Introduction: 303(d) Water Quality Impairment Listings
This section of the Clean Water Act calls for identification and listing of impaired waterways on what is known as the 303(d) Impaired Water Bodies List. Scientific validation of specific pollutants is a significant component of the listing process. It is usually reviewed every two years. Of the 84,000 chemicals in existence, only a minute number are tested.
Currently the Russian River and tributaries are listed for temperature and sediments. Some segments are also listed for pathogens and the Regional Board is considering inclusion of the entire river and its tributaries. In addition, the very degraded Laguna de Santa Rosa (major tributary to Russian River) is also listed for nitrogen, phosphorus, dissolved oxygen, pathogens, dissolved oxygen, and Mercury. After listing occurs, sources and quantities are determined and stringent limits assigned, under the ‘total daily maximum load’ (TMDL) process.
RRWPC strongly advocated for the listing of the lower river for nutrients in 2010. While it has not formally happened as yet, nutrients have been included in all monitoring protocols assigned by Regional Board. Because clear numeric standards have not yet been established, specific permit limits have not been determined but there is a general acceptance that nutrient pollution in the lower river is a problem.
- RRWPC to State Water Board, April 7, 2015: Letter regarding SCWA data that phosphorus in the Russian River in 2014 was out of compliance at all monitoring sites along the lower River.
- Linda Sheehan, Earth Law Center, 8-8-2014: Letter to North Coast Regional Board regarding Resolution No. R120140043 and Staff Report for the 2012 Integrated Report for the Clean Water Act Section 305(b) Surface Water Quality Assessment and the 303(d) List of Impaired Waters. For many years, RRWPC has been concerned about persuading the State and Regional Boards to consider low flow as a water quality impairment, but there has been great resistance on their part to do so. During this most recent impairment listing process, Linda and a group of ten organizations wrote a brilliant letter that addresses many of the key issues. We include that here for your information.
- Comments to J. Shu of the State Water Board, 8-30-2010: RRWPC’s recommendations for the 2012 303(d) listings currently being reviewed by the State.
- List of Attachments: Comments to J. Shu of the State Water Board, 8-30-2010 Some of attachments have active links to documents or photos.