Response of SCWC

SCWC disagrees with RRB's contention that SCWC is not required to comply with the Cryptosporidium Action Plan because it is not a "legally enforceable regulation." SCWC contends that in so arguing, RRB ignores California's Surface Water Treatment Rule which RRB admits is an enforceable regulation - and the relationship between the Surface Water Treatment Rule and the Cryptosporidium Action Plan.

SCWC states that in short, the Surface Water Treatment Rule and the Cryptosporidium Action Plan require a finished water turbidity of no more than 0.1 NTU. SCWC believes it must comply with this requirement. Further, SCWC points out that, leaving no room for doubt, DHS informed SCWC that if the Sonoma Treatment Plant "is not achieving these goals the Department will expect the utility to take actions, and incorporate those actions into its operations plan, to improve the performance of its treatment facility."³