July 19, 2017
Mr. David Kuszmar, PE
Watershed Protection Division, TMDL Unit
North Coast Regional Water Quality Control Board
5550 Skylane Boulevard, Suite A,
Santa Rosa, CA 95403
(delivered via E-mail to David.Kuszmar@waterboards.ca.gov)
Dear Mr. Kuszmar,
I am writing to provide comments on the “Attachment 1 to Resolution No. R1-2017-0027, Water Quality Trading Framework for the Laguna de Santa Rosa Watershed, Public Review Draft, June 14, 2017. (draft Framework) I want to see the draft framework strictly adhere to the Guiding Principles of Sound Science, Accountability, Transparency and (public) Accessibility to ensure any transactions are held to the same standards required of NPDES Point Sources in the Federal and State Clean Water Act. In general I think it is dishonest to call this a Water Quality Trading program since it is proposed to conduct trades for POLLUTANTS and polluted runoff not Clean Water or Water Quality so it should be called what it really is, a Water Pollution Trading program and not spin reality.
I believe there are too many avenues to avoid meeting the 4 key principles listed above and offer the following suggestions to remedy those deficiencies:
As Water Pollution Trading is not expressly authorized in the Clean Water Act, we expect the above comments to be incorporated into the draft Framework prior to adoption later this year to be consistent with NPDES requirements so that this program complies with the mandates of NPDES permits.
Thank you for the opportunity to comment on this document.
(Your name, Address or email & city you live in)