The BBPB supports appropriate local advocacy initiatives aimed at improving public access and water quality in the harbors and rivers of New York City, as an integral part of its stated mission and in addition to its continuing public boating and youth programs.

In the past summer season alone, more than 6,000 members of the public participated in our kayaking programs at Brooklyn Bridge Park, and scores of our trained volunteers took part in organized kayaking trips to Governor's Island, Liberty Park, Newtown Creek and other New York Harbor destinations. 

Unfortunately, we have often been forced to suspend our public kayaking programs on short notice due to concerns about water quality in the Park's East River embayments following heavy rains – concerns which subsequent testing results proved to be justified. We are active participants in the volunteer-based water testing program organized by our colleagues in the NY Water Trail Association.

We are strongly committed to the improvement of maritime water quality throughout the New York metropolitan area, and we welcome the initiative of the New York State Department of Environmental Conservation to amend its current Water Quality Standards Regulations.   

We support the recommendations made by other area human-powered boating groups at the recent DEP public hearings for the reclassification of the 'designated use' of  New York City waterways to 'primary contact,'  as human-powered boating exposes people to the same risks of unclean water as swimming. As others urged in their testimonies, water quality must be improved to protect all existing and future users of these water bodies.

We also urge you to consider the detailed recommendations below from BBPB board member Rob Buchanan, submitted earlier on behalf of the Water Trail Association. Rob's comments are based on the Association's experience in its invaluable water testing program, on which BBPB and other community boating groups depend to protect the health and safety of participants in their boating programs:

In addition to our biannual survey, the Water Trail Association also operates an ambitious water quality testing program in partnership with The River Project. For the past three years we've used volunteer samplers to test the water for sewage-indicating bacteria (Enterococcus) at more than 30 launch sites around the harbor. From May to October, we test every Thursday morning at the most popular launch sites for human-powered boaters, and we publish our results on the Water Trail Association website every Friday afternoon. The idea is to create a reliable, up-to-date, and easy-to-interpret database that harbor boaters can use to predict likely water quality at their preferred launch site. 

While all of us who boat or swim in the harbor are heartened by the changes you are proposing, I'd like to signal a couple of major concerns. 

First, the DEC should not rely only on established data (e.g., the NYC DEP's Harbor Survey) to obtain an accurate picture of harbor water quality, but instead expand its data collection to include near-shore testing points that will more accurately reflect the quality of the water that recreational users are likely to encounter. That could mean encouraging the DEP and other agencies to test in new locations, or incorporating the results of non-government agencies who are already testing in near-shore locations, or both. 

Second, once the goal of 'swimmability' for all of the city's waterways is announced, the DEC should anticipate a great public demand for specific, accurate and easy to understand information. Therefore, as a part of the rule making process, you should require the agencies you regulate to improve their monitoring, data presentation, and notification efforts so that they are more easily understood by the general public. 
 
Third, in the interest of consistency and to advance public awareness, the DEC should use the most widely used and best understood means of evaluating contamination. This means using Enterococcus results as your standard, just as the New York City Department of Health does in evaluating water quality at the city's bathing beaches. To rely on older standards and numbers will only confuse the public, whom this initiative is ultimately meant to serve.