BACWA Bulletin - January 2020

Table of Contents


Register now for 2020 BACWA Annual Members meeting

BACWA Annual Members Meeting will be held January 10, 2020, at the Scottish Rite Center, 1547 Lakeside Drive, Oakland. The program for the meeting is now posted. Register here for the event. 

BACWA welcomes Lorien Fono as Executive Director, effective February 1

With the retirement of current BACWA Executive David Williams at the end of January, the BACWA Executive Board has appointed Lorien Fono as the new Executive Director. Dr. Fono has served BACWA as Regulatory Program manager since 2012, and has supported its committees, engaged with regulators on key issues, and been involved with the day-to-day administration of the BACWA organization. She looks forward to working with the Bay Area POTW community in this new capacity, and to guide BACWA in continuing to provide the high level of service that our members expect. 

SCAP Executive Director to speak about SoCal exfiltration study at Jan 30 Collection Systems Committee meeting 

In 2019, the San Diego Regional Water Quality Control Board released an investigative order that would require stakeholders to identify and quantify the sources and transport pathways of human fecal material into the San Diego River watershed. The tentative investigative order identifies sewer exfiltration as a source of human fecal material in the San Diego River watershed and requires the stakeholders to provide the San Diego Water Board with an estimation of the exfiltration of wastewater from the sanitary sewer collection system to the San Diego River watershed. This directive is alarming to collection system owners since there are so many other sources of human fecal material such as homeless encampments, illegal dumping or illicit connections. Recently we have heard of other Regional Boards contemplating similar investigations. Steve Jepsen, Executive Director of the Southern California Association of POTWs (SCAP) will give a presentation describing the exfiltration study at the January 30 Collection Systems Committee meeting in Alameda.  

Wastewater coalition submits comments on OPC draft 5-year plan

The California Ocean Protection Council (OPC) recently released their Draft 5-year Plan which includes a provision to set a target date by 2022 for phasing out coastal discharges into the ocean, with the intent of achieving an 80-100% reduction in ocean discharges by 2040. The goal is included as part of Objective 1.2 which seeks to “Minimize Causes and Impacts of Ocean Acidification and Hypoxia.” Previous drafts of the OPC's priorities gave no indication this type of provision related to ocean discharge would be included in the 5-year plan. The draft plan had been planned for adoption on November 13th, however, adoption was postponed until February 2020 following stakeholder requests for an extension. BACWA joined with other public agency associations to submit a joint comment letter raising concerns about the goal to phase out coastal discharges. CASA plans to meet with key staff at the OPC regarding the goal, and pending the outcome of those discussions, BACWA and the other associations will provide comments at the adoption hearing scheduled for February 26, 2020.

BACWA submits comments on draft ELAP regulations

On Friday, October 11, the State Water Board provided Notice that ELAP’s 4th draft of regulations had been posted for public comment. The BACWA Laboratory Committee has expressed concerns that the draft regulations give too little guidance on enforcement and do not include the due process considerations that may need to be included legally, and that would lead to more fair decisions. As written, ELAP can take different enforcement actions for the same non-compliant act. This lack of guidelines could lead to inconsistent application and unfair enforcement actions being applied to one lab but not to another for the same issue. BACWA sought legal assistance to provide a review of the proposed language to help inform our community's response. BACWA provided a comment letter, as well as oral comments at the public hearing at the State Water Board on Wednesday, December 18.  Based on feedback from State Water Board members at that workshop, State Water Board staff are working to set up another stakeholder workshop early in the new year to address stakeholder concerns. The State Water Board will consider adoption of the proposed ELAP regulations at their March 17, 2020 meeting.

BACWA submits comments on EPA's Draft National Reuse Action Plan

The EPA is developing a National Reuse Action Plan that will inform a strategy to promote water recycling. The draft National Water Reuse Action Plan was posted for public comment in September and highlights key actions that support consideration and implementation of water reuse across the water sector. BACWA and CASA submitted comments on the draft Plan, highlighting how funding shortfalls and the difficulty forming interagency agreements are the biggest hurdles to recycled water project implementation. BACWA will work with EPA to develop an action addressing how to approach such interjurisdictional challenges. 

BACWA recruiting new Assistant Executive Director

BACWA is seeking a part-time Assistant Executive Director to provide professional services to the Executive Director in support of the agency and its programs. The Assistant Executive Director will support the Executive Director and Regulatory Program Manager in general administrative and logistical work. Core areas of responsibility include financial management, meeting support, document management, and communication and website management. To be considered for this opportunity, please visit: to apply.

Member News 

Send in updates from your agency to post here!

What's new in BACWA's Committees

AIR Committee

At the December meeting, the committee discussed implementation of Rule 11-18 and AB617, development of Regulation 13 pertaining to climate pollutants, and SB 1383 Regulations. The next meeting will be held on March 25. See previous AIR meeting materials.


The December meeting featured a presentation on mobile washer permitting. DPR and TDC Environmental will provide an update on pesticides regulation at the February meeting. Please note that BAPPG has begun offering contact credits (CWEA) for meeting attendance. For more information, see previous BAPPG meeting materials.

Collections Systems Committee

The October meeting featured an update from Regional Water Board staff, an update on the SSS WDR re-issuance process, and a roundtable discussion on how to encourage or compel homeowners to address deficiencies such as illicit downspout connections. The January 30th meeting will include a presentation by Steve Jepsen on exfiltration, or sewer leakage (see above). Please note that BACWA's Collection System Committee has begun offering contact credits (CWEA) for meeting attendance. For more information, see previous Collections Systems Committee Reports.

Laboratory Committee

State Water Board staff attended the December meeting to discuss the committee's concerns with the proposed ELAP regulations. Please note that BACWA's Laboratory Committee has begun offering contact credits (CWEA) for meeting attendance.

Permits Committee

At the December meeting, the committee reviewed the data for the Group Annual Report required by the 2nd Watershed Permit.  Regional Water Board staff attended the December meeting, and provided draft NPDES permit language implementing the expected State Toxicity Provision. The committee will review the proposed language at the February meeting. For more information about committee activities, please see previous Permits Committee Reports.

Pretreatment Committee

The October committee meeting was held at the City of Hayward on October 21. A key item that was covered was Hydrofluoric Acid (HF) Training: Awareness and safety considerations during inspections and sampling. The next meeting is scheduled for February 5.

Operations and Maintenance Infoshare Group

The October meeting was held at Fairfield Suisun Sewer District and featured a discussion about onboarding new staff, as well as preparing and responding to planned safety power shutdowns. The next meeting will be held at Oro Loma Sanitary District.

Recycled Water Committee

The November meeting featured a discussion about the OPC's draft 5-Year Plan (see above) and EPA's draft Water Reuse Action Plan. The next meeting, in January, will feature a discussion about the information request being developed for the Recycled Water Evaluation required by the 2nd Nutrient Watershed Permit. Updates on this study will be a standing item on future committee agendas. For more information about committee activities, please see Recycled Water Committee meeting notes.

Upcoming Events

BACWA Annual Members Meeting, January 10, 2020, Scottish Rite Center, Oakland, CA.

Exfiltration presentation at BACWA Collection Systems Committee, January 30, 2020, 10am to noon, City of Alameda Public Works, 950 W. Mall Square, Alameda.

BACWA External Representation

Collaboration with outside groups and initiatives is an important facet of BACWA's mission. Below is a list of BACWA's representatives to these technical, regulatory, and management groups:

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