Frequently Asked Questions about Discharge Compliance
Last updated 12/4/07
Why is river discharge being studied now?
In preparation for a range of regulatory outcomes, the long process of studying and evaluating the discharge options is being conducted far in advance of when the options will need to be implemented.
Why not continue Laguna discharge?
Continued Laguna discharge may be possible, but the Laguna is an impaired waterway, with low flows during parts of the discharge season. Staff predicts that by 2010 or so, new and anticipated regulatory rules could make Laguna discharge difficult, if not impossible unless changes to the timing and quality of discharge are made.
What specific areas along the River are being considered for discharge?
No decision has been made regarding discharge location(s). A range of options are described in the Draft Engineering Report for the Discharge Compliance Project. The locations under consideration are; (D1) Downstream of Steelhead Beach, (D3) Downstream of the Hwy 101 bridge in Healdsburg, and (D4) downstream of the Alexander Valley Road bridge.
What will these discharge projects cost?
Estimated costs range from about $35 million for the least costly direct discharge options to over $100M. The costs depend on many factors, such as distance of the discharge location from existing pipelines and methods for compliance with, nutrient, CTR, temperature and oxygenation regulations.
What is the relationship between the Sonoma County Water Agency’s (SCWA’s) North Sonoma County Agricultural Reuse Project (NSCARP) and the City of Santa Rosa’s reuse projects?
SCWA’s NSCARP is intended to provide recycled water for irrigation in place of native water that could be left in the River and tributaries for the benefit of salmonid fish. The City of Santa Rosa’s Geysers Pipeline and recycled water are included in the NSCARP project description so both SCWA and the City have the option of future cooperation to implement NSCARP. However, NSCARP would need to meet the City’s criteria as a condition of making its recycled water available to SCWA. The City has not determined if NSCARP meets its criteria and no decision has been made to provide recycled water to NSCARP. More information about NSCARP can be found at: http://www.scwa.ca.gov/projects.
I thought the City was considering Indirect Discharge in Alexander Valley.
Early studies included the possibility of indirect discharge in Alexander Valley, but the option has been dropped. After preliminary review of indirect discharge with the Regional Water Quality Control Board, it appears that the City could not receive permits for an indirect discharge facility within the time frame needed.
What about environmental documentation of the new discharge options?
A Notice of Preparation was distributed in August 2006 followed by a scoping period with 3 public meetings. In December 2006, the City initiated preparation of an EIR for the Discharge Compliance Project. The Draft EIR is expected to be available in the January of 2008 and any decisions regarding a selected Project to be made in Summer 2008.
What are the new regulations and how would relocating the discharge point help?
Several regulatory changes have or are currently occurring that compel the City to relocate its discharge.
Temperature and nutrient conditions in the Laguna de Santa Rosa (where discharge currently occurs) are considered by the Regional Water Quality Control Board to be impaired, and it has announced its intent to issue more stringent regulations.
In 2000 the U.S. Environmental Protection Agency issued guidelines for water quality objectives for surface waters and the State issued guidelines for implementing these objectives. Based on these guidelines, the Regional Water Quality Control Board imposed stringent limits on the quality of the City’s effluent for particular constituents (including cyanide, copper, nickel and lead) that may be unattainable at the current discharge location without changes to discharge timing or quality.
The City’s studies indicate that the City cannot comply with the current nor the future regulations under its current Laguna discharge practices and that compliance is possible if the timing, quality and/or location of the discharge is changed. More detailed studies which will be part of the Draft EIR are underway to evaluate discharge timing changes, discharge locations in the Russian River, and effluent quality changes that would provide compliance. Discharge to the River provides greater opportunity for immediate dilution, has greater water volume and moves faster. All of these factors help to minimize adverse impacts and comply with regulations.
How would human health and aquatic life be affected by discharge relocation?
The existing and proposed regulations driving the Discharge Compliance Project were developed for the protection of aquatic life, so relocating the discharge to a location where compliance with these regulations can be attained is expected to reduce the effect of discharge on aquatic life. In addition, studies are being conducted to evaluate the effect of the Project on human health. The effect of regulated and non-regulated compounds (such as personal care and pharmaceutical products) on human health and aquatic life will be evaluated. The results of these studies will be included in the Draft EIR.