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SCWC Letter on SCWA’s Reuse Plan

The letter attached in rtf format and pasted below was sent today. SCWC letterhead was used for the signed original sent by snail mail. The letterhead footer included all current SCWC organizations except CNPS and LWV. Their abstentions from last week were not converted to votes in favor by our deadline of yesterday at noon. All other abstentions were converted to votes in favor.

Thanks everyone.

Stephen

Russian River County Sanitation District
c/o Sonoma County Water Agency
P.O. Box 11628
Santa Rosa, CA 95406

July 18, 2007

Re: Russian River County Sanitation District Irrigation Reliability and Beneficial Reuse Project Draft Environmental Impact Report.

The Sonoma County Water Coalition (SCWC) includes more than 30 organizations representing more than 25,000 concerned citizens.

SCWC believes that the proposed Russian River County Sanitation District Irrigation Reliability and Beneficial Reuse Project may not meet the long-term water management needs of western Sonoma County, and, if approved and implemented, will require significant mitigation to avoid severe environment impacts.

There are various questions that require answers before the public and other agencies can properly evaluate this project:

Project Scale:

According to the DEIR, this project is intended to solve a problem created by the inadequacy of the existing 38 acres used for spreading wastewater on the Burch property and 41 acres at the Northwood Golf Course. The project envisages an enlarged spreading area of what appears from maps included in the DEIR to be in excess of 2,000 acres, 32 miles of pipelines, up to 1,000,000 gallons of storage tanks, pumps and other installations. A 100-acre redwood irrigation project in the Guerneville area would be more than enough to serve as an adequate alternative project to satisfy the needs of this system. The project would therefore appear to be an over-enthusiastic solution to the stated problem and may induce growth in the west county. There seems to be a mismatch between the scale of the project and the need that it is addressing. What are the unstated growth objectives in the Guerneville, Occidental and Camp Meeker areas that this wastewater project is intended to serve?

Inter-subbasin Movement of Water:

Wastewater intended for this project will all be generated within the lower Russian River basin. Significant land area intended for irrigation by this project is in the Green Valley basin. There are therefore concerns that the project will cause significant imbalances in the hydrology and have impacts on the groundwater and surface water quality of Green Valley Creek. Green Valley Creek provides habitat for coho salmon, steelhead and other sensitive species. What studies have been done to address this issue?

Spheres of Influence:

Approximately 200 acres of agricultural land proposed for irrigation by this project in the lower Green Valley basin is also proposed for irrigation by treated wastewater generated by the Graton Community Services Wastewater Treatment facility. This potential conflict is mentioned in the DEIR. How will it be resolved?

Cumulative Impact of This Project and Other Projects

What is the cumulative impact of this project, proposed projects to upgrade and expand the RR CSD plant to include disinfection and to construct a new 4.5 million gallon storage equalization basin, and projects involving wastewater from Occidental and Camp Meeker?

Cost Estimates:

It is noticeable that this DEIR does not include an engineering report and provides estimates neither of capital cost nor of operating costs. How much will it cost to build this project? Who will pay these capital costs? How much will it cost to operate the project? Who will pay these operating costs? What will be the financial terms now or in the future of agreements with owners of land irrigated by wastewater generated by this project?

Accumulation of Pollutants in Soils and Food Crops:

Treated wastewater intended to be used for irrigation within the project area will contain detectable levels of endocrine-disrupting personal care products, hydrocarbons, pharmaceuticals and other as yet unregulated emerging contaminants. These pollutants may accumulate in soils and in food crops. What monitoring programs will be included in this project to assess and manage this impact?

Accumulation of Pollutants in Groundwater:

Treated wastewater intended to be used for irrigation within the project area will contain detectable levels of endocrine-disrupting personal care products, hydrocarbons, pharmaceuticals and other as yet unregulated emerging contaminants. These pollutants will accumulate in groundwater. What monitoring programs will be included in this project to assess and manage this impact?

Incidental Run-off:

Treated wastewater intended to be used for irrigation within the project area cannot reliably meet Basin Plan discharge requirements for wetlands or instream flows. Application rates of treated wastewater may exceed the ability of soils to absorb and plants to transpire all wastewater applied. This may result in incidental run-off to rivers and creeks. The project must therefore include a third-party monitoring program to assess and prevent this impact. What plans have been made for this?

Greenhouse Gas Emissions:

This DEIR must also address greenhouse gas emissions produced directly and indirectly by the various alternatives, and a demonstrable, valid and measurable program for reducing or eliminating any new greenhouse gas emissions as a result of this project.  (See, for example, California Attorney General v. City of Bakersfield, for guidance in how to address this.)

We thank you for the opportunity to comment on this project and await your responses in due course.

Sincerely,

Stephen Fuller-Rowell
Sonoma County Water Coalition