S.W.I.M. Coalition & Member Comment Letters to DEP

S.W.I.M. Coalition, our members, and community partners have been busy attending public meetings and writing comment letters to the City over the past few months as the Combined Sewer Overflow Long Term Control Plans have been released. See all the letters here

We are very concerned about the general approach in the 6 plans (out of 11 the City plans to release between now and 2017) they have released so far. The general trend in almost all of the plans appears to be: to do the bare minimum.

Our Key Concerns Are:

  • Despite acknowledging massive amounts of sewer overflow, the plans often point the finger at other pollution sources, arguing that further CSO reductions would not meet water quality goals because those other sources (including sources controlled by the City) would still remain.  Instead, for each water body, the DEP should determine the necessary pollution reduction levels from all sources to achieve fishable, swimmable waters.  This is the only way to determine the necessary targets for CSO reduction.
  • Many of the plans propose to disinfect overflowing sewage with chlorine, rather than actually reducing the volume and frequency of sewage overflows. We think the City can do better than that and propose more solutions that address CSO volume. Also, high doses of chlorine may pose health and environmental risks that need to be studied carefully.
  • Many of the plans propose a very limited amount of Green Infrastructure, which can capture and filter stormwater runoff before it reaches local sewers and waterways, thereby reducing sewer overflows. DEP has not yet assessed the full potential to deploy green infrastructure in each watershed.  
  • Although DEP has made improvements to its public engagement process in recent years, there have still been many instances where public meetings were not well-advertised, and where complex technical information was not presented in a way the average citizen can understand.  Good plans need to account for the concerns of well-informed local communities; this requires better public engagement by DEP.

While we realize and respect that the water quality improvement plans are immense in scale and the standards set forth by state and federal agencies are high and difficult for the City to meet in every case, nevertheless, we are concerned that many opportunities for improvement are getting missed. If the City doesn’t pursue aggressive action plans now while the proposals are in the development stage, there is a good chance that, at the very least, another generation of New Yorkers will face chronically unhealthy conditions in our local waterways.

As of December 28, 2015, we have requested a meeting with DEP to review our concerns and have distributed our key concerns to elected officials and stakeholders citywide in the hopes that we can all work together to improve the health of waterways and neighborhoods for many generations to come.

Check out our LTCP Fact Sheet to learn more about the plans and what you can do to let the City know you expect more of them as they develop long-term water quality improvement plans. Our voices matter!

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