New sewer regulations on the way…..The North Coast Regional Board is gearing up to develop new septic regulations to satisfy requirements of AB 885, a controversial regulation in the making for over ten years and finally approved a few years ago. AB 885’s intent is to clean up waterways allegedly polluted by failing septics, and its implementation in our area relies on their assessment of bacterial problems in the lower Russian River, a process to be completed within two years.
Russian River Watershed Protection Committee supports requirements that provide assurance of environmental protections that address health concerns and beneficial uses, yet appropriately distributes responsibility for identified problems. Much of the human caused degradation in the lower river occurs upstream of Forestville, including the Laguna, and all should be clearly identified and addressed.
Besides septics, Regional Board staff has identified many other sources of bacterial contamination. The nature and scope of the problem must be scientifically analyzed and all contributing sources must be adequately quantified. To the extent that septics are culpable for polluting river and streams, it is extraordinarily important that governmental agencies assist our community of modest incomes to arrange funding and administrative oversight to fix the problems and the public must be fully engaged in the process at all stages.
We live in an extraordinarily fragile environment that includes a major flood plain, steep slopes with high landslide potential, huge heritage trees, soils with high ground water and liquefaction potential, and more. Conventional sewers are inappropriate in this environment and are far more expensive to construct than in flat plains.
TMDL Process and AB 885…..Several years ago, the river segment between Guerneville and Monte Rio was designated as impaired (i.e., degraded) by bacterial pathogens. This designation was the first step in the process for addressing bacterial pollutants under the Clean Water Act and was based on scientific studies affirming the problem.
This process is closely connected to AB 885, which calls for regulating septics according to the severity of water quality problems in the area where they operate. There are five tiers of requirements for different circumstances, with the most restrictive being those properties within 600’ of an impaired water body. Regulatory requirements can include repair or replacement of current systems, innovative community solutions, or hookups to centralized treatment systems such as Russian River County Sanitation District, OR they may severely constrain what owners can do with their property.
TMDL Findings on source of problem….As part of the Total Daily Maximum Load (TMDL) assessment, Regional Board must first determine where the bacteria is coming from and who is responsible for generating it. Here are some of their conclusions:
- Bacteria numbers are higher in the winter (especially after heavy rains) than in summer.
- During summer, they are higher in tributaries than the Russian River.
- Dairies are high contributors.
- When river flows are low, concentrations of human source bacteria go way up (2009 was a bad year)
- Levels are higher in populated areas than in rural ones, including densely populated areas such as those in semi-rural lower Russian River. (Yet E. Coli did not show up most summers.)
- They are higher during holiday weekends on popular beaches (especially July 4th weekend) than at other times.
- At Healdsburg Memorial Beach they found higher levels when large numbers of people were swimming.
- High levels of Enterococcus bacteria at Monte Rio Beach are related to water levels at the Estuary (higher bacterial levels when mouth is closed- a circumstance that Biological Opinion encourages each summer).
- Evidence exists of high bacterial counts in five tributaries of the Russian River Watershed including: Green Valley, Dutch Bill, Laguna, Santa Rosa.
- There is a relatively new pathogen indicator studied by Regional Board staff called Bacteroides which is ostensibly a better indicator of human source bacteria than conventional indicators such as Total Coliform and Enterococcus. We are concerned that there are currently no specific standards for these new indicators.
Staff claims that the following Basin Plan statement, “The bacteriological quality of waters of the North Coast Regional shall not be degraded beyond natural background levels,” is in effect setting a standard whereby almost any evidence of bacteroides is evidence of pollution (and can be interpreted that it is therefore deserving of appropriate regulation under AB 885). No one has defined the meaning of natural background levels.
Weekly samples taken on major beaches every summer for years…..Regional Board staff and County public health departments have taken weekly samples on many lower river beaches each summer for years, from Healdsburg to Monte Rio, the purpose being to assure that indicator bacterial standards were met. And most of the time standards, as they were then defined, were met. Beaches were almost never closed, and only on occasion were notices posted telling people to swim at their own risk.
Weekly water samples were tested for total coliform, E. Coli, and Enterococcus, indicators of human and animal pathogens. In data for the last six years, 2009 was very bad because of severely limited flows, but most other years there was no identified problem. For instance, between Forestville and Monte Rio there were no exceedances of the standard in 2014, 2011, 2010, and only one or three in 2013 and 2012. Now Regional Board staff considers most of those tests inadequate and have adopted the bacteroides measure.
Inconsistencies? We think there are inconsistencies with some of the conclusions. Their stated purpose was to address exposures of recreationists to pathogens, but then they provide data that attributes increased pathogens to the recreationists themselves. We know they are also are concerned about the homeless population. In either case, installation of inexpensive porta-potties along the river could solve the problem.
We also question why sewered areas along the river show almost as much bacteria as downstream areas still on septic? Could it be that our very expensive sewer system (RRCSD) is as much of a polluter as area septic tanks? Or could it be that most of the pollution is coming from upstream for which others should be held accountable?
There is no question that some things will need to change in the world of septic maintenance, and un-sewered areas will probably need to submit their septics to regular inspections and to follow up with repairs or replacement if proven to be not functioning properly. Or, they can be required to hook up to a centralized system. But in any case, if regulators encourage expensive options then institutional assistance must be provided, since most individual homeowners simply can’t afford remedies proposed thus far. The County and Regional Board need to facilitate and arrange funding for this process.
(Plans for community system in Monte Rio were dropped about seven years ago when price tag went to $22 million for 600 parcels and similarly in Occidental/Camp Meeker when pipeline project costs came to $22 million there as well.)
It is critical that septic owners take an interest and play an active role in this issue.
Regional Board has provided recent staff reports and pathogen studies on the TMDL at their website.