Letter to Sonoma County Board of Supervisors in their role as chair of SCWA
The Clean Water Coalition of Northern Sonoma County submitted a letter to the Supervisors in their role as the Board of the Sonoma County Water Agency. Fred Corson recommended that our January 12, 2015 letter to Matthias St. John, Executive Officer of the NCWRCB also be included in the packet. Enclosed is our original January 8, 2017 letter, with an amended list of attachments and the January 12, 2015 CWC letter.
The questions raised by residential well owners along the path of the pipeline and in the zone of influence of wastewater irrigation are legitimate concerns, especially given the hydrology of the Dry Creek and Middle Reach aquifers. As the drinking water source for over 700,000 Sonoma County Water Agency customers, protection of this high quality drinking water aquifer is in the public interest. As stated in many reports, south of Dry Creek the groundwater flows — i.e. the underflow of the Russian River — and wastewater delivered within 50 feet may flow into a residential well.
We trust the Supervisors will take action on our requests to: 1) ensure well testing for baseline groundwater quality and a process for residential well owners to seek remedies should degradation of water quality or contamination occur; 2) encourage Healdsburg to amend their assumptions and methodology to define an agronomic rate that aligns with the State’s definition and allows for supplemental water; and 3) require metering and monitoring of User Agreements limiting the rate and total amount of wastewater and fertilizers applied on vineyards.
Links below provide background and key documents.
January 8, 2017 Letter to Board of Supervisors
January 12, 2015 Letter to the NCWRCB
January 29, 2014 Letter to City of Healdsburg
March 3, 2014 Letter to the NCWRCB
Field Demo Project
Petition to State Board — Correct errors in Healdsburg’s NOA
Since 2010, the Clean Water Coalition (CWC) has submitted numerous substantive letters and technical reports to the North Coast Regional Water Quality Control Board (Regional Board) to ensure that Healdsburg’s tertiary wastewater discharges on agricultural lands, through voluntary User Agreements, have adequate controls to protect our wells and high quality drinking water aquifer from degradation.
On July 1, 2016 the Regional Board approved Healdsburg’s Notice of Applicability (NOA) based on a theoretical determination of maximum hydraulic “agronomic” irrigation rates. The NOA has significant errors in methodology and assumptions, a definition of agronomic rate that does not comply with the State’s criteria and that may result in over irrigation and excess nutrient loading, especially given the proposed rate and timing of wastewater irrigation do not account for the soil’s water holding capacity (i.e. supplemental water).
The State Board’s 2014/2016 General Order defines Agronomic Rate as:
“The rate of application of recycled water to plants necessary to satisfy the plants’ evapotranspiration requirements, considering allowances for supplemental water (e.g. effective precipitation), irrigation distribution uniformity, and leaching requirements, thus minimizing the movement of nutrients below the plants’ root zone.”
Healdsburg’s NOA overstates the maximum rate of irrigation and inappropriately assumes recycled water irrigation will begin in the spring, when soils may be saturated. Application rates higher than the agronomic rate may lead to runoff or the accumulation of nutrients (nitrates) and organic chemicals in the soil, which are then flushed by winter rains into the groundwater.
Petition to State: On August 1, 2016, the Russian River Keeper et al, filed a petition with the State Water Resources Control Board (State Board) requesting the State Board review and set aside the Regional Board’s approval of Healdsburg’s permit for wastewater drip irrigation on AG lands.
This petition requests that the State require the Regional Board and Healdsburg to correct the inconsistencies with the General Order, address impacts to our high quality drinking water aquifer and other violations under the Anti-degradation policy. If left unchallenged, these violations could set a dangerous precedent for areas with pristine groundwater sources.
Links below provide background and key documents.
SWRCB Petition-Russian Riverkeeper dated 2016-08-01
Exhibit A with NOA attachments (A-D)
Exhibit C UnivCalgary Nitrate Fate Study
Exhibit D UnivWaterloo Nitrate Study
March 2016: Healdsburg adds up to 25,000 acres to proposed Wastewater Irrigation Plan Healdsburg has 138 million gallons of wastewater requiring disposal from May 15 to September 30 each year. Current Ag lands under contract and trucking use about 10 million gallons annually. In August, Healdsburg approved pipeline extensions both to the north and south of the plant to bring another 600 acres into the recycled water program, for discharge of a projected 37 million gallons (See map: new pipeline extensions cost Healdsburg ratepayers about $1.1 million.)
With another 100 million gallons of wastewater requiring disposal, the city approved an amendment to its 2005 Environmental Impact Report (EIR) to expand the potential areas for wastewater irrigation reuse projects to Alexander, Dry Creek and Russian River valleys. This amendment proposes both truck and piped delivery of recycled water to irrigate up to 25,000 acres total over a 5-year period, ending in 2020. (NOA has not been approved for this added acreage.)
The Amendment to the EIR erroneously concludes that the soils and drainage characteristics in the three valleys are similar to that studied in the 2005 EIR. Several technical studies refute this claim. The EIR then alleges that if there are new environmental effects, they won’t be significant because wastewater will only be applied for 5 years, and the “only change” is the source of water from our high quality groundwater supplies to recycled water irrigation.
The characteristics of the water used for Ag irrigation and the lack of adequate controls in Healdsburg’s User Agreements are the issue. Per our Petition to the State Board, Healdsburg’s proposed rate of wastewater irrigation and lack controls and lead to the accumulation of nitrates and organic chemicals in our soils, ultimately degrading our high quality drinking water aquifer.
Links to Healdsburg documents and staff reports.
March 2016 Addendum to 2005 FEIR
Patrick Fuss Staff Report
Healdsburg’s Wastewater Irrigation Plans
The Clean Water Coalition (CWC) is working with the North Coast Regional Water Quality Control Board (WQCB) to ensure that Healdsburg’s discharges to agricultural lands, through voluntary User Agreements, have adequate controls to ensure the protection of our high quality drinking water aquifer. The following provides the background and key documents.
Healdsburg’s Resolution: On February 14, 2014, the Healdsburg City Council passed a resolution for Healdsburg to provide wastewater from their plant to construction companies and farmers via truck or pipeline connections in lower Dry Creek and the Middle Reach vineyards to the west and south of their sewage treatment plant. And, per May 8, 2014 letter the Regional Board’s Executive Director approved these deliveries during the emergency drought - irrigation seasons 2014 and 2015. Press Democrat Article May 8, 2014
The City Public Works department has posted its Technical Report, with maps of the irrigation areas, and Appendices, on the Document Central portion of Healdsburg’s website. The Figure 1 Map (Page 4 of Technical Report) outlines the lands slated for the first phase of wastewater irrigation, and negotiations are underway with Syar Industries to pipe their vineyards for recycled water irrigation.
Healdsburg has the right to provide voluntary pipeline irrigation to any of the landowners identified in the 2005 Environmental Impact Report; the EIR’s diagram shows the current potential irrigation areas. And, the City has discussed plans to expand the area for pipeline deliveries in the future.
State Order - June 3, 2014: The State Water Resources Control Board issued its General Waste Discharge Requirements for Recycled Water Use order (Order WQ 2014-0090). Some foundational tenants of this Order are that:
1) Special considerations are required in high quality groundwater aquifers, such as those along the Russian River and Dry Creek. Section 22 states, “The quality of some waters is higher than established by adopted policies and that higher quality water shall be maintained to the maximum extent possible consistent with the Anti-degradation Policy.”
2) Infrequent monitoring to the low regulatory bar of Title 22 standards. Then, Section 23 states that, “Salt and Nutrient Management Plans, developed in accordance with the Recycled Water Policy, will require analysis on an ongoing basis to evaluate inputs to the basin, the salt and nutrient mass balance, and the available assimilative capacity.”
3) Irrigation with recycled wastewater must be at “agronomic rates” - defined by the State Order as:
"The rate of application of recycled water to plants necessary to satisfy the plants’ evapotranspiration requirements, considering allowances for supplemental water (e.g. effective precipitation), irrigation distribution uniformity, and leaching requirement, thus minimizing the movement of nutrients below the plants’ root zone."
CWC Concerns: The Clean Water Coalition has concerns with the methodology and certain findings in the Technical Report, and is working with the Regional Board to address concerns over the allowed irrigation discharge rate, as it appears to be significantly above measured "agronomic rates" for grapevine irrigation in the Middle Reach valley lands. The Healdsburg Technical Report and User Agreement have a definition of “agronomic rates” that differs from the State definition in several ways.
The Technical Report has no set definition, just a complicated set of tables on Page 11-12, and a set of Best Management Practices on pages 14-15. User Agreement Definition: “Agronomic Rate means the hydraulic loading reasonably necessary to satisfy the water uptake needs of the use area considering plant, soil, and climate demands.”
The Technical Report goes on to say that the Compliance monitoring program will be:
“To assess compliance with agronomic rate requirements, the City also compiles and reports the following information to the Regional Water Board on a monthly basis: Total Volume of Recycled Water Delivered; Total Area of Application; Total Nitrogen Application Rate and Rainfall (daily).”
On January 12, 2015, the CWC submitted a letter to the North Coast Regional Water Quality Control Board expressing concerns with the timing, volume
and terms for treated wastewater application to vineyards with alluvial soils in close
proximity to ground water.
CWC Letter of Jan 12, 2015 to North Coast Regional Water Quality Control Board
Greenspan response to Walker report
Press Democrat: Healdsburg gets OK to use Treated Wastewater for Vineyards
Healdsburg Request to North Coast Regional Water Quality Control Board for Authorization for Short-Term Use of Disinfected Tertiary Recycled Water for Vineyard Irrigation
Healdsburg Wastewater User Agreement: Appendix B
Agreement for Delivery and Use of Recycled Water
Healdsburg Recyled Water/Drip Irrigation Report
Proposed Pipeline Irrigation Map
Ag Reuse Map from 2005 EIR
Clean Water Coalition Advocates Reverse Osmosis
The Clean Water Coalition (CWC) continues to advocate that the City of Healdsburg research and consider a Reverse Osmosis system. Such an addition to the treatment plant would provide Healdsburg with longer-term options to capture significant value for advanced treated recycled water. The CWC believes that Reverse Osmosis is a superior solution, economically and environmentally, to vineyard drip irrigation.
The CWC’s January 2014 letter to the City of Healdsburg requested that the Public Works department explore the addition of a Reverse Osmosis train (i.e. equipment) to the treatment plant to allow year round discharge to the Basalt Pond as a cost-effective short-term option.
Since 2008, Healdsburg’s Wastewater Treatment Plant has used modern membrane bioreactor technology with microfiltration membranes,. The microfiltration technology makes Healdsburg’s 1 million/gallon per day plant an ideal candidate for addition of Reverse Osmosis equipment to generate advanced recycled wastewater.
Although Healdsburg’s plant produces wastewater with relatively low levels of nitrates, dissolved solids, and metals, our primary concern is that regulatory testing and reporting requirements to meet Title 22 standards are only for a small number of constituents. Reverse Osmosis would resolve many of these concerns and create a resource of value versus a water to be discharged for the City of Healdsburg.
Concerns with Agriculture Irrigation with Wastewater: The CWC and its member organizations worked closely with the Regional Board to ensure Healdsburg’s 2010 Permit included exacting requirements for Technical Reports, irrigation application at true agronomic rates, and other protections for surface water and groundwater quality. The definition of Agronomic Rate is key to all the requirements set by the State Board and the Regional Water Quality Control Board; thus Healdsburg’s definition and maximum rate of discharge is a concern because discharge above agronomic rates or during times when the ground is saturated may result in constituents of concern and nitrates percolating below the root zone, causing possible groundwater quality impacts.
Westside Community to Save Agriculture and Syar Industries study to define Agronomic Rates in Middle Reach
North Sonoma Agricultural Reuse Project - NSCARP - On Hold
NSCARP would contaminate current and future drinking water supplies.
Project proponent: Sonoma County Water Agency
Three of the most precious Sonoma County wine growing regions -- the Alexander, Dry Creek and Russian River Valleys -- would be turned into mega-leachfields for municipal wastewater -- if the NSCARP project is ever built. This controversial $350million+ plan for 17 reservoirs full of effluent, 111 miles of new pipelines, and 16 pumping stations -- makes no sense.
It threatens to contaminate drinking water; the wastewater is already committed to safer and greener purposes; and the so-called "recycling" project does not free up additional drinking water supplies.
THE WASTEWATER NEEDS MORE CLEANING TO BE SAFE ENOUGH FOR LOCAL SOIL CONDITIONS
Scientific studies show that the level of wastewater treatment is inadequate for application via irrigation over large parts of the Alexander, Dry Creek and Russian River Valleys, particularly on valley floors.
CONTAMINANTS WILL LEACH INTO WATER SUPPLIES
The many contaminants in municipal wastewater that are not removed by tertiary treatment will leach through the thin layers of coarse-grained, alluvial soil in the area, concentrate locally in groundwater, pass into wells and community drinking water supplies, and increase risks to public health, especially for infants.
IT'S A SHORT-SIGHTED IDEA - THREATENING BILLIONS OF GALLONS OF DRINKING WATER
Our groundwater aquifers are a critical supply of drinking water for Sonoma and Marin Counties. The Alexander Valley aquifer, for example, contains more than three times the volume of water than Lake Sonoma. Many groundwater sources in California have already been polluted by agriculture and wastewater disposal, and this project would compromise our regional supply with long-term build-ups of contaminants, including nitrate, heavy metals, organic compounds, pharmaceuticals and endocrine disruptors.
IT'S INTRUSIVE & DANGEROUS – PUTTING GOVERNMENT IN CONTROL
Government can require farmers to use wastewater if it is made available, and could control the timing and amount of wastewater use. Riparian and other water access rights may be eliminated. Mandated wastewater irrigation turns vineyards into leachfields risking contamination of nearby wells. Proposed regulations (AB885) require regular well testing and place the clean-up burden on the well owner.
WON'T HELP IN A DROUGHT -- NOT A "DEPENDABLE" SUPPLY
Wastewater recycling and reuse are helpful in a drought only when drinking water quality is protected. Additional treatment can address these risks and such alternatives must be considered. Sonoma County should look to other counties that are investing in advanced treatment facilities to enhance drinking water supplies.
Furthermore, SCWA cannot demonstrate that there will, in fact, be a regional surplus of watewater available for agriculture in dry years.
COSTLY, WASTEFUL & UNWANTED - PROJECT IS UNNECESSARY AND ILL-CONCEIVED
Other local agencies, including the City of Santa Rosa, are already implementing considerably better, safer, and cheaper projects to reclaim municipal wastewater.
A LIKELY P.R. NIGHTMARE FOR WINE AND TOURISM
Public perception of wastewater irrigation could seriously damage the premium Sonoma wine industry, on which all of our hospitality and tourism industries depend.
More about NSCARP
Water agency proposes massive wastewater reuse project
Healdsburg Tribune March 28, 2008
Farmers, vintners cool to prospect of recycled water for irrigation
THE PRESS DEMOCRAT May 16, 2007
CWC Technical Comments on Final EIR
Wastewater irrigation questioned by growers
Healdsburg Tribune - May 17, 2008
NSCARP Draft EIR/EIS
EPA Comments on draft EIR/EIS
North Coast Regional Water Quality Control Board Comments on Draft EIR/EIS