1. To:
From:
Date:
Re:
Interested Parties
Carl LoBue, The Nature Conservancy
January 12, 2014
Further discussion on advancing the level of treatment of sewage at Bay Park STP assuming
approval, funding, and installation of an ocean outfall.
Several weeks ago, The Nature Conservancy submitted a letter to US EPA, HUD, and FEMA urging
them to come together to express support, allocate and prioritize funding, and expedite process and
permitting for the rehabilitation, re-engineering, and fortification of the Bay Park Sewage Treatment Plant
and the ancillary wastewater treatment infrastructure of south-west Nassau County. In particular, the
letter documented the rationale to:
•
•
•
•
•
•
•
replace the existing outfall pipe that discharges to Reynolds Channel with an outfall to the
Atlantic Ocean;
consolidate treatment of sewage from adjacent communities to meet current and
anticipated regional wastewater needs;
fortify the treatment plant facility and its vulnerable assets to prevent damage from future
storms;
modernize technology to advanced treatment that will reduce nitrogen;
adopt design plans that can readily accommodate future treatment for emerging
contaminants;
transform to real-time digital monitoring and automated flow and discharge compliance
reporting, and
establish a community oversight board as part of the agreement with private professional
operator(s).
Significantly, these recommendations mirror those expressed by US Senator Schumer in May 20131, and
represent consensus of a long list of community stakeholders and civic leaders. These recommendations
were developed as a result of thorough review of the findings of a series of publicly financed studies and
planning documents that were produced just prior to and immediately after Hurricane Sandy2,3,4.
Based upon findings of studies specifically focused on eutrophication impairments and TMDL
development for the western bays, there is now wide-spread anticipation that Limit of Technology (LOT)
nitrogen removal standards will soon be mandated should Bay Park Sewage Treatment Plant (STP)
continue to discharge to Reynolds Channel4. As a follow-up to the December 11th letter, The Nature
Conservancy would like to more fully elaborate the rationale for our call for advancing the treatment level
and thus improving the quality of sewage effluent, assuming that there will be approval and financial
support to consolidate treatment, and relocate the combined western bays sewage effluent (Bay Park,
Long Beach, Lawrence, Cedarhurst, and Atlantic Beach) through a new outfall pipe to the New York
Bight.
Consideration of what treatment standards are appropriate with relocation of the outfall to NY Bight will
ultimately require an Environmental Impact Statement (EIS) that considers the anticipated impacts based
on the new location5. Such impacts will be directly related to the volume and contents of the sewage
effluent, therefore, alternatives that include different levels of treatment must be considered as part of the
NEPA process. Information on the impacts of large volume sewage discharges on marine systems, our
current understanding of conditions in NY Bight, and the options available for treatment have greatly
expanded since EPA last completed the Environmental Impact Statement that approved construction of
the then proposed Cedar Creek and Bergen Point STP ocean outfall projects in 19726. In addition, we

2. believe that common sense, good science, and legal requirements dictate that the new EIS should consider
cumulative impacts of other sewage discharges into NY Bight.
Pending the thorough review that will be part of that EIS, our
view that some level of advanced treatment should be included
as plans are currently developed to upgrade this facility is based
upon a basic understanding of the impacted areas. New York
Bight is obviously a far larger waterbody than the poorly flushed
western bays7. Thus, in and of itself, moving the sewage
outfall outside of the estuary and away from densely
populated bayside communities is projected to provide
significant mitigation of environmental, human health, and
quality of life issues that are currently problematic within
the estuary and along the ocean beaches that chronically
accumulate decomposing sea lettuce, a noxious algae8. That
is why there is very strong support within a broad coalition
for relocating the outfall to NY Bight, and why we strongly
encourage relocation of the outfall under any circumstances.
New York Bight, however, is not an inexhaustible receiving
body for secondary treated sewage. Cumulatively, New York
Ocean
sewage
outfalls
in
NJ
(from
Clean
Ocean
Action.org)
Bight is already receiving sewage from 14 separate ocean
outfalls in New Jersey, two on Long Island (Bergen Pt. and
Cedar Creek), and also receives sewage effluent via conveyance from NY/NJ Harbor and Jamaica Bay.
Although less research has been done on the cumulative impacts of sewage effluent in NY Bight than has
been done in adjacent estuaries, recent studies show that New York Bight is already failing to attain NYS
DEC’s and USEPA’s best usage criteria for dissolved oxygen9, which is a symptom of eutrophication
observed in other areas where there are high nitrogen loads from sewage and/or agriculture. In addition,
model projections suggest that pending nitrogen and carbon TMDLs in New York Harbor Estuary will
not significantly mitigate the area or decrease days of non-attainment of best use in NY Bight9. These
findings in and of themselves strongly suggest that the chronic addition of large volumes of secondary
treated sewage will result in additional impairments to NY Bight.
Projected
days
of
dissolved
oxygen
standards
non-­‐
attainment
under
baseline
conditions.
Based
on
SWEM
results
and
NYS
DEC
Chronic
Dissolved
Oxygen
Standard
for
marine
waters.
1989
hydrodynamics
From
HydroQual
2010
report
to
US
EPA/NY
9
NJ
HEP

3. In the absence of incorporating additional nitrogen reducing treatment technology and in the reengineering of the Bay Park STP, the total additional nitrogen loads to NY Bight from the new outfall
will be greater than the 2,445 tons of total nitrogen annually (much of it in the form of ammonium),
which are now discharged from Bay Park (2,247 tons), Long Beach (157 tons), Atlantic Beach (11 tons),
and Lawrence (30 tons) STPs8. The effluent is likely to exceed the current loads because of the
anticipated addition of the Cedarhurst district, eventual expansion of sewer service to Point Lookout, and
projected population growth and new development in the County.
Public concerns over the impacts of the existing sewage discharges to fisheries, wildlife, recreation, and
human health within New York Bight and its fringing ocean beaches in NY and NJ have already
prompted calls from Clean Ocean Action and its supporters for a federally designated ocean management
area from Cape May to Montauk Point called the New York Bight Clean Ocean Zone where all additional
sewage discharges would be prohibited10. However, as detailed in our December 11th letter, The Nature
Conservancy has concluded that in order for Long Island to remain a vibrant and attractive place to live
and work, the option of discharging highly treated sewage effluent to NY Bight must remain open.
Reasons for this conclusion follow.
As you of course are aware, there are well-documented environmental, human health, and economic
development needs to modernize Long Island’s wastewater infrastructure. Three million residents rely on
Long Island’s sole source underground drinking water aquifers for all of our fresh water needs. These
aquifers are already compromised and trending worse from elevated nitrate and other compounds such as
pharmaceuticals that originate from cesspools and septic systems11. Upgrading the 70% of Suffolk
County and almost 30% of Nassau County that still rely on cesspools and septic systems will require
sewer expansion, particularly in high groundwater areas were septic systems are failing. Recharging
groundwater aquifers with this volume of sewage is currently not viable11. And, almost every single fresh
and estuarine surface water body on Long Island is already impaired12, disqualifying them as preferred
areas for additional sewage discharges. Thus, even when the technology for recovering resources
from wastewater becomes
more accessible, Long
Island will still be forced to
look towards New York
Bight as receiving water
for additional sewage
effluent in the future
because other options are
severely limited. Ocean
resources and clean
beaches are incredibly
valuable to Long Island,
thus it is critical to assure
that effluent is treated to
high enough standards to
avoid further
compromising the integrity
of this nationally
significant waterbody.
Notably, the nitrogen limits that are appropriate for a new ocean outfall at Bay Park are not as expensive
or cumbersome as the LOT standards that would most certainly be required should the outfall location
remain inside the estuary. Specifically, we are recommending total nitrogen discharge standards of 8 mg
N/l. Treatment to this level is far less expensive than treatment to 3 mg N/l (LOT). For example, the

4. State of New Hampshire estimated the costs to upgrade its effluent standards to 8 mg N/l for STPs
discharging to Great Bay, NH would be 55% of the capitol cost and 25% of the operations and
maintenance costs required to upgrade them to 3 mg N/l14. We are also recommending that the
reconstructed Bay Park plant be designed and fortified in such a way as to readily accommodate treatment
add-ons to achieve higher standards and/or target emerging contaminants in the future. This is a common
sense design approach that will save money and expedite future upgrades and resource recovery
opportunities. The redesigned plant should also utilize ultra-violet (UV) as opposed to chlorine as a
disinfectant. This process will not only render the final effluent more compatible with living marine
resources in NY Bight, it will also be cost effective because the increases in the costs for chlorine and
sodium hypochlorite are outpacing the costs of energy to run the UV system2.
We strongly recommend that NYS DEC and US EPA apply a cooperative multi-agency precautionary
approach to the current situation at Bay Park The plant must undergo massive re-engineering now. In
fact engineering designs will need to be completed in advance of the final findings of the ocean outfall
EIS. It is more fiscally responsible to anticipate the treatment upgrades now as part of the re-engineering
and fortification designs of the plant compound. Conversely, the annual addition of roughly 2,500
tons of nitrogen into a waterbody that is already failing to fully achieve its best use designation, less
than 3 miles from Long Island’s most populous ocean beach community, is an unnecessary gamble
that is inconsistent with the missions of these agencies and with major investments currently being
made to revitalize the city of Long Beach.
Finally, any degradation of NY Bight would negatively impact fisheries and coastal economies of New
York and New Jersey. Based on experience it would take years of expensive taxpayer funded research to
thoroughly document these types of problems, and then additional years of costly studies to develop a bistate TMDL for NY Bight. Subsequent to that it would take more than a decade to phase in upgrades to
the new and recently re-designed STP at Bay Park at a time when there will unlikely be the financial
resources available to make those upgrades. In that scenario, New York would once again be in the
undesirable and expensive position of having to restore a major waterbody as opposed to simply
protecting it. We are convinced that the approach most consistent with Governor Cuomo’s
forward-looking philosophy of preparing infrastructure for the future is to rebuild Bay Park STP
now in a way that anticipates future needs. Then, even if conditions in NY Bight deteriorate in the
future, the focus can be on modernizing the older existing treatment plants rather than re-building Bay
Park for a second time.
Right now there is an unprecedented outpouring of community support for making necessary investments
in Nassau County’s wastewater infrastructure. Prior to Hurricane Sandy the dialog around Bay Park STP
issues was mired in animosity and contempt among community groups and stakeholders towards
government officials who were blamed for years of neglect, endless studies, and seeming inaction. But
the need to come together after Sandy has completely transformed the tone of the civic discourse. The
tone now is of collaboration towards a universally supported vision for modern, well managed wastewater
treatment system that complement’s NY Rising’s goals for resilient and vibrant waterside communities in
southwest Nassau County. As final plans emerge, however, we are concerned that a failure to take
advantage of the opportunity to improve treatment will create the appearance that a decision has been
made to simply relocate the ongoing chronic sewage caused problems from the bayside of Long Beach
Island to the ocean side of Long Beach Island. This will fracture the unity, foster mistrust, and give voice
and momentum to otherwise well-intentioned advocates who steadfastly oppose any and all additional
sewage discharges into New York Bight.

5. While the expense may seem to be daunting, the investment now to increase wastewater treatment and
move the outfall can be a win-win for everyone -- NYS DEC, the other government agencies, the people
living in the community and the environment. As always, I am available should you have any questions.
Sincerely,
Carl LoBue
Sr. Marine Scientist
The Nature Conservancy on Long Island NY
250 Lawrence Hill Rd
Cold Spring Harbor NY, 11724
631-367-3384 ext 113
clobue@tnc.org
Footnotes
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2.
3.
4.
5.
6.
7.
8.
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10.
11.
12.
13.
14.
Schumer C. US Senator. May 29 2013 letter to EPA, FEMA, and HUD.
Dvirka and Bartilucci 2009. Long Beach Sewage Treatment Plant Alternatives Feasibility Study.
http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&ved=0CEcQFjAA&url=http%3A%2F%2Fwww.l
ongbeachny.gov%2Fvertical%2Fsites%2F%257BC3C1054A-3D3A-41B3-8896814D00B86D2A%257D%2Fuploads%2F%257B35FF376B-F530-458D-A4893C68164D6284%257D.PDF&ei=YObFUpvXLMKY2QWm_oDwCg&usg=AFQjCNFzVf-NJXaRzd1k0IDnx3nzSYLrQ&sig2=P871DQ54fMw5x8SDAai5Aw&bvm=bv.58187178,d.b2I
Gulbransen T., et al 2013. Ecosystem Assessment and Nitrogen Management in Western Bays. NY. Report to NEIWPCC
CH2MHILL. 2013. Nassau County Bay Park Sewage Treatment Plant Report for the Conceptual Study of Alternatives to Meet Future
Nutrient Limits. Prepared for NCDPW.
NEPA and EIS compliance criteria. http://www.epa.gov/compliance/basics/nepa.html#eis
EPA 1972. Environmental Impact Statement on Wastewater Facilities Treatment Construction Grants in Nassau and Suffolk
Counties, NY.
http://nepis.epa.gov/Exe/ZyNET.exe/2000P6DM.PDF?ZyActionP=PDF&Client=EPA&Index=Prior%20to%201976&File=D%3A%5
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Wilson R. and D. Yang. 2013. Quantitative Description of the Spatial Patterns in Residence Times within the Hempstead Bays
Region. A Report to Battelle Memorial Institute and New York State Department of State. April 2013
Swanson L. et al. 2013. A Synthesis of Loadings, Monitoring, Information, and Impairments in the Western Bays. A Report to
Battelle Memorial Institute and New York State Department of State. April 2013
HydroQual 2010. Final Technical Report – Assessment of NY Bight Data Technical Memoranda. NEI 0286-007.
http://harborestuary.org/reports/nutrient/AssessmentOfNYBight0410.pdf
Clean Ocean Action NY Bight Clean Ocean Zone Federal Proposal 2011 www.cleanocean.worldpress.com
CDM 2010. Suffolk County Comprehensive Water Resources Management Plan.
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Wood, C. 2006. Recharge for a Sole-Source Aquifer: The Successes and Failures of Cedar Creek Treatment Facility, Nassau County,
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NYS DEC 2011. The Atlantic Ocean/Long Island Sound Basin Waterbody inventory and Priority Waterbodies List. Vol 2. Nassau
and Suffolk Counties. http://www.dec.ny.gov/docs/water_pdf/pwlalis11v2.pdf
Trownbridge, P., 2010. Analysis of Nitrogen Loading Reductions for Wastewater Treatment Facilities and Non-Point Sources in the
Great Bay Estuary Watershed. Report for State of New Hampshire Department of Environmental Services
http://des.nh.gov/organization/divisions/water/wmb/coastal/documents/gb_nitro_load_analysis.pdf