RRCSD 2021 Permit comments, 4/14/2021

Russian River Watershed Protection Committee
P.O. Box 501
Guerneville, CA 95446

April 14, 2021

Emailed to:  NorthCoast@waterboards.ca.gov
CC to Cathy Goodwin, Matt St. John

RRWPC Comments on: Proposed Waste Discharge Requirements Order No. R1-2021-0002 for Russian River County Sanitation District (RRCSD) and Sonoma Water (SW): Russian River Wastewater Treatment Facility

By Brenda Adelman for RRWPC

RRWPC supports many of the requirements in this draft permit. We are especially impressed with the focus on disaster preparedness assessment reports and action plan requirements for facilities vulnerable to natural disasters. Sonoma Water staff has informed us many times of the complexities (and expenses) of running a system that has been regularly affected over the years by major floods, numerous landslides, forest wildfires, major breakdowns and failures of facilities that brought large fines and penalties, and more. Only Occidental County Sanitation District has higher fees county wide than we do. (RRCSD Fee for coming year: $1,774 per hookup)

We have spent some time looking at the Hazard Mitigation Plan finalized and accepted by FEMA on April 16th, 2018. To the best of our knowledge, it has done a pretty thorough job of describing the hazards in the system, at least in terms of the system components to which they had access. We are supportive of the Draft Permit’s reopener clause, allowing almost immediate access between permits when new, unexpected problems occur and need to be addressed rapidly.

Russian River Watershed Protection Committee was founded in the late 1970’s when Don Head and Hal Wood visited our town (i.e., Guerneville) to meet with some of us who had been protesting the prospects of a new sewer system that had been defeated in two local elections mainly because of its high cost. Ultimately, we got to know these gentlemen well as we became more involved in the project. A ten year moratorium had been placed on new and replacement septic systems by the Regional Board and Public Health Department and eventually the county prevailed in hooking up the system after a great deal of protest and opposition. (The business community was mostly in favor of the project as they had the most severe septic problems. Since they could not afford the costs on their own, the project was expanded to include most of the community. Monte Rio abstained from hooking up at the time.)

As it turned out, as the Regional Board certainly knows, the lower river is a very harsh environment in which to construct and run a conventional sewer system. For a long time there were numerous E. coli violations that generated many penalties over the years and ended with the construction of improved disinfection equipment, and denitrification components. Now pump stations and force mains are badly in need of upgrade and repair as they are causing serious problems and coming to the end of their useful life. (The system was built in a harsh environment for conventional sewer systems. For example, the Geysers project is the longest (40 mile) uphill pipeline having the steepest incline, but only has 5 pump stations, while little Guerneville’s has 11 lift stations. Most major components last at least 50 years, yet many of RRCSD’s are lasting less than 38).

Now in its 39th year, the system is in current need of a new force main pipeline, lift station repairs and replacements and has numerous thus far unquantified vulnerabilities. It’s capacity is limited by inadequate storage and irrigation areas. Installation of new components at its current location is limited by geological hazards. There is a flood plain to deal with, high water tables and weak soils with huge liquefaction potential in the floodway. And huge periodic floods are guaranteed. There are a multitude of algal problems, including those of the toxic variety during low flow, bacterial issues have been identified, and we are promised seven years of timber harvest activity on the property where the treatment plant and irrigation fields reside.

For a while, the County pushed to regionalize most of the West County and hook numerous communities to RRCSD. It was the intent to take communities like Occidental, Camp Meeker, Graton, Forestville, Monte Rio and Villa Grande and many small enclaves in between, most of which are not in the flood plain, and hook them up to this very fragile facility subject to a multitude of hazards. (Monte Rio and Villa Grande are currently being considered for hookup to this system. They are subject to the same hazards, and in their proximity to the river environment, may have fewer options than other communities. Yet there is a long way to go before local citizens weigh in, environmental impact reports are produced, and cost figures are calculated. As some have recently noted, the issue has become one of deciding between two difficult choices, septic system upgrades and replacements that will require much higher standards than are now in effect, or hook up to a central sewer system with a multitude of complex requirements and high operation and maintenance costs.)

All these communities are different and pride themselves on having unique character and energy and almost none want a large scale utility that brings much of West County together under one wastewater roof. The people who live here, for the most part, do not like lawns and sidewalks; they are nature lovers who revere the redwood studded steep hills, the river, and are willing to put up with the natural hazards we all face from time to time. This area is the vacation land for the greater Bay Area, and most don’t want to see large amounts of new development on our crooked and pot holed roads. But none of this measures up to the fact that RRCSD operates in a major flood plain, one which has received more settlements by FEMA for flood damage than any other in the Country. (not sure if we still hold that unusual status) We have learned to cope, but that does not mean we should subject others to our situation.

RRCSD Draft Permit Issues of concern to RRWPC:
Most of our concerns revolve around inadequate summer irrigation constraints on Silver property (land disposal), including inconsistent definitions of ponding, unclear inspection frequencies, and stalling on critical repairs that have frequently led to major violations, possible timber harvest impacts on irrigation program, and geological hazards. (We wrote three comment letters concerning THP. We do not quote from them in this document but include letters as attachments since they discuss irrigation issues that we would like included in record. Attachment 1.)

We abhor RRCSD spills and breakdowns including SSOs during floods and otherwise. We support system upgrades, and want to see nutrient and phosphorus problems addressed. We are concerned about future expansion potential that could open up the back hills and other communities to extensive new development. While this permit is not required to address all these issues, and is not subject to CEQA, nevertheless, they are relevant and we wish to put them on the table for some kind of acknowledgement and consideration.
Finally, it seems ironic that after all the work on the pathogen TMDL, the operators, SCWA, are thus far allowed to delay collection system upgrades and lift stations repairs when faced with major discharges of raw sewage during high floods. (The permit clearly states that operators are not obligated to make improvements until they have the funds; well, the funds are nowhere in sight and are not anticipated any time soon.) Since it’s been eight years since the first major break down, how long will it take for serious action to occur?

Outline of Main Concerns….
• Proposed Land Irrigation Discharge Management Plan;
o Land Disposal inadequacies/analysis of water use
o Geological issues on upper and lower Silver property spray fields
o (We strongly support comments of John Dunlap on this issue.)
• Extensive SSOs and other spills during high flows and related floodplain issues.
• River nutrient issues and inadequate attention to phosphorus: also new aquatic plant (Azolla) found to grow in excess in the river
• RRCSD system capacity for expansion (or not)
o Monte Rio and Villa Grande
o 735 parcels bordering current district of which 395 are vacant
• Minutia and Miscellaneous: Small mistakes, typos, brief issues, etc., appearing in catch all section.

Irrigation Management Plan:
RRWPC strongly supports the concept of a proposed new irrigation management plan. Would the Plan be reviewed and updated every year? We believe it should be, as it may take a while to implement a new management program and modifications may be needed over time. The definition of ‘ponding’ and other terms in this current permit intended to control ground water intrusion and runoff, and also the extent of irrigation to be applied to the land, are too vague. Also some of the terms seem to contradict each other in various sections of this Draft Permit when describing how measures are to be defined. For example: on pages 12 and 13 the following statements are made:
• “The Permittee shall operate the forest irrigation system in a manner that minimizes the potential for runoff.” (
• “Irrigation areas ( shall be managed to prevent ponding” and
• “Irrigation water shall infiltrate completely within a 48-hour period….”(
Items through don’t consider factors mentioned by Vic Madrid below. For instance, in the upper field, perhaps an irrigation set back would be helpful in preventing runoff down steep slope. Or the potential for landslide may not be considered. In light of the poor definition of “ponding” and an unclear description of the 3 acre upper irrigation site, it’s unknown whether a setback may be necessary. What is the frequency of inspections on this parcel?

We believe that the only way the Plan could be an effective management tool would be to require relatively frequent review and updates. We expect reviews to focus on practices the Permit addresses such as prevention of excessive ponding, surface water runoff, potential groundwater impacts and possible exacerbation of hazards (This last one is our especial concern and would like hazard related improvements to be incorporated into the Plan). Also, what protections are in place to assure that pesticides do not reach the river?

Where mandatory ‘periodic’ inspections are defined in this current Draft Permit how should ‘periodic’ be defined? ( page 12) Every several days, week, month, year? There are undefined factors that are not at all clear in this draft permit that affect ponding potential and the current frequency of inspections does not seem adequate to address them. While we are waiting for the Management Plan to be developed and approved, what exactly is required in the meantime?

Besides the need to define the words ‘periodic’ and ponding, the term ‘reasonable’ is another catch all term that needs clear definition. We are looking now at page E-47 where it calls for ‘reasonable’ BMPs and management practices. We know it shows up in other places but won’t list them all. What is the definition of ‘reasonable’ in these contexts? (

We decided to take one vague term and go through the permit to demonstrate the various uses of the term ‘ponding’… Here is what we found: Review management plan annually to address non-compliance of persistent or excessive ponding (what is considered ‘excessive’?)…. Manage irrigation areas to prevent ponding (altogether?) and conditions conducive to proliferation of …disease vectors…. Irrigation water shall infiltrate completely within a 48 hour period… (Does this mean it’s okay for 47+ hours?)
Page E-6: 003: “Since irrigation application rates exceed hydraulic agronomic rates, this Order identifies this practice as land disposal rather than water recycling.” (Implication here that less care given to amount of water used and fewer controls in effect.) What’s a ‘reasonable’ BMP (to prevent violations of ponding)? All observations of over-application (includes ponding): Do these observations come after the 48 hour time limit for infiltration? (Most of these entries don’t mention the 48 hour limit.)

Another concern is that we did not see any directions for frequency of inspections for land disposal fields. Can violations occur during that 48 hour period where ponding is allowed?

Page F-7: 2.1.4: ….manage effluent irrigation on land disposal to minimize ponding…..
We ask: minimize compared to what?

Page F-55; 4.7.1.: States that Discharge Management Plan is needed to determine that spray irrigation rates must not result in ponding… Yet in earlier pages (above) the Order implicates that ponding is okay for 48 hours or less. So here we have an Order declaring that standing water invites disease vectors, but it’s okay for 48 hours, but later on it states that ponding is prohibited, without explaining the discrepancy. The term ponding is never clearly defined.

Along with ponding, runoff is supposedly forbidden, but there are no definitions or specific measures regarding how it is to be controlled during land disposal. We have said almost nothing about spray irrigation of ‘recycled water’ on the golf course because requirements are far more stringent and apparently golf course managers have more at stake regarding compliance, but we always assumed that the same treatment plant water was going both places. It is curious to us that on page F-8: 2.2.4. It says: “Between May 15 and September 30, effluent not utilized by the gold course and effluent not meeting turbidity specifications but meeting all other relevant permit requirements, is land applied at the Burch property at Discharge point 003.” Why is this legal? Why does some of the water not meet turbidity standards? How is it that two levels of wastewater treatment are separated? If it goes to golf course first and then to Silver fields, how does it lose turbidity along the way?

Factors that affect ponding and need to be carefully monitored…
Vic Madrid, licensed geologist, states in a paper he wrote entitled, “Simple Water Balance of RRCSD Upper Zone spray operations using the WEPP model with Cligen Climate simulator”.
He states, “…the amount of spray water reaching the ground varies considerably depending on a variety of factors including seasonal weather, spray water droplet size, spray discharge rate, wind speed and direction, air temperature, and relative humidity at the time of spraying. Potentially the continuous praying of treated effluent in the upper zone spray area during the Reclamation Season could significantly alter natural seasonal soil wetting and drying cycles.” So how can operators know when ponding or runoff occurs, except in a very general way? If it is considered, how is it managed? And will the new Management Plan address these circumstances? How can simply spraying water on a field and coming back to check it ‘periodically’ is showing any care at all for preventing the runoff and excessive ponding?

Madrid concludes: The ongoing RRCSD Upper Zone spray operations most likely maintain a spray impacted area that is at or near 100% saturation for the entire season, essentially eliminating the natural wetting and drying cycles on this hill slope. The saturated soil conditions could increase landslide risk especially on hill slopes that exceed 50%. During an above average future rainfall season, especially one with high intensity events, this Upper Zone impacted area will already be saturated at the onset of these events. This will result in increased soil pore pressure, runoff, and erosion in an area where numerous debris flows and road failures have already been identified by the Silver Estates Timber Harvest Plan….”

Furthermore, states (p. 12) that irrigation areas, “…shall be managed to prevent ponding and conditions conducive to the proliferation of mosquitoes and other disease vectors, and to avoid creation of a public nuisance or health hazard.” This provides the rationale for why it’s important NOT to allow ponding, but doesn’t really explain how it will be managed to achieve the desired result. (I suppose that will be the task of the Irrigation Management Plan, but it still leaves this current permit incomplete for the next year, and unable to determine if its requirements will be fulfilled and goals realized.) To my mind, managing the Silver Property irrigation sites in a way that prevents polluting land and waterway, is to manage it all as a recycled water permit that abides by agronomic rates.

In the permit ponding is not allowed after 48 hours, but in a conversation we had with three RB1 staff on 2-25-21, my notes state that it was stated that ponding is not allowed at all. In light of prior comments, based on Draft Permit, ponding is allowed for 48 hours. Which is correct? Also, the lower field has a high water table. Does this contribute to soggy conditions? For instance, does it limit drainage of the irrigated water? 2019 was a very wet year. Was groundwater very high in the spring time? Is that another factor that needs to be considered?

Furthermore, states that, “Irrigation water shall infiltrate completely within a 48-hour period;….” How is the area being irrigated and then dried determined? What is the typical size of the area? Are there buffers between areas that can catch spray without being re-saturated too quickly? To what extent is temperature a factor (and on the other end of the spectrum, fog) in the amount of drying time needed? Do they calculate all factors above when determining how long any specific area is irrigated? How do they make and then apply those calculations? How will tree harvesting of large trees impact this? How will management adjustments be made to accommodate new conditions?

So if inspection schedule is not specified, and irrigation continues on the same basis as now, how do they know if two day’s irrigation has been absorbed and new irrigation waters applied separately? Do they inspect each time or do they assume all ponding will be evaporated after two days? It would seem like they would need to irrigate for one day and then inspect at the end of the next day to see if wastewater has been absorbed by the ground before they irrigate further. How is this managed? Or do they need to check after 2-3 hours? Are there any environmental changes (such as with soil characteristics) resulting from the long time irrigation with wastewater as Mr. Madrid suggests? Are they ever required to test soils at some point to see if any undesirable constituents are accumulating?

Also, those who have seen the lower field have stated over the years that it has been super-saturated. Around the late-1980’s I was taken on a tour of the field and it was extremely wet. Others who have seen it more recently also characterize it as having wetland levels of standing water in places. One person claimed, in comments to CalFire regarding the Silver THP, that if it has wetland characteristics, it needs to be managed as a wetland. Is it possible for this permit to allow the creation of a wetland without designating associated requirements as such? Also, someone shared a photo with us of a ditch near the Clar tree with running water in it. Apparently it is shown on a map going down to the river and was taken at the end of the irrigation season. At the end of the irrigation season, one would not expect to see natural flows from rain, leaving one to believe that likely the ditch is filled with treated wastewater.

Bob Rawson was one of the first managers of the RRCSD Treatment Plant. He submitted a comment letter to CalFire recently regarding irrigation at the facility. (Attachment 2) He states, “…severe damage was caused by logging on the Burch property after the plant was constructed. Logging created depressions and damaged the soil structure, tree roots, distribution piping and irrigation controls in the irrigation system. This logging damage reduced transpiration capacity as the compaction of the soil reduced soil acceptance rate. The depressions left by logging filled with effluent from the irrigation sprinklers. Tree stumps and these compact depressions created ideal habitat for the proliferation of Aedes increpitus mosquito. When timberlands are flooded by the river or irrigation that exceeds soil acceptance rate and transpiration capacity; the mosquito eggs hatch into the larvae in the shallow water. The larva quickly molts and become adults, which lay eggs creating multiple successive swarms. AEDES and other mosquitoes are known to carry Equine encephalitis, and other insect borne pathogens of great public health concern.” What role might the recently assessed seven year Silver Property Timber Harvest Plan (THP) contribute to such circumstances? Do the operators of the irrigation system have the ability to do something about this?

While the soil and ground damage Bob refers to here, may have been addressed in earlier THPs, nevertheless, other THP’s have occurred since then. Interestingly, we have heard that the previous THP did not cut trees on the upper irrigation field. Why is that not the case this time? Formerly RRWPC has requested that a capacity study be conducted to see how cutting even more trees in the lower field will exacerbate current problems and limit capacity of wastewater irrigation applications. The Draft Permit prohibits the creation of a vector problem, but gives no acknowledgment of previous irrigation problems because of the harvest, nor any suggestions on to how to prevent it, other than management activities that have either not always been followed, or not discovered because of inadequate management. We do know that there was a young man who lived with his family in the house next to the treatment plant who developed encephalitis many years ago.

It concerns us that there is no requirement to address CEQA issues in this permit. While permits normally are intended to address environmental impacts of described activities (in this case, irrigation of two fields on the Burch property) and mitigate them, there is no discussion of any changes brought about by years of heavy irrigation on this land with wastewater. Not conducting any kind of environmental review in such a hazard ridden location, seems to be a penny wise and pound foolish practice. Would you agree? If soils are weakened, as Madrid suggests they would be, and landslides occur, this should be noted as a hazard resulting from irrigation practices. Has anyone addressed this issue?

While we have seen contradictory and unclear statements about when and where pesticides and herbicides will be used over the seven years they will be tree harvesting, we are concerned that the impacts of the summer watering on these toxins should be evaluated, especially for glyphosate and other chemicals that may be applied through the harvest process. Is there any risk that these toxins would mix with irrigation water and at times end up in the river?

Evaporation vs. Transpiration?
Rawson goes on to claim that irrigation capacity will be affected by cutting more trees as well as causing environmental damage and possibly other human health problems. He states, “It is my opinion that any removal of redwood trees will reduce their total mass and number of transpiring units.” This in turn, he says, will reduce total transpiration even if reduced canopy allows some trees to transpire more. I would interpret that to mean a loss of irrigation capacity.

My thoughts on the situation include a need for an interactive analysis of water uptake of trees being cut, amount of irrigation applied, average wind, heat, soil conditions, slope, evapotranspiration, etc. Scientific information is needed on how remaining trees and irrigation capacity will be impacted by the harvest. For instance, if the same irrigation amount is applied to fewer trees, what will happen?
This is an important issue, because it is the explanation given by foresters to justify loss of ‘canopy’ (i.e., tree harvest) We have heard that forests store huge amounts of carbon, which is highly desirable to prevent planetary warming. Also, redwoods are capable of holding water for long periods; they also absorb moisture from the fog. So every time foresters take down a tree, they are removing a large moisture reservoir that is shared with the forest and not reserved for a single tree. It is also true that the trees absorb some of the irrigation water on the ground in summer. People used to joke about how green and thick the vegetation grows next to the septic tank. (especially the leaky ones?)
So what we would like to know, what type of irrigation area is preferred in order to maintain an irrigation program, an empty lot with the sun burning down where large amounts of evaporation occurs, or a green forest filled with large mature trees that may get little sunlight, but welcome the summer damp from the irrigation? How do they compare? The big question is: if numerous trees are cut, would that reduce the capacity of the irrigation field in terms of water sprayed?

SCWA promises to address Extensive SSOs and other spills during high flows and other floodplain issues.
The ‘Report of Waste Discharge’ dated Oct. 30, 2018, states (page 2), “The District’s long-term capital improvement plan (CIP projects) include headworks and lift station improvements; clarifier seismic retrofit; and force main replacement.” (emphasis added) Does ‘long term’ mean indefinitely here? It seems as though when a condition is causing serious failures in the system that is subject to an ACL, there should not be indefinite timelines connected to implementation.

On the same page we find the following: “The CIP through 2023 does not include any projects beyond that described above for the WWTF.” But it then also states, “However, the District is looking at improvements for all of the lift stations in the collection system. These facilities are approaching the end of their useful life, with most being over 35 years old, and many of the facilities may not meet current State or National safety or electrical standards.” Isn’t that reason enough to make them get moving on the assessment at least? (emphasis added)

On page F-6 it further states: “This Order requires the Permittee to continue to work on its I&I reduction program, conduct an engineering evaluation of the collection system and how it interacts with the treatment plant during flood conditions, and to develop a written plan that describes an implementation plan to notify the public when there are SSOs or unauthorized discharges from the collection system or the treatment plant.” We would like to also suggest that SCWA be required to warn residents when the river is toxic during high floods, and great care should be taken to avoid contact with its waters at that time as much as possible.

On page E-43 Special Provision Calls for Sewer Evaluation and Capacity Assurance Plan/Engineering Study Work Plan due Feb. 1, 2022. But on page 3 of the Russian River County Sanitation District Spring 2021 News, distributed by the same Agency responsible for implementing this permit, it states, “This year we have made several adjustments to keep rate increases at a minimum, including….. delaying studies and capital improvement projects.” (Our rate increase is 4% this year, up to $1,774.) This implies that they will not do the study this year, which I believe has been requested since 2014 when the system had a major breakdown at Vacation Beach. No funds have been requested for the project in their budget for next fiscal year. (Attachments 3 & 4)

Section on page F-69 of the Fact Sheet states, “This provision is included to ensure that the Permittee implements measures and actions to minimize the potential for sanitary sewer overflows and bypass events at the Facility….it is necessary for flood control and flood reduction measures to occur on an ongoing basis and prior to storm events to minimize the potential for SSO’s and bypass events to occur.”

The section goes on to describe the SSO events of 2017 and 2019 as having a combined amount of raw sewage spilled in 2017 to 1,031,663 gallons and in 2019, 1,312,815 gallons. It states, “These SSOs occur in neighborhoods and pose a public health risk to the residents.”

The Order requires (page F-6) that the Permittee continue to, “…work on its I&I reduction program, conduct an engineering evaluation of the collection system and how it interacts with the treatment plant during flood conditions, and to develop a written plan that describes an implementation plan to notify the public when there are SSOs or unauthorized discharges from the collection system or the treatment plant.” The term “work on” is rather vague here. Can you put some kind of time line/deadline on this?

This section mentions that SCWA is required to submit a work plan for revising its Sewer Evaluation and Capacity Assurance Plan and that the analysis to study the pipeline and the pump stations should be included in the Plan. (page F-70) This study calls for an assessment of the collection system and the Treatment Plant during flood events and states the deficiencies in the collection system and treatment plant and a Capital Improvement Plan to reduce and mitigate spills and protect public health.

This sounds wonderful but no deadlines are specified and SCWA has been told since 2014 they have to do this. We call for specific deadlines for this project with no further delays. If it happens again and people get sick, all parties will be culpable. Besides, SCWA’s RRCSD Spring 2021 News (Vol.9. Issue #1) states on page 3 that they don’t intend to do this: “This year we have made several adjustments to keep rate increases at a minimum, including….. delaying studies and capital improvement projects.” We have also looked at RRCSD’s proposed budget for next year and saw no item listed for such a study. Was the Regional Board aware of this decision?

The commitment to begin replacing the force main pipeline needs to begin. These studies have been promised since 2014. Delay has been the name of the game for the last seven years. How long do we have to wait for protection from the flow of raw sewage on our streets, like a third world country? We would like to know what steps have been taken and/or will be taken to obtain government loans and/or grants to do this preliminary work? How much money are they saving by not initiating the study now? Too much time has passed and a schedule of upgrades is needed. This Order should compel the discharger to, at a minimum, have a deadline for assessment work during the term of the permit. They should also be compelled to make a serious effort to obtain funds, and especially grants, for that work. SCWA managers are master experts at coming up with funds for water programs. We have a new administration now and it’s time for them to make new friends in Washington DC.

We acknowledge that the permit clearly states that while the design capacity of the RRCSD is 710,000 gpd dry weather flow, the operating capacity is limited to 500,000 gpd until the system increases storage and irrigation capacity to match increased flows. But for the record, we want to comment on what’s going on in the real world concerning this issue. It is related to the need to comply with the not yet authorized (by State Water Board) of the pathogen TMDL approved by the Regional Board in August, 2019. This ruling will require that properties along the Russian River and its tributaries meet new requirements for septic systems, that are considerably more stringent than those in force up to now.

Lynda Hopkins, Fifth District Supervisor established an Ad Hoc group of citizens and concerned agency staff persons that is referred to as the Lower Russian River’s Citizens Advisory Group (CAG). This group has been meeting for the last three years for the purpose of providing citizen input into the implementation of new septic requirements that will fulfill the intent of the approved Total Maximum Daily Load (TMDL) established by the North Coast Regional Water Quality Control Board.

The Regional Board’s TMDL requirements at this time (April, 2021) are yet to be authorized by the State Water Board. Similarly, the new OWTS Manual is about to be distributed and must be authorized by the County of Sonoma and the North Coast Board. The Group has identified three broad potential solutions for bringing Monte Rio and Villa Grande septic systems in compliance with the new requirements, which have not as yet been finalized. These two side by side communities are seen as the test case for implementation although the final map of affected properties along the Russian River and its tributaries has not been finalized as yet. In conversations and documents thus far, three potential approaches are being looked at to resolve the issue.
• First approach is the upgrade over time of all septic systems according to new codes in defined district. In this case, while it is anticipated that low interest loans will be available to low income home owners, there is concern that not all properties will be capable of meeting the new standards. For those people, and others who do not want to partake of that solution, (continued on next line)
• …there will be the possibility of creating community solutions, where several, or many properties will be hooked up to a community leach field or, in lieu of that, construct some kind of government approved alternative system.
• Finally, there is the proposal to consider the option of hook up to a central sewer system like the Russian River County Sanitation District. While a precise determination is far from finalized, it appears that several people in the group, including representatives from SCWA, who are also operators of RRCSD, may view the central sewer option as the easiest to fund and adopt.

• There are some critical issues that are not resolved in this NPDES Revised Permit for the RRCSD (seen as the most logical receiver of Monte Rio and Villa Grande wastes). We believe that the proposed permit should address issues defining capacity expansion:
On page 7 of the draft permit, it states capacity as: “The average dry weather flow (ADWF) of waste through this facility shall not exceed 0.51 million gallons per day (mgd), measured daily and averaged over a calendar month, unless the Permittee demonstrates that it has storage and recycled water capacity to handle a higher ADWF, not to exceed 0.71 mgd.” (emphasis added)

o Sonoma County Water Agency, (SCWA) states in the RRCSD Spring 2021 News on page 2, that there are 3215 equivalent single-family dwellings within service area, and system has capacity of 710,000 gallons per day. (emphasis added) Also, on page F-6 of the Fact Sheet, in describing the Wastewater Treatment Facility, it fails to mention this limit. For consistency and clarity, shouldn’t the 0.50 summer limit be mentioned wherever the issue of system capacity is discussed?

o SCWA fails to address the situation of not having 710,000 gpd capacity until they provide adequate storage to the system which is now absent, and also have adequate summer irrigation capacity to operate between May 15th and September 30th, when they are not allowed to discharge into the Russian River. For Regional Board to merely state that SCWA has to provide the capacity or be in violation, is in this case inadequate, for if all uses aren’t planned for to begin with, then when violations occur, there will be no immediate and viable remedy for perhaps a very long time, and that is an unacceptable situation.

o While the Regional Board clearly states that capacity will not be increased until irrigation and storage needs are addressed to meet additional septage, the Permit (Board) does NOT also demand that force main and lift stations be improved before increased capacity is granted. RRWPC believes that this is a critical issue that needs to be addressed.

o To the best of our knowledge, it has not been technically determined in recent years, how much wastewater is generated per single family dwelling in our area, so it would be hard to determine how much capacity or how many hookups would be available to expand the system. It would also behoove the managers of the system to determine how much capacity is available to expand? There are at least two considerations that have to be addressed:
♣ Summer homes and homes utilized as vacation units presumably don’t use anywhere as much water as homes utilized full time. Also the number of people residing in a unit would have a big impact on the amount of water used. Finally, weekend visitations can wreck havoc on the system. How would massive crowds affect capacity if the system were expanded? Furthermore, at any time any of these accommodations could be converted to full time use and capacity would increase.

• We have heard SCWA staff make statements to the effect that by expanding the system, they will have more funds to make the upgrades that would be necessary to accommodate additional flow. This is misleading since the expense of accommodating new additions may be far more than the new revenue coming in. Current ratepayers should not have to pay for accommodations for future growth outside of current District boundaries. Since all this may come to a head before the next permit cycle, shouldn’t some attention to this be addressed in this permit?

♣ If this is not included, does it mean the Regional Board plays no role in planning how precise numerical capacity limits will be enforced? We see that on pages F-5 and F-6 there is reference to a plan that will address deficiencies in the system. We ask you to also include analysis of any future possible expansion efforts that are planned for the next 5 years. Besides Monte Rio and Villa Grande, that should also include all developed parcels of the approximately 750 parcels that surround the current RRCSD District boundaries. (We have a parcel map of the area.)

• One other issue that we did not see addressed is that during high waters, houses in the flood plain sometimes have toilets and other drains flooded and this helps inundate the system and contributes to the surging manholes. We know that some people in the flood plain did not evacuate and we have seen no reports about water entry through open drains. What is being done, or can be done, to deal with this problem? In regards to hooking up other communities in the flood plain, it would seem that this issue needs to be carefully addressed.

Issues with Phosphorus given slight attention in this process..
The Order gives this topic short shrift mainly, we believe, because there are no numeric standards established yet. Because it may be eons before this occurs, and because biostimulatory growths pervade the lower river (perhaps the upper as well), we are extremely disappointed that your monitoring program only calls to monitor this constituent twice a year.

Algal growth is one of the most prevalent water quality problems in the lower river and deserves, at the very least, to have a serious study done on the types of local aquatic growth and their descriptions. For the last ten years, under the Biological Opinion, the Water Agency has monitored numerous constituents, including pathogens and nutrients along the lower river every week from May 15th to October 1st every year. And results are always the same, the only consistently excessive perimeter, out of way over a dozen, is phosphorus. (Attachment 6: partial data from SCWA files)

Furthermore, people send us pictures all the time of the blooms they see along the river banks. There was a newly arrived aquatic plant covering much of the lower river last year (identified as Azolla); where does it come from and what are its attributes? (Attachment 5: Azolla photos by Barbara DeIonno:)
None of this is to even mention the toxic algae found several years ago when a few dogs died from ingesting it. We expect extremely low flows this year because of drought and are concerned that we may have a similar problem this year.
Pg. E-29: Why is phosphorus only monitored semiannually? Perhaps the worst nutrient pollution of the lower river in the summer time is from phosphorus. Why has there been no action by your agency on this issue? The problem appears far more prevalent that the pathogens receiving TMDL status a year ago.

Minutia: (miscellaneous items and questions)
P.2 #1: Removal of limitations on bis(2-ethylhexyl) phthalate because of no reasonable potential. Question: Aren’t phthalates found in products made with plastic which would imply toxicity in the environment? It is our impression that phthalates are commonly found in wastewater discharges and that even minute amounts can have toxic impacts on humans and the environment. Can you explain basis for this action in that regard?

Page F-5 Facility Description: refers to Vacation Beach as Vacation Park. I believe the word ‘Park’ is incorrect.

Bottom of F-5 states: “The Permittee is also implementing a project to assess the condition of the headworks and aging lift stations, and to prioritize necessary rehabilitation and/or replacement of its aging infrastructure.” This document was released in March, 2021. Please note that the word used here is “implementing”, not planning or anticipating. Was that intentional?

Pollutant Minimization Program (Pg. A-5): If they do fish tissue studies for toxins, can they be required to also include vitellogenin studies? I don’t think they are expensive or complicated.

Page F-6 2.1.2. Why is there no mention of summer capacity limit of 0.51 mgd during irrigation season?

Pg. E-47: Land Discharge Report: What is considered a “reasonable” number of inspections over the year and “reasonable” intervals between inspections? From our perspective, twice a week would be reasonable and a lesser number would be problematic unless there were ways to check from the treatment plant through the use of cameras and other remote equipment that could reveal any problems. Are there ever problems of damaged irrigation equipment from animals and wildlife?

P. E-42: Land Discharge Specifications and Requirements are to be revised as necessary after initial March 1, 2022 requirement. What would trigger a revision under “revise as necessary”?

(Ran out of time. Comments are mostly complete but not quite. Brenda)


1. Letters from RRWPC regarding Silver Property THP: Sept. 28, 2020, Dec. 16, 2020, and Jan. 14, 2021

2. Robert Rawson Letter regarding Silver Property THP: Mar. 5, 2021

3. RRCSD Spring News 2021, by Sonoma Water Page 3: bottom

4. RRCSD Final Fiscal Report 2021-2022 Pg 1

5. Barbara DeIonno’s river photos: Spring, 2021

6. Water Quality Report, Monte Rio: 2020 summer season