Joint Comments on Beneficial Uses and Mercury Objectives Jan 20, 2017 Comment Letters Agency: State Water Resources Control Board Subject: Comment Letter – Beneficial Uses and Mercury Objectives Other signatories: California Water Association, California Municipal Utilities Association Letter excerpt: We appreciate that it is the State Water Board’s preference, as indicated by staff at the workshop, to promulgate the mercury water quality objectives, instead of EPA, so that it can develop concurrently a program of implementation. We generally support the State Water Board’s preference, and recognize the potential advantages in designing a comprehensive mercury program versus a piecemealed approach that would require multiple rulemakings. For this reason, we recommend working with EPA to request a minimum 3-month automatic extension of the June 30, 2017 Consent Decree due date, and the adjustments to the schedule for the public rulemaking process set forth above. To show the feasibility of our request to revise the rulemaking schedule to provide a robust and transparent rulemaking process, we provide an alternative conceptual schedule for the process in Attachment A of this letter. A rulemaking of this magnitude, scope, complexity, and technical nature – not to mention the regulatory implications of the program which will likely extend far beyond regulation of mercury in light of the new beneficial use categories proposed – surely warrants more than five and a half weeks total of public review and comment, and more than a single workshop and Board hearing. Download joint comment letter
