RRWPC Letter to Regional Board: Santa Rosa Proposed Waste Discharge Requirements

December 3, 2012

Comments on:  Proposed Waste Discharge Requirements and Master Reclamation Permit Order No. R1-2013-0001, NPDES (National Pollutant Discharge Elimination System) Permit # CA0022764

(See list of attachments referenced below.)

Dear Mr. St. John and Regional Board Members:


RRWPC has been tracking Santa Rosa’s wastewater activities, including their various permits and environmental studies, since 1985, when City officials allowed over 750 million gallons of secondary wastewater to be illegally discharged into the Russian River.

As citizen activists, RRWPC has represented property and business owners and recreationists in the lower river for 32 years.  We have studied documents, provided comments and expert testimony; we have attended meetings and given testimony mostly on water quality issues, and we have been involved in several legal challenges in regard to Santa Rosa’s wastewater discharge EIRs.

RRWPC has also been tracking the State’s Recycled Water Policy from early on. We provided comments and testimony to the State Board on the Policy and other documents related to it.  We generated letters on the issue of Recycled water and incidental runoff from other environmental groups and many members of the public.  (We attach comments on Recycled Water Policy {#1} and Amendment {#2}. We also attach Complaint {#3} submitted on Santa Rosa’s irrigation overflow.)  We also have written several articles for the Sonoma County Gazette on this and related issues.

Furthermore, we provided comments on both MS4 Permits in reference to incidental runoff and also the Basin Plan Amendment.  We submitted extensive comments to the Legislature on AB 2398 earlier this year.  Our major concern with this legislation, was that it was going to declassify tertiary wastewater as a waste when used for landscape irrigation.  Partly because of our comments, along with general public concern, the Bill was dropped for this year’s legislative session.

Just weeks after this Bill began its rounds late last February, a new Study was released by twelve scientists (Vandenberg, L.N., et al., Hormones and endocrine disrupting chemicals: low dose effects and non-monotonic dose responses. Endocrine Reviews, 2012. 33(3): p. 378- 455.) {#4}.  This study analyzed over 800 papers on endocrinology and toxicology over the prior three years.  According to Dr. Vandenberg, lead author, the conclusion was drawn that: “…low dose effects and non-monotonic dose responses are common for EDCs, and in fact may be the expected type of biological response for this large class of chemicals. Most importantly, we have a great understanding of the mechanisms behind these types of effects; hormones act in the body at exceedingly low concentrations, i.e. in the part per trillion or part per billion range.”  (Dr. Vandenberg’s letter {#5} to the State Board regarding Recycled Water Policy Amendment and also study she referred to are attached to this document and are also part of the record for the Recycled Water Policy Amendment.)  (both documents attached)

She also stated in her letter to the State Board: “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.”

Although they have not yet made a final ruling on the Amendment, the State has not responded to either Dr. Vandenberg’s comments or RRWPC’s on this topic other than to say they “considered” our comments.  In our view, without further detail about what the “consideration” entailed, they did not really consider it at all.

The major point we are making here, and in relation to the proposed draft NPDES and Reclamation Permits, is that our concerns about ‘incidental runoff’ have not been addressed at any point in the process, and as a result of this new study, have in fact been deepened.  In a recent email concerning responses to comments on the Amendment, I wrote to State Board Staff regarding the State Scientific Panel’s decision to not require monitoring for endocrine disrupting chemicals of wastewater used for landscape irrigation:  “Please forgive me for saying that it is beyond belief that this State Scientific Panel declares otherwise, without any acknowledgment of the issue, let alone detailed analysis.  We strongly suggest that, at a minimum, the Scientific Panel address this issue specifically and give a meaningful justification for ignoring the findings of so many bonafide experts in the field.

The responses you provided to us say nothing about these scientific findings.  Rather they merely state that, regarding both my comments and Dr. Vandenberg’s, that all our comments have been ‘considered’.    No description was provided explaining what such consideration included.”

Conventional risk assessment assumes that the dose makes the poison.  Only 125 toxins are currently regulated and the list has not changed for decades, even though over 80,000 chemicals exist, and about 2000 new ones are added each year.

As the impacts accumulate over the years, the greatest concern now is the unknown result of multiple merging compounds.  Rather than the single dose response, it is critical that scientists develop protocols for testing multiple compounds at once.  According to Linda Birnbaum {#6}, head of NIEHS (National Institute of Environmental Health Sciences) and National Toxicology Program, that is happening right now.  She says, “Basically, we can  screen up to 10,000 chemicals a year at 15 different dose levels for at least 70 or more different kinds of responses.  We can begin now to do this with mixtures where we can make many different kinds of mixtures because we can test so many at a time.” (Chemical “Soup” Clouds Connection between Toxins and Poor Health, by Brendan Borrell, 11-23-12)

Also, rather than wait for single chemicals be proven dangerous, the Precautionary Principle, calling for caution from the start, should be implemented as soon as possible.  This would require that chemical companies prove that a chemical is safe before widely adopted, rather than placing the burden on the public who now serve as guinea pigs for the chemical and pharmaceutical industries.

A New York Times article (Sept. 6, 2012) entitled How Dangerous is your Couch (about flame retardants) illustrates the problem {#7}.  It states, “But of the 84,000 industrial chemicals registered for use in the United States, only about 200 have been evaluated for human safety by the Environmental Protection Agency.  That’s because industrial chemicals are presumed safe unless proved otherwise under the 1976 federal Toxic Substances Control Act.”

In Sonoma County, according to State pesticide reports 2006-2010 {#8}, the most common pesticides and herbicides used were 1,3 Dichloropropene, glyphozsate, mancozeb, and simazine.  When lands are irrigated using those chemicals, it is likely they will end up in the soil, ground water, and surface water (when runoff occurs).  According to the PAN Pesticides Data Base, Mancozeb is listed as a “bad actor” chemical that is carcinogenic, and a developmental or reproductive toxin and suspected endocrine disruptor.  Simazine is also listed as a “bad actor”, a ground water contaminant, and developmental or reproductive toxin.  It is a suspected endocrine disruptor.   1,3-Dichoropropene is listed in Wikiup as carcinogenic to animals and possibly humans as well.

Since the reclamation permit relies on a yet to be produced Groundwater Management Plan and Salt and Nutrient Management Plan, and also a study to determine agronomic rates for irrigation, it’s hard to say how the conclusion can be drawn that impacts will be minimal.  Neither the permit nor the Reclamation Plan makes mention of the need to limit irrigation on lands that have been treated with bioactive chemical products, including fertilizer.  What is the fate of the chemicals listed above if the lands that use those products are over-irrigated? How will they impact the wildlife and aquatic life that have to live in the water 24/7?

Another critical issue is that worldwide, amphibians are disappearing so fast that scientists say they might be facing mass extinction.  According to reports, these creatures have been on earth for 300 million years (including frogs, toads, and salamanders).  There are approximately 6,300 know species and as many as 168 species have gone extinct in the last two decades. 1,856 species are considered threatened and 2,469 have been declining in that same time period.  Amphibians are important to the ecosystem since they eat mosquitos, some of which are disease bearing vectors.  Their decline may be a strong indication of chemical contamination impacts to our environment.

In the Russian River, frogs appear to be in serious decline.  According to AmphibaWeb, University of California at Berkeley {#9}, suspected reasons for decline are habitat loss, invasive species, climate warming, chemical contaminants, and disease.  These are the same issues for the salmonids, which have been well documented to be in serious decline as well.

Tyrone Hayes is a professor at UC Berkeley and renown expert on the impacts of chemicals on frogs.  He was one of the scientists who participated in the important study of which Dr. Laura Vandenberg was the lead author.  He is best known for his work with atrazine and frogs whereby at exposures in the parts per billion range, male frogs develop female reproductive organs.  Because frogs breath through the skin, they are exposed to endocrine disrupting contaminants much more easily.  They can be seen as the canary in the mine.

Summary of Main Permit Issues:

RRWPC strongly supports comments by John Short on this permit.

NPDES Fact Sheet:

  • Assumes that flow increases to treatment Plant up to 25.9 mgd would be used for/by reclamation and not discharge.  Therefore the requirements for increased capacity will be far less stringent.  Yet summer irrigation discharge cannot be adequately quantified and is bound to occur, especially if irrigation occurs at night or the late evening.
  • Page F-12: 3A concludes that CEQA review has been adequate even though this section comes immediately after the one describing three enforcement actions during the course of the last permit.  It seems as though there have been changed conditions since the last permit had been approved that should be addressed.  There was no updated CEQA process by the City since December, 2007, which is now five years ago.  Changed conditions include lowering of Russian River flows because of the Biological Opinion; adoption of the Recycled Water Policy, which encourages much greater reuse of wastewater at a time when runoff can have much greater impact, adoption of the MS4 permit which allows incidental runoff and finally the Basin Plan Amendment allowing incidental runoff.
  • This permit fails to clarify how runoff will be controlled and what amount of runoff will be considered ‘incidental’. The Draft Permit does not define how proper application rates will be achieved. Therefore it can’t possibly assure that anti-degradation goals will be realized.  It fails to define how agronomic rates will be calculated and therefore limits ability to define runoff itself.  It allows ponding, a sign of over irrigation, for up to 24 hours.  It calls for self-reporting, but allows nighttime irrigation when agronomic rates are much lower and there is much greater risk of runoff.  Who will be watching?  Will these ‘incidental’ discharges be part of the Laguna TMDL?We are concerned about the assumption that runoff will be so negligible that it can’t possibly do any harm.  Further, it does not account for health and safety risks resulting from unregulated and undocumented chemicals that may be left in the wastewater as noted above.  (Also please see John Short’s comments regarding implication that existing irrigation sites are exempt from State law and only new sites have to meet minimum standards.)
  • What safeguards are in place to assure that all self-monitoring reports will be conducted strictly according to protocol?  How do you know whether test samples used the proper water source?  How do you know that undesirable results weren’t thrown out and the test repeated until desired results were achieved?  If irrigation is at night, who will know whether agronomic rates are being met?  How is the amount of runoff calculated, especially if most occurs at night?
  • While Santa Rosa’s BODs, TSS, total coliform bacteria, and settleable solids in their wastewater is generally in compliance and less than permit limits, nevertheless, these discharges have been going on for a long time, and we wonder how much sediment accumulation has occurred?  Bacterial and nutrient problems keep getting worse in the lower river, ludwegia is now a constant nuisance that may harbor pathogens, including West Nile Virus, possibly causing illness to those recreating and pets utilizing the river.As the river becomes more impaired with sediments, to what extent will these problems become exacerbated?  Is there a point where it will become necessary to adjust (raise) limits for Santa Rosa’s discharge because the impairment has gotten worse?  (I guess this would be part of a sediment TMDL, but we are concerned about on-going incremental increases that over time, turn into a much bigger problem.
  • The MS4 Permit and Basin Plan Amendment were authorized for ‘incidental runoff’ before information had been attained on salt and nutrient issues, groundwater studies by USGS were available, and TMDLs had been promulgated for Laguna nutrients, dissolved oxygen and temperature.  Naturally, without adequate information, the CEQA equivalent could not possibly have addressed these issues.  While it is good that Santa Rosa discharges must meet a “no net nutrient” standard, this incidental runoff will be allowed to add relatively high levels of nutrients (phosphorus in particular) with no clear enforcement mechanisms defined. The agronomic rates will be determined in a later report and the application rates are as yet undefined. The nutrient application rate is undefined. (John Short addresses this also.) If this process has followed a CEQA equivalent, why are critical requirements dependent on future reports?   Future reports not allowed as mitigation in CEQA and I don’t think they should be allowed here either unless public process is reopened.
  • The Fact Sheet (p. F-20) refers to the Recycled Water Policy’s mandate to develop an area wide salt and nutrient management plan (rather than individual assessments).  It seems as though it should be necessary to do both.  As they are waiting for data from USGS for the Plan, and this can take an unknown amount of time, it seems as though individual projects need to do some kind of assessment in light of Laguna and River impairments.  This permit document seems to be filled with ‘donut holes’ where a fairly stringent goal is stated (compliance with Anti-Degradation for instance), but then is surrounded by slippery contingencies that allow escapes through the back door, mostly provided by the Recycled Water Policy.
  • The Recycled Water Policy Amendment calls for no monitoring of endocrine disrupting chemicals for application of tertiary wastewater on landscapes.  RRWPC has written extensive comments on this, which went unanswered. (See attachments) As mentioned before, Dr. Vandenberg wrote of the low dose effects on endocrine disrupting chemicals.  They did not respond to her either.  The justification for this finding (by State Scientific Panel) was first that these chemicals have no impact at low doses.  Then they switched horses to say that there is little likelihood of exposure.  This also is false, since we have photographed extensive over-irrigation of wastewater repeatedly at bus stops across the street from Santa Rosa’s Utility Center.  These chemicals have huge impacts on young people, and repeatedly flooded area next to City bus stop.    We submitted dated pictures to Regional Board in early 2012 to prove this.It’s as if all of the chemicals and chemical compounds that have been demonstrated to cause serious and sometimes fatal impacts to humans, children and future generations, and wildlife, have no basis in reality because the State and Federal Government have not been able to set standards for most of the poisons in our environment.  It’s absolutely shameful.  Politicians have determined that business is much more important than human health and well being, let alone the needs of the environment.  In light of all the extirpation being caused, this problem is on the same scale as global warming.

    Nicholas Kristof, in a May 2, 2012 column in the New York Times {#10} said, “Endocrine disruptors are everywhere….Test your blood or urine, and you’ll surely find them there, as well as in human breast milk and in cord blood of newborn babies.  In this campaign year, we are bound to hear endless complaints about excessive government regulation.  But here’s an area where scientists are increasingly critical of our government for its failure to tackle Big Chem and regulate endocrine disruptors adequately…..Last year, eight medical organizations representing genetics, gynecology, urology and other fields made a joint call in Science magazine for tighter regulation of endocrine disruptors….Shouldn’t our government be as vigilant about threats in our grocery stores as in the mountains of Afghanistan?”

    Yet the draft permit states on page 15, “The discharge shall not cause receiving waters to contain toxic substances in concentrations that are toxic to, or that produce detrimental physiological responses in humans, plants, animals, or aquatic life. Compliance with this objective will be determined by use of indicator organisms, analyses of species diversity, population density, growth anomalies, bioassays of appropriate duration, or other appropriate methods, as specified by the Regional Water Board.”  It is really hard to believe that with all the health problems showing up prematurely  in the general population, the disappearance and malformations of wildlife being observed, it’s a little hard to believe that Santa Rosa has such a sterling record in regards to their toxicity testing.  Why is the City so resistant to testing for endocrine disrupting chemicals in their wastewater (especially estradiol) if their treatment methods are so reliably safe?  Why are they resistant to testing fish living in their wastewater for signs of vitellogenin production (fish feminization).  Years ago Santa Rosa’s BPU agreed to do this, and two weeks later withdrew their commitment.

  • What administrative penalties for over irrigation have been handed out?  RRWPC has filed complaints on multiple Rohnert Park and Santa Rosa over-irrigation incidents, with numerous dated and identified photos, and nothing seemed to happen in the public view.  What does it take for the Regional Board to issue a Cease and Desist Order?  How can the public maintain confidence in this process when things are somehow dealt with behind the scenes?  We have a similar concern about the Nutrient Offset program.  Santa Rosa identified an offset project (Beretta Dairy).  There was a public comment period.  RRWPC submitted a lengthy letter, and the next thing we heard, the project had been approved.  Now, a new notice has gone out on a different project.  What’s the point of commenting, WHEN THE PUBLIC IS NOT INCLUDED IN THE PROCESS???
  • Another factor inadequately considered, is that of discharge to a waterway when low flows predominate. Could one say that even a small discharge into a very low flowing and water quality impaired stream, will have a much bigger impact than if normal flows were taking place.  The NPDES discharge permit covers the period when flows tend to be higher and therefore the impaired constituent would be somewhat diluted.  Is dilution considered when setting standards?  If it is, then shouldn’t standards be raised when discharge is allowed under summer conditions, especially where heat is a factor?In fact, the impacts of this discharge on the environment during summer conditions have not been fully explored.  We all know, even without scientific studies, that the Laguna impairments are greatly exacerbated during heated summer conditions.  We wonder if that was factored in when the standards were set up?  Whether or not it was, shouldn’t it be considered now?

    In fact it seems as though there may be a conflict between the permit

    In reference to the summer discharge prohibition, the Fact Sheet states on page F-24, “The discharge of wastewater effluent from the Subregional System…is prohibited during the period of May 15th to September 30th….” And it explains, “The original intent of this prohibition was to prevent the contribution of wastewater to the baseline flow of the Russian River during the period of the year when the Russian River and its tributaries experience the heaviest water contact recreation use.”  Did the standard change when the discharge went from point to non-point by virtue of its use as irrigation?  This assumption that only occasional and minimal discharges will occur is simply not verifiable by the record, since it is so hard to ascertain the estimates of runoff that actually occurred.

    F-28 & 29 indicate that the RPA for dichlorobromomethane and chlorodibromomethane indicates their limits may be exceeded through the discharge of wastewater.   How will public health and other beneficial uses be protected if these substances are distributed on the land and into the atmosphere through the spray process?  In fact, what is the fate of public health if this is sprayed into areas where the public is present?  (Size and strength of spray is an issue also that needs to be considered when calculating agronomic rates of application.  There is one property on Guerneville Rd. by Campobello that uses a gigantic spray that I often see going into the nearby creek and occasionally into the road. It’s and ag field around 3200 Guerneville Rd. on south side of road.)

    While no net loading of nutrients is applied to surface discharge, when the discharge is considered reclamation, the no net discharge does not seem to apply in that monitoring for phosphorus is not required for landscape irrigation (or for endocrine disrupting chemicals either).  Unless there are specific application rates in the reclamation permit, there will be no clear handle to judge compliance and whether anti-degradation standards are being met.

    John Short states that, “The proposed permit is seriously flawed in seemingly creating regulatory standards for reclamation discharges, allowing ground water degradation in certain cases and dismissing potential permit violations due to reclaimed water use while implying the most (if not all) existing reclamation sites do not meet the stated standards.  Discharges (except from future facilities) would not be expected to meet the minimum criteria in the State Recycled Water Policy, the Basin Plan discharge prohibitions and the state anti-degradation policy.  The Board seems to imply that existing reclamation sites are somehow exempt from state policy and only new facilities must comply with minimum standards.”

    The Fact Sheet states on Pages 31 & 32: “…biostimulatory components of discharges from the Laguna Subregional System have a reasonable potential to contribute to and promote excessive aquatic growth occurring within the Laguna de Santa Rosa and are, therefore, contributing to exceedance of the Bain Plan’s narrative water quality objective for biostimulatory substances and the impairment of the Laguna de Santa Rosa. In order to control the level of nutrient discharged to receiving waters, comply with the narrative water quality objective, and prevent additional degradation of beneficial uses, this Order establishes effluent limitations for total nitrogen and total phosphorus.”

    This is followed by a chart that compares typical water quality levels of other water bodies with Santa Rosa’s Total Kjeldahl Nitrogen and Total Phosphate. Other nutrient impaired water bodies averaged 1.06 for Nitrogen and 0.60 for Phosphate.  Santa Rosa’s average reading between September, 2006 and August, 2010 was 1.3 and 2.2 respectively.  That means Santa Rosa’s phosphate readings are almost four times the level of other impaired water bodies and much more than what I believe is normally recommended (.01).  Does this not justify the thorough study of phosphorus for irrigation use and the implementation of VERY stringent measures to prevent all runoff?  DO THE LIMITATIONS NOTED ON TOP OF PAGE F-32 APPLY TO RECLAMATION WASTEWATER?   If so, there should be very few circumstances, and those should be much more specifically defined, where ‘incidental runoff’ should be allowed. And yet the Reclamation Permit fails to specify phosphorus limits to be met and monitored for the Salt & Nutrient Management Plan. The very next section on Aquatic Toxicity goes on to state that  effluent monitoring for nitrate and ammonia.  Why was phosphorus not included?  Why is there no RPA for Phosphorus but there was for ammonia and nitrates? (p. F-39)

    The permit assumes that summer discharges will be negligible based on some anticipated agronomic studies that will occur in the future.  While it is true that the permit can be reopened, as mentioned before, we don’t trust the process if nighttime irrigation is promoted and allowed.  RRWPC photographs of runoff that included pictures of irrigation water running down the drain clearly indicated that it was occurring and when it was occurring (date).  Yet we were told we didn’t have enough information with our photos. (All were clearly identified as to location, time, and temperature).

    The public has the same problem.  We don’t trust that this runoff is benign, is as low an amount as claimed in reports, is monitored and reported in a timely fashion, and is so negligible as to not causing any water quality problems and meets anti-degradation requirements.  If water quality is to be protected, and anti-degradation requirements met, it is critical that specific guidelines be included in the Reclamation Permit that calls for setbacks, preference for drip rather than spray irrigation, (more stringent controls needed for spray), limitations on strength of spray, specific criteria for determining agronomic rates that should be adjusted daily, if not hourly, more regular inspections by irrigating staff, periodic inspections by Regional Board staff, etc.  (In fact, our concerns seem justified by the Chart mentioned above.

    We pose the question: Since no net loading is allowed for regular winter discharges, at what point does that standard apply for summer irrigation runoff, when the nutrient problem is often greatly exacerbated in the Laguna and Russian River?  Further, when we are in a draught period with high temperatures, the nutrient problem can become so great that even a little runoff can become a serious problem, especially in relation to algae, Ludwigia, and other invasive species.  The exact point at which runoff becomes a permit violation is undefined! If this is incorrect, please spell out the specific measurable circumstances where a violation will known to occur.  This is particularly important where nutrients are concerned.

  • Radiological waste:  top of page F-25 states that discharge of radiological waste is prohibited.  Since all such waste has a very long half-life, and since radiological waste is now regularly flushed down toilets, how does treatment plant deal with this?  The waste has to go somewhere, and wherever it goes, it’s radioactive.  I have never heard this addressed anywhere.  How can the public be assured that the treated waste that is sprayed on play areas where the general public recreates is not radioactive?Prior to around 1993, hospitals kept radiated patients in isolation for three days, checked them out with a Geiger counter before they are allowed to leave, and then stored all waste products for least 50 years, etc.  I know this from personal experience since in 1974 I received a radioactive isotope treatment for thyroid cancer. Now hospitals do none of that.  Patients go home or to a hotel or motel while they are radioactive.  Their radioactive waste goes down the toilet.
  • In a similar vein, we are deeply concerned about cancer causing chemotherapy drugs that patients take at home, assimilate in their bodies, and flush down the toilet.  In an article entitled Chemo Drugs Pose Serious Public Health Risks by Frank Carini of ecoRI News Staff (11-19-12) {#11} it states, “About 85% of chemotherapy patients receive their infusions at a hospital or health-care facility.  They are then sent home—typically without warning about the dangers the chemicals that soon will be exiting their bodies can pose to family members and caregivers for the next two to three days…some chemicals used in medical treatments were actually more dangerous than those that are regulated in factories….Pharmaceuticals are nasty, and specifically designed to interact with the human body.”
  • Also, “Of the 212 or so drugs used in various chemo treatments—the first were descendants of mustard gas…These drugs are excreted in active form, in the few days after each chemotherapy infusion….This means that during those two to three days, a patient’s sweat, saliva, vomit, urine, and feces contain quantities of dangerous chemicals.  Anyone who touches these contaminated fluids…..can absorb dangerous amounts of an active cytotoxic drug.”  The article goes on to say there are no regulations to control disposal of these substances.  Generally people are just told to flush everything down the toilet.  In the meantime, the EPA and the FDA each point the finger as being responsible for regulating these dangerous substances.  It is so discouraging that everyone pretends that a few self monitored BMPs by Santa Rosa is going to protect us .
  • Anti-Degradation:  (page F-47): Fact Sheet states:  “The authorized rate of discharge is increased above that of the previous permit, but the rate of discharge authorized to discharge to surface waters has not increased.”  It goes on to state that the increased volumes of water will go to the Geysers and to the Urban Reuse Project.  Once again we challenge that the rate of discharge will increase with summer runoff, unless most stringent requirements are placed in permit to assure that won’t happen.  Some think that past behavior is predictive of future actions.When RRWPC filed complaint on Rohnert Park’s over irrigation practices we discovered that Rohnert Park and Santa Rosa had an agreement that was about 17 years old at the time and had never been enforced.  Supposedly, Santa Rosa had not monitored RP’s irrigation.  We documented a great deal of runoff that was repeated over a period of time.  We never got formal feedback on this by Regional Board staff although we understand there were some changes made.  We really don’t know what is happening now in terms of protecting against irrigation runoff.

    Basically the same thing happened with Santa Rosa’s irrigation last winter when we discovered and documented extensive runoff at a time when there were freezing temperatures and frost on the grass.  We believe that Regional Board and City staff followed up on this, but we don’t know what they did and whether everything has been consistently in compliance now this last summer.

  • Discharge of recycled water, according to Fact Sheet (Page F-48) may result in degradation in ground water from salts and nutrients.  This is expected to be addressed in the Salt and Nutrient Management Plan.  We wonder if buildup of salts in soils, the reason why many vineyard managers are hesitant to use recycled wastewater, will be studied in the Salt and Nutrient management plan? Nonetheless, when a problematic issue comes up around this plan, and the possibility of some degradation is acknowledged, the phrase “maximum benefit to the State” appears to make some degradation equal in importance to increased water supplies.  Six very non-specific goals are then stated to assure that water quality will not be degraded as a result of this project.The Fact Sheet then describes (Page F-50) requirements in the Reclamation Permit that gives terms of this Order.  This includes programmatic  and site-specific technical reports containing hydraulic and nutrient agronomic rates for every new irrigation project that comes on line.  RRWPC believes that ALL reclamation sites should be held responsible for such reports and that the reports should detail the conditions under which irrigation should take place. (John Short addresses this also.)  There should be no irrigation in winter months and/or when the temperature reaches a certain level, say 45 degrees.  (So little water can be soaked up by the ground when cold temperatures prevail, that it’s not worth the energy needed to irrigate.)  Slopes should be considered and setbacks from streams should be required of all irrigators, not just new ones.  Wind, weather forecasts, soil type, saturation, etc. should all be considered no less than on a weekly basis. And types and strengths of sprays should also be addressed.
    • There is so much available about the impacts of low dose exposures to endocrine disrupting chemicals that it is a travesty to ignore it.
    • The length of time it will take to complete and implement the Salt & Nutrient Management Plan and Engineering Study to determine agronomic rates and impacts of salt and nutrients is unreasonable (up to five years).
    • Salt and nutrients should be fully assessed for surface as well as ground waters.
    • Incidental runoff is poorly defined and that will allow a much greater amount of runoff.  Further, it would make it harder to enforce.
    • North Coast Board should review reclamation contract between Rohnert Park and Santa Rosa every two years to ascertain that it is adequate and being fully implemented.
    • All irrigators should be required to have irrigation setbacks of 100’ from streams.
    • Strict application limits should be put on lands where pesticides, manure, and herbicides are applied.
    • Clarify and differentiate application of waste discharge requirements in conjunction with health services policy in regard to irrigation water.
    • Amount of runoff also needs to be linked to flows.  Because of Laguna impairments, numerical standards should be established related to flow AT POINT OF DISCHARGE.
    • All important decisions should involve meaningful public input.
    • Regional Board should spell out BMPs and considerations for developing agronomic rates.
  • Summary and Conclusion:

    Santa Rosa has improved its treatment system greatly over the years.  Nonetheless, we have noticed a pattern of resistance to regulatory enforcement of late.  Santa Rosa has established a presence in State Agencies, committees, etc. and has influenced legislation and Scientific Panel appointments that have sometimes not bode well for the environment.    We sincerely hope that the Regional Board will put water quality first on their list of priorities and always remember that Tertiary wastewater is not potable water and as such, needs to be carefully regulated for all uses.