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EXHIBIT 1 TMDL PERMIT MODIFICATIONS at the SOUTH COUNTY RO PLANT, NORTH COUNTY RO PLANT, AND WEST REGIONAL WWTF GENERAL The Indian River Lagoon (IRL) is an important recreational and economic resource to the state and region. According to the St. Johns River Water Management District, the total estimated annual economic value of the lagoon is $3 . 7 billion, supporting 15 , 000 full and part-time jobs and providing recreational opportunities for 11 million people per year. For these reasons, among others , it was designated in the 1987 Surface Water Improvement and Management ( SWIM) Act as a priority waterbody in need of restoration and special protection. Rising levels of excess nutrients (nitrogen and phosphorus) in the IRL have become a real concern, as these excess nutrients can contribute to loss of sea grass beds, fish, dolphins, manatees, and hundreds of other species in what is considered the most biodiverse estuary in the United States . By dedicating millions of dollars to the Spoonbill Marsh, Egret Marsh, PC Main and the PC South Algal Turf Scrubber treatment systems, Indian River County has become a proactive leader in nutrient reduction, paving the way for other utilities throughout the State . As a result of the new treatment systems, IRC has significantly reduced the amount of excess nutrients (nitrogen and phosphorus) being discharged into the Indian River Lagoon by the County water and wastewater plants . The County has taken a strong stance in implementing projects that will create a "net positive environmental benefit" to the Indian River Lagoon, to the extent that IRC worked with FDEP to create for the first time, a new permit requirement for Spoonbill Marsh that defines a net positive environmental benefit as "an evaluation of nutrients in terms of a reduction in (a) concentration, (b) mass loading, and (c) biological impact of the discharge flowing into the Indian River Lagoon. " In simpler terms, the amount of excess nutrients being discharged from the County utility plants must be less than the amount of nutrients that naturally exist at the outfall into the Indian River Lagoon. The new systems are not only providing a "net positive environmental benefit", but they are providing substantial additional treatment which results in an improvement of the source lagoon water quality. Although the payback for these projects has already been realized in considerable environmental benefits and through compliance with the current permits, there are potential benefits that have not yet been realized. The current FDEP permits are overly constraining . We are proposing to work with FDEP to obtain credit on the plant permits for the millions of dollars spent by IRC to remove thousands of pounds of nitrogen and phosphorus from the IRL . In the last month alone, 905 lbs of nitrogen and 337 lbs of phosphorus were removed by the Egret Marsh, PC Main and Spoonbill Marsh treatment systems . This would equate to over 10 ,000 lbs per year of nitrogen and 4 , 000 lbs per year of phosphorus . The County has exhaustive data to support an increase in nitrogen and phosphorus limitations on the South County RO Plant industrial waste permit (FDEP Permit Number 3 1 -FL003 7940), North County RO Plant NPDES discharge permit (FDEP Permit Number 3I -FL0166511 - 004) , and the West Regional Domestic Waste Permit (FL0041637 -006) . To obtain credit on the permits for the nutrient reductions, historical sampling and existing pilot study data must be analyzed and summarized in a report for each plant, along with an FDEP permit application. If Page 1 of 4