Great Bay Estuary Draft NPDES Permit

On January 8, 2020, EPA Region I issued the Draft Great Bay Total Nitrogen General Permit (Draft GP) for thirteen wastewater treatment facilities (WWTFs) located in twelve communities that discharge treated wastewater containing nitrogen within the Great Bay Estuary (GBE) watershed; Rochester is one of those communities.  According to EPA, proposed Draft GP nitrogen reductions are in response to concerns regarding loss of eelgrass in GBE.  The City of Rochester has serious concerns about the scientific basis, legality, and potential financial impact of the Draft GP, as more thoroughly expressed in the May 2020 comments submitted to EPA Region 1 (see attached documents).

The City of Rochester is committed to doing its part to ensure a healthy Great Bay Estuary.  Since 2014, the City’s WWTF has implemented optimization efforts to reduce the amount of total nitrogen (TN) in its effluent, resulting in a decrease of more than 70% compared to prior levels.  Rochester continues to invest in optimization of TN treatment, as evidenced by a $3 million capital improvement project in 2020 to construct a Chemical Storage and Feed Building at the WWTF.  Rochester anticipates even lower TN levels from its WWTF in the near future; however, the Draft GP as proposed will require significant upgrades to the WWTF pushing Rochester to upgrade to the current limits of technology.  Therefore, Rochester, and many other commenters, have requested an independent peer review of the Draft GP.  Before Rochester makes further significant investments in its WWTF, and puts further financial stress on its rate payers, questions regarding the scientific basis of the Draft GP need to be answered.