In a June 16 letter to State Water Resources Control Board (State Board) Executive Director Tom Howard, California Water Association (CWA) joined numerous water associations and individual water agencies and utilities in requesting an extension of the public comment period and an additional opportunity for input by the regulated water community regarding the State Board’s Draft Statewide National Pollutant Discharge elimination System Permit for Drinking Water Systems Discharges, released for public comment on June 6,2014. The public comments were due on July 8, and the State Board originally scheduled a public hearing on July 15 and final approval of the permit for August 5.

In its letter, CWA said it was concerned that the current public process fails to substantively comply with applicable notice requirements and fails to provide stakeholders with a meaningful opportunity to work with the State Board staff to resolve policy and operating issues created by the Draft Permit. CWA also was concerned that the Draft Permit issued did not contain an essential attachment (Attachment G) dealing with Total Maximum Daily Loads and Waste Load Allocations to Water Purveyors that is critical to fully understanding the manner in which the permit will be implemented. Given these deficiencies, CWA requested the State Board:

  1. Hold one or more additional staff/stakeholder workshops;
  2. Direct staff to develop a revised Draft Permit for a 45-day comment period following the issuance of Attachment G and the last workshop;
  3. Extend the comment deadline accordingly, from July 8; and
  4. Postpone and reschedule the July 15 public hearing and August 5 approval date.

On June 20, the State Board agreed to these requests, scheduling workshops for early and mid-July, extending the public comment period until August 5, and the adoption meeting until September 19.

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