The ‘OU-2 Proposed Plan’ is the first major decision the EPA is undertaking in the Superfund cleanup of Newtown Creek since the waterbody’s designation in 2010. The plan is specifically focussed on the impacts of chemicals discharged annually to the Creek via Combined Sewer Overflows (CSO). While the plan is rather complicated in the use of technical data, modeling and analysis the conclusion is clear: EPA is recommending ‘No Further Action’ to reduce hazardous CSO discharges. The first Superfund decision in 10 years since the listing of Newtown Creek is to take CSO pollution reduction off the table.
Newtown Creek Alliance and the Newtown Creek Superfund Community Advisory Group (CAG) find this conclusion to be unacceptable. EPA is allowing New York City to continue the ongoing pollution of our waterway, destruction to it’s ecosystems, and ongoing dangers posed to those that live or work near the Creek or seek to utilize the waterway for recreational and/or educational purposes.
The EPA is accepting public comments until February 28th. We urge anyone with an interest in the true cleanup of Newtown Creek to submit your own comments to EPA and have created a simple form letter to help individuals personalize their comments and speak directly to the issues/concerns most important to them. View the form letter here and please cc: firstname.lastname@example.org so we can keep track of public comments.
Written comments on the proposed plan, postmarked no later than close of business February 28, 2020, may be emailed to email@example.com or mailed to:
U.S. Environmental Protection Agency
290 Broadway, 18th Floor
New York, NY 10007
- EPA Has a Responsibility to Address All Pollution Sources, Including CSO Discharges.
- It Is Illogical to Compare CSO Discharges to Other Pollution Sources Yet to Be Evaluated.
- It Is Premature to Take CSO Reduction Off The Table.
- A 61% Reduction of COPCs from CSOs Is Insufficient.
- Superfund Grants EPA Authority to Impose CSO Reduction Beyond the Clean Water Act Requirements.
- “No Further Action” Is an Action Requiring National Consistency Review.
- The City’s Pollution Models Include Unrealistic Assumptions that Underestimate Future CSO Discharges.
- The Solution to Pollution Is Preventing Overflow, not Track-Back, Dredging or Sorbent Pads.
- EPA Should Be Consistent With Gowanus Methodology and CSTAG Recommendations.