Tag Archives: Nitrogen Reduction Strategy

MCWRS’s Workshop Discusses the Future of New England’s Rivers

On March 21, MCWRS hosted a free workshop on the future of New England’s rivers at the Springfield Water and Sewer Commission. Coalition members and non-members were invited to learn about these timely topics. Ed Capone, Service Coordination Hydrologist at the National Oceanic and Atmospheric Administration’s (NOAA) Northeast River Forecast Center (NERFC) presented his work forecasting river flows. The NERFC, one of 13 river forecast centers in the U.S., monitors Massachusetts’s six major river watersheds and works to protect life and property. At NERFC, Mr. Capone and the team calibrate and implement hydrologic and hydraulic models and produce temperature and precipitation forecasts to provide (1) river flow and stage forecasts, (2) guidance on the rainfall needed to produce flash flooding, (3) streamflow predictions, (4) ice jam and dam break support, and (5) water supply and reservoir inflow forecasts.

NOAA studies whole watersheds, and understands that its stakeholders, like the Coalition, are interested in an integrated approach to flooding, water quality, water availability, drought, and climate change, to understand both near- and long-term risks. Mr. Capone reported on observed trends in climate change, such as the increase in amounts and intensity of annual precipitation, warming annual temperatures, and extreme seasonal variations in snowfall that are trending, overall, downward in total amounts. Most notably, intense precipitation events (the heaviest 1%) have increased by 74% in the Northeast, the highest increase in the country. This is reflected in the rise in flooding frequency, especially minor flooding, for smaller watersheds and highly urbanized areas, as well as magnitude. Significant snow storms in the Northeast have also dramatically increased, particularly in the past decade. He explained that the amount of moisture in snow determines the amount of runoff, so a large storm of “dry” snow may have little impact. In terms of Massachusetts’s drought, Mr. Capone explained that drought periods are not uncommon and can happen despite an increase in rainfall.  One of the challenges in managing drought is that the definition can vary by state. He observed that a precipitation deficit may trigger water conservation measures when ground and surface water supplies are actually unaffected.

For Massachusetts and New England, the increase in flooding is related to more slow-moving storms, multiple events in close succession, and a tropical connection. New England’s proximity to Gulf and Atlantic moisture streams and the blocking effects of weather systems to the north play a role, as does even modest changes in ocean and air temperatures that allow the atmosphere to hold more water. The region has been a hotspot for record floods and rainfall over the past 10 years, along with increased yearly rainfall and annual temperatures.

Steven Wolosoff, Senior Environmental Scientist at CDM Smith, discussed the U.S. Environmental Protection Agency’s (EPA) Long Island Sound Nitrogen Reduction Strategy and its impacts in Massachusetts. Mr. Wolosoff explained that the issue is hypoxia, or low dissolved oxygen (DO), in the western portions of Long Island Sound (LIS) in the summer months, which affects bottom dwelling organisms that cannot move away from the area. A 1985 LIS study attributed hypoxia to increases in human wastewater, which led the agency to create a use impairment indicator and hierarchy evaluation system. The 2000 Total Maximum Daily Load (TMDL) study required specific actions, including a 58.5% reduction in nitrogen from in-basin (New York and Connecticut) sources from publicly-owned wastewater treatment plants (WWTP), and created a trading program. It also required that out-of-basin sources from Massachusetts, Vermont, and Canada reduce treatment plant contributions by 25%, nonpoint sources by 10%, and atmospheric deposition by 18%.

Since then, there has been a dramatic reduction of 51.5% in nitrogen contributions from Connecticut and New York WWTPs and the number of days with hypoxia has been reduced. Despite this, in 2015, the Connecticut Fund for the Environment petitioned EPA Regions 1 and 2 to develop a new or amended TMDL, stating that planned actions are not sufficient, climate change will worsen impairments in western LIS, nonpoint source treatment is insufficient, and there is new evidence of embayment impairments. EPA has moved forward with changes, focusing on additional nitrogen removal and addressing embayments Mr. Wolosoff noted that the changes to allowable nitrogen loads amount to a revised TMDL, not a reduction strategy.

Nitrogen sources include atmospheric deposition, wastewater treatment plant effluent, stormwater runoff, septic systems, agricultural runoff, and natural background (or ambient) amounts. EPA’s goal is to reach the natural, pre-colonial levels of nitrogen in LIS, which is not feasible or practical. All out-of-basin sources, including all Massachusetts sources, are already below pre-colonial levels. And, when attenuation is factored in, little benefit is derived from requiring additional controls. He added that the western LIS is most affected by hypoxia, yet Massachusetts’s contribution is to the eastern end. Also, links to local embayments are unclear.  The science indicates that sources in New York and Connecticut immediately adjacent to LIS are the dominant sources of nitrogen and dwarf inputs from other areas of New England. Mr. Wolosoff reviewed lower-cost options for reduction at treatment plants, but noted that stormwater Best Management Practices (BMPs) are more cost-effective than changes to WWTPs. The most effective BMPs appear to be yard waste pick up, street sweeping, and catch basin cleaning, which address the largest sources. When monitoring for DO, it’s important to note where samples are taken, as levels vary by depth, and should be conducted before and after measures are implemented. As the Coalition has noted previously, EPA has not engaged with Massachusetts stakeholders on what amounts to a TMDL revision that will significantly impact them.

You can learn about Nitrogen Trading at the Coalition’s 8th Annual Water Resources Strategies Symposium on May 17 in Marlborough. Stay tuned for future free workshops on other timely and regional topics.

MCWRS Reflects on 2016 Successes and Kicks off 2017 with a Bang!

MCWRS wishes to thank all our members and partner organizations for their continued support in 2016. As we launch 2017, we’re taking a look back at last year’s accomplishments.

We fought EPA on the MA MS4 Permit. After EPA issued the Final Permit in April, MCWRS rallied  communities and jointly filed a Petition for Review of the Final Massachusetts Small Municipal Separate Storm Sewer General Permit (MS4). The appeal was filed with the Town of Franklin in the First Circuit of the United States Court of Appeals in Boston. Briefing motions were filed in November and the Court is expected to set a briefing schedule soon. For more information, please visit our website.

We continued to advocate for MassDEP’s management of the NPDES program. In April, Governor Baker filed legislation for the Massachusetts Department of Environmental Protection (MassDEP) to take over the National Pollutant Discharge Elimination System (NPDES) Permit program from the U.S. Environmental Protection Agency (EPA) Region 1. MCWRS President and Chairman, Phil Guerin, provided testimony at the hearing on this bill in May and we submitted a comment letter in June. MCWRS will continue to advocate for this transfer of authority and urge the Governor to refile the legislation this session.

We launched our new visual identity. At the start of 2016, we presented a new look which reflects who we are as an organization and our growing role as the voice for environmental, social, and fiscal responsibility. Our branding was first revealed at the MA Municipal Association (MMA) Trade Show and it helped our materials stand out at the 2016 Symposium.

We expanded our educational opportunities. The Coalition continued to host free workshops in conjunction with our Board meetings. In March, participants heard an update on biosolids disposal regulations and learned about phosphorus removal technologies and capabilities. The June workshop focused on drinking water and featured a presentation on MassDEP’s Assistance Program for Lead in School Drinking Water, as well as an overview of emerging contaminants. Stay tuned for more workshops in 2017!

We had our largest Annual Symposium to date. The Coalition’s 7th Annual Water Resources Strategies Symposium in May was a major success! The event attracted over 115 participants and featured many prominent speakers, including a keynote address from Lieutenant Governor Karyn Polito and presentations by representatives of the Massachusetts Department of Environmental Protection (MassDEP). At the Symposium, MCWRS presented the 2016 Joseph J. Superneau Leadership Award to Ronald Labelle, former Commissioner of the Department of Public Infrastructure for the City of New Bedford who retired in 2016.

We welcomed new members. We welcomed new members in 2016 who joined for the fiscal year 2017, including the City of Melrose, and the towns of Leominster, Pepperell, and Wilbraham. We’re only halfway through the fiscal year, so there’s still time for you to join!

Our Board welcomed a new director and a new VP. The MCWRS Board of Directors welcomed Tom Holder, now the Director of Public Works in Wayland. President and Chairman Phil Guerin, Treasurer Cheri Cousens, and Secretary Bob Ward were reelected to their positions. Vonnie Reis was elected as the Executive Vice President and Vice Chair.

We continued to track important water resources policies, regulations, and issues. From EPA’s nitrogen reduction strategy for the Long Island Sound to MassDEP’s guidelines for performing infiltration/inflow (I/I) analyses, MCWRS continues to alert our members of interesting events, educational opportunities, regulatory hearings, and updates that matter to them.

We’re gearing up for another great year. The Coalition looks forward to more events and continued progress in 2017. Mark your calendar for the 8th Annual Water Resources Strategies Symposium on May 17 at the Marriott Courtyard Boston Marlborough.

EPA Hosts LIS Nitrogen Reduction Strategy Webinar

The U.S. Environmental Protection Agency (EPA) and its contractor, Tetra Tech, hosted a webinar about the Long Island Sound Study and its progress on the Nitrogen Reduction Strategy on December 19, 2016. The Nitrogen Reduction Strategy was created to meet a Total Maximum Daily Load (TMDL) to help alleviate hypoxia caused by low levels of dissolved oxygen in the open waters of the Sound. Tetra Tech will use existing hydrodynamic models and “good data” from existing studies to develop nitrogen thresholds and loads for the Sound, and allocation options (Mike Paul, Tetra Tech). The data is sourced from various universities, watershed groups, and the U.S. Geological Survey (USGS), and can date back to the 1970s. There does not appear to be a commitment to a new comprehensive sampling program, and how historical data will be screened to determine its accuracy and usefulness is not clear. Utilizing older data, from a multitude of sources, with inconsistent and non-uniform collection techniques as the foundation for science-based rulemaking does not make sense.

EPA repeatedly emphasized that transparency is critical in this process and the importance of collaborating with neighboring states and partners. However, EPA failed to truly embrace the public process, noting that it does not intend to do extensive outreach to the communities in neighboring states affected by the Strategy. Instead, it hopes that state agencies will reach out to the communities, and that other entities will periodically “check in” on the website for program updates. An EPA representative explicitly stated that the Strategy would not be open to public comment because they did not want to “be overwhelmed by having to respond to each comment.” EPA and Tetra Tech said comments may be accepted through an online form for certain technical documents, but that they are not required to respond to them, because it is not a rulemaking process. According to an EPA representative, a public meeting was held in Massachusetts explaining the Study and Strategy in May and that periodic webinars would inform stakeholders on progress. The level of outreach EPA intends to do to notify communities of the webinars is unclear. So far, for the most part, the process has been under the radar.

Becky Weidman of the Massachusetts Department of Environmental Protection (MassDEP) is one of the only Massachusetts representatives on any of the 12 different advising committees. The Science and Technical Advisory Committee guiding the Study and developing the criteria is made up of a variety of universities, colleges, environmental groups, and government agencies from Connecticut and New York. Massachusetts municipalities and utilities have no significant representation on any committees. MCWRS acknowledges EPA’s efforts to inform the public and focus efforts on LIS communities. However, Massachusetts communities should also be actively and directly involved in the planning process, since they will ultimately be issued National Pollutant Discharge Elimination System (NPDES) Permits reflecting the results of the study. Retrofitting wastewater treatment plants to meet stringent nitrogen limits can exceed hundreds of millions of dollars. When science-based studies are utilized to develop criteria for revised TMDLs and for setting nutrient limits in NPDES permits, it sounds like rulemaking, which requires a prescribed public comment period and process. ‘Hoping’ that State partners will update permittees and communities about the Study is disingenuous and subverts the spirit of the rulemaking process. Not surprisingly, the webinar reemphasized a well-known issue in the tenuous relationship between EPA and municipalities/utilities; EPA touts public involvement, working with communities, and relying on ‘good’ science, but often fails to put its words into action.