Joint Comment Letter: Revised Draft of Amendments to Section 650, 672, 672.1, 672.2 of Title 14 of the CCR Regarding Invasive Mussels

Agency: California Department of Fish and Wildlife

Subject: Comment Letter regarding Revised Draft of Amendments to Sections 650, 672, 672.1, and 672.2 of Title 14 of the California Code of Regulations

Letter excerpt:

The Association of California Water Agencies (ACWA) and the undersigned organizations appreciate the opportunity to continue to provide comments to the California Department of Fish and Wildlife (CDFW) on the revised proposed regulatory amendments to Sections 650, 672, 672.1, and 672.2 of Title 14 of the California Code of Regulations regarding the management of invasive mussels. ACWA represents approximately 470 local public water agencies that supply water for domestic, agricultural, and industrial uses to over 90 percent of California's population. Invasive mussels negatively impact California water systems' ability to store and convey drinking and irrigation water, generate hydropower, and manage flood control facilities. Once established, they can spread rapidly through connected water systems, compounding their impact over time. While we appreciate CDFW's efforts to align regulations regarding invasive mussel management with current conditions and to explore proactive measures to further prevent their spread, we are disappointed that the amended proposed regulatory text does not address any of the concerns we raised in the initial 45-day comment period.

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