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NYC Watershed: Policy Formulation
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Nationwide Permits and 401 Water Quality Certification

Safeguarding wetlands and water resources is a key element of watershed protection and critical to New York City's successful renewal of Filtration Avoidance Determination (FAD) approved by the U.S. Environmental Protection Agency’s . Wetlands naturally purify water by filtering out sediments, detoxifying harmful chemicals, and processing nutrients that can cause algae blooms in reservoirs. Even the smallest marsh or bog has a beneficial impact on the water supply. Any diminution of the beneficial cumulative effects of these wetlands and water resources can degrade the quality of drinking water for over half of New York State. Further degradation of water quality could lead to loss of the FAD and an require construction of estimated $10 billion filtration plant with operations costs at $1 million per day.

Requiring Individual Permits (as opposed to general Nationwide Permits) from the U.S. Army Corps of Engineers (ACOE) for wetlands and water resource-related projects would affect only a minimal amount of economic activity, while having a significant impact on watershed protection. Under these circumstances, a requirement for Individual Permits would hardly stifle economic development in the watershed.

Action Required

Heightened protections have already apply in the East-of-Hudson Watershed, but action must be taken to ensure that the same protections apply in the West-of-Hudson Watershed. Several actions are needed to achieve heightened protections in the West-of-Hudson Watershed and ensure more stringent permit review by ACOE.

1) Governor Paterson should issue an Executive Order designating the West-of-Hudson portion of the New York City water supply as “Critical Resource Waters.”

2) ACOE's New York District should make a Critical Resourse Waters designation for the West-of-Hudson Watershed as a regional condition to the Nationwide Permit Program.

3) New York should deny Section 401 Water Quality Certification to ACOE's March 2007 Nationwide Permits.

To learn more about the importance of the Critical Resource Waters designation, click here.


 
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