The North Coast Regional Board has conducted numerous studies over the last ten years to justify widespread new regulations to control pathogens in the Russian River and its major tributaries. About 20 years ago, legislation known as AB 885 triggered this activity, although Russian River septic systems had long been blamed by upstream neighbors for polluting the Russian River. While several other sources of bacterial pollution were acknowledged in the Regional Board’s 350+ page TMDL Report, most of the document focused on septic systems as having the greatest need for remediation.
Bacterial sources hard to identify….There are billions of bacteria in the environment, and most of them are beneficial and necessary for good health. Specific disease causing pathogens are often hard to identify, and often impossible to trace to a specific source. Regional Board scientists utilized several different methods and types of analysis to draw conclusions about the occurrence of disease causing organisms, the likely source of origin, and the need to control them as much as possible. What they could not do was assess the pathogen contributions of specific septic systems and/or individual contributors.
Total and fecal coliform limits had been the preferred measures for years, and are still utilized by public health departments as indicators of water health safety at public beaches, but recently (November, 2018) the State Board adopted EPA limits naming E. coli in fresh water and enterococcus in saline water as the preferred measures. This necessitated a major rewrite in the Regional Board’s current Pathogen TMDL, which had already gone through two revisions. It is expected that the new version will be approved by the Board at their meeting in Santa Rosa on Wednesday, August 14, 2019, in spite of the fact that serious problems have been identified in recent comments by County staff and others.
County Comments Critical of Study Conclusions and Action Plan…All along, RRWPC has called the Board’s attention to the E. coli monitoring data for the Biological Opinion which took place over nine years (2010-2017) at numerous lower river beaches between May 15th and October 1st each year. A 2010-2017 graph demonstrates that E. coli exceedances occurring over that entire period was only 7% of the samples. Furthermore, no data trend indicated septic system problems in summer time. Where there were exceedances, they were isolated and often corresponded to busy recreational weekends. Recently, the County submitted over six pages of critical comments about a PhyloChip study that had been commissioned by the Regional Board. Here are some of County staff’s conclusions:
- Large segments of the impacted public were not given notice of proposed new regulations.
- In the PhyloChip Microbial Analysis (Don’t worry, this is just a title and you don’t need to understand it.), County authors accused the Staff Report of glossing over implications of the study’s findings and claimed the extent of the pathogen problem is far less than previously concluded. (This was the same conclusion RRWPC came to in regard to the E. coli data in the Russian River main stem.) Also, enterococcus in fresh water is no longer indicator of pathogen impairment according to commenters, yet Staff Report continued to use it.
- There was inconsistency of fecal indicator tests in detecting risks of various bacteria.
- Many affected properties serve as low income housing, yet inadequate information has been provided about potential costs of meeting new requirements, nor assurances given that grants and/or loans would be available.
General Findings regarding pathogenic sources and locations….The latest version of the Board’s Draft Action Plan for Total Maximum Daily Load estimates the presence of pathogens that are in the water and where they might have come from. Yet, in most cases, they can’t pinpoint which septic system, or group of systems, if any, is contributing to the excess. They can discriminate between human and animal waste and can provide a very rough estimate of where each came from based on land use. Certain conclusions resulted from their studies and include some of the following:
- Most pathogens are found in winter during and after major storms. Few are present in summer.
- Pathogens are found in tributaries in summer but few exceedances found in lower river main stem.
- Monitoring data indicates few E. coli exceedances in lower river in summer except
- On major beaches (e.g., Healdsburg & Monte Rio) after a big recreational weekend or music event.
- Homeless encampments are sometimes a significant source of pathogens.
- Dairies are a significant source of bovine pathogens.
- Forests contribute least amount of bacteria. Based on Bacteroide levels which may or may not be pathogens, areas of dense housing such as lower river tend to have greater amounts of Bacteroides. Yet the lack of E. coli pollution seems to indicate the trees may be an unconsidered factor.
- Many of the pathogens in lower river come from upper river and Laguna.
- Even though few, if any, people recreate in the middle of a deadly flood and storm, the Regional Board is nevertheless protecting these activities during entire year.
Implementation Role of technical and citizen groups….The implementation plan for this new regulation will probably not begin for a year, after several State agencies give their approval. At that point, Regional Board staff will begin sending letters of inquiry to all properties within 200’ of the Russian River and main tributaries (not sure which tribs, but probably includes Mark West Creek, Santa Rosa Creek, Green Valley, Dutch Bill Creek, and a few others). We don’t know how detailed the letter will be, but it will ask questions about your septic system. They mostly want to determine who has antiquated systems that do not meet code, and all cesspools will fall in that category. It will also require everyone to get a septic system inspection by a licensed professional within five years.
In the meantime, a group has been formed to help develop a plan of implementation of the new regulations. (Over time, we will explain these, but it’s premature right now because they are still in flux.) There are nine local citizens, led by a technical group of agency people representing the County (Planning Department and Sonoma County Water Agency) and the North Coast Regional Board. This group is tasked with developing a work plan in order to obtain grant(s) and low cost loan funding for the Monte Rio and Villa Grande areas.
The Plan, to serve as a potential model for other similar communities, will probably assess three alternatives including: individual septic system alternatives, community septic alternatives, and hookup to Russian River County Sanitation District (RRCSD). The main concern about hooking up to RRCSD, is that in order to be cost efficient, all or most of both communities would all have to hookup. This would include hooking up even those who have systems that are relatively new and meet current requirements. That might not be fair to those who went to great lengths and expense to upgrade their system to make it compliant. Some individual parcels may also have problems with the inability to use any part of the septic dispersal area’s reserved space for any addition to the structure (according to Sonoma County Plumbing Code).
RRWPC needs your continuing support! RRWPC counts on your continued support to sustain our river protection work, but some of you have not donated for a long while. We generally keep supporters on our list for 2-3 years after their most recent donation, and then we cull the list, usually at the start of each year, assuming that unresponsive supporters are no longer interested in what we do. For those affected, we hope to hear from you soon so that we know you continue to be interested in receiving our mailers and supporting our work. Any sized donation is appreciated. We rely on six mailers a year for our entire fiscal support. On the label by your name you will see two numbers that represent the month and year we last heard from you. Also, we encourage those of you who have not shared email addresses as yet to sign up so that you can receive important messages sent out between mailers. Of course we welcome the responses of any and all of those on our list.