COMMENT LETTER 552, FRED CORSON, PRESIDENT, DRY CREEK VALLEY ASSOCIATION
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COMMENT LETTER 552, FRED CORSON, PRESIDENT, DRY CREEK VALLEY ASSOCIATION

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INCREMENTAL RECYCLED WATER PROGRAM FINAL EIR RESPONSE TO COMMENTS COMMENT LETTER 300, CHRIS DEGABRIELE, GENERAL MANAGER, NORTH MARIN WATER DISTRICT Response to Comment 300-1 Comment Summary: The comment states that NMWD has reviewed the Draft EIR and expresses gratitude at the opportunity to comment. Additionally, the commentor understands that the Draft EIR is programmatic. The City appreciates the comments. The commentor is correct that the Draft EIR is programmatic. Response to Comment 300-2 Comment Summary: The comment encourages expansion of urban and agricultural recycled water use to an even greater area, and advocates regional cooperation in developing recycled water programs. The Sonoma County Water Agency is interested in cooperating with waste dischargers to convey even more recycled water to urban and agricultural water users and offset diversion from the Russian River. Please refer to Master Response A – Statements of Opinion for or against a Program Alternative or Component. Actions of the Sonoma County Water Agency, as defined in their ndRussian River Action Plan, 2 Edition (March 2003), that may have a cumulative impact with regard to the IRWP have been included in the list of cumulative projects in Appendix D. Response to Comment 300-3 Comment Summary: The comment asks why avoided potable water costs were not included. Cost analysis is not required under CEQA. The data to develop avoided potable water costs were ...

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Response to Comment 300-1
Comment Summary: The comment states that NMWD has reviewed the Draft EIR and
expresses gratitude at the opportunity to comment. Additionally, the commentor understands
that the Draft EIR is programmatic.
The City appreciates the comments.
The commentor is correct that the Draft EIR is
programmatic.
Response to Comment 300-2
Comment Summary: The comment encourages expansion of urban and agricultural recycled
water use to an even greater area, and advocates regional cooperation in developing
recycled water programs. The Sonoma County Water Agency is interested in cooperating
with waste dischargers to convey even more recycled water to urban and agricultural water
users and offset diversion from the Russian River.
Please refer to Master Response A – Statements of Opinion for or against a Program
Alternative or Component. Actions of the Sonoma County Water Agency, as defined in their
Russian River Action Plan, 2
nd
Edition (March 2003), that may have a cumulative impact
with regard to the IRWP have been included in the list of cumulative projects in Appendix D.
Response to Comment 300-3
Comment Summary: The comment asks why avoided potable water costs were not included.
Cost analysis is not required under CEQA. The data to develop avoided potable water costs
were unavailable at the time the Draft EIR was written. These costs will be developed and
included in an economics analysis, as part of the IRWP Master Plan currently in being
developed.
Response to Comment 300-4
Comment Summary: The comment expresses concern about direct discharge to the Russian
River and strongly suggests that the City commit to additional treatment for any direct
discharge because water quality thresholds will continue to become more stringent.
The Draft EIR has acknowledged that discharge will be subject to future regulatory
requirements. Page 1-2 of the Draft EIR states that “regulatory requirements applicable to
recycled water discharge into the Russian River and its tributaries have increased since the
Geysers Recharge Project was selected, and additional regulatory requirements are
anticipated.” As noted on page 2-71 of the Draft EIR, “In order to meet the requirements of
the California Toxics Rule (CTR) for discharge to surface waters, all of the Discharge
options may include advanced membrane treatment to the extent needed to comply with
CTR.” Please refer to Master Response A – Statements of Opinion for or against a Program
Alternative or Component.
OCTOBER 20, 2003
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PAGE 300-1
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PARSONS
PAGE 300-2
Response to Comment 300-5
Comment Summary: The comment expresses concern about discharge above the SCWA
collectors and states that they have requested that DHS make a conclusive determination
about whether a discharge would result in the requirement for treatment of SCWA water
supply. The comment further states that Santa Rosa should pay for any additional treatment
that might be required.
The City of Santa Rosa has consulted with the Department of Health Services (DHS) and to
date (October 2003) there has been no determination from DHS regarding the requirements
for additional treatment should the City discharge above the Sonoma County Water Agency’s
(SCWA) collectors.
The City does not agree that the discharge of recycled water would trigger additional
treatment requirements based on our findings presented in Appendix I.1 (Human Health Risk
Assessment) of the Draft EIR. In addition, only one of the five SCWA intakes is considered
by the DHS to be under the direct influence of surface water and thus subject to the Surface
Water Treatment Rule (SWTR) and any Final Enhanced SWTR.
The four other water
agency intakes and District wells are considered by the Department to be not under the direct
influence of surface water according to the SWTR. The DHS considers the “not under the
direct influence” status of the Water Agency intakes to be subject to periodic review because
of the potential that the filtration characteristics of River sediments may change or the quality
of the River would be degraded. In addition, the SCWA is constructing a 6
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collector.
Construction is expected to be complete in 2004 and at that time will be tested to ascertain
whether DHS will consider it to be under the direct influence of surface waters.
Response to Comment 300-6
Comment Summary.
The comment quotes a section of the Draft EIR concerning
methodology for evaluating potential health impacts from recycled water. It then points out
that an inconsistency exists between Table 4.7-5 and Table 4.6-21 in that copper, lead,
nickel, and zinc are all showing an increase from pre- and post-geysers recharge baselines.
The apparent inconsistency is due to differences in what each of the tables is presenting.
Table 4.7-5 presents the concentrations of constituents in fresh, undiluted recycled water,
comparing data collected between 1988 and 1995 to data collected 1997 to 2002. Table 4.6-
21 presents the estimated concentrations of constituents in the Russian River with varying
percentages of recycled water.
These estimates are calculated using both the ambient
concentration of constituents and the recent (1997 to 2002) concentration in recycled water.
Response to Comment 300-7
Comment Summary: The comments states that Chapter 4.7 of the Draft EIR references only
current Maximum Contaminant Levels, that regulatory requirements are becoming more
stringent and that a comparison to Public Health Goals plus a sensitivity analysis based on
the assumptions and variables used in the evaluation should be provided.
Public Health Goals (PHGs) are required for drinking water contaminants for which there
already is a primary drinking water standard (maximum contaminant level, or MCL) as well
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PAGE 300-3
as for any newly regulated contaminants.
The Office of Environmental Health Hazard
Assessment has adopted PHGs for 46 chemicals in the last two years.
PHGs are
concentrations of chemicals in drinking water that are not anticipated to produce adverse
health effects after lifetime exposure. They are to be based on risk assessments conducted
using "most current principles, practices, and methods used by public health professionals"
and certain public health criteria. PHGs are solely health-based; the evaluations provide
health related information to the California Department of Health Services for consideration
of updating state Maximum Contaminant Levels (MCLs) on the basis of the most recent
toxicity data and risk assessment methods. As such, PHGs are advisory, and information on
PHGs may or may not result in changes in MCLs. MCLs are thus the appropriate parameter
to use as criteria for the IRWP EIR.
Response to Comment 300-8
Comment Summary: The comment states that a discussion in Chapter 4.6 of the Draft EIR of
the anti-degradation policies of the EPA and State Water Resources Control Board supports
the commentor’s request for a Department of Health Services determination regarding water
treatment of SCWA water that might be required as a result of increased discharges to the
Russian River.
Please refer to Response to Comment 300-5.
Response to Comment 300-9
Comment Summary. The comment quotes a section of the Draft EIR that summarizes Policy
RC-3E of the Sonoma County General Plan and states the belief that direct and indirect
discharge would not comply with these policies, pointing out that direct and indirect
discharge alternatives are considered to have a significant impact in the Draft EIR.
The Draft EIR includes Policy RC-3E in its discussion of relevant Goals, Objectives and
Policies on Page 4.6-23 and directs the reader to the evaluation of criteria 1-4 of the Water
Quality Section. The City of Santa Rosa agrees that direct and indirect discharge alternatives
may not comply with these policies as well as some of the other alternatives. However, this
Draft EIR presents and evaluates a variety of alternatives. These alternatives were picked to
meet the mandate for a reasonable range of alternatives that could feasibly achieve the
Program Objectives. These alternatives were also specifically defined in such a way that
they would allow for the evaluation of the maximum range of potential environmental
impacts of any Program that the City may ultimately select. The Draft EIR identifies Indoor
Water Conservation as the environmentally superior alternative (Chapter 1 page 22).
Response to Comment 300-10
Comment Summary. The comment quotes the Draft EIR as stating some constituents do not
meet their respective CTR criteria. The comment further states that the project description
includes advanced membrane treatment (AMT) as needed to avoid exceeding CTR criteria
but says that the Subregional System has not committed to AMT.
The City is committed to AMT as needed to avoid exceedences of CTR criteria in the
receiving water if an alternative is selected that requires discharge. As noted on page 2-71 of
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PAGE 300-4
the Draft EIR, “In order to meet the requirements of the California Toxics Rule (CTR) for
discharge to surface waters, all of the Discharge options may include advanced membrane
treatment to the extent needed to comply with CTR.” The commentor is correct that no
commitments regarding AMT or any other component has been made, and cannot be made
until this EIR is certified.
Response to Comment 300-11
Comment Summary. The comment states that it appears that constituents in the Russian
River will increase from the pre- and post-geysers recharge baseline which is contrary to
antidegradation policies. The comment also states that the Draft EIR lists impact 6.12.1 as
significant because indirect discharge will exceed numeric criteria for constituents.
Some (not all) constituents are predicted to increase from the pre- and post-geysers recharge
baselines with the IRWP.
However, in the Draft EIR, the significance of impacts was
evaluated assuming no dilution for receiving waters.
Whether or not the increase in
constituents in the Russian River constitutes significant degradation will be determined in an
Antidegradation Analysis to be conducted after a project is selected.
The City agrees that the Draft EIR lists impact 6.12.1 as significant because indirect
discharge will exceed numeric criteria for some constituents after mitigation, specifically
cyanide.
Response to Comment 300-12
The comment suggests that alternatives for discharge above the SCWA collectors not be
considered further because of the cost and time required to perfect discharge alternatives.
Please refer to Master Response A – Statements of Opinion for or against a Program
Alternative or Component.
Response to Comment 300-13
Comment Summary: The comment is the comment letter submitted September 27, 1998 for
the Santa Rosa Subregional Long-Term Wastewater Project Draft Environmental Impact
Report/Environmental Impact Statement (Long-Term EIR).
This comment letter was numbered 18 in the Long-Term EIR and the response to the
comments presented in the letter can be found in Volume 20 on pages 6.3-295 through 6.3-
299.