RRWPC Comments on THP #1-20-00084-SON, 9/28/2020

Forest Practice Program Manager


135 Ridgway Ave.

Santa Rosa, CA 95401


RE:  Silver Estates THP #1-20-00084-SON

First: we apologize for not submitting this letter by the Sept. 5th deadline.  Between mandatory eviction orders due to the Walbridge Fire and COVID precautions that presented severe disruptions in our lives, I was unable to obtain the information needed to write this letter in a timely manner. In the meantime, I heard there was an extension for comments because of the fires, but never learned the final date, so I hope these comments will be accepted and responded to.

 Brief History of RRCSD Irrigation:

RRWPC has been tracking water quantity and quality issues in the lower Russian River for 40 years, with a special focus on wastewater treatment and discharge.  While we are neither scientists nor legal experts, we have studied wastewater issues all that time and have accumulated a vast array of reports, studies, and presentations from experts on these issues.  We are a nonprofit public benefit organization incorporated in the State of California, and our supporters include property and business owners, nature lovers, summer home owners, and many other concerned citizens in the lower river area from Healdsburg to Jenner.

RRWPC supporters and activists utilize the Russian River for recreation and/or tourism, for fishing, swimming, for artistic expression, spiritual wellbeing, for exercise and personal health of ourselves, family, friends and pets, and for replenishment of health and energy needed to balance out the stresses of modern day life.  Because of its proximity to Bay Area urban centers, the beautiful and peaceful lower Russian River is easy to access and allows a natural refuge from every day cares.

RRWPC was born of citizen concern for the development of our Russian River County Sanitation District, its collection and distribution system, its irrigation system, it storage and discharge, and all combining to serve as the  wastewater treatment facility.  The District has a 100 year contract with the property owners to use their property (the Silver property, owned by the Burch family) for summertime irrigation of wastewater (May 15th through October 1st).  RRCSD utilizes the lower property and sections of the upper for their irrigation.  I do not know the precise location of their upper irrigation area although judging by the information I have read in the THP, at least some of the harvest will be in the upper areas used for irrigation.

Originally the Northwood golf course was expected to apply two thirds of the wastewater generated in the summer time to their property since river discharges of treated wastewater were not allowed between May 15th through October 1st of each year.  It was soon discovered however, that the golf course could only absorb about half of that amount, and the property on which the treatment plant was situated would have to absorb the rest.  There were runoff and ponding problems with the system and the lower portion was often over saturated.  Redwood trees suffered and illegal runoff caused water quality problems for the Russian River through the discharge of pathogens and nutrients.  In at least one case, the groundwater was contaminated and operations needed to be altered to address this issue.

Over the years these problems were mostly resolved through system upgrades, but summer treatment capacity continues to be limited and there is a need to prevent further problems.  While the system appears to serve the current summer population, treatment capacity is still limited by inadequate irrigation areas.   Severe winter flooding issues also plague the system and we are concerned that this timber harvest project could exacerbate the problems.

RRWPC has numerous concerns about this project which we hope can be addressed.  Some of these are directly related to the wastewater treatment system and some related to more general community impacts.

Need for traffic review:

If giant timber trucks and bulldozers and other heavy equipment are going to traverse Neeley, there needs to be a traffic study to address the impacts on the local population. Will this be provided?  In many places the road is extremely narrow with blind curves and there are questions about whether two large trucks can pass one another safely in all places without doing damage to themselves or local property.  This road would need to be shared between RRCSD trucks and heavy equipment along with local residents.  (Neeley Road dead ends at the Treatment Plant.  Have these issues been addressed in THP documents?)

We are concerned that this project could make ingress and egress on this local limited roadway more difficult and cause problems in places that could impact the Russian River. In February of 1998, a major slide occurred at the plant which caused serious problems, and at various times, there have been significant slides along Neeley Rd. that had great  impacts on local residents, since in winter that road is the only ingress and egress to and from their properties.  While the THP provides criteria for choosing harvest sites, in most cases I didn’t see where they also considered potential conflicts with public road use by the District and residents of the area.  We believe there is need of traffic review that provides some kind of consideration for sharing use of this deteriorating road by large trucks and other vehicles.  (It is unclear whether slides on Neeley Road could affect the Russian River, but if slides might be generated by the project, and could reach the river, we would like to know what impacts it might have.  Similarly if such an event impacts local homes, it should be addressed as well.)

There is a back road leading over the hill from the Treatment Plant to Highway 116 that was unpassable for a long time due to slides and think it is now planned to also use this road for timber harvest operations.  What kind of coordination would occur between timber use and treatment plant use for limited roadway?  Who’s responsible for potential damage to the road and surrounding environment?  Would the plant operation be prohibited from using roads needed for the timber harvest?  Has there been any coordination with this?

There are parking issues in some segments of this road.  Will people be able to continue to park their cars safely and not worry about additional traffic and adequate passing room?  In summer there are many people, including children, who come up to recreate and often walk along the side of the road, due to a lack of sidewalks.  What care will be taken to assure their safety at all times?  Also, while they will not work in the rain, the ground may be wet and slippery for days afterwards as runoff comes down the hillsides.  How do you determine when it’s too wet to work and/or when conditions are safe?

Fire risk of logged properties:

We know that Cal Fire is having the worst fire season of their entire history, and still has two months to go. Sonoma County has accounted for numerous major fires over the last three years.  While the THP claims that taking large trees and leaving the shrubs and small trees (some of which would be poisoned with herbicides and left to die) is a good fire prevention tactic, we have heard many experts state the opposite.  In fact, we have learned that some Native Americans, with very good result, regularly set fire to brush, ground cover and small trees, and do so successfully, leaving the big trees to reduce carbon, provide shade to cool the creeks, and other environmental benefits.

Most environmentalists I have spoken with agree that what burned in recent major fires in our area, was the ground cover, and generally NOT so much the large trees. (Of course some large trees met their demise, but usually not the old redwoods.) Yet it is clear that harvesting large trees (redwoods and Doug firs) is the intent of this harvest, since the owner’s exclusive interest is really for the trees’ monetary value.  To be told that taking the large giants is good for the environment is not believed by the community however.


Given that global warming provides the likelihood that vegetation will dry up more than previously, and if ground cover and small trees are left while the large trees are taken, and given that this is a residential neighborhood, it is important that this project be carefully analyzed to address these concerns.  What is the increased fire risk to local residents if years of collected dead ground cover catch fire and then move much more quickly uphill where only small vegetation exists?  What is the risk to potential loss of property?  What is the risk to the river from pollution carrying sediment runoff and potential landslides in almost bare areas? What are the risks to local traffic from greatly increased use of Neeley Road by big trucks?  And finally, what is the risk to the functioning of RRCSD’s future operations as a result of potential impacts?

This project is planned to take place over the next seven years and there may be many opportunities for harm, especially as global warming heats up further and the remaining vegetation becomes more fire prone.  (We are further concerned is that once the project is approved and things are up and running, enforcement of promised constraints will fall by the wayside.  How is this project being monitored?)


RRCSD Hazard Mitigation Plan expresses concern about fire potential

The Russian River County Sanitation District (RRCSD) Local Hazard Mitigation Plan (April 16, 2018, lists three potential fire hazard related issues that don’t seem to be considered in the THP.   They are as follows  (page 47):

  1. Access to RRCSD Facilities may become difficult for maintenance and fire suppression.
  2. Wildfires could cause landslides as a secondary natural hazard, which can induce additional sediment loading with potential risk to facilities.
  3. Critical facilities in the planning area are at risk and have the potential of functional downtime post-event such as loss of power at the treatment plant and pump stations.  This creates not only a need for mitigation, but also a need for continuity of operations planning to develop procedures for providing services without access to essential facilities.

Please provide mitigations for these concerns in so far as the operation could create circumstances which favor large fire events.  It is said that fires occurring in harvested areas where large trees are removed and small trees, brush, and ground cover plants and/or debris remain, are far more likely to produce intense fires.


Consideration of landslide resulting from timber harvesting activities and possible impacts to treatment system and collection system pipelines:

Much of the RRCSD collection system, including pump stations, pipelines, and other parts, are potentially subject to landslides.


The Local Hazard Mitigation Plan states on page 31: “Active land sliding located along the north edge of the treatment plant has previously inundated a portion of the plant improvements.  The remaining landslide mass is contained by concrete rails adjacent to the plant property line at the toe, but the feature extends upslope onto the private property north of the plant.  Landslide potential is high on all slopes above the plant.  Southward-facing slopes have static and seismic landslide potential with potential impact to the plant facilities.”  (emphasis added)


What are the landslide and debris flow risks to the treatment plant and irrigation areas that may be generated by this project, either during harvest or soon after?   Deep seated landslides  can cause rotation slumps of the top 5 to 30 feet of soils, according to the study.  This can cause pipelines to break.  It is of special concern not only to the treatment plant, but also to the hillsides above neighborhood homes.  Can the falling of a giant tree after winter storms cause such a slide?  (I realize the THP indicates that no tree cutting will occur when ground is wet, but if surface appears dry, but the soil below is wet, can such an event be triggered?   Also, will the project be activated in any areas currently being irrigated in summer?  RRCSD irrigation after October 1st will not be allowed.


On page 40 it states that the wastewater treatment system at the end of Neeley Road has been, “ …adversely affected by a debris flow circa 1992 that originated off-site on the slopes and travelled between the clarifier area of the plant and the mechanical building, into the downslope effluent storage reservoir.  All of the slopes bordering the northern boundary of the site should be considered to have a high potential for landsliding, both statically (due to heavy winter rains) and seismically (due to intense shaking).  There is little or no protection from such slope movements to protect the facility at this site.”  What impact could the felling of a large tree have on sliding potential where sensitive soils and steep hillsides exist?


Wouldn’t it be prudent to conduct a geotechnical assessment to determine risk of landslides and liquefaction potential to specific areas on Neeley Road and Treatment Plant areas before disrupting this hazardous area with the felling of very large trees, the possible movement of soils, and other potential land movement?  (I am unaware whether such assessment has been conducted.)


The document further states on page 41, in regard to the lower part of the property, “….the southern half of the WWTP site is underlain by fill over young alluvium; which has a very high liquefaction potential and at least a moderate lateral spread susceptibility.  Groundwater has also been demonstrated to be shallow, varying from 5 to 15 feet below existing ground surface.  If such a phenomena were to occur, differential settlement and lateral movement would most likely disrupt pipelines and other infrastructure and may result in slope failure or rupture of reservoirs.” How is this being dealt with as single trees will be harvested in that area, I believe.


Concerns regarding conflicts with irrigation operations:

We noticed in the THP that RRCSD would have the irrigation heads painted a bright color so as to be visible during harvest operations and thereby prevent harm to the equipment.  Does this mean that tree felling WILL occur in the irrigation areas?  (I read somewhere that you will ‘try’ not to damage any irrigation infrastructure in the work area, implying that you will be working in or near irrigation fields.  Would any harvesting occur on irrigation areas during operations between May 15th and Oct. 1st?  We have heard that as much as 2.5 acres could be clear cut in the upper part of the property which may include the irrigation area, but that could be very destructive of the irrigation operation.  Wastewater could certainly not be irrigated on barren hillsides.

Even if only a limited number of trees would be taken, we wonder if the irrigation areas could be avoided altogether or if not, what measures could be taken so that irrigation could continue to safely occur?  What measures will be taken to prevent winter slides throughout the property and the potential for release of large amount of sediment into the rivers and destructive of downhill properties because, not so much because of tree removal, but because of increased irrigation water that is no longer taken up by the fallen trees?

Tree removal in areas now being irrigated can have a serious impact on irrigation capacity.  No ponding is allowed in their discharge permit for more than a brief time during and after irrigation, if there are depressions where trees used to be, irrigation water is bound to collect in ways it didn’t before, unless much less water is applied.  Studies have been done to determine the amount of water taken up by irrigation and a single redwood tree can take up hundreds of gallons a day (I don’t have access to the studies right now, but can arrange to locate them.)  I’m guessing that Doug Firs would use similar amounts.  So depending on whether and how many trees are cut in irrigation areas, will you determine how much more irrigation area is needed to allow for the same amount of wastewater disposal as now?  (People used to joke about how well their plants were doing near the septic tank.)

How will you proceed with the harvesting in irrigation areas?  Will you coordinate with the Water Agency, operators of the RRCSD?  I read in the THP that there will be no tree removal when the ground is wet, which makes us wonder what determines wet ground (when does irrigation occur), for how long, and how long it dries between applications?  The Agency is pretty secretive about their operations on that property; I would like to ask for full transparency regarding how the two operations plan to coordinate so as to allow adequate irrigation applications to meet RRWPC needs and allow for the application of current irrigation amounts and still abide by all regulatory requirements?  Perhaps no harvesting will take place in irrigation areas, but I don’t recall seeing that in the THP.

Somewhere I read that none of the operations of this project would cause sediments to enter the river.  Yet I don’t believe you have addressed irrigation on harvested areas and what impact that might have on the release of sediments?  I haven’t seen the property, so I can’t picture what impacts might occur as a result of this project.  Is there a detailed explanation provided somewhere?  I also wonder how much input you have received from the North Coast Regional Water Board?  I was told they would weigh in on this but have heard nothing since.  What is their view of this operation and have they asked for certain considerations in order to protect the river?

Importance of retaining fully functional irrigation area

Sonoma County Water Agency (SCWA) has made numerous efforts in the past to find additional irrigation area.  They even developed a plan to send two big pipelines to the Graton area via River and Hwy 116 roads.  That would have been an extremely expensive solution that would have been unaffordable to our small district.  (Note: While they have been publicizing lately that they have over 3100 developed parcels in the district, we do not believe that is true.  Until about two years ago, they stated on many occasions that there are about 2600+ developed parcels and the remainder are either governmental properties such as parks, and undeveloped and undevelopable parcels that are undeveloped.  RRWPC has purchased lists in the past from the County and we know this to be true.)

There is another tangential consideration that has not been mentioned.  If the project inadvertently triggers landslides, spills toxic substances, or allows fine sediments into the river in spite of efforts to do otherwise, and this happens in summer when low flows demanded by the Biological Opinion are in effect, the results are likely to be far more dire than when under normal flows.  Next year will  likely to see the permanent lowering of summer flows arise as an issue.  Any pollution getting into the river at the lower levels mentioned, will have far more dire effects then when flows are high.  After a normal rain year, flows would normally run at 125 cubic feet per second (cfs) or more past the Hacienda Bridge, the measuring point for the lower river.  Following a dry winter, minimum flows could go down to 85 cfs, unless the State Water Board approves a Temporary Urgent Change Petition to bring it down even lower.  (This year such a Petition was approved to bring flows as low as 40 cfs, but thankfully, actual flows never went below 80 cfs the entire summer.)  Once lower flows are approved, whether they go that low is up to the discretion of the operator or Mother Nature.

In addition, the sediments can carry phosphorus into the water.   Studies show that excessive phosphorus resides in the river at least in summer, and most likely all year round.  That phosphorus helps to generate massive amounts of algae in the lower river that sometimes includes cyanobacteria that seems to proliferate when low flows and hot weather occurs.  All of these issues come together to cause degradation of the river in summer time.  We believe it behooves foresters interested in cutting trees along the river to address these issues.


Furthermore, one of the major considerations for a new wastewater disposal option for the communities of Monte Rio and Villa Grande was the possibility of hooking up these communities to RRCSD in order to avoid supposed summer bacterial contamination of the Russian River.  How could this expansion be considered if ongoing timber harvest over the next seven years does not allow for any expansion of the irrigation area?  (Such an expansion would require sites with adequate vegetation to be irrigated.)  Has loss of agronomic rates occurring after harvest been calculated?  We suggest that someone do that.


Thank you for the opportunity to comment on behalf of Russian River Watershed Protection Committee.






Brenda Adelman: Chair of the Board