On 20 May 2014, CSPA submitted comments on the proposed General Order Waste Discharge Requirements for Recycled Water by the State Water Resources Control Board. The Order will regulate the discharge of recycled water to land and surface waters. CSPA believes that the proposed Order is not protective of water quality and is contrary to explicit requirements of the federal Clean Water Act.
Additionally, CSPA protested the Board’s use of the Governor’s declaration of a state of emergency due to severe drought to avoid having to comply with the California Environmental Act (CEQA) is unacceptable and illegal. The provisions of the Order will extend far into the future beyond the present drought period. Indeed, it is unlikely that water-recycling projects implemented pursuant to this Order could be developed and implemented in time to have a material effect on the present drought. Given the potential threats to water quality, a Negative Declaration would be inadequate and a full CEQA document must be prepared.