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.

AdvanSix requests that I be a member of the proposed Technical Advisory Committee for the regulatory action.  AdvanSix is covered both directly and indirectly by the proposed regulations, and AdvanSix has played an active role in the development and implementation of other water regulatory programs.  For example, AdvanSix played an active role in developing the WQMP regulations and Nutrient General Permit, served as the Virginia Manufactures Association’s (VMA) representative on the RAP assisting in the development of numeric chlorophyll a criteria for the James River, and also served as VMA’s representative in the work group under Executive Order 52, one of the catalysts for the NOIRA.