Comment Letter – Variance Policy – Scoping Comments

Dear Ms. Townsend:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide these comments in response to the State Water Resources Control Board’s (State Water Board) Notice of Public Scoping Meeting for a Statewide Water Quality Standards Variance Policy. CVCWA represents over 50 publicly-owned treatment works (POTWs) that provide wastewater collection, treatment, and disposal for over 7 million people in the Central Valley. CWCWA’s mission is to represent the interests of wastewater agencies in the Central Valley in regulatory matters that balance the need for environmental protection based on sound scientific information with a fair and reasonable economic basis. CVCWA was instrumental in the development of the Central Valley Regional Water Quality Control Board’s (Central Valley Water Board) variance policy, and has a significant interest in the development of a statewide variance policy.

Comment Letter on ELAP Regulations Development/Laboratory Standard

Dear Chair Marcus:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the California Environmental Laboratory Accreditation Program’s (ELAP) recommendation to adopt Volume 1 of The NELAC Institute’s (TNI) 2016 Standard as the basis for the quality management system (QMS) for California laboratory accreditation.1 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. Many of our members operate environmental laboratories to provide compliance monitoring and ensure proper operation of their wastewater treatment plants in a manner that is protective of public health and the environment. Others rely on small local laboratories to perform basic testing. In this letter, we provide further comments regarding ELAP’s proposal to base forthcoming regulations on the 2016 TNI Standard, and its potential impact on publically-owned treatment works (POTWs) in the Central Valley. This letter is not intended to provide an exhaustive list of provisions within the 2016 TNI Standards that we believe are problematic, but rather provide a few examples of some of the problems that specific provisions will create for municipal laboratories, especially small laboratories.

CVCWA Comments on Proposed 303(d) List Revisions

Dear Mr. Simi:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide comments on the proposed revisions to the Clean Water Act Section 303(d) List of Impaired Water Bodies (303(d) List) within the Draft 2014 Integrated Report. CVCWA represents the interests of over 50 publically-owned treatment works (POTWs) in the Central Valley in regulatory matters related to water quality and the environment. CVCWA’s member agencies are directly and indirectly impacted by the proposed update to the draft 303(d) List.

Draft Basin Plan Amendments for Pyrethroid Pesticides

Dear Ms. Fojut:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the proposed Basin Plan Amendments for Pyrethroid Pesticides to the Water Quality Control Plan for the Sacramento-San Joaquin River Basins (Draft BPA). 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 comments regarding the Draft BPA, and its potential impact on Central Valley publically-owned treatment works (POTWs).

Comments on the Draft Water and Sediment Quality Criteria Report for Fipronil, October 2016

Dear Ms. Fojut,
The Central Valley Clean Water Association (CVCWA) represents over 50 publicly-owned treatment works (POTWs) that provide wastewater collection, treatment, and disposal for over 7 million people in the Central Valley. CWCWA’s mission is to represent the interests of wastewater agencies in the Central Valley in regulatory matters that balances the need for environmental protection based on sound scientific information with a fair and reasonable economic basis.

Central Valley Clean Water Association’s Comments on the Cities of Fresno and Clovis Regional Wastewater Reclamation Facility

Dear Mr. Mushegan:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the tentative Waste Discharge Requirements for the Cities of Fresno and Clovis Regional Wastewater Reclamation Facility, Fresno County (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 requirements that Fresno replace all monitoring wells that have gone dry, Discharge Specification D.1, electrical conductivity (EC) objectives and limitations, and ultraviolet (UV) disinfection dosing specifications.

Full Letter – CVCWA Comments on Regional Wastewater Reclamation Facility

Central Valley Clean Water Association’s Comments on the Tentative Order for the El Dorado Hills Wastewater Treatment Plant

Dear Mr. Kirn:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the Tentative Order for El Dorado Irrigation District’s (EID) El Dorado Hills 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.

Full Letter – CVCWA Comments on EID El Dorado Hills

Comments on the Tentative Waste Discharge Requirements for El Dorado Irrigation District, Camino Heights Wastewater Treatment Facility

Dear Ms. Fu:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for El Dorado Irrigation District’s Camino Heights Wastewater Treatment Facility (WWTF). CVCWA is a non-profit organization representing 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. For the following
reasons, CVCWA respectfully requests that you revise the Tentative Order to reflect that the applicable water quality objective for electrical conductivity (EC) is a range, rather than 900 micromhos per centimeter (µmhos/cm).

Comments on the Tentative Waste Discharge Requirements for the City of Modesto Water Quality Control Facility

Dear Ms. Jimmerson:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for the City of Modesto Water Quality Control Facility (Modesto WQCF). CVCWA is a non-profit organization representing 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.