University of New Hampshire CARSEY RESEARCH Carsey School of Public Policy Regional Issue Brief #47 Spring 2016 Clean Water for Less Integrated Planning Reduces the Cost of Meeting Water Quality Goals in New Hampshire Alison Watts, Robert Roseen, Paul E. Stacey, Renee Bourdeau, and Theresa Walker Summary Rising populations and increased development in New Hampshire coastal communities have led to a decline in water quality in the Great Bay Estuary. Responding effectively and affordably to new federal permit requirements for treating and discharging stormwater and wastewater will require innovative solutions from communities in the area. In March 2015, the Water Integration for Squamscott–Exeter (WISE) project completed an integrated planning framework through which the coastal communities of Exeter, Stratham, and Newfields could more afford- ably manage permits for wastewater and stormwa- ter. However, meeting maximum goals for nitrogen reduction will require collaboration and commitment from all municipalities in the watershed, whether regulated under the Clean Water Act or not. Introduction The New Hampshire Great Bay Estuary and portions surface water, require nitrogen controls as low as 3 mil- of the tidal rivers that flow into it have been negatively ligrams per liter (mg/l)—the lowest technically feasible impacted by human development. The Piscataqua level—on effluent from wastewater treatment plants.2 Region Estuaries Partnership has identified caution- Municipalities, EPA regulators, and community stake- ary or negative conditions or trends in fifteen of holders are now discussing strategies that would allow twenty-two indicators of ecosystem health.1 In 2009 communities flexibility to integrate permit requirements many parts of the estuary were listed as “impaired” by between wastewater and stormwater, and/or combine the New Hampshire Department of Environmental requirements among multiple permit holders in order to Services (NHDES) on measures such as nitrogen over- devise control options that might be more cost-effective. enrichment. Though nitrogen is naturally present in The enactment of the Clean Water Act (CWA) in estuarine water, excess amounts support algae growth, 1972, with its ambitious goals to restore the chemi- decrease oxygen, and ultimately damage aquatic spe- cal, physical, and biological integrity of U.S. surface cies. Permits now issued by the U.S. Environmental waters and to eliminate pollutant discharges by 1985, Protection Agency (EPA), which regulates discharges to led to dramatic improvements in water quality, as 2 CARSEY SCHOOL OF PUBLIC POLICY wastewater and industrial dis- FIGURE 1. THE EXETER–SQUAMSCOTT WATERSHED charges were treated or eliminated. These “point sources” (discharges from a single location, such as a pipe) are now largely regulated through permits that restrict pollutants based on the condi- tion of the receiving water body. However, nonpoint sources, such as agricultural runoff, groundwa- ter, atmospheric deposition, and diffuse runoff from the land are not generally restricted under the Clean Water Act. The regulation of sources generated by multiple parties is difficult, and federal and state agencies are currently working to develop more effec- tive and pragmatic approaches. These include integration among permits, individual or regional watershed-based permitting, and the expansion of regulatory author- ity to control nonpoint sources. All of these methods are potentially applicable to the Great Bay region. How Integrated Planning Works Existing wastewater treatment facilities (WWTFs) in the Great Bay region currently operate under discharge permits which set effluent limits on harmful Note: The communities of Exeter, Stratham, and Newfields border the Exeter–Squamscott River. pollutants. Many communities Municipal discharges to the river must comply with stringent nitrogen wastewater discharge permits. in the region must also address Source: From: The Lower Exeter and Squamscott Rivers, A Report to the General Court New Hamp- the discharge of urban stormwa- shire Rivers Management and Protection Program, Department of Environmental Services Office of the ter under a municipal separate Commissioner, Febrary 2011. storm sewer system (MS4) permit. Nonregulated discharges, such as Integrated planning and inte- narrows the options for more stormwater outside of urban areas, grated permitting allow munici- cost-efficient approaches to water are addressed only voluntarily, palities to meet multiple permit management.3 Consequently, if at all, and may be a significant requirements under an overarch- the EPA has become receptive to source of pollution. The MS4 ing structure that may encompass municipal proposals for integrated permits are not connected to the several municipalities or private plans that allow local officials to wastewater treatment permits, and parties (see Box 1). The EPA rec- prioritize actions across multiple historically little coordination has ognizes that meeting the goals of permits. Recently issued WWTF occurred between the programs. water-related permits individually permits to the towns of Exeter CARSEY SCHOOL OF PUBLIC POLICY 3 and Newmarket in southern New The Exeter–Squamscott Box 1: Definitions Hampshire include provisions that Watershed allow nitrogen reductions from Integrated Planning—Individual both regulated and nonregulated The Exeter River, in southeastern permits are issued, but permit stormwater and nonpoint sources New Hampshire, runs approximately requirements are combined under to be used to meet permit limits. 30 miles from the town of Chester to a local agreement, such as a memo- The communities are still required the Great Dam in downtown Exeter. randum of understanding. to upgrade their wastewater facili- Below the dam the river is renamed ties, but they may, for example, be the Squamscott, and forms part of the Integrated Permitting—A single able to avoid some costs associated Great Bay tidal estuary (Figure 1). permit combines obligations with reducing nitrogen levels in The watershed encompasses from multiple permits. The per- wastewater by reducing nitrogen 80,000 acres and includes portions mittees are mutually obligated to levels in stormwater. Additional of thirteen municipalities. The lower meet requirements. For instance, cost savings could derive from Exeter–Squamscott River subwater- stormwater and wastewater obli- a regional approach that meets shed, which includes the communities gations for one or more commu- targeted reductions by prioritizing of Exeter, Stratham, and Newfields, nities could be combined. lower-cost treatments across encompasses 19,000 acres—24 per- Watershed-Based Permitting—A a larger landscape. cent of the total—but generates nearly single permit is issued to all of the 50 percent of the nitrogen released to entities within a watershed region. the river (Figure 2). FIGURE 2. SOURCES OF NITROGEN IN THE SUBWATERSHED Note: Exeter, Stratham, and Newfields generate approximately 50% of the nitrogen load to the Exeter–Squamscott River. The remaining inputs come from developed and natural land in the upper watershed. Loads are in tons per year. 4 CARSEY SCHOOL OF PUBLIC POLICY Only two of these munici- What Is the Advantage of Fifty-year lifecycle costs, which palities, Exeter and Newfields, Integrated Planning? include facility operations and currently generate wastewater dis- maintenance, are estimated at charges that require EPA permits. If communities work together, they $100 million–$220 million for Stratham is unregulated now, but can prioritize nitrogen reduction the three communities (Figure 4). it has been notified of a pending strategies across the watershed, Integrated subwatershed planning MS4 permit requirement. starting with the most cost-effec- presents a potential cost benefit In 2013, the Water Integration for tive actions. Figure 3 shows the of over $100 million. Much of the Squamscott–Exeter (WISE) project4 capital cost associated with three savings is achieved by applying was initiated to develop a frame- scenarios: integrated subwatershed the most cost effective treatments work for an integrated nitrogen con- planning, where the three com- first, regardless of municipal or trol plan for these communities. The munities work to meet all permit permit boundaries. project brought together municipal requirements together; individual decision makers, the Rockingham community permitting, where each What Are the Drawbacks Planning Commission, the Great community addresses each of its to Integrated Planning? Bay Estuarine Reserve, univer- permits separately; and integrated sity researchers, and engineering permitting, where one community Integrated planning allows flex- consultants to work with state and (Exeter) combines requirements for ibility in both the timing and federal regulators to identify permit two permits, without coordinating methods used to meet the required elements amenable for integration with other communities. The WISE pollutant load reductions, but it and to develop scenarios combin- cost analysis found that the greatest can be enforced only to entities ing alternative levels of treatment degree of cooperation—integrated that are already subject to permits. that would be acceptable to the subwatershed planning—leads to In order to meet recommended regulatory agencies. The project the greatest cost savings. team developed nitrogen control strategies for a range of potential FIGURE 3. COST DIFFERENTIAL ASSOCIATED WITH THREE PERMITTING scenarios based on permit require-