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Therefore hundreds of wastewater treatment systems in Florida would need to be completely <br />replaced to meet this standard, at exorbitant cost. <br />Moreover, in the case of stormwater, the City of Casselberry is a largely built -out urban area <br />and thus faces tremendous challenges. The City is clearly devoted to protection of its surface <br />waters. It has adopted an aggressive Stormwater, Lakes Management, and Water Quality <br />Master Pian with an equally aggressive Stormwater and Lake Management Utility Fee, funding <br />approximately $10 million in projects through 2017, many specifically targeted at improving <br />water quality for the purpose of achieving Total Maximum Daily Loads for the Lake Jesup <br />Watershed. Even with such funding, especially with limited land availability and prohibitive <br />acquisition cost, stormwater retrofits have a very high cost to benefit ratio for nutrient removal. <br />In light of this, any new, more restrictive criteria, such as NNC, must be reasonable, attainable, <br />and scientifically sound for the City to be able to support them. EPA has not demonstrated with <br />any level of certainty that NNC meets any of these three criteria. Therefore, the City objects to <br />the proposed NNC and requests that the items proposed herein are thoroughly addressed <br />before any further consideration of these criteria. <br />Should you have any questions or concerns, please feel free to contact me at (407) 262-7725, <br />ext, 1233. <br />Sincerely, <br />Ed Torres, M.S., P.E., LEED AP <br />Public Works Director <br />Cc: Barbara Lipscomb, City Manager <br />Kelly Brock, City Engineer <br />Alan Ambler, Utility Manager <br />wcvw.easse]berty.org <br />