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by David Keller
FOER Bay Area Director
Sonoma County Water Agency (SCWA) is seeking millions of dollars from the Bureau of Reclamation to build a huge pipe and pumping network, in order to export treated wastewater from their contractor cities to southern Sonoma and Napa valleys for more agricultural irrigation. This would put added demands on SCWA water sources including our Eel River to supply new growth, rather than maximize the reuse of treated wastewater to first displace potable water demands for landscaping, toilets, industrial and commercial uses.
Senate Bill S.1472 (Feinstein, Boxer) and H.R.236 (Thompson, Woolsey) are funding bills requested by SCWA for this purpose, and they have already been heard in subcommittees in both the House and Senate. Friends of the Eel River (FOER) urges you to write to Senator Bingamen (D, NM) expressing your opposition, AS SOON AS POSSIBLE. We provide key addresses and a link to the complete bills below.
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An Open Letter to the Senate Energy and Natural Resources Committee objecting to additional demands on the Eel and Russian Rivers and Groundwater.
September 25, 2007
Senator Jeff Bingaman
Chairman, Senate Energy and Natural Resources Committee
703 Hart Senate Office Building
Washington, DC? 20510
RE: S.1472 North Bay Water Reuse Program Act of 2007
Companion Bill, H.R.236
Dear Chairman Bingaman,
Members of the Senate Energy and Natural Resources Committee:
The following comments on S.1472 are submitted on behalf of Friends of the Eel River.
Since 1994, Friends of the Eel River (FOER) has been dedicated to its mission to restore the Eel River and all of her tributaries to a natural state of health and abundance, wild and free.The Eel River was declared a National Wild and Scenic River in 1981, home to dwindling populations of federally listed Coho and Chinook Salmon and Steelhead. FOERs 2500 members live and work throughout the North Coast and Bay Area of California.
Plans made and actions taken by the Sonoma County Water Agency (SCWA) and other jurisdictions have both direct and indirect influence on the health and restoration of the Eel River, and as such, we appreciate the opportunity to provide these comments.
FOER has worked diligently to protect and restore our beleaguered water resources and fisheries in both the Eel River and the Russian River (connected through diversions from the Eel River at the Potter Valley Project PG&E hydropower facilities), as well as address the overdrafted and declining groundwater basins throughout Sonoma County. SCWA (the largest municipal water wholesaler in Sonoma and Marin Counties) is currently subject to California State Water Resources Control Board (SWRCB) mandatory 15% cutbacks in withdrawals from the Russian River to protect its Fall-run Chinook. SWRCB has also asked SCWA to devise plans for future water supplies that involve no increases in demands from the Russian River.
Planning for the long-term future of reliable water supplies in our region while protecting and restoring our public trust and resources has required a shift in public policy.
We are working with policy makers, agricultural interests, and commercial and residential ratepayers to reduce demands for potable water, to maximize water efficiencies and conservation (saving energy and greenhouse gas emissions, too). We also support appropriate reuse of highly treated wastewater within the SCWA service areas to displace potable water demands, and eliminate exports of SCWA water to other regions.
We are now seeing water planning that incorporates some of the best thinking in the nation, allowing at least one city (Petaluma) to plan for its next 20 years growth with a zero-increment in potable water demand. This example follows the lead of other municipal water suppliers in California (including Los Angeles, East Bay Municipal Utility District and Marin Municipal Water District), which have proven that intelligent use of all water resources is not only feasible, but a requisite tool for the arid Wests future. Unfortunately, our review of the North Bay Water Reuse Program Act of 2007 (Project) S.1472 (Feinstein-sponsor, Boxer-sponsor) and H.R.236 (Thompson, Woolsey) brings us to strongly oppose this legislation for a number of reasons:
1. S.1472 fails to set any priority that recycled water should be first used to offset and reduce local potable water demands. Instead, it provides for irrigation of tens of thousands of acres of new and expanded agricultural lands using treated municipal wastewater derived from SCWA municipal customers (except wastewater from the city of Napa).
That recycled water wont, then, be available to offset new or existing municipal potable water demands. While some of this wastewater is currently discharged into San Pablo Bay, reuse of the water to substantially reduce demands on the already overtaxed SCWA water supply system should come first.
2. S.1472 fails to set any limits on the quantities of water to be exported for expanded agricultural irrigation and environmental restoration in the proposed Project areas.
3. S.1472 fails to require addressing the impacts to the Eel and Russian Rivers and groundwater caused by exportation of their waters to regions outside the SCWA service area in both Sonoma and Napa counties, primarily in different watersheds.
4. S.1472 fails to provide built-in limits on how far the pipelines and pumps may be built and what areas would be served. The bill also fails to provide limits on future use of the pipelines, including the pipelines and pumps that would serve the Napa-Sonoma Marsh Restoration Project at the tail end of the Project pipeline.
5. S.1472 precedes any environmental evaluation, under NEPA or CEQA, of the Project and its impacts, benefits and deficiencies. For instance, similar proposals (i.e. another SCWA-proposed Bureau of Reclamation project, the North Sonoma County Agricultural Reuse Project) for use of treated wastewater in the Dry Creek and Alexander Valley regions of the Russian River for irrigation of premium vineyards has recently met with significant opposition by local ranchers, who dont want treated wastewater used for application to their world-class grapes, soils or groundwater.
6. S.1472 fails to consider alternative sources of recycled water from outside the SCWA water supply system, other than Napa. The nearby City of Vallejo (through the Vallejo Sanitation and Flood Control District) should be a first choice, as it is already discharging 12-60 millions of gallons per day of treated wastewater into San Pablo Bay.
While various public wastewater plant operators and water contractors have shown interest in expanding the local reuse of recycled water, some have expressed concerns over costs of the infrastructure improvements required to meet current and projected reuse opportunities within their service areas. Rather than providing this financial assistance to agencies and ratepayers, S.1472 would take that water out of their service areas to supply a large expansion of agricultural users - primarily grape growers in Sonoma and Napa valleys - in areas that are currently water-scarce.
Even the current Draft Sonoma County General Plan states:
Any consideration to export additional water resources places primary priority upon the benefit of and need for the water resources in Sonoma County and shall assure that water resources needed by urban, rural and agricultural water users in Sonoma County will not be exported outside the county. (Policy WR-5a)
FOER supports this policy, and would add equivalent protections and priorities for water resources needed by the dependent natural resources in Sonoma County as well.
S.1472 and H.R.236 significantly violate this trust and critical public policies, and is antithetical to our communitys hard work to come to grips with our intertwined water, natural resource and population futures.
We urge you to defeat this defective bill. We offer our assistance in rewriting it in the next session to address these urgent concerns.
Please send your letters ASAP to:

Senator Jeff Bingaman, (D, NM) Chairman, Senate Energy and Natural Resources Committee, 703 Hart Senate Office Building, Washington, DC? 20510

Senator Pete Dominici (R, NM), Ranking Member, 328 Hart Senate Office Building, Washington, DC 20510

Senator Diane Feinstein, 331 Hart Senate Office Building, Washington, D.C. 20510

Senator Barbara Boxer, 112 Hart Senate Office Building, Washington, DC 20510

Or, call the Capitol switchboard, and ask for the Senators offices: (202) 224-3121

Texts of bills:
S.1472 (Feinstein/Boxer)? http://thomas.loc.gov/cgi-bin/query/z?c110:S.1472:
H.R.236 (Thompson/Woolsey): http://thomas.loc.gov/cgi-bin/query/z?c110:H.R.236: