e-mail from Keith Lichten,
Regional Water Quality Control Board, to
Greg Bartow, San Francisco Publich Utilities
Commission,
accepting the proposed monitoring plan subject
to terms included in the following discussion:
Greg,
Thank you for your email and for your patience. As discussed
below, we
do accept the proposed monitoring plan. We have the following
additional discussion.
As we discussed Friday, we remain concerned that the sampling may be of
limited utility in addressing any potential public health and
beneficial uses impacts to Lake Merced resulting from the discharge of
large volumes of stormwater into the Lake, either directly or, perhaps,
through a wetland filter. We recognize that the current sampling
is
not intended to characterize Lake circulation or provide detailed
information such as change over time in coliform levels in the Lake
after a stormwater runoff event. Additional sampling may be
needed in
the future to address the potential impacts of stormwater diversions
with respect to public health and beneficial uses, before more
permanent or larger-scale projects should be implemented. As a
part of
that, it will also be important to consider what opportunities are
present to communicate to Lake users any potential water quality issues.
We strongly support the collaboration of Daly City and SFPUC staff, and
welcome it as, indeed, necessary in order to develop a solution that
may be capable of addressing upstream flooding issues and opportunities
to augment Lake levels. Additionally, we support in concept
proposals
such as the current draft/conceptual proposal, which is (or which may
be?) to use freshwater stormwater runoff to augment Lake levels after
discharging it through a constructed wetland filter.
As you state, we strongly support attempts to sample Lake water quality
within 24 hours of a rainfall--and particularly 24 hours of a runoff
event. This has the potential to suggest, at least anecdotally,
whether current sampling may be capturing peak pollutant levels
resulting from runoff events.
Also as you state, we understand that you will work to set up, within
the next month, a meeting to discuss statistical analysis issues on the
sampling. This meeting will include Daly City and SFPUC
staff/consultants (including those sufficiently versed in statistical
analysis to discuss the project's approach and whether there may be
opportunities to look at different analytical methods), Water Board
staff, and members of the interested public (including John Plummer).
Again, we support SFPUC's and Daly City's combined efforts, and are
hopeful that your work will result in a win-win that can reduce Daly
City flooding, help Lake levels, and appropriately protect public
health and beneficial uses at the Lake (maybe that's
win-win-win?). We
accept the 2005-2006 Lake Merced Sampling Plan prepared by EOA, Inc.,
with the two conditions described above.
Please contact me as below if you have any questions or comments on
this matter.
Regards,
-Keith H. Lichten, P.E.
Senior Engineer
San Francisco Bay Regional Water Quality Control Board
1515 Clay Street, Suite 1400
Oakland, CA 94612
(510) 622-2380 direct
(510) 622-2460 fax
klichten@waterboards.ca.gov
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