To Whom It May Concern:

The California Wastewater Climate Change Group (CWCCG) appreciates the opportunity to comment on the draft report Safeguarding California: Reducing Climate Risk (Draft Safeguarding Plan) prepared by the California Natural Resources Agency (CNRA). The CWCCG is a statewide group of small, medium, and large municipalities that collect and treat over 90 percent of the municipal wastewater in California, many of whom also provide recycled water services and actively participate in the beneficial use of biosolids and biogas. The CWCCG’s mission is to address climate change policies, initiatives, and challenges through a unified voice advocating for wastewater community perspectives. CWCCG members are actively engaged in helping the State achieve its multiple mandates and goals set for 2020 under Assembly Bill 32 (AB 32) to mitigate climate change and its impacts. These include: (1) providing 33 percent of the State’s energy needs from renewable sources; (2) reducing carbon dioxide equivalent emissions to 1990 levels; (3) reducing the carbon intensity of transportation fuel used in the State by 10 percent; and (4) recycling 75 percent of the solid waste generated in the State.

Dear Mr. Harvey:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative Waste Discharge Requirements and Master Recycling Permit (Tentative Order) for the City of Tulare Wastewater Treatment Facility (Tulare 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 Mr. Kirn:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the Preliminary Draft Order for the City of Davis Wastewater Treatment Plant (WWTP). 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 approach these matters in a way that balances environmental and economic interests consistent with applicable law.

Dear Ms. Gaido:
The Central Valley Clean Water Association (CVCWA) appreciates this opportunity to provide comments on the Tentative Waste Discharge Requirements for the Shasta County Service Area No. 8 (Shasta CSA No. 8) Palo Cedro Wastewater Treatment Plant (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 comments regarding the setback limits for land application areas.

Dear Ms. Creedon:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide comments on the 2013 joint triennial review of the water quality control plans for the Sacramento River and San Joaquin River Basins and the Tulare Lake Basin (Basin Plans). 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.

Dear Ms. Holmes:

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 Tracy’s Wastewater Treatment Plant (WWTP). 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 approach these matters with a perspective that balances environmental and economic interests consistent with applicable law.

Dear Chairman Hoppin and Members:
The Central Valley Clean Water Association (CVCWA) appreciates this opportunity to comment on the State Water Resources Control Board (State Water Board) June 2012 Policy for Toxicity Assessment and Control – Public Review Draft (Draft Policy) and Draft Staff Report and Environmental Checklist (Draft Staff Report).

CVCWA consists of public agencies located within the Central Valley region, and under the jurisdiction of the Central Valley Regional Water Quality Control Board. Our members provide wastewater collection, treatment and water recycling services to millions of Central Valley residents and businesses. CVCWA is also a co-signatory on comments sent by the Associations (CASA, Tri-TAC, SCAP, BACWA, CVCWA, and RCRC. In addition to those comments, this letter provides additional detailed comments on issues of greatest importance to CVCWA. Our specific comments are included below.


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.