Commentary

WHAT WATERSHED PROTECTION NEEDS NEXT: A FRAMEWORK FOR PUBLIC UNDERSTANDING

by Albert F. Appleton

In 1990, the newly elected Dinkins Administration rejected the widespread conclusion that growing development pressures had made filtration of the water from the City's 2,000 square miles of upstate watersheds unavoidable. Since then, watershed protection has been a major policy imperative for New York City. The logic behind choosing watershed protection over filtration is simple economics. Filtering half a trillion gallons of water, the amount that the City uses each year, would be prohibitively expensive. Protecting the watershed costs far less and is far better environmentally as well.

Between 1990 and 1993, the City put in place the institutional infrastructure of watershed protection. It obtained two filtration avoidance decisions from the United States Environmental Protection Agency (EPA) that put off the requirement to filter through the end of 1996. The City also created a successful agriculture-friendly, clean water partnership program with watershed farmers. When the Giuliani Administration came to power in 1994, it made the usual changes in personnel and political perspective, but otherwise continued those efforts and, in early 1997, completed an upstate-City watershed protection partnership agreement. EPA thereupon granted the City a further filtration avoidance through 2002, with longer term avoidance possible based on watershed protection progress. Watershed protection has been one of the few areas of policy continuity between the two administrations, one likely to continue into the next Mayoralty and beyond.

Since then, on the key question of watershed protection progress, the debate has not gotten beyond the usual conflict between environmentalists demanding tougher government, and the government disputing the need for it. Environmentalists have raised questions about the pace of land acquisition, about proposed exceptions to septic management requirements, whether inappropriate development permits are being granted and, most recently, about the wisdom of State Department of Transportation proposals to expand the highways next to the Kensico Reservoir. But the typical push and pull between government and environmentalists has overshadowed the larger question: What measures must be taken to protect the watershed, and are they being implemented?

The agency that could fill this gap - EPA, the overseer of watershed progress - hasn't. EPA gets dozens of progress reports and reams of data on the City's watershed protection program. But to date, EPA has not systematized or reported this material in any way that could guide public understanding of the issue.

It is imperative that EPA address this problem, for this summer it will conduct a midcourse review of the City's watershed protection progress. The ultimate purpose of this process is public review and accountability. The importance of watershed protection makes public understanding of its progress critical. The benchmarks by which progress is measured need to be clear and intelligible to the public. EPA therefore needs to work with city and state governments, and citizen and environmental stakeholders, to create a simple, clear framework for reviewing watershed protection progress, one that can inform the public and give structure not only to the watershed debate, but to the watershed program itself.

Techno-babble and bureaucratic rhetoric aside, The actions needed to protect the watershed are very straightforward. Pollution levels in the watershed are low enough so that the City can meet drinking water standards without filtering its water, but high enough to be a matter of concern. Drastically reduce those levels and then prevent them from regrowing and the City can enjoy pure unfiltered water well into the 21st century.

This adds up to two sets of needed actions.

I. To reduce pollution:

  1. Upgrade all sewage treatment plants in the watershed to eliminate effluent discharges into streams, either by discharging sewage effluent sub-surface or, where sub-surface discharge is not possible, or by using micro-filtration techniques to remove over 99% of effluent pollution;
  2. Many watershed homes and businesses rely on septic systems, often old and placed dangerously near streams. Modernize these systems and insure their discharge is not getting into streams via groundwater flows;
  3. Control and reduce agricultural pollution runoff;
  4. Clean up pollution hotspots, such as old landfills, toxic sites, abandoned quarries, etc;
  5. Control excessive stormwater runoffs from roads and developments;
  6. Restore degraded stream corridors and minimize erosion sources; and
  7. Reduce phosphorous overloads in the City's many currently euthropic (algae producing) reservoirs to below 90% of the euthropic level;

II. To keep future pollution levels from regrowing:

  1. Carry out large-scale land acquisition to protect large forested and naturally vegetated landscapes where any further development is a water quality threat, specifically: the West Branch Reservoir Basin, the Esopus Creek corridor, the viewsheds of the Ashokan and Rondout receiving reservoirs, all large undeveloped land parcels in the Kensico Reservoir Basin;
  2. Ban any new sewage discharges into watershed streams;
  3. Prevent any loss of watershed wetlands;
  4. Preserve currently undisturbed stream corridors;
  5. Insure environmentally appropriate land development to minimize storm water runoff, including strict limits on impervious, paved over surfaces;
  6. Establish systematic pollution prevention programs with watershed businesses and governments;
  7. Invest in natural resource based watershed economic development that preserves landscapes and provides jobs for under-employed watershed residents;
  8. Identify the natural limits on pollution loadings for each watershed reservoir basin to insure that any new development can be accommodated within the basin's environmental carrying capacity.

"How'm I doing?" was Ed Koch's familiar refrain. In terms of watershed protection, the answer to his question is still unclear. We need EPA's leadership to structure the mid-course review so that it guides public understanding and provides detailed specifics on how each of these tasks are being carried out, so that the public can judge whether pollution loadings are in fact being reduced, that barriers to pollution regrowth are being put in place and working, and that the City remains on course to enjoy pristine, low cost, unfiltered mountain water.

Between 1990 and 1993, Albert F. Appleton served as Commissioner of the New York City Department of Environmental Protection and initiated the development of New York City's comprehensive watershed protection program.

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