Joint Comments on Proposed New Water Quality Beneficial Uses Oct 17, 2016 Comment Letters Agency: State Water Resources Control Board Subject: Proposed New Water Quality Beneficial Uses Other signatories: Rural Counties Representatives of California, California Association of Sanitation Agencies, California Building and Industry Association Letter excerpt: Our organizations write to respectfully request that the State Water Resources Control Board (“SWRCB”) move forward with determining the need for Proposed New Water Quality Beneficial Uses (“Proposed Beneficial Uses”) in a process that is separate from the notice and comment period that will be held for the Statewide Mercury Amendment to the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays and Estuaries (“Mercury Amendment”). While our organizations and members appreciate the focused outreach that has been held by the SWRCB staff thus far in regards to the Proposed Beneficial Uses, and the clarifications that were provided in the Frequently Asked Questions document (“FAQ Document”) that was circulated at the September 20, 2016 SWRCB meeting, we have not had adequate time to fully evaluate the impacts that these Proposed Beneficial Uses could have on our members’ operations and compliance obligations. We encourage the SWRCB to hold a technical workshop and circulate a staff report prior to issuing a draft of the Mercury Amendment, so that we and our members have an opportunity to address our questions regarding the development and implementation of the Proposed Beneficial Uses prior to engaging in the review process that will be required in order to review the Mercury Amendment itself. Download joint comment letter
