Taunton River above Cherry St in the Town of Bridgewater October 15, 2003

Would you let your children swim here?

They should be able to.

The Taunton's water should look like this.

Our Public Comments

29 September, 2003

Ellen Roy Herzfelder, Secretary

Executive Office of Environmental Affairs

251 Causeways Street, Suite 900

Boston, MA 02114


EOEA # 13109 Brockton Advanced Wastewater Treatment Facilities Upgrades

Dear Secretary Roy Herzfelder,

The following are our public comments regarding MEPA project # 13109 City of Brockton, Brockton Advanced Wastewater Treatment Facility Upgrades. We submit these comments to urge the secretary to require an Environmental Impact Review of this project before any treatment upgrade projects to the Brockton AWRF begin. CDM states the following on page 1 of attachment 1 in the ENF. "Wastewater treatment in Brockton first began in the early 1900s, at a site west of the Veterans Administration Hospital on Belmont Street. Additional sewer construction and treatment facilities were required in the City by 1960, and a new plant was placed into service at the site of the current treatment facility. By the late 1970s, this plant was nearing the end of its 20-year design life, and a major plant expansion project was completed in the mid-1980s. Since that major expansion, the Brockton WWTF has not undergone a major plant-wide upgrade program." Shortly after completion of this "major plant expansion project" the upgraded and expanded plant was failing to meet permit limits, and in 1988 the City of Brockton entered into a consent decree with the regulating authorities. On November 14, 2001

the Ma DEP issued a notice of non-compliance to the City of Brockton, it is our understanding that this action initiated this current upgrade proposal.

Fifteen years ago the Cityís newly updated and expanded plant was failing to meet permit limits less than five years after the update was completed. Which means that from 1988 until today the Brockton AWRF has been pouring significant volumes of pollution into the Salisbury Plain, Matfield and Taunton Rivers "the receiving waters". While CDM maintains on page 3 section A of the ENF that "The WWTF has had intermittent difficulty complying with most of its effluent criteria." The EPA Region 1 office had the following to say in a June 2003 press release regarding the Brockton WWTF "The city's treatment plant, which discharges to the Salisbury Plain River, has consistently failed to meet pollution discharge limits in its federal permit over the last decade. Inspections by EPA and the Massachusetts Department of Environmental Protection (DEP) and the plant's own reports document equipment failures, operator errors, chemical feed problems and chronic bypassing of treatment equipment at the plant. This has led to excessive discharges of sewage solids, bacteria, ammonia and chlorine into the river, which flows to the Matfield River which downstream becomes the Taunton River. The discharges had the potential to cause significant aquatic ecosystem system damage and public health problems in the river, especially during the dry season when water levels in the river are lower."

The focus of our comments and our primary concern with this proposed plant upgrade is that it could follow in the footsteps of the "major plant expansion project" undertaken by the city in the mid 1980's. As we pointed out above this plant was failing shortly after being upgraded. Without the more detailed information provided by an EIR we cannot make an informed decision about the viability of this proposed 2003 "major plant expansion project."

If, "most planning sources project that the population in Brockton will decline between 2000 and 2025," (project narrative, pg 3) how certain can the City be of needing 2.5+ mgd (requested increase of 2.5 plus the up to 12.5 mgd peak flow volume realized by the elimination of I&I)



What is the cost associated with I&I removal over the long term and the costs associated with plant expansion and the increase in operating costs of an expanded plant?


Have conservation measures been implemented in Brockton and member communities?


The facilityís current NPDES permit will expire at the end of this month and it is likely the EPA will renew the permit with more stringent or new permit limits for several constituents. (EPA letter 8/9/02) Knowing what limitations will be imposed on the effluent quality would be one of the most important factors in the selection and design of upgraded treatment methods. Wouldnít it be judicious to know what the ultimate effluent quality goal is before proceeding with the permitting of the facility changes?


The Salisbury Plain River is on the stateís list of impaired waters as are some downstream reaches of the Taunton River system. The effluent flow already constitutes most of the flow in the Salisbury Plain downstream of the discharge point. EPAís NPDES Unit letter of 8/9/02 stated, "An increase in the design flow will not be authorized without a determination that toxicity and nutrient issues can be addressed to a level that will result in full attainment of the designated uses of the receiving water." How likely is it for an increase of 2.5 mgd in effluent volume to be granted by EPA?


Should an increase in volume be granted, it is routine for the EPA to keep the loadings of total suspended solids loading and biological oxygen demand at existing levels. The facility already has problems meeting TSS limitations and the table on page 4 of the project narrative indicates loadings will increase after the plant expansion and upgrade. The project narrative does not explain the expected ability or comply with TSS beyond listing predicted loadings in 2025. What are the differences in loadings for existing design capacity versus expanded capacity? How will the problem of increased loads be addressed so the facility will be in compliance?


This same chart indicates a marked increase in phosphorus loadings. The existing 1.0 mg/l Phosphorus limit is likely to be more stringent. (EPA NPDES Unit letter 8/9/02 to City). How will the City deal with both an increase in flow volume and a reduction in concentration and possibly loadings for phosphorus?


The copper concentrations in the facilityís effluent are well above permit limits, (often more than 200% above permit limits as shown on the EPA NPDES ECHO web data base). The facilities assessment evaluated only controls and treatments at the WWTP, all dismissed in favor of pursuing , "alternative regulatory means to control copper, such as use of Whole Effluent Toxicity testing result. " (project narrative pg. 6) Regulatory actions do not control copper, thus reducing the harmful affects of copper on marine and aquatic organisms, only removal or source reduction reduce copper concentrations. A move to use WET test results would simply reduce the testing frequency for copper from monthly, (and possibly more frequently in future NPDES permits) to quarterly. This would reduce the number of permit exceedances in a year but would not reduce the degradation of copper on the receiving waters and in sensitive resource areas such as Narragansett Bay. This is definitely not a solution and it is unlikely the EPA will grant a special exception for the Brockton facility. Has source reduction been evaluated, (e.g. changes in potable water pH levels)?


The updates at the facility offer a great opportunity to improve storm water runoff from this 37.6 acre site. The ENF does not provide detail on the storm water treatment plans for the site, it is unclear if only certain sections will have improvements to meet DEP policy or if all storm flows will be meeting 85% TSS removal. Given the problems with TSS in the effluent and the proximity of the storm water discharges to the outfall, retaining as much storm water on site as possible and having all runoff meet 85% removal would help lessen impacts to the Salisbury Plain River. What are the specific storm water remediation systems to be used at the site?


Did the $3,000,000 I&I study recently completed by the City determine the existing percentage of infiltration and inflow (I&I) in the system?


If I&I was reduced to the levels recommended by the US EPA, what would the average and peak flows be at the facility and would the new found capacity be adequate to cover new future flows?


The City is undertaking a two phase I&I remediation project, what will be the amount of I&I removed after the completion of this project?


How was the need for an additional 2.5 million gallons per day of treatment capacity at the plant calculated?


Did the increase take into account the reductions in flow associated with I&I removal?



Our first concern is the Inflow and Infiltration issue. I/I has plagued this plant throughout its history. CDM states the following in the ENF "The quantity of inflow from extraneous sources, is extremely high and must be reduced in the future for the plant to operate within itís capabilities." They go on to give examples of the cityís current efforts but provide no information on how successful these efforts have been. CDM also states in section 3.2.4 page 3-3 of their Facilities Assessment-Brockton Advanced Wastewater Treatment Facility, Project Evaluation Report 2002 " the estimated average I/I (annual average infiltration) of 12.35 mgd compares well to the estimated quantity of 10 mgd, from the previous studies. A discussion of the I/I studies and results follows later in this report. The increase of the present infiltration estimate from 10.0 mgd to 12.35 mgd is most likely due to inaccuracy in I/I flow monitoring and the potential addition of infiltration sources since 1996." They go on to say that the average infiltration component of the flow to the WWTF is 57% of the average daily plant influent flow. More than half of the flow entering this plant is from a leaky sewer system. Does Brockton need to add additional flow to the plant or fix their sewer system? In this same report CDM states "previous I/I studies recommended specific improvements to the sewer system that would result in the reduction of I/I over the 20 year planning period. It was assumed that 1.0 mgd of infiltration (average I/I) would be removed from the system over the 20 year planning period. The future I/I flow was only reduced to 11.35 mgd because reoccurring and new defects in the collection system are expected to minimize the measurable impact of rehabilitation." This seems a rather half hearted effort at I/I reduction. Given the cityís past history in addressing chronic permit violations one has to wonder if this is an indication that the city is more interested in appeasing the regulatory authorities than fixing the problem.

Furthermore how accurate are CDMís infiltration reduction figures? It is clearly in the cityís best interest to be permitted as much flow as possible. If the city is able to reduce infiltration by 2mgd or 5mgd or 10 mgd and still maintain a permit limit for 21.5 or 22.2 mgd they will be able to replace the non-revenue generating flow with an additional X amount of actual revenue generating flow. Is the city underestimating its infiltration reduction numbers to receive and maintain a higher daily flow limit in their discharge permit?

It appears at this point in time future I/I reductions are a big question mark. While the city is currently trying to address these issues, there is no real data in this ENF describing how successful these current efforts have been. Will the city continue to aggressively work on these projects in the future? Administration changes, budget constraints and priorities are all subject to change. As problems are fixed more are likely to arise within the cityís antiquated sewer system. If the city does not or cannot significantly reduce their I/I problems what impact will these additional flows (I/I + additional 2.5 mgd flow increase requested by the city) have on the Salisbury Plain, Matfield and Taunton Rivers "the receiving waters".

In the ENF CDM states the plants current design capacity is 18.0 mgd. They are requesting an increase of 2.5 mgd, bringing the treatment capacity up to 20.5 mgd. They predict the future flow (2025) to be 20.49 mgd. They also list the historic flow (98-02) at 19.79 mgd. These figures appear problematic. In the Facilities Assessment-Brockton Advanced Wastewater Treatment Facility, Project Evaluation Report 2002 CDM states that the current plant flow is 21.5 mgd and they estimate the future average daily flow (2025) at 22.2 mgd. Which figures are accurate? It appears that the city is proposing to increase the flow from 18mgd to 20.5 mgd when according to CDMís numbers the plant is currently treating 21.5 mgd. While their may be a simple answer for this apparent discrepancy, these figures are relevant and constructive. They provide valuable insight as to how close to the compliance limit this plant will be even after completion of the proposed update and in a best case I/I scenario. Furthermore, to our knowledge these figures do not include the potential addition of several more mgd of water which will be available to the city upon completion of the Aquaria freshwater desalinization plant in Dighton on the lower Taunton River. In order to make sound environmental and fiscal decisions we need clearer and more detailed information than is contained in the ENF.

Further more it is our understanding that an EIR is mandatory for any increase in interbasin transfers of 1 mgd or more. According to the EIR for the Aquaria freshwater desalinization plant in Dighton, an MOU has already been signed with the City of Brockton to purchase the water generated at the Aquaria facility. The Water Resources Commission has determined this water sale to be an interbasin transfer. This means the WWTP upgrade involves an interbasin transfer and should be categorically included to complete an EIR.

One other potential negative impact of Brocktonís I/I reduction efforts is a potential increase of effluent discharge during summer low flow periods. It is during these periods that the Salisbury Plain, Matfield and Taunton Rivers " the receiving waters" are most vulnerable. The following facts and figures provide some insight into how dominant the plants effluent flow is in this river system. While we recognize that the following is a simplified account of the dilution of effluent from the Brockton AWRF, it is instructive and again provides some idea of how dominant the plants effluent flow is in the Salisbury Plain, Matfield and Taunton River "the receiving waters".

"USGS partial recording station stream flow data for similar-sized streams in the Taunton River Basin suggest that the naturally occurring 7Q2 at the site locale without augmentation by the City of Brockton AWRF would be approximately 1.7 cfs. The 7Q10 at this point on the Salisbury Plain River would be approximately 0.6 cfs. Finally, USGS long-term monitoring of streams throughout the basin suggests a naturally-occurring minimum monthly mean flow of 0.8 cfs in this segment of the Salisbury Plain River." (Epsilon Associates, inc 1998 water resources 29298/deir/Sec5.8water.doc)

Therefore if the historical plant effluent flow (98-02) equals 19.79 mgd or 30.5 cfs there is a mixture of 927 thousand gallons of river water (0.6 cfs divided by .647 = 927 tgd) to 19.79 million gallons per day of effluent during periods of low flow. In other words the Salisbury Plain below the Brockton AWRF is a river of effluent. Unfortunately the Brockton AWRF impacts do not end with the Salisbury Plain. According to USGS Survey Water-Resources Investigations Report 84-4283 the Salisbury Plains major tributary Beaver Brook has a 7Q10 of .6 cfs or 463 thousand gallons per day. Where the Salisbury Plain and Beaver Brook conjoin is the beginning of the Matfield River. Therefore at the beginning of the Matfield River the approximate mix of effluent to water is 1.4 mgd water to 19.79 mgd effluent during low flows. Therefore at this point 2.2 miles downstream of the Brockton AWRF the river is little more than a river of effluent. The next significant down stream tributary (in terms of flow contribution) to the Matfield River is the Satucket River. Satucket is approximately 3 miles downstream from the confluence of the Salisbury Plain and Beaver Brook According to USGS Survey Water-Resources Investigations Report 84-4283 Satucketís 7Q10 is 1.3 cfs or approximately 2 mgd. Therefore at this river junction the ratio of water to effluent is approximately 3.3 mgd water to 19.79 mgd effluent during periods of low flow. Therefore at this point approximately 5.2 miles downstream of the Brockton AWRF the river is little more than a river of effluent. Down stream of Satucket approximately 8.2 miles from the Brockton AWRF the Matfield River joins the Town River to become the Taunton River. According to USGS Survey Water-Resources Investigations Report 84-4283 the Town Riverís 7Q10 is 2.7 cfs or 4.1 mgd. Therefore at this river junction the ratio of water to effluent is approximately 7.4 mgd water to 19.79 mgd effluent during low flows. Therefore at this point approximately 8.2 miles downstream of the Brockton AWRF the river is little more than a river of effluent. The next down stream tributary is the Winnetuxet River which is several miles below the confluence of the Town and Matfield River. According to USGS Survey Water-Resources Investigations Report 84-4283 the Winnetuxet has a 7Q10 of 7.8 cfs or 5 mgd. Therefore at this river junction some 14 miles from the Brockton AWRF the ratio of water to effluent is approximately 12.4 mgd water to 19.79 mgd effluent.

We assume that as Brockton reduces I/I they will replace it with actual sewage flow (CDM assessments and the ENF seem to imply this). Therefore when and if I/I is reduced to acceptable levels the plant will be putting out a fairly constant flow of 20.5 mgd or 22.2 mgd (depending on which CDM estimate is accurate). This steady effluent flow has the potential to create further stress on an aquatic ecosystem that is currently failing.

When you review the actual daily effluent flows from the plant as opposed to the average flow, there appears to be a significant drop in plant effluent flows during periods of low water. In effect the plants flow appears to fluctuate with the rising and lowering of groundwater levels. In periods of high groundwater the plants flow goes up due to infiltration. In periods of low water the flow appears to drop significantly (see attached daily plant flows, Attachment # 1). According to Brockton WWTP flow data 1/1/99-12/31/01 between the months of June and mid September actual plant effluent flows dropped well below 18 mgd for significant periods of time. If this infiltration flow is reduced and then replaced by a constant year round flow of 20.49 or 22.2 mgd it could have a devastating impact on the already failing aquatic ecosystem of the Salisbury Plain, Matfield and Taunton Rivers " the receiving waters". Again according to actual daily plant flows the plantís flow fluctuates between 15.5 and 18.0 mgd during low summer flows if in the future the flow becomes steady at 20 plus mgd there will be an additional 4.0 to 6.0 mgd of effluent entering the river system when it is most stressed. This would be the equivalent of adding six new treatment plants about the size of the Middleboro WWTF. If one such new plant were proposed on any one of these rivers an EIR would likely be required.

One could reasonably argue that during low flow periods the headwaters of the Matfield and Upper Taunton Rivers are the Brockton AWRF. While the physical discharge of the plant is at the plant site, the overwhelming dominance of its flow has the effect of turning the Salisbury Plain River into an extended sluice way comprised of 95% effluent. This in turn becomes the Matfield River and then further down stream the Taunton River. The ENF fails to take any of this into account. Rather it focuses on the area directly around the plant and does not address any downstream impacts. In the ENF the Natural Heritage and Endangered Species Program was asked the following, "We are hereby requesting your review of rare species habitats, exemplary natural communities, estimated habitats of state-listed rare wildlife, and certified vernal pools in the area of the Brockton Advanced Wastewater Treatment Facility." The Natural Heritage and Endangered Species Program response was "At this time we are not aware of any rare plants or animals or exemplary natural communities that would be aversely affected by the proposed plant." This would be accurate in the area directly associated with the plant. However as we have pointed out in our comments this plantís effluent discharge impacts are evident along the whole Taunton River system down to and including Mount Hope Bay in Rhode Island (EPA estimates 30% of nitrogen loads into Mount Hope Bay are from the Brockton WWTP).

We would suggest that due to the dominance of the plants discharge in the river system "the area of the Brockton Advanced Wastewater Treatment Facility" is far longer and wider than the area directly associated with the plant. And as you move downstream you begin to find rare species habitats, exemplary natural communities and estimated habitats of state-listed rare wildlife. The following information is from the Upper Taunton River Wild & Scenic Study of the Upper Taunton River. Bear in mind the low flow figures we provided and the dominance of it being effluent from the plant. The following two discussed segments are the two upper most segments of the Taunton River.


Mill Street, Bridgewater to Auburn Street, Bridgewater/Middleborough:


Two rare freshwater mussels, Triangle Floater (Alasmidonta undulata, Special Concern) and Tidewater Mucket (Leptodea ochracea, Special Concern), have been documented from this section of the river as occurring in small populations. Three common species of mussels are also present. There are twelve species of freshwater mussels in the state; six of these are listed as rare. In general, the presence of several species of mussels, especially rare mussels, indicates good water quality (this may not be the case at this site as past water quality monitoring by the Taunton River Watershed Alliance and Bridgewater State College indicate periods of marginal water quality for this segment). Threats to the continued viability of rare mussel populations include pollution from either point or non-point sources, drastic decreases in water levels from water withdrawals, or excessive turbidity due to erosion upstream. Protecting water quality and quantity will, in general, protect the mussels.

This section of the river and most of the land adjacent to the river has been designated by the Natural Heritage Program as BioMap Core Habitat for seven species of rare reptiles and amphibians (five turtles, one toad, and one salamander). Core Habitat consists of the most viable habitat state-wide for terrestrial and wetland rare plants, rare animals and exemplary natural communities. This area of Core Habitat along the Taunton (including downstream sections below Auburn Street) was designated for these rare reptiles and amphibians because of the high density of Potential Vernal Pools, diverse wetland types interspersed with uplands for nesting, and relatively unfragmented landscape.


Auburn Street, Bridgewater/Middleborough, to the Nemasket River:

Long-leaved Panic-grass (Panicum longifolium, Threatened), Mystic Valley Amphipod

(Crangonyx aberrans, Special Concern), and Spotted Turtle (Clemmys guttata, Special Concern) have been documented from the low-lying, often-wet land along the Taunton in this section of the river. All three of these, in their different ways, depend on moist to wet areas for their livelihood. Spotted Turtles (in fact, all turtles) are particularly susceptible to read traffic. Therefore, preventing the establishment of new roads is needed to protect these reptiles.

A little farther from the river, two rare owls, Barn Owl (Tyto alba, Special Concern) and Long-eared Owl (Asio otus, Special Concern), have been reported breeding in the woods and open fields of this area. The Barn Owl prefers open grassy areas, which are habitat for Meadow Voles, its principal food source, This owl nests in cavities, using natural holes in trees as well as old buildings and barns. Long-eared Owls roost and nest in dense conifer stands next to open fields, where they hunt. Both owls are declining because of the conversion of agricultural or natural fields to development.

Additionally, along this part of the Taunton there is a good example of an Alluvial Red Maple Swamp, which is a type of natural community that develops along a slow-moving river where the river regularly floods its banks. The soils of alluvial Red Maple Swamps are more poorly drained than those of true flood plain forest. If the swamp holds water from springtime flooding long enough, the area may function as vernal pool habitat. Many rare reptiles and amphibians use vernal pools for breeding, feeding, or rehydration; thus, the presence of the Alluvial Red Maple Swamp and the relatively high density of Potential Vernal Pools along much of the upper Taunton contributes to the long-term viability of several rare reptiles and amphibians.

With regards to downstream vernal pools, this should be a habitat of critical concern when reviewing this permit. Due to this river systems low relief it often overflows its banks during high flows and after heavy rains. The polluted water in the river often pours through the woods inundating large areas of potential vernal pool sites. What impact does this effluent have on these valuable habitats. See attached photo of one such area on the Matfield River below Rt.18 East Bridgewater.

It is clear to anyone who spends time on these rivers and reviews the limited water quality monitoring surveys that this whole system suffers significant impairments due to this plants discharge. In fact both the Salisbury Plain and Matfield are on the 303d list as impaired waters. In our many trips from above the Brockton AWTF down to the confluence of the Town River we have yet to find a single living or dead freshwater mussel in the Salisbury Plain or Matfield River. The following is from Mussel Facts From Biology in Focus U.S. Geological Survey.

"Poised on the brink of mass extinction, freshwater mussels are the largest group of endangered animals in North America. About 70 percent of the 300 native species are considered endangered, threatened or of special concern. Biologists see the mussels' plight as a serious warning for our global ecology as a whole-when mussels begin to disappear, it is a sign that other species, and entire ecosystems, may be in peril as well.

Mussels not only oblige us as environmental barometers, but they also strengthen the health and stability of a stream. As mussels feed and breath, they filter water and make it cleaner. and because mussels are at the foundation of the aquatic food web, they contribute to the survival and vitality of other animals. A stream with abundant mussels can usually support more muskrats, otters, wading birds and game fish.

The number of imperiled mussels in the United States forecasts an extinction crisis that, unless prevented, may result in the complete loss of dozens of species and further impoverishment of aquatic ecosystems."

This is troubling, that we have found no freshwater mussels here. Is the absence of mussels due to the plant? Will increased plant flows help to restore mussels to these streams? Will increased plant flows impact the threatened species in the uppermost segments of the Taunton River directly downstream from here. Furthermore as mentioned above the Upper Taunton River is currently being studied for inclusion as a federally designated Wild and Scenic River. At the same time we have been working for the past several years to restore alewives to their historic spawning grounds in Robbins, Stump and Monponsett Ponds via the Satucket River a tributary of the Matfield. This is an ongoing cooperative effort with the towns of East Bridgewater, Halifax, Hanson along with MA River Restore Program, MA DMF, American Rivers and the Army Corp of Engineers all taking part. When this project is completed it will give alewives access to several hundred acres of spawning habitat. This has the potential to re-establish an upstream run of close to one million adult alewives and a down stream run of perhaps hundreds of millions of juvenile alewives. Because the Satucket is a tributary to the Matfield these fish will have to migrate through its waters. There is a great deal of concern that because the juveniles migrate down stream beginning in July when dissolved oxygen levels recorded in the Matfield often drop below the MA designated standard of 5.0 mg/l (see attachment for DO figures, Attachment # 2) that future water quality in the Matfield could be a limiting factor in our alewife restoration efforts.

The following is water quality monitoring data from various sources performed on the Upper Taunton River and its watershed in the recent past. We have attached copies of the pertinent studies to our comments for your convenience.

In the Matfield & Salisbury Plain River Watersheds Nonpoint Source Pollution Assessment Report May 19, 2003 page 45 the following was observed at a sampling site at High St. Bridgewater Matfield River. This site is approximately 8 miles downstream of the Brockton AWRF and one quarter mile upstream of the beginning of the Taunton River. "Copious amounts of macrophytes and algae were observed at this site which could be a result of the elevated nutrient levels found at this site. Strong chlorine odors were also noted during every visit to this site, which can be an indication of over chlorination by a sewage treatment plant or chemical industry, or discharge of swimming pool. Evidence of primary recreation was noted at this site in the form of a rope swing. It is advised that such activities should be actively prohibited."

The following is from the same study at the sampling site at Belmont St. Bridge Salisbury Plain River East Bridgewater (this site is about one and a half miles below the Brockton AWRF)

"SPR1 was sampled on five dates and exhibited elevated levels of bacteria on two out of three wet weather sampling days, with a peak level of 14,000 col/100 ml on 6/6/02. This site ranks as number 7 on the "Recommended Priority for Site Management (during wet weather)" list (Table 9), and number 4 on the "Recommended Priority for Site Management (during dry weather)" list (Table 10). Which means overall this site was relatively bad in terms of water quality during wet and dry weather conditions."

The following is from the Draft Taunton River Watershed Assessment Report 1998, Taunton River Watershed Benthic Macroinvertebrate Biomonitoring.

The surveyor had the following comments on this sampling site (TRO3) which is also at Belmont St. East Bridgewater Salisbury Plain River.

"I recommend omitting TRO2 as an upstream reference site and instead using the regional reference station TRO1 as the primary reference for TRO3. With an EPT index of 1 and a taxa richness of only 6, it would seem unconscionable to place TRO3 anywhere near the non-impaired category. The relatively high habitat assessment score (83% comparable to the regional reference station) received by TRO3, coupled with its low metric scores, lead me to believe that impairment to the invertebrate community is primarily due to degradation of water quality. The Brockton WWTP seems the likely pollution source here, although a horse farm adjacent to the stream at Belmont St. may be a possible source of nutrient loading."

The following is from summer 2000 over night nutrient studies performed by the Bridgewater State College Watershed Access Lab on the Upper Taunton River. (See attachment for more detail Attachment # 3)

"Once again, the nutrient loading in the Upper Taunton River near the confluence of the Matfield and Town Rivers is mostly due to the contributions from the Matfield River Basin."

"Surveys of tributaries within the Matfield Basin revealed that most of this load appears to be from the Brockton Sewage Treatment Plant by late summer"

It is our understanding that high loads of phosphorus can be a limiting factor in freshwater systems, causing algae blooms which in turn reduce levels of dissolved oxygen. The following are DO levels found at several sample sites below the Brockton AWRF during the Matfield & Salisbury Plain River Watersheds Nonpoint Source Pollution Assessment Report May 19, 2003.(see attachment for more detail Attachment # 2)

Salisbury Plain River sample site SPR1 at Belmont St. East Bridgewater (7/24/02/ 2.4 mg/l) (8/30/02/ 4.4 mg/l) (6/20/02/ 4.3 mg/l) (8/7/02/ 1.9 mg/l) Mean DO 3.3 mg/l.

Matfield River three separate sample sites MR1 being High St. Bridgewater approximately 8 miles downstream of plant and one quarter mile above the beginning of the Taunton River.

(7/10/02/ 3.6 mg/l) (7/24/02/ 5.6 mg/l) (9/16/02/ 3.9 mg/l) (6/24/02/ 5.0 mg/l) (8/8/02/ 5.4 mg/l) Mean DO 4.6 mg/l

Given the degree of impairment and the dominance of the plants flow in these rivers we feel that the City of Brockton should be required to perform an in-stream water quality monitoring program as part of an EIR if one is ordered. (See Attachment # 4 for Matfield and Salisbury Plain Summaries)

Having reviewed both this ENF and the Facilities Assessment-Brockton Advanced Wastewater Treatment Facility, Project Evaluation Report we have found that the River or Rivers are seldom mentioned in these voluminous reports and assessments. The only mention of the Salisbury Plain by CDM is to simply identify it as the "receiving waters." This is troubling in that the Salisbury Plain River is far more than "the receiving waters" it is in fact a river and the dominant contributor to a much larger interconnected, fluid river system. Since this plants construction in the 1960's we know of no detailed study that has been done to determine this plants impact on the Salisbury Plain, Matfield or Taunton River "the receiving waters".

Whether or not our comments are relevant to this ENF, we are not certain. However we do feel it is important to put a face to the names of the rivers which make up this river system. We feel it is time to re-introduce ourselves to this system, not as individual streams, rather as a single system of which they are.

Names have become a curse to the Salisbury Plain and Matfield Rivers. We have a tendency to use our river names to create boundaries within a natural system where no boundaries exist. Salisbury Plain ends at the Matfield. The Matfield ends where it joins the Town River, and here a different river begins, the Taunton. Salisbury Plain and Matfield are polluted and ugly. The Taunton is clean, wild and scenic.

Confounding this is a regulatory process which by its nature, unintentionally defines our river within the confines of a discharge permit filled with numbers and letters. This regulatory process works well on many of our rivers. It has not worked on the Salisbury Plain, Matfield or Taunton. When 95% of a streams flow is effluent it ceases to function as a stream and becomes a sluice way for effluent. Can life live in a sluice way of effluent? Yes, some can, and we marvel at this life every time we travel the Salisbury Plain and Matfield Rivers. Can this sluice way function as the diverse healthy ecosystem that it once was? No. The Salisbury Plain and Matfield Rivers were at one time American shad, blueback herring, sea lamprey, white perch, brook trout and perhaps even Atlantic salmon rivers. The upper Taunton River had all of the above along with rainbow smelt, tom cod, striped bass and the Atlantic sturgeon. Today these species exist here as remnant populations if they exist here at all.

How has the Brockton AWRF impacted this system in the past? Has it had any impact at all? How will the Brockton AWRF impact this system in the future? Will it have any impact at all? We have no doubt there will be those who will argue the Brockton AWRF has had minimal impact on our river system. They will use numbers, letters and equations to tell us the plants effluent meets or at least intermittently meets the discharge permit. They will use the regulatory process to define our river. They will try to avoid talking about our river system which flows crippled and fractured along its course to Mount Hope Bay.

We must not allow our rivers or any river to be defined in such a manner. We must not allow our names for rivers to become barriers where none exist. We must redefine our rivers, our river systems in our own words. These words must be carefully chosen words drawn from our rivers water, its history and its potential, rather than from the pages of discharge permits. To clean up this river system and restore its native aquatic species we must in a sense be a river. We must be patient and relentless like the river itself. In time the river turns stones to sand and wears jagged rock smooth. In time it has the same effect on people, who grow weary of living with a dirty, polluted river which cannot support the wonderfully diverse aquatic ecosystem that it once did. These rivers have followed the same courses for some 12,000 years and in all likely hood will do so for 12,000 more. Theyíre clean up and restoration is not a matter of if but when, and now is a good time to start. Please require the City of Brockton to do an Environmental Impact Review on this project.



Tim Watts

Glooskap and the Frog

633 Wareham St.

Middleboro Ma 02346

Comments submitted by Doug Watts of Friends of the Kennebec Salmon


To Whom It May Concern:

 My name is Douglas Watts. I was born in Brockton, Massachusetts and grew up in North Easton, Massachusetts. I now reside in Augusta, Maine. My mother, grandmother and great-grandparents grew up alongside the Matfield River. A cherished childhood memory of my mother was picking wild grapes along the Matfield River each fall during the 1940s and making wild grape jelly from them.

 After the Brockton wastewater plant began discharging into the Matfield River in the 1970s, it became impossible to go near the river. As a child during the 1970s, I remember driving down Matfield Street during the summer and my parents rolling up the car windows because the stench of human fecal matter in the river was so strong.

 In recent years, I have kayaked the Salisbury Plain River and walked along the Matfield River on a number of occasions. Today, the overpowering stench of human feces in the Salisbury Plain and Matfield Rivers has been replaced with the overpowering stench of chlorine from the Brockton wastewater treatment plant.

 I am a professional researcher for numerous organizations and governmental agencies in the field of coastal river ecology, with an emphasis on the water quality and physical habitat requirements of diadromous fish species native to New England. I have conducted field assessments of hundreds of miles of rivers and streams in the State of Maine to document existing water quality and habitat conditions and the use of these waters by native diadromous and resident fish species.

 I am intimately familiar with the various river and streams which are tributary to the Taunton River, having canoed, fished, swam and walked in them for all of my life.

 It is my professional opinion that the Salisbury Plain and Matfield Rivers below Brockton wastewater plant are today the most polluted and impaired river segments in all of New England.

 It is my professional opinion that the Salisbury Plain and Matfield Rivers below the Brockton wastewater plant are by far the most polluted and impaired tributaries of the Taunton River drainage.

 It is my professional opinion that the discharge of the Brockton wastewater plant to the Taunton River is the key limiting factor preventing the restoration of the river's native aquatic species assemblage, including Atlantic sturgeon, striped bass, anadromous brook trout, blueback herring and American shad.

 It is my professional opinion that the proposed changes to the Brockton wastewater plant will do virtually nothing to restore the native aquatic species assemblage of the Salisbury Plain, Matfield and Taunton Rivers to a condition of health.

 My visual and olfactory observation of the Taunton River from the mouth of the Matfield River to Pratt's Bridge in Middleborough, indicates the effluent discharge from the Brockton wastewater plant has severe impacts on the entire freshwater portion of the Taunton River.

 During a canoe trip on the Taunton River below Titicut Street in Bridgewater on Thanksgiving Day, 2001, I noted a very strong odor of chlorine in the water at sites more than 15 miles below the Brockton wastewater plant. The odor of chlorine in the Salisbury Plain River below the wastewater plant was stronger than a swimming pool just after it has been chlorinated.

 Flow data from the Brockton wastewater plant, when compared with river flow data from the USGS gage at Titicut Street on the Taunton River, demonstrates that during summer low flow periods, the flow of the upper Taunton River is predominately effluent discharged from the Brockton wastewater plant. In essence, during low flow periods, the upper Taunton River IS the effluent from the Brockton wastewater plant.

 The effects of nutrient loading (nitrogen and phosphorus) on the upper Taunton River from the Brockton wastewater plant are obvious and severe for many miles downstream.

 Massive amounts of filamentous algae coat and cover the river substrate in the river's shallows and riffles from summer to late fall. This carpet of filamentous algae precludes the use of the river's stony substrate by benthic macroinvertebates. During the evening, this algae consumes enormous amounts of dissolved oxygen from the river.

 The very gentle gradient of the upper Taunton River makes it especially sensitive to human inputs of nitrogen and phosphorus because there are few rapids or riffles to allow for re-aeration. The Brockton wastewater plant is by far the largest contributor of anthropogenic nitrogen and phosphorus to the upper Taunton River.

 Extensive colonies of Tubifex worms in the Salisbury Plain River directly below the Brockton wastewater plant further demonstrate the severity of dissolved oxygen depletion in this river segment due to the effluent discharge from the Brockton wastewater plant. Tubifex are well known to prefer waters deprived of dissolved oxygen. Colonies of Tubifex should not be present at all in the Salisbury Plain and Matfield Rivers, which have a multitude of riffles and rapids to provide for re-aeration and robust levels of dissolved oxygen.

 The physical, chemical and ecological impacts of the Brockton wastewater plant discharge on the Salisbury Plain and Matfield Rivers must be viewed through the lens of native aquatic species abundance, since these animals are the most accurate and sensitive indicators of water quality in the affected river reaches.

 The Salisbury Plain and Matfield Rivers below the Brockton wastewater plant are bereft of most of their native aquatic species. Even pollution tolerant members of the freshwater mussel family, such as the Eastern elliptio and Eastern floater, are almost completely absent from these river reaches. In contrast, these mussel species, as well as the Alewife floater and Triangle floater, are very abundant in the Satucket River, an unpolluted tributary to the Matfield River just a few miles away from the Brockton wastewater plant.

 Native fish species such as the blacknose dace, white sucker and various darters are quite numerous in the Salisbury Plain River directly above the Brockton wastewater discharge, even though in-stream habitat conditions are severely impacted by non-point source pollution, stream channelization and road sand. The numbers of these native fish species declines dramatically in the Salisbury Plain River below the Brockton wastewater plant discharge.

 Based on historic records, life history and habitat requirements, the native fish species assemblage of the Matfield and Salisbury Plain Rivers includes at minimum: American shad, resident and anadromous brook trout, striped bass, blueback herring, sea lamprey, American eel, white perch, yellow perch, pumpkinseed, white sucker, chain pickerel, nine-spine and brook stickleback, banded killifish, fallfish and various native darter and cyprinid species.

 Today, these native fish species are either completely absent or exist in very low numbers below the discharge outfall of the Brockton wastewater plant.

 Because there are no migration obstacles for diadromous fish below the Brockton wastewater plant discharge outfall or the entire Taunton River, lack of physical access to the Salisbury Plain and Matfield Rivers for diadromous fish species can be dismissed as a cause for this absence.

 The historic presence and abundance of diadromous species such as American shad, sea-run brook trout and striped bass in the upper Taunton River is well documented in historic records. Historically, dissolved oxygen and other water quality parameters in the upper Taunton and Matfield Rivers were sufficiently high to support an abundance of these native fish species.

 Today, measured dissolved oxygen levels in the upper Taunton and Matfield Rivers are well below the tolerance levels for these species. The only known cause of this depletion in dissolved oxygen is the Brockton wastewater plant.

 The severe water quality impact of the Brockton wastewater plant discharge completely precludes the ability of American shad, striped bass, blueback herring and sea-run and resident brook trout from restoring themselves to the upper Taunton and Matfield Rivers. If it did not, these fish would be abundant there today.

 The wastewater from a city of 100,000 people cannot be discharged into a stream as the Salisbury Plain River. The laws of physics mandate that such an enormous input of wastewater to such a small receiving stream must massively degrade the ecology of the receiving water for many miles downstream.

 Today, the Maine Department of Environmental Protection is removing wastewater treatment discharges to rivers and streams with a drainage size of less than 200 square miles. The Maine Department of Environmental Protection has found that wastewater discharges from towns of only 5,000 people can have severe water quality impacts when discharged into streams of similar size as the Salisbury Plain and Matfield Rivers. The Maine DEP is now converting these wastewater plants to land based discharges, which consist of spraying treated effluent over forested land so as to utilize the buffering and filter capacity of soil.

 As a native of Massachusetts, I wish that the Laws of the Commonwealth and the U.S. Clean Water Act will be respected in this proceeding. The illegal and disgusting condition of the Salisbury Plain, Matfield and Taunton Rivers today -- 30 years after passage of the Clean Water Act -- suggests otherwise.



 Douglas Watts

38 Northern Avenue

Augusta, ME 04330


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