RRWPC Comments: Draft Salt & Nutrient Management Plan

Abbreviations used below: TMDL- total maximum daily load; TDS-total dissolved salts; CEC’s-constituents of emerging concern

August 17, 2012

Russian River Watershed Protection Committee has numerous concerns about the Santa Rosa Plain Subbasin Salt and Nutrient Management Plan, referred to here as “The Plan”.  We strongly believe that this Plan whitewashes the anticipated impacts of significantly increased wastewater applications to urban and rural landscapes in summer months.

Furthermore, it avoids looking at the serious implications for surface wastewater runoff at a time when many creeks are either very dry, or contain very low flows. The nutrients will impact the creeks before affecting the ground water.  It is absurd that nutrient impacts on the surface water are not being studied as part of this Plan, especially since the waterway is so highly impaired for those pollutants.

While the explanation given is that surface water impairments are being studied through another process (TMDL); that process appears to have been stalled, perhaps waiting for the irrigation projects to be imbedded so as to come in after the fact.  Water quality issues in the Laguna have been sliced and diced many different ways, so that the left hand doesn’t know what the right is doing.  Without an integrated process, the measures needed to fix the problems will not be effective.  These problems have been greatly exacerbated since I started work on these issues, 27 years ago.  Many plans have been written and many inadequate attempts to fix the problem, all to no avail.  I include recent photos of the Laguna taken at the Occidental Bridge near Sanford Road which speak for themselves.  It is clear that the Laguna is choked with Ludwigia and other excessive vegetation.

Additionally, the Plan avoids discussing the serious impacts from low dose exposures to endocrine disrupting chemicals of both humans and wildlife and avoids looking at phosphorus as another problematic nutrient.  In fact, it doesn’t even study the problem with ‘blue baby’ syndrome in the study area.  Have such problems been reported?  Have local health agencies and hospitals been consulted about that?

This draft document is a plan to manage salt (total dissolved solids) and nutrient (nitrate) impacts to groundwater resulting from the anticipated increased use of wastewater to irrigate lands in the Laguna watershed.  It is supposedly also intended to examine all sources of these pollutants and others in so far as they create groundwater pollution in the designated project area.  Santa Rosa is in charge of developing the Plan, but has a vested interest in minimizing the impacts of nutrients in their wastewater that have been harming the environment for the entire time they have been discharging into the Laguna.  Yet they failed to address the possible accumulation that occurred over all those high discharge years.