February 12, 2002

The Commission’s review and comments on the Stage 2 Rochester Embayment RAP reflect an assessment of the document submitted in relation to the five Stage 2 requirements outlined in the introduction , consideration of the implementation of an ecosystem approach to the restoration and protection of beneficial uses, and an assessment of adequacy of public consultation.

Have in-place remedial measures been evaluated?

Monroe County Health Department staff members and Task Group members of the Water Quality Management Advisory Committee (WQMAC) completed a comprehensive review of in place remedial measures. A summary of this evaluation is presented in Table 6-1 of the Stage 2 Rochester Embayment RAP.

Have alternative additional measures to restore beneficial uses been evaluated?

Chapter 7 of the Stage 2 RAP complies precisely with this requirement of the Annex 2 of the Agreement. In addition, the authors divided the chapter into sections addressing urban and rural remedial measures and devised tables which summarize how proposed measures would contribute to beneficial use restoration. This contributes to a much more useful evaluation of potential remedial measures.

Have additional remedial measures to restore beneficial uses been selected?

Additional remedial measures to restore beneficial uses have been selected. In accomplishing the selection, a ranking mechanism was utilized. As a result, rather than facing an unranked list of possible actions, implementors are provided with concise guidance specifying which actions are of highest utility to the RAP effort.

Has a schedule for implementation been adopted and have persons and agencies responsible for implementation of remedial measures been identified?

Since RAP documents often become rather dated, the schedule for implementation is denoted by a high, medium or low priority rather than by year. This adaptive approach appears to have proven quite workable. Responsible agencies or persons are clearly outlined.

Has an ecosystem approach been taken to the restoration and protection of beneficial uses?

The Stage 2 RAP document indicates a clear commitment to an ecosystem approach to the restoration and protection of beneficial uses. In particular, the matrix detailed in Table 6-1 outlines the influence of 53 water quality-related activities on the 14 potential use impairments.

Was the public consulted adequately?

The WQMAC, which has existed in some form for over 20 years, was the principal means of achieving adequate public consultation during the RAP process. Through its monthly meetings, the WQMAC has performed in an exemplary manner to assist the Monroe County Health Department toward the goal of a desirable level of public consultation.

Conclusion

The Monroe County Health Department is responsible for an outstanding example of a Stage 2 RAP. In particular, this document which are prepared in cooperation with the WQMAC outlines an impressive evaluation of proposed remedial measures. This evaluation in conjunction with the ranking mechanism used in selected remedial measures will provide a solid foundation for future RAP-related decision making. The New York State Department of Environmental Conservation is commended for its effective delegation of RAP development to county government. This empowerment of local government helps to ensure the interest and involvement of local citizens.