Draft California 2024 Integrated Report (303(d) List/305(b) Report)

Supporting Information

Regional Board 2 - San Francisco Bay Region

Water Body Name: Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
Water Body ID: CAR2063004020210616049073
Water Body Type: River & Stream
 
DECISION ID
144037
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Alkalinity as CaCO3
Final Listing Decision: Do Not List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: Insufficient information is available to determine beneficial use support for this waterbody-pollutant combination with the statistical power and confidence required by the Listing Policy. Beneficial use support will be reassessed in a future cycle, if more data are available.
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation: After review of the available data and information, SWRCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list because it cannot be determined if applicable water quality standards are not being exceeded.
 
 
Line of Evidence (LOE) for Decision ID 144037, Alkalinity as CaCO3
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 276844
 
Pollutant: Alkalinity as CaCO3
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Dissolved
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Alkalinity as CaCO3.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: The USEPA recommended alkalinity criterion continuous concentration (CCC) for the protection of aquatic life in freshwater is a minimum value of 20,000 ug/L (4-day average).
Guideline Reference: National Recommended Water Quality Criteria. United States Environmental Protection Agency. Office of Water. Current as of 08/03/2016.
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 144037, Alkalinity as CaCO3
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 276845
 
Pollutant: Alkalinity as CaCO3
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Dissolved
 
Beneficial Use: Warm Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Alkalinity as CaCO3.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: The USEPA recommended alkalinity criterion continuous concentration (CCC) for the protection of aquatic life in freshwater is a minimum value of 20,000 ug/L (4-day average).
Guideline Reference: National Recommended Water Quality Criteria. United States Environmental Protection Agency. Office of Water. Current as of 08/03/2016.
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
150928
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Ammonia
Final Listing Decision: Do Not List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: Insufficient information is available to determine beneficial use support for this waterbody-pollutant combination with the statistical power and confidence required by the Listing Policy. Beneficial use support will be reassessed in a future cycle, if more data are available
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation: After review of the available data and information, SWRCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list because it cannot be determined if applicable water quality standards are not being exceeded.
 
 
Line of Evidence (LOE) for Decision ID 150928, Ammonia
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 278072
 
Pollutant: Nitrogen, ammonia (Total Ammonia)
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 7
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 7 samples exceeded the water quality threshold for Ammonia as N.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: The Total Ammonia criterion continuous concentration (expressed as a 30-day average) to protect aquatic life in freshwater is Temperature and pH dependent, and was calculated according to the formula listed in the Aquatic Life Ambient Water Quality Criteria for Ammonia - Freshwater 2013 document.
Objective/Criterion Reference: Aquatic Life Ambient Water Quality Criteria for Ammonia - Freshwater 2013
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2014-04-29 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 150928, Ammonia
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 279005
 
Pollutant: Ammonia (Unionized)
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Ammonia as N, Unionized.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan, San Francisco Bay Basin, Chapter III Water Quality Objectives, Section 3.3.20 Un-Ionized Ammonia: The discharge of wastes shall not cause receiving waters to contain concentrations of un-ionized ammonia in excess 0.025 mg/l (as N), expressed as an annual median.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 150928, Ammonia
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 279121
 
Pollutant: Ammonia (Unionized)
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Warm Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Ammonia as N, Unionized.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan, San Francisco Bay Basin, Chapter III Water Quality Objectives, Section 3.3.20 Un-Ionized Ammonia: The discharge of wastes shall not cause receiving waters to contain concentrations of un-ionized ammonia in excess 0.025 mg/l (as N), expressed as an annual median.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 150928, Ammonia
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 277621
 
Pollutant: Nitrogen, ammonia (Total Ammonia)
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Warm Freshwater Habitat
 
Number of Samples: 7
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 7 samples exceeded the water quality threshold for Ammonia as N.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: The Total Ammonia criterion continuous concentration (expressed as a 30-day average) to protect aquatic life in freshwater is Temperature and pH dependent, and was calculated according to the formula listed in the Aquatic Life Ambient Water Quality Criteria for Ammonia - Freshwater 2013 document.
Objective/Criterion Reference: Aquatic Life Ambient Water Quality Criteria for Ammonia - Freshwater 2013
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2014-04-29 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
151734
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Benthic Community Effects
Final Listing Decision: Do Not List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: Benthic Community Effects are being considered for placement on the CWA section 303(d) List under sections 3.9 of the Listing Policy. Under section 3.9, additional lines of evidence (LOEs) associating the Benthic Community Effects decision with a water or sediment concentration of pollutants other than benthic-macroinvertebrate bioassessment or habitat assessment LOEs are necessary to place a water body on the 303(d) List for Benthic Community Effects.

Two line(s) of evidence evaluating benthic-macroinvertebrate bioassessment data is/are available in the administrative record to assess this indicator. Two of two benthic-macroinvertebrate samples exceed the California Stream Condition Index (CSCI) impairment threshold. However, a minimum of two benthic-macroinvertebrate samples are needed to assess listing status.

Based on the readily available data and information, the weight of evidence indicates that there is sufficient justification against placing Benthic Community Effects in this waterbody segment on the CWA section 303(d) List.

This conclusion is based on the staff findings that:
1. The data used satisfies the data quality requirements of section 6.1.4 of the Policy.
2. The data used satisfies the data quantity requirements of section 6.1.5 of the Policy.
3. Two of two benthic-macroinvertebrate bioassessment samples had CSCI scores below 0.79. The available information is insufficient to determine whether the waterbody/pollutant combination should be placed on the 303(d) List of impaired waters at this time.
4. Pursuant to section 3.11 of the Listing Policy, no additional data and information are available indicating that standards are not met.
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation:
 
 
Line of Evidence (LOE) for Decision ID 151734, Benthic Community Effects
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 306440
 
Pollutant: Benthic-Macroinvertebrate Bioassessments
LOE Subgroup: Population/Community Degradation
Matrix: Water
Fraction: None
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 2
Number of Exceedances: 2
 
Data and Information Type: Benthic macroinvertebrate surveys
Data Used to Assess Water Quality: Water Board staff assessed data for 206PET090 to determine beneficial use support and the results are as follows: 2 of 2 samples exceeded the threshold. CSCI scores were from 0.334768 to 0.443069.
Data Reference: California Stream Condition Index (CSCI) Scores for the 2024 Integrated Report for Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: All waters shall be maintained free of toxic substances in concentrations that are lethal to or that produce significant alterations in population or community ecology or receiving water biota. In addition, the health and life history characteristics of aquatic organisms in waters affected by controllable water quality factors shall not differ significantly from those for the same waters in areas unaffected by controllable water quality factors.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: The California Stream Condition Index (CSCI) is a biological scoring tool that helps aquatic resource managers translate complex data about benthic macroinvertebrates found living in a stream into an overall measure of stream health. The CSCI score is calculated by comparing the expected condition with actual (observed) results (Rehn, A.C. et al., 2015). CSCI scores range from 0 (highly degraded) to greater than 1 (equivalent to reference). CSCI scoring of biological condition are as follows (per the scientific paper supporting the development of the CSCI scoring tool): greater than or equal to 0.92 = likely intact condition, 0.91 to 0.80 = possibly altered condition, 0.79 to 0.63 = likely altered condition, less than or equal to 0.62 = very likely altered condition. Sites with scores below 0.79 are considered to have exceeded the water quality objective for the aquatic life beneficial use. 
Guideline Reference: Bioassessment in complex environments: designing an index for consistent meaning in different settings
 
Spatial Representation: Samples were collected from station 206PET090.
Temporal Representation: Samples were collected from 4/3/2003 to 4/28/2016.
Environmental Conditions:
QAPP Information: Data were collected using Surface Water Ambient Monitoring Program protocols
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
144031
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Chloride
Final Listing Decision: Do Not List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: Insufficient information is available to determine beneficial use support for this waterbody-pollutant combination with the statistical power and confidence required by the Listing Policy. Beneficial use support will be reassessed in a future cycle, if more data are available.
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation: After review of the available data and information, SWRCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list because it cannot be determined if applicable water quality standards are not being exceeded.
 
 
Line of Evidence (LOE) for Decision ID 144031, Chloride
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 281118
 
Pollutant: Chloride
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Dissolved
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Chloride.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: The chloride criterion continuous concentration (expressed as a 4-day average) to protect aquatic life in freshwater is 230000 ug/L (230 mg/L)(USEPA National Recommended Water Quality Criteria, 2006).
Guideline Reference: National Recommended Water Quality Criteria. United States Environmental Protection Agency. Office of Water. Current as of 08/03/2016.
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 144031, Chloride
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 281119
 
Pollutant: Chloride
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Dissolved
 
Beneficial Use: Warm Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Chloride.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: The chloride criterion continuous concentration (expressed as a 4-day average) to protect aquatic life in freshwater is 230000 ug/L (230 mg/L)(USEPA National Recommended Water Quality Criteria, 2006).
Guideline Reference: National Recommended Water Quality Criteria. United States Environmental Protection Agency. Office of Water. Current as of 08/03/2016.
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
144032
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Chlorophyll-a
Final Listing Decision: Do Not List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: Insufficient information is available to determine beneficial use support for this waterbody-pollutant combination with the statistical power and confidence required by the Listing Policy. Beneficial use support will be reassessed in a future cycle, if more data are available.
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation:
 
 
Line of Evidence (LOE) for Decision ID 144032, Chlorophyll-a
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 282554
 
Pollutant: Chlorophyll-a
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Chlorophyll a.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: North Carolina Administrative code (NCAC), Title 15A – Environmental and Natural Resources, Subchapter 2B-Surface water and wetland standards, Rule 0211-Fresh surface water quality standards for class C waters (Class C is defined as freshwaters protected for secondary recreation, fishing, aquatic life including propagation and survival, and wildlife).Section 3(a) of Rule 0211 applies to all fresh surface waters and states that chlorophyll a is not to exceed 40 ug/L.
Guideline Reference: North Carolina standards, criteria, or toxic concentrations. Adopted per title 15A North Carolina Administrative Code subchapter 2B - Surface water and wetland standards
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 144032, Chlorophyll-a
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 282865
 
Pollutant: Chlorophyll-a
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Chlorophyll a.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: North Carolina Administrative code (NCAC), Title 15A – Environmental and Natural Resources, Subchapter 2B-Surface water and wetland standards, Rule 0211-Fresh surface water quality standards for class C waters (Class C is defined as freshwaters protected for secondary recreation, fishing, aquatic life including propagation and survival, and wildlife).Section 3(a) of Rule 0211 applies to all fresh surface waters and states that chlorophyll a is not to exceed 40 ug/L.
Guideline Reference: North Carolina standards, criteria, or toxic concentrations. Adopted per title 15A North Carolina Administrative Code subchapter 2B - Surface water and wetland standards
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 144032, Chlorophyll-a
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 282943
 
Pollutant: Chlorophyll-a
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Warm Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Chlorophyll a.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: North Carolina Administrative code (NCAC), Title 15A – Environmental and Natural Resources, Subchapter 2B-Surface water and wetland standards, Rule 0211-Fresh surface water quality standards for class C waters (Class C is defined as freshwaters protected for secondary recreation, fishing, aquatic life including propagation and survival, and wildlife).Section 3(a) of Rule 0211 applies to all fresh surface waters and states that chlorophyll a is not to exceed 40 ug/L.
Guideline Reference: North Carolina standards, criteria, or toxic concentrations. Adopted per title 15A North Carolina Administrative Code subchapter 2B - Surface water and wetland standards
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 144032, Chlorophyll-a
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 282555
 
Pollutant: Chlorophyll-a
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Warm Freshwater Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Chlorophyll a.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: North Carolina Administrative code (NCAC), Title 15A – Environmental and Natural Resources, Subchapter 2B-Surface water and wetland standards, Rule 0211-Fresh surface water quality standards for class C waters (Class C is defined as freshwaters protected for secondary recreation, fishing, aquatic life including propagation and survival, and wildlife).Section 3(a) of Rule 0211 applies to all fresh surface waters and states that chlorophyll a is not to exceed 40 ug/L.
Guideline Reference: North Carolina standards, criteria, or toxic concentrations. Adopted per title 15A North Carolina Administrative Code subchapter 2B - Surface water and wetland standards
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2016-04-28 and 2016-04-28
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
149044
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Microcystins
Final Listing Decision: Do Not List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: Insufficient information is available to determine beneficial use support for this waterbody-pollutant combination with the statistical power and confidence required by the Listing Policy. Beneficial use support will be reassessed in a future cycle, if more data are available
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation: After review of the available data and information, SWRCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list because it cannot be determined if applicable water quality standards are not being exceeded.
 
 
Line of Evidence (LOE) for Decision ID 149044, Microcystins
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 284598
 
Pollutant: Microcystins
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Water Contact Recreation
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Microcystins, Total.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: The California Cyanobacteria and Harmful Algal Bloom (CCHAB) Network established 6 ug/L of microcystins as the water concentration protective of swimmers and other contact recreational users including water-skiing/jet-skiing, fishing, boating, sail boarding, and canoeing.
Guideline Reference: Appendix to the CCHAB preliminary changes to the statewide voluntary guidance on cyanoHABs in recreational waters, January 2016. Appendix A. Description of cyanotoxin triggers in recreational waters.
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2015-04-07 and 2015-04-07
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 149044, Microcystins
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 284682
 
Pollutant: Microcystins
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Wildlife Habitat
 
Number of Samples: 1
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 1 samples exceeded the water quality threshold for Microcystins, Total.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: California Office of Environmental Health Hazard Assessment (OEHHA) established 2 ug/L of microcystins as the subchronic water concentration for dog intake/ingestion (Office of Environmental Health Hazard Assessment Public Health Action Level for microcystin and Human Recreational Uses (May 2012)). OEHHA Action Level for subchronic water intake, dog.
Guideline Reference: Toxicological Summary and Suggested Action Levels to Reduce Potential Adverse Health Effects of Six Cyanotoxins
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2015-04-07 and 2015-04-07
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
144035
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Temperature, water
Final Listing Decision: Do Not List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Impairment from Pollutant or Pollution: Pollution
 
Regional Board Conclusion: This pollutant is being considered for placement on the CWA section 303(d) List under section 3.2 of the Listing Policy.

Zero samples exceeded the objectives, guidelines, or criteria for beneficial uses applicable to this water segment-pollutant combination, which is less than the minimum number of exceedances needed to place the water segment on the section CWA section 303(d) List for conventional or other pollutants (Table 3.2 of the Listing Policy).

The data used satisfies the data quality requirements (section 6.1.4) and data quantity requirements (section 6.1.5) of the Listing Policy.

Pursuant to section 3.11 of the Listing Policy, no additional data and information are available indicating that standards are not met. Based on the readily available data and information, the weight of evidence indicates that there is sufficient justification against placing this water segment-pollutant combination on the CWA section 303(d) List.
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list because applicable water quality standards are not being exceeded.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation:
 
 
Line of Evidence (LOE) for Decision ID 144035, Temperature, water
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 298713
 
Pollutant: Temperature, water
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Not Recorded
 
Beneficial Use: Fish Migration
 
Number of Samples: 20
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 20 samples exceeded the water quality threshold for Temperature.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Temperature objectives for surface waters are specified in the San Francisco Bay Regional Water Quality Control Plan. The following temperature objectives apply to surface waters: The natural receiving water temperature of inland surface waters shall not be altered unless it can be demonstrated to the satisfaction of the Regional Board that such alteration in temperature does not adversely affect beneficial uses. The temperature of any cold or warm freshwater habitat shall not be increased by more than 5 degrees F (2.8 degrees C) above natural receiving water temperature.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: Scientific literature reviewed by the Washington Department of Ecology and U.S. EPA indicates that stream temperatures higher than 21C are associated with avoidance behavior and migration blockages in steelhead trout.
Guideline Reference: EPA Region 10 Guidance for Pacific Northwest State and Tribal Temperature Water Quality Standards. EPA 910-B-03-002. Region 10 Office of Water, Seattle, WA
Guideline Reference: U.S. Environmental Protection Agency (USEPA). 2001. Issue Paper 1: Salmonid Behavior and Water Temperature Prepared as Part of EPA Region 10 Temperature Water Quality Criteria Guidance Development Project. Region 10, Seattle, WA. EPA-910-D-01-001 May 2001.
Guideline Reference: Washington State Department of Ecology (WDOE). 2002. Evaluating Standards for Protecting Aquatic Life in Washington’s Surface Water Quality Standards: Temperature Criteria. Draft Discussion Paper and Literature Summary. Publication Number 00-10-070.
Guideline Reference: Beschta RL, Bilby RE, Brown GW, Holtby LB, Hofstra TD. 1987. Stream temperature and aquatic habitat: Fisheries and forestry interactions. In: Salo EO, Cundy TW, eds. Streamside management: forestry and fishery interactions. College of Forest Resources, University of Washington, Seattle. Contribution No. 57. Proceedings of a Symposium held at University of Washington, February 12-14, 1986, pp. 191-231.
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2014-04-29 and 2016-06-10
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 144035, Temperature, water
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 289194
 
Pollutant: Temperature, water
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Not Recorded
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 34
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 34 samples exceeded the water quality threshold for Temperature.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Temperature objectives for surface waters are specified in the San Francisco Bay Regional Water Quality Control Plan. The following temperature objectives apply to surface waters: “- The natural receiving water temperature of inland surface waters shall not be altered unless it can be demonstrated to the satisfaction of the Regional Board that such alteration in temperature does not adversely affect beneficial uses. - The temperature of any cold or warm freshwater habitat shall not be increased by more than 5°F (2.8°C) above natural receiving water temperature.”
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: Per Effects of Temperature, Dissolved Oxygen/Total Dissolved Gas, Ammonia, and pH on Salmonids (Carter 2008, Moyle 1976, and USEPA 1977), the lethal temperature evaluation guideline for both the steelhead adult migration and holding and the steelhead juvenile growth and rearing life stages is 24°C.
Guideline Reference: Temperature criteria for freshwater fish: protocol and procedures. Ecological Research Series. EPA-600/3-77-061 (NTIS PB270032). Prepared by W.A. Brungs and B.R. Jones. U.S. Environmental Protection Agency, Washington, D.C
Guideline Reference: Inland Fishes of California
Guideline Reference: Effects of Temperature, Dissolved Oxygen/Total Dissolved Gas, Ammonia, and pH on Salmonids. Implications for California's North Coast TMDLs. California Regional Water Quality Control Board, North Coast Region
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2014-04-23 and 2016-06-10
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
144036
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Turbidity
Final Listing Decision: Do Not List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: Insufficient information is available to determine beneficial use support for this waterbody-pollutant combination with the statistical power and confidence required by the Listing Policy. Beneficial use support will be reassessed in a future cycle, if more data are available
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation: After review of the available data and information, SWRCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list because it cannot be determined if applicable water quality standards are not being exceeded.
 
 
Line of Evidence (LOE) for Decision ID 144036, Turbidity
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 302826
 
Pollutant: Turbidity
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Warm Freshwater Habitat
 
Number of Samples: 5
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 5 samples exceeded the water quality threshold for Turbidity.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: Turbidities of 40 NTU or greater can cause a reduced foraging efficiency and a shift in prey selection in piscivorous fish (largemouth bass) due to interference with their ability to find prey (Shoup, D.E. and Wahl D.H., 2009). The application of this evaluation guideline was restricted to the dry season (May to October) because runoff and resuspension of fine substrate during storm events may naturally elevate turbidity compared to baseflow conditions. The magnitude and duration of these increases will vary depending on the watershed’s geology and land use and may not represent a chronic turbidity problem. Turbidity is naturally higher in tidal river systems, so sample locations with salinity regimes (i.e., Freshwater or Marine) designated as “Marine” were excluded from this analysis.
Guideline Reference: The Effects of Turbidity on Prey Selection by Piscivorous Largemouth Bass
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2014-05-15 and 2015-06-30
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 144036, Turbidity
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 289906
 
Pollutant: Turbidity
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 5
Number of Exceedances: 1
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 1 of 5 samples exceeded the water quality threshold for Turbidity.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan for the San Francisco Bay Basin: Controllable water quality factors shall not cause a detrimental increase in concentrations of toxic substances found in bottom sediments or aquatic life. Effects on aquatic organisms, wildlife, and human health will be considered.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline: Sigler et al. (1984) states that turbidities of 25 NTUs or greater caused reduction in juvenile salmonid growth due to interference with their ability to find food. The application of this evaluation guideline was restricted to the dry season (May to October) because Coho and steelhead early life stages are present during the dry season and feeding becomes infrequent during the winter months (Moyle 2002). Additionally, runoff and resuspension of fine substrate during storm events may naturally elevate turbidity compared to baseflow conditions. The magnitude and duration of these increases will vary depending on the watershed’s geology and land use and may not represent a chronic turbidity problem. Turbidity is naturally higher in tidal river systems, so sample locations with salinity regimes (i.e., Freshwater or Marine) designated as “Marine” were excluded from this analysis.
Guideline Reference: Effects of chronic turbidity on density and growth of steelheads and coho salmon. Transactions of the American Fisheries Society 113:142-150
Guideline Reference: Inland Fishes of California
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2014-05-15 and 2015-06-30
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
144034
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: pH
Final Listing Decision: Do Not List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: Insufficient information is available to determine beneficial use support for this waterbody-pollutant combination with the statistical power and confidence required by the Listing Policy. Beneficial use support will be reassessed in a future cycle, if more data are available.
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should not be placed on the section 303(d) list. The readily available data and information is insufficient to determine, with the power and confidence of the Listing Policy, the applicable beneficial use support rating.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation:
 
 
Line of Evidence (LOE) for Decision ID 144034, pH
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 286927
 
Pollutant: pH
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: None
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 20
Number of Exceedances: 0
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 0 of 20 samples exceeded the water quality threshold for pH.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan, San Francisco Bay Basin, Chapter III Water Quality Objectives, Section 3.3.9 pH states: The pH shall not be depressed below 6.5 nor raised above 8.5. This encompasses the pH range usually found in waters within the basin. Controllable water quality factors shall not cause changes greater than 0.5 units in normal ambient pH levels.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2014-04-29 and 2016-06-10
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
144033
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Oxygen, Dissolved
Final Listing Decision: List on 303(d) list (TMDL required list)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Sources: A Source Unknown
Expected TMDL Completion Date: 2037
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: This pollutant is being considered for placement on the CWA section 303(d) List under section 3.2 of the Listing Policy. Under section 3.2 a single line of evidence is necessary to assess listing status.

NUMBER lines of evidence are available in the administrative record to assess this pollutant. Fourteen of thirty-four samples exceed the Basin Plan's COLD dissolved oxygen objective.

Based on the readily available data and information, the weight of evidence indicates that there is sufficient justification in favor of placing this water segment-pollutant combination on the CWA section 303(d) List.

This conclusion is based on the staff findings that:
1. The data used satisfies the data quality requirements of section 6.1.4 of the Policy.
2. The data used satisfies the data quantity requirements of section 6.1.5 of the Policy.
3. Fourteen of thirty-four samples exceed the Basin Plan's COLD dissolved oxygen objective and this exceeds the allowable frequency listed in Table 3.2 of the Listing Policy.
4. Pursuant to section 3.11 of the Listing Policy, no additional data and information are available indicating that standards are not met.
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should be placed on the section 303(d) list because applicable water quality standards are exceeded and a pollutant contributes to or causes the problem.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation:
 
 
Line of Evidence (LOE) for Decision ID 144033, Oxygen, Dissolved
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 285774
 
Pollutant: Oxygen, Dissolved
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Cold Freshwater Habitat
 
Number of Samples: 34
Number of Exceedances: 14
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 14 of 34 samples exceeded the water quality threshold for Oxygen, Dissolved.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Dissolved oxygen objectives for waters designated as cold water habitat shall be of a 7.0 mg/l minimum. (Water Quality Control Plan, San Francisco Bay Basin, Chapter III Water Quality Objectives.)
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2014-04-23 and 2016-06-10
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 144033, Oxygen, Dissolved
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 285471
 
Pollutant: Oxygen, Dissolved
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: Total
 
Beneficial Use: Warm Freshwater Habitat
 
Number of Samples: 34
Number of Exceedances: 9
 
Data and Information Type: PHYSICAL/CHEMICAL MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and results are as follows: 9 of 34 samples exceeded the water quality threshold for Oxygen, Dissolved.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Dissolved oxygen objectives for waters designated as warm water habitat shall be of a 5.0 mg/l minimum. (Water Quality Control Plan, San Francisco Bay Basin, Chapter III Water Quality Objectives.)
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site: 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the dates of 2014-04-23 and 2016-06-10
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
 
DECISION ID
149883
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
Pollutant: Indicator Bacteria
Final Listing Decision: List on 303(d) list (being addressed by USEPA approved TMDL)
Last Listing Cycle's Final Listing Decision: New Decision
Revision Status Revised
Sources: A Source Unknown
TMDL Name: Petaluma River Bacteria TMDL
TMDL Project Code: 1283
Date TMDL Approved by USEPA: 05/10/2021
Impairment from Pollutant or Pollution: Pollutant
 
Regional Board Conclusion: This pollutant is being considered for placement on the CWA section 303(d) List under sections 2.2 and 3.3 of the Listing Policy. Under section 3.3 of the Policy, a minimum of one line of evidence is needed to assess listing status.

Three lines of evidence are available in the administrative record to assess this pollutant. Seven out of ten samples exceeded the statistical threshold value objective.
Based on the readily available data and information, the weight of evidence indicates that there is sufficient justification for placing this water segment-pollutant combination in the Being Addressed portion of the CWA 303(d) List because a TMDL has been completed and approved by RWQCB and USEPA, and is expected to result in attainment of the standard.
This conclusion is based on the staff findings that:
1. The data used satisfies the data quality requirements of section 6.1.4 of the Policy.
2. The data used satisfies the data quantity requirements of section 6.1.5 of the Policy.
3. Seven out of ten samples exceeded the statistical threshold value objective and these exceed the allowable frequency listed in Table 3.2 of the Listing Policy.
4. The Petaluma River Bacteria TMDL was approved by USEPA on 05/10/2021.
5. Pursuant to section 4.11 of the Listing Policy, no additional data and information are available indicating that standards are not met.
 
Regional Board Decision Recommendation: After review of the available data and information, RWQCB staff concludes that the water body-pollutant combination should be placed on the section 303(d) list because applicable water quality standards are exceeded and a pollutant contributes to or causes the problem.
 
State Board Review of Regional Board Conclusion and Recommendation:
 
State Board Decision Recommendation:
 
 
Line of Evidence (LOE) for Decision ID 149883, Indicator Bacteria
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 300403
 
Pollutant: Escherichia coli (E. coli)
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: GeoMean
 
Beneficial Use: Water Contact Recreation
 
Number of Samples: 6
Number of Exceedances: 4
 
Data and Information Type: PATHOGEN MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and the results are as follows: 4 of the 6 samples exceeded the geomean water quality threshold for E. coli. This is a six week rolling geomean that is calculated weekly.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: The bacteria water quality objective to protect the REC-1 beneficial use for waters where the salinity is equal to or less than 1 part per thousand 95 percent or more of the time applies a rolling six-week geometric mean of E. coli, not to exceed 100 cfu/100 mL (ISWEBE 2018).
Objective/Criterion Reference: Inland Surface Waters, Enclosed Bays, and Estuaries Plan. Part 1: Trash Provisions; Part 2: Tribal Subsistence Beneficial Uses and Mercury Provisions; Part 3: Bacteria Provisions and Variance Policy
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site(s), station(s): 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the days of 2014-04-23 and 2016-03-29 .
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 149883, Indicator Bacteria
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 300354
 
Pollutant: Fecal Coliform
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: 90th percentile
 
Beneficial Use: Non-Contact Recreation
 
Number of Samples: 2
Number of Exceedances: 0
 
Data and Information Type: PATHOGEN MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and the results are as follows: 0 of the 2 samples exceeded the water quality threshold for Coliform, Fecal. The water quality threshold is based on a 30-day 90% percentile.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: Water Quality Control Plan, San Francisco Bay Basin, Chapter III Water Quality Objectives, Section 3.3.1 Bacteria: Table 3-1 provides a summary of the bacterial water quality objectives and identifies the sources of those objectives. The fecal coliform objective for non-contact recreation is a 30-day 90th percentile less than 4000 MPN/100 ML.
Objective/Criterion Reference: Water Quality Control Plan (Basin Plan) San Francisco Bay Basin (Region 2)
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site(s), station(s): 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the days of 2014-04-23 and 2014-05-22 .
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.
 
Line of Evidence (LOE) for Decision ID 149883, Indicator Bacteria
Region 2     
Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River)
 
LOE ID: 300418
 
Pollutant: Escherichia coli (E. coli)
LOE Subgroup: Pollutant-Water
Matrix: Water
Fraction: STV
 
Beneficial Use: Water Contact Recreation
 
Number of Samples: 10
Number of Exceedances: 7
 
Data and Information Type: PATHOGEN MONITORING
Data Used to Assess Water Quality: Water Board staff assessed SWAMP RWB2 Monitoring data for Ellis Creek subwatershed (Sonoma County, tributary to Petaluma River) to determine beneficial use support and the results are as follows: 7 of the 10 samples exceeded the Statistical Threshold Value (STV) water quality threshold for E. coli. The STV is based on a 10% exceedance rate that is calculated monthly.
Data Reference: Field, Habitat, Tissue, Toxicity, WQ data from the California Environmental Data Exchange Network assembled for the 2024 Integrated Report in Region 2.
 
SWAMP Data: SWAMP
 
Water Quality Objective/Criterion: The bacteria water quality objective to protect the REC-1 beneficial use where the salinity is less than 1 parts per thousand 95 percent or more of the time applies a statistical threshold value to E. coli of 320 cfu/100 mL, not to be exceeded by more than 10 percent of samples within a calendar month (ISWEBE 2018).
Objective/Criterion Reference: Inland Surface Waters, Enclosed Bays, and Estuaries Plan. Part 1: Trash Provisions; Part 2: Tribal Subsistence Beneficial Uses and Mercury Provisions; Part 3: Bacteria Provisions and Variance Policy
 
Evaluation Guideline:
Guideline Reference:
 
Spatial Representation: The samples were collected at 1 monitoring site(s), station(s): 206PET090 (Ellis Creek - 1.7mi upstream of Petaluma River confluence. At Ely Rd crossing.).
Temporal Representation: The samples were collected between the days of 2014-04-23 and 2016-03-29 .
Environmental Conditions:
QAPP Information: SWRCB. 2018. This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements..
QAPP Information Reference(s): This is a placeholder reference for data that was collected after QAPP requirements were developed, but exempt from the requirements.