SITE INFORMATION AND CORRESPONDENCE

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Bruce Coleman 3 - 15 October 2004 The following discussion provides information on permits required by the Regional Water Board for the project. Waste Discharge Requirements Because wastewater will be generated and treated, stored, or disposed on site, WDRs will be required. The project proponent shall submit an RWD at least 140 days prior to discharging wastewater at the site as required by California Water Code Section 13260. Objections to the WDRs may cause significant delays in the adoption of WDRs by the Regional Board. Although the DEIR doesn't address surface water discharge of treated wastewater(with the exception of a brief reference in Section 6.1.1 DEIR V.II), staff question the long term wastewater plans for the City. The extensive developments are likely to eventually result in requests to discharge wastewater into surface water. The Regional Board staff previously submitted comments to the City of Lathrop (see attached letter dated 16 December 1999)regarding a proposed NPDES discharge, outlined several concerns regarding the process, and requested additional information if the process were to proceed. The long term wastewater disposal needs for the community need to be resolved, and appropriate permit limitations established before subdivisions are approved for development. Construction Stormwater Permit An NPDES General Permit for Storm Water Discharges Associated with Construction Activities, Order No. 99-28-DWQ is required when a project involves clearing, grading, disturbances to the ground, such as stockpiling, or excavation. Currently, construction activity that involves soil disturbances on construction sites one acre or greater or which are part of a larger common plan of development or sale require a construction storm water permit. Because construction associated with the project will disturb more than one acre,the property owner needs to obtain permit coverage under the NPDES General Permit No. CAS000002 for Discharges of Storm Water Associated With Construction Activity. Before construction begins,the proponent must submit an NOI to comply with the permit to the State Water Resources Control Board and an SWPPP must be prepared. Water Ouality Certification- Wetlands If a U.S. Army Corp of Engineers (ACOS) permit is required due to the disturbance of wetlands,then Water Quality Certification must be obtained from the Regional Board prior to initiation of project activities. Section 401 of the Federal Clean Water Act requires that the project proponent for any project that impacts surface waters of the United States (such as streams and wetlands)must request a 401 Water Quality Certification from the Regional Board. The Water Quality Certification must be obtained prior to initiation of project activities. The proponent must follow the ACOE 404(b)(1) Guidance to assure approval of their 401 Water Quality Certification application. The guidelines are as follows: 1. Avoidance(Is the project the least environmentally damaging practicable alternative?) 2. Minimization(Does the project minimize any adverse effects to the impacted wetlands?) 3. Mitigation(Does the project mitigate to assure a no net loss of functional values?) W:IS finf1\9ev JWwnLL tl p WW1AAicNatd Lcm 12WN.A