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RRWPC Comments: Draft Salt & Nutrient Management Plan

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.

RRWPC Letter to Regional Board on Nutrients, 7-26-2012

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:

  • The application documents extensive dairy waste violations which form the premise for the project, yet no enforcement had been imposed at Beretta’s dairy as it discharged pollutants into the Laguna for many years.  (Including uncontrolled release of manure leachate from solids handling and uncontrolled raw wastewater released from confined loafing areas located just feet from Roseland Creek)

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.

  • Approval of any offset triggers the need for adjustment and alteration of the City’s Wastewater NPDES. This process is subject to public review and comment (CEQA also?) and SHOULD NOT BE SUBJECT TO ANY AUTOMATIC APPROVAL!
  • City claims large nutrient reduction numbers utilizing measures that should be implemented anyway (offsets proposed for activities that should be prohibited or, at least, addressed by the dairy permit program).  Approval (which occurs automatically 60 days after the city makes its proposal if project is not denied) will allow the city to continue discharging nutrients and other pollutants for years to come.  It will also allow increased discharges despite 303d listing.
  • Additionally, any offset program should wait to look at TMDL findings thatmay point to the need for pollution control work in areas other than dairy runoff.

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.

Sonoma County Gazette, September 2012

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.

Sonoma County Gazette, August 2012

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.

L. Vandenburg, Phd. Letter to Water Control Board

The Tufts Center for Regenerative and Developmental Biology 200 Boston Ave Suite 4600, Medford MA 02155 Phone: 617-627-4094 email: Laura.Vandenberg@tufts.edu June 27, 2012 Jeanine Townsend, Clerk to the Board State Water Resources ...

River Friends Email, March 2011

March 2011 River friends: For many years RRWPC has been submitting comments to the State Water Board and the Regional Board expressing concerns about their Water Recycling Policy that allows “incidental runoff” by wastewater ...