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Basin Plan Amendment Decisions at Water Board Meeting

Hi everyone:
There is an extremely critical meeting coming up at the North Coast Regional Board on July 23rd at about 9 AM at their offices near the airport at 5550 Skylane Blvd.
This is the meeting where they will decide on a Basin Plan Amendment (water law for the North Coast and Russian River) that would allow for some “incidental discharges” of wastewater as a result of summer irrigation in the urban areas.  It does not currently apply to agriculture but could be implied to do so down the road.  This is Item #10 on their agenda for that day.  As of tomorrow, you will be able to view the response to comments (submitted last Jan. 29th), staff report and proposed resolution and Amendment language.
BASICALLY THIS NEW AMENDMENT GREATLY DIMINISHES THE CURRENT WASTE DISCHARGE PROHIBITION THAT EXISTS.  IT WILL LEGALIZE “INCIDENTAL DISCHARGE” OF WASTEWATER IRRIGATION IN URBAN AREAS DURING SUMMER WHEN FLOWS ARE GREATLY LOWERED, RECREATION USE IS HIGH, AND THE CREEKS’ ABILITY TO ASSIMILATE POLLUTION IS GREATLY DIMINISHED,
WHILE THERE ARE OTHER TYPES OF “LOW THREAT DISCHARGES” MENTIONED IN THIS AMENDMENT, THE OTHERS CAN BE PLANNED AND MITIGATED IN ADVANCE, THE SUPPOSED “LOW THREAT” DISCHARGE OF WASTEWATER CAN HAPPEN ANY TIME, ANYWHERE. SUPPOSEDLY BEST MANAGEMENT PRACTICES (BMPs) WILL CONTROL THIS, BUT CANNOT BE FULLY TRUSTED.  WE BELIEVE THE BMPs SHOULD BE ESTABLISHED FIRST, BEFORE THIS AMENDMENT IS AUTHORIZED.
THESE DISCHARGES SHOULD NOT BE ALLOWED.  THERE ARE MANY UNREGULATED TOXINS IN WASTEWATER HAVING MANY UNKNOWN IMPACTS.  STRONGER CONSERVATION MEASURES BY LANDSCAPERS AND BUSINESS PARK OWNERS COULD MAKE IRRIGATION WITH WASTEWATER UNNECESSARY AND SHOULD BE PRIORITIZED.
PLEASE PLAN TO ATTEND THIS MEETING IF AT ALL POSSIBLE.  EVEN IF YOU DON’T SPEAK, WE NEED SUPPORTIVE FRIENDS IN THE AUDIENCE.
TO GET BACKUP INFORMATION:
Google North Coast Regional Water Quality Control Board
Open:  (on left) Decisions Pending & Opportunities for Public Participation then: Basin Plan Start then: Basin Plan Amendments & Projects then: Low Threat Discharge Amendment
There is also a meeting the day before (1:30) on the Storm Water Permit which addresses the same issue but a decision will not be made on that permit until Oct. and the Basin Plan change will be decided at this meeting. If you can only go to one, the Basin Plan meeting is much more important for now.
I have attached my comments on both the MS4 Permit which were just submitted and which address these issues and my comments on the Basin Plan Amendment from last January,  and also an article that has been submitted to the West County Gazette that will come out within the week.  This will give you an idea of the key issues.
Mainly:  we do not believe that “incidental runoff” from wastewater irrigation should be allowed until one or both of the following occurs:
A much higher degree of wastewater treatment is achieved OR The promised Best Management Practices are fully vetted and approved in a public process BEFORE the Amendment is approved.
If you cannot attend but want to send a protest email, please send to the following:
Mona Dougherty at MDougherty@waterboards.ca.gov John Short at JShort@waterboards.ca.gov Cat Kuhlman at CKuhlman@waterboards.ca.gov
If you have questions about this, please feel free to email me.
ALSO:  PLEASE PASS THIS MESSAGE AROUND TO YOUR LISTS OF PEOPLE WHO MIGHT BE INTERESTED IN THIS ISSUE.
Thank you and have a nice day.
Brenda
Hi everyone:
There is an extremely critical meeting coming up at the North Coast Regional Board on July 23rd at about 9 AM at their offices near the airport at 5550 Skylane Blvd.
This is the meeting where they will decide on a Basin Plan Amendment (water law for the North Coast and Russian River) that would allow for some “incidental discharges” of wastewater as a result of summer irrigation in the urban areas.  It does not currently apply to agriculture but could be implied to do so down the road.  This is Item #10 on their agenda for that day.  As of tomorrow, you will be able to view the response to comments (submitted last Jan. 29th), staff report and proposed resolution and Amendment language.
BASICALLY THIS NEW AMENDMENT GREATLY DIMINISHES THE CURRENT WASTE DISCHARGE PROHIBITION THAT EXISTS.  IT WILL LEGALIZE “INCIDENTAL DISCHARGE” OF WASTEWATER IRRIGATION IN URBAN AREAS DURING SUMMER WHEN FLOWS ARE GREATLY LOWERED, RECREATION USE IS HIGH, AND THE CREEKS’ ABILITY TO ASSIMILATE POLLUTION IS GREATLY DIMINISHED,
WHILE THERE ARE OTHER TYPES OF “LOW THREAT DISCHARGES” MENTIONED IN THIS AMENDMENT, THE OTHERS CAN BE PLANNED AND MITIGATED IN ADVANCE, THE SUPPOSED “LOW THREAT” DISCHARGE OF WASTEWATER CAN HAPPEN ANY TIME, ANYWHERE. SUPPOSEDLY BEST MANAGEMENT PRACTICES (BMPs) WILL CONTROL THIS, BUT CANNOT BE FULLY TRUSTED.  WE BELIEVE THE BMPs SHOULD BE ESTABLISHED FIRST, BEFORE THIS AMENDMENT IS AUTHORIZED.
THESE DISCHARGES SHOULD NOT BE ALLOWED.  THERE ARE MANY UNREGULATED TOXINS IN WASTEWATER HAVING MANY UNKNOWN IMPACTS.  STRONGER CONSERVATION MEASURES BY LANDSCAPERS AND BUSINESS PARK OWNERS COULD MAKE IRRIGATION WITH WASTEWATER UNNECESSARY AND SHOULD BE PRIORITIZED.
PLEASE PLAN TO ATTEND THIS MEETING IF AT ALL POSSIBLE.  EVEN IF YOU DON’T SPEAK, WE NEED SUPPORTIVE FRIENDS IN THE AUDIENCE.
TO GET BACKUP INFORMATION:
Google North Coast Regional Water Quality Control Board
Open:  (on left) Decisions Pending & Opportunities for Public Participation then: Basin Plan Start then: Basin Plan Amendments & Projects then: Low Threat Discharge Amendment
There is also a meeting the day before (1:30) on the Storm Water Permit which addresses the same issue but a decision will not be made on that permit until Oct. and the Basin Plan change will be decided at this meeting. If you can only go to one, the Basin Plan meeting is much more important for now.
I have attached my comments on both the MS4 Permit which were just submitted and which address these issues and my comments on the Basin Plan Amendment from last January,  and also an article that has been submitted to the West County Gazette that will come out within the week.  This will give you an idea of the key issues.
Mainly:  we do not believe that “incidental runoff” from wastewater irrigation should be allowed until one or both of the following occurs:
A much higher degree of wastewater treatment is achieved OR The promised Best Management Practices are fully vetted and approved in a public process BEFORE the Amendment is approved.
If you cannot attend but want to send a protest email, please send to the following:
Mona Dougherty at MDougherty@waterboards.ca.gov John Short at JShort@waterboards.ca.gov Cat Kuhlman at CKuhlman@waterboards.ca.gov
If you have questions about this, please feel free to email me.
ALSO:  PLEASE PASS THIS MESSAGE AROUND TO YOUR LISTS OF PEOPLE WHO MIGHT BE INTERESTED IN THIS ISSUE.
Thank you and have a nice day.
Brenda