Thomas A. Love, P.E.
General Manager
Danielle D. Maurizio, P.E.
Interim CEO
December 13, 2011
Regional Water Quality Control Board, Santa Ana Region
Attention: Mr. Kurt Berchtold
3737 Main Street, Suite 500
Riverside, California 92501-3348
Subject:
Draft Basin Plan Amendment R8-2012-0002
Dear Mr. Berchtold,
The Chino Basin Watermaster and the Inland Empire Utilities Agency (IEUA) are engaged in a
program to achieve hydraulic control of the Chino Basin such that there would be no
groundwater outflow from the Chino-North management zone. Watermaster and IEUA
developed a comprehensive hydraulic control monitoring program pursuant to the 2004 Basin
Plan Amendment (R8-2004-0001) that specifically required monitoring to demonstrate the state
of hydraulic control and to report on that monitoring. Watermaster and IEUA submitted a
monitoring plan to the Regional Board on May 4, 2004 and the Regional Board approved the
Plan on April 15, 2005 in R8-2005-0064. The monitoring plan contains groundwater level and
quality monitoring, surface water discharge and quality monitoring, and a description of how
these data would be evaluated to determine the state of hydraulic control. Watermaster staff
has faithfully executed this monitoring program and provided timely monitoring reports to the
Regional Board.
The 2004 Basin Plan Amendment inserted a table into Basin Plan that defines minimum surface
water monitoring requirements for the Watermaster and the IEUA’s hydraulic control monitoring
plan. This table includes the location of surface water sampling, the frequency of monitoring
and the chemical constituents.
Watermaster staff has shown the Regional Board staff that it can demonstrate the state of
hydraulic control through the use of groundwater level and quality data alone and that the
surface water monitoring is no longer required. The surface water monitoring program
component of the Hydraulic Control Monitoring Program has cost about $250,000 per year. In
October 2008, Watermaster staff started working Regional Board staff to remove the surface
water monitoring requirements contained in the Basin Plan and R8-2005-0064. Regional Board
staff concurred and Watermaster and Regional Board staff have worked together to develop a
Basin Plan Amendment to eliminate the current surface water monitoring mandated in the Basin
Plan and subsequently require Watermaster and IEUA to develop a new monitoring program
under the direction and approval of the Regional Board Executive Officer.
Last week, Regional Board staff provided Watermaster and IEUA with a draft Basin Plan
Amendment that it intends to notice later this month and subsequently take to their board for
approval on February 10, 2012. We have reviewed the draft Basin Plan Amendment that would
reduce the surface water monitoring requirements for the Watermaster and IEUA and find them
consistent with our previous discussions.
There are two other proposed Basin Plan changes in the draft resolution: a modification to the
boundary of the Prado Basin management zone and proposed definitions of incidental and
intentional recharge. We are concerned that including these other proposed Basin Plan
changes in the same resolution could cause a delay in the Board’s approval of the Basin Plan
changes desired by the Watermaster and the IEUA if there is opposition to these other changes.
Watermaster and IEUA have no opinion to the proposed change in the Prado Basin
management zone boundary and we are not knowledgeable as to other stakeholders and their
concerns.
We do believe that the proposed definition of incidental and intentional recharge is premature at
this time and that there needs to be a clear understanding of how these definitions will be used
to regulate surface water discharge to streams and planned groundwater recharge projects. We
believe that these definitions and the regulatory construct in which they will be used needs to be
vetted through the Basin Monitoring Task Force and that this vetting process will take
considerable time.
We therefore request that you delete the proposed Basin Plan change related to the Prado
Basin management zone boundary change and the proposed basin plan change related to
these recycled water definitions and proceed only with the change related to Watermaster and
IEUA’s hydraulic control monitoring program. These other basin plan changes can be included
in the forthcoming Basin Plan Amendment related to the wasteload allocation. For every month
that the Basin Plan amendment to modify the monitoring program is delayed, the Watermaster
and IEUA incur about $16,000 in costs to collect data that no longer required to demonstrate
hydraulic control.
If you have any questions on this letter, please call the undersigned.
Thomas A. Love, P.E.
General Manager
Danielle D. Maurizio, P.E.
Interim Chief Executive Officer
Inland Empire Utilities Agency
P.O. Box 9020
Chino Hills, CA 91708
909.993.1740
Chino Basin Watermaster
9641 San Bernardino Road
Rancho Cucamonga, CA 91730
909.484.3888