The BCA is a signed agreement between the City of Rochester, Monroe County Department of Public Health, and the New York State Department of Health, which outlines commitments and deadlines for the City of Rochester to bring its facilities into compliance with LT2. Enforcement actions and penalties due to the LT2 regulations are deferred as long as the City of Rochester meets the conditions of the agreement.

Why is this study happening?

In March 2006, the USEPA adopted a new regulation known as LT2. Part of LT2 requires that Public Water Systems which store water in an open finished reservoir to either install a cover or treat the water to insure adequate inactivation of viruses and parasites. Although LT2 is the primary driver of this study, there is a need to improve reservoir conditions, which are adversely impacted by various environmental factors. These conditions leads to additional operations costs and also diminishes water quality.

The purpose of this study to investigate options for addressing LT2 and improving other unique water quality and operational challenges associated with Highland Reservoir, including deposition of seeds, leaves and pollen from nearby trees. LT2 compliance options to be evaluated will include: covering the reservoir, replacing it with a tank, removing the reservoir from service and several treatment methods. Consideration will also be given to extending the current BCA.​

If the City does not comply with the LT2 requirements, the City could be subject to a fine by MCDOPH and NYSDOH.

Learn more about the EPA's LT2 Rule

Operational constraints

Highland Reservoir faces unique challenges for operations and maintenance as well as water quality due to the arboretum that surrounds the reservoir. The trees surrounding the reservoir deposit large quantities of seeds, pollen, leaves and other material in the reservoir throughout the year.

The spring and fall seasons present especially difficult operational challenges. In spring, sycamore seeds and cottonwood dander frequently plug the reservoir outlet screens (wedge wire screens).

Throughout the fall, leaves settle to the bottom of the reservoir, often clogging the outlet screens. In addition, too many leaves can lead to water quality issues such as algae and bacteria growth. Removal of the leaves is a highly labor-intensive operation and must be performed several times throughout the year. This cleaning process requires shutting off Highland Reservoir for periods of time. Wind and storm events can disturb accumulated leaves and other vegetative matter causing additional plugging of the reservoir outlet screens.