Wastewater Associations Ask State Water Board for More Time on Proposed ELAP Fees

"The CWEA Laboratory Committee members respectfully submit the following comments."

By CWEA, Wastewater News

CWEA’s Laboratory Committee Chair Josie Teller from the City of Davis led an effort to craft a comment letter regarding the State Water Board draft regulations to raise ELAP fees.

In summary, CWEA’s comment letter recommends:

1. Request to Delay the Adoption and Initiate a Collaborative Process
2. Regulatory Language Needs Clarification
3. Reporting Mechanism (tools)
4. Request to Revise Reporting Frequency
5. Enforcement Ramifications
6. Request for Inclusion of a Sunset Date

 The collaborative process as requested could potentially result in discovery of alternative fee changes to components of future new ELAP fees that are reasonable and sustainable. One option for consideration is setting fees on individual FOAs rather than grouping the FOAs based on a tiered system and adding fee components based on complexity of the method or technology.

Download the CWEA Comment Letter – Proposed ELAP Fee Draft Regulatory Language

Additional association comment letters

• • CASA Comments on Proposed ELAP Fee Structure Regulations
  • CVCWA ELAP Fees Comment Letter