Tuesday, March 16, 2010

EPA Withdraws Decision

Well maybe people can be made to listen. It looks like our efforts are having some effect.

On February 22, 2010 the Environmental Protection Agency withdrew its approval of the City of Marlborough’s 44% increase in wastewater discharge to the Assabet River. OAR and the Town of Stow had appealed the permit modification in January 2010 citing violation of state water quality standards.


In December 2009 DEP received public comment on a study of other ways to reduce phosphorus in the river, including removing sediment and dams. “Based on the sediment and dam removal study, it is clear that the only feasible way to meet water quality standards in the near future is to have more stringent limits at the wastewater treatment plants,” said OAR’s Acting Executive Director, Alison Field-Juma. “Marlborough’s request to increase their discharge to the river should have been evaluated in light of this new information, as required by law. Until the big questions are solved, allowing an increase in treated effluent discharged to the river is premature, at best. There are alternatives that would still allow the communities to grow, but not pollute the river,”

New discharge permits for the four municipal wastewater treatment plants on the Assabet (Westborough, Marlborough Westerly, Hudson and Maynard), are due out in 2010 and are required to meet the water quality standards. This would become increasingly difficult if the treatment plant discharges were increased.

Thanks to everyone for all the letters and support. Vigillent we must remain.

Tuesday, January 26, 2010

Letter to the DEP V

December 19, 2009

To Whom it May Concern:

I wish to state my opposition to the dam removal project proposed by the Army Corps of Engineers.

The many letters of protest that the proposal has generated iterate most of my ideas: the ridiculous ecological disaster of the dam removal, the irreparable damage to the environment, the prohibitive costs, the problems of fire protection, the possible damage to local wells, and the biased financial interests of the current polluters, the “watertreatment” facilities. I have been to two of the hearings on this proposal, and the many people who speak seem universally appalled by the whole procedure as well as the proposal itself.

My voice represents a small neighborhood of abutters to the river in the Marlboro Road district of Gleasondale (Stow). We have gathered together and discussed the proposal, and we look with alarm on those outsiders who apparently think they act in our behalf. Furthermore, at one of the meetings, the Army Corps representative smiled smugly and implied that the protesters were common “tree-huggers,” i.e., disillusioned and romantic wild–life lovers who stand in the way of progress. With this kind of “dispassionate” and biased opinions running the show, we who are citizens feel steamrollered by a machine which has no particular feeling for the area they seek to destroy.

My tax money indirectly paid for the survey. Our tax money pays the salaries of the Corps of Engineers and the Massachusetts Conservation Corps. Why, then, do they conveniently pocket the Stow protestors as a group to whom thy are not directly responsible?

The proposal to remove the dams is environmentally faulty and financially ridiculous. Kindly hear the many voices of reason and a pursue a more rational course of action.

Letter to the DEP IV

Regarding the proposal by the Army Corps of Engineers to possibly remove the Ben Smith and other dams along the Assabet River.

December 20, 2009

To Whom It May Concern,

I am adding my voice to those against the Corps’ dam removal proposal. Dam removal is NOT the best solution. I’m aware that many have written letters more eloquently—some with greater knowledge of the details. I join them in saying that removing the dams would have more of a negative than a positive impact on the Assabet River.

I have attended three meetings presented by the Army Corps of Engineer during the past two years. From the beginning, the studies and viewpoints seemed to me to be distorted (mostly
one-sided) and disingenuous. There were no details put forth initially on the impact dam removal would have on certain areas of the Assabet (such as in Stow). No study was done on the environmental impact. If some portions of the river are all but “disappeared” what happens to those areas, the water supply, the residential and business wells, the water-life, wild-life, recreational use, etc. as a result?! It also seems to me:

• Allowing the destruction of some of the most beautiful, vibrant, and useful portions of the Assabet Rver and surroundings should NOT be allowed.

• These areas are used and enjoyed by many, including kayakers, hikers, canoers, hunters, fishemen, families—as well as treasured abutters and those living in towns near the Assabet.

• Not only is the Assabet a source of beauty and a haven for wildlife, we in Stow depend on it as a source of water (wells) and fire protection (from the river water).

• A great part of the solution lies in holding the water treatment plants responsible for higher standards; towns with water treatment plants pouring their waste into the river should be held accountable for better treatment facilities; for educating their residents and businesses to use less-polluting substances that end up in the Assabet; to cut back on the waste amount they can put into the river.

My husband I have been abutters to the Assabet River since moving to the Gleasondale area of Stow in 2001. It was the magnificent beauty, the wildlife, and the serenity of this portion
of the river that drew us here. “A “pocket of peace!” is how a visiting friend from Holland refers to it. Not a day goes by without us counting our blessings and good fortune to have our home be this sweet and semi-wild Assabet River! Daily we celebrate the abundant wildlife that inhabit these environs: red-tailed hawl, heron, owls, frogs, a variety of fish species, turtles, muskrats, otter, fisher-cat, river snakes,several duck species, to name just some. As one neighbor down the road put it, “we don’t even have to drive to Maine for this.”

We are aware that over the years many have put in immense effort in cleaning up the river (such as OAR) and bringing it to its current standard. As this is our “back yard” we not naturally want to protect this, and we also feel a responsibility to do whatever we can to protect the Assabet River and wetlands for the future. Once gone, it will not come back.

Finally—as I consider proposed “solution” of dam removal, I cannot help but wonder: Who is getting to decide (and how) which portions of the Assabet River to possibly destroy in order to “save” the river?

Increases in Discharge and TMDL

The discharge permit for the Marlborough treatment plant, which also serves Northborough, was modified in November, 2009 to allow a 40% increase in the wastewater the plant discharges to the Assabet River. The law requires that the permit modification, issued under the state and federal Clean Water Acts, contain sufficient limits on pollutant discharge to enable the river to meet its water quality standard. The river does not yet meet this standard (Class B—clean enough for fishing and swimming), due primarily to the phosphorus contained in the wastewater discharges from four municipal treatment plants.


Why when the Assabet River does not meet the current clean water standards would this plant be allowed to dump more pollutants into our river.

We thought we were talking about TMDL. The Total Maximum Daily Load of phospourus in the river.

The discharge of phosprous is measured in mg/l (milligrams/liter)
A 40% increase in (liters) without a decease in (milligrams/liter) leads to a 40% increase in phospourus.

The current permit includes an annual average flow limit of 2.89 MGD and a 54 month compliance schedule for meeting the April- October 0.1 mg/l monthly average total phosphorus limit. Because the compliance schedule for meeting the new phosphorus limit was a contested condition, the schedule did not become effective until May 17, 2006, making the final compliance date November 17, 2010. An interim total phosphorus limit of 0.75 mg/l average monthly is in effect for the months of April- October. The monthly average total phosphorus limit of 1.0 mg/l for the months of November- March was required to be met within one year of the issuance date of the permit.


Because of the flow increase, EPA made changes to the effluent limitations to ensure that the discharge does not exceed the wasteload imposed by the TMDL nor exceed applicable water quality standards. The specific changes are described below.

Total Phosphorus

The total phosphorus concentration limits in the permit modification have not been changed, but mass limits have been added, calculated using the concentration limits and a flow of 2.89 MGD. In order to achieve these mass limits as the discharge flow increases, the facility must achieve ever-lower concentrations of total phosphorus, down to 0.07 mg/l to achieve the summer limits at the new design flow and 0.7 mg/l to achieve the winter limits at the new design flow.


Status Quo is not good enough. The river does not currently meet the Class B standard (clean enough for fishing and swimming).

Why is this plant still not being held to a year round limit of 0.07mg/l. The technology is available.

If the City of Marlboro can not afford to not to pollute our river. Then we say they can not afford to continue with this unchecked development.

Common sense tells us that some of the money from all this development, which is currently going to line the pockets of developers and politicians, needs to be redirected towards correcting the problems with this and other wastewater treatment plants along this river.

Enough is enough the Assabet River can no longer be Marlboro's or anyone else's sewer.