Joint Comments on Water Quality Enforcement Policy Modifications

  • Mar 3, 2017
  • Comment Letters

Agency: State Water Resources Control Board

Subject: Water Quality Enforcement Policy Modifications – Request for Stakeholder Process

Other signatories: California Association of Sanitation Agencies, Bay Area Clean Water Agencies, Central Valley Clean Water Association, Southern California Alliance of Publicly Owned Treatment Works

Letter excerpt:

Instead, we urge you to sponsor and oversee a meaningful stakeholder process to discuss the proposed modifications as was done in 2009 when this policy was first proposed and adopted. Such a process is needed in order to adequately understand the reasons for changes to the existing policy, to discuss modifications that restore flexibility and negate against unnecessarily increasing penalties for specific types of discharges, and to weigh the benefits of increasing the amount of penalties that can go towards Supplemental Environmental Projects (SEPs) and Enhanced Compliance Projects (ECAs) from the current cap of 50%. Allowing stakeholders to engage together and understand each other’s positions and the ramifications of the modifications will ensure a more fair, clear, and consistent final policy. Because the current 2010 policy will remain in place, there is no time constraint on adoption, which allows for this stakeholder process to be undertaken.

The signatories to this letter are understandably concerned that their voices have not been heard. Before and after the first hearing, each entity sent letters asking for modifications to the policy, and SCAP even sent in redlines of the entire proposed policy. A few changes were made in response to comments from the water supply community, including ACWA and the California Water Association. However, no changes were made to address the remaining valuable and thoughtful comments, especially those made by the publicly owned treatment works community. This is why, at the last hearing on this item, you heard comments asking for changes to be made.

Download joint comment letter

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