Dear Mr. Brockenbrough:

 

Hanover County appreciates the opportunity to comment on the Watershed General Permit (WGP) for Chesapeake Bay nutrient discharges. We offer the following comments on the proposed WGP for consideration:

 

1)      Hanover County strongly supports the WGP. We believe it is critical to POTW’s being successful in doing their part to help Virginia meet its goal of improving water quality in the Chesapeake Bay.

 

2)      Hanover County supports the proposal to implement the new delivery factors in the last year of the general permit, 2016. This time is necessary in order for compliance plans to be restructured.

 

3)      In speaking with DEQ staff, we understand that delivery factors were modified based on the latest finalized version of the Chesapeake Bay Watershed Model, as required by the regulations.  We also understand that delivery factors may change again in the future with the next iteration of the Chesapeake Bay Watershed Model.   Constantly changing delivery factors is problematic for localities and POTW’s as they try to implement programs and improvements to meet the goals of the Chesapeake Bay TMDL.  Based on state and federal representations, localities and POTW’s are operating under the premise that trading will be an important tool available for complying with these new requirements. We are concerned about the long term viability of trading nutrients if delivery factors are constantly changing.

 

4)      It appears that delivery factors were manipulated in a somewhat arbitrary manner to calibrate the very complex Chesapeake Bay Watershed Model. As an example, the Doswell WWTP and White Birch Facility share a common outfall and yet different delivery factors are now used in the model for total nitrogen. A second example is that the Totopotomoy WWTP discharges to the tidal Pamunkey.  It was originally given a delivery factor 1.0 for both TN and TP. It now has delivery factors of 0.87 TN and 0.77 for TP. Other facilities which discharge in the same general area still have a delivery factor of 1.0. Conceptually we understand the purpose of using delivery factors and we agree that their use is appropriate in the model. To date, an explanation of the science/ logic behind individual delivery factors has not been available.

 

5)   Hanover County has reviewed VAMWA's comments and endorses them, in particular VAMWA's comments on the James River Aggregate Delivered Waste Load Allocations. We have not repeated VAMWA's comments but please consider them also made by Hanover County.

 

Again, thank you for the opportunity to comment on the WGP.  Please feel free to contact me if Hanover County can be of any assistance.

 

Sincerely,

Steven Herzog, P.E.

Director

Hanover County Department of Public Utilities

P.O. Box 470

Hanover, VA 23069

Phone: 804-365-6022

FAX: 804-365-6263

Email: spherzog@co.hanover.va.us