[from Town Hall Coalition]


Dear Friends:


On Thursday, July 23rd, the North Coast Regional Water Quality Control Board will probably give final approval to a Basin Plan Amendment, which will legalize, for the first time in the North Coast, certain kinds of wastewater and other runoff into our creeks and streams during the summer

months. Up to now, there has been a summer prohibition of wastewater discharges from May 15th to October 1st.


PLEASE READ THIS NOTICE AND TRY TO COME TO THE MEETING, EVEN IF YOU DON'T


CHOOSE TO SPEAK. WE NEED STRONG SUPPORT ON THIS VERY SIGNIFICANT


DECISION!!! It will be held at 5550 Skylane Blvd. at Regional Board offices on Thursday, July 23rd.

The meeting will commence at 8:30, but the Amendment is item #10 and probably won't be heard until at least 10 AM, but maybe later than that. We tried to get a more time certain hour, but this is the best we could do. We know it is a hard time to get away, but this is an extremely important issue. PLEASE PASS THIS NOTICE AROUND TO PEOPLE ON YOUR OWN LISTS. You are welcome to have people email me with questions.

The issue is a plan to call partially treated wastewater "recycled water" (or non-storm water discharge or low threat discharge) Along with this is the implication that if it meets certain (very old) Health Department standards, that it is just as good as potable water. (I have heard City staff refer to the wastewater as simply "water")


In our view, the State has not demonstrated that the wastewater will be free of hormones, other endocrine disruptors, personal care products, etc. that have been implicated in sex reversals in wildlife, lowered sperm counts in men, cancer in humans, pets, and wildlife, and many other anomalies, to name just a few. (After 15 years of pressure, the State has just set up a "blue ribbon committee" to study the issue.)


One of the main reasons given for pushing this Amendment is that all the other Regional Boards in the State have either given it their blessing or have no prohibition as to its use, and therefore, the North Coast has to have it too. This reasoning hardly instills confidence in those of us who have seen the State make very unwise choices from time to time. If the State needs to save water, their very first priority should be to do just that, and go a lot further with conservation, rather than focus on spreading potentially harmful substances all over the area.


In fact, the use of wastewater will discourage conservation because the cost of the infrastructure, including energy (pumping) and capital costs, will put pressure on urban folks to use the wastewater rather than reduce their use of potable water. In dry years, there probably wouldn't be enough wastewater to go around anyway, and once again dead lawns will predominate, rather than drought resistant plantings. Several years ago, Santa Rosa's proposed urban irrigation program was costed out at $150 million dollars.

The City has pushed hard for the summer runoff Amendment and claim they can't do a recycled water project unless they get it. Comments on this Amendment were submitted on Jan. 29, 2009, but responses were released only on July 13th, giving us little time to consider the final draft document.


Santa Rosa has already developed urban irrigation policies and proposed practices, but those won't come up for public consideration until AFTER the Basin Plan Amendment is approved. (We had asked Reg. Bd. staff to incorporate the BMPs into the Basin Plan Amendment process. They would not do it.

The way the irrigation program will work is that the City will be in charge of overseeing the program, including the third party implementers, the monitoring, and the reporting. If anything goes wrong, it will be their responsibility to report it. The Regional Board checks their submissions for compliance, but seldom, if ever, carefully investigates unless they receive a complaint, and sometimes not even then. It appears as though most everything is based on trust. In our experience however, people frequently develop blinders, with the idea that "...what I don't know, can't hurt me."

What concerns us, is that the City has been irrigating agricultural fields for years, but it's never been clear whether the irrigators are following all the rules. The City's annual reports are extremely vague and reports of problems are extremely infrequent. I know of few, if any, penalties on Santa Rosa for improper irrigation.

On May 26th, a lead story in the Press Democrat described Richard and Sara Lee Kunde's 15 million gallon wastewater pond and their extensive use of wastewater for irrigation. The story indicated that the wastewater was used for frost protection, among other things, implying that over-irrigation may have occurred, since frost protection involves the spray of vast amounts of water over a short period, and almost always involves runoff.


I asked Regional Board staff if they knew about the pond and the wastewater use and whether there were any problems with it. I wanted to know if they had input into the development of the pond. Regional Board staff knew NOTHING about the pond and assumed that everything was legal and that runoff did not occur. This is based on the fact that the City never reported any problem. This is of great concern, because we had the impression that the City's operations were carefully monitored. The implication of this situation is that the irrigation component is barely monitored (by the Regional Board) at all.

This situation has extensive implications for this Basin Plan Amendment! It is of special concern because over-irrigation is rampant with potable water, just think what will happen if wastewater is readily available. Supposedly the BMPs would prevent wastewater from getting into streams except on rare occasions, but unfortunately, we don't think the enforcement process has been strong enough to certify that this will indeed be the case.


PLEASE HELP OUR EFFORT. PLEASE LET ME KNOW IF YOU CAN MAKE THE MEETING.


Brenda