Joint Comments on Statewide Dredged or Fill Procedures Aug 18, 2016 Comment Letters Agency: State Water Resources Control Board Subject: Statewide Dredged or Fill Procedures Other signatories: Association of California Cities – Orange County Bay Area Council Bay Planning Coalition Building Industry Association of Southern California Building Industry Legal Defense Foundation California Alliance for Jobs California Association of REALTORS® California Association of Winegrape Growers California Building Industry Association California Business Properties Association California Cattlemen’s Association California Chamber of Commerce California Construction and Industrial Materials Association California Farm Bureau Federation California Forestry Association California League of Food Processors California Municipal Utilities Association California Manufacturers and Technology Association California Water Association Construction Industry Coalition on Water Quality Dairy Cares Kaweah Delta Water Conservation District Large-Scale Solar Association League of California Cities Orange County Business Council Pacifica Legal Foundation Valley Ag Water Coalition Western Growers Association Western States Petroleum Association Wine Institute Letter excerpt: While we appreciate the State Board’s efforts to create a program that is consistent with the Corps’ current regulatory requirements, we continue to have concerns about the scope of the Procedures, which are overbroad relative to the needs and legal authority; redundant and sometimes conflicting requirements caused by the excessive scope; and vague and undefined terms that are likely to lead to inconsistent applications. Accordingly, if the State Board determines it needs to act, we encourage the adoption of a program that fills the regulatory gap by protecting non-federal waters of the state as if they were regulated by the Corps’ current procedures under the 1987 guidelines, including adopting a wetlands definition that is identical to the well-established definition used by the Corps. These and other comments are addressed in the attached comment package. Download joint comment letter
