Re: Croton Watershed Filtration Plant

Dear Administrator Whitman:

The consent decree entered into by the Environmental Protection Agency with respect to the Croton Water Supply System should be renegotiated. Improvements in the protection of the watershed and advances in science since the entry of the consent decree mandate a reexamination of how best to deliver water to the nine million people in New York City and Westchester affected by the decree.

The proposed filtration plant is estimated to cost 650-700 million dollars to build and approximately $100 million annually to operate. The construction of a filtration plant for the Croton water supply, because of its linkage to the Catskill-Delaware water supplies, is likely to necessitate the construction of a filtration plant for those water systems as well at an estimated additional cost of over $5 billion and an additional annual maintenance cost of hundreds of millions of dollars. The US EPA should not require the incursion of costs in that order of magnitude unless still mandated by public health concerns. Such sums, if not necessary to maintain water quality, are better spent on sorely needed sewer and water infrastructure, distribution system repairs in New York City and on watershed protection.

Since 1998 developments have undercut the basis for the US EPA's position in entering into the consent decree:
· regulations for wetlands and watershed protection in the New York City watersheds have become more stringent thereby improving the natural filtration process;
· several communities in the Croton watershed have passed open space referenda to effect acquisition of open space for preservation in the watershed thereby reducing real estate development pressures;
· the siting of septic tanks on slopes of greater than 15% is no longer permitted which in effect preserves much of the hilly terrain in the watershed from real estate development;
· storm water management is being improved due to new federal regulations and specific local action plans;
· scientific alternatives have been proposed to address seasonal quality concerns of the Croton reservoir water; these alternatives, if adopted would cost a pittance as compared to the proposed chemical filtration plant;
· the extreme difficulties associated with siting a filtration plant in an area as densely populated as the New York City metropolitan area, as highlighted by the New York Court of Appeals recent decision requiring parkland alienation before the site selected by the city could be utilized, suggest that alternatives to filtration which protect public safety must be revisited ; people should not be unnecessarily subjected to huge chemical plants in their "backyards";

New York has been fortunate in having high quality unfiltered water, regarded by many as the "champagne of waters" for all these years because of its magnificent watersheds. We ask that the EPA not require the chemical treatment of these waters through a filtration plant at a potential cost of many billions of dollars without a reexamination of changed circumstances and science. Protected watersheds are natural and proven barriers not subject to the human error necessarily associated with any manmade protection. Since 1998 mechanisms have been put in place to protect those watersheds and scientific solutions have been presented to cure any existing water quality problems without filtration. New York City rate payers water bills will shoot up astronomically with filtration. We owe it to future generations to reconsider and renegotiate the consent decree lest we leave them to inherit an earth with irretrievably decimated and irreplaceable watersheds.

We would like to congratulate you on your appointment as Administrator of the EPA and thank you for your consideration. We would be happy to sit down and discuss this matter and answer any questions you may have.

Sincerely yours,

Edna Sussman
Executive Director