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Basin Plan, Section III-3.00. <br /> The adopted regulatory criteria and applicable guidance include standards up to <br /> 500 times less stringent than the effluent limitations presented in the tentative Permit.' <br /> The Regional Board has failed to produce any evidence that imposing an effluent <br /> limitation of 2,2 MPN/100 ml, 7-day median (23 MPN daily maximum) is necessary to <br /> protect beneficial uses in Dredger Cut, White Slough, and Bishop Cut and/or that the <br /> Basin Plan fecal coliform objectives are not protective. Furthermore, claiming that a 200 <br /> MPN (30-day average)fecal coliform objective is under-protective does not support the <br /> conclusion that a 2.2 MPN (7-day average) total coliform limitation is required to be <br /> protective. <br /> As defined in the California Water Code Section 13050(h): <br /> `Water quality objectives' [in basin plans] mean the limits <br /> or levels of water quality constituents or characteristics that <br /> are established for the reasonable protection of beneficial <br /> uses of water or the prevention of nuisance within a specific <br /> area. <br /> The Regional Board determined that the water quality standard for bacteria of 200 <br /> MPN fecal coliform is protective of public health for REC-1 purposes-pursuant to the <br /> public participation requirements of the Porter-Cologne Act. (Basin Plan at i-1.00.-)'This <br /> objective was based upon federal water quality criteria specifically designed to protect <br /> contact recreation from pathogens due to human sources. The Basin Plan specifically <br /> references EPA criteria documents as information relied upon to develop protective <br /> permit limitations. See, e.g., Basin Plan at III-1.00 and IV-17.00. The State Board and <br /> EPA approved this objective as protective of body contact recreation. <br /> The public and all California administrative agencies (including DHS) have had <br /> the opportunity to comment on the Basin Plan, as recently as the fall of 1998 during the <br /> DHS has admitted that these requirements are the most restrictive in the Country. See, Hultquist <br /> Testimony. <br /> NPDESPermitComments Exhibit 2 Page 12 12/17/99 <br />