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.
The Plan is intended to address impacts up to 2035, yet is based mostly on old well data that goes back to the 1940’s and 1950’s and admits to having inadequate information and frequently asserting that this is a work in process, with which we would have no problem if it is not used to authorize irrigation projects until complete. This is the first salt and nutrient plan in the state (I believe), or at least in our section of the State, and is primarily intended to generally address salt and nutrient problems in the larger Laguna area, including Windsor, Airport, Rohnert Park and Cotati. It may also serve as a prototype for other plans to come. Therefore, it should set a standard of care that provides meaningful projections in order to protect ground water resources for future generations. Right now we just see estimates, guesses, conjectures, and other inadequacies that fail to justify the conclusion that increased irrigation with Santa Rosa’s wastewater will not cause harm.
The authors have admitted to many data weaknesses in this study. There is very limited well data, estimates are used to assess the groundwater composition in too many instances, spacial averages are relied upon, and geological and soils information is incomplete. To allow the plan in its current form to guide the implementation of new irrigation projects before much more significant data is available, other than as a templet on how to move towards that goal, would be a waste of funds and/or harmful to human health and the environment.
The Laguna de Santa Rosa is a severely impacted water body. There are signs of nutrient pollution everywhere, and to plan any activity that is likely to make it worse is problematic. To conclude that salt and nutrients have minimal impact on groundwater, which this study appears to do, while allowing extensive summer irrigation runoff into the Laguna, which regulators appear prone to allow, would not only exacerbate surface water conditions, but it would ultimately add to groundwater problems as well.
For the most part, this study artificially ignores the interface between surface water and groundwater and avoids addressing the issues of endocrine disruptors and the impacts of low dose exposures to the vast array of chemicals that cause these harmful effects. A significant amount of ground water recharge occurs in the area of streambeds. There is a dynamic relationship between the surface and ground waters, with groundwater filling creeks in winter and creeks filling groundwater in summer. None of that is mentioned or addressed in this study.
I recently became aware of a groundwater study on nitrate released earlier this year, that addresses nutrient problems in California’s Tulare Lake Basin and Salinas Valley.This study was commissioned by the State Water Board (citation below):
Center for Watershed Sciences • University of California, Davis Groundwater Nitrate Project, Implementation of Senate Bill X2 1 Prepared for California State Water Resources Control Board • January 2012
This study has literally volumes of information on all aspects of the problem and should serve as a model for our local study, which at this point is grossly inadequate. It is quite voluminous and provides extensive data and expert analysis to describe the problems. It does not draw conclusions based on flimsy and/or non-existant data. It fails to make broad generalizations that assert that if the increased amounts of nutrients are below Water Quality Objectives, then it is okay to authorize the project. In fact, it emphasizes the problems with buildup of nutrients and their long term effects, including the great difficulty and expense of remediation.
Phosphorus should be analyzed….We are concerned about the Plan’s avoidance of analyzing phosphorus. Using nitrate to represent nutrients exclusively is inadequate because, although there
is a lot of nitrate in the environment, phosphorous is a limiting factor for nutrient impacts (a small amount of P leads to large impacts of N). Since this project is really all about significant increases of wastewater irrigation, it is important to reveal extensive phosphorus loadings that will come from the wastewater. Also, this Plan failed to include any wastewater salt and nutrient data, other than conclusive statements and general summaries about average nutrient and salt content in wastewater. Santa Rosa’s wastewater has relatively high amounts of phosphorus.
Although nutrients in deeper aquifers might not be active without oxygen or microorganisms, they immediately will have an impact when pumped out for reuse (or seep out into creeks). This kind of impact will be “temporal” meaning different in different seasons – so averaging over a year is invalid. For example, nitrate is immediately available to plants (including algae) but in winter there are other limits to growth, so the impact is less than spring/summer.
Nitrate also interacts with microorganisms so it can be converted back to ammonia or to gas – with very different outcomes for water quality. Another concern is that under anoxic conditions, nitrate is converted to nitrous oxide which has a climate impact 300 times that of CO2. This is a major concern about overuse of ag fertilizers – so much so that the US congress transferred all research away from EPA into the Department of Agriculture (and then restricted the department from engaging in climate research).
The analysis of TDS is also inadequately analyzed because different salts come from different sources and have different impacts (e.g. chloride and sodium from reclaimed wastewater can impact plants; heavy metals from the source water/soils and from urban piping can cause bioaccumilation impacts). The study never differentiates the various salts. Perhaps they all behave similarly while underground, but what happens when they are regurgitated from a well to irrigate fields? Since they generally avoid soil amendments, can vineyards be expected to use much of the wastewater for irrigation?
Policy calls for addressing, “….other significant chemical compounds…..”
Executive Summary (ES) commences with the statement that the Recycled Water Policy requires Salt & Nutrient Management Plans be developed to “…manage salts, nutrients, and other significant chemical compounds on a watershed, or basin-wide basis.” (emphasis added)
Yet there is almost no information on any of the chemicals that need to be addressed, other than a chart of Basin Plan Objectives. It is possibly assumed that this will be addressed through a different process. Yet the Recycled Water Amendment specificially states, as noted above, that other significant chemical compounds should be addressed in this Plan.
The most controversial part of the Recycled Water Policy was the part on ‘incidental runoff’. A scientific panel was established to address this issue, and came to the conclusion that monitoring of individual contaminents of emerging concern (CECs) did not need to occur for irrigating landscapes with wastewater. Since their report was released last year however, a new report on endocrine disruption was released in March of this year that contradicts those findings (the panel assumed that doses were insignificant and therefore did not need to be considered. This new study, bringing together a dozen scientists who are experts in various aspects of this field, demonstrated that low dose impacts of these chemicals on the endocrine system of humans and wildlife, caused a vast array of birth defects, human illness and conditions leading to illness resulting from exposure to minute amounts.)
We have written several commentaries on recycled water that refers to this study,
Hormones and Endocrine-Disrupting Chemicals: Low-Dose Effects and Nonmonotonic Dose Responses by Laura N. Vandenberg, Theo Colborn, Tyrone B. Hayes, Jerrold J. Heindel, David R. Jacobs, Jr., Duk-Hee Lee, Toshi Shioda, Ana M. Soto, Frederick S. vom Saal, Wade V. Welshons, R. Thomas Zoeller, and John Peterson Myers.
We will attach our comments on Recycled Water Policy Amendment to more fully explain our concern about this issue. Since all discharges of wastewater, whether used for irrigation or simply discharged, begin on the surface (unless injected, which is not the case here). Therefore, it would seem required under anti-degradation rules to address the water quality impacts of runoff on surface water conditions since these discharges will be applying considerably increased amounts of wastewater under summer conditions.
We submitted a comment letter to the State Board written by Laura N. Vandenberg and an article she included entitled: “Environmental Chemicals: Large Effects from Low Doses” which clearly points out the problem with the findings of the State’s Scientific Panel. Her article appeared in Environmental Health, San Francisco Medicine, June, 2012. The whole June issue is devoted to this topic.
Dr. Vandenberg states in her letter:
The concept of low dose effects and non-monotonic dose responses is not at the fringe of science. The Endocrine Society, the world’s largest professional association of clinical and research endocrinologists, has released two recent statements regarding EDCs, and has repeatedly reiterated the conclusion that low doses of EDCs are harmful to humans and wildlife [3, 4]. This conclusion has widespread acceptance in the field of endocrinology due to the strength of the published data. Additionally, following the publication of our review [2], Dr. Linda Birnbaum, Director of the National Institutes of Environmental Health Science (NIH) and one of the world’s leading toxicologists wrote an editorial stating: “the question is no longer whether nonmonotonic dose responses are ‘real’ and occur frequently enough to be a concern; clearly these are common phenomena with well-understood mechanisms
Spatial Averaging and existing water quality…
This Plan supposedly analyzed groundwater quality including the amount of nitrogen and salts. It was determined that the resulting amounts were below the Water Quality Objectives and therefore less than the assimilative capacity of the basin. It seems as though Water Quality Objectives should be seen as the worst case and not the goal of the project as indicated below. Groundwater stays in the aquifer; it does not wash out to sea and therefore these objectives don’t leave much leeway for its protection.
Page iv of Plan states,
The antidegradation analysis estimates the change in basinwide TDS and nitrate concentration over a 25-year time horizon using the estimates from the loading analysis combined with estimates of existing water quality, water budget estimates from previous reports, and estimates of concentrations from surface water recharge and from the use of additional recycled water. The analysis estimates a projected increase in TDS concentrations from 290 mg/L to 388 mg/L and in nitrate (as N) concentrations from 1.3 mg/L to 1.6 mg/L over the period of 25 years (see Figures ES-4 and ES-5). These values are both below the North Coast Regional Water Quality Control Plan’s (Basin Plan) Water Quality Objectives: 500 mg/L for TDS and 10 mg/L for nitrate. The bulk of the increase in concentrations is attributed to existing activities, with only 1 percent of the TDS loading and none of the nitrate loading caused by increases in recycled water usage to meet the stated goals. (emphasis added)
Notice the sixfold use of the word estimates. This Plan sets a low standard, based on pure guesswork by merely staying below current limits, and fails to address the underlying problems associated with going up to or over those limits, either on the surface where the irrigation water is first applied, nor in the ground where, once it gets to significant levels is very difficult and expensive to remove. The Water Quality Objective is just a number that provides a limit, but once that limit is reached in groundwater, it becomes a problem that is extremely difficult to remediate. If so little of this Plan is based in the reality of actual data, then projects should not be allowed to move forward until adequate data is available. Furthermore, if such plans do move forward, they tend to become entrenched, and harder to control at the point where the pollutants do exceed the Objective levels.
This report also provides virtually no data on the salts and nutrients in the wastewater to be irrigated, that verifies their claims or demonstrates data consistency. It concludes that groundwater quality will be degraded over time in violation of State anti degradation water quality standards. (TDS will increase 25% over the 25 years, bringing it much closer to the Water Quality Objective than it is now, which, as I mention above, is not really a good thing and should not automatically justify the addition of expanded wastewater irrigation activities.) USGS will be developing a model over the next five years that will give much more information on water budget and flows. RRWPC believes that that would be the appropriate time to develop this Plan. It is essential that the underground nutrients be tracked and their fate be understood. Otherwise, water quality protections are virtually impossible, especially in light of anticipated nutrient level increases.
There is an emphasis in this Plan, based on a State Water Board Resolution 68-16 (Written in 1968, we wonder if more recent resolutions have negated this statement?), that (in reference to water quality conditions), says on page 10-7 & 8: “…such existing high quality will be maintained until it has been demonstrated to the State that any change will be consistent with maximum benefit to the people of the State, will not unreasonably affect present and anticipaqted beneficial use of such water and will not result in water quality less than that prescribed in the policies.” The Plan then goes on to conclude that since Water Quality Objectives will not be exceeded, and the economic importance of water supplies and agricultural and urban uses, “…the qualitative cost-benefit analysis concludes that the increases are consistent with the maximum benefit to the people of the State of California.” Well, we certainly hope the people of the State of California get to weigh in on this conclusion!
There is also an assumption that current standards won’t be changed over those years. I found the following on the web that indicates there is not one standard used for all conditions:
“Typical effluent permit limits for nitrogen compounds in wastewater effluent vary, but all are based on location of final effluent discharge. A wastewater plant that discharges to a spray field may not have a limit on nitrogen while a plant that discharges to percolation ponds may have an effluent nitrate limit of 12 mg/L. A treatment plant that discharges to a nearby stream or river may have a total nitrogen limit of 3 mg/L, or a unionized ammonia limit of 0.2 mg/L. “
There are examples of lessons from similar urban/ag areas such as the Central Valley and Chino. Groundwater contamination by ag chemicals and manure were growing but ignored until the housing bubbles created a large municipal/public demand. By that time, the groundwater couldn’t meet potable standards – even after dilution with State Water Project supplies – requiring costly Reverse Osmosis treatment. Even low initial impacts that are growing slowly can balloon quite fast into a crisis. For example, if there is ever a time when grapes grow out of favor, crops can change and extensive soil amendment applications can occur again. This has happened many times before, even though the current crops seem relatively stable at this time.
Furthermore, the Draft Plan identifies many “hot” spots in the watershed that may deserve remediation. These might be located where certain high discharge activities are occurring (high amounts of recycled water, manure ponds, etc). The plan should propose investigation and remediation of these areas where public health standards are exceeded. (Figure ES-2 and Figure ES-3) This Plan should clearly identify priority areas that need special attention. Simply relying on Best Management Plans (BMPs) (not yet clearly defined) is not going to offer any protections from a potentially serious problem. BMP’s that are not backed up with the possibility of regulatory action, are bound to be ineffective. Usually where there’s a serious problem, there is someone who doesn’t care about doing things right, let alone reliably implementing best management practices.
Assimilative Capacity and the problem with averaging….
Assimilative Capacity is determined based on squshy estimates and averages of a limited amount of information on actual salt and nutrient conditions, a limited number of well samples, and issues around well depth and ground water levels. The kind and amount of information available is really inadequate to base any long term plans for increased irrigation. One thing that is badly needed is a map that indicates areas currently being irrigated with indications of new planned irrigation areas, if they are known. This should be overlaid or compared with the TDS and nutrient maps showing areas of greatest accumulations. If this is a true plan, that information is essential.
The authors of this Plan admit to concerns about using a model from 1987 since more current USGS data is not yet available. How can this old information be credible? How can a study based on data that is 25 years old allow conclusions about current conditions? It would seem appropriate to complete this study when USGS releases the pertinent information needed to properly address these issues. Furthermore, there have been numerous reports of dramatic increases in groundwater pumping due to new development and vineyard installation over the years. Data should be modified to show updated groundwater pumping in the basin. If this means waiting for the USGS Study, then we should wait.
The formula for determining assimilative capacity of basin to absorb nutrients and salts utilizes spatial averaging based on average well monitoring data in the Laguna. The resulting number is deducted from water quality objectives (10 mg/l and 500 mg/l) to determine assimilative capacity for the whole Laguna based on about about 75 well logs, with some areas exceeding limits. While “spatial” averaging is applied throughout the Laguna flood plain, they admit that there are some areas where water quality conditions are worse and pollutant concentrations are higher. In these situations, how can spatial averaging indicate specific site conditions in any given location in any meaningful way? It seems as though averaging actually diminishes the problem by eliminating peaks and valleys. The real focus should be on hot spots where serious excursions have been identified.
When determining assimilative capacity, averaging ignores the high concentrations in certain locations. Some of these are shallow private wells that can impact human health. Section 1.5 of the report says (a) this is a first step that will be improved over time every 5 years to include new details, (c) the focus is on municipal supply from deep
aquifers and the impact of reclaimed municipal wastewater, and (c) USGS will include shallow depths and surface-ground water interactions. Every elementary statistics text warns against using an average value when you have significant extremes that need to be explained – i.e. the lack of data in this report is the very reason for immediately ordering a monitoring plan.
The truth is, a family who loses a baby to ‘blue baby syndrome’ cares little about the average assimilative capacity of the project area in the form of a specific number, they care about cleaning up their well, so they can drink water without killing family members. In other words, site specific measures and analysis is critical to the health of those who live there and drink water from contaminated wells. Yet none of that is planned for this study, and that may be it’s most egregious fault.
This Plan focuses on monitoring and BMP’s as a remedy for increased salts and nutrients. Yet we are not given a road map as to where extra salts and nutrients are likely to end up. While there is a projected increase (significant for salts), if it were to end up in one general area, it could be more of a problem than if it had been spread around. Nor are their many specific BMPs mentioned. That too is left for future development.
The fact remains that much more study needs to be done. By putting this project on hold until more information is available, probably wouldn’t have much effect on current irrigation practices. First, Santa Rosa has been drilling various sites to find an emergency supply on the west side of town. That would be another source of information. More wells would give more reliabile information. Furthermore, non-supply wells such as those monitored by the Regional Board and Sonoma County PRMD should be added as well. These wells are typically located near urban areas where risks to groundwater quality are high.
As for Table ES-1 numbers are expressed in acre feet goals. Ag irrigation for 2010 was 5,039 AF. We have no idea what that covers. Are those agricultural lands currently using recycled water? Where are they located? (general area) Whose water are they using? We’re not sure what the numbers for Santa Rosa are based on either. Is Santa Rosa’s ag irrigation under ag irrigation or Santa Rosa/Rohnert Park? We do know that in 2009 Santa Rosa irrigated about 2 BG. Figuring one acre foot as 325,000 gallons, that would make their irrigation amount for that year as 6154 AF. I could find no explanation for the numbers on this Table.
Furthermore, since the Geysers itself is a recycled water project, it would appear to meet recycled water goal required by the CA Water Recycling Policy all by itself but does not appear to be considered in the Table. There is no analysis for why, given that Santa Rosa recycles so much to the Geysers, they would need the amount they do for irrigation. According to their Urban Water Management Plan, they need to offset water use so they can have more available water for new growth. I don’t think that is mentioned in this Plan, nor is their an analysis of how their portion of the State’s goal of recycling 2.5 million AF by 2030 will be met through this Plan.
The increase in the amount of irrigation water to be applied to Laguna area appears neglible. Up through 2004, Santa Rosa applied an average of about 4 BG to the Laguna agricultural areas for summer irrigation before the Geysers Project went on line. Gradually that amount came down to 2 billion gallons in 2009, which comes to about 6154 AF, almost the same as the 6138 planned amount for 2035. Which is a little less than what is estimated in Table ES-1. Yet right above that it estimates an annual increase of 1700 to 3100 AF. Please clarify these numbers and give more detailed information upon what they are based.
Stated Limits of Plan….
Page 1-5 states some of the limits of the plan already alluded to in comments above.
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- The focus of the Plan is on monitoring, which is fine as long as no long range decisions are made based on the acknowledged limitations of the value of the Plan.
- This Plan is intended to be Regional and will not address site specific issues with salt and nutrients. Our concern about this approach is clearly defined above.
- The Plan is designed as a regulatory document to meet requirements of the Recycled Water Policy. This Plan comes up short for reasons already mentioned above. (Need to indicate how much of their water use will and is being recycled and this should include the Geysers project and water balance analysis needed)
- Also, full analysis of salts and nutrients, including phosphorus, in Subregional System wastewater is needed. 1% is claimed, but no data given. Mass loading numbers for several years would be important.
- Plan admits that salt and nutrient impacts to surface water should be considered, but claims that occurs in other regulatory processes such as NPDES Permits. Does the Recycled Water Policy specifically authorize that approach? It seems as though that bifurcation should not be allowed in areas that are impaired for nutrients. Would any permits to discharge/irrigate be allowed under the Recycled Water Policy alone, or would it always involved the NPDES Permit?
- The Plan admits to focusing on deep wells because they are generally municipal wells and data is more available. Yet it also says that little data is available on shallow wells and that the USGS Report will be relied upon for that important information. It is our view that this Study has very limited value without it.
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Existing Ground Water Quality….
Page 3-5 excludes consideration of monitoring for CECs based on the Scientific Panel’s finding that no monitoring was necessary. In spite of great publicity of a new study mentioned earlier, this Plan simply dismisses the extensive evidence of 850 studies indicating that when it comes to endocrine disruption, low doses are highly significant.
Table 3-1 shows that a low percentage of the wells for which information was available had exceedances of water quality. That they did not include shallow wells, which have the worst problems. So in order to get good results, the Plan focuses on the data provided where they are least likely to see a problem. Do the authors consider this a valid scientific approach? It’s like you tell the doctor you have a stomach ache and he tells you that you have no need to worry, your feet are fine! You have cherry picked the data you want to consider and then come to the conclusion that all is fine. In the meantime, the poor people who’s wells are contaminated will be told that nutrient and salt pollution is not a problem for them because area wide there has been no problem demonstrated by the data.
Page 3-9 indicates that almost equal amounts of recharge come from ground surface and from streams. It would seem pertinent to address salt and nutrient problems in surface waters if this is the case.
Best Management Plan Strategy….
Vineyards regularly measure salts and nutrients in their soils. I have frequently heard that salts in particular are a major concern. Yet there is no information on how many acres of vineyards irrigate with wastewater. I would imagine that if they used it, it would be used sparsely. Why was there no information on this use? How many acres irrigated, etc? Also, what are the numbers they are looking for, in terms of loading?
Dairies are a major source of nutrients and source of salts as well. This study merely states that the dairy waiver program will provide more and new information. And then what happens? This Plan needs to explain the program in more detail. Most are endocrine disruptors and to err on the side of caution, it would be important to identify and mitigate pesticide and herbicide use when irrigation occurs, especially near creeks and streams. I believe Regional Boards are responsible for this, but I never hear of anything coming from it. With irrigation there will be runoff and with runoff will come the endocrine disrupting chemicals that turn male frogs in to females, cause birth defects in human and animal offspring, and cause many diseases that none of us want to deal with. It’s hard to imagine why people in Canada and Europe are taking this problem seriously, and our regulators are doing nothing.
It says on page 5-1 that BMPs are being implemented to avoid runoff, but nothing is said about what is being done. It is important to make addressing that issue part of this document. On the following page it speaks of BMPs that reduce the likelihood of overapplication of fertilizers and soil amendments on grounds where recycled water is applied. Reducing the likelihood sounds very squshy. Please tell us what is being done.
Reliance on BMPs without any regulatory back up, is rather weak. The people who would cooperate are usually not those creating the problem. It is essential that regulatory enforcement back things up when the BMP approach breaks down. North Coast Regional Board has hardly any enforcement staff and relations with the polluters have become much too cozy. We realize that the political and monetary climate is not conducive now to heavy enforcement, but sometimes becomes necessary, or the message may be sent that they simply don’t care anymore about protecting the public good.
Page 5-2 states:
Given the lack of near-term exceedance of water quality objectives shown through the groundwater quality trend analysis in Chapter 7 and given the improved technical information and tools that will be released in the coming years by the USGS, no additional specific BMPs are proposed in the Plan at this time.
This is the kind of generalization that we were concerned about. The Plan relies on old and averaged data, no site specific information, long time periods for data over large areas, no site specific analysis even where hazards exist at site specific locations, no shallow well data, etc. and you want us to believe that no additional specific BMPs are necessary at this time.
Loading analysis:
On page 6-1 a loading source should include pets and wild animals.
This section ignores the contribution of salts and nutrients loading from urban irrigation. Throughout this document there is no analysis of salt and nutrient loadings from urban wastewater irrigation by the various entities involved, including Santa Rosa, Rohnert Park, Windsor, and Airport.
Methodology…..As stated over and over, not only by yours truly, but by the document itself, this study fails to provide adequate information to fully accomplish the purpose at hand, which is to assess the contribution of salt and nutrients basin wide, but not necessarily avoiding specific hot spots resulting from greatly increased wastewater irrigation. Once again, the document verifies the lack of substance to this effort in the following statement:
To support this Plan and to better understand the significance of various loading factors, a GIS loading model is developed. The loading model is a simple, spatially based mass balance tool that represents TDS and nitrogen loading on an annual-average basis. It is not a calibrated model as insufficient data are available to support such an effort, and therefore results are more uncertain than results from a fully calibrated model. Despite the uncalibrated nature of the model, it is considered suitable for this analysis of basin conditions, with the recognition that a more rigorous model, potentially based on the ongoing USGS modeling effort, may be required to support future work.
So is it suitable, or is it not? One cannot have it both ways! Furthermore, when wastewater irrigation was first proposed and then discussed with the Regional Board, the promise was that wastewater would only be applied at agronomic rates. In other words, there would be no runoff, because there would be no over-watering. That is not mentioned here however. Only in extremely limited circumstances would incidental runoff be allowed to occur.
The document goes on to state in regards to load determination and the model:
Estimate the TDS load applied to each parcel based on the land use practices, irrigation water source and quantity, septic load, and infrastructure load. The loading model assumes that no salt is removed from the system once it enters the system. Other transport mechanisms could reduce the total quantity of salt in the basin.
Estimate the nitrogen load applied to each parcel based on the land use practices, irrigation water source and quantity, septic load, and infrastructure load. The loading model assumes that a portion of the applied nitrogen is used by plants and removed from the system. Additional nitrogen is converted to other species and is lost from the system as well. Hydraulic conductivity is used to reflect the mobility of the nitrogen into the aquifer before being converted or used.
Notice that here the loadings are to be based on each parcel, whereas earlier in the document it clearly stated they would not look at salt and nutrients on a parcel specific basis. So which is it?
In general, this document hopscotches around issues that are critically important to those who rely on wells for their water supply that may be contaminated from salts and nutrients, possibly making their water undrinkable.
The extra water that may become available as a result of offsetting potable supplies with wastewater irrigation will not really benefit those who draw their water from the wells being threatened. The ‘well being’ of the utilities may predominate but at what cost to others? There are about 40,000 well owners in Sonoma County. Who is truly looking out for their interests in this matter?