Some of you were wondering if the environmental challenge to Santa Rosa’s NPDES permit, lead by Alan and others, was also dismissed. I thought it was, but here is Alan’s verification.
Forgive duplications. I can generally support Alan’s comments, but the devil is in the details. This business of incidental runoff in the summer is still a big problem in my mind. It will take stringent controls and a lot of management to prevent significant long term problems.
I want to thank Alan and Mike Lozeau for the work on this permit challenge. I feel this dismissal is very good news, even though the permit is less than perfect.
Have a nice day.
Dear Council Members and Creek Managers:
As you can see by the attached notice, the Petition (appeal) to the
State Water Resources Control Board by the City of Santa Rosa for
relief of responsibility to meet standards imposed by the current
NPDES/Waste Water Discharge Permit has been dismissed.
Obviously, the SWRCB and the Regional Board think the current NPDES
permit is fair and essential to the task of recovering beneficial
uses of water in the Laguna.
Both the Laguna and Santa Rosa Creek remain on the State’s Impaired
Water Bodies (303 d) list.
It is incumbent (the City is responsible) for the City to address
issue related to discharge of pollutants into the Laguna and Santa
Rosa Creek. The City will be held physically and financially
accountable for any failures in this area. Efforts by the City’s
consultants, to the tune of millions of dollars, to evade such
responsibility can be better spent in by addressing pollutant control issues.
The City has made some progress in their Stormwater (Non-Point
Source) program, recycling, and creek management. Though progress has
been made and acknowledged (thank you for your efforts) – greater
efforts and successes are mandatory.
Improvements can be made in the following areas:
Better management for Santa Rosa Creek as a functioning stream. Use
of Santa Rosa Creek sole as a storm drain for “flood control”
purposes will not allow recovery. Let your own biologists guide
you. Improvement in management can occur without spending tons of
money. Improving riparian filtration would help a lot.
Better enforcement of your Stormwater – Non-Point Source control
plan. You have made progress – but – more enforcement is needed – in
including strict standards for discharge from impervious surface
areas. Your own building inspectors should be trained to spot and
enforce issue. Greater effectiveness in this area would help limit
Water Recycling should be strongly encouraged. I know you are trying
to move forward in this area. More can be done. Safety systems to
protect from accidental discharge of recycled water need to be in place.
Please consider incorporation of these ideas and – below:
New – Encourage placement of water collection systems for homes and
impervious surface areas. These systems can help, both, with water
use, peak discharge control, and pollution control.
New – Use of waste water to irrigate City owned Redwood
plantation(s). This can pencil out in the long run – even if David
Smith says no.
Carry On !