Letter: Santa Clara River Estuary

January 16, 2018

Gina Dorrington
Ventura Water
501 Poli Street, Room 120 Ventura, CA 93002
via email: gdorrington@venturawater.net

RE: SCRE Special Studies – Water Recycling Opportunity

Dear Ms. Dorrington:

The Ventura County Chapter of the Surfrider Foundation has voiced concerns with water quality at the mouth of the Santa Clara River since our Blue Water Task Force identified high bacteria levels at this popular surfing location in the early 1990’s. Recognizing the benefits of integrated water management, the Surfrider Foundation has been a longtime proponent of recycled wastewater to enhance our coastal ecosystems. Wastewater discharges have historically impaired coastal water quality, and even with advances in technology, increased nutrient levels impact receiving waters.

We would like to re-state our support for 100% recycling of the city’s wastewater to eliminate the discharge into the Santa Clara River Estuary.

We do not concur with the analysis presented at the November stakeholder meeting that oversimplify the ecosystem associated with the Santa Clara River Estuary (SCRE.) Indeed, as other commenters have noted, this system is in fact much more representative of a coastal lagoon, since it does not maintain a perennial opening to the ocean. Indeed, it is this fact that creates the problems with the wastewater discharge. Without a regular exchange between the lagoon and the ocean, nutrient rich wastewater accumulates in an unnatural manner behind the beach berm. Only during large winter storm events or human intervention does this lagoon breach. This results in unnaturally high water levels and poor water quality.

Finding of Enhancement is Flawed:

Any conclusion that determines that the lagoon is enhanced by the wastewater discharge are flawed. Although the resource agencies rightly are concerned for the endangered and special status species that rely on habitat at the mouth of the Santa Clara River, current conditions limit, rather than support those species. The unnaturally high water levels resulting from the discharge create a simplified pond habitat that is subject to episodic draining. Sea water exchange, a necessary part of this ecosystem, is also precluded with the flooded lagoon. The elimination of habitat complexity and poor water quality has created an ideal habitat for non-native species, most prominently carp. From our experience on the Ventura River, carp are the predominant fresh water species below the Ojai Sanitary District discharge on the lower Ventura River, relegating this reach to migratory status for the endangered Southern Steelhead. Steelhead may survive in such an environment, but they certainly wouldn’t choose it.

An Opportunity for Ecosystem Benefits:

A more complete ecosystem view of the situation has not been conducted as part of the SCRE analysis. By focusing exhaustively and exclusively on the Santa Clara River Estuary, the potential benefits of eliminating the wastewater discharge have not been fully considered. Consider this fact:

50% or more of the discharge originates from the Ventura River

The City of Ventura relies on a wellfield at Foster Park and surface storage from Lake Casitas for more than half the water supply. Both of these sources are currently stressed from over allocation during the prolonged drought.

How could a point source discharge directly into the Santa Clara River Estuary be considered to mimic “natural” processes and enhance the habitat, when much of the water originates from the adjacent watershed?

Most significantly, studies have documented the high quality spawning, rearing, and refugia habitat in the Ventura River upstream of the Foster Park wellfield. However, flows in this reach have become seriously impaired by over-extraction of groundwater, to the point that in recent years this refugia habitat has dried up for extended periods during the critical summer and fall months. It should be noted that this reach of the Ventura River was historically known as the “live reach,” for the rising groundwater in the vicinity of Casitas Springs, which was also named for this phenomenon. These are precisely the conditions that favor native species such as the southern steelhead. Indeed, recent population surveys have documented the presence of native trout in this reach.

Water Budget Perspective:

Consider the potential benefits from developing a “new” supply from recycled water. These slightly outdated supply and demand numbers are taken from the City's 2013 Final Comprehensive Water Resources Report. It is evident from this graph that if 'new' sources of water are not found the city will outgrow its water supply in the near future.

The red arrow shows that the potential for recycled water in Ventura is close to 50% of demand. (Of course the actual volume would be less than this depending on treatment and reuse options, but this demonstrates the overall magnitude.) Therefore water recycling would provide an opportunity to eliminate the flooding problem at McGrath as well as offset municipal water demand (i.e. an 'integrated solution'.) This demand offset could provide an opportunity to reduce pumping at the Foster Park wellfield during dry months of the year to sustain the critical habitat within the “live reach” of the Ventura River.

Recommendation:

We encourage the City of Ventura and the stakeholder resource agencies to carefully reconsider the potential benefit from maximizing the recycled water potential. Rather than choosing to maintain an artificial pool at the Santa Clara River Estuary, which has very limited habitat benefits, demand offsets gained through recycling 100% of the wastewater effluent may be applied to the enhancement of the comparatively high quality habitat in the Ventura River. In turn, the coastal lagoon will return to a more natural hydrology with improved water quality and habitat, while also eliminating the non-native habitat conditions that are currently degrading the SCRE ecosystem.

Sincerely,

A. Paul Jenkin, M.S.
Ventura Campaign Coordinator, Surfrider Foundation (805) 205-4953 pjenkin@surfrider.org

cc: SCRE Stakeholder e-mail list 

References:
Steelhead Population and Habitat Assessment in the Ventura River / Matilija Creek Basin 2006-2012 FINAL REPORT

Ventura River Ecosystem - wastewater, VenturaRiver.org