APAP Approval

1. Lahontan Regional Water Quality Control Board
May 25, 2022 WDID 6A091701001
Kirk Wooldridge, General Manager
Tahoe Keys Property Owners Association
356 Ala Wai Blvd.
South Lake Tahoe, CA 96150
KWooldridge@tahoekeyspoa.org
Approval of the First and Second Amendments to the Aquatic
Pesticide Application Plan for the Tahoe Keys Lagoons Aquatic Weed
Control Methods Test, Order No. R6T-2022-0004, NPDES Permit No.
CA620220
The California Regional Water Quality Control Board, Lahontan Region (Lahontan
Water Board) received the final, first Aquatic Pesticide Application Plan (APAP)
Amendment submittal on May 18, 2022, and final, second APAP Amendment submittal
on May 24, 2022, to fulfill requirements of Section VI.C and Section VI.D of Order R6T-
2022-0004 (Order). The purpose of this letter is to acknowledge receipt of the final
APAP amendments and to approve the final first APAP amendment and final second
APAP amendment.
Section VII.C of the Order requires the Tahoe Keys Property Owners Association
(TKPOA) to submit two APAP amendments and both amendments must be approved
by the Lahontan Water Board Executive Officer before an application of rhodamine
aquatic dye, triclopyr or endothall may occur. The first APAP amendment must be
submitted within 45 days after the adoption date of the Order for Executive Officer
approval and must be made available to the public for a 30-day public comment period.
The second APAP amendment must be submitted at least 30 days before the expected
day of first application of aquatic herbicides and Rhodamine WT for Executive Officer
approval and must be made available to the public for a 15-day public comment period.
Both APAP Amendment submittals were received within the required Order timeframes
noted above. The first APAP amendment was publicly noticed for 30-days via the Water
Boards Lyris email system on March 3, 2022, and 29 public comments were received at
the close of the 30-day comment period. All public comments received were in support
of the first APAP amendment changes in APAP Section 3.2.2. The second APAP
Amendment was publicly noticed for 15-days via the Water Boards Lyris email system
on April 25, 2022, and no public comments were received at the close of the 15-day
comment period.

2. Tahoe Keys Property Owners Assoc. - 2 - May 25, 2022
Lahontan Water Board staff reviewed the draft first APAP amendment and draft second
APAP amendment for completeness and provided the TKPOA comments on the
amendments. TKPOA then resubmitted the amendments, and the Water Board
received the final First Amendment on May 18, 2022, and the final Second Amendment
on May 24, 2022. Lahontan Water Board staff have reviewed the final amendments for
completeness in response to the Order requirements of Section VI.C and VI.D and have
determined the amendments to the APAP are acceptable. Minor edits were requested
by staff to address in the amendments but the documents are considered acceptable
with the understanding that the 24 hour Rhodamine WT dye monitoring will be done
outside of the lakeside of the double turbidity curtains during the application event,
visual monitoring will be conducted with standard water quality monitoring and must be
conducted at all the NPDES compliance monitoring locations, and the Event Monitoring
will be conducted at 3 days after treatment (DAT). Lahontan Water Board staff have
recommended the approval of the APAP amendments.
This approval addresses the changes made to APAP Amendment 1 and Amendment 2
to ensure compliance with NPDES Section VI.C and the MMRP. Changes made to any
section of the APAP not specifically required by section VI.C or the MMRP were not
reviewed by staff with the intent of being accepted by the Executive Officer and are not
accepted as part of this letter. Only the information provided in the APAP Amendments
directly responding to the Order requirements in Section VI.C and Section VI.D are
recommended for approval from Water Board staff. When implementing the Tahoe Keys
Lagoons Aquatic Weed Control Methods Test, the TKPOA must demonstrate
compliance with the MMRP and NPDES MRP.
Therefore, consistent with Section VI.D of Order R6T-2022-0004, I hereby approve the
final, first and final, second APAP amendment submittals received on May 18, 2022,
and May 24, 2022, respectively.
If you have questions regarding this matter, please contact Rob Tucker at 530-542-5467
or email robert.tucker@waterboards.ca.gov, or Tiffany Racz at 530-542-5424 or email
tiffany.racz@waterboards.ca.gov. Please identify the WDID No. in the subject line
assigned to this Project, in any future correspondence regarding this Project.
MICHAEL R. PLAZIAK, PG
EXECUTIVE OFFICER
cc:
Dr. Lars Anderson, TKPOA Consulting Scientist, UC Davis
Rick Lind, President, Sierra Ecosystems Associates