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Pathogen Sources

Water quality monitoring results indicate the following source categories have potential to discharge fecal waste to surface waters in the Russian River Watershed: 

Sources of Human Fecal Waste Material: 

• Treated Municipal Wastewater to Surface Waters;
• Untreated Sewage from Sanitary Sewer Systems;
• Wastewater from Percolation Ponds and through Spray Irrigation;
• Runoff from Land Application of Municipal Biosolids and Biosolids Storage Areas;
• Runoff from Water Recycling Projects;
• Onsite Wastewater Treatment Systems;
• Recreational Water Uses and Users;
• Homeless and Illegal Camping; and
• Storm Water to Municipal Separate Storm Sewer System (MS4s) and Areas Outside MS4 Boundaries.

Sources of Domestic Animal and Farm Animal Waste:

• Pet Waste;
• Non-Dairy Livestock and Farm Animals; and
• Manure from Dairy Cows.

The regulatory mechanism for controlling each potential fecal waste source category is described in the table below.

Fecal Waste Source Category   Implementing Parties (Source) Implementation Actions and Compliance Date(s)
Municipal Wastewater Discharges  City of Ukiah, City of Healdsburg, City of Santa Rosa, Russian River CSD, Occidental CSD, City of Cloverdale  Compliance with the applicable National Pollutant Discharge Elimination System permits - Ongoing 
Wastewater Holding Pond Discharges to Surface Water  Town of Windsor, City of Santa Rosa, Graton CSD, Forestville WD, Russian River CSD, other entities with storage pond discharges to surface water 1. Within five year after the effective date of this Action Plan, the Regional Water Board will update waste discharge requirements (WDRs) to include water quality-based effluent limitations for fecal indicator bacteria that will ensure compliance with wasteload allocations for E. coli bacteria.
2. Within ten years after the effective date of this Action Plan, in accordance with an approved compliance schedule, implementing parties shall achieve compliance with wasteload allocations for E. coli bacteria.
Percolation Pond and Irrigation Discharges  Calpella CWD, Hopland PUD, City of Cloverdale, City of Ukiah, Geyserville CSD, Airport-Larkfield-Wikiup SZ, Russian River CSD, other publically and privately-owned wastewater treatment facilities in the Russian River Watershed that collect, treat, and dispose of or recycle treated effluent to land via percolation ponds or by irrigation.  Compliance with the applicable Waste Discharge Requirements - Ongoing 
Sanitary Sewer Systems City of Ukiah, Ukiah SD, Calpella CWD, Hopland PUD, City of Cloverdale, Geyserville CSD, City of Healdsburg, Town of Windsor, Airport-Larkfield-Wikiup SZ, City of Santa Rosa, South Park CSD, City of Cotati, City of Rohnert Park, City of Sebastopol, Sonoma State University, Graton CSD, Forestville WD, Russian River CSD, Occidental CSD, and other public entities that own or operate sanitary sewer systems  Compliance with the applicable Waste Discharge Requirements - Ongoing
Land Application of Treated Municipal Sewage Sludge 
(Biosolids) 
City of Santa Rosa, other public and private entities applying biosolids as a soil amendment   Compliance with the applicable Waste Discharge Requirements - Ongoing 
Recycled Water Irrigation Runoff  Entities permitted to beneficially reuse treated wastewater through irrigation to land, Regional Water Board   1. Compliance with the applicable Waste Discharge Requirements - Ongoing.
2. Within one month after the effective date of this Action Plan, each entity that is permitted to beneficially reuse treated wastewater and is implementing a Recycled Water Best Management Practices (BMP) Plan or equivalent BMP Plan shall submit to the Executive Officer written certification that its existing BMP Plan adequately prevents and/or minimizes overspray, spills, and incidental runoff.

3. Within two years after the effective date of this Action Plan, each entity that currently recycles water without a Recycled Water BMP Plan or equivalent BMP plan shall develop and implement a Recycled Water BMP Plan. Where the entity is the producer and user of recycled water, the entity shall also submit to the Regional Water Board Executive Officer a Title 22 Engineering Report approved by the State Water Board Division of Drinking Water. 

The Regional Water Board will require submission of the certification statement and, where necessary, notices to update existing Recycled Water BMP Plans under authority of section 13267 subdivision (b) of the Water Code. New Recycled Water BMP Plans, or equivalent BMP Plans, shall be submitted as part of a Notice of Intent for coverage under general WDRs or in conjunction with a report of waste discharge. 

Urban Runoff Sonoma County, Sonoma County Water Agency, City of Cloverdale, City of Cotati, City of Healdsburg, City of Rohnert Park, City of Santa Rosa, City of Sebastopol, City of Ukiah, Town of Windsor, County of Mendocino   1. Compliance with the applicable National Pollutant Discharge Elimination System permits, including implementation of approved Pathogen Reduction Plans – Ongoing.
2. Within two years of the effective date of this Action Plan, Municipal Separate Storm Sewer System (MS4) enrollees (excluding the Sonoma County Water Agency, who does not have land use authority) without an approved Pathogen Reduction Plan shall develop and implement a Pathogen Reduction Plan approved by the Regional Water Board Executive Officer.
For Phase I MS4 Permittees without approved Pathogen Reduction Plans on the effective date of the Action Plan, the Regional Water Board will require submission of the Pathogen Reduction Plans under authority of section 13267 subdivision (b) of the Water Code. For Phase II MS4 Permittees, the requirement to develop and implement a Pathogen Reduction Plan will be incorporated in the renewal of the Phase II MS4 Permit. 
California Department of Transportation (Caltrans) Storm Water  Caltrans Compliance with the applicable National Pollutant Discharge Elimination System permits – Ongoing  
Large Onsite Wastewater Treatment Systems  Owners and operators of all Onsite Wastewater Treatment Systems (OWTS)-otherwise known as septic systems- with projected flow greater than 10,000 gpd or owners of OWTS with project flow greater than set forth in an approved Local Area Management Plan, Regional Water Board  1. Within three months after the effective date of this Action Plan, owners and operators of OWTS with projected flow of over 10,000 gpd shall submit a Report of Waste Discharge (ROWD), or equivalent, to the Regional Water Board.
2. Within one year after the effective date of this Action Plan, based on the ROWDs received the Regional Water Board may issue WDRs or Waivers of WDRs for Large OWTS located in the geographic area of an Advanced Protection Management Program.

Existing, New and Replacement  Onsite Wastewater Treatment Systems  Owners of Onsite Wastewater Treatment Systems (OWTS)-otherwise known as septic systems, Regional Water Board, Sonoma County, Mendocino County   

Owners and operators of Existing, New, and Replacement OWTS shall:

1. Immediately comply with local codes and ordinances pertaining to OWTS.
2. Maintain their OWTS in good working condition, including inspecting the OWTS and pumping of solids as necessary, or as required by local ordinances, in order to maintain proper function and assure adequate wastewater treatment and disposal.
3. Notify the local agency in the event that their OWTS has pooling effluent, discharges wastewater to the ground surface, or has wastewater backed up into plumbing fixtures.
4. Notify the local agency in the event that their OWTS septic tank has failed such that wastewater is leaking from the tank or groundwater is infiltrating the tank.
5. As directed by the Regional Water Board, provide information to the Regional Water Board to assess the performance of their OWTS.
6. As directed by the local agency, obtain an appropriate local agency permit for the repair or replacement of an OWTS deemed to be in need of corrective action pursuant to this Action Plan, and complete OWTS repairs or replacement within the time specified by the local agency or the Regional Water Board.
7. At least every five years, obtain required inspections and reports and submit to the Regional Water Board, or as directed by the Regional Water Board Executive Officer, the results of inspections, corrective actions, and other required information.

The Regional Water Board will:

1. Within six months after the effective date of this Action Plan and pursuant to section 13267 of the California Water Code, commence with notification process to require owners and operators of OWTS within the boundaries of the APMP to submit information pertaining to their OWTS to the Regional Water Board.
2. Within five years after the effective date of this Action Plan, complete the initial assessment of OWTS within the boundaries for the APMP.

The Regional Water Board, Sonoma County, and Mendocino County will:

1. Coordinate to procure funding assistance for disadvantaged communities and other individual OWTS owners affected by this Action Plan – Ongoing.
2. Develop public outreach actions to involve the public in decision-making related to abatement actions for existing OWTS within the APMP designated areas that are in need of correction action. Outreach actions might include citizen advisory groups and public meetings- Ongoing.

Recreational  Water Uses and Users  Regional Water Board, Sonoma County, Mendocino County  1. In accordance with a Memorandum of Understanding, Sonoma County, the Sonoma County CDC, and the Regional Water Board will work with local entities and private parties along the Russian River to address water quality impacts relative to recreational water uses, and to promote the installation and location of sanitary facilities along the Russian River for use by recreational water users – Ongoing.
2. Mendocino County and the Regional Water Board will develop a Memorandum of Understanding or equivalent agreement to address water quality impacts relative to recreational water uses -Ongoing.

Homeless Encampments; Illegal Camping  Regional Water Board, Sonoma County, Sonoma County Community Development Commission (CDC), Mendocino County  1. In accordance with a Memorandum of Understanding, Sonoma County, the Sonoma County CDC, and the Regional Water Board will implement a Joint Protocol to address water quality impacts relative to homeless encampments - Ongoing.

2. Mendocino County and the Regional Water Board will develop a Memorandum of Understanding or equivalent agreement to address water quality impacts relative to homeless encampments -Ongoing.


The Regional Water Board will prioritize permitting for homeless-dedicated and affordable housing projects in the Russian River area for which Regional Water Board permits are required - Ongoing.

Non-dairy Livestock and Farm Animal Waste  Owners and operators of animal facilities, inclusive of animal husbandry, livestock production, other similar agriculture  operations, and commercial animal boarding facilities   Within two years after the effective date of the Total Maximum Daily Load Action Plan, owners and operators of animal facilities shall implement Best Management Practices (BMPs) to properly contain and dispose of waste, and mitigate for potential water quality impacts resulting from surface runoff of animal waste, or submit a Report of Waste Discharge if such BMPs are not implemented or if directed by the Regional Water Board Executive Officer.                                                  
Dairies and Cow Dairies and Concentrated Animal Feeding Operations (CAFOs) Owners and Operators of CAFOs not subject to National Pollutant Discharge Elimination System permits   1. Compliance with the applicable Waste Discharge Requirements (WDRs) or Waivers – Ongoing.
2. Within two years after the effective date of this Action Plan, enrollees under the Conditional Waiver of WDRs shall update and implement required plans (i.e. Water Quality Plan, Waste Management Plan, or comparable plans) to address sources of bacteria.
Dairies and Cow Dairies and Concentrated Animal Feeding Operations (CAFOs) Owners and Operators of CAFOs subject to National Pollutant Discharge Elimination System permits   1. Compliance with the applicable National Pollutant Discharge Elimination System permits - Ongoing.
2. Within two years after the effective date of this Action Plan, enrollees under Waste Discharge Requirements shall update their permit-required management plans to address sources of bacteria.

Russian River Clean

Contact Information

Russian River Clean

Alisha O'Loughlin

Lower Russian River Ombudsperson


County Administrator's Office
County of Sonoma

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County Administration Building
575 Administration Drive
Suite 104A
Santa Rosa, 95403