Dear Mr. Kirn:

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 Nevada City Wastewater Treatment Facility (Nevada 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.

Dear Chairman Hoppin and Members of the Board:

On behalf of the Clean Water Summit partners, thank you for the opportunity to submit comments on the proposed revisions to the regulations governing Wastewater Treatment Plant Classification, Operator Certification, and Contract Operator Registration (the “proposed regulations”). The Clean Water Summit is a coalition of regional and statewide associations representing municipal agencies throughout California that provide wastewater collection, treatment, biosolids, renewable energy and recycled water services to millions of Californians.

Dear Mr. Isenberg:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide comments on the Delta Stewardship Council’s Recirculated Draft Delta Plan Program Environmental Impact Report (RDPEIR). CVCWA is a nonprofit association of Publicly Owned Treatment Works (POTWs) throughout the Central Valley whose primary mission is to represent wastewater agencies in regulatory matters while balancing environmental and economic interests. CVCWA members have a deep commitment to the protection of beneficial uses in the waters of the Central Valley, and have a special interest in the recovery of the Delta ecosystem. Many of CVCWA’s members will be directly impacted by the Delta Plan and have a significant interest in its development and implementation.

Dear Mr. Warner:

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 Dunsmuir Wastewater Treatment Plant (WWTP) in Shasta and Siskiyou Counties. 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. Upon reviewing the Tentative Order, CVCWA has concerns with respect to several issues. First, CVCWA is concerned with the proposed application (or lack thereof) of appropriate dilution credits. Second, CVCWA is concerned with the reasonable potential analysis statements concerning ammonia. Third, CVCWA is concerned with the inclusion of a Compliance Schedule for a Inflow and Infiltration Reduction Project and Wet Weather Capacity Improvements in the City’s NPDES permit. CVCWA’s comments and recommendations with respect to these issues are provided herein.

Dear Mr. Brownell:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the proposed amendments to the Water Quality Control Plan for the Sacramento River and San Joaquin River Basins to Establish Salinity Water Quality Objectives in the Lower San Joaquin River (LSJR Basin Plan Amendment). CVCWA is a nonprofit 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. CVCWA appreciates the opportunity to comment on the LSJR Basin Plan Amendment and to offer language similar to that which has been developed for the State Water Resources Control Board’s (State Board) Bay-Delta Plan.

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 Wastewater Treatment Plant (WWTP) of the City of Angels (City). 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.

Dear Mr. Fu:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit comments on the Tentative Order for Calaveras County Water District’s (District) Douglas Flat/Vallecito Wastewater Treatment Facility (WWTF). 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 carefully review permits for POTWs being proposed for adoption with a perspective to balance environmental and economic interests consistent with applicable law.

Elevated salinity and nitrate levels in surface water and groundwater are an increasing water quality concern throughout California, with salinity and nitrate impairments having been identified throughout the Central Valley. Therefore, in 2006, the Central Valley Regional Water
Quality Control Board, the State Water Resources Control Board, and stakeholders began a joint effort to develop a workable plan to address salinity, including nitrates, throughout the region in a comprehensive, consistent and sustainable manner.. Central Valley Salinity Alternatives for
Long-Term Sustainability (CV-SALTS) is a collaborative basin planning effort aimed at developing and implementing a comprehensive salinity and nitrate management program. The CV-SALTS Management Practices Subcommittee is working to identify effective management
practices (MPs) that will reduce salinity and nitrate discharges from a multitude of sectors, including drinking and irrigation water, stormwater, wetlands, municipal and industrial wastewater, food processing industries, agriculture, and dairies.

Dear Mr. McClure:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the Administrative Draft Basin Plan Amendment for Diazinon and Chlorpyrifos for the Sacramento and San Joaquin River Basins (Draft Amendments). 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. We approach these matters with a perspective that balances environmental and economic interests consistent with state and federal law. With respect to the Draft Amendments, CVCWA is concerned primarily with the requirement that waste load allocations would be assigned to all POTWs, even if their discharge does not exhibit reasonable potential. CVCWA also has concerns with the proposed monitoring requirements for POTWs.

Dear Ms. Harder:

The Central Valley Clean Water Association (“CVCWA”) appreciates the opportunity to submit comments on the tentative Waste Discharge Requirements and Master Reclamation Permit Order R5-­‐2007-­‐0113-­‐01 for the City of Lodi White Slough Water Pollution Control 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 spirit, we provide the following comments on the antidegradation findings, application of Title 27 to the various land application areas and their compliance schedules, and groundwater limitations