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While dredging is not an approved BMP, the Conowingo Dam was considered a BMP. Would not a revitalized reservoir with increased storage capacity not be considered a BMP?
Is there an implementation deadline for the Conowingo WIP?
I realize there is a financing strategy being developed, however financing was also mentioned in the WIP which suggested utilizing existing state resources such as the Ag Nonpoint Source Program. I think it’s important to note that we are already utilizing state funding resources for implementation of our jurisdictional WIP, and the programs are already oversubscribed so there needs to be new funding for implementation of these loads.
The USC has concerns with the identified highly effective N basin map and workload that has already been accomplished in those areas. Was an analysis completed before choosing those watersheds that looked at work that has been accomplished since 1995 in those watersheds, to verify that we can indeed adopt additional practices that will address Nitrogen loading?
Is there a projected date of when the financing strategy be released to the public and will there be a public comment period after its released?
In regards to tracking and reporting. The Upper Susquehanna Coalition (USC) in conjunction with NYS Department of Environmental Conservation (NYSDEC) have spent numerous staff hours and significant funding to develop and enhance a BMP tracking and reporting system that meets the requirements of the Chesapeake Bay program. Annually we submit practices to the NEIEN and addressing the minimal errors that arise. The USC would like to continue the use of this system and not be required to change our approach for the Conowingo WIP when we will be tracking and reporting the same practices.The USC has also developed a BMP Verification program based on CB program protocols and requirements and does not want to develop a separate system for the Conowingo WIP, as our approach has been adopted in 18 counties in NY. It would be too confusing to have both a separate tracking, reporting and Verification program for the Conowingo WIP and our Jurisdictional WIP.
NYSDEC has not adopted local planning goals for their jurisdictional WIP and this approach is supported by the USC. A watershed approach to implementation is working for NYS and allows for us to implement practices across the watershed. The suggestion that Milestones will be developed along with local load allocations for the Conowingo WIP is very concerning for the USC as this is not how we currently operate. We want to see the continued flexibility that we have with our jurisdictional WIP kept for the Conowingo WIP with watershed goals not county or local planning goals.
Will implementation in non-targeted watersheds be given credit?
What entity will be responsible for enforcing this WIP?