Great Bay Municipal Coalition
New Hampshire Water Pollution Control
Association
June 13, 2013
Dean Peschel
Peschel Consulting
603-781-5931
Great Bay Municipal Coalition
Dover, Exeter, Newmarket, Portsmouth, and
Rochester
Protect Estuary resources
Understand the science
Invest in solutions that address cause of resource
degradation to the extent necessary
History of Nitrogen Issue
NH Estuary Program TAC 2005-2008
Concluded N not cause eelgrass loss
2009 NHDES Numeric Nutrient Criteria
Concluded N was the cause of eelgrass loss
Established a 0.3 mg/l TN water column transparency
based WQ standard to protect eelgrass
2009 NHDES declared Great Bay Impaired
2011 EPA issues draft NPDES permits
Limits of technology (3 mg/l)
Conceptual Model
Excess Nitrogen stimulates phytoplankton growth
(chl-a)
Excess phytoplankton in the water reduces light
transparency
Reduced light transparency impacts eelgrass
Conclusions
Reducing nitrogen levels in the estuary will not
materially improve water column transparency
Proposed 0.3 mg/l TN transparency based WQ
standard is unjustified
Plan that makes sense
Best use of available resources
Addresses point and non point sources
Monitors progress and adapts
Coalition Adaptive Management proposal (Oct.-11)
Utilizes recommendations from the Piscataqua River Estuary
Partnership's CCMP
Adaptive Management Proposal
• Coalition WWTP's discharging to the estuary
8 mg/l N permit limits; Operational within 5 yrs
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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 permits
3 mg/l TN permit limit
Extended schedule
Required to develop plan to reduce nonpoint
Both communities have to build new treatment plants
Dover has a draft permit (3mg/l TN)
Rochester and Portsmouth expect draft permits in
near future
2012 State of Estuaries Report
2012 PREP State of Estuaries Report
2012 SOE Report confirms
Algae (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 NHDES
RSA 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
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Flexibility
2012 draft MS4 permit >200 pages
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Prescriptive
Overwhelming
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Cost
Municipal Resources
NH Stormwater Coalition
Opportunity
60 MS4 NH Communities
Represent >750,000 NH residents
Challenges
Large and Small communities
Unfamiliar working together
Concerns over fairness and approaches
Coalition Building
Funding formula has changed
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Local responsibility
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Provide funding
Insure resources are spend wisely
Local and Regional Coalitions
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Political support
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Federal
State
Financial cost sharing
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Legal expertise
Technical expertise