PEPA would like WJWW to answer this question. WJWW proposes to build the filtration plant with its “substantial portion…underground” within the sensitive Kensico Reservoir Boundary. However, they own a nearby parcel at 12 Stone Ridge that is outside of the Watershed. It is counterintuitive for WJWW to build the filtration plant in the protected Watershed when they own an alternative location outside the Watershed that can support the filtration plant.
Westchester Joint Water Works' ("WJWW") Rye Lake Water Filtration Plant is proposed to be located within the Kensico Watershed Boundary, on Purchase Street and in a residential neighborhood, adjacent to the Purchase Quaker’s Meeting House and historic burial grounds.
No! PEPA has never objected to the construction of the WJWW plant. Over the course of WJWW's decades-long attempts to construct a filtration plant, PEPA only observed. PEPA did not oppose the project or take action since we are aware this is a court mandated project necessary to comply with surface water treatment rules
However, in 2020 when PEPA learned the WJWW had relocated the project from the site they already own (12 Stoneridge Road) to the Purchase Street site that is located within the Kensico Watershed Boundary we asked WJWW to reconsider and build the plant at its original location.
The nearby "Single-Family Residence" labeled as (3) is not to scale or shown in actual proximity. In reality, the filtration plant will tower above the nearby single-family residences. Furthermore, according to the WJWW website “a substantial portion of the plant will be underground…. adjacent to an active area at Westchester County Airport, which comprises commercial, business and private aviation services.” Construction of substantial, intricate underground plumbing within the watershed seems especially risky.
Using information from a WJWW report (March 2019) PEPA has created an approximation to compare the size of proposed filtration plant to the actual private residence closest to it:
WJWW proposes to build the filtration plant with a “substantial portion…underground” sited within the sensitive Kensico Watershed. However, they own a nearby parcel at 12 Stone Ridge that is outside of the Watershed. It is risky and counterintuitive for WJWW to build the filtration plant in the protected Watershed when they own an alternative location outside the Watershed that can support the filtration plant.
Source: WJWW website
Source: Town Harrison website
Based upon the above images PEPA has created an approximation to show relative location:
Yes! Comments submitted by the NYC Department Environmental Protection during the State Environmental Quality Review Process emphasized the importance of studying alternatives with a focus on “the original 2002 site” for the filtration plant that is located outside of the Kensico Watershed Boundary.
In its comment letter regarding the Draft Scope for DEIS for Westchester Joint Water Works Filtration Plant, Harrison, NY, dated April 16, 2021, the NYCDEP stated:
Click here to read the full comment letter by NYC Department Environmental Protection.
“Westchester Joint Water Works has been required to construct the filtration plant due to its failure to meet the standards needed for filtration avoidance for a public water supply. A Consent Order was issued by the Westchester County State Supreme Court in 2001 in response to a lawsuit brought by the New York State Department of Health requiring WJWW to proceed with the construction of the plant. More recently, in March 28, 2019, WJWW received a U.S. Environmental Protection Agency (“EPA”) Administrative Order to submit a Corrective Action Plan outlining provisions to be taken to achieve compliance with the disinfection byproduct maximum contaminant levels (“MCLs”), including haloacetic acids and total trihalomethanes. On November 26, 2019, EPA issued a superseding Administrative Order which included an obligation to commence design of the proposed filtration plant. This Administrative Order requires the plant to be in operation by October 15, 2024. PEPA does not disagree that a filtration plant needs to be constructed. However, PEPA does object to the current location selected for the proposed filtration plant, especially when there is an alternative location close by that will have many fewer negative impacts on the community and the environ.”
Yes! Nature works to reduce the amount of artificial treatment needed to filter water for free. Allowing the area within the Watershed to remain in its natural wooded state to function as a green filter would also prevent other harmful pollutants that would be introduced by the filtration plant including construction debris, stormwater runoff, and pollution from daily operations.
Trees, wetlands, and other plant materials are great at filtering water. They are the first natural filtration process our source water encounters. Trees in a watershed absorb rainfall and snowmelt, slow storm runoff, recharge aquifers, and filter pollutants from the air and runoff. In fact, when you turn on the faucet to fill your glass, you are drinking water that was filtered largely by trees.
New York City is world-renowned for its clean and delicious drinking water. The NYC Watershed delivers roughly 1.2 billion gallons of water each day to 9 million homes - 90% of New York City and 85% of Westchester. The Watershed’s forests, swamps, and soils act as natural filters, removing pollutants, and making NYC’s drinking water supply the largest unfiltered system in the U.S. (Columbia Climate School)
In order for drinking water to remain unfiltered, all public water companies, including WJWW, are required to obtain a Filtration Avoidance Determination (FAD), Unfortunately, WJWW is one of only three surface water suppliers in New York State that failed to obtain a filtration avoidance determination (FAD) under the Federal Surface Water Treatment Rule enacted in 1991. Because the WJWW was unable to timely obtain a FAD, the New York State Department of Health (DOH) initiated a legal proceeding to require the WJWW to construct a water filtration plant. As a result of this proceeding, the Courts issued an order to construct a water filtration plant. NYC, on the other hand, has obtained a filtration avoidance determination and is able to supply water without filtration.
Answers vary depending on the source.
In a comment letter regarding Draft Scope for DEIS for Westchester Joint Water Works Filtration Plant, Harrison, NY, March 23, 2021, the "Moving Harrison Forward" team estimated the amount of WJWW's water bill is expected to increase 15% annually for the next five years, resulting in a WJWW bill at the end of the period that will be 82% higher than it is today. Read the entire comment letter with calculations here.
The Journal News, on July 21, 2005, reported that WJWW had advised that "the treatment plant’s cost could boost local water bills by as much as 40% according to the utility."
WJWW microsite claims “there will be an increase in water rates by approximately 7%. This translates to a total cost per gallon of approximately 1.2 cents in contrast to the cost of a gallon of bottled water, which is upward of $1.00.” Source: Westchester Joint Water Works Website. WJWW Filtration Microsite. Retrieved September 9, 2021, from https://wjwwfiltration.org/
The 7% increase WJWW is reporting on their website today is in sharp contrast to the 40% increase they projected and stated to the Journal News in July 2005, over 15 years ago when the plant was originally proposed.
PEPA believes the disaparities need to be clarified and if necessary corrected and encourages all WJWW customers to contact their local officials regarding the possible increase in water rates due to the construction of the filtration plant, regardless of its location.
WJWW purchased the original site at 12 Stoneridge Road around 2002. Starting in 2007, WJWW invested substantial funds to design a filtration plant at the alternative site located further down Purchase Street. Having invested these funds already and having proceeding through a significant portion of the State Environmental Quality Review (“SEQRA”) process for that site, there could be significant costs savings by moving the plant to this alternative location. While the total investment made designing the filtration plant at the original site is not known, a report by Lakhani and Jordan, the engineering firm connected with the original site plan, indicates their work was extensive. According to the Lakhani and Jordan website, their firm was “involved in the design of a new 30,000 SF water treatment facility located on a 13-acre lot in Harrison, NY. Thus, it is believed that much of the work to develop the filtration plant at the alternative site has already been completed.
No! It is clear from the Town/Village Harrison’s Comprehensive Plan that the Town desires to continue low-density development in Purchase to maintain the low-density character of the area. The addition of a 30-MGD Dissolved Air Flotation/Filtration (DAFF) 30,000 SF water treatment plant located on 13.4 acres, that would stand at the very entryway to Purchase, is in sharp conflict with the Comprehensive Plan’s goal. Putting the filtration plant in the alternative location would comply with the Comprehensive Plan and create fewer impacts than the currently proposed location.
SEQRA requires “a description and evaluation of the range of reasonable alternatives to the action that are feasible, considering the objectives and capabilities of the project sponsor” (6 N.Y.C.R.R.§617.9(b)). While an applicant is not required to consider sites it does not own or have the option to purchase, an applicant must include the consideration of other properties owned/controlled by WJWW and determine if any of these properties could be used to meet the applicant’s objectives for the project. If viable alternative sites are available, they should be advanced for full evaluation in the DEIS. As discussed above, there is at least one alternative site that is owned by WJWW that was previously considered as a viable location for a water filtration plant in or around 2007-2008 that must be evaluated before WJWW begins to develop the proposed site for the filtration plant. WJWW, however, is continuing to invest significant funds in designing the filtration plant in a location that will have significant negative aesthetic and environmental impacts.
There are many negative aesthetic impacts that will result from the construction of the plant in its current proposed location. These impacts include stormwater runoff from construction activities, which is problematic because of chemicals and sediment being washed into nearby water bodies. Good environmental policy should move development away from sensitive areas where polluted runoff will do the most harm and to protect wooded and other open spaces that can naturally filter rainwater. Building the plant on the original alternative site instead of the proposed County-owned site inside the Kensico Watershed Boundary would be good policy and comply with strategies for reducing stormwater pollution.
Yes. According to the WJWW microsite “sound-dampening features will be included in the design.” This location, however, is already surrounded by residential neighbors who are already adversely impacted by noise pollution caused by the airport. This plant’s construction will amplify the noise significantly. Other substantial negative impacts would include construction truck traffic and traffic from deliveries of chemicals and other potentially hazardous materials once the filtration plant is operational.
Of greater concern are the negative aesthetic impacts that will result from the construction of the filtration plant. The proposed filtration plant will be significantly larger than a residential facility and will be much closer to Purchase Street than any of the existing airport structures. It will also be much more visible to the public from Purchase Street. Further, trees act as a sound barrier and to build the filtration plant in the proprosed location requires the removal of over 10 acres of trees that are currently acting as a buffer to airport noise.
Yes, it does, in many places, including Chapter 2 and Chapter 6.
Chapter 2: Townwide Analyses declares the important role Kensico plays in providing clean water for nine million people. “As Harrison obtains its water from this water supply system, the protection of the quality of Kensico is vital for both New York City and Harrison. Kensico Reservoir the Kensico Reservoir is the final stop for 90% of New York City’s drinking water supply before it enters the water tunnels that carry it to consumers’ taps. Normally, all of the water from the City’s Catskill and Delaware watersheds – located in parts of Ulster, Delaware, Greene, Schoharie and Sullivan Counties west of the Hudson River – flows into the Kensico Reservoir.” (page 74)
This chapter also points out the importance of regulating “stormwater management in the northern portion of Harrison, within the city’s watershed boundary, due to the critical role of Kensico Reservoir in New York City’s water supply. NYCDEP has set down regulations for development in the form of the Rules and Regulations for the Protection from Contamination, Degradation, and Pollution of the New York City Water Supply and its Sources (Watershed Regulations) 1997.” (Page 71)
Chapter 6 Plan Concepts and Future Use Plans states that “the Kensico Reservoir requires protection. There are a number of natural resources requiring protection: steep slopes, wetlands, watercourses, ponds, and Kenisco Reservoir. Harrison already controls development that might harm any of these resources, as does the New York City Department of Environmental Protection through its Watershed Regulations. This plan recommends revising regulations to more clearly create permanently preserved open space. Such open space may be habitat or environmentally sensitive land. This change would lead to greater protection of environmental resources in future large-scale development.” (Page 138)
Given the importance of the Kensico Watershed, it makes no sense to contruct a large industrial filtration plant in the area selected by WJWW. This is especially true when an alternative location that has already been studied exists outside the Watershed.
Final thoughts: Given the importance of the Kensico Watershed, it makes no sense to construct a large industrial filtration plant in the area selected by WJWW. This is especially true when WJWW owns an alternative location that has already been studied and exists outside of the protected Watershed.