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CLEAN UP CAYUGA LAKE NOW.

Honorable Andrew M. Cuomo
Governor, State of New York
The Capitol
Albany, NY 12224

Dear Governor Cuomo:

We, the undersigned, write to request that you take immediate action to eliminate massive water quality impairments in Southern Cayuga Lake caused by excessive phosphorus and turbidity that New York State has failed to remedy for more than 50 years.

This matter warrants your urgent attention. Not only has your Department of Environmental Conservation (DEC) failed to clean up Cayuga Lake's long-standing pollution problems, it actually made them far worse by improperly granting a 1998 discharge permit to Cornell University's Lake Source Cooling facility in clear violation of the Clean Water Act.

As you will see from the information that we are providing for your review, water quality impairments are worse than ever in Southern Cayuga Lake. The problems are so widespread and extreme that the impacts could be irreparable.

Cayuga Lake Listed in the National Impaired Waterbody Registry

In 1998, the southern 5,000 acres of Cayuga Lake were listed in the national 303(d) impaired waterbody registry due to excessive phosphorus and turbidity. Phosphorus promotes the growth of algae and weeds. Turbidity is suspended solid material. High bacteria levels were later identified as an additional impairment.

These pollution problems are why public bathing has been prohibited for nearly a half-century along the southern shore of Cayuga Lake at Stewart Park.

Lake Source Cooling’s Discharge Permit Granted Improperly

In 1998, your Department of Environmental Conservation (DEC) granted Cornell’s Lake Source Cooling facility a discharge permit that violated a key provision of the Clean Water Act which prohibits issuance of discharge permits that contribute to the violation of water quality standards. This permit allowed Lake Source Cooling to discharge phosphorus into an area of Cayuga Lake that already had excessive phosphorus levels.

Water Pollution Documented to Have Grown Worse Since LSC Began Operation

Since LSC began discharging phosphorus into Cayuga Lake, Cornell's regulatory compliance monitoring demonstrates that a key measure of algal biomass called chlorophyll a has increased up to more than 50% over an area of approximately 6,000 acres.

Cornell’s own Before-After-Control-Impact study documented a statistically significant correlation between the operation of Lake Source Cooling and the increase of chlorophyll a at Site 7, the site in the most impaired area of the Southern Lake, compared with the control Site 4.

That determination requires the Lake Source Cooling Discharge to be moved off the shallow “shelf” of Southern Cayuga Lake or treated to remove phosphorus.

Request for Immediate Action

Despite all this documentation, DEC has done nothing to clean up Southern Cayuga Lake’s worsening pollution problems. It failed to require LSC’s discharge pipe to be moved or for its wastewater to be treated. It failed to propose or adopt a Total Maximum Daily Load (TMDL) comprehensive clean up plan required as a "high priority" by 2004. It even allowed LSC’s discharge permit to lapse in 2008.

Against that background, we ask that you fulfill the following requests:

First, DEC must require Lake Source Cooling's effluent discharge to be treated using Best Available Technology or moved "off the shelf."

Second, DEC should permit an alternative solution of converting the "once-through, non-contact" cooling water discharge to a "closed-loop" system that would eliminate any transfer of SRP from the bottom of Southern Cayuga Lake to shallower areas. This would constitute an ideal resolution to the current Lake Source Cooling nutrient-loading problem.

Third, DEC must tolerate no further delay in issuing a renewal of the Lake Source Cooling discharge permit in order to implement the provisions referenced above.

Fourth, DEC must require a Total Maximum Daily Load clean up plan to be proposed and implemented within one year. Any further delay in this matter must not be tolerated.

Fifth, DEC must reject any proposal that allows Cornell University to delay enforcement of its Lake Source Cooling permit or play any role in preparing a proposed TMDL. Either action would clearly pose an unacceptable conflict of interest.

Finally, we request that you make a public commitment to permit public bathing at Stewart Park by 2015.

Very truly yours,

Click Here to See Signatures

Learn More About Cayuga Lake’s Water Pollution Problems. Click here to see maps and photos documenting algae and weed problems: http://toxicstargeting.com/sites/default/files/pdfs/LSC_120515.pdf


This circa 2000 photo documents that after Lake Source Cooling began operation, an algae and weed infestation spread from a relatively confined area immediately west of the Cayuga Heights sewage treatment plant approximately 800 feet south to the shoreline of Stewart Park and west across the entire lake. Many residents of that area cannot even launch their boats due to the algae and weed infestations.

See: http://toxicstargeting.com/sites/default/files/pdfs/LakeSourceCooling_12...






BACI Findings

Cornell was required to provide a Before-After-Control-Impact study to determine if LSC had made existing water quality impairments worse in the area of Cayuga Lake with the worst algae and weed problems: Site 7.

That study demonstrated a statistically significant correlation (p-value

Table 6. Results from Welch t-tests comparing log-transformed chlorophyll a for the pre startup (7/9/98 – 6/29/00) and post start-up (7/6/00 – 10/24/05) intervals for the selected impact-control pairs. The 8 outliers identified in Table 2 have been omitted from this analysis. Standard deviation is abbreviated Sd. Standard deviation is abbreviated Sd. Raw p-values, Bonferroni-adjusted p-values, and Benjamini & Hochberg (1995) adjusted p-values (B&H) are presented. Effect size represents the percent change in chlorophyll a at the impact site relative to the control site.

Table 6. Results from Welch t-tests comparing log-transformed chlorophyll a for the pre startup (7/9/98 – 6/29/00) and post start-up (7/6/00 – 10/24/05) intervals for the selected impact-control pairs. The 8 outliers identified in Table 2 have been omitted from this analysis. Standard deviation is abbreviated Sd. Standard deviation is abbreviated Sd. Raw p-values, Bonferroni-adjusted p-values, and Benjamini & Hochberg (1995) adjusted p-values (B&H) are presented. Effect size represents the percent change in chlorophyll a at the impact site relative to the control site.

[SOURCE: “A Before-After-Control-Impact Analysis for Cornell University’s Lake Source Cooling Facility.” 2008. Prepared by Upstate Freshwater Institute, Syracuse, NY. Sponsored by Cornell University.]

Lake Source Cooling: 

Total Signatory Count: 93