LIST OF RECOMMENDATIONS

Water Quality

• The high level of Croton water quality indicates that the Croton watershed has a natural “immune system”, aided by its abundance of wetlands and forests that protect it against the pressures of development. If these natural resources are protected, and measures instituted to mitigate the effects of poorly-planned development, water quality will improve even further. In the following, we presents measures that can be taken to accomplish those ends.
  

Development and Land Acquisition

• New York City should appropriate $200 million towards land purchases and the acquisition of conservation easements in the Croton Watershed, particularly in Putnam County. Within the next three years, the City should itself set a goal, preferably in partnership with other government agencies, private citizens and land trusts, to protect at least half of the 30,750 acres that still need protection. With local sentiment running high against the rapid disappearance of open space, the City would find the strong support among the citizenry that would make such protection possible.
  
  

Stormwater Runoff from Nonpoint Sources

• DEP should contribute its fair share to protect its Croton reservoirs by actively participating in the remediation of those sites identified by Trout Unlimited.
  
  
• DEC should assign all reservoirs East of Hudson (EOH) the 15 µg/L phosphorus concentration limit. This will result in less phosphorus being allowed into the reservoirs (i.e., lower TMDLs), better water quality, less chlorine required for disinfection with, consequently, lower concentrations of disinfection byproducts.
  
  
• DEP and DEC should lend their expertise to help towns comply with their phosphorus reduction requirements, and provide legal backup for the lawsuits that will inevitably follow.
  
  
• It is critical that strict compliance with Phase 2 regulations be enforced by the regulatory agencies. If necessary, extra staff should be hired and funding should be included in the New York State budget. Given the size of the fines DEC imposes (up to $25,000 per violation), a vigorous enforcement program would likely generate enough revenue to be self-financing.
  
  
• Within each sub-drainage basin in a new development submitted for approval, the level of imperviousness should be kept at 10% or below unless the developer can prove, based on site specific data - not the Nationwide Urban Runoff Program (NURP) data which are national averages – that the proper mitigation methods can maintain the phosphorus runoff at its pre-development levels. DEP engineers should be at the disposal of town lead agencies to help carry out such site plan reviews.
  
  
• Agencies such as DEP, DEC and DOT should encourage and facilitate the use of pervious driveways and parking lots among homeowners and for commercial enterprises. Towns should be made aware of the advantages of pervious paving, and assisted in revising their codes to permit the use of such products.
  
  
• In the watershed, more accurate methods and models than the Simple Method for predicting pollutant loads should be required. Furthermore, the input data used in the model (e.g., on phosphorus) should be determined by pre-development, on-site measurements, and then compared with post-development on-site measurements to determine if the stormwater management devices are performing as predicted. This type of analysis, which includes the measurements of on-site data, is currently being carried out by DOT engineers in a sub-basin of the Kensico Reservoir.
  
  
• The Stormwater Pollution Prevention Plan (SPPP) for a development should be included in the overall site plan from the start. Furthermore, all SPPPs should clearly designate the agency responsible for their devices’ maintenance.
  

Wetlands

• We recommend that no wetlands be crossed to allow more development unless there is a feasible way of installing a bridge crossing.
  
  
• The safeguards against wetlands impacts that are implicit in the Critical Resource Waters designation should be fully enforced by the lead agency during the site plan review of any application where wetlands, or other waterbodies are involved.
  
  
• Within the watershed, 150 feet should be the minimum buffer width. No stormwater management devices should be allowed within buffers – a common practice. Buffers should remain thickly vegetated and not transformed into lawns.
  
  
• The remapping of Westchester and Putnam County wetlands will require DEC trained staff to enforce the new regulations. Additional staff should be hired as needed.
  

Wetlands Mitigation

• We recommend that until the science of wetlands mitigation progresses well beyond the current “hit-or miss” stage, no mitigation be acceptable as a substitute for wetland destruction. At the very least, the presently accepted 5-year monitoring limit should be extended over the entire lifetime of the mitigation wetland.
  

Forests

• Not a single tree should be cut down in Putnam County’s Nimham Forest until DEC can prove that its forest management proposal will improve water quality in the West Branch Reservoir, as claimed.
  
  
• Fishing, hiking, camping, hunting, cross-country skiing, and horseback riding are recreational activities that already bring revenue to the watershed counties. These sources will disappear if the forests are scarred with tree stumps and the streams are choked with sediment from runoff. The recreational value of preserving the watershed forests should be promoted by DEP as a source of income that easily surpasses the income from logging. At the same time, DEP should educate the public, the local municipalities and the county governments on the irreplaceable value of forests in protecting water quality.
  
  
• Town planners should be encouraged and helped to incorporate strong tree protection laws into their town codes.
  

Groundwater and Stream Contamination by Pharmaceuticals
and Road Salt

• DEP should hasten the upgrades of the remaining WWTPs that, so far, have not been upgraded, to microfiltration. DEP should also institute a septic upgrade program for the Croton, similar to its successful septic upgrade program for the Catskill/Delaware watershed.
  
  
• DEP should partner with local Conservation Advisory Boards and Garden Clubs to instruct watershed residents on alternative methods of landscaping their property without the use of, or at the very least – minimum use, of pesticides, herbicides and fungicides.
  
  
• We urge the county, state and federal Departments of Transportation to reduce their excessive use of road salt. New technologies such as infrared equipment, give truck operators an estimate of road temperature and a better estimate on the amount of salt that is needed. In areas contiguous to drinking water reservoirs, more environmentally benign products such as KA and CMA should be used.
  
  
• Groundwater resources should be mapped throughout the watershed, and water budgets prepared. In areas that are largely dependent on groundwater to supply their needs, local municipalities, with the help of DEC, should inventory this resource, should inventory this resource, and development kept within the available groundwater limits. Recharge areas should be kept free of impervious surfaces.
  

Waterfowl Management Program

• DEP should extend to all Croton Watershed reservoirs that need it, an effective program to protect them from waterfowl pollution.
  

Wastewater Treatment Plant Upgrades or Diversion

• We recommend that a non-segmented, comprehensive study of the effects of upgrades and/or diversion on Westchester County’s environment, development patterns, demographics and economy be carried out prior to deciding which path to follow: diversion or upgrades of WWTPs and individual septics.