CSPA
California Sportfishing Protection Alliance
“Conserving California’s Fisheries"

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CSPA files comments on Turlock Water Quality Control facility, scolds Central Valley Board's violation of federal regulatory requirements

February 3, 2009 Attached are comments by the California Sportfishing Protection Alliance (CSPA) regarding the uncirculated redline/strikeout late changes for the proposed City of Turlock Water Quality Control Facility NPDES permit that will be considered on 5 February 2009. These very late changes continue the Central Valley Board's recent policy of routinely making significant and substantial late revisions to proposed NPDES permits without public circulation or provision for meaningful public comment. This policy is in violation of fundamental federal regulatory requirements for permit issuance and deprives CSPA and the public of due process rights.

CSPA comments on late revisions