WATER POLICY

Association of Sanitation Agencies (CASA) and WateReuse California (collectively, the Associations) are pleased to provide comments on the proposed Amendment to the Recycled Water Policy (Amendment) regarding monitoring of constituents of emerging concern (CECs) in recycled water used for groundwater recharge and landscape irrigation. We offer our suggestions in the spirit of continuing the collaboration that resulted in the Recycled Water Policy (Policy) and the convening of the Science Advisory Panel (expert panel) that developed recommendations for CEC monitoring. As an overarching comment, we continue to urge the State Water Resources Control Board (Board) to adhere as closely as possible to the recommendations of the expert panel, as the June 2010 report represents the “best available science ” on the potential health and environmental effects of CECs related to the use of recycled water for landscape irrigation and groundwater recharge. Basing decisions on recycled water permits on the “best available science ” is a principle that has been consistently endorsed by the Board and by the Policy stakeholders group. In addition, relying on the expert panel’s specialized expertise is the best way for the Board to assure the public that CECs in recycled water are receiving appropriate scrutiny. The expert panel’s recommended approach ensures that agencies will identify the presence and concentrations of CECs well before those concentrations can pose any risk to public health. This approach, which addresses occurrence in recycled water and treatment plant performance, should giv