Comments on the Tentative Waste Discharge Requirements and Master Reclamation Permit for City of Lathrop, Lathrop Consolidated Treatment Facility, San Joaquin County

Dear Mr. Armstrong:

The Central Valley Clean Water Association (CVCWA) appreciates the opportunity to comment on the tentative Waste Discharge Requirements and Master Reclamation Permit for the City of Lathrop (City) Lathrop Consolidated 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 applicable groundwater objectives, the performance-­‐based effluent limitation for total dissolved solids, and the recycled water specifications, and request revisions as indicated herein.