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August 30, 2010
Jeffrey Shu
Environmental Scientist
State Water Resources Control Board
Division of Water Quality
1001 I St., 15th Floor
Sacramento, CA 95814
(916) 323-1308 (phone)
(916) 341-5584 (FAX)
Dear Mr. Shu:
This letter is being submitted on behalf of Russian River Watershed Protection Committee in response to your Agency’s request for information on the 2012 303(d) List. We had emailed a partial submission to you on July 15, 2010, with three attachments, but we are resubmitting that information with this packet so it will be a complete submission. Our comments address circumstances in the Laguna de Santa Rosa, a major tributary to the Russian River, and the lower Russian River from the confluence of the Laguna/Mark West Creek into the Russian River and down to the Estuary.
We are concerned citizens who are neither scientists nor lawyers, but it is our intent to submit photographs, testimonies, reports, Regional Board documents, etc. to make the case that the Laguna de Santa Rosa should be listed for the invasive plant, Ludwigia, and that the lower Russian River (Forestville to Duncans Mills) should be listed for nutrients (The Laguna is already listed for nutrients.)
In reviewing the requirements for submitting data for the 303(d) list, we are finding it difficult to document our submission in every detail requested (specific camera settings, etc). Also, as ordinary citizen activists, we are not able to provide scientific data with any authority and so we are relying for the most part on photographic evidence. The photos submitted with this report are representative of hundreds that we have on file. If more pictures become necessary later on, we would be happy to provide them (same locations, but different angles, magnifications, etc.) We can also give more information on specific photos as per request.
RRCSD Storage
By Brenda Adelman
The Russian River County Sanitation District (RRCSD) needs additional storage capacity at the treatment plant in order to keep it from discharging contaminants into the Russian River during high water periods. Russian River Watershed Protection Committee (RRWPC) agrees that it is necessary. According to official documents, approximately 30 million gallons of storage is needed in order to fully serve current ratepayers under all river flows. RRCSD currently has 3.5 million gallons (mg) of storage, and the proposed new storage basin would give us 3.5 mg more at a cost of $4.5 million dollars.
We agree on the need for storage, but this is where the agreement stops. Sonoma County Water Agency (SCWA), operators of the system, have neglected developing a master plan for this and other components as required in the General Plan, which states that no projects can be implemented until a master plan is complete. Yet SCWA has proposed several component projects with separate environmental reviews. Their intent has been to use inappropriate and possibly illegal methods to turn RRCSD into a regional system.
Russian River County Sanitation District’s Proposed New Discharge Permit
by Brenda Adelman
Even after $5 million dollars worth of improvements a few years ago, the Russian River County Sanitation District (RRCSD) treatment system does not function properly during high flows. The system has violated its discharge permit every year since the Sonoma County Water Agency (SCWA) took over in 1995. A year ago, the District was fined $99,000 out of a possible $170,000 for permit violations occurring between Oct. 1, 2004 and May 31, 2007, consisting of 34 effluent limit violations and six prohibited discharges.
Recently, on December 1st, comments were due to the Regional Water Quality Control Board on RRCSD’s proposed new discharge permit. In order to address the system’s problematic history, many new requirements are being imposed.