AGENCY TESTIMONY
Future challenges to maintaining the Filtration Avoidance Determination
0:38:42
·
4 min
The commissioner outlines future challenges to maintaining the FAD and emphasizes the need for the FAD to evolve based on emerging threats and scientific evidence.
- The FAD is not permanent and can be revoked if obligations are not met or water quality standards fail
- Climate change is increasing the frequency of intense storms, posing new challenges
- Increasing wildlife populations, particularly around the Kensico Reservoir, are a new source of potential contamination
- The FAD must evolve to address both historic and new threats
- DEP must plan for the possibility of full filtration in the future, even while seeking to avoid it
Rohit T Aggarwala
0:38:42
By being an esteemed presence in the watershed, we can ensure that there is long term support that will allow us to protect the fad for generations to come and for DEP to play a leading role in defining the future of the fad.
0:38:56
As successful as it is, the fad is not necessarily permanent.
0:38:59
It can be revoked on fairly short notice if we failed to fill our obligations or if our water quality fails to meet standards, even if those standards are caused by storms or other factors beyond our control.
0:39:11
There are only 6 water systems in the United States that have fats or their equivalents, and one of them, Portland, Oregon.
0:39:17
Recently lost their fat because of the detection of naturally occurring pathogens that had not been in their source water before and required filtration to eliminate.
0:39:26
EPA gave Portland only 10 years to build their treatment plant, which at 135,000,000 gallons a day is less than 110th the size of the plant we would need, and their filtration plant will cost roughly $2,000,000,000.
0:39:43
This cost and reinforces the fact that we have to be vigilant.
0:39:47
Also reminds us that the fad must be based on the science.
0:39:51
The fad has succeeded not because it was good environmental policy or good economic policy.
0:39:56
It has succeeded because it was sound water quality policy.
0:40:00
The scientific review by the national academy that I mentioned, found that our land acquisition program could use adjustment.
0:40:07
The region is divided into 4 areas.
0:40:10
Priority areas 1 through 4 based on their potential impact that based on their potential to impact water sources.
0:40:17
Most important are the lands bordering our reservoirs and their tributaries, and these are priority areas 1 and 2.
0:40:24
Further away, our lands in priority areas 3 and 4.
0:40:27
Until now, we have sought to acquire land in all of these areas.
0:40:31
But the National Academy found that continued purchases in areas 34 would have no more benefits to water quality, while land and priority areas 1 and 2 remain as important as ever, if not more so.
0:40:43
As a result, we recently altered our land acquisition practices to focus more on areas 1 and 2 and to end programmatic purchases in areas 3 and 4.
0:40:54
Going forward, we must continue to ensure that the FAD evolves as threat to water quality evolve.
0:41:00
Increasing water quality standards mean that there are limits to how much chlorine we can use to disinfect water after a major storm.
0:41:07
Climate change means that intense storms are more frequent.
0:41:11
While we have traditionally worried about human and agricultural contamination, the massive rebound in wildlife populations, particularly around the Kensiko reservoir, means that these are also now a source of potential contamination, especially after severe storms, and after the short term extreme droughts that climate change may be may bring.
0:41:31
And in fact, is bringing since we are in one right now.
0:41:35
The new fad in 2027 will continue to protect will need to continue protect to protect against historic threats.
0:41:42
And also guard against these new ones.
0:41:45
What is certain is that the fad will need to evolve.
0:41:48
If it does not, it is far more likely to fail.
0:41:52
And if it does not evolve based on the science, it will certainly fail.
0:41:56
This is one more reason that DEP must be an esteemed presence in the watershed and that we have to invest in our own research.
0:42:03
We need to ensure that DEP has the standing to play a leading role in defining the future of the fat.
0:42:09
We must also plan for the possibility of full filtration at some point in the future, even as we seek to avoid it.
0:42:16
The current FAD requires DEP to maintain contingency plans for filtration and the experience of Portland, again, given only 10 years to build its filtration plant demonstrates the importance of such contingency planning.
0:42:30
As I mentioned, the FAD has been a point of pride for DEP and the city for many decades.
0:42:35
It is a credit to our staff, to the many involved in creating it as the chairman so eloquently described, and to the generations of dedicated civil servants who preceded us, preceded us, and laid the groundwork for the system we managed today.
0:42:49
Before concluding, I'll take a few minutes to speak about each of the bills on today's agenda.
