LRWP comments on NJDEP Integrated Report

The LRWP submitted the letter below in response to NJDEP request for public comment on the proposed 2016 303(d) List of Water Quality Limited Waters, including the Lower Raritan, South River and Lawrence Brook Watersheds (WMA9). This “Integrated Report” is prepared pursuant to Section 305(b) of the Federal Clean Water Act to meet requirements to biennially prepare and submit to the USEPA a reporting addressing the overall water quality of the State’s waters, including support of designated uses.

October 16, 2019

TO: Jack Pflaumer, Environmental Scientist 1 / New Jersey Department of Environmental Protection

RE:         DRAFT 2016 New Jersey Integrated Water Quality Assessment Report for the Raritan Water Region

Dear Mr. Pflaumer –

The Lower Raritan Watershed Partnership (LRWP) is New Jersey’s newest watershed association, representing the state’s Lower Raritan Watershed. Partners include county, municipal and academic entities, as well as community garden, environmental, fishing, boating, student, business, service and other community interests. Our mission is to restore, enhance, and conserve, the natural resources of New Jersey Watershed Management Area 9 through science-based stewardship, education and innovation.

The LRWP appreciates the NJDEP’s basin-wide approach to pollutant modeling in the 2016 Integrated Report for the Raritan Water Region, and likewise appreciates the attention it gives to upstream impacts which affect the entire Raritan Basin. However, we feel the NJDEP approach falls short in significant ways. We have a number of specific concerns:

  1. NJDEP fails to include Watershed Management Areas 7 and 9 in the 2016 Total Maximum Daily Load Report addressing Total Phosphorus, Dissolved Oxygen, pH and Total Suspended Solids impairments.

We understand that the 2016 TMDL Report is a study of non-tidal waters. However, no justification for focusing solely on non-tidal waters at the exclusion of WMA9 and WMA7 – a significant portion of the Raritan Basin – is provided. Furthermore, aside from brief mention of the need for watershed based plans (pp 64-65) there is no indication in the 2016 Integrated Report of when TP, DO, pH and TSS pollutant reduction planning will begin for the tidal and adjacent watershed areas of the Raritan Basin, or how this might proceed

2.The 2016 Integrated Report presents an inadequate assessment of pathogens (enterococcus) in our Lower Raritan waters.

In fact, we do not see evidence in the report or appendices that the Lower Raritan River waters have ever been formally monitored for enterococcus. Without adequate analysis and reporting of pathogens in the SE1 waters of the estuary, including the inland portion of the Raritan River, the quality of the state’s waters is overstated on page 29 of the report: “A net zero change in Enterococcus listings reflects the continued excellent recreational water quality in New Jersey’s ocean waters, as well as stable conditions in the bays and estuaries.”

3. Page 32 of the 2016 Integrated Report fails to include Monmouth County as a constituent of the Raritan Water Region.

It is critical that NJDEP includes all portions of the Raritan Basin, including the tidal and associated watershed areas of WMA9 and WMA7, in comprehensive water quality planning. Failure to include areas of WMA9 and WMA7 in water quality analyses, in TMDL development for pollutants like TP, DO, pH and TSS and enterococcus, and in watershed based planning efforts, significantly compromises water protection in areas where the majority of the Basin’s population reside.

Failure of NJDEP to include all portions of the Raritan Basin in these analysis and planning activities has repercussions. Federal funding for conservation and restoration of our waterways and watersheds is prioritized based on planning and implementation of projects that address water quality impairment through implementation of NPS pollution controls, including those specifically identified in approved TMDL implementation. NJDEP’s failure to ensure that areas like WMA9 and WMA7 that do not have TMDLs or watershed based plans puts these areas at tremendous disadvantage in seeking federal funds to protect our local waters and watersheds.

The LRWP requests a meeting with NJDEP to discuss the above, and to develop a strategic plan for prioritized approaches for pollutant management in the tidal portions and other overlooked areas of the Raritan Basin. Please contact me at your earliest convenience.

Sincerely,

Heather Fenyk, Ph.D., AICP/PP

President and Founder, Lower Raritan Watershed Partnership



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