CSPA Joins in Opposing Inadequate SF Bay PCB Pollution regs

By Bill Jennings, Executive Director, CSPA

June 8, 2009 -- CSPA has joined other environmental and fishing groups in asking the State Water Resource Control Board to reject the San Francisco Bay Total Daily Maximum Loading (TMDL) for Polychlorinated biphenyls (PCBs).  TMDLs must be incorporated into Water Quality Control Plans (i.e., Basin Plans) and the State Board and USEPA must approve all TMDLs developed by Regional Boards.   

TMDLs are regulatory processes, pursuant to the federal Clean Water Act, that: 1) identify the mass/concentration of pollutants exceeding water quality standards, 2) determine the sources and safe discharge rates of that pollutant and 3) assign discharge reductions to identified sources.  PCBs are synthetic chemicals that bioaccumulate in fish tissue and cause detrimental effects to aquatic and estuarine species. They are probable human carcinogens and exposure has been documented to damage human reproductive, endocrine and immune systems.  

San Francisco Bay has exceptionally high concentrations of PCBs.  The San Francisco Regional Water Quality Control Board adopted a TMDL for PCBs that failed to consider risks to subsidence fishermen and failed to include an effective implementation plan that will meaningfully reduce PCB pollution.

The deadline for comments to the State Board was 4 June 09 and the issue will be heard at an upcoming Board meeting that has not yet been scheduled.  CSPA will testify that the proposed TMDL is not protective of aquatic life, human health and lacks a defensible and effective implementation plan.

Coalition Letter