LAW, ADVOCACY & POLICY

Charles River Watershed Association Advocacy

2005 Comment Letters

Every year, Charles River Watershed Association writes dozens of letters to the Massachusetts Environmental Policy Act Office analyzing the environmental impacts of potential developments within the watershed.  Comment letters constitute one of the most important tools of advocacy CRWA and the public has at their fingertips.

Below are a selection of our comment letters from 2005.

Draft State Water Conservation Standards - November 3, 2005
The Massachusetts Water Conservation Standards have not been updated in more than a decade, during which time the stresses on the Commonwealth’s water resources have become quite evident. In a joint letter to the state, CRWA and the Conservation Law Foundation call for clearer policies on water conservation and water program planning, better water audits, and more metering.  

Waldenwoods, Milford, Final Environmental Impact Plan- August 23, 2005
Building on the recommendations submitted for the DEIR in May, CRWA makes a number of suggestions for how the project should address irrigation, rare species habitat, stormwater management, and the general project layout in relation to the surrounding wetlands. Specifically, CRWA voices concern about the connection between bedrock withdrawals by the project's wells and ground water levels. CRWA also highlights the rudimentary nature of the project's stormwater management plan. Suggestions include: rain gardens, alternative street design to reduce impervious surfaces, and cisterns to collect and re-use rain water off of roofs for irrigation.

Eaglebrook Village, Draft Environmental Impact Report- July 25, 2005
CRWA makes a number of suggestions for topics that should be covered by the FEIR, including measures to improve: 1. Stormwater management (such as using low-impact development techniques like planting native vegetation in buffer strips and rain gardens), 2. Wastewater management (such as reducing pesticide and fertilizer use to minimize nutrient loading), 3. Water supply issues (such as using low-flow toilets and reporting well locations), and 4. Transportation management (such as encouraging combined residential and commercial zoning and aggressive encouragement of carpooling).

Schoolmaster Lane, Environmental Notification Form (ENF)- July 25, 2005
Dedham continues to run on a water deficit and DWWD has trouble meeting water demand. CRWA notes that the ENF does not allude to the difficulty of DWWD providing the necessary potable water for the Schoolmaster Lane project. In addition, the ENF does not take into account the number of other projects in development in Dedham that also have significant water requirements.  Specifically, CRWA recommends a "water banking" system as part of which for every gallon of additional demand the project requires, the proponent of the project will retain two gallons of water within the basin. Low-impact development techniques are also advocated.

Dedham Westwood Water District Draft Environmental Impact Report- July, 25, 2005
CRWA raises concerns about the potential admission of the Dedham Westwood Water District (DWWD) into the Massachusetts Water Resources Authority (MWRA), calling for a Final Environmental Impact Report to evaluate a wide variety of issues including  the interconnected problems of the water supply and the wastewater system in the DWWD.  Problems include a high level of groundwater infiltration into the Dedham sewer system and water demand outstripping supply in both Dedham and Westwood. Joining the MWRA to alleviate water supply issues for the DWWD may not be a real solution to the watershed issues of the DWWD.

Wastewater Effluent Limits for Biotechnology- July 18, 2005
As the Department of Environmental Protection (DEP) sets new limits for wastewater effluent for biotechnology facilities, CRWA calls for a tightening of restrictions in the proposed limits and suggests that the limits can set a valuable standard that will not only protect the environment and public health but also will help drive innovative technologies. Unfortunately, the proposed limits may set a dangerous precedent for the future instead.  For example, CRWA argues that DEP's proposed limit on mercury is higher than current standards and is actually 80 times higher than the limit in the Massachusetts Water Resources Authority. 

Waldenwoods, Milford, Draft Environmental Impact Report- May 24, 2005
CRWA notes that the project affects the headwaters of the Charles River, an area that is already highly stressed, and the project may create a net water deficit for the headwaters area. Local water sources Echo Lake and Milford Pond show signs of being negatively impacted. The project will affect both the Charles River and Echo Lake and will affect a rare species habitat. CRWA makes suggestions for more effective management of irrigation, rare species habitat, stormwater runoff, and water conservation. 

Public Private Partnerships’ Guidelines- May 16, 2005
CRWA recognizes the need for public private partnerships, and commends the April 2005 guidelines released by the Executive Office of Environmental Affairs's (EOEA) new Office of Public Private Partnerships (OPPP); however, CRWA identifies the need for clearer specifications of monetary allowances, public benefit, and public access to ensure that private involvement does not replace state responsibilities and funding.

Town of Lincoln’s Water Management Act (WMA) Permit Application- April 15, 2005
The Town of Lincoln submitted a required permit application  because the town exceeded authorized water use since 1995. CRWA comments that the heavy water use of the Town of Lincoln, which continues to exhibit increasing water usage, is not in keeping with population growth or other towns in the Charles basin. CRWA suggests amendments to the permit requiring that Lincoln institute: streamflow limits, an offset feasibility study, a waterbank program, and a retrofitting program of all public buildings with water saving devices.

Eaglebrook Village, Environmental Notification Form- March 30, 2005
After the proposal of significant development plans for the Eaglebrook Village in Wrentham, CRWA makes suggestions for the draft environmental impact report (DEIR) including more analysis of how the project will affect water use, wastewater, stormwater, wetlands, and transportation issues in the area, and how these potential challenges may be mitigated.

Urban Ring Phase 2 DEIR - March 30, 2005
As Boston begins to develop its new "urban ring" of public transportation, several concerns about the project's Draft Environmental Impact Report exist.  CRWA comments on the effects to the Fenway neighborhood, alternatives to a tunnel in that area, stormwater management throughout the urban ring and a general concern for the implementation strategy of the entire project.

Fairfield Green in Dedham, Environmental Notification Form (ENF) - March 29, 2005
CRWA suggests that an Environmental Impact Report be issued to address the water, wastewater, stormwater and transportation issues created by the Fairfield Green project in Dedham.  CRWA identifies existing problems Dedham has had with water use outstripping supply and groundwater infiltration, suggesting that the initial ENF does not take into account Dedham's potential incapability to provide the potable water required by the project. CRWA suggests the integration of low impact technologies, such as rain gardens, grass swales, and bioretention basins, into the project's design.

Dedham Senior Campus Community, Final Environmental Impact Report - March 11, 2005
CRWA identifies issues that require further mitigation including the project's impacts on water, stormwater, impervious surfaces, and traffic.  Problems include Dedham's man-made water cycle that is running on a water deficit and removes water from the area without allowing for local aquifer recharge. DWWD is refusing the project public water for irrigation resulting in the planned use of wells which will draw water at the time of year that water in the Charles is already at its lowest. CRWA suggests reducing the amount of turf (which is relatively impervious) on the site, exploring artificial turf products, and relying on rainwater for irrigation.  CRWA also recommends metering the wells and reducing site imperviousness by building structured parking.

Shrewsbury Draft Water Withdrawal Permit Affecting Poor Farm Brook- February 1, 2005
CRWA notes that the draft permit fails to require sufficiently stringent conditions to avoid extreme impacts of water withdrawal on Poor Farm Brook. Levels of withdrawal allowed by the permit distinctly exceed established safe yield, conflicting with WMA policy. The permit also fails to adequately protect local fisheries, habitat, and water-based recreation.  CRWA urges the withdrawal of the permit.

Performance Partnership Agreement 2005-2006 (DEP and EPA) - January 18, 2005
The recent Performance Partnership Agreement (PPA) for the DEP and EPA effectively presents a great deal of information and is an improvement of last year's document; however, CRWA has some suggestions including a "place-based" focus on individual watersheds, a need to integrate inflow-outflow factors such as wastewater, stormwater and water supply in streamflow decision-making, a need for more flow gages, and addressing chronic understaffing problems.