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Comments on SR’s Waste Water Storage Facilities Proposal

City of Santa Rosa
Board of Public Utilities
69 Stony Circle
Santa Rosa, CA 95401

Subject: Initial Comment (Concerns) Waste Water Storage Facilities Proposal

These comments are delivered to the Board of Public Utilities and the City Council in lieu of attendance of a meeting on this subject that was scheduled for today. Notice of the meeting published in the Press Democrat was late and failed to declare the scope of the project and responsible department (BPU) and contact information.

The need, extent, cost, and potential effects of this proposed project are extensive. Before needless expenditure and serious error is incurred serious thought and environmental review is necessary – considering all options, possibilities and consequences. The City of Santa Rosa has serious waste water issues to deal with. Limiting the impacts from waste water discharge will, both, reduce the burden on the rate payer and the environment. Coast Action Group is interested in conserving in the area of economics and environmental resources.

The first recommendation we would make is to work harder on the infiltration problem. Reducing the amount of waste water treated (through infiltration reduction) not only reduces demand for storage, the overall costs of treatment and discharge requirements would be reduced.

In consideration of new storage facilities and their placement, the following issues must be considered:

Placement of storage facility in areas near the bottom of the drainage area, near the Laguna, will cause unavoidable consequences due to changes in hydrology – increased flooding. Evidence from recent flooding events indicate that, mostly due to development – increased impervious surface area, the hydrograph for the area has changed where lag time to peak flow is reduced with resulting significant changes of quantities of water and increased flooding. Large storm events have been known to flood the current site of the waste water plant. Use of land for storage in the flood prone areas will limit the available area (in areas known to flood) for runoff storage thus raising flood water levels.

Thus, any environmental review of this project must consider the impacts of such construction on the hydrograph and flood storage capability of the area. It is suggested that storage sites out of the flood plain be considered. There should be a prioritization of available sites by relevant issues such as adverse hydrologic impacts and risk and other important unavoidable impacts.

Environmental review for this project must also consider:

Consistency with the City’s Standard Urban Storm Water Plan – Goals to preserve natural areas, reduce pollution, and to reduce peak runoff.

Consistency with Basin Plan (Water Quality Control Plan) for the area.

Consistency with the tiger salamander management and recovery plan.

Consistency with protection of federally listed species.

Note: Please consider Coast Action Group an interested party in regards to this project. Coast Action Group requests formal noticing on actions related to this project.

Sincerely,
For Coast Action Group
Alan Levine