Sonoma County Gazette, September 2008

“Incidental Runoff”

by Brenda Adelman

Wastewater discharged into local streams by sewage treatment plants is subjected to lengthy and complex State permit requirements that can run as much as a 100 pages long.  The permits include directions on water quality limits, monitoring, receiving water standards, and protections of beneficial uses, among other things.  They describe when and where discharges can occur and penalties to be imposed when compliance fails.  As treatment systems age, and pipeline replacement lags, the opportunities for failure (and fines) increase.  The Regional Water Quality Control Board is charged with overseeing this very complex process.

Yet, of more than 80,000 chemical pollutants on the market, discharge permits regulate only about 126 of them. Currently, no regulations exist to monitor and limit the discharge of either personal care and cleaning products or pharmaceuticals, especially hormones, steroids, and anti-bacterial products, recently accused of causing bacterial illnesses to become more resistant to treatment.

Recent studies have shown trace amounts of cancer causing and endocrine disrupting chemicals in national rivers and streams and drinking water supplies.  Even more alarming are the latest reports indicating that at least 46 million Americans are known to be exposed to drug-contaminated drinking water supplies.  The tests have not been done in our area yet, so we don’t know if we are part of that group.

And species are being lost at an unprecedented rate. Currently, the Living Planet Index claims that the bird, fish, mammal, reptile, and amphibian populations worldwide have dropped by almost a third in the last 35 years. Only this month, the United States Geological Survey (USGS) claims in a very new study that nearly 40% of North America’s fish species are in jeopardy, and our area (mid Pacific Coast) has been identified as one of the most threatened.

Yet the State, facing a serious water shortage crisis, is now promoting a program to greatly increase goals for increased irrigation with recycled wastewater from 500,000 acre feet a year to two million acre feet by 2030.   To make this policy more palatable, treated sewage is now consistently referred to as recycled water, as though by sanitizing the words, they create a different product.  The State is strongly promoting the idea of offsetting water use by greatly expanding recycled wastewater in summer, water short months.

Normally, application of treated wastewater to land is safer than discharging into waterways, although only if done in a manner that prohibits runoff into streams.  And that’s the hard part.  The State proposed a Recycled Water Policy last year and it met with a great deal of consternation from various environmental, business, and agency groups.  Environmental groups objected on the basis that all incidental discharge must be regulated in the same way as intentional winter discharges, since the toxic constituents are the same.

With the State Water Board’s concurrence, a representative group was formed to study, modify, and make recommendations on the policy to which all stakeholders could agree.  A draft was presented to the Board in early September and the group agreed on all points, but one, and that was “incidental runoff’.  Incidental runoff is not clearly defined; but is intended to mean some runoff that is accidentally spilled, small in amount, and considered to have inconsequential impacts.  The committee, not able to agree on this issue, left it to the State Board to define.  Our local Regional Board is considering a Basin Plan Amendment to legalize it.

Normally Department of State Health Title 22 regulations apply to the application of wastewater to land.  These regulations are meant to protect the public from mostly acute illness, and does not address protection of aquatic life and the environment from these discharges, especially during a time when flows are very low (and getting lower) and unable to assimilate residual toxins in the wastewater.

The State (and the City of Santa Rosa who is planning a large program of urban irrigation) refers to inconsequential runoff in order to justify using it to offset potable water.  The problem of defining, successfully and consistently monitoring and regulating these “incidental” events is daunting.  No one has addressed the possible impacts if numerous, cumulative impacts occur at the same time.

Extensive carelessness with irrigation water has been regularly observed, and most people really aren’t aware of the difference between potable and treated wastewater.  We can easily picture children and pets playing in the water and ingesting it with unknown results.  Where irrigation is allowed to occur, it should be on large publicly owned parcels, that are carefully monitored and regulated and discharge permits should be required.  Furthermore, irrigation should not be allowed near creeks, especially where pesticide use occurs.

Some of our local streams are filled with Ludwigia and are literally dying in the summer.  They cannot assimilate additional toxic loads now, but to make the problem worse, the National Marine Fisheries Service will be demanding lower summer Russian River flows to protect the fish.  That combination of circumstances would increase possible harm to people AND fish because of greater potential for exposure to harmful toxins that are not assimilated by flows.  Lower flows cause the toxic load to become more concentrated.

We must maintain the summer prohibition of wastewater discharges to protect the health of humans and the environment.  RRWPC will keep you posted on future critical actions on this issue.  Please contact us at if you want to be on our mailing list to stay informed about this issue.