Saturday, November 14, 2009

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.


  1. Why are the wastewater treatment facilities being granted exemptions to existing state and federal statues as to phosphorus discharge levels? I can appreciate the concerns of residents of Shrewsbury and Marlboro as to not wanting to pay more for their sewage treatment, however, why should residents of other towns bear the cost of their waste? Why can’t they be compelled to abide by the 0.1mg/l discharge limit? Removal of the historic Ben Smith dam irrevocably alters our towns’ wildlife habitat, scenic beauty, and recreational opportunities, while doing nothing to alter the root cause of the pollution in the river: Excessive discharge of phosphorus during the winter months, 10 times the recommended level of 0.1 mg/l. This river has undergone many changes over my lifetime. It is now a vibrant, rich ecosystem. Further improvements to the quality of the river and its environs is highly desirable, and therefore eliminating the discharge of waste water into the river should be the top priority of anyone interested in protecting and nurturing our local ecosystem. The removal of the dam only transfers the problem downstream while diminishing our local resources. The externalities of the river clean-up should be borne by those causing the pollution in the first instance. DEP should not be granting waivers and instead should be enforcing its own guidelines for phosphorus discharge.

  2. At last nights meeting, Rick Dunn of the DEP would not comment. If it was possible to hold these limits. Maybe Thursday he will have a better answer for us.