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