RRWPC Comments to Regional Board, 9-29-2017: Staff Report for the Russian River Watershed Pathogen TMDL Plan

North Coast Regional Water Quality Control Board
Submitted by Email on September 29, 2017 to: NorthCoast@waterboards.ca.gov
Attention: Alydda Mangelsdorf

RRWPC Comments on: Staff Report for the Action Plan for the Russian River Watershed Pathogen Total Maximum Daily Load (TMDL Plan)

Comments by Brenda Adelman for RRWPC

Thank you for the opportunity to comment on this very important document. We very much appreciate your decision to address the needs of the community in the matter of sewer upgrades through a revision of the earlier version (2015) of this TMDL Plan. We believe you have addressed several important issues raised by the community, including development of a map indicating properties affected by the program, focus on properties that are 600’ from the river bank of the main stem river and also impaired tributaries, development of potential funding sources to assist low income property owners, inclusion of local citizens in the planning process, etc.

We realize that much still needs to be done in regard to implementation of the Plan. RRWPC will attend meetings and stay involved, but our main focus of our comments is to analyze the identified justification for the pathogen TMDL, including the extent and kind of pollution, its identifiable sources, as well as proposed remediation and/or prevention.
While we believe in and support addressing the issue of failing septic systems, we still have problems with some of the TMDL Plan conclusions and hope they can be remedied before final action is taken. We believe that too little information is provided about the origins of other pathogen sources, needed to determine the extent of harm by each source. We do support a program to identify antiquated systems within 600’ of impaired water bodies, and do everything possible to bring out-of-compliance systems up to standard.

We submitted comments on the first version Oct. 8, 2015, and expect that you have those on file. You had requested that those who already submitted comments not duplicate them in this response. Unfortunately, that is very difficult for us, since we feel we have a slightly different perspective now that includes some new information. We also wish to reorganize some of the information presented in 2015. We will do our best to avoid unnecessary duplication.

RRWPC Advocates for Clean Water…
RRWPC has always advocated for clean water. We support the proposed initial assessment of septic systems in the lower Russian River and the plan to have regular inspections that will examine systems every five years. It is well known that many of the systems are past their prime and may not be functioning as they should. We support Regional Board attempts to obtain funding for low income property owners and urge you to see that no one loses their home because of new regulations. We hope funding efforts are successful and we also urge you to look into the possibility of a buy-out program for residences adjacent to the river and in need of major repair. (Apparently Houston had/has a buy-out program funded with a large amount of FEMA funds allocated to avoid future repetitive loss requests.) Is there any reason why you can’t implement a plan to upgrade septic systems near the river or creeks that are in disrepair without having the completed TMDL at this time?

2012 Listing of Russian River Under 303 (d):
The Russian River reach between Fife Creek in Guerneville and Dutch Bill Creek in Monte Rio was listed as impaired in 2012 under 303(d) of Clean Water Act. On page 1-4 of TMDL Plan, it states that river was impaired due to bacteria which probably means ‘pathogens’. We have not seen E. coli data in the last five years that supports the continued listing of that segment. Were pathogens found recently during summer? How many samples, and during which years was the listing based? What would it take to delist impairment? Monte Rio Beach is another 3 miles downstream. There is a summer dam upstream of Guerneville and another one mile down at Vacation Beach. About 30% of the listed reach has conventional sewer services. Guerneville, Vacation Beach and Monte Rio Beach seldom have E. coli exceedances in summer, and generally when they do, they occur only on crowded vacation weekends. Why is there no analysis of the impacts of summer dams and closed mouth conditions on Monte Rio Beach in terms of E. coli exceedances?

We are concerned that bacterial pollution is ephemeral and the conditions under which the listing took place, may not still occur. While the TMDL Plan asserts that the goal of this effort is to protect human health during summer recreation, if septic systems and treatment plants are going to fail, it regularly occurs in winter during heavy rainfall. Is it the intent of this effort to list the entire Russian River as impaired?

Some pollution assessments are inadequate, inaccurate, and/or misleading….
RRWPC’s main concern with this process relates to a number of inadequacies in the Action Plan as we see it, such as:
• This Pathogen TMDL Action Plan is intended to protect those who recreate in summer from disease causing pathogenic exposure, yet by the Plan’s own admission, most pathogen exceedances in the lower Russian River of E. coli occur in winter during rainstorms and saturated conditions. (Winter data is often averaged in with summer data in this Plan, thereby giving the appearance that conditions are worse than they are. Most maps, which seldom give sampling dates, do the same thing.)
http://www.waterboards.ca.gov/bacterialobjectives/docs/draft_staff_report.pdf Also, the State’s Bacteria Provisions Staff Report allows the following (page 9): “The temporary suspension of REC-1 objectives due to high flows would be limited to periods when specific conditions exist that are both unsafe for REC-1 uses and when the objective is temporarily not attainable. The proposal is being considered for fresh waters during extreme high water flows where the REC-1 use is temporarily unattainable. In addition, the temporary seasonal suspensions of REC-1 objectives would be permitted when low flows…..exist due to seasonal fluctuations creating unsafe conditions for REC-1 uses.” This possible provision is not mentioned in the North Coast Plan, but it would make sense when Russian River flows go over 300 cfs or so. High winter flows are a health and safety concern, and I believe that is the level where canoes can no longer be rented. (Canoes do not come under Rec-1, but this serves as an indication that beyond a certain flow, conditions become unsafe in the river.) How is it that the North Coast TMDL Plan takes the position that Rec-1 occurs year-round and needs to be managed for pathogens during the entire year?
• The State only requires monitoring of E. coli in fresh water streams. (Page 6 of Staff Report in above link): “The Bacteria Provisions for fresh waters propose to establish E. coli as the sole indicator organism for bacteria based on U.S. EPA Recreational Water quality Criteria recommendations.” The North Coast TMDL states that Enterococcus and Bacteroides would add another measure of safety because there are occasional false positives with E. coli and Enterococcus. EPA has stated that there are false positives for enterococcus and didn’t mention false positives for E. coli.
Why add the burden and expense of unnecessary testing in this case, when in other cases such as with toxins and other pollutants, it is common for NO monitoring to occur due to trouble and expense? In fact, too many types of monitoring in this case may add confusion rather than provide certainty. Which results will you believe? It’s like going for a second opinion from a doctor. Do you believe the first or the second opinion? In the data I have seen, there have been few instances when E. coli and Enterococcus are exceeding limit at the same time. (One of the peer reviewers suggested that it would be good to consider E. coli, Enterococcus, and Bacteroides in determining health risks, but neither the EPA nor the State Water Resources Control Board thought that was necessary. I assume that the Department of Health Services concurs, so who is right?)
We realize this sounds like we don’t support monitoring. It’s just that the way this Plan has been configured, we don’t think it makes common sense to go through elaborate monitoring efforts, and then only require one contributor (septic systems) to be more accountable then all the rest. The strong emphasis on septic systems is out of balance with other contributing sources in terms of detailed specifications, number of pages devoted to it, and level of scrutiny involved.
• Many pathogenic sources ending up in the lower river cannot be distinguished from those that may be local contributions. How can all sources be identified and quantified for the TMDL? For example, wastewater discharges, irrigation runoff, storm water runoff, recreational use, homeless encampments, etc. can end up in the river and contain pathogens that are separate from leaking septic systems. Redwood trees, of which we are surrounded, are well known to drink up summer runoff from septic systems, so what ends up in the river in summer, may almost always be from another source. How can you identify those? This Action Plan doesn’t inform us.

Page 6-49 of the TMDL Plan has a list of Fecal Waste sources. You should add others, such as sediment deposits containing pathogens, accidental or intentional dumping of items in the river, such as probable spills of raw sewage being trucked long distances under dangerous winter conditions, flooding, mouth closures that back up flow, low flow planned to sustain mouth closures, etc. Also, the Plan discloses that more bacterial contamination has been found in some of the major creeks, yet doesn’t really describe the extent to which this impacts the river.

Wastewater discharge facilities carefully measure bacteria at the end of the treatment chain. They do not currently measure bacteria at the point of discharge. What is known about pathogen regrowth in the ponds? Is there specific monitoring data on this? (We are glad that when it comes up for NPDES Permit review, they will be required by the new permit to monitor bacteria at the point of discharge.)

Similarly, we recall no quantification or discussion of pathogens that attach to sediments and travel to lower river from other locations, and then become roiled up during summer recreation activities. What are the chances for bacterial exceedances resulting from Santa Rosa’s discharges last winter of 1.1 billion gallons?
• Forested areas are the land use found in the TMDL Plan to have the least amount of bacterial pollution. The lower river is dominated by forests which, in all likelihood, soak up septic waste in summer, yet this is not acknowledged or discussed in this Action Plan. Might that explain why there are relatively few exceedances of E. coli and Enterococcus in summer?
• The Microbial Analysis (May 1, 2014 Final Report Eric Dubinsky and Gary Andersen of Lawrence Berkeley National Laboratory) entitled: “Russian River Human Impact Study PhyloChip Microbial Community Analysis”,
https://www.waterboars.ca.gov/northcoast/water_issues/programs/tmdls/russian_river/pdf/140606/russian_river_human_impact_study_phylochip_microbial_community_analysis.pdf states that in summer, tributaries have more bacterial pollution than the main stem Russian River. What could explain this? Do small stream size and low flow levels contribute to pathogen pollution? If so, how would pathogen pollution from lowered summer flows (as per Biological Opinion), should it occur, impact this problem in the lower river? Also, eventually that pollution flows to the main stem. What happens then?
Similarly, Rich Holmer stated at the September 20th meeting that on busy weekends in summer, pathogen exceedances occurred the weekend the river mouth was closed, and did not occur the weekend when a similar number of people were present, but the mouth was open (in Monte Rio). Public Health and Water Agency have the monitoring data on bacterial pollution and SCWA has data on mouth closures going back to 1995. Can this be analyzed, in combination with flow data (SCWA) for the TMDL? Obviously, one observation is not enough to draw a scientific conclusion.

In the Beach Recreational Impact study, https://www.waterboards.ca.gov/northcoast/water_issues/programs/tmdls/russian_river/pdf/131126/Russian_River_Beach_Recreation_Impact_Study_Report_Nov2013.pdf , it stated that Monte Rio flows were not measured for the first study in 2012 due to tidal influence. In that earlier Beach Recreation Impact Study of November, 2012, they conducted an initial study of recreational impacts on bacterial pollution and discovered that stream hydrology changed significantly without warning after removal of the seasonal dam at Vacation Beach. For that and other reasons, they had to redo study the following year. It seems as though the combination of low flow, vacation dams, and mouth closures may contribute to bacterial problems at Monte Rio Beach rather than failing septic systems.

To further document evidence of a lack of bacterial pollution: Looking at page 4-7 of the Action Plan, Table 4.2 indicates that of 52, 30-day sample periods taken for E. coli bacteria between 2001 and 2013, at Steelhead Beach only 1 period was out of compliance (2%). None were out of compliance at Hacienda Bridge, Johnson’s Beach, Casini Ranch Campground and Dutch Bill Creek. At Monte Rio, with the highest count, 5 of 61 sample periods were out of compliance with current regulations (8.2% of samples). At Duncans Mills, immediately downstream of Casini’s, there was one period not in compliance out of 12 periods studied (8.3%). Apart from Monte Rio, there hardly seems to be a problem. How can this describe a water body in need of a pathogen TMDL?
• We continue to be confused about the ‘verification’ of human source pollution with bacteroides, which, according to our understanding, is a bacterial source and not a reliable pathogen indicator. If the E. coli seldom shows up in areas with bacteria (i.e., lower river beaches), how can you deduce that pathogens are present based on bacteroides? How can bacteroides be a deciding factor in circumstances where existing pathogens do not exceed limits? In an Informational Document from the State Water Board for the Public Scoping Meeting for Proposed Statewide Water Contact Recreation Bacteria Objectives Amendments to Water quality Control Plans for Inland Surface Waters…” dated January 7, 2015, http://www.waterboards.ca.gov/bacterialobjectives/docs/information_doc_bacteria_objectives.pdf it states on page 3: while they recommend the use of E. coli and Enterococcus for pathogen indicator, it also states: “Studies have also found that while enterococci acts as a good indicator in some fresh waters, it can exist and multiply in other fresh waters and create false positives in samples. E. coli has been found to be the most reliable indicator organism in all fresh waters.”
• Also, why is there no analysis of the impact of floods, similar to urban runoff, as that has to be a huge source of pathogens in winter? We assume there is no way to differentiate the various sources in that situation or any way of telling where the pathogens end up. Could PhyloChip analysis help, even though very expensive?
• Another issue is discarded garbage in the river (Homeless are mentioned, but recreational users and fishermen could also be responsible.). To what extent can pathogens reside in discarded products? While there have been some great river clean ups and this may no longer be a major concern, it’s something that can always become a future problem again.

So what this all boils down to is: at any given time, how can you tell where the pollution comes from and the amounts dispersed? How can you assume waste comes from septic systems since there are so many sources of human caused pathogens? Furthermore, it appears that the Agency has given up on source quantifications and allocations for the TMDL; aren’t those allocations the whole point of the Program? (**See Note immediately below)

(**Note: I have a partial document that appears to be from your agency that starts on page 5 and is identified as “File: Russian River TMDL September 30, 2013”. On Page 5 it lists some findings that includes the following: “Enterococcus bacteria appear to exceed the BAV load more often than E. coli bacteria….. No reduction in E. coli bacteria load is needed at any location in the main stem Russian River. However, the tributaries (Laguna de Santa Rosa and Santa Rosa Creek) show an increasing need for E. coli load reductions with higher flows. The higher E. coli bacteria loads associated with higher flows likely come from nonpoint sources that mobilize and are transported during storm events.”

On page 9 there is a chart labeled “Table 4. Load Reductions Needed to Meet the E. coli Bacteria Beach Action Values” On top it lists categories: low flows, dry conditions, mid-range flows, wet conditions, and high flows. The names of 15 lower river beaches appears on the left column under location. Under low flow category the following reductions are noted: Hacienda Bridge: 91%, Forestville Access Beach: 93%, Steelhead Beach: 95%, Healdsburg Memorial Beach: 52%, Camp Rose Beach: 31%, Laguna de Santa Rosa: 0%, and Mark West Creek: 98%. But for the following, all the other categories for all beaches was 0%. Laguna de Santa Rosa: dry conditions: 94%, Mid-range flows: 97%, Wet conditions: 99%, high flows: 99.5%. Mark West Creek: low flows: 98%, dry conditions: 69%. Santa Rosa Creek at Railroad St.: dry conditions: 94%, mid-range flows: 97%, wet conditions: 99%, and high flows: 95%. This indicates huge impairment in the Laguna de Santa Rosa and Mark West Creek. Then this goes into the Russian River at Forestville where pathogens are also very high. When it all merges together like that, how can you figure out where it really came from? In some of the agricultural areas, even the bacteroides are very high.

I’m not sure I understand all the many implications of this information, but I would love to see the rest of this document and I wonder why it didn’t seem to be referenced in the new version of the Action Plan. Did I miss it? It did seem to verify that in most locations, that E. coli was not a problem. Another chart noted that Enterococcus was a little more of a problem, especially at Johnson’s Beach. I know that the latter had about 14 exceedances of the latter in 2009. The current version of the document just gives a brief one paragraph summary of the information on page 7-3 and included no charts or graphs.)

Important PhyloChip study fails to reveal significant OWTS pollution…
The following study was commissioned by the Regional Board in 2014, entitled: “Russian River Human Impact Study: PhyloChip Microbial Community Analysis” (ibid. see above) Scientists conducted site variability studies (of microbial source identification), land use variability, recreational beach use, and effects of onsite wastewater treatment systems (septic). There are numerous conclusions and interpretations that seem to support our own assessment.

The first paragraph of the Introduction states: “Currently there is insufficient understanding concerning the composition of the overall microbial population (microbiome) and variation therein to accurately assess the risk to the bathing public from the presence of pathogens using the current indicator organism methodology. This lack of understanding and other issues also make it difficult to assess the effectiveness of pathogen reduction by pollution control projects.” (emphasis added) This is a serious allegation and makes one wonder about the validity of this entire project. What is the “current indicator organism methodology” they are referring to? Could it be the same things I write about on prior pages?

Then again, “A major problem facing the regulators is that there is lack of information regarding the microbial ecology of recreational waters, especially from non-point source pollution.” They then specify a lack of adequate information on storm water or sewage treatment plant outfalls. And further: “Current indicator bacteria tests do not identify the potential sources for these bacteria, thus making it impossible to ascertain the source of pathogen indicator bacteria causing exceedance of water quality objectives.” (emphasis added)

On page 20 in the section on Effects of Onsite Wastewater Treatment Systems it summarizes by stating that “Wet periods have strong effect on the bacterial community at Russian River beaches in the lower watershed and on creeks in all land use types…..Recreational beach use was also associated with human fecal signal. The inconsistency of conventional fecal indicator tests in detecting these risks warrants further investigation.” (one of our major concerns-emphasis added)
Regarding Site Variability it says:
• “No fecal signal was found in any dry period samples collected from the Russian River.”
• In wet period samples, “Traditional fecal indicator tests did not exceed water quality limits…at Johnson’s Beach and Monte Rio Beach…..” (We believe that this would change when soils are saturated and needs to be studied.)
• “Dry period samples from tributaries in impaired watersheds contained a greater variety of taxa than the Russian River… In the wet period, Green Valley Creek, Santa Rosa Creek, and Laguna de Santa Rosa exceeded all fecal indicator tests but contained low numbers of diagnostic fecal bacteria.” (What is diagnostic fecal bacteria? How does that differ from diagnostic fecal bacteria?)
Regarding Land Use Variability it says:
• Land use showed no significant effects on composition or structure of bacterial communities. All land uses contained greater amounts of bacteria in wet periods than dry for all land use types and associated with high counts of fecal indicator bacteria.
• Only one location showed human fecal signal in dry period, yet during wet periods, high fecal counts in areas with onsite septic systems during wet period were not associated with a human fecal signal. (Does this mean that the high fecal counts didn’t come from septics?)
Recreational Beach Use states:
• Johnson’s Beach had a human fecal signal at end of monitoring period that marginally exceeded limit for enterococcus. E. coli was below concentration limit. No indication of human fecal signal in samples from Monte Rio Beach. (emphasis added)
Effects of OWTS:
• Conclusion: “No sites in areas with both high parcel density and high septic risk contained evidence of human fecal signal in spite of high numbers of fecal indicator bacteria.” Emphasis added. Does this conflict with information in TMDL Plan?
• “There were no trends in bacterial communities associated with samples that exceeded concentration limits of Enterococcus fecal indicators but had low concentrations of E. coli fecal indicators.”
• Wet periods have strong effect on the bacterial community at Russian River beaches in the lower watershed and on creeks in all land use types.” Most risk occurs in wet weather with possible risk at lower river beaches.
• “Recreational beach use was also associated with human fecal signal. The inconsistency of conventional fecal indicator tests in detecting these risks warrants further investigation.” (I thought fecal indicators were present during periods of high use. What is the fecal signal referred to? How does it differ from fecal indicators?)
Could the information above, along with conclusions drawn by scientists, prevent the overall listing of the Russian River as impaired under 303(d) for pathogens at this time? It seems as though the evidence for contamination risk at lower main stem beaches in summer during off weekdays and most weekends, is very weak and/or confused at best. The analysis on pages 4-21 through 23 don’t identify when the Regional Board samples were taken (summer or winter?) so it’s hard to know the significance for recreation. Nevertheless, the current Action Plan seems to merge summer and winter on all/most maps/graphs and text in order to show high pathogen counts for the sake of the listing. We don’t think this is fair.
Regional Board Recreation Impact Study…
The Regional Board completed an earlier Beach Recreation Impact Study Report that was released in November, 2013 and was based on monitoring that previous summer Healdsburg (Memorial Beach) and Monte Rio Beaches. https://www.waterboards.ca.gov/northcoast/water_issues/programs/tmdls/russian_river/pdf/131126/Russian_River_Beach_Recreation_Impact_Study_Report_Nov2013.pdf

Samples were taken for a week between July 2nd through July 9th between 12 and 4 pm when recreation assumed to be the highest.
Some conclusions were as follows:
• Sampling variability similar at both beaches for Enterococcus and for all Bacteroides
• Also much higher concentrations of E. coli and Enterococcus observed on July 2nd at Monte Rio and July 4th at Healdsburg compared to other days in sampling period
• Significantly higher bacteroides concentrations observed on July 3rd at Monte Rio and July 5th & 6th at Healdsburg compared to other days during sampling period
• Significantly higher E. coli and Enterococcus concentrations were followed the next day by significantly higher Bacteroides concentrations at both beaches
• Swimming recreation and number of people on shore were much higher on July 4th at both beaches
• Enterococcus concentrations measured at Monte Rio showed relatively strong association with Estuary water surface elevations, high concentrations with higher water surface elevations
Monte Rio:
• E. coli, Enterococcus, and Bacteroides all high on July 2nd and 3rd
• E. coli, Enterococcus and Bacteroides all low on July 8th and 9th
• Monte Rio exceedances: E. coli normal on July 2nd, but on June 25th & 27th it was 609 and 355 respectively.
Given the findings in both studies, it appears safe to conclude that summer recreation on beaches is probably responsible for all or most pathogenic bacteria contamination. That, taken with the evidence that most septic systems that fail, do so in wet, rainy periods rather than the dry season, makes us wonder how failing septic systems cause illness to people recreating in summer on beaches?

Can TMDL requirements be met in this Plan?
Definition of a TMDL according to US EPA in their document: “Program Overview: Total Maximum Daily Loads (TMDL)”: “The objective of a TMDL is to determine the loading capacity of the waterbody and to allocate that load among different pollutant sources so that the appropriate control actions can be taken and water quality standards achieved. The TMDL process is important for improving water quality because it serves as a link in the chain between water quality standards and implementation of control actions designed to attain those standards.” (emphasis added) We assume that the total loading limit is represented by the objectives for E. coli and Enterococcus. But do they bioaccumulate? If each discharger of pathogens is allowed the same loading limit, don’t those contributions accumulate? It’s not clear how this will work.
According to the he contents of a TMDL should include:
• Identification of waterbody, pollutant of concern, pollutant sources & priority ranking**
• Applicable WQS and numeric water quality target**
• Loading capacity**
• Load allocations and waste load allocations**
• Margin of safety
• Consideration of seasonal variations**
• Reasonable assurance for PS/NPS
• Monitoring plan to track TMDL effectiveness
• Implementation plan
• Public participation

RRWPC is most concerned about understanding those with asterisks (**). We cannot address those topics in regard to all the contributors of pathogens to the lower river. We do have a lot of experience regarding landscape irrigation with wastewater however, and want to use former writings to indicate the kinds of information that could have been obtained or was not considered. As the attached RRWPC writings indicate, Regional Board has not attempted to address any of the above topics during the Subregional Reclamation System’s reclamation permit renewal process. Bacteria was not an issue at the time. There was enough information available so that much could have been assessed at the time to deal with this issue. The lack of a good definition of INCIDENTAL RUNOFF allowed all kinds of summer wastewater discharges into the badly impaired Laguna de Santa Rosa.

The Waste Load allocations given on page 7-2 appear to state that the standard to be met in the future is the same as a waste load allocation to be applied to all of the different contributors. But most of the contributors have never been monitored so you really don’t know the starting point. You don’t know how much they have to reduce in order to come into compliance. That seems to imply that you are shooting in the dark in terms of BMPs, which the Plan seems to prefer in terms of implementation. There would have to be very timely monitoring and reporting if these end results are to be enforced. This would be especially difficult for nonpoint sources of discharge that must begin to sample at least weekly. It is very difficult to see how this will all work out in real life.

Waste Load Allocations for irrigated wastewater….
Since we know the most about this topic, here are our concerns about meeting requirements.
How does the TMDL program work for something like summer landscape irrigation? With wastewater discharges, Subregional system will be required to monitor at the point of discharge (from storage pond to creek), rather than at the point of completed disinfection treatment at the plant. Regrowth can occur at the storage pond, and it can probably also occur in the pipes that travel to the landscape area. Is that correct? There are ways of estimating how much wastewater runs off. I wrote about all this in detail for the Subregional Reclamation System’s last permit.

RRWPC witnessed so much “incidental” irrigation that consistently occurred. It was NOT incidental. It was constant, repetitive, conscious, unaddressed, excessive, etc.

We state in our Dec. 3, 2013, comments to Regional Board concerns about recycled water requirements: (Link: RRWPC Comments on Waste Discharge Requirements and Master Reclamation Permit for the City of SR Subregional Water Reclamation System, Sonoma County, December 3, 2012

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. 

Here are links to short documents giving detailed information on examples of runoff:
RRWPC ADDENDUM: Waste Discharge Requirements and Master Reclamation Permit for the City of SR Subregional Water Reclamation System, Sonoma County, July 22, 2013

RRWPC Addendum #2: Waste Discharge Requirements and Master Reclamation Permit for the City of Santa Rosa, 11-21-2013

RRWPC also filed a complaint around 2010 or 2011 and submitted many pictures of excessive irrigation, including many examples of runoff into storm drains. There are at least 200 photos in your office giving evidence to the problem. Whatever was done about it, I never learned, other than to hear that irrigation was to take place at night when I couldn’t see it.

I found Rohnert Park to be much worse than Santa Rosa, who I think corrected all or most of their problems. In fact, at the permit hearing, Rohnert Park staff was laughing and joking about how much wastewater they irrigate on landscapes each summer. No one ever talked about bacteria at the time and it was assumed that if it was okay at the end of the disinfection treatment, it was okay for spreading on parks and schools where children walk and play.

Here are some of the things we saw that need to be corrected:
• Sprays are usually too strong and uncontrolled and went on far beyond the saturation point and was often spread through the air catching people in the face if they didn’t duck.
• We watched wastewater going down the drain in summer (and took pictures) and had no idea how much time went by as that occurred.
• We watched sprays going into the street and sidewalk areas and down slopes to streets.
• We reported this and little happened that we were aware of (Santa Rosa gradually got better, but we continued to see runoff in Rohnert Park for quite some time. Much of the irrigation moved to the nighttime and we had to stop monitoring the situation because of that.)

Here’s one more document belonging to that group:
RRWPC Comments on Waste Discharge Requirements and Master Reclamation Permit for the City of SR Subregional Water Reclamation System, Sonoma County, July 22, 2013

We will end here. Thank you for the opportunity to comment.

Brenda Adelman