(December 18, 2018) NACWA provided comments to the EPA Region 2 Long Island Sound Office on December 14 regarding the latest technical report from the Regions on their Nitrogen Reduction Strategy, which is part of a broader effort to improve water quality in the Long Island Sound.
NACWA has been raising concerns on the Strategy for the past year, most recently writing the Regional Administrators in April — that letter was included as an attachment to NACWA’s December 14 letter.
NACWA’s new letter raises concerns over the technical basis for the nitrogen concentration endpoints presented in the Subtask F&G Memorandum, but the Association’s main concern remains the process that EPA is using to conduct the work. Rather than update the existing dissolved oxygen total maximum daily load (TMDL) that has been in place for the Sound for almost two decades, EPA is relying on narrative water quality criteria to develop what it considers to be safe loadings of nitrogen based on the protection of eel grass in key embayments and other waters that abut the Sound.
Despite assurances from the Regional Administrators that these studies will not have regulatory implications, the numbers that are developed will no doubt serve as the basis for future permit limits and other requirements. NACWA continues to work with its members in the Long Island Sound watershed on this issue and has engaged EPA Headquarters as well. Contact Chris Hornback, NACWA’s Deputy Chief Executive Officer, with any questions.