June 25,2002

Bob Smith

45 School Street

Brockton, MA 02301

Dear Mr. Smith:

The following are my questions and comments submitted as public comments regarding the proposed update of the Brockton Sewer treatment plant on Oak Hill Way in the city of Brockton. They focus on the impact that the plant has on the Salisbury Plain, Matfield and Taunton Rivers.

My experience with the plantís impact on these rivers has been gained by paddling down and wading in these rivers. Observing the river in such a manner from above and then below the plant provides a perspective that has been lacking regarding the Salisbury Plain and Matfeild Rivers. It would be a worthwhile exercise for those involved in this decision making process to do as I have done. Take a canoe trip down the river from above the plant to its confluence with the Town River, where the Taunton River begins. Then take a trip down one of our healthy rivers. This simple exercise would provide a fresh and sorely needed new perspective on how degraded these rivers truly are due to the treatment plant.

For many years Brockton has been a water starved community. Although, there is little land for new industrial and commercial development there is an abundance of vacant and underutilized properties within the city. Recently the city has signed an agreement to purchase significant amounts of water from a desalinization plant scheduled to be built by 2004. When the future plant flow was calculated, was the increased water supply from the desalinization plant considered? If not, how will this effect future flows.

Much of the proposed plants ability to meet future permit requirements appear to hinge on the assumption that the city can significantly reduce inflow and infiltration. At the public meeting on 3/18/2002, a Brockton enterprise reporter asked the cityís DPW director if you had full funding and manpower to fix the cityís sewer lines how long would it take? The director replied that it would take twenty years. Is it reasonable to assume that the city can reduce inflow and infiltration in a timely fashion? Would twenty years be considered timely? If they do not reduce inflow and infiltration as estimated what will be the consequences for the river and the city?

The second paragraph of section 1.5 2.1 of the draft report reads "There is some indication that permitting authorities may apply more stringent effluent limitations on nitrogen and phosphorus in the future. They did not include these changes in the recent (October 1999) Brockton permit but could be added when they renew the permit in 2003 or in subsequent permit cycles. The analysis and recommendations of this report do not consider the potential changes to future permits. Process modifications required for future permit changes would not conflict with the improvements recommended in this report."

Given the increased concerns over nutrient loading in Mount Hope Bay and the Wild and Scenic River study now underway on the upper Taunton River. Future permits will require more stringent limits on nitrogen and phosphorus. This has been confirmed through personal communication with the EPA. The proposed updates to the plant do not include mechanisms to further reduce phosphorus. Therefore it is conceivable given the construction time line (work to begin in mid 2003 with completion being in 2008) that the plant will not be able to meet permit limits upon its completion. Is this wise planning? Has there been a cooperative effort between the city and the regulatory agencies to determine what these future limits might be? If not why? To under take such a project at such an expense without considering these factors seems to defy common sense.

The time line of this project is unacceptable. According to the implementation schedule the plant will not be up and running until 2008. During this time will the plant remain out of compliance with its current permit? If so than it will surely be further out of compliance when a more stringent permit is issued in 2003. It is understood that this time line is beneficial to the cityís taxpayers. However, it leaves the riverine and human communities downstream to bear the burden of a foul river system for several more years.

The draft report states that the receiving waters of the sewer plant (Salisbury Plain River) are listed as Class B waters according to Massachusetts Water quality standards. It is my understanding that the Class B rating is the goal to attain in the future not the actual rating of the waters. In fact both the Salisbury Plain and the Matfeild Rivers are listed on the EPA 303(d) list as impaired waters. Am I correct in this assumption? If so the final report should indicate that the river does not meet Class B standards.

Presently the Salisbury Plain and much of the Matfield River are little more than sluice ways for treated sewer water. The flow from the treatment plant simply overwhelms the natural flow of these rivers. The effects of these flows can be seen and smelt all the way down to Middleboro. The effects of the plant can also be found in the waters of Mount Hope Bay.

The impact of the sewer plant on the Taunton River watershed can best be seen at the confluence of the Town River and Matfield River. This is where the Taunton River begins. If you were to paddle up the Taunton River from the Rt. 104 bridge in Bridgewater, the tributary to the left would be the Town River. Here the water is a clear amber color and odorless. The tributary to the right would be the Matfield River. Here the water is brown and cloudy and smells like a laundromat in the riffles. Anyone traveling this area can clearly see that the Taunton River assumes the characteristics of the Matfield River.

Over the years people have accepted that the Salisbury Plain and Matfield Rivers have become sewer sluice ways. In the future they will not accept this. Furthermore, they will certainly not accept the Taunton River becoming more like the Matfield River. If future flows are increased without significantly improving, the quality of the effluent this is what will happen. The proposed plant update and its time line will not meet future water quality demands. Rather than putting forth a genuine effort to meet the future water quality demands of the public, the city of Brockton has proposed a sand castle built in defiance of the rising tide.


Tim Watts

633 Wareham Street

Middleboro, MA 02346