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Moraff, Kenneth [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=B6170EF3BAEF40C3BDECAB56FD74B07A-MORAFF/ KENNETH] 2/12/2018 5:30:31 PM Dunn, Alexandra [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=426d0177eaab4001a5c85f051565997e-Dunn, Alexa]; Zellem, Michael [Michael.Zellem@nh.gov]; Ross, David P [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=119cd8b52ddl4305a84863124ad6d8a6-Ross, David]; Campbell, Ann [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=b8c25a0c2fb648b6a947694a8492311e-Campbell, Ann] Scott, Robert [Robert.Scott@des.nh.gov]; Gutro, Doug [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=d9e540aa74014778b84c89fe816d9dbf-Gutro, Doug] RE: Dover Meeting Follow Up
Mac - happy to talk about the questions in your email - are you free later this afternoon? I'd like to have Doug Gutro join us - he's chief of our public affairs/government relations office.
Ken
From: Dunn, Alexandra Sent: Monday, February 12, 2018 8:53 AM To: Zellem, Michael <MichaeI.ZeIlem@nh.gov>; Ross, David P cross.davidp@epa.gov>; Moraff, Kenneth <Moraff.Ken@epa.gov>; Campbell, Ann cCampbell.Ann@epa.gov> Cc: Scott, Robert cRobert.Scott@des.nh.gov> Subject: RE: Dover Meeting Follow Up
Mac,
Thanks for this! You have put an excellent summary together.
In Region 1 we are expediting partial approval of the 2014 and 2016 NH 303(d) lists. Our suggestion is to approve the 90% of work around which there is no disagreement, and then move to work more closely on the other areas hopefully with a goal to resolve them quickly too.
We will continue to work as a team and keep you informed.
Alexandra Dapolito Dunn, J.D. Regional Administrator
Region 1 New England 5 Post Office Sq. Suite 100 Mail Code: ORAOl-4 Boston, MA 02109-3912
Desk: (617) 918-1012
Mobile:!
Ex. 6
Fax: (617) 98 -"l2
dunn.alexandra@epa.gov
From: Zellem, Michael [mailto:Michael.Zellem@nh.gov] Sent: Friday, February 9, 2018 2:35 PM
Sierra Club v. EPA 18cv3472 NDCA
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To: Dunn, Alexandra <dunn.alexandra@epa.gov>; Ross, David P cross.davidp@epa.gov>; Moraff, Kenneth <Moraff.Ken@epa.gov>; Campbell, Ann <Campbell.Ann@epa.gov> Cc: Scott, Robert <Robert.Scott@des.nh.gov> Subject: Dover Meeting Follow Up
Hello Alex, Dave, Ken, & Ann,
Alex and Dave -
Thank you both so much for taking the time to meet with our towns concerning their permits. They feel that after years of fighting the state and the EPA, their concerns are finally being heard. The Governor is incredibly appreciative of your engagement on in this matter. I enjoyed meeting you both and hope we get a chance to work together in the future. Alex, the Governor further appreciates the letter that you just sent.
All -
The towns were less organized with action items than I was lead to believe they would be. I am a little nervous that they left the meeting believing that EPA would give them all status quo permits with no numerical nitrogen limit. As I understand it, EPA cannot do this, and even if they could, it would likely to lead to a protracted fight with CLF. Please correct me if I am wrong on these points.
The towns are beginning to view EPA as more of a partner than a combatant, and I think their historic lack of trust is being overcome. In light of the towns agreeing to be dealt with individually, I believe the action item is for EPA staff to begin to engage the towns in a technical discussion on what an adaptive management permit would look like for them, and what the process to get and implement those permits will be.
The Governor has four goals for these permits:
1. The towns get and implement the permits on schedule. The Governor does not want the towns or the EPA to drag their feet, or protract the process, creating uncertainty for businesses.
2. The permits and any potential consent agreements give the towns the certainty they need for their long-term planning. There is a fear among the towns that a future administration will turn the tables on anything that is agreed to.
3. The permits are innovative and allow the tows the flexibility through adaptive management to best address their unique situations.
4. The permits are written to best prevent a protracted legal fight with CLF, which creates uncertainty for the municipalities and local businesses.
The Governor shares your goal for science-based decision making, and we are planning on increasing funding for data collection on the health of the Great Bay. We want NH DES and EPA to have the best data possible.
The City of Portsmouth mentioned the potential Lonza expansion at the Pease Tradeport. This is a priority of the Governor, and the wastewater treatment expansion is critical for the expansion to proceed. I hadn't mentioned this prior, at this point in the process it is a bit premature to discuss the wast water permit, as we have little idea of what kinds of capacity upgrades will be required, It is, however, good for EPA to know that this is out there.
Ken & Ann -
I would love to sit down and get the EPA's stance on the science behind all of this. I have DES' and the towns' narratives but I would like to understand where EPA stance on how we have gotten to this point. Furthermore, I would like to understand what difference of opinion between DES and EPA is that has been holding up NH's 2014 and 2016 303(d) lists.
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Thank you, everyone, for working on this issue, the Governor really appreciate all the effort that is being put in!
Mac Zellem
Policy Adviser, Office of Governor Christopher T. Sununu
State of New Hampshire Michael.Zellem@nh.gov
^X. 6 p----------------------------,
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Sierra Club v. EPA 18cv3472 NDCA
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