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AGENCY TESTIMONY
MS4 areas and challenges in implementing green infrastructure
0:28:20
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3 min
Deputy Commissioner Licata addresses the challenges of implementing green infrastructure in Municipal Separate Storm Sewer System (MS4) areas, as proposed in Intro 1254. The bill would require DEP to install 2,400 greened acres in MS4 areas by 2035, but the department has concerns about this mandate.
- DEP believes that the 'greened acre' metric is not the best indicator of progress for green infrastructure programs.
- Green infrastructure may not be the most effective tool for stormwater management in all MS4 areas due to factors like high groundwater tables.
- The bill's mandate may not be achievable given the limited time frame and available space in MS4 areas, which make up only about 40% of the city.
Angela Licata
0:28:20
The second bill is Intro twelve fifty four, which would require DEP to install 2,400 greened acres in the MS 4, or the municipal separated storm sewer areas, by 02/1935.
0:28:37
As we discussed with your staff last week, we are fully committed to expanding GI across the city, but we believe that the green to acre metric is not the best indicator of progress.
0:28:51
As a quick background for those listening, MS4 oh, I said that already.
0:28:56
In this system, separate pipes carry wastewater and stormwater as opposed to the combined sewer area where the wastewater and stormwater are in one pipe.
0:29:08
So as the chair said earlier, 60% of the city has combined sewers and about 40% are MS4 areas or direct drainage.
0:29:22
Our first concern for greened acres is that we no longer rely on that as an indicator for our GI program with New York State DEC.
0:29:34
At one point in the program when it began in 2012, there was a greened acre target, but we have since realized that it's not a good metric because of the concept of green acres does not fully capture what the green infrastructure does.
0:29:52
We continue to report greened acres, however, in our New York City Greened Infrastructure Annual Report, and we brought a few extra copies of the Greened Infrastructure Annual Report, which was just released on April 30.
0:30:09
Another concern is that we don't know if GI is the best tool to address stormwater management and water quality needs in all of the MS 4 areas.
0:30:18
As I have described today, DEP has developed a suite of tools because different tools are best suited for different goals and for different areas of the city.
0:30:27
Mandating a fixed amount of green to acres could be counterproductive because it could require us to install GI where it's not going to be effective.
0:30:37
Finally, the bill's mandate may not be achievable.
0:30:41
For the past thirteen years, we have been installing GI across combined sewer areas.
0:30:46
With our 16,000 assets, we have just reached 2,800 greened acres.
0:30:54
The bill requires nearly the same amount of greened acres to be installed in the MS four areas over the next ten years.
0:31:01
There may simply not be enough time or enough space in the MS 4 areas to accomplish that.
0:31:08
A minority of the city is MS 4, as we stated, and GISI is not appropriate for much of that area.
0:31:16
For example, we know that many areas with separated sewers in the city like Southeast Queens have high groundwater tables, which makes them ineligible for green infrastructure.
0:31:27
We share the council's goals of expanding stormwater management infrastructure through the MS4 areas, and we appreciate the council's continuous support of our efforts.
0:31:36
We have already started installing GI in strategic MS4 areas such as schoolyards and street medians with partners like DOT, DOE, and the Trust for Public Land.
0:31:47
As council is aware, it is important to remember that while green infrastructure provides many community benefits, the goal of the program is not simply to green the city.
0:31:56
These are engineered systems that are built to enhance the way the city manages stormwater by reducing CSOs, improving water quality, and reducing flooding where possible.
0:32:06
Thank you again to the council, to the committee and Chair Gennaro for your continued support of nature based solutions for stormwater management and other challenges.
0:32:15
My colleagues and I are now happy to answer any questions that you may have.