The NH Department of Environmental Services recently released its long-awaited draft Great Bay Non-Point Source Nitrogen Study, providing a breakdown of the sources of nitrogen pollution in the estuary, and additional insights on how to improve and protect water quality.

According to the draft study, the Great Bay estuary receives, on average, a total load of 1,225 tons per year of nitrogen pollution.  Of that total load, 390 tons (32 percent) come from sewage treatment plants. The remainder – approximately 900 tons per year – comes from a variety of so-called “non-point” sources: sources of pollution that are less discrete and less concentrated than what many of us may think of as a pipe discharging pollution from a facility. The draft study looked at four major “non-point” inputs of nitrogen pollution – atmospheric deposition, chemical fertilizers, septic systems and animal waste.

The study found that atmospheric deposition accounts for roughly 280 tons of nitrogen pollution annually (23% of the nitrogen load to the estuary). While a large percent of this is from out-of-state sources, such as polluted air from the Midwest, the rest comes from New Hampshire.

We can all help, by taking actions that reduce air pollution – such as by driving less, carpooling, using public transportation, using less electricity, and purchasing power from sources other than PSNH, which continues to operate polluting coal-fired power plants like Portsmouth’s Schiller Station. CLF has joined the empowerNH campaign, which provides information about how you can switch away from PSNH’s dirty, expensive energy and purchase cheaper, cleaner power.

According to the study, chemical fertilizer is another source of nitrogen pollution, adding 30 tons of nitrogen per year, or 18% of the estuary’s total load. Lawns and agricultural areas each contribute about the same amount, while recreational fields, parks and golf courses are only responsible for a small fraction of the total. The message here is clear – agricultural operations need to implement best management practices, and we need to have smaller lawns and use less fertilizer. Learn how you can have a healthy lawn and protect the environment.

Did you also know that more than half of the nitrogen load to the Great Bay estuary comes from human waste?

Human waste from septic systems accounts for 240 tons per year of nitrogen pollution. Add that to the 390 tons per year from sewage treatment plants – the single largest source of nitrogen pollution (and a source that can be easily controlled through sewage treatment upgrades) – and human waste accounts for a whopping 630 tons per year, meaning over half of the total nitrogen load to the estuary comes from human waste.

Animal waste accounts for the remaining 110 tons per year of nitrogen pollution in the estuary, with livestock responsible for most of this total. The rest is from pet waste. While pet waste is not a big part of the problem, reducing the water quality impacts of our pets is something all pet owners can do. Learn about environmentally friendly ways to care for your pet.

According to the study, much of the nitrogen from these non-point sources reaches the estuary through stormwater runoff. This means that in addition to reducing pollution from sewage treatment plants, we have to tackle the difficult challenge of stormwater pollution. Looking forward, it will be essential for communities to adopt “green infrastructure” approaches that reduce runoff, and to promote more compact development patterns as opposed to land-consuming sprawl. Incredibly, as a result of sprawl, impervious surfaces (roads, parking lots and rooftops) in New Hampshire’s coastal watershed increased 120 percent since 1990!

The study also modeled nitrogen loads for individual subwatersheds and towns to identify “hot spots.” These results should be useful in prioritizing efforts to reduce non-point sources of nitrogen and will complement a study being completed by the UNH Water Resources Center to pinpoint many of these hot spots.

Did you find this information useful, interesting, or believe more work needs to be done? Then you can be involved. The Department of Environmental Services is accepting public comments on the draft report until August 16, 2013.

For more information about the Great Bay-Piscataqua Waterkeeper and my work to protect the Great Bay estuary, visit: http://www.clf.org/great-bay-waterkeeper/. You can also follow me on Facebook and Twitter.

This past Friday, staff from the New Hampshire Public Utilities Commission and The Liberty Consulting Group issued the results of their investigation (PDF) into the impacts of PSNH’s failing business model and “ever higher costs” to consumers. The Union Leader and NHPR were quick to quote the report’s damning conclusion:

In summary, the situation looks to worsen, as continuing migration from PSNH’s default service by customers causes an upward rate trend. We find no supportable basis for optimism that future market conditions will reverse this unsustainable trend, especially in the near term. To the contrary, the PSNH fossil units face uncertainties that combine to create a risk of further, potentially substantial increases in costs.

This underlines the benefits of abandoning PSNH’s residential energy service, noting that “PSNH’s default service rate has exceeded [competitive supplier] rates since mid-2009.” As PSNH itself stated in a filing before the NH Supreme Court in May, PSNH energy service ratepayers “have the legal right and ability to avoid payment of PSNH’s default energy service rate entirely by buying their electricity from a competitive electric power supplier.” The PUC staff’s report serves as a call to action for New Hampshire consumers to save money, protect their finances, and improve the environment by buying energy from lower cost and more efficient energy suppliers.

PSNH’s only public response to the report thus far has been to cite the dispatch of their coal units during extreme temperature events this year as evidence that the plants are necessary “insurance” against natural gas price increases. The report itself contradicts this, however, noting that even at this year’s levels of natural gas price spike frequency and severity in New England (due to a cold winter and a late spring heat wave two weeks ago), natural gas price fluctuations “have not served to give the PSNH fossil units enough of a boost to overcome their negative value,” and that PSNH has not offered any data or analysis to rebut this finding. That is, even with the extreme peaks of electric demand felt in the past year requiring their use more often than in the past few years, PSNH’s fossil fuel fired power units still lose ratepayer money.

The report assesses the real financial impacts of PSNH’s past and possible future decisions to invest in their coal units rather than shut them down, and demonstrates that the ratepayer money lost if PSNH’s electricity generation is sold off will be lower than many might fear. The key points raised by the report include:

• Even in a best case scenario, PSNH’s already above-market rates will continue to climb. The investigation calculated PSNH’s energy service rates with a myriad of possible variables, including high natural gas prices and lower coal prices (the scenario that PSNH claims will validate its economic decisions) and a migration rate lower than PSNH reported this April. In all cases, the report found that PSNH’s default energy service rate would climb still higher than their current well above market 9.54 cents per kilowatt hour rate, to 10 or 11 cents per kilowatt hour.
• Customers continue to flee PSNH’s energy service. CLF has been reporting the steep increase in residential customers rejecting PSNH’s high energy service rates for a while now. We’ve also noted that most large commercial customers had migrated away from PSNH years ago. The combination of these two trends led to the report this May that migration across all customers reached half of PSNH’s total load as of the end of April.
• The full cost of the Scrubber Project has yet to be felt by ratepayers. PSNH has started recovering the cost of the ill-founded scrubber installation at Merrimack Station to the tune of 0.98 cents per kilowatt hour on a temporary basis. The report estimates that full recovery of the scrubber’s cost would nearly double that amount, to 1.8 cents per kilowatt hour added to ratepayers’ bills. This, of course, is a cost that competitive energy service providers don’t have to deal with.
• Looming environmental compliance projects as Scrubber redux? PSNH is currently waiting for its new final permit from EPA for cooling water withdrawal and discharge at Merrimack Station. The final permit is likely to require cooling water intake structures (like those constructed at Brayton Point Station in MA), at a price tag of $111 million or more, in addition to other protections for water quality and wildlife. Costs associated with new or impending air quality requirements would require additional compliance at significant cost, and these estimates don’t even take into account the risk posed by CLF’s ongoing Clean Air Act citizen suit.
• Potential ratepayer costs from divestment of PSNH’s electricity generation would be minimal. If PSNH’s generating assets are sold, New Hampshire state law allows PSNH to recover from ratepayers costs that are not covered by sale proceeds (“stranded costs”). The report roughly estimates that potential energy service rate increases to cover stranded costs would be no more than 0.9 cents per kilowatt hour and possibly much less, given the high value of PSNH’s hydro generation units.

The report ultimately recommends that the PUC initiate a proceeding to solicit formal feedback on the report and its conclusions. This proceeding would likely result in firmer value estimates for PSNH’s assets, interim steps that could be accomplished through the PUC’s existing authority, and more detailed recommendations for legislation.

As CLF and the Empower NH coalition have repeatedly noted, promoting and advancing competition in New Hampshire’s energy service markets yields only benefits for the state’s electricity ratepayers in the face of PSNH’s “ever higher costs” to ratepayers. While the PUC and the Legislature decide how to implement the recommendations of this report, ratepayers should continue to vote with their feet and leave PSNH’s energy service.

Hardly a day goes by at CLF that we don’t think about how to describe the work we do more simply and clearly. The issues we work on are complicated; the solutions often complex and nuanced. But the need to help people understand our role and theirs in protecting New England’s environment is critical to our shared success.

This week, we launched something completely different to help educate New Hampshire residents about how their choice of electricity supplier can save them money and help the environment. The multimedia campaign, called EmpowerNH, is the creation of a newly formed coalition of retail electricity suppliers, trade and consumer groups and CLF. The coalition grew out of a common interest among this diverse set of stakeholders in promoting a competitive electricity supply market in New Hampshire. As CLF Scoop has been reporting, PSNH’s state-sanctioned practice of charging sky high rates to keep its old, dirty coal plants in business has prompted tens of thousands of residential customers to switch to competitive suppliers, who are are currently offering better rates for cleaner power. The EmpowerNH campaign aims to inform consumers about their power to choose an alternative to PSNH, and make it easy to access information and compare offers from competitive suppliers.

The centerpiece of the campaign is a short video that uses whimsical drawings and stop motion animation to tell the story of electric supply competition in New Hampshire. Take a look, and let us know what you think. And if you like it, please share it with your friends!