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Friday, August 14, 2020


A better strategy

Jul 9, 2020

To the editor:
I was elected into office for a variety of reasons, and a primary one in the towns of Highland and Bethel within my district had to do with the under-construction Eldred Preserve.
While on the campaign trail, I heard many times of the discontent with the fact that the Preserve's developer plans to discharge up to 17,000 gallons of wastewater every day into the pristine Halfway Brook, which flows south through Eldred and into the Delaware River at Barryville. I promised then that I would do all that I could to address this situation, and this letter is part of that effort.
Let me be clear that I fully support a thriving local economy, which my colleagues and I are striving to create every day we're in office. The Preserve promises to be a significant source of employment, along with tax revenue, when it's in full operation, and from what I know, it will capitalize on everything we love about Sullivan County - relaxing accommodations, beautiful natural resources, hospitable dining.
But it can do all that without polluting the environment at the same time. The proposal to discharge 17,000 gpd of wastewater after primary treatment is unnecessary and inappropriate given the high quality of the receiving stream and associated wetlands that will be impacted, as well as downstream aquatic habitats. Halfway Brook is a Class B(T) stream known for its recreation, including trout fishing and swimming. Halfway Brook's high water quality ensures its tremendous ecological and recreational value but also means the stream has little buffering capacity, and little ability to accept and process point source loads of nutrients, BOD, and salts without impacting the water quality and the best uses of the stream, associated lakes and wetlands.
The Eldred Preserve should be required to use, and should want to use, non-discharge alternatives that protect the creek, those who are downstream, and the ecological health of our region.
A large-scale, well-functioning septic system or other non-direct discharge strategy - which the owner of the Preserve can easily afford - is far preferable to the direct discharge of additional flow and pollution to this sensitive stream of such importance to the region's quality and health.
Further, there is reason to be concerned that the Preserve is anticipating additional development and expansion at this site that would increase the quantity of wastewater and pollution discharged to Halfway Brook. It is important that the Preserve and the NYS Department of Environmental Conservation be required to disclose whatever is anticipated for this site that would result in an increased volume of wastewater discharges.
Halfway Brook drains directly to Delaware River Basin Outstanding Basin Waters, which we know as the Upper Delaware Scenic and Recreational River. Outstanding Basin Waters are those waterways with the most pristine quality in the Delaware River Basin and as a result have the highest level of anti-degradation protection available in the Delaware River Basin Commission's Special Protection Waters Program.
The ongoing quality and beauty of this stretch of river is directly dictated by the health of the tributaries that feed it. Harmful impacts to the Halfway Brook will have implications for the outstanding water quality, scenic, and recreational values of the Delaware River.
I've been in touch with the Delaware Riverkeeper Network about this matter, and they urge rejection of the surface discharge and that a non-discharge alternative be mandated. As they've said and I'll vigorously endorse, it's wrong to sacrifice the very nature that attracts customers to these kinds of businesses.

Robert A. Doherty

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