Hanover County appreciates the opportunity to comments on the Watershed Permit Regulations for total nitrogen and total phosphorus discharges.  Municipal wastewater dischargers need stability in nutrient load allocations as planning and construction of necessary improvements takes years, associated construction costs and operating expenses take time to incorporate into the charges paid by customers in order to avoid rate shock, and effective long term planning for trading and permit compliance requires stability.

Hanover requests that the load allocations and delivery factors that become effective 1/1/2021 under the current general permit, be maintained for the full 5 years of the next permit cycle.