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Appendix C Summary of the Committee's Letter Reports (May 1985 to August 1989) The Committee on Irrigation-Induced Water Quality Problems (CIIWQP) and its subcommittees chose to use letter reports as their pri- ma~y mechanism to formally convey recommendations and comments to the San Joaquin Valley Drainage Program (SJVDP) and the National Irri- gation Water Quality Program (NIWQP). These letter reports were issued in response to briefings, draft documents, and other requests for assistance. They often provided specific scientific advice, but they also were used to convey the committee's overall sense of the adequacy and breadth of the ongoing research program. Although it is not possible to track precisely the responses to the reports, overall it was felt that the letter reports have had significant impacts. October 1985 CIIWQP Following briefings about the SJVDP, this letter report calls for improved coordination of research activities, better overall program management, and a program for public participation. Other areas of concern include the need for data management and the ongoing interpretation of data; the importance of quality assurance and quality control; the need to consider agricultural chemicals in the design of analytical studies; the significance of economic, legal, and institutional constraints on the choice of solutions; and the need to consider on-farm management options. 143

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144 April 1986 CIIWQP IRRIGATION-INDUCED WATER QUALITY PROBLEMS Responding to briefings provided by the University of California research program related to irrigation drainage problems in the San Joaquin Valley, this letter report praises the research address- ing on-farm water and salinity management, transport processes, and trace element chemistry. However, the committee believes the university researchers should be better integrated into the over- all SJVDP research program. Research areas requiring attention include public health concerns, economic evaluations of potential alternative solutions, and the long-term impacts on ecosystems. The committee urges that recommendations from its October 1985 letter report be implemented as soon as possible (such as develop- ment of a strong public participation program; full consideration of economic, institutional, and legal factors; investigation of pub- lic health concerns; and development of a quality assurance and quality control program and a data-management program). June 1986 Subcommittee on Public Health This letter report reviews the research proposed by the SJVDP related to public health. Generally, the report is favorable, but it identifies some deficiencies in five areas: (1) the need for a more coherent conceptual approach; (2) identification of hazards; (3) exposure assessment; (4) integration of public health delivery services; and (5) the establishment of a public health subcommittee within the SJVDP. June 1986 Subcommittee on Quality Assurance and Quality Control This letter report reviews a draft quality assurance plan for the SJVDP. It is critical of the plan and provides many suggestions for improvement in the areas of (1) quality assurance policy and man- agement; (2) data quality objectives and sampling procedures; (3) analytical procedures; (4) data reduction, validation, and reporting; and (5) performance and system audits. The subcommittee stresses that a well-designed quality assurance plan is essential. September 1986 CIIWQP This letter report asks the SJVDP to assess a proposal for the cleanup of Kesterson Reservoir made by the Lawrence Berkeley Laboratory of the University of California regarding maintaining flooded conditions. The committee recommends that basic studies

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SUMMARY OF LETTER REPORTS 145 of the biological cycling of selenium in saline and alkaline aquatic ecosystems be given high priority. It recommends that a thorough monitoring system be established to assess the impacts of this management approach on plants, animals, sediments, and water. February 1987 Subcommittee on Public Health This is a supplement to the June 1986 letter report from this subcommittee that recommends that as the SJVDP evaluates the feasibility and desirability of various solutions, it should explicitly address the public health concerns that might be raised by such actions. March 1987 Subcommittee on Quality Assurance and Quality Control This letter report strongly recommends that the SJVDP hire an ex- perienced quality assurance and quality control manager as soon as possible. It also stresses that data management must be performed so that it ensures that useful information is not lost. The com- mittee raises concerns that the quality control protocol for plant tissue appears to lack the rigor of other protocols (such as those for water, soil, sediment, and animal tissue). July 1987 CIIWQP This letter report commends the SJVDP for making progress, especially for establishing a citizens' advisory committee. It urges the addition of a quality assurance and quality control officer and an experienced research biologist. The committee still believes that the SJVDP gives inadequate attention to comprehensive, integrated planning, and it stresses that the SJVDP must consider all the available options, even those that are politically unpalatable. July 1987 Subcommittee on Economics and Policy This letter report reminds the SJVDP that the interactions between human activities and the environment cannot be ignored and that technology must be seen in light of evolving social and economic systems. It advises the SJVDP to develop an analytical method- ology to identify diverse and often conflicting environmental and economic considerations; examine equity issues; and broadly eval- uate the general public policy issues involved in the alternative solutions being studied. The committee also stresses the impor- tance of addressing legal issues.

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146 IRRIGATION-INDUCED WATER QUALITY PROBLEMS May 1988 Subcommittee on Economics and Policy This letter report comments on the SJVDP publication Developing Opinions: An Overview of Efforts to Solve Agricultural Drainage and Drainage-Related Problems in the San Jouquin Valley. The report also stresses several points regarding the continued need for a broad focus in the SJVDP's research, the importance of not narrowing the choice of alternative solutions prematurely, and the urgent need to initiate the planned legal and institutional policy analysis. July 1988 CIIWQP This letter report to the U.S. Department of the Interior's Na- tional Irrigation Water Quality Program (NIWQP) which was es- tablished in 1987 commends the program for its initial efforts to investigate potential irrigation-related water quality problems throughout the West. It reviews the committee's involvement in that ongoing effort, including its review of draft work plans for reconnaissance-level and detailed studies and suggestions to im- prove them. The letter anticipates the committee's increasing in- volvement in the NIWQP's activities. December 1988 Subcommittee on Quality Assurance and Quality Control This letter report, the third from the Subcommittee on Quality As- surance and Quality Control, stresses the continued importance of quality assurance and quality control activities as the SJVDP winds down its data collection and begins to synthesize information. It also urges the SJVDP to create a central repository of information under a single manager. May 1989 CIIWQP This letter report addresses the U.S. Department of the Interior's NIWQP and contains comments in response to a briefing of pre- liminary data from the NIWQP's second set of reconnaissance studies. It provides suggestions to improve data uniformity and identification of the causes of identified problems, and it calls for the NIWQP to synthesize the myriad data into a comprehensive analysis with systematic conclusions.

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SUMMARY OF LETTER REPORTS 147 August 1989 Subcommittee on Economics, Policy, and Systems Analysis (previously two separate subcommittees) This letter report to the SJVDP discusses the continued develop- ment of the WADE computer model and the need to be frank about both its strengths and weaknesses. The necessity of outside peer review is stressed. The letter also comments on the SJVDP's progress in conducting legal and sociological analyses. August 1989 CIIWQP This letter report expresses strong dissatisfaction with the political influences that have directed the SJVDP to look for solutions only within the confines of the San Joaquin Valley. This committee sees this as a short-sighted approach and again urges policymakers to address the long-term impacts of irrigated agriculture.

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