August 2013, Newsletter: Santa Rosa Wastewater Discharge Meeting


It feels like summer is passing us by at the speed of light!   But for one very hot week, the weather has been as good as it gets.  Locally the river has been running low, but not totally diminished, and people seem to be having a good time. And RRWPC continues our watchful eyes on new regulatory actions that will impact the river’s future health.

Saga of Santa Rosa’s wastewater discharges continues into 28th year …..

Recently the North Coast Regional Board released Santa Rosa’s revised discharge and reclamation permits for public comment. The permits regulate treated wastewater discharges into Laguna tributaries during winter and also wastewater irrigation practices occurring mostly in summer.  Since the Geysers Project came on line in late 2004, very little has been discharged into the Russian River during winter season.

Wastewater irrigation is really a discharge…..

We have written extensively on the State Water Board’s decision in 2009 to ease water shortages by promoting widespread reuse of treated wastewater for irrigation purposes.  This translates into about 2.3 billion gallons of Santa Rosa’s treated wastewater applied in summer to urban areas by both Santa Rosa and Rohnert Park. The irrigated wastewater represents about a third of Santa Rosa’s annual total and contains many unregulated chemicals and compounds that can pollute our creeks.

This irrigated wastewater is intended to stay on land and allow it to be taken up by crops or evaporated into the atmosphere, but for occasional small amounts that accidentally escape.  Yet there is significant evidence (especially in Rohnert Park) that a substantial amount of runoff, poorly monitored and inadequately controlled, ends up in our water quality impaired tributary streams and then empties into the Russian River.

For instance, Cotati/RP School District irrigated 47,660,146 gallons in 2012 on 77 acres (618,963 gallons per acre) and reported only 4 spills for a total of 20 gallons. The Denner property (agricultural) irrigated 485,418 gallons per acre that same year and was paid to use the wastewater, yet applied 25% less wastewater per acre than the school district. Mountain Shadows Apartments in Rohnert Park irrigates two acres at almost a million gallons an acre to water their urban parcel and claimed 4 spills for 40 gallons in 2011.

Important permit hearing on August 22nd…..(This meeting has been changed to November 21, 2013.

On August 22nd, 2013, the Regional Board will review Santa Rosa’s discharge permit which includes the “Reclamation Permit” that regulates irrigation. (Call 576-2220 for agenda details.) This permit supposedly assures that spills will be incidental and beneficial uses will be protected.  RRWPC has found that the permit is strong in requirements, but very weak in monitoring, direction in specific best management practices to prevent runoff, and almost totally lacking in regulatory follow-up.

In reality spills are only dealt with when observed and reported.  Since irrigation monitoring is required monthly, that leaves 29 or 30 days where irrigation can be happening out of view.  Also, there is little or no investigative work by regulators to assure that operations are reasonable and proper and according to the law. While there is some clarity in the definition of incidental runoff, there are few specific management tools to assure runoff is regularly avoided. If spills are happening and go unobserved and unreported, they must not exist as far as regulators are concerned. The system relies on self reporting.  In other words, the fox is guarding the chicken house.

The Regional Board oversees compliance with the Permit, but relies on affidavits from Santa Rosa officials to certify report accuracy.  The responsible staff sign off based on reports from their lead staff.  It is unclear whether lead staff actually go on site regularly and check irrigation practices directly.  At each site there is an authorized person in charge, who signs off on reports saying no, (or some) spills have occurred. But that person may not have been present when problems occurred (if any did), since it was probably a workman or landscape contractor who actually implemented the irrigation.

RRWPC comments on Draft Reclamation Permit…..

RRWPC permit comments (see focused on allegations of extensive over-irrigation of wastewater on Rohnert Park properties, the large number of repeat offenders, the lack of detail in their reporting,  inadequate oversight, and overall seeming lack of concern for preventing discharges into our streams in the summer time.

In 2010, after two formal complaints of over-irrigation in Rohnert Park had been filed with Regional Board, it was determined that all 20 of RP’s irrigation sites should be monitored daily. In an unprecedented effort, monitoring was conducted for 14 consecutive days of all RP sites, during which time 129 overflow instances were noted. If extrapolated for the whole summer, we are talking about very significant numbers.  Yet the Reclamation Permit appears to call for only monthly monitoring of irrigation sites so most of these incidences would have been missed under normal circumstances.

Irrigating urban parcels without causing runoff is extremely problematic under the best of conditions, since most sites contain major amounts of impervious surfaces, as opposed to agricultural areas in large open spaces.  The permit allows for incidental runoff only when very minimal, occasional, and clearly accidental.  The sites monitored above were repeat offenders with some over irrigating on over half of those 14 days.

Clearly the monitoring should be far more extensive if runoff events are to be managed in the way promised.  Other management options would be to require low pressure sprays or drip irrigation, setbacks of at least 100 feet from creeks and waterways and 25 feet from streets, driveways, sidewalks and other impervious surfaces.  Penalties and fines should be heavy for repeat offenders and source of recycled irrigation water should be shut down  for anyone over-irrigating three times or more in a season.  In addition, agronomic rates should be required to be calculated on a frequent basis.

Estuary Project Update…….

Still nothing happening with the Estuary Project.  The river mouth was closed most of June and has been open most of July.  We’ve heard that the Water Agency is still waiting for some of their permits.  Storage in Lake Mendocino has stayed comfortably over the storage curve so flows have not gone down as low as we feared.  Unless we have another super hot spell, it looks like we may make it through this summer avoiding super low flows (below 80 cfs at Hacienda).  Cross your fingers!

RRWPC needs your help…..

RRWPC is in need of donations of any size for mailers and other expenses. Please give as generously as you can, especially if you have not given in awhile. (month & year of last donation is on envelope).  If it’s been for a long time, we hope to hear from you soon.

Also, please pass this information on to other interested parties. It is especially important that you mail the target letter! (The target letter is also on our website at if you need another copy or want to pass it around.) Thank you for your support!