DEEP: Phosphorus Reduction Strategy for Inland Non-tidal Waters

Phosphorus Reduction Strategy for Inland Non-Tidal Waters
In June 2009, the Connecticut Department of Energy and Environmental Protection (DEEP) proposed a strategy to address the need for a reduction in phosphorus loadings to non-tidal surface waters from municipal wastewater treatment plant discharges.  That strategy has been the topic of numerous discussions between DEEP, stakeholders, and U.S. EPA.  A strategy has been developed which will be revised as warranted, to address the concerns raised by those parties. 
A Coordinating Committee and three Workgroups was established to meet the PA 12-155 requirement that DEEP collaborate with municipalities to address the goals of the legislation.
Coordinating Committee
The Coordinating Committee has completed it's report to the Legislature which is available below:
Recommendations for Phosphorus Strategy Pursuant to PA 12-155 Final Report including Appendices, February 16, 2017. (NOTE: Appendix I: CT WQS must be downloaded separately).
The Coordinating Committee met quarterly to integrate and coordinate the activities of the three Workgroups, and address issues which cut across the scopes of the Workgroups.  The Committee will report to the State Legislature, and coordinate within DEEP to assure the recommendations address EPA's requirements. 
The fifth Coordinating Committee Meeting was held on February 20, 2015 at 1 p.m. in the Russell Room, on the third floor at CT DEEP Headquarters.
A meeting of the Workgroup co-chairs was held on November 18, 2014 at 10 a.m. at DEEP Headquarters. 
The fourth Coordinating Committee meeting was held on August 11, 2014, at 1 p.m. in the Russell Room, on the third floor at CT DEEP Headquarters.
A meeting of the Workgroup co-chairs was held on July 23, 2014, at 1 p.m. at Southington Town Hall.
The third Coordinating Committee meeting was held on May 12, 2014, at 1 p.m. in the Holcombe Room, on the fifth floor at CT DEEP Headquarters.
The second Coordinating Committee meeting was held on February 10, 2014 at 1 p.m. in the Phoenix Auditorium, on the fifth floor at CT DEEP Headquarters.  
The first Coordinating Committee Public Meeting was held on September 30, 2013 at DEEP Headquarters.  This Informational Presentation from the meeting includes:  a PA 12-155 Summary, DEEP's "Collaboration Commitment", Workgroups, and Next Steps.
The 9/30/2013 meeting broke into the three workgroups after discussion of the presentation.
Nonpoint Source (NPS) Phosphorus Workgroup #1
Propose statewide response to address phosphorus nonpoint source pollution of water. 
This Workgroup interfaced with and utilized the CT DEEP Nonpoint Source Management Program Plan Update for Public Involvement.  The DEEP NPS Management Program Plan Update conducted a Stakeholder public meeting on October 31, 2013 at 9:30 a.m. in DEEP's Phoenix Auditorium.
Meeting Schedule for the NPS Phosphorus Workgroup 
  • November 20, 2014, from 10 a.m. to 11:30 a.m., in Holcombe Room, 5th floor, DEEP Headquarters
  • October 7, 2014, from 1 to 2:30 p.m., Room 2B, DEEP Headquarters.
  • July 22, 2014, from 1 to 2:30 p.m., Holcombe Room, 5th floor, DEEP Headquarters.
  • May 6, 2014, from 1 to 2:30 p.m., Room 2B, DEEP Headquarters.
  • March 24, 2014, from 1 to 2:30 p.m., Room 2B, DEEP Headquarters.
  • February 10, 2014, from 10 to 11:30 a.m., Room 2B, DEEP Headquarters. 
  • January 6, 2014 from 1 to 2:30 p.m., Room 2A, DEEP Headquarters. 
  • November 25, 2013, from 1 to 2:30 p.m., Room 2B, DEEP Headquarters.
  • October 25, 2013 from 1 to 2:30 p.m., DEEP Holcombe Room.
Meeting Schedule for NPS Onsite Wastewater Systems Subcommittee
  • June 24, 2014, at 10 a.m., Room 2B, DEEP Headquarters
  • March 10, 2014, at 1 p.m., Room 2A, DEEP Headquarters
  • Friday January 17, 2014, 1 p.m., Room 2B, DEEP Headquarters
Meeting Notes for the NPS Phosphorus Workgroup
Scientific Methods Workgroup #2
Propose scientific methods to measure current phosphorus levels and to make future projections of phosphorus levels.
DEEP contracted with the Connecticut Academy of Science and Engineering (CASE) to conduct a Phosphorus Study:  Methods to Measure Phosphorus and Make Future Projections which has been reviewed and coordinated with the Scientific Methods Workgroup.
CASE gave the following presentation with details of their report at the February 20, 2015 Coordinating Committee meeting:  CASE Study Briefing for PA 12-155 Phosphorus Coordinating Committee 
Meeting Schedule for the Scientific Methods Workgroup
  • November 6, 2014, 1:30 to 3:30 p.m., room 2B, DEEP Headquarters
  • Thursday, September 11, 2014, 1-3 pm, Room 2B, DEEP Headquarters.
  • The meeting planned for June 24, 2014 was cancelled
  • Thursday May 22, 2014, 9:30 a.m. - noon in Room 2B, DEEP Headquarters
  • Thursday March 6, 2014, 1-3 p.m., Room 2B, DEEP Headquarters 
  • Thursday January 16, 2014, 1–4 p.m., (cancelled)
  • Thursday December 19, 2013, 1-4 p.m., 5th Floor Ensign Room, DEEP Headquarters
  • Thursday November 21, 2013, 9 a.m.–12 p.m., room 2B, DEEP Headquarters
  • October 31, 2013, 9 a.m. to 12 noon, room 4B, DEEP Headquarters
Meeting Notes for the Scientific Methods Workgroup
Municipal Implementation Workgroup #3
Propose approaches and guidance for municipalities to comply with DEEP Water Quality Standards based on EPA criteria for phosphorus.
Meeting Schedule for the Municipal Implementation Workgroup
  • Monthly meetings were scheduled on the second Tuesday of each month from 9:00 a.m. to 11:00 a.m. at DEEP Headquarters.
Meeting Notes for the Municipal Implementation Workgroup
Questions or Comments on DEEP's Phosphorus Reduction Strategy and PA 12-155 compliance process may be submitted by email to:
Supporting Information
Why is phosphorus a water quality concern?
Phosphorus is a naturally occurring element that is essential to support plant growth. When present in excessive amounts, phosphorus contributes to a process called “eutrophication” that can impair both aquatic life and recreational use of Connecticut’s water resources.  Eutrophication, or nutrient enrichment, is a serious threat to water quality in Connecticut. Excessive loading of phosphorus to surface waters as a result of discharges from industrial and municipal water pollution control facilities (WPCF) or nonpoint sources such as runoff from urban and agricultural lands, can lead to algal blooms, including blooms of noxious blue green algae, reduction in water clarity, and in extreme cases, depletion of oxygen, fish kills, and other impairments to aquatic life. Currently, 21 water body segments have been identified on Connecticut’s List of Waters Not Meeting Water Quality Standards, where nutrient enrichment is a contributing cause of the impairment. Other water bodies that are not currently listed may also be impacted by nutrient enrichment and could cross the threshold to impaired status if nutrient loads from point and nonpoint sources are not effectively managed.
Nutrient enrichment has also been identified as one of the most pressing water quality issues facing the nation as a whole. As a result, the Federal Environmental Protection Agency has increased pressure on all states to take aggressive action to limit the quantity of phosphorus being discharged to surface waters. In Region 1, EPA has mandated that all New England states establish limitations on phosphorus in all wastewater discharge permits where the potential exists for the discharge to contribute to eutrophication and impair designated uses in downstream waters.
How is the strategy different from the one presented in June 2009?
The revised strategy addresses concerns regarding the protection of aquatic life in rivers and streams.  The revised strategy uses best available science to identify phosphorus enrichment levels in waste receiving streams that adequately support aquatic life uses.  The methodology focuses on significant changes in stream algae as the key aquatic life response to excess phosphorus loading.  The methods used to develop this strategy were approved by the U.S. EPA in a letter dated October 26, 2010, as an interim strategy to establish water quality based phosphorus limits in non-tidal freshwaters for industrial and municipal WPCF's National Pollutant Discharge Elimination System (NPDES) permits until numeric nutrient criteria are established in Connecticut's Water Quality Standards (WQS).
Does the strategy cover non-waste receiving streams?
The strategy currently only covers waste receiving rivers and streams.  Ongoing work is currently being conducted to refine the approach through additional data collection and by expanding the methodology to include non-waste receiving streams.  It is expected that the ongoing work will lead to numeric nutrient criteria for all freshwater rivers and streams in the next WQS review cycle.
Additional Documentation and History of the Process
note: The criteria proposed in this document were not approved.
Public meetings were held regarding nonpoint source strategies (11/28/2012), and point source strategies (12/6/2012) for phosphorus controls in CT non-tidal waters. 
Comments on this process were submitted by email until January 11, 2013 to: 
Comments received by email and summaries from two PA 12-155 Public Meetings:
Written Comments Received from:
Greg Bollard, Friends of the Lake (Lillinonah)
Bart Clark Oakwood EA, #1, comments on NPS meeting
Jonathan Luiz, Columbia Town Administrator
Mike Ruef, Coventry WPCA
Elizabeth Gara, COST
David Day, Danbury DPUC
Lawrence Kendzior, Meriden City Manager
William Dickinson, Wallingford Mayor
Raymond Drew, Torrington WPCA
Kachina Walsh-Weaver, CT Conf. of Municipalities
Roger Reynolds, CT Fund for the Environment 
Vincent Susco, CT Assoc. of WPCAs

Fred Andes, CT Municipal Nutrient Group

Robert Lee, Plainville Town Manager 
Southington Delegation Legislators
2011 Phosphorus Strategy Documentation
Additional Information
Watershed Summary Fact Sheets
Nutrient Enrichment Analysis Watershed Overview  (PDF) Includes proposed phosphorus limits for Publicly Owned Treatment Works
Technical Documentation of Prior Proposals
EPA Documents
Content Last Updated on May 22, 2017