The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the California Environmental Laboratory Accreditation Program’s (ELAP) Draft Emergency Regulations governing fees for the program. 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 CVCWA’s member agencies operate ELAP-accredited laboratories, and pay ELAP’s fees accordingly. However, these agencies’ labs are typically smaller and have tighter budgets. Thus, fee increases for ELAP accreditation is important to the bottom line for these laboratories.

On July 16, 2019, the State Water Resources Control Board (Board) will be considering a proposed Resolution adopting an emergency regulation amending the Environmental Laboratory Accreditation Program Fee Schedules in Title 22, California Code of Regulations Section 64806, which increases fees by 20 percent. Specifically, the base/administrative charge would increase from $1,890 to $2,268, and the Field of Testing fee would increase from $851 to $1,021. CVCWA would like to express its concern regarding these large increases, the need for service performance from ELAP, the overall cost of compliance of both these fees and ELAP regulation proposals, and the need for additional stakeholder involvement in future fees. State Water Resources Control Board.

Since the Board took oversight and operation of ELAP five years ago, ELAP fees have already increased by 97 percent. The current proposal would increase the current fees by an additional 20 percent, which would equate to a total 136 percent increase in fees since ELAP moved over to the Board from the Department of Public Health (DPH). CVCWA recognizes that when this occurred the program was underfunded, and that increases in fees were both needed and expected for the program to be self-sustaining. However, despite the almost doubling of fees to date, we are still concerned that the program is still not functioning at a level needed to provide an adequate level of service both needed and expected by the laboratory community. Primarily, these service concerns surround timely accreditation renewals, including addressing the backlog of audit inspections needed for accreditation and communication between ELAP and the laboratory community when changes are made to the application or compliance process.

In addition to these large fee increases, CVCWA’s main concern continues to be the overall cost of compliance if and when new accreditation standards are adopted, and the long-term viability of our small laboratories to provide the essential support services to our treatment plants. CVCWA urges ELAP staff to continue to work with the stakeholder community and to incorporate a California quality management system that would enhance the viability of our small laboratories.

A framework for a new fee structure for ELAP has been recently presented to stakeholders on June 13, 2019. This was the first meeting to discuss a revised framework since 2017. CVCWA is supportive of the development of a new framework, but hopes that Board staff will continue to involve stakeholders in its development going forward. Relatedly, we request that Board staff publish a schedule for the fee restructuring process and opportunities for stakeholders to remain engaged.

CVCWA appreciates the opportunity to provide comments on this matter. Please contact me for any further assistance you may need at (530) 268-1338 or eofficer@cvcwa.org.

Dear Mr. Harvey:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit comments on the Tentative Order for the Mariposa County Lake Don Pedro Wastewater Treatment Facility (Tentative Order). 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. Palmer:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for the Linda County Water District’s (District) Wastewater Treatment Plant (WWTP). 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 Ms. Soria:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for the Lamont Public Utilities District Wastewater Treatment Facility (Lamont WWTF). CVCWA is a non-profit organization that represents 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 Ms. Sullivan:

The Central Valley Clean Water Association (CVCWA) offers these comments for consideration by the Central Valley Regional Water Quality Control Board (Regional Water Board) staff on the Delta Regional Monitoring Program (RMP) June 14, 2012 Draft Framework (Draft Framework). CVCWA represents more than 50 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. There are no fewer than fourteen publically owned treatment works (POTW) and combined sewer system (CSS) member agencies within the legally defined Delta.

Dear Mr. Hatton:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for the Hume Lake Christian Camps Wastewater Treatment Facility (WWTF). CVCWA is a non-profit organization that represents 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 that balances environmental and economic interests consistent with state and federal law.

Dear Ms. Thayer:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the proposed order to amend Order No. R5-2005-0040 (NPDES No. CA0085103) (Proposed Order), which consists of a master reclamation permit for the City of Lincoln (Lincoln). 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 Ms. Matthews:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for the Delleker Wastewater Treatment Plant (WWTP) of the Grizzly Lake Community Services District
(District). 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 groundwater limitations for electrical conductivity (EC) and total dissolved solids (TDS). CVCWA’s comments and recommendations with respect to these issues are provided herein.

Dear Ms. Littlejohn:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide these comments as part of the Central Valley Water Quality Control Board’s (Central Valley Water Board) California Environmental Quality Act (CEQA) scoping process. CVCWA is a non-profit organization that represents publicly owned treatment works (POTWs) throughout the Central Valley Region in regulatory matters affecting surface water discharge and land application. We approach these matters with a perspective to balance environmental and economic interests consistent with applicable law. We are submitting these comments because the effort to evaluate the MUN use in agriculturally (Ag) dominated water bodies of the Central Valley and to develop subsequent Basin Plan amendments may have significant impacts on CVCWA’s members and other POTWs throughout the Region.

Dear Ms. Townsend:
The Central Valley Clear Water Association (CVCWA) appreciates the opportunity to submit comments on the Supplemental Notice of Preparation (NOP) and Notice of Scoping Meeting for Environmental Documentation for the Update and Implementation of the Water Quality Control Plan for the San Francisco Bay/Sacramento-San Joaquin Delta Estuary (Bay-Delta Plan). CVCWA is a non-profit organization representing more than 50 publicly owned treatment works (POTWs) throughout the Central Valley Region, including POTWs that discharge to the Bay-Delta. CVCWA represents its members on a number of 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.