“Runoff” is Polluted Water Entering our Rivers

By Brenda Adelman
Twenty-five years ago, river citizens were enraged when they learned that Santa Rosa was planning an illegal dump of 800 million gallons of secondarily treated wastewater into the Russian River because their storage ponds were too full. Russian River Watershed Protection Committee has been pressuring them incessantly ever since to limit winter discharges. The City finally achieved zero discharge last year. But sadly, some summer discharges have just been legalized in the guise of “non-storm water runoff”!
New permit allows some runoff into impaired water bodies…..
On October 1st, the Regional Water Quality Control Board adopted a new joint permit for Santa Rosa, the Sonoma County Water Agency, and the County of Sonoma, with the intent of controlling storm and non-storm water runoff. Storm water runoff causes many pollutants deposited on city streets during the dry season, such as grease and oil from vehicles, to run off into our waterways when it rains and seriously degrade water quality.

Russian River Watershed Protection Committee and numerous other groups strongly support these new controls. But we adamantly oppose allowing “non-storm water runoff” from wastewater irrigation. Wastewater runoff contains many unregulated and poorly monitored chemicals, including endocrine disruptors, pesticides and herbicides, pharmaceuticals, and the growing problem of anti-biotic resistant germs. Regional Board staff have been severely cut back because of State budget problems, and a lack of adequate oversight would cause wastewater to ‘slip through the cracks’….

Santa Rosa is planning a new pipeline project to irrigate business park lawns and public parks in the summer, using wastewater on the landscaping that would normally be watered with potable supplies. This permit legalizes “accidental” wastewater runoff. Yet accidents happen all the time, but now concerned citizens would be prohibited from filing lawsuits if violations are not enforced by regulatory agencies.

The new permit requires “best management practices” of irrigation contractors, with the intent of preventing runoff. Yet we have witnessed first hand rampant irrigation runoff in Rohnert Park (not party to this agreement, but part of Santa Rosa’s Subregional Wastewater Treatment System and under a special reclamation permit that is currently not adequately enforced). We worry that similar runoff practices will occur in Santa Rosa as well and in fact, this last summer, they discovered about 40 over-irrigation incidents a week using potable water.

The Laguna is extremely water quality impaired and the Russian River is only slightly better. Both have serious temperature and sediment problems and the Laguna is badly impaired by nutrients. (Treated wastewater has a lot of nutrients.) Invasive plants are totally choking many of the streams west of Rohnert Park, and irrigation runoff is probably a contributory cause.
Major concerns about the Non-Storm Water Runoff requirements…
• Tertiary treated wastewater is considered safe enough by health regulators to reuse in most circumstances but for direct ingestion, in spite of the voluminous information about the hazards to humans and wildlife from unregulated pharmaceuticals, personal care products, anti-biotic resistant pathogens, etc. It will take many years for State Regulations to catch up with the problem and in the meantime, many species (including human) will greatly suffer as a result of increased contact with many unregulated, toxic substances.

• The State has approved a Water Recycling Policy which heavily promotes the use of wastewater for irrigation in order to save potable water. This is a notable goal, but in the case of Santa Rosa, an urban irrigation program WILL NOT SAVE ANY WATER. They will just transfer some of their agricultural irrigation to the urban area. Furthermore, most wastewater is under contract to be reclaimed at the Geysers anyway. So the goals of the State's Water Recycling Policy are already being realized by Santa Rosa and the City’s planned urban irrigation program IS REALLY UNNECESSARY.

• This permit fails to provide any precise numerical meaning of “incidental runoff”. We have no idea if “incidental” or similar euphemisms could mean 5 gallons, 50 gallons, 500 gallons or 5000 gallons. Furthermore, harm may be impossible to prove, especially since a leak can go undiscovered for weeks and still be legal under this permit.

• The new permit supposedly only allows discharges that are truly accidental and where only a “small” (undefined) amount escapes. What is not clear is how they will determine that broken irrigation equipment was not formerly in a state of disrepair, and is broken for the first time, and is discovered almost immediately after it accidentally breaks.

• It is unclear how best management practices will prevent harm from occurring. Specific controls will be implemented by Santa Rosa through third party contracts and there will be no direct Regional Board staff oversight in the monitoring of runoff incidents. Incidental runoff is stated as infrequent, short in duration, low in quantity, accidental, etc., but we have no idea how that will be enforced through best management practices. If “accidents” go a long time before being discovered, the water quality ramifications could be severe. (Santa Rosa will require that third party contractors check the system every week or two, while true compliance should demand inspections every hour or two.)

• This permit fails to differentiate between summer and winter runoff and the comparative impacts to aquatic life and their habitat based on amount of flow in receiving waters. It assumes that ANY discharge from irrigation runoff will be so inconsequential that it is not necessary to describe impacts. Yet the mere fact that the Laguna is grossly impaired for nutrients, should demand a higher regulatory standard.

• This permit fails to address, not only unregulated pollutants in the wastewater, but the massive chemicals and fertilizers used on lawns to keep them green. These will runoff into the drainage/receiving water along with the wastewater and exacerbate the toxic impacts even further.

Santa Rosa has allowed their reclaimed water to be used for irrigation for at least 40 years. Currently there are about 85 contractors using their wastewater, including the City of Rohnert Park, who regularly allows wastewater runoff.

So now Santa Rosa will have permission to legally 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. We fail to see how this program will improve our creeks and resolve the long term problems of high temperature, high nutrients, and low dissolved oxygen.

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