A Cleaner Charles River Campaign

Stormwater Pollution Talking Points

Charles River Watershed Association (CRWA) and Conservation Law Foundation (CLF) have identified eight talking points for commenting on stormwater discharges in these towns.  We invite you to expand upon these points in your comments to EPA. 

• Stormwater runoff is the most significant source of pollution to the Charles River watershed.  When it rains, oil, grease, gasoline, pet waste, cleaning agents, pesticides, fertilizers, and trash on streets, parking lots and other paved surfaces, wash into storm drains. From there, pollutants discharge into the Charles River.

• Stormwater is a major cause of water quality degradation, affecting fisheries, habitat, aquatic flora, recreational uses and aesthetic beauty.

• Effective stormwater management plans are critical to protecting valuable surface water resources from stormwater and ensuring sustainable water use.  All municipalities in the Charles River Watershed are required to develop and implement effective stormwater management plans, and report annually on their progress. 
  
• Certain areas of the Charles have been designated by DEP as "impaired" by pollutants including nutrients, metals, oil and grease, pathogens and priority organic pollutants.  Stormwater is the main source of these pollutants.  The regulations require that stormwater plans specifically address these pollutants.  DCR and the nine towns fail to do so in their plans. 

• Storm sewer operators are legally required to make sure in their plans that their stormwater discharges do not negatively affect water quality.  They can do this by reducing stormwater discharges as much as possible, and reducing the pollutants in the remaining stormwater.  Of the nine towns attending this meeting, some have made significant efforts to comply with the requirements of federal and state regulations.  Others have not.  DCR has failed to comply with the requirements of the stormwater program; it has not submitted plans for most of its properties, and the ones it has submitted are clearly deficient.

• Healthy river flow during the summer is threatened by increases in impervious surfaces, which stop rainwater from seeping into the ground.   Decreased groundwater supplies, combined with increased pumping from upstream water supply wells, make the river even less capable of absorbing polluted stormwater.  Rain should be entering the river as clean groundwater; instead, it is entering the already-stressed river as polluted stormwater.  Thus, the pollutants are more concentrated and do more damage to the ecosystem.  Innovative stormwater management techniques, which reduce runoff at the source by using on-site controls that mimic predevelopment hydrology by decreasing impervious surface areas and promoting infiltration, storage and detention of runoff on site, should be adopted in order to address both pollution reduction and sustainable water use.

• It is vital that these nine towns and DCR design and implement stormwater management plans that comply with the law and effectively address pollution redcution and sustainable water use.  Stormwater discharges represent one of the last great hurdles before we achieve a healthy Charles River, and it will take the complete commitment of all our watershed's towns, DCR, DEP and EPA to address the problem.

• We urge EPA to do a thorough and substantive review of all the nine lower basin communities' stormwater management programs as well as that of DCR to ensure compliance with state and federal clean water laws.

For more information on stormwater permitting, visit:

http://www.epa.gov/boston/npdes/stormwater/index.php

http://www.mass.gov/dep/brp/stormwtr/stormreg.htm

For more information about stormwater in the Charles River, please contact:

Ariel Dekovic, Charles River Watershed Association
48 Woerd Avenue
Waltham, MA 02453
Phone: 781-788-0007 x200
Email: adekovic [at] crwa.org

Carol Lee Rawn, Conservation Law Foundation
62 Summer St.
Boston, MA 02110-1016
Phone: 617-350-0990
Email: clrawn [at] clf.org

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