Field Hearing – “EPA Overreach and the Impact on New Hampshire Communities”

Witness and Testimony Documents
Mayor of Rochester
New Hampshire
Peschel Consulting LLC
Hall & Associates
Public Works Director
City of Portsmouth, New Hampshire
Regional Administrator
EPA New England Headquarters, Region 1
June 04, 2012,

 

9:00amET on Monday, June 4, 2012 at the Exeter Town Office Building, 10 Front Street, Exeter, New Hampshire

As we begin this discussion, everyone here today cares about the health of the Great Bay Estuary and wants to work to improve it.  Unfortunately, the methods employed by the EPA have created an economically unviable path for New Hampshire’s communities. Rather than take a reasoned approach to improve the estuary, the EPA has embarked on a costly nitrogen reduction effort based on speculative science that could cost Great Bay communities upwards of $160 million dollars in initial compliance costs and annual costs of $25 million.

Under the Clean Water Act, the National Pollutant Discharge Elimination System, or NPDES permits place limits on pollutants that can be discharged into surface waters.  The Great Bay Estuary must obtain these permits from the EPA.  While the Great Bay communities agree with the EPA that nitrogen reduction is a priority, EPA’s approach to the issue appears to be extreme—with sweeping, all-or-nothing requirements that will create a major economic detriment to the area.

The EPA’s process comes at a price tag approaching a billion dollars over the 20-year life of the project.  For households, that means an average of a 100% increase in their annual costs. Hoping to avoid this massive cost burden, the Great Bay Municipal Coalition of communities has proposed an Adaptive Management Plan, or AMP.  Their standard would reduce nitrogen levels by 73%–back to their 1980’s levels and cut the cost nearly in half, while still providing for significant improvements in water quality.

EPA’s proposal would impose extreme costs on the citizens of the Great Bay communities, despite a viable alternative, because the science underlying this stringent new standard is questionable.  The EPA’s approach is unrealistic and renders the communities unable to sustain their economic base.