Many thanks to Eagle Street Rooftop Farm for hosting our meeting yesterday! The scenery was bucolic but the discussion turned to the serious topic of public notification…here are the bullet points.
The following points were revisited by Coalition members with representatives from NYC DEP (Chris Hawkins, Scott Johnson, Mikelle Adgate) present. Click here to download as a tidy pdf.
• The major North River WPCP bypass and subsequent public notification was observed by Coalition members to be inadequate, citing the failure to alert and prevent the organized boating community from holding programs Wednesday and Thursday, as well as the widespread observance of swimming and fishing in close vicinity to sewer bypasses on the Hudson and Harlem Rivers.
From Rob Buchanan of NYC Water Trail, “From our perspective the notification last week was not ‘ample,’ as you put it, but inadequate–dangerously so. We saw a few news stories on Wednesday that mentioned the possibility of a release, but heard nothing definitive until Thursday morning, when we called the DEP. If there was a Notify NYC bulletin, we didn’t receive it (please do forward that, by the way). Furthermore, at no point did the DEP, either in phone conversations or in its written ‘updates,’ convey to us that the releases were happening all up and down the West Side and in the Harlem, rather than at the North River plant itself. If it weren’t for the Riverkeeper reports, in fact, we still wouldn’t know that. As a result, at least three West Side boating groups put people in the water Wednesday evening and Thursday morning. At my boathouse, we sent out a large group of rowers from Stuyvesant High School as part of our regular youth programming. There is no way that would have happened if we had had an accurate picture of when the releases began and where they were occurring.”
• Waterfront uses on all 600 miles of NYC waterfront, not just the handful of bathing beaches, require public notification that represents a nuanced, accessible (ie, visually-based) portrayal of what is happening in the water.
• If CSO public notification was happening properly, it would be in place for emergencies such as dry weather bypasses.
• Near shore monitoring – as most recently demonstrated by Riverkeeper – most accurately captures the severe but localized water quality impairments related to CSO events and dry weather bypasses and should be used (in conjunction with modeling, in advance of receiving lab reports on water quality samples) as the basis for issuing use advisories, not 30-day averages the DEP currently depends on, nor the mid-channel samples DEP has been taking.
• High-resolution rainfall data correlated with real-time CSO monitoring should be prioritized as the basis for a predictive notification system. The location and occurrence of CSO events is what should be communicated, not the “diluted message” of 30-day averages.
• Internet-based alerts methods do not reach a significant portion of waterfront users, and should be complemented with use-specific direct outreach methods.
• Existing networks within the boating, swimming, fishing, etc. communities should be utilized and proactively provided with timely and complete information. Same goes for broadcast media – in particular, broadcast meteorologists.
• The city is required by local, state, and federal law to notify the public of the occurrence and location of CSOs, and of the nature and duration of conditions that are potentially harmful to users of affected waterbodies. (See the EPA CSO Control Policy, the city’s NPDES permits (issued by NYSDEC), and Local Law 5 of 2008.)
• The DEP/DOH advisories – or ‘recommended use restrictions’ – have been interpreted by many agencies and individuals as an outright ban on boating, and there’s a common perception that the river is ‘closed.’ However, the Coast Guard is the only agency that can close the waterways. The DEP should strenuously avoid taking on the role of an ‘enforcement’ agency and instead focus on providing clear information to harbor stakeholders, so that we can all make educated decisions on getting back in the water.
The S.W.I.M. Coalition has previously identified for DEP the following examples of public notification BMPs, most recently in a letter to the Commissioners of NYCDEP and NYCDHMH from June 30 (available here):
1. Metropolitan Water Reclamation District of Greater Chicago: A color-coded graphic representation of the waterways appears on the web page depicting the occurrence of CSOs and waterway diversions to Lake Michigan. This map is updated on a daily basis seven days per week. Upon occurrence of a CSO in a given waterway segment, the color of the segment shown on the map changes from blue to red. The color of the waterway segment downstream of the segment on which a confirmed CSO has occurred will, by default, also changes to red, indicating that the water quality of that segment may be affected as well. The on-line maps of CSOs are updated as the information becomes available and are typically certified the following day. In conjunction with the above maps, a CSO Synopsis Report that provides “start and stop” times for individual CSO discharge points is also available on the website.
2. Pittsburgh – Allegheny County Sanitary Authority (ALCOSAN) and Allegheny County Dept of Health (ACDH) maintain 44 “Flag Sites”. This program flies a CSO flag at marinas and river access locations when river contact recreation is ill-advised. If the flag is up, river use is constrained. CSO events and awareness on the flag system is reported through local TV, radio and print media. In addition, ALCOSAN maintains a color-coded Sewer Overflow Advisory Key (SOAK), that “grades” current water quality by a visual color key, indicating conditions in terms of appropriate recreational uses and stores a history of water quality alerts online.
3. 3 Rivers Wet Weather Demonstration Project (3RWW) Calibrated Radar Rainfall Data: Beginning in 2001, 3RWW operates and maintains 33 rain gauges throughout Allegheny County, which collect actual rainfall during wet weather events. The primary radar source used for the County is the National Weather Service (KPBZ) NEXRAD radar, located in Moon Township. NEXRAD is the rainfall radar usually seen on TV. The radar data gathered during a wet weather event is calibrated with the rain gauge data collected during the same time period for every one square kilometer in Allegheny County. Communities in the ALCOSAN service area need accurate rainfall data to analyze and design cost-effective sewer rehabilitation projects and long-term sewer maintenance plans. Through this calibrated system, high-quality rainfall data is available online about two weeks after the end of each month. In 2002, 3RWW expanded the system to cover all 130 Allegheny County municipalities and to provide real-time rainfall data, which is critical for optimizing the operation of wet weather treatment and storage facilities.
4. Philadelphia RiverCast: a forecast of water quality that predicts potential levels of pathogens in the Schuylkill River between Flat Rock Dam and Fairmount Dam in Philadelphia. RiverCast Water Quality Designations are based upon historical relationships between water quality, stream flow, and rainfall data, and on the United States Environmental Protection Agency’s “Implementation Guidance for Ambient Water Quality Criteria for Bacteria” (USEPA, 2002). This document identifies the maximum level of bacteria measured in a single sample that would be within acceptable illness levels for recreational activities that may involve complete immersion in the water. The conditions and Water Quality Designations defined by the historical data were tested on a set of recent data (2004 to 2005) to assess the accuracy of the relationships and the RiverCast predictions. This testing showed that the RiverCast relationships are very conservative. 65% the time the RiverCast prediction was accurate. 35% of the time the prediction was conservative (higher bacteria levels were predicted than measured). There were no examples of predicted levels lower than the measured levels.