REMARKS
Explanation of Filtration Avoidance Determination requirements and challenges
0:04:21
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5 min
Council Member Gennaro provides a detailed explanation of the Filtration Avoidance Determination (FAD) requirements and the challenges involved in maintaining it. He emphasizes the rarity and importance of the FAD for New York City's water supply.
- The FAD requires DEP to meet stringent water quality standards to avoid filtration
- NYC's FAD is unique due to the large population living in the watershed
- The EPA initially had reservations about granting the FAD to NYC
- Maintaining the FAD requires ongoing efforts in watershed protection and water quality control
- Losing the FAD would necessitate building a costly filtration plant
James F. Gennaro
0:04:21
Because the water supply is derived from so called surface waters, meaning from reservoir waters fed from river streams and precipitation, federal law requires DEP to either filter the water prior to delivery to the end user or meet objective and stringent water quality standards such that filtration is unnecessary.
0:04:44
I think it's appropriate for me here to mention that.
0:04:49
It's very rare for a watershed that you you for for for a surface water, you know, watershed, not to have to abide by the surface water treatment rule of the Safewater Drinking Act, which requires that all watersheds that use surface water be filtered.
0:05:11
And when that rule was first put into effect, there was no such a thing as a filtration avoidance determination.
0:05:18
There was no provision in the rule to get 1.
0:05:20
If he used surface water, he had to filter.
0:05:23
And it was the EPA administrator under Bush 41, who was on his way out of office.
0:05:31
I think his name was Riley, who thought it'd be a good idea for those watersheds that were completely pristine not to be burden, you know, like, you know, not to have the regulatory burden of having to put up a filtration point when they didn't need 1.
0:05:48
And and, you know, so many watersheds, you know, try to apply for a filtration for a filtration for a fad and are turned down, and there are precious few that actually have that.
0:06:01
We'll hear that in the testimony of the EP.
0:06:05
And, you know, New York City was a real challenge in that we have I mean, The number that was thrown around 30 years ago is 50,000 people living in the watershed.
0:06:14
I don't know what the number is now.
0:06:16
We have scores of sewage treatment plant that discharge and the EPA you know, had some trepidation about even considering to give us a fad.
0:06:29
And this is all this is this is kind of like old guy in law here if when I you know, like, when you know stuff, you wanna shared with younger generations.
0:06:40
So the EPA did a smart thing.
0:06:42
They empanel a blue ribbon panel of 10 watershed experts from around the country, and they deliberated for a while, they're all kinds of analysis, and they came back with unanimous report that or the analyst conclusion that New York City, that that the EPA should not even entertain the notion of giving, you know, New York City a fad.
0:07:09
And so EPA, with that in hand, went to New York City and said, you know, we're gonna make some history here.
0:07:16
We got a lot of people living in this watershed.
0:07:18
We got We've got this panel of experts.
0:07:21
Every single one says we shouldn't even be entertaining this, but we're gonna jump you through all kinds of hoops to make you do all kinds of investments, do land acquisition of farm program, new water rules that hadn't been, you know, updated since 1953.
0:07:36
And we're gonna try to make some history here while at the same time putting the EP on a track of building a water filtration plant just in case this this this This process didn't work out for maintaining the fan.
0:07:50
And the EPA was so interested in this that ordinarily the EPA devolves primacy over, you know, the day to day upgraded the Fed to the state health department.
0:08:01
But in this case, the the EPA itself held on to primacy itself for 10 years, which it rarely does.
0:08:08
And so it's good for people to know that we made a lot of history and, you know, a lot of good people came together to, you know, make this happen.
0:08:17
It's just very, very difficult to get and even harder to maintain.
0:08:20
And I think a lot of credit goes to DEP, as I said, for doing this day to day.
0:08:26
Upholding of the fad.
0:08:28
Now the fad police are like the New York State Department of Health.
0:08:33
And so so as they say now, you know, where was I before I get wrapped up in my own rhetoric here, filter the water prior to deliver the end meter.
0:08:46
Okay.
0:08:46
Fine.
0:08:49
Specifically, you know, having a fad, this means that DEP must maintain adequate disinfection systems and want more should control programs, keep concentrations of turbidity, which is kind of a fancy way of saying sediment.
0:09:04
And there are things that you don't want in water that can attach to these particles And so we have to, you know, keep our concentrations of turbidity low, blow certain thresholds, and meet other requirements, or risk losing our filtration avoidance and termination, the fad.
0:09:23
The fad came, if things happen, it can go away, and then we have no other option than to build the filtration of did than to build a filtration plant, which at the time was estimated 30 years ago to be 6 $8,000,000,000, who knows what it would cost today.
0:09:40
I look forward to hearing from the DEP about the good work they are doing to safeguard our drinking water supply and maintain the status of our fad.
