Member Comments on Statewide Procedures for Discharges of Dredged or Fill Materials

  • Sep 18, 2017
  • Comment Letters

Agency: State Water Resources Control Board

Subject: Statewide Procedures for Discharges of Dredged or Fill Materials into Water of the State

Signatories: San Bernardino Valley Water Conservation District, City of Ventura, Santa Clara Valley Water District

Letter excerpt:

Our comments focus on the Proposed Regulatory Program’s effects on our water agencies’ ability to sustainably, reliably, and in an environmentally sensitive manner provide for augmentation of water supply, storage, and capture, as well as natural treatment of urban runoff, storm water, wastewater treatment plant discharges, and impaired surface waters. Specifically, our comments address and provide relevant examples of the substantial costs and permitting and project implementation delays associated with the Proposed Regulatory Program’s new permitting requirements for activities related to Multi-benefit Constructed Facilities, which are artificial, man-made, or improved facilities operated to provide water supply/quantity, water storage, water conveyance, water quality treatment, and/or storm water, runoff or flood protection functions, while also providing other environmental benefits, such as: groundwater recharge; natural beds, banks, soils, or substrates; and wetland, riparian, or other habitat and vegetation, including, without limitation, naturalized surface water, runoff, or storm water quality treatment facilities or structural best management practices; naturalized surface water, runoff, storm water, or flood management swales, conveyance channels, or basins;naturalized percolation ponds and percolation channels; bio-filtration and bio-retention basins, ponds, and wetlands; and naturalized groundwater and surface water storage facilities.

Download member comment letter

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