January 22, 2013
Dear Board Members:
This message is a brief follow up on your meeting today (1-22-13) where three of you approved the Recycled Water Policy Amendment.
During the meeting today my recent email comments were mentioned and mischaracterized by staff as having no new content. This is not true as I had included a reference to the EPA plan to study research and findings of the scientific study by 12 acclaimed scientists on low dose effects of endocrine disrupting chemicals released in March, 2012. I had submitted this study with earlier comments we made last year on the Recycled Water Policy Amendment, which appears on today’s agenda.
I requested that your Board include a reopening clause on this one issue, should the EPA find validity in the vast amount of scientific evidence that had been compiled and presented in the March, 2012 study on this topic, and which your Scientific Panel ignored, rather than allowing five years to go by before you consider this issue again. No mention was made of this part of my comments although one of you stated that it takes too long to go through the public comment process, so it will not come up again for five years. Is that a good reason not to revisit a project of such potentially cataclysmic outcomes?
It was also mentioned today that the State’s Scientific Panel found no need to study endocrine disruption in irrigated tertiary wastewater used for landscape irrigation because humans won’t be drinking the wastewater. It is hard to agree with the idea that direct ingestion will not occur, nor should it be the only concern. One does not have to drink the water to be exposed to it. People can breathe the spray; they can absorb it through their skin when the spray wanders through the air in places where it shouldn’t; vulnerable children can come in contact with the wastewater at irrigated bus stops where we have photographed excessive pooling on multiple occasions (and any other place where runoff has occurred including waterways in summer), and the fetus’ of pregnant women may also be harmed as well. And none of this considers the full time exposure of aquatic life to the runoff that could easily contain endocrine disrupting chemicals that may destroy their lives. (Staff never addressed our allegation that the runoff will carry such chemicals, regularly applied to the irrigated landscape, into the water with it.)
Ironically, today’s papers contained an article closely related to this topic by the outstanding columnist, Nicholas Kristoff, entitled “Warnings from a Flabby Mouse”, which we attach here. I urge you to read it. He is a master at pulling appropriate information together in a focused format that gets at the core of the issue and has written many such articles on this topic.
I understand why your Board is anxious to develop new water supplies for the State of California. RRWPC does not completely oppose wastewater reuse, but we are enormously concerned that there is inadequate oversight to assure that irrigation runoff will be truly incidental. There is a saying that I am sure I don’t recall exactly, but it goes something like this: When the cat’s away (i.e. enforcement), the mice will play (irrigators that don’t know or care about runoff). As per Kristof’s article, they will probably all get fat.
Brenda Adelman Russian River Watershed Protection Committee