Sonoma County Gazette, July 2009

Basin Plan Amendment

By Brenda Adelman

As flows in the Russian River are being reduced to a dribble this summer, the North Coast Regional Board, normally in charge of water quality, is going to change the Basin Plan to accommodate summer discharges of treated wastewater, now redefined as “non-storm water discharge”.

Regional Board legalizing wastewater irrigation runoff…..
Until now, summer irrigation runoff has been illegal, even though it happens frequently.  This Amendment is motivated by pressure from the State Water Board to encourage irrigated wastewater reuse in order to stretch the water supply.  The problem is that this waste is not as safe as regulators say it is.

The legal language in the proposed Amendment fails to account for all the real problems including the unregulated and untreated chemicals in the wastewater such as pharmaceuticals, personal care products, the existence of cancer causing agents,  anti-bacterial chemicals that destroy our ability to fight infections, endocrine disruptors that cause sex reversals and many other problems in wildlife, and much more….

Furthermore, the runoff can carry toxic pesticides and fertilizers used on the lawns into our river along with the wastewater at a time when very low flows can’t assimilate it.

Russian River Watershed Protection Committee fought long and hard for twenty-five years to get discharges out of the Russian River because of water quality issues.  This was the first year of ZERO winter discharge by Santa Rosa (hurrah!), but water quality regulators are now getting ready to legally allow “accidental” summer irrigation discharges.

With flows getting lower by the day, ANY discharge can further harm our already impaired river.  Bacteria counts at Johnson’s and Monte Rio Beaches have already been out of compliance eighteen times since May 28, 2009.  Since they don’t monitor the lower river for most toxins, we have no idea what other problems may be occurring.  While we don’t know what caused the bacteriological problems, it is the combination of various factors, many of which result from wastewater discharges, that have been cause for great concern.

Regional Board staff now claim that they need to legalize some runoff in order to regulate all the illegal runoff.  (Yes, you are reading that sentence right!)   Santa Rosa has been pushing hard for this change for years, both at the State and local levels. We’d like to give regulators the benefit of the doubt, but it just doesn’t pass the smell test.  When pressed, Regional Board staff admit that they are promoting incidental runoff under pressure from the State Board.

July 23rd, around 9 AM the Amendment will come before the Regional Board for approval.   Please see announcement below.

Stringent conservation should take priority over “incidental” wastewater discharges….
Ironically there was a high level State wide water “conservation” committee established several years ago that seemed to prioritize wastewater reuse over other more advanced conservation practices.  But there are huge advantages to doing everything technically possible to save fresh water resources before allowing the use of partially treated wastewater to legally enter our water supply.

Many of us have become water hogs without realizing it.  We use about twice as much water as people in some advanced countries and probably ten times more than those in undeveloped areas.   Yet it is far safer, cheaper, energy independent, and sustainable to use our fresh water much more frugally than to look to treated sewage reuse to sustain our natural supplies.

RRWPC does not oppose all reuse; we just want people to be very aware of all the untreated chemical toxins going down our drains and the difficulty in treating them all.  This is a public health issue thus far not adequately addressed.  We believe water resources will be far more sustainable for future generations if we learn to live with consuming much less water.

A lot more can be done to develop landscapes with drought resistant plants.  That is far more sustainable than generating more and more wastewater at great cost and then exposing children, pets, wildlife, and everyone else to unknown toxins they can’t see, touch, or smell.  There is no motivation to use drought resistant plants or conserve if large amounts of irrigation wastewater is readily available and easily applied.

Best management practices (BMPs) are expected to prevent runoff…
To confuse things, Basin Plan Amendment language has been proposed that would still claim that irrigation runoff is “illegal”, but would be forgiven under certain circumstances.  Those circumstances are referred to as BMP’s or Best Management Practices.  BMP’s are the practices used to allow activities that really should be allowed only as a last resort.  Sometimes, when no one is looking,  BMP management deteriorates.  For BMP’s to really work, constant vigilance by the regulators is needed, but with our State going broke, and Regional Board staff being cut back (and not paid) as we write, such oversight cannot be relied upon.

The fox will then be guarding the chicken house.  The City of Santa Rosa will be responsible for contracts with third parties to run the irrigation program “responsibly” and according to laws.  The City has fought long and hard to get this change in the rules.  They have stated numerous times that they would not do an irrigation reuse program unless “incidental runoff” is legalized.  In our view, that is an admission that they know the BMP’s won’t prohibit runoff.  Everyone has witnessed runoff from landscape irrigation.  It is hubris to think it can be controlled.

It is good that stronger regulations will be put in place to govern most discharges that enter the storm drain system and subsequently go into the creeks and rivers and have thus far been unregulated, but this wastewater runoff issue can undo many of the benefits claimed by the other parts.

Basin Plan appears to support our concern….
Proposed Basin Plan language comes close to supporting our view in regards to irrigation with wastewater.  It says,

Due to the unplanned nature of incidental discharges, this category of non-storm water discharges poses a slightly greater risk to water quality due to the potential for higher levels of pollutants and less opportunity to control the rate, volume, and timing of the discharge.”

This is an understatement.  There is really no way of controlling cumulative impacts.  That means that if a hundred small discharges happen to occur at once, it can have a major water quality impact at a time when human use is at its greatest and dilution capacity of the river at its minimum.  They say that the “dose makes the poison”, and that can happen here as well.  And there’s no way to control it if it does.

Brenda can be reached through email at Please contact her with any questions you have.  Also, you can view the website at  Donations to RRWPC via PayPal are very much appreciated.