E. coli: Why Monterey County Made a Poor Decision on the Type of Water to Use for Irrigation of Their Croplands

The problem was so acute by the 1970s that the local planners started to seriously look at alternatives to recharging their groundwater supply with high quality water. One of the more obvious solutions was to build a dam and use that source to irrigate crops and also recharge the groundwater supply. But for various reasons, that idea was never seriously adopted except for the construction of the dam forming Lake Naciemento which discharges water into the Salinas River for recharge purposes.

The problem was that even with the Naciemento Lake water, the seawater intrusion was still overtaking and ruining agricultural and domestic water wells year by year. The planners also looked at building a delivery system to allow them to take fresh canal water from the State Water Project in the Central Valley. Again for various reasons, that obvious solution was rejected by the Monterey County leaders.

In the meantime, Monterey County was realizing that government regulatory restrictions on handling effluent were increasing and their supply of effluent was also increasing with growth in the Monterey County population. It was clear that this was going to be a big problem for the County in terms of the cost of safe sewage effluent disposal and treatment.

My guess is that somebody thought, “Hey, why don’t we solve both problems with the same solution? Let’s take our tertiary-treated sewage effluent and pipe it to the farm site and use it to irrigate our crops in the area of this salt water intrusion, some 12,000 acres worth (18.75 square miles of cropland.)

1992-Present

In 1992 the Monterey Regional Water Pollution Control Agency (MRWPCA) and the Monterey County Water Resources Agency (MCWRA) formed a partnership to build two projects: a water recycling facility at the Regional Treatment Plant; and a distribution system including 45 miles of pipeline and 22 supplemental wells. Its stated objective was “to retard the advance of seawater intrusion by supplying irrigation water to nearly 12,000 acres of farmland in the northern Salinas Valley.” They believed that “this would significantly reduce the draw of water from the under ground aquifers”. The $78 million projects were completed in 1997 after three years of construction.

Reading from the current MRWPCA webpage they say:

“In the mid 1970s, a group of community leaders began discussing the idea of recycling wastewater. This led to the extensive five-year Monterey Wastewater Reclamation for Agriculture Study that began in 1980. The final results of this research proved that recycled water is safe for the irrigation of crops that are consumed without cooking. Today, this definitive report is used as the standard in countries all over the world.”

The MRWPCA goes on to say, “the use of highly treated wastewater to irrigate landscaping has been practiced for years, yet for food crops, it is relatively new”. (Emphasis added) They say further, “In the future, MRWPCA plans to additionally supply recycled water to city parks, roadway landscape and golf courses.”

They describe the tertiary treatment disinfection process they utilize thusly, “The disinfection process destroys bacteria and germs by maintaining a specific chlorine level in the water for two hours. The final product is clear, odorless and safe to use for irrigation.”

Finally, the MRWPCA says, “After treatment, the recycled water is held temporarily in an 80-acre/foot storage pond before it is distributed to farmlands via an underground 45 mile long pipeline system. During the rainy season, when the growers don't need the treated water, it is safely discharged two miles into the Monterey Bay.”

Monterey County Grand Jury Report 1999

It didn’t take long after MRWPCA and MCWRA started delivery of the tertiary treated sewage effluent to farms that serious complaints surfaced from farmers. In a 1999 Monterey Grand Jury report the first finding stated that sixty-five percent of the growers responding to a survey indicated dissatisfaction with the quality of water received. Further, eighty-two percent either believed or were uncertain whether or not long-term use of the water would have a detrimental effect on the productivity of the land. Fifty-four percent were dissatisfied with the Agency’s responsiveness to issues raised by the growers in the CSIP area. Comments were also received regarding the need for better cost controls over operations and variations in water quality based on the amount of blending with well water.

It was clear to the Grand Jury that these were issues requiring a formal response from the Monterey County Board of Supervisors (MCBOS). While the entire report of the findings of the County Board of Supervisors can be found on the Monterey County Court website, I will summarize the MCBOS responses here.

To the finding described above, the MCBOS responded that:

The Board of Supervisors partially disagrees with this finding. Water quality and customer service have been priorities of the MCWRA from the onset of the Castroville Seawater Intrusion Project (CSIP). The MCWRA recognizes that high quality customer service requires communication and responsiveness. Both are vital elements in the success of new and innovative projects. The development of relationships with the agricultural community began in the 1970's and 1980's during the Monterey Wastewater Reclamation Study for Agriculture (MWRSA) and continues today through the interactions of the Water Quality and Operations Committee and outreach efforts conducted by the MCWRA. Agency customer service and outreach efforts include:

1) Grower information meetings (held monthly for the first full year of operations and continue semi-annually; meeting attendance dropped over the first year from approximately 50 per meeting to less than ten per meeting).
2) A public outreach and education program developed by Ketchum Inc. is in position with a comprehensive response package developed for CSIP area grower/shippers.
3) Water Quality and Operations Committee (monthly meetings are held to discuss operations issues and customer concerns and provide a forum for direct input regarding the CSIP operation to the MCWRA Board of Directors).
4) Commitment of a full time staff member as an on-site grower liaison.

The second finding of the Grand Jury report found:

The Monterey Wastewater Reclamation Study for Agriculture Final Report, the pilot program for CSIP, did not adequately address the long-term effects of use of reclaimed water on agricultural lands.

To the finding described above, the MCBOS responded that:

The Board of Supervisors wholly disagrees with this finding. The Monterey Wastewater Reclamation Study for Agriculture (MWRSA) evaluated agronomic impact on soils in the CSIP area for five consecutive years and found no adverse impacts.

Based on a preliminary assessment by a Plant-Water Relations Specialist, the salinity of the CSIP water could be detrimental to certain crops grown in the project area. In 1998 and 1999, crop yields in the CSIP area were not adversely impacted by the use of recycled water. No reports were received indicating the salinity of the water delivered by the CSIP had detrimental impacts on the crops grown. Further, while the original MWRSA study did not evaluate the impact of recycled water on strawberries; there is no conclusive evidence that the water delivered by the CSIP would be detrimental to strawberries.

The Grand Jury also recommended:

The Agency, in conjunction with the Water Quality and Operations Committee, seek an independent, authoritative determination as to the agricultural suitability of the CSIP water and the long-term effect of use of this water on agricultural land.

To this recommendation the MCBOS said:

The recommendation will not be implemented because it is not warranted. The MWRSA study broke new ground in the area of recycled water research. It was the first comprehensive evaluation of agronomic use of recycled water in California, and is still cited as a reference in the development of recycled water projects. The study monitored and evaluated impacts on soil over a five-year period and found no adverse impacts from recycled water use on the MWRSA study area soils, nor were any indicators of adverse conditions identified. While the MWRSA study developed new information never before compiled and established a new standard for recycled water research, it was never intended to be the end of the monitoring and data development for the CSIP. The MCWRA and the MRWPCA have continued to monitor, study and evaluate the short and long-term impacts of the CSIP on the soils and crops grown in the project area. Laboratory monitoring budgets for the first two years of operation have exceeded $35,000 and the proposed SMP will provide additional data to build upon the work conducted under the MWRSA study. Both MCWRA and MRWPCA continue to be fully committed to evaluate and improve CSIP water quality.

To the recommendation that “The Agency increase blending of the CSIP water with well water until such time as the salinity of the effluent leaving the plant can be reduced to levels that do not impact crop yields.” The MCBOS again replied:

The recommendation will not be implemented because it is not warranted.

Blending of well water with recycled water is designed into the project through the operation of the 21 supplemental CSIP wells. Perhaps the single most important area for improved CSIP water quality is the agronomic issue of salt (or sodium) reduction. The MCWRA and MWRPCA have adopted a progressive and proactive approach to salt reduction leading to the MRWPCA Salt Reduction Program and the Salt Management Plan (SMP). Through these programs the MCWRA and MRWPCA have implemented programs to improve water quality and promote long-term satisfaction of the CSIP growers.

The project was not designed to meet all irrigation demands through the use of recycled water. For instance, water delivered in 1998 and 1999 was one-third well water and two-thirds recycled water, yielding a Sodium Absorption Ratio (a measure of agronomic water quality and sodium impact to the soil) of less than four (4). The MCWRA and MRWPCA are also developing CSIP operational protocols to better control the equity of blended water throughout the CSIP delivery area. When growers have identified the need to use well water in lieu of project water, the MCWRA has accommodated them by operating project wells and providing the growers well water. The MCWRA grower liaison provides day-to-day contact and field support for the CSIP growers.

To the recommendation by the Grand Jury that “The Agency conduct a survey of the different soil characteristics in the CSIP service area to determine if some land should be excluded from irrigating with CSIP water based on the nature of the soil and its ability to tolerate this water” the MCBOS gave what we now can see as their usual response, to wit: “The recommendation will not be implemented because it is not warranted.”

And to end their response and recap their position and basic unwillingness to change procedure and practice at the CSIP, they said:

“Finally, it should be noted, the Castroville Seawater Intrusion Project (CSIP) is the first large-scale project using recycled water as a source of water supply augmentation, and represents a departure from most if not all existing recycled water projects in California. Most present day recycled water projects have been driven by the need to manage the discharge of treated waters. The recycled water delivered by the project is key to the long-term reduction of seawater intrusion, and essential in the Monterey County Water Resources Agency’s (MCWRA) effort to preserve prime agricultural lands and the quality of life in the Salinas Valley.

Conclusion

It would appear that one of the few actions they implemented as a result of the Grand Jury report was to hire a top level public relations (PR) firm. From this action and their above response we may conclude that they believed their main problem was one of public relations and the complaints by farmers and users of CSIP were “unwarranted”.

Since that time there has been no official complaint about the system’s performance in spite of repeated national E.coli crisis traced back to the Salinas Valley. One would naturally expect that after the complete denial of the concerns of the area farmers in 1999, most people would eventually give up and determine that the elected leadership was going to continue to be unresponsive. I think that is exactly what has happened.

Over the past 10 years the FDA has increased its oversight and articulated concern and in this latest situation was forced to bring in the U.S. Department of Justice and the FBI, who are currently working to find the reason for the outbreaks.

State regulators do not require growers to test irrigation water for contaminants. To us the cause seems apparent and at the same time the circumstance seemingly most glaringly ignored by investigators. For us, the main and continuing problem is the use of tertiary treated effluent to irrigate crops consumed fresh without cooking. In particular and most vulnerable are the soft tissue, leafy green vegetables, lettuce and spinach. In the attachment to this essay I have provided a lengthy commentary which largely explains the substance of our research which contends that constant contamination can be expected from continuing to use CSIP water.

One of the major flaws in the Monterey County study efforts was an overemphasis on the soil-water effects from an agricultural perspective and a grave under-emphasis on the human health factors. One of the things we have learned from our critique of this series of actions by Monterey County over the past decade is the clear conclusion that the scientific dynamics are so complicated that they require a multi-disciplined analysis with a very wide breath of professional disciplines included in the review.

We believe that as long as crops such as lettuce and spinach are grown using tertiary treated sewage effluent, there will be continual outbreaks of E. coli 0157:H7 and similar pathogens including viruses and the resultant pain, suffering and death that can occur. This is what the FDA means when it recently predicted that without a change in practice there will be a 21st E.coli case arising from Salinas Valley. Why are they so sure? We think it’s probable that the FDA is aware of the dangers of the CSIP and such a prediction with 100% certainty is easy to make in those circumstances.

Frank Pecarich retired from the Washington, D.C. headquarters of the US Bureau of Reclamation in 1987. During his 26 year federal career he worked as a soil scientist with the USDA on the now- published Soil Survey for Monterey County. He lives in Ventura County.

An informational hearing is scheduled for Wednesday, October 11, 2006 before the California State Senate Governmental Organization Committee that is titled "Unraveling the e.coli outbreak: Are state emergency response systems prepared for outbreaks of foodborne illnesses?" Perhaps the state should be asking other questions as well.