Agenda 11-02-23; 4-a - Resolution Endorsing Consensus Principles II for Revised Falls Lake Rules

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1=43 • Community acceptance of widespread installation and maintenance could present an additional hurdle to implementation. • Local governments cannot condemn land for stormwater treatment, so all systems would require willing landowner participation. Implications for a Revised Nutrient Management Strategy Given the cost and constraints listed above, the use of pump-and-treat systems to reduce total nitrogen loads to Falls Lake by 50 percent from recent levels is not feasible. Because of the nutrient reductions that have already been achieved, the mostly natural state of this watershed, and the relative stability of chlorophyll-a concentrations in Falls Lake, nutrient load reductions at the scale necessary to achieve compliance with the chlorophyll-a standard are not reasonable. This hypothetical pump-and-treat scenario is presented to illustrate the challenges faced by UNRBA members and others in this watershed. The UNRBA is not attempting to avoid costs or responsibility. Rather, this scenario and the modeling discussed previously demonstrates UNRBA's commitment to finding management strategies that will protect water quality instead of applying conventional approaches to try to reach an unrealistic goal. The data show that achieving the chlorophyll-a standard as currently assessed is not attainable in all areas of Falls Lake. The UNRBA has extensively researched this system and evaluated several scenarios to guide readoption of the Falls Lake Rules. The result of these efforts and discussions with stakeholders indicate that the most effective means to reduce nutrient loading from the watershed and protect water quality in Falls Lake is a measured and incremental investment program that focuses on watershed health. The path forward requires a revised nutrient management strategy that focuses on clear, attainable objectives that continue to maintain the reservoir's designated uses. To move management actions forward with broad support from stakeholders,the revised strategy should not focus on nutrient pounds delivered to Falls Lake with the only goal being attainment of the chlorophyll-a standard. There are finite resources within this watershed, and those allocated to this effort need to be used for enhancing and protecting the entire watershed in sustainable, resilient, and meaningful ways. Economic Considerations As recommended in the Framework for a Reexamination Strategy of Stage II of the Falls Nutrient Strate the UNRBA planned to supplement monitoring and modeling efforts with a cost-benefit analysis (CBA). The CBA would update the DWR Fiscal Analysis by comparing modeling scenarios that would meet the chlorophyll-a standard in Falls Lake. However, monitoring data and calibrated models revealed that none of the scenarios investigated would comply with the chlorophyll-a standard as currently applied. As no reasonable means of meeting the standard was identified, a formal CBA of nutrient management strategy alternatives could not be conducted during the development of these recommendations. However,the UNRBA will cooperate with DWR to assist in developing a more thorough economic analysis during the rule revision process to evaluate impacts of rule language and alternative strategies as needed. The UNRBA continues to compile information from the local governments to support this effort. Stakeholder Involvement Some of the efforts on this vital component of the reexamination have already been briefly noted in this document. Stakeholder engagement for this effort is not limited to specific events but rather is an ongoing commitment to develop the science, support a revised strategy, communicate preliminary findings, and share perspectives on how these findings guide the reexamination. 24