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Great Bay Municipal Great Bay Municipal CoalitionCoalition
New Hampshire Water Pollution ControlNew Hampshire Water Pollution Control
AssociationAssociation
June 13, 2013June 13, 2013
Dean PeschelDean Peschel
Peschel ConsultingPeschel Consulting
603-781-5931603-781-5931
Dover, Exeter, Newmarket, Portsmouth, Dover, Exeter, Newmarket, Portsmouth, and Rochesterand Rochester
Protect Estuary resourcesProtect Estuary resourcesUnderstand the scienceUnderstand the science
Invest in solutions that address cause of Invest in solutions that address cause of resource degradation to the extent necessaryresource degradation to the extent necessary
Great Bay Municipal CoalitionGreat Bay Municipal Coalition
History of Nitrogen IssueHistory of Nitrogen Issue NH Estuary Program TAC 2005-2008 NH Estuary Program TAC 2005-2008
Concluded N not cause eelgrass lossConcluded N not cause eelgrass loss
2009 NHDES Numeric Nutrient Criteria 2009 NHDES Numeric Nutrient Criteria Concluded N was the cause of eelgrass lossConcluded N was the cause of eelgrass loss
Established a 0.3 mg/l TN water column Established a 0.3 mg/l TN water column transparency based WQ standard to protect transparency based WQ standard to protect eelgrasseelgrass
2009 NHDES declared Great Bay 2009 NHDES declared Great Bay ImpairedImpaired
2011 EPA issues draft NPDES permits 2011 EPA issues draft NPDES permits
Limits of technology (3 mg/l) Limits of technology (3 mg/l)
Conceptual ModelConceptual Model
Excess Nitrogen stimulates phytoplankton Excess Nitrogen stimulates phytoplankton growth (chl-a)growth (chl-a)
Excess phytoplankton in the water reduces Excess phytoplankton in the water reduces light transparencylight transparency
Reduced light transparency impacts Reduced light transparency impacts eelgrasseelgrass
ConclusionsConclusions
Reducing nitrogen levels in the estuary Reducing nitrogen levels in the estuary will not materially improve water column will not materially improve water column transparency transparency
Proposed 0.3 mg/l TN transparency Proposed 0.3 mg/l TN transparency based WQ standard is unjustifiedbased WQ standard is unjustified
Plan that makes sensePlan that makes sense
Best use of available resourcesBest use of available resources
Addresses point and non point sourcesAddresses point and non point sources
Monitors progress and adaptsMonitors progress and adapts
Coalition Adaptive Management proposal (Oct.-Coalition Adaptive Management proposal (Oct.-11)11)
Utilizes recommendations from the Piscataqua River Estuary Utilizes recommendations from the Piscataqua River Estuary Partnership's CCMPPartnership's CCMP
Adaptive Management Proposal
• Coalition WWTP's discharging to the estuary 8 mg/l N permit limits; Operational within 5 yrs
• Invest in WQ and Habitat monitoring & research
• Invest in habitat restoration projects• Stormwater improvements• Septic system contribution reduction
strategy • Fertilizer use controls• Stream and wetland buffers• Support land conservation
Recent Developments
Newmarket and Exeter have final permits3 mg/l TN permit limit
Extended schedule
Required to develop plan to reduce nonpoint Both communities have to build new treatment plantsDover has a draft permit (3mg/l TN)
Rochester and Portsmouth expect draft permits in near future2012 State of Estuaries Report
2012 PREP State of Estuaries Report
2012 SOE Report confirmsAlgae (phytoplankton) blooms have not increased in more than 30 years
Macroalgae is an emerging problem that requires additional research
Effect of nitrogen loads on system not fully determined and requires more research
Eelgrass in Little Bay have rebounded to highest level in decades
Excessive rainfall during 2004-2007 resulted in
a temporary peak in nitrogen levels
Current Coalition Efforts
State law suit NHDESRSA rule making
Federal law suit EPA Appeal of Newmarket NPDES permit NH Legislative effort
Require NHDES to conduct independent peer review of 2009 Nutrient Criteria
Initiate rule making process on appropriate WQ standard
Current Coalition Efforts
Preparing for peer review of 2009 Nutrient Criteria
Communities partnering with PREP to conduct eelgrass mapping 2013
Completing development of a hydrodynamic model of the estuary
Draft NH Stormwater Permit
2003 MS4 permit < 50 pages• Flexibility
2012 draft MS4 permit >200 pages• Prescriptive• Overwhelming
– Cost– Municipal Resources
NH Stormwater Coalition
Opportunity60 MS4 NH Communities
Represent >750,000 NH residents
ChallengesLarge and Small communities
Unfamiliar working together
Concerns over fairness and approaches