Reference Documents

Thursday, September 11, 2014

CDOs on Regional Water Board Agenda!

Find relevant links here for the September 25, 2014 meeting:

Agenda link—see Item 13, "Enforcement"
http://www.swrcb.ca.gov/centralcoast/board_info/agendas/2014/Sepember/agenda_files/agenda_sep2014%20a.htm

Relevant documents page, off which are numerous links.
http://www.swrcb.ca.gov/centralcoast/board_info/agendas/2014/Sepember/item13/index.shtml

To cut to the chase, the Enforcement Staff's recommendations are thus:
  1. The County has not yet completed the community system, and while we are confident that it will, this outcome is not guaranteed.
  2. The main requirement of the orders, hooking up to the sewer when it becomes available, cannot yet be complied with. This requirement should stay in place until the system is available.
  3. Even when the system is available, there may be dischargers in the prohibition zone who are reluctant or refuse to hook up. Leaving these orders in place maintains a disincentive for order recipients to continue violating the prohibition after construction of the sewer system. 
We ALL should have gotten CDOs OR NOVs to begin with. In other words, we all should have been treated equally. While I disagreed many times with the frantic fight against these orders, as in real life, they didn't amount to much unless one chose to react that way about them (think of all of those who simply signed that paper and moved on), the unfairness to not be treated equally, I think, we can all agree on.

There are just as many NOV holders, probably more actually, who may not comply with hooking up to the sewer when it is available, so point 3 just seems to be a way to cut costs or something on a CDO holder who does not comply. In other words, maybe the Board would have to start from scratch with a non-compliant NOV holder, but it wouldn't with a CDO holder? Again, it just looks like playing unfavorites. 

So, IMHO, I believe the Board should adopt the resolution offered which TERMINATES these orders!
http://www.swrcb.ca.gov/centralcoast/board_info/agendas/2014/Sepember/item13/item13_att2.pdf


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