Chair Marcus and Board Members:

At a meeting held on April 9, 2013 regarding the Phase 2 Bay-Delta Plan update,comments were invited by the State Board on the discussion that occurred that day and on thereport titled Comprehensive (Phase 2) Review and Update to the Bay-Delta Plan, Draft Bay-DeltaPlan Workshops, Summary Report (Summary Report) that was used to initiate the discussion.The Central Valley Clean Water Association (CVCWA) is providing comments to identify concernswith the report and to seek modification of the report. Additionally CVCWA is reiterating someof the comments we made at the Board meeting concerning the proposal to evaluate nutrients.

Dear Ms. Gotham:
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 Mt. Shasta and U.S. Department of Agriculture, Forest Service’s (collectively, “City”) City
of Mt. Shasta Wastewater Treatment Plant (WWTP). CVCWA is a non-profit organization that represents 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 balance environmental and
economic interests consistent with state and federal law.

Dear Ms. Marcus:
The Central Valley Clean Water Association (CVCWA) appreciates this 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 laboratory accreditation as the California laboratory standard. 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 ensure proper operation of their wastewater treatment plants in a manner that is protective of public health and the environment. Additionally, others rely on small local laboratories to perform basic testing. In this letter, we provide comments on ELAP’s proposal to use the 2016 TNI as the California laboratory standard, including our concerns about the unintended consequences of adopting this standard and the lack of a real stakeholder process leading up to this proposal.

Dear Ms. Holmes:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit comments on the Tentative Order for Mountain House Community Services District’s (District) Mountain House 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 carefully review permits for POTWs being proposed for adoption with a perspective to balance environmental and economic interests consistent with applicable law.

Dear Mr. Maruya:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the draft report, “Monitoring Strategies for Chemicals of Emerging Concern (CECs) in California’s Aquatic Ecosystems”. 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 to balance environmental and economic interests consistent with state and federal law.

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.

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.

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.

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).

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.