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Water Supply needs prioritized over clean water…..
Increased State approved recycled wastewater may run off into city streets next summer as regulatory oversight is about to become less rigorous, reflecting strong pressures to increase wastewater reuse to stretch the summer potable water supplies. The goal is to offset California’s potable water use by 2.5 million acre feet (about 812 billion gallons) with irrigated wastewater by the year 2030. The practice is not limited to urban areas, as emphasis on irrigated wastewater expansion is aimed at agriculture as well.
A few years ago the Regional Board legitimized most summer irrigation runoff through a Basin Plan Amendment. They referred to the allowed runoff as ‘incidental’ and defined it as irregular incidents that were not due to negligence, such as an occasional broken sprinkler head. Yet numerous runoff incidents were observed and photographed since then showing wastewater going into the drainage system. (See March, 2012 issue of Gazette on Page 1.)
When these repeated and non-incidental incidents were reported to authorities, citizens were informed that further proof was necessary to actually show the runoff entering the waterway (as opposed to going down the drain), a virtually impossible task. Since the runoff was witnessed on four different occasions in less than a month, by definition it should have been treated as a Basin Plan violation. (Attached picture of ponded wastewater accessible to children, located across the street from Santa Rosa’s Utility Department, and photographed on about six different occasions over the last eight months.) We are concerned not only for the wastewater runoff, but also the applied endocrine disrupting pesticides and herbicides that come with it.
Abbreviations used below: TMDL- total maximum daily load; TDS-total dissolved salts; CEC’s-constituents of emerging concern
August 17, 2012
Russian River Watershed Protection Committee has numerous concerns about the Santa Rosa Plain Subbasin Salt and Nutrient Management Plan, referred to here as “The Plan”. We strongly believe that this Plan whitewashes the anticipated impacts of significantly increased wastewater applications to urban and rural landscapes in summer months.
Furthermore, it avoids looking at the serious implications for surface wastewater runoff at a time when many creeks are either very dry, or contain very low flows. The nutrients will impact the creeks before affecting the ground water. It is absurd that nutrient impacts on the surface water are not being studied as part of this Plan, especially since the waterway is so highly impaired for those pollutants.
While the explanation given is that surface water impairments are being studied through another process (TMDL); that process appears to have been stalled, perhaps waiting for the irrigation projects to be imbedded so as to come in after the fact. Water quality issues in the Laguna have been sliced and diced many different ways, so that the left hand doesn’t know what the right is doing. Without an integrated process, the measures needed to fix the problems will not be effective. These problems have been greatly exacerbated since I started work on these issues, 27 years ago. Many plans have been written and many inadequate attempts to fix the problem, all to no avail. I include recent photos of the Laguna taken at the Occidental Bridge near Sanford Road which speak for themselves. It is clear that the Laguna is choked with Ludwigia and other excessive vegetation.
Additionally, the Plan avoids discussing the serious impacts from low dose exposures to endocrine disrupting chemicals of both humans and wildlife and avoids looking at phosphorus as another problematic nutrient. In fact, it doesn’t even study the problem with ‘blue baby’ syndrome in the study area. Have such problems been reported? Have local health agencies and hospitals been consulted about that?
This draft document is a plan to manage salt (total dissolved solids) and nutrient (nitrate) impacts to groundwater resulting from the anticipated increased use of wastewater to irrigate lands in the Laguna watershed. It is supposedly also intended to examine all sources of these pollutants and others in so far as they create groundwater pollution in the designated project area. Santa Rosa is in charge of developing the Plan, but has a vested interest in minimizing the impacts of nutrients in their wastewater that have been harming the environment for the entire time they have been discharging into the Laguna. Yet they failed to address the possible accumulation that occurred over all those high discharge years.
Mr. Matt St. John: Executive Officer
Mr. Charles Reed
North Coast Regional Board
5550 Skylane Blvd. #A
Santa Rosa, CA 95403
July 26, 2012
Dear Mr. St. John and Mr. Reed:
RRWPC is an interested party in the Nutrient Offset Policy for the City of Santa Rosa. (RESOLUTION NO. R1-2008-0061)
Russian River Watershed Protection Committee (RRWPC) is a nonprofit public benefit corporation that has been tracking water quality issues for the last 30 years on behalf of the lower Russian River community. During those years, RRWPC has appeared before the Regional Board innumerable times to provide testimony on a multitude of issues. Of late, we have been most concerned about summer irrigation runoff, especially where recycled wastewater is applied. We submitted extensive comments to the State Board during the 303(d) process asking that the Laguna be listed for Ludwigia and the lower river for nutrients. In this instance, we express concerns about Santa Rosa’s proposed nutrient offset program.
Concerns about Resolution….We have numerous concerns about Santa Rosa’s proposed Nutrient Offset Policy, which contains proposed activities expected to mitigate the City’s wastewater nutrient content and thereby nutrient discharges to the Laguna:
Control of raw wastewater from confined animal areas is a basic requirement of state regulations and Regional Board permits and therefore is not eligible for nutrient offsets. Any dairy that allows uncontrolled discharges of wastewater from these facilities should be subject to enforcement action by the Regional Board.
In other words, this proposed project for nutrient offsets purports to address problems that should already be controlled.
Need for greater public input and staff review….We request that the RWQCB stop the clock on this proposed project at the Beretta Dairy, in order to ensure adequate time for appropriate staff and public review and comment. We request that staff deny the project, without prejudice, to prevent automatic approval and so as to allow time for review and modifications. If the project were to receive automatic approval, staff may not have the ability to condition, deny or terminate that approval. City attorneys wrote the resolution language assuming automatic approval of the project as written. Any approvals given should be subjected to annual review with the requirement to be re-approved each year.
Estuary Lawsuit Settled: A Brief History…..
A year has gone by since the Sonoma County Water Agency (SCWA) Board of Directors (County Supervisors) authorized the Final Environmental Impact Report (EIR) for the Estuary Project, a plan to construct a channel to keep salt water from intruding into the Estuary, but allow fresh water to seep out. The purpose was to raise fresh water levels in the estuary lagoon to benefit the growth of juvenile stealhead fish preparing for their ocean sojurn.
At that Board meeting in mid-August of 2011, representatives of National Marine Fisheries Service (NMFS) made threatening statements to the Board of Supervisors, to the effect that they would be in violation of the Endangered Species Act if they did not approve the project, implying something horrific would happen if they did not approve the EIR. They also strongly implied that anyone else trying to stop the project would also be in violation. Unfortunately, the Biological Opinion, requiring both the Estuary Project and Fish Flow Project (Low Flow) became federal law without any public environmental review; California Environmental Law is circumvented by the Endangered Species Act.
What we don’t know can hurt us…..
In the 1950’s, medical doctors extolled the virtues of smoking cigarettes in public advertisements. People were lighting up in restaurants, airplanes, movie theaters and almost everywhere. As late as the 1980’s, smoke was so thick in the main room of the Santa Rosa Vets Auditorium bingo games, that one could barely see across the room.
And now, after many deaths from lung cancer, heart disease, and emphysema were directly attributed to cigarettes, along with suffering and bad health of others who had their quality of life substantially reduced, and since the discovery that non-smokers coming in contact with second hand smoke were every bit as much at risk, we have witnessed a paradigm shift where one can no longer even smoke in bars or outdoor cafes. Smokers have become pariahs in office buildings and are no longer allowed to light up on public transportation. In only 25 years, millions of people were inspired to give up this severely addictive habit, their quality of life immediately improved, and for many, years were added back on to their lives.