Lahontan Regional Water Quality Control Board
Planning and Toxics Units
2501 Lake Tahoe BIvd.
South Lake Tahoe, CA 96150

August 11,1997

To Whom It May Concern:

Thank you for the opportunity to comment on the Draft EIS for Rangeland Health Standards and Guidelines for California and Northwestern Nevada. The Susanville and Bakersfield Resource Areas are the two areas, at least in part, which fall under the jurisdiction of the Regional Water Quality Control Board, Lahontan Region. We had previously sent comments on the proposed standards and guidelines to Jim Morrison on September 13, 1996.

State law assigns responsibility for protection of water quality within the Lahontan watershed basin to the Regional Water Quality Control Board, Lahontan Region ("RWQCB"). The RWQCB implements and enforces the Porter-Cologne Water Quality Control Act ("Porter-Cologne Act," California Water Code ß13000 et seq.) and the Water Quality Control Plan for the Lahontan Region ("Basin Plan"). All Bureau of Land Management projects must comply with all substantive and procedural requirements of the Porter-Cologne Act and the Basin Plan.

Please accept the following comments:

1. We request that the Draft ElS standards and guidelines specifically acknowledge that all grazing activities shall be managed to achieve compliance with State water quality standards. The Basin Plan containS narrative and numerical water quality objectives that have been adopted to assure adequate protection of beneficial uses. The standards and guidelines should recognize these water quality objectives (including the Nondegradation Objective), and be written and implemented to achieve compliance with all objectives.

Alternative 1: The Bakersfield Resource Area specifically acknowledges the need to meet California State water quality standards. They state: "Surface and groundwater quality complies with California, or other appropriate (e.g. Nevada or Tribal) water quality standards.

The Susanville Resource Area does not specifically acknowledge the need to achieve California State water quality standards. They state: "At a minimum, water quality is adequate for desired beneficial use of water resources on public lands." We request acknowledgement that State water quality standards need to be met with a statement much as was done by the Bakersfield Resource Area.

Alternative 2: This alternative does not specifically acknowledge the need to meet California State water quality standards. This alternative states: "Water will have characteristics suitable for existing or potential beneficial uses." We r­cknowledgement that State water quality standards need to be met with a statement similar to that proposed by the Bakersfield Resource Area in alternative 1.

Alternative 3: This alternative does not mention water quality as a Fall-Back Standard. There should be a recognition in the Fall-Back Standards that State water quality standards need to be met.

Alternative 4: This alternative acknowledges the need to meet California State water quality standards.

For clarification it should be~noted that adherence to implementation of Best Management Practices (BMPs) does not automatically ensure that the applicable State water quality standards are being met. Thus, while BMPs remain an important tool for use by the BLM to achieve compliance with State water quality standards, additional mitigation must be applied where BMPs alone would be insufficient to achieve full compliance with all applicable State standards.

Please keep Fred Blatt of my staff informed of this proposed action and submit copies of all environmental and decision documents to this office for our review. Thank you for this opportunity to comment. Please call Fred Blatt of my staff if you have any questions regarding these comments.

Sincerely,

Ranjit S. Gill, Ph.D., Chief
Planning and Toxics Unit

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