On May 6, 2025, California Coastkeeper Alliance, alongside Orange County Coastkeeper and San Diego Coastkeeper, appeared before the California State Water Resources Control Board to advocate for the approval of the San Diego Regional Board’s Basin Plan Amendment (BPA) to incorporate Biological Objectives.
The amendment would mark a significant advancement in how California protects and restores the health of its waters – not only through chemical and physical indicators, but through biological conditions.
Why Biological Objectives Matter
San Diego County is the most biologically diverse county in the United States. As such, protecting the biological health of its waters is paramount.
Biological objectives evaluate the health of aquatic life in waterways based on scientific assessment of invertebrate communities in those waterways. These metrics give us a clearer, more comprehensive picture of water quality – something that chemical parameters alone cannot completely capture.
Both the Clean Water Act and California’s Porter-Cologne Act support the use of biological objectives. In fact, the San Diego Basin Plan already designates at least ten beneficial uses aimed at preserving and enhancing aquatic life. That’s why, after years of scientific development and public process, the San Diego Regional Water Quality Control Board adopted the BPA on December 8, 2020.
But nearly four and a half years later, it still awaits approval from the State Water Board.
A History of Delay
Despite being ready for final action, the Basin Plan Amendment has been delayed at every turn. To illustrate: the initial public comment period in 2021 was extended by a month; consideration of the BPA was removed from the State Board’s September 2024 meeting agenda and indefinitely delayed; the State Board reopened the record for the submission of new evidence in 2025; a public workshop was held on May 6, 2025 with no timeline for consideration of approval of the BPA.
These delays are not just procedural – they represent missed opportunities to protect Region 9’s waters from further degradation.
Misleading Opposition
Much of the so-called “new evidence” submitted by opposition is irrelevant to the BPA and reflects a concerning attempt to stall process.
The bulk of the opposition’s 770-page submission consists of news articles and transcripts about flooding in the San Diego region, particularly the neighborhood along Chollas Creek. While flooding is a serious issue, the materials submitted as “new evidence” do not demonstrate that the BPA would interfere with flood control or emergency maintenance.
In fact, the San Diego Regional Board has clearly explained, on numerous occasions, that nothing in the BPA prevents routine or emergency flood control efforts. The real challenge facing the City of San Diego’s flood response is a chronic stormwater funding shortfall, not regulatory red tape.
According to the City’s own budget analysts, the stormwater infrastructure deficit stands at $3.5 billion over the next five years. This funding crisis, not the BPA, is the root cause of deferred maintenance and increased flood risk.
Moreover, many of the documents submitted as “new” evidence reference data from as far backas 2014, long before the close of the original comment period. These submissions are not only untimely but undermine the administrative process.
CCKA’s Position: Approve the BPA Without Further Delay
California Coastkeeper Alliance strongly supports the adoption of the Basin Plan Amendment to incorporate Biological Objectives.
We commend the San Diego Regional Board for its leadership in developing these scientifically sound protections. While the delay has been frustrating, the BPA still represents a landmark step for regional water quality.
We urge the State Water Resources Control Board to approve the BPA and send it forward for final authorization.
The time for delay is over. California’s waterways and the communities that depend on them deserve action now.
Policy Analyst Marty Farrell advocates for statewide policies and programs that protect the health of California’s water.
