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.