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QWASQ ORANGE WATER & SEWER AUTHORITY <br />Quality Service Since 1977 <br />July 10, 2007 <br />Dr. David H. Moreau, Chair <br />North Carolina Environmental Management Commission <br />1617 Mail Service Center <br />Raleigh, NC 27699-1617 <br />SUBJECT: COMII~NTS ON PROPOSED WATER SUPPLY NUTRIENT STRATEGY <br />FOR B. EVERETT JORDAN RESERVOIR <br />Deaz Dr. Moreau: <br />The Orange Water and Sewer Authority (OWASA) Board of Directors appreciates the <br />opportunity to comment on the proposed Jordan Lake Nutrient Strategy and Rules. As you <br />know, we provide water supply and wastewater services to approximately 80,000 people in the <br />Carrboro-Chapel Hill community, including the University of North Carolina at Chapel Hill, <br />and our Mason Farm Wastewater Treatment Plant discharges to Jordan Lake's Upper New Hope <br />Arm. <br />One of OWASA's core values is environmental stewardship. We are proud of our proactive <br />record in source water protection, innovative wastewater treatment, water conservation and <br />demand management. In late 2008 our new water reclamation system will go into operation <br />when the University of North Carolina at Chapel Hill begins using more than 500,000 gallons of <br />highly treated wastewater per day for non-potable heating and cooling purposes on the <br />University campus. This will increase to neazly two million gallons per day in the future, <br />significantly reducing demands for OWASA drinking water and also decreasing our wastewater <br />dischazge to Jordan Lake. <br />As in the past, OWASA will do our part to protect this valuable regional resource and will <br />comply with the nutrient reduction requirements that the Environmental Management <br />Commission (EMC) adopts; but we respectfully offer several significant concerns and <br />constructive suggestions about the proposed Nutrient Strategy and Rules. <br />Hish Costs and Uncertain Benefits <br />The NC Division of Water Quality's (DWQ) carefully documented Fiscal Analysis estimates <br />that the Nutrient Strategy and proposed Rules will cost more than $900 million to implement. <br />There is, however, broad scientific and professional consensus that the predicted response of <br />400 Jones Ferry Road Equal Opportunity Employer Voice (919) 968-4421 <br />PO Boz 366 Printed on Recycled Paper FAX (919) 968-4464 <br />Carrboro, NC 27510-0366 www, owosa, org <br />9 <br />