RRWPC Newsletter, April 2021: Drought, Septic Systems & Sewage Violations

Spring is here and things are popping….
After a very slow winter, things are popping now. Life has gotten busy, and things are ‘a changing…’ In order to keep you informed, we are making this letter a four pager. Drop us a note and share your thoughts with us.
It’s a bad one…..
As if we needed something else to worry about, we now face serious drought that may be the worst since that of 1976-77. It seems strange however, that drought has only been declared for our area. At a news conference on April 21st, when asked whether there would be statewide mandates called for to address water shortages,

Governor Newsom claimed that conditions vary across California and for now, drought would only be called for Sonoma and Mendocino Counties. It is also strange that his declaration did not include Marin, which is also dependent on Russian River water for a significant amount of its supply. And his drought declaration for our area included no conservation goals.
While the situation is complicated, we can’t help but wonder if the Potter Valley Project, with Eel River transfers substantially diminished, and PGE pulling away from responsibility for the facility, and while others are trying to go through the elaborate and difficult process of taking charge through the re-permitting process, it may take years to resolve. In the meantime, fishery groups are fighting to eliminate the dam, which they say is blocking many miles of fishery habitat and will possibly destruct in a major earthquake. There are many high powered interests involved in this highly controversial situation, including eight county administrations, (some for and some against maintaining the facility), Native American tribes, agricultural interests, large fishery groups, Congressman Huffman, Army Corps of Engineers, Federal Energy Regulatory Commission (FERC), National Marine Fisheries Service, Sonoma County Water Agency, State officials, and property owners up and down the river. Needless to say, potential costs to the economy are huge. RRWPC has been tracking this issue from the sidelines.
Many drought signs on lower river…
Yesterday’s flows at Hacienda Bridge on April 23rd, were measured at a mere 81 cubic feet per second (cfs). Since 2004, and probably prior to that, the river hasn’t been that low before mid-June at the earliest, and that’s two months from now. Last year at this time the river was running at 294 cfs. About one inch of rain is predicted this week, and it would not come as a surprise if no more rain falls for the rest of the season. This may sadly be the year when, through deprivation, we learn to treasure our waterways even more than we have up to now. What would it be like to really run out of water?
Sonoma County Water Agency (SCWA) reports that Santa Rosa rainfall is 39% of normal (13” of rainfall so far compared to seasonal average of 36”). Lake Sonoma water supply capacity is now at 62% and Lake Mendocino is 37%. By comparison, last year at this time Lake Sonoma was at 88.5% and Lake Mendocino at 71%. (On 10-1-77 storage on North Coast was 18% of capacity.) We have about six months of spring and summer left this year with Lake Mendocino at 37%, needing to serve about 2/3 of the Russian River (to Dry Creek confluence downstream of Healdsburg) in both Mendocino and Sonoma Counties for the entire summer. If the State Water Board labels this a critical dry year, and chances have seldom been more likely, flows may go as low as 35 cfs. (Dry year is 85 cfs.)
Whatever happens, flows will be very low this year, and conditions will be ripe for large algae blooms. Since it’s difficult to distinguish toxic algae from non-toxic, it’s best if children, pets, and even adults stay out of the water under those conditions, especially during and right after holiday weekends. Dogs are particularly sensitive to that toxin. By the way, some of you alerted us to a new bloom covering much of the lower river last summer. We checked into it and was told by an expert that it is called Azolla and is a benign aquatic plant. At this point that is all we know but we will keep asking around.
Lake Sonoma water supply is now around 62%, which is about 2/3 full, and represents almost a 2 years supply. It is unlikely however, that SCWA will be very free with that water, as they will be mindful of saving it for urban contractors during a possible third year of drought. Also, they will be required to time releases that support fish migration in Dry Creek and lower Russian around October. The National Marine Fishery Service (NMFS) is responsible for implementing the Biological Opinion, which protects salmonid species under the Endangered Species Act. They too have a very influential voice in what flows are released into the river.
So the important word now is conservation, conservation, conservation. Please don’t leave water running anywhere unnecessarily. Be thoughtful about taking shorter showers, minimize plant and garden watering, turn faucet off when brushing teeth and washing hands, etc. You know what to do; it’s a matter of remembering. It’s not just potable water that’s in short supply, it’s recycled water as well (treated wastewater). Let’s all treat water as though it’s the most important feature of our home, as it now is.
Russian River County Sanitation District in need of major repairs….
In past newsletters, we have devoted a lot of space to discussion of the need for repair of major infrastructure at the Russian River County Sanitation District. (RRCSD) You will recall that during the February, 2019, big flood in Guerneville, over one million gallons of RAW sewage spewed on the streets in the Vacation Beach area and even across the River at the Main Pump Station. People in the area were walking through turds and toilet paper near the pump station (See photos on our website www.rrwpc.org )
Along with a local citizen, Esa Parr Day, RRWPC filed a complaint (June, 2019) about the problem to the North Coast Regional Water Quality Control Board (Regional Board for short). Until recently, and for almost two years, every time we asked about the complaint and what action will be taken, we were told that staff was preparing an Administrative Civil Liability (ACL) which is a step in the penalty phase. In other words, they were telling us that they were taking action and not just putting us off.
In the meantime, the five year review of RRCSD’s discharge permit came up and we were in the process of studying the document and writing comments. The day before comments were due, the staff person asked if we would be submitting comments and we replied in the affirmative. (A big portion of our comments, focuses on the spills and major problems with the summer irrigation, which partially occurs on two Silver property sites, and is now slated for timber harvest.) Twenty minutes after we submitted our comments, the Regional Board released the Notice of Violations described below. We are guessing that they didn’t want to make the violations part of the permit process, which we would have done. Nevertheless, not knowing this would happen, we had raised several of the key issues in our comment letter anyway.
Notice of Violations of Statewide General Waste Discharge Requirements….
This five page document dated April 14, 2021, discloses a variety of violations that we probably never would have known about if not for State and Regional Board staff inspection of the facility and a detailed list of violations that were also responsive to our complaint. The inspection was in response to extensive overflows in the collection system in both 2017 and 2019. There was also an history of other break downs and a prior Administrative Civil Liability Order from 2016 that had not been fulfilled. Whether they would have conducted the inspection and wrote up the list without our complaint is conjecture. They found and named so many violations that we will just report on the most significant ones.
“Russian River CSD and Sonoma Water discharged approximately 2.3 million gallons of partially or untreated wastewater to Waters of the United States on multiple dates including January 9 and 11, 2017, and February 14 and 26, 2019…..”
“Russian River CSD and Sonoma Water failed to appropriately respond to these SSOs by failing to recover as much of the wastewater discharged as possible for proper disposal….”
“Russian River CSD and Sonoma Water failed to allocate adequate resources for the operation, maintenance, and repair of its sanitary sewer system…..” (Our sewer fee on October, 2021, property bill will be $1,774. Occidental is the only county sanitation district that pays more.)
“Russian River CSD and Sonoma Water failed to properly manage operate and maintain parts of the collection system resulting in the surcharge of manholes and a lift station, pump stations nearing the end of their useful lives, lift stations being out of service for an extended period of time, and the presence of fats, oils, and grease in at least one wet well…..”
“Russian River CSD and Sonoma Water failed to provide adequate capacity to convey base flows and peak flows, including flows related to wet weather events…..”
(Four more items follow this prior one and then….)
“Russian River CSD and Sonoma Water did not include in its Overflow Emergency Response Plan….an adequate program to ensure an appropriate response to all overflows, such as procedures for recovering SSOs, nor a program to ensure that all reasonable steps are taken to contain and prevent the discharge of untreated and partially treated wastewater to waters of the United States and to minimize or correct any adverse impacts on the environment resulting from SSOs….”(SSOs are Sanitary Sewer Overflows)
Then finally, “For discharges of waste to waters of the United States, California Water Code section 13385 authorizes the imposition of administrative civil liability in an amount not to exceed $10,000 per each day of violation and $10.00 per gallon of waste over 1,000 gallons discharged and not cleaned up.” (Recall there was 2.3 million gallons discharged, most of which was not cleaned up until days after the spill. That could come to $23 million dollars, not counting the daily penalty which goes back 4 years.) Of course the penalty won’t go that high, but there may be a substantial penalty, all things considered. Yet they could put more effort into obtaining low cost loans and grants. They do it all the time for water projects.
What is not being mentioned in all this is that Sonoma County Water Agency had committed to the Regional Board that they would commission a study to analyze the parts of the system that have been causing the most problems, such as the lift stations and the force mains (includes pipe under river that transports waste from north side of river to treatment plant to the south). But in the Spring 2021 Report to ratepayers sent out in March, it stated that in order to keep rates at a minimum, they would defer maintenance where possible and delay studies and capital improvement projects.

Then after all this….
The Citizens Advisory Group (CAG), Sonoma County Water Agency, County administration and Planning Department, District 5 Supervisorial staff, and Regional Board staff will move forward on a plan to either repair or replace Monte Rio and Villa Grande septic systems so that they could meet new guidelines required by the Regional Board. They may also consider an option of hooking all systems to Guerneville with a pipeline that might traverse the new Monte Rio bridge now on the planning board. Or they can have some kind of combination. The job of the consultants will be to produce a menu of possible remedies that as complete as possible.
Furthermore, SCWA had just received notice that they were granted $500,000 from the State for doing the assessment for such a plan. It was roughly estimated (an off the cuff estimate by one county official) that such an expansion could cost $100 to $200 million to address lower river hookups (Are they thinking of hooking the entire lower river to Guerneville?) With all the spill problems we are having and the desire to address river pathogens, it is conceivable that our current problems would transform into something much more difficult if Camp Meeker, Occidental, and all the houses in between, including other small enclaves along the river, were hooked up to RRCSD.
Furthermore, the Water Agency staff person present admitted they are pushing septic to sewer as we strongly suspected, we assume because hookups to a central wastewater facility is easier to fund and manage than septic upgrades would be. The group has had many discussions over the last three years at monthly meetings about what entity would manage the system. We believe that Water Agency would welcome an expansion of RRCSD hookups, but we surmise that managing and inspecting septic systems is probably not their ‘cup of tea’.
RRWPC Comments on Revisions to RRCSD Discharge Permit….
In the midst of all this, RRCSD Discharge Permit review was taking place and RRWPC submitted eleven pages of comments. (on website side bar near top) Some of our most significant concerns regarded the irrigation fields on the Silver Property. (Those comments are also on the website.) The sewer system has inadequate storage and summer irrigation area to run the system properly, let alone nothing for new hookups. The treatment plant was originally intended to process 710,000 gallons a day, but until they expand those two elements, their daily capacity is limited to 510,000 gallons per day. Due to environmental constraints, component expansion will not be easy to accomplish, will require a public review process, and will cost a great deal of money.
Can you help us spread the word…..?
RRWPC would like to get this letter out to as many people as possible, especially in the West County affected area. Do you know someone who might like to receive a copy? If so, can you copy and mail it to them and ask them to send us a note or email us to get on our list? Or, you can send me an email and I could send an electronic version. Or third, you can go on our website and copy it there electronically. (You will find it on the home page.) This information should be especially important to anyone who owns a property with a septic system or is located in a county sewer district. Please help if you can.
RRWPC needs your continued support!
RRWPC requests your continued support to sustain our river protection work. For those who have not donated recently, we appreciate any donation so that we know you remain interested in receiving our mailers and supporting our work. RRWPC relies exclusively on six (or fewer) mailers a year for our entire fiscal support. You may contribute via check by mail to address above, or PayPal at our website. Thank you for your support.

By comparison, on Oct. 1, 1975, storage on the North Coast was 90% of capacity, On Oct. 1, 1976, storage was about 80%, and on Oct. 1, 1977, about 18%, an historical low.