharger and the surrounding community, including an evaluation of the ability to bear such costs and a consideration of these costs compared to the environmental benefit likely to be gained.

INFEASIBLE, IMPRACTICABLE OR UNREASONABLE: a detailed and well-documented demonstration that a discharge or discharges cannot comply with water quality standards due to insurmountable technical, logistic or resource limitations and that such constraints cannot be overcome without incurring significant adverse impacts (including widespread and substantial economic hardship) that are generally deemed worse for the affected community than those caused by the non-compliant discharges. Such a demonstration also requires an evaluation of the regulatory option to prohibit non-compliant discharges. Notably, dischargers remain obligated to implement Best Efforts to reduce pollutant loads as much as is reasonably possible even if it is not feasible or practicable to achieve full compliance with water quality standards.

REASONABLE PROGRESS TOWARD ATTAINMENT: a detailed and well documented demonstration that an iterative and adaptive program for implementing Best Management Practices (BMPs) is effectively reducing the mass or concentration of certain chemical constituents discharged to or measured within the receiving waters in accordance with a series of targets, deadlines and metrics (collectively "milestones") established by the Regional Board.

PACKAGE Page 35

SNMP GLOSSARY Draft for Discussion on 10/20/16 Pg. 7 of 9

Programmatic Terms ALTERNATIVE COMPLIANCE PROGRAM (ACP): for discharges that are unable to achieve

compliance with traditional receiving water limitations, project(s) designed to provide the same or higher level of intended protection to water users that may be adversely affected by the discharge. For example, where a discharge is unable to comply with water quality objectives for nitrate, the discharger may seek an exception and offer to provide a safe and reliable alternative water supply for nearby drinking water wells that exceed or threaten to exceed the primary MCL for nitrate. This approach is considered a form of Alternative Compliance because it assures protection of the beneficial use, where that use actually occurs, by other means. Alternative Compliance Programs are used in conjunction with other non-traditional regulatory options (incl.: variances, exceptions, offsets, management zones and assimilative capacity allocations) to mitigate the adverse effects from pollution until a feasible, practicable and reasonable means for meeting water quality objectives becomes available for certain regulated discharges.

EXCEPTION TO WATER QUALITY STANDARD: A special authorization, adopted by the Regional Board through the normal public review and approval process, that allows a discharge to groundwater, subject to various conditions, without an obligation to comply with certain water quality objectives that would normally apply to the given discharge. Exceptions are limited to a specific term that is determined by the Regional Board. Exceptions must be periodically reviewed by the Regional Board to assure compliance with the requirements which were imposed as a condition for granting the exception. Exceptions apply solely to groundwater Basins, Sub-basins or Management Zones or to discharges thereto.

VARIANCE TO WATER QUALITY STANDARD: A special authorization, adopted by the Regional Board through the normal public review and approval process, that allows a discharge to surface waters, subject to various conditions, without an obligation to comply with certain water quality objectives that would normally apply to the given discharge. Variances are limited to specific terms governed by federal law and must also be approved by U.S. EPA. Variances apply solely to surface waterbodies or discharges to those surface waters.

TRIGGER(s): A concentration or level for a specific constituent (e.g. TDS) or parameter (e.g. Electrical Conductivity) which, when equaled or exceeded, may require some dischargers to initiate certain actions or implement certain measures.

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SNMP GLOSSARY Draft for Discussion on 10/20/16 Pg. 8 of 9

Programmatic Terms (cont.) OFFSET PROGRAM: Project(s) implemented in conjunction with, but separately from, a

discharge that are designed to demonstrate that the collective net impact of both on the receiving water quality is better than what is expected to occur if the discharge complied with the Waste Discharge Requirements (WDRs) that would normally be imposed in the absence of any Offset Program. For example, a discharge with TDS concentrations higher that the applicable water quality objectives to a groundwater basin lacking assimilative capacity for TDS, may demonstrate compliance by increasing the recharge of sufficient low TDS stormwater to the same groundwater basin so that the volume-weighted average of the discharge and the proposed offset project is less than the applicable water quality objective and the net effect of the combined effort would improve (reduce) average TDS concentrations in the receiving water. Alternatively, another discharger in similar circumstances, may propose to construct and operate a reverse osmosis system designed to remove more salt from the aquifer than the increment over and above the water quality objective that is added to the aquifer by the discharge. For both examples, the minimum acceptable offset ratio would be determined by the Regional Board. Because an Offset Program computes compliance based on a volume-weighted average, an Alternative Compliance Program may or may not also be required to mitigate the potential to cause or contribute to an area of localized impairment depending on the relative location of the discharge and the related offset project and their proximity to water supply wells.

EARLY ACTION PLAN (EAP): A plan that identifies specific activities, and a schedule for

implementing those activities, that will be undertaken to assure immediate access to safe drinking water for those who are dependent on groundwater from wells that exceed or threaten to exceed the Primary MCL for nitrate. An EAP must be prepared and submitted by any discharger or group of dischargers seeking an exception or variance from water quality standards and must be implemented pending approval of a final exception or variance with its attendant conditions. In some cases, an EAP must also be submitted when a discharger or group of dischargers seek an allocation of assimilative capacity in order to address areas of localized water quality impairment.

PACKAGE Page 37

SNMP GLOSSARY Draft for Discussion on 10/20/16 Pg. 9 of 9

Fig. 1: Subdivisions of a Groundwater Basin or Sub-basin

Land Surface

PACKAGE Page 38

CV-SALTSModification to Antidegradation Analysis

Schedule - Oct 17, 2016

Dec

Item 20 21 22 23 24 25 26 27 28 29 30 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 1

Contract Ageeement NTP

Revision of Policy #1Conference call with Legal (date TBD)

Draft revised Policy

Review/Comment by Legal

Finalize Policy write up

Revision of Policies #2‐#3Conference call with Legal (date TBD)

Draft revised Policy

Review/Comment by Legal

Finalize Policy write up

Revision of Policies #4‐#5Conference call with Legal (date TBD)

Draft revised Policy

Review/Comment by Legal

Finalize Policy write up

Revision of Policies #6‐#7Conference call with Legal (date TBD)

Draft revised Policy

Review/Comment by LegalFinalize Policy write up

Revision of Policies #8‐#9Conference call with Legal (date TBD)

Draft revised PolicyReview/Comment by Legal

Finalize Policy write up

CV-SALTS Final Review (Final approval)LWA Final RevisionsStop Work

CV-SALTS Executive Committee Meeting

Weekend Dates

LWA Work Efforts

CV-SALTS Legal Work Efforts

October 2016 November 2016

CV‐SALTS Schedule

Oct 2016 PACKAGE Page 39

CV-SALTSModification to Antidegradation Analysis

Cost Estimate - Oct 17, 2016

Tasks Tom

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Notes $280 $260 $140Revision of Policy #1 (Tess Dunham Lead)

Conference call with Legal 1 1 540$ Participation in Oct 20 CVSALTS meeting to discuss modifications 6 2 2,200$

Review revised Policy 2 2 1,080$

Modify template for Federal Antideg Analysis 4 2 1 1,780$

Sub-Total 5,600$ Revision of Policies #2-#3

Conference call with Legal 1 hour + 1 hour prep 2 2 1,080$

Draft revised Policy 4 hours per Policy 4 4 2,160$

Finalize Policy write up2 hours per Policy/Inclusion in Full Report 2 2 1 1,220$

Sub-Total 4,460$ Revision of Policies #4-#5

Conference call with Legal 1 hour + 1 hour prep 2 2 1,080$

Draft revised Policy 4 hours per Policy 4 4 2,160$

Finalize Policy write up2 hours per Policy/Inclusion in Full Report 2 2 1 1,220$

Sub-Total 4,460$ Revision of Policies #6-#7

Conference call with Legal 1 hour + 1 hour prep 2 2 1,080$

Draft revised Policy 4 hours per Policy 4 4 2,160$

Finalize Policy write up2 hours per Policy/Inclusion in Full Report 2 2 1 1,220$

Sub-Total 4,460$ Revision of Policies #8-#9

Conference call with Legal 1 hour + 1 hour prep 2 2 1,080$ Draft revised Policy 4 hours per Policy 4 4 2,160$

Finalize Policy write up2 hours per Policy/Inclusion in Full Report 2 2 1 1,220$

Sub-Total 4,460$

Finalize Antideg Analysis

Up to 10 hours each - address final comments/participate in additional calls as needed

10 10 4 5,960$

Sub-Total 5,960$ Project Tasks Totals 29,400$

LWA

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Oct 2016 PACKAGE Page 40

CV-SALTS Meeting Calendar

1 2 3 Light Red conflicts

Sun Mon Tue Wed Thu Fri Sat Sun Mon Tue Wed Thu Fri Sat Sun Mon Tue Wed Thu Fri Sat January is a Thursday/Friday

1 1 2 6 1 2 3 4 5 6 10 1 2 3 4 5

2 3 4 5 6 7 8 9 7 7 8 9 10 11 12 13 11 6 7 8 9 10 11 12 Wed/Thurs 4th or 3rd

3 10 11 12 13 14 15 16 8 14 15 16 17 18 19 20 12 13 14 15 16 17 18 19 Dark Green Exec Comm Policy

4 17 18 19 20 21 22 23 9 21 22 23 24 25 26 27 13 20 21 22 23 24 25 26 Fridays at 1:00 pm

5 24 25 26 27 28 29 30 10 28 29 14 27 28 29 30 31 Lt. Green Hatch Exec Comm Admin

6 31 or State Board Presentation

Yellow Salty 5

4 5 6 Lower SJ River Committee

Sun Mon Tue Wed Thu Fri Sat Sun Mon Tue Wed Thu Fri Sat Sun Mon Tue Wed Thu Fri Sat Regional Board Breifing 8/17

14 1 2 23 1 2 3 4 TAC Meeting

15 3 4 5 6 7 8 9 19 1 2 3 4 5 6 7 24 5 6 7 8 9 10 11

16 10 11 12 13 14 15 16 20 8 9 10 11 12 13 14 25 12 13 14 15 16 17 18

17 17 18 19 20 21 22 23 21 15 16 17 18 19 20 21 26 19 20 21 22 23 24 25 Regional Board Presentation 6/22

18 24 25 26 27 28 29 30 22 22 23 24 25 26 27 28 27 26 27 28 29 30

23 29 30 31 Wednesday Meetings are DRAFT

May be held by Webinar or

7 8 9 in person in Sacramento half day

Sun Mon Tue Wed Thu Fri Sat Sun Mon Tue Wed Thu Fri Sat Sun Mon Tue Wed Thu Fri Sat

27 1 2 32 1 2 3 4 5 6 36 1 2 3

28 3 4 5 6 7 8 9 33 7 8 9 10 11 12 13 37 4 5 6 7 8 9 10

29 10 11 12 13 14 15 16 34 14 15 16 17 18 19 20 38 11 12 13 14 15 16 17

30 17 18 19 20 21 22 23 35 21 22 23 24 25 26 27 39 18 19 20 21 22 23 24

31 24 25 26 27 28 29 30 36 28 29 30 31 40 25 26 27 28 29 30

32 31

10 11 12

Sun Mon Tue Wed Thu Fri Sat Sun Mon Tue Wed Thu Fri Sat Sun Mon Tue Wed Thu Fri Sat

40 1 45 1 2 3 4 5 49 1 2 3

41 2 3 4 5 6 7 8 46 6 7 8 9 10 11 12 50 4 5 6 7 8 9 10

42 9 10 11 12 13 14 15 47 13 14 15 16 17 18 19 51 11 12 13 14 15 16 17

43 16 17 18 19 20 21 22 48 20 21 22 23 24 25 26 52 18 19 20 21 22 23 24

44 23 24 25 26 27 28 29 49 27 28 29 30 53 25 26 27 28 29 30 31

45 30 31

2016

July August September

October November December

Notes/Key

January February March

April May June

8/6/2016

PACKAGE Page 41