Dear Ms. Soria:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the tentative Waste Discharge Requirements for the City of Delano, Wastewater Treatment 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 effluent limitation for total nitrogen.

Dear Ms. Fojut:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to provide the early 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 development of water quality objectives and a total maximum daily load (TMDL) for pyrethroid pesticides may have significant impacts on CVCWA’s members and other POTWs throughout the Region.

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.

Dear Ms. Thayer:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit comments on the tentative Waste Discharge Requirements for the Placer County Sewer Maintenance District 3 (District) 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 spirit, we
provide the following comments regarding the Tentative Order’s justification for Biological Oxygen Demand and Total Suspended Solids effluent limitations.

Dear Mr. Meeks:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the proposed amendment to the Water Quality Control Plan for the Tulare Lake Basin to remove the Municipal and Domestic Supply (MUN) and Agricultural Supply (AGR) beneficial uses from groundwater within horizontally and vertically delineated areas underlying a portion of the historical Tulare Lake Bed. 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.

Dear Ms. Fu:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the tentative Waste Discharge Requirements for the California Department of Corrections and Rehabilitation, Mule Creek State Prison 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 the following comments regarding the land application area specifications and the effluent limitation for total nitrogen.


Chair Marcus and Board Members:

At a meeting held on April 9, 2013 regarding the Phase 2 Bay-Delta Plan update,comments were invited by the State Board on the discussion that occurred that day and on thereport titled Comprehensive (Phase 2) Review and Update to the Bay-Delta Plan, Draft Bay-DeltaPlan Workshops, Summary Report (Summary Report) that was used to initiate the discussion.The Central Valley Clean Water Association (CVCWA) is providing comments to identify concernswith the report and to seek modification of the report. Additionally CVCWA is reiterating someof the comments we made at the Board meeting concerning the proposal to evaluate nutrients.

Dear Ms. Gotham:
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 Mt. Shasta and U.S. Department of Agriculture, Forest Service’s (collectively, “City”) City
of Mt. Shasta Wastewater Treatment Plant (WWTP). CVCWA is a non-profit organization that represents 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 balance environmental and
economic interests consistent with state and federal law.

Dear Ms. Marcus:
The Central Valley Clean Water Association (CVCWA) appreciates this opportunity to comment on the California Environmental Laboratory Accreditation Program’s (ELAP) recommendation to adopt Volume 1 of The NELAC Institute’s (TNI) 2016 standard as the basis for laboratory accreditation as the California laboratory standard. 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 our members operate environmental laboratories to ensure proper operation of their wastewater treatment plants in a manner that is protective of public health and the environment. Additionally, others rely on small local laboratories to perform basic testing. In this letter, we provide comments on ELAP’s proposal to use the 2016 TNI as the California laboratory standard, including our concerns about the unintended consequences of adopting this standard and the lack of a real stakeholder process leading up to this proposal.

Dear Ms. Holmes:
The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to submit comments on the Tentative Order for Mountain House Community Services District’s (District) Mountain House 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 carefully review permits for POTWs being proposed for adoption with a perspective to balance environmental and economic interests consistent with applicable law.