Action Alerts

Nov 20, 2011: PENDING PESTICIDES PERMIT

The application of pesticides directly into surface water is highly problematic and, in the view of many, too lightly regulated. Two years ago, the Sixth District Court agreed. The court ruled that applications of pesticides into water count as point-source discharges and must be regulated under the National Pollutant Discharge Elimination System (NPDES) permit program. This requirement also covers aerial spraying of pesticides over forests. As a result, the EPA and states are required to write NPDES permits for application of pesticides to waters.

A proposed general permit for Connecticut is pending. It will be superimposed on the existing permit program. IT IS VITALLY IMPORTANT TO GET THIS RIGHT. The proposed permit appears to be weaker in some respects than the federal general permit. DEEP has requested that, if we are considering asking for a public hearing, we give them a chance to meet with concerned people first.

IF YOU WOULD LIKE TO LEARN MORE ABOUT THIS PESTICIDES PERMIT, PLEASE CONTACT RIVERS ALLIANCE. Call 860-361-9349, or write to rivers@riversalliance.org

Here is the notice from the DEEP, with a link to their website. Notice of tentative determination to issue the General Permit for Point Source Discharges to the Waters of the State from the Application of Pesticides. To view this public notice, please visit  www.ct.gov/dep/cwp/view.asp?a=2586&Q=490672&depNav_GID=1511

Here is link to the EPA website explaining the general permit they have issued.  http://cfpub.epa.gov/npdes/home.cfm?program_id=410

----- ARCHIVED OLDER ALERTS ----

Stormwater Hearing

Subject: DEP's official report on water

Hello, Water Watchers:  The DEP is asking for comments on its 2011 official report to Congress, which must be submitted every three years under the Clean Water Act. The deadline is May 11 2011, but if you need more time, please request it. (The informational meeting was May 5. The release date was April11.) 

DEP's page describing the report is at  http://www.ct.gov/dep/iwqr, or click here to go to the Report itself.  The summary is copied below for your convenience, followed by a copy of the summary table.

The name of the document is the Integrated Water Quality Report. It combines the so-called 305(b) list and the 303(d) list. The latter is also called the "impaired waters" list. The numbers refer to sections of the Clean Water Act.

It is important to ask for corrections if you see errors, especially if you think your favorite water body is misclassfied. Note, that an "impaired designation" is supposed to lead eventually to a clean-up plan, often called a TMDL (for "total maxmum daily load"). If your stream or lake has problems, and has not been assessed, ask for an assessment. (We can help if you do not know how to get started.)

One way to deal with this huge document is to look at some of the summaries and the water quality criteria. I noticed, for example, that lakes are shown as amazingly clean, which does not accord with observations. Probably high-quality reservoirs are included here -- anyway I am going to ask for clarification.

If you are interested in, say, just one river, type the name of the river in Find, and you should be taken from section to section for all the information on that river. (Keep punching Next.)

Some of the most interesting sections are at the end. You will see them in the Table Contents. My favorites are:

Table 3-2. Connecticut Impaired Waters List ......................................................................................... 207
Table 3-3. Waterbodies with Adopted TMDLs (Category 4a) ................................................................ 365
Table 3-4. Pollution Control Measures for Category 4b Waterbody Segments ...................................... 373
Table 3-5. Nonpollutant Impairments (Category 4c) ............................................................................... 378
Table 3-6. Reconciliation List ................................................................................................................. 382
Table 3-7. Waterbodies Removed from Connecticut's Impaired Waters List ......................................... 393

Note "Nonpollutant Impairments" is a kind of do-nothing category of problems that are tricky to handle with a TMDL or simply deemed too difficult to solve.

The Reconciliation List helps to track changes. Pollution Control Measures is eye-opening, a must-read.

Comments should go to erik.bedan@ct.gov.

If you have questions, we will try to help. The DEP page describing the the Report is at http://www.ct.gov/dep/iwqr 

Thanks, Margaret (Telephone numbers below)

Rivers Alliance of Connecticut
7 West Street, POB 1797
Litchfield, CT 06759
Tel: 860-361-9349 Fax: 860-361-9341 Cell: 203-788-5161 http://www.riversalliance.org/
Serving all the waters of Connecticut
Contacts: Margaret Miner, Rose Guimaraes

Summary
(from http://www.ct.gov/dep/lib/dep/water/water_quality_management/305b/draft_ct_integratedwaterqualityreport_2011.pdf#page=5 )

Water quality in Connecticut has improved over the last few decades as a result of protective laws, remediation efforts and a substantial investment in improved wastewater treatment. There are still gains to be made in these areas. The projected costs for necessary upgrades and improvements to municipal sewage infrastructure, exclusive of phosphorus needs, are estimated to be approximately $3.572 billion over the next 20 years (US EPA, 2010a and b). Additionally, further improvements are needed with respect to stormwater management and nonpoint source pollution control.

Many of the remaining causes of impairment of Connecticut surface waters are difficult to identify (e.g., “cause unknown”) and/or correct (e.g., CSOs, urban stormwater runoff). Future management efforts will need to focus not only on wastewater treatment, collection and infrastructure, but also on control and mitigation of nonpoint pollution sources and coordinated watershed efforts. Initiatives will require input from the numerous public and private interests that regulate and oversee land use management and environmental policy, especially at the local level.

The CT DEP has staff focused on increasing awareness of Low Impact Development (LID) techniques for reducing stormwater and nonpoint runoff. We are working with our partners at the federal, state and local levels to provide information, educational materials and technical assistance in the application of LID techniques, building on existing programs such as the Governor‟s Responsible Growth Initiative, the 3 University of Connecticut‟s Extension System NEMO program and US EPA‟s Smart Growth Program. The goal is to build better relationships and promote LID management practices with local land use agencies, academic institutions, nonprofit groups, the building industry and the public. Incorporating LID into land use plans can decrease impervious surfaces and limit runoff, leading to improved water quality and recharge of our rivers, streams and groundwater supplies.

All graphics on this page courtesy the CT DEP