RRWPC Comments (October 26, 2021) on: Lok Guernewood Park Development Co.,
Permit Sonoma File No. PLP18-0012
For Public Hearing by Board of Zoning Adjustments (BZA) on October 28, 2021
RRWPC came into being in 1978 as a result of concerns about the initial planning and construction of the Russian River County Sanitation District (RRCSD). We commented on the many issues that arose during construction. We initiated three successful citizen propositions attempting to change certain aspects of the project. And we have tracked the project, and its many evolutions, ever since.
RRCSD went on line in 1983 and has had many challenges ever since. In the last 7-8 years the collection system has shown signs of significant wear and tear and some officials have informally estimated that repairs
to the force main alone may run as high as $8M, which the community cannot afford. (This estimate may be too low as other repairs are needed and cost overruns are typical with such projects. RRCSD more than doubled in cost during the course of construction.)
Initially we were not intending to submit comments on this project because at the time of the notice, I was recovering from a painful and limiting broken shoulder resulting from a bad fall. At a recent RRWPC Board meeting we discussed the extensive and justified community concern (sewer issues were mentioned by many), and the potential harmful impacts from this project to the Russian River County Sanitation District (RRCSD) collection system, and it was decided that we should report about the serious limitations of the system as we were aware of them.
Our goal with this letter is to call attention to serious problems with the collection system, the need for major rehabilitation of pump stations and major pipelines, etc., and why we believe that potential impacts need to be addressed by the Initial Study for the Lok Resort Project. We have great concerns about violations of RRCSD’s NPDES Permit noted by the Regional Water Quality Control Board (Regional Board) in a letter written in April of this year to operators, Sonoma County Water Agency. We are concerned that circumstances may be exacerbated as a result of this project. We are particularly concerned because of the size of this Resort Project, the potential addition of large amounts of raw sewage, and the fact that the site is only about half a mile up from the main pump station, where some of the worst problems occur. We are unhappy that there was no analysis of the amount of sewage that would be generated until AFTER the project is approved and during the sewer permit process. In fact, there was no environmental analysis of pipeline installation. How many redwood trees have to be cut because of the sewer? Will tree cutting needed for putting pipeline in be in addition to the 75 trees to be removed?
RRWPC’s most recent Board meeting took place the week before comments were due. On Friday I began to gather documents on the Planning record about the sewer, but it appeared at first there was nothing. I talked to personnel at the North Coast Regional Water Quality Control Board (Regional Board) and no one I spoke with had submitted anything. I talked to the person at Sonoma Water who deals regularly with RRCSD and he told me they conveyed the information that there was capacity for the project, but there was no discussion or report on possible impacts, nor even a statement of their having looked into it. The day before comments were due on October 26th, a Planning staff person sent me a link to a different version of the Initial Study, and it included a two page generic document from Sonoma Water giving requirements for obtaining a hookup permit but no analysis of environmental impacts. In all, I found no other record of information on the RRCSD nor any discussion of what environmental impacts the project would generate.
Brief History of RRCSD and Sanitary Sewer Overflows….
The Russian River County Sanitation District watershed consists of 2700 acres and covers Rio Nido, Guerneville, Guernewood Park, and Vacation Beach areas. There are approximately 3200 equivalent single family dwellings (esd’s) with each home being one esd and business esd’s apportioned according to use. For instance, the new four story Health Center will only need about 7 esd’s. (It might increase slightly.)
The RRCSD is mostly a gravity fed system having 11 pump (lift) stations that move raw sewage from two sides of the river starting at Rio Nido north of the river and the end of Drake Road south of the river. The Drake Road segment of the pipe crosses the Guerneville Bridge and heads north over the river where it joins the pipeline with all the sewage from Rio Nido and properties in the district north of there. It then travels down Hwy 116 to the main pump station, crossing the river passing near Vacation Beach Pump Station and then to the treatment facility at the end of Neeley Road. (These are main sewer lines.)
There is a separate pipe that travels down Neeley Road and meets the pipeline from the other side of the river near the Vacation Beach lift station, the last lift station before sewage arrives at the Guerneville Treatment Plant about a mile or so further down Neeley Road at the end of the street. The hotel project site is about a mile west of Guerneville on Hwy.116. The main pump station receives waste from Drake Rd. and all the district properties north of Hwy 116 west of town and also River Road east of town to Rio Nido. The resort is about one mile west of Guerneville and the Main Pump station is about another half mile or so west of that. There are five miles of pressurized force main, six miles of lower flood plain (sewer service laterals) and eleven pump stations located throughout the system.
Original Construction nightmares abounded….
We could spend pages telling stories about the years of original construction between 1978 and 1983 (Fifth District Supervisor Ernie Carpenter could write a book on it.) but that’s not our purpose here. The main point to make is that construction was way over bid and the County had trouble finding contractors to do the work with the funds available. I’m fairly certain I remember that they had to go through at least two bidding processes and then ended up with thirty change orders to pay for many unanticipated needs. The contractor ended up suing the County and I think maybe the engineer as well. I know they ended up with new engineers and contractors and had to correct some of the work that had already been completed.
The EPA and the State issued grants for 75% of the project and ended up claiming back a part of it because they believed the system should be sized for summer flows and didn’t acknowledge winter floods for sizing capacity. It was a royal mess! So it would be no surprise if we learned that the original project may have been made with inferior supplies in order to cut costs. (We learned that the pump stations were definitely inferior when built.)
In the “Attachment B to April 14, 2021 Notice of Violation: Collection System Compliance Evaluation Inspection Report” Sonoma Water engineer, George Lincoln stated, when describing his concerns about the pipes, “….his primary worry is possibly losing a force main or experiencing a catastrophic event. He is less worried about the smaller force mains, but the 16-inch force main running from the main lift station to the plant is a concern due to the material. He said it is a cement mortar-lined steel pipe, but not as thick as traditional C200 (steel) pipe.” The 2017 Inspection notes of the collection system stated that the “Lift stations are past their useful life spans.”
In 2014, there was a serious accidental pipe break (16” pipe) near the Vacation Beach Pump Station causing 100,000 gallons to spill into the Russian River. This is also the same general area where a surging manhole leaked raw sewage and was part of 3.2 million gallon spills during the flood of February 26, 2019. In 2014, the 16” underground pipe had ruptured sending untreated sewage to the surface, after which it travelled towards and into the river 40 yards away near Orchard Road in Vacation Beach.
It turns out that Water Agency personnel got rid of the water on the street by diverting it into a neighbor’s yard, where it traveled downhill to a creek that was a tributary of the Russian River. All the wastewater ended up in the river but they had reported only half of the water that ended up in the river (half in the back yard). Regional Board staff discovered this ‘mistake’ during an inspection of the area near the Vacation Beach pump station and it became part of penalty negotiations on the spill.
County Water Agency staff claimed the aging system was causing most of the problems. The system is now 37 years old; problems were noted 7 years ago and most sewer systems last about 50 years or more, when properly constructed. But we also observe that ours is located in a much more difficult environment (Santa Rosa has five pump stations for their 40 mile climb to the Geysers Steam Fields and RRCSD has 11. But Santa Rosa has only numerous small creeks to contend with and not a raging river in winter. (Even during normal winters, the RRCSD infrastructure gets a good workout.) Luckily much of our area empties out of people during winter, or things could be much worse.
(Note: We wonder how the hotel facility could be used for emergency housing in winter during flood periods when the outside ground is flooded and visitors would probably need to be evacuated so as not to further impact sewage flows? What happens with guests when the water gets turned off because of contamination concerns.) Have operation plans been developed for inclement weather and natural disasters?
In any case, the important thing to emphasize is that we have a very vulnerable system that exceeds the 3.5 million gallon treatment plant capacity easily during floods and pipes are often used for storage so that all wastewater can be treated before discharge. When the river exceeds the 40 foot level, that’s when things start to break down. The February 15, 2014 copy of the Press Democrat in the article “Sewage spill’s aftermath” by Derek Moore, states, “….spill appears to be the largest since 1999, when 100,000 gallons of raw sewage flowed into the river over five days as the result of employee error at a small pumping station.
That same year, more than a million gallons of partially treated wastewater flowed into the river during three days of flooding, when high water inundated the treatment plant near Guerneville. And in 2010, about 300,000 gallons of treated wastewater spilled into the river.”
Local mom helps bring sewage surcharging to attention of officials….
In mid-March I got an email from Esa Parr Day, a mother with three children and currently chair of our local Russian River Recreation and Park Department. I had known Esa for many years. Her father had been on our Board of Directors for a long time.
Anyway, Esa and her family live right across from the Vacation Beach children’s park and Vacation Beach Pump Station. Her daughter loved the park right across from her house, but it became unusable after the late February, 2019, spill after the major flood. Esa had been in touch with several of the agencies and felt she was given the run around. While Sonoma Water did eventually clean it up, it was still not clean enough for a small child to play.
Together Esa and I and others had put together public information on the spill; we advocated for steps to be taken to improve public notice of periodic spills. (There had also been a flood in 2017 and other times before.) Esa and her husband and some neighbors had taken many pictures of the 2019 event and documented what happened over those days and the time each photo was taken. They put together a notebook of the event. (Sonoma Water staff had said that the spilled sewage was highly diluted and you couldn’t see toilet paper and turds, but if you go to www.rrwpc.org on the Home Page, you will see the picture and others taken by Esa and friends.)
We attended several Regional Board meetings and met with County Supervisor Hopkins and lead staff from Sonoma County Water Agency about this issue. But we didn’t feel that staff was moving very fast with meaningful action, so in June, 2019, RRWPC submitted a formal complaint asking for the County to take action to fix the problem. (Copy of Complaint can be found on RRWPC website under North Coast Regional Water Quality Control Board/West County Wastewater and also other documents on this issue.) You can also read March, September, and November newsletters from 2019, for more information on the spill.
Notice of Violations (April 14, 2021)…..
It took two years-worth of pleading, but the Regional Board came out with an impressive list of violations of the Treatment Plant and collection system. We will put several key documents on our website, but here are a few of the violations on the list:
- RRCSD and Sonoma Water discharged approximately 2.3 million gallons of partially or untreated wastewater to Waters of the United States on…..January 9 & 11, 2017, February 7, 2017, and February 14 and 26, 2019
- RRCSD and Sonoma Water failed to allocate adequate resources for the operation, maintenance, and repair of its sanitary sewer system…..
- RRCSD 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, etc…..
- RRCSD and Sonoma Water failed to provide adequate capacity to convey base flows and peak flows, including flows related to wet weather events….
- RRCSD and Sonoma Water did not properly report SSOs……
The Regional Board has identified the conditions that Sonoma Water needs to accomplish. We don’t know if the timing is right, but it would be very beneficial if some of these could be integrated into the Lok Resort Project permit and if part of the process would involve the developer conveying how the project might address some of these issues regarding their site. In any case, we would like to see some of these addressed in light of whatever amount of sewage the project would be adding to the system. And also 16” pipeline capacity should be determined BEFORE the permit is given. (We understand that a new analysis will take place.)
Sonoma Water tried to make the case that the fault should lie with flood circumstances and the lack of adequate funds available to manage the system. One concern we have about this process is the amount of the penalty is decided in secret. Also, supposedly if the Water Agency agrees to the penalty they can use half of it to do a project that benefits the river. It used to be required that money be used to fix some component of the sewer system. They changed it so that any established organization can apply for the funds available for a river environmental project. RRWPC believes strongly that the funds should go for fixing some of the identified problems in RRCSD. Under the circumstance where they are penalized for not having money to fix the system, the penalty funds should be used for just that, not something else that fosters continued violations and penalties on the system while allowing some other entity to benefit.
Eventually we will learn what penalty is decided on and that might drive the amount of work that can be done. We urge you to read this short document (Notice of Violations and Compliance Evaluation Inspection Report as they lay out the problems with the system in clear language.) When the Water Agency claims there is not enough money to make upgrades, they up our fees every year 4% to 6%. Ratepayers are now paying $1,794 a year. There are about 3200 units in the entire system and that would come to $5.5 million. Have there been audits of how they spend this money? I know they share staff, equipment, motor vehicles and trucks with other sewer systems (Sonoma Water manages eight county wastewater systems.)
We will keep tracking this issue. As for the Resort Project, we think there should be a substantial fee charged by the County that is added to the hookup fee and that mitigates for adding so much wastewater pressure to the system in a location that can least handle it. It would be wise to use toward new, badly needed infrastructure. We think this should be paid and esd’s determined BEFORE any permits are issued along with a capacity analysis of the 16” force main pipe.
I don’t know how many trees were lost in the fire in Armstrong Park, but I suggest that replacement trees for the ones taken off the Resort Property should be replaced in Armstrong at a 3 to 1 basis. (This is my personal idea and I know that a lot of others would need to sign off on it.) Also we want to know if additional trees will be removed (beyond the 75 acknowledged) in order to lay the sewer and water pipes? How many, and what size trees?
Finally, we agree with all others who feel this project is just too large. If possible, diminish it as much as possible.
Brenda Adelman for RRWPC Board