Pathogen TMDL: Guerneville meeting coming up soon!
Two regulatory actions currently proposed by the Regional Water Quality Control Board will soon have a significant impact on the lives of many river property owners: they are the Russian River Watershed Pathogen Total Maximum Daily Load (TMDL) Action Plan (Action Plan) and the Basin Plan Amendment.
The goal of the Plan is expressed as follows: “Discharges containing fecal waste material from humans or domestic animals to waters of the state within the Russian River Watershed that cause or contribute to an exceedance of the bacteria water quality objectives not otherwise authorized by discharge requirements or other order or action of the Regional or State Water Board are prohibited.”
The main intent is to protect the human health of those in direct contact with river water such as swimmers, waders, etc. and to avoid beach closures resulting from excessive pathogen levels. While we support the intent, the task of the TMDL is to analyze the extent of pollution, who contributors and how much, and then allocate ‘loading’ limits that each ‘polluter’ can legally contribute. Yet we question whether Action Plan’s evidence clearly indicates sources of pathogen pollution. Much remains to be done regarding Plan implementation, and many issues resolved before full implementation can occur.
Action Plan to address antiquated cesspools and failing septic systems….
While there is evidence that would allow someone to question whether the actual pathogenic condition of the river is as bad as surmised by the Plan, it is still important that antiquated septic systems that have not been inspected or upgraded for many decades and are situated within 600’ of the river or a major tributary, be assessed. This is necessary to help assure sustained pathogen-free river water quality for recreation, drinking water, and aquatic life, and to prevent potential invasion and spread of pathogenic bacteria, viruses, etc. Furthermore, the growing number of antibiotic resistant strains, and reluctance of pharmaceutical companies to develop new drugs to address the need, makes this situation critical.
There is a very important meeting coming up soon during which Regional Board staff will present and explain proposed Plan and new requirements on Wednesday, September 20, 2017, at the Guerneville Vets Building at 16225 1st St. in Guerneville between 5:30 and 8:00 pm. We urge you to attend. Comments and questions from the audience will be allowed. (We recommend you review 41-page easy-to-read Action Plan Presentation posted at RRWPC’s website. www.rrwpc.org )
Written comments and questions on the Plan may be submitted by email to Alydda Mangelsdorf at NorthCoast@waterboards.ca.gov through Sept. 29th, faxed to (707) 523-0135, or mailed to California Regional Water Quality Control Board, ATTN: Alydda Mangelsdorf, 5550 Skylane Blvd. Suite A, Santa Rosa, CA 95403. Documents can be obtained at http://www.waterboards.ca.gov/northcoast/water_issues/ it is important to write “TMDL Action Plan” in your heading.
Who is affected?
Specific requirements for septic systems have not been developed as yet; the County Well & Septic division will work out a detailed plan which will be implemented by their office in cooperation with the North Coast Regional Board and Community Development Commission. There is an integrated map on the web where people can go to identify their property and determine if they will be affected, but we have heard mixed reports about the accuracies of the map. Contact staff if you have problems as I think they are working on it. Those of you who own property within 600’ of the top of the riverbank and have a septic system on your property, would be informed as to the problems and potential remedies after a survey is completed. Those on sewer in the 600’ area could have their private laterals inspected, since property owners are responsible for upkeep of lateral pipelines hooking to main sewer lines. Thus far we have been unable to learn what is planned for those on sewer, but we suspect that they are concerned about degraded private laterals in the flood plain. (They listed Guerneville and Rio Nido as contributing to pathogen pollution in river and we don’t know why.)
What will they do about implementation of the Plan ?
The Plan lays out timelines and actions for many dischargers. For the onsite wastewater treatment systems (OWTS), there will be an Advanced Protection Management Program (APMP) established as required by the Plan. This will be organized by the County and Regional Board and will delineate geographic area of APMP. It will also develop minimum requirements or special provisions for entity. A specific map of properties within 600 linear feet from top of bank in horizontal direction on either side of entire Russian River main stem is being developed and will include tributary watersheds where there are more than 50 parcels per square mile. Parcels not in boundary do not need to comply with requirements. Local creeks in West County requiring remediation include: Dutch Bill, Green Valley, Laguna, Santa Rosa, Mark West, and Windsor Creeks.
Septic systems not only source of pathogens ….
The Action Plan identifies several other contributing sources of pollution to the river, including homeless encampments, wastewater discharges from treatment plants, wastewater runoff from landscape and agricultural irrigation, recreational water uses, urban runoff, etc. In most situations, it is difficult, if not impossible, to discern various recreation sources of human bacteria (some use river as a toilet unfortunately) from that found near homeless encampments and septic systems. And pathogens can be stored in the sediments and stirred up and released by river recreational activities also. So, while RRWPC agrees that it’s important to identify and improve failing and antiquated septic systems, we are not certain about the scope of the problem in that case, especially since septic systems generally fail in the winter during heavy rain and may not be contributing extensively to summer pollutant loadings.
For example, page 4-7 of the Action Plan indicates that of 52, 30-day sample periods taken for E. coli bacteria between 2001 and 2013 in summer (12 years of data), at Steelhead Beach, only 1 period was out of compliance (2%). None were out of compliance at Hacienda Bridge, Johnson’s Beach, Casini Ranch Campground and Dutch Bill Creek during that time. At Monte Rio, with the highest count, 5 of 61 sample periods were out of compliance with current regulations (8.2% of samples). At Duncans Mills, immediately downstream of Casini’s, there was one period not in compliance out of 12 periods studied (8.3%). If failing septics are a contribute bacterial contamination to the river in summer, why are these numbers so low? (Most instances of pathogen exceedance were for enterococcus and not E. coli, but most of the time beaches remained open and warning signs went up, which indicates that the exceedances were not very large.)
This information raises some observations and questions:
• Most exceedances seem to occur at beaches populated by many people. Many beaches generally have no exceedances even when surrounded by residences with septic systems. Could it be that septic systems are not causing exceedances?
• Most exceedances are less than 10% of the total samples documented. Does that justify labeling entire river as impaired for bacterial pollution?
• Regional Board studies assert that most bacteriological contamination occurs during wet weather. How can it be assumed that failing septic systems cause bacterial contamination during summer?
This program is important and failing septics should be improved, but we want a fair and valid analysis of the scope of the problem. Please contact Charles Reed at Regional Board with questions: (707) 576-2752 or Charles.Reed@waterboards.ca.gov and plan to attend meeting on September 20th noted above.
RRWPC needs your continued support….
Because RRWPC is a small group that depends exclusively on mailers for the funds to continue our river protection work, we request your support in each mailer, yet don’t expect a response every time. We include the month and year of your most recent donation on the outer envelope. We especially hope to hear from those who have not given recently, although all donations are welcome. PayPal is set up on our website at www.rrwpc.org for those who prefer that mode of contribution. We are extremely grateful for your support.
This letter is a revised version of one mailed to RRWPC list on Sept. 11, 2017.