This draft letter from SCWA by Randy Poole to the City of Santa Rosa is fascinating.
September 25, 2006
Pat Fruiht, City Manager’s Office
City of Santa Rosa
P.O. Box 1678 Santa Rosa, CA 95402-1678
Re: Discharge Compliance Project
Dear Ms. Fruiht,
The Sonoma County Water Agency (Agency) has reviewed the Initial Study, Notice of Preparation of an Environmental Impact Report (EIR), and Draft Engineering Report for the City of Santa Rosa’s (City) Incremental Recycled Water Program – Discharge Compliance Project (Discharge Compliance Project).
The Agency’s comments are focused on concerns regarding 1) potential conflicts with the proposed expansion of the Agency’s water supply facilities; 2) potential water quality concerns regarding how the City’s project could impact the way the Agency’s facilities are operated; 3) how the City’s project could impact listed fish species and recovery planning efforts in the Russian River; and 4) that the City should focus on reuse of this resource instead of disposal into the Russian River.
The City’s proposed Discharge Compliance Project proposes a new direct or indirect wastewater discharge location along the Russian River. The Agency operates six collector wells along the Russian River in the Mirabel and Wohler area which supply drinking water for approximately 600,000 people in Sonoma and Marin Counties, including residents of the City.
In addition, the Agency has been evaluating an expanded water supply system which could include new collectors upstream of the Agency’s existing collectors. Similar to the results shown for river discharge locations in the City’s Draft Engineering Report for the Discharge Compliance Project, there may be only a few locations along the Russian River that are suitable for the Agency to install water diversion structures and pipelines.
In addition, the features that make a site suitable for a river discharge location may also be the same features that make a site suitable for water diversion facilities. The Agency is concerned that the City’s Discharge Compliance Project could have detrimental impacts on the planned infrastructure necessary for the Agency’s water supply project and may cause significant delays in the Agency’s environmental review process.
Attached is a map from the Agency’s Notice of Preparation of an Environmental Impact Report for the Agency’s Water Supply, Transmission and Reliability Project which shows the area of interest for the Agency’s future water supply facilities along the Russian River.
The Agency recommends that the City coordinate with the Agency so that the City’s Discharge Compliance Project doesn’t impact the Agency’s ability to construct future water supply facilities. The Agency and its customers (including the City) have benefited from having water supply facilities that provide a high quality source of drinking water that is relatively inexpensive to operate.
The only treatment necessary beyond the natural filtering provided by the sand and gravel materials along the Russian River is: 1) the addition of chlorine to provide a residual amount of disinfectant throughout the transmission system; and 2) the addition of sodium hydroxide to adjust the pH of the water. The Agency and its customers have not had to share in the expense of constructing and operating a surface water treatment plant.
The potential impact of a new wastewater discharge location on the Russian River, which could jeopardize the way the Agency’s existing water supply facilities are operated, needs to be considered. Accordingly, the Agency has brought this item before the Technical Advisory Committee of the Water Advisory Committee (TAC/WAC) in October (2006) to have the TAC/WAC provide direction on what position the Agency should take with regards to the City of Santa Rosa’s Discharge Compliance Project.
***additional comments from TAC/WAC to be added here***
Attached are copies of comments from the Agency submitted to the City January 12, 1987 and October 7, 1996 with regards to a proposed Russian River wastewater discharge associated with the City’s Long- Range Wastewater Management Plan and Subregional Long-Term Wastewater Project. These comments from 1987 and 1996 express the Agency’s concerns with how a direct wastewater discharge into the Russian River could impact the Agency’s water supply facilities due to the presence of pathogens and inorganic and organic compounds that may be present in the wastewater.
The concerns brought up in these comment letters are still valid and currently there are additional concerns that need to be addressed associated with the emerging issue of pharmaceuticals and personal care products that may remain in treated wastewater. Pharmaceutically active compounds (e.g., caffeine, nicotine, and aspirin) and numerous personal care products (such as fragrances and sunscreens) and drugs from a wide spectrum of therapeutic classes can enter waterways through a variety of routes including treated wastewater.
The City should study what potential impacts to water supplies and the aquatic environment could occur as a result of discharging the City’s wastewater into the Russian River. Since 1991, the National Marine Fisheries Service (NMFS) has listed twenty-six Evolutionarily Significant Units (ESUs) of salmonids on the Pacific Coast as endangered or threatened species under the federal Endangered Species Act (ESA). The ESA requires that recovery plans be developed and implemented for the conservation and survival of these species.
For recovery planning, NMFS has divided the ESUs on the Pacific Coast into nine geographic domains and will develop recovery plans for each. The Russian River watershed is part of the North-Central California Coast Recovery Planning Domain (Planning Domain), which encompasses watersheds from Mendocino County to Santa Cruz County and supports populations of coho and Chinook salmon and steelhead.
These populations of salmonids have been federally listed as Threatened or Endangered since the late 1990’s. Efforts to restore habitat and identify what is needed to recover these populations have been ongoing ever since. In the Russian River some of these efforts have included implementation of the coho salmon broodstock program at the Don Clausen Hatchery, many habitat restoration and fish passage projects funded through the Pacific Coastal Salmon Recovery Fund (and other state and local funding sources), as well as, completion of a state recovery strategy for California coho salmon.
While these efforts have fostered the development of federal-state- local partnerships in salmonid recovery and conservation, little real progress can be made without the commitment and involvement of the state and local entities affected by the listings.
Recognizing this, beginning in February and again in June of 2006, the Board of Directors of the Sonoma County Water Agency approved funding assistance to NMFS to facilitate the development of federal recovery plans for coho and Chinook salmon and steelhead in our region. Additionally, the Agency’s Board approved funding to support the development of a local plan to begin implementing early recovery actions as specified in the state’s coho recovery strategy and to support a position at NMFS to work with agencies and landowners toward development of a salmonid conservation plan for Alexander and Dry Creek valleys.
To these ends the Agency has provided over $700,000 in funds and proposes to continue supporting development of recovery plans on two fronts. The first, by identifying local solutions that address salmonid fisheries and that are compatible with local responsibilities, and the second by acquiring, collecting, and developing the data needed to assess factors limiting salmonid recovery in all the watersheds that make up the ESU.
On September 11, 2006, NMFS published their intent in the Federal Register to prepare recovery plans for all the listed ESUs of salmon and distinct population segments (DPS) of steelhead in California by January 2008. Given the considerable federal, state and local effort to support recovery plan development for the salmonid populations in our Planning Domain, the City should in the Discharge Compliance Project EIR evaluate how the City’s project could impact these three listed fish species in the Russian River watershed and identify ways in which the City can help with recovery planning efforts.
The Agency recommends that instead of looking at disposal into the Russian River that the City view this wastewater as a valuable resource that can be utilized to offset potable water use through urban reuse to directly offset Russian River water and for agricultural reuse (such as that being studied for the proposed North Sonoma County Agricultural Reuse Project) which can help reduce the reliance on groundwater and help reduce the need for surface water diversions. We appreciate the opportunity to comment on this project.
If you have any questions regarding the comments, please contact me at 547-1900.
Randy D. Poole General Manager/Chief Engineer