LAW, ADVOCACY & POLICY

Charles River Watershed Association Advocacy

2006 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 2006.

Westwood Station, Expanded Environmental Notification Form - September 25, 2006
CRWA comments on the Dedham Westwood DEIR, taking note of the large demands that would be placed on the water district.  A few of CRWA's comments are: the EIR should contain more detail about wastewater management and irrigation demand, clarify whether any wastewater infiltration is planned during the summer months, and the proponent should commit to exceeding the building code requirements for lower water use plumbing fixtures.

Newton Dock Comments, Chapter 91 License Application - September 21, 2006
CRWA is concerned that a large private boat dock, proposed in Newton, will detract from the public’s use, enjoyment and the aesthetic beauty of the river, and may encourage similar development for other private residences abutting the river in this area.  CRWA suggestions the size of the dock be dramatically reduced and long-term boat docking prohibited. 

Storrow Drive Tunnel, Environmental Notification Form - June 13, 2006
CRWA's suggestions to alleviate environmental impacts include water quality impact assessments followed by the implementation of stormwater source control and best management practices, and thorough analysis of potential impacts to groundwater. 

Dana Farber Cancer Institute, Environmental Notification Form - May 11, 2006
CRWA suggests that the cumulative environmental impacts of increased development in the Longwood Medical Area need to be addressed, including increased use of the Emerald Necklace Park system. Stormwater drainage needs to be assessed, with special consideration to the Muddy River, as do groundwater impacts from the proposed underground parking facility.

Legacy Place Development, Draft Environmental Impact Report - May 10, 2006
CRWA does not believe that the DEIR adequately and properly complies with MEPA, and thus requests that a further report be issued to more closely examine issues of an alternatives analysis, stormwater and drainage, and water and wastewater.

Proposed changes to MA Surface Water Quality Standards - March 1, 2006
In a joint letter to the state, CRWA and the Conservation Law Foundation (CLF) express concern that that the revisions fail to establish a narrative streamflow criteria, ignore the impacts of low flow and activities other than “discharges” on water quality and designated uses, and also seriously weaken the bacteria standard.

Chestnut Hill Square, Draft Environmental Impact Report - February 21, 2006
CRWA is particularly interested in the redevelopment of this site because of its location in the headwaters area of Saw Mill Brook, a tributary to the Charles River that has been significantly impacted by development. CRWA suggests that the FEIR should provide significantly more detail on the stormwater management system, more detailed plans for sustainable site provisions, and an analysis of opportunities to incorporate Low Impact Development techniques appropriate for urban areas.

Franklin Heights Estates, Environmental Notification Form - February 15, 2006
As the town of Franklin is one of the fastest-growing in the I-495 region, CRWA  recommends that an EIR be submitted to address the amount of impervious surface, ability of the municipal water supply to meet increased demand, and implementation of water conservation measures. Stormwater management and wetlands buffer zones are also areas of concern with this project.

South Natick Hills, Environmental Notification Form - January 9, 2006
CRWA requests that an EIR be prepared, including a detailed alternatives analysis for the site, thorough analysis of the hydrologic impacts of the proposed project, documentation of the proposed stormwater management plan (both conventional and Low Impact Development, or LID, techniques), an assessment of the opportunities and alternatives for maximizing groundwater recharge while still protecting groundwater quality and documentation of the assertion that there is sufficient water supply and wastewater capacity for this project.