Save the Sound Comments on the Suffolk County Subwatersheds Wastewater Plan and Draft Generic Environmental Impact Statement

Ken Zegel, PE
Associate Public Health Engineer
Suffolk County Department of Health Services

Dear Mr. Zegel,

On behalf of Save the Sound, a 501(c)(3) non-profit corporation dedicated to protecting and restoring Long Island Sound and its tributary waterways, please accept these comments expressing our strong support for the Suffolk County Subwatersheds Wastewater Plan (SWP) and Draft Generic Environmental Impact Statement (DGEIS).

Background

Excess nitrogen (nitrogen pollution) entering the groundwater and coastal waters of Long Island is widely known to be a serious threat to the health of the inhabitants of the island both human and animal. It is already costing Long Island residents and businesses by degrading ecosystems, contaminating drinking water supplies, reducing coastal resiliency and harming the local economy. Sources of nitrogen pollution include septic systems, cesspools, wastewater treatment plants, polluted storm water runoff, and residential and agricultural fertilizers. Before recovery from damage already done can start, all of these sources must be addressed with a coordinated and timely strategy, such as the Subwatersheds Wastewater Plan.

The U.S. Environmental Protection Agency (EPA) region 1 and 2 released an updated strategy to reduce nitrogen inputs to Long Island Sound in December of 2015. This strategy specifically directed New York State and Connecticut to assess the local nitrogen loading in the bays, harbors and coves of Long Island Sound, and to set location-specific endpoints for nitrogen in locations found to be suffering from excess nitrogen. In 2016, the New York State Department of Environmental Conservation (DEC) released the Long Island Nitrogen Action Plan (LINAP) which provides a roadmap to reduce nitrogen that is consistent with the actions in the SWP. Together these plans show broad-based consensus on the federal, state and local level that nitrogen pollution is a very serious threat that warrants the coordinated, long term actions and investment contained in the SWP.

Support for the Suffolk County Subwatersheds Wastewater Plan

Save the Sound strongly supports the SWP and the DGEIS. We feel the SWP provides an urgently needed countywide strategy to tackle nitrogen pollution in Long Island’s surface waters and groundwater. Specifically, the plan 1) provides a wastewater management strategy to reduce nitrogen pollution from point and non-point wastewater sources, 2) will drive the development of strategies to address nitrogen from non-wastewater sources by identifying waterbodies where additional mitigation measures may be required to restore water quality, 3) supports policymakers and stakeholders in making informed decisions on best management practices that address both types of source pollution, and 4) meets the goals set out in the EPA Nitrogen Strategy, NYS Long Island Nitrogen Action Plan, and the county’s Reclaim Our Water initiatives.

Robust scientific research, supported by pilot studies in the field, confirm that replacing aging cesspools and septic systems with new Innovate/Alternative Onsite Wastewater Treatment Systems will dramatically reduce nitrogen reaching the groundwater and surface waters. Upgrading treatment plants, expanding sewer districts, incorporating green infrastructure, and fertilizer use restrictions will also reduce nitrogen loads. We have the solutions to bring about the needed reductions, now we need the shared commitment, funding and political will to get those solutions implemented on a large scale in Suffolk County.

Under County Executive Bellone’s leadership, and with the support of many partners and stakeholders, Suffolk County has been successful creating innovative funding mechanisms to start this work. Save the Sound strongly supports the goal of establishing a stable and recurring funding mechanism to make the advanced onsite systems or sewer connections affordable for homeowners. A dedicated funding stream has proven effective in long term water quality restoration efforts in other parts of the country, such as Chesapeake Bay and Puget Sound, and will be critical to sustain this effort on the scale needed over the 50 years of the plan.

Save the Sound strongly agrees with the inclusion of phosphorous reduction in the SWP and the goal of establishing ecological endpoints. Monitoring dissolved oxygen, chlorophyll-a, water clarity and algal blooms will establish the efficacy of site-specific nitrogen reduction efforts and allow for the refinement of those strategies as needed. We also agree with the integration of sea level rise and salinity data throughout the life cycle of the plan. Overall, we support the integrated approach detailed in the SWP which creates a solid scientific footing and allows for the flexibility needed to update strategies as more data and/or changing conditions are measured.

Recommendations

Based on our participation in the public hearings on September 5 and 6, 2019 we offer the following recommendations for your consideration:

  • Address the impact on seniors selling their primary homes without having installed an Innovate/Alternative Onsite Wastewater Treatment Systems by providing access to grants to cover expenses at that time.
  • In the plan itself, clearly identify how towns and villages will be engaged in meeting the goals of the plan.
  • When presenting the Innovate/Alternative Onsite Wastewater Treatment Systems and the financing options for getting those installed, be sure to include the cost of maintenance on existing cesspools and onsite systems so homeowners do not have the misperception that their existing systems bare no costs.
  • Don’t let perfect be the enemy of the good. Emphasize the iterative nature of the plan and the fact that the public and elected officials will have ongoing input as different aspects are rolled out.

In conclusion, we appreciate County Executive Steve Bellone and his staff for their leadership on Reclaim Our Water and DEC staff for its leadership on LINAP. Together with the Subwatersheds Wastewater Plan, we believe fully and expeditiously implementing these initiatives are the key to solving Long Island’s water quality crisis. We thank you for the opportunity to submit these comments on behalf of Save the Sound and our members.

Respectfully submitted,

Tracy Brown
Director, Save the Sound


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