The California Chamber of Commerce's comments on the State Board's proposed sediment quality objectives ("SQOs") are attached to this cover letter, along with a technical memorandum prepared by our expert consultants.! The Chamber's members include over 15,000 California businesses, including many parties that potentially will be impacted by the development and implementation of SQOs for California's bays and estuaries. Accordingly, the Chamber and its members have a very strong interest in encouraging reasonable and cost-effective approaches to managing impacted sediments. As you know, the State Board has recognized the Chamber's interest in this rulemaking by appointing it, pursuant to California Water Code Section 13394.6, to the Sediment Quality Objectives Advisory Committee ("Advisory Committee"). To facilitate the State Board's review, and without waiving any arguments, we have outlined our main comments below. Overview The SQO rulemaking presents the State Board with an important and challenging task. There are no SQOs in California, and few across the country. Given the magnitude of this rulemaking, it is critical that the State Board take the time to ensure that the SQOs are scientifically and legally defensible. To achieve these objectives, the State Board should develop SQOs that are consistent with the following principles: The Chamber requests that the State Board place all of these materials in the Administrative Record for these proceedings
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