Bronx Council for Environmental Quality

01.04.19 BCEQ Comments to NYSDEC on NYCDEP extension request to March 31, 2020

Here are our comments on the New York City Department of Environmental Protection (DEP) request for a modification to the New York State Department of Environmental Conservation on the milestone to submit an approvable Citywide/Open Waters Long Term Control Plan (Citywide LTCP) from December 31, 2018 to March 31, 2020.  (DEC Case #CO2-20110512-25 modiying #CO2-20000107-8O). The continued delay of this plan has had and will continue to have a major impact on the Bronx.  The first step and easiest method toward an effective participatory community based planny process is to reinstate the Citywide CAC on a monthy basis.

Our history of comment on the Open Waters plan is long and extensive.  In 2016[1] we wrote that we needed a separate written Harlem River – Wards Island Watershed – Waterbody study and plan, including a timetable for agreed upon green infrastructure.  By 2018, we refined our needs[2] and added some of the following points to the 2016 letter:  100% Green Infrastructure as the “Preferred Alternative”; fund maintenance for GI projects in the build contracts; provide a separate Bronx Harlem/Hudson River LTCP timetable for completion in 2021 or within a five-year planning period; hold other alternatives and the method of comparing and evaluating each; and adopt new design criteria based on measurable goals to encourage and provide incentives for zero discharge of runoff to the local pipe, above and beyond the requirements of the law and regulations.  We also urged the Daylighting of Tibbetts Brook in and around Van Cortlandt Park, and Brook Park in Mott Haven.  We are a member of and support the 11-8-2018 SWIM letter.[3]

In addition, we have worked toward identifying the projects that the DEP could use to solve the problem of CSO pollution in Bronx waterbodies.  This will enable the DEP to capture runoff in some of the highest catchment areas and outfalls of the city in the Harlem River.  The list includes the Daylighting of Tibbetts Brook in Van Cortlandt Park, the Brook Park Created Wetland from adjacent homes roof runoff, the Amalgamated Hilltop Project[1] including the conversion of DEP property into a Rain Garden Open Space, the Riverdale Neighborhood House GI playground, and the Living Shoreline proposals for Van Cortlandt Park, the Harlem River and Westchester Creek.  DEP commitment to projects such as these is essential to the effectiveness of the LTCP as they provide quick and measured easy results indicating a movement toward zero discharge of stormwater. In that way, the City would have better estimates of the treatment train as it would be released from capturing storm events.  READ FULL LETTER FOR MORE BCEQ Letter to DEC on DEP 2018 Extension Request 01.04.2019

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[1] Hilltop Plan GI Neighborhood Concept Plan can be viewed at: http://bit.ly/2rUDflk

[1] http://www.bceq.org/wp-content/uploads/2016/11/BCEQ-Harlem-River-LTCP-2017-v3-Signed-10.20.pdf

[2] http://www.bceq.org/wp-content/uploads/2018/01/Long-term-control-plan-for-the-Bronx-Harlem-Hudson-River-Jan-2018-FINAL.pdf

[3] https://drive.google.com/file/d/1P8Jc2-B7SKSWLJC2vhed35gT9wt2t3mi/view

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