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• • <br /> CITY COUNCIL H. DIXON FLYNN <br /> STEPHEN J. MANN, Mayor CITY O F L O D I City Manager <br /> ALAN S. NAKANISHI ALICE M. REINICHE <br /> Mayor Pro Tempore City Clerk <br /> CITY HALL, 221 WEST PINE STREET <br /> SUSAN HITCHCOCK RANDALL A. HAYS <br /> KEITH LAND P.O. BOX 3006 City Attorney <br /> PHILLIP A. PENNING LODI, CALIFORNIA 95241-1910 <br /> (209) 333-6706 <br /> FAX (209) 333-6710 <br /> December 17, 1999 <br /> Robert S. Fagerness, P.E. <br /> Associate Water Resource Control Engineer <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 95827-3098 <br /> SUBJECT: Tentative Discharge Requirements for City of Lodi <br /> This letter provides the City's comments on the Tentative Waste Discharge Requirements <br /> and associated documents dated November 5, 1999. Our comments consist of this letter <br /> and three Exhibits. The first Exhibit contains specific comments on the permit. The <br /> second Exhibit contains detailed comments and the third Exhibit contains comments on <br /> legal, policy, and regulatory issues which were raised in our comments on the first draft. <br /> The City has previously provided comments on earlier drafts of the permit. (Letters and <br /> attachments dated May 27, 1999 and February 25, 1999. These comments are <br /> incorporated by reference. In addition we may supplement these comments and expect to <br /> provide evidence and make statements at the hearing on our permit. <br /> If the permit is issued as written, many of the requirements will place the City in <br /> violation of the permit at the outset. While we look forward to making <br /> improvements to water quality and the environment at our treatment facility, we <br /> object in the strongest manner possible to the immediate imposition of new <br /> requirements and interpretations of past requirements that will-result in SB 709 <br /> fines exceeding $100,000 annually. - <br /> It is unreasonable to take such an action and we ask that the permit be modified to <br /> provide a reasonable compliance schedule within the permit to meet all the new <br /> requ' ements and i terpretations. <br /> Richard C. Prima; Jr. <br /> Public Works Director <br /> RCP/pmf <br /> Enclosures --� <br /> cc: Dixon Flynn, City Manager <br /> Fran Forkas,Water/Wastewater Superintendent <br /> 1T r <br /> Robb Beggs,West Yost&Associates ~t rT <br /> Max E. Burchett,Whitley, Burchett and Associates, Inc. p <br /> Paul Simmons, DeCuir&Somach <br /> Wastewater Treatment Master Plan Advisory Panel <br /> John Hall, Hall&Associates <br />