Friday, December 18, 2009

Letter to the DEP III

Massachusetts DEP
Division of Watershed Management
Attn: Alice M. Rojko
627 Main Street
Worcester, MA 01608

CC: Congresswoman, The Honorable Niki Tsongas, Massachusetts Fifth District; MA State Senator Mr. James Eldridge; MA State Representative Ms. Kate Hogan; Engineer Inspector General, US Army Corps of Engineers; Town of Maynard, Chairman Board of Selectmen, Mr. David Gavin; Maynard Town Administrator Mr. John Curran; Chairman Maynard Conservation Commission Mr. Fred King; Town of Stow, Chairman Board of Selectmen; Mr. Stephen M. Dungan; Chairman Stow Conservation Commission Mr. David Coppes;

RE: Assabet River Dam Removal and US Army Corps of Engineer draft report

December 18, 2009

Dear Ms. Rojko,

As abutters to the Ben Smith Impoundment and the Assabet River, the proposal to remove the historic Ben Smith Dam will have a direct impact on our family, our home, our community and the history that reminds us of who we are, and how and why we happen to be here in Maynard and Stow.

Our family has lived alongside the Assabet River for multiple generations as have many of our neighbors. We have seen great floods. We have seen the river run multi-colored from dyes that were dumped directly into the water. We have seen duckweed so thick you could walk on it. We have seen this river used as a dump site for household waste, tires, cars etc. We have made great strides over the years to clean up the river. However, the Assabet River's pollution problems are still here, just not as obviously as before. But should we throw out the baby with the bath water?

We believe that the negative impact of removing the Ben Smith Dam 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 our entire neighborhood would have to be dug up for multiple years to remove sediment. All this so that waste water treatment facilities (WWTFs) can continue to pollute the Assabet River. No, thank you.

The Ben Smith Dam is in excellent shape. It is properly maintained and is not at risk of failing. However, removing it has many risks and consequences.

If this plan were to go forward it would mean the loss of water for recreation, agriculture and fire protection, and loss of critical water sources for area businesses such as orchards, farming, golf courses, etc. It would also cause a multi-year disturbance of hundreds more acres of our neighborhood – a plan that would require the removal of 42,000 truck loads of sediment, that can not be disposed of anywhere in New England. We also would loose the recreational value of the area for most, if not all, of the year. Canoeing, kayaking, and fishing will be greatly impacted if not outright lost. Additionally, shallow wells will obviously be affected by this drop in the water table, however people with artisian wells need also be concerned. The loss of hundreds of cubic acres of impounded water will have a significant impact on groundwater recharge as well as deep aquifer recharge.

In addition, the function of flood control can not be glossed over, as more and more development has occurred in historic floodplain areas protected by dam. All dams, even ones that have been converted to fixed weir, provide flood control. It is a natural consequence of restricting the river. Most of the Town of Maynard is down stream of the Ben Smith Dam. And therefore will be at greater risk of flooding if this dam is removed.

The historic mill complex and its associated structures, like the dam and the impoundments, are resources that must be protected. Without the physical reminders of our history, we will quickly fall victim to the allure of revisionist history. Tearing down buildings and changing the names of streets or removing the vestiges of industrialization besmirches the memory of all those hardworking people who made it possible. Out of sight is out of mind, and out of the history books.

This proposal and all it entails, will only allow WWTFs to continue to pollute the Assabet River. Dam removal only relocates the problem down stream. We are very concerned that this is the same water that ultimately finds its way into the Billerica public drinking water supply. And as if all that were not enough, 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 must fix this problem at the source. The WWTFs are the cause of the phosphorous issues in the Assabet. It seems clear that the best solution for all involved is tighter winter limits on phosphorous discharge, followed by a plan to discontinue the practice of surface water discharge entirely.

The current practice of discharging waste water into the river is unsustainable and it must ultimately be stopped. Phosphorous is only the tip of the iceberg - nitrogen, pharmaceuticals, etc., are also being dumped into our river. The towns operating these WWTFs are pumping water from ground and local surface sources and then dumping the majority of it out of the recharge areas of their water supplies. These towns need to keep their water local to recharge their local ground water sources.

Why is the Marlboro facility being allowed an increase of discharge into the river instead of utilizing groundwater disposal, like the Acton WWTF? While at the same time the current TMDL can not be met. Any increases in discharge are in direct contradiction to reducing total phosphorous levels in the Assabet.

The recommendation to remove the Ben Smith Dam must be stricken from the US Army Corps of Engineers' "Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study." The data in the report does not support the conclusion. The scope of this study was so limited as to exclude the obvious option of tighter winter limits. Fortunately CDM had to model this scenario anyway. It is the baseline condition for all of their models. Unfortunately we have not been given a straight answer as to what the appropriate winter limit is to get us the “magic” 90% reduction in P Flux. The recommendation to remove the Ben Smith Dam can not possibly be drawn from this report. There are so many contraindications to this plan that further study would be good money after bad. It is clear from the report that the conclusion must be tighter winter limits on phosphorous discharge.

This report and its executive summary must be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1mg/l must be mandated for any and all discharges into the Assabet River with no exceptions. Towns that are currently discharging into the Assabet River need to start allocating open space in their own communities for groundwater discharge sites or they will have to curtail their development plans.

The above abutter objections must be clearly outlined in the report, in the conclusion and in the executive summary.

Thank you. We are happy that our voices can be heard in this great democracy. We have faith that the peoples voices will be heard and reflected in the actions of our elected representatives.

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