North Coast Regional Water Quality Control Board
Attention: Alydda Mangelsdorf
This comment letter addresses the document entitled Implementation Plan for the Pathogen TMDL (Appendix A of Staff Report). The first 2.5 pages provide a brief summary of the findings in the Staff Report for this project and the rest addresses the implementation plan. Therefore, we request that you consider our comments on the Staff Report submitted on September 29th, as they are pertinent to the first part of the Amendment. We request that our written concerns be responded to for both the TMDL Pathogen Action Plan and the Basin Plan Amendment.
Furthermore, we have some thoughts and perspectives to add that were not included in our original comments, including that there are only vague, non-specific promises proposed regarding enforcement plans. Furthermore, we continue to be bothered by the fact that this Plan does not include actual quantities for either total loadings and/or allocations.
The purpose of the TMDL Action Plan (Staff Report) and the Action Plan to be added as a Basin Plan Amendment, is to address water quality problems in Russian River waters identified as impaired for pathogens, by implementing programs that address the problem. (In the lower river, only the section between Fife Creek in Guerneville and Dutch Bill in Monte Rio are formally listed along with parts of the Laguna). It is unclear whether there is an active intent to designate the entire river as impaired for pathogens at this point. Currently, the main implementation focus appears to be on revising and expanding septic system requirements. RRWPC has studied the documents (along with several of the studies and back up information) and has concerns about the conclusions drawn regarding identification and quantification of pathogenic bacteria, and that some of our prior comments might not have adequately analyzed our concerns. These comments will hopefully clarify our perspective.
Bacteroides role in determining pathogen sources….
RRWPC has the impression that, while EPA allows either E. coli or Enterococcus levels to serve as indicators of pathogenic pollution for fresh water, they appear to prefer the former because Enterococcus readings are stated to sometimes suffer from false positives. We did not see that EPA assigns the same problem to E. coli readings. (We have no disagreement with the level of exceedance.) On the other hand, the State Water Board seems to feel that either indicator is valid for fresh water. Neither of these regulators appear to mention Bacteroides as the necessary arbiter of illness risk assessment.
In fact, in the Peer Review comments on pages 10-11, the subject comes up: (Comment #16) “Even when a specific host appears to be the source of fecal pollution based on host specific markers, fecal coliform levels rarely correspond to Bacteroides levels in affected waters.” The response on the following page states, “Generally, we found no significant relationship between concentrations of culturable fecal indicator bacteria and DNA-based markers….Bacteroides is not used independently as a numeric TMDL target in the Public Review Draft Staff Report as described in more detail in the response to PAH Comments 9 and 10.”
In going to # 9, we note the interesting comment, “A more holistic approach to watershed management is advocated. Where there are bacterial markers of human or bovine waste, there may also be compounds of emerging concern and nutrients.”
The Response states: “….Bacteroides bacteria concentrations were assessed independently of the E. coli data to assess compliance with the natural background objective…..Bacteroides bacteria are recommended…only to assess whether the impairment is from natural, human, or domestic animal sources…..” BUT, while it is true that you establish Bacteroides in greater abundance in areas of denser populations, you never establish whether the Bacteroides are from homeless encampments, treated wastewater discharges either from pond runoff or irrigation over spray, leaky sewer pipes, recreational use during busy weekends, etc. Thereby you cannot conclude that it is a result of failing septic systems.
Furthermore, while Bacteroides indicate the presence of human sourced bacteria that is no more than seven days old, it does not necessarily indicate the presence of pathogens. Most of the summer pathogens in the river appear to be more from recreational use (see Beach Study) rather than failing septic systems. Actually, there are very few E. coli exceedances in the lower river in summer. It has been well documented that most of septic system failures occur during winter rain events when the ground is saturated and the trees don’t need the water.
The great irony of all this, is just days ago, we came across the recent article in the October 6, 2017 issue of Environmental Health News: Science News for Students by Kathryn Hulick, entitled “Good germs lurk in gross places: The secret superpowers of poop,, dog drool and snot.” https://www.sciencenewsforstudents.org/article/good-germs-lurk-gross-places
“Ari Grinspan performs a fecal transplant at Mount Sinai Medical Center in New York City. Here, he injects fecal material directly into a patient’s intestines, or bowels. Some transplants use a tube placed down a person’s throat. Or patients may swallow the fecal material in pills or a special drink.”
“That’s because human feces contain trillions of bacteria. These tiny germs live inside all of us, forming communities called microbiomes….Each microbiome is a miniature ecosystem full of different species. These communities exist on our skin, in our noses and elsewhere, especially in our guts.”
“In many human diseases, the gut microbiome is out of whack. Getting it back to normal might treat or even cure the disease. And one way to do that is to put into the sick person’s intestines a sample of good germs from the feces of a healthy person.”
“Poop isn’t the only disgusting substance with the potential to promote health. A team of researchers in Canada has found that dogs are good for babies’ health-not because they’re cute and lovable, but because they’re dirty. When babies grow up around dog drool, fur and muddy paw prints, they develop healthier gut microbiomes. And a German research team probing people’s noses found a surprise in the microbiome there. It was a brand-new antibiotic. “Snot bad!”
Humor aside, we are not suggesting that you should ignore the control of pathogens in the river, but rather point out the irony that sometimes the bad things we try to control cause us to miss out on some necessary beneficial impacts. Bacteroides consist of mostly beneficial bacteria necessary for health. To use that to indicate a possible pollution problem, while not addressing the question of why, if the river is contaminated with pathogenic bacteria, there aren’t more exceedances of E. coli and Enterococcus seen on a regular basis, appears to be a weakness of this work?
We have laid out many reasons for why the current Action Plan is weak in terms of identifying, controlling, and addressing pollutant sources, priority rankings, loading capacities, load allocations, and seasonal variations. We summarize our concerns:
• There is no safe level beyond which an exceedance is determined for Bacteroides. Yet you use that measure, containing mostly beneficial bacteria, as an indicator of the existence of pathogenic pollution. In your view, not expressed by EPA or State Water Board, even when E. coli and Enterococcus are within a safe range, any finding of Bacteroides can be an indicator of fecal waste, and is therefore out of compliance with the goal of the Plan since pathogens MAY be present, at least as far as septic systems are concerned.
This view is transformed into the goal of the Plan 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.”
• How might you determine with certitude whether a given fecal waste material will cause such contamination, let alone whether it comes from septic systems or homeless encampments, or beach goers, event attendees, wastewater irrigation runoff, point source wastewater spills or discharges, roiling of waters containing upstream pathogens in sediment, etc. All of these are human source contributors and can’t be differentiated in most cases. Is there any way to determine location of specific sources and times of discharge for any of the bacterial pollutants travelling downstream?
• There are few summer exceedances of E. coli most years, and we believe that’s because the lower river contains extensive forestlands, and the giant trees soak up whatever effluent might be seeping out of the older systems. (We do not advocate allowing failing systems to continue without remedy; we just want you to consider the probable reason as to why you don’t see much pollution in the lower river in summer. Your own documents all state that most of the pathogenic exceedances from septic systems occur during heavy rains when the ground is saturated in winter, and we add that it’s also the time when the trees have little need for the water.) Certainly a parcel of any size having huge trees nearby, should be treated differently than a parcel with none.
• As for Enterococcus exceedances, those frequently occur during very low flows, such as in 2009. That was a year when early signs of toxic algae were first noticed as well. The Staff Report on the TMDL Action Plan comments on the frequency of beach notices, but what they fail to mention is that there were very few closures and some were not even for pathogenic pollution, but for excessive algae (cyanobacteria). Most of the notices were warning of potential problems. The only total closure I remember for pathogens, was this year when too many people came to Monte Rio for July 4th weekend and a few days later it was discovered that pathogen levels were excessive and the beach was closed for about 3 days.
• We would also like to request that you address the condition whereby exceedances are very sporatic, or where half the summer season has no exceedances and the other half have some. Nowhere did we see the situation where exceedances occur occasionally and not regularly. Wouldn’t the latter be expected where a septic system is not functioning properly?
• The Amendment devotes many pages to a program attempting to control septic systems within 600’ of the river, but few specifics are mentioned for things like the need for porta-potty stops for canoeists and kayakers and homeless, effective best management practices for agricultural and landscape wastewater irrigators, and elaborate septic systems for homes that may or may not be affordable.
Concerns about irrigation runoff….
This is the topic that RRWPC is most familiar with among those mentioned as contributing pathogens to the river. We have written many comment letters on the Recycled Water Policy, the Amendment to the Policy, the Basin Plan Amendment in the North Coast Basin Plan on agricultural and urban irrigation controls, etc. We attached our comments on Santa Rosa’s November, 2013, Revised Reclamation Permit to our recent comments on the Draft Report on the Pathogen TMDL. We didn’t clearly explain our reason for doing this and would like to do so here.