Thursday, November 19, 2009

Upstream Downstream a Contemporary Fable

It was many years ago that the villagers of Downstream recall spotting the first body in the river. Some old timers remember how spartan were the facilities and procedures for managing that sort of thing. Sometimes they say, it took hours to pull 10 people from the river, and even then only a few would survive.

Though the number of victims in the river has increased greatly in recent years, the good folk of Downstream have responded admirably to the challenge. Their rescue system is clearly second to none: most people discovered in the swirling waters are reached within 20 minutes-many less than 10. Only a small number drown each day before help arrives - a big improvement from the way it use to be.

Talk to the people of Downstream and they'll speak with pride about the new hospital by the edge of the waters, the flotilla of rescue boats ready for service at a moment's notice, the comprehensive plans for coordinating all the manpower involved, and the large numbers of highly trained and dedicated swimmers always ready to risk their lives to save victims from the raging currents. So it cost a lot, say to the Downstreamers, but what else can descent people do except to provide whatever is necessary when human lives are at stake.

Oh, a few people in Downstream have raised the question now and again, but most folks show little interest in what's happening Upstream. it seems there's so much to do to help those in the river that nobody's got time to check how all those bodies are getting in the river in the first place. That's the way things are sometimes.

Strength in Numbers

There is strength in numbers. No this is not about boring calculations.

It is about our ability to get our voices heard. We can be more effective as a group than as unorganized individuals.

Along this line we are thinking about a community group to represent the interests of those along the Ben Smith Impoundment and elsewhere along the Assabet River. Other Community Action groups have been very successful at influencing public policy.

If you would like to be a part of the new "Ben Smith Consortium" Please take the time to send your contact information to or follow the permanent email link to the right.

Together we can make this happen.

Wednesday, November 18, 2009

Wayland has to Hold 0.1mg/l Year Round

In an agreement between US EPA and the Town of Wayland signed in August of  2009

"A year-round total phosphorous effluent limit of 0.1mg/l for the discharge to either the wetland or the Sudbury River"$File/EPA%20R1%20Wayland%20Fourth%20Status%20Report%20-%20Exhibit%201%20settlement%20agreement...69.1.pdf

Sounds like its not as impossible as the "consortium" would like you to believe.

Make sure the DEP understands that the Assabet is just as important as the Sudbury.

What Can You Do? (11/18/09)

Attend the meeting this Thursday in Stow, see post below for info.

If you are writing a letter please bring it and read it aloud, so that others can hear your concerns and include them in their letters to the DEP.

After attending the first meeting Tuesday night, we were amazed at the difference between this meeting and meetings we have attended that were sponsored by OAR, the Organization for the Assabet River. There was open and fair dialogue, and we were told that if the DEP received comments in writing (preferably by email), those concerns would be included in the report. 

Don't drop the ball, make sure you send your letters!

Monday, November 16, 2009

Letter to the Conservation Commission

Dear members of the Conservation Commission,

We need your help,

Many property owners abutting the river and elsewhere in town are concerned about the Army Corps of Engineers proposal to remove the Ben Smith Dam in Maynard. As you know this will affect hundreds of acres of wetland in Stow and Maynard. While we understand that wetlands protection is not the only mandate of the Conservation Commission, we are very concerned about this impact. We are also concerned about the impact to agriculture recreation and open space.

"Today many Conservation Commissions spend the bulk of their time hearing and conditioning wetlands cases. While this responsibility is vital, it often leaves inadequate time for open space protection and other matters. " - Mass. Assoc. of Cons. Coms.

The resource value created by the Ben Smith Dam goes far beyond the wetlands issue.

We the people are very concerned that when a property owner wishes to build a shed, remediation and landscaping plans that are "invasive" to our lives and privacy are required. However when large government agencies plan to modify hundreds of acres of wetlands, that they don't even own, as a limited project, the Conservation Commission is strangely silent.

What is the Conservation Commission doing to make sure that the Army Corp of Engineers and the DEP for that matter are not allowed to come into our town and mandate the loss of water for agriculture and fire protection along with the loss of 100 acres of wetlands, and a multi-year disturbance of hundreds more acres? This disturbance will likely cause contaminated sediment to be dislodged and transported down stream effecting plants animals and people. Irrigation and drinking water sources will be disrupted by changes in water level or by dislodged contaminates (Billerica?). We will loose the recreational value of the area for most if not all of the year. Canoeing kayaking and fishing will be greatly impacted. The Historic Mill Complex and its associated structures, like the dam and the impoundment, are resources that must also be protected. And what really bothers us is that - all this is so other towns can save a few bucks and continue to pollute our river. We have paid for Title V septic systems sometimes more than once. We have been forced to put in new wells to accommodate increasingly complex septic systems that take up more space in our yards -- why shouldn't the WWTFs in these other towns have to do the same?

We the People would like the Conservation Commission to represent the will of the people in our town and stop this from happening.

Make sure the Army Corp of Engineers is clear that we will not go forward with this plan. And that those objections are recorded within their report.

Let the DEP know we will not allow other towns to continue to pollute the Assabet River. These WWTFs must be made to hold their phosphorous discharges to 0.1mg/l all year long.

If the Conservation Commission is unable or unwilling to do so we will take our issues directly to the selectmen.

Thank you,

The People who live here.

Sunday, November 15, 2009

Assabet River Sunset

The neighborhood is a buzz with talk of the river's future

But on a night like this we long for days that move at the speed of the river

Is it so wrong to move slowly?

The Assabet is in no rush, perhaps we should heed its lesson

Letter to the DEP

Ms. Rojko

As abutters to the Ben Smith Impoundment in Maynard MA, the proposal to remove the Historic Ben Smith Dam will have a direct impact on our family and our home. We believe that the negative impact on the recreational value alone would be enough to oppose this plan. But the loss of history, culture, and community identity could not be remediated. As we have researched more we realize that the claims of environmental improvement will actually result in a loss of 100 acres of wetlands. In addition we are to have our entire neighborhood dug up for multiple years. All this so that WWTFs can continue to pollute the Assabet River. Dam removal only relocates the problem down stream. It seems clear that the best solution for all involved is tighter winter limits on phosphorous discharge.

We request that the recommendation to remove the Ben Smith Dam be stricken from the US Army Corps of Engineers "Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study". We feel that this proposal does not meet the TMDL Phase II requirement of a 90 percent reduction in sediment phosphorus flux and is repugnant to the myriad concerns acknowledged in the report.

We request that instead the report should be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1mg/l should be mandated for any and all discharges into the Assabet River with no exceptions.

We also request that the above abutter objections are clearly outlined in the report and in the conclusion.

Thank you,

We'd like to see more sample letters keep them coming.

Saturday, November 14, 2009

Nothing in this Hand....Where did those wetlands go?

From the Corps of Engineers report.

"* MADEP classified a significant portion of the Ben Smith Impoundment area as Deep Marsh ~100 acres. However if this classification were changed to open water then the change in wetlands would be as shown in parentheses in the above Table."

Why would the Corps want to change the classification of these wetlands? 

Wouldn't it be nice if every time we ran across a problem in life we could just change the rules and make that problem go away?

"The term “freshwater wetlands”, as used in this section, shall mean wet meadows, marshes, swamps, bogs, areas where groundwater, flowing or standing surface water or ice provide a significant part of the supporting substrate for a plant community for at least five months of the year; emergent and submergent plant communities in inland waters; that portion of any bank which touches any inland waters. "

"The term “marshes”, as used in this section, shall mean areas where a vegetational community exists in standing or running water during the growing season and where a significant part of the vegetational community is composed of, but not limited to nor necessarily including all, of the following plants or groups of plants: arums (Araceae), bladder worts (Utricularia), bur reeds (Sparganiaceae), button bush (Cephalanthus occidentalis), cattails (Typha), duck weeds (Lemnaceae), eelgrass (Vallisneria), frog bits (Hydrocharitaceae), horsetails (Equisetaceae), hydrophilic grasses (Gramineae), leatherleaf (Chamaedaphne calyculata), pickerel weeds (Pontederiaceae), pipeworts (Eriocaulon), pond weeds (Potamogeton), rushes (Juncaceae), sedges (Cyperaceae), smartweeds (Polygonum), sweet gale (Myrica gale) water milfoil (Halcragaceae), water lilies (Nymphaeaceae), water starworts (Callitrichaceae), water willow (Decodon verticillatus). "

"The term "marshes," as used in this section, shall mean areas where an emergent vegetative community exists in standing or running water during most of a normal growing season and where a significant part of the vegetative community is tolerant of sustained partial submergence. Deep marshes have near continuous standing water and are dominated by aquatic plants with floating leaves."

"The term "wetland succession," as used in this section, shall mean the following generalized sequence in wetland evolution. For freshwater wetlands the sequence is pond, to deep marsh, to shallow marsh, to shrub swamp, to forested swamp, to bog."

That sure sounds a lot like the Ben Smith Impoundment.

Don't let the DEP reclassify your wetlands out of existence.

You Want to Dig up What???

Proposed Dredging from Dowtown Maynard a mile upstream past Crow Island

Not sure how hydraulic dredging equipment at Rt 117 will be able to dredge a mile upstream.

Why would the schedule for Gleasondale be 35% longer for less than half the dredge volume? It seems like the sediment removal for the Ben Smith Dam was glossed over in the 20 month schedule presented.

Only $13M, but wait that just leaves us with a 150 acre dirt pit. How much is the effort to revegitate with non invasive species going to cost?

BTW how much for the great new park that will bring more dogs and visitors, with their associated waste, litter and poop, into our back yards?

How much did we really end up spending on the Big Dig? 4X overruns are pretty common place these days. So that $13M is quickly going to end up being $50+M. And where is this money coming from?

I'd like to talk to these guys with the deep pockets. I'm sure they have a good reason why we can't spend this money to address the root cause of this problem, excessive phosphorous levels caused by these WWTFs. Its time to stop playing the games and make these facilities clean up their acts.

If DEP wants to spend $50M the right place is on these WWTFs not on dam removal.

Why is the Corps of Engineers Involved?

Back in 2005

FEDERAL FUNDS SOUGHT FOR CLEANUP -- A recent trip to the nation's capital yielded no commitments but ''cautious optimism" about the possibility of getting aid from the federal government for the cleanup of the Assabet River, according to Paul Blazar, town executive assistant. Blazar met with aides to several Massachusetts senators and congressmen to ask for help with the multimillion-dollar cleanup required by state and federal environmental agencies. Blazar represented a consortium of affected communities -- Hudson, Marlborough, Maynard, Northborough, Shrewsbury, and Westborough. With him were two representatives of the private Organization for the Assabet River. While the congressional aides promised to look for funds, one likely source, the Army Corps of Engineers, has had its budget slashed for next fiscal year. ''Any cautious optimism is tempered by that reality," Blazar said. -- Connie Paige

Paul Blazar is the executive assistant for the Town of Hudson.

Back in 2001

"recognizing that impending environmental regulations will probably restrict the town's current waste-water discharge into the Assabet River, Hudson, Massachusetts' officials are considering imposing a moratorium on new sewer connections"

I guess Paul or some others came up with a better plan...........

Why not get the Corps of Engineers involved, then somebody else can pay to clean up this mess.

I guess some of us are still confused as to how this plan, of taking down dams and letting this phosporous, which is acknowledged as "bad", flow further down stream, fixes the problem?

Letter to the Editor

Dear Editor:

Advocates of removing the Ben Smith Dam on the Assabet River in Maynard note two primary problems with the Assabet River: (1) the discharge problem wherein wastewater treatment plants upstream of Stow discharge wastewater including phosphorus into the Assabet River which causes the growth of algae and duck weed and (2) the impoundment problem wherein the phosphorous settles in the slow moving water behind the Ben Smith Dam and continues to cause the growth of algae and duck weed.

Remove the dam, these advocates assert, and the impoundment problem goes away.

The truth is, the impoundment problem pales in comparison to the discharge problem caused by wastewater treatment plants upstream from Stow discharging phosphorus into the river. Removing the dam has nothing to do with the discharge problem. But, if the discharge problem were eliminated, the impoundment problem would be corrected as well.

Many communities including several on the Assabet River, others in Massachusetts, and across the nation do not discharge wastewater into rivers. Numerous technologies exist for wastewater treatment other than discharging wastewater into our nation’s rivers. Restoring the Assabet River to its “natural” state is a fiction so long as wastewater treatment plants continue to discharge wastewater into our river.

We, the home and property owners on the Assabet River who look at and interact with the river every day by kayaking, boating, fishing, hunting, and the like urge our local, state, and federal officials to seriously consider the real impact of removing the Ben Smith Dam. We would much rather deal with the duck weed and algae in August of each year than an unsightly one foot deep impassable narrow stream, the loss of wetlands, and our way of life.

Leave the dam alone.


Letters like this need to be read by the people making these decisions.

If you have written or are about write a letter, and you would like to share it with others who might not be skilled writers, please let us know. We will start a new post for your letter, so that others will be able to see and comment on what you think.

These Measures Are Inadequate

"Phase 2 of the TMDL required additional projects be implemented to continue to decrease total phosphorus loading to the river. The phosphorus TMDL indicated that to achieve water quality standards a 90 percent reduction in sediment phosphorus flux was needed in addition to decreasing the WWTFs effluent to 0.1 mg/l. Measures suggested to achieve the 90 percent sediment phosphorus flux reduction included dam removal and dredging. If these measures were determined to be inadequate in achieving the desired reduction in phosphorus loading to the river then further decreases in discharges of phosphorus from the WWTFs would be required."

Based on the CDM study, Removal of the Ben Smith Dam plus the summer limits of 0.1mg/l are projected to create a 70% reduction. 60% of that is reduction from the summer limits.

It is pretty clear -- and it has been for some time now -- that this proposal does not meet the TMDL requirement.

In addition this proposal does not address the "root cause" of this issue. "Consortium Towns" are dumping too much phosporous into the Assabet River. Taking any dams out will only allow this pollution to float further downstream and become someone elses problem.

Please, as abutters and stakehholders, make sure the Mass DEP understands: We the citizens of Maynard and Stow are tired of having our home used as a dumping ground so others can save a few bucks. If the DEP feels that there is an extra $13-$50 million of state and federal money floating around to remove our dam, then lets spend it to really fix the problem.

I'm still waiting for an answer: Why can't these new wastewater treatment facilities (WWTF) hold 0.1mg/l in the winter? Even if the 0.1mg/l winter limits are only half as effective as the summer limits that still makes the 90% reduction mandated.

The new Co-Mag systems that these WWTF are installing can do it in the summer.

Thursday, November 12, 2009

Who Would Want to Take Down Our Dam?

From the Blog "Shrewsburied," Thursday, November 15, 2007
(Shrewsburied covers issues of concern to residents of Shrewsbury)

"Sewer fees up 70% in 2010"

"Much of the revenue from the higher fees will fund a $19.5 million upgrade of the treatment plant. Specifically, a new phosphorus-removal system will reduce the amount of phosphorus discharged from the plant into the Assabet River. Presently each day the plant discharges about 28 pounds of phosphorus dissolved in 4.4 million gallons of treated water; by 2010, that will drop to about 4 pounds in 4.65 million gallons. The state and federal governments want less phosphorus in the Assabet River because phosphorus fertilizes algae growth in the river during late summer."

"The state encouraged the town to build the treatment plant, and the state approved the location, design, and operation of the plant. The state also specified the standards that the treated water must meet before it can be discharged into the Assabet. But when the state decided that the plant was polluting the Assabet, Shrewsbury -- not the state -- had to pay to correct the problem. Tens of millions of dollars that could have been spent on Shrewsbury's schools, police, and other departments will instead be spent to clean a river that doesn't even flow through Shrewsbury."

The Assabet does flow through Stow and Maynard and that's where some of the sewerage that these towns are dumping is ending up. Beyond that, in order to be able to continue dumping in our yards these towns would like to take down the Ben Smith Dam because it will save them tax dollars, and BTW its not their town.

I would like to give the good people of Shewsbury, Northboro, Westboro, Marlboro, Hudson and even Maynard, the benefit of the doubt here. I'm sure they are not aware of what the "Consortium" is doing in their names.

I am a bit concerned that the "Consortium" proposes that it is OK to continue polluting the river, so long as it flows away quickly. If it doesn't pool up and linger too long in front of anyone important's home, then its OK. I wonder what the people of Billerica think about all this.

Here's a picture of the water intake station for the Town of Billerica Drinking Water Plant along the Concord River......Guess where what we dump into the Assabet ends up?

The Assabet River is not a magic conduit. Things that are dumped into the river do not magically disappear. They end up somewhere else. And when they do somebody has to clean up the mess. Taking down these dams will just move the problem somewhere else.

I personally do not feel that my community should have to pay the price so that people in these "Consortium" towns can avoid paying to clean up their own mess.

Wednesday, November 11, 2009

Not all Dams Should be Torn Down

From American Rivers Inc. , an organization that "protects and restores America's rivers for the benefit of people, wildlife, and nature":

"While hundreds of dams have been removed, that does not mean that all dams should be torn down. In fact, very few of all documented dams in the United States are even being considered for removal. The removal of 400 dams represents just over one-half of one percent of the more than 75,000 dams over six feet tall existing across the country. Many dams continue to serve important public or private functions such as flood control, irrigation, and hydropower generation. In some cases, changing the way a dam operates will provide enough ecological improvements to the river to justify the continued benefits of the dam. In other cases, removing a dam could have adverse ecological effects – such as the release of contaminated sediments – that are too costly to mitigate. And in some cases, dams are retained because they represent a significant aspect of the community’s history."

"Making a final decision, once all of the information is collected, will be affected by many factors, including:

• The ecological circumstances surrounding the case;
• The economic circumstances surrounding the case;
• The complexity of the issues;
• The legal and political context in which a decision must be made;
• The impetus for considering dam removal (e.g., fisheries restoration goal, dam safety concern);
• The identity of the decision makers (e.g., dam owner, state agencies);
• The amount of controversy surrounding the decision; and
• The number, identities, and strength of various stakeholders."

Some who have and continue to hold one sided meetings pushing the agenda of Dam Removal would like these bottom two issues not to exist.

And if we remain silent they won't exist.

Take the time to let these people know that there is a hugh amount of controversy surrounding this; and as abbutters and citizens of the towns affected by this plan we are stakeholders and our strength is growing. We must enter our concerns into the public record NOW.

Send a letter or two, to those decision makers. Other posts will show you how.

Monday, November 9, 2009

An Additional Finding

Also in the Army Corps of Engineers Sediment and Dam Removal Feasibility Study....

"An additional finding of the CDM analysis was that phosphorus discharge in the winter is an important part of the annual phosphorus budget in the Assabet River. This finding appears to indicate that lower winter limits on WWTFs discharge of phosphorus may contribute significantly to reducing sediment phosphorus flux and might be another control measure for DEP and stakeholders to consider to control phosphorus loading to the river." Page ES-2

Although this sounds like a much simpler and farther reaching solution, the Army Corps of Engineers has decided that The Ben Smith Dam should be removed because it would provide "a 2.8 lbs/day decrease in P loading". How many extra pounds per day are being dumped into the river from November to March?

And BTW, if the Million Dollars per Decrease in Impoundment River Mile(DIRM)M$/DIRM is half as much for Allen Street, why has the Ben Smith Dam been selected. I think it's pretty clear that this recommendation was based on DPO, that's Dollars (to the Corps) per Option.

Well since we are talking "Metrics", here's one: Cost per Page (CPP) at 330 pages and one million dollars this report has a CPP of $3,030/page. Is that good? Is that bad? Well, we could compare that to the CPP of other government reports but that's not really very useful is it? Maybe we should look at non government reports as well.....

What is the Value per Dollar or VPD for each of our options here. Is the VPD of this report greater than the VPD of Upgrading Waste Water Treatment Facilities? Is it greater than operating these facilities so that they do not pollute in the winter as well as in the summer?

I guess it all depends on who you ask. I'm sure the people doing the dumping will have a much different opinion than those getting dumped on. I guess my family should just be thankful our drinking water does not come from the river.

Is it just possible that there are better things to spend our taxpayer dollars on than enabling municipalities to continue to pollute. What's the VPD for just doing what's obvious: a year round limit of 0.1mg/l?

(math geeks please note the VPD for doing nothing is infinite)

What Can You Do? (11/9/09)

READ the reports - Follow the link to the Army Corp of Engineers Reports:

ATTEND the public informational meetings!!! Bring your questions & comments.

Two public informational meetings will be held to present the analyses and findings of the planning study:
Date: Tuesday – November 17, 2009
Registration at 5:30 p.m. with presentation from 6:00 to 8:00 p.m.
Best Western Royal Plaza Hotel and Trade Center - Salon E
181 Boston Post Road
Marlborough, MA 01752

Date: Thursday – November 19, 2009
Registration at 5:30 p.m. with presentation from 6:00 to 8:00 p.m.
Hale Middle School
55 Hartley Road
Stow, MA 01775

And more importantly:

WRITE a letter - Make sure the DEP knows what the people who live here think.
MassDEP will consider all comments on this draft report and it will be revised as appropriate.

All comments must be submitted in writing, preferably in an electronic format, and must be received by December 21, 2009. Comments should be submitted to:


Or mail to:
MassDEP - Division of Watershed Management
627 Main Street
Worcester, MA 01608
Attention: Alice M. Rojko

The Army Corps of Engineers Report - First Impression

I would like to say that although I have not completed the entire 330 pages (I have read about half of it so far), I would like to say that I am quite impressed with the level of detail covered by this report.

I am also a bit disappointed that most of it was a mere footnote to the recommendation in the conclusion. I guess I'm a little unclear on the purpose of the report vs the propaganda it's being used for. Was the purpose of the report to tell us which Dam to take down or should it have better addressed whether we should take these dams down at all? I'm pretty sure I can argue for the feasibility of anything so long as I can disregard all the contra-indicators.

What is this Blog About

As you may or may not know there is a movement afoot to change our river and our community. People have been spending our tax dollars studying how to best change our river and directly effect our lives and property. The Army Corps of Engineers has completed a study and has issued their draft report recommending the removal of the Historic Ben Smith Dam, which will require dredging from the millponds in downtown Maynard past Crow Island.

How will removing the Dam affect our river?

For those of you who are not aware, the Ben Smith Dam is part of the historic mill complex in Maynard. It is responsible for the current geography of the river from Maynard to Gleasondale. Removing the Dam will result in the water level dropping 7 feet – turning the river into a shallow narrow stream, severely curtailing if not eliminating it's viability for Canoeing Kayaking or Fishing, not to mention destroying its current beauty and aesthetics along with 100+ acres of wetlands. Ask your conservation commission if this really qualifies as a "Limited" project.

Why would anyone want to remove the Dam?

Some would like you to believe that the Dam is the cause of our river not meeting state and federal clean water standards. On the other hand some believe that removing the Dam will only allow towns upstream to save their local tax dollars and continue to pollute our river. A consortium of towns who dump their wastewater into our river have decided that it is better to remove our dam then for them to simply conform to the same clean water standards in the winter that they are already required to comply with in the summer.

Why, after the enormous capital expenditures these towns have undertaken to upgrade their wastewater treatment plants to hold a 0.1 mg/l phosphorous discharge level in the summer, do they still balk at the incremental cost to maintain this level in the winter? It is stupefying that they would rather ruin the profound natural beauty of our neighborhood, the recreational value, and the wildlife habitat – as if dumping their waste into our yards was not insult enough.

Are there other solutions?

How far could the million dollars spent on this study – or the proposed $13 million (More like $50M) that it would cost to remove the Ben Smith Dam – go towards winter operating costs? But that's state and federal money instead of their town money so that makes it better for them but unfortunately it is at our expense.