The Solution: ​ ​ Value Engineering Staff completed a detailed review of DEP documentation regarding nutrient pollution within Goshenhoppen Creek.  Through conversations with DEP Biologists, it was determined that the source of the pollution was a point source upstream of Lower Frederick Township.  
Value Engineering staff submitted a detailed waiver request as part of their Notice of Intent (NOI) to DEP to remove the PRP burden from Lower Frederick Township.  This waiver request was removed, exempting Lower Frederick Township from the onerous task of developing and implementing a PRP for the Goshenhoppen watershed in the 2018-2023 permit cycle.  Lower Frederick Township is one of the very few municipalities in Southeastern PA that does not have a PRP or TMDL requirement for this permit cycle.