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CSPA
files comments on City of Woodlands request for renewal Of Waste
Discharge Requirements for their Water Pollution Control Facility
December 30, 2008 -- On December 26th, CSPA's Executive Director, Bill Jennings, filed comments on the proposed permit, requesting status as a designated party for the proceeding.
In review, CSPA found that the proposed Permit contains Effluent Limitations less stringent than the existing permit for Settleable Solids and Oil and Grease contrary to the Antibacksliding requirements of the Clean Water Act and Federal Regulations, 40 CFR 122.44 (l)(1). Further, the proposed Permit contains an inadequate antidegradation analysis that does not comply with the requirements of Section 101(a) of the Clean Water Act, Federal Regulations 40 CFR § 131.12, the State Board’s Antidegradation Policy (Resolution 68-16) and California Water Code (CWC) Sections 13146 and 13247.
Read CSPA's Comments and Request for Designated Party Status