Comments on Proposed Changes to Sanitary Sewer System (SSS) Waste Discharge Requirements (WDR) Monitoring and Reporting Program (MRP)

Dear Mr. Norman:
The undersigned statewide associations (Associations) sincerely appreciate the opportunity to provide written comments on proposed administrative changes to the Sanitary Sewer System (SSS) Waste Discharge Requirements (WDR) Monitoring and Reporting Program (MRP) released in draft form by State Water Board staff on August 14, 2012. Our associations represent public wastewater agencies providing sewer collection, wastewater treatment, and water recycling services to millions of Californians. Our associations are committed to the effective and appropriate implementation of the SSS WDR and have been partners with the State Water Resources Control Board in facilitating understanding of and compliance with the order. We also appreciate the two Data Review Committee meetings that were held in late August, 2012 to obtain feedback in a workshop setting on the proposed MRP.

Comments on the Tentative Waste Discharge Requirements for City of Delano

Dear Ms. Soria:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the tentative Waste Discharge Requirements for the City of Delano,Wastewater Treatment Facility (Tentative Order). CVCWA is a non-profit association of public agencies located within the Central Valley region that provide wastewater collection, treatment, and water recycling services to millions of Central Valley residents and businesses. We approach these matters with the perspective of balancing environmental and economic interests consistent with state and federal law. In this
letter, we provide the following comments regarding the effluent limitation for total nitrogen.

Comment Letter – Proposed SWRCB Bacteria Provisions

Dear Ms. Townsend:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide written comments on the State Water Resources Control Board’s (State Water Board’s) proposed Part 3 of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California (ISWEBE)—Bacteria Provisions and a Water Quality Standards Variance Policy (Bacteria Provisions). CVCWA is a non-profit association of public agencies located within the Central Valley region that provide wastewater collection, treatment, and water recycling services to millions of Central Valley residents and businesses. We approach these matters with the perspective of balancing environmental and economic interests consistent with state and federal law.

ELAP Year 2 ERP Report and Additional Comments on ELAP’s Consideration of Lab Standards

Dear Ms. Townsend:
The Central Valley Clean Water Association (CVCWA) appreciates this opportunity to comment on the Final Recommendations by the Expert Review Panel for the State of California’s Environmental Laboratory Accreditation Program (ELAP) Year 2 Final Report (ERP Report). CVCWA would also like to take this opportunity to provide additional comments on ELAP’s continued consideration of adopting Volume 1 of The NE LAC lnstitute’s (TNI) 2016 Standard as the basis for the quality management system (QMS) for California laboratory accreditation. CVCWA believes it is appropriate to incorporate comments on the 2016 TNI standard as a California Regulation in this letter, as the ERP Report is largely focused on ELAP’ s adoption of this standard. CVCWA appreciates the opportunity to partner with ELAP to further explore strategies, options, and implementation plans related to the new California lab accreditation standards and regulations.

Comments on the Tentative Amendments to the Waste Discharge Requirements for the Town of Discovery Bay Community Services District Discovery Bay Wastewater Treatment Plant (Order No. R5-2008-0179-01)

Dear Mr. Mamidi:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative amendments to the waste discharge requirements (Order No. R5-2008-0179-01 or “Tentative Order”) for the Town of Discovery Bay Community Services District’s (District) Wastewater Treatment Plant (WWTP). CVCWA is a non-profit organization that represents more than 50 publicly owned treatment works throughout the Central Valley Region in regulatory matters affecting surface water discharge, land application, and water reuse. We approach these matters with a perspective to balance environmental and economic interests consistent with state and federal law.

Comment Letter – Statewide Biological Objectives Policy – CEQA Scoping Comments

Dear Ms. Townsend:

Tri-TAC, the Southern California Alliance of Publicly Owned Treatment Works (SCAP) and the Central Valley Clean Water Association (CVCWA) appreciate the opportunity to provide written comments on the State Water Resources Control Board’s (State Water Board’s) Statewide Biological Objectives Policy and Program of Implementation for Perennial and Wadeable Streams CEQA Scoping Document (Policy). Tri-TAC is jointly sponsored by the California Water Environment Association, the League of California Cities, and the California Association of Sanitation Agencies. SCAP is a non-profit organization providing regulatory assistance to 86 public agencies that provide essential water and wastewater treatment to nearly nineteen million people in Southern California. CVCWA is a non-profit organization representing more than 50 publicly owned treatment works (POTWs) throughout the Central Valley Region in regulatory matters affecting surface water discharge, land application, and water reuse. Our associations collectively represent public wastewater agencies providing sewer collection, wastewater treatment and water recycling services to millions of Californians. We encourage the State Water Board to proceed carefully on this Policy, as the consequences could have profound impacts on current and future water supply and flood control, energy consumption, climate change, and the ability to provide sanitation, housing, and other services to the public.

CVCWA Comments on Draft Field-Based Methods for Developing Aquatic Life Criteria for Specific Conductivity

Dear Ms. Flaherty:
The Central Valley Clean Water Association (CVCWA) and the California Association of Sanitation Agencies (CASA) appreciate the opportunity to provide comments on the U.S. Environmental Protection Agency’s (USEPA) Draft Field-Based Methods for Developing Aquatic Life Criteria for Specific Conductivity (Draft Methods).1 CVCWA is a nonprofit association of publicly owned treatment works (POTWs) throughout the Central Valley of California whose primary mission is to represent wastewater agencies in regulatory matters while balancing environmental and economic interests. CVCWA members have a strong commitment to the protection of aquatic life in Central Valley waters. CASA is an association of local agencies engaged in advancing the recycling of wastewater into usable water and the generation of renewable energy and other valuable resources. Through these efforts we help create a clean and sustainable environment for Californians. Many of CVCWA’s and CASA’s members will be directly affected by the Draft Methods and therefore have a significant interest in their development and implementation.

Comments on the Tentative Waste Discharge Requirements Order R5-2013-XXXX, Calaveras County Water District Saddle Creek Golf Course, L.P., Copper Cover Wastewater Reclamation Facility, Calaveras County

Dear Ms. Harder:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit comments on the tentative Waste Discharge Requirements for the Calaveras County Water District Copper Cove Water Reclamation Facility (Tentative Order). Although we recognize that our comments on this permit is being submitted late, we are providing these comments in writing to express our concern and provide an opportunity prior to the hearing for Central Valley Water Board staff to consider and address these comments.

California Wastewater Climate Change Group Comments on the DRAFT report Safeguarding California: Reducing Climate Risk

To Whom It May Concern:

The California Wastewater Climate Change Group (CWCCG) appreciates the opportunity to comment on the draft report Safeguarding California: Reducing Climate Risk (Draft Safeguarding Plan) prepared by the California Natural Resources Agency (CNRA). The CWCCG is a statewide group of small, medium, and large municipalities that collect and treat over 90 percent of the municipal wastewater in California, many of whom also provide recycled water services and actively participate in the beneficial use of biosolids and biogas. The CWCCG’s mission is to address climate change policies, initiatives, and challenges through a unified voice advocating for wastewater community perspectives. CWCCG members are actively engaged in helping the State achieve its multiple mandates and goals set for 2020 under Assembly Bill 32 (AB 32) to mitigate climate change and its impacts. These include: (1) providing 33 percent of the State’s energy needs from renewable sources; (2) reducing carbon dioxide equivalent emissions to 1990 levels; (3) reducing the carbon intensity of transportation fuel used in the State by 10 percent; and (4) recycling 75 percent of the solid waste generated in the State.

Central Valley Clean Water Association’s Comments on the Preliminary Draft Order for the City of Davis Wastewater Treatment Plant

Dear Mr. Kirn:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the Preliminary Draft Order for the City of Davis Wastewater Treatment Plant (WWTP). CVCWA is a non-profit organization representing more than 50 publicly owned treatment works (POTWs) throughout the Central Valley in regulatory matters affecting surface water discharge, land application, and water reuse. We approach these matters in a way that balances environmental and economic interests consistent with applicable law.