ichael Lozau | Drury - PDF document

1 term cont loadi alter to ju d not in
term cont loadi alter to ju d not in C o pract e mbe 27, 2 0 M ichael Lozau | Drury L Oak Street m eda, Califo r ect: o L o Mr. Lozea u e reviewed Irrigated L a I R”) (July 2 8 g -Term Prog r m orandum C o r am” (July 2 ce water an d . The Alte r P EIR does n r ol of conta ermore, the n g to surfac e n e d ge the meri h o mment (2) b i cable contr o ) . rief qualita t 0 eau nia 94501 o n o ng-term Irr i u : he “Draft P r a nds Regula t 8 h r am Develo p o ncerning t h 2 010). I hav e d groundwa t r natives ar e ot evaluate t m inated disc h PEIR provi d e water and e se are fund a ts and short c h e cumulativ b elow. Fin a o l or techno l t ive analysi n the Draft P r i gated Land s r ogram Env i t ory Progra m h ave also re v p ment Staff h e Economic e prepared r monitori n e not Adeq u t he relative e h arges from d es no quan t groundwate mental fla w c omings of t e impact to w a lly, the PEI R l ogy (BPTC s of the alter n 1 r ogram Env i s Regulator y i ronmental I m (ILRP) wi t v iewed the “ Report (Jul y Analysis o f c omments o n n g and man a u atel ffectivenes itative anal y r that woul d w I t he alternati v w ater qualit y R fails to pr ) as require d n atives is as N e w E m i ronmental Program I mpact Rep o t hin the Cen t “ Irrigated L a y 2010) and f the Irrigate n the PEIR t h a gement pra c u ated s of the five operations i y sis of the a m d result from I R that leav e v es. Becaus y cannot be o vide a b asi by Resolu t follows. 2503 Eastbl u w port Beach, C Fax: ail: mhagem mpact Rep o o rt (PEIR) f o tral Valley R a nds Regula t the “Draft T e d Lands Re g h at address p c tices. n the Centr a m implement the reader w e contamin a predicted, a s s to determi n t ion No. 68- 1 u 0 C alifornia 926 6 (949) 717-00 6 Matt Hagema n (949) 887-90 1 a nn@swape.co rt for the o r the Long- R egion” ory Progra m T echnical in the a l Valley. ntaminant tion of the w ith no basi a nt loads are s discussed 16 (Oct. 28, 0 0 6 9 n 3 m Alternative 1, because it is the status quo would fail to reduce contaminant loads and improve water quality and, because it relies on regional or watershed scale monitoring, would not allow for a determination of BPTC. To determine BPTC, monitoring and data comparison is necessary upgradient and downgradient of points of control, i.e., where measures are implemented in the field. Because of the reliance on current management practices and because only regional monitoring is to be used, Alternative 1would not result in measureable improvement to water quaAlternative 2, which includes some groundwater management prdemonstrably reduce contaminant loads and improve water quality. The groundwater management practices include only token wellhead protection measures involve only the placement of dirt in berms adjacent to the wellhead to prevent movement of surface water to the wellhead. These minor improvements are already required under Title 3, California Code of Regulations Division pesticides are mixed, rinsed and stored. s/emon/grndwtr/gwregsinfo0702.pdf) Implementation of these measures more broadly, i.e., at all farms, is not likely to result in significant water quality gains because the berms would only marginally protect against pesticide and nitrate transport in stormwater in the areas where wellheads are address subsurface transport of pesticides and nitrates. No farm-scale monitoring requirements are indetermination of BPTC is not possible. Because only token wellhead protection measures are to be undertaken, Alternativmeasureable water quality improvements and may be just as likely to result in water Alternative 3 requires farm plans that use concerns. This alternative is an improvement and may result in some gains in water quality; however, because no surface water or groundwater monitoring is required, the implementation of this alternative would not result in measureable improvement to water not allow for BPTC determinations. Alternative 4 provides for nutrient management and regional or individual monitoring under a tiered hierarchy. Whereas use of tiering is acceptable in determining the intensity of monitoring, the option to participate in regional scale monitoring would not allow for the determination of BMP effectiveness nor BPTC. Costs under Alternative 4 could also ality information from public water supply systems into a database to compliment the data obtained from Tier 2 and Tier 3 farms that e in regional groundwater mon3, Alternative 4 may provide some gains in wabe measurable because only regional monitoring is required. Alternative 5 requires surface

2 water and groundwater monitoring at indi
water and groundwater monitoring at individual farms and would likely be most protective of water quality. Because discharger-scale monitoring evaluated and a determination of BPTC could be made. As monitoring data from BMPs are evaluated, BPTC can be determined The monitoring under this alternative, however, is duplicitous and overly burdensome. Instead, use of a tiering scheme (i.e., to reduce monitoring at low risk farms in low risk environments) would reduce costs as would better coordination between farms in fulfilling monitoring requirements. For example, if groundwater wells were to be ng at neighboring farms could farm’s downgradient well serving as the adjacent farm’s upgradient location. Alternative 5, while inefficient, would result in the greatest potential for water quality gains because of the monitoring that would be required at farms. , a quantitative estimate of the contaminant loads to surface water and groundwater needs to be integrated Program Description. Additionally, consideration of each alternative’s capability to meet BPTC needs to be incorporated into Chaptescale that allows for the determination of BPTC. Cumulative Impacts on Downstream Ecologic Receptors are not Assessed The PEIR fails to consider cumulative impacts of the alternatives on ecologic receptors the Central Valley, namely the Delta and the San Francisco Bay and Estuary. Wildlife in example, special-status fish species such as the Delta Smelt and anadromous fish such as y, contaminant loading of pesticides and nutrients to upstream waters impacts habitat for these fish and their prey yet no ecies is given in Section 6, Cumulative and Growth-Inducing Impacts. The PEIR states only in Chapter 6: Because many of the existing effects discussed in the section “EImpaired Water Quality on Fish” are cumulative, it is difficult to determine the ources. For example, low DO in the Stockton Deepwater Ship Channel is a result of contamination from upstream ltural runoff) and discharges from the Stockton sewage treatment plant (Lehmaparks and the resultant contaminant runoff also cumulatively contribute to impacts This level of analysis is insufficient and provides no basis for comparison of the cumulative impacts that would result from the fiwritten to estimate and incorporate contaminant loads from agricultural practices on irrigated lands to both surface water and groundwater under each alternative. The contaminant loads should be compared to other contaminant loads to predict cumulative impacts from Central Valley irrigated agriCumulative effects are essential to consider, given the impdownstream ecologic receptors. For example, pelagic organisms such as the delta smelt are in decline in the upper San Francisco Estuary. The decline is not only because of direct smelt mortality from entrainment at pump intakes but also because of exposure of smelt and smelt prey to toxics and nitrogen. om/releases/2010/05/100517161144.htm ater_issues/programs/bay_delta/pelagic_org anism/docs/pod_ieppodmt_2007synthesis_011508.pdf contaminants, including pesticides, have been linked to the decline Upper Sacramento River om/releases/2008/12/081209100940.htm. Cumulative impacts are also important to consider in the decline of anadromous fish, where contaminants are Cumulative impacts are also important to consider in impactexample, the growth of water hyacinth (Eichhornia crassipes) in the Sacramento-San water hyacinth has resulted in impacts n and significant impacts, the PEIR fails to discuss cumulative impacts to water quality, fisheries, and recreation from implementation of the cumulative impacts stems from the fact that contaminant and nutrient loads were not quantifin Comment 1. The PEIR needs to conduct a thorough assessment of cumulative impacts that will include consideration of contaminant contributions from irrigated agricultural lands to surface water and groundwSurface Water Monitoring Required under Alternatives 4 and 5 is Vague The PEIR lacks fundamental detail regarding those alternatives where farm-scale surface water monitoring may be conducted (i.e., Alterna2 and Tier 3 monitoring for Altern stormwater, tile drainage monitoring for constituents stormwater, tile drainage monitoring for constituents The PEIR describes surface water monitoring under Alternative 5 as follows: monitoring and tracking for each field and submit the results to the Central Valley Discharge monitoring for constituents of concern Tailwater discharges monthly. Storm water discharges during the first event of the wet season (between ng the peak storm season (typically Discharges of subsurface (tile) drainage systems annually. (PEIR, p. 3-28) The P

3 EIR is vague on how surface water monito
EIR is vague on how surface water monitoring practices and resultant data would Board would review and approve monitoring plans of third parties and legal entities and would review monitoring reports (PEIR, p. 3-e-certified laboratories, methodology for selection of constituents stormwater sampling (i.e., upgradient/downgradient, pre- and post BMP). We understand the PEIR is a programmatic EIR; however, some level of detail is needed in a revised PEIR to evaluate the effectiveness of the farm-scale surface water monitoring that is to Contaminated Groundwater is not More than two million Californians have been ls of nitrates in contamination and includes, as Figure 5.9-17, a map that shows nitrate contamination to Incredibly, however, the PEIR makes no attempt analyze how nitrogen-based fertilizer contaminated groundwater, the health impacts of that exposure, or how implementation Alternative 1: Nutrient management would improve both surface water quality and groundwater quality by improving the use of chemicals and using improved application techniques, and by limiting the use of nutrientsrient management efforts would somehow improve water quality is not borne out by recent data. In proposed in Alternative 1, has resulted in an increase, statewide, in limit for nitrates, from nine in 1980 to 648 by 2007. (sfgate.com/2010-05- 17/news/20901575_1_nitrate-contamination-water-supply-water-systems wells sampled statewide, 1,077 active and standby drinking water wells have conc of m o stan infa nitra scie be e x The field meas e ntrations o f : //www.swr ty, more th a d ard for nitr a r al Valley. re than 25 y d ard for nitr a : //www.swr ing and impases in nitra t t h effects of e baby synd t stomach c o ’s ability to e diate medi c n ant women t e concentra t n tific studies defects and : //www.swr EIR shoul d x posed to ni t a ssessment ; nitrogen f a toring; and a urement of e o rmance of t h C alifornia ation of nit r e rely, Hagemann, f nitrate abo v c b.ca.gov/w n 40% of p r a te and state w ( http://www ears of dat a a te is growi n c b.ca.gov/g lementation e d r inking exposure to r ome.” Tox i o nvert nitrat e carry oxyge al care sinc e are suscept i t ions in thei r suggest a li n certain typ e c b.ca.gov/w be rewritte n t rates in dri n o f each alter n a te and tran s a summary n e ach of the a h e alternati v D epartment ate trends. v e the drink i a ter_issues/ ivate dome s w ide, the m a . swrcb.ca.g , the numb e n g as a perce n a ma/docs/ek of Alternat i w ater violat i nitrates mo s i c effects of e to more to n to body ti s e the conditi i ble to meth e r drinking w n kage betw e e s of cance r . ter_issues/ to include n king water f n ative shoul d s port in soil, n itrogen im p a lternatives e that is sel e o f Public He a 6 ng water st a p rograms/ga tic water w e a jority of nit r o v/gama/do r of wells t h n tage of all n d ahl_gra20 ves 1 and 2 i ons in the C s t notably r e m ethemogl ic nitrite, a s sues. Infan t on can lead e moglobine ater are at s a e en high nitr rograms/ga an assessm e f rom agricul t d include a n surface wa t p acts to wat e i s critical. A e cted shoul d a lth databas e a ndard of 45 a ma/docs/co lls exceed t rate exceed e c s/ekdahl_g at exceed t h n itrate dete c 0 9.pdf) Cle a would likel y C entral Vall e e sults in met h o binemia oc c a process th a n ts with thes e to coma an d m ia and sho u a fe levels. A r ate levels i n a ma/docs/co nt of the po t ural practic n estimate o f t er, and gro u e r supplies. L A n annual as d be require d e should be 5 mg/L. c _nitrate.pd nces appea r r a2009.pdf e drinking w c tions. rly the stat u y lead for f u e y. hemoglobi ur when b a a t interferes w e symptoms d eventually u ld be sure t A dditionall drinking w a c _nitrate.pd tential for t h es in the Ce n f nitrogen lo a u ndwater; ni t L inking mo n sessment o f d required as a f ) In Tulare water to be in th e O n the basi s w ater s quo is not u rther emia or a cteria in the w ith the t hat the y , some a ter with f ) e public to n tral Valley a ding to t rogen itoring to f the he 13,000- a tool for e s conc e (http : Cou n stan d Cent r of m o stan d (http : wor k incre t “blu e infa n b odyimm e Preg n nitra t scie n b irth (http : P be e x The a field s mon i meas o well C eval u e Matt e ntrations o f : //www.swr c n ty, more th a d ard for nitr a r al Valley. ( o re than 25 y d ard for nitr a : //www.swr c k ing and impases in nitra t t h effects of e baby synd r n t stomach c o ’s ability to e diate medi c n ant women t e concentra t n

4 tific studies defects and : //www.swr c
tific studies defects and : //www.swr c P EIR shoul d x posed to ni t a ssessment o s ; nitrogen f a toring; and a urement of e o rmance of t h C alifornia D u ation of nit r e rely, Hagemann, f nitrate abo v c b.ca.gov/w a a n 40% of p r a te and state w ( http://www . y ears of dat a a te is growi n c b.ca.gov/g a lementation t e d r inking w exposure to r ome.” Tox i o nvert nitrat e carry oxyge n c al care sinc e are suscept i t ions in thei r suggest a li n certain typ e c b.ca.gov/w a d be rewritte n t rates in dri n o f each alter n a te and tran s a summary n e ach of the a h e alternati v D epartment o r ate trends. v e the drink i a ter_issues/ p r ivate dome s w ide, the m a . swrcb.ca.g o a , the numb e n g as a perce n a ma/docs/ek d of Alternat i w ater violat i nitrates mo s i c effects of e to more to n to body ti s e the conditi i ble to meth e r drinking w n kage betw e e s of cance r . a ter_issues/ p n to include n king water f n ative shoul d s port in soil, n itrogen im p a lternatives i v e that is sel e o f Public He a 6 i ng water st a p rograms/ga m s tic water w e a jority of nit r o v/gama/do c e r of wells t h n tage of all n d ahl_gra20 0 i ves 1 and 2 i ons in the C s t notably r e m ethemogl o x ic nitrite, a s sues. Infan t on can lead e moglobine m ater are at s a e en high nitr p rograms/ga m an assessm e f rom agricul t d include a n surface wa t p acts to wat e i s critical. A e cted shoul d a lth databas e a ndard of 45 a ma/docs/co c e lls exceed t rate exceed e c s/ekdahl_g r h at exceed t h n itrate dete c 0 9.pdf) Cle a would likel y C entral Vall e e sults in met h o binemia oc c a process th a n ts with thes e to coma an d m ia and sho u a fe levels. A r ate levels i n a ma/docs/co c e nt of the po t ural practic n estimate o f t er, and gro u e r supplies. L A n annual as d be require d e should be 5 mg/L. c _nitrate.pd f t he drinking e nces appea r r a2009.pdf) O h e drinking w c tions. a rly the stat u y lead for f u e y. t hemoglobi n c ur when b a a t interferes w e symptoms d eventually u ld be sure t A dditionall y n drinking w a c _nitrate.pd f tential for t h es in the Ce n f nitrogen lo a u ndwater; ni t L inking mo n sessment o f d and use of t required as a f ) In Tulare water r to be in th e O n the basi s w ater u s quo is not u rther n emia or a cteria in the w ith the t hat the y , some a ter with f ) h e public to n tral Valley a ding to t rogen n itoring to f the t he 13,000- a tool for e s . Letter 13 - Att G monitoring and tracking for each field and submit the results to the Central Valley Discharge monitoring for constituents of concern Tailwater discharges monthly. Storm water discharges during the first event of the wet season (between ng the peak storm season (typically Discharges of subsurface (tile) drainage systems annually. (PEIR, p. 3-28) The PEIR is vague on how surface water monitoring practices and resultant data would Board would review and approve monitoring plans of third parties and legal entities and would review monitoring reports (PEIR, p. 3-e-certified laboratories, methodology for selection of constituents stormwater sampling (i.e., upgradient/downgradient, pre- and post BMP). We understand the PEIR is a programmatic EIR; however, some level of detail is needed in a revised PEIR to evaluate the effectiveness of the farm-scale surface water monitoring that is to Contaminated Groundwater is not More than two million Californians have been ls of nitrates in contamination and includes, as Figure 5.9-17, a map that shows nitrate contamination to Incredibly, however, the PEIR makes no attempt analyze how nitrogen-based fertilizer contaminated groundwater, the health impacts of that exposure, or how implementation Alternative 1: Nutrient management would improve both surface water quality and groundwater quality by improving the use of chemicals and using improved application techniques, and by limiting the use of nutrientsrient management efforts would somehow improve water quality is not borne out by recent data. In proposed in Alternative 1, has resulted in an increase, statewide, in limit for nitrates, from nine in 1980 to 648 by 2007. (sfgate.com/2010-05- 17/news/20901575_1_nitrate-contamination-water-supply-water-systems wells sampled statewide, 1,077 active and standby drinking water wells have Letter 13 - Att G to predict cumulative impacts from Central Valley irrigated agriCumulative effects are essential to consider, given the impdownstream ecologic receptors. For example, pelagic organisms such as the delta smelt are in decli

5 ne in the upper San Francisco Estuary.
ne in the upper San Francisco Estuary. The decline is not only because of direct smelt mortality from entrainment at pump intakes but also because of exposure of smelt and smelt prey to toxics and nitrogen. om/releases/2010/05/100517161144.htm ater_issues/programs/bay_delta/pelagic_org anism/docs/pod_ieppodmt_2007synthesis_011508.pdf contaminants, including pesticides, have been linked to the decline Upper Sacramento River om/releases/2008/12/081209100940.htm. Cumulative impacts are also important to consider in the decline of anadromous fish, where contaminants are Cumulative impacts are also important to consider in impactexample, the growth of water hyacinth (Eichhornia crassipes) in the Sacramento-San http://www.dbw.ca.gov/PDF/Egeria/WHSciProbsExcerpts.pdf water hyacinth has resulted in impacts n and significant impacts, the PEIR fails to discuss cumulative impacts to water quality, fisheries, and recreation from implementation of the cumulative impacts stems from the fact that contaminant and nutrient loads were not quantifin Comment 1. The PEIR needs to conduct a thorough assessment of cumulative impacts that will include consideration of contaminant contributions from irrigated agricultural lands to surface water and groundwSurface Water Monitoring Required under Alternatives 4 and 5 is Vague The PEIR lacks fundamental detail regarding those alternatives where farm-scale surface water monitoring may be conducted (i.e., Alterna2 and Tier 3 monitoring for Altern stormwater, tile drainage monitoring for constituents stormwater, tile drainage monitoring for constituents The PEIR describes surface water monitoring under Alternative 5 as follows: Letter 13 - Att G would be required, BMP effectiveness could be evaluated and a determination of BPTC could be made. As monitoring data from BMPs are evaluated, BPTC can be determined The monitoring under this alternative, however, is duplicitous and overly burdensome. Instead, use of a tiering scheme (i.e., to reduce monitoring at low risk farms in low risk environments) would reduce costs as would better coordination between farms in fulfilling monitoring requirements. For example, if groundwater wells were to be ng at neighboring farms could farm’s downgradient well serving as the adjacent farm’s upgradient location. Alternative 5, while inefficient, would result in the greatest potential for water quality gains because of the monitoring that would be required at farms. , a quantitative estimate of the contaminant loads to surface water and groundwater needs to be integrated Program Description. Additionally, consideration of each alternative’s capability to meet BPTC needs to be incorporated into Chaptescale that allows for the determination of BPTC. Cumulative Impacts on Downstream Ecologic Receptors are not Assessed The PEIR fails to consider cumulative impacts of the alternatives on ecologic receptors the Central Valley, namely the Delta and the San Francisco Bay and Estuary. Wildlife in example, special-status fish species such as the Delta Smelt and anadromous fish such as y, contaminant loading of pesticides and nutrients to upstream waters impacts habitat for these fish and their prey yet no ecies is given in Section 6, Cumulative and Growth-Inducing Impacts. The PEIR states only in Chapter 6: Because many of the existing effects discuImpaired Water Quality on Fish” are cumulative, it is difficult to determine the irrigated lands and other sources. For example, low DO in the Stockton Deepwater Ship Channel is a result of contamination from upstream nonpoint sources (possibly including agricultural runoff) and discharges from the Stockton sewage treatment plant (Lehmaparks and the resultant contaminant runoff also cumulatively contribute to impacts This level of analysis is insufficient and provides no basis for comparison of the cumulative impacts that would result from the fiwritten to estimate and incorporate contaminant loads from agricultural practices on irrigated lands to both surface water and groundwater under each alternative. The contaminant loads should be compared to other contaminant loads Letter 13 - Att G the status quo would fail to reduce contaminant loads and improve water quality and, because it relies on regional or watershed scale monitoring, would not allow for a determination of BPTC. To determine BPTC, monitoring and data comparison is necessary upgradient and downgradient of points of control, i.e., where measures are implemented in the field. Because of the reliance on current management practices and because only regional monitoring is to be used, Alternative 1would not result in measureable improv

6 ement to water quaAlternative 2, which i
ement to water quaAlternative 2, which includes some groundwater management prdemonstrably reduce contaminant loads and improve water quality. The groundwater management practices include only token wellhead protection measures involve only the placement of dirt in berms adjacent to the wellhead to prevent movement of surface water to the wellhead. These minor improvements are already required under Title 3, California Code of Regulations Division pesticides are mixed, rinsed and stored. http://www.cdpr.ca.gov/docs/emon/grndwtr/gwregsinfo0702.pdf) Implementation of these measures more broadly, i.e., at all farms, is not likely to result in significant water quality gains because the berms would only marginally protect against pesticide and nitrate transport in stormwater in the areas where wellheads are address subsurface transport of pesticides and nitrates. No farm-scale monitoring requirements are indetermination of BPTC is not possible. Because only token wellhead protection measures are to be undertaken, Alternativmeasureable water quality improvements and may be just as likely to result in water Alternative 3 requires farm plans that use concerns. This alternative is an improvement and may result in some gains in water quality; however, because no surface water or groundwater monitoring is required, the implementation of this alternative would not result in measureable improvement to water not allow for BPTC determinations. Alternative 4 provides for nutrient management and regional or individual monitoring under a tiered hierarchy. Whereas use of tiering is acceptable in determining the intensity of monitoring, the option to participate in regional scale monitoring would not allow for the determination of BMP effectiveness nor BPTC. Costs under Alternative 4 could also be reduced by incorporating groundwater quality information from public water supply systems into a database to compliment the data obtained from Tier 2 and Tier 3 farms that e in regional groundwater mon3, Alternative 4 may provide some gains in wabe measurable because only regional monitoring is required. Alternative 5 requires surface water and groundwater monitoring at individual farms and would likely be most protective of water quality. Because discharger-scale monitoring Letter 13 - Att G Sept e M Loze m j term I Lon g Me m Prog r surfa1 P cont r Furt h loadi n alter n to ju d not q in C o pract b e mbe r 27, 2 0 M ichael Loz L Oak Street m eda, Califo r ect: C o L o Mr. Lozea u e reviewed t Irrigated L a I R”) (July 2 8 g -Term Prog r m orandum C o r am” (July 2 ce water an d . The Alte r P EIR does n r ol of conta m h ermore, the n g to surfac e n atives. Th e d ge the meri h o mment (2) b i cable contr o ) . b rief qualita t 0 eau L LP r nia 94501 o mments o n o ng-term Irr i u : t he “Draft P r a nds Regula t 8 , 2010). I h r am Develo p o ncerning t h 2 010). I hav e d groundwa t r natives ar e ot evaluate t m inated disc h PEIR provi d e water and e se are fund a ts and short c h e cumulativ b elow. Fin a o l or techno l t ive analysi s n the Draft P r i gated Land s r ogram Env i t ory Progra m h ave also re v p ment Staff h e Economic e prepared c t e r monitori n e not Adeq u t he relative e h arges from d es no quan t groundwate r a mental fla w c omings of t e impact to w a lly, the PEI R l ogy (BPTC s of the alter n 1 r ogram Env i s Regulator y i ronmental I m (ILRP) wi t v iewed the “ Report (Jul y Analysis o f c omments o n n g and man a u atel y Eval u e ffectivenes s agricultural t itative anal y r that woul d w s of the PE I t he alternati v w ater qualit y R fails to pr o ) as require d n atives is as N e w E m i ronmental I y Program I mpact Rep o t hin the Cen t “ Irrigated L a y 2010) and f the Irrigate n the PEIR t h a gement pra c u ated s of the five operations i y sis of the a m d result from I R that leav e v es. Becaus y cannot be o vide a b asi s d by Resolu t follows. 2503 Eastbl u w port Beach, C Fax: Tel: m ail: mhagem a I mpact Rep o o rt (PEIR) f o tral Valley R a nds Regula t the “Draft T e d Lands Re g h at address p c tices. alternatives i n the Centr a m implement a e the reader w e contamin a predicted, a s s to determi n t ion No. 68- 1 u ff Dr, Suite 2 0 C alifornia 926 6 (949) 717-00 6 Matt Hagema n (949) 887-90 1 a nn@swape.co o rt for the o r the Long- R egion” t ory Progra m T echnical g ulatory p in the a l Valley. ntaminant a tion of the w ith no basi a nt loads are s discussed n 16 (Oct. 28, 0 6 6 0 6 9 n n 1 3 m m s Letter 13 - Att