Future Discharges of Treated Wastewater to Russian River

Letter from Sonoma County Water Agency SCWA (R.Poole) to Santa Rosa -- re: future discharges of treated
wastewater to the Russian River.
October 20, 2006

September 25, 2006
Pat Fruiht, City Manager's Office
City of Santa Rosa
P.O. Box 1678
Santa Rosa, CA 95402-1678
Re: Discharge Compliance Project

Dear Ms. Fruiht,

The Sonoma County Water Agency (Agency) has reviewed the Initial Study, Notice of Preparation of an Environmental
Impact Report (EIR), and Draft Engineering Report for the City of Santa Rosa's (City) Incremental Recycled Water
Program - Discharge Compliance Project (Discharge Compliance Project). The Agency's comments are focused on
concerns regarding 1) potential conflicts with the proposed expansion of the Agency's water supply facilities; 2)
potential water quality concerns regarding how the City's project could impact the way the Agency's facilities are
operated; 3) how the City's project could impact listed fish species and recovery planning efforts in the Russian River;
and 4) that the City should focus on reuse of this resource instead of disposal into the Russian River.

The City's proposed Discharge Compliance Project proposes a new direct or indirect wastewater discharge location
along the Russian River. The Agency operates six collector wells along the Russian River in the Mirabel and Wohler
area which supply drinking water for approximately 600,000 people in Sonoma and Marin Counties, including residents
of the City.

In addition, the Agency has been evaluating an expanded water supply system which could include new collectors
upstream of the Agency's existing collectors. Similar to the results shown for river discharge locations in the City's
Draft Engineering Report for the Discharge Compliance Project, there may be only a few locations along the Russian
River that are suitable for the Agency to install water diversion structures and pipelines.

In addition, the features that make a site suitable for a river discharge location may also be the same features that
make a site suitable for water diversion facilities. The Agency is concerned that the City's Discharge Compliance
Project could have detrimental impacts on the planned infrastructure necessary for the Agency's water supply project
and may cause significant delays in the Agency's environmental review process.

Attached is a map from the Agency's Notice of Preparation of an Environmental Impact Report for the Agency's Water
Supply, Transmission and Reliability Project which shows the area of interest for the Agency's future water supply
facilities along the Russian River. The Agency recommends that the City coordinate with the Agency so that the City's
Discharge Compliance Project doesn't impact the Agency's ability to construct future water supply facilities.

The Agency and its customers (including the City) have benefited from having water supply facilities that provide a
high quality source of drinking water that is relatively inexpensive to operate. The only treatment necessary beyond
the natural filtering provided by the sand and gravel materials along the Russian River is: 1)the addition of chlorine to
provide a residual amount of disinfectant throughout the transmission system; and 2)the addition of sodium hydroxide
to adjust the pH of the water. The Agency and its customers have not had to share in the expense of constructing and
operating a surface water treatment plant. The potential impact of a new wastewater discharge location on the
Russian River, which could jeopardize the way the Agency's existing water supply facilities are operated, needs to be
considered. Accordingly, the Agency has brought this item before the Technical Advisory Committee of the Water
Advisory Committee (TAC/WAC) in October (2006) to have the TAC/WAC provide direction on what position the
Agency should take with regards to the City of Santa Rosa's Discharge Compliance Project.

Attached are copies of comments from the Agency submitted to the City January 12, 1987 and October 7, 1996 with
regards to a proposed Russian River wastewater discharge associated with the City's Long- Range Wastewater
Management Plan and Subregional Long-Term Wastewater Project. These comments from 1987 and 1996 express
the Agency's concerns with how a direct wastewater discharge into the Russian River could impact the Agency's water
supply facilities due to the presence of pathogens and inorganic and organic compounds that may be present in the

The concerns brought up in these comment letters are still valid and currently there are additional concerns that need
to be addressed associated with the emerging issue of pharmaceuticals and personal care products that may remain
in treated wastewater. Pharmaceutically active compounds (e.g., caffeine, nicotine, and aspirin) and numerous
personal care products (such as fragrances and sunscreens) and drugs from a wide spectrum of therapeutic classes
can enter waterways through a variety of routes including treated wastewater.

The City should study what potential impacts to water supplies and the aquatic environment could occur as a result of
discharging the City's wastewater into the Russian River.

Since 1991, the National Marine Fisheries Service (NMFS) has listed twenty-six Evolutionarily Significant Units (ESUs)
of salmonids on the Pacific Coast as endangered or threatened species under the federal Endangered Species Act
(ESA). The ESA requires that recovery plans be developed and implemented for the conservation and survival of
these species.

For recovery planning, NMFS has divided the ESUs on the Pacific Coast into nine geographic domains and will
develop recovery plans for each. The Russian River watershed is part of the North-Central California Coast Recovery
Planning Domain (Planning Domain), which encompasses watersheds from Mendocino County to Santa Cruz County
and supports populations of coho and Chinook salmon and steelhead. These populations of salmonids have been
federally listed as Threatened or Endangered since the late 1990's.

Efforts to restore habitat and identify what is needed to recover these populations have been ongoing ever since. In
the Russian River some of these efforts have included implementation of the coho salmon broodstock program at the
Don Clausen Hatchery, many habitat restoration and fish passage projects funded through the Pacific Coastal Salmon
Recovery Fund (and other state and local funding sources), as well as, completion of a state recovery strategy for
California coho salmon.

While these efforts have fostered the development of federal-state-local partnerships in salmonid recovery and
conservation, little real progress can be made without the commitment and involvement of the state and local entities
affected by the listings. Recognizing this, beginning in February and again in June of 2006, the Board of Directors of
the Sonoma County Water Agency approved funding assistance to NMFS to facilitate the development of federal
recovery plans for coho and Chinook salmon and steelhead in our region.

Additionally, the Agency's Board approved funding to support the development of a local plan to begin implementing
early recovery actions as specified in the state's coho recovery strategy and to support a position at NMFS to work
with agencies and landowners toward development of a salmonid conservation plan for Alexander and Dry Creek

To these ends the Agency has provided over $700,000 in funds and proposes to continue supporting development of
recovery plans on two fronts. The first, by identifying local solutions that address salmonid fisheries and that are
compatible with local responsibilities, and the second by acquiring, collecting, and developing the data needed to
assess factors limiting salmonid recovery in all the watersheds that make up the ESU. On September 11, 2006, NMFS
published their intent in the Federal Register to prepare recovery plans for all the listed ESUs of salmon and distinct
population segments (DPS) of steelhead in California by January 2008. Given the considerable federal, state and
local effort to support recovery plan development for the salmonid populations in our Planning Domain, the City should
in the Discharge Compliance Project EIR evaluate how the City's project could impact these three listed fish species in
the Russian River watershed and identify ways in which the City can help with recovery planning efforts. The Agency
recommends that instead of looking at disposal into the Russian River that the City view this wastewater as a valuable
resource that can be utilized to offset potable water use through urban reuse to directly offset Russian River water
and for agricultural reuse (such as that being studied for the proposed North Sonoma County Agricultural Reuse
Project) which can help reduce the reliance on groundwater and help reduce the need for surface water diversions.

We appreciate the opportunity to comment on this project.

Sincerely, Randy D. Poole
General Manager/Chief Engineer


Statement of Bob Quint, Acting Deputy Commissioner, Operations
Bureau of Reclamation
U.S. Department of the Interior
Before the
Natural Resources Committee
Subcommittee on Water and Power
U.S. House of Representatives
H.R. 716
Santa Rosa Urban Water Reuse Plan Act

May 17, 2007
Madam Chairwoman and members of the Subcommittee, I am Bob Quint, Acting Deputy Commissioner of the Bureau
of Reclamation. I am pleased to provide the Department of the Interior's views on HR 716, a bill to authorize
Reclamation to participate in the design, planning, and construction of the Santa Rosa Urban Water Reuse Plan. The
Department does not support HR 716.

HR 716 would amend the Reclamation Wastewater and Groundwater Study and Facilities Act (Public Law 102-575,
Title XVI), to include the City of Santa Rosa, California, Urban Water Reuse Plan. Under the proposed legislation costs
incurred by the City of Santa Rosa prior to the date of enactment would be credited by the Secretary toward the total
cost of the Santa Rosa Urban Water Reuse Plan.

There is not sufficient information, such as the engineering and economic feasibility, financial capability of the project
sponsor, and environmental effects, regarding this proposed project. The Department supports efforts to increase
local water supplies and increase recycled water use in the West. However, because technical studies are not
complete, the feasibility and cost effectiveness of this project cannot be determined. Title XVI provisions require that
these technical studies be completed and reviewed to determine the feasibility and cost effectiveness. Moreover, of
the 32 specific Title XVI projects authorized to date, 21 have received funding. The remaining estimated total
authorized Federal cost share of these 21 active Title XVI projects is at least $328 million. Given the costs of the
currently active Title XVI projects, we do not support the authorization of new projects at this time.

While Reclamation does not support new authorizations for Federal cost sharing of water recycling projects, we
understand that the projects established by Title XVI are important to many water users in the West. To that end,
Reclamation has set about revising and improving its Directives and Standards that govern reviews of Title XVI
projects. By doing so, we believe that Reclamation can play a more constructive role with local sponsors in weighing
the merits and ultimate feasibility of proposed water recycling projects.

The Administration appreciates local efforts to address future water issues. However, in light of the concerns
expressed above, we cannot support HR 716.

Madam Chairwoman, this concludes my testimony. I would be pleased to answer any questions.


Food Engineering Magazine

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E coli outbreak not surprising

November 1, 2006

According to a recent FDA report, the September 14th CDC-confirmed E coli outbreak affecting 204 people in 26
states was traced back to Monterey County spinach grower and producer, Natural Selection Foods in San Juan
Bautista, CA. But contamination is not a new problem for producers of leafy vegetables from this region. In fact, an
FDA Update from October 6, 2006 states there has been a long history of E. coli O157:H7 outbreaks involving leafy
greens from central California. In its November, 4, 2005 letter to California lettuce growers and packers, FDA cited 18
E coli outbreaks since 1995, of which eight completed tracebacks lead to Salinas, California.

FDA is checking several potential sources for the E coli, which is known to come from cattle feces, but has yet to list a
definitive root cause. With cattle ranches nearby the producer, potential sources under investigation by the California
Department of Health Services include improper handling of manure as fertilizer, agricultural runoff, stray cattle, and
infected irrigation water, the latter of which has been suspect for some years by some government officials. Farms in
the area use recycled sewage-derived water for spray irrigation, which is transported in underground pipelines from a
public water treatment center.

Although effluent water meets all EPA guidelines, the USDA suspects pathogen “regrowth” in the transmission of the
water. A USDA lab study assessed the survival and regrowth potential present in tertiary effluent as it passed through
a model distribution system over an 11-day period. It found that population numbers of bacteria increased by three to
four orders of magnitude, potentially placing the water out of compliance at its point of intended use.

There have not yet been tests with published results that show bacteria growth on plant leaves when delivered by
spray irrigation. The USDA is diligently working on “recycled water” issues but reports several unknowns. “Using
present technologies, municipal wastewater treatment may not completely disinfect recycled irrigation waters, allowing
pathogenic microbial populations to re-grow in water storage and transmission systems. As a result, recycled water
used for agricultural and municipal irrigation can contain enough pathogenic organisms to threaten human health.”