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 

McGrath State Beach flooding

This year's drought combined with the constant artificial flow into the Santa Clara River estuary have resulted in a flooded campground at McGrath State Beach.  As documented by the ongoing studies, up to 9 million gallons per day currently discharged from the City of Ventura's wastewater treatment plant create artificially high water levels in the coastal lagoon.  Winter floods naturally breach the lagoon, which then takes months to re-fill, but without significant river flows the sand berm keeps the rivermouth closed.  In 2010 an artificial breach resulted in rapid draining of the lagoon and death of steelhead trout and other endangered species.  (see Estuary breach kills fish)

photo: VCStar.com

This is just one symptom of a complex water management issue that begins at the Ventura River - this year the river has dried up at Foster Park, one of the the city's primary water supplies.  This water is piped to homes and businesses in the city, used once, and discarded as 'wastewater' which is treated and discharged into the Santa Clara River.  We continue to advocate for 'Integrated Water Management' that would increase water use efficiency though conservation and decentralized re-use.

Surfrider submitted written comments on February 28, 2013 that included this statement:

The Surfrider Foundation’s national ‘Know Your H2O’ campaign recognizes the importance of integrated water management as a solution to coastal problems. Many municipalities are responding to the global water crisis through the implementation of water recycling to diversify their water supplies. The SCRE Phase 2 study does an excellent job of identifying opportunities for wastewater reuse throughout the City of Ventura, and has identified a number of projects that may become components of an integrated water management strategy.

As we have commented previously, it is important to recognize that, on average, two thirds of the water discharged into the Santa Clara River Estuary comes from the Ventura River. The report notes that the city’s water supply is stretched thin, and this is evidenced in the current drought that has dried up the Ventura River, including the City’s wellfield at Foster Park. Cumulative impacts within the Ventura River have resulted in a 303d impairment listing for pumping and diversion. Therefore, a watershed-based strategy designed to restore instream resources and protect groundwater basins is essential to addressing multiple regulatory pressures and to ensure the long-term viability of the city’s water supply.
We agree with the general consensus from the stakeholder workshop that implementing Indirect Potable Reuse (IPR) and Direct Potable Reuse (DPR) within the City of Ventura is the highest and best use of the city’s wastewater. As discussed in the report, the Ventura River provides higher quality water than the groundwater on the East side. Therefore there is some merit to keeping Ventura River water within that watershed as proposed with the North side decentralized treatment plant. We also recommend that an East side decentralized wastewater treatment plant remain as a possible alternative in this strategy. This plant should be included in planning for urban expansion on the east side because treating and reusing water nearer its source would provide other long-term benefits. For instance, the location of the existing treatment plant within the floodplain of the Santa Clara River and an area of potential sea level rise inundation makes it vulnerable to catastrophic events that may require its relocation within the 50- to 100-year time frame. A citywide decentralized water reclamation system would reduce this vulnerability and limit the potential impacts from future flooding while increasing overall water use efficiency. 

...To summarize, we strongly support an expanded water-recycling program within the City of Ventura, but disagree with the analysis of habitat enhancement from the wastewater discharge into the Santa Clara Estuary. We encourage the City to continue to develop an integrated water management plan that considers the broader long-term benefits of increased water use efficiency.



In the news:
     mcgrath-state-beach-campground-flooded-closed
     A no-win situation in the McGrath State Beach flooding

More info: SCRE Special Studies - http://www.cityofventura.net/rivers

On this blog: http://www.venturariver.org/search/label/wastewater

Surfrider comment letter:  https://dl.dropboxusercontent.com/u/39386757/SCRE%20Studies%20Surfrider%20comments%20Feb-2013.pdf

..

Ventura Water Pure Ocean Outfall

The City of Ventura is planning to construct an ocean outfall extending approximately 6,800 feet offshore from Marina Park near the Ventura Harbor.  The outfall and associated pipeline will ultimately serve to dispose of concentrated "brine" from the planned "Ventura Water Pure" wastewater recycling facility.    A new underground pipeline will connect the existing Ventura Water Reclamation Facility to the outfall.  

Initially the City will discharge up to 4.7 million gallons per day (MGD) of tertiary-treated water through the ocean outfall. The Ventura Water Reclamation Facility currently discharges tertiary-treated wastewater into the Santa Clara River Estuary (SCRE) near its connection to the Pacific Ocean.  In March 2010, the Ventura Coastkeeper and Heal the Bay filed a lawsuit alleging that the discharges of the tertiary-treated effluent into the estuary violated State and Federal law.  The City settled and entered into a consent decree requiring the City to develop alternatives that would improve conditions for the habitats and species within the estuary.  The first phase would discharge up to 90% of the City's treated wastewater offshore by 2030.  

The City is also currently planning for the Ventura Water Pure reclamation facility which would further process the tertiary wastewater using reverse osmosis and other treatments to allow injection into local aquifers.  This would provide a new source of water through Indirect Potable Reuse (IPR) to help accommodate the City's growth.  The byproduct of this process is a concentrated "brine" which will be disposed offshore through the ocean outfall.  

Construction will mainly impact Marina Park and the harbor area to install the plumbing necessary to disharge offshore as shown in the illustration below. A 20-inch diameter high-density polyethylene (HDPE) Conveyance Pipeline will connect from the wastewater treatment plant at Harbor Boulevard and Olivas Park Drive, extending north along Harbor Boulevard, then west on Schooner Drive, and northwest along Anchors Way where it would connect to the Harbor Crossing. The 20-inch pipe will be bundled with two 8-inch sewer pipes in a 36" pipe to be drilled 30 feet below the harbor bottom to connect with the Ocean Outfall at Marina Park.  

The City completed their environmental analysis of this project in 2019 with an addendum in 2022.  

BACKGROUND AND ANALYSIS:

Surfrider has advocated for water recycling over the past decades, and this ocean outfall is a necessary component of this.  Recycling is accomplished by reverse osmosis which generates a “brine” that has to be disposed of.  Once the WaterPure facility is operating this outfall will be primarily for brine disposal.  In the interim, while the facility is being constructed, the outfall will be used for offshore disposal of tertiary treated wastewater.  This would effectively relocate the disharge from the estuary/nearshore to a mile offshore in Pierpont Bay to comply with a court order resulting from Wishtoyo/HealtheBay lawsuit.
Some of Surfrider's prior comments on this issue are here: https://www.venturariver.org/search?q=scre

There are some unavoidable impacts with this project, but in the long term it should lead to improvements in our regional water supply and water quality as well as eliminating the impacts to the Santa Clara River Estuary.  Concerns include whether offshore currents could bring the effluent back onshore and of course the implications of sea level rise.   Coastal Commission Staff recognized the sea level rise concerns by reducing the permit from 50 yr to 30 yr at which point they would revisit it.

A big concern is the City's ambition that this outfall could one day be used for an intake of ocean water for desalination.  Surfrider and others have concerns about ocean desalination due to the impacts on the marine ecosystem and the carbon footprint of this energy intensive process.  

IN THE NEWS:

California's Ventura Gets $173M in EPA Loans for More Resilient Water Supply, ENR, May 24, 2023

Key funding comes through from EPA to boost water supply in Ventura, VC Star, May 24, 2023

Ventura has been awarded federal loans covering half the costs for a program to convert treated wastewater into safe drinking water and reduce discharges of effluent into the Santa Clara River estuary.

Speaking at a news conference Tuesday at the city's water reclamation plant, officials said the venture will benefit the environment, boost water supplies by up to 20% and protect the community against drought.

The financial award is a "monumental milestone," Ventura Mayor Joe Schroeder said at the invitational event where federal, state and city officials celebrated the nearly $174 million in funding and promoted the benefits of the project called VenturaWaterPure.

The loans will pay for half of the $354 million to be spent on an initial phase, program Director Linda Sumansky said. Around 60% of the roughly 5.5 million gallons of treated effluent going into the estuary daily will be diverted and an advanced purification plant built. A second phase allowing all the effluent to be diverted will cost another $80 million.

REFERENCE:

Ventura Water Pure: https://www.cityofventura.ca.gov/1646/VenturaWaterPure
Library of Documents: https://www.cityofventura.ca.gov/1685/Library-of-Reports

Pending permit applications include:

California Coastal Commission: Staff Report, Exhibits
State Lands Commission:  Staff Report

More on this Blog:  https://www.venturariver.org/search/label/wastewater