Proposed bacteria regulations may impact river housing…..Reassuring words from Regional Board Staff during the meeting in Monte Rio on September 22nd, went something like this, “No one will lose their home because of new septic regulations meant to protect the health of those who recreate in the river.”
But why did few people in the audience believe these words? While the regulators’ goal was not meant to remove people from their homes, proposed standards aim to keep all bacteria out of the Russian River but for those contributed by wild animals, probably an impossible standard to meet. Regarding the funding of this task, while the agency provided a list of potential funders for septic replacement and repair, low-income homeowners know it’s very difficult to actually obtain those funds without obligating themselves to major debt.
At that same meeting, concerned citizens pleaded with Regional Board staff for a map designating high priority areas. They were told it wouldn’t be provided. So far it is unknown who will be most affected by new rules, no idea of what individual septic improvements might be required, let alone what they might cost. While officials claim that the Russian River County Sanitation District causes as much pollution as septic systems, nevertheless hooking up is considered an option for some.
But we all want a clean river, free of disease causing bacteria, and we want to affordably fix those infrastructure problems that are REALLY broken and causing harm, while not forcing unnecessary regulations on those whose plumbing hardware causes no problem. Programs are needed to identify which systems are allowing pathogens to reach the waterway. The broad approach where everyone is ‘guilty until proven innocent’, is not fair to those who have invested over the years in maintaining their systems.
County speaks out…..In what may be an unprecedented action, the County sent a strongly worded comment letter to the Regional Board recently lambasting them about this project. They objected to the very short duration of the comment period (already closed after only 90 days although staff took over five years to develop report); they objected to the lack of adequate notice to the people in high priority areas (including most of the lower river and Healdsburg area); they objected to being targeted as the agency to oversee ALL current septic systems, which has never before been their charge, they had concerns about being held solely responsible for finding remedies for the homeless population, and finally, they stated that potential costs to homeowners could cause them to lose their homes.
As already indicated, there are numerous contradictions in the Draft Staff Report for the Russian River Watershed Pathogen Indicator Bacteria Total Maximum Daily Load (TMDL). (Draft Report) This is the 345 page document released late last August, establishing complex new requirements aimed at assuring that there are no pathogens above natural background levels in the Russian River and its tributaries. The comment period has already closed, although Russian River Watershed Protection Committee is challenging a similar situation on a previous major permit approval in the belief that written comments should be accepted up until the close of the public hearing, whether or not staff can reply to them. By cutting off public comment and by allowing inadequate time for comments, both written and oral, Board members are demonstrating that they don’t care about the needs of the community.
What is even more egregious, as soon as the TMDL is approved, the Report states that it will then sit on a shelf until the State Board completes their review of Bacteria standards, which they expect to be changed. They will do this so they won’t have to change the document more than once after regulations are revised by the State. In other words, they are rushing the public in the expectation they will then stop the process. If this concerns you, please attend the Regional Board hearing on Nov. 19, 2015 in Santa Rosa. Call (707) 576-2220 for the agenda. Also, there is a letter you can download, sign, and send before that date at RRWPC website at www.rrwpc.org. Please help pass the word.
What is staff report about? The staff report is a culmination of many years of tracking pathogen indicators in order to identify and control bacterial and other disease causing organisms. The validity of various indicators has changed over the years and, since 1986, ‘total coliform’ and ‘fecal coliform’ data samples have been discredited by EPA. Yet even now, official Health Department data continues to utilize discredited indicators, including recent samples, and irregularly collects those that are currently favored (E. coli and enterococcus). This causes inconsistency in data analysis and reliability. The Regional Board’s charge is to determine, through the TMDL process, as defined by the Clean Water Act (federal) and the Porter-Cologne Act (State), whether the pathogen load is excessive, where it is coming from, and how to assign loading limits to identified contributors.
Identified sources of pollutants…Through extensive data analysis, Regional Board Staff identified contributors to the problem, including homeless encampments, centralized wastewater treatment facilities, septic systems, storm water runoff, wild animal waste, pet waste, agriculture, livestock waste, forestlands, and more. The Draft Report attempts to calculate excessive amounts of bacterial contamination, determine roughly where they are coming from, and describe possible ways to limit human exposure. They admit their tasks are not complete, but it is unclear what public participation will be allowed once this is approved. Timeline requirements of new septic regulations (AB 885) may be driving this train.
Interestingly, the Report verified that runoff from forestlands had the least amount of fecal indicator bacteria even though Guerneville area was noted has having a high level of contamination in spite of all our trees and our sewer system. They don’t consider the role our forests play in drinking up septic water, especially in a drought. That latter could explain much lower levels of river bacteria in summer, which is the recreation season and of greatest concern. In fact, page 5-9 of the document indicates that Russian River Fecal Indicator Bacteria during dry periods is within acceptable limits in forestlands. Based on evidence we have seen, that appears to be the case, yet the document targets our area as one of the most problematic.
Repeatedly the assertion is made that all bacteria have statistically significant higher concentrations in wet periods, yet Report also stated wet and dry periods in developed areas had the same concentrations. Report lumped together Monte Rio, Guerneville, Rio Nido, and Forestville in their analysis of fecal coliform, without explaining why a sewered area had as many pathogens as septic areas. Furthermore, while report admitted that highest concentrations of pathogens occur in winter, they didn’t clarify whether winter pathogens (possibly coming from Santa Rosa) might be causing problems in lower river during summer.
This Report still needs a lot of work in our view. Please send letters to Regional Board staff as posted at www.rrwpc.org