University of New Hampshire
IN-50: Innovation D

UNH is part of an innovative partnership with a dozen neighboring communities working towards a collective goal to limit the pollution to the Great Bay Estuary. The partnership has been many years in the making, and has been developed thanks in part to research, advocacy and operational collaboration from UNH faculty, staff and students. This is new approach to environmental permitting and regulation, and to collaborative nitrogen management, will not only significantly reduce pollution in Great Bay Estuary, but has the potential to become a powerful new tool for the USEPA in regulating nitrogen pollution beyond New Hampshire.
In late 2020, the United States Environmental Protection Agency issued a Great Bay Total Nitrogen General Permit for Wastewater Facilities in New Hampshire for 13 eligible wastewater treatment facilities (WWTFs), including the facility owned and operated by the Town of Durham. (UNH, while not the operator of the facility, partners closely with the Town to meet permitting regulations.) The General Permit became effective beginning on February 1, 2021.
The General Permit establishes total nitrogen effluent limitations, monitoring requirements, reporting requirements and standard conditions. USEPA developed the General Permit, as part of an Adaptive Management Framework (AMF), to comprehensively regulate nitrogen loading from the 13 WWTFs on a watershed-wide scale. The General Permit also incorporates an innovative and adaptive approach to achieve reductions in total nitrogen loads to the Great Bay estuary through a combination of mandatory load limits at the WWTFs and voluntary nonpoint source nitrogen reductions. This approach is similarly based in part on work done collaboratively between UNH and the Town of Durham; in 2014 we developed the Oyster River Integrated Watershed Plan for Nitrogen Load Reductions, which sought to develop a more cost-effective and sustainable means to meet future permitting compliance needs and improve water quality in the Oyster River watershed, and ultimately the Great Bay, through an Integrated Permitting approach. The approach provided implementation strategies that balanced upgrades to the WWTF with nonpoint and point source stormwater control measures in an effort to reduce existing and future nitrogen loads to the Oyster River estuary and achieve other water quality objectives. These are now part of the General Permit.
The General Permit is only one aspect of the AMF; other elements include ambient monitoring, pollution tracking, reduction planning, and review. Implementing an adaptive management approach includes collaboration among USEPA, the State of New Hampshire, and public and private stakeholders like UNH. The collaboration entails participation in the following:
• Monitoring ambient water quality in the Great Bay
• Tracking loads of total nitrogen
• Planning for overall source reductions
• Evaluating a load-based threshold, 0.32 milligrams per liter (mg/L) instream total nitrogen criterion, or other threshold for demonstrating attainment of water quality standards
• Establishing a timeline for completing a total nitrogen total maximum daily load (TMDL) for the Great Bay.
UNH and the Town of Durham are partnering on this work; we’ve developed and jointly submitted a new AMF Proposal to the EPA, describing the steps, activities, and measures that the Town and UNH will take to improve water quality from nonpoint sources into Great Bay from the town during the General Permit term. This proposal will be a living document that will be reviewed, updated and/or modified (as needed) annually to reflect the current understanding of the Great Bay and the progress made by the Town, UNH and other relevant parties. The updates and modifications will be informed based upon the outcomes from implementing the efforts outlined in this proposal and collaborating with the other seacoast communities and key stakeholders.