Comment

We respectfully remind the District that opportunity cost must be considered in failing to examine the alternatives discussed (herein). Specifically, please consider the cost of time lost in litigation

Response

Time lost could also slow the District from implementing projects that clearly benefit the environment. Based on the preliminary permitting work in the report, DEQ’s regulatory framework for surface water discharges appear to support discharge of effluents having a lower quality than an MBR plant would provide, without Advanced Treatment, outside the nutrient season.