On 6 June 2011, CSPA and C-WIN submitted final comments on the proposed extension of the existing Irrigated Lands Program waiver to the Central Valley Regional Water Quality Control Board (Regional Board). The Regional Board will consider a two-year extension of the existing waiver at its 9 June 2011 hearing.
CSPA informed the Regional Board that renewing the existing waiver program for two additional years is inconsistent with California’s Antidegradation Policy, the State Water Resource Control Board’s Policy for Implementation and Enforcement of the Nonpoint Source Pollution Control Program and the public interest requirements of the Water Code. Additionally, the Regional Board cannot rely upon the PEIR to comply with the California Environmental Quality Act for the proposed waiver renewal because the PEIR is legally and factually deficient. Waiver Renewal Comment Letter