Comments on the Tentative Waste Discharge Requirements for City of Galt, Wastewater  Treatment Plant and Reclamation Facility, Sacramento County

Dear Mr. Pelkofer:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the tentative reclamation permit for the City of Galt, Wastewater Treatment Plant and Reclamation 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 letter, we provide the following comments regarding the citations to federal authorities, the interpretation of the Title 27 exemptions, certain land discharge specifications that are not consistent with Title 22, the groundwater limitation for total nitrogen, and the storm water discharge prohibition.