Great Bay Estuary Water Quality Coalition (Dover, Durham, Rochester, Portsmouth, Exeter, Newmarket) Works to Protect $250 Million in Taxpayer Funds

The Great Bay Water Quality Coalition, consisting of the municipalities of Dover, Durham (serving the University of New Hampshire), Exeter, Newmarket, Portsmouth and Rochester, have joined together to try to ensure that scarce municipal dollars (DES estimate $250M) are directed to infrastructure, programs and practices with demonstrable environmental benefits to the Great Bay Estuary.  The Great Bay Estuary is an important and irreplaceable resource; yet, regulatory decisions by the State of New Hampshire’s Department of Environmental Serves (DES) relative to nutrient criteria for the Great Bay Estuary may result in municipal dollars being misdirected.

          The Health of the Great Bay and DES Action:  Much has been written regarding the decline of eelgrass and oyster beds in the Great Bay Estuary; yet, the causes of that decline are not well understood.  In 2008, DES identified nitrogen as a prime water quality concern in the Great Bay Estuary.  Nitrogen enters water systems through both point sources, such as discharges from wastewater treatment plants, and non-point sources, such as storm water runoff, septic systems and fertilizers.  Excessively high levels nitrogen can, in some systems, impair eelgrass and oyster beds.

• Since 2008, the Coalition has questioned DES’ data and conclusions relative to role of nitrogen in the Great Bay Estuary relative to other factors (i.e. turbidity and sediment accumulation, effects of flood events, etc.) .
• June 2009 - ignoring objections from the Coalition, DES issued its report entitled Numeric Nutrient Criteria document for the Great Bay Estuary establishing allowable nitrogen limits effecting point and non-point sources discharges.
• The nutrient criteria document concludes that the Great Bay and Piscataqua River are impaired for nitrogen.
• 2010 - Communities continue to question the accuracy of the science; additional sampling conducted for the communities by UNH has brought into question whether nitrogen is the source of water quality problems in the Great Bay.

          The Local Impact of DES’ Regulatory Actions Regarding Nitrogen:  New permits for wastewater treatment plants are expected to have unreasonably low nitrogen limits that may result in no demonstrable environmental benefit.

• Scarce dollars will be spent on misdirected capital improvements.
• Operational requirements to achieve low nitrogen limits are not sustainable; personnel, electrical and chemical cost increases will be substantial.
• DES acknowledges cost to wastewater plant communities will be in excess of $250M
• These unfunded mandates could take away our NH advantage.   Even if nitrogen is a concern, overregulation of wastewater plants will not solve the problem.
• DES acknowledges that the vast majority of nitrogen (70-80%) entering the Great Bay Estuary comes from sources other than wastewater treatment plants.    
• Moratoriums on development may be mandated.

          How Can Citizens Help? After almost two years of requests, in December 2010 DES signaled its possible willingness to collaborate with the communities to conduct a comprehensive peer review of nitrogen impacts to the Great Bay Estuary.

• Encourage collaborative efforts between DES and communities to evaluate the science.
• Encourage informational meetings to hear communities concerns.
• Talk with legislators to increase understanding of impact of regulatory actions.
• Encourage EPA not to issue wastewater permits with unreasonably low nitrogen limits until DES and the communities complete a comprehensive peer review of the science. 

         Attached you will find the coalition's most recent correspondence with DES regarding this matter.