As NYS DEC approves many of NYC DEP’s CSO ( Combined Sewer Overflow ) Long Term Control Plans, one remains in limbo: the Coney Island Creek LTCP. There have been multiple correspondences between NYC Department of Environmental Protection (DEP) and the New York State Department of Environmental Conservation (DEC) since DEP submitted their proposed plan to DEC in June 2016, but none of them have been published on DEP’s website and were only obtained by requesting them directly from DEP. The correspondence between DEP and DEC reveals important water quality nuances that SWIM and other advocacy organizations have been calling attention to for years.
The Coney Island Creek LTCP proposes no new grey infrastructure to further reduce CSO volume that discharges into the Creek. The LTCP states that the recent upgrades to the Avenue U Pumping Station (from the Waterbody/Watershed Facility Plan in 2009) have significantly reduced CSO into Coney Island Creek, and further efforts to reduce the volume would not improve water quality in the Creek because of the pollutants that enter the Creek from “other sources.” Thus, DEP’s only proposal is to install green infrastructure in the CSO drainage area to manage stormwater runoff in a mere one percent of the impervious area (much smaller than the citywide goal of 10% impervious area managed).
In the response to the City’s LTCP submission, DEC questions DEP’s water quality results. DEP has been finding very high rates of Fecal Coliform to Enterococcus bacteria in their water quality sampling*. The usual ratio of Fecal Coliform bacteria to Enterococcus is about 10:1. In Coney Island Creek sampling, DEP has been reporting ratios on the scale of 500:1! While the letters indicate the cause in this extreme ratio is unclear, DEP seems to indicate that Fecal Coliform bacteria is regrowing in the sediment of some of the shallow, stagnant waters like those at the head of Coney Island Creek. These patterns have also been recorded in water quality results for Bergen Basin and Newtown Creek - other shallow, low-flow waterways - and present significant risks to public health for the citizens who use these waterways for boating, fishing, wading, and religious and educational purposes.
The above water quality testing scenarios present the City and State with an opportunity to reassess their water quality standards (which are outdated and supposed to have been updated in 2015 according to federal mandate), and update to the Federal Clean Water Act Standards, using Enterococcus as the sewage indicating bacteria over Fecal Coliform.
*Reminder, both Fecal Coliform and Enterococcus are fecal-indicating bacteria. For years, SWIM has been advocating for DEC to upgrade its water quality standards to match the EPA’s standard to use Enterococcus over Fecal Coliform. Enterococcus bacteria are more able to survive in saltwater, and more scientifically accepted as an indicator of sewage pollution in coastal recreational waterways.
Here is a recent article about the state of affairs in the creek.
Photo Credit: NYCEDC