Del Mar City Council
September 22, 2026

Residential land uses range from low density (where houses are on lots of more than an acre) to high density, multiple-unit structures. The boundaries of the Urban Service Areas (PRMD 2010) were used to identify those urban and residential areas that are sewered to receive domestic wastewater treatment.
 Developed Non-Sewered – Residential land uses identified by Fry et al. (2011) where the houses are outside of the boundaries of the Urban Service Areas (PRMD, 2010) and assumed to use individual septic systems for disposal of domestic waste.

For each of the five land cover categories, six water samples were collected at three different locations during both wet and dry periods. Samples were analyzed for E. coli, human-host Bacteroides, and bovine-host Bacteroides bacteria. Visual comparison and statistical hypothesis tests were made between different data groupings. More information on the assessment methods is available in Butkus (2013a).

4.2.1. Results
The results of the land cover analysis are presented in Figures 4.4 through 4.9. Results indicate that human-source Bacteroides bacteria are present in all locations and in all land use categories. Pathogenic indicator bacteria concentrations in wet periods have statistically-significant higher concentrations than dry periods.

Runoff from forest lands has statistically-significant lower concentrations of pathogenic indicator bacteria than runoff and base flow in all other land cover categories assessed.

Runoff from shrubland, agricultural areas, and forested areas have statistically-significant lower pathogenic indicator bacteria concentrations than runoff from developed areas (both sewered and non-sewered areas).

A stable isotope analysis, which measures oxygen and nitrogen in the water sample, was also conducted on samples from different land use categories to help identify the source of the water associated with the bacteria in samples. The results show that most of the September 222026 Item 7
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nitrate measured in the samples was from soil, which was likely carried into the water column through rainfall-induced erosion. The results also show that several of the samples collected during wet weather in both sewered and non-sewered developed areas were likely derived from domestic wastewater, which suggests that storm events may be transporting untreated domestic wastewater from sanitary sewer overflows and exfiltration, failing sanitary sewer pipelines and sewer laterals, and failing septic systems into streams. Discharges from municipal wastewater treatment facilities are not sources as sample locations were upstream of their discharge locations.

Reading a Box & Whisker Plot
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Figure 4.4. E. coli Bacteria Concentrations Measured in the Russian River Watershed during Dry Periods by Land Cover Category.

Figure 4.5. E. coli Bacteria Concentrations Measured in the Russian River Watershed during Wet Periods by Land Cover Category
1 10
100
1,000
10,000
Forest Land Shrubland Agriculture Developed
Onsite Septic
Developed
Sewered
E. coli Bacteria Concentration (MPN/100mL)
Land Use
Russian River Watershed
Dry Period E. coli Bacteria Concentrations
REC-1 Geomean Criterion
1 10
100
1,000
10,000
100,000
Forest Land Shrubland Agriculture Developed
Onsite Septic
Developed
Sewered
E. coli Bacteria Concentration (MPN/100mL)
Land Use
Russian River Watershed
Wet Period E. coli Bacteria Concentrations
REC-1 Geomean Criterion
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Figure 4.6. Human-specific Bacteroides Bacteria Concentrations Measured in the Russian River Watershed during Dry Periods by Land Cover Category.

Figure 4.7. Human-specific Bacteroides Bacteria Concentrations Measured in the Russian River Watershed during Wet Periods by Land Cover Category. 10 100
1,000
10,000
100,000
1,000,000
10,000,000
100,000,000
Forest Land Shrubland Agriculture Developed
Onsite Septic
Developed
Sewered
EBacteroides Bacteria Concentration
(16S rRNA genes/100mL)
Land Use
Russian River Watershed
Dry Period Human-specific Bacteroides Bacteria Concentrations Current Reporting Limit
10 100
1,000
10,000
100,000
1,000,000
Forest Land Shrubland Agriculture Developed
Onsite Septic
Developed
Sewered
Bacteroides Bacteria Concentration
(16S rRNA genes/100mL)
Land Use
Russian River Watershed
Wet Period Human-specific Bacteroides Bacteria Concentrations Current Reporting Limit
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Figure 4.8. Bovine-specific Bacteroides Bacteria Concentrations Measured in the Russian River Watershed during Dry Periods by Land Cover Category.

Figure 4.9. Bovine-specific Bacteroides Bacteria Concentrations Measured in the Russian River Watershed during Wet Periods by Land Cover Category. 10 100
1,000
10,000
100,000
Forest Land Shrubland Agriculture Developed
Onsite Septic
Developed
Sewered
EBacteroides Bacteria Concentration
(16S rRNA genes/100mL)
Land Use
Russian River Watershed
Dry Period Bovine-specific Bacteroides Bacteria Concentrations Current Reporting Limit
10 100
1,000
10,000
100,000
1,000,000
Forest Land Shrubland Agriculture Developed
Onsite Septic
Developed
Sewered
Bacteroides Bacteria Concentration
(16S rRNA genes/100mL)
Land Use
Russian River Watershed
Wet Period Bovine-specific Bacteroides Bacteria Concentrations Current Reporting Limit
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4.3 POINT SOURCE FACILITIES AND ACTIVITIES
This section describes existing and potential point sources of pathogens to surface waters in the Russian River Watershed. Clean Water Act section 402 addresses direct discharges of waste into navigable waters. Direct discharges or "point source" discharges of pollutants come from any discernible, confined, and discrete conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, or vessel or other floating craft. This term does not include agricultural stormwater discharges and return flows from irrigated agriculture.

Point source discharges to waters of the United States are regulated under the federal National Pollutant Discharge Elimination System (NPDES) program. Point source discharges to waters of the state are regulated under waste discharge requirements (WDRs). The point sources described in this section were identified by querying the California Integrated Water Quality System (CIWQS) database for existing facilities regulated by a NPDES permit.

4.3.1 WASTEWATER DISCHARGES TO SURFACE WATERS
Wastewater discharges to surfaces waters in the Russian River Watershed occur from both direct permitted discharges and from unpermitted spills and leaks. The following sections identify sources in the watershed.

4.3.1.1 Municipal Wastewater Discharges To Surface Waters The watershed contains nine municipal wastewater treatment facilities that are authorized under NPDES permits to discharge treated domestic wastewater into surface waters. Table

4.1 summarizes these facilities (per information obtained from CIWQS in Nov. 2013) and describes their level of treatment. Figure 4.1 shows the locations of these facilities in the watershed. All facilities in the watershed treat to secondary or tertiary levels. Secondary treatment refers to physical, chemical, and biological unit processes used to meet federal standards in 40 C.F.R. §133.102 for biochemical oxygen demand (BOD), total suspended solids (TSS), and pH. Tertiary treatment is generally defined as treatment beyond secondary levels to achieve a higher level of BOD or TSS removal or to remove constituents of concern such as nutrients or toxic compounds.

To achieve water quality objectives, protect beneficial uses, protect public health, and prevent nuisance, surface water discharges are prohibited from May 15 through September

30. During the remainder of the year, discharges are limited to one percent of the flow volume in the receiving water unless specifically exempted in the NPDES permit. For authorized discharges of wastewater to the Russian River and its tributaries during October 1 through May 14, the Basin Plan requires that discharges of municipal waste “shall be of advanced treated wastewater in accordance with effluent limitations contained in NPDES permits for each affected discharger, and shall meet a median coliform level of 2.2 MPN/100 mL.” The Regional Water Board has defined advanced wastewater treatment in individual permits as treated effluent meeting, in part, disinfection standards, including September 222026 Item 7
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total coliform thresholds, consistent with tertiary treated recycled water requirements set forth in title 22 of the California Code of Regulations.

Disinfection standards in municipal NPDES permits consist of effluent limitations for total coliform bacteria and other process requirements to ensure adequate effluent disinfection.

For surface water discharges, municipal NPDES permits in the Russian River Watershed prescribe uniform effluent limitations for total coliform bacteria that require:
 The 7-day median concentration not exceed an MPN of 2.2 per 100 mL;  The number of coliform bacteria not exceed an MPN of 23 per 100 mL in more than one sample in any 30-day period; and
 No single sample exceed an MPN of 240 total coliform bacteria per 100 mL.

In addition to effluent limitations for total coliform bacteria, municipal NPDES permits also require compliance with disinfection process requirements depending on the permitted facility’s method of disinfection. For wastewater treatment facilities that employ an ultraviolet (UV) disinfection process, permittees are required to ensure a minimum UV dose, maintain a minimum UV transmittance, and perform appropriate operation and maintenance activities specified by Division of Drinking Water of the State Water Resources Control Board. For wastewater treatment facilities that utilize chlorine as a means of disinfection, permittees must demonstrate a continuous chlorine residual after treatment or provide a minimum CT (the product of total chlorine residual and modal contact time) value of not less than 450 mg-min/L at all times.

Regional Water Board staff used discharger-specific effluent monitoring data from selfmonitoring reports to assess total coliform bacteria concentrations in the effluent from these facilities. Table 4.4 shows that disinfection methods are highly effective at meeting effluent limitations for total coliform bacteria.

4.3.1.2 Recycled Water Holding Ponds
The beneficial reuse of treated wastewater, which is also known as recycled water, is common in the Russian River Watershed as a means to conserve scarce potable water supply and to comply with stringent discharge requirements imposed in NPDES permits in the watershed, including the Basin Plan’s prohibition against summertime discharges of waste to the Russian River and its tributaries. For these and other reasons, many wastewater treatment facilities temporarily store recycled water in large holding ponds for later distribution to recycled water users or until conditions are suitable and permitted for discharge to surface waters.

Although advanced wastewater treatment systems in the Russian River Watershed are operated to produce recycled water that is essentially pathogen-free and suitable for water recycling, this same recycled water, when stored in open-air holding ponds, may become contaminated as a result of regrowth of bacteria or through contribution of fecal matter from wildlife, particularly birds that frequent the storage ponds. Thus, the original bacterial water quality of the recycled water demonstrated immediately after disinfection cannot be guaranteed during storage.

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Figure 4.10. Municipal NPDES Wastewater Treatment Facilities in the Russian River Watershed
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Table 4.4: Municipal NPDES Wastewater Treatment Facilities in the Russian River Watershed and Percent Compliance with Total Coliform Effluent Limitations
Permit No. Facility Name Capacity
(mgd)
Treatment
Type
Percent Compliance
Daily
Max.
7-Day
Median
Monthly
Max.

CA0022888 City of Ukiah
Wastewater Treatment Plant 3.01 Tertiary 100.0% 93.9% 100.0% CA0022977 City of Cloverdale
Wastewater Treatment Plant 1.0 Secondary 100.0% 100.0% 100.0% CA0025135 City of Healdsburg
Water Reclamation Facility 1.4 Tertiary 100.0% 98.4% 100.0% CA0022764 Santa Rosa Subregional
Water Reclamation System 21.34 Tertiary 99.9% 100.0% 99.9% CA0023345
Town of Windsor Wastewater
Treatment, Reclamation, and Disposal
Facility

1.9 Tertiary 100.0% 96.1% 100.0%
CA0023639
Graton Community Services District
Wastewater Treatment, Reclamation,
and Disposal Facility

0.397 Tertiary 100.0% 100.0% 100.0%
CA0023043
Forestville Water District Wastewater
Treatment, Reclamation, and Disposal
Facility

0.130 Tertiary 99.9% 83.6% 99.7%
CA0024058 Russian River County Sanitation District
Wastewater Treatment Facility 0.71 Tertiary 100.0% 100.0% 100.0% CA0023051 Occidental County Sanitation District
Wastewater Treatment Facility 0.05 Secondary 100.0% 97.6% 100.0% Many studies document the occurrence of fecal indicator bacteria and other opportunistic pathogens in open-air reservoirs, but the public health risk associated with pathogens in recycled water storage ponds has not been well-documented. Regional Water Board staff evaluated monitoring data for treated effluent discharges from the open-air, recycled water storage ponds at Vintage Greens used by the Town of Windsor. Monitoring results from 2007-2011 indicate measureable concentrations of E. coli, sometimes at levels exceeding the U.S. EPA (2012) Beach Action Value of 235 cfu/100 mL. These results are shown in Figure 4.2.

In the Russian River Watershed, municipal wastewater treatment facilities that discharge to surface waters directly or indirectly after storage employ either chlorine or ultraviolet light as a means of wastewater disinfection. Research assessing the regrowth or photoreactivation of bacteria or pathogens in storage ponds is sparse; most recent work has focused on photoreactivation after exposure to ultraviolet light. One study reviewed by Regional Water Board staff used biochemical fingerprinting to show that the fecal contamination in a golf course pond supplied with chlorine-disinfected recycled water was not related to the recycled water and that the fecal indicator bacteria did not regrow in the ponds (Casanovas-Massana 2012). Another case study (Basu 2007) of fecal coliform regrowth in a full-scale operating wastewater treatment facility using ultraviolet disinfection concluded that bacterial regrowth in recycled water systems is a concern, but that exceedances of effluent limitations for fecal coliform in this study could be attributed to poor effectiveness of the ultraviolet disinfection system. The report also summarized September 222026 Item 7
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recent research on the topic, indicating that photoreactivation of bacteria diminishes drastically with dosages of ultraviolet radiation above 50 MJ/cm2.

Based on studies reviewed by Regional Water Board staff, discharges of treated wastewater from recycled water holding ponds will likely contain E. coli and other fecal indicator bacteria in concentrations above the TMDL targets. However, it is not clear whether the sources of detected E. coli bacteria are of human origin and therefore pose a more significant threat to public health or whether their presence is a result of contamination by birds and other wildlife that frequent the storage pond.

Figure 4.11: E. coli Bacteria Concentrations in a Recycled Water Holding Pond at Vintage Greens in Windsor

4.3.1.3 Sanitary Sewer Systems
Sanitary sewer systems collect and transport municipal wastewater from private residences, commercial buildings, industrial facilities, and institutional buildings to a wastewater treatment facility for treatment and disposal and/or reuse. Some sanitary sewer systems also convey stormwater and groundwater that may inadvertently enter the system. Sanitary sewer infrastructure is comprised of some or all of the following components: service laterals, collector sewers, connection wyes between laterals and collector sewers, interceptor sewers, manholes and cleanouts, pump stations, and force mains. Typically a public entity (e.g., municipality or county sanitation district) owns and is responsible for maintaining all components of the system except the service laterals, which 1 10
100
1000
2007 2008 2009 2010 2011 2012
E. coli Bacteria Concentration
(MPN/100mL)
Vintage Greens Recycled Water
E. coli Bacteria Concentrations in Holding Pond
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connect the individual building to the sewer system and are located on private property.

Where sewers are installed on private property such as a mobile home park or apartment complex, ownership and maintenance responsibility, including the connection point, is the responsibility of the property owners unless there are subdivision covenants or written agreements and easements which clearly indicate otherwise.

There are twenty-one public sanitary sewer systems in the watershed, as shown in Table

4.3 and based on CIWQS data from November 2013 and sanitary sewer management plans submitted by municipalities.

Table 4.5. Sanitary Sewer Systems in the Russian River Watershed Sanitary Sewer System Population
Served
Number of
Service
Connections
Miles of
Force
Main
Miles of
Gravity
Sewer
Miles of
Laterals
Calpella County Water District 450 100 0.3 2.9 1
City of Cotati 7,265 2,300 1 32 26.6
City of Rohnert Park 40,794 8,427 7.5 77 71.8
City of Santa Rosa 167,815 48,396 6.3 582 355
City of Sebastopol 7,750 2,800 2 25 53
City of Cloverdale 8,500 3,200 0.1 32.3 21
Forestville Water District 865 438 1.5 6 3.4
Graton Community Services District 1,815 445 0.3 6.5 4
City of Healdsburg 11,700 4,600 2.9 53.1 87
Hopland Public Utility District 1,200 288 0.6 4.4 6
Airport/Larkfield/Wikiup Sanitation Zone 9,306 1,937 1 10 9.2 Geyserville Sanitation Zone 809 267 1 4.3 1.3
Occidental County Sanitation District 636 71 1.5 1 0.3
Russian River County Sanitation District 7,377 2,467 5 35 11.7 Sonoma State University 10,000 18 0 2.5 1.2
South Park County Sanitation District 10,400 1,717 0 18.3 25.3 Ukiah Valley Sanitation District 5,000 4,971 1 43 44
City of Ukiah 16,500 5,642 0 44 44
Town of Windsor 26,950 8,250 1 92 60
Totals 343,179 100,040 34 1,151 863
Overflows of wastewater from the sanitary sewer can be caused by grease blockages, root blockages, sewer line flood damage, pump station power or mechanical failures, and surcharged pipe conditions from excessive stormwater or groundwater inflow and infiltration (I/I). Releases of wastewater from the sanitary sewer can also occur as a result of poor sewer design, pipe or material failures, construction-related damage, or lack of a preventive maintenance program, which includes sufficient planning for system rehabilitation and replacement. Private building laterals can crack, become disjointed or displaced, and blocked with roots or other debris and result in an overflow. Untreated sewage from sanitary sewer system releases can contain high levels of pathogenic microorganisms and other pollutants.

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All federal and state agencies, municipalities, counties, districts and other public entities that own or operate sanitary sewer systems greater than one mile in length that collect and/or convey untreated or partially treated wastewater to a wastewater treatment facilities are required to enroll for coverage under General Waste Discharge Requirements for Sanitary Sewer Systems, Water Quality Order No. 2006-0003-DWQ (General Order).

The General Order establishes minimum requirements to prevent sanitary sewer overflows (SSOs). Reporting requirements are included to ensure adequate and timely notifications are made to appropriate local, state, and federal authorities in the event of SSOs from publicly-owned sewer infrastructure. Table 4.6 lists the details for SSOs reported to the CIWQS SSO database since 2007 that equaled or exceeded 1,000 gallons, resulted in a discharge to a drainage channel and/or surface waters, or discharged to a storm drain and were not fully captured and returned to the sanitary sewer system. These data are based on information retrieved from CIWQS in November 2013.

Private sewer laterals are owned and maintained by the property owner. Private sewer laterals are not regulated under the General Order and, therefore, owners of private laterals are not required by permit to report SSOs that occur as a result of a failure or blockage in the lateral. Because of the sheer number of private laterals connected to a municipal sewer system and the limited jurisdiction that municipalities have over sewer laterals on private property, SSOs from private sewer laterals often go unreported and corrective actions to stop the SSO may be delayed. Most municipalities have established local ordinances that require property owners connected to the municipal system to design and install new laterals in accordance with local standards and maintain existing service laterals and cleanouts in good working order at the owner’s expense. Local ordinances that require property owners to inspect their private service laterals at a property transfer, in response to chronic SSOs, or changes in use are rare in the Russian River Watershed. At least one public sanitation district within the Russian River Watershed offers a program that enables eligible ratepayers to replace leaky or deteriorating service laterals at the expense of the municipality.

Table 4.6. Sanitary Sewer Overflows in the Russian River Watershed from 2007 to Nov 2013 Responsible Agency Number
of SSOs
Volume of
SSO
(gallons)
Volume that
Reached Surface
Water (gallons)
% that
Reached
Surface Water
Calpella County Water District 1 1,500 990 66%
Forestville Water District 2 155 70 45%
Graton Community Services District 2 600 198 33%
City of Healdsburg 3 1,887 1,774 94%
City of Rohnert Park 2 305 241 79%
City of Santa Rosa 7 24,213 19,855 82%
City of Sebastopol 10 41,991 33,024 79%
Airport/Larkfield/Wikiup Sanitation Zone 1 60 50 83%
Occidental County Sanitation District 2 316 215 68%
Russian River County Sanitation District 3 1,704 699 41% City of Ukiah 9 2,045 1,677 82%
Ukiah Valley Sanitation District 3 1,750 1,085 62%
Town of Windsor 7 6,612 4,298 65%
Total SSOs since 2007 52 216,638 196,112 91%
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4.3.1.4 Sanitary Sewer Exfiltration
Exfiltration is different from SSOs. Overflows from sanitary sewer systems are usually caused by I/I leading to surcharged pipe conditions. This results in direct overflows to receiving water or land or causes sewer backups into residential or commercial buildings.

Exfiltration is generally described as a sewer leaking from its inside to its surrounding outside and occurs primarily at defective joints and cracks in service laterals, local mains and trunk sewer lines. Factors that contribute to exfiltration include: size and length of sewer lines, age of sewer lines, construction materials, and depth of flow in the sewer.

Geological and climatic conditions that contribute to exfiltration include groundwater depth, soil type, faults, and rainfall.

Exfiltration from sanitary sewer systems is not explicitly regulated in the North Coast Region. However, compliance with requirements for proper operation and maintenance of public sanitary sewer systems set forth in the Sanitary Sewer Systems General Order may help reduce or eliminate exfiltration over time. The occurrence of exfiltration is thought to be limited to those areas where sewer elevations lie above the groundwater table. Since groundwater elevations near surface waterbodies are typically near the ground surface, sewers near surface waterbodies generally are below the groundwater table and infiltration (rather than exfiltration) might be expected to dominate the mode of sewer leakage in these areas.

4.3.1.5 Other NPDES Facilities
Fish Hatcheries
There is one fish hatchery within the Russian River Watershed: Warm Springs Dam Fish Hatchery. The facility is owned by the U.S. Army Corps of Engineers and is operated by the California Department of Fish and located at the base of Warm Springs Dam in Healdsburg.

The facility is regulated under Waste Discharge Requirements Order No. 97-61 (NPDES Permit No. CA0024350).

The facility is designed to raise approximately 161,000 pounds (800,000 fish) per year for release to the Russian River, and it feeds up to 40,000 pounds of feed during the month of maximum feeding. Influent to the facility comes from Warm Springs Dam (Lake Sonoma) and, if necessary, from a series of wells adjacent to Dry Creek. Influent flow is aerated and routed to twenty ponds/raceways, which discharge to a single, full flow pollution control pond with a minimum detention time of 2.5 hours. Treated wastewater from the pollution control pond is discharged to Dry Creek, which is tributary to the Russian River, and also is used for landscape irrigation on less than five acres at an adjacent visitor center and day use area.

Waste Discharge Requirements Order No. 97-61 contains effluent limitations and monitoring requirements for effluent flow, suspended solids, settleable solids, and chloride.

E. coli and Bacteroides bacteria are found in the intestinal tracts of warm-blooded animals.

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bacteria comes from ingestion of the bacteria from other sources and are not produced within the fish. Fish simply serve as a vector for E. coli transmission from other sources (Hansen et al. 2008). Therefore, fish hatcheries are not considered a source of E. coli and Bacteroides bacteria for this TMDL.

Other Permittees
There are a number of permittees in the Russian River Watershed that are regulated under NPDES permits for waste discharges to surface waters, but do not receive, treat or discharge domestic wastewater under conditions of the permit (Table 4.5). These permitted discharges are not expected to be a source of pathogens in amounts that contribute to the pathogen impairment in the watershed.

Table 4.7: Other NPDES Facilities in the Russian River Watershed Permit No. Permittee Name Facility Type
CA0023655 Sonoma West Holdings Plant #2 Facility Food Processing CAG911001 JDS Uniphase Laboratory
CA0005843 Mendocino Forest Products Ukiah Sawmill Saw Mill CAG990002 AT&T Statewide Cable System Utility Structure CAG990002 Pacific Bell (AT&T) Utility Structure
CAG990002 Pacific Gas & Electric Company Utility Structure CAG990002 Sprint Utility Structure
CAG990002 Verizon California Utility Structure
CAG990005 Sonoma County Water Agency Aquatic Herbicide
CAG990004 Marin/Sonoma Mosquito and Vector Control District Pesticide/Vector Control CAG990005 Potter Valley Irrigation District Aquatic Herbicide CAG990005 City of Santa Rosa Aquatic Herbicide
CAG990005 Sonoma County Regional Parks Aquatic Herbicide

4.3.2 WASTEWATER DISCHARGES TO LAND
The following sections identify known wastewater discharges to land in the Russian River Watershed and discuss the likelihood that discharges are sources of pathogens to surface waters.

4.3.2.1 Municipal Wastewater Discharges to Land
The Russian River Watershed contains five municipal wastewater treatment facilities that are authorized under WDRs to discharge treated domestic wastewater to land (Figure

4.12). Table 4.8 summarizes these facilities (based on information obtained from CIWQS in November 2013) and describes their treatment capabilities and methods of effluent disposal or reuse.

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Figure 4.12. Municipal WDR Wastewater Treatment Facilities in the Russian River Watershed
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Table 4.8. Municipal WDR Wastewater Treatment Facilities in the Russian River Permit No. Facility Name Capacity
(mgd) Treatment Type/Disposal Method
86-16 Calpella County Water District 0.04 Aerated pond treatment, disinfection and percolation disposal
R1-2008-0003 Hopland Public Utility District 0.09 Aerated pond treatment, disinfection, and percolation disposal
88-52 Santa Rosa Oakmont
Wastewater Treatment Plant 0.065
Activated sludge, filtration,
disinfection, spray irrigation or
transfer to Laguna Treatment Plant
R1-2001-0069 Airport/Larkfield/Wikiup
Sanitation Zone 0.9
Aerated pond treatment,
microfiltration, disinfection, and spray
irrigation disposal
97-67 Geyserville Sanitation Zone 0.092 Aerated pond treatment, disinfection, and percolation disposal
Municipal wastewater treatment facilities discharging to land in the watershed rely primarily on aerobic pond systems for waste treatment to achieve the effluent quality necessary to protect groundwater quality. Disinfection using chlorine is commonly used to comply with an average monthly effluent limitation for total coliform of 23 MPN/100 mL.

Final disposal of treated effluent is through percolation to groundwater or spray irrigation to pasture land.

Municipal wastewater disposed of through spray irrigation from facilities that are operating properly and whose discharge conforms to conditions prescribed in waste discharge requirements is not expected to cause bacterial contamination of groundwateror surface waters. Municipal wastewater discharged to percolation ponds that are proximate to surface waters have the potential to contribute to bacterial loading in surface waters, depending on site specific conditions.

4.3.2.2 Land Application of Municipal Biosolids
Both Class A (Exceptional Quality) and Class B municipal biosolids contain pathogens, including bacteria, parasites, and viruses. Exposure to these pathogens may occur through direct contact with biosolids, through inhalation, ingestion of food that has come into contact with biosolids or through contact with vectors (flies, mosquitos, birds, rodents, etc.) that can transport from biosolids to humans. Federal regulations at 40 CFR 503 establish minimum standards for the regulation of biosolids using various risk assessment methodologies. Compliance with these regulations is assumed to minimize the human health risk associated with the land application of municipal biosolids.

In July 2004, the State Water Board adopted General Waste Discharge Requirements for the Discharge of Biosolids to Land for Use as a Soil Amendment in Agricultural, Silvicultural, Horticultural, and Land Reclamation Activities, Water Quality Order No. 2004-12-DWQ (General Order). The General Order incorporates the minimum standards established by the Part 503 Rule and expands upon them to fulfill requirements of the California Water Code.

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When biosolids are applied to ground surfaces where there is an increased risk that biosolids may migrate off the application site (e.g., where ground slopes are greater than 10 percent), the Regional Water Board Executive Officer may require an Erosion Control Plan to assure containment of the biosolids on the application site.

4.3.2.3 Private Domestic Wastewater Discharges to Land > 1,500 GPD Land discharges of large and medium-sized domestic wastewater or combined industrial/domestic wastewater systems are regulated under state-issued WDRs. Large systems have the capacity to treat more than 20,000 gallons per day (gpd) and are regulated by the Regional Water Board through individual WDRs. Medium-sized systems, which have a capacity of 1,500 gpd to 20,000 gpd, are typically regulated by individual or general WDRs.

In the Russian River Watershed, small volume domestic wastewater systems (e.g., septic systems with design flows less than 1,500 gpd and with subsurface effluent disposal) are typically regulated by local permits issued by the Sonoma County Permit and Resource Management Department or the County of Mendocino Department of Public Works. Small systems are treated as nonpoint sources in this TMDL project due to their generally diffuse occurrence in the watershed; see Section 4.2.1 for more information.

There are nineteen large and medium-sized domestic wastewater treatment facilities in the Russian River Watershed currently regulated under WDRs that discharge to land through conventional septic tank/leachfield systems, subsurface drip irrigation systems, percolation ponds, or spray irrigation. Table 4.9 summarizes these facilities and describes their treatment capabilities and methods of disposal.

WDRs for large wastewater discharges include effluent limitations, discharge prohibitions, and other conditions established to protect water quality and beneficial uses. Septic systems are designed in accordance with minimum standards for siting, design, and operation contained in the Basin Plan and other requirements set forth by the applicable local regulatory agency. Minimum standards that are critical to effective onsite treatment and disposal of waste include adequate separation to groundwater and drinking water sources, favorable soil characteristics and geology to maximize soil treatment, and suitable waste application rates. Land disposal systems conforming to prescribed minimum standards and operating properly are not expected to cause bacterial contamination of groundwater and surface waters. Land disposal through percolation ponds that are proximate to surface waters have the potential to contribute to bacterial loading in surface waters, depending on site specific conditions.

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Table 4.9. Private Domestic WDR Wastewater Treatment Facilities in the Russian River Watershed Permit No. Facility Name (Location) Capacity
(gpd) Treatment Type/ Disposal Method
97-10-DWQ Old Crocker Inn (Cloverdale) 1,875 Conventional septic tank/leachfield system 97-10-DWQ The Farmhouse Inn (Forestville) 3,285 Aerobic pretreatment and subsurface drip irrigation
97-10-DWQ Kendall-Jackson Wine Center
(Fulton) 5,850 Aerobic pretreatment with subsurface drip irrigation 97-10-DWQ Gurdjieff Foundation
(Guerneville) 2,490 Aerobic pretreatment with subsurface drip irrigation and at-grade disposal system 97-10-DWQ Sonoma-Cutrer Vineyards
(Santa Rosa) 1,800 Aerobic pretreatment with subsurface drip irrigation 97-10-DWQ Coppola Winery (Geyserville) 12,000 Aerobic pretreatment, disinfection, and subsurface drip irrigation
97-10-DWQ Jordan Vineyard and Winery
(Healdsburg) 3,500 Aerobic pretreatment and mound disposal 88-064 Rodney Strong Vineyard
(Healdsburg) 60,000 Aerated pond treatment, disinfection, and percolation disposal 97-10-DWQ Camp Newman (Santa Rosa) 20,000 Aerobic pretreatment with subsurface drip irrigation
97-10-DWQ Camp Royaneh (Cazadero) 16,600 Aerated pond treatment and percolation disposal
97-10-DWQ Camp Wente (Ukiah) 10,875 Conventional septic tank/leachfield system R1-2006-0053 Bohemian Grove (Monte Rio) 2,250,000 Aerated pond treatment, disinfection, and spray irrigation disposal
98-125 Odd Fellows Recreation Club
(Forestville) 45,000 Clustered, conventional septic tank/leachfield system 97-10-DWQ
Salvation Army-Lytton Springs
Rehabilitation Facility
(Healdsburg)
11,000 Aerated pond treatment, disinfection, and
spray irrigation disposal
R1-2012-0099
(waiver) EJ Gallo Winery (Healdsburg) 3,060 Conventional septic tank/leachfield system R1-2003-0068 Humane Society of Sonoma
County 2,423 Aerobic pretreatment and mound disposal
R1-2003-0029 Mayacamas Golf Club (Santa
Rosa) 4,900 Aerated pond, microfiltration, disinfection, spray irrigation R1-2002-0087 Vintner’s Inn (Santa Rosa) 32,000 Activated sludge system with surface drip irrigation
87-094 Rio Lindo Academy (Healdsburg) 75,000 Solids separation with evaporation/percolation disposal
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4.3.2.4 Wineries and Food Processors
The Russian River Watershed is home to more than 100 small and large commercial wineries. Winery waste includes pomace (grape skins, stems, and seeds), lees (dead and residual yeast cells, and other grape solids that settle to the bottom of a wine barrel or fermentation tank), bottle and barrel rinse water, and equipment/floor wash water.

Disposal of winery process wastewater through subsurface disposal (i.e., septic systems) is the common practice for small wineries. Larger wineries may use aerated pond systems to treat process wastewater prior to disposal or reuse through vineyard irrigation. Domestic, human waste is commonly disposed of in individual septic systems separate from the process wastewater disposal systems. However, there are some wineries in the Russian River Watershed that combine domestic and process wastewater streams and dispose of wastewater in septic systems, percolation ponds, or through vineyard irrigation. Winery process wastewater is not expected to contain a bacteria at levels of public health concern.

Disposal of combined domestic and process wastewater through percolation and vineyard irrigation is a potential source of pathogen indicator bacteria unless treatment includes disinfection.

Wineries whose waste discharges may affect waters of the state are required to obtain coverage under Order No. R1-2002-0012 (General Waste Discharge Requirements for Discharges of Winery Waste to Land) or under individual WDRs for large volume discharges or combined domestic and process wastewater systems. Wineries whose discharge is a low threat to water quality may qualify for a waiver of WDRs.

There are five food processing facilities in the watershed that discharge process wastewater to land and are regulated under individual WDRs or a waiver of WDRs. These facilities were identified as a result of a query of the CIWQS database in November 2013.

None of these permits contain effluent limitations. Other food processing facilities in the watershed have been identified by Regional Water Board staff. It is expected many of these facilities will enroll under a general waste discharge requirement permit or waiver of WDRs that are under development.

Generally, Good Manufacturing Practices (GMPs) and Sanitation Standard Operating Procedures (SSOPs) are the foundations for food safety programs for food processors. GMP regulations are designed to control the risk of contaminating foods with chemicals and microbes during their manufacture, and include practices for the cleaning and sterilization of equipment, pest control, and quality assurance assessment. SSOPs are specific, written procedures necessary to ensure sanitary conditions in the facility. SSOPs are required in all meat and poultry processing plants, in accordance with CFR Title 9 Part 416. Compliance with these practices and procedures will prevent contamination or adulteration of food products and will minimize the bacterial load discharged from the facility.

Although the level of bacteria associated with food processors is not currently known, given the nature of these discharges and the product sanitation safeguards, these facilities are not expected to be a source of pathogens in amounts that contribute to the pathogen impairment in the watershed.

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Table 4.10. Private Domestic WDR Wastewater Treatment Facilities in the Russian River Watershed
Permit No. Facility Name
(Location)
Design or
Permitted Flow Treatment Type/ Disposal Method
No. 79-019
Santa Rosa Meat and
Poultry Company
(Santa Rosa)
1,000 gpd
Specialty meat shop where industrial and
domestic wastewater flows through a septic
tank, one tank for industrial waste and one
tank for domestic waste, the flows are then
combined and chlorinated before disposal
into an evaporation/percolation pond.

No. 80-047 Timber Crest Farms
(Healdsburg) 10,000 gpd
Discharges wash water from the five
individual wineries and one food processor
renting space from the former dehydrated
fruit processing facility to a spray irrigation
system during the processing season (JuneSeptember).

No. 85-079 Manzana Products
Company (Graton) 25,000 gpd
Apple processing and canning plant that
discharges wash water to a spray irrigation
system during seasonal operations.

No. 88-071
Sonoma West
Holdings-South
(Sebastopol)
50,000 gpd
Multi-tenant food and beverage processing
facility that generates wash water. During
dry weather, wash water is spray irrigated
on 2.6 acres. Runoff from the spray fields is
collected and re-irrigated, discharged to
percolation beds, and/or retained in storage
tanks. During wet weather, all wash water is
directed to the percolation ponds and/or to
storage tanks. Domestic wastewater is
disposed of through an OWTS.

R1-2012-0116
(Waiver)
Olive Leaf Press
(Sebastopol)
120,000 gallons
storage capacity
Organic farm that produces olive oil from
Sonoma County-grown olives. The facility is
used for both the pressing of olives and
grapes along with the manufacturing of olive
oil. The facility is covered by the categorical
waiver policy as an agricultural commodity.

Wash water is stored in tanks and land
applied to 50 acres of agricultural land.

4.3.2.5 Mobile Home Parks & Campgrounds
There are 133 mobile home and special occupancy (RV) parks in the Russian River Watershed (CDHCD 2014). Most of these mobile home parks, RV Parks, and campgrounds are located within municipal sewer districts and discharge domestic wastewater to treatment facilities. However, forty-one of these parks are located outside of sewered areas and consequently dispose of domestic waste onsite via an individual septic system.

Because these septic systems are commonly large capacity, located adjacent to surface waterbodies, and often poorly maintained or overloaded, they have the potential to be a source of pathogenic bacteria. Figure 4.13 shows the locations of these facilities and provides an estimate of their wastewater flow volume based on the assumption that 250 gallons per day of wastewater is produced per mobile home or campground space (U.S.

DHEW 1972).

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Figure 4.13. Unsewered Mobile Home Parks and Campgrounds September 222026 Item 7
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4.3.3 STORMWATER
Bacteria sources contained in stormwater runoff include failing septic tanks, sewer and sewer lateral overflows, decaying organic material, and the improper disposal of household pet waste.

The NPDES Stormwater Program regulates
stormwater discharges from municipal
separate storm sewer systems (MS4s),
construction activities, industrial facilities,
and state highways. Permitted facilities in the
watershed are listed in Table 4.11. Most
stormwater discharges are considered point
sources, and operators of these sources may
be required to receive an NPDES permit
before they can discharge. In 1987, the U.S. Congress broadened the definition of "point source" to include construction and industrial stormwater discharges and municipal separate storm sewer systems (CWA §402(p)).

4.3.3.1 Municipal Stormwater
The 1987 amendments to the Clean Water Act required the U.S. EPA to address stormwater runoff in two phases. Phase I of the NPDES Storm Water Program began in 1990 and applied to large (serving 250,000 people or more) and medium (serving between 100,000 and 250,000 people) municipal separate storm sewer systems (MS4) and eleven industrial categories including construction sites disturbing five acres of land or more. Phase II of the NPDES Storm Water Program began in 2003 and applies to small MS4s (serving less than 100,000 people) including non-traditional small MS4s, which are facilities such as military bases, public campuses, prison and hospital complexes and construction sites disturbing from one up to five acres of land. The CWA requires that MS4 permits must “require controls to reduce the discharge of pollutants to the maximum extent practicable (MEP), including management practices, control techniques and systems, design engineering methods and such other provisions as the [U.S. EPA] Administrator or the state determines appropriate for the control of such pollutants.”
Within the Russian River Watershed’s urban boundaries, stormwater runoff and nonstormwater runoff is regulated under a Phase I MS4 Permit. The current Phase I MS4 Permit, Order No. R1-2009-0050 (NPDES Permit No. CA0025054), names the City of Santa Rosa, County of Sonoma, and the Sonoma County Water Agency as permittees. However, a number of communities within the Russian River Watershed that are enrolled under the Phase II Small MS4 Permit (Order No. 2013-0001- DWQ effective July 1, 2013) are meeting their Phase II MS4 requirements by voluntarily complying with the Phase I MS4 Permit.

These communities are the City of Cotati, the City of Rohnert Park, the Town of Windsor, the City of Sebastopol, the City of Ukiah, the City of Healdsburg, and the unincorporated communities of Guerneville, Monte Rio, Forestville, Graton, and Occidental.

Table 4.11. Permitted Stormwater Facilities in
the Russian River Watershed
Program Number of
Enrollees
Municipal Phase I MS4 3
Municipal Phase II MS4 6
Stormwater Construction 83
Stormwater Industrial 169
Caltrans 1
Total 260
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Under terms of the Phase I MS4 Permit, permittees are required to possess the legal authority to prohibit discharges of non-stormwater from dumping and disposal of materials such as litter, household refuse, and other materials that have the potential to become sources of pathogenic bacteria. . Permittees are also required to implement, in coordination with other public entities, as appropriate, a Public Information and Participation Program (PIPP) that includes education materials to inform the public on the proper disposal and storage of animal wastes.

Sources of pathogen indicator bacteria in urbanized areas (areas within MS4 boundaries) include SSOs, combined sewer overflows, illicit discharges to storm sewer systems (e.g., power washing), failing OWTS, wastewater treatment plants, urban wildlife, domestic pets, and agriculture (UWRRC 2014). The UWRRC report found that indicator bacteria concentrations in wet weather, urban discharges from MS4s were orders of magnitude above primary contact recreation standards. The report also found that epidemiological studies were limited, particularly during wet weather, and inconclusive regarding the human health risk associated with recreational activities in receiving waters impacted by urban runoff.

4.3.3.2 Industrial Stormwater
The most common pollutants of concern in industrial stormwater are suspended solids, oxygen-demanding substances (BOD), nutrients, and heavy metals. Most industrial categories are related to heavy industry and certain light industrial facilities and are unlikely to discharge a significant level of bacteria or other pathogens found in human domestic waste. However, some facilities that require coverage under a stormwater permit, such as concentrated animal feeding operations, solid waste transfer stations, sewage treatment plants, and composting operations, are potential sources of pathogenic bacteria and other public health-related pollutants.

Currently, stormwater discharges associated with industrial activities, unless otherwise excluded, are regulated under NPDES Industrial General Permit (Order 97-03-DWQ, NPDES No. CAS000001). Beginning on July 1, 2015, stormwater discharges associated with industrial activities, unless otherwise excluded, will be regulated under a new NPDES Industrial General Permit (Order 2014-0057-DWQ). Industrial facilities obtain permit coverage based on whether or not their Standard Industrial Classification (SIC) code is included in those specific categories. The Industrial General Permit requires the implementation of Best Conventional Treatment Economically Achievable (BAT) and Best Conventional Pollutant Control Technology (BCT) to reduce or prevent pollutants in stormwater discharges and authorized non-stormwater discharges. .

Compliance with requirements in the General Permit will ensure that stormwater discharges from industrial sites are not a significant source of pathogenic bacteria. No WLAs are needed for industrial stormwater discharges. However, the need for WLAs may be reevaluated in future TMDLs in the event there is new information implicating industrial stormwater as a significant source.

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4.3.3.3 Construction Stormwater
Construction activities that result in a land disturbance equal to or greater than one acre are required to have coverage under the Construction General Permit (Order 2009-0009- DWQ, as amended by Order 2010-0014-DWQ and Order 2012-006-DWQ). The objective of the Construction General Permit is to prevent or minimize the discharge of constructionrelated pollutants from work sites.

The primary potential sources of pathogens at construction sites are temporary sanitary facilities on work sites that are poorly designed or maintained and thus are a potential source of pathogenic bacteria. Operators of construction sites where there are no permanent sanitary facilities or where permanent facilities are too far from the construction site will provide sanitary facilities for construction personnel in one or more locations throughout the work site. A well-designed and maintained work site will include BMPs for portable sanitary facilities that include setbacks from waterbodies, storm drains, and gutters, location of toilets on surface areas that will absorb spills instead of transporting contamination to surface waters, and provisions to prevent vandalism and toppling of the enclosures due to exposure to high winds. Recommended maintenance activities include establishment of an appropriate cleaning and maintenance schedule, and inspection schedules to detect damage, leaks, and spills, and disposal for rinse water from cleaning activities into a sanitary sewer system.

Compliance with requirements in the Construction General Permit will ensure that stormwater discharges from construction sites are not a significant source of pathogenic bacteria. No WLAs are needed for construction stormwater discharges. However, the need for WLAs may be reevaluated in future TMDLs in the event there is new information implicating construction stormwater as a significant source.

4.3.3.4 Caltrans Stormwater
The California Department of Transportation (Caltrans) is responsible for the design, construction, management, and maintenance of the state highway system, including freeways, bridges, tunnels, and associated properties. Major state highways in the Russian River Watershed include Highways 101, 116, 128, and 12.

Caltrans is subject to the stormwater permitting requirements of Clean Water Act section 402(p). Caltrans is currently operating under a statewide stormwater permit (Order 2012-011-DWQ) that regulates all stormwater and non-stormwater discharges from Caltrans MS4s and maintenance facilities. Caltrans’ Storm Water Management Plan, which is updated annually, describes the procedures and practices used to reduce or eliminate the discharge of pollutants to storm drainage systems and receiving waters. Construction activities associated with Caltrans projects are covered by Order 2009-0009-DWQ, as amended.

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The State Water Board adopted Order 2014-0077-DWQ as an amendment to the Caltrans permit to add requirements related to completed TMDLs. Under the statewide permit and TMDL amendment, Caltrans is required to prioritize reaches across the state and then to implement best management practices and control measures to achieve 1,650 Compliance Units each year in the highest priority reaches. One Compliance Unit is equal to one acre of Caltrans right-of-way from which runoff is retained, treated, or otherwise controlled prior to discharge to the relevant reach. Caltrans is encouraged to establish cooperative implementation agreements with other parties that have responsibility to attain a TMDL.

Also under the statewide stormwater permit, Caltrans is required to prepare a TMDL Status Review Report to be submitted with each Annual Report. The TMDL Status Review Report includes (1) a summary of the effectiveness of the control measures installed for each reach that has been addressed, as a result of BMP effectiveness assessment, (2) a determination as to whether the control measures have been or will be sufficient to achieve WLAs and other performance standards by the final compliance deadlines, (3) where the control measures are determined not to be sufficient to achieve WLAs or other performance standards by the final compliance deadlines, a proposal for improved control measures to address the relevant pollutants, and (4) a summary of the estimated amount of pollutants that were prevented from entering into the receiving waters. The TMDL Progress Report is subject to public review and comment.

Homeless encampments within the Caltrans right-of-way are a source of both trash and pollutants in waterways. As described in a 2013 study for the Contra Costa County Flood Control and Water Conservation District, larger, well-established encampments usually have a designated “toilet area,” but it is likely that occupants also use the water to dispose of waste (DeVuono-Powell 2013). Where the disposal of urine and human fecal matter in water occurs, there is a high potential that this is a source of pathogenic indicator bacteria. In areas within Caltrans rights-of-way that do not contain bacteria-generating sources such as homeless encampments, restroom facilities, garbage binds, etc., the contribution of pathogen indicator bacteria to waterbodies is not believed to be a significant source of pathogens that present a human health risk (Caltrans 2012).

4.4 NONPOINT SOURCES
The term "nonpoint source" is defined as any source of water pollution that is not from a discernible, confined, and discrete conveyance. Per definitions in the Clean Water Act, agricultural discharges are also considered nonpoint sources even when conveyed through a pipe. Nonpoint source pollution comes from many diffuse sources and is caused by rainfall or snowmelt moving over and through the ground. As the runoff moves, it picks up and carries away natural and human-made pollutants, depositing them into streams and other waters.

This section primarily focuses on controllable nonpoint sources in developed areas and agricultural areas, since the runoff from these areas show the highest concentrations of pathogenic indicator bacteria.

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4.4.1 ONSITE WASTEWATER TREATMENT SYSTEMS
About one-fourth of all American households rely on onsite wastewater treatment systems (OWTS) to dispose of their wastewater, which translates to about 20 million individual systems nationwide (Wilhelm et al. 1994). Table 4.12 presents estimates of the houses and population that are connected to sanitary sewers in the Russian River Watershed. The estimates show that about 31% of the houses in the watershed are not connected to a sanitary sewer and are assumed to use OWTS for treatment of domestic waste. The estimates were made from the 2010 U.S. Census.

Table 4.12. Estimates of Houses, Population & Acres of Sewered and Non-Sewered Areas in the Russian River Watershed
Areas Houses Population Acres
Count Percent Count Percent Count Percent
Sewered 113,631 69% 288,225 72% 83,644 9%
Non-sewered 51,537 31% 111,147 28% 866,608 91%
Total within Russian
River Watershed 165,168 100% 399,372 100% 950,252 100%
Conventional OWTS operate simply: after solids are trapped in a septic tank, typically a 1,000 to 1,500-gallon concrete or fiberglass tank, wastewater is distributed to a subsurface drain field and allowed to percolate through the soil. Bacteria in the wastewater are effectively removed by filtering and straining water through the soil profile. Viruses are not effectively filtered in soil because of their small size. Instead viruses are removed through adsorption to soil particles and by inactivation in the soil.

Effective pathogen removal in OWTS is dependent on proper siting and installation of the OWTS components, proper maintenance, and operation of the system within design specifications. OWTS can fail when wastewater rises to the ground surface, is intercepted by high groundwater, or passes through the soil profile without adequate treatment.

The results of the land cover-based source analysis (see Section 4.2) indicate that humansource Bacteroides bacteria concentrations are higher in areas with OWTS as compared to urban sewered areas. The analysis indicated that OWTS are a contributing source of pathogenic indicator bacteria. In order to confirm this finding, Regional Water Board staff conducted a more focused study on the potential influence of OWTS on pathogenic indicator bacteria concentrations in receiving surface waters. The sampling methods, results, and an analysis of the data are presented in the “Onsite Wastewater Treatment System Impact Study Report” (NCRWQCB 2013a). The study compared water samples collected downstream of small watersheds that drain areas with densely situated OWTS and watersheds that drain areas with a relatively low density of OWTS. Results show that a higher parcel density in areas with only OWTS is directly associated with higher concentrations of both Bacteroides and E. coli bacteria, confirming that OWTS contribute to pathogenic indicator bacteria in surface waters. Figure 4.14 shows the distribution of these concentrations by parcel densities. High parcel densities range from 0.76 to 3.99 parcels per acre (0.25 to 1.3 acres/parcel). Low parcel densities ranged from 0.01 to 0.11 parcels per acre (9.1 to 100 acres/parcel).

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Figure 4.14. Comparison of the distribution of E. coli and Bacteroides bacteria concentrations by parcel densities

4.4.2 RECREATION AT PUBLIC BEACHES
There are many public swimming beaches along the mainstem Russian River. Several of the most popular beaches are shown in Table 4.13 and Figure 4.15. Swimming and other water contact recreation in the river can be a source of bacteria and other pathogens through direct human urination or defecation in the water or along the shore. Pathogens may also be washed off the body during immersion.

Regional Water Board staff
conducted a focused study on
the potential influence of
intensive recreation on
pathogenic indicator bacteria
concentrations at public
beaches (NCRWQCB 2013b).

Water samples were collected
for analysis of pathogen
indicator bacteria at Veterans
Memorial Beach and Monte
Rio Beach during the week of
the Independence Day
holiday in 2013.
1 10
100
1,000
10,000
100,000
E. coli Bacteria
High Parcel
Density
E. coli Bacteria
Low Parcel
Density
All Bacteroides
Bacteria
High Parcel
Density
All Bacteroides
Bacteria
Low Parcel
Density
E. coli Bacteria Concentration (MPN/100mL)
All Bacteroides Bacteria Concentration (16SrRNA genes/100mL) Septic Source Study Results
Comparison of Parcel Densities
Table 4.13. Popular Swimming Beaches along the Russian River Recreational Beach Name Location
Mill Creek Park Potter Valley
Mariposa Swimming Hole Redwood Valley
Vichy Springs Park Ukiah
Mill Creek Park Ukiah
Cloverdale River Park Cloverdale
Alexander Valley Campground Healdsburg
Veteran Memorial Beach Healdsburg
Riverfront Park Windsor
Mirabel Park Campground Forestville
Steelhead Beach Forestville
River Access Beach Forestville
Sunset Beach Forestville
Johnson’s Beach Guerneville
Monte Rio Beach Monte Rio
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Figure 4.15: Popular Swimming Beaches along the Russian River September 222026 Item 7
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Water samples were collected during the afternoon when human recreational use was the highest. Sonoma County Park staff counted recreators on the beach and in the water at Veterans Memorial Beach each day at 14:00 hours (Figure 4.16). Recreator counts were not available for Monte Rio Beach. Figures 4.17 through 4.19 show photographs of both beaches on Independence Day. Figures 4.20 and 4.21 show E. coli concentrations measured at those beaches during the study.

The study found that the percentage of human-host Bacteroides showed a relatively strong positive association with swimming recreation, with the higher percentages of human-host Bacteroides observed on days with a larger number of people swimming. A moderately positive association was found for E. coli concentrations with swimming recreation. The results indicate that intensive human contact recreation at public beaches on the most popular hot summer days contributes to pathogenic indicator bacteria concentrations in surface waters. The less intensive recreation that is more common during summer weekdays and throughout the non-summer season results in lower pathogenic indicator bacteria concentrations.

Figure 4.16. Counts of People Recreating at Veteran Memorial Beach in Healdsburg. 0 500
1,000
1,500
2,000
7/2/2013 7/3/2013 7/4/2013 7/5/2013 7/6/2013 7/7/2013 7/8/2013 7/9/2013 Number of People
People Recreation Counts
Veteran's Memorial Beach at Healdsburg
People Swimming People on the Shore Total Recreators
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Figure 4.17. Veteran Memorial Beach on Thursday, July 4, 2013 at 12:30 Figure 4.18. East Monte Rio Beach on Thursday, July 4, 2013 at 14:00 September 222026 Item 7
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Figure 4.19. West Monte Rio Beach on Thursday, July 4, 2013 at 14:00 Figure 4.20. E. coli Bacteria Concentrations Measured at Veteran Memorial Beach in Healdsburg
0 50
100
150
200
250
300
350
400
450
7/2/2013 7/3/2013 7/4/2013 7/5/2013 7/6/2013 7/7/2013 7/8/2013 7/9/2013 E. coli Bacteria Concentration
(MPN/10mL)
Veterans Memorial Beach in Healdsburg
E. coli Bacteria Concentrations
Median and Range of Replicate Samples
TMDL Geomean Target
TMDL STV Target
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Figure 4.21. E. coli Bacteria Concentrations Measured at Monte Rio Beach in Monte Rio

4.4.3 HOMELESS ENCAMPMENTS
Homeless encampments are potential, but unconfirmed, sources of bacteria. Many riparian areas within the Russian River Watershed serve as temporary shelter for homeless people and these areas most often do not have sanitary disposal facilities. The discharge of untreated human waste directly to surface waters within these riparian corridors from homeless encampments likely explains the presence of human-source indicator bacteria found in undeveloped areas.

The Russian River Watershed covers large areas of Mendocino and Sonoma counties.

Applied Survey Research (2005) estimates that 5,335 people were homeless in Mendocino County and 78% of those were unsheltered. This represents 6% of the overall population of 90,816 people in Mendocino County. Applied Survey Research also estimates that 9,749 people were homeless in Sonoma County and 77% of those were unsheltered. This represents 2% of the overall population of 484,102 people in Sonoma County.

Information about farmworkers, both permanent and itinerant, in the Russian River Watershed is similarly difficult to obtain. Based on estimates for Napa County (BAE 2013), which has a similar agricultural profile to Sonoma County, it can be similarly estimated that agriculture employers in Sonoma County hire as many as 7,000 workers during peak farm employment periods, which correspond to the May-June growing season and the AugustOctober harvest period. While many of these seasonal workers obtain permanent or semipermanent lodging in private accommodations or in County-subsidized housing, many other farmworkers seek temporary lodging in encampments where restroom facilities are 0 50
100
150
200
250
300
350
400
450
500
7/2/2013 7/3/2013 7/4/2013 7/5/2013 7/6/2013 7/7/2013 7/8/2013 7/9/2013 E. coli Bacteria Concentration
(MPN/10mL)
Monte Rio Beach in Monte Rio
E. coli Bacteria Concentrations
Median and Range of Replicate Samples
TMDL Geomean Target
TMDL STV Target
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not available. Where itinerant farmworker encampments are located near water courses, there is an increased opportunity for human waste contamination.

4.4.4 RECYCLED WATER DISCHARGES FROM LANDSCAPE IRRIGATION Although advanced wastewater treatment systems in the Russian River Watershed are operated to produce recycled water that is essentially pathogen-free and suitable for water recycling, this same recycled water, when stored in open-air holding ponds, may become contaminated as a result of regrowth of bacteria or through contribution of fecal matter from wildlife, particularly birds that frequent the storage ponds.

Most major municipalities in the watershed are either actively participating in water recycling programs or are contemplating becoming involved. The largest water recycling program in the region, the Santa Rosa Subregional Water Reclamation System, accepts and treats municipal wastewater from the communities of Santa Rosa, Cotati, Rohnert Park, and Sebastopol for use as recycled water for urban and agricultural irrigation on over 6,400 acres of land. Other communities, such as the Town of Windsor, the Russian River Community Services District in Guerneville, and the Airport-Larkfield-Wikiup communities also use recycled water for local irrigation projects. Currently, there is no recycled water used for landscape irrigation in Mendocino County. Recycled water producers are regulated under General Waste Discharge Requirements (Order 2014-0090-DWQ) or individual waste discharge requirements.

The Santa Rosa Non-Storm Water Discharge Best Management Practices (BMP) Plan was required by NPDES MS4 Permit Order No. R1-2009-0050 and sets forth approved protective measures that are required of all applicable discharges in order to minimize or prevent the effects of non-stormwater discharges (City of Santa Rosa 2013). The BMP Plan describes runoff control measures to be implemented for both landscape irrigation in urban settings and agricultural irrigation in rural settings. By controlling runoff from recycled water use areas, these BMPs will also help reduce human-source bacteria entering receiving waters. The non-stormwater BMP Plans for Sonoma County Water Agency and Sonoma County are in development or are being reviewed by Regional Water Board staff.

Although local recycled water programs are generally well-managed, unintentional spills of recycled water occur periodically. Large volume spills are typically the result of broken recycled water lines in rural properties, but often occur as a result of operator error or inattention. Large volume spills of recycled water have the potential to adversely impact water quality, but are a low risk to contribute pathogenic indicator bacteria because the recycled water has been disinfected to meet tertiary treatment standards prior to entering the recycled water distribution system. Small volume spills occur more frequently, often as a result of unintentional overspray, mechanical breaks, vandalism, or other unforeseen conditions. The contribution of pathogen indicator bacteria from small volume spills and other incidental runoff events is de minimus and not expected to be a source of pathogens in amounts that contribute to the pathogen impairment in the watershed.

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4.4.5 PET WASTE
Domesticated pets can be a major source of pathogenic indicator bacteria, especially dogs and cats. Domesticated dogs can be a significant source of fecal material based on their population density, high defecation rate, and pathogen infection rates (Schueler 2000). A single gram of dog feces contains 23 million fecal coliform bacteria (van der Wel 1995).

Dogs have been found to be significant hosts for Giardia, Salmonella, and Pseudomonas bacteria (Pitt 1998). Lim and Oliveri (1982) concluded that dog feces were the single greatest source contributing fecal coliform and fecal streptococcus bacteria in urbanized Baltimore catchments. Trial et al. (1993) reported that cats and dogs were the primary source of fecal coliform bacteria in urban catchments in the Seattle area.

Improper pet waste disposal has the potential to deliver pathogenic indicator bacteria to surface waters through stormwater discharges. Since storm drains do not always connect to treatment facilities, untreated animal feces often end up in surface waters.

Most pet waste management programs focus on increasing public awareness. Many communities implement pet waste management programs by posting signs in parks or other pet-frequented areas, by mass mailings, and by broadcasting public service announcements. Sign posting is one of the most common outreach strategies. Signs can designate areas where dog walking is prohibited, where waste must be recovered, or where dogs can roam freely. A "pooper-scooper" ordinance is an effective solution. Many communities have pooper-scooper laws that mandate pet waste cleanup. Because pet waste management is focused toward individual pet owners, the program is dependent on the participation and cooperation of all pet owners, and pet waste management programs must be enforced. With an increase in public knowledge of stormwater regulations, proper disposal of pet wastes can lead to a significant reduction of bacteria discharged in stormwater.

All MS4 permits issued in the Russian River Watershed require the implementation of a Public Information and Participation Program (PIPP). The PIPP involves using effective mechanisms and programs, guided by a detailed outreach strategy, to engage the public's interest in preventing stormwater pollution.

4.4.6 LIVESTOCK WASTE
A large number of bacterial pathogens found in manure from livestock have the potential to cause illness in humans. These organisms include, but are not limited to, Salmonella, Campylobacter, E. coli, Leptospira, and Clostridium bacteria (U.S. EPA 2009). Several viruses found in livestock waste have the potential to cross from animals to humans, and thus have the potential to cause disease in humans (Mattison et al. 2007; McAllister and Topp 2012).

Pathogens can be discharged directly to watercourses when livestock have access to streams. They can also be carried to surface waters in stormwater runoff or in runoff resulting from over-application of liquefied manure to pasture land.

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The estimated number of different types of animals in Sonoma and Mendocino counties is shown in Table 4.11. The Russian River Watershed covers large areas of both counties.

Data presented in this table were obtained from several sources, as described below.

Table 4.14. Inventory of Livestock Animals in Mendocino and Sonoma Counties Animal Type
Mendocino County Sonoma County
Number
of Animals Citation Number of Animals Citation
Laying Hens and Pullets 8,973 USDA (2007) 5,764,700 Linegar (2013) Cattle and calves 18,800 Morse (2012) 68,762 Linegar (2013) Horses 2,509 USDA (2007) 17,794 Benito (2005)
Sheep and lambs 9,200 Morse (2012) 22,543 Linegar (2013) Goats 1,454 USDA (2007) 2,146 Linegar (2013)
Hogs 1,450 Morse (2012) 1,029 Linegar (2013)

4.4.7 DAIRIES, MANURE HOLDING PONDS, & LANDSCAPE APPLICATIONS OF MANURE
Any release of manure to surface waters from holding ponds and landscape application from confined animal facilities has a significant potential to impact bacterial water quality due to the large amount of stored and land-applied manure and the high concentration of fecal bacteria in raw manure (up to 100 million fecal coliform per gram). Most large-scale dairies in the Russian River Watershed store manure in massive lagoons that can hold millions of gallons of liquid manure. Waste lagoons can break, spill, leak, or fail. Lagoon linings can crack and allow liquefied manure to seep into surface waters or shallow groundwater. Pipes and hoses connecting to lagoons or spray fields may fail or leak (Marks 2001). In addition, many dairies spread or spray liquefied manure on pasture land. When liquid waste is over-applied or inappropriately applied to farm fields through irrigation, runoff of manure to surface waters can result.

The Regional Water Board implements the Water
Quality Compliance Program for Cow Dairies and
Concentrated Animal Feeding Operations (CAFOs).

Initiated in 2012, this program includes a NPDES
permit for CAFOs that discharge directly to surface
waters, a General GWDR permit for dairies that do
not meet minimum standards for the protection of
surface water and groundwater, and a Conditional
Waiver for dairies that meet minimum standards in
Title 27 of the California Code of Regulations for
confined animal facilities. These regulatory tools
require management of process water, manure, and
other organic materials at dairy operations
including holding ponds and the application of such
materials to cropland.

In accordance with Title 27, the dairy permits
require retention ponds and manured areas at
Table 4.15. Dairies in the Russian River
Watershed
Dairy Name Location
Aggio Dairy Inc. Santa Rosa
Amos Brothers Dairy Santa Rosa
Beretta Dairy Santa Rosa
Bucher Farms Healdsburg
Buttke Dairy Sebastopol
Carinalli Dairy Sebastopol
Cunningham Dairy Santa Rosa
Dotti Brothers LLC Santa Rosa
Jack Dei Dairy Sebastopol
Joe Matos Cheese Factory Santa Rosa
Joe Pinheiro Dairy Santa Rosa
Jones Dairy Santa Rosa
Mello Dairy Santa Rosa
Mello Farms Santa Rosa
Morrison Brothers Dairy Santa Rosa
Rancho Laguna Dairy Santa Rosa
Steve Riebli Dairy Sebastopol
Terra Linda Dairy Santa Rosa
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confined animal facilities in operation on or before November 27, 1984, to be protected from inundation or washout by overflow from any stream channel during 20-year peak stream flows. Retention ponds are required to be lined with, or underlain by, soils which contain at least 10 percent clay and not more than 10 percent gravel or artificial materials of equivalent impermeability. While these permit requirements will protect against a significant amount of manure discharges from holding ponds, discharges are likely when streams exceed the 20-year peak stream flow rate. The dairy permits specify that waste storage facilities constructed after January 19, 2012 should be located outside of floodplains, unless site restrictions require location within a floodplain, in which case, the waste storage facility shall be protected from inundation or damage from a 100-year flood event. Manure ponds constructed after January 19, 2012, must include a pond liner that does not exceed a unit seepage rate of 1X 10-6 centimeters per second.

The dairy permits also authorize the application of manure and process waters to land only if such application is at rates that are reasonable for the crop, soil, climate, special local situations management systems, and type of manure.

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SEASONAL VARIATION AND CRITICAL CONDITIONS
This chapter describes the seasonal variation of pathogen indicator bacteria throughout the year and describes the critical or extreme condition for the purposes of setting allocations to meet water quality standards.

5.1 SEASONAL VARIATION

5.1.1 Wet Periods vs. Dry Periods
Regional Water Board staff collected water samples for measurement of pathogenic indicator bacteria at numerous locations in the Russian River Watershed from 2011 to 2013 (NCRWQCB 2012; NCRWQCB 2013a; NCRWQCB 2013b). Water samples were collected in both dry and wet periods for analysis of E. coli, human-host Bacteroides, and bovine-host Bacteroides bacteria concentrations. Dry period samples were collected after 72 hours of no rainfall. Wet period samples were collected during storm events of at least

0.1 inches of rainfall that were preceded by 72 hours of no rainfall.

Figures 5.1 through 5.3 compare the distribution of pathogenic indicator bacteria concentrations sampled during wet and dry weather periods. All three indicator bacteria show significantly higher concentrations measured during wet weather compared to dry weather samples. This finding indicates that higher pathogenic indicator bacteria levels are associated with higher flows that are associated with storm events.

5.1.2 Effects of Low Mainstem Flows
Regional Water Board staff also evaluated the relationship between E. coli bacteria concentrations and dry season stream flows in the mainstem Russian River (Butkus 2014b). The assessment found that there is not a statistically significant correlation between summer daily mean stream flow rates and E. coli bacteria concentrations at Camp Rose Beach, Veteran Memorial Beach, Steelhead Beach, Johnson’s Beach, or Monte Rio Beach, as shown in Figures 5.4 through 5.8. In other words, E. coli levels do not vary significantly due to flows in the mainstem during dry summer periods.

This conclusion is supported by an additional analysis undertaken to evaluate if E. coli concentrations are different in years with lower flows under a Temporary Urgency Change Petition (TUCP)4 than in years without a petition (Butkus 2014b). There is no statistically

4 The Sonoma County Water Agency (SCWA) controls and coordinates water supply releases from Coyote Valley and Warm Springs dams in accordance with minimum instream flow requirements specified by the State Water Board. These minimum instream flow requirements vary based on water supply conditions.

Since 2002, SCWA has requested temporary changes to the Decision 1610 minimum instream flow requirements from the State Water Board. SCWA filed Temporary Urgency Change Petitions (TUCP) in 2002, 2004, 2007, and 2009 to request reductions in Russian River instream flows to address low storage levels in Lake Mendocino. TUCPs filed from 2010 through 2014 were required by the Russian River Biological Opinion September 222026 Item 7
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5.2 CRITICAL CONDITIONS
The critical condition can be thought of as the "worst case" scenario of environmental conditions in the waterbody, a condition where the pollutant loading is greatest, but the waterbody continues to meet water quality standards. Critical conditions are the combination of environmental factors (e.g., stream flow, temperature, etc.) that result in the attainment of standards with an acceptably low frequency of occurrence (U.S. EPA 1999).

Pathogenic indicator bacteria concentrations do not have a specific period of time that could be considered a critical condition. During wet weather periods, pathogenic indicator bacteria concentrations are much higher than during dry periods, and often exceed the numeric targets. Therefore, wet weather conditions can be considered a critical condition for bacteria levels. However, during the summer, low-flow period there is much more exposure to pathogenic indicator bacteria through recreation. Therefore, summer recreation periods can also be considered a critical period. Since both wet and dry periods are critical conditions, the same loading capacities apply throughout the year and should not vary according to season.

under the Endangered Species Act to reduce instream flow conditions to improve habitat for the threatened and endangered salmonid species.

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Figure 5.2. Distribution of Human-host Bacteroides Bacteria Concentrations collected during Dry and Wet Weather Periods
1 10
100
1,000
10,000
100,000
Dry Period Wet Period
E. coli Bacteria Concentration
(MPN/100mL)
Russian River Watershed
E. coli Bacteria Concentrations
REC-1 Geomean Criterion
10 100
1,000
10,000
100,000
1,000,000
Dry Period Wet Period
Bacteroides Bacteria Concentration
(16S rRNA genes/100mL)
Russian River Watershed
Human-source Bacteroides
Bacteria Concentrations
Analytical Reporting Limit
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Figure 5.4. Correlation between E coli Bacteria Concentration and Stream Flow Measurements at Camp Rose Beach during the dry season
10 100
1,000
10,000
100,000
1,000,000
Dry Period Wet Period
Bacteroides Bacteria Concentration
(16S rRNA genes/100mL)
Russian River Watershed
Bovine-source Bacteroides
Bacteria Concentrations
Analytical Reporting Limit
1 10
100
1000
10 100 1000
E. coli Bacteria Concentration
(MPN/100mL)
Stream Flow at USGS Gage 11464000
(cfs)
Russian River
at Camp Rose Beach
Measurements
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1 10
100
1000
10 100 1000
E. coli Bacteria Concentration
(MPN/100mL)
Stream Flow at USGS Gage 11464000
(cfs)
Russian River
at Veteran's Memorial Beach
Measurements
1 10
100
1000
10 100 1000
E. coli Bacteria Concentration
(MPN/100mL)
Stream Flow at USGS Gage 11467000
(cfs)
Russian River
at Steelhead Beach
Measurements
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Figure 5.8. Correlation between E coli Bacteria Concentration and Stream Flow Measurements at Monte Rio Beach during the dry season
1 10
100
1000
10 100 1000
E. coli Bacteria Concentration
(MPN/100mL)
Stream Flow at USGS Gage 11467000
(cfs)
Russian River
at Johnson's Beach
Measurements
1 10
100
1000
10 100 1000
E. coli Bacteria Concentration
(MPN/100mL)
Stream Flow at USGS Gage 11467000
(cfs)
Russian River
at Monte Rio Beach
Measurements
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CHAPTER 6

LINKAGE ANALYSIS
This chapter describes the link between the Bacteroides, E. coli, and fecal coliform bacteria numeric targets, loading capacities, and load allocations used in this TMDL project and attainment of the Bacteria Water Quality Objective. If Bacteroides, E. coli, and fecal coliform bacteria measures are met, applicable standards will be attained. This section includes information previously discussed in Section 2.1 on water quality standards.

6.1 BACTEROIDES BACTERIA LINKAGE
Bacteroides bacteria numeric targets, loading capacities, and load allocations are used in this TMDL project as measures to show attainment of the natural background portion of the Bacteria Water Quality Objective.

For this TMDL project, natural background is interpreted to mean the quality of water that in the absence of significant human disturbance or alteration is in a minimally disturbed condition. Waters are determined to not be in a minimally disturbed condition if Bacteroides bacteria are significant enough to be present in a water sample at levels above the laboratory reporting limit. The laboratory reporting limit is the level at which the laboratory is 95% confident that the Bacteroides bacteria are present in the sample and are accurately counted. If bacteria are present and can be quantified with certainty, it is highly likely that fecal waste material is present and the bacteriological quality of the water has been degraded beyond natural background or minimally disturbed levels. This is a conservative assumption. It is supported by data from the one minimally disturbed site measured in the Russian River Watershed. It is also supported by U.S. EPA guidance which states that using conservative assumptions in derivation of numeric targets is an appropriate approach for providing a margin of safety, which is a required element of a TMDL.

The human host Bacteroides bacteria numeric target is protective of recreational uses. This target is based on epidemiological studies that link Bacteroides concentrations to illness rates. Wade et al. (2006) found a relationship between Bacteroides bacteria concentrations and gastrointestinal illness. Wade et al. (2010) estimated the probability of gastrointestinal illness due to increasing concentrations of Bacteroides bacteria. Based on this probability, a Bacteroides bacteria geometric mean of 60 genes/100mL corresponded to about 30 gastrointestinal illnesses per 1,000 swimmers. Ashbolt et al. (2010) compared human-specific Bacteroides bacteria concentration to Norovirus concentrations. From these estimates, a Bacteroides bacteria concentration of 860 genes/100mL corresponded to about 30 gastrointestinal illnesses per 1,000 swimmers. Soller et al. (2010a) identified Norovirus as the pathogen most responsible for a majority of gastrointestinal illness. Since the human Bacteroides numeric target is set at the reporting limit, which is currently 60 genes/100mL, it is equal to or less than the concentrations associated with approximately 30 illnesses per 1,000 swimmers and is protective of recreational uses.

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6.2 E. COLI BACTERIA LINKAGE
E. coli bacteria numeric targets, loading capacities, and load allocations are used in this TMDL project as the measures to show attainment of the recreation portion of the Bacteria Water Quality Objective and support of the Water Contact Recreation Beneficial Use.

E. coli is a species of the fecal coliform group, and it is specific to fecal material from humans and other warm-blooded animals. The U.S. EPA recommends E. coli bacteria criteria as the best indicator of health risk from water contact in freshwater. The U.S. EPA published criteria under Section 104(v) of the federal Clean Water Act for the purpose of protecting human health in waters designated by states for use for swimming, bathing, surfing, or similar water contact activities (U.S. EPA 2012). Development of the criteria includes epidemiological studies, quantitative microbial risk assessment, site characterization studies, methods development and validation studies, modeling, assessment of levels of public health protection, and literature reviews. The U.S. EPA also considered relevant studies conducted by independent researchers.

The epidemiological investigations were conducted at U.S. beaches between 2003 and 2009. As a group, these investigations are referred to as the National Epidemiological and Environmental Assessment of Recreational Water (NEEAR) study. The NEEAR study enrolled 54,250 participants, encompassed nine locations, and collected and analyzed numerous samples from a combination of beaches (U.S. EPA 2010). The NEEAR study defined a case of illness as “any of the following within ten to 12 days after swimming: (a) diarrhea (three or more loose stools in a 24-hour period), (b) vomiting, (c) nausea and stomachache, or (d) nausea or stomachache and impact on daily activity” (U.S. EPA 2010).

Of all the adverse health effects considered, the NEEAR epidemiological studies found the strongest association between E. coli bacteria and gastrointestinal illnesses. Other health issues that could have been caused by pathogens from fecal matter include upper respiratory illness, rashes, eye ailments, earaches, and infected cuts. The U.S. EPA (2012) concluded that criteria based on protecting the public from gastrointestinal illness using pathogenic indicator bacteria concentration will prevent most types of recreational waterborne illnesses.

An increase in E. coli bacteria concentrations correlated well with an increase in illness rate, verifying the linkage between the E. coli bacteria concentration-based numeric targets, loading capacities, and load allocations in this TMDL project and risk of illness during water contact recreation and non-contact water recreation (i.e., REC-1 and REC-2 beneficial uses).

6.3 FECAL COLIFORM BACTERIA LINKAGE
A fecal coliform bacteria numeric target, loading capacity, waste load allocation, and load allocation are used in this TMDL project to show attainment of the shellfish portion of the Bacteria Water Quality Objective. In order to protect and maintain the potential use of an individual to harvest and consume filter-feeding freshwater shellfish from the Russian September 222026 Item 7
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River Watershed, the fecal coliform numeric target, loading capacity, and load allocations are based on and equal to the lower of the two values contained in the shellfish portion of the Bacteria Water Quality Objective.

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CHAPTER 7

TMDL CALCULATIONS AND ALLOCATIONS
A TMDL is a calculation of the maximum amount of a pollutant that a waterbody can receive and still meet water quality standards. The TMDL equals the loading capacity of the waterbody for the pollutant plus a margin of safety to account for any uncertainties. For this TMDL project, an implicit margin of safety is included in the determination of the loading capacities so the loading capacities are equivalent to the TMDL values. The loads are allocated among the various sources of that pollutant. Anthropogenic pollutant sources are characterized as either point sources that receive a wasteload allocation or nonpoint sources that receive a load allocation. Point sources include all sources subject to regulation under the NPDES program (e.g., wastewater treatment facilities and some stormwater discharges). Nonpoint sources include a variety of diffuse sources transported by water moving over and through the ground.

7.1 TMDLs, LOADING CAPACITIES & MARGIN OF SAFETY
The TMDLs for the Russian River Watershed are shown in Table 7.1 and are expressed as concentrations of human host and domestic animal Bacteroides bacteria, E. coli, and fecal coliform bacteria in surface waters and discharges. In accordance with 40 CFR §130.2(i), the TMDLs are be expressed as concentrations instead of loads. This is appropriate since public health risks associated with recreation are based on concentrations of pathogen indicator bacteria in water and not the total load of bacteria passing through the Russian River in a day.

The TMDLs are set to equal the loading capacities for each parameter and attain standards.

The TMDLs are equivalent to the numeric targets and the wasteload and load allocations.

Table 7.1 TMDLs, Loading Capacities, Wasteload Allocations, and Load Allocations Parameter
Portion of the Bacteria
Objective the Target
will Attain
TMDL, Loading Capacity,
Wasteload Allocation & Load Allocation
Human Host
Bacteroides Natural Background
No more than 10% of the daily median sample values shall exceed the laboratory quantitative reporting limit within a calendar year or permitted discharge period. The current human host reporting limit is 60 genes/100mL.

Domestic
Animal
Bacteroides
Natural Background
No more than 10% of the daily median sample values shall exceed the laboratory quantitative reporting limit within a calendar year or permitted discharge period. The current bovine host reporting limit is 30 genes/100mL.

E. coli Geometric
Mean Recreation No more than 50% of the samples collected* within a calendar year or permitted discharge period shall exceed 100 cfu/100mL**.

E. coli Statistical
Threshold Value Recreation No more than 10% of the samples collected* within a calendar year or permitted discharge period shall exceed 320 cfu/100mL**.

Fecal Coliform Shellfish Consumption None of the samples shall exceed 43 MPN/100mL. * No fewer than 5 samples collected within a calendar year or permitted discharge period should be used to calculate the Geometric Mean and Statistical Threshold Value ** Colony forming units (cfu) are equivalent to the most probable number (MPN) values.

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7.1.1 BACTEROIDES BACTERIA TMDLS/LOADING CAPACITIES
The human-host and domestic animal Bacteroides bacteria TMDLs/loading capacities are the same as the Bacteroides bacteria numeric targets. They are set to attain the natural background portion of the Bacteria Water Quality Objective.

The Bacteroides bacteria TMDLs are set at the minimum laboratory quantitative reporting limits of the standard calibration curves derived for qPCR human-host and bovine-host analyses levels. During the development of the TMDL the quantitative reporting limits for human-host and bovine-host Bacteroides bacteria were 60 and 30 genes per 100mL, respectively. The reporting limits will likely change in the future due to technological improvements in laboratory methods. If so, the revised lower quantitative reporting limits will become the TMDL/loading capacity values.

Current recommended genetic markers and protocols for Bacteroides bacteria analysis are described by Griffith et al. (2013). Additional markers may also be appropriate in the future as technology advances to improve assay sensitivity and performance5. The intent behind the allowable 10 percent frequency of exceeding the criteria is to be consistent with the Water Quality Control Policy for California’s Clean Water Act Section 303(d) List (SWRCB 2004), which is also known as the Listing Policy, when comparing data results to the reporting limit. The Listing Policy describes the process for making non-attainment decisions for conventional pollutants (e.g., pathogen indicator bacteria) where more than 10 percent of the samples exceed applicable water quality standards.

7.1.2 E. COLI BACTERIA TMDLs/LOADING CAPACITIES
The E. coli geometric mean and statistical threshold value (STV) TMDLs/loading capacities are the same as the E. coli bacteria numeric targets. They are set to attain the recreation protection portion of the Bacteria Water Quality Objective.

A minimum of five samples collected within a year or permitted discharge period should be used to calculate the geometric mean and STV. An averaging period longer than 30 days was selected for the loading capacity to provide a larger and more representative sample of the true distribution of E. coli bacteria concentrations. The geometric mean and STV should be calculated in a static, not rolling, fashion.

5 For example, measurement of Bacteroides bacteriophages may provide additional information on animal hosts. Bacteroides bacteria are rapidly inactivated by environmental oxygen levels, but Bacteroides bacteriophages are resistant to degradation. One group of phages that specifically uses B. fragilis strain HSP40 as host is found only in human feces and not in feces of other animals.

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7.1.3 FECAL COLIFORM BACTERIA TMDL/LOADING CAPACITY
The fecal coliform bacteria TMDL/loading capacity is the same as the fecal coliform bacteria numeric target. It is set to attain the shellfish consumption portion of the Bacteria Water Quality Objective.

7.1.4 MARGINS OF SAFETY
The Clean Water Act and regulations require that a TMDL include a margin of safety (MOS) to account for any lack of knowledge concerning the relationship between the load and wasteload allocations and water quality (CWA §303(d)(1)(C), 40 C.F.R. §130.7(c)(1)). U.S.

EPA (1991) guidance explains that the MOS may be implicit (i.e., incorporated into the TMDL through conservative assumptions in the analysis) or explicit (i.e., expressed in the TMDL as loadings set aside for the MOS).

Implicit margins of safety are used for Bacteroides and E. coli bacteria TMDLs. For humanhost and domestic animal-host Bacteroides, the conservative assumption used to set the numeric targets provides an MOS in favor of water quality protection. The conservative assumption is that fecal waste material is present and the bacteriological quality of water has been degraded beyond natural background if Bacteroides bacteria are present and can be quantified above laboratory reporting limits with certainty. For the E. coli bacteria TMDLs, the implicit margins of safety are due to the selection of the U.S. EPA criteria (2012) associated with 32 illnesses per 1,000 recreators, instead of 36 illnesses per 1,000 recreators. By selecting the values linked to fewer illnesses, an additional MOS is provided for those partaking in water contact recreation in the watershed.

7.2 WASTELOAD ALLOCATIONS
Regulations require that a TMDL include wasteload allocations (WLAs), which identify the portion of the loading capacity allocated to individual existing and future point sources (40 C.F.R. §130.2(h); 40 C.F.R. §130.2(i)).

The concentration-based WLAs for Bacteroides, E. coli, and fecal coliform bacteria are shown in Table 7.1 and apply to all existing and new point source discharges that are likely to include pathogens or pathogen indicator bacteria in the Russian River Watershed.

Examples of point sources include but are not limited to discharges from wastewater treatment facilities, municipal separate storm sewer systems, and confined animal feeding operations. Table 7.2 lists the existing point sources of pathogens in the watershed. The Bacteroides, E. coli, and fecal coliform bacteria WLAs shall be incorporated into permits for discharges of pathogen or pathogen indicator bacteria point sources at the time of permit adoption or permit renewal. The compliance point for the WLAs shall be at the point of effluent discharge from the point source to the receiving water, or at a location where sample results are representative of the targeted waste stream.

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Table 7.2 NPDES Permittees with WLAs in the Russian River Watershed Facility Name Facility Type NPDES
Permit No.

Applicable WLAs*
E. coli Bacteroides Fecal
Coliform
City of Cotati Phase II MS4 Stormwater CAS0000004 Y Y Y City of Healdsburg Phase II MS4 Stormwater CAS0000004 Y Y Y City of Rohnert Park Phase II MS4 Stormwater CAS0000004 Y Y Y City of Ukiah Phase II MS4 Stormwater CAS0000004 Y Y Y
Sonoma State University Phase II MS4 Stormwater CAS0000004 Y Y Y Town of Windsor Phase II MS4 Stormwater CAS0000004 Y Y Y Cloverdale City WWTP Municipal Wastewater CA0022977 Y N Y Forestville Water District Municipal Wastewater CA0023043 Y N Y Healdsburg City WWTP Municipal Wastewater CA0025135 Y N Y Occidental CSD Municipal Wastewater CA0023051 Y N Y
Santa Rosa Subregional Facility Municipal Wastewater CA0022764 Y N Y SCWA Graton CSD Municipal Wastewater CA0023639 Y N Y
SCWA Russian River CSD Municipal Wastewater CA0024058 Y N Y Ukiah City WWTP Municipal Wastewater CA0022888 Y N Y
Windsor Town WWTP Municipal Wastewater CA0023345 Y N Y
* Bacteroides WLAs do not apply to several facilities because the facilities disinfect their wastewater.

The Bacteroides bacteria WLAs do not apply to disinfected point sources in order to avoid false positive results. Disinfected waters include, but are not limited to, wastewater treated with chlorine, ozone, or UV light. While disinfection processes kill bacteria cells and eliminate the risk of illness to humans, pieces of the nucleic acids that make up the bacterial DNA may persist in the water post-death in a non-viable state. These DNA pieces may be counted in molecular amplification methods like qPCR which rely on the detection of DNA or RNA gene sequences to quantify bacteria.

Several NPDES permit holders in the Russian River Watershed are not a source of pathogens or pathogenic indicator bacteria. These include, but are not limited to, discharges from waterway modification permits related to aquatic pesticide application, discharges from log deck sprinkler water runoff, and discharges of highly treated groundwater that was previously contaminated with petroleum hydrocarbons and volatile organic compounds. Consequently, WLAs have not been assigned to these facility types in this TMDL.

7.3 LOAD ALLOCATIONS
Regulations require that a TMDL include load allocations (LAs), which identify the portion of the loading capacity allocated to existing and future nonpoint sources. LAs may range from reasonably accurate estimates to gross allotments (40 C.F.R. §130.2(g)).

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the Russian River Watershed. Examples of nonpoint sources include but are not limited to domestic wastewater discharges < 1,500 gpd, discharges from homeless encampments, pet waste, and livestock waste. The Bacteroides, E. coli, and fecal coliform bacteria LAs shall be incorporated into nonpoint source permits at the discretion of the Regional Water Board at the time of adoption of a new or renewed nonpoint source permit. Additional, non-permit implementation actions to attain the LAs are described in Chapter 8. These include efforts to identify, cleanup, and prevent nonpoint source discharges through the use of public outreach and education, best management practices, assessment, and adaptive management.

7.4 ESTIMATED REDUCTIONS NEEDED
Regional Water Board staff conducted an analysis of the reductions likely needed to achieve the TMDLs for Bacteroides and E. coli bacteria concentrations at numerous locations in the watershed (Butkus 2013c). The estimated percent reductions needed are provided here to highlight priorities for implementation actions; they are not the load allocations.

Human-host and bovine-host Bacteroides bacteria measurements collected between 2011 and 2013 were used to estimate the percent reduction needed to meet the TMDL values, as shown in Table 7.3. Most locations measured in the tributaries do not meet the LAs and will require controls to reduce bacteria loads. Percent reductions of human-host Bacteroides bacteria concentrations needed to meet the TMDLs range from 83% to 99%.

Percent reductions of bovine-host Bacteroides bacteria concentrations needed to meet the LAs range from 16% to 99%.

E. coli bacteria measurements collected since 2001 were used to estimate the percent reduction needed to meet both TMDL values, as shown in Table 7.4. In all cases, a larger percent reduction is needed to meet the STV as opposed to the geometric mean. All locations in the mainstem Russian River met the TMDLs for E. coli bacteria concentrations and require no reductions. However, most of the tributaries do not meet the LAs for E. coli bacteria and will require controls to reduce bacteria loads. Percent reductions of E. coli bacteria concentrations needed to meet the TMDLs in tributaries range from 49% to 99%.

Percent reductions needed to attain the TMDLs are also presented by land cover type in Table 7.5. Additional information is available in a memorandum to the file by Butkus (2013c).

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Table 7.3 Percent Reductions Needed to Meet Bacteroides Bacteria TMDLs Location
Human Host Bacteroides Bovine Host Bacteroides
Median
Bacteroides
in genes
per 100mL
Reduction
Needed to
Attain 60
genes per
100mL
Median
Bacteroides
in genes
per 100mL
Reduction
Needed to
Attain 30
genes per
100mL
East Fork Russian River at East Road, Potter Valley 5,949 99.0% No Data No Data Russian River at East School Way, Redwood Valley 979 93.9% No Data No Data Russian River at Lake Mendocino Drive, Ukiah 3,275 98.2% No Data No Data Russian River at Vichy Springs Road, Ukiah 11,803 99.5% No Data No Data Russian River at Talmadge Road, Ukiah 9,293 99.4% No Data No Data Russian River at River Road, Hopland 1,898 96.8% No Data No Data Russian River at Commisky Station Road, Cloverdale 2,731 97.8% 5,413 99.4% Russian River at River Park, Cloverdale 1,087 94.5% 710 95.8% Russian River at Hwy 128 Bridge, Geyserville 13,501 99.6% 236 87.3% Russian River at Jimtown Bridge, Healdsburg 37,052 99.8% 116 74.1% Russian River at Camp Rose Beach, Healdsburg 31,055 99.8% 286 89.5% Russian River at Veteran Memorial Beach, Healdsburg 14,921 99.6% 381 92.1% Russian River at Steelhead Beach, Forestville 48,485 99.9% 23,684 99.9% Russian River at River Access Beach, Forestville 57,554 99.9% 14,710 99.8% Russian River at Johnson’s Beach, Guerneville 1,677 96.4% 85 64.7% Russian River at Monte Rio Beach, Monte Rio 8,898 99.3% 762 96.1% Russian River at Public Boat Ramp, Jenner 4,837 98.8% 2,682 98.9% Abramson Creek at Willowside Road Path, Santa Rosa 273,401 99.9% 425,164 99.9% Blucher Creek at Lone Pine Road, Cotati 18,022 99.7% 177,248 99.9% Copeland Creek at Commerce Blvd, Rohnert Park 19,928 99.7% 51,685 99.9% Crane Creek at Snyder Lane, Rohnert Park 26,703 99.8% 23,602 99.9% Dutch Bill Creek at Main Street, Monte Rio 416 85.6% 15 0.0% Foss Creek at Matheson Street, Healdsburg 37,346 99.8% 8,668 99.7% Gossage Creek at Stony Glen Lane, Cotati 29,902 99.8% 76,895 99.9% Green Valley Creek at Martinelli Road, Forestville 17,016 99.6% 72 58.3% Laguna de Santa Rosa at Community Center, Sebastopol 7,469 99.2% 514 94.2% Mays Creek at Neeley Road, Guerneville 1,325 95.5% 608 95.1% Palmer Creek at Palmer Creek Road, Healdsburg 2,781 97.8% 106 71.7% Piner Creek at Fulton Road, Santa Rosa 12,394 99.5% 3,274 99.1% Santa Rosa Creek at Hwy 12 Bridge, Santa Rosa 2,727 97.8% 181 83.4% Santa Rosa Creek at Railroad Street, Santa Rosa 32,909 99.8% 7,765 99.6% Van Buren Creek at Erland Road, Santa Rosa 2,089 97.1% 2,265 98.7% Unnamed Creek at Lambert Bridge Road, Healdsburg 5,257 98.9% 453 93.4% Unnamed Creek at Fitch Mountain Road, Healdsburg 238 74.8% No Data No Data Unnamed Creek at Fredson Road, Healdsburg 8,580 99.3% No Data No Data Unnamed Creek at West Dry Creek Road, Healdsburg 4,040 98.5% No Data No Data Unnamed Creek at Alexander Valley Road, Healdsburg 2,031 97.0% No Data No Data Unnamed Creek at Redwood Drive, Healdsburg 2,310 97.4% No Data No Data Unnamed Creek at Limerick Road, Healdsburg 20,000 99.7% 1,966 98.5% Unnamed Creek at Summerhome Park Road, Forestville 7,975 99.2% No Data No Data Unnamed Creek at Trenton Road, Forestville 48,200 99.9% No Data No Data Unnamed Creek at Del Rio Court, Forestville 3,460 98.3% No Data No Data Unnamed Creek at River Road, Rio Nido 3,600 98.3% No Data No Data Unnamed Creek at Foothill Dive, Monte Rio 371,000 100.0% No Data No Data Unnamed Creek at Duncan Road, Monte Rio 353 83.0% No Data No Data September 222026 Item 7
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Table 7.3 Percent Reductions Needed to Meet Bacteroides Bacteria TMDLs Location
Human Host Bacteroides Bovine Host Bacteroides
Median
Bacteroides
in genes
per 100mL
Reduction
Needed to
Attain 60
genes per
100mL
Median
Bacteroides
in genes
per 100mL
Reduction
Needed to
Attain 30
genes per
100mL
Unnamed Creek at Old Monte Rio Road, Monte Rio 25,100 99.8% No Data No Data Unnamed Creek at Main Street, Monte Rio 1,392 95.7% No Data No Data Unnamed Creek at Moscow Road, Duncans Mills <60 0% No Data No Data Unnamed Creek at Lakeside Ave, Camp Meeker 9,090 99.3% No Data No Data Unnamed Creek at Sanford Road, Sebastopol 1,576 96.2% 482 93.8% Unnamed Creek at Daywalt Road, Cotati 37,632 99.8% 867,503 99.9% Unnamed Creek at River Road, Fulton 2,759 97.8% 768 96.1% Table 7.4 Percent Reductions Needed to Meet E. coli Bacteria TMDLs in Tributaries Tributary Location
E. coli Reduction
Needed To Attain
Geometric Mean
≤ 100 cfu/100mL
STV
≤ 320 cfu/100mL
Atascadero Creek at Green Valley Road 80% 91%
Foss Creek at Matheson Street 97% 99%
Green Valley Creek at Martinelli Road 12% 49%
Laguna de Santa Rosa at Sebastopol Community Center 42% 92% Santa Rosa Creek at Highway 12 60% 66%
Santa Rosa Creek at Railroad Street 79% 84%
Table 7.5 Percent Reductions Needed to Meet TMDLs by Land Cover Category Land Cover Category
E. coli Human-Host Bacteroides Bovine-Host Bacteroides
Dry
Period
Wet
Period
Wet &
Dry
Periods
Dry
Period
Wet
Period
Wet &
Dry
Periods
Dry
Period
Wet
Period
Wet &
Dry
Periods
Developed Non-Sewer 82% 99% 98% 98.6% 99.9% 99.3% 93.8% 99.9% 96.5% Developed Sewer 46% 98% 98% 97.7% 99.8% 99.5% 93.1% 99.9% 99.1% Shrubland 57% 98% 96% 98.6% 99.9% 99.7% 96.1% 99.9% 99.9% Agriculture 0% 96% 87% 97.9% 99.9% 99.8% 95.5% 99.9% 99.6% Forest Land 0% 56% 33% 0% 97.5% 94.9% 0% 96.1% 89.3%
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CHAPTER 8

IMPLEMENTATION
The purpose of the Implementation Plan is to describe the steps necessary to reduce pathogen concentrations and achieve the TMDLs. The Implementation Plan identifies:

1. Actions that staff expects will reduce pathogens

2. Parties responsible for taking these actions

3. Regulatory mechanisms by which the Regional Water Board will ensure that these actions are taken

4. A timeline for completion of actions.

8.1 WASTE DISCHARGE PROHIBITIONS
Discharges of fecal material from humans or from domestic animals to waters of the state are controllable water quality factors that shall conform to the Bacteria Water Quality Objective. Controllable water quality factors are those actions, conditions, or circumstances resulting from man’s activities that may influence the quality of waters of the state and that may be reasonably controlled.

In accordance with Water Code section 13243 and in order to achieve the Bacteria Water Quality Objective, protect present and future beneficial uses of water, protect public health, and prevent nuisance, this TMDL sets forth the following discharge prohibition:

Discharges of waste containing fecal material from humans or domestic animals to waters of the state within the Russian River Watershed that cause or contribute to an exceedance of the Bacteria Water Quality Objectives not authorized by waste discharge requirements or other order or action of the Regional or State Water Board are prohibited.

Examples of domestic animals include, but are not limited to, horses, cattle, goats, sheep, dogs, cats, or any other animal(s) in the care of any person(s). Exceptions to the prohibition include discharges in accordance with waste discharge requirements or other provisions of the Water Code, Division 7, as amended. Compliance with this Waste Discharge Prohibition implies compliance with the wasteload and load allocations for this TMDL.

Sources of human fecal material identified in this TMDL project include:
 Discharges of municipal wastewater directly to surface waters  Discharges of non-municipal wastewater directly to surface waters  Discharges of untreated sewage from sanitary sewer systems  Discharges of wastewater from percolation ponds and through spray irrigation  Discharges of runoff from land application of municipal biosolids  Discharges to land from water recycling projects
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 Discharges from onsite wastewater treatment systems
 Discharges from recreational water uses and users
 Discharges from homeless encampments
 Discharges of stormwater to MS4s and from areas outside MS4 boundaries.

Sources of domestic animal and farm animal waste identified in this TMDL project include:
 Discharges of pet waste
 Discharges from non-dairy livestock and farm animals
 Discharges of manure from dairy cows.

8.2 IMPLEMENTATION ACTIONS
The implementation actions included in this TMDL address pathogens from specific controllable pathogen sources, including humans and other domesticated animals. Each probable source, its responsible parties, and its implementation actions are described in the following sections and summarized in Table 8.1.

8.2.1 MUNICIPAL WASTEWATER DISCHARGES TO SURFACE WATERS There are four municipal wastewater treatment facilities in the Russian River Watershed that collect, treat, and discharge fully-treated effluent directly to the Russian River or its tributaries. These facilities are operated by:
 City of Ukiah
 City of Healdsburg
 City of Santa Rosa
 Occidental County Sanitation District
The waste discharges are regulated under existing NPDES permits that include effluent limitations and disinfection specifications to ensure treatment processes achieve effective and reliable pathogen reduction. Disinfection requirements in these permits are derived from standards for tertiary-treated recycled water contained in title 22 of the CCR. The limitations are consistent with Basin Plan requirements for advanced treated wastewater for such discharges. When a disinfection system operates properly and attains the effluent limitations, direct discharges of treated wastewater to surface waters will also attain E. coli wasteload allocations.

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Table 8.1. Summary of Implementation Actions
Source Responsible Party Allocations (WLAs & LAs) &
Effluent Limitations (ELs)
Plan
Required
Regulatory
Mechanism Time Schedule
Direct Wastewater
Discharges to Surface
Waters
NPDES Municipalities  E. coli WLAs
 Fecal Coliform WLA
 Total Coliform ELs
None Permit
Revision
 Update Permits as soon as practicable
Holding Pond
Discharges to Surface
Waters
NPDES Municipalities  E. coli WLAs & ELs
 Fecal Coliform WLA & EL
Bacteria Load
Reduction
Plan
Permit
Revision
 1 year to submit evidence of no contribution or
BLRP
 3 years to update Permit
 Up to 10 years for compliance schedule
Percolation Pond
Discharges to Land
Special Sanitary Districts
Private WWTPs
 Total Coliform EL
 Fecal Coliform WLA & EL
None Permit
Revision
 Update Permits as soon as practicable
Sanitary Sewer Systems GWDR Permittees  E. coli LAs
 Bacteroides LAs
 Fecal Coliform LA
Sanitary
Sewer
Management
Plan
13267 Order  1 year to submit updated SSMP to Regional Water Board
Land Application of
Biosolids
GWDR and WDR
Permittees
 E. coli LAs
 Bacteroides LAs
 Fecal Coliform LA
Erosion
Control Plan
13267 Order  1 year to develop and submit an Erosion
Control Plan to Regional Water Board
Recycled Water Use Recycled Water
Producers
Recycled Water Users
 E. coli WLAs
 Fecal Coliform WLA
NonStormwater
BMP Plan
13267 Order  1 year to prepare and submit an updated NonStormwater BMP Plan to Regional Water Board
OWTS – High Priority Sonoma County
Mendocino County
 E. coli LAs & Performance
Standards
 Bacteroides LAs
 Fecal Coliform LA &
Performance Standards
 TSS Performance Standards
Advance
Protection
Mgmt Plan
Basin Plan
Amendment
 5 years to develop and submit APMP
OWTS – Medium
Priority
Sonoma County
Mendocino County
 E. coli LAs
 Bacteroides LAs
 Fecal Coliform LA
Advance
Protection
Mgmt Plan
Basin Plan
Amendment
 5 years to develop and submit APMP
OWTS – Low Priority Sonoma County
Mendocino County
 E. coli LAs
 Bacteroides LAs
 Fecal Coliform LA
Advance
Protection
Mgmt Plan
Basin Plan
Amendment
 5 years to develop and submit APMP
Private Large OWTS Owners of large OWTS  E. coli LAs & Performance Standards
 Bacteroides LAs
Report of
Waste
Discharge
13267 Order &
Permit
Adoption or
 6 months to prepare and submit a ROWD
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Table 8.1. Summary of Implementation Actions
Source Responsible Party Allocations (WLAs & LAs) &
Effluent Limitations (ELs)
Plan
Required
Regulatory
Mechanism Time Schedule
 Fecal Coliform LA &
Performance Standards
 TSS Performance Standards
Revision
Recreation Uses Sonoma County
Mendocino County
 E. coli LAs
 Bacteroides LAs
 Fecal Coliform LA
Bacteria Load
Reduction
Plan
13267 Order  1 year to submit BLRP
Homeless & Illegal
Camping
Sonoma County
Mendocino County
Municipalities
 E. coli LAs
 Bacteroides LAs
 Fecal Coliform LA
Bacteria Load
Reduction
Plan
13267 Order  1 year to submit BLRP
Stormwater – Municipal MS4 Permittees  E. coli WLAs
 Bacteroides WLAs
 Fecal Coliform WLA
Possible
ROWD
Revision to
Phase I MS4
Permit or
Revision to
Attachment G
for Phase II
Permit
 Submit Phase I Permit revision as soon as
practicable
Stormwater – Caltrans Caltrans  E. coli WLAs
 Bacteroides WLAs
 Fecal Coliform WLA
Bacteria Load
Reduction
Plan
Revision of
MS4 Permit

Pet Waste Sonoma County
Mendocino County
Municipalities
 E. coli LAs
 Bacteroides LAs
 Fecal Coliform LA
Bacteria Load
Reduction
Plan
13267 Order  1 year to submit BLRP
Livestock & Farm
Animals
Ranch and farm owners  E. coli LAs
 Bacteroides LAs
 Fecal Coliform LA
None Revision of
Dairy Permits
 2 years to establish and implement BMPs to
qualify for waiver of need to submit ROWD
 Revision of Dairy Program Conditional Waiver
of WDRs to accommodate non-dairy livestock
and farm animals
Dairies - NPDES NPDES Dairies  E. coli WLAs
 Bacteroides WLAs
 Fecal Coliform WLA
Bacteria Load
Reduction
Plan
Permit
Revision
 2 years to prepare and submit a BLRP
 Permit revision anticipated for 2017
Dairies – Waiver &
WDRs
Waiver and WDR Dairies  E. coli LAs
 Bacteroides LAs
 Fecal Coliform LA
Bacteria Load
Reduction
Plan
Permit
Revision
 2 years to prepare and submit a BLRP
 Permit revision anticipated for 2017
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In order to ensure that direct discharges of treated wastewater from municipal wastewater treatment facilities to the Russian River and its tributaries maintain existing performance, and thus remain in compliance with Basin Plan standards, these permittees are required to attain the following effluent limitations:

1. The median concentration of total coliform bacteria shall not exceed 2.2 MPN/ 100 mL, using the daily bacteriological results of the last 7 days for which analyses have been completed

2. The number of total coliform bacteria shall not exceed 23 MPN/ 100 mL in more than one daily result in any 30-day period

3. No daily total coliform result shall exceed 240 MPN/ 100 mL.

To demonstrate compliance with limitations, direct dischargers of treated wastewater shall conduct daily effluent monitoring at a location or locations where a representative sample of the effluent can be collected. Direct dischargers shall provide to the Regional Water Board monthly discharge monitoring reports and other reports, as necessary, to demonstrate compliance with effluent limitations and with the E. coli and fecal coliform wasteload allocations. The Regional Water Board will include the above effluent limitations and requirements in applicable waste discharge requirements as soon as is practicable, but no later than at the time of the facility’s next permit renewal.

8.2.2 WASTEWATER HOLDING POND DISCHARGES TO SURFACE WATERS There are six municipal wastewater treatment facilities in the Russian River Watershed that collect, treat, dispose, or recycle municipal wastewater and discharge treated effluent from a wastewater holding pond to the Russian River or its tributaries. These facilities are operated by:
 City of Santa Rosa
 Forestville Water District
 Graton Community Services District
 Occidental County Sanitation District
 Russian River County Sanitation District
 Town of Windsor
Each municipality and special district authorized to discharge treated wastewater from wastewater holding ponds to the Russian River or its tributaries shall maintain compliance with the following effluent limitations (which equal the E. coli and fecal coliform wasteload allocations) using the bacteriological results of holding pond effluent samples collected at least weekly for the calendar month for which analyses have been completed:

1. The geometric mean concentration of E.coli bacteria shall not exceed 100 MPN/ 100 mL, and

2. The STV for E. coli bacteria shall not exceed 320 MPN/ 100 mL, and

3. No daily fecal coliform result in any calendar month shall exceed 43 MPN/ 100 mL.

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Within one year of the effective date of this TMDL, each municipality and district permitted to discharge treated wastewater from wastewater holding ponds to surface waters shall provide evidence that its discharge is in compliance with the E. coli and fecal coliform WLAs in this TMDL or prepare and submit to the Regional Water Board a Bacteria Load Reduction Plan (BLRP) (further described in Section 8.3). The BLRP shall provide a description and a time schedule up to three years for actions that will bring the municipality into compliance with the E. coli and fecal coliform WLAs. Possible compliance actions could include any combination of the following:
 Upgrades to existing disinfection systems to a process more completely destructive of wastewater pathogens (e.g., ozone, heat sterilization, ultrafiltration)  Initial or additional disinfection of holding pond effluent immediately prior to discharge
 Zero discharge through expansion of recycled water use or enlargement of wastewater holding ponds
If studies or other evidence demonstrate that human-source bacteria are effectively killed or removed from the waste stream and are not present in the holding pond discharge, the municipality or district will be considered to be in compliance with the waste load allocations.

Within three years of the effective date of this TMDL, the Regional Water Board will include the above effluent limitations and requirements in applicable waste discharge requirements. Following the inclusion of effluent limitations and requirements, affected facilities shall conduct effluent monitoring for E. coli bacteria at least weekly at a location or locations where a representative sample of the effluent can be collected. Affected facilities shall provide to the Regional Water Board monthly discharge monitoring reports and other reports, as necessary, to demonstrate compliance with effluent limitations.

8.2.3 PERCOLATION PONDS AND DISPOSAL BY SPRAY IRRIGATION There are six municipal wastewater treatment facilities and seven 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 spray irrigation.

These facilities are operated by:
 Bohemian Grove (private)
 Calpella County Water District (public)
 Camp Royaneh (private)
 City of Cloverdale (public)
 City of Ukiah (public)
 Geyserville County Sanitation Zone (public)
 Hopland County Water District (public)
 Mayacamas Golf Club (private)
 Rio Lindo Academy (private)
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 Russian River County Sanitation District (public)
 Rodney Strong Vineyards (private)
 Salvation Army Lytton Springs Rehabilitation Facility (private)  Vintner’s Inn (private)
Each municipality, district, and private wastewater treatment facility permitted to discharge treated municipal or domestic wastewater to a percolation pond within the Russian River Watershed shall use a treatment process designed to meet the following effluent limitations:

1. The geometric mean concentration of total coliform bacteria shall not exceed 23 MPN/100 mL in any calendar month.

2. No daily fecal coliform result in any calendar month shall exceed 43 MPN/ 100 mL.

The effluent limitation for total coliform bacteria is derived from standards for disinfected secondary-23 treated recycled water contained in California Code of Regulations, title 22, chapter 3, article 1, section 60301.225. Disinfection systems that are designed to consistently achieve this level of disinfection are effective in reducing most wastewater pathogens to non-detectable or very low levels. Use of an effluent disinfection system to meet this total coliform bacteria effluent limitation will ensure compliance with load allocations for E. coli bacteria in this TMDL. The effluent limitation for fecal coliform implements the load allocation in this TMDL for fecal coliform.

For percolation ponds where it can be demonstrated that wastewater at no time contributes pathogen indicator bacteria to flow in surface waterbodies, alternative effluent limitations, discharge specifications, or permit requirements may be established in individual waste discharge requirements at the discretion of the Regional Water Board, and based on site specific conditions. Where wastewater disinfection systems are not used as a means to attain bacteria load allocations, the load allocations applicable to these discharges include Bacteroides, in addition to E. coli bacteria and fecal coliform bacteria effluent limitations.

For disposal of wastewater to land through spray disposal, attainment of bacteria load allocations is achieved through proper treatment plant design and siting and through compliance with waste discharge requirements that contain discharge specifications and other requirements that prevent the creation of runoff that could impact surface water.

To demonstrate compliance with these bacteria limitations, facilities shall conduct effluent monitoring at a location or locations where a representative sample of the effluent can be collected, and provide discharge monitoring reports to Regional Water Board staff. The frequency of effluent monitoring for bacteria established in waste discharge requirements is at the discretion of the Regional Water Board, but shall be sufficient to ensure demonstrate compliance with effluent limitations. Waste discharge requirements shall provide justification for the frequency of monitoring. Justification shall be based on factors such as discharge flow, proximity of the discharge to surfaces waters or other site conditions, and effluent variability.

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The Regional Water Board shall include the above effluent limitations and requirements in applicable waste discharge requirements as soon as is practicable.

8.2.4 SANITARY SEWER SYSTEMS
There are eighteen sanitary sewer systems in the Russian River Watershed that collect and convey domestic wastewater to wastewater treatment facilities for treatment, and disposal or recycling. These facilities are operated by:
 Airport/Larkfield/Wikiup Sanitation Zone
 Calpella County Water District
 City of Cloverdale
 City of Cotati
 City of Healdsburg
 City of Rohnert Park
 City of Santa Rosa
 City of Sebastopol
 City of Ukiah
 Forestville Water District
 Geyserville County Sanitation Zone
 Graton Community Services District
 Hopland County Water District
 Occidental County Sanitation District
 Russian River County Sanitation District
 Sonoma State University
 South Park County Sanitation District
 Town of Windsor
 Ukiah Valley Sanitation District
In order to comply with this TMDL, each municipality and district shall (1) maintain compliance with General Waste Discharge Requirements for Sanitary Sewer System, Water Quality Order No. 2006-0003-DWQ (General Order) and all amendments and subsequent updates to the General Order.

In addition, within one year of the effective date of this TMDL, the municipality or district shall submit an amendment to its approved Sanitary Sewer Management Plan (SSMP) that describes actions with time schedules that it takes or plans to take to further minimize sanitary sewer overflows, spills, and exfiltration from its sanitary sewer system. Possible actions might include:
 Increasing the frequency and method of surveillance of sanitary sewer pipes, pump stations, siphons, and other sewer infrastructure that are located where overflows, spills, and exfiltration may adversely impact the Russian River or its tributaries.  Accelerating schedules for pipeline rehabilitation and/or replacement.

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 Revising sewer design standards to specify construction materials and methods that will ensure a water-tight sanitary sewer system for new and replacement sewer components in areas adjacent to the Russian River and its tributaries.  Establishing local ordinances to require property owners to inspect their private sewer lateral upon property transfer, in response to chronic SSOs, or after significant changes in property use
 Developing programs to enable and help finance ratepayers to voluntarily inspect and repair deteriorating private service laterals.

The Regional Water Board will require submission of the SSMP amendment under authority of section 13267 subdivision (b) of the California Water Code.

8.2.5 LAND APPLICATION OF BIOSOLIDS
Currently, the City of Santa Rosa is the only public or private entity permitted for the land application of biosolids as a soil amendment in the Russian River Watershed. In order to comply with this TMDL, the City of Santa Rosa shall maintain coverage for its biosolids land application projects under General Waste Discharge Requirements for the Discharge of Biosolids to Land for Use as a Soil Amendment in Agricultural, Silvicultural, Horticultural, and Land Reclamation Activities, Water Quality Order No. 2004-12-DWQ (General Order), and all amendments and subsequent updates to the General Order, or equivalent individual waste discharge requirements.

In addition, within one year of the effective date of this TMDL, the City of Santa Rosa shall prepare and submit an Erosion Control Plan that describes actions and time schedules for enhanced protections to prevent the movement of biosolids from the application area.

Enhanced protections might include:
 Increasing minimum allowable setbacks
 Installing vegetation buffer strips between the application area and gullies, washes, and other areas that are vulnerable to erosion and washout  Decreasing the pathogen concentration of land-applied biosolids.

The Regional Water Board will require submission of the Erosion Control Plan under authority of section 13267 subdivision (b) of the Water Code. Applicants seeking permit coverage for future projects involving the land application of municipal biosolids shall be required to prepare and submit an Erosion Control Plan, as described above, with the Notice of Intent.

8.2.6 RECYCLED WATER
There are six municipal wastewater treatment facilities and districts responsible for water reclamation projects in the Russian River Watershed that recycle treated effluent through spray irrigation. These facilities are operated by:

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 Airport/Larkfield/Wikiup Sanitation Zone
 City of Cotati
 City of Healdsburg
 City of Rohnert Park
 City of Santa Rosa
 City of Sebastopol
 City of Ukiah
 Forestville Water District
 Graton Community Services District
 Occidental County Sanitation District.
 Russian River County Sanitation District, and
 Sonoma State University
 Town of Windsor
Each municipality and district that is permitted to beneficially reuse treated wastewater for landscape irrigation, agricultural irrigation, or other use allowable under California Code of Regulations, title 22, chapter 3, article 3, section 60303 through 60307 shall maintain compliance with water recycling requirements in State Water Resources Control Board Order WQ 2014-0090-DWQ, General Waste Discharge Requirements for Recycled Water Use, subsequent general orders, individual waste discharge requirements, or Master Water Reclamation Permits.

In addition, within one year of the effective date of this TMDL, each responsible party shall submit to the Regional Water Board a Non-Storm Water Best Management Plan that provides a description and a time schedule for actions that will bring the municipality into compliance with the E. coli and fecal coliform WLAs. The Non-Storm Water Best Management Plan shall describe actions that prevent recycled water spills and incidental runoff from reuse areas adjacent to the Russian River and its tributaries. Possible actions might include:
 Evaluating and, when necessary, improving BMPs to prevent overspray, spills, and incidental runoff
 Increasing setbacks from recycled water points of use to waterbodies, curbs, pavement and stormwater inlets
 Improving compliance with recycled water user requirements through increased public outreach and, when necessary, through progressive enforcement.

The Regional Water Board will require the submission of a Non-Storm Water Best Management Plan under authority of section 13267 subdivision (b) of the Water Code.

8.2.7 INDIVIDUAL ONSITE WASTEWATER TREATMENT SYSTEMS
An Advanced Protection Management Program (APMP) is the minimum required management program for all OWTS located in the Russian River Watershed. Based on evidence of exceedances of the E. coli objectives and the presence of human-source pathogenic indicator bacteria in the tributaries and in association with areas with a high September 222026 Item 7
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density of OWTS, this TMDL prescribes a risk-based management approach for the regulation of individual OWTS in the Russian River Watershed. This management approach mandates special requirements for OWTS whose operation is likely to pose the greatest threat to public health and water quality.

In its APMP, each county shall identify priority areas based on the threat to water quality from OWTS discharges. The priority ranking scheme must consist of at least three threat ranks: High Priority, Medium Priority, and Low Priority. Although the rough boundaries of the High, Medium, and Low Priority Areas are described below, each county’s APMP must include a procedure to further define and rank communities and other areas based on the threat to water quality from OWTS within these areas.

High Priority Areas
High Priority Areas include:
 Areas with a high density of OWTS in the lower Russian River Watershed, including the communities of Jenner, Cazadero, Monte Rio, Camp Meeker, Guerneville, Rio Nido, Summer Home Park, Hacienda, Mirabel, and Fitch Mountain near Healdsburg  Other high density areas identified by the county
 Areas within 600 lineal feet in the horizontal (map) direction of the mainstem Russian River and the following tributaries: Austin Creek, Dutch Bill Creek, Fife Creek, Green Valley Creek, Laguna de Santa Rosa, Santa Rosa Creek, and Mark West Creek.

In High Priority Areas, each county shall ensure that all existing, new, and replacement OWTS include supplemental treatment components for pathogens in accordance with requirements in sections 10.10.2 through 10.15 of the Basin Plan’s OWTS Policy for impaired areas. Supplemental treatment components shall ensure effluent does not exceed a 30-day average of 30 mg TSS/L and can achieve an effluent E. coli bacteria concentration of less than or equal to 100 MPN/100 mL.

In addition, to ensure that OWTS in high risk areas are properly managed, each county shall create or facilitate the creation of a local On-Site Wastewater Zone pursuant to Division 6, Part 2, Chapter 3, sections 6950 through 6982 of California Health and Safety Code or other OWTS Management Program that achieves the following goals:

1. Ensures that individual OWTS work properly and do not threaten public health, local water resources, or the environment

2. Identifies all existing OWTS, assesses their performance, and corrects problems

3. Ensures that all new OWTS and replacement OWTS are correctly designed, sited, constructed, and installed

4. Extends the lifespan of OWTS through ongoing maintenance, reducing potential costs of repair and replacement

5. Educates homeowners about the importance of good system operation and maintenance practices
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6. Encourages water conservation and graywater reuse

7. Provides ongoing monitoring of and record keeping for OWTS.

The establishment of an On-Site Wastewater Zone is not required for the following:

1. OWTS within an established municipal sewer district or county sanitation district, and

2. OWTS that are permitted or operating on or prior to the effective date of this TMDL and whose owners: (a) commit by way of a legal document within 4 years of the effective date of this TMDL to connect to the sanitary sewer system of a permitted municipal wastewater treatment facility; and (b) the specified date for the connection to the centralized wastewater collection and treatment system does not extend beyond 10 years from the effective date of this TMDL.

In areas where the establishment of an On-Site Wastewater Zone is required, the APMP should describe the critical components of an effective OWTS management program.

Critical components should include:
 Legal authority and mechanism for funding the program  Authority to inspect and monitor individual OWTS within the program boundary  Authority to conduct routine operations and maintenance activities and issue operational permits
 Authority and expertise to review and approve OWTS designs  Enforcement authority for noncompliance with rules, requirements, and/or standards  Public education and training.

In areas within established municipal sewer districts, county sanitation districts, community service districts with sewer authority, or future expanded sewer districts, the responsible local agency shall require that each existing, new, and replacement OWTS within its jurisdiction connect to the sanitary sewer system or shall require that each existing or replacement OWTS comply with the performance standards in sections 10.10.2 through 10.15 of the Basin Plan’s OWTS Policy for impaired areas. Thereafter, the responsible local agency shall comply with an Advanced Protection Management Program in accordance with section 10 of the Basin Plan’s OWTS Policy.

Medium Priority Areas
Medium Priority Areas include:
 Areas with a high density of OWTS in the middle and upper Russian River Watershed (including Oakmont in East Santa Rosa, North Cloverdale, Talmage, and Redwood Valley)  Other high density areas identified by the county
 Areas and communities not in High Risk Areas, but where OWTS are within 600 lineal feet in the horizontal (map) direction of the mainstem Russian River and the following tributary streams: Big Sulphur Creek, Little Sulphur Creek, Commisky Creek, Dry Creek, Feliz Creek, Forsythe Creek, Franz Creek, Maacama Creek, Mill Creek, Pieta Creek, East Fork Russian River, Sausal Creek, and York Creek
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In Medium Priority Areas, each county shall comply with minimum responsibilities of a local agency administering a Local Agency Management Program in accordance with section 9 of the Basin Plan’s OWTS Policy.

To ensure that OWTS in medium priority areas are properly managed, the responsible agency shall create or facilitate the creation of a local On-Site Wastewater Zone or other OWTS Management Program, as described in section on High Priority Areas above.

Low Priority Areas
Low Priority Areas include:
 Areas within the Russian River Watershed that have not been designated as high or medium risk by the county.

In Low Priority Areas, each county shall implement requirements consistent with Tier 0, Tier 2, and Tier 4 of the Basin Plan’s OWTS Policy.

Within six months of the effective date of this TMDL, Sonoma County and Mendocino County must each prepare and submit a BLRP to the Regional Water Board that provides a schedule for developing or updating its APMP for OWTS in the Russian River Watershed. In addition to the BLRP requirements described in Section 8.3, the BLRP may also include:
 A time schedule to investigate whether a community is contributing to impairment  A period of time for owners of individual OWTS to demonstrate that their existing OWTS meets performance standards or is protective of water quality by means of adequate system design and site conditions
 A time schedule to develop a local grant or loan program that would provide funding to owners of individual OWTS to help them comply with program requirements.

8.2.8 LARGE ONSITE WASTEWATER TREATMENT SYSTEMS
Within six months of the effective date of this TMDL, owners of existing, new, and replacement OWTS with a project flow greater than 10,000 gpd or large OWTS not regulated by the local agency shall submit a Report of Waste Discharge containing information about their OWTS. Based on the Report of Waste Discharge, the Regional Water Board may issue WDRs or Waivers for the OWTS.

OWTS subject to this subsection that are identified in this TMDL as being located in High and Medium Priority Areas shall include supplemental treatment components for pathogens in accordance with requirements in sections 10.10.2 through 10.15 of the Basin Plan’s OWTS Policy for impaired areas. Supplemental treatment components shall ensure OWTS effluent does not exceed a 30-day average of 30 mg TSS/L and can achieve an effluent E. coli bacteria concentration of less than or equal to 100 MPN/100 mL. In Low Priority Areas, appropriate discharge requirements shall be prescribed by the Regional Water Board.

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For large OWTS permitted, constructed, or operating prior to the effective date of this TMDL and regulated by existing waste discharge requirements, the Regional Water Board shall include in the waste discharge requirements, as soon as is practicable, effluent limitations and other requirements to demonstrate compliance with the above discharge specifications. For permitted large OWTS, the Regional Water Board shall require the submission of the report of waste discharge under authority of section 13267 subdivision (b) of the Water Code.

For large OWTS constructed after the effective date of this TMDL, effluent limitations and other requirements shall be established in waste discharge requirements as the permits are adopted.

8.2.9 RECREATIONAL WATER USE
Within two years of the effective date of this TMDL, Sonoma County and Mendocino County shall prepare and submit a BLRP that describes actions to reduce bacteria loading associated with activities at recreational beaches and other known swimming areas within their jurisdiction to attain load allocations. Potential implementation actions could include:
 Installing temporary or permanent restroom facilities, including diaper changing stations, near the recreation use areas and signage to effectively direct recreators to restroom facilities
 Establishing interagency agreements with local sanitation districts to provide maintenance and waste disposal for temporary restroom facilities  Developing and distributing educational & outreach materials (fliers, brochures) to inform river recreators about proper waste disposal and sanitation at beaches and access points along the Russian River and tributaries
 Conducting outreach to private recreational beach operators and commercial river outfitters to improve beach housekeeping and provide adequate sanitation facilities for customers
 Publicizing locations of public restroom facilities on the county website and at recreational outfitters’ headquarters
 Improving restroom facilities at popular private beaches  Limiting availability of parking along county roads near beach areas where waste collection is difficult.

The Regional Water Board will require submission of a BLRP under authority of section 13267 subdivision (b) of the Water Code. Regional Water Board staff will review the BLRP and determine the appropriate program actions to regulate the implementation actions proposed in the BLRP.

8.2.10 HOMELESS AND FARMWORKER ENCAMPMENTS AND ILLEGAL CAMPING To comply with this TMDL, Sonoma County, Mendocino County, and municipalities within the Russian River Watershed shall prepare and submit a BLRP that describes actions to: (1) September 222026 Item 7
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correct noncompliance with existing ordinances pertaining to illegal camping and farmworker housing; and (2) provide waste disposal for homeless persons currently residing along watercourses and other areas within the public space. The BLRP must include an implementation schedule that ensures attainment of load allocations in the shortest time practicable, milestones to achieve compliance, a commitment to provide periodic status reports to the Regional Water Board to monitor progress toward completing the BLRP and compliance milestones, and a monitoring plan through which compliance with WLAs can be assessed.

Implementation actions might include:
 Providing or improving options for shelters, transitional housing, affordable housing, and other homeless services
 Conducting public outreach to owners of private property in the Russian River Watershed to inform and assist them on how best to prevent illegal camping and trespassing on their property, including how to report illegal use to local law enforcement
 Establishing a program, including a hotline, for reporting homeless encampments and facilitating camp cleanup activities
 Installing physical barriers to prevent illegal camping and habitation under bridges and overpasses
 Initiating and participating in pilot programs that provide public restroom facilities along public trails and upgraded restroom facilities at public parks.

Options to reduce water quality impacts of homeless and farmworker encampments can also be combined with efforts to reduce homelessness. Sonoma County, Mendocino County, and municipalities are encouraged to fully fund and implement goals, objectives, and policies contained in their general plans for homeless and farmworker populations.

More affordable, available housing will result in fewer residents seeking shelter along waterways, away from adequate sanitation facilities.

Where suitable housing for homeless persons and farmworkers exists or is planned, and the housing unit is served by an individual septic system, community septic system, or other approved waste treatment and disposal system, the design, installation, and operation of the system shall comply with the Local Agency Management Program for the local agency with jurisdiction over individual septic systems.

The Regional Water Board will require submission of a BLRP under authority of section 13267 subdivision (b) of the Water Code. Regional Water Board staff will review the BLRP and determine the appropriate program actions to regulate the implementation actions proposed in the BLRP.

8.2.11 URBAN STORMWATER RUNOFF
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(MS4) Permit. The current Phase I MS4 Permit, Order No. R1-2009-0050 (NPDES Permit No. CA0025054) became effective on October 1, 2009, and continues in force until a new permit is issued. Small MS4s within the watershed are enrolled under Water Quality Order No. 2013-0001-DWQ, National Pollutant Discharge Elimination System (NPDES) General Permit No. CAS000004, Waste Discharge Requirements (WDRs) for Storm Water Discharges from Small Municipal Separate Storm Sewer Systems (Phase II MS4 General Permit).

Permittees currently named under the Phase I MS4 Permit are:
 City of Santa Rosa
 County of Sonoma
 Sonoma County Water Agency
Small MS4s in the Russian River Watershed currently enrolled under the Phase II MS4 General Permit are:
 City of Cloverdale
 City of Cotati.
 City of Healdsburg
 County of Sonoma
 Sonoma County Water Agency
 Sonoma State University
 Town of Windsor
In order to comply with this TMDL, discharges of urban stormwater from MS4s in the Russian River Watershed shall attain the Bacteroides, E. coli, and fecal coliform bacteria waste load allocations.

Upon renewal of the Phase I MS4 permit or as soon as is practicable, the Regional Water Board will establish effluent limitations for MS4s at end-of-pipe, or other locations where representative samples of effluent from the MS4 can be collected, to comply with wasteload allocations and a compliance schedule to achieve final limitations.

For Phase II MS4 permittees, TMDL-specific permit requirements shall be submitted to the State Water Board for inclusion in Attachment G of the Phase II MS4 General Order, as soon as practicable.

8.2.12 CALTRANS STORMWATER RUNOFF
The California Department of Transportation (Caltrans) is regulated under General Storm Water Permit (NPDES Permit No. CAS000003), Waste Discharge Requirements Order No. 2012-0011-DWQ and Order 2014-xxxx-DWQ, which is an amendment to include TMDLspecific permit implementation requirements. The statewide permit regulates stormwater and non-stormwater discharges from the Department’s properties and facilities, and discharges associated with operation and maintenance of the state highway system.

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load allocations identified in Table 8.1. Upon renewal of the statewide stormwater permit or as soon as is practicable, Regional Water Board staff will work with the State Water Board to include the Russian River Pathogen Indicator Bacteria TMDL in the TMDL requirements of the permit to ensure compliance with wasteload allocations. Permit renewal is likely in 2017 or 2018.

Implementation actions might include:
 Managing irrigation to ensure overwatering and runoff does not occur  Identifying and fixing broken sprinklers and irrigation pipes  Increasing infiltration by improving soil structure and texture  Adding structural management practices such as biofiltration strips, biofiltration swales, bioretention and biodetention basins
 Diverting stormwater runoff to bioretention/biodetention/infiltration basins  Sweeping
 Cleaning up illegal dumping
 Limiting or excluding access for camping under bridges and in the right-of-way  Developing and implementing a program, in collaboration with local jurisdictions, to report, respond to, and remove homeless encampments.

8.2.13 PET WASTE
Sonoma County, Mendocino County, and municipalities within the Russian River Watershed shall prepare and submit a BLRP that describes actions to reduce the deposition of pet waste on public property. Possible actions may include:
 Improving or establishing a pet waste program that could include more widespread availability of pet waste collections systems and a higher profile outreach program to educate the public about proper disposal of pet waste and the environmental consequences of improper disposal, and
 Partnering with local businesses and organizations to sponsor the installation, operation, and maintenance of pet waste collection systems.

The Regional Water Board will require submission of a BLRP under authority of section 13267 subdivision (b) of the Water Code. Regional Water Board staff will review the BLRP and determine the appropriate program actions to regulate the implementation actions proposed in the BLRP.

8.2.14 NON-DAIRY LIVESTOCK AND FARM ANIMALS
Owners and operators of animal facilities, inclusive of animal husbandry, livestock production, other similar agriculture operations, and commercial animal boarding facilities, shall implement best management practices to properly contain and dispose of waste, and mitigate for potential water quality impacts resulting from surface runoff of animal waste.

Possible actions may include:
 Regular cleanup of manure and soiled bedding in animal habitation areas  Use of impermeable surfaces for storage of manure
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 Use of onsite composting to stabilize and reuse manure  Siting of manure storage areas away from water courses and off slopes  Reduction of stormwater contacting manure storage areas, paddocks, and kennel areas
 Use of vegetated buffers to encourage uptake of pollutants  Limiting of animals’ access to waterways.

The requirement of owners and operators of animal facilities to submit a Report of Waste Discharge for discharges from these operations is waived for animal facilities that implement these or similar best management practices. To implement this waiver, the Regional Water Board shall revise, as soon as practicable, the Conditional Waiver of Waste Discharge Requirements for Existing Cow Dairies in the North Coast Region, to include animal facilities as described above.

8.2.15 DAIRIES & CAFOs
Each cow dairy and CAFO in the Russian River Watershed is required to maintain compliance with the prohibition against the discharge of animal waste and with WLAs for the Russian River Watershed included in this TMDL. WLAs for CAFOs will be incorporated into the NPDES permit as effluent limitations.

Within one year of the effective date of this TMDL, in order to prevent discharges of animal waste to surface water, each enrollee under the Conditional Waiver of Waste Discharge Requirements, Waste Discharge Requirements, or NPDES Permit, or the holder of an individual dairy WDR is required to prepare a BLRP for their dairy facility to control manure, litter, and process water from the dairy production and pasture areas. The BLRP is intended to complement existing requirements in Nutrient Management Plans already required for enrollees under Waste Discharge Requirements and the NPDES permit.

However, BLRPs must include actions beyond what is currently required in Nutrient Management Plans.

At a minimum, the BLRPs shall include:
 Actions, such as riparian fencing, that prevent animal access to water courses and provide a vegetated buffers to reduce manure runoff.
 A surface water monitoring plan that includes routine monitoring for pathogen indicator bacteria to demonstrate attainment of WLAs. Coordination between dairies and CAFOs, including but not limited to group monitoring, is encouraged.  An implementation schedule, with a commencement date not exceeding two years from the effective date of this TMDL.

The Regional Water Board will incorporate the requirement to prepare and implement a BLRP into renewed Conditional Waiver of Waste Discharge Requirements, Waste Discharge Requirements, or NPDES Permit when these order come up for renewal, and into new dairy WDRs as they are proposed and adopted.

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8.3 BACTERIA LOAD REDUCTION PLAN
The goal of the BLRP is to describe and ensure effective implementation of actions that will reduce pathogens and indicator bacteria to attain the WLAs and LAs in the Russian River Watershed. The BLRP should be designed to identify, eliminate, reduce and clean up existing sources to the maximum extent practicable, prevent and control new sources, monitor, and implement additional actions as necessary.

The BLRPs can be developed cooperatively with other responsible parties or individually.

A responsible party that is required to submit BLRPs for more than one source type may combine the individual BLRPs into one master document.

8.3.1 TIME SCHEDULE FOR PLAN DEVELOPMENT, REVIEW, AND APPROVAL The following is the development, review, and approval process for a BLRP:

A. The responsible party or parties develops a draft BLRP.

B. The responsible party or parties submits its BLRP to the Regional Water Board in accordance with Table 8.1. Additional time to submit a BLRP may be granted by the Regional Water Board’s Executive Officer upon the request of the responsible party or parties if necessary due to the complexity or level of public involvement in the BLRP.

C. Regional Water Board staff reviews the BLRP and recommends approval of the BLRP once it is complete.

D. Within 9 months of the submittal of a complete BLRP, Regional Water Board staff will publicly notice a Memorandum of Recommended BLRP Approval for 21 days.

E. For BLRPs approved at the Executive Officer level, the Board will be informed of BLRP approvals via the monthly Executive Officer’s Report.

F. Any BLRP approved at the Executive Officer level may be petitioned to the Regional Water Board for its consideration.

8.3.2 PLAN ORGANIZATION
The BLRP shall contain the following elements in order to be deemed complete and approvable. Should an element not apply, the responsible party or parties should provide a brief explanation of its inapplicability.

A. Party Information and Legal Authority

1. The BLRP shall include the name of the responsible party or parties.

2. For a municipality, state, federal, or other public agency, the BLRP shall include the name of the duly authorized representative(s). A duly authorized representative is either a principal executive officer or ranking elected official, or a duly authorized representative of that person. A duly authorized representative is also a person who has responsibility for the overall operation of the subject facility or activity.

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3. The BLRP shall include a map of the responsible party’s or parties’ jurisdictional boundary along with the receiving waters and sub-watershed boundaries that overlap the jurisdictional boundary to facilitate planning, assessment, and collaborative decision-making.

4. The BLRP shall include a demonstration that the responsible party or parties or duly authorized representative(s) possess the legal authority to implement the actions contained in the BLRP, such as through ordinances, service agreements, or other legally binding procedures.

B. Sources

1. The BLRP shall include the sources of pathogens and indicator bacteria most likely causing exceedances of the WLAs or LAs within the jurisdiction of the responsible party or parties.

2. The sources shall be identified on a map.

3. The BLRP shall describe how sources are determined and characterized.

C. Description of Actions

1. The BLRP shall include a description of specific actions or treatment facilities that are being implemented or will be implemented to reduce the concentration of pathogens and indicator bacteria from identified sources.

2. The locations of the actions shall be identified on a map if appropriate. For example, it is appropriate to map new restroom facilities, but not appropriate to map public outreach efforts.

3. The BLRP shall include scientific and technical documentation used to conclude that the actions, once fully implemented, are expected to achieve compliance with the WLAs and LAs.

4. If the BLRP is a cooperative document among multiple responsible parties, the BLRP shall indicate which party is responsible for each action.

D. Schedule

1. The BLRP shall include a schedule for implementing the actions within the shortest time practicable.

E. Monitoring, Reporting, and Adaptive Management

1. The BLRP shall describe the frequency of periodic status reports, which shall be submitted to Regional Water Board staff. Reports shall include the status of the actions taken and to be taken, and any other necessary content.

2. The BLRP shall describe how, when, and where the effectiveness of actions will be monitored and assessed. The BLRP shall describe the frequency of effectiveness monitoring reports and assessments, which shall be submitted to Regional Water Board staff. The purpose of effectiveness monitoring is to understand if actions are improving pathogen and indicator bacteria concentrations (or loads) in the Russian River and its tributaries.

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3. All instream water quality data collected to satisfy the BLRP shall be collected in accordance with a Quality Assurance and Project Plan developed per U.S. EPA (2002c). Additionally, such data shall be uploaded by the responsible party or parties into the California Environmental Data Exchange Network.

4. The BLRP shall describe how the BLRP will be updated based on monitoring and performance assessments. It is expected that, in some cases, additional actions will be required if data from effectiveness monitoring shows exceedances of allocations.

It is expected that the BLRP will be assessed and revised at least every 5 years.

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CHAPTER 9

MONITORING
Monitoring provides data and information that allows for assessment and adaptive management. By monitoring discharges and receiving waters, it is possible to evaluate the progress toward completion of implementation actions. By identifying the actions that work best, monitoring data enables more efficient distribution of funds and resources and subsequent improvements in BLRPs and permit requirements. By assessing implementation actions and instream data, it is possible to evaluate the progress toward attainment of the TMDLs/loading capacities. And finally, monitoring data provides the feedback that indicates if modifications of the TMDL targets and water quality standards are necessary.

This chapter describes TMDL requirements and responsible parties for monitoring, assessment, and adaptive management, while also providing an umbrella stewardship approach for cooperation and collaboration in the Russian River Watershed.

9.1 STEWARDSHIP & THE RUSSIAN RIVER WATERSHED MONITORING PROGRAM There are many opportunities for cooperation and collaboration in regards to monitoring in the Russian River Watershed. Residents, recreators, cities, counties, state agencies, federal agencies, and other stakeholders have a vested interest and/or specific TMDL requirements to address sources of pathogens and indicator bacteria and monitor the effect of those actions. By forming a monitoring coalition to identify problems, develop and implement solutions, coordinate monitoring, evaluate progress, and make adjustments, more progress toward a healthy watershed can be made with less cost. These elements are keys to the concept of watershed stewardship.

Regional Water Board staff will work to form a Russian River Watershed monitoring coalition to help coordinate and conduct required monitoring. The watershed-wide monitoring program will be modeled on the Klamath Basin Monitoring Program and San Francisco Bay Regional Water Board’s Regional Monitoring Program. It will likely include:
 Coordinating instream sampling efforts to reduce duplication of efforts and costs  Coordinating sampling methods, protocols, and Quality Assurance/Quality Control requirements so data from multiple entities are comparable  Compiling and sharing data with possible upload of data to the California Environmental Data Exchange Network
 Assessing and interpreting data to inform load reduction actions  Reporting and sharing data and information with stakeholders and the public  Conducting regular meetings to share and discuss implementation activities, data results, research, and other information critical to water quality and the health of the Russian River Watershed
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9.2 MONITORING & REPORTING OF IMPLEMENTATION ACTIONS
As described in Chapter 8, dischargers and parties responsible for sources of pathogens and indicator bacteria are required to develop and implement a BLRP. The BLRP includes requirements to report the status of individual implementation actions to the Regional Water Board. Dischargers and responsible parties are also required to monitor, assess, and report on the effectiveness of their implementation actions required under a BLRP. The purpose is to understand if actions are improving pathogen and indicator bacteria concentrations (and loads) in the Russian River and tributaries. Regional Water Board staff will evaluate this information on a responsible-party-by-responsible-party basis to ensure implementation actions are executed as planned and on schedule, and are being maintained and working as expected. If this is not the case, staff shall work with responsible parties to revise the BLRP and use alternative implementation actions.

Regional Water Board staff shall compile the above information, assess progress and effectiveness on a watershed or sub-watershed scale, and provide a report on a regular basis, likely every five years. The report may be accomplished through an informational presentation to the Regional Water Board or as part of a larger stewardship report.

9.3 MONITORING & REPORTING OF TMDL ATTAINMENT
In order to assess changes in in-stream conditions and attainment of the TMDLs/loading capacities, indicator bacteria data shall be collected in mainstem Russian River and tributary sites.

The County of Sonoma, the County of Mendocino, City of Healdsburg, City of Sebastopol, and the City of Santa Rosa shall sample E. coli, Bacteroides, and fecal coliform bacteria concentrations at the mainstem Russian River beaches shown in Figure 9.1 and listed in Table 9.1 at least weekly from May 15 through September 30. The monitoring can be conducted by the monitoring coalition, or individually. All instream water quality data collected shall be collected in accordance with a Quality Assurance and Project Plan developed per U.S. EPA (2002c). Additionally, such data shall be uploaded by the coalition or individual into the California Environmental Data Exchange Network.

The Sonoma County Department of Health Services, Environmental Health and Safety Section currently conducts this monitoring at several of the beaches listed in Table 9.1. In past years, the Regional Water Board has provided funding and staffing. There may be future opportunities for the Regional Water Board and other stakeholders to partner with the counties to ensure this monitoring is funded and executed. Additionally, this monitoring effort may be used to satisfy effectiveness monitoring requirements in the counties’ BLRPs. The Regional Water Board’s authority to require this monitoring is found in section 13267 subdivision(b) of the Water Code.

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Table 9.1 TMDL Attainment Monitoring Locations
Responsible Party Russian River Beach Location
County of Mendocino
Russian River at Mill Creek Park Potter Valley
Russian River at Mariposa Swimming Hole Redwood Valley
Russian River at Vichy Springs Park Ukiah
Russian River at Mill Creek Park Ukiah
County of Sonoma
Russian River at Cloverdale River Park Cloverdale
Russian River at Veteran Memorial Beach Healdsburg
Russian River at Riverfront Park Windsor
Russian River at Steelhead Beach Forestville
Russian River at River Access Beach Forestville
Russian River at Sunset Beach Forestville
Russian River at Johnson’s Beach Guerneville
Russian River at Monte Rio Beach Monte Rio
Green Valley Creek at Martinelli Road and River Road Forestville City of Healdsburg Foss Creek at Matheson Street Healdsburg City of Sebastopol Laguna de Santa Rosa at Sebastopol Community Park Sebastopol City of Santa Rosa
Matanzas Creek at Doyle Park and Bethards Drive Santa Rosa Santa Rosa Creek at Highway 12 Santa Rosa
Santa Rosa Creek at Railroad Street Santa Rosa
The assessment of E. coli, Bacteroides, and fecal coliform concentrations and TMDL target attainment in tributary streams and creeks shall be assessed by Regional Water Board staff by compiling available instream data. High priority tributary sites to sample are listed in Table 9.1, although others may be appropriate. Available data may include effectiveness monitoring data submitted by the monitoring coalition or by individual responsibility parties under their BLRPs, data collected by other watershed stakeholders, and data collected by the Surface Water Ambient Monitoring Program and other Regional Water Board efforts if needed. These data could be shared and coordinated via a cooperative Russian River Watershed monitoring coalition.

Regional Water Board staff will assess progress toward attainment of the TMDLs/loading capacities on a watershed or sub-watershed scale, and provide a report on a regular basis, likely every five years. The report may be accomplished through an informational presentation to the Regional Water Board or as part of a larger stewardship report.

9.4 POST TMDL-ATTAINMENT OR NON-ATTAINMENT PROCEDURES
When reaches of the Russian River and/or its tributaries attain the TMDLs/loading capacities, it is assumed that wasteload and load allocations are attained in the watersheds, and the following procedures shall take place in those reaches. Should instream data again identify impairment after TMDL attainment, these procedures shall not apply.

1. Effluent limitations will remain in place.

2. Implementation actions already in place shall be maintained by the responsible party or parties.

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3. Implementation actions that are described in a BLRP but have not yet been put into place shall not be required.

4. Status reports shall no longer be required.

5. Effectiveness monitoring shall continue to ensure water quality does not degrade, although the monitoring and reporting frequency can be reduced if requested of the Executive Officer by the responsible party or parties.

If all sources identified in the BLRPs are reasonably controlled and the TMDLs/loading capacities are not met, then a revision of the TMDL, Water Contact Recreation Beneficial Use, or Bacteria Water Quality Objective may be appropriate.

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CHAPTER 10

CEQA ANALYSIS
To be developed.

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1. CHAPTER 11

ECONOMIC ANALYSIS
To be developed.

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2. CHAPTER 12

ANTIDEGRADATION ANALYSIS
To be developed.

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3. CHAPTER 13

PUBLIC PARTICIPATION SUMMARY
To be developed.

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4. CHAPTER 14

NINE KEY NONPOINT SOURCE ELEMENTS
To be developed.

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APPENDIX A

TYPES OF PATHOGENS & TYPES OF PATHOGEN INDICATOR BACTERIA A.1 TYPES OF BACTERIA
Pathogens most commonly identified and associated with waterborne diseases can be grouped into the three general categories: bacteria, protozoans, and viruses (U.S. EPA 2001).

A.1.1 Bacteria
Bacteria are microscopic unicellular organisms ranging from approximately 0.2 to 10 micrometers (µm) in length. They are distributed ubiquitously in nature, including the intestinal tract of warm-blooded animals. Many types of harmless bacteria colonize the human intestinal tract and are routinely shed in feces. In addition, pathogenic (diseasecausing) bacteria, such as verotoxigenic E. coli (including serotype 0157:H7), Salmonella, and Campylobacter, are present in the feces of infected humans and animals and can contaminate surface water and groundwater as a result of inadequate waste treatment or disposal methods. Many groups of intestinal bacteria, including the coliform and enterococcus groups, have historically been used as an indication that an environment has been contaminated with human sewage.

A.1.2 Protozoans
Protozoans are unicellular organisms that are present primarily in the aquatic environment. Of the 35,000 known species of protozoans, almost 30 percent are pathogenic. Pathogenic protozoans can occur in humans and animals where they multiply in the intestinal tract of the infected individual or animal and are later excreted in feces as cysts. Protozoan cysts do not reproduce in the environment, but are capable of surviving dormant in the soil and surface water for extended periods of time, which makes them a prominent public health concern.

Two waterborne protozoans of major public health concern are Giardia lamblia and Cryptosporidium parvum. The Giardia organism inhabits the digestive tract of a wide variety of domestic and wild animal species, as well as humans. Once shed in feces, Giardia cysts are frequently found in rivers and lakes. Infection by Giardia can result in giardiasis in humans, which is characterized by gastroenteritis, particularly among the young and elderly. Giardia is considered nonpathogenic in cattle because it is usually found in animals that have normal feces and no sign of disease. However, among the human population, giardiasis affects approximately 200 million people worldwide and is one of the most prevalent waterborne diseases in the United States. Cryptosporidium species are a group of parasitic protozoa that are recognized as pathogens of domesticated livestock, poultry, and wildlife and are readily transmitted to humans. Cryptosporidium oocysts are about 4-6 µm in diameter, slightly larger than bacteria, and relatively unaffected by conventional methods of wastewater disinfection, such as chlorination. Infection by Cryptosporidium can September 222026 Item 7
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A.1.3 Viruses
Viruses are obligate intracellular parasites, incapable of replication outside of a host organism. They are very small, ranging from 0.02 to 0.2 µm. Viruses that are of a public health concern are viruses that replicate in the intestinal tract of humans, and are referred to as human enteric viruses. Sewage overflows and improperly functioning sewage systems are considered to be primarily responsible for water contamination. Individuals can become infected through consumption of contaminated water, swimming in contaminated water, or through person-to-person contact with an infected person.

Symptoms of infection include vomiting and diarrhea, with the severity of disease and mortality increasing in older age groups. The most significant human enteric viruses include hepatitis A, rotaviruses, noroviruses, adenoviruses, enteroviruses, and reoviruses.

A.2 TYPES OF PATHOGEN INDICATOR BACTERIA
Several groups of intestinal bacteria have been used as indicators that a waterbody has been contaminated with human sewage and that pathogens are present. Most strains of pathogen indicator bacteria do not directly pose a health risk to swimmers and those recreating in the water, but indicator bacteria often co-occur with human pathogens and are easier to measure than the actual pathogens that may pose the risk of illness. It is impractical to directly measure the wide range of types of fecal-borne pathogens (bacteria, viruses, and protozoans) and the methods to detect human pathogens are characteristically expensive and inefficient, or may be not available.

E. coli bacteria, Bacteroides bacteria, and the microbiome community are used in the Russian River Watershed as indicators of pathogens. These indicators are described in Chapter 2.

Although total coliform, fecal coliform, and Enterococcus bacteria have been historically used as indicators, they do not indicate potential pathogen presence as well as E. coli bacteria or Bacteroides bacteria, and are not used for this TMDL project. More information on these parameters is found in this Appendix.

A.2.1 Total Coliform Bacteria
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A.2.2 Fecal Coliform Bacteria
Fecal coliform bacteria are a subgroup of total coliform bacteria found mainly in the intestinal tracts of warm-blooded animals, and thus, are considered a more specific indicator of fecal contamination of water than the total coliform group. Fecal coliform bacteria concentration criteria were initially recommended by U.S. EPA (1976) for assessing support of recreational use. However, since 1976, several key epidemiological studies were conducted to evaluate the criteria for effectiveness at protecting public health from water contact recreation (Cabelli et al. 1982; Cabelli et al. 1983; Dufour 1983; Favero 1985; Seyfried et al. 1985a, Seyfreid et al. 1985b) The studies concluded that the U.S. EPA (1976) recommended fecal coliform bacteria criteria had no scientific basis. As a result of the new information derived from epidemiological studies, the U.S. EPA (1986) changed the criteria recommendation to use the pathogen bacteria indicators of E. coli and Enterococcus bacteria, instead of fecal coliform bacteria.

In addition, detection of fecal coliform bacteria in recreational waters may overestimate the level of fecal contamination because this bacteria group contains a genus, Klebsiella, with species that are not necessarily fecal in origin. Klebsiella bacteria are commonly associated with soils and the surfaces of plants, so that areas with allochthonous organic debris may show high levels of fecal coliform bacteria that do not have a fecal-specific bacteria source.

A.2.3 Enterococcus Bacteria
Enterococcus bacteria are a subgroup within the fecal streptococcus bacteria group.

Enterococcus bacteria are distinguished by their ability to survive in salt water, and therefore more closely mimic more pathogens than the other indicators in marine environments. U.S. EPA (2012) recommends enterococcus bacteria concentration as the best indicator of human health risk in salt water for recreation.

U.S. EPA (2012) states that Enterococcus bacteria concentrations may also be used as an indicator of human health risk in fresh water. Similar to E. coli bacteria, the Enterococcus bacteria criteria are established for both the geometric mean and the STV for protection of water contact recreation. The criteria are based on epidemiological studies at U.S. beaches.

The studies enrolled participants at a number of beach study sites and followed them to compare incidence of illness between the exposed (swimmers) and unexposed groups.

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Concerns have been identified for application of the Enterococcus bacteria concentration criteria (U.S. EPA 2012) as an indicator of fecal contamination in freshwater. First, there is concern about applying the Enterococcus bacteria concentration criteria in freshwater when some Enterococcus bacteria can come from non-fecal sources. The criteria are based on epidemiological studies that found association between illness and Enterococcus bacteria concentrations in surface waters with known sources of human fecal waste, specifically Enterococcus faecalis and Enterococcus faecium. Most research has found that the bacteria species Enterococcus faecalis is found mostly in humans, dogs, and chickens, and may or may not come from other warm-blooded animals (Wheeler et al. 2002).

Enterococcus faecium is commonly found in production animals (Fisher and Philips 2003).

Enterococcus hirae is frequently found to originate from domestic animals (Devriese et al. 2002). However, sources of Enterococcus bacteria in many surface waters may also be from non-fecal, natural sources. Enterococcus mundtii and Enterococcus casseliflavus are associated with plant sources, for example (Ferguson et al. 2005; Ferguson et al. 2011).

Second, using Enterococcus bacteria concentrations to assess whether there is potential for sewage and human pathogens assumes that bacteria do not persist or regrow in the environment. Studies have shown that these bacteria persist in benthic sediment and can regrow when re-suspended into the water column. Hartel et al. (2005) found that Enterococcus bacteria survived desiccation and regrew in rewetted sediment. Sediment collected in the riparian habitat and from naturally occurring drain surface biofilms in fresh water urban streams were found to be significant reservoirs of Enterococcus bacteria (Roberts 2012). Anderson et al. (1997) found that a large portion of Enterococcus bacteria load in urban and rural waterways came from non-human sources, including large loads from senescing algae. Urban runoff samples have been found to contain relatively higher proportions of Enterococcus mundtii and Enterococcus casseliflavus suggesting runoff sources are associated with plant species (Ferguson et al. 2013). Bacterial growth of Enterococcus casseliflavus on drain surfaces has been found to serve as a chronic low-level source of Enterococcus bacteria measurements collected in urban runoff (Ferguson et al. 2013). These studies indicate that elevated Enterococcus bacteria concentrations in water samples might be due to instream conditions that lead to regrowth and not due to contributions from fecal matter. Thus, the source exposure assumptions used to develop the Enterococcus bacteria criteria may not be applicable to the sources found in the Russian River Watershed.

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Also, bacterial cultural methods for Enterococcus (e.g., the IDEXX Enterolert® or membrane filter methods) measure all species of the genus Enterococcus, including species that are not of fecal origin. False positive results would be unacceptable if the Regional Water Board uses these results as the basis for decisions regarding listing of waterbodies, compliance with water quality criteria, and compliance with numeric TMDL targets.

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California’s Wadeable Streams. Final Technical Report. California Water Boards. Surface Water Ambient Monitoring Program.

Palencia, L. and E. Archibald. 2013. Sonoma County Water Agency Watershed Sanitary Survey. Second Update. Final Report. November 2013.

Pitt, R. 1998. "Epidemiology and Stormwater Management." In Stormwater Quality Management. CRC/Lewis Publishers. New York, NY. As reported in (Schueler 2000).

Roberts, G.S. 2012. When Bacteria call the Storm Drain “Home”. Stormwater Journal for Surface Water Quality Professionals. May 2012. Santa Barbara, CA.

Schueler, T. 2000. Microbes in Urban Watersheds: Concentrations, Sources, & Pathways:

The Practice of Watershed Protection. Center for Watershed Protection, Ellicott City, MD.

Watershed Protection Techniques 3(1): 554-565.

Sercu, B. Van De Werfhorst, L.C., Murray,L.S. and P.A. Holden. 2010. Cultivationindependent analysis of bacteria in IDEXX Quanti-1 Tray/2000 fecal indicator assays.

Applied Environmental Microbiology, doi:10.1128/AEM.01113-10, American Society for Microbiology.

Seyfried, P.L., Tobin, R.S., Brown, N.E., and P.F. Ness, P.F. 1985a. A prospective study of swimming-related illness: I. Swimming-associated health risk. American Journal of Public Health 75:1068-1070.

Seyfried, P.L., Tobin, R.S., Brown, N.E., and P.F. Ness. 1985b. A prospective study of swimming-related illness: II. Morbidity and the microbiological quality of water. American Journal of Public Health 75:1071-1075.

Shanks, O.C., White, K., Kelty, C.A., Sivaganesan, M., Blannon, J., Meckes, M., Varma, M., and R.A. Haugland. 2010a. Performance of PCR-based assays targeting Bacteroidales genetic markers of human fecal pollution in sewage and fecal samples. Environmental Science and Technology 44(16):6281-6288.

Shanks, O.C., White, K., Kelty, C.A., Hayes, S., Sivaganesan, Jenkins, M., Varma, M., and R.A.

Haugland. 2010b. Performance Assessment PCR-Based Assays Targeting Bacteroidales Genetic Markers of Bovine Fecal Pollution. Applied and Environmental Microbiology 76(5):
1359–1366
Soller, J.A., Bartrand, T., Ashbolt, N.J., Ravenscroft, J., Wade, T., 2010. Estimating the primary aetiologic agents in recreational freshwaters impacted by human sources of faecal contamination. Water Research 44 (16), 4736e4747.

Sonoma County Department of Health Services (SCDHS). 2014. Fresh Water Quality Sampling: Russian River Beaches and Spring Lake Lagoon. Data downloaded on November 14, 2014 from http://www.sonoma-county.org/health/services/pdf/russianriver2014.pdf.

September 222026 Item 7
Peer Review Draft Staff Report
for the Action Plan for the Russian River Watershed Pathogen Indicator Bacteria TMDL References 165
Stoddard, J.L., D.P. Larsen, C.P. Hawkins, R.K. Johnson, and R.H. Norris. 2006. Setting Expectations for the Ecological Condition of Streams: The Concept of Reference Condition.

Ecological Applications 16(4), 2006, pp. 1267-1276.

Trial, W. et al. 1993. Bacterial Source Tracking: Studies in an Urban Seattle Watershed.

Puget Sound Notes 30:1-3. As reported in (Schueler 2000) Tyler, J. 2013. Personal Communication from James Tyler, Supervising Environmental Health Specialist with the County of Sonoma Department of Health Services to Steve Butkus (Regional Water Board Staff) on October 4, 2013.

U.S. Census Bureau (2010) Annual Estimates of the Resident Population. April 1, 2010.

Available at http://www.census.gov/2010census/popmap/ipmtext.php?fl=06 U.S. Census Bureau (2013). Annual Estimates of the Resident Population. July 1,2013.

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http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=bkm k
U.S. Department of Health, Education, and Welfare (U.S. DHEW). 1972. Manual of SepticTank Practice. Rockville, MD.

U.S. Environmental Protection Agency (U.S. EPA) 1976. Quality Criteria for Water. U.S. EPA, Washington, DC.

U.S. Environmental Protection Agency (U.S. EPA) 1986. Ambient Water Quality Criteria for Bacteria – 1986. Publication No. EPA440/5-84-002. U.S. EPA, Washington, DC.

U.S Environmental Protection Agency (U.S. EPA) 1999. Protocol for Developing Nutrient TMDLs. Publication No. EPA 841-B-99-007. Office of Water (4503F). U.S. EPA, Washington, DC.

U.S. Environmental Protection Agency (U.S. EPA) 2001a. Protocol for Developing Pathogen TMDLs. Publication No. EPA 841-R-00-002. Office of Water (4503F). U.S. EPA, Washington, DC.

U.S. Environmental Protection Agency (U.S. EPA) 2001b. EPA Requirements for Quality Assurance Project Plans. Publication No. EPA/240/B-01/003. U.S. EPA, Washington DC.

U.S. Environmental Protection Agency (U.S. EPA) 2002a. Method 1600: Enterococci in Water by Membrane Filtration Using membrane-Enterococcus Indoxyl-β-D-Glucoside Agar (mEI). Publication No. EPA 821-R-02-022. U.S. EPA, Washington, D.C.

U.S. Environmental Protection Agency (U.S. EPA) 2002b. Method 1603: Escherichia coli (E. coli) in Water by Membrane Filtration Using Modified Membrane-Thermotolerant Escherichia coli Agar (Modified mTEC). Publication No. EPA 821-R-02-023. U.S. EPA, Washington, D.C.

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Peer Review Draft Staff Report
for the Action Plan for the Russian River Watershed Pathogen Indicator Bacteria TMDL References 166
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U.S. Environmental Protection Agency (U.S. EPA). 2009. Review of zoonotic pathogens in ambient water. Publication No. EPA 822-R-09-002. USEPA, Washington, D.C.

U.S. Environmental Protection Agency (U.S. EPA) 2010. Report on 2009 National Epidemiologic and Environmental Assessment of Recreational Water Epidemiology Studies (NEEAR 2010 - Surfside & Boquerón). Publication No. EPA-600-R-10-168. U.S. EPA, Washington, DC.

U.S. Environmental Protection Agency (U.S. EPA) 2012. Recreational Water Quality Criteria.

Publication No. EPA 820-F-12-058. U.S. EPA, Washington, DC.

U.S. Food and Drug Administration (U.S. FDA) 2011. Guide for the Control of Molluscan Shellfish. National Shellfish Sanitation Program. U.S. FDA, College Park, MD. van der Wel, B. 1995. "Dog Pollution." The Magazine of the Hydrological Society of South Australia 2(1)1. As reported in (Schueler 2000).

Wexler, H.M. 2007. Bacteroides: the Good, the Bad, and the Nitty-Gritty. Clinical Microbiology Reviews 20(4):593-621.

Wheeler, A.L., Hartel, P.G., Godfrey, D.G., Hill, J.L., and W.I. Segars. 2002. Potential of Enterococcus faecalis as a Human Fecal Indicator for Microbial Source Tracking. J. Environ.

Qual. 31:1286–1293.

Wilhelm, S., S. Schiff, and J. Cherry. 1994. Biogeochemical Evolution of Domestic Wastewater in Septic Systems: 1. Conceptual model." Groundwater 32: 905-916.

Yakub,G.P., Castric, D.A., Stadterman-Knauer, K.L., , Tobin, M.J., Blazina, M., Heineman, T.N., Yee, G.Y. and L. Frazier. 2002. Evaluation of Colilert and Enterolert Defined Substrate Methodology for Wastewater Applications. Water Environment Research Vol. 74, No. 2 (Mar. - Apr., 2002), pp. 131-135.

Zhang, Z., and B.E. Johnson. 2010. HEC-HMS Development in Support of Russian River Watershed Assessment. Publication No. ERDC/EL TN-10-3. U.S. Army Corps of Engineers.

Army Engineer Research and Development Center, Vicksburg, MS. 1 September 222026 Item 7
CAHAN San Diego Alerts are intended for the use of public health, medical and laboratory professionals in San Diego County. This alert has been approved for reproduction and distribution to interested professionals. An online CAHAN San Diego application is available at http://www.cahansandiego.com for appropriate and interested individuals.

To: CAHAN San Diego Participants
Date: December 16, 2020
From: Epidemiology and Immunization Services Branch, Public Health Services Health Advisory: Leptospirosis outbreak in dogs
This health advisory informs physician and veterinary health providers about a recent outbreak of leptospirosis in dogs.

Situation
Since October 2020, thirty-four confirmed and presumptive cases of leptospirosis have been reported in the local dog population in San Diego County, primarily originating from the Hillcrest and Mission Hills areas. Several cases required hospitalization and at least one dog was euthanized. Although combinations of serology and polymerase chain reaction (PCR) testing of blood and urine were used to diagnose the dogs, the causative Leptospira species or serovar(s) involved are not known.

A major risk factor noted in the reported canine leptospirosis cases was boarding at kennels that allow dog-to-dog interactions. Two cases had no apparent links to boarding, one of which frequented dog parks. The kennels that were linked to cases notified the owners of all potential contacts of diagnosed cases and closed for at least two weeks for cleaning and disinfection.

No human cases from exposure to the infected dogs have been reported to date.

Key Messages
• Since October 2020, over 30 cases of canine leptospirosis have been reported in San Diego County, primarily originating from the Hillcrest and Mission Hills areas. • Boarding at kennels that allow dog-to-dog interaction is a major risk factor. • Leptospira spirochetes are shed in urine and transmission to other dogs and people can occur via direct contact with mucous membranes and broken skin. Contaminated soil, water, bedding, and food can act as fomites.
• No human cases from this canine outbreak have been reported; however, vigilance is recommended especially in those presenting with fever, myalgias, negative tests for SARS-CoV-2 and influenza, and history of ill canine contact. • Clinical signs in dogs and people are varied and can range from mild fever to renal, hepatic, pulmonary, gastrointestinal, and hemorrhagic syndromes. • Quadrivalent Leptospira vaccine is recommended for dogs, especially those boarding in kennels.

September 222026 Item 7
CAHAN San Diego Alerts are intended for the use of public health, medical and laboratory professionals in San Diego County. This alert has been approved for reproduction and distribution to interested professionals. An online CAHAN San Diego application is available at http://www.cahansandiego.com for appropriate and interested individuals.

Background
Leptospirosis is a disease caused by various species of spirochete bacteria called Leptospira. These bacteria can infect multiple species of mammals, including humans, dogs, rats, mice, raccoons, skunks, opossums, cows, and pigs. The bacteria are shed in the urine of infected animals (especially rodents) and may contaminate food, water, soil, or bedding. Organisms enter through direct contact with skin abrasions, mucous membranes, or drinking contaminated water.

Although leptospirosis in humans is a reportable disease in California, it is not reportable in animals, and the local incidence in canines is unknown. According to California Department of Public Health veterinary subject matter experts, outbreaks of canine leptospirosis are uncommon in the state and individual cases do not often come to the attention of public health. Only 29 canine leptospirosis cases were reported over a ten-year period in Los Angeles County, where veterinary laboratories began reporting cases in 2014.

In the United States, human leptospirosis is uncommon (100-150 cases annually) and usually occurs after recreational exposure to contaminated lakes or streams, not from canine contact. The disease more frequently occurs in Mexico and Hawaii and is considered one of the most widespread zoonotic diseases in the world, with over one million cases annually. Since 2010, there have been seven confirmed and probable cases in humans in San Diego County. No cases had onset in 2020 and two cases had onset in 2019, both acquired during foreign travel.

Canine leptospirosis has an incubation period of 5-15 days, or longer when associated with chronic infections. Dogs may have subclinical infection or present with signs that include fever, lethargy, vomiting, anorexia, and icterus. Illness can progress to renal, hepatic, pulmonary, hemorrhagic, and gastrointestinal syndromes, and death or chronic renal disease can result in untreated cases. Due to the zoonotic potential, protective clothing, especially gloves, are recommended when handling suspected cases. Cats are more resistant to infection but may exhibit mild disease.

Rodent control is an important tool to prevent leptospirosis in pets. In addition, a quadrivalent vaccine available for dogs is protective against the included or heterologous serogroups. The American College of Veterinary Internal Medicine (ACVIM) recommends annual leptospirosis vaccination for all at-risk dogs, especially those that frequently visit dog parks and nature areas or spend time outdoors, including the backyard. Infrequently, vaccine reactions can occur, but are thought to relate to other vaccine components and at a rate no different than with other vaccines. Additional diagnostic, treatment, and vaccination information on canine leptospirosis can be found in the references below.

Although human cases linked to direct contact with an infected dog are rare, care should be exercised by owners of infected dogs. The disease is not transmitted from human to human. The incubation period in people is 2-30 days but is usually 5-14 days. The disease presentation can be subtle with fever (classically biphasic) and myalgias (typically of the calves and lower back). Other symptoms may include headache, conjunctival suffusion, nausea, vomiting, diarrhea, abdominal pain, cough, and a skin rash.

More severe cases are associated with transaminase and creatinine elevation. Overlap with multiple potential presentations of COVID-19 (flu-like illness, weakness, vomiting, mental confusion) is notable.

Laboratory diagnosis in humans can include urine PCR (first seven days of illness) or IgM antibody testing (low sensitivity in the first week of disease). A fourfold rise in IgG titer greater than two weeks after initial infection is confirmatory. Treatment for the milder forms of infection in adults include oral September 222026 Item 7
CAHAN San Diego Alerts are intended for the use of public health, medical and laboratory professionals in San Diego County. This alert has been approved for reproduction and distribution to interested professionals. An online CAHAN San Diego application is available at http://www.cahansandiego.com for appropriate and interested individuals.

antibiotic regimens with doxycycline, amoxicillin, or azithromycin; more severe illness is treated with parenteral ceftriaxone or penicillin G. Infectious diseases consultation is recommended for complex cases. See the Centers for Disease Control and Prevention (CDC) Fact Sheet for Clinicians for more information on presentation, diagnosis, management and prevention.

Recommendations for Veterinary Providers
• Include leptospirosis in differential diagnoses of dogs with fever of unknown origin or acute renal disease that were at kennels or dog parks within the prior 30 days. • Use appropriate personal protective equipment and procedures while handling suspect and infected dogs; minimize urinary contamination of the environment, immediately decontaminate contact surfaces but do not pressure wash so aerosols are not created. • Isolate infected dogs (can be at home – educate owners of appropriate preventative measures) for at least one week while being treated with appropriate antibiotics to prevent spread. • Immunize at-risk dogs annually using a quadrivalent Leptospira vaccine, including those that board at kennels and frequent dog parks, streams, and lakes.
• Canine or other animal leptospirosis cases can be reported to the County Epidemiology Unit by calling 619-692-8499 during normal business hours or by sending an Animal Disease/Death Report Form by fax to 858-715-6458 or by secure email to [email protected].

Recommendations for Medical Providers
• Consider leptospirosis in differential diagnosis of individuals presenting with febrile illness (especially with myalgia, headache, conjunctivitis, skin rash, and/or abdominal symptoms) and an exposure history to an ill dog, especially one that has been kennel boarded. Fresh water swimming exposure is also an epidemiologic clue, especially as part of overseas travel. • Obtain appropriate laboratory leptospirosis confirmation and exclude infection with novel coronavirus and influenza. See attached CDC Fact Sheet for Clinicians for details. • Strongly suspected milder cases could be empirically treated with oral doxycycline, amoxicillin, or azithromycin.
• Human leptospirosis cases should be reported to the County Epidemiology Unit within one week by calling 619-692-8499 during normal business hours or by submitting a Confidential Morbidity Report by fax to 858-715-6458 or by secure email to [email protected].

Resources
• CDC Leptospirosis website (includes sections on pets and technical information for providers) • The Center for Food Security and Public Health Leptospirosis website • 2010 ACVIM Small Animal Consensus Statement on Leptospirosis: Diagnosis, Epidemiology, Treatment, and Prevention. 2011; J Vet Intern Med, Jan; 25(1):1-13 • Klaasen H, Adler B. Recent advances in canine leptospirosis: focus on vaccine development. 2015; Vet Med (Auckl), 6:245-260
• Brook W. Leptospirosis in Dogs. Veterinary Partner rev. 10/10/2019 • Moore GE, Guptill LF, Ward MP, Glickman NW, Faunt KK, Lewis HB, Glickman LT. Adverse events diagnosed within three days of vaccine administration in dogs. 2005; J Am Vet Med Assoc, 227(7):1102-1108.

September 222026 Item 7
CAHAN San Diego Alerts are intended for the use of public health, medical and laboratory professionals in San Diego County. This alert has been approved for reproduction and distribution to interested professionals. An online CAHAN San Diego application is available at http://www.cahansandiego.com for appropriate and interested individuals.

Thank you for your participation.

CAHAN San Diego
County of San Diego Health& Human Services Agency
Epidemiology and Immunization Services Branch
Phone: (619) 692-8499; Fax: (858) 715-6458
E-mail: [email protected]
Secure Website: https://member.everbridge.net/892807736722952/login Public-AccessWebsite: http://www.cahansandiego.com
September 222026 Item 7
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Fax 2-page form to: (213) 481-2375
5/2013
Species of Animal
Other Identifying Information
Breed Color
Sex Name
Age Animal/Case ID
Number of Animals Multiple (give number )
Livestock Wild animal
Zoo animal
Domestic Pet
Exotic
One
Type of Animal Involved

1. Animal Information
NO

2. Animal Owner (if applicable)
Name(s)
Address
City, ZIP
Telephone
Is it okay for Public Health to call the owner(s) to ask more aboutthe history? YES

3. Animal Location (where in community animal originated, if not same as owner) Name(s)
Address
City, ZIP
E‐mail

4. Reporting Veterinary Clinic or Shelter
Name of Veterinarian or Technician
Vet Clinic Name
Address
City, ZIP
Telephone Fax
Date of presentation

5. History
Date of onset of first symptoms
Date of death(s), if applicable
History (include vaccine history, if applicable):

County of San Diego Epidemiology Unit
Fax (858) 715-6458
[email protected]
Animal Disease/Death Reporting Form
(if the disease you are reporting has a specific form, ideally use that form instead) Date form completed
SUSPECTED DISEASE/CONDITION BEING REPORTED:
page 1 of 2
Fax form to: (858)715-6458 or emailto [email protected] 12/15/2020
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Fax 2-page form to: (213) 481-2375
5/2013

6. Clinical Findings
Highest Body Temperature
Physical Examination
Treatment Date Describe Treatment

1. 2.

3. 7. Treatment. Please describe treatment given, particularly antibacterial, antiviral, antifungal, antiparasitic.

8. Laboratory Results Please fax all laboratory results to us along with this form.

Animal Disease/Death Reporting Form, page 2
Normal
Yes No
Comments
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
General
Skin
Head Area
Respiratory
Cardiovascular
Abdomen/digestive
Reproductive/Urogenital
Musculoskeletal
Nervous
Lymph nodes
Other Yes No
Fax form to: (858) 715-6458 or email to [email protected] p. 2 of 2

9. Additional Comments. Please use an additional sheet if needed.

September 222026 Item 7
CS287535B January 30, 2018

LEPTOSPIROSIS
Fact Sheet for Clinicians
Background
• Leptospirosis is a disease that is caused by
spirochete bacteria in the genus Leptospira.

There are 10 pathogenic species, and more
than 250 pathogenic serovars.
• While leptospirosis occurs worldwide, it is
more common in tropical or sub-tropical
climates.
• It is estimated that more than 1 million cases
occur worldwide annually, including almost
60,000 deaths.
• In the United States, approximately
100–150 leptospirosis cases are reported
annually. Puerto Rico reports the majority of
leptospirosis cases, followed by Hawaii.
• Outbreaks of leptospirosis tend to occur
after heavy rainfall or flooding in endemic
areas, especially areas with poor housing
and sanitation conditions.

Transmission
• Leptospires are spread
by the urine of infected
animals (rodents, dogs,
livestock, pigs, horses,
wildlife).
• The bacteria can survive
for weeks to months in
urine-contaminated
water and soil.
• People can be infected through
» Direct contact with the urine or reproductive
fluids from infected animals
» Contact with urine-contaminated water
(floodwater, rivers, streams, sewage) and
wet soil
» Ingestion of food or water contaminated
by urine or urine-contaminated water
• Transmission occurs through mucous
membranes, conjunctiva, and skin cuts
or abrasions.
• Human-to-human transmission is very rare
but has been documented through sexual
intercourse and breastfeeding. Transmission
has also rarely occurred through animal bites.
• High-risk activities can include wading,
swimming, or boating in floodwater or
freshwater (rivers, streams, lakes) that
may be contaminated with animal urine.

Some actions like prolonged immersion
in, submerging head in, or swallowing
contaminated water can particularly
increase risk.
• Other high risk activities can include direct
contact with animals and activities that can
lead to skin abrasions and water or soil
exposure, such as clearing brush, trekking,
and gardening.

Leptospira spp. bacteria
September 222026 Item 7
Clinical Findings
• Incubation period is 2–30 days; most illnesses occur 5–14 days after exposure.
• Most infections are thought to be asymptomatic.
• Approximately 90% of clinical illnesses present as a nonspecific acute febrile illness, while approximately 10% progress to severe, potentially fatal illness with multi-organ dysfunction.
• Illness may be biphasic, with the patient briefly recovering from mild illness, but then developing more severe illness. • Symptoms can include fever, headache, myalgia (typically of the calves and lower back), conjunctival suffusion,
nausea, vomiting, diarrhea, abdominal pain, cough, and
sometimes a skin rash.
• Severe symptoms can include jaundice, renal failure,
hemorrhage (especially pulmonary), aseptic meningitis,
cardiac arrhythmias, pulmonary insufficiency, and
hemodynamic collapse. Combined renal and liver failure
associated with leptospirosis is referred to as Weil’s
disease.
• Leptospirosis during pregnancy can cause fetal
complications including fetal death or abortion.
• The case fatality rate for leptospirosis is approximately 5%–15% among patients with severe illness. Among
patients with severe pulmonary hemorrhagic syndrome,
the case fatality rate can exceed 50%.

Treatment
Early treatment may decrease
the severity and duration
of disease. In patients with
a high clinical suspicion of
leptospirosis, initiating antibiotic
treatment as soon as possible
without waiting for laboratory
results is recommended.
• For patients with mild
symptoms, doxycycline
is the drug of choice (100
mg orally, twice daily), if
not contraindicated. Other
options include azithromycin
(500 mg orally, once daily),
ampicillin (500-750 mg orally,
every 6 hours), amoxicillin
(500 mg orally, every 6 hours).
• For patients with severe
disease, IV penicillin is
the drug of choice (1.5
MU IV, every 6 hours), and
ceftriaxone (1 g IV, every
24 hours) can be equally
effective.

September 222026 Item 7
Laboratory Testing
• Antibodies for leptospirosis develop
between 3-10 days after symptom onset,
thus any serologic test must be interpreted
accordingly – negative serologic test results
from samples collected in the first week
of illness do not rule out disease, and
serologic testing should be repeated on a
convalescent sample collected 7-14 days
after the first.
• In the acute phase of illness, leptospires
are present in the blood (septicemia) for
approximately the first 4–6 days of illness.

Leptospires may be shed intermittently in
the urine after approximately the first week
of illness onset. Due to the transience of
leptospires in body fluids, a negative PCR
test does not rule out leptospisosis.
• It is best to submit as many specimen
types as possible. Recommended
specimens based on collection timing:
» Acute illness (first week): whole blood
and serum
» Convalescent illness (after first week):
serum +/- urine
Supportive Diagnostic Tests
• IgM-based commercial assays, such as
» ELISA IgM
» ImmunoDOT
» Lateral flow tests
• IgM assays are screening tests and
results should be confirmed using one
of the confirmatory methods below.

Confirmatory Diagnostic Tests

1. Microscopic agglutination test (MAT) — confirmatory serologic testing, available at CDC » Acute and convalescent serum samples collected 7–14 days apart is ideal. » If only one serum sample can be sent for testing, a sample collected after the first 7–10 days of illness is preferred.

2. Polymerase chain reaction (PCR) – available at CDC and some commercial labs Recommended samples
» Whole blood collected in the first week of illness (in the first 4 days is ideal) » Urine (collected at least 1 week after symptom onset is ideal) » Cerebrospinal fluid from a patient with signs of meningitis » Fresh frozen kidney and/or liver (if available from deceased patients) — kidney preferred

3. Pathology (immunohistochemistry) — available at CDC
» Formalin-fixed tissues: from the kidney (preferred), liver, lung, heart, or spleen Sample Submission
To submit specimens to CDC for confirmatory
testing, or if you have questions regarding
leptospirosis diagnostic testing, contact CDCINFO at 800-232-4636. Information on sample submission, including the sample submission form
(DASH Form 50.34) and shipping instructions can
be found at: http://www.cdc.gov/ncezid/dhcpp/
bacterial_special/zoonoses_lab.html.

Unless authorized to send directly to
CDC, all specimens should be sent
and processed through the state/
territorial public health laboratory.

September 222026 Item 7
Prevention
• The first line of leptospirosis prevention is to
avoid exposure.
• Avoid wading, swimming, bathing,
swallowing, or submersing head in
potentially contaminated freshwater (rivers,
streams) especially after periods of heavy
rainfall or flooding.
• Avoid contact with floodwater, and do not
eat food contaminated with floodwater.
• If exposure cannot be avoided, wear
appropriate personal protective equipment
(PPE) (rubber boots, waterproof coveralls/
clothing, gloves). Cover open wounds with
waterproof dressings.
• Treat unsafe or potentially contaminated
drinking water by boiling or chemically
treating.
• Keep rodent populations (rats and mice) or
other animal pests under control. Do not
eat food that may have been exposed to
rodents and possibly contaminated with
their urine.
• Some studies have shown that
chemoprophylaxis with doxycycline might
be effective in preventing clinical disease
and could be considered for people at high
risk and with short-term exposures.

Surveillance and Reporting
• Leptospirosis is a nationally notifiable
disease.
• The Council of State and Territorial
Epidemiologists (CSTE) leptospirosis case
definition can be found at: https://wwwn.
cdc.gov/nndss/conditions/leptospirosis/
case-definition/2013/. Please note the
difference between laboratory tests
that are “supportive” of a “probable”
case classification versus those that
provide evidence for a “confirmed” case
classification.
• Please report confirmed and probable cases
of leptospirosis to CDC via your state/
territorial health department using the CDC
leptospirosis case report form found at:
https://www.cdc.gov/leptospirosis/health_
care_workers/index.html
For more information about leptospirosis, call
1-800-CDC-INFO or visit www.cdc.gov/leptospirosis.

September 222026 Item 7
For more information visit cdc.gov/leptospirosis
To report canine and human cases, please contact the
County of San Diego Epidemiology Unit at (619) 692-8499, or [email protected]
Leptospirosis in Dogs
What is leptospirosis?
 A bacterial disease that affects humans and animals, including dogs.  Symptoms can vary and might include fever, decreased energy, lack of appetite, conjunctivitis, vomiting, and diarrhea, and might progress to more severe illness.

How is it spread?
 In the urine and birthing fluids of infected animals.  Dogs and people can be exposed to the bacteria through contact with contaminated urine, and urine-contaminated water, soil, bedding, or food.

What is the risk to dogs and people?
 The bacteria can be shed intermittently in the urine of infected dogs, including those that are not showing signs of being sick. It can be spread from dog to dog and, rarely, to people. The bacteria can be present in a dog’s urine for several months after recovery from illness if not properly treated with antibiotics. The shedding period can be shorter if the dog is treated with antibiotics.

Recommendations
• Infected dogs should be placed in floor-level cages, if possible, and housed away from high-traffic areas to limit urine-contamination. • Kennels should be clearly marked with warning label to alert people to the presence of a leptospirosis positive dog.
• Pregnant or immunocompromised staff should avoid contact with infected dogs.
• Staff should wear gloves when handling an infected dog, and additional protective equipment such as a face shield and a gown when cleaning up the dog’s urine.
• Staff should wash their hands after handling an infected dog, the dog’s urine, or anything that may have been contaminated by the dog’s urine. • Avoid pressure-washing areas where infected dogs are housed, to avoid aerosolization of bacteria.
• Infected dogs should be walked in a designated and easy to clean area, with hard, non-permeable surfaces, away from other dogs. • Disinfectants, such as a 1:10 bleach solution (1 part bleach, 9 parts water), should be used to clean areas where infected dogs are housed and where they have urinated.
• Normal laundering of urine-contaminated bedding and towels will inactivate the bacteria.
• Ask owners if their dog has been recently ill or been previously vaccinated against leptospirosis.
• Notify public health if staff that have been caring for infected dogs develop signs of illness.
12/15/2020
September 222026 Item 7
From San Diego Tribune, see article for inset:
“He said the QR code for off-leash incidents will allow the kind of fast responses needed to disincentivize such activity, which often leads to dog poop on fields where children play.”
Tuesday, August 11th 2026
e-Edition
Have a gripe about San Diego’s city
services? You’ll soon have new ways to
complain
The city is expanding the popular Get It Done tipster app and adding a special quick-response code for reporting
illegal off-leash dogs in parks.

A person walks their dog off leash at Rancho Bernardo Community Parkon Thursday, Nov. 16, 2023 in San Diego, CA. (Meg McLaughlin / The San Diego Union-Tribune) September 222026 Item 7
By DAVID GARRICK | [email protected]
PUBLISHED: August 11, 2026 at 5:00 AM PDT
It will soon become a lot easier to report broken drinking fountains, malfunctioning sprinklers, litter and other problems in San Diego city parks thanks to an expansion of the popular Get It Done tipster app.

City officials say they will also add a special quick-response code for reporting illegal off-leash dogs at parks the city operates jointly with local schools — a controversial problem that officials have struggled to address.

It will be easier to report parks problems — and get them fixed more quickly — because Get It Done now allows tipsters to report 46 specific kinds of park problems, instead of just submitting general parks complaints.

The new feature was added to the Get It Done website in February, and city officials say they will extend the feature to the better-used smartphone app in late summer or early fall. More than 75% of Get It Done complaints come from smartphones.he Wearables Data Your Doctor Actually Wants Another new feature is complaint-specific estimates for how long a fix is likely to take. City officials say this boosts transparency, sets reasonable expectations and may deter people from repeatedly issuing the same complaint.

The city hopes to use data from the new category-specific complaints to make the time estimates more precise and reliable, said Conrad Wear, a city program manager overseeing the parks portion of Get It Done.

He said the QR code for off-leash incidents will allow the kind of fast responses needed to disincentivize such activity, which often leads to dog poop on fields where children play.

The upgrades to Get It Done come just after the app marked its 10th anniversary this spring. Since 2016, Get It Done has received 3.5 million complaints, and the smartphone app has been downloaded 275,000 times.

September 222026 Item 7
City officials say the tool has streamlined the reporting of complaints from residents about homeless encampments, graffiti, illegal dumping, abandoned vehicles, flooding and many other problems.

The reports are highly accurate because residents take pictures of the problems they see, and the satellite technology in their phones provides the precise locations of the problems to officials.

The city receives more than 1,000 complaints a day, about 700 of them related to city parks.
“Get It Done has dramatically improved city operations over the past 10 years,” said Alex Hempton, the city’s chief innovation officer.

A new analysis of parks complaints since the start of 2025 found a sharp disparity between San Diego’s nine City Council districts, with the lion’s share coming from District 2 – Point Loma, Ocean Beach and Clairemont – and District 3, which includes downtown, Hillcrest and North Park.

The number of complaints from District 2 was 3,255 and the number from District 3 was 2,666. That compares to 664 from District 6, which includes Mira Mesa and University City, and District 8, which includes Logan Heights, Otay Mesa and San Ysidro.

The leading parks for complaints are Balboa Park, some shoreline parks, NTC Park at Liberty Station, Ward Canyon Neighborhood Park and Presidio Park.

The top parks complaints since the start of 2025, in order, have been graffiti, illegal dumping, malfunctioning sprinklers, tree hazards, off-leash dogs, litter, broken drinking fountains, damaged playground equipment, restroom problems, brush management and lighting issues.

Wear said providing estimates of repair times is a key move for the city.

On litter complaints, the city estimates five days. Other estimates are 20 days for sprinklers, 30 days for drinking fountains and 45 days for park equipment.

For restrooms, the city estimates five days for supply problems like lack of toilet paper but 15 days for repairs like a broken sink.

The average time to fix a problem overall is roughly 11 days, and half of all complaints are resolved within two weeks, Wear said.

September 222026 Item 7
September 22
2026 Item 7
Voice of San Diego

POSTED IN EDUCATION
School District Closes PB Park
Because of Dog Poop and Holes
by Jakob McWhinney, September 18, 2025
Crown Point Junior Music Academy / Photo by Adriana Heldiz Sign up for The Morning Report with all your must-read news for the day.

This story has been updated.

September 222026 Item 7
During the Thursday recording of the Voice of San Diego Podcast, San Diego City Council President Joe LaCava dropped some news:
“The joint use field at Crown Point Junior Music Academy is going to be closed to the public because of the dogs and the dog owners that have beaten up the field so badly that it is now unplayable and dangerous for the students.”
LaCava predicted more of San Diego Unified’s joint-use fields would close in the future.
“I think the school district is finally going to say ‘Enough is enough.

We cant risk the health of our students,’” LaCava said.

Samer Naji, San Diego Unified’s facilities spokesperson, said LaCava is right. The district has decided to keep the public out.

On Friday, after our story published, Naji wrote in an email that the closure was a temporary measure meant to allow the field to “return to a clean, healthy, and safe facility for students and families, and to deter future misuse of the facility by individuals who permit their pets to run off-leash.”
He said it wasn’t the first to be closed to the public because of dogs.

Joint-use facilities have been around San Diego for years. The district and the city celebrated many of the openings of the school fields to the public. They were a way to increase public parkland without building new parks. San Diego Unified and the city of San September 222026 Item 7
Diego have hundreds of such joint-use sports fields or swimming pools scattered around the region.

Because they tend to be surrounded by fences, though, the district’s joint-use fields in particular have become ideal destinations for San Diegans with dogs who ignore leash laws, Naji said. It hasn’t been so ideal for the district, though. Naji said many of its joint-use fields have been beset by dog poo and holes. “Primarily because of student safety, cleanliness or hygiene, we have many areas throughout the district where kids are
uncomfortable using their fields,” Naji said.

The district credits the city for starting to contract with the San Diego Humane Society a couple of years ago to try to rein in bad behavior, but Naji said it hasn’t been enough.
“It’s become untenable,” Naji said. “As a school district, we’re spending a lot of money on these fields. The city needs to uphold its end of the bargain, which is that these fields remain clean and safe for students.”
There have been some efforts to get ahead of the doodoo, though.

Naji said the district will begin warning residents if they are at risk of losing access to the park. Staff has been developing a stoplightesque warning system with colored markers at each of the jointuse fields.

If the marker on the field is green, it’s all good. Enjoy! If the district gets complaints about the quality of the field from the school’s September 222026 Item 7
principal, the marker will change to yellow. That means the field is at risk of closure. If the district receives another complaint, the marker will change to red. That will trigger a field closure, like Crown Point’s
Naji said he takes no pleasure in having to up the pressure. He loves the district’s joint-use program and thinks it’s one of the best in the country. Besides, these facilities should be enjoyed by everyone.

But, he said, visitors need to remember one thing: “The fields are for kids – human kids.”
September 222026 Item 7
Dog waste and human health risks
As much as dogs by tradition are humans’ best friend, their waste, just like humans, can carry pathogenic microorganisms and parasites that can transmit to humans, so called zoonotic infections.

The vast majority of dog owners are very responsible and pick up after their dog, but then there is the occasional one that doesn’t – mistakenly or not. Additionally, if a dog has a more serious digestive infection, that waste is impossible to be picked up but will seep into the grass and dirt. These bacteria and parasites survive in the environment for weeks to months, which is why a youth/kid play area and a dog park should not be a combined space but separated. Listed below are the most well known zoonotic infections that can occur from dogs to humans via the fecal-oral route, especially to children who play on the ground.

Parasites:

Dogs and cats with roundworms and/ or hook worms pass worm eggs in their feces. These eggs might contaminate a large area quickly and can survive for weeks (even years in areas such as parks and playgrounds).

Roundworms1: Once round worm eggs enter the body, they hatch into larvae and travel through the liver, lungs and other organs, most commonly without damage. However, serious cases can cause liver damage, nerve damage and blindness.

Hookworms1: Hookworm eggs hatch into larvae in the soil and cause skin infections if touched by bare feet or hands. Hookworm infection symptoms are red, itchy tracks in the affected skin, with the rare occasion of one particular sub-species finding its way into deeper tissue with serious damage to the intestine and other organs.

Giardia2.3: Despite the risks are smaller getting infected by Giardia from dog to human (most often not zoonotic), the so called giardia cysts that are formed in the intestine of an infected dog/individual are passed through the feces and can via its protective shell survive in the dirt for months. Once a zoonotic giardia cyst infects a human, the cyst breaks down, allowing the parasite to cause the symptomatic infection of severe intestinal discomfort and disease, weeks of painful stomach cramping, diarrhea, followed by dehydration and malnutrition. The infection also often leads to lactose intolerance for years, long after the infection is cleared.

Cryptosporidium4: Thick-walled cysts (oocysts) of the parasite is shed from the intestine to the environment through the feces of an infected dog. Due to its thick walls, it is extremely resistant to harsh environmental conditions and can survive for months outside the body. Infection occurs via ingestion from contact with infected material. Once inside the body, the thick wall dissolves and the parasite can start its lifecycle in the intestine of the infected individual. As few as 10 cysts of the parasite can cause illness. Symptoms include watery diarrhea, stomach cramps, nausea, vomiting, fever, dehydration and muscle aches.

September 222026 Item 7
Bacterial pathogens:

Non-typhoid Salmonella, such as Salmonella enterica, S. typhimurium, S. anatum, and S. enteritidis is shed via feces of infected dogs that sometimes are symptom-free5,6. These bacteria can be transmitted to humans via the fecal-oral route and cause severe intestinal illness including diarrhea (sometimes for months and sometimes bloody), stomach cramps and fever. Alarmingly, often these bacteria also carry antibiotic resistant genes.

Pathogenic E. coli 7,8 shed via feces from infected dogs can survive for weeks after deposition. The pathogen can be transferred to humans via the fecal-oral route and causes diarrhea, intestinal discomfort and dehydration.

Campylobacter jejuni,9,10 is shed via feces from infected dogs and can be transmitted to humans via the fecal-oral route. Symptoms include diarrhea (often bloody), vomiting, abdominal pain and fever.

Leptospirosis12 can transfer to humans via contact with infected dogs’ urine. It enters the person via cuts or skin abrasions upon contact with infected body fluids, such as urine. Symptoms include fever, muscle aches and can also lead to severe kidney and liver damage.

Antibiotic resistant Enterococci and Staphylococcus aureus, both opportunistic pathogens, can be shed via dog feces and cause severe wound infections in humans via contact with open wounds11.

References:

1. https://archive.cdc.gov/www_cdc_gov/parasites/resources/roundworms_hookworms.html

2. https://www.mayoclinic.org/diseases-conditions/giardia-infection/symptoms-causes/syc20372786

3. https://www.cdc.gov/giardia/about/index.html

4. https://www.cdc.gov/cryptosporidium/about/index.html

5. https://pubmed.ncbi.nlm.nih.gov/39547953/

6. https://www.cdc.gov/salmonella/signs-symptoms/index.html

7. Appl Environ Microbiol. 2015 Jun 19;81(14):4801–4808. doi: 10.1128/AEM.00705-15

8. https://pubmed.ncbi.nlm.nih.gov/32076735/

9. https://www.cdc.gov/mmwr/volumes/67/wr/mm6737a3.htm

10. https://dph.georgia.gov/epidemiology/acute-disease-epidemiology/foodborne-andwaterborne-diseases/campylobacter

11. https://pmc.ncbi.nlm.nih.gov/articles/PMC3564131/

12. https://www.gideononline.com/blogs/10-bacterial-infections-from-your-pets-how-to-stay-safe/ by Camilla Rang, PhD Microbiology and Molecular Biology September 222026 Item 7
September 22
2026 Item 7
1 Robert Silva
From: E K <[email protected]>
Sent: Friday, September 18, 2026 7:57 AM
To: City Clerk Mail Box
Subject: Article 7
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear City Clerk,
I am writing regarding the future of the off-leash dog area at Del Mar Shores Dog Park and my concern about the possibility that Del Mar could lose or substantially reduce what is effectively the City’s only year-round land-based offleash recreational area.

I believe that before any decision is made regarding the allocation of this limited public recreational space, the City should carefully consider the demographics of the residents who actually live in Del Mar, the estimated number of dogs in the community, the frequency with which different groups use the park, and the availability of comparable recreational facilities in the surrounding area.

According to the U.S. Census Bureau’s most recent American Community Survey estimates, Del Mar has approximately 3,903 residents and a median age of approximately 55.5 years. The same data estimates approximately 260 residents under the age of 10.

Del Mar therefore has a substantial older-adult population and a comparatively small population of young children. That should be an important consideration when deciding how scarce recreational land is allocated.

The number of dogs residing in Del Mar also appears to be substantially greater than the number of young children.

The U.S. Census Bureau estimates that Del Mar has approximately 1,855 households. San Diego County emergencyplanning documents use an estimate that approximately 48% of households have dogs, with an average of approximately 1.49 dogs per dog-owning household. Applying that methodology to Del Mar produces an estimated dog population of approximately 1,327 dogs.

This is, of course, an estimate rather than an actual license count, which is why I respectfully ask the City to obtain and disclose the current number of active dog licenses associated with Del Mar addresses. However, the estimate provides useful context regarding the potential number of residents who depend upon recreational facilities suitable for dogs.

The disparity in available recreational facilities is also noteworthy.

Within approximately five miles of central Del Mar, there appear to be more than 20 existing baseball, softball and T-ball diamonds available at numerous school and park locations throughout Del Mar, Solana Beach and Carmel Valley.

September 22, 2026 Item 7
2 By comparison, within approximately the same five-mile area, there appear to be only about three year-round landbased locations that provide officially authorized off-leash dog recreation. Shores Park is the only such land-based yearround off-leash opportunity within the City of Del Mar itself.

Even Delmar Shores Dog Park is not presently a conventional full-time dog park. The City currently allows off-leash use of the athletic field only during specified hours.

The frequency of use should also be part of this discussion. Del Mar residents and their dogs use Shores Park throughout the year as part of their daily routines. Residents can be seen there every day using the space for exercise, social interaction, and regular neighborhood recreation.

By contrast, as I understand the current use of the field, Little League occupies the space only periodically — for a limited number of hours, primarily on certain Sunday mornings during portions of the season. If that understanding is correct, the City is comparing a year-round, near-daily recreational use by local residents with a much more intermittent organized sports use.

That difference matters. The value of a public recreational space should not be measured solely by whether a particular organized activity can take place there, but also by how many days of the year the space serves the community and how consistently residents rely upon it.

The City itself has recognized the importance of the off-leash use. During the Shores Park Master Plan process, an offleash grassy area was identified as a Tier 1 priority amenity, and prior community outreach reflected support for a dedicated off-leash dog area separate from recreational turf.

I also believe it is important to distinguish between the number of children participating in Del Mar Little League and the number of those participants who are actually residents of the City of Del Mar.

Del Mar Little League serves families beyond the approximately 4,000 residents of the City itself. Accordingly, total Little League enrollment should not automatically be treated as equivalent to recreational demand generated by Del Mar residents.

I also believe the City should give meaningful consideration to the needs of Del Mar residents and property owners who directly support the City through local taxes, assessments, and other municipal revenues. When evaluating competing uses of limited public land, it is reasonable to distinguish between recreational demand generated by tax-paying Del Mar residents and demand generated primarily by participants who reside outside the City.

This is particularly relevant if a significant portion of Little League participation comes from families who do not live within Del Mar, while the residents who rely on Shores Park for daily off-leash recreation are members of the Del Mar community itself.

This is not an argument against Little League or recreational opportunities for children. Those uses are valuable. Rather, it is a request that the City evaluate competing uses of an unusually scarce public resource using objective data, frequency of use, actual resident demand, and the availability of alternative facilities.

The comparison deserves careful consideration:

Del Mar has approximately 260 residents under age 10.

Using San Diego County’s household methodology, Del Mar may have approximately 1,327 dogs.

There are more than 20 baseball, softball and T-ball diamonds within approximately five miles of central Del Mar.

September 22, 2026 Item 7
3 There appear to be only about three year-round land-based off-leash dog facilities within that same general area.

Shores Park is the only year-round land-based off-leash recreational opportunity within the City of Del Mar itself.

Del Mar residents use the off-leash area throughout the year and on a near-daily basis, while Little League use appears to be limited to comparatively short, periodic blocks of time during the season.

For many Del Mar residents, particularly older residents, walking and exercising a dog is not merely a pet-related activity. It is a regular source of outdoor exercise, community interaction and social connection.

Before the City approves any plan that would eliminate or materially reduce off-leash dog recreation at Shores Park, I respectfully request that the City obtain and make publicly available:

1. The current number of active dog licenses associated with addresses within the City of Del Mar.

2. The current number of Del Mar residents by age, particularly ages 5–9 and 10–14.

3. The number of current Del Mar Little League participants whose primary residence is actually within the City of Del Mar.

4. The actual number of days and hours per year that Little League or other organized baseball programs use Shores Park.

5. Any available usage data regarding the number of residents using the Shores Park off-leash area.

6. An inventory of baseball and softball diamonds within approximately five miles of Del Mar, together with an inventory of dedicated year-round off-leash dog facilities within the same area.

These figures would allow the City Council and the community to evaluate the Shores Park Master Plan based on measurable community need and actual patterns of use rather than assumptions about recreational demand.

I respectfully urge the City to preserve a meaningful, dedicated, year-round off-leash dog area at Shores Park as part of any final master plan.

Thank you for your consideration. I would also appreciate having this correspondence included in the public record regarding the Shores Park Master Plan.

Sincerely,
Evan Kuester
Del Mar Resident
Evan Kuester - Artist - Designer - Engineer
https://evan-kuester.squarespace.com
September 22, 2026 Item 7
1 Robert Silva
From: Brad Becker <[email protected]>
Sent: Friday, September 18, 2026 9:27 AM
To: City Clerk Mail Box
Subject: Red Dot-Winston Master Plan
Attachments: PastedGraphic-2.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Hi Im in strong support of the Shared field with dog park and kids baseball or whatever sport.The size of the dog park matters and is a huge asset to the community.

Thanks
Brad Becker
152 8th st
Del Mar ca 92014
Brad Becker
President
687 S. Coast Highway 101, Suite 233
Encinitas, CA 92024
© 858.395.4075

[email protected]
September 22, 2026 Item 7
1 Robert Silva
From: Katharine L. <[email protected]>
Sent: Friday, September 18, 2026 9:44 AM
To: City Clerk Mail Box
Subject: 9/22 Meeting - #7 Agenda Item
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Hello, I'm writing to support the dog park integration into the new plan for Shores Park. The dog park is an integral part of the Del Mar community. Since getting a dog in late 2025, I've been at the park weekly, getting to know my community, letting the dogs play and enjoying the gorgeous view. Everyone at the park holds one another accountable to clean up after our pets.

The park is especially necessary during the summer when the rules on the beach change. The limited sidewalks throughout Del Mar make it scary to walk my dog (though I still do) and having an open area for her to run each day is a must.

Parks create community and I encourage you to vote to allow the continued shared use of the Shores Park.

Thank you,
Katharine LiMandri
September 22, 2026 Item 7
1 Robert Silva
From: Buck <[email protected]>
Sent: Friday, September 18, 2026 9:48 AM
To: City Clerk Mail Box
Subject: Master Plan for Shores Park
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Regarding item 7 on the city council meeting agenda:

My wife Millicent "Penny" Abell and I strongly support the Master Plan for Shores Park.

Julian L "Buck" Abell
351 Serpentine Drive
September 22, 2026 Item 7
1 Robert Silva
From: Patti Passov <[email protected]>
Sent: Friday, September 18, 2026 9:48 AM
To: City Clerk Mail Box
Subject: Shores Park
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Please approve this plan. We need this
Patti
Sent from my iPhone
September 22, 2026 Item 7
1 Robert Silva
From: Patty O' Sullivan <[email protected]>
Sent: Friday, September 18, 2026 11:59 AM
To: City Clerk Mail Box
Subject: dog park
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Hello- My name is Patty O'Sullivan and I (with my dog Jack) are long time users of the dog park at the Winston school field. I was encouraged to hear last month that the dog park will be left to the same area and times.

Apparently this Tuesday night there is a meeting for further discussion. I would like to make it known that I would like the earlier decision to stand and allow the same hours and days for the dog park to be unchanged. I will try to make it Tuesday night but wanted my opinion known. Thank you- Patty 858. 922-3514 September 22, 2026 Item 7
1 Leslie Carrillo
From: Janet Wilson <[email protected]>
Sent: Saturday, September 19, 2026 2:18 PM
To: City Clerk Mail Box
Cc: Tracy Martinez; Terry Gaasterland; John Spelich; Dan Quirk; Janet Wilson Subject: City Council Meeting - Item 7 – Shores Park: Design, Restrooms, and Community Building Parking
Follow Up Flag: Follow up
Flag Status: Flagged
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Dear City Council,
I appreciate all the hard work and time the Shores Park Advisory Committee put into their recommendation.

I attended several Shores Park meetings, and a disproportionate amount of time was spent debating shared use of the field. As a result, I believe the other parts of the park did not get the committee’s full attention. I expect Tuesday’s City Council meeting will be more of the same. The shared-use issue must be settled so you can focus on the rest of the design, including the lower park area and community building.

Lower Level
The lower level needs a restroom so parents don’t have to gather up all their children and head uphill every time one needs the bathroom. Equip the children’s playground, but decide on additional equipment later because this is a small park, and what seems like a good addition now might not make sense later. See how people use the park and then expand the equipment.

Transition Between Lower and Upper Areas
The sunset decks are fantastic, and I’d like to see more of them. All the pathways and little niches along the hillside make the design feel cluttered (and look expensive), but a small stage (similar to the corner at L'Auberge) with seating terraced into the slope would make good use of the hillside.

Access
Add a crosswalk on Camino del Mar at 8th Street or Wesley Way.

Community Building and Associated Parking
Parking is an ongoing challenge in Del Mar. I expect the new Community Building will become a busy hub. It is intended to serve Community Connections, the Del Mar Foundation, the Historical Society, and possibly other community organizations, but its day-to-day use is still defined only by generic bubbles.

September 22, 2026 Item 7
2 The new building was placed, then moved, then moved again. Each time, parking was squeezed into whatever space was left. Currently, the plan shows 19 spaces next to the building.

Currently, the plan is for Staff to meet with building users to refine the floor plan after Council gives direction. It doesn't make sense to approve parking before understanding how the building will be used.
 How many individual offices or workstations are planned?  How many employees will work there on a typical day?
 Will any first-floor space be used for offices or staff work areas?  How many people will the building accommodate during simultaneous programs, meetings, or events?
Those answers will help guide how much adjacent parking is needed and help determine where the building should be located. Also, how will those spaces be managed? Employees and general park users could fill the convenient spaces before seniors, program participants, instructors, and visitors arrive.

Parking needs should be based on understanding how the building will be used and how many people will be there at the same time. Right now, the cart is before the horsepower! Thank you,
Janet Wilson
September 22, 2026 Item 7
1 Leslie Carrillo
From: Janet Wilson <[email protected]>
Sent: Saturday, September 19, 2026 3:50 PM
To: City Clerk Mail Box
Cc: Dan Quirk; Terry Gaasterland; Tracy Martinez; John Spelich; Janet Wilson Subject: City Council Meeting - Item 7 – Shores Park: Shared-Use Field Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear City Council,

I support retaining the existing shared-use field in the final Master Plan, as the advisory committee recommended in a 5–2 vote.

I heard comments during one meeting that the “dog people” weren’t compromising or “giving up” anything. That is not true. Restrictions were introduced back in 2012, and the off-leash time has been limited to about 27 hours a week (2½ hours each morning and three afternoons from 3:30 p.m. until dusk), depending on the season. I’d say that was a compromise, and although owners initially opposed the restrictions, limiting the hours had an unexpected benefit: it brought people together. It is a closeknit community, and I believe limiting the hours has also helped preserve the grass.

The “dog people” have embraced the restrictions and aren’t asking for anything more, except I think they would like a dog fountain!
Shared-Use Field - A 13-Year History of Success

In December of 2012, after a successful trial of the shared-use field concept, Council unanimously adopted Ordinance 875.

In 2015, staff reported good maintenance and few complaints, and Winston School supported offleash dog use.

Council unanimously adopted Ordinance 910.

In 2020, staff again reported good maintenance and few complaints, and Winston School supported off-leash dog use.

Council unanimously adopted Ordinance 974.

In the 2024 review, staff identified concerns about some owners staying past 8:30 a.m. or using the field during unauthorized midday hours. However, staff described complaints and violations as “infrequent” and said dog owners generally kept the field clean. Staff also reported that new fencing and three access gates had recently been installed to fully enclose the field and improve safety for all users. In the staff report, staff committed to increased patrols, enforcement, and updated signage to address use outside the designated hours.

September 22, 2026 Item 7
2 Council unanimously adopted Ordinance 1005, continuing shared use.

Shared-Use Field - Concerns

I attended several Shores Park advisory committee meetings and heard that fencing and locking the gates largely resolved concerns about use outside the designated hours.

The other concern is dog waste. Children deserve a clean place to play, and dog owners are responsible for picking up after their dogs.

When I’m at the park, owners consistently point out dog dirt and help each other pick it up. Any waste left behind needs to be cleaned up, and owners who fail to pick up should face enforcement. I’m also wondering if the grass watering schedule could be coordinated with the end of off-leash hours (which may also help chase off time offenders).

And keep in mind that once the lower park is developed, there will be both a children’s playground as well as a large grassy, dog-free lawn to play on.

Shared-Use Field - Size (0.86 acre)
The field is 37,500 square feet, or about 0.86 acre. I normally see 10–15 dogs on the field, sometimes 20 or more!

The American Kennel Club’s Establishing a Dog Park in Your Community says an ideal dog park should include “one acre or more of land.” One acre is 43,560 square feet.

AARP’s Dog Park Details and Design recommends about one to five acres, explaining that smaller spaces can become overcrowded.

Our field is smaller than those recommendations.

Making it any smaller, when it already supports a very large and active community of dogs and their owners, doesn’t make sense.

Please retain the existing shared-use field at its current size. Address any violations through enforcement. Shared use makes sense because park space is limited, and the lower-level dog-free lawn and children’s play area will give families another option.

Thank you,
Janet Wilson
September 22, 2026 Item 7
1 Leslie Carrillo
From: Kathy Ellis <[email protected]>
Sent: Sunday, September 20, 2026 9:54 PM
To: City Clerk Mail Box
Subject: red dot: Shores Park Comments
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Mayor and Members of the Del Mar City Council,
I am writing again to respectfully ask the City Council to reject ANY proposal that would permanently continue or expand the practice of using the same recreational turf at Shores Park as both an off-leash dog area and a children's athletic/recreational field.

This is not an argument against dogs or against providing Del Mar residents with a safe and appropriate place for their dogs and the owners social time. I support providing A DEDICATED DOG AREA. My concern is the decision to use the same physical playing surface for dogs and children at different times.

The City's own September 8, 2025 Shores Park Master Plan staff report provides compelling reasons for separating these uses. The report states that a dedicated, fenced/secure off-leash dog area was recommended by the City's self-insurance Joint Powers Authority and that separation is important to the health and safety of park users. The report specifically identifies URINE, FECES, HOLES, and grass wear caused by dogs as risks to human users!
That finding should not be overlooked!!
Children use recreational fields differently from adults. They sit, fall, slide, kneel, place their hands on the ground, and frequently come into contact with the soil and grass. Young children are also more likely to touch their faces or mouths while playing. Even with responsible dog owners like myself, and regular waste removal, it is unrealistic to assume that we remove every trace of dog waste and contamination before children use the same surface.

There is also a broader question of consistency in Del Mar's approach to public recreation. The City already prohibits dogs from the children's Tot Lot and adjacent grass area at Powerhouse Park.Del Mar has therefore recognized that children's recreational areas warrant protection from dog activity.

Why should a children's athletic field at Shores Park be held to a different standard? Would you want your grandchildren sliding into bases on the baseball field that every day I see dogs pee all over? Do you want your granddaughter practicing her cartwheels where my 100 pound dog just had loose stool that I cannot possibly clen completely up?
I respectfully ask the City Council to adopt the safer and more responsible solution:

September 22, 2026 Item 7
2 Provide a dedicated, fenced off-leash dog area that is physically separated from the family athletic and recreational fields.

This approach places each use where it can be managed safely and appropriately.

And if you go forward with approval of shared use, I request in writing that the City provide the public with clear answers to these questions:

1.) What sanitation and disinfection procedures are required between off leash dog use and families athletic/recreational use?
2) Who is responsible for inspecting the field for feces, holes, urine contamination and damaged grass? 3) What specific standard determines when the field is considered safe for children following dog use? 4) Has the City conducted any assessment of potential bacterial or parasitic contamination of the grass and soil at Shores Park?
4) What liability concerns has the City's self-insurance JPA identified regarding shared use? 6) Why should a seperate dog area not be the preferred solution when City staff has already identified separation as the safer approach?
The City has an opportunity to design Shores Park thoughtfully for the long term rather than continuing a poor arrangement simply because it has been used that way in the past and certain members of this community are thinking of their own convenience and not the families and children that live here or visit our town.

Please put children's health and safety first and approve your plan for a seperate, dedicated dog area.

Thank you for your consideration and your service to our community.

Dr. Donald and Katherine Ellis
11th Street, Del Mar
[email protected]
858755-6755
--
Katherine Ellis
September 22, 2026 Item 7
1 Leslie Carrillo
From: Joy Ehrenfeld <[email protected]>
Sent: Sunday, September 20, 2026 5:43 PM
To: City Clerk Mail Box
Cc: Tracy Martinez; John Spelich; Terry Gaasterland; Dan Quirk Subject: Red dot-City Council Sept 22, 2026-Item #7
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Hello Mayor Martinez, Deputy Mayor Spelich and Council Members Gaasterland and Quirk, I’d like is to see the Community Center Building rebuilt on Expansion Lot A at the Civic Center Complex at 11th St and CDM. This is the separate lot that Jim Watkins wanted designated for a fine dining restaurant.

If we did this we would then have room on the upper level of the Shores Park for a very large dog park. Del Mar desperately needs a dedicated dog park.

If you do decide to continue with a shared field, which I think is a bad idea, please try something new. In San Diego on their joint-use sports fields they have initiated a new Pilot program.

It’s a color-coded system:

Begin with a "Green Status” on the baseball field and if there is a reported dog waste within the first 30 days, move from “Green" to “Yellow Status”. A second dog waste incident during the next 30 days and the field moves to “Red Status" and the field is then closed to the public for 15 days. After that the field will reopen in “Yellow Status” and return to “Green” if no additional incidents are reported for 30 consecutive days. Continued violations may result in subsequent closures of 30 and then 60 days.

These changes would give a huge incentive for dog owners to obey the rules and would go a long way to improving the conditions for the children who use the field.

Please read the article below about this program and please consider trying this if you do decide to stick with the shared field!
Sincerely,
Joy Shadle Ehrenfeld
220-10th Street
September 22, 2026 Item 7
2 City, SDUSD begin pilot program to reduce dog waste on joint-use fields
By City News Service
Published August 11, 2026 at 8:40
The San Diego Unified School District and city of San Diego on Monday launched a color-coded signage system at three district locations aimed at keeping joint-use fields clean, safe and available to students and the public.The fields, open to the public during non-school hours, are popular for recreation, including dog walking and play. However, school staff said some dog owners do not clean up after their pets, creating an unsanitary situation.

The new color-coded system, which is being implemented as a pilot program, could result in a field being temporarily closed to the public for 15, 30 or 60 days, depending on field conditions and the amount of dog waste. Signs will indicate whether a field is open, at risk of closure. "The joint-use program benefits our communities by providing increased access to outdoor space, especially in communities that lack traditional park space," said Andy Field, director of the Parks and Recreation Department. "We are asking the public to work together to keep these fields clean and safe for each other, our pets and for the school children who play and exercise there each day." The city and school district have 96 joint-use fields, which are typically constructed by SDUSD and maintained by the city.

Beginning Monday, the first day of classes at most SDUSD campuses, three joint-use fields at Pacific Beach Middle School, Birney Elementary School and Franklin Elementary School will begin in "green status," meaning they remain open for public use.

According to the city, one reported incident of dog waste within a 30-day period will move a field from green to yellow status, indicating that it is at risk of closure. A second incident during the same 30-day period will move the field to red status and result in a 15-day closure.

After the closure, the field will reopen in yellow status and return to green if no additional incidents are reported for 30 consecutive days. Continued violations may result in subsequent closures of 30 and then 60 days.

September 22, 2026 Item 7
3 "The city's goal is to keep joint-use fields open and available to the public," a city statement read. "The partnership with SDUSD expands recreational opportunities, particularly in communities where traditional park space is limited. These sites also advance SDUSD's goal to develop quality schools in every neighborhood that provide resources and support the needs of the communities they serve." The pilot program could expand throughout the city if it proves successful.

Pet owners looking for places where dogs can exercise off-leash can use more than 20 off-leash dog areas throughout the city. To report off-leash dog violations, residents can use the Get It Done app.

September 22, 2026 Item 7
1 Leslie Carrillo
From: Barbara Aufiero <[email protected]>
Sent: Monday, September 21, 2026 6:11 PM
To: City Clerk Mail Box
Cc: Barbara Aufiero
Subject: Shores Park Design Plan
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear City Council,
As a Del Mar resident who lives directly across the street from The Winston School, I support the Shores Park design plan that includes the following:
● Joint Athletic Field/Dog Park – I believe the concern regarding potential dog-to-human disease transmission can be addressed through appropriate monitoring and documentation of any illness or disease incidence. As a dog owner, I have witnessed something very special when Del Mar’s dogs come together to play on this spacious field. The benefit extends beyond the park itself: when dogs regularly meet and socialize, they become familiar with one another, which can contribute to friendlier interactions and fewer conflicts when encountering each other throughout the community. ● Playground – While Del Mar’s young children already have access to a playground at Powerhouse Park, I do not object to adding a second playground at Shores Park, provided that it does not come at the expense of the dog park.
●Community Building Parking Lot – As a resident of 9th Street, I strongly prefer a plan in which the parking lot is not located along 9th Street. If that is not possible, I would support the smaller parking lot option, tucked away from 9th Street and buffered by attractive green landscaping. An asphalt parking lot prominently visible from 9th Street would detract from the neighborhood’s curb appeal and the character of the surrounding area.

Thank you for considering the perspective of a nearby resident and dog owner as you evaluate the Shores Park design.

Respectfully submitted,
Barbara Aufiero
September 22, 2026 Item 7
1 Leslie Carrillo
From: [email protected]
Sent: Tuesday, September 22, 2026 11:54 AM
To: City Clerk Mail Box
Cc: [email protected]
Subject: Red Dot ~ Shores Park Master Planning
Attachments: Shores Park Red Dot for Susan Maronde.docx Follow Up Flag: Follow up
Flag Status: Completed
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

I have never submitted a red dot so forgive me if I did something incorrectly. My address is 704 Nob Avenue, Del Mar.

Susan L Maronde
(858)922-0043
September 22, 2026 Item 7
Shores Park Layout – Please Reconsider the Playground Location My name is Susan Maronde and I live at 704 Nob Avenue. I have been a Del Mar resident for 25 years and my husband for 30 years. We live just blocks from Shores Park, our son grew up playing Del Mar Little League, and we have had several dogs over the years. I currently serve on the City’s Parks & Recreation Committee, so feel particularly invested in the Council’s decision regarding the Shores Park layout.

I strongly urge the City Council to reconsider placing the children’s playground in the lower area of the park. From both personal experience and a practical perspective, I believe the current layout creates several concerns:
 The playground should be located where families can easily access the restrooms. As a parent, I remember how important it was to be able to quickly get children to the restroom. Placing the playground as far away from the restrooms as possible does not seem practical or family-friendly.
 The playground should allow siblings to safely play while other children participate in sports. When my son played baseball, I clearly remember younger siblings safely playing on the adjacent playground while parents could keep an eye on everyone. That proximity was an important part of making the park work for families. The proposed layout appears to separate the playground from the baseball fields in a way that could make it much more difficult for parents to supervise children participating in different activities.
 Children and dogs should not share the same play area. I have personal experience with this issue. My son once stepped in dog feces while playing on the baseball field.

Combining children’s play areas with spaces where dogs are allowed creates an avoidable health and safety concern. Children’s playgrounds and dog areas should be clearly separated.

I also want to clarify an important point regarding the Parks & Recreation Committee. As a committee member, I understand that the committee did not take a formal vote or poll to determine how our representative would vote on the Shores Park layout. Therefore, the vote by our representative in support of the current plan should not necessarily be interpreted as reflecting the position of the entire committee. The committee may ultimately have supported the proposal, but that determination was never made through a vote. I personally would have voted against the current layout.

Shores Park should be designed around the way Del Mar families actually use the park— with safety, accessibility, supervision, and the needs of children at the center of the decision.

I respectfully ask the City Council to take another look at the proposed layout and, in particular, reconsider the placement of the children’s playground in the lower area of the park. A thoughtful adjustment now could make Shores Park a safer, more functional, and more familyfriendly resource for Del Mar for many years to come.

September 22, 2026 Item 7
1 Robert Silva
From: Laura DeMarco <[email protected]>
Sent: Tuesday, September 22, 2026 2:38 PM
To: City Clerk Mail Box
Subject: Item 7: Opposition to Shores Committee Masterplan draft Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

RE: Shores Park Draft Masterplan
Dear City Council Members and Staff,
The only flat grassy playing field for the children and athletes of Del Mar and the Winston School cannot continue to be used as a dog park. Furthermore, Shores Park recreational space needs be expanded, not encroached upon by the proposed new parking lot or a new building not used for school use based on the following:
1) The Kerckhoff family gifted the Shores School property in January 1946 to the Del Mar Union School District (DMUSD) with the explicit deed restriction “for school purposes only” to serve the children of Del Mar. The school’s recreational facilities included a playground, blacktop sports court for basketball and other sports, and the only flat grassy playing field in Del Mar, the founding field of Del Mar Little League. Notably, DMUSD never allowed dogs on the Shores campus and playing fields nor does it currently allow them on any of its nine remaining campuses. 2) DMUSD trustees cited honoring the Kerckhoff deed restriction and continuation of the Winston School lease for why the 5.4 acre school site was sold to the city of Del Mar for a discounted price of $8.5M. The purchase agreement was signed on July 30, 2007 and escrow closed on May 21, 2008. 3) The Kerckhoff deed restriction was also cited in the following August 2007 Del Mar city council resolution: “The purpose of the acquisition is to preserve the current open space and recreational uses of the property, including the ball field, and to permit the continued operation of the Winston School in keeping with the original dedication.” 4) The Winston School spearheaded the Shores fundraising campaign with $3M, including a $1M matching gift that was used to raise another $2.5M from the community. Donors checked one of two boxes in their donor form when they made their donation: Winston School or Recreational Open Space. In addition to the donor form and August 2007 city council resolution, the donor packet included a schematic showing a separate dog park so the playing fields were only for children, their families, sports teams, athletes, picnickers, and the summer cinema series. This was necessary to counter the objection of lead donors who refused to fund an “$8.5M dog park!” I urge the city council to: 1) eliminate shared use for dogs on Del Mar’s only flat grassy playing field that can used for organized youth sports and the Winston School; 2) create a separate dog park; 3) restore the only playground in the densely packed southern section of Del Mar where there is little to no yard space; 4) expand Shores street parking by covering the deep, dangerous ditches lining both sides of 9th Street and creating diagonal parking on 9th and Stratford; 5) pursue joint use of Winston’s renovated facilities which includes a state of the art auditorium; multi-station culinary kitchen; physical therapy/yoga workout room; art and computer studio; meeting rooms and classrooms so it becomes another community center; and, 5) expand use of existing facilities for DMCC and other civic organizations at the Civic September 22, 2026 Item 7
2 Center, Library, Powerhouse Community Center, and St. Peter’s Church so no new building encroachments are needed at Shores Park.

Furthermore, as the lead fundraiser for the historic Shores Campaign and the donor who personally funded the first two and only non-refundable escrow deposits necessary for the property’s acquisition, I urge the city council to change the entire 5.4 acre Shores property zoning to public parkland with school facilities as an allowed use. This will honor the intent of our donors to preserve and protect the Shores like Seagrove Park and Powerhouse Park, which the state cannot require to be affordable housing sites, unlike public facilities, the Shores current zoning.

Thanks for your consideration,
Laura
Co-Chair
Friends of Del Mar Parks
September 22, 2026 Item 7
1 Leslie Carrillo
From: Anne Farrell <[email protected]>
Sent: Sunday, September 20, 2026 2:34 PM
To: City Clerk Mail Box
Cc: Tracy Martinez
Subject: Red Dot for Item 8: Tree Policy
Attachments: Red Dot letter 09-20-26 (Farrell).pdf
Follow Up Flag: Follow up
Flag Status: Completed
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Please distribute this red-dot letter to the City Council, Planning Director, and City Manager.

Thank you,
Anne Farrell
Via Alta, Del Mar
September 22, 2026 Item 8
Anne Farrell
1415 Via Alta | Del Mar CA 92014
(858) 750-5615 | [email protected]
September 20, 2026
To: Mayor Tracy Martinez and Members of the Del Mar City Council RE: September 22, 2026 Council Meeting Docket, Red Dot for Item 8: Tree Policy Dear Mayor Martinez and Councilmembers:

I have signed the letter from Dolores and Richard Jamison, which gives an excellent overview of the complex challenges of tree policies in Del Mar, and I urge you to read it carefully and take action as recommended.

The environmental, climate, and aesthetic contributions of our trees – especially our Torrey Pines – are irrefutable. However, it is beyond time for the Council to seriously revisit all of our tree policies – not as a reactive action and piecemeal “solutions” but rather as a careful and comprehensive assessment of where we are vis-à-vis our tree canopy and where we should go. Over recent years, we have seen many projects go through the DRB with approval to remove many trees, simply to accommodate basements, ADUs, and other structures. I saw that in a direct neighboring property on Via Alta, where a veritable forest of trees (including a Torrey Pine) was removed, a big loss for the neighborhood and city canopy.

The International Society of Arboriculture (ISA) is the gold standard in the science and art of tree planting, care, and maintenance. It is essential that Del Mar’s ISA-certified arborist be involved every step of the way if we are changing policies and recommendations for citizens.

Unfortunately, I have very personal knowledge of the dangers of unhealthy Torrey Pines. There was an 80-foot Torrey on my western neighbor’s property that likely was there long before any houses were built. Mine was built in 1938 and I am sure that this Torrey Pine was there then. It was increasingly unhealthy and about 4 years ago, an enormous limb fell onto our property. The scale was astonishing and it was only one limb. You can see below the photos of what happened. It took a team of workers and $14,000 just to clean up and repair the damage. Ultimately, the neighbor had to remove the tree at enormous expense.

But today, as I face west from the kitchen and living room windows, I can clearly see at least seven large Torrey Pine trees on neighbor properties that appear to be just as unhealthy as the one that fell on our property. The crowns of the trees are gray or dead, and I imagine that strong winds could take some of them down. If you’d like to see this for yourself, you’re welcome to come over.

What we need ASAP is a comprehensive and accurate City-led arborist inventory of our trees, with indications of those that are unhealthy; we could then offer citizens ISA-certified arborist recommendations about proper care or need for removal. If Torrey Pines need to come down, then they should be replaced with an environmentally responsible variety of trees – we absolutely must do all we can to retain our tree canopy for all the reasons the Jamison’s expressed so articulately in their letter. Given the huge cost of removing mature Torreys, the Council should also discuss ways that they could financially help residents address the critical tree issues that affect us all. We know that sick Torreys can infect other Torreys, and that could devastate the inherent beauty of Del Mar.

September 22, 2026 Item 8
I am asking the City Council to undertake an informed, careful, thoughtful process that addresses City-wide needs, not just offer a knee-jerk reaction to the fallen tree on Ocean View. I believe that the staff proposal (particularly in Item 8: eliminating the tree replacement requirement) is truly reactive and could have some terrible unintended consequences. Moreover, we need any tree policy changes to comport with the thoughtful tree-related policies and recommendations in the City’s Design Guidelines, a document that I worked on (along with Richard Jamison and other community members) in that committee many years ago. We spent a long time researching best practices, and urge you to review that document as you proceed.

Thank you,
Fallen Torrey Pine limb & branches – Via Alta
Above: taken the day the limb fell. It
was at 7 in the morning, and the sound
of the break and crash was like a
railroad car coming straight at you. Very
scary.

Left: after the tree limb and debris was
removed – the black metal fence had to
be totally replaced, there was severe
damage to the stucco wall, to the
flagstone pavers, the in-ground jacuzzi,
and other areas. We are lucky that the
limb fell as it did – not onto our house or
the neighbor’s house. Only about 6 feet
more and we’d have been crushed.

September 22, 2026 Item 8
1 Leslie Carrillo
From: Dolores Davies <[email protected]>
Sent: Monday, September 21, 2026 8:00 AM
To: City Clerk Mail Box; Tracy Martinez; John Spelich; Terry Gaasterland; Dan Quirk Cc: Richard Jamison
Subject: September 22, 2026 Council Agenda; Red Dot; Item #8 Attachments: Tree.Removal.Policy.Amnesty.92026.pdf
Follow Up Flag: Follow up
Flag Status: Completed
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Hi Sara,
If you could print the attached document for item #8 discussion, that would be appreciated. This letter is from me, Richard Jamison and 60+ neighbors.

Thanks so much,
Dolores
Dolores Davies Jamison
Crest Road
September 22, 2026 Item 8
Mayor & City Council Members, City Manager and Planning Director City of Del Mar
September 22, 2026–Council Docket
RE: Item 8–Red Dot—Tree Removal Policy
Note: This letter represents the opinions of more than 60 Del Mar residents.

Dear Mayor Martinez and Members of the City Council:

While we take public safety very seriously, and empathize with the resident on Ocean View whose home was damaged by a large and clearly unstable Torrey Pine tree, what staff is proposing in item #8–especially the elimination of the tree replacement requirement—seems both reactive and piecemeal in terms of approach.

If there are clear public safety issues in the Ocean View neighborhood relative to an existing Torrey Pine tree (or trees), we would urge the City to direct the City’s arborist to inspect this (or these) tree/trees as soon as possible and grant permits to those residents whose trees are diseased or unstable, posing a public safety hazard. Given that the City has allowed more that 450 protected trees (mostly Torrey Pines) to be removed over the last decade—with only four denials—why is a 30-day amnesty period even needed? Has the City checked to see if peer cities are adopting this approach due to possible El Niño storms? It would be unconscionable to hold a 30-day amnesty period allowing the removal of protected trees, without the involvement of the City’s ISAcertified arborist.

While we don’t see any real need or evidence that would justify a 30-day amnesty period, if the City insists on going this route, the City and its arborist should identify high-risk trees and follow standard professional practice for hazardous tree assessment and removal as codified in ISA Best Management Practices and ANSI A300 Part 9 (Tree Risk Assessment). Projects that are in the DRB pipeline (starting with the original application including CPP, Variances, etc.) should not be considered for the amnesty period as the authority to approve protected tree removals for those projects should remain with the DRB. If the City were to allow DRB pipeline projects to remove protected trees under an amnesty policy on the basis of a possible El Niño emergency that may not materialize in Del Mar, it would undoubtedly be highly divisive and detrimental to the integrity of the design review process.

Sadly, too many large trees—both protected and unprotected—have been lost during the DRB process due to the lot-clearing that often occurs to accommodate houses, basements, swimming pools, ADU’s etc. Many of these new residences are landscaped with small trees that don’t thrive in our coastal climate and will provide little shade, carbon sequestration, wildlife habitat, or aesthetic softening of new structures (required by the DRO). Unlike many of our peer cities, Del Mar has no tree replacement policies to mitigate State-mandated housing developments such as ADU’s and SB 9 projects nor any street tree planting requirements for residential neighborhoods.

September 22, 2026 Item 8
The City currently has an important project on its work plan for this year—the Comprehensive Tree Policy and Regulatory Standards Update. Staff have chosen to “align” this project with the State’s future implementation of “Zone Zero” defensible space regulations. We are puzzled as to why planning staff are recommending a new tree replacement approach in high fire hazard severity zones. Has Fire Chief Davidson reviewed and sanctioned this approach? Shouldn’t this approach be assessed holistically, when the Comprehensive Tree Policy project is underway? Given that the vast majority of Del Mar parcels now lie within the high or very high fire hazard severity zones, this proposal could eliminate a large number of Torrey Pines while likely providing no replacement trees, which would only serve to undermine the health of our urban forest. While we are certainly open to allowing for other tree species to be considered as replacement trees when Torrey Pines (or Monterey Cypress) are removed and cannot be replaced for legitimate reasons, we need to work collaboratively with the City arborist to finalize such a list. A small group of residents representing the Del Mar Garden Club and the new Del Mar Fire Safe Council are working on developing a list of fire-resistant plants and trees that are well-suited for Del Mar, and are hoping to get this list finalized and approved by the City arborist, as part of the updated public tree policy manual.

The City’s Sustainability Advisory Council (SAC) has long been urging the City to conduct this holistic review and updating of the City’s Tree ordinances (DMMC 23.50 &

11.13), and tree policies, including the public tree policy manual, to bolster the health and safety of our tree canopy. After many years of delay, this important project is now on the City’s work plan for this year, and should be a high priority.

Del Mar needs a healthy tree canopy for many reasons, including the carbon sequestration that will be needed to meet the goals of our Climate Action Plan, to be updated next year. A reduced tree canopy not only means less carbon sequestration, but also more air pollution, and less cooling of our streets and neighborhoods. It is welldocumented that a street with more tree canopy can reduce air temperatures by at least 10 degrees and land temperatures by up to 22-25 degrees. Many of us who enjoy walking the streets of Del Mar experienced this cooling phenomenon firsthand during the recent extreme heat we endured.

Educating our residents about the proper care of the trees, and ensuring the health and safety of our urban forest, was identified by SAC as a top priority in updating the public tree policy manual. SAC envisioned that this document could provide essential guidance to residents on tree selection, care and maintenance. Many residents don’t realize that introducing a heavily irrigated planting area such as a lawn near a Torrey Pine is a recipe for disaster, as the trees can develop root rot and structural instability. In addition, many do not realize that a large Torrey Pine in our urban setting—at some point— will benefit from a crown reduction to reduce the chance of it dropping branches or toppling in an extreme wind event. It should also be noted that trees produce September 22, 2026 Item 8
adaptive growth as a result of the mechanical stress of prior wind storms, so nature has not left them helpless to face the future.

Given that so many Torrey Pines have been removed over the last few decades, it is clear that we need to replenish our urban forest. While we should do all we can to maintain those healthy and stable Torrey Pines that remain, it is time for us to diversify our tree canopy by encouraging the planting of other native and well-acclimated tree species that thrive here, are fire resistant, harbor wildlife, and will contribute to the carbon sequestration, cleaner air, and cooling that is needed. Changing our protected tree ordinance now by eliminating the need for tree replacements would be a drastic measure that would seriously undermine our tree canopy and the environmental and physical benefits it provides.

In closing, we would urge you to direct the City’s arborist to examine the tree (or trees) in the Ocean View area that residents believe pose a real public safety hazard. Then, please move forward as quickly as possible to begin the long-awaited work in reviewing and updating the City’s tree ordinance, policies, and public tree manual, along with those recommendations made by SAC.

Thank you for considering these suggestions.

Best Regards,
Richard & Dolores Davies Jamison Mary Friestedt
Crest Road Bellaire Street
Amy Isackson Ann Feeney & Don Mosier
Pine Needles Drive Rimini Road
Penny & Buck Abell Rosanne Holliday
Serpentine Drive Crest Road
Palmer & Susan Taylor Sandy & Bram Dijkstra
Via Alta Rimini Road
Doug & Janette Shelton Katherine Sohn
Rimini Road 26th Street
Tanya Schneiderman John Goodkind
Hoska Drive Forest Way
Joan Jacobs Ron & Arlene Prater
Ocean View Avenue Zapo Street
Dwight Worden John & Mary Giebink
Seaview Avenue Stratford Court
September 22, 2026 Item 8
Carol Isackson Beth Levine
Pine Needles Drive Crest Road
Stacey & Jeff Eaton Catherine & Peter Cramton
Ocean View Highland Avenue
Ron & Sally Taylor Cathy & Shige Iwane
Crest Road Pine Needles Drive
Pat Bone Frank & Linda Chisari
Culebra Street Crest Road
Gloria Sandvik & Harold Feder Carol Kerridge
Crest Road El Amigo Road
Anne Farrell Sheila & Michael Sharpe
Via Alta 15th Street
Betsy & Walt Dembitsky Deborah Isackson-Groban
Luneta Drive & Stephen Groban
7th Street
Wendy & John Ross Judy & Marc Schuckit
Klish Avenue Kalamath Street
Art Olson & Shirley King Mara Bickett
Avenida Primavera Van Dyke Avenue
Phil & Eric Gerber Jason Dempsey
Pine Needles Drive Crest Road
Alice Brown John & Gale Graybill
Avenida Primavera 15th Street
Lucy Taylor Scott Kemp & Greg Pongracz
15th Street Umatilla Street
Nick & Fran Frost Joan & Craig Brown
Crest Road Crest Road
September 22, 2026 Item 8
1 Leslie Carrillo
From: Janet Wilson <[email protected]>
Sent: Monday, September 21, 2026 1:30 PM
To: City Clerk Mail Box
Cc: Dan Quirk; John Spelich; Tracy Martinez; Terry Gaasterland; Janet Wilson Subject: City Council Item 8 - Tree Removal Fee Waiver and Wildfire Prevention Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear City Council,
The City needs to be prepared for El Niño storms. I support the proposed fee waiver for safety-related tree removals because residents should have a timely, affordable way to address hazards before they become emergencies.

Our High and Very High Fire Hazard Severity Zone designations also identify the need for preventive action. Residents should be able to address identified wildfire hazards before Santa Ana conditions arrive or a brush fire starts.

Please consider including wildfire prevention in the proposed tree-removal relief:
 Extend the fee waiver to removals needed to reduce wildfire risk, as identified by the Fire Marshal, with arborist input when necessary. Consider waiving City arborist review charges as well.
 Ensure replacement planting does not recreate a hazard.

I also support the requests in the red-dot letters from Dolores Davies Jamison, Richard Jamisonm and Anne Farrell to move forward with a comprehensive review of our tree policies.

Thank you,
Janet Wilson
September 22, 2026 Item 8
1 Leslie Carrillo
From: Amy Isackson <[email protected]>
Sent: Monday, September 21, 2026 2:58 PM
To: City Clerk Mail Box
Subject: Item 8 Red Dot, Tuesday, September 22, 2026
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

September 20, 2026
To: Mayor Tracy Martinez and Members of the Del Mar City Council Re: Red Dot for Item 8: Tree Policy on the September 22, 2026 Council Meeting agenda Dear Mayor Martinez and members of the Del Mar City Council, I am writing to express my concern about Item 8 on your Tuesday, September 23rd meeting agenda.

While public safety is paramount, the solution to managing protected trees is not a reactive emergency ordinance to allow them to be cut down and to diminish Del Mar’s tree canopy.

My Ocean View Avenue neighbors’ concerns regarding imminent danger from Torrey pines should be evaluated by the city’s International Society of Arboriculture (ISA) certified arborist as quickly as possible.

Removal permits should be issued, if it is determined that the trees threaten people and their homes. However, we need to make sure we use accurate criteria to make that determination.

According to Sean Wheatley and Brian Douglas’ testimony during Public Oral Communication on 8/25/26, arborists said that the tree that fell on Wheatley’s home appeared healthy. The 1998 emergency permitting memo lays out a set of conditions that must be met for emergency removal of a protected tree. With the help of ISA-arborists, we must determine whether this twenty-eight-year-old prescription remains the best practice and whether it would have caught or will catch a tree like the Wheatley’s.

In addition to addressing the immediate concern, we need a careful and comprehensive community-wide study of our protected trees conducted by people who know what they’re doing in order to create a comprehensive community-wide solution. The Torrey pine (Pinus torreyana) is the rarest pine in the United States, perhaps even the world. But as our climate changes, we are seeing that many of our protected trees are struggling, and some have become diseased and are becoming hazardous.

With the help of experts including arborists, fire marshals, and tree scientists, we need to evaluate whether protected trees are a manageable risk here in Del Mar and, if so, what are the best practices. How can we best manage risk at the same time that we protect and grow the city’s tree canopy? We need to make sure our understanding of Torrey pines in a changing climate is up-to-date and ask the difficult question: should we continue to protect Torrey pines and plant new ones or are there other types of native tree that would be more appropriate now for our changing climate?
It is critical that we get this right for the health of our community, as pointed out by Dolores Davies Jamison and Richard Jamison’s letter, but also as stewards of one of two areas worldwide where Torrey pines grow September 22, 2026 Item 8
2 naturally. A recent wildfire severely damaged the majority of the Torrey pines on Santa Rosa Island, with the National Park Service estimating that 60-80 percent of them may die. This makes our community’s good management of these rare and majestic trees even more essential.

Amy Isackson
Pine Needles Dr.

September 22, 2026 Item 8
1 Leslie Carrillo
From: Allan Wegner <[email protected]>
Sent: Monday, September 21, 2026 5:04 PM
To: City Clerk Mail Box
Cc: Susan Wegner
Subject: Council Docket Item 8, Tree Policy – Red Dot
Follow Up Flag: Follow up
Flag Status: Flagged
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Mayor & City Council Members, City Manager and Planning Director City of Del Mar September 22, 2026–Council Docket
Subject: Council Docket Item 8, Tree Policy – Red Dot
Dear Mayor Martinez and Members of the City Council:

Regarding he Council Docket Item 8–Red Dot Tree Policy: we are in full agreement with the letter sent earlier this week by Richard and Dolores Davies Jamison, plus fifty-nine (59) other Del Mar residents, which cautions against passage of the this one time ordinance.

We would like to mention that one of the main reasons we moved to Del Mar was for the beautiful park-like setting and numerous trees that characterizes our town, as reflected in the City’s official logo:

Without our mature tree canopy, the esthetic and financial value of the area would be greatly diminished.

In addition, all of the mature trees in Del Mar provide the significant benefit of erosion control, especially during our short, but intense rainy season. Because the National Weather Service is predicting a more intense El Niño stormy season this year than previous, it is cited as the motivating factor for the subject docket item. Given the intense rain a “super” El Niño stormy season will bring, we will need more more soil erosion protection this year - not less. Hence, removing mature trees without careful oversight is not a desirable option.

We too, take public safety very seriously, and we empathize with the resident on Ocean View, whose home was damaged by an unstable Torrey Pine tree. Thank goodness, no loss of life or injury resulted. Because our home is situated on one of the highest elevation points in the City, the two extensive groves of Torrey Pine trees on our property are subject to damage during high wind storms.

Thus, we are continually concerned as to whether one of the many protected trees on our property will damage our structures.

While we don’t know the circumstances surrounding that unfortunate and preventable accident on September 22, 2026 Item 8
2 Ocean View, we would like to mention that we have encountered no delays in quickly securing permits on two occasions to remove three (3) protected trees that posed a danger to our home.

As the City Staff outlines in their Agenda Report, the existing Tree Removal Permit has multiple provisions for owners to expeditiously secure a tree removal permit. Hence, there is no ostensible reason for what appears to be a reactionary ordinance. In fact, having unregulated removal of trees could exacerbate erosion concerns - an unwanted effect of the proposed ordinance.

Thank you for your consideration,
Allan and Susan Wegner
Crest Road
September 22, 2026 Item 8
1 Leslie Carrillo
From: Allan Wegner <[email protected]>
Sent: Tuesday, September 22, 2026 7:50 AM
To: City Clerk Mail Box
Subject: Council Docket Item 8, Tree Policy – Red Dot – A Suggested Alternative Policy Follow Up Flag: Follow up
Flag Status: Flagged
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Mayor & City Council Members, City Manager and Planning Director City of Del Mar
September 22, 2026 — Council Docket
Subject: Council Docket Item 8, Tree Policy – Red Dot – A Suggested Alternative Policy Dear Mayor Martinez and Members of the City Council:

Given the significant potential for unintended consequences if the proposed ordinance is adopted, we would like to suggest an alternative Tree Policy — one that avoids both the likely negative impacts of the currently proposed policy (described in our letter from yesterday and in the letter submitted by Richard and Dolores Davies Jamison, et al.) and the public safety concerns raised by the recent super El Niño storms that prompted this Tree Policy docket item.

An obvious alternative is to reduce both the height and bulk of large trees deemed to pose a risk to persons or property during severe winter storms. Stout, well-maintained trees retain the soil-erosion benefits of mature trees while eliminating public safety concerns, provided they are pruned properly.

On our own property, we have successfully avoided both soil erosion and property damage by proactively pruning the large Torrey Pine trees in our two groves, keeping them robust and stormresistant.

We therefore suggest that the City adopt a policy — similar to its wildfire fuel-reduction policy — that supports and encourages residents to reduce the bulk and height of large trees, mitigating both the public safety risk and the mudslide risk these trees can pose in severe storms.

Thank you for considering this suggested alternative.

Regards,
Allan and Susan Wegner
Crest Road
September 22, 2026 Item 8
1 Leslie Carrillo
From: Ann Feeney <[email protected]>
Sent: Tuesday, September 22, 2026 12:48 AM
To: City Clerk Mail Box
Subject: Item 8 Red Dot - Trees
Follow Up Flag: Follow up
Flag Status: Flagged
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Dear Mayor and City Council members,

I am fully supportive of everything that is in the letter written by Richard and Dolores Jamison, which I signed. I completely understand the concerns of the residents who brought this forward, but I would just like to emphasize a few points that the Jamisons raised.

1. Our Climate Action Plan passed in 2016 has the aim to increase our tree canopy, yet it is obvious that our tree canopy has diminished in the time since that was adopted. Trees sequester carbon, provide shade and cooling, provide habitat for birds and animals, and beautiful our city. We need to reverse that trend and work to increase our tree canopy.

2. The Sustainability Advisory Committee has advocated for years for the city to undertake a Comprehensive Tree Policy study and ordinance, and in ~2018, we provided a detailed list of items that we wished to be considered for that ordinance to help preserve mature healthy trees. At last, the tree study is on the city workplan for this fiscal year. Please accelerate this study and associated ordinance and do not make any hasty interim decisions until the study is well underway.

3. Torrey Pines are iconic trees and should be protected. However, if one is a danger to a building, it is reasonable to consider allowing it to be removed. Nonetheless, there is no reason why replacement trees should not be mandated. If we want to stop decreasing our tree canopy, in direct opposition to our CAP, then we need to require replacement trees. They need not be Torrey Pines if the Fire Marshall thinks they are a fire risk, but there are many other trees that could be used as replacement trees.

Sincerely
Ann Feeney
524 Rimini Rd.

September 22, 2026 Item 8
September 22, 2026 Item 8
September 22, 2026 Item 8
September 22, 2026 Item 8
Stephanie Fantino
Ingrid Willsey and
Michael Marnie Mahoney
Becky and Walt Dembitsky Mary Ellen Buchler
September 22, 2026 Item 8
1 Robert Silva
From: Joe Sullivan <[email protected]>
Sent: Friday, September 18, 2026 11:49 AM
To: City Clerk Mail Box
Subject: Red Dot for September 22 Council Meeting
Attachments: RED DOT re Lagoon clearance.docx
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Please distribute red dot attached and included below

RED DOT
September 18, 2026
TO: City of Del Mar
City Council
FROM: Joe & Alice Sullivan
Ocean Front, Del Mar
SUBJ: Item 10: Emergency Declaration re San Dieguito Lagoon We commend the Council and City staff for their urgent efforts to prepare for the forecast flood risk associated with El Niño, potentially amplified by the approaching Kelvin wave.

While much of the attention has focused on the beachfront, there is also a significant risk of major flooding should Lake Hodges Dam overtop or, in a more severe scenario, fail. We strongly support the declaration of an emergency and the request that appropriate agencies expedite the clearance of accumulated sand from the San Dieguito Lagoon.

We also urge the Council to immediately request that the California Coastal Commission issue an emergency permit authorizing the temporary placement of riprap on the beach, should such measures become necessary to protect public and private property.

Respectfully submitted,
September 22, 2026 Item 10
1 Leslie Carrillo
From: [email protected]
Sent: Saturday, September 19, 2026 7:30 AM
To: City Clerk Mail Box
Subject: Red Dot Sept 22: Item 10
Follow Up Flag: Follow up
Flag Status: Flagged
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I strongly support the declaration of an emergency and the request that appropriate agencies expedite the clearance of accumulated sand from the San Dieguito Lagoon. Furthering this need is that fact that we could see controlled release of water from Lake Hodges, as we saw in 1983, or uncontrolled spilling.

I also hope the City considers taking whatever preventative measures are necessary to protect the beach colony, whether that be a berm or temporary rip rap.

Thank you,
Lucille Lindsey
September 22, 2026 Item 10
1 Leslie Carrillo
From: Heather Lindsey <[email protected]>
Sent: Saturday, September 19, 2026 8:02 AM
To: City Clerk Mail Box
Subject: Red Dot Item 10: 9/22 Emergency Declaration re San Dieguito Lagoon Follow Up Flag: Follow up
Flag Status: Flagged
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To City Council,
I encourage Council to follow the staff recommendation and support the declaration of an emergency to expedite the clearance of accumulated sand from the San Dieguito Lagoon. And I thank staff and council for their efforts in this. This is of great value in protecting the entire beach colony.

I thank the City for ensuring the cleaning of the flapper valve as well, especially in light of the impact the Kelvin wave will play on its functionality.

On a similar note, I encourage Council and staff to consider obtaining permission to use rip rap so that if it becomes necessary, Del Mar is in a position to act.

Lastly, I politely ask that Council and staff consider investigating the placement of a berm along the entire stretch of Del Mar Beach November through January, assuming there is still sand then and it can do so without taking sand from the lower beach. In a normal year, when the ocean level is a foot lower because there is no El Niño and no Kelvin wave, then I understand the strategy of only placing a berm at public access points, because those smaller berms plus the seawall and ocean front homes provide enough protection from wave action. Odds are that this year will be different. In a scenario where wave action is so strong that the sea walls and ocean front homes only mitigate the flooding, the water will quickly rush down the side of the homes and start flooding the homes below. If we build the berm, the worse case scenario is that the sand washes away. The best case scenario, beyond saving sand on Del Mar beach, is that it could add another line of defense, with the sea wall as the second; then, the first row of home and whatever additional protection the homeowner employs is the third, and then whatever flood prevention protection the beach colony homeowner has employed is the fourth.

Thank you,
Heather Lindsey
September 22, 2026 Item 10
1 Leslie Carrillo
From: karen lare <[email protected]>
Sent: Saturday, September 19, 2026 12:54 PM
To: City Clerk Mail Box
Cc: John Spelich; Terry TG. Gaasterland; Tracy Martinez; Dan Quirk Subject: Red Dot for upcoming Sept 22 meeting item on Sand Emergency Follow Up Flag: Follow up
Flag Status: Flagged
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Honorable Mayor and Council,
I had an opportunity to see and read the article and associated staff report on the sand emergency for the San Dieguito Lagoon. I first want to commend the staff that produced the thoughtful and thorough report. It does a great job of not just calling for emergency dredging but details out the reasons that the city (and the lagoon) are in this position today. This history is important as the longer term implications will need to be assessed once the short term dredging need has been completed.

I encourage all council members to read the details of the report and to support its unanimous approval at your upcoming meeting. Time is of the essence and so any request for additional details (I cannot imagine you would need more than the report contains) or delay on your part would slow down a process for approval and hence slow down the work needed to remove the accumulated sand that may cause severe flooding in the beach community should we get the predicted strong winter storms.

Once again, the city staff has produced a strong factual report and I hope that you all can follow their lead and approve it quickly and support the necessary work by State and Federal Agencies to accomplish the swift dredging of excess sand build-up.

Karen Lare
Sea Cliff Way Del Mar
Begin forwarded message:

From: City of Del Mar <[email protected]>
Date: September 18, 2026 at 7:05:57 AM AKDT
To: [email protected]
Subject: Del Mar Weekly, September 18, 2026
Reply-To: [email protected]

September 22, 2026 Item 10
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DM Weekly header
Issue No. 380 · September 18, 2026
[email protected]

TOP STORIES
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Del Mar surfers
Oct. 8-11: Surf Del Mar Festival
The Surf Del Mar Festival, a four-day celebration of surfing and its ties to Del Mar, runs from Oct. 8-11 at locations throughout the city.

The schedule includes a reception, climate symposium, art walk, film festival, party, reunion, surf writer's book fair, woody wagon parade, concert at Powerhouse Park, screening of Endless Summer, student art walk and Women on the Waves discussion.

The Del Mar Historical Society is producing the event.

Open website
September 22, 2026 Item 10
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Tuesday: Council to consider local emergency
declaration for sedimentation in lagoon
Amid predictions of severe winter storms, City staff is recommending that the City Council on Sept. 22 declare a local emergency in response to the high buildup of sand in the inlet to the San Dieguito Lagoon.

An excess of sand in the inlet, lagoon basins and river channel impedes tidal exchange and increases the risk of flooding to low-lying neighborhoods.

The sand buildup is tied to a 2024 sand replenishment project in Solana Beach.

In a draft resolution to declare a local emergency, Del Mar seeks authority to increase the volume of sand that existing permits allow to be removed from the lagoon.

Open staff report
Tuesday: Council to consider
concept design for Shores Park
The City Council on Sept. 22 is set to consider a concept design for Shores Park as recommended by the Shores
Park Master Plan Ad-hoc Advisory Committee.

The Council's consideration follows months of committee meetings and moves Del Mar toward adopting a final
Master Plan for the City-owned property on Stratford
Court at 9th Street.

In 2008, the City purchased the 5.3-acre property from Del Mar Union School District to preserve open space, recreational uses and the continued operation of the Winston School, which leases a portion of the property.

Open staff report
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Tuesday: City Council meeting
A regular meeting of the City Council begins at 4:30 p.m. Tuesday, Sept. 22, at the Del Mar Civic Center Town Hall, 1050 Camino Del Mar. Regular City Council meetings are held on the first and third Tuesdays of the month.

September 22, 2026 Item 10
4 Request to speak
Watch meeting
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Click to open full agenda

PUBLIC SAFETY
National Preparedness Month,
Week 3: Make a Plan
Make an evacuation plan for your family: what to do,
where to go, and how you’ll stay in touch during an
emergency.

Family members may not be together when an
emergency hits, and your usual way out of the
neighborhood may not be open or safe.

Start with more than one evacuation route.

Pick a family meeting place—like a park or a school—that everyone knows.

Agree on how you’ll reach each other if you’re separated. Consider naming an out-of-area contact the whole family can call.

Make the plan specific to your household, then practice it! Everyone should know where they’re going, how they’re getting there, and what to do.

Del Mar Weekly will cover topics related to emergency preparedness every Friday in September.

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Fire Marshal Medi Maldonado
September 22, 2026 Item 10
5 Oct. 3: Open house at Del Mar
Fire Station
The Del Mar Fire Department is hosting an open house
from 10 a.m. to 2 p.m. Oct. 3 at the fire station at 2260 Jimmy Durante Blvd.

During the all-ages event, visitors can tour the station, meet Del Mar's first responders and enjoy snacks,
giveaways and live music courtesy of The Rockademy.

Open flier
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Lifeguards awarded Patrick
OHarra Memorial Scholarships
Standing alongside the Patrick OHarra Inflatable Rescue Boat, Del Mar Lifeguards Ben Kuleto and Taylor Lyon
display recently awarded Patrick OHarra Memorial
Scholarship certificates.

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LGs with certificates
Crime blotter: Sept. 11-17
Incidents: 0
Source: San Diego County Sheriff's Office
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Sheriff's star

COMMUNITY BRIEFS
Thursday: E-bike safety event
In partnership with County Supervisor Terra LawsonRemer, the San Diego County Bicycle Coalition and Scripps Trauma Prevention, the City of Del Mar is
hosting an e-bike safety talk and helmet giveaway at 6
p.m. Thursday, Sept. 24, in the Del Mar Civic Center
Town Hall.

A one-hour presentation will cover state laws and what
parents and young riders need to know before hitting the road.
"This is a free event," Lawson-Remer said, "and every young rider who comes will go home with a new helmet."
Register
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September 22, 2026 Item 10
6 City calendar listing
Sept. 26: Del Mar Recycles
Ready to clear some clutter?
The City of Del Mar and EDCO are sponsoring a free
recycling, shredding and mulch event from 9 a.m. to
noon Saturday, Sept. 26, at the lower parking lot of
Shores Park. Enter off of Stratford Court south of Ninth Street.

Residents can responsibly dispose of electronic waste, fluorescent bulbs, household batteries and sharps.

Household hazardous waste and pharmaceuticals will not be accepted.

A certified paper shredder will provide onsite shredding of up to three banker boxes full of documents per household.

Residents also can self-load up to three barrels of mulch and compost while supplies last.

The event is open to City of Del Mar residents and businesses only. The collection of sharps is limited to residents only.

Open webpage
.

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Sept. 27: Del Mar Community
Picnic
Mark your calendars for the Del Mar Community Picnic
from 1 to 4 p.m. Sept. 27 at Powerhouse Park.

Food, games and music by the band Prairie Sky are
planned for guests of all ages. No registration is required.

The Del Mar Foundation organizes the annual event.

Open website
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September 22, 2026 Item 10
7 Oct. 2: City Council candidate
forum
The League of Women Voters of North County San
Diego is hosting a forum for Del Mar City Council
candidates from 1 to 2:30 p.m. Oct. 2 at the Del Mar
Civic Center Town Hall.

The forum will be recorded and posted on the City's
website.

Four candidates have qualified to compete for two seats on the Del Mar City Council in the Nov. 3 General Election. The candidates, in randomized ballot order by last name as set by the Secretary of State, are: Meghan O. Spieker, Jeff Sturgis, Terry Gaasterland and Jas Grewal.

Candidate statements, timelines and voter information can be found on Del Mar’s November 2026 Election webpage.

Open webpage
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Oct. 7: Climate symposium
Register now for a free symposium, "The Health Impacts
of Wildfires, Storms, and Extreme Temperatures:

Understanding Risks and Taking Action," from 6 to 8:20
p.m. Oct. 7 at the Del Mar Civic Center Town Hall.

Open website
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SDG&E reminder: Help is
available on utility bills
Amid high electricity demand during the recent heat
wave, SDG&E this week issued a reminder that financial
assistance is available.

Programs include: California Alternate Rates for Energy (CARE), Family Electric Rate Assistance (FERA), flexible payment arrangements, Energy Savings Assistance
(ESA) Program, and Medical Baseline Allowance for qualifying customers.

Open webpage
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SDGE logo

DEL MAR VILLAGE ASSOCIATION
September 22, 2026 Item 10
8 Oct. 1: Gather Dinner Series
DMVA is organizing an intimate dining experience at 6
p.m. Oct. 1 at Coral Del Mar, where Head Chef Jesus
Baños will serve a multi-course meal with paired
cocktails and wines. Seats are limited to preserve the
intimacy of the one-night-only gathering.

Dinner details
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DEL MAR COMMUNITY CONNECTIONS
Remembering Louise Keeling
In a remembrance published this week, Del Mar
Community Connections celebrates the life of Louise
Barthold Keeling.

A Del Mar resident since 1956, Mrs. Keeling raised five children in the community with her late husband, Charles David Keeling.

A musician, writer, educator and community volunteer,
Mrs. Keeling was 95.

Open remembrance
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Louise Keeling

COMMITTEE VACANCY
Undergrounding Program Advisory Committee
(1 voting resident member). Closes 4:30 p.m. Sept. 25.

Committees, Vacancies and Volunteer Requirements
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MEETINGS
Location: Del Mar Civic Center Town Hall, 1050 Camino Del Mar Tuesday, Sept. 22
City Council, 4:30 p.m.

September 22, 2026 Item 10
9 Wednesday, Sept. 23
Design Review Board, 6 p.m.

Thursday, Sept. 24
E-bike Safety Talk and Helmet Giveaway, 6 p.m.

Saturday, Sept. 26
Del Mar Recycles Event (lower parking lot of Shores Park) 9 a.m.

Full calendar
DO YOU REMEMBER?
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Surfing contest circa 1984. Photo: Tracy Weaver
TALK TO US!
[email protected]
858-755-9313
www.delmar.ca.us/delmarweekly
September 22, 2026 Item 10
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1050 Camino del Mar, Del Mar, CA 92014
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September 22, 2026 Item 10
1 Leslie Carrillo
From: Kerridge, Carol <[email protected]>
Sent: Sunday, September 20, 2026 10:39 AM
To: City Clerk Mail Box
Subject: Red Dot Item #10 Declaration of a Local Emergency Due to High Volume of Sedimentation in the San Dieguito Lagoon
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear City Council Members and Staff,
I am totally supportive of the Staff recommendation to adopt a resolution declaring a local emergency due to a high volume of sedimentation in the San Dieguito Lagoon.

I am concerned and agree with Staff that the water quality of our lagoon can potentially become impaired due to sand buildup which can block the continuous flow of water. The water can then stagnate, creating reduced oxygen levels and increase the risk of bacterial and/or viral contamination. These conditions could potentially seriously endanger the livelihood of our entire lagoon ecosystem.

Sadly, I believe this situation has already occurred within the last year or so within the San Elijo Lagoon just to the north of us.

Please consider declaring this important issue as an emergency to be resolved as soon as possible.

Sincerely,
Carol Kerridge
Del Mar
September 22, 2026 Item 10
1 Leslie Carrillo
From: Udo Wahn <[email protected]>
Sent: Monday, September 21, 2026 10:02 AM
To: City Clerk Mail Box
Subject: Red dot Item 10 Sept 22, Council meeting
Follow Up Flag: Follow up
Flag Status: Flagged
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September 21, 2026
Re: Resolution to Declare an Emergency at the San Dieguito lagoon-Item 10 Honorable Mayor Martinez and City Council Members,
As a 43 year resident of Del Mar, I am writing in support of approving the Resolution to Declare an Emergency due to the high level of sand in the San Dieguito Lagoon. Emergency action should be taken to allow SCE and the USACE to dredge up to 50,000 cubic yards of sand per dredge event and their permits should reflect that change in allowable amounts to be dredged..

This is of critical importance to protect the health of the lagoon and help prevent flooding of City and private properties. This is especially important with forecasts of a severe El Nino event this fall/ winter and should be done without delay.

Thank you,
Udo Wahn, M.D.
1227 Stratford Court
Del Mar
Udo Wahn, M.D.

September 22, 2026 Item 10
1 Leslie Carrillo
From: Serge Dedina <[email protected]>
Sent: Monday, September 21, 2026 10:28 AM
To: City Clerk Mail Box
Subject: WILDCOAST Support Item 10 9/22/26
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear City of Del Mar Mayor and City Council:

WILDCOAST, strongly urges you to support Item 10 for the Sep 22, 2026, City Council Meeting agenda and declare a state of emergency over the buildup of sediment in San Dieguito Lagoon, a California state marine protected area.

Due to the emerging "Godzilla" El Niño, it is more urgent than ever that the City of Del Mar pressure USACE to remove sediment from San Dieguito Lagoon. The City cannot wait for federal agencies to fail to act.

From an ecological perspective, removing sediment will improve the health of this MPA and enhance the lagoon's flood control qualities.

Serge Dedina, Ph.D
Executive Director

WILDCOAST
2010 Jimmy Durante Blvd,
Del Mar, CA 92014
September 22, 2026 Item 10
1 Leslie Carrillo
From: Andrea Gilman <[email protected]>
Sent: Tuesday, September 22, 2026 11:36 AM
To: City Clerk Mail Box
Subject: Red Dot - Ocean Front Standing Water and Winter Flooding Follow Up Flag: Follow up
Flag Status: Flagged
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Dear Mayor Martinez and Councilmembers,
Below is a photograph of Ocean Front near my home on August 31, 2026 (1834 ocean front) It hadn’t rained for days. Standing water on Ocean Front is common, and I have been told it may be related to high tides, but I’m not sure if that is accurate.

Recently, I’ve heard that a “coastally trapped Kelvin wave” is expected to reach the San Diego coast in early October. I didn’t know what a Kelvin wave was, but I have learned that NOAA says these El Niñorelated waves can raise coastal sea levels by about 6 inches, and those elevated levels can persist for several months or longer.

And yesterday, a statewide state of emergency was declared to prepare for El Niño and the associated risks of heavy rain and coastal flooding.

I am very concerned about what persistent higher sea levels from Kelvin waves, combined with El Niño winter conditions, could mean for this area.

It is important to make sure the drainage and any necessary pumping systems in this area are functioning properly before the coming coastal and winter conditions.

I am requesting that the City investigate the source of this recurring standing water and plan for the increased risk of flooding this winter.

Thank you,
Andrea Gilman
909-720-7565
September 22, 2026 Item 10
2 September 22, 2026 Item 10
501 W. Broadway, Suite 800 San Diego, CA 92101 Ph: 619.278.0701 Fx: 619.278.0705 www.jmhamiltonlaw.com
The Law Office of
Julie M. Hamilton
September 22, 2026
Mayor Tracy Martinez
City of Del Mar
1050 Camino Del Mar
Del Mar, CA 92014
[email protected]
RE: Declaration of Local Emergency Due to High Volume of Sedimentation in the San Dieguito Lagoon.

Honorable Mayor Martinez:

I represent the Del Mar Sandy Lane Association (“Sandy Lane”), which includes the 12 homes south of the San Dieguito River, located between Camino Del Mar and the beach. Sandy Lane is asking the City of Del Mar to balance the need for sand replenishment with the impacts of sand replenishment on theSan Dieguito Lagoon.

Sandy Lane challenged the approval of the San Dieguito Lagoon Wetland Restoration Project due to concerns with the migration of beach sand into the inlet; thereby depleting the amount of sand available to the beach. Sandy Lane was assured that opening the river mouth would add sand to the beach south of the river. This conclusion was based on the faulty opinion the river would carry sand toward the ocean. Sandy Lane correctly disagreed with this opinion.

Both the City of Del Mar and the California Coastal Commission adopted an extensive monitoring program to survey the width of the beach before and after each time the inlet was opened. The agencies also agreed that any dredge spoils that are appropriate will be deposited on the beach south of the river mouth.

Sandy Lane is asking the City of Del Mar to ensure that monitoring of the beach width continue before and after dredging to assure the dredging of the lagoon does not lead to a loss of sand on the beach south of the river mouth. Sandy Lane’s second request is that any suitable dredged sand be placed on the beach in front of Sandy Lane, south of the river mouth. Finally, Sandy Lane is requesting that any dredging push the river mouth to the north to protect the existing revetment on the south side of the river. This revetment protects the homes on Sandy Lane and the pedestrian path located along the revetment west of Camino Del Mar.

September 22, 2026 Item 10
Mayor Tracy Martinez
September 22, 2026