SR’s Water and Wastewater Plans

Water Watchers:

I’ve been extremely busy with my faire, which will thankfully be over in ten days, and I’ve neglected to keep you all posted on today’s very important BPU meeting (Thurs. At 1:30 starting in Mayor’s Conference Room and then moving to City Council Chambers). Of course it cannot be a coincidence that the BPU is discussing four major new documents in one meeting right before a major holiday. (Perhaps the recent election has something to do with this. Could they be ramming all their projects through before new BPU members are appointed?)

They will be talking about recommended storage sites for their irrigation program, their Draft Screening Report for “discharge compliance” (ie, river discharge, which, by the way, is not being pursued to accommodate new growth, they say), their new Water Master Plan and Wastewater Master Plan. I have obtained most of the documents (the latter two cost $235) but have had no time to read much as yet.

I believe there will be formal action on these at their Dec. 5th meeting. The following projects have been recommended to be dropped from further consideration from their “Discharge Compliance Project”:

Direct discharge site D2. This is the Windsor site just upstream of SCWA Wohler facilities and River Front Park. (near Windsor River Rd.) The other direct discharge sites (Forestville, Healdsburg, and Alexander Valley) will continue to be studied.

Indirect discharge will also be dropped along with the “No discharge, 100% reuse project”.

BPU packets are on their website, or if you come to the meeting, they have hard copies of their agenda materials available. Also, you can download the Screening Report from their website.


PS: Board of Supervisors will consider the new Urban Water Management Plan on Dec. 5th at their meeting in the AM.

Santa Rosa Creek Plan and Toxic Wastes in Water

In part, my response to the Toxics in the steam issue, was somewhat flippant. The type and levels of toxics is not news and is a serious problem – and needs to be looked at by the City and administering agencies.

As far as the City of Santa Rosa goes, the City Council, at great cost to the waters in it’s sphere of influence and economic cost to the City has abdicated understanding and control of the situation to consultants and the BPU. This has put the City in the position of spending great sums of money not to solve pollutant problems.

Addressing, both, the City NPDES Waste Water Permit conditions and the toxic issue (as they are linked by the permits and by emperical interaction) will take organized action by the City, responsible agency, and clean water advocates. The City Wide Creek Master Plan and associated DEIR are open for comment.

The City Wide Creek Master Plan and DEIR must address degraded conditions and 303 (d) listings of Santa Rosa Creek and it’s tributaries and how the Master Plan and the City Storm Water Plan will effectively address the issue of pollutant control and pollutant inputs. Also, the Master Plan and DEIR must address the issue and effects of Santa Rosa Creek discharges to the Laguna.

The fact that the City of Santa Rosa’s Stormwater Plan is not enforceable or effective must be a consideration in the above noted action is a great place for the City and all interested parties to address these issues and the inter-relationship of this issue with the Waste Water NPDES permit.

It is not clear if the City Council should be approached now on the issue of directions and choices – or – if more work should be done by agency and the City Wide Creek Plan to clarify some issues.

Help Defend the Listing of Coho Salmon

I am asking for monetary support to help defend the listing of Coho salmon as Endangered under the California Endangered Species Act.

Recently a trial court spurned a legal challenge to the listing of Coho salmon as endangered under the California Endangered Species Act – CESA..

The CESA listing for Coho is important and provides enforceable language to support land use and water use activity for recovery of the species (See Coho Recovery Guidelines at the DFG website). Actions include language for stream protection, water use and diversion, and some logging regs.

Ag and timber interests have chosen to appeal the lower court decision and challenge the listing in the State Court of Appeals. See message, below, from CalTrout – litigation lead.

Defending our position will cost money. I would like to raise $2,000 to add to the $5,000 to $7,000 already committed – with a total goal of about $10,000.

Please help support our position(and our rivers and fish) in the courts with a donation.

Please write a check to CalTrout for $50, $100, or more. Identify your check for “Coho defense”.

Please send checks to me – or – CalTrout at addresses noted below in this e-mail.

If you mail a check directly to CalTrout, please let me know so I can keep track of funds and checks.

Thank You!

The appeal for the coho litigation has been filed (see the attached notice).

The most notable things are:
1) CFA et al. (the petitioners and plaintiffs) are now represented by Pacific Legal Foundation
2) California Chamber of Commerce, Greater Eureka Chamber of Commerce and Save our Scott and Shasta Valleys, Inc. are not listed on the appeal as petitioners and plaintiffs
3) The petitioners and plaintiffs have elected to proceed without using the trial courts record (reporter’s transcript or clerk’s transcript) but rather by creating their own by appendix
4) The petitioners and plaintiffs opening brief is due no later than 70 days (12/20/06) from this notice of appeal, and ours is due within 30 days after theirs (1/19/07)
5) My understanding is that if we win on appeal and it is published the case will then be precedent setting

We will need to raise additional funds to meet this challenge and might also want some organizations/groups to file Amicus Briefs.

Please let me know who is willing to assist in this effort. We have far too much invested to discontinue with this important effort to protect fish and watersheds.

Best wishes,

Thomas J. Weseloh
Northcoast Manager, California Trout
1976 Archer Rd.
McKinleyville, CA 95519
707 839-1056 phone
707 839-1054 fax

Alan Levine
Coast Action Group

Waterborne Drugs A Growing Concern

By Mike Lee

JOHN GIBBINS / Union-Tribune

Water samples from Otay are prepared for analysis at the San Diego Water Department’s water quality laboratory.

At homes across San Diego, thousands of residents take medications each day for everything from Alzheimer’s disease to sexual dysfunction. But their bodies don’t absorb 100 percent of each drug. The unused portion is excreted and – literally – flushed down the toilet along with whatever outdated pills that people might dump into the bowl for disposal.

From there, the medicine mixes with cleaning agents, hormones, plasticizers and a plethora of other compounds in the city’s wastewater.

Under a controversial proposal to be considered by a City Council committee tomorrow, some of the water treated at San Diego’s North City Water Reclamation Plant would be purified enough to become drinking water. The effort is designed to reduce the region’s reliance on imported water.

But what about drugs and other possibly dangerous substances that might remain in the recycled water?

Water providers don’t routinely check for pharmaceuticals, personal-care products or numerous other substances that scientists call “emerging contaminants.” Sewage plants aren’t designed to remove them. Neither federal nor state agencies regulate them in water supplies. And California hasn’t taken some of the most basic steps to keep them out of the state’s waters.

Continue reading “Waterborne Drugs A Growing Concern”

Santa Rosa NPDES Permit Appeal and Letter by RW and CAG

See attached appeal by River Watch and Coast Action Group and letter pasted below to Santa Rosa City Council from Coast Action:

Dear City Council Members:

The City of Santa Rosa has filed an appeal to their new Wastewater NPDES permit.

As stated previously, I think this is a mistake as the permit was quite lenient – allowed for discharge beyond acceptable standards and allowed for pollution trading as a method to reach “Zero” discharge.

Northern California Riverwatch and Coast Action Group have filed a petition with the SWRCB requesting compliance with the Clean Water Act, State Water Code, and the Basin Plan for the North Coast Region. I suggest you take the time to read the petition.

As you can see, the NPDES process can, should, and will likely become more arduous. It is time to look at future outcomes and options rather than adhering to the policy of hiring experts and lawyers that can do little to change the inevitable (under the law). Solving this problem mandates personal understanding and involvement by those in charge of the process – the City Council.

For many years you have committed, on a yearly basis, millions of dollars in ways that have not and will not work for the interests if the City. This several million dollars per year expenditure adds little to problem resolution. It only retards progress towards a solution and misdirects dollars that could have been spent on solutions. It should also be added that the burden of these expenses related to increased discharges is unfairly supported by the historic base of ratepayers when new development should support additional increased costs for the need for pollution control.

Outcome of the Petition(s)

As stated previously, the State Board may chose not to hear either petition. If the State Board hears the petition(s) the outcome may be a stronger permit.

Are the petition(s) preludes to litigation. I hope not. This is always a possibility. Again. looking at the law fair argument can be made for a stronger permit – with time and money wasted will be the final result.

Outcome of Laguna TMDL

The Laguna will remain listed as impaired (contrary to efforts of your consultants who against all evidence still claim that the City’s wastewater is not a contributor and their is no science to show nutrients are causing the problem).

The Regional Board has given staff direction to move forward with the TMDL (and Action Plan) for the Laguna. The TMDL will find that the Laguna is grossly overloaded with nutrients (Nitrogen and Phosphorus) the are having a biostimulatory effect and creating a public nuisance – ludwigia problem.

It will be found that the contributing factors are: Santa Rosa City Wastewater, Agriculture, Santa Rosa City Stormwater (development, urban runoff, other sources), , and County Stormwater Sources (not necessarily in order of contribution size).

Of all the sources listed above, which is most controllable? The Basin Plan mandates the limitation of any controllable pollutant input to an impaired waterbody. It is fairly obvious what inputs will be limited right off the bat – wastewater. Ag and stormwater contributions will be dealt with next.

Areas where the City can make progress in pollution trading:

The current NPDES permit, as written, allows for final pollutant input goal of “Zero” to be accomplished via pollution trading. It would be wise for the City to take this up as progress in this are can be cost effective and show results in the short term. Stormwater pollutant inputs into the Laguna (and Santa Rosa Creek) are probably more nutrient rich and chemical laden than the wastewater discharges. The City probably can get Regional Board, EPA, technical and funding help in dealing with this problem.

With the City’s consultants and resources still rigidly married to the idea that fighting the NPDES permit and ignoring the Laguna and stormwater problems, it will be difficult to get movement going in a new direction.

Below are some notes from previous communications with the City on the Stormwater issue:

I like the Prince Greenway and use it all the time. It is a great asset to the City.

However it has nothing to do with protecting the Beneficial Uses of Water.

Santa Rosa Creek (and tribs) are a mess and deliver pollutants to the Laguna. Santa Rosa Creek is listed as impaired for pathogens, temperature, sediment, nutrients, etc.. Not much is going on, in the case of the City, in terms of restoration and/or protect beneficial uses by limiting pollutant inputs. This problem exacerbates conditions on the Laguna – which intern compromises with the City’s waste water NPDES permit.

The City’s Stormwater Ordinance and implementation program is out to lunch (ineffective and not be enforced). This adversely influences the problems mentioned above.

My suggestions to start to initiate remedy (areas where the City can start working )are:

* Put more toilets where indigent folks can have access and not poop in the Creek(s).

* Do better enforcement on storm water issues.

* Initiate an education and enforcement program for dog poop animal waste control

* Do more waste water recycling for irrigation. You are already moving in this direction – more can be done. This suggests less need for nutrients to support plant growth as the recycled water is nutrient rich. Thus, the City can ask SR residents, via an education program, to use less nutrients for lawns and gardens

* Work with, and/or comment on, Sonoma County programs (i.e. GP 2020) where the County has jurisdiction on responsibility for activities that effect Santa Rosa Creek and Laguna resources. The City has been silent here. This needs to change. What the County does in this area effects the City.

* Get expert opinion for basis in Santa Rosa Creek (and tributary) activities that would provide protection and restorative process.

Finally: The Laguna ( and Russian River) TMDL will indicate activity necessary to comply with beneficial uses protection for Santa Rosa Creek as well as the Laguna. Consultation with the Regional Board staff to address issue will be necessary. It would be wise to start this process immediately so as not to waste money and resources. The Regional Board staff are well versed in the issues and can be helpful in solving some of these problems for the City.

It might be wise not to place all bets on your attorneys and consultants – do some research on you own. It will be way less expensive than blindly going down the same path.

Summary of NPDES conditions

The NPDES was adopted by the Board, in total, and then amended with the following exceptions related to the three basic outstanding issues:

1) Monitoring at point of discharge – The City of Santa Rosa may submit an alternative monitoring plan within 180 of adoption of the permit. The RB EO has 90 days to accept, reject, or work out modifications of any proposed alternative monitoring plan. Then, the City must implement in 90 days.

2) Sanitary Sewer Overflows prohibition – remains in the permit in original form

3) Biostimulant Limitations – Revision of language with Alternative (g) – reopening language

(g) The Discharge can complete a study justifying alternative final numerical limitation that demonstrates, if alternative limitations are allowed, will not violate receiving water standards – violate water quality objectives for the Laguna. The RB can reopen the order and make modifications.

(g) Existing water quality effluent limitations for biostimulants will stand. Such limitations may be adjusted by TMDL findings. “No net loading” effluent limitations can be met by; 1) reducing effluent concentrations, 2) reducing loads through recycling, 3) reducing loads by offset trading with other sources. This reopener is attached to the completion of the above mentioned study.

4) The Board gave staff direction to start moving on the TMDL for the Laguna. This may settle or adjust some issue.

Thus, the future of the NPDES is attached to the TMDL for the Laguna and the Russian River

In the interim, mass loading limits are in force. I am not sure about the final limitation. Historic inputs of 270,000 pounds of N and 48,000 pounds of P seem like a lot – while the City of Santa Rosa continues to deny that nutrients are impacting the Laguna. Under the NPDES permit, compliance with Water Quality Objectives are mandated to occur in 5 years. The EPA may agree with the above noted changes – or – they may indicate and require some changes.

Alan Levine
Coast Action Group


Santa Rosa Water and Population

Daisy Pistey-Lyhne – Greenbelt Alliance wrote:
Thought you all might be interested in reading about a recent meeting between Concerned Citizens for Santa Rosa, and Dick Dowd of the Board of Public Utilities. He mentioned some info given to him by Brenda Adelman.

From: Anne Seeley, Concerned Citizens for Santa Rosa

Our guest today was Dick Dowd, Chairman of the Board of Public Utilities. He was invited as a result of his recent declaration to the City Council that future water supply options are limited and that the Urban Reuse Water Program (URWP) being considered as part of the Incremental Wastewater Reuse Program is the best way to offset potable water use.

Dick described the dual responsibilities of the BPU: to ensure water supply as well as handle the wastewater treatment and disposal side. Our current system was created on the basis of older General Plans in Santa Rosa and Rohnert Park than current ones predicting 30,000 more residents. In addition, there are the challenges of the California Toxics Rule and new plans for protection of California Tiger Salamander.

The Sonoma County Water Agency (SCWA) has been to Washington D.C, trying unsuccessfully to obtain greater river water supplies. Dick described the 4 options for ensuring adequate drinking water: 1) greater supply from the river; 2) groundwater – studies are underway on this and 3 or 4 new wells have been drilled that yielded poor quality and/or quantities of water; 3) agricultural reuse offsets for potable water – the North County Ag District, for which the Geysers pipeline was upsized, hasn’t resolved its disputes over where storage ponds will be provided and how such water will then be shared; 4) an Urban Reuse program which could offset with recycled water the good drinking water that irrigates golf courses, parks, large multi-family housing projects and large commercial site plantings.

It was interesting that he described the suggested pipeline from Lake Sonoma to the river option as being a $500 million to $1 billion project, and very difficult to pull off.

For the URWP, storage is needed, just as in the ag projects. One reservoir site being considered is at Place To Play. The projected cost is $120 million. Currently, service to homes is not being considered, as there are risks with over-irrigating, and monitoring of thousands of homes by the BPU staff would be impossible.

On the wastewater side, Dick said that options being considered are sending up to 19 million gallons a day, up from 11 now, and switching the discharge site from the Laguna to direct discharge to the river. {Studies are underway re indirect vs. direct discharge, but my impression is that direct discharge is going to happen.} For conservation, the city has installed about 50,000 1.6 gallon toilets, and is now planning a program for “double flush” toilet installations.

Brenda Adelman has provided the BPU with analyses of recent population changes versus increases in treatment plant volumes, showing that the city’s projections for sewage flows are overstated, resulting in bigger program plans. Len Holt asked if the EPA is considering rules on endocrine disruptors in recycled water, and didn’t get an answer, as Dick described the multiple challenges the system has to meet.

Hi river lovers:

The City keeps saying they need to discharge as much as 4.5 billion
gallons during wet years. I pointed out that they only discharged 1.3
billion last year which was a VERY wet year. (The 4.5 BGY is really based
on pre-Geysers discharges).

The only reason they need to discharge during wet years is because they have leaky pipes that allow great amounts of infiltration. The pipes were built to last about 50 years at most, but the City has a 120 year “aggressive” replacement schedule. They find it easier to just engineer solutions that involve high costs and environmental destruction.

More conservation, fixing their pipes at a 50 year, rather than 120 year
cycle, and sending a little more to the Geysers, would solve the problem
without river discharge. The summer irrigation program they are planning
for $1.25 Million is not going to help a lot in the winter time unless they
have humungous storage ponds to store the water. Furthermore, there is
great risk of “incidental” runoff in the summer, during the no discharge
season, when creeks and people are much more vulnerable.


PS: The growth chart shows that SR and RP only project 30,000 more people
by 2020 (recent articles in PD imply GP projections may not reach that
however). The Growth chart shows past growth, as well as additions to flow
to Treatment Plant (TP) from that growth. The point of the second chart is
that wastewater production from anticipated growth is not keeping pace with
estimates. In 1985, flow to the TP was around 13 million gallons (MG) and
now it’s about 17.5 MG. That’s 4.5 MG in 20 years. Yet the City is
projecting twice as much to serve 30,000 people only 14 years from now. It
just doesn’t add up. The City is greatly inflating their numbers.

Identifying A New Generation Of Byproducts From Water Disinfection

Source: American Chemical Society

California scientists have identified a “new generation” of by-products of the disinfection processes used to purify drinking water at municipal water treatment plants. Such compounds, which wind up in drinking water, are termed disinfection byproducts (DBPs). The U. S. Environmental Protection Agency currently regulates some as potential health risks.

Stuart W. Krasner and colleagues tested water from 12 treatment plants specifically chosen for waters high in DBP precursors and natural organic matter in order to facilitate detection of DBPs. They tested the water for levels of regulated DBPs and 50 unregulated DBPs regarded as posing the greatest health risks. Their report is scheduled for the Dec. 1 issue of the semi-monthly ACS journal, Environmental Science & Technology.

Some treatment plants have switched from chlorine to alternative disinfectants such as ozone, chlorine dioxide and chloramines to minimize formation of DBPs. The alternative disinfectants minimized formation of some regulated DBPs. However, researchers found higher levels of other regulated and unregulated DBPs in water from plants using alternative disinfectants.

The researchers also found 28 previously unreported DBPs. Toxicity studies are needed to help determine the health implications of these emerging DBPs, researchers indicated.

Preserving Clean Water by Preserving Open Space

Jane’s letter to the PD:

Dear Editors,

I loved the Yes on F mailer, target of Chris Coursey’s politically-based critique. In the past, preserving clean water resources may have been seen as just a side benefit of preserving undeveloped lands for parks, resource conservation, and agricultural land preservation–but I challenge Mr. Coursey to name a more important resource than clean water. That mailer displays the success of a many-year citizen-based campaign to educate the County on the water-protective benefits of open space preservation.

Mike Dombeck, a former U.S. Forest Service Chief, once said: “I’m worried that we may, as a society, lose our appreciation of what the land does for us; why open space is important Š The fact that a single tree sequesters about 13 pounds of carbon each year. That a single tree produces enough oxygen for a family of four to breathe. The water filtration functions of the vegetation on the landscape. It’s important for people to appreciate and connect to the land.”

New York City has known this for generations. Because New York long ago put its money into preserving the Catskills lands that yield its water supply, New York City residents pay the least of any eastern U.S. city and have the purest water. The strategy is much cheaper than building and maintaining industrial centers for treating drinking water, and all citizens benefit from it. Sonoma County citizens should start demanding that their water suppliers adopt similarly conserving policies.

Instead of criticizing the Open Space District’s focus on water, let’s celebrate its purchases that protect over 10,000 acres of major ground water basins or natural recharge areas, and over 56,000 acres that drain to those areas, plus the headwaters of Santa Rosa Creek, Paulin Creek a large part of Dry Creek, and more. Yes on F!

Jane Nielson
President, Sebastopol Water Information Group

Stream Protection Resources

Here are some stream protection resources you requested. I had a hard time narrowing things down, some of this you probably have, but I hope they’re useful.


    EPA model ordinance language with issues and examples.
    SF Bay Regional Water Quality Control Board survey and paper on riparian ordinances and issues surrounding them.
  3. Berkeley Summary
    Document by Berkeley Creeks Task Force with lessons learned and recommendations.
  4. Santa Clara RiparianCorridor Study
    Used in the development of the Santa Clara Creeks Protection Ordinance. Good summary of considerations and science.
  5. OrdinanceGuideOalkand
    Example of a good local stream protection ordinance.
  6. NapaSetbackTechnicalMemoExerpts
    Jones & Stokes Memo with summary of science and policy of stream setbacks.
  7. SetbackLaw
    Summay of relevant case law dealing with stream buffers and takings by Ellison Folk, Shute, Mihaly & Weinberger LLP


    Good summary of stream science from a consortium of 15 federal agencies.
    National Research Council book on riparian area science and management.


    National Management Measures to Protect and Restore Wetlands and Riparian Areas for the Abatement of Nonpoint Source Pollution by EPA. Good federally endorsed BMPs.
  2. Stream Protection Local Governments
    This has a short section on building community support as well as other resources.
    How to engage stakeholders and facilitate buy-in.

Ben Livsey
Environmental Specialist
California Regional Water Quality Control Board
San Francisco Bay Region
1515 Clay Street, Suite 1400
Oakland, CA 94612