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Comment on Santa Rosa’s Discharge Compliance EIR

Hi water warriors!

I want to share this message with you that I recently sent to Regional Board staff.  It gives some information about SR BPU’s meeting yesterday on the consultant contract.

Please feel free to pass this around.  I’d be interested in feedback if you have any.

Have a nice day.


PS:  I’m also going to send this to Sonoma Wildlife and River Issues, so please, please forgive duplications.

Subject: Santa Rosa’s Discharge Compliance EIR

Dear Regional Board Staff:
I wanted to share my EIR comments with you on Santa Rosa’s Discharge Compliance Project and also give you some background information about them.

I am at a real disadvantage in that I have limited scientific and computer model expertise.  Commenting on Santa Rosa’s document was not easy for me, as it does present an enormous amount of technical information.  I am sure that some/much of it can be very useful for your work on permits, etc. however.  In most instances, I was unable to judge the usefulness and validity of the information presented although I had concerns about many of the assumptions upon which the project was based.  A lot of it also seem repetitive and of questionable usefulness.  Much of it seemed like padding to me.

I ended up just looking at certain sections and focused on water quality and project description.  I focused on the big picture in terms of the actual need for the project, the sizing of it, and current economic and cultural conditions, the sizing of which I believe was vastly over-inflated.  The EIR for instance, provided no update on population trends and said nothing about current economic and housing crises.  It was designed in a vacuum.

At the BPU meeting yesterday, they were scheduled to approve the next phase of the contracts with the three major contractors.  At that meeting I made the case that site #D1 was fatally flawed and that I don’t think they will be able to get the permits for them.  The EIR describes tearing up Steelhead Beach, a relatively new public river access, to place a 30′ paved road where there is now a 6′ wide trail in order to install a 48"pipe that would accommodate 69 mgd. They even had the nerve to call it an "improvement". This road would be used regularly for maintenance of the huge diffuser that would be placed in the river bed. It would also involve removal of a very large amount of riparian habitat. Who knows what other damage that would do? (There are other impacts as well which are described in my comments.)

The park is owned by the Resource Conservation Board of the CA. Dept. of Fish & Game.  It is managed by County Regional Parks as a habitat preserve and low impact public access.  SR would need a County use permit among other things.  Parks has already expressed grave reservations about this use of the property for a sewer system.

In the meantime, the City has already taken two of the four sites out of consideration (one the week before the close of the comment period). Yesterday I asked the BPU to take this one off as well.  They looked very uncomfortable; in my view their resistance on this was very weak, especially since they had set the precedent of removing two others (the first was just upstream of SCWA wells, which the latter protested heavily).  That does not mean however, that it would be an easy task to remove that site.  It is an action many are committed to however.

They denied approving the new consultants contracts to respond to the EIR comments and other tasks; they want more information because they are concerned about possible padding in the $750,000 contract for all consultants.  Also, the bonds they would use won’t sell until early July, so there is no huge hurry.

My comments were in two parts.  For several reasons, listed in my second set of comments, I was late with the second set.  It appears as though they will respond in writing to both sets however.  They claim they got about 1000 comments (NOT 1000 letters); they added up the comments in all letters; not sure how many letters there were.  It’s tricky however, since many of the questions were quite expert in nature and will require outside experts in some cases to respond to them.  Some responses require very brief answers and take little time to write.

In my comments, I recommend that they need no discharge at all (or hardly at all).  These are backed up by the situation last year of having only 190,000 mg to discharge (as opposed to 4 BG before the Geysers was on line).  Also, I believe that the City’s average dry weather flow was around 15.6 mg last year.  It has been going down at the same time that the population has supposedly been going up.  Of course, none of that was analyzed in determining the future capacity needs of the system.

I believe that a combination of increased Geyser’s discharge, ag and urban irrigation, more conservation (which they will have to do anyway because of these water shortages), more storage (we are not opposing that and I’m not sure if anyone else is either),  more I&I (this EIR did not even take credit for the small amount they are doing now), and perhaps a very minimal amount of Laguna discharge as backup during wet years (assuming they deal with the nutrient issue and hopefully do advanced treatment) will suffice without the very environmentally harmful and super expensive river discharge.  (I didn’t address the Healdsburg discharge simply because I knew less about the site and I knew others would address that.  Also, I felt it would be less likely to be selected since the environmental impacts were greater because of the lower flow available for "mixing".

I am disappointed that so much reliance seemed to be on "mixing".  Yet I was pleased to see that the Laguna discharge would be done in a much more sensitive manner, instead of the large dump during high flows that characterized their past methods.  It was unclear to me whether the Laguna discharge would continue to be based on flows at the Hacienda Bridge or of the receiving water itself.  It was also unclear how discharges would be managed during floods when Delta Pond has to be opened up to flood waters. If you can answer my question, I would appreciate it.

I would welcome any response you have.  If you submitted comments on the document, I would love to see those.  I would also ask that these comments (and this message) be made available to your Board members.

Thank you and have a nice day.


PS:  One other point I wanted to make.  The document talks about impacts as through these new systems would always be operating properly.  I submitted copies of all the ACL’s since 1995 indicating all failures of the system, asking that they describe impacts when these failures occur.  I believe that system failures should be fully considered when permits are written, if they aren’t already.  Certainly they should be considered in EIRs.

One last thing.  This EIR relies heavily on certain future actions by your Board which may be controversial, such as the mixing zone issue.  I am also concerned about the way the CTR issue is being handled, although I don’t have the scientific expertise to challenge it directly.  It seems that the City is successfully getting most of the regulatory barriers removed to move forward.  While there are many details in the permit that appear to guide their projects in an environmentally sensitive way, nevertheless, the fact of all these violations demonstrates that this does not always work out. Also, staffing is not always adequate to fully monitor activities.  I am very concerned about the "incidental runoff" issue for this reason.