CASA Provides Detailed Comments on Proposed Revisions to the Monitoring and Reporting Program for the Sanitary Sewer Systems Statewide General Order
On October 2, 2012, CASA provided detailed comments to the State Water Resources Control Board (State Water Board) staff regarding the proposed revisions to the Monitoring and Reporting Program (MRP) for the General Waste Discharge Requirements for Sanitary Sewer Systems (SSO WDR). These revisions can be implemented with the State Water Board Executive Director’s approval and do not have to go before the State Water Board. CASA and Tri-TAC have scheduled a meeting with the State Water Board Executive Director and Assistant Executive Director to express our concerns and attempt to scale back the proposed MRP.
CASA, along with the California Water Environment Association (CWEA) and Tri-TAC, expressed support for three of the proposed changes to the MRP: (1) delineating three categories of overflows in place of the current two; (2) clarifying the event-based approach to reporting; and (3) clarifying that agencies should only contact Cal EMA for immediate reporting.
Key areas of concern include:
- The revised draft MRP goes beyond the intent expressed by State Water Board members, which was not to change the WDR. Many of the proposed changes to the MRP create new policy or substantive requirements, which should only be imposed through amendments to the WDR.
- The intent of the SSS WDR and the MRP is to reduce SSOs. If the extensive requirements in the revised MRP are implemented, agency staff will be spending all their time and resources with compiling more documentation, which will divert resources that are being used to reduce SSOs.
- It is inappropriate to require all agencies to comply with significant new requirements when only a few agencies are reporting a significant number of overflows and overflows to surface waters. For example, it is recognized that only 2% of the overflows in California are more than 1,000 gallons.
To review the complete set of comments, [click here]