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need to strengthen the permit to a level that would be protective of the river and questioned certain assumptions that were made when modeling the proposed plant. The majority of my comments were focused on the use of nutrient offsets in the permit. PEC believes the use of offsets cSuld lead to detrimental impacts to Virginia waters. While offsets may help improve the Chesapeake Bay, they could lead to an unacceptable level of pollution in the Rush. We believe Virginia should not adopt a policy of allowing offsets. A high level of
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