CONNECTICUT WATER POLLUTION

ABATEMENT ASSOCIATION

P.O. Box 765 Vernon, CT 06066-0765

 

 

 

State of Connecticut September 26, 2000

Department of Environmental Protection

Bureau of Water Management

Planning and Standards Division

79 Elm Street

Hartford, CT 06106-5127

Attention: Paul E. Stacey

Re: WLA Comments

Dear Mr. Stacey:

The Connecticut Water Pollution Abatement Association (CWPAA) is pleased to submit the following comments in response to the State of Connecticut, Department of Environmental Protection proposed Nitrogen Waste Load Allocation (WLA) for Water Pollution Control Facilities in Connecticut.

  1. The WLA should not be included in the Total Maximum Daily Load Analysis of Nitrogen to Long Island Sound (TMDL) for submission to the USEPA until the Nitrogen Trading Program is adopted by the Legislature. The Nitrogen Trading Program will take into account the different locations of the treatment facilities and their impacts to Long Island Sound. This would equalize the actual impacts the facilities would have on the Sound.
  2. Since the Nitrogen Trading is not in effect two WLA’s should be issued to the Municipalities of Connecticut:
    1. One if a Nitrogen Credit Trading program is in place,
    2. The other, for implementation if the Nitrogen Credit Trading Program fails to materialize. This WLA should be significantly higher then what the DEP has proposed to assign to most municipalities and would be based on the actual proportion of the impact on the water quality of Long Island Sound.
  3. The DEP should use their original approach to ratchet the target loads in three five-year increments. This would allow municipalities to plan and capitalize Nitrogen Removal Projects without being subject to credit costs at least for the first five years.
  4. The CWPAA requests that the CTDEP respond to the CWPAA comments regarding the TMDL and receive a copy of the final draft prior to issuing the TMDL to the USEPA.

If you have any Questions on the CWPAA comments on the Nitrogen WLA please contact me at (860) 441-6736.

Sincerely yours,

Carl Almquist

President CWPAA

Cc: Gian Carl-Casa, CCM

CWPAA Board of Directors

CWPAA Membership via WWW.CWPAA.org

Faxed to Paul Stacey 9-27-00

E-mailed to Paul Stacey 9-27-00

Certified Mail – 9-28-00