Keuka Lake Association

― KEUKA LAKE WATERSHED PROTECTION PLAN - FINDINGS & RECOMMENDATIONS ―

Introduction

An old saying, "We are all part of the problem and all part of the solution", is an appropriate first-principle for individuals and communities interested in protecting the watershed. All lands and activities in the watershed will have either a positive or negative impact on water quality. Most activities do not individually harm groundwater, streams or the lake. Taking a look at the big picture or watershed, these small individual sources added together may indeed cause problems. For example, one poorly operating onsite wastewater (septic) system may not pollute the whole lake, but hundreds together, along with other sources such as runoff from unstable roadbanks and/or over-fertilized lawns or agricultural fields, may lead to unsightly, unsafe water or algae blooms.

In this section of the report, the intent of the research was to determine the potential impacts of all land uses and activities in the watershed. The researchers used a variety of standard survey and field methods for evaluating each source. For each evaluation, the goal was to screen the entire watershed and, if possible, identify priority areas. To accomplish this task, the watershed was divided up into 29 smaller drainage areas or subwatersheds, where pollution potential could be compared based on pollution loading potential.

The results of the research are are summarized here and include a description of the situation, analysis and recommendations. Each section includes an interpretive watershed map highlighting the areas of greatest potential concern for that particular source of pollution. In some cases, such as recreation and residential, a map was not an appropriate method to convey the findings.

Finally, it should be noted that much has been accomplished in the watershed directly as a result of working on and completing this report. Many of the recommendations have already been implemented and nearly one million dollars in state and federal grants have been secured to date for this purpose, primarily for agriculture, road bank stabilization and salt storage facilities. Those programs that have already begun will be highlighted to illustrate the positive contributions made by organizations and individuals.

Many of the recommendations relate education, continuing research and developing watershed wide programs. For a number of these recommendations the Keuka Lake Association has stepped forward to spearhead the effort. A committee representing the Association has reviewed these recommendations and has set priorities and established timelines to move forward.

Other cooperating organizations will be called upon to review and determine if they have the resources to implement the remaining recommendations. The success of this plan will depend on the continued active involvement, cooperation and commitment made to protect and enhance this resource.

AGRICULTURE

SITUATION

Agriculture employs 34,300 acres or 34% of the land within the Keuka Lake watershed. Farming and related industries, such as wineries, offer tremendous benefits to the area, providing jobs, taxes and tourist revenues for local communities. Agricultural lands preserve open space, protect water quality and add to the unique scenic beauty of the area.

The estimated 365 farms in the watershed include a wide variety of agriculture: 37% have livestock; 40% of cropland is devoted to hay; 24% to vineyards or orchards; 20% to corn; 13% to small grains and 3 % to vegetables and other fruit. The amount of farm land has grown recently, largely as a result of an increase in family dairy farms in the northern part of the watershed.

ANALYSIS

To assess the potential pollution impact from agriculture, the Yates and Steuben County Soil and Water Conservation Districts sent a written survey to all watershed farmers. Data from the survey was used to develop a matrix of twelve "pollution potential factors." Statistical analysis ranked the potential impact of each factor. Combining them gives an overall picture of potential pollution for the entire watershed, and for each subwatershed or direct drainage area.

In addition to the survey, computer modeling was used to estimate the potential loading of sediment and nutrients reaching the lake from agricultural activities. Sediment is a major water pollutant and also serves as a transport medium for other pollutants such as pesticides and nutrients from fertilizers or animal waste.

Combining these two analytical methods provided a clearer picture of the potential impact of agricultural activity in the watershed. These results revealed low potential agricultural loading in twelve subwatersheds or drainage areas. Nine areas showed moderate potential for agricultural pollution. A high risk for agricultural pollution was identified in eight subwatersheds, containing almost 20,000 acres of farm land. Intensive cropping operations and high concentrations of animals, with associated manure management issues, predominate in these watersheds. Farm planning and implementation activities should target these areas first.

POLLUTION PREVENTION ACTIONS

Goal:

To reduce the impact of agricultural sources of sediment and nutrients on the water resources of the Keuka Lake watershed.

Existing Measures:

Highly Erodable Lands (HEL):To receive United States Department of Agriculture benefits, farmers must comply with conservation practices on both highly erodable land and wetlands.
Environmental Quality Incentives Program (EQIP): This USDA program provides financial assistance to enable farmers in priority watersheds to adopt soil and water conservation practices that would otherwise be beyond their economic means. To date, more than $1 million has been spent to help area farmers implement a wide variety of conservation practices, ranging from controlling soil erosion to reducing pesticide and fertilizer use.

Recommended Measures:

Agricultural Environmental Management (AEM): AEM is voluntary program that supports the overall watershed planning process. AEM provides technical assistance to help farmers plan, carry out and document environmental protection programs. The program is strictly voluntary and relies upon strong involvement by individual operators. Initially, AEM will target the eight priority subwatersheds which have the highest pollution potential.

DEVELOPMENT

SITUATION

Development makes up about 2.3% of the total acreage in the Keuka Lake Watershed. Most development is residential, consisting almost entirely of single-family homes. Approximately 40-50 new homes are built in the watershed annually. Thus the impact of "development" in the watershed is the sum of numerous individually-constructed, detached, single-family homes. Development is especially concentrated within a dense band along the lakeshore (Figure 7-??).

Studies show that "high-density residential development" produces more nutrients and contaminants per acre than properly managed agricultural land. Sources of pollution from development include failing septic systems, stormwater runoff from roofs and driveways, erosion and sedimentation during and after construction of homes and driveways, improper lawn care practices and potential pollutants associated with private docks.

Construction activities can also cause the release of nutrients, organic matter and toxic substances. In addition, activities associated with development create sources of pollutants (e.g., automobile emissions, atmospheric pollutants, lawn and garden chemicals, litter, etc.) which, when transported by surface runoff, can lead to water quality problems. The impact of construction on lakefront sites is often further heightened by steep slopes, poor soils and large homes on small lots.

ANALYSIS

Zoning: All municipalities in the Keuka Lake watershed have zoning ordinances that regulate land use. The Towns of Potter, Pulteney, Urbana and the Village of Hammondsport have subdivision regulations that address some issues of site planning for multi-lot developments. These Towns also have site plan review laws: however, these only apply to commercial, industrial, or Special Permit uses. No municipality in the watershed has laws regulating the construction of single-family homes to protect water quality. While development pressures in the watershed are limited, the current zoning flexibility does create the potential for undesired growth.

Stormwater management & erosion control: Both the quantity and quality of stormwater runoff can be significantly affected by land development. Construction activities alter natural vegetation allowing soil erosion and may alter natural drainage patterns. Roofs and driveways may increase runoff and decrease the soil area available to soak up water. The proximity of development to the lake or a tributary greatly increases the potential impact. With no local erosion and sedimentation control laws in place, preventative measures depend almost entirely on voluntary compliance with best management practices from homeowners or contractors.

Development trends: A study of building permit data projects a continued slow rate of development in the watershed, with no drastic changes in population or land use expected in the near future. However, there are noticeable concentrations of new construction on the east shore of the east branch of the lake and at the western tip of the Bluff. In these areas, various combinations of steep slopes, poor drainage, and shallow soils create significant pollution potential. Such developments may need to be more closely monitored by local governments.

POLLUTION PREVENTION ACTIONS

Goal:

To minimize the potential impacts to water quality from new construction.

Existing Measures:

NYSDEC law regulates construction activities that disturb more than five acres.
State Environmental Quality Review (SEQR) is conducted for development that exceeds certain standards (i.e., structures greater than 4,000 SF) or those involving special permits or variances. SEQR does consider impacts to water quality. However, construction of single family homes - the majority of development in the watershed does not require an environmental assessment.

Recommended Measures:

Review all existing municipal land use regulations (i.e., comprehensive plans, zoning codes, subdivision regulations, site plan review), as well as their implementation and enforcement, for adequacy in minimizing the impacts to water quality from development.
- Lead Agency: Yates County Planning Department Costs: $4,500 Source: Grants
Educate local decision makers through a series of training seminars for legislative, planning and zoning boards, as well as Code Enforcement Officers and Highway Superintendents, about the use of recognized development Best Management Practices (BMPs) to protect water quality.
- Lead Agency: Yates County Planning Department Costs: $1,000 Source: In Kind
Develop a model uniform Stormwater/erosion and Sedimentation Control law that can be demonstrated and implemented by all municipalities in the watershed. This code should consider the impacts of single family construction. - Lead Agency: Yates County Planning Department Costs: $10,000 Source: In Kind

FOREST RESOURCES

SITUATION

Forests now occupy 54,600 acres (54%) of watershed land. This acreage is almost entirely privately owned. The only public tract, the Urbana State Forest, encompasses about 2,200 acres.

Economic value: Hardwood lumber is the major forest product in the watershed. Although no major forest product companies are located within the watershed, there are good markets for the timber locally. While a precise assessment is difficult, the estimated volume of timber within the watershed is approximately 155 million board feet. Assuming an average value of $150 per thousand board feet, this watershed timber yield has a potential value of $23 million.

Benefits to Water Quality: In addition to their economic value, forest lands provide a great deal of protection to our streams and lakes by hindering the erosive forces of rainfall and runoff. Trees intercept rainfall, while leaf litter and humus protect the soil surface from erosion. Forest buffer zones along stream corridors and lakes reduce the amount of sediment and nutrients reaching these waters. Many of the steep lands within the watershed have reverted back to forest cover. This may be the best use of these lands for the protection of water resources.

ANALYSIS

Timber harvesting is an integral part of managing forest lands. Without the periodic income from timber harvesting, many landowners would probably sell these lands for building lots or convert them to uses that might not be as desirable for water quality, wildlife and green space.

Most water quality concerns arise on forested lands during timber harvesting. Major areas of concern are the condition of landings, skid roads, skid trails and stream crossings. During harvesting, forest leaf litter is disturbed and soil is exposed, increasing the risk of erosion and sediment delivery to streams and the lake.

The responsibility for proper timber harvesting rests with both landowners and harvesters. Since timber harvesting is an infrequent event for most forest owners, the biggest challenge is to make sure owners have the necessary information or professional assistance to both protect the environment and maximize profits at the time of harvest. This has several benefits:

Provide an incentive to maintain lands in forest production by maximizing timber sale revenues.
Reduce the potential for pollution from timbering by ensuring the use of best management practices (BMP).
Increase the utilization of a renewable resource from non-industrial private forests.

POLLUTION PREVENTION ACTIONS

Goal:

To reduce the potential impacts of forest harvesting activities on water quality in the Keuka Lake Watershed.

Existing Measures:

NYS DEC provides direct forest management assistance and Best Management Practices advice to landowners. Similarly, timber harvesters should implement the DEC's Silvicultural Best Management Practices. These practices will protect forest, soil and water resources and should also prove to be a good business practice for timber harvesters.

Recommended Measures:

Encourage all forest landowners in the watershed to contact the following for initial timber harvesting advice:

Provide the following resource information in the Yates and Steuben Soil & Water Conservation District offices and promote its availability through such means as District newsletters:
- Forestry Workshop: hold a biannual educational workshop for watershed forest landowners. Workshops could be sponsored through DEC, SWCD's, CCE and NY Forest Owners' Assoc.
INACTIVE LANDFILLS AND DUMPS

SITUATION

There are no active, permitted landfills in the Keuka Lake watershed. There are ten identified inactive dumps and landfills and one major automotive junkyard., discussed in a previous section. One site - the Urbana Landfill - contains hazardous waste and represents a potential threat to public health. It is currently under DEC Class 2 remediation.

Two other landfills, Lakeshore (Hammondsport) and Hadey's (Urbana), may have received the same types of industrial waste. A fourth landfill, the Pulteney Town Dump, may be a contributor to the presence of DDT in the Wagener's Glen tributary.

While the other six landfills do not appear to pose a pollution threat, enough risk to health and water quality exists due to the presence of DDT in the Pulteney dump and the possibility of toxic pollution from the Lakeshore and Hadey landfills to justify continued concern.

ANALYSIS

Inactive landfills pose a potential human health risk from exposure to toxic and pathogenic contaminants, including heavy metals, pathogens, nutrients and a wide variety of organic chemicals. While pathogens and nutrients are generally not considered a major threat from landfills, heavy metals and organic chemicals can remain toxic for years.

In recent years, there has been a growing recognition by the public and elected officials that inactive landfills are a potential threat to human health and water quality. Since remediating a landfill is an expensive process and money available from federal and state sources is limited, it is necessary to rank the landfills in the watershed to determine how best to allocate available funding.

Using a variety of rating factors, such as level and toxicity of contaminant generation, the likelihood of contaminant transport in water and the significance of the receiving waterbody, the Keuka Lake Looking Ahead report ranks each landfill in terms of its risk to both surface and groundwater quality.

These rankings suggest that further study is needed to assess the pollution potential of the landfills not currently under remediation (all except the Urbana hazardous waste site). A low-cost, logical next step is to physically observe the sites and obtain more detailed information on land cover, depth to bedrock, private well locations, historical waste disposal practices, and water quality monitoring. The Urbana, Lakeshore and Pulteney landfills have been walked and physically evaluated. Hadey's junkyard (F), Hammondsport (J), Reservoir Hill (E), and the Wayne landfill (B) could be investigated next. The remaining dumps are the lowest priority based on this ranking.

POLLUTION PREVENTION ACTIONS

Goal:
Existing Measures:
- Survey landfills for KLLA project (completed).
- Ongoing engineering study and remediation activity by DEC for the Urbana landfill.
Recommended Measures:
- Conduct a preliminary study to determine the location of each landfill, its dates of operation, the type of materials disposed at each and the vulnerability of water resources .
- Conduct designated surface water quality tests as needed.
- Conduct an intensive groundwater study of targeted sites to determine leachate characteristics and measure the impact of leachate on water quality and public health.
- An engineering study may be needed to develop recommendations for properly closing and securing sites.
- Grant proposals may need to be written to secure funds from the NYS Environmental Protection Fund to work on this project. Other options include municipal sponsorship or DEC grants.
- Public educational materials should be developed to describe landfill issues, such as the difference between old and new types of landfills, threats to public health and water quality, and the need to ensure that sites are closed properly.
MINED LANDS

SITUATION

Because of its bedrock and glacial geology, there are only sand and gravel mining operations in the Keuka Lake watershed. Nine sand and gravel mines are currently operating in the watershed under permits from NYS DEC. Numerous other mine sites are inactive or operate beneath the level of activity requiring permits (generally 1000 tons removed per year).

Permitted mines are required to have reclamation plans and performance bonds. Operating permits include specifications for the protection of adjacent surface and groundwater. The NYS DEC permitted mines are in varying stages of excavation. Three are inactive, six are active, and one permit has expired with reclamation not approved.

Many gravel pits in the watershed were operated and abandoned before the permit system was started. Such inactive, non-permitted and poorly regulated mines may pollute surface and groundwater. Unrestricted runoff from bare mine banks may carry significant sediment loadings. Once bare, mine banks are difficult to revegetate and can remain a problem for decades.

ANALYSIS

Even with the current permit system, plans for reclamation of mines have not provided sufficient bonding to cover the cost of reclamation. Many mine owners have abandoned their mines and bonds, and the State has seldom used the forfeited bonds for proper closure and reclamation.

There are an estimated 27 abandoned, non-closed gravel pits, including 6 large abandoned mines, in the Keuka Lake watershed. Non-reclaimed mines can cause several problems:
- First, they are a direct public safety hazard. Caving banks, steep slopes and unmarked cliffs have led to numerous tragedies.
- Second, uncontrolled runoff from the steep and unvegetated banks of gravel pits contributes large quantities of sediment to adjacent streams and other water bodies.
- Third, unsecured and abandoned gravel pits are seen by some as good, cheap places to dump waste. Rising disposal costs will likely aggravate this problem. Unfortunately, the porous nature of the soils underlying gravel pits practically ensures infiltration of pollutants into groundwater and, ultimately, neighboring wells.
- Unpermitted pits will only be addressed by the NYS DEC Bureau of Minerals under two conditions: 1) if there is a contravention of New York State water quality standards or, 2) if a previously unpermitted pit is re-opened to mining in quantities of over one thousand cubic yards per year. Citizens living in the vicinity of these pits who wish to see them reclaimed should monitor activity in the mines. Documented surface water quality problems from runoff, renewed mining activity, or well-water test results indicating illegal dumping may trigger regulatory action
POLLUTION PREVENTION ACTIONS

Goal:
Existing Measures:
- State law specifies the role of local governments in reviewing and regulating mining activity. Specifically, local governments enforce zoning laws and specify conditions relating to mine roads and haul roads. In addition, local ordinances may regulate aspects of mining or mine reclamation that are not regulated by the state. Local governments are also empowered to enforce the special conditions and reclamation requirements listed in NYS DEC mining permits.
Recommended Measures:
- Inventory unpermitted mines in the watershed; prioritize and rank mines for potential to pollute surface or groundwater.
- Share information on permitted mines with regulatory officials.
- Contact owners of mines regarding reclamation.
- Inform local governments of their right to regulate mines.
- Close access to abandoned mines.
- Reclaim polluting, abandoned mines.
RECREATION

SITUATION

Keuka Lake and its watershed provide a diversity of outdoor recreation opportunities. The Finger Lakes Association estimates that water-based recreation produces $15 million in local revenues annually, nearly $5 million from fishing alone. A 1997 survey of members of the Keuka Lake Association identifies a number of important environmental and quality of life issues, including concerns about Personal Watercraft (PWC) and motorboat activity, shoreline modification and erosion, spills and boat waste, and fuel and oil pollution of the lake.

ANALYSIS

Motorized boating: To enthusiasts and the local economy, the benefits of power boating are tremendous. But they do come with a cost. Concerns over fuel spillage, exhaust, noise, sediment pollution from wave action, conflicts with other recreational pursuits, safety, visual impacts and poor sanitation (human or fish waste and boating debris) raise issues that need to be addressed in the watershed management plan .
- Fuel Losses: Based on current testing programs, fish populations and tissue health, water clarity and algae levels, and drinking water supplies do not indicate problems related to motorboat fuel losses. However, to date no studies have been done examining the potential impact of all fuel combustion by-products, including several known carcinogenic and mutagenic substances, so the true impact of fuel losses is unknown at this point.
- Spills and boat waste: Since the cumulative impact of fuel or oil spills may be long-lived and significant, it is reasonable to be concerned about the prospect of spills polluting wetlands, streams, aquifers and the lake itself. Floating waste has not been noticed as a significant problem on Keuka. However, there is only one pumpout facility for marine waste holding tanks and portable toilets on the lake, located at the NYS Park in Branchport.
Shoreline modification and erosion: Some owners of lakeshore property have constructed retaining walls, either under DEC permits or before permits were required. The result has been the reduction of natural wetland and littoral ecosystems. Among other problems, this increases flooding and erosion by reducing the shoreline's ability to contain extra water from minor floods.

Conflicting uses: Conflict between boaters, PWC users and people who want to enjoy solitude or other passive forms of recreation is a primary concern for many residents surveyed by the KLA. This inherent conflict between more active uses (PWCs) and more passive ones (enjoying the view) is exacerbated by high volumes of boat traffic or special events like boat races.

Personal watercraft-jetskis: PWCs have become the most exciting, dangerous, popular and unpopular watercraft to splash the market in years. The KLA survey found PWCs to be the #1 concern threatening other recreational pursuits. PWC safety issues are also a great concern, particularly in light of the power and speed of the craft.

POLLUTION PREVENTION ACTIONS

Goal:
Existing Measures:
- Keuka Lake has special laws governing boat speed and noise. Day, night and nearshore speeds are regulated. The Yates and Steuben Sheriffs operate full-time summer boat patrols on the lake to enforce these and other ordinances regulating littering, water safety, PWC operation and requirements for sealed heads on boats.
Recommended Measures:
- Increase education for all boaters, old as well as young, on Keuka Lake.
- Increase enforcement of existing navigation laws.
- Increase statewide enforcement for boating violations. Work with other lake associations, law enforcement agencies and local legislatures to develop an effective strategy.
- Reexamine boat speed regulations for operating near shore (200') and during high water levels.
- Add more public rest rooms and pumpout stations on the lake.
- Promote signage for all houses/docks on the lake.
- Examine and recommend a strategy for dock and mooring issues.
- Increase public review and communication for special boating events, such as races.
- Examine and recommend a strategy for increasing keep back requirements from bathing areas for all boats (currently 500' for jetskis and 200' for other motorized craft).
- Increase education on the importance and protection of the littoral zone.
- Minimize impacts of sedimentation and nutrients on the lake to protect recreation uses and benefits.
- Promote tourism and recreation with cooperating organizations consistent with protecting the health of the lake.
RESIDENTIAL LAND USE

SITUATION

To collect information on fertilizer and pesticide use by homeowners, the Yates County Soil and Water Conservation District conducted a survey of over 800 members of the Keuka Lake Association. The survey, which also included sections on yard waste disposal and drinking water sources, produced a number of useful findings:
- 57% of respondents used fertilizers for lakeshore lawns, gardens and ornamentals.
- The majority manage yard waste by leaving it on the lawn, composting or mulching.
- 47% of respondents use pesticides at their lakeshore residence, primarily for weed control and garden insect management. Of these:
  - 58% of survey respondents listed the lake as their primary drinking water source. Of these:
    - 15% of respondents get their drinking water from wells or municipal sources. 27% purchase bottled water or bring water from a permanent residence .
    - 86% of the respondents with unwanted pesticides would like a pesticide collection day.
    ANALYSIS
    
    Most Keuka Lake residents are using pesticides and fertilizers responsibly. However, 85% of lakeshore residences are within 200 feet of the lake, a critical area where improper practices or poor timing can have an immediate and significant impact.
    
    Fertilizers and pesticides are used on about half of lakeshore properties, creating a significant potential pollution source. To minimize possible runoff, fertilizer applications should not be made when the ground is frozen, the grass is dormant or when heavy rains are expected. Soil testing should be used along with label recommendations to minimize excessive application of fertilizers.
    
    Seventy percent of yard waste materials are managed properly by composting, leaving on the lawn or mulching. Education is still needed to reach the 30% who are landfilling, burning or depositing yard waste on streambanks. Both of the last two directly impact lake water quality.
    
    Fifty percent of pesticide users would like to have a pesticide collection day to dispose of unused pesticides. Presently, a fish consumption advisory is in effect on Keuka Lake due to accumulations of toxins in fish. Removing excess, banned or unusable pesticides such as DDT from the watershed benefits and protects the water supply.
    
    Fifty-eight percent of the lakeshore residents use the lake as their drinking water source. Of these, 49% use pesticides and 39% use fertilizers. Since drinking water is the prime and best use of the lake, these chemicals should be used carefully and judiciously.
    
    Information on the environmental impact of lawn fertilizers and pesticides needs to be made widely available and repeated regularly. Articles in the KLA newsletter, newspapers, public forums, and special homeowner publications, including the Keuka Lake Book, are promising education options.
    
    POLLUTION PREVENTION ACTIONS
    
    Goal:
  - Existing Measures:
    - The primary pesticides found in Keuka Lake fish tissue (including DDT) are banned in the US but are highly persistent in the environment.
    - Cornell Cooperative Extension offers numerous publications and resource materials concerning pest management around the home.
    - County extension agents are available to offer recommendations for homeowner problems.
  - Recommended Measures:
    - Promote pesticide awareness through pamphlet distribution, media publications and workshops.
    - Establish a household hazardous wastes and pesticide collection facility or periodically hold collection days for the agricultural community and homeowners.
    - Require stormwater controls in all new developments, including capture and treatment of initial storm runoff.
    - Work cooperatively with lawn and tree care companies to promote Integrated Pest management (IPM) programs for homeowners. Enact IPM standards to protect watershed soil and water resources.
    - Offer on-site lawn care consultation through Cornell Cooperative Extension.
      - POLLUTION PREVENTION ACTION
    ROADBANK EROSION
    
    SITUATION
    
    The erosive potential of an area is based on many factors, including the erodability of the soil, land use, slope, concentration of flows, and length of slope. Roads exacerbate several of these factors. Roads must rapidly spill water collected on their surfaces. Road ditches often collect water that would otherwise seep into the ground or leave the area in small streams. Once collected, the water has much more energy to erode soil. Ditches are graded to convey water to centrally located culverts, which makes flows more turbulent and erosive. With close to 400 miles of public and private roads in the watershed, road and ditch erosion constitute a significant source of potential pollution.
    
    ANALYSIS
    
    The Keuka Lake Foundation, Inc. and the Yates County Water Resources Alliance sponsored a detailed survey of all public roads in the Keuka watershed. Estimates of erosion losses were calculated for each road. For roads on steep slopes, erosion was categorized as moderate, severe, and very severe.
    - A "very severe" designation implies estimated soil losses in the range of 82 tons per mile.
    - "Severe" conditions imply estimated soil losses of 33 tons per mile.
    - "Moderate" conditions imply estimated soil losses of 16.4 tons per mile or less.
    - In calculating sediment loading from road ditch sources, a base figure of 8.2 tons per mile was used for all roads not designated as moderate, severe, or very severe.
    - POLLUTION PREVENTION ACTION
    This survey found that of 381 miles of public roads the watershed, approximately 66 miles have moderate erosion potential, 36 miles have severe erosion potential, and 24 miles have very severe erosion. A conservative estimate puts total road erosion at over 6300 tons of sediments per year.
    
    The overall ratings of the subwatersheds and direct drainages are illustrated in Figure 7-??. Subwatershed and direct drainage rankings were determined by comparing miles of very severe erosion, total tons of erosion and average tons per mile of erosion.
  - Goal:
  - Existing Measures:
    - Cornell Local Roads Program: Provides highway superintendents with technical training in cost-effective, environmentally smart road maintenance and construction.
    - Existing Regulations: NYS DEC, DOT and local laws establish responsibilities for erosion control and stormwater management but often fail to address special conditions and problems.
    - Town Highway Superintendents Road and Water Quality Handbook: Provided to highway officials to help guide road construction and maintenance decisions.
  - Recommended Measures:
    - Increase use of Cornell Local Roads Program training by highway officials.
    - Organize local training programs through SWCD and the highway superintendents association. SWCD can also provide technical assistance for erosion control and stormwater management.
    - Include erosion and sediment control standards in all highway construction and maintenance plans, bids and contracts.
    - Require timely re-vegetation of road ditches and banks.
    - Require structural measures to control sediments and other pollutants from stormwater runoff.
    - Establish and enforce site and construction standards and erosion control measures for private roads.
    - Extend town laws for erosion and sediment control to include most highway practices.
    - When permits are required for protection of waters, wetlands, etc., assign responsibility for application and enforcement to highway superintendents, not contractors.
    ON-SITE WASTEWATER TREATMENT
    
    SITUATION
    
    On-going water quality monitoring confirms the potential for contamination of drinking water supplies by septic system discharges. Fecal coliform bacteria counts in Keuka Lake have exceeded or nearly exceeded established maximum acceptable levels during certain times of the year and in certain locations around the lake. As might be expected, the bacteriological contamination in Keuka Lake is greatest at the peak of the summer recreational season, when the lakefront population and water-based recreation is greatest.
    
    In several areas within the watershed, soil conditions make the design and construction of effective on-site wastewater treatment systems difficult. (Figure 7-??) These locations include the hamlets of Pulteney and Branchport, the southern perimeter of Keuka Lake and the village of Hammondsport. This constitutes a drag on development and improvement of properties in those areas. Improved wastewater treatment treatment facilities would dramatically improve opportunities for growth and development in these locations.
    
    ANALYSIS
    
    On-site wastewater septic systems are the one nonpoint source of pollution for which an organized watershed-wide remediation and management program currently exists. In the 1980's this program began with lake water testing for the presence of fecal coliform bacteria. The testing program continues today, sponsored by the Keuka Lake Association in cooperation with the Yates County Soil and Water Conservation District, Cornell Cooperative Extension-Yates County, and the towns and villages bordering the lake.
    
    In 1993, the Keuka Watershed Improvement Cooperative (KWIC) was formed by Barrington, Hammondsport, Jerusalem, Milo, Penn Yan, Pulteney, Urbana and Wayne to oversee a newly adopted wastewater law and consider other threats to Keuka Lake as they may arise. The municipalities also agreed to uniformly enforce and implement the wastewater law.
    
    Recognizing that the highest and best use of the lake is to supply public and private drinking water, the purpose of the uniform law is preservation of surface and groundwater quality and protection of public health. To this end, it requires a permit for construction or alteration of any on-site septic system not already subject to continuous review by the NYS Departments of Health and Environmental Conservation.
    
    Septic system inspections and approvals are required for all systems in Zone One, "the critical water quality protection zone," consisting of all land within 200 feet of the lake or its major tributaries. Inspections are also required for all real property transfers, building permit applications requiring bedroom expansion and for high maintenance systems, such as aerobic treatment devices and holding tanks. The intent of the program is to identify and correct existing problem systems and enforce strict adherence to current design standards for new projects.
    
    POLLUTION PREVENTION ACTIONS
    
    Goal:
  - Existing Measures:
    - As a result of he KWIC program, the following measures are required by all municipalities in the watershed:
    - Recommended Measures:
      - Promote appropriate maintenance practices in all phases of program implementation.
      - Hold annual educational forums for contractors and others associated with septic system design and construction.
      - Identify and secure the resources necessary to meet the annual goal for Zone One and holding tank inspection program.
      - Continue monthly and annual reporting of program progress and monitor water quality status in Keuka Lake as documented in the annual monitoring report.
      - Develop and maintain a system to review and document interpretations of the state sanitary codes and their relationship with the uniform fire prevention and building code.
      - Encourage development of sanitary public and private water supplies.
      - Assist as appropriate in the development of public wastewater collection and treatment projects.
      - Develop more complete assessment of the wastewater treatment and water supply needs of problematic locales.
      STREAMBANK EROSION
      
      SITUATION
      
      Erosion of streambanks is one source of sediment loading into Keuka Lake. The 132 tributaries that enter Keuka Lake represent 308 miles of streams in the watershed. The Erosion and Sediment Inventory (EASI) conducted in 1974 by the USDA Soil Conservation Service estimated 157 miles of actively eroding streambank in the watershed. The estimated sediment contribution from the 157 miles of streambank averaged 78 tons of sediment yield/mile/year. The total sediment yield from streambanks was estimated to be 3% of the total for the watershed. Streambank erosion was also named a high priority nonpoint source pollution in the Water Quality Management Plan for Yates County, 1981. Keuka Lake, Big Gully, Sugar Creek and many unnamed tributaries were listed as impacted water resources from streambank erosion in the 1981 study. Current county water quality strategies for Yates and Steuben County also name streambank erosion as a high priority nonpoint source.
      
      ANALYSIS
      
      A study by the Yates County Soil and Water Conservation District developed an Erosion Potential Index for subwatersheds and direct drainage areas in the watershed. Based on the EPI, each source was rated as having a HIGH, MODERATE or LOW potential for erosion.
      
      To assist decision makers in prioritizing the need for remedial activities, the study also ranked the erosion potential of each subwatershed and drainage area.
      
      POLLUTION PREVENTION ACTIONS
      
      Goal:
    - Existing Measures:
      - A number of town, county and state highway departments have implemented streambank protection practices at road and culvert intersections. Additional streambank work away from the highways has been concentrated on Cold Brook and Mitchellsville Creek. Private landowners have also protected numerous streambank problem areas in both counties.
    - Recommended Measures:
      - Encourage the use of vegetative filter strips to protect stream corridors (NYSDEC, 1986).
      - Promote the installation of fencing to exclude livestock from streams (NYSDEC, 1986).
      - Diminish peak streamflows during storms through land use regulations, stormwater and erosion control ordinances (NYSDEC, 1992).
      - Develop educational programs on the protection of stream and shoreline areas.
      DEICING SALT
      
      SITUATION
      
      Salt, primarily sodium chloride, is used by area highway departments to help deice road surfaces during the colder months of the year. Each highway department has individual policies and procedures regarding salt application, salt/sand mixtures and storage.
      
      There are several environmental concerns regarding the use of deicing salts. After application, salts are highly soluble in water. They easily wash off pavement into surface waters and leach into soil and groundwater. High concentrations of salt can damage and kill vegetation, disrupt fish spawning in streams, reduce oxygen solubility in surface water, interfere with the chemical and physical characteristics of a lake, pollute groundwater making well water undrinkable, disintegrate pavement, and cause metal corrosion of bridges, cars and plumbing.
      
      Salt piles: There are five municipal salt storage pile sites within the Keuka Lake. All five are exposed directly to the weather. Two legislative activities related to the control of stormwater runoff from uncovered salt storage piles are being discussed: A proposed bill in the state legislature would require all salt storage piles to be covered. This would effectively eliminate one contributing source of pollution to Keuka Lake. The recently adopted federal stormwater management regulations may also apply to control of stormwater runoff from uncovered salt storage piles. NYS DEC is responsible for determining if these regulations apply to salt storage piles in the watershed it seems probable that they do.
      
      ANALYSIS
      
      In 1995, the Keuka Lake Association mailed a survey to highway departments in Yates and Steuben Counties regarding road salt use and storage. The response by the departments was very good, providing detailed information on total mileage maintained and total amount of salt used for the 1994-95 season. The departments were also asked for the locations of salt/mix piles and if they are exposed or covered. Policies and procedures used by each municipality and the State were surveyed.
      
      Road mileage within the watershed was estimated for each municipality to determine the amount of salt applied in the watershed and within each subwatershed by each department. Salt application rates by municipality varied from 2.48 - 7.29 tons/mile/year, averaging 5.22.
      
      The subwatershed data were compiled to show which have HIGH, MODERATE, or LOW application rates and which contribute HIGH, MODERATE or LOW amounts of salt to the watershed. The presence of exposed salt/mix pile(s) were also considered in the rankings.
    - POLLUTION PREVENTION ACTIONS
      
      Goal:
    - Existing Measures:
    - Recommended Measures:
    - Store salt and salt/mixes in permanently roofed structures, on an impermeable surface, a safe distance from water bodies, to avoid problems with runoff. Cornell Local Roads Program has information on constructing such a facility. A containment area for mixing and loading should also be developed to prevent runoff.
      - Municipalities should practice sensible salting, using only as much salt as necessary for public safety. In the 1980s, Farmington and Gorham implemented such a policy. It included increasing the percentage of sand in their mix from 1:1 to 3:1, doing more plowing and less salting, salting mainly intersections, and posting signs to inform drivers of the reduced salting policy. These practices reduced salt use by approximately 12-15%.
      - Additionally, salting equipment should be maintained in good condition to insure proper delivery and spreading rate. Highway departments should practice careful mixing and loading procedures to prevent spills. Departments should keep abreast of research and new technologies concerning deicing salt. Such information could be part of an educational program for highway personnel. A regular forum could be sponsored by the Cornell Local Roads Program and the Yates/Steuben County Highway Superintendent's Association.
      - Promote public awareness and education about safe winter driving. "Sensible salting requires sensible driving." Information distributed in Monroe County and in Farmington could be updated and printed at a minimal cost. Newspaper articles, ads and town and county newsletters to residents could also be used to disseminate the information.
      - Continue a regular survey of highway departments' salt use. This is a reasonable way to quantify how much salt is being applied to the watershed as part of the ongoing effort to monitor the health of the lake. Since the groundwork has been done as part of the first survey, future efforts will be minimal.
      - Monitor salt concentrations during winter runoff events for tributaries of concern. Although this is being treated as an independent option for the purposes of this report, it should be part of a comprehensive annual sampling and monitoring program.
      POINT SOURCE POLLUTION
      
      SITUATION
      
      Point sources are defined sites, such as a pipe discharging industrial wastewater, where pollutants are released into the environment. Because the source of the pollution is clear, point sources tend to be easier to identify and monitor than nonpoint source pollution. Existing laws and regulations allow the State of New York, municipalities, and local resource managers to identify and monitor current and potential point sources of pollution.
      
      State Pollutant Discharge Elimination System (SPDES) permits: The SPDES permit is a five year contract between the NYS DEC and any facility discharging wastewater directly into surface or groundwater. SPDES permits are divided into two categories: significant and non-significant.
      - SPDES permits for significant discharges cover release of large amounts of wastewater or wastewater which includes toxic substances. Permit holders must sample, analyze and report regularly to the DEC the amount of permit-controlled pollutants they discharge. The DEC inspects each permit facility on a yearly basis.
      - SPDES permits for non-significant discharges also require sampling and analysis, but do not require reporting to the DEC. The DEC does not inspect non-significant facilities when renewing permits. Data about non-significant SPDES permits is difficult to obtain.
      There are 27 significant SPDES permits within the watershed. Of these, 14 discharge to groundwater and 13 discharge to surface waters. Five discharge directly into Keuka Lake.
      
      Chemical and petroleum storage: NYS DEC regulations govern the sale, storage, and handling of these substances to prevent leaks and spills. Controls include: registration and inspection of storage and handling facilities; design, construction and operation standards; requirements for reporting leaks and spills and corrective action to be taken; and requirements for proper facility closure. The 46 petroleum bulk storage facility permits in the watershed cover 104 active petroleum storage tanks and 78 closed or removed tanks. Two facilities have permits for storing hazardous substances: Penn Yan Marine (propane) and Philips Lighting (ammonia, phosphoric acid, sodium hydroxide, and hydrochloric acid).
      
      Hazardous waste spills: 114 hazardous waste spills were identified by the DEC within the watershed since 1974. Petroleum products accounted for 95 of these. Significant spills include one spill of 4000 gallons of #2 Fuel by the Taylor Wine Company and spills of hydrogen chloride and muriatic acid reported between 1988 and 1992 by Phillips Lighting.
      
      The Cold Brook subwatershed, which includes part of Hammondsport, reported 43 spills, more than one third of all spills in the watershed. The Pulteney subwatershed reported nine spills; the Sugar Creek South subwatershed, which includes Branchport, reported eight; Grove Springs and East Bluff subwatersheds each reported seven spills.
      
      Hazardous waste sites: As of October 2004, there is one hazardous waste site in the Keuka Lake Watershed, the Urbana Landfill.
      - The Urbana Landfill, located within the Cold Brook Subwatershed, was leased as a town dump between 1968 and 1978. It was used for the disposal of household wastes and roughly 16,000 gallons of oil, solvents, and paint residue. The site was partially closed with an incomplete soil cover in 1979. Analysis of site groundwater, surface water, soil and air showed elevated levels of 1,2-dichloroethene, thichlorothine, vinyl chloride, phenol, and zinc. High levels of volatile organic compounds were found in adjacent tributaries, suggesting groundwater contamination. However, testing of adjacent wells showed no site-related contamination. In 1994 , NYS DEC reclassified the landfill as a Class 2 hazardous waste site, i.e., one that poses a "Significant threat to the public health or environment - action required."
      De-listed hazardous waste sites: Penn Yan Aero service was removed from the Registry of Inactive Hazardous Waste Sites in New York State by the NYSDEC in 2001.
      - Penn Yan Aero Service, Inc. is located south of the village of Penn Yan. From the mid 1960s until 1988, a drywell on the site was used for disposal of spent solvents. In 1988, a remedial investigation concluded that contamination at the site "could potentially impact groundwater quality." Wells below the site showed low-level concentrations of solvents. In 1996, the DEC accepted a remediation plan from the owner that consisted of removing a drywell and reducing contamination levels in the adjacent soil to acceptable levels. The site was excavated and soils were remediated according to the plan. Follow-up groundwater sampling showed no contaminants above drinking water standards. The site was deleted by the NYSDEC from the New York State Registry of Inactive Hazardous Waste Disposal Sites in 2001, noting "the NYSDEC concluded that this site has been properly remediated and that no further action is required."
      ANALYSIS
      
      While the SPDES permit system effectively regulates significant discharges of pollutants, controls on non-significant discharges are both less stringent and less transparent. Non-significant SPDES permits are renewed or extended administratively without DEC review. The actual condition and functioning of non-significant systems are not physically inspected at the time of permit renewal. Non-significant sampling data is kept by the facility owner and is not available to the public, nor is the data reviewed by the DEC on a regular basis.
      
      NYS DEC is severely limited in manpower and dollars. As a result, when a non-significant system is reported as failing, it is difficult to get the DEC to respond. Moreover, non-significant SPDES permit information is difficult to obtain. Non-significant SPDES permit data is not entered in the State's computerized Permit Compliance System (PCS). Instead, a request for the data must be made under the Freedom of Information Law.
      
      POLLUTION PREVENTION ACTIONS
      
      Goal:
    - Existing Measures:
    - Recommended Measures:

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