The Regional Water Board proposes to establish a Total Maximum Daily Load (TMDL) based on a proposed Garcia River Watershed Water Quality Attainment Strategy for Sediment (Strategy) and to adopt a corresponding amendment to the Water Quality Control Plan for the North Coast Region (Basin Plan). Alternatives to the proposed action include: 1) No Action; 2) Accept the Garcia River Sediment Total Maximum Daily Load promulgated by U.S. Environmental Protection Agency, Region IX, on March 16, 1998, and adopt only the Implementation Plan and Monitoring Plan sections of the proposed Basin Plan amendment; 3) Postponement of action to a later date; and 4) Adoption of a modified Strategy and/or Basin Plan amendment for the Garcia River .
This alternative will result in the need for the Regional Water Board to incorporate a Garcia River Sediment Total Maximum Daily Load established by the USEPA.. The USEPA, Region IX promulgated a Garcia River Sediment Total Maximum Daily Load on March 16, 1998. Under the terms of the Clean Water Act, this alternative would not relieve the Regional Water Board of its obligations to incorporate a TMDL for the Garcia River into its Basin Plan and to implement the TMDL.
Alternative 2. Accept the Garcia River Sediment Total Maximum Daily Load promulgated by U.S. Environmental Protection Agency, Region IX, on March 16, 1998, and adopt only the Implementation Plan and Monitoring Plan sections of the proposed Basin Plan amendment.
This alternative may satisfy the requirements of the federal Clean Water Act. However, this alternative will result in a TMDL that might not accurately depict on-site conditions and provides neither a schedule nor a means for compliance. This alternative would be a. significant change to the proposed Basin Plan amendment, and would require future public notice and comment.
Alternative 3. Postponement of action to a later date.
The short-term result of this action would be similar to that discussed under Alternative 1.
Alternative 4. Adoption of a modified Strategy and/or Basin Plan amendment for the Garcia River.
The Regional Water Board may adopt a modification to the Strategy and/or Basin Plan amendment as long as it is considered to be a logical out growth of the proposed action. However, if the modifications are not a logical out growth of the proposed action, future public notice and comment will be required.
Significant changes to the Staff Report dated December 9, 1997 are indicated by bold font and strikeover.
The proposed Basin Plan amendment will increase fish populations in the Garcia River. Although no attempt is made in this discussion to consider what portion of the loss of the Garcia River fishery is attributable to sediment compared to overfishing or other stressors, higher fish populations will benefit the public by increasing opportunities for recreational fishing and benefit the commercial fishing industry by increasing catches of salmon. It is not possible to estimate these benefits with any certainty, because it is not known exactly how fish populations will increase following implementation of the proposed basin plan amendment. However, estimates are available of the decline in fish populations occurring since the late 1960s. These estimates, discussed in more detail below, indicate that the deterioration in water quality that has occurred since the late 1960s is resulting in a loss of $370,000 annually to the commercial fishing industry and is resulting in lost recreational values of and other public values of about $90,000 annually. This figure gives an indication of the magnitude of the problem and puts the cost of implementing the plan in perspective.
Commercial Fishing. According to the Department of Fish and Game, fish populations in the Garcia River have fallen by 70 percent since the late 1960s. This drop in river salmon population in will result in lower ocean populations, which will reduce commercial catches. An estimate of the effect of the fall in fish populations commercial fishing operations is developed in Table 2. This estimate indicates that net incomes of commercial fishing operations have been reduced by an estimated $370,000 annually by the drop in fish population in the Garcia River.
Recreational Fishing. Lower fish populations will also tend to reduce ocean sport fishing. Losses to ocean anglers can be estimated by applying an estimate of the reduction in fishing days resulting from the lower fish population to the value of a day’s fishing to an angler. This value is the difference between the maximum that an angler would be willing to pay for a day’s fishing and the actual cost of the trip. Surveys of anglers and studies of the travel costs that ocean anglers are willing to incur indicate that the net value of a day’s fishing is about $72. This figure represents the value lost if a declining fish population deters anglers from taking trips. The lost value to anglers resulting from reduced opportunities for ocean fishing is $46,000 annually (see Table 4).
Losses to anglers fishing on the river itself are estimated in a similar way. Details are in Table 4. The total lost value resulting from decreased opportunities for inland fishing is $14,000 annually.
Other Values. In addition to these losses, the deterioration in water quality results in a loss in value to the general public. Just as anglers derive value from active use of the fishery by catching fish, the general public derives value from visiting in the area and knowing that the river is in good condition. This nonuse value is of significant importance. A review of studies of the use and nonuse values associated with improved water quality and fisheries (Fisher and Raucher 1984) indicates that nonuse values are at least half as great as recreational use values. Other studies have indicted that nonuse values can be more than twice recreational use values (Sutherland and Walsh 1985, Sanders et al. 1990). Applying the more conservative figure to total recreational benefits the loss in value to the general public resulting from deterioration in water quality in the Garcia River is about $30,000 annually.
Table 4. Losses Resulting From Declining Fish Populations in the Garcia River
(NOTE: TABLE 4 NOT AVAILABLE AT THIS TIME)
Costs of the Proposed Basin Plan Amendment
The proposed Basin Plan amendment sets forth land use measures which are needed to decrease the discharge of controllable sediment to the Garcia River. As such, the analysis which follows of the economics resulting from adoption of the proposed Basin Plan amendment will focus on the cost of compliance. It is recognized that because the Basin Plan amendment sets forth general practices, there are unknown factors associated with determining the actual costs of compliance. The costs for implementing the land use practices set forth in the proposed Basin Plan amendment will take place over a time period of twenty to fifty years. Sustained Yield Plans, which may be accepted by the Regional Water Board as providing sufficient information to demonstrate compliance to the proposed Basin Plan amendment, have objectives for even longer time periods of up to one hundred years. Because of the very long term nature of achieving compliance, it is very difficult to arrive at a true picture of net costs and benefits. In addition, many of the measures set forth in the proposed Basin Plan amendment will be completed either voluntarily or as a result of other laws and regulations, which include the Forest Practices Act, the Endangered Species Act, the Garcia River Gravel Management Plan, and local permitting regulations. The costs and benefits of the proposed Basin Plan amendment will be borne by land owners in the Garcia River Watershed and the public.
The proposed Basin Plan amendment will require landowners who do not
voluntarily choose to develop their own site specific
land management practices that will prevent future sediment delivery to
the waters of the State, to either cease discharges of sediment, comply
with specific management practices including road design, construction,
and reconstruction measures. In order to encourage voluntary compliance,
avoid duplicity in planning efforts, and minimize costs, the proposed Strategy
and Basin Plan amendment permits land owners to submit Ranch Management
Plans, Non-Industrial Timber Management Plans, Sustained Yield Plans, and/or
Habitat Conservation Plans that contain site specific land management practices
that will result in water quality protection and restoration roughly equivalent
to the Basin Plan amendment. For gravel operations, The Garcia River
Gravel Management Plan will be utilized whenever possible to demonstrate
compliance with the land use management practices set forth in the proposed
Basin Plan amendment.
The Garcia River watershed encompasses an area of 73,223 acres. It is
estimated that approximately 14,000 acres within the Garcia River watershed
are used for agricultural purposes. To date, 80% of the commercial Ranch
Owners within the watershed, estimated to encompass 2,200 acres of land
within the watershed, have committed to submit letters of intent to develop
a Ranch Management Plan on a voluntary basis for their
properties. Also, two major timber companies, Coastal Forestlands and
Louisiana-Pacific Corporation, estimated to encompass approximately 37,000
acres, have already or are in the process of preparing Sustained Yield
Plans. Because of this widespread voluntary effort, the additional
Additional costs associated with the proposed Basin Plan amendment
will likely apply primarily to the landowners who are not currently involved
in efforts to reduce sediment discharge in the Garcia River watershed.
It can be estimated that 73,223 -(.8 x 2,200) - 37,000, or approximately
34,463 acres of land, (land area encompassing 47% of the watershed), will
voluntarily comply with the proposed Strategy and Basin
Plan amendment by submitting a Site-Specific Sedimentation Reduction Plan
but that 53% of the watershed will bear additional costs directly resulting
from the proposed Strategy and Basin Plan amendment. For convenience, this
figure is also used in later discussion to provide estimates for the costs
of inventories, field fencing, and road maintenance. For the purposes of
discussion, however, costs will be projected for the entire watershed,
and also for the portion of the watershed estimated to be most affected,
which is estimated to be 53% of the watershed. In addition, to minimize
costs and to provide a consistency of approach, Regional Water Board staff
will encourage landowners within watershed planning areas to combine planning
and sediment control efforts wherever possible.
1. The Baseline Data Inventories
The proposed Basin Plan amendment will require land owners to conduct
an inventory of the sources of sedimentation on their properties to provide
a basis for establishing a program for reducing the sources. Regional Board
staff intends to set up a training session or sessions for landowners who
will need to prepare inventories as a result of the proposed Basin Plan
amendment to better prepare land owners to conduct their own inventories.
It is expected than an inventory would be valid unless the use of the land
changed significantly. A cost range of $200 to $400 per mile of road
for professional services to prepare the inventories was provided by Pacific
Watershed Associates. There are an estimated 116 miles of known permanent
(all season) roads, 344 miles of known seasonal roads, and 72 miles of
known temporary roads (jeep road/timber operations only) in the Garcia
River watershed. For this analysis it is assumed that all of these roads
could potentially produce sediment delivery, and are therefore subject
to the standard of practice set forth in the proposed Strategy and Basin
Plan amendment. It can be assumed that the costs for conducting an inventory
of skid trails and other potential sources of sediment delivery would be
approximately the same, per mile. As more information is developed as to
the extent of the potential delivery sites, the estimates for the costs
of the inventories can be revised, if necessary, at a future date. Using
the cost range of $200 to $400 per mile of road, it is estimated that a
high-end cost for conducting the inventories could range from $68,000
to $137,600 $106,400 to $212,800 for the entire watershed,
but is more likely to range from 53% x ($106,400 to $212,800), or $56,932
to $112,800. It should be kept in mind, however, that professional
services will not be required to conduct all of the inventories, and that
the Regional Water Board will encourage landowners to conduct their own
inventories whenever appropriate.
2. Loss of Riparian Growing Area
The proposed Basin Plan amendment is likely to restrict land use and require additional land management practices in areas within the Garcia River Watershed which are classified as being within a Riparian Management Zone. In addition, the value of the land in the riparian management zone may or may not change as a result of the proposed Strategy and Basin Plan amendment. The restrictions and additional practices will apply to land area adjacent to watercourses which directly support beneficial water uses (known as Class I and II watercourses under Forest Practice rules), and watercourses which do not directly support beneficial uses (known as Class III watercourses under Forest Practice rules). The affected land area will be a 100-foot strip of land of each side of Class I and II watercourses and a 50-foot strip of land on each side of Class III watercourses. Within the Garcia River Watershed, there are 140 miles of known Class I and Class II watercourses, and 245 miles of Class III watercourses. Potentially, the total affected area for Class I and II watercourses could be 140 x 2 = 280 miles x 100 feet, or 3,394 acres and for Class III watercourses could be 245 x 2 = 490 miles x 50 feet, or 2,970 acres.
Losses Due to Restrictions in Land Use: Timber companies have indicated that approximately 6% of their total volume comes from the near stream riparian protection area - widths from 75 feet to 150 feet on Class I streams. A 25-foot no cut or management zone is not comprised of significant merchantable material, and may represent a loss in volume of less than 1% (probably less than 0.5%). (Source: Alan Levine)
Loss of riparian growing area in managed agricultural areas under Range Management Plans would be a similarly low figure. (Source: Alan Levine)
In some circumstances, the proposed Basin Plan amendment may require
that fencing be installed to restrict livestock from the Riparian Management
Zone. It is estimated that approximately 14,000 acres within the Garcia
River watershed are used for agricultural purposes. It is estimated that
30 miles of Class I and II watercourse are located within portion of the
watershed used for agricultural purposes. An estimated cost for New Zealand
fencing, based on values provided by ranchers in the Stemple Creek watershed
is $3 per foot. Therefore, a maximum one-time cost of $3 x 30 miles x 5,280
feet per mile x 2 = $950,400 for fencing is estimated for the entire Garcia
River watershed. However, eighty percent of the commercial agricultural
land owners, estimated to encompass 80% x 2,200 acres or 1,760 acres, encompassing
an estimated 12% of the entire watershed, have indicated through letters
of intent that they will voluntarily comply with the Basin Plan amendment.
In addition it is estimated that 53% of the remaining agricultural land
owners will voluntarily comply with the Basin Plan amendment. Using those
estimates for voluntary compliance, it It is estimated that for
the portion of the watershed probably affected by the proposed Basin Plan
amendment due to nonvoluntary compliance is at most [53% x $950,400] -
[12% x $950,400] = $389,664. As an alternative to field fencing, riparian
management zone protection may result in relocation of water sources for
livestock. No estimate for this potential cost is provided.
Estimated Costs for Additional Land Management Practices: The proposed Basin Plan amendment seeks that landowners establish and maintain 100% surface vegetation within the Riparian Management Zone. To implement this requirement, the use of the land within the Riparian Management Zone may be restricted. In addition, there are costs associated with stabilizing soils within the Riparian Management Zone.
A cost to stabilize exposed soil is estimated to be $120 per acre when mulch is used. This estimate is based on the cost for straw of $60 per ton and an application rate of 2 tons per acre.
A cost to stabilize exposed soil is estimated to be $42,560 per acre when rock is used. This estimate based on recent costs incurred by a private land owner to provide bank stabilization with rock in Sonoma County in 1996.
For the purposes of this discussion, it is assumed that 1% of the Riparian Management Zone will require stabilization. This estimate is based on field observation. Using that assumption, a one-time cost for stabilization could range from $120 x (3,394 + 2,970) x .01 = $7,637 if mulch is used, to $42,560 x (3,394 + 2,970) x .01 = $2,708,518 if rock is used. This range of estimates applies to the entire watershed. An estimated range of costs to the approximately 53% of the land area that is likely to be affected by the proposed Basin Plan amendment is from $7,637 x 53%, or $4,048 (for mulch), to $2,708,518 x 53% = $1,435,514 (for rock).
3. Costs of Increased Road Maintenance
There are an estimated 116 miles of known permanent (all-season) roads, 344 miles of known seasonal roads, and 72 miles of known temporary road (jeep road/timber operations only) in the Garcia River watershed. For this analysis, it is assumed that all of these roads could potentially deliver sediment to a watercourse, and are therefore subject to the standard of practice set forth in the proposed Basin Plan amendment. The cost to bring or maintain these roads into compliance with the measures set forth in the proposed Basin Plan amendment is estimated to be approximately $500/mile/year. This estimate is based on costs reported to have been incurred by a private land owner in Sonoma County between 1990 and 1994 for comparable road construction and maintenance, and is amortized over the expected life of the road. Using that cost estimate, it can be projected that the costs of increased road maintenance which may result from the proposed Basin Plan amendment would be $500 x (116 + 344 + 72) = $266,000 per year for the entire Garcia River watershed. An estimated cost for the approximately 53% of the land area that is likely to be affected by the proposed Basin Plan amendment is $266,000 x 53% = $140,980.
There will be costs, not set forth at this time, for road abandonment. The proposed Strategy sets forth a goal of reducing area covered by roads, land and skid trails by 30%, and would add 3% to 5% to the land areas capable of forest production, thus improving production and income over time. The stabilization and prevention of soil loss from erosion sites will enhance land productivity over time. (Source: Alan Levine)
Monitoring of the effects of the proposed Strategy and Basin Plan amendment will require a minimum of one sampling location within each of the twelve hydrologic subwatersheds within the Garcia River watershed. This expense will be borne by the Regional Water Quality Control Board. In addition, the proposed Monitoring Plan may require a landowner to monitor sites on his or her property in order to assess the progress towards compliance with the targets set forth in the Strategy. There are no laboratory costs associated with the monitoring, and it is expected that the landowner could conduct the needed field measurements without assistance. The costs associated with monitoring will be the time required for landowners to conduct the monitoring, which are estimated to be two man-days per year for each small landowner who submits a Site Specific Sedimentation Reduction Plan or who complies with the Garcia River Watershed Sedimentation Reduction Plan. Landowners of larger properties are expected to bear additional costs for monitoring.
Restoration efforts, which will involve the use of public and private funds, is an element of the proposed Basin Plan amendment. Potential public funding sources for restoration efforts include grants to implement Sections 205(j) and 319(h) of the federal Clean Water Act. These funding sources are administered through the State Water Resources Control Board. Additional potential funding sources and sources of assistance for landowners are listed below.
The National Conservation Reserve Initiative Program (CRP), administered through the United States Department of Agriculture (USDA), is an attempt to use grass and trees to protect and enhance streams. The USDA pays up to 50% of the cost to establish buffers; the agency also makes an annual rental payment on the land being conserved for the life of the CRP contract, an estimated 10 to 15 years. An additional 20% incentive payment over the rental can be paid for certain buffers such as riparian forest buffers and filter strips. The program allows for continuous sigh-up through the USDA's Farm Service Agency under the Conservation Reserve Program.
Salmon and Steelhead Restoration Account (SSRA) Senate Bill 271, sponsored by Senator Mike Thompson, and administered by the California Department of Fish and Game
This account, which resulted from Senate Bill 271, is administered by the Department of Fish and Game. Funds from this account may be used primarily for salmon and steelhead restoration in coastal drainages in California and provides for $3,000,000 for 1998, and $8,000,000 per year until year 2004, for finding solutions to the problems affecting salmon and steelhead fisheries. Under this program, grant money is available for watershed evaluation, assessment, and planning, project evaluation, monitoring, and maintenance, and private sector technical training and education.
Wildlife Habitat Incentives Program (WHIP)
This voluntary program provides cost-share payments to help establish and improve fish and wildlife habitat. Agreements are developed between the U.S. Department of Agriculture's Natural Resources Conservation Service and private landowners , wildlife agencies, and nonprofit or private organizations, for a period of five to ten years. Under the agreements, the landowner agrees to install and maintain the WHIP practices and allow NRCS or its agent access to monitor the effectiveness of the practices while the USDA agrees to provide technical assistance and pay up to 75 percent of the cost of installing the wildlife habitat practices.
Environmental Quality Incentives Program (EQIP)
This program available to agricultural producers which addresses water quality problems such as soil erosion, agricultural water conservation, and wildlife habitat preservation and development. It will fund up to 75 percent of a project, up to no more that $10,000 per year to landowners with a conservation plan approved by the Resource Conservation District. The funds are available every year and are offered through a contract which can be effective for up to five years.
Stewardship Incentive Program (SIP)
This is a federally funded forest assistance program for qualifying landowners of twenty to 1000 acres of forestland, and provides up to 75 percent reimbursement to property owners. Potentially funded projects include: preparation of a property, neighborhood or watershed management plan; tree planting; three thinning; fuels management; erosion control; stream bed restoration; riparian and wetland restoration; and fish and wildlife habitat improvement. The contract is effective for twelve months, and can provide up to $10,000 assistance per year.
Forestry Incentive Program (FIP)
This is a federally funded forest assistance program aimed at improving the productivity of timberland. Qualifying landowners ca be reimbursed up to 65 percent o their expenses for tree planting, pruning, or slash disposal. A FIP project must be maintained for at least ten years and provides up to $10,000 in a fiscal year.
Economic Analysis of Gravel Mining Proposals Along the Garcia River, prepared by Noreen Doyas for Friends of the Garcia River, September 1993
Garcia River Watershed Water Quality Attainment Strategy Economics Analysis Supplement, from Alan Levine, Coast Action Group, October 27, 1997
Garcia River Watershed maps plotted by Coast-Cascade GIS, California Department of Forestry
Statement of E.V. Toffoli, Regional Manager of State Coastal Commission, regarding Appeal No. 227-77, Monetary Estimates for Anadromous Fisheries Value of Garcia River, dated September 14, 1979
Telephone conversation with Danny Hagans, Pacific Environmental Consultants
U.S. Environmental Protection Agency. Regulatory Impact Assessment of the Proposed Water Quality Standards for the San Francisco Bay/Delta and Critical Habitat Requirements for the Delta Smelt, draft for public comment. December 1993
Fisher A. and R. Raucher. Intrinsic Benefits of Improved Water Quality Advances in Applied Microeconomics, vol. 3, pp. 37-66. 1984
Sanders, L.D., R.G. Walsh and J.B. Loomis. Toward Empirical Estimation of the Total Value of Protecting Rivers, Water Resources Research, vol. 26, no. 7, pp. 1345-57. 1990
Sutherland, R.J. and R.G. Walsh, Effect of Distance on the Preservation Value of Water Quality. Land Economics, vol. 61, no. 3, pp 282-91. 1985
