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.