Dear Chairman Hoppin and Members of the Board:

The Central Valley Clean Water Association (CVCWA) submits these comments on the proposed order in the Petitions of Sacramento County Sanitation District and California Sportfishing Protection Alliance (Waste Discharge Requirements Order No. R5-2010-0114 [NPDES NO. CA0077682] for the Sacramento Regional County Sanitation District, Sacramento Regional Wastewater Treatment Plant, Sacramento County) (hereafter “Proposed Order”). CVCWA is a non-profit organization whose members include publicly owned treatment works (POTWs) throughout the Central Valley Region. We represent our members in regulatory matters affecting surface water discharge and land application with a perspective to balance environmental and economic interests consistent with state and federal law. Because the Proposed Order would have far-reaching consequences for POTWs throughout the Region, we offer the following comments.

Dear Ms. Townsend:
The Central Valley Clean Water Association (CVCWA) appreciates this opportunity to provide comments on the Proposed Rulemaking for 1,2,3- Trichloropropane Maximum Contaminant Level. CVWA 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 municipal and domestic beneficial uses in Central Valley waters. The Proposed Rulemaking will inadvertently impact POTWs because maximum contaminant levels (MCLs), once adopted, become water quality objectives per incorporation by reference language in the Central Valley Water Quality Control Plans. Accordingly, it is imperative that the Division of Drinking Water consider such impacts when it adopts MCLs. CVCWA provides the following comments on the Proposed Rulemaking because of this impact.

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.

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.