Comments on the Recirculated Draft Delta Plan Program Environmental Impact Report, Volume 3, November 2012, SCH No. 2010122028

Dear Mr. Isenberg:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide comments on the Delta Stewardship Council’s Recirculated Draft Delta Plan Program Environmental Impact Report (RDPEIR). CVCWA is a nonprofit association of Publicly Owned Treatment Works (POTWs) throughout the Central Valley whose primary mission is to represent wastewater agencies in regulatory matters while balancing environmental and economic interests. CVCWA members have a deep commitment to the protection of beneficial uses in the waters of the Central Valley, and have a special interest in the recovery of the Delta ecosystem. Many of CVCWA’s members will be directly impacted by the Delta Plan and have a significant interest in its development and implementation.

Full Letter – Comments on the Recirculated Draft Delta Plan Program Environmental Impact Report, Volume 3, November 2012, SCH No. 2010122028

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Comments on Renewal of Waste Discharge Requirements (NPDES Permit No. CA0078441) for City of Dunsmuir Wastewater Treatment Plant, Shasta and Siskiyou Counties

Dear Mr. Warner:

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 Dunsmuir Wastewater Treatment Plant (WWTP) in Shasta and Siskiyou Counties. 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 the inclusion of a Compliance Schedule for a Inflow and Infiltration Reduction Project and Wet Weather Capacity Improvements in the City’s NPDES permit. CVCWA’s comments and recommendations with respect to these issues are provided herein.

Comments on the Tentative Waste Discharge Requirements for the City of Tracy’s Wastewater Treatment Plant

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Water Quality Control Plan for the Sacramento River and San Joaquin River Basins to Establish Salinity Water Quality

Dear Mr. Brownell:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the proposed amendments to the Water Quality Control Plan for the Sacramento River and San Joaquin River Basins to Establish Salinity Water Quality Objectives in the Lower San Joaquin River (LSJR Basin Plan Amendment). CVCWA is a nonprofit 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. CVCWA appreciates the opportunity to comment on the LSJR Basin Plan Amendment and to offer language similar to that which has been developed for the State Water Resources Control Board’s (State Board) Bay-Delta Plan.

Full Letter – Water Quality Control Plan for the Sacramento River and San Joaquin River Basins to Establish Salinity Water Quality

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The Central Valley Clean Water Association’s Comments on the Tentative Waste Discharge Requirements for the City of Angels Wastewater Treatment Plant

Dear Ms. Jimmerson:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the tentative waste discharge requirements (Tentative Order) for the Wastewater Treatment Plant (WWTP) of the City of Angels (City). 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.

Full Letter – The Central Valley Clean Water Association’s Comments on the Tentative Waste Discharge Requirements for the City of Angels Wastewater Treatment Plant

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Central Valley Clean Water Association’s Comments on the Tentative Order for the Douglas Flat/Vallecito Wastewater Treatment Facility

Dear Mr. Fu:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit comments on the Tentative Order for Calaveras County Water District’s (District) Douglas Flat/Vallecito Wastewater Treatment Facility (WWTF). 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.

Full Letter – Central Valley Clean Water Association’s Comments on the Tentative Order for the Douglas Flat/Vallecito Wastewater Treatment Facility

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Comments on the Administrative Draft Basin Plan Amendment for Diazinon and Chlorpyrifos for the Sacramento River and San Joaquin River Basins

Dear Mr. McClure:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit these comments on the Administrative Draft Basin Plan Amendment for Diazinon and Chlorpyrifos for the Sacramento and San Joaquin River Basins (Draft Amendments). 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. With respect to the Draft Amendments, CVCWA is concerned primarily with the requirement that waste load allocations would be assigned to all POTWs, even if their discharge does not exhibit reasonable potential. CVCWA also has concerns with the proposed monitoring requirements for POTWs.

Full Letter – Comments on the Administrative Draft Basin Plan Amendment for Diazinon and Chlorpyrifos for the Sacramento River and San Joaquin River Basins

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Comments on the Tentative Waste Discharge Requirements and Master Reclamation Permit Order R5-­‐2007-­‐0113-­‐01, City of Lodi White Slough Water Pollution Control Facility, San Joaquin County

Dear Ms. Harder:

The Central Valley Clean Water Association (“CVCWA”) appreciates the opportunity to submit comments on the tentative Waste Discharge Requirements and Master Reclamation Permit Order R5-­‐2007-­‐0113-­‐01 for the City of Lodi White Slough Water Pollution Control 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 spirit, we provide the following comments on the antidegradation findings, application of Title 27 to the various land application areas and their compliance schedules, and groundwater limitations

Full Letter –  CVCWA Comments Lodi Order R5-2007-0113-01Download

CVCWA Comments on Renewal of Waste Discharge Requirements and NPDES Permit for the River Highlands

Dear Mr. Taylor:
The Central Valley Clean Water Association (CVCWA) appreciates this opportunity to provide comments on the Tentative Waste Discharge Requirements and NPDES permit for the River Highlands Community Services District (River Highlands CSD) Hammonton Gold Village 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 toxicity trigger of >1 toxic unit.

Full Letter – CVCWA Comments on Renewal of Waste Discharge Requirements and NPDES Permit for the River Highlands

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Comprehensive (Phase 2) Bay-Delta Technical Workshops

Dear Ms. Riddle:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide input on the format and questions for workshops on the Comprehensive (Phase 2) Review of 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.

Full Letter – Comprehensive (Phase 2) Bay-Delta Technical Workshops

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Comments on the Tentative Waste Discharge Requirements Order R5-­‐2013-­‐XXXX (NPDES No. CA0079243), City of Lodi White Slough Water Pollution Control Facility, San Joaquin County

Dear Ms. Harder:

The Central Valley Clean Water Association (“CVCWA”) appreciates the opportunity to submit comments on the tentative Waste Discharge Requirements for the City of Lodi White Slough Water Pollution Control 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 spirit, we provide the following comments on the effluent limitation for temperature, reasonable potential determinations based on best professional judgment and the turbidity discussion in the Fact Sheet.

Full Letter – Tentative Waste Discharge Requirements Order R5-­‐2013-­‐XXXX (NPDES No. CA0079243), City of Lodi White Slough Water Pollution Control Facility, San Joaquin County

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