Sonoma County Gazette, October 2012

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.

State ignores comments on endocrine disruption…..Now the Policy is about to be finalized and the State has totally ignored RRWPC’s extensive comments submitted on the toxins and low dose impacts released into our waterways as a result of increased irrigation.  They ignored the major new study that came out last March and which we reviewed in a previous article.  They ignored the comments of the lead author of the study, Dr. Laura Vandenberg, who emphasized the problems associated with low dose exposures and their possible effects on the health of humans and wildlife.  (Study:  Vandenberg LN, Colborn T, Hayes TB, Heindel JJ, Jacobs DR, Lee D-H, Shioda T, Soto AM, Vom Saal FS, Welshons WV, et al. (2012). Hormones and endocrine disrupting chemicals: Low dose effects and non-monotonic dose responses 2012.  Endocrine Reviews. Online 2012 Mar 14.)

Dr. Vandenberg’s letter states, “….the US FDA has identified more than 1000 EDCs in current use, a significant percentage of the over 80,000 chemicals currently in commerce.”  The central focus of her comments is on low dose effects and the assumption by many scientists that low dose exposures are not a problem and need not be addressed.  (You can read her comments on RRWPC’s website.)


We have one last opportunity to comment on this Policy before it becomes finalized.


Please sign comment letter about irrigation runoff of toxins…..
Comments are due on the revised Recycled Water Policy Amendment on October 9th at noon.  A Target Letter can be found at or email Brenda at and we will send you a copy.  If you wish, you can just sign it and either mail by Oct. 6th or email by Oct. 8th.  Further directions will appear at the website or by return email.  Please help stop runoff of chemical pollutants into our river.

It’s not that irrigated wastewater is entirely bad and should not be allowed, although advanced conservation, seldom discussed lately, is far cheaper and much more respectful of limited water resources.   Huge fiscal savings are realized when water does not have to be treated at the Subregional  (or other) Treatment Plant(s).

What we don’t know, won’t hurt us?
Utility officials  and others are continually selling us on the quality and safety of the wastewater, reminding us incessantly that it is highly treated and meets all drinking water standards.   What they don’t mention is that they only test for 125 chemicals of the more than 80,000 on the market (and 2000 new ones added annually).   The Recycled Water Policy determines that endocrine disrupting chemicals will NOT be monitored in tertiary wastewater used for irrigation (including many pesticides, herbicides, personal care products, pharmaceuticals, etc.).

(For a wonderful source of information and endocrine disrupting exposures, go to the website of the San Francisco Medical Society at  and look up the June, 2012 issue of their magazine, San Francisco Medicine: Environmental Health.  The whole issue is full of article that are fascinating to read and easily understood by the layperson.)

There will also be no attempt to determine synergistic effects when these chemicals interact with one another. By avoiding a vast array of information on this topic, they ignore a whole body of science that demonstrates innumerable concerns for the health of wildlife, aquatic life, small children and older adults or those with impaired immune systems resulting from minute exposures to these toxins.  If they can do nothing else, RRWPC encourages them to monitor for the hormone 17B-estradiol in the tertiary wastewater, with more extensive testing to be conducted if tests are positive.

Policy may bypass Clean Water Act…
The Policy appears to bypass the Clean Water Act when it states:  “The Regional Water Boards shall not issue requirements for monitoring of additional CECs, beyond the requirements provided in this Policy.” (CEC’s are Contaminants of Emerging Concern which includes endocrine disruptors.)   Since no CECs will be monitored, this means that chemicals demonstrated to harm many species will not be studied, let alone limits established and enforced, thereby assuring that harm will occur.  (Several countries in Europe have already banned some of these toxins.)  These chemicals have been known to cause and/or contribute to birth defects, cancer, heart problems, autism, Diabetes, obesity, Parkinson’s disease, etc., exemplified by male frogs growing female reproductive organs when exposed to atrazine in the parts per billion range.

We interpret the above statement to mean that the Regional Board cannot EVER monitor endocrine disrupting chemicals in irrigation water as long as the Policy exists.   Since the Policy focuses on drinking water impacts and relies for the most part on State Health Department’s administration, it seems as though the Clean Water Act and protection of all beneficial uses has been thrown out the window in regard to using recycled tertiary wastewater for landscape irrigation.