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Ventura County Agricultural Water Quality Coalition
916 W. Ventura Boulevard
Camarillo, California 93010
(805) 388-2727 • (805) 388-2767 Fax
www.vcawqc.org

July 18, 2006

California Regional Water Quality Control Board
Los Angeles Region
320 West 4th Street, Suite 200
Los Angeles, California, 90013
Attn: Yanjie Chu

Subject: Upper Santa Clara River Chloride TMDL Implementation
Plan Re-Consideration

Dear Mr. Chu:

The Ventura County Agricultural Water Quality Coalition (Coalition) is writing this letter in response to the Sanitation Districts of Los Angeles County (SDLAC) comment letter dated June 19, 2006 on your Staff Report (May 2006). The Coalition has a number of concerns with the representations of the SDLAC and their proposed new alternative. We find it necessary to provide an alternative perspective to the SDLAC claim to “always take an aggressive approach”. Our experience with the SDLAC is the opposite. When faced with responsibility for water quality degradation, the SDLAC resort to obfuscation, delay and dissembling. Their 100+ page comment letter is testimony to this. They continue to request more time and more study.

The SDLAC claim that compliance will have a negative impact on the water reclamation plants and on ratepayers. The SDLAC has an obligation to protect beneficial uses in the watershed that are impacted as a result of their discharges. It is regrettable that maintaining a sustainable environment requires the expenditure of capital, but because it will cost money is not an excuse for exceedingly long compliance time frames and unproven solutions.

SDLAC claim that proceeding with Alternative 4 will “undermine current source control reduction efforts”. To date, these source control efforts have shown little ability to correct the problem. We have very little confidence that continued travel down this pathway will result in timely water quality improvements.

LACSD assert no evidence of effect on strawberries and avocados. However, the Literature Review and Evaluation (LRE) reviewed about 200 technical articles on the chloride and salinity sensitivities of avocado, strawberry and nursery plants. The LRE found a range of hazard thresholds of chloride sensitivity for avocado of 100 –117 mg/L. The LRE was further reviewed by an independent Technical Advisory Panel (TAP) and the majority TAP opinion concurred with the 100 –117 mg/L threshold range.

The Coalition believes the existing Water Quality Objective (WQO) for chloride of 100 mg/L is within a scientifically defensible range for protection of agriculture. The LRE also raises the specter of even lower values to protect other crops. Continued detailed study of avocados is not necessary - enough information exists to maintain the WQO. We are interested in protecting the beneficial use of agriculture, not allowing degradation to occur to the point we have large scale production failure. LACSD appear to favor “waiting until the canary is dead to evacuate the coal mine”. We depend on high quality water for our members’ livelihoods and cannot afford to wait until broad impacts are upon us. It will be too late for Ventura County agriculture at that point.

LACSD indicates that the “sequential approach is imperative because the project to be covered by the EIR will not be identified until the scientific studies are completed . . .”. The Coalition maintains that the scientific studies that are being proposed are not critical to establishing the TMDL. Evidence from the literature is sufficient to establish a TMDL that is protective of avocados without ANY additional studies. If there is a burning desire to conduct more studies to further refine the TMDL in the future, we have no objection. The evidence in the literature review would suggest that the TMDL might need to be lower to protect other crops (e.g. ornamental plants) and LACSD might
be careful of what they wish for.

LACSD have included gargantuan cost estimates for advanced water treatment at the Saugus and Valencia Water Reclamation Plants and construction of the brine line. Based upon costs of treatment at the Orange County Water District’s Groundwater Replenishment System, the capital cost of microfiltration/reverse osmosis is approximately $3.50/gallon of treatment capacity. Given the small size of the Saugus and Valencia plants (5 and 17 MGD respectively according to the LACSD website) and the need to treat only approximately ½ of the flow (to blend back with untreated water), the collective treated capacity for new RO facilities would be about 11 MGD. Even assuming $4.00/gallon as the capital cost, RO would require approximately $50M dollars. The cost estimate of $350M espoused by LACSD would leave a staggering $300M for the cost of a brine line; this same line was estimated by the Calleguas Municipal Water District to cost $65M. It is further important to note that other brine line users would help pay for the line – LACSD would not shoulder that burden alone. This is curiously left out of their comments.

It is also important to factor in the significant benefit that reuse of that highly treated supply would create. Instead of discharge to the Santa Clara River, the highly treated water could be used in lieu of water purchases from the Metropolitan Water District of Southern California. It appears that LACSD have made every effort to understate the impacts of the discharge on agriculture, overestimate the costs of compliance (even resorting to scare tactics among the rate payers regarding massive rate increases) and ignore some of the benefits of reuse of this water supply.

LACSD have proposed a new “Option 5” that:

· Shortens the implementation schedule to 5 years;
· Only supports “cost-effective solutions” which, to-date, seem to only be the solutions the LACSD deem cost-effective;
· Ensures quality that is protective of salt sensitive crops (upper end of LRE guidelines at the point where the water is diverted);
· Allows for drought relief and requires LACSD to provide another suitable irrigation supply; and
· Lowers existing interim chloride limits based on observed reductions in chloride loads to the District’s two WRPS.

The Coalition cannot accept “Option 5” for the following reasons:
· Cost-effective to LACSD appears to be to do nothing other than try to limit self-regenerating water softeners.
· Moves the point of compliance to the point of surface diversion which would obfuscate LACSDs’ responsibility for reducing discharges. (Who would be responsible if the value did not meet the TMDL at that point? One can only imagine the protracted argument regarding incremental responsibility that would occur should a violation occur.)
· Has interim chloride limit reductions occur ONLY if the LACSD passive programs for chloride reduction achieve any success. This is hardly inspirational action.

Finally, the Clean Water Act clearly states that agricultural uses are designated uses of the waters. [See, 33 U.S.C. § 1313 (c)(2)(A).] In addition, agricultural supply is clearly defined as a “beneficial use” under the Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties. Thus, agricultural uses must be protected by water quality standards, contrary to the Districts’ arguments at A-17.

The Coalition is in favor of Alternative 4 to provide this protection. Alternative 4:
· Revises the TMDL schedule according to findings obtained from the Literature Review Evaluation (LRE) study and the Groundwater and Surface Water Interaction Model (GSWI) study;
· Establishes implementation milestones; and
· Accelerates the overall TMDL schedule from 13 to 10 years.

The decision to carry out the actions proposed in Alternative 4 will positively impact the agricultural stakeholders. The triggering of TMDL implementation tasks based on the scientific results from theLRE and GSWI studies would mean that implementation tasks can be tailored towards attaining a chloride Site Specific Objective (SSO) in the USCR. By also including implementation milestones, task objectives and deliverables will be made clear.

The Coalition also strongly supports the acceleration of the TMDL schedule from 13 to 10 years because it will help establish the Water Quality Objective (WQO) for chloride sooner than first anticipated by three years. This will in turn speed up the initiation of the advanced treatment of WRP effluent which is much needed to improve the effluent chloride concentration to meet WQO. Implementation of advanced treatment will benefit the health of the USCR, groundwater, and production of salt-sensitive crops in the USCR watershed.

For all of the foregoing reasons, the Coalition respectfully urges the Board to adopt Staff Report’s recommendation, Alternative 4.

Respectfully submitted, Respectfully submitted,

By ___________________ By _____________________
Robert P. Roy Rex Laird
Co-Chair Co-Chair
RPR/le

cc: Jonathan Bishop, Executive Officer
Sam Unger, Acting Chief
Ventura County Agricultural Water Quality Coalition
916 W. Ventura Boulevard
Camarillo, California 93010
(805) 388-2727 • (805) 388-2767 Fax
www.vcawqc.org

Coalition Members:

Ventura County Agricultural Assn.
Ventura County Farm Bureau
Western Growers
California Avocado Commission
California Strawberry Commission
Ventura County Economic
Development Association
Association of Water Agencies
of Ventura County
United Water Conservation District
Supervisor John Flynn, 5th District -
Ventura County
A.A. Naumann, Inc.
Camulos Ranch Company
Oxnard Lemon Company
Somis Pacific Agricultural Mgmt.
Saticoy Lemon Association
Limoneira
Ventura Pacific Company
Calavo Growers
Sunrise Growers
Catalinos Berry Farms
D.W. Berry Farms
Iwamoto-Gean Strawberry Farms
Anacapa Berry Farms
Westview Berry Farms
Pacifico Berry Farms
Mugu Ranch Partnership
Conroy Farms
Mandalay Berry Farms
Pac-Man General Partnership
Montalvo Farms
Festival Farms
Gull Island Farms
Dullam Nursery