OK, everyone join hands.

Kumbaya my Lord, kumbaya
Kumbaya my Lord, kumbaya
Kumbaya my Lord, kumbaya
Oh Lord, kumbaya

Someone's singing Lord, kumbaya
Someone's singing Lord, kumbaya
Someone's singing Lord, kumbaya
Oh Lord, kumbayah

Someone's laughing, Lord, kumbaya
Someone's laughing, Lord, kumbaya
Someone's laughing, Lord, kumbaya
Oh Lord, kumbaya

Someone's sleeping, Lord, kumbaya
Someone's sleeping, Lord, kumbaya
Someone's sleeping, Lord, kumbaya
Oh Lord, kumbaya
 

Oh well, that didn't work, the rivers still a mess. Time for plan B

 

 Rotting From The Head Down

 

 

August 10, 2004

Executive Office of Environmental Affairs

100 Cambridge Street, Suite 90

Boston, MA 02114

RE: Public Comments for the Report of the Water Policy Task Force

Dear :

We appreciate this opportunity to provide our input into this report of the Water Policy Task Force. Glooskap & The Frog is a very small group whose main area of focus is the rivers of the Upper Taunton River Watershed. Although we are somewhat ignorant in regard to some of the wider water use issues and proposed policies, we feel that our perspective gained from the muck and mire of our orphaned streams and the regulatory process which maintains them as such may be of some usefulness to this process.

We refer to them as "our orphaned streams" in the literal sense, because they are ours (no one else wants them) and they have been orphaned by a non responsive regulatory process, and indifferent municipalities. Their orphaned state is evident in the abuses they have suffered historically, currently, and by the abuses they will continue to suffer in the future if our regulations are not enforced and our policies are not followed up with swift and decisive action.

The policies set forth in this document all appear sound and well considered. We take great comfort in the fact that Joan Kimball of Ma Riverways is a member of the Task Force, with out the guidance of Joan and the rest of the Riverways staff many small groups like ours could not remain effective.

Our concerns are not so much with the policy, but with the implementation of it. Our experience on two of our orphan streams, Salisbury Plain River and Matfield River, have been extremely frustrating. While there appear to be abundant volumes of regulations and carefully considered policy guidelines available to address and remedy our orphans ailments, few have been enforced or implemented.

One particular area of concern begins on page 11 of the report, it reads as follows....

" The state would like to take strong measures to infiltrate and recharge water and treated wastewater into the ground to the maximum extent possible so as to enhance base flows of our rivers and thus maintain a healthy flow of water especially in the high demand summer months."

Following this statement, under Recommendation #4 the report goes on to say.....

"Movement of wastewater from the area of origin to wastewater treatment facilities and finally to discharge areas is the leading cause for water deficits in many of our river basins. Keeping water and wastewater local is one of the main focus areas of this water policy"

The above statements do not break any new ground, they have been generally recognized and embraced in literature published by Federal and State Regulatory Agencies for quite sometime. What we find troubling is the fact that at the same time this task force was being convened, and at the same time public comments are being accepted on it, the Executive Office of Environmental Affairs and Ma DEP have approved the polar opposite for the City of Brockton Sewer Treatment Plant.

The expansion approved by EOEA and Ma DEP will allow the City to increase their discharge from 18 mgd to 20.5 mgd. This 21.5 mgd expanded discharge will empty into our orphan stream which has a 7Q10 of 0.39 mgd (EPA region 1, 1999 NPDES permit). One of the repercussions of this expansion has been a push by surrounding communities to take advantage of the plants increased capacity to sewer there own towns. The towns of East Bridgewater, West Bridgewater, Halifax, Hanson, Easton and Avon are all seeking access to the Brockton Plant. Furthermore, and more troubling is that the City of Brockton has been playing an active role in marketing their soon to be expanded plant to these communities. It is also worth pointing out that the Mayor of Brockton, John Yunits is a member of the Water Policy Task Force.

Fortunately EPA recognized this early on in the permit drafting process and responded by putting language in the draft NPDES permit prohibiting Brockton from accepting additional flows from communities outside the City of Brockton. The above mentioned towns have challenged this language in the draft permit, and on August 25, just a couple weeks after the comment period closes on this draft water policy report the reopened public comment period on the Brockton NPDES will close and a public hearing will be held to determine wether or not these towns will have access to the Brockton Plant.

The implications and impacts of such an expansion appeared to be of little concern to the EOEA and Ma DEP when the City of Brockton filed an ENF on the expansion of this plant in September 2003. In fact, despite detailed comments regarding these issues filed by Glooskap and the Frog, Ma Riverways and others, and despite the fact that our orphan streams flow with more than 90% effluent during summer flows, Secretary of the Executive Office of Environmental Affairs Ellen Roy Herzfelder signed off on and approved the ENF without addressing any of our concerns. Despite the fact that the whole Taunton River, from Bridgewater to Mount Hope Bay would be impacted Secretary of the Executive Office of Environmental Affairs Ellen Roy Herzfelder did not see fit to require anything more than an ENF on this project. Despite the fact that this expansion could impact the headwater streams and aquifers of an area from Monponset Ponds, across East Bridgewater, to Brockton, up to Avon, down and across to and through Easton, back through West Bridgewater and the Hockomock Swamp, Secretary of the Executive Office of Environmental Affairs Ellen Roy Herzfelder did not see fit to require anything more than an ENF for this project. This is troubling to say the least.

While there is little data to determine the long term impacts of such a project, common sense and policy guidelines set forth by EPA, EOEA and the Mayor of Brockton suggest that sewering the whole of the upper Taunton River Watershed and sluicing our precious water away down Salisbury Plain River is not wise planning? Yet, this is exactly what Secretary of the Executive Office of Environmental Affairs Ellen Roy Herzfelder has approved, and exactly what task force member John Yunits, the Mayor of Brockton has been lobbying for over the past several years.

" The state would like to take strong measures to infiltrate and recharge water and treated wastewater into the ground to the maximum extent possible so as to enhance base flows of our rivers and thus maintain a healthy flow of water especially in the high demand summer months."

"Keeping water and wastewater local is one of the main focus areas of this water policy."

As we said in the beginning of our comments "we are somewhat ignorant in regard to some of the wider water use issues and proposed policies" however it appears there is a conflict here between the written policy of EOEA and the real life action of the EOEA. This proposed paper policy must be supported with action and the support of EOEA, otherwise it is quite worthless, and would waste the honest efforts of many fine people and organizations.

If the Secretary of the Executive Office of Environmental Affairs Ellen Roy Herzfelder and the Mayor of Brockton truly embrace the policies of the Water Quality Task Force, we look forward to standing shoulder to shoulder with them or their representatives at the NPDES public hearing on August 25 in opposition to this expansion. Furthermore, we look forward to working with you and these communities to find real long term solutions to our regions drinking and wastewater issues. The policies set forth in this report will guide us well in this endeavor.

 

Sincerely,

Timothy A. Watts

Underpaid Executive Director

Glooskap and the Frog

 

Report Here

 

Our Public Comments on the reopened Brockton Sewer Plant discharge permit.

U.S. Environmental protection Agency

Massachusetts Office of Environmental Protection - CPE

1 Congress Street - Suite 1100

Boston, MA 02114-2023

Attn: Betsy Davis

 

RE:   Public Notice Number  MA-047-04

         Permit Numbers  MA 0101010

 

What it boils down to is neither the City of Brockton, EOEA, DEP or EPA have a legal, moral or any other obligation to provide sewer service to surrounding communities. They simply don’t. However the City of Brockton, EOEA, DEP, EPA and we, the citizens of this Taunton River Watershed do have a legal responsibility under the Federal Clean Water Act and a moral responsibility to future generations to protect and restore the biological integrity of Salisbury Plain River and all of our waterways. Over the past fifteen years or so we collectively, have failed miserably in regard to the Salisbury Plain and the rivers which receive it.

This permit as currently drafted represents the first time a genuine effort has been made to bring Salisbury Plain incrementally closer to attaining the goals set forth in the Clean Water Act. However, it must be understood that this permit as written represents an incremental step in the process, not the final step. It is unlikely that this permit and the plant upgrade will be sufficient to allow this river to meet its attainment goal of a class B waterway. This is not my opinion it is the opinion of EPA Region 1 staff, as related to me by them.

EPA has indicated their approach to this plant is from the bottom up, meaning minimize its impacts on Mount Hope Bay first and then focus more directly on the problems in the river itself.  When TMDL’s are completed for the impaired waters of Mount Hope Bay and the Taunton River it is likely that more stringent permits and further upgrades will be required. When TMDL’s are calculated for the impaired waters of the Matfield and Salisbury Plain Rivers further work will surely be needed. The language in this permit which prohibits additional hookups to outside communities is an acknowledgment of this fact. This permit recognizes and provides for the City’s current and future needs and also recognizes our legal and moral responsibility to our environment. In this case an environment which spans an area from the uppermost reaches of the Taunton River Watershed to Mount Hope Bay.  

This permit as drafted does not limit the City of Brockton’s ability to expand, revitalize or pursue any of its long term planning efforts within city borders. In fact the expansion and upgrade proposed by the City has been approved in full by EOEA. The city proposed what they wanted for a sewage facility and they got it. Prohibiting additional hookups from outside the current service area is an essential step in the incremental process of restoring the aquatic ecosystems of the Taunton River. It also protects and conserves the water resources of the upper Taunton River watershed. In fact prohibiting further sewer connections to surrounding communities is in keeping with current EOEA policy as outlined in the Draft Report of the Water Policy Task Force.

 

The following is from the EOEA webpage titled Water Policy Principles

 

PRINCIPLES OF THE WATER POLICY TASK FORCE

The Water Policy Task Group sought to advance the following environmental principles:

Keep water local and seek to have municipalities living within their water budget by addressing issues

from a watershed perspective;

Protect clean water and restore impaired waters;

Protect and restore fish and wildlife habitat; and

Promote development strategies consistent with sustainable water resource management

Recognizing that current utilization patterns of the Commonwealth’s water resources are frequently not

sustainable, that the Commonwealth’s economic growth and quality of life depend on a sustainable water

supply, and that we must create a more effective partnership with municipalities that are empowered with

critical land use and development decision-making authority, the Water Policy Task Force set itself the

following five principles:

The following are excerpts taken from the report of the Water Policy Task Force July 2, 2004.

“We need to rethink how we convey water from its source. We have designed our infrastructure to transport rainfall quickly away from where it lands on the ground, instead of letting it infiltrate. We transport our wastewater as far away as possible from our aquifers, thus preventing recharge. While transporting dirty water away made sense historically we now need to focus on how to keep water clean, and retain and restore it after use so it can be returned locally. Today, with significant improvements in wastewater treatment techniques and standards leading to a treatment level that has made the water potable, it makes little sense to discharge such large quantities of treated water so far away from its source”.

We also need to consider how our aging infrastructure unintentionally transports water. Aging sewer, storm water and water supply infrastructure leak water. Water supply infrastructure can leak water into the ground via cracks in the pipes that are supposed to be sending water to users. Leaking sewer infrastructure takes on ground water and conveys it to treatment plants resulting in increased load on the plant, increased treatment costs, and loss of ground water from aquifers. While many systems practice regular leak detection and repair there are many old systems in Massachusetts that have problems so large that fixing them becomes an overwhelming economic burden. Because of inefficient use, a history of piping water away from its source, and costly, aging infrastructure some of the Commonwealth is plagued by low river flow levels and impaired waters. As development increases outward from the Greater Boston area, more watersheds could face similar difficulties.

“The Commonwealth also has impaired waters and debilitated aquatic habitat areas. Ensuring clean water requires that we do a better job of limiting point and non-point source pollution. Past patterns of growth have introduced impacts such as changes in temperature and oxygen due to runoff, discontinuous critical habitat areas, and altered habitats”.

The problems described above will only get worse if we continue to grow and manage water in the way we have over the past half-century. Over the past 20 years, considerable land mass has been developed, rippling outward from Boston in a series of concentric rings: yet the growth has not, however, sufficed to meet the state’s housing needs. Assuming build-out according to current local zoning, growth will mean both increases in the demand for water, and the development of land critical to future drinking, recreational and habitat purposes. A wise response would be to promote more compact and higher density growth centers, which leave critical water resource areas and habitat areas undeveloped; smarter residential and commercial, as well as highway, designs that incorporate strategies such as water conservation, wastewater recharge and re-use, and storm water recharge; and finally, the aggressive restoration of critical water resources”.

 

RECOMMENDATION 4: Increase treated wastewater recharge and reuse.

 

“Movement of wastewater from the area of origin to wastewater treatment facilities and finally to

discharge areas is the leading cause for water deficits in many of our river basins. Keeping water and wastewater local is one of the main focus areas of this water policy. Wastewater accounts for a large percentage of the water that is lost from a basin; water that could replenish groundwater, rivers, lakes, ponds and wetlands, as well as be used for specific human needs. In areas that are located in stressed basins, the wastewater can be put to valuable use. Once the wastewater is treated and free of pathogens and contaminants, this nutrient rich medium can be used for crops, golf courses, aquaculture, etc. Because of the high nutrient content of the water, crop yields using treated wastewater is higher compared to using regular potable freshwater. Currently treated wastewater is being used in many other states, (e.g., California, Arizona, Florida) and around the world (e.g., Mexico, Mediterranean region, the Caribbean, Peru, India, etc.). The treated wastewater can also be used to augment base flows by direct injection.”

Common sense and our states own policy as quoted recognize that “The problems described above will only get worse if we continue to grow and manage water in the way we have over the past half-century.” To regionalize this plant beyond its current connections to include the towns of East Bridgewater, West Bridgewater, Easton, Avon, Halifax and Hanson is to do exactly what Ma EOEA says we should not do. If indeed we do allow expansion of this plant, then the words of EOEA water policy will come true “The problems described above will only get worse “ The language in this permit which reads “(Page #4 NPDES Permit # MA0101010 paragraph #3;) Flows originating from the Towns of Abington and Whitman are limited each to 1MGD. The permitte shall not accept any new sewer connections in other communities from facilities not currently connected to the WWTP. Increased flows from facilities currently connected to the WWTP shall be offset, to the extent feasible, in order to minimize any net increase in flow to the WWTP.” must remain in the final permit to begin the process of leaving the past half-century behind as Ma EOEA recommends. EPA has wisely taken this bold step to protect our aquatic environments and water supplies from ourselves and from a state agency which is apparently incapable of reading their own website. If dilution is the solution to pollution our course is clear, we must incorporate this language in the final permit for the Brockton Sewer Plant.   

Sincerely,

Tim Watts

Underpaid Executive Director

Glooskap and the Frog 

 

 

 

Glooskap & Frog Home

 

 

 

 

 


 

 

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