Coastal Pathogen Source Reduction Strategy

Announcements

On April 2, 2025, the North Coast Regional Water Quality Control Board adopted Resolution R1­2025­0010 supporting the submittal of the Coastal Pathogen Source Reduction Strategy (Implementation Plan) to the State Water Resources Control Board (State Water Board) to Include as part of the 2028 California Integrated Report for Clean Water Act 303(d) List and 305(b) Report (Integrated Report).

Background

The 2012 Clean Water Act (CWA) Section 303(d) List of Impaired Waterbodies (Section 303(d) List) identifies six North Coast coastal streams as impaired for the water contact recreation (REC-1) beneficial use, and twelve (12) North Coast ocean beaches as impaired for REC-1 and/or Shellfish Harvesting (SHELL) beneficial use. These streams and beaches have been listed as impaired due to exceedances of the REC-1 and/or SHELL fecal indicator bacteria water quality objective (objective). Additional studies conducted by the North Coast Regional Water Quality Control Board (North Coast Water Board) staff also identified thirteen other coastal streams in the North Coast region that are not identified on the Section 303(d) List, but which have at least one exceedance of the REC­1 objective.

The presence of fecal waste material in water is correlated with the potential presence of illness-causing pathogens, such as bacteria, viruses, or protozoa. These organisms can cause illness either through direct contact or incidental water ingestion, impacting REC-1 beneficial use, or through ingestion of contaminated shellfish, impacting SHELL beneficial use.

Overview

Under the CWA Section 303(d), the North Coast Water Board is required to establish a Total Maximum Daily Load (TMDL) for those pollutants identified as causing impairment of waters on the 303(d) List. The United State Environmental Protection Agency’s (U.S. EPA) 2022­2032 Vision for the CWA Section 303(d) Program (EPA Vision) also recognizes the use of alternative plans (including a Category 4b demonstration) in addition to, or in lieu of, TMDLs. The EPA Vision recognizes that certain alternatives may be more immediately beneficial or practicable for restoring water quality, and encourages the most effective approach be applied for restoring water quality.
A Category 4b demonstration documents the manner in which established or planned pollution control requirements are expected to result in the attainment of an applicable objective in a reasonable period of time. If accepted by U.S. EPA, a Category 4b demonstration would result in a determination that a TMDL is not needed to restore supporting conditions for beneficial uses in the waters addressed because alternative mechanisms are expected to do so. U.S. EPA undertakes review and acceptance of Category 4b demonstrations as part of the Integrated Report process.
Consistent with the EPA Vision, the North Coast Water Board staff have developed the Coastal Pathogen Source Reduction Strategy (Implementation Plan) as a Category 4b demonstration. The Implementation Plan identifies existing or planned permit conditions and regulatory authorities to address the controllable anthropogenic (human, dog, cattle) fecal sources that have been identified as sources leading to impairment of REC­1 and/or SHELL in certain waterbodies. The Implementation Plan addresses pathogen impairment in six streams and at nine beaches along the North Coast. In addition, although not required as part of a Category 4b demonstration, the Implementation Plan also addresses the need for source control for 13 additional Humboldt County streams currently not on the Section 303(d) List, but where data indicates at least one exceedance of the REC­1 bacteria objective as well as evidence of anthropogenic sources of fecal pollution. Three impaired ocean beaches are not addressed in the Implementation Plan as these beaches did not show evidence of anthropogenic fecal sources that could be controlled. Available data collected from these three beaches indicate wildlife (gulls, deer, and elk) as the sources of fecal pollution.
On April 2, 2025, the North Coast Regional Water Quality Control Board adopted Resolution R1­2025­0010 supporting the submittal of the Coastal Pathogen Source Reduction Strategy (Implementation Plan) to the State Water Resources Control Board (State Water Board) to Include as part of the 2028 California Integrated Report for Clean Water Act 303(d) List and 305(b) Report (Integrated Report).

Staff will submit the Implementation Plan as an attachment to the 2028 Integrated Report via the State Water Board. As part of the Integrated Report processes, the Category 4b demonstration will undergo review by State Water Board staff, a period of public review and comment, consideration by the State Water Board for approval, and consideration by U.S. EPA for acceptance. The Integrated Report public review and comment period, including the Implementation Plan, would be anticipated to occur in early 2027, followed by State Water Board adoption of the Integrated Report in 2028 and ultimately submittal to the U.S. EPA for approval later that year.

Impaired Streams addressed in the Implementation Plan
A map of the area around Humboldt Bay showing the sampling stations along the REC-1 impaired streams in Humboldt County.

Impaired Ocean Beaches in Humboldt County addressed in the Implementation Plan
A map of coastal Humboldt County showing the locations of the REC-1 and/or SHELL impaired beach sampling stations

Impaired Ocean Beaches in Mendocino County addressed in the Implementation Plan

A map of coastal Mendocino County showing the locations of the REC-1 and/or SHELL impaired beach sampling stations

Impaired Ocean Beach in Sonoma County addressed in the Implementation Plan

A map of the area around Bodega Bay in Sonoma County showing the location of the Campbell Cove at Bodega Bay sampling station

Polluted Streams (Currently not listed as impaired on the  Section 303(d) List) addressed in the Implementation PlanA map of the area around Humboldt Bay showing the locations of the sampling stations along the thirteen polluted streams currently not listed on the Section 303(d) List but having at least one exceedance of the REC-1 Objective

  (Page last updated 6/10/25)

 
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