CASA Submits Comments on State Water Board Toxicity Provisions

On December 21, CASA submitted comments on the State Water Board’s toxicity provisions. The provisions will impact dischargers to inland surface waters, estuaries and bays. Most notably, the provisions would impose numeric water quality objectives and limits for toxicity and mandate use of the test of significant toxicity.

CASA has been working with State Water Board staff on different iterations of the provisions for the last several years. CASA’s comments focus on the inappropriateness of numeric limits for toxicity, various implementation issues associated with new testing requirements and procedures and the use of specific test species that are known to have a high rate of false indications of toxicity. CASA will continue to work with staff, State Board members and other partners in the water and wastewater community to address these issues. The provisions are expected to be adopted in spring of 2019.