August 30, 2010
Jeffrey Shu
Environmental Scientist
State Water Resources Control Board
Division of Water Quality
1001 I St., 15th Floor
Sacramento, CA 95814
(916) 323-1308 (phone)
(916) 341-5584 (FAX)
Dear Mr. Shu:
This letter is being submitted on behalf of Russian River Watershed Protection Committee in response to your Agency’s request for information on the 2012 303(d) List. We had emailed a partial submission to you on July 15, 2010, with three attachments, but we are resubmitting that information with this packet so it will be a complete submission. Our comments address circumstances in the Laguna de Santa Rosa, a major tributary to the Russian River, and the lower Russian River from the confluence of the Laguna/Mark West Creek into the Russian River and down to the Estuary.
We are concerned citizens who are neither scientists nor lawyers, but it is our intent to submit photographs, testimonies, reports, Regional Board documents, etc. to make the case that the Laguna de Santa Rosa should be listed for the invasive plant, Ludwigia, and that the lower Russian River (Forestville to Duncans Mills) should be listed for nutrients (The Laguna is already listed for nutrients.)
In reviewing the requirements for submitting data for the 303(d) list, we are finding it difficult to document our submission in every detail requested (specific camera settings, etc). Also, as ordinary citizen activists, we are not able to provide scientific data with any authority and so we are relying for the most part on photographic evidence. The photos submitted with this report are representative of hundreds that we have on file. If more pictures become necessary later on, we would be happy to provide them (same locations, but different angles, magnifications, etc.) We can also give more information on specific photos as per request.
We would also like to note that RRWPC fully supports the Coast Keeper Alliance submission on the 2010 303(d) process, especially as it relates to listing all water bodies for pollution and pollutants, water flows as they impact water quality, and impacts of global warming on flows and water quality.
RRWPC Standing:
Russian River Watershed Protection Committee (RRWPC) is a nonprofit public benefit corporation with over 1000 supporters on our mailing list and hundreds of other supporters in the community whom we have not identified. We have been in existence for over 30 years and have been tracking water quality issues all that time. We regularly write for the Sonoma County Gazette and over the years have had numerous letters and columns in the Press Democrat and most other local newspapers. We network regularly with other water activists and are active members of the Sonoma County Water Coalition.
We are located in the lower Russian River (Guerneville), an incredibly beautiful recreational area that hosts visitors from all over the world. Besides the river, we are home to ancient redwood forests and beautiful wooded hillsides. We enjoy a watershed environment that is unique to the Northern California area. Unfortunately, the lower river is also the recipient of many water quality problems caused by human-caused degrading land use activities such as gravel mining, excessive and uncontrolled water diversions, timber harvest activities, riparian destruction, wastewater discharges and polluting agricultural practices, etc. The survival of three salmonid fish species has been declared at serious risk.
RRWPC focuses on water quality issues that affect our section of the river. We attend most Regional Board meetings held in our area and have provided extensive testimony over the years to both that Board and the State Water Resources Control Board (Water Board) on water quality and quantity issues. We have especially emphasized the impacts of wastewater discharges from centralized sewage treatment systems. For the last several years, our attention has turned to the water quality impacts of lowered flows.
Decision 1610 recommended flow changes
We are particularly concerned now that the Sonoma County Water Agency, under direction of the National Marine Fisheries Service’s 2008 Biological Opinion, has and will apply to the State Water Board for both Temporary Urgency Changes (annually until permanent change is issued) and Permanent Changes to Decision 1610, State law that governs Russian River flows. Furthermore, the Biological Opinion orders SCWA to petition the State to lower summer flows by as much as 44% as measured at the Hacienda Bridge.
We believe that further permanent water quality degradation has and will result from these changes. (Our concerns have been documented in our comments to the State Board on Petitions for both temporary and permanent changes, Attachments #1 and #2.) The Russian River is already listed under the 303(d) list for temperature, sediments, and pathogens (pathogens listed only between Guerneville and Monte Rio and at Healdsburg Bridge). When low flow is added to the mix, you have a recipe for extensive nutrient and pathogen pollution, which is exactly what is happening now. (The Biological Opinion failed to address expected water quality impacts to the lower river resulting from lowered flows as measured at Hacienda, but SCWA as lead agency, will develop an environmental impact report to address permanent changes to Decision 1610.)
Last year’s summer flows were extremely low, especially in August, and we took weekly pictures of the lower river from early June through early October to document extensive nutrient pollution. (Minimum summer flow as measured at the Hacienda Bridge is normally 125 cubic feet per second (cfs). The July, 2009 average was 95 cfs, August was 63 cfs and September 80 cfs. according to SCWA data) We also documented the impact of the opening and closing of the river’s mouth on the Monte Rio Beach.
Representative pictures appear in a report we assembled entitled, “RRWPC 2009 Photo Project” (Attachment #3). Photos in this report show extensive nutrient pollution in the lower Russian River, including many forms of algae and extensive outcroppings of invasive Ludwigia. The Regional Board does not recommend listing the lower river for nutrients, although they are well informed of the problems. This may be more a consideration of funding inadequacies, than water quality need.
The compelling reason for requesting that the river be listed for nutrients, is that both Ludwigia and nutrient pollution proliferate in conditions of low flow, high temperatures, inadequate riparian coverage, excessive sediments, and generally degraded conditions, all of which exist in both the Laguna and much of the lower Russian River. By making low flows permanent, as is the intention of the Biological Opinion, these impaired conditions would be greatly exacerbated. They need to be addressed. Summer temperatures in the lower river average 20 to 25 degree Celsius as reported by SCWA’s regularly collected data (Example: Attachment #4).
Laguna impacts on Russian River…..
The Laguna joins Mark West Creek in a field near River Rd. between Trenton-Healdsburg and Slusser Roads. Windsor Creek joins Mark West near Trenton-Healdsburg Rd. and River Road, a little bit downstream of the Laguna/Mark West Creek confluence. Mark West Creek then travels about two miles to where it joins the Russian River right as the river comes down from the north to make its major bend heading west. (near the town of Forestville) These tributary watersheds make up about 21% of the flow in the 110 mile Russian River basin. (I have been looking for a clear map of this confluence and could not locate one. The confluence can be seen on Google Earth at 38N29 122W53.)
This is also close to the location for the Sonoma County Water Agency’s diversion and distribution facility that serves eight major, mostly urban contractors who sell water to approximately 600,000 people. The Agency holds water rights at four locations to divert up to 75,000 acre feet a year. (Collection wells take water from about 60-80 feet under ground and are not influenced by surface water flows.) Starting slightly upstream of the SCWA facility and all the way to Healdsburg, about a dozen gravel pits, several of which have been converted to recreational use, are located. (These can be clearly seen on Google Earth also.) There have been several breachings of these pits over the years and one of the pits has been used to store Healdsburg’s wastewater for that time. Concern has often been expressed about the loss of the natural gravel aquifer and the potential need to construct an extraordinarily expensive disinfection facility should the aquifer’s storage capacity become inadequate. New gravel mining projects are currently being proposed.
The Laguna de Santa Rosa itself has about a dozen tributaries that drain from the urban areas. Other major tributaries are affected mostly by agricultural land use, although the main stem of the Russian travels north through Healdsburg, Cloverdale, Ukiah, etc. All of these tributaries contribute vast amounts of sediments, nutrients, pathogens, and other pollutants that ultimately are transported and get deposited in the lower river, with the Laguna probably the most egregious contributor. This is an especially serious problem coming from storm water runoff, but is currently starting to be addressed through a new MS4 Permit by the Regional Board.
The USGS Hacienda Gauge that measures flow is located about 3-4 miles downstream of the Laguna de Santa Rosa/Mark West Creek/Windsor Creek confluence with the Russian River and about 4-5 miles upstream of the town of Guerneville. Mark West Creek and Windsor Creek drain large areas to the north and northeast and have their own water quality problems, which we will not address here, exacerbating existing water quality degradation in the lower river. (For about 30 years, Santa Rosa was allowed to discharge 5% of river flow as measured at Hacienda, which is about 12 miles downstream of their point of discharge. The 5% was based on flow that included their discharge, which once got as high as 150 million gallons in a single day. It was not uncommon for daily discharges during a storm to reach 50 mgd.)
The Laguna de Santa Rosa, for many years the prime receptor for huge volumes of Santa Rosa’s wastewater discharges (up to four billion gallons a year including wastes generated by Cotati, Sebastopol, and Rohnert Park) is severely degraded and listed on the 303(d) list for nitrogen, phosphorus, temperature, dissolved oxygen, sediments, mercury, and in some locations, pathogens.
In a Regional Board Interoffice Communication to Bob Klamt, intended to clarify the impact of Santa Rosa’s nutrient contribution to the Laguna while discharging, Cathy Goodwin states on March 10, 1994, “Nutrient concentrations increased at the two Laguna stations down-gradient of the City’s Delta Pond discharge: Laguna at River Road and Mark West Creek at Trenton-Healdsburg Road.” Also, “In the Russian River, nutrient concentrations increased at the two stations down-gradient of the Laguna’s confluence with the Russian River.” (Attachment #5)
In the summer, pollutants and nutrients becoming very concentrated in the low-gradient Laguna flow and have resulted in ever expanding and extremely excessive Ludwigia and algal problems. The algae, Ludwigia, excessive nutrients, dissolved oxygen, and excessive temperatures, all work together synergistically to exacerbate problems created separately by individual impairments.
This complexity is described in the following report on pages 9-10 of the Interim Staff Report from the Regional Board on January 27, 1993 (Attachment #6): “Nutrient cycling in a stream system is complex and tied to the various interrelationships of primary producers (algae and aquatic macrophytes), nutrient inflow from surface and ground water and waste discharges, sediment-water interactions, and nutrient outflow (residence time in the stream). At any given point in time the various nutrient forms are a result of the actions of all those factors. The primary relationships in nutrient cycling are in plant productivity tying up the available nutrients, settling of particulate matter containing those tied-up nutrients (organic nitrogen and phosphorus), and release of the nutrients via decomposition in the sediments. Phosphate generally tends to bind to particulates if they are available and fall out of the water column. Nitrate is more mobile and tends to dissolve in the water. Both nutrients are most readily available in dissolved form.”
The presence of the Ludwigia is a culmination of a long-standing problem and in turn then creates additional ones. It invites mosquitoes that carry West Nile Virus and possibly other pathogens. It chokes waterways and eliminates biodiversity. It is almost impossible to fully remove and it spreads profusely everywhere it goes where conditions are right. It likes the same conditions as algae: low flow, shallow depth, warm water, sunlight, and lots of sediment. And when the vegetation dies off, the biomass remains if not flushed out by fast moving flows, only to feed more mass when conditions are ripe again. During summer in the Laguna such conditions commonly occur.
Ludwigia (Laguna de Santa Rosa)
Ludwigia has been rampant in the Southwest part of the Laguna and is rapidly spreading. Numerous experts and agencies have openly acknowledged the extent of the problem.
The Sonoma County Water Agency’s May 12 2005 document entitled “Frequently Asked Questions about Ludwigia and West Nile Virus”, states; “Ludwigia has spread very rapidly in our watershed over the past 10 years. In areas where it has taken hold, it has almost completely smothered native wetland plants. Summertime dissolved oxygen levels in Ludwigia areas are so low that many fish species cannot survive. Open-water areas favored by waterfowl are choked with this weed, greatly reducing their habitat value. Waterways are obstructed by the accumulated perennial biomass, which may also trap sediment and debris, contributing to ongoing flood-control issues. Biomass doubles in 15-20 days in slow-moving waters, and it is estimated that there is now more than 10,000 tons (20 million pounds) of accumulated Ludwigia biomass.” (emphasis added) (Attachment #7)
The opening paragraph of the Laguna Foundation’s “Ludwigia Control Project Final Report” January, 2008, states, “Ludwigia sp. is a non-native invasive aquatic plant from South America that has invaded the Laguna de Santa Rosa watershed. The scale of the invasion threatens water quality, biodiversity and channel capacity and hampers efforts to control mosquitoes. The Ludwigia Control Project (LCP) was a three-year effort to reduce the extent and density of the Ludwigia sp. in two of the worst affected areas of the Laguna de Santa Rosa. Spearheaded by the Laguna de Santa Rosa Foundation, the general approach included application of aquatic herbicide followed by mechanical removal of biomass. The total project area comprised 5.3 miles of channel and 99 acres of floodplain.” (Attachment #8)
RRWPC attended meetings of the Task Force established to address this issue and implement and oversee the project. Periodically we took pictures of the most infested area that is easily accessible. There are also several before and after pictures in the Ludwigia Control Project Final Report mentioned above. (Stony Point Rd. Bridge over Bellevue Wilfred Channel, just south of the Rohnert Park Expressway: This area can also be viewed at Google Earth: 38N25 and 122W49). (Attachments #15 & #16)
While we could not access the 111 acres of the Laguna Wildlife Area owned by CA Fish and Game, we did track the very visible Laguna as seen from the bridge on Occidental Road which is less than a mile upstream of the DF&G property. (Google Earth at 38N21 and 122W44) At no time before this year did we see significant amounts of Ludwigia present from the Occidental Road Bridge. Yet this year, after last year’s very low flows, the creek has been almost totally covered with the invasive plant. We provide pictures taken just recently in mid-August, 2010. (It seems that where there are these extensive infestations, the only un-infested location is under the bridge itself although algae has been photographed in those areas. This appears to indicate that temperature and light and perhaps water depth are major factors in Ludwigia’s spread.) (Attachment #14)
In fact, the Conclusion of the Final Ludwigia Report states, “The three-year effort to control Ludwigia through herbicide application and mechanical removal has yielded mixed results at considerable cost. The degree and duration of control are closely linked to physical conditions at the site and annual variations in temperature and precipitation. Clearly there continues to be a need to address to the underlying conditions that promote Ludwigia growth in the watershed. Long-term Ludwigia control will require systemic approaches that address the primary stressors in the Laguna. Reducing inputs of nutrients and sediment is paramount. This process will begin when the Regional Water Quality Control Board completes its TMDL pollution plan, sometime around 2011. Although measurable differences may be more than a decade away, it is a positive step.”
(Note: as of the end of August, 2010, a great deal of work needs to be accomplished before the TMDL is complete. This work has barely begun, in fact very little work has been done on nutrient pollution, and a completion date of 2015 at this point would probably be optimistic.)
The focus in the shorter term should shift to manipulation of physical conditions as part of larger restoration plans. Perhaps the most effective action will be water level manipulation. This entails creating conditions that promote either deep water or the absence of water during summer months. Methods may include targeted sediment removal, creation of low flow channels, and reduction of summer irrigation runoff. Because accumulated sediment is very likely enriched with nutrients, its removal in key areas will also serve to remove accumulated nutrients from the system. Because sediment removal will create considerable disturbance, it should always be accompanied by restorative actions such as establishment of riparian forest.”
Over-irrigation of wastewater causes runoff….
It is important to emphasize the reference to irrigation runoff in the paragraph above. The highly Ludwigia infested Wilfred-Bellevue Channel (see pictures: Attachments #13, #15, #16) is immediately west of Rohnert Park. Rohnert Park generously irrigates their public facilities in the summer with wastewater. RRWPC has documented extensive runoff from their irrigation program which was inadequately overseen by Santa Rosa, the entity holding the Reclamation Permit and responsible for the wastewater.
After a complaint was filed, on March 30, 2010, the Regional Board issued a Notice of Violations regarding unauthorized recycled water discharges from Sonoma State University and from Rohnert Park (Attachment #9) The most recent contract between Santa Rosa and Rohnert Park defining terms of RP’s irrigation requirements was dated 1993, and clearly outdated. Furthermore, it was clear that the requirements in that document were not even being followed, or the runoff would not have occurred. It appears that until the complaint was filed, neither Regional Board nor Santa Rosa staff had been monitoring the requirements in the permit.
It is our understanding that Regional Board staff are imposing much more stringent monitoring and reporting requirements now on Santa Rosa and Rohnert Park and the issue is being addressed. Nevertheless, as irrigation with wastewater in all of the local cities is currently being greatly expanded, due to significant encouragement from the State’s new Recycled Water Policy, there will be many future opportunities for this problem to increase throughout the area.
Since 2008, when the Laguna Foundation’s report and pictures indicated that the Bellevue Wilfred Channel had been essentially cleared (at a cost of over $2 million dollars and the use of a great amount of chemical herbicides), we have been photographing that area. In 2009 and 2010, the invasive plant returned with a vengeance, is now worse than it ever was, completely filling the Channel where a creek once flowed, as portrayed in the several pictures taken very close to where the final pictures in the Ludwigia Report were taken in August, 2007. (Attachments #13, #15, #16)
While we have not surveyed all (or even most) Laguna streams for Ludwigia infestation, the seriousness of what we have seen, and the probable impacts to the lower Russian River, we are motivated to request a 303(d) listing for Ludwigia in the Laguna. As already noted, there has been a significant new infestation in the area around the Occidental Road Bridge, which is about five miles downstream of the Rohnert Park infestation.
Because the Laguna is already designated as having the multiple impairments that exacerbate the problem, the likely increase of an even greater infestation of Ludwigia is very imminent and deserving of the special attention a separate 303(d) listing would give it.
Development of a Conceptual Model….
In 2007, the Laguna Foundation published a study called, “The Altered Laguna: A Conceptual Model for Watershed Stewardship” (Attachment #10). This model was intended to serve as the organizing and launching document for the Laguna TMDL process.
The Report stated (p.51), “As exotic invasive plants, such as invasive Ludwigia sp., increasingly take hold in native plant communities, they threaten native biodiversity by changing the native vegetation structural diversity, often completely ‘taking over’, not only out-competing native plants and establishing an extensive and expanding mono-culture, this process so fundamentally changes the original native ecosystem, causing the local extinction of organisms rightly linked to the original community structure and function (National Invasive Species Council 2001).“ This report establishes a framework for identifying data gaps, system indicators, monitoring regimes, and restoration targets.
Page 2 states, “In the highly complex Laguna de Santa Rosa watershed system, predictions are only possible by close examination of all system components. Our understanding of the linkages among these components is made tangible through a series of steps that progress from the conceptual model addressed in this report to dynamic modeling simulations in the near future.” The report then goes on to define the various steps needed to obtain information that integrates and informs all the possible variables.
Phosphorus study of Santa Rosa’s wastewater…
On January 28, 2000, Dan Wickham and Bob Rawson published a report entitled “Phosphate Loading and Eutrophication in the Laguna de Santa Rosa”. This study quantified the amount of phosphorus loading into the Laguna from wastewater discharges. The information in this report was primarily responsible (we believe) for the listing of phosphorus on the 2002 303(d) list.
The report makes several critical findings, which are not only important for the existing listing for the Laguna, but the requested listing for the Russian River.
(page 6-7 of report)
1. It is affirmed that limiting phosphorus availability in lakes is the single, most important and necessary step to be taken now in eutrophication control.
3. Because all inputs are additive, and therefore potentially significant, all should be considered for control.”
4. Municipal sewage is the major point source. All such discharges to lakes and other susceptible waters should be treated to reduce phosphorus content to realistic target levels.
6. Nutrient budgets should be established….
8. Where slow flushing impedes improvement from curtailed phosphorus inputs, accessory steps to inactivate, harvest, or other wise retrieve nutrients from lakes much be considered.
Wickham and Rawson demonstrated that (p.7), “The average reading of phosphate concentration (measured as P) presented in the Subregional EIR prepared I 1996 equals 4.2 mg/L (Appendix I). It should be noted that typical concentrations of phosphate (as P) in most natural water bodies are less than ranges from 0.005-0.1 mg/L (Wetzel, 1983).” The authors went on to estimate that Santa Rosa releases the equivalent of 2,300,000 lbs. of commercial fertilizer into the Laguna per year. (Attachment #11) (We are just submitting part of this lengthy document, but the full report can be provided if requested.)
Thankfully, the City sends most of its wastewater to the Geysers now (since 2004), but where did all that phosphorus end up? How much is still bound up in Laguna and Russian River sediments and the accumulated biomass currently sitting in our river bottom, feeding all the algae that proliferates ever more each year? Furthermore, we wonder how much phosphorus other wastewater dischargers are putting in the Russian River? If the Russian were listed for nutrients, this would have to be evaluated and addressed. (This will be addressed further in comments below.)
Photos demonstrating Ludwigia problem in Laguna….
We offer these pictures as examples of the severe Ludwigia problem in the Laguna. It is important to note that in every case, one could see water under the bridge; Ludwigia did not grow well in the cooler, darker water (perhaps deeper as well. This was visibly noted in the Final Ludwigia Report by the Laguna Foundation in Appendix I. Also, there is a good map of the area on page 3 of the Report. (Attachment #8)
Hinebaugh Creek: Pictures #1219 & 1377 taken on 8-11-10 on Labath St. in Rohnert Park just north of Rohnert Park Expressway. One picture is looking east and one west although I don’t recall which is which. In any case, there is no Ludwigia in this creek at this location is about 2/3 mile upstream from Stony Point Bridge over the Bellevue-Wilfred Channel. (Attachment #12)
Bellevue-Wilfred Channel at Milbrae Bridge: (between Labath and Langner) in Rohnert Park: This is approximately two miles from the Stony Point location of this same creek. Picture #1229 looks south and #1380 looks north. They were both taken on 8-11-10. (Attachment #13)
Laguna de Santa Rosa from Occidental Bridge: (about eight miles north of Bellevue-Wilfred Channel at Stony Point) Pictures taken on August 8, 2010. Photos #1173/#1331 look south and #1192/#1300 look north. (Attachment #14)
Bellevue-Wilfred Channel from Rohnert Park Expressway, just east of Stony Point Rd. Pictures taken on 8-11-10. #1211 looks north and #1218 and #1364 both look south. These views are right around the corner from the Stony Point Rd. pictures and have the worst Ludwigia infestation. (Attachment #15)
Stony Point Rd. 1/8th block south of Rohnert Park Expressway: Pictures taken on 8-11-10 except for #1004 which was taken 5-2-10. #1359 is a picture of algae right under west side of bridge. Pictures #1004 and #1198 are looking toward the west and taken on the west side of the bridge. Pictures #1206 and #8226 were taken on the east side of the bridge looking towards the east. (Attachment #16)
Finally, we believe that it is extremely important to list Laguna Ludwigia because this invasive plant is rapidly spreading and threatens many miles of waterway. Furthermore, it can seriously impact the flooding situation downstream, as the Laguna serves as a storage area for the Russian River during floods and relieves the lower river area of many inches of flooding under normal conditions. We have not had a major flood since this plant has proliferated and we are very concerned about the damage it can do.
Lower Russian River Algae Problems….
As mentioned earlier, the Biological Opinion requires that the Sonoma County Water Agency (SCWA) apply annually to the State for Temporary Urgency Change Orders to lower required minimum flows designated in Decision 1610 until a permanent
It is particularly interesting this year we had a great deal of rain that then combined with a very cool summer. The reservoirs are full in late August and there could even be a problem with flooding if they don’t get the levels down soon. (As I write this on August 28th, Lake Mendocino water supply pool is 86% full and Lake Sonoma is almost 93% full.) Even though the State issued the Order to lower flows in June, it simply has not happened because reservoir levels have been too high and more substantial releases needed to be made. Until about a week ago, flows at the Hacienda Bridge averaged about 170 cfs most of the summer. On August 28t, the flow was 99 cfs. In addition, the creeks were generally flowing higher than normal and feeding the river as well.
The Biological Opinion does not concern itself with these complexities, but only with the specific water supply operations of the SCWA working jointly with the Army Corps of Engineers (ACOE). In order to try and save the steelhead, the National Marine Fisheries Service (NMFS) wants the mouth of the river closed during the summer months so as to provide fresh water rearing habitat in the Estuary. The plan is to construct a barrier beach during the mouth’s first natural closing, and leave it closed until mid-October. Because properties flood in the town of Jenner when the river gets too high, the plan is to lower flows in the entire river in order to accommodate the project.
This situation motivated us to institute a photo project last summer between June and September so we could visually document the lower river’s condition during the low flows. We took weekly pictures at numerous locations and less frequent pictures at other locations between Forestville and Duncans Mills. What we observed was that the lower the flow, the worse the algae, especially when temperatures were high. The Russian River is already listed for temperature and sediment impairments along with pathogen impairments between Guerneville and Monte Rio. It made sense that beneficial uses would be impacted by severely lowered flows. (There are two summer dams in Guerneville: one at Johnson’s Beach and one at Vacation Beach downstream. These locations have plenty of water for recreation and we haven’t noticed much algae except at Vacation Beach. See photos)
As mentioned before, RRWPC published our 2009 Photo Project Report in June, 2010. (Attachment #3) That report included pictures of many kinds of algae and Ludwigia showing up in the river. The problem was worse in August, when flows at the Hacienda Bridge averaged 63 cfs. It was the third year of a draught period that left reservoirs at about half the normal level. Cities were forced to seriously conserve. Luckily it was a cool summer and no disasters occurred. We can anticipate a real problem however if there are two back-to-back years of low rain and high summer temperatures.
(We are not submitting separate photos for last year because we believe that the Photo Project provides examples of impairments that we saw. We could make additional photographs available, or the original digital versions of the ones in the Report, if requested. Also, we include a packet of testimonials about the condition of the river from our RRWPC supporters. Attachment #17).
Monte Rio affected by closed river mouth….
Last year we learned that the mouth of the river would be opened on Oct. 6th. We rushed to Monte Rio to get pictures of the water level before that occurred. Then the following day we went back and found water levels down about three to four feet. We have since heard reports from people who have floating docks in the Villa Grande area that the level can go down as much as five feet in places. (The amount of decrease may depend on the width of the channel at that location and depth of river.) The before and after pictures appear in our Photo Report.
On the day after the opening (10-7-09), we saw lines of algae marking the place where the water had been the day before. We reported the situation to the North Coast Regional Board. Because we expressed concern about the possible presence of toxic blue green algae, staff told us they would send someone out to take samples. The worst algae we viewed occurred at the Kid’s Beach in Monte Rio and by the Vacation Beach Dam (one mile downstream of Guerneville).
On Oct. 20th we got an email from John Short of the North Coast Regional Board stating that, “Our staff went out to the river last Monday in response to your email. Algae was observed and collected at the kiddie swim area in Monte Rio. L Staff also visited the Vacation Beach site and collected samples there as well. Staff evaluation of the Monte Rio algae sample verified the presence of anabaena, a blue green algae in the neurotoxin family. The Vacation Beach sample was negative for blue green algae. We are contacting Sonoma County Health Department to alert them to these results. The populations of these algae tend to decline significantly in the fall due to lower temperatures and added flows.” (Attachment #18) John and other staff later made other statements about this finding that expressed uncertainty about the results. RRWPC believes that whatever the results, enough uncertainty about the types and amounts of algae exists so that these areas should be tested periodically and perhaps regularly until more is known.
Serious algae problem downstream from Monte Rio Bridge….
Towards the end of July, 2010, we got an email from some physicians telling us about massive algae in their Monte Rio area. They sent pictures of some toxic algae down loaded from Wikipedia and wondered whether that was the same as what they saw near their homes? We did note that these pictures looked very similar to the ones we had put in our Photo Report on page 6: #7239 and page 8: #3311. (We are attaching email we received with names removed. Attachment #19)
We were invited to take photos from their ramp and they also sent us some early morning shots that clearly indicated that over half of the water surface was covered in floating algae. The pictures they sent in email were taken from their deck are Attachment #25. One of the physicians states in the email, “The algae bloom this last week in our experience has been the worst we have ever seen. E. found some interesting links and the lyngbya in particular which is rampant does release dermatotoxins, that should cause real concern for those who use the waters for recreation. We look to you and your organization as to what can be done and the impact of the low flow decision. Thanks.”
We notified Regional Board staff of the problem and were very pleased that they took our report seriously. Along with RRWPC board member Dennis O’Leary, I met with Matt St. John, Clayton Creager, Steve Butkus of the Regional Board staff and Walter Kruse and Jim Tyler of County Environmental Health Services at the Monte Rio Beach on July 27th. We also visited the private residence in the Monte Cristo area a mile downstream. Samples were taken and tested, but we did not see whether they took samples of the algae that looked like the toxic algae in the pictures.
A report later identified the algae as two green algal filamentous species and not blue green algae. Staff’s report of our meeting (Attachment #20) claimed, “Based on visual assessment of the percent cover and density of algae at these locations, staff characterize the total algal biomass at these sites as high, but not uncharacteristic for this time of year.”
We feel that this statement really minimizes the seriousness and scope of the problem. Everyone we spoke with who live in the area agreed that this season has been the worst. Furthermore, we don’t know whether samples were taken representing all types of algae present. Interestingly, water levels were much higher in the Forestville area and most algae we photographed last year were more submerged and less visible to the eye.
At a meeting I attended of Northwood homeowners on August 28th, questions arose about the Russian River County Sanitation District (RRCSD), immediately upstream of the golf course around which the houses are located. I mentioned that I noted a quarter or half-mile stretch of Ludwigia along the same bank as the outfall downstream. People agreed that this could be a problem and one person told me that they have seen foam coming into the river from that location. It is also fascinating that the line of Ludwigia stops just downstream of the outfall and a little upstream of Northwood. (We clearly remember that Cathy Goodwin stated on several occasions over the last several years that algae are very problematic in that location.)
We have wondered for a long time whether the RRCSD and/or Northwood may be contributing more nutrient pollution in our area? Furthermore, immediately upstream of the Treatment Plant, and for about one mile where houses have septics and are not hooked up to sewer, we noticed no signs of nutrient pollution. Similarly, closer to the Monte Rio Bridge where non-sewered houses were located, there was also little nutrient pollution on the bank where the houses were located. Conversely, in Guerneville (though upstream of the Treatment Plant), where houses are hooked up to the sewer, there were numerous outcroppings of Ludwigia, although not as bad as in the Monte Rio area.
We believe that a thorough investigation of nutrients discharged by RRCSD and/or the golf course, and the impact they may be having on the lower river is called for. We also think it would be important to have a study documenting types of nutrient pollution (including Ludwigia), their density, and land use practices nearby. While we realize that as yet, numeric limits do not exist for nitrogen and phosphorus, the Basin Plan clearly states: “Water shall not contain biostimulatory substances which promote aquatic growths in concentrations that cause nuisance or adversely affect beneficial uses.” We strongly believe that if the lower river is listed for nutrients, the Regional Board will have a much more reasonable basis for imposing strict nutrient constraints on RRCSD and any other dischargers. All public facilities near the river should be carefully checked as well.
Increased pollution over the years, a long time resident’s view…
On August 13th, I visited Gary Getchell, local builder, whose family has lived in the Monte Rio/Monte Cristo area for generations. By that time, the surface algae had retreated due to cooler temperatures and higher winds. It was still possible to see mats of algae below the surface however. We talked about the frequent accusations that failing septics are polluting the lower river. While both of us acknowledge that there may be some failing septics, he made several cogent points about that issue and others that I would like to mention here.
- Septics are better now than before and many along the river have been upgraded. There has been very little new growth in the area and a lot of housing rehabilitation (building permits require septic upgrade) This point can be verified by the fact that dry weather flows to the Russian River County Sanitation District Treatment Plant have remained fairly constant for the twenty-five years of its existence. (Sewer District is “next door” to Monte Rio.)
- In 1985 tougher leach line regulations went into place giving better protection.
- Fifty years ago there was no algae. Urban areas were far less developed and there was much less wastewater and storm drain runoff being discharged. There was less agricultural development. Gary believes that much of the pollution is coming from upstream.
- Many species that used to be abundant on the river are now gone: frogs, pollywogs, tree frogs, fresh water eels, etc. Of course the salmon are almost gone also. Other species are becoming much less prevalent.
- There’s been a significant drop in water level (some neighbors disagree on this, but Gary is basing it on his knowledge of where water levels are now compared to permanent features such as logs and trees and where they were before.).
- Finally Gary said that the algal mats on the bottom of the river, which are visible, are as much as three to four feet deep and growing worse all the time.
Follow up on 2009 Photographic Report….
We have taken many pictures in 2010 of the same river areas that appeared in our Photographic Report and new ones as well. These pictures serve as our evidence for the nutrient pollution we have been describing.
Hacienda: (Attachment #21)
West bank looking downstream from Hacienda Bridge: #1274 and #6980. Both were taken on 8-12-2010. River flow at this location was 178 cfs.
East bank looking upstream from Hacienda Bridge. #1449 taken 8-12-10 when flows at that location were 178 cfs. #8092 was taken on 8-16-09. Flows on that date at that location were 51 cfs. These two pictures visibly demonstrate the difference that occurs during much lower flows.
Monte Rio Beach to Vacation Beach: (Attachment #22)
View of South bank: #1297 taken .3 mile from Monte Rio stop sign next to theater (pull off on Hwy. 116) on 8-25-10 (no Ludwigia visible)
View of South bank: #1299, #1300, #1506, #1508 taken1.2 miles from Monte Rio stop sign on 8-25-10. This area just east of Northwood has a lengthy and solid line of Ludwigia and is immediately downstream of the RRCSD. (.3 mile further down the road: 1.8 miles from stop sign, there was a turn out and no Ludwigia was present) This solid patch of Ludwigia is unusual on the river. All of our other pictures indicate outgrowths in patches, not a straight line going for a relatively long distance. We estimate it was maybe one half of a mile or more.
Pictures of same area taken by Larry Hanson while canoeing down river between Monte Rio Beach and just east of Northwood Golf Course and just downstream of RRCSD on August 24, 2010: The 2009 Photo Report shows same location last year on page 10, #3200
- Just downstream of Monte Rio Beach: #P8240035 & P8240006/ Immediately past beach area, Ludwigia was very sporadic/can see lots of algae in this area/also low water in this area (Ludwigia mostly on north bank.)
- Between Monte Rio Beach and Northwood although location of specific photos is vague/P8240010, P8240025, P8240012, P8240029 Long line of algae and Ludwigia appears to stop just past Northwood Golf Course and is located on south bank.
Steelhead Beach: (Attachment #23)
Pictures taken on August 12, 2010, between the Boat Ramp and the Kid’s Beach. #1248, #1251, #1414, #1431 River flows were around 178 cfs. This is a about 2-3 miles upstream of the Hacienda Bridge. There was a great deal of Ludwigia but not much algae was visible #7-31c taken by Tom Meldau and Shane McColgin shows patches of Ludwigia similar to this year. Last year flows were at 51 cfs this time of year. Can’t tell if Ludwigia was worse last year in these photos.
Vacation Beach: (Attachment #24)
This is a relatively small beach with a parking lot with a boat ramp about a mile downstream of Guerneville. There is a road and a summer bridge. It is less than a mile upstream of RRCSD. There was a lot of heavy algae on the beach. I had been there three weeks earlier when water levels were higher and had not seen the algae. All pictures in this group were taken on August 25, 2010. I don’t have exact Hacienda flow on this date, but on Aug. 22, 2010, the flow was 123 cfs and going down. Photos: #1316, #1323, #1517, #1520, and #1523. All pictures taken on beach and road just downstream of dam.
Villa Grande: (Attachment #25)
This is a small community one mile downstream of Monte Rio Beach and the location of the worst algae we saw anywhere. We took pictures at a private residence and this was one of the locations where Regional Board took samples and claimed this was ordinary filamentous green algae. Pictures #1144, #1150, and #1156, were all taken by me on July 23, 2010 on the dock of a private residence. The owner of the property provided photos #river5 and #river7 and they were both taken on July 30, 2010.
Conclusion:
This whole issue is a work in process. There is a great deal of information to come forward about water quality in the lower Russian River and we ask you not to close the door on information gathering.
There is going to be an environmental review on changes to Decision 1610 where all of these comments and much more will be submitted about the impacts of lowered flows on the Russian River.
Related to that, the State Board, during review of SCWA’s Temporary Urgency Change Petition to lower flows in the Russian River in 2002, 2004, 2007, 2009, and 2010 asked for nutrient monitoring of the Russian River. Regional Board has admitted that nutrient data thus far collected has been inadequate, mainly because detection limits were too low. In 2010, more stringent guidelines for collecting data have been in effect, but we have been unable to attain the information for this paper. We anticipate that more information will become available in the near future.
The Regional Board has just begun the process of developing information on a Laguna TMDL. This is critical to addressing the Ludwigia issue, which we believe needs to be addressed in its own right, as we hope we have demonstrated.
USGS has been studying water quality in the lower river for years now and hopefully in some point in the near future a full report will become available, which we have not seen as yet.
Finally, one last issue we will add here, is that often people rely on major floods to flush out the river of nutrients and all the other toxic garbage that gets thrown in there. We have not had a major flood in a long time. We have been in a draught period most of the last five years. While 2009-10 rain season was a fairly good one, it did not produce a flood. Weather is becoming more and more unpredictable; we may be faced with a deluge next winter….or not! To count on such events to clean up our river is not a worthy option.
We urge you to seriously consider all we have said in this paper and we look forward to your response.
Sincerely,
Brenda Adelman: Chair
Russian River Watershed Protection Committee
List of Attachments
Recommendations for 2012 303(d) List
Submitted on Aug. 30, 2010, to SWRCB
By Brenda Adelman for RRWPC
1. RRWPC Comments to SWRCB on Petition for Permanent Change to D1610:
May 13, 2010
2. RRWPC Comments to SWRCB on Temporary Urgency Change Petition re: D1610: June 23, 2010
3. RRWPC 2009 Photo Project: June, 2010
4 A & B: Johnson’s Beach water quality data: 7-18-2010 & 8-13-2010
5. Memo to Bob Klamt from Cathy Goodwin on 3-10-94
6. Interim Staff Report: North Coast Regional Board, Jan. 27, 1993
7. “Frequently Asked Questions”, SCWA, May 12, 2005
8. “Ludwigia Control Project Final Report” Laguna Foundation January, 2008
9. Letter from Regional Board to Miles Ferris giving notice of violations for SSU and Rohnert Park discharges, Feb. 22, 2010
10. “The Altered Laguna”, Laguna Foundation, Tetra Tech, Philip Williams & Assoc., 2007, pages 2, 51-52
11. Phosphate Loading and Eutrophication in the Laguna, Dr. Daniel E. Wickham and Robert W. Rawson, Jan. 28, 2000
12. Hinebaugh Creek: Photos: August, 2010
13. Bellevue-Wilfred Channel from Millbrae Bridge: Photos: August, 2010
14. Laguna de Santa Rosa from Occidental Rd. Bridge: Photos: August, 2010
15. Bellevue-Wilfred Channel from Rohnert Park Expressway: Photos: August, 2010
16. Bellevue-Wilfred Channel from Stony Point Rd.: Photos: August, 2010
17. Packet of testimonials by RRWPC supporters
18. John Short email re: Blue Green Algae: 10-19-2009
19. Email from Monte Rio residents about excessive algae: July 17, 2010
20. Lower Russian River Algae Conditions on July 27, 2010: Clayton Creager, Steve Butkus, and Matt St. John Aug. 3, 2010
21. Hacienda Photos: August, 2010
22. Monte Rio Beach to Vacation Beach Photos: August, 2010
23. Steelhead Beach Photos: August, 2010
24. Vacation Beach Photos: August, 2010
25. Villa Grande Photos: July and August, 2010