Although overall supportive CVCWA shared the following three concerns:
- The draft staff report and associated economic analysis are incorrect in assuming no additional cost for WWTP dischargers to monitor for E. coli.WWTP dischargers that meet effluent limitations based on Title 22 disinfection requirements should not be required to monitor for E. coli.
- The 13241 analysis does not include a description of the water quality conditions that are achievable through coordinated control of all factors which affect water quality in the area.
- Appendix C of the draft staff report uses an inappropriate conversion factor to convert fecal coliform objectives to E. coli objectives.
Comments Letter – August 16, 2017 | Comments Letter – February 14, 2018
In January 2018, SWRCB released a new draft of this objective and implementation plan. The new draft plan includes a provision that any Publicly Owned Treatment Works (POTWs) which currently applies more stringent bacteria requirements is already in compliance and will not have to change their current monitoring methods as compliance with existing criteria is sufficient.