1. December 11, 2013
Center for Conservation
P.O. Box 5125
East Hampton, NY 11973
Tel (631) 329-7689
Fax (631) 329-0215
www.nature.org/longisland
Uplands Farm Sanctuary
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Cold Spring Harbor, NY 11724
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Fax (631) 367-4715
www.nature.org/longisland
Mashomack Preserve
P.O. Box 850
Shelter Island, NY 11964
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Worldwide Office
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Arlington, VA 22203
Tel (703) 841-5300
www.nature.org
Honorable Judith Enck
Regional Administrator
Environmental Protection Agency Region 2
290 Broadway New York, NY 10007-1866
Honorable Mirza Orriols
Deputy Region II Administrator
HUD New York City Regional Office
26 Federal Plaza, Room 3541
New York, NY 10278-0068
Honorable Jerome Hatfield
Region II Administrator
FEMA Federal Regional Office
26 Federal Plaza
New York, NY 10278-0002
Dear Regional Administrator Enck, Deputy Administrator Orriols, and Regional
Administrator Hatfield,
We are writing to seek your assistance with respect to one of the most serious
outstanding post-Sandy environmental and human health issues: the redesign,
reconstruction, and fortification of the Bay Park Sewage Treatment Plant and
ancillary wastewater infrastructure in Nassau County, New York. There is an
urgent need to address both the historic deficiencies and the future ability of this
facility, which services more than 500,000 people, to withstand severe weather
events. Along with this pressing need comes a unique opportunity to take
action that will preserve public health, protect public safety, and profoundly
improve the environment.
The information outlined in this letter is intended to provide context that
explains the need to replace the existing outfall pipe with an outfall to the
Atlantic Ocean, consolidate treatment and outfalls to meet current and
anticipated regional waste water needs, fortify the treatment plant compound
and vulnerable assets to prevent damage in future storms, modernize to
advanced treatment technology that reduces nitrogen and will readily
accommodate future treatment for emerging contaminants, and transition to
digital monitoring and compliance reporting with a community oversight
board.
For the reasons set forth below, we respectfully request that your respective
agencies provide priority attention, effort, and funding support to achieve the
significant public health, safety, and environmental quality benefits offered by
this opportunity. As a key part of this initiative, The Nature Conservancy offers
our assistance, and the assistance of the Western Bay’s Coalition, in organizing
dialogs with the scientific experts, local community and civic groups, and/or
local government elected leaders and agency heads, with the goal of facilitating
a thorough and expedited path forward. To succeed we will need a strong,
collaborative effort by your respective offices and the impacted communities,
and that will only happen with your participation.

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Background
As you know, the Bay Park Sewage Treatment Plant was inundated by nine feet of seawater in
Superstorm Sandy. Plant failure resulted in raw sewage flooding streets and homes during and
immediately after the storm and 2.2 billion gallons of raw and partially treated sewage being discharged
into an environmentally sensitive estuary in the weeks and months that followed the storm1. Engineers
have undertaken great efforts to put temporary measures in place. However, as of my most recent tour
of the facility, the plant was still relying on backup generators that burn 5,000 gallons of diesel every 18
hours costing $700,000 per month in fuel. The result is that the adjacent residential community
experiences noise and air pollution from these temporary generators 24 hours per day and components
designed to capture and utilize sewage generated methane gas as fuel are not fully functional. In short, it
is a continuing community health and environmental crisis. And should another storm come, we are just
as vulnerable as we were pre-Sandy.
The Western Bays Coalition of the South Shore Estuary Reserve Council has been working for over a
decade to lay the groundwork to reduce the adverse impacts of waste water discharges to western bays
of Nassau County. Through this group, over $1.64M has been directed towards studying issues related
to the sewage outfalls in this area since 2008. As a consequence, today Nassau County leadership, civic
groups, residents, scientific experts, and environmental advocates are largely united in their non-partisan
vision with respect to moving forward to end decades of waste water discharge pollution and adding
resiliency to Nassau’s coastal communities.
The Bay Park Sewage Treatment Plant
services 40% of Nassau County’s
population (approximately 500,000
people). Adjacent to Bay Park there
also are serious waste water treatment
infrastructure needs required to
support the 48,000 residents and
hundreds of businesses on Long
Beach Island. The aging and
inadequate nature of the sewage
treatment infrastructure in these areas
was not caused by Superstorm Sandy.
Based on recent scientific
documentation linking waterway
impairments to sewage effluent, a
process to impose new strict treatment
standard requirements and plant
modifications was already underway
before the storm.
1
Raw sewage from underground sewer pipes contaminated streets and
adjacent homes and buildings during and immediately following
Sandy. Newsday Photo
Kenward A. et al. 2013. Sewage Overflows from Hurricane Sandy. Climatecentral.org Princeton NJ.

3. Page 3 of 10
The impacts to people’s lives and the
surrounding environment resulting
from the failure of the treatment
plant and the underground pipes
during Sandy cannot be understated.
As we think about rebuilding,
however, it is essential to
acknowledge that there were very
serious pre-existing problems.
Studies and planning efforts already
underway are providing clear
guidance on the appropriate way to
rebuild and re-engineer these
systems after Sandy. If the goal for
the Sandy recovery efforts is for
south shore communities of Nassau
The plume from more than 50 million gallons per day of raw and
County to be more resilient than
partially treated sewage discharging from the Bay Park Sewage
before the storm, then we cannot
Treatment Plant Outfall Pipe into Reynolds Channel in close
simply fortify and rebuild the
proximity to densely populated bayside communities of Long Beach,
Island Park, and Harbor Isle. Newsday Photo 11/14/12
sewage treatment infrastructure to
the same specifications that were
originally utilized in 1955 when the plant was first constructed. We must instead (a) take into
consideration the significant impairments that pre-storm plant operations were causing, (b) incorporate
all the information we have gained from recent studies and analyses, (c) anticipate the significant
pending regulatory changes concerning sewage treatment discharge standards in this area as well as
projected population increases, and (d) embrace modern rebuilding designs that will accommodate
additional treatment add-ons and resource recovery opportunities over the coming decades.
I am fully confident that the sewage treatment infrastructure of southern Nassau County can be reengineered and fortified in a way that addresses both pre-and post-Sandy environmental, quality of life,
and human health impacts to the western bays and surrounding communities. In fact, improving
conditions in the western bays and adjacent ocean beaches will most assuredly have positive economic
consequences as natural resources recover and the quality of waterways become more compatible with
aquatic recreation, rebuilding goals for depleted fisheries, and enhancing Nassau’s water dependent and
water enhanced businesses. I am similarly confident that the level of coordination and cooperation that
will be required of multiple federal, state, and local agencies needs to be extraordinary. It is the hope
and expectation of all that are invested in this process to see hand-in-hand cooperation among agencies,
so that plans are thoughtfully crafted, coordinated, funded, permitted, and expedited through to
implementation in a time frame that matches the expectation for distribution and expenditure of Sandy
related funding.
Preceding Sandy
In 2008 NYS DEC and US EPA added the Western Bays of the South Shore Estuary Reserve to its
303(d) list of waterbodies impaired by nitrogen pollution calling for the development of regulatory
limits on nitrogen discharges (Total Daily Maximum Load – TMDL). This listing calls out excessive
growth of the macro-algae Ulva (sea lettuce) as a primary impairment. Ulva is known to grow
excessively in the presence of nitrogen, in this case from sewage. Recent scientific studies (Gobler and

4. Page 4 of 10
Wallace 20132) identify additional impacts of nitrogen loading of the western bay such as harmful algal
blooms, hypoxia, and deterioration of the integrity of salt marsh islands that creates greater risk of wave
and water damage for bayside communities. Managers at US EPA have access to the studies that are
forming the scientific foundation for the pending Nitrogen TMDL so our intent is not to replicate details
of those reports here. In general the very high year-round, persistent nitrogen loading to the western
bays (2,800,000 kg of total nitrogen per year3) are coupled with long estuary residence times (poor
oceanic flushing). Combined, these phenomena create a variety of environmental degradation problems
that not only constitute use impairments in
the bay (Swanson et. al. 20134), but also
impact the ocean beaches, human health,
quality of life, and the local economy.
Noxious hydrogen sulfide gas originating
from decomposing Ulva impacts
communities, beaches, and seaside dining
establishments with the odor of rotting eggs
during the prime summer season. Seaweed
gets so thick on some of the otherwise prime
ocean facing beaches that the town of
Hempstead must use public financing for
manual removal from popular beaches on a
daily basis. As the excessive algal growth
decays at the bottom of the bay it smothers
sea life and depletes oxygen from the
waterways.
Recent Stony Brook University studies confirm Bay Park
effluent fuels Ulva growth
Hundreds of millions of dollars are being
spent to recover Long Beach after Superstorm
Sandy. Yet without the proper re-engineering
of sewage treatment and where it is
discharged, Long Beach and the town of
Hempstead will never realize the full
economic potential of this island/city of
48,000 people because the water and
shorelines will not meet their best-usage
designations. Natural maritime resources and
the recreational and the economic
opportunities they provide were the prime
reason that Long Island’s beach, fishing, and
boating communities were originally
Despite the town’s daily cleaning, masses of rotting sea
established. If these communities are to
lettuce, fueled by sewage, keeps people away from prime
remain attractive and viable as the risks and
beaches and kept many from enjoying the water at Point
costs of living near the coast increase, than
Lookout on this hot July day in 2013. Newsday Photo
integrity of the marine and coastal natural
assets needs to reverse from its declining trajectory.
2
Gobler,C. and R. Wallace 2013. Nutrient Assessment and Management in Shallow Coastal Waters of Hempstead Bay.
Gulbransen T., et al 2013. Ecosystem Assessment and Nitrogen Management in Western Bays. NY. Report to NEIWPCC
4
Swanson L. et al. 2013. A Synthesis of Loadings, Monitoring, Information, and Impairments in the Western Bays. A
Report to Battelle Memorial Institute and New York State Department of State. April 2013
3

5. Page 5 of 10
Natural infrastructure at risk puts communities at risk
Nowhere in New York State are densely populated low-elevation communities more protected from
wave energy and coastal erosion by salt marsh islands than along the south shore bays of Nassau
County. Windy days are common along the south shore of Long Island, but in the western bays, the
expansive marsh islands leave little fetch for waves to develop. In contrast, roughly 20 miles east in
central and eastern Great South Bay there are no marsh islands and that area is well known for its
‘choppy’ wave energy. In fact, the frequency and magnitude of wave energy in central Great South Bay
has dictated a completely different style of coastal development as compared to the western bays which
are protected from wave energy by salt marsh islands. While bay front communities in the western bays
are characterized by backyard finger piers that hold small boats – this type of construction could not
withstand the chronic wind-blown waves that are common along open sections of bay to the east.
AB
Salt marsh islands along the south shore of Nassau County reduce the fetch from every direction, significantly
reducing wave energy during windy days that are common along Long Island’s south shore. A, B, Bay Park and
Long Beach STP outfalls in Reynolds Channel
Unfortunately, the integrity of the salt marsh islands in the western bays is compromised by excessive
nitrogen pollution that is largely originating from sewage effluent. As described in Deegan et al. 20125,
salt marshes respond to high levels of nitrogen by reducing below-ground biomass (roots). As root
density declines, marshes are more susceptible to collapsing along the edges. This phenomenon is
already evident throughout the western bays. Expansion of below ground roots is an important
mechanism for how marshes keep up with sea-level rise. Most bay-front homes and docks in the
western bays are not constructed to withstand the kind of chronic wind-wave energy that is typical in
areas to the east that do not have protection from extensive marsh islands. If the western bays marshes
continue to erode at the edges and fail to keep up with sea level rise, built infrastructure along the bay
will be in serious jeopardy. Damage from chronic wave energy will prevent tying up boats up along
piers and bulkheads which has historically been a primary asset for the value and desirability of these
coastal residential properties. Therefore efforts aimed at reducing the amount of nitrogen loaded to the
5
Deegan L., et al 2012: Coastal eutrophication as a driver of salt marsh loss Nature 490, 388–392

6. Page 6 of 10
western bays through improvements to sewage treatment and re-location of the sewage outfalls are
essential steps for rehabilitating the natural infrastructure that protects and adds resilience to Nassau
County’s bay-side communities.
A
B
C
A: Harbor Isle: example of existing bay-facing development along the western bays showing docks and piers
that are only possible because of the wave energy protection afforded by marsh Islands B: Marsh calving in
the western bays: a symptom of weakened root systems C: Choppy wave conditions: common in parts of
Long Island’s south shore bays absent of the protection of extensive marsh islands.
The case for an ocean outfall
The western bays and area in which the Bay Park and Long Beach sewage treatment plant outfalls
discharge to Reynolds Channel are now proven to be poorly exchanged with ocean water (Wilson and
Yang 20136) and much more environmentally sensitive than previously realized. The combination of
continuous high sewage loads and poor flushing has led to a series of use impairments, the intensity of
which radiate in severity around the outfall locations (Swanson et al. 2013). In addition to contaminants
of emerging concern within secondarily treated sewage, the Bay Park and Long Beach sewage treatment
plant outfalls contribute 94% (87.9% and 6.1% respectively) of the total dissolved nitrogen loaded to
west bay (Swanson et al. 2013), and sewage is conservatively estimated to contribute 79.4 of the
nitrogen to the entire western bays estuary complex (Gulbransen et al. 2013). This estuary is seriously
impaired by nitrogen pollution. Degradation of the estuary has broad ranging impacts to the greater
ocean ecosystem by negatively impacting potentially prime nursery and foraging area for economically
and ecologically important fish and wildlife. In addition, excessive macro algae mats that accumulate in
the bay eventually wash up and decompose on popular ocean facing public beaches such as Point
Lookout. Experts testified at a Western Bays Education Forum in January 2013 that even if nitrogen
reduction standards were imposed at the limit of technology, the location of the outfall pipe in the
6
Wilson R. and D. Yang. 2013. Quantitative Description of the Spatial Patterns in Residence Times within the Hempstead
Bays Region. A Report to Battelle Memorial Institute and New York State Department of State. April 2013

7. Page 7 of 10
environmentally sensitive poorly flushed estuary in close proximity homes and businesses would still be
a problem. Thus relocation of Bay Park STP outfall pipe to the ocean is the top recommendation of the
scientific experts studying this issue (Swanson et al. 2013) and was the most highly scored alternative
recommended by engineering consultants for Nassau County (CH2MHILL 2013)7.
Hesitant of advocating for a project that might simply re-locate a problem from one location to another,
members of the Western Bays Coalition seriously considered all other potentially viable options for an
outfall location and/or resource recovery/beneficial reuse opportunities. What the Coalition has
determined is that there is simply nowhere else in Nassau County to relocate over 50 million gallons per
day of treated sewage. No other surface water body can handle this volume of flow. And $22 million
dollars in experiments and pilot efforts to recharge aquifers in Nassau with sewage led to abandonment
of this concept once results indicated that it was causing dangerous contamination of underground
aquifers that represent the sole source of drinking water for almost 3 million Long Islanders (Wood
20068). Similarly, there is no-viable resource recovery option now or in the foreseeable future that could
utilize anything remotely close to this volume of treated sewage.
Documented disruptions at the sewage treatment plant in the last several years, not the least of which
occurred during Superstorm Sandy, highlighted another very serious rationale for outfall relocation to
the ocean. High volume sewage outfalls in close proximity to densely populated fishing and boating
communities creates a significant human health threat under extenuating scenarios when plant
operations fail to meet their discharge standards. While ideally future disruptions can be averted, history
proves that failures do occur and we would be naive to believe they won’t occur again. If Sandy had
occurred in the warm summer months, the discharge of raw and partially treated sewage in such close
proximity to waterfront communities would have triggered serious human health crises at the exact time
that residents and emergency response crews were already dealing with many other storm related crises.
Installation of an ocean outfall is an additional safeguard for the health and safety of all waterside
residents on the mainland, the bay islands, and on Long Beach Island because in the event of plant
failure it is still possible to get sewage away from the most sensitive and populated areas.
These facts provide the basis for The Nature Conservancy’s assertion that a new ocean outfall is an
essential component of Sandy recovery projects associated with wastewater treatment failures in Nassau
County. We believe that the regulatory requirements for a rigorous Environmental Impact Study for an
ocean outfall should begin right away, and that careful consideration should be made to put the outfall in
a location that has the fewest negative consequences, and construct it in a way that accommodates all of
the anticipated sewage discharge needs of the region. Importantly, we assert that an ocean outfall will
not negate the need to modernize Nassau’s aged waste water treatment and transport system through the
additional components outlined below.
The case for consolidation and expansion
If Sandy taught us anything, it’s that valuable and critical infrastructure should not be located in highly
vulnerable areas. This is the case for the two sewage treatment plants on Long Beach Island (Long
Beach STP and the smaller Atlantic Beach STP). The treatment capacity at Bay Park STP should be
expanded to include the processing of sewage from these two districts as well as continue with pre7
CH2MHILL. 2013. Nassau County Bay Park Sewage Treatment Plant Report for the Conceptual Study of Alternatives to
Meet Future Nutrient Limits. Prepared for NCDPW.
8
Wood, C. 2006. Recharge for a Sole-Source Aquifer: The Successes and Failures of Cedar Creek Treatment Facility,
Nassau County, Long Island. Hydrogeology: Wastewater Reclamation and Groundwater. Dartmouth Undergraduate Journal
of Science

8. Page 8 of 10
Sandy plans to redirect sewage from Cedarhurst and Lawrence to Bay Park via a pumping station at
Inwood. A pumping station that delivers untreated sewage to Bay Park STP could be located at the site
of the current Long Beach STP and consideration should be made towards rehabilitating and
repurposing Bay Park’s existing under-bay outfall pipe into a sewer main that delivers sewage from
Long Beach to Bay Park for treatment. Thus all of the sewage from Long Beach, Atlantic Beach,
Cedarhurst, Lawrence, and Bay Park Sewer districts would be treated at a single centralized plant that is
re-engineered with state of the art sewage treatment technology and a new outfall pipe to the Atlantic
Ocean. If it turns out that it is unfeasible to discontinue treating sewage on Long Beach, then the outfall
from that facility should still be tied into the new ocean outfall at Bay Park. In addition to assuring that
the re-engineered Bay Park can handle the expansion to cover the existing sewage districts, the plant
should also prepare for eventually connecting the remaining pockets of un-sewered areas within and
adjacent to these sewer districts, (such as Point Lookout). Projections should also factor in anticipated
population growth in the Nassau County. Even if additional connections are phased in over time, it will
be more cost effective to include these forecasted needs as part of the re-engineering and reconstruction
now. Economy of scale will make it more efficient and more practical to have higher treatment
standards, implement modern resource recovery techniques, and manage operations at one centralized
plant.
The open space surrounding the Bay Park Sewage Treatment Plant compound provide fortification and expansion
options. Newsday Photo looking south
The case for fortification
By all accounts the low elevation and bay-side location of the Bay Park Sewage Treatment Plant
requires that it be fortified for storm surge protection. To avoid potential damages in future storms at

9. Page 9 of 10
least some of this fortification needs to take place in advance of expensive re-construction of the plants’
electrical system which was completely destroyed when it was flooded with sea water during Sandy. It
is my opinion that in its recent conceptual study of Bay Park Sewage Treatment Plant alternatives,
CH2MHILL unnecessarily disregarded all re-engineering and advanced treatment/capacity options that
would require additional facilities or an expansion of the footprint of the existing plant compound.
Serious consideration should now be given to what, if any of the open land around the plant should be
contained within the first level compound fortification and what if any could be re-purposed to achieve
all the objectives laid out here. While a proposal to re-purpose any open space would most certainly
require a thoughtfully facilitated dialog with the adjacent community, it is our impression that the
community would be open to solutions that met their demands for noise and odor reduction and cleaner
water. It’s probable that a high vegetated berm constructed around the compound would be perceived
positively. Some of the owners of Sandy damaged homes immediately adjacent to the north side of the
compound may even welcome conversations about voluntary acquisition options. Now is the time for
all serious options to be on the table.
The case for modernization
There was a time when Nassau County residents were very proud of their state-of-the-art sewage
treatment plants and school students would take field trips to learn about modern sewage treatment. The
re-engineering of Bay Park STP provides an opportunity to once again utilize modern treatment
techniques that improve the quality of the effluent, reduce noise and odor in the adjacent community,
and recover and utilize resources such as but not limited to methane gas. Recovery of latent heat from
generators has the potential to be used to accelerate biological nitrogen reactions in winter while
modernization that increases energy efficiency or resource recovery may be eligible for assistance from
US DOE or NYSERTA. Ultraviolet treatment should be used rather than chlorine to disinfect pathogens
which will save in chronic chemical costs and be better for the environment. It is fully anticipated that
over the coming decades there will be a need or desire to add on emerging treatment technology and/or
separate portions of the effluent for beneficial re-use. The re-engineered plant should be designed with
this in mind to facilitate future upgrades and additions.
The case for stricter discharge standards and advanced treatment
The installation of an ocean outfall is in no way intended to simply relocate environmental problems
from the bay to the ocean. Although dilution will most certainly be greater in the ocean than it is in
Reynolds Channel, the ocean beaches of western Long Island are prime recreation areas that are heavily
utilized. It is likely that hundreds of millions of dollars will have be spent to rebuild the beach economy
on Long Beach Island after Sandy. The days of permitting sewage discharges into any surface waters
without strict treatment standards are at an end. As regulators formulate the precise level of treatment
based on the location and volume of flow from this new ocean outfall it is important to recognize the
potential for cumulative impacts of this outfall with the other two Long Island ocean sewer outfalls
(Cedar Creek and Bergen Point). In addition, it is important to acknowledge that to the east 70% of
Suffolk County is still relying on more than 400,000 septic systems and those systems need to be phased
out as they are polluting drinking water supplies and near shore waterways. As waste-water treatment
becomes centralized, at least for high density areas in western and eastern Suffolk County, there will be
pressure to discharge more sewage effluent to the ocean either through Bergen Point or new locations.
Simultaneously to the west, there are serious environmental issues surrounding the aging New York City
sewage treatment plants that currently discharge into Jamaica Bay. Thus overtime it is likely that there
will be additional ocean sewer outfall proposals from NYC. The importance of near shore ocean natural
resources, the high value of the ocean beach, fishery, and recreation based economy of the area, and the
potential for cumulative impacts among existing and anticipated ocean discharges should all factor into

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setting strict standards for the discharge of nutrients and other potentially harmful components of
sewage effluent through the new ocean outfall.
The case for professional operators with community oversight
When Nassau County officials first proposed bringing in private companies to operate the County’s
sewage treatment operations, many of the members of the Western Bays Coalition were uncomfortable
with the idea and feared there would be a loss of oversight. After working on these issues for the last
several years, however, the Coalition has come to recognize that an established, exceedingly
experienced, qualified, professional contractor specializing in waste water treatment and management is
an essential component to this solution. Another part of the solution is a community oversight board and
digital real time dashboard for monitoring key parameters of discharged effluent. This kind of oversight
will not only help achieve local goals, but can also facilitate an expedited and simplified process for
meeting the plant operators and County’s reporting requirements to the state and federal regulatory
agencies. If done correctly the monitoring dashboard could feed information directly to New York State
in a way that is compliant and consistent with the Sewage Right to Know Law passed by Governor
Cuomo in August of 2012.
Conclusion
The time to re-build, modernize, and storm proof the aging Bay Park sewage treatment plant is now. I
urge the leaders at your agencies to assist Nassau County in securing the necessary federal aid to address
all of the issues outlined above. Our communities and bays deserve a fully functioning state of the art
sewage treatment facility. Superstorm Sandy has exposed the weaknesses of the Bay Park STP while
offering a unique opportunity to repair failing infrastructure, upgrade inadequate treatment, and
simultaneously increase resiliency and quality of life in the coastal communities in southern Nassau
County. I recognize that to achieve these goals in a reasonable timeframe will require unprecedented
cooperation and communication among federal, state, and county agencies. To the extent that it is
helpful I offer assistance moving forward.
Thank you very much for your attention to this very important issue.
Sincerely,
Carl LoBue
Senior Marine Scientist
The Nature Conservancy on Long Island
250 Lawrence Hill Rd, Cold Spring Harbor NY 11724
clobue@tnc.org, (631) 367-3384 ext 113
cc
Honorable Shaun Donovan, Secretary HUD
Honorable William Fugate, Administrator FEMA
Honorable Gina McCarthy, Administrator EPA