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C. The SWIFT Project. HRSD's Sustainable Water Initiative For Tomorrow ( "SWIFT ") Project was conceived with multiple benefits in mind for the Hampton Roads region. Aside from TMDL benefits, this innovative water purification project is designed to enhance the sustainability of the long -term groundwater supply and help address other environmental pressures such as sea level rise and saltwater intrusion. The SWIFT Project is intended to achieve these benefits by taking already- treated wastewater that would otherwise be discharged into the Chesapeake Bay watershed, purifying it through additional rounds of advanced water treatment to meet drinking water standards, and injecting the resulting drinking quality water into the Potomac aquifer deep underground. With respect to TMDL benefits, SWIFT will result in a significant reduction in the total volume of HRSD discharge to the Chesapeake Bay watershed, to achieve greater environmental benefits with corresponding significant reductions of TN, TP and TSS discharges to the Chesapeake Bay watershed. D. Legal Authority. Pursuant to Virginia Code § 62.1- 44.19:21, the City may acquire and use TN and TP credits for purposes of compliance with the Chesapeake Bay TMDL loading reductions of its MS4 VPDES Permit, including credits generated by the HRSD Plants by discharging less TN or TP than permitted under the Watershed General Permit. Pursuant to Virginia Code § 62.1- 44.19:21.1, the City may also acquire and use TSS credits for purposes of compliance with the Chesapeake Bay TMDL loading reductions of its MS4 VPDES Penntt, including credits generated by the HRSD Plants by discharging less TSS than allocated under the Chesapeake Bay TMDL. With respect to all three parameters, it is recognized that this authority does not limit or otherwise affect the authority of DEQ to establish and enforce more stringent water quality -based effluent limitations in pen-nits where such limitations are necessary to protect local water quality and, further, that the use of water quality credits does not relieve an MS4 pen-nit holder of any requirement to comply with applicable local water quality -based limitations. E. Redevelopment -Based MS4 TMDL Action Plan. The City expects to achieve its Chesapeake Bay TMDL reduction goals more cost - effectively by utilizing HRSD- generated TN, TP and TSS credits before and during operation of the SWIFT Project in lieu of stonnwater retrofit projects on a condensed 10 -year schedule (i.e.. Second and Third Bay TMDL Permit Cycles) coupled with ongoing stonr►water quality improvements from redevelopment projects, which are subject to TP reduction criteria (and associated TN and TSS reductions) under the applicable water quality design requirements of DEQ's Virginia Stormwater Management Program Regulation, 9VAC25- 870- 63.A.2. By aligning with the nonnal redevelopment cycle rather than scheduling retrofits prior to redevelopment activity, the City's Chesapeake Bay TMDL Action Plan will also conserve scarce state and local resources for other important water quality projects. F. Credit Trading Premise of SWIFT. For all of the above reasons and others, the ability to generate TN, TP, and TSS credits through the SWIFT Project and apply those credits as progress under the Hampton Roads localities' MS4 Permits and associated TMDL Action Plans is a fundamental premise for the SWIFT Project. HRSD