The second paragraph of the Introduction states that this proposal seeks to determine whether aging septic systems are causing water quality impairments in the lower Russian River in the communities of Monte Rio and Ville Grande. We support the work plan proposal for this purpose. We believe it is still an open question that needs professional exploration through individual septic system inspections by qualified experts who can then determine adequacy before proposed projects are developed. We support targeting all antiquated cesspool systems within 100’ of the river/tributary bank that are not treating septic waste to the required level.
The third paragraph of this section however, indicates that widespread contamination has already been demonstrated by water quality monitoring of bacteria and other indicators of wastewater discharge and poses health hazards to the ecosystem and its visitors. Yet, based on our understanding of the extensive data collected in the last eight years, very few samples taken in the main river during summer indicated E. Coli exceedances (State and EPA regulatory indicator of pathogenic pollution in fresh water) and we don’t believe that the mere presence of bacteria alone establishes the health risk implied. We have concerns that this description is misleading, causing the river to appear as a cesspool of disease-causing organisms, which, given the popularity of its beaches, and the lack of beach closures due to contamination, (but for high visitor use on July 4th holiday last year) hardly seems to be the case. (Note: North Coast Basin Plan still calls for total coliform limits, which is a measure disqualified by EPA several years ago. The State Water Board is expected to adopt the current EPA standard for E. coli sometime next week. It is likely the Regional Board will also adopt the same later this year.)
Most E. Coli indicators showed up in the winter, after major storms, and often appear to come from upstream sources. We question how the substitution of bacterioides, which indicate local human source bacterial levels, can scientifically indicate pathogenic exceedances? We also question whether “widespread contamination” has been adequately demonstrated, as we do not believe that the mere presence of bacterioides proves contamination.
Also, the report needs to differentiate between pathogenic levels found in tributaries and the main stem, as well as seasonal and situational differences. In addition, forest areas have been found to have the least amount of pathogenic contamination, we wonder whether lower river redwood forests have been accounted for in determining the extent and impact of summer pathogens in our area?
And finally, the State Board will make its final decision on adopting the following at their meeting next Tuesday, of which the pertinent section to our work is:
Part 3 of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays and Estuaries of California—Bacteria Provisions and a Water Quality Standards Variance Policy” (Part 3 of the ISWEBE) …. The documents can be found at the State Water Boards Website: http://www.waterboards.ca.gov/bacterialobjectives/.
Within the ISWEBE document, the following segment is included:
“A WATER BOARD may adopt a high flow suspension of the water contact recreation (REC-1) beneficial use that reflects water conditions considered unsafe for the REC-1 beneficial use due to high water flow or velocity. A rain fall measure, flow measure, or other requirements shall be established by the WATER BOARD to describe specific conditions during which the high flow suspension would apply.”
We assume that this provision, were it to be adopted by the Regional Board, indicates that at the time when septic systems are most likely to release pathogens, is the very time when that release could be allowed. The assumption, we presume, is that the force and flow of the water, and the unlikely situation that REC-1 activities are taking place at that time, indicates that public health and safety issues would not be a factor.
2.1 Project Need and Purpose:
The statement describes the housing stock in the lower river, stating that, “…only a few have centralized sewer service.” Supervisor Hopkins recently circulated the following data as background information for the lower river MAC indicating that Guerneville and Rio Nido have combined population of 4777 people, far greater than the 1686 population of Monte Rio/Villa Grande. It might also be mentioned that only the more developed areas of Monte Rio and Villa Grande will be addressed through this program.
Forestville: 3,385 people (12.14 mi2) (some on sewer and some not)
Hacienda: 1,572 people (6.55mi2) (none on sewer)
Guerneville: 2,804 people (6.89 mi2) (mostly if not all sewered)
Rio Nido: 1,973 people (4.73 mi2) (mostly if not all sewered)
Monte Rio/Villa Grande: 1,686 people (9.85 mi2) (none on sewer)
Cazadero: 792 people (8.85 mi2) (none on sewer)
The second paragraph of Section 2.1 speaks of the river segment between Guerneville and Monte Rio as having authorized bacteria TMDL in 2000. Guerneville’s sewer system (Russian River County Sanitation District or RRCSD) had spills and bacterial exceedances for years and may have provided the basis for this listing (pathogenic pollution exceedances), otherwise we wonder why a mostly sewered area would be polluting, unless from tributaries? While more recent evidence of exceedances in Dutch Bill Creek have been identified, we still question the general use of bacterioides for the lower river as an indicator of pathogens. If there is data that indicates extensive E. coli pathogen exceedances in our river reach, we have not seen it.
To be clear, we support inspections and expert determinations that septic systems are functioning properly and meet current standards (or not). The paragraph at the top of page 3 stating that all septics are expected to provide “….adequate removal of pathogenic organisms, comply with the Pathogen TMDL’s Fecal Waste Discharge Prohibition, and ensure that ambient pathogen indicator bacteria concentrations are protective of REC-1 beneficial uses.” These requirements clearly call for ambient pathogen indicator bacteria concentrations that protect REC-1 uses.
As for the goal of protecting REC-1 beneficial uses (bottom of page 3), Work Plan assumes that widespread contamination with bacteria is a threat to the watershed. If the existence of bacteria also indicates widespread pathogenic organisms, we question how river can be as contaminated as described if only one beach closure occurred in the last 8 years in the lower river because of a human health risk? (I believe that 2009 was the most recent year that warnings were posted for bacterial contamination, although I think it was 2014 and 2015 when beaches were posted for cyanobacteria, which was a different situation probably resulting from high phosphorus levels, warm temperatures, and low river flows. In August, 2009, flows were extremely low, getting down to 47 cfs in August.)
This issue has been addressed extensively in the pathogen TMDL documents by Regional Board staff. RRWPC has been concerned all along however about the replacement of a bacteroides standard in light of the lack of E. coli exceedances in the lower river. We don’t know if that substitution is used anywhere else.
Throughout some of this work plan, when project area is mentioned, an impression is given that in each case, there are fully defined projects being considered. It is our understanding that numerous project components were to be considered as part of each project, and that at some point, two of 4 projects, each having a variety of features and designs would be selected by the CAG. We have difficulty picturing how we can get to that stage without some difficulty. We question how the complicated process of organizing multiple varied approaches over the whole study area into one project will be determined until all sites are evaluated and property owners consulted?
If a hookup to RRCSD is one of the two final projects considered, a large area of, if not all contiguous properties would need to be involved, in order for the project to be viable economically. A package of multiple approaches would probably not be possible in combination with that selection Since it is likely that there will be a large number of challenging parcels, we are concerned that the one hookup to RRCSD might become the choice by default (not that some of the very difficult parcels will not also have problems with a central sewer lateral hookup).
It is interesting that major upgrades for RRCSD are currently being contemplated, funding options pursued, a new lateral ordinance is being prepared, making it look as though this may already be a preferred option. It is also an issue that hookup to an existing POTW might be more likely to meet funding eligibility requirements than a multi-system approach using community septic systems. In addition, SCWA staff is more familiar with large systems and may have a predisposition towards that solution. Yet there are environmental benefits to small community systems that may be much more cost effective for home owners and that gives them more control. With an RRCSD hookup, they would be responsible for not only lateral hookup costs, hookup fees, annual operation and maintenance fees, etc., (over $1500 a year now) but also maintenance of the lateral, which in time could become very expensive also. (Would funding sources be willing to finance individual homeowners? More information on this would be helpful.)
We support a program to replace cesspools within 100’ of the riverbank with systems that meet current standards. How we get there is the devil in the details.
In conclusion, we urge that everyone involved have great sensitivity to the hardships some property owners may incur as a result of this process.
Sincerely, Brenda Adelman
PS: One more thing: CAG might consider including a section about environmental challenges for this program in the Monte Rio/Villa Grande area in comparison to other areas with flat geography and no floods. Also, a brief history of the work that has been done so far by the community in attempting to develop sewer for the area over the last 20 years or so would be helpful.