On October 1st, sometime after 8:30 (probably 9 AM) the North Coast Regional Board will consider final approval of the MS4 Storm Water and Non-Storm Water Discharge Permit for SCWA and Santa Rosa at their office at 5550 Skylane Blvd.
In general, this is a good permit in terms of addressing storm water runoff issues. (toxic runoff occurring during early rain storms in the late fall) What I am deeply concerned about however, is the cavalier treatment of “incidental runoff” which will carry out the recent approval of the Basin Plan Amendment to legalize summer irrigation runoff when streams are most vulnerable.
Board staff have been giving me the run around on this issue for a long time now. They have not adequately addressed my concerns about environmental impacts resulting from this practice (they claim all runoff will be infrequent and inconsequential) and they are giving me the run around about limiting my ability to submit new information and constraining my ability to address the Board by limiting my comments to 3 minutes (something they have not done in a very long time). I also don’t think they will allow me to submit recent pictures of irrigation overflow to Board Members.
Let me tell you the key issue, but first:
Santa Rosa gives Rohnert Park treated wastewater to use for irrigation. There is a reclamation permit constraining the use of that wastewater. There have been very few violations reported and those were always reported by outside observers. The Cities are allowed to do their own monitoring and of course almost never find anything wrong.
I have known for a long time that Rohnert Park irrigates excessively. This August, Dawna Gallagher and I went out at different times, early in the morning (I got there at 7 AM) and took many pictures of irrigation water running off into the drains. Because most of the sites irrigate before dawn, I could not get all the pictures I wanted. At 7 AM there were many damp pavements where it was apparent that water had run off earlier. I did not take pictures of those. Nevertheless, we got almost 100 pictures of irrigation water going into the streets and into drains, some of which we will submit to the Board, but it is likely that they won’t admit them into the record or allow Board members to see them until the item is resolved They have done this to me many times. They hold on to things I want distributed at the meeting until the item is over.
Santa Rosa has a reclamation permit that makes them ultimately responsible for RP’s irrigation runoff. I am most concerned because I believe that the severe nutrient pollution in the Laguna and tribs and the resulting massive Ludwigia growth is at least partially a result of this over watering. (Take a look at the Bellevue-Wilfred Channel on the Stony Point Bridge just south of Rohnert Park Expressway sometime
The Reclamation Permit states, among numerous other things, “Recycled water shall be applied in such a manner so as not to exceed vegetative demand or field capacity.” We have pictures of water running into pavements and into drainages. Almost every site where we saw sprinklers going, there was runoff. Some of the sites were over irrigating with water and not wastewater, even though RP claims great conservation savings.
Worst of all, there was a large amount of over irrigation with wastewater ON RP’s OWN CITY PROPERTIES.
The Laguna is severely impaired and is due to soon be studied in order to determine waste load allocations of nutrients. This is no time to be pushing a summer wastewater irrigation program until that study is complete.
The State has approved a Water Recycling Policy and are heavily promoting the use of wastewater for irrigation in order to save potable water. This sounds like a notable goal, but in the case of Santa Rosa, an urban irrigation program WILL NOT SAVE ANY WATER. They will just stop some of the irrigation and reclamation they are doing now and transfer it to the urban area. Furthermore, given SCWA’s recent change in direction regarding additional water supplies, there is likely to not be as much wastewater produced, and most of that is under contract to go to the Geysers and be reclaimed there. So the goals of the State’s Water Recycling Policy are already being realized in our area (to the City’s credit) and the urban irrigation program with wastewater IS UNNECESSARY. (as more and more lawns get replaced, such an irrigation program can turn out to be a huge waste of money
At any rate, the MS4 permit fails to specifically numerically define “incidental runoff” or non-storm water runoff as they call it now. They merely define it as runoff that is infrequent, low volume, accidental, etc. The problem is that they are not at all clear in how that will be assured. The Regional Board will rely on BMPs and self monitoring for regulatory compliance. This in light of a severely impaired water body that would receive the runoff. The Regional Board WOULD CONDUCT NO OVERSIGHT OTHER THAN READ ANNUAL REPORTS PRODUCED BY THE CITY OF SANTA ROSA.
Santa Rosa developed a Water Recycling Manual for their planned urban irrigation project (ultimately to cost as much as $150 million) The plan is to have third party contractors who will oversee new city irrigation sites. One of their requirements is to check the system EVERY WEEK OR TWO!!!! So tell me, how much wastewater can be released from a broken sprinkler head in two weeks?
This irrigation program would be almost impossible to enforce. (During this summer SR had “water cops” going around checking for over irrigation with potable water and found 40 incidences a week of people over watering. Now if that were wastewater, think of all the pollution!!) They would need frequent checks (hourly?) to assure that “incidental runoff” is truly incidental. OTHERWISE, IT IS SIMPLY LEGALIZING SUMMER WASTEWATER DISCHARGES!!
So now Santa Rosa will have this permission to allow incidental runoff. When it happens, it will get into the creeks and streams at a time when flow is low and they can be heavily impacted by nutrients, pesticides, herbicides, soil amendments, and all the unregulated stuff in the wastewater itself! People who recreate in the river may have to now further worry about antibiotic resistant super bugs, now found to be proliferating in water treated with UV disinfection (as SR’s system is).
THIS IS POTENTIALLY A HUGE PROBLEM AND THE REGIONAL BOARD IS JUST GIVING ME THE COLD SHOULDER AND PUSHING IT THROUGH. I NEED YOUR HELP. PLEASE SEND EMAILS TO CAT KUHLMAN PROTESTING THIS. USE ANY OF THE INFORMATION IN THIS LETTER AND PLEASE COME TO THE MEETING NEXT THURSDAY TO PROTEST. PLEASE ASK REGIONAL BOARD NOT TO ALLOW THIS RUNOFF UNTIL A NUTRIENT TMDL IS DEVELOPED FOR THE LAGUNA.