2109 UPDATE to Healdsburg's Wastewater Irrigation Expansion Plan

          February 5, 2019 Notice of Preparation for Subsequent Environmental Impact Report (EIR): Not all Westside Area or Healdsburg residents received a letter from the City of Healdsburg, so we've posted Healdsburg's letter. Neighbors and community groups were required to request technical studies and mitigation measures to address Healdsburg's expanded wastewater irrigation plan by March 9,2019. WASA submitted a letter to Healdsburg, and the WCA March 4, 2019 letter attached all previous letters (links below). 

          Healdsburg is developing a Subsequent EIR (SEIR) with full assessment of all impacts, as required, given the 2005 EIR did not address all impacts, the previous EIR Addenda were for temporary irrigation during drought years, that is now being made permanent, and new uses are proposed for wastewater irrigation.  NOTE: See below reference information on the difference between a Subsequent EIR vs Supplemental EIR:

          Since 2005, the Westside Association to Save Agriculture (WASA), the Clean Water Coalition, and the Russian RiverKeeper have been pro-actively working with the City of Healdsburg to ensure its original plans to dispose of 138 million gallons - now increased to 197 million gallons - of tertiary wastewater each year does not impact City of Healdsburg, SCWA or domestic wells in the area. Issues include the build up of nitrates in the soil and contamination risks to our high quality drinking water aquifer.  

          Conditions have changed since 2005: the acreage for potential wastewater irrigation has more than tripled, and many new, highly impactful uses are proposed. Thus, it is expected that impacts will increase in severity; for example, Healdsburg now proposes frost protection, which poses surface and groundwater contamination risks. Cannabis irrigation, especially trucking significant quantities of wastewater into water scarce areas, risks contamination of soils and local, enclosed aquifers. 

          Community and environmental protection groups have written substantive letters to the City of Healdsburg; unfortunately, private well owner concerns in the zone of discharge have been ignored. Given the City of Healdsburg is working with a new consulting firm, and the wastewater expansion plan may impact its own water wells, WASA and the WCA resubmitted issues raised previously and again requested required technical analyses. We trust a more complete Subsequent EIR will protect the County's water supplies.  See 2016 Phase 1 Pipeline Plan and Capital Expenditures. 

          The Russian RiverKeeper letter was also attached.  The water contamination potential is so serious that the RiverKeeper organization challenged Healdsburg in Superior Court on technical issues. Judge Hardcastle heard the case on Wednesday, February 13, 2019; and ruled against the RiverKeeper organization's requests to ensure irrigation was limited to the vineyard agronomic rates and that extra measures be taken to protect the drinking water aquifer for 700,000 people. 

          Given the loss of these protections, technical experts must be hired to review and comment on Healdsburg's studies in the forthcoming EIR.  

         Until residents received Healdsburg's August, 2018 letter, local well owners had not been informed of this project by either the City of Healdsburg or the North Coast Water Quality Control Board (NCWQCB). There were no public hearings for well owners in the area of disposal prior to the July 2016 decision.  The 2018 notice informed residents of a Scoping Session to merely amend the 2005 Environmental Impact Report.  WASA, WCA as well as multiple members requested a Subsequent EIR.   

          In August, 2018, Healdsburg announced plans to substantially increase the acreage for potential wastewater irrigation on the aquifer lands and in the watersheds along the Russian River, with disposal between May 15 to September 30. The new acreage includes the western hills for pasture irrigation, and/or up to 3,000 gallons/day of wastewater truck hauling to cannabis grows along dirt roads in fragile watershed lands. The City is proposing to spend millions in pipeline expansion to reach new, yet unstudied, areas. See Exhibit 2 Map

          Per the State of California rules, expanding the disposal area by 4,700 additional unstudied acres and new uses in unstudied watershed areas, required Healdsburg to prepare a new, subsequent EIR.

"CEQA Guidelines Section 15163 states that a lead agency may choose to prepare a supplement to an EIR rather than a subsequent EIR if proposed changes meet the conditions described in CEQA Guidelines Section 15162 and if only minor additions and changes would be necessary to make the previous EIR adequate."

Thus, Healdsburg's Proposed Plan requires an SEIR: To increase the volume of water in its wastewater disposal plan and to eliminate discharges to Russian River surface waters the City proposed to: (NOTE: This plan was prior to the February, 2019 floods when the Russian River breached Basalt Pond. In March and again in May 2019, WCA requested the City of Healdsburg to provide information as to its new plans for summer discharge (starting May 15) when  discharges to the River are prohibited.  To date, no information has been provided.)

• Install recycled water conveyance pipelines; (Need information on capital costs associated with this newest expansion.)
  
  
• Add approximately 2,100 acres of land to receive recycled water through new pipelines (2018 Proposed Area); then add another 2,630 acres of land that potentially could receive recycled water at a future date (2018 Program Expansion Area).
  
  
• Add new uses to the list of tertiary wastewater use beyond those currently allowed in the water recycling program:
  • orchards (apple, peach, plum/prune);
  • cannabis;
  • irrigated pasture;
  • direct livestock watering (not including dairy cows);
  • frost protection; and
  • other agricultural uses occurring in the vicinity of the WWTP.  (Note: bee keeping could be adversely impacted)

Frost protection, which is currently prohibited due to water quality impacts from high application rates and runoff given saturated soils, should be removed from the proposal.  

          Previously, the University of California stated that wastewater application on grasslands for cattle feed, at the appropriate agronomic rate (defined below), was preferable to vineyard irrigation. As cannabis operations take huge amounts of water, wastewater application may be acceptable for grows in industrial or commercial zoned areas, yet application on lands in the watershed areas has not been studied.  

2017 HISTORY: August, 2017 State Water Board decision: Under voluntary User Agreements, land owners can irrigate with wastewater to within 50 feet of a residential well, yet well owner remedies, should a well become contaminated, are not clearly defined. Currently, wastewater cannot be used for frost protection, as saturated soils will allow wastewater to flow into streams.  

2016 HISTORY: The Clean Water Coalition of Northern Sonoma County (including WASA, the Russian River Keeper, City of Healdsburg representatives and associations from Alexander and Dry Creek valleys), wrote numerous letters, conducted technical analyses and met continuously with public officials to refine the analyses and assumptions carried forward from the 2005 Final Environmental Impact Report.  

          At that time, the proposed wastewater discharge was on about 600 acres of vineyard lands in Middle Reach - the 2018 proposal adds over 4,000 acres both above and below Healdsburg's wells.   

         The Clean Water Coalition (CWC), Russian River Keeper and WASA have 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. The full past history is on the Clean Water Coalition of Northern Sonoma County website. In 2018, the Clean Water Coalition transferred its records and funds to the Russian River Keeper, which is now the organization spearheading this effort.

          Importance of Agronomic Rate:  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 -  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 Notice of Applicability 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.

For more information, and a summary of findings from the field study to determine Agronomic Rate in the Middle Reach, accounting for supplemental water from precipitation, see Middle Reach Vineyard Irrigation Demonstration Project.  

           Petition to State Water Board: 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. For more information, including links to the City of Healdsburg documents:

Go to > Clean Water Coalition of Northern Sonoma website.  

          In March 2016: Healdsburg added up to 25,000 acres to the proposed Wastewater Irrigation Plan: Healdsburg proposed disposing of up to 138 million gallons of wastewater from May 15 to Sept 30 each year - this is now increased to 197 million gallons. 

          By 2016, Ag lands under contract and trucking use only amounted to about 10 million gallons annually. In August, 2016, 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.  (A 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. 

2016 North Coast Regional Water Quality Control Board (NCWQCB) - State Water Board Process: History and Status: On August 1, 2016, the Russian RiverKeeper and certain Clean Water Coalition members petitioned the State Water Board to rescind and require the City of Healdsburg and the NCWQCB to correct the errors in methodology and assumptions in Healdsburg's permit to dispose of 138 million gallons of tertiary wastewater through irrigation of on 600 acres of agricultural land. One primary concern is the approved irrigation rate, which may be up to 3 times more irrigation than the vines actually need.  

         In 2012, WASA, in association with the Sotoyome Resource Conservation District, conducted a vineyard irrigation demonstration project for the Middle Reach.  This project was defined to demonstrate an effective range of irrigation water application rates and management practices using a set of tools that provide information on soil moisture reserves and vine water status.  Resulting data provided an approximate agronomic irrigation rate designed to avoid undesirable levels of vine stress while avoiding deep percolation beyond the root zone.  

          The data and findings from the demonstration project were submitted to Healdsburg as input to the Technical Studies required by the State Water Board's General Order that requires application only at Agronomic Rates, defined 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 disregarded this study and used a methodology that did not allow for supplemental water resulting in an irrigation rate that may be up to 3 time more irrigation water than the vines actually need.  The Vineyard Irrigation Demonstration Project summary provides information on why irrigation rates above the agronomic rate may degrade soil, grape and water quality.  

HISTORY 2014: 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 Dem Article May8,2014

        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."   

       The Clean Water Coalition put its concerns with the methodology and certain findings in the Technical Report into the Administrative Record. The Regional Board still needs 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.  The 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.

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."