On 8 August, CSPA joined with Earth Law Center, PCFFA, California Coastkeeper Alliance, Friends of the Eel River, Karuk Tribe and the Russian and Klamath Riverkeepers in submitting comments on the North Coast Regional Water Quality Control Board’s (Regional Board) proposed Integrated Report for the Clean Water Act Section (CWA) 305(b) Surface Water Quality Assessment and the 303(d) List of Impaired Waters. The coalition has been actively involved in the Regional Board’s Integrated Report process for the last four years.
The letter criticized the Regional Board’s failure to identify North Coast waters that are impaired because of a lack of flow and noted that other states routinely list waterways as “impaired” because of low flow. Lack of flow can be both a contributing source of impairment and a cause of impairment, just as is the case for pollutants. The CWA makes clear that waterways that are impaired by lack of flow should be placed on the 303(d) list. The coalition pointed out that a number of rivers, like the Shasta and Scott, are virtually dewatered during significant periods of the year and obviously qualify as waterways impaired by lack of flow.