Comment submitted by Paul Lackemacher, Bay County Utility Services, Bay County, Florida

Elizabeth Southerland, Director January 7, 2012 Office of Science and Technology U.S. Environmental Protection Agency Ariel Rios Bldg 1200 Pennsylvania Ave., N.W. Washington, D.C. 20460 RE: Request for Extension of Comment Period – Phase I Remand and Phase II NNC Rules Director Southerland: Bay County Utility Services request that EPA extend the comment period for both proposed Phase I Remand Rule and Phase II Rule (Docket ID No.’s EPA-HQ-OW-2009-0596 & 2010-0222). Rational for Requested Extension; Due to the highly technical nature of the Phase I and Phase II Numeric Nutrient rulemaking, the comment time period is insufficient. EPA’s time period does not allow those being regulated to properly digest and evaluate the breath and length of theses rules. EPA published five separate notices proposing TMDLs on November 30, 2012 and also released a pre-publication draft of its Phase I remand rule, re-proposing numeric nutrient criteria for streams and down stream protection values for unimpaired lakes. On the same date, EPA issued a pre-publication of its Phase II proposing numeric nutrient criteria (downstream protective values) for Florida marine and estuarine waters. On December 18, 2012, EPA published its proposed Phase I Remand and Phase II rules in the Federal Register, yet the appendices for the technical support document for the proposed Phase I rule were not made available to comment on until December 20, 2012? These various rule proposals have resulted in three overlapping comment periods. Comments directed to the proposed TMDLs must be submitted by January 29, 2013. Comments to the Phase I Remand must be filed by February 1, 2013 and comments to Phase II rule must be submitted by February 19, 2013. The extremely short (concurrent) comment periods are unreasonable and place those being regulated with unrealistic expectations to provide sound scientific and technical comments to the rules. The proposed numeric nutrient rul