Water Quality Trading Framework for the Laguna de Santa Rosa Watershed

Water Quality Trading Framework 2021 Update

During a public hearing on December 2, 2021, the Regional Water Board adopted Resolutions No. R1-2021-0041 and R1-2021-0042 modifying the Water Quality Trading Framework for the Laguna de Santa Rosa Watershed (WQTF) as included in the wastewater NPDES permits for the City of Santa Rosa and Town of Windsor, respectively. The WQTF is available to both the City of Santa Rosa and the Town of Windsor for complying with “no net loading” effluent limitations for total Phosphorus in each of their NPDES permits. The adopted Amendment Orders and the Modified NPDES Permits, including the updated WQTF attachments, are available at the following links:

City of Santa Rosa:

Windsor Water District:

Audio recordings and other materials related to the December 2, 2021 hearing can be found on the December 2021 Regional Water Board’s meeting agenda webpage.

The primary changes to the WQTF as incorporated into the wastewater NPDES permits for the City of Santa Rosa and Town of Windsor are:

  1. The Amendment Orders establish a subset of multi-benefit projects that shall generate credits that do not expire.
  2. Other modifications, administrative changes, and new requirements have been included to better support the WQTF and the above change.

Framework Development and Documents

During a public hearing on July 11, 2018, the Regional Water Board adopted Resolution No. R1-2018-0025 (adopted Resolution) approving the Water Quality Trading Framework for the Laguna de Santa Rosa Watershed (approved Framework). The approved Framework is intended to replace the existing Santa Rosa Nutrient Offset Program and is available to both the City of Santa Rosa and the Town of Windsor as an approved method for complying with “no net loading” effluent limitations for total phosphorus in each of their NPDES permits. The adopted Resolution and approved Framework are available at the following links:

Audio recordings and other materials related to the July 11, 2018 hearing can be found on the July 2018 Regional Water Board’s meeting agenda webpage.

In 2017, Regional Water Board staff developed a draft Resolution No. R1-2017-0027 (draft Resolution) and draft Water Quality Trading Framework for the Laguna de Santa Rosa Watershed (draft Framework). A public workshop on the draft Resolution and Framework was held during a regular meeting of the Regional Water Board on June 29, 2017. Audio recordings and other materials related to the workshop (including copies of the draft Resolution and Framework) are available on the June 2017 Regional Water Board’s meeting agenda webpage.

The draft Resolution and Framework were open for public review and written comment between June 14, 2017 and July 21, 2017. A total of 11 unique comment letters were received from interested parties. Regional Water Board staff considered all comment letters received, prepared detailed written responses to those comments, and revised the draft Resolution and Framework accordingly. Staff’s responses to substantive comments are available alongside other materials related to the July 11, 2018 hearing on the proposed (i.e., revised) Resolution and Framework on the July 2018 Regional Water Board’s meeting agenda webpage.

The approved Framework is a revised, expanded, and improved version of the Santa Rosa Nutrient Offset Program. Its provisions are based on USEPA policy, guidance from national experts, local stakeholder recommendations, and on public comments received on the draft Framework. References used by staff to develop the approved Framework include, but are not limited to the following:

Regional Water Board Adopted Orders: National Guidance & References: Local Guidance & References:

Individual Credit Tracking

In accordance with the requirements of the Framework, an Accounting Ledger is provided to track individual credits and takes the form of a spreadsheet that complies with the requirements of the Framework. The Ledger further provides additional features that make it more useable and informative. Once credits have been verified per the Framework, the Ledger will be populated to reflect their status. Additionally, Regional Water Board’s March 1, 2022 letter authorizing the transfer of phosphorus credits form the NOP to the WQTF is provided in the link below:

Pre-Qualified Practices Library

The Water Quality Trading Framework distinguishes between practices and projects. Practices are the methods through which credits can be generated, while projects are the activities that employ practices to actually generate credits. The Framework stipulates that practices may be pre-qualified for use in future projects. In order for this to occur, practices must be posted and noticed for a 30-day public comment period. Once approved for pre-qualification, the pre-qualified practices must be available to the public in a library of pre-qualified practices. That library is below.

Channel Restoration: Sediment Removal, Low-Flow Channel Creation, Bank Grading, and Riparian Planting

Credit Generating Projects

Colgan Creek Reaches 1 and 2



Santa Rosa Nutrient Offset Program

On July 24, 2008, the North Coast Regional Water Quality Control Board adopted Resolution No. R1-2008-0061 approving the Santa Rosa Nutrient Offset Program for the City of Santa Rosa Subregional Water Reclamation Facility, a publicly owned treatment works. The program provides a framework for the City of Santa Rosa to comply with “no net loading” effluent limitations for nutrients that appear in its facility’s National Pollutant Discharge Elimination System (NPDES) permit, Order No. R1-2013-0001 (previously Order No. R1-2006-0045).

In accordance with the Santa Rosa Nutrient Offset Program, the Regional Water Board Executive Officer will accept or reject proposed nutrient reduction project(s) submitted by the City of Santa Rosa in writing within 60 days of receiving the submittal(s) or the project(s) will be deemed accepted. The Executive Officer will provide notice and the opportunity for the public to comment on proposed project(s). After consideration of any public comments and all available information, the Executive Officer may suggest modifications to the project(s) as necessary for acceptance.

In order to gather comments regarding proposed project(s) from concerned agencies and the public, proposed project submittals are posted on this webpage for no less than 21 days.

Annual Compliance Reports

Project Information

Laguna de Santa Rosa Reaches 1 and 2

Nunes Ocean View Dairy – Manure Reuse

Pepperwood Preserve – Erosion Control Treatments Beretta Dairy – Manure Management Practices

Email Subscriptions

To receive notices and information from the North Coast Regional Water Quality Control Board about the Santa Rosa Nutrient Offset Program and the Draft Water Quality Trading Framework for the Laguna de Santa Rosa Watershed, please request to be added to our email subscription list by visiting: https://www.waterboards.ca.gov/resources/email_subscriptions/reg1_subscribe.html and click on “Santa Rosa Nutrient Offset Program.”


Contact Information

For more information about the Santa Rosa Nutrient Offset Program or the Water Quality Trading Framework for the Laguna de Santa Rosa, please contact Matthew Herman at (707) 576-2683 or by email at: matthew.herman@waterboards.ca.gov.