EIS Appendix V - Effluent Study indicates the discharge would be directly into the Wilfred-Bellevue Channel and then flow into the "Laguna de Santa Rosa flood control channel" south of the site. The Appendix notes that Laguna flows reverse during flooding periods, particularly during high tides.

The Casino proposes a discharge much higher in the system than the Subregional Laguna Treatment Plant. The rationale behind this approach is that any nutrient loading resulting from the discharge is trivial compared to the Laguna Plant nutrient load. This ignores some basic and documented facts.

The second fallacy is that the additional discharge volume is small compared to the Laguna Treatment Plant. While technically correct,, this defies the entire purpose of cumulative impact analysis. The latest new increment of additional wastewater from the Casino may be a tipping factor in terms of regulatory thresholds or localized biological impacts.

The third is the apparent assumption that the Regional Water Quality Control Board would agree to determine the allowed Casino discharge volume be based upon flows in the Russian River, as opposed to at the point of discharge. Agency studies have confirmed that the proportion of wastewater within the Laguna can be quite high relative to natural flows. While the Santa Rosa Subregional system has historically been allowed to discharge based upon Russian River volumes, there is no reason or evidence to suggest that the Regional Board would extend such a standard to a new discharger, particularly one that is even farther from the Laguna/Russian River confluence.

The fifth problem is that if the Wilfred-Bellevue Channel is contained within a public utility easement (presumably in favor of the Sonoma County Water Agency in its capacity of managing infrastructure to reduce flood impacts), then some permission may be required from the Water Agency in terms of construction encroachment or actual discharge. Again, the Casino must demonstrate both the engineering capacity and legal ability to discharge into the Channel, or demonstrate an alternative discharge point that would not rely upon the Wilfred-Bellevue Channel. Such an alternative discharge point would require significantly longer infrastructure extension to permit direct discharge into the Laguna. As noted above, this would present new water quality impact issue as well new potential impacts upon CTS habitat or populations.  And this is the FIGR's preferred alternative!