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Epa letter U S Department of Justice Environment and Natural Resources Division - - - - Environmental Enforcement Section P O Box Washington DC VIA EMAIL AND FEDERAL EXPRESS Con ?dential Settlement Communication Subject to Fed R Evid November Telephone -

U S Department of Justice Environment and Natural Resources Division - - - - Environmental Enforcement Section P O Box Washington DC VIA EMAIL AND FEDERAL EXPRESS Con ?dential Settlement Communication Subject to Fed R Evid November Telephone - Facsimile - Facsimile - Jose de la Fuente Lloyd Gosselink - Attorneys at Law Congress Avenue Suite Austin TX - Re United States v City of Corpus Christi Texas S D Tex ?? o ?er of settlement pursuant to Executive Order Dear Mr de la Fuente I write in response to the injunctive relief proposals submitted by the City of Corpus Christi ??City ? in August of and March and April of our subsequent conversations and the City ? s supporting submissions ??City Submissions ? As you are aware the United States and the City have been engaged in negotiations since early in an e ?ort to resolve the City ? s lengthy history of CWA violations We have made some progress in reaching an agreement on the terms necessary to avoid litigation over the City ? s CWA violations and we are willing to accept some of the City ? s most recent proposals to further this e ?ort However it appears that we have reached an impasse particularly with respect to the compliance deadlines for the necessary remedial measures The City ? s proposed compliance horizon which runs as long as years for some projects is simply too long and not supported by the City ? s recent Financial Capability Assessment ??FCA ? Since the City has violated e uent limits at its six waste water treatment plants ?? WWTPs ? more than times These violations include exceedances of the City ? s NPDES permit limits for ow enterococci fecal coliform total suspended solids biological oxygen demand ammonia nitrogen copper residual chlorine and pH During this same period raw sanitary sewage over owed from the City ? s wastewater collection and treatment systems and into people ? s homes and City neighborhoods more than times Sanitary sewer over ows ??SSOs ? are known to contain a variety of pathogenic substances that are harmful to public health and the environment In addition elevated levels of enterococci bacteria have been found in the waters surrounding Corpus Christi some of which are water quality impaired for bacteria CAs we have discussed the City ? s FCA does not conform to the relevant Environmental Protection Agency ??EPA ? guidance and does not support the City ? s proposed schedule for resolving the City ? s ongoing CWA violations The City improperly included in ation or ??escalation ? costs The City improperly included costs associated with capital projects the City has declined to obligate itself to complete as part of a consent decree ??CD ? with the United States The City also improperly included costs associated with work scheduled after the proposed conclusion of the CD An analysis which is based on the City Submissions but conforms to the EPA guidance makes clear that