LAW, ADVOCACY & POLICY

Charles River Watershed Association Advocacy

2007 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 2007.

Stone Ridge (Milford), Environmental Notification Form - December 3, 2007
One of the least environmentally-sensitive projects we have reviewed this year, CRWA encourages an in-depth alternatives analysis that will consider environmental impact to the river, wetlands, habitat, and open space. The site's stormwater management system should be improved to filter and treat runoff, and reduce phosphorus loading by 65% to comply with the new Total Maximum Daily Load.

Read the Secretary's Certificate filed Dec. 12 requiring Stone Ridge to file an EIR, based on comments by CRWA and others.

Dexter School, Chapter 91 License Application - June 21, 2007
CRWA promotes public use of the river and we are concerned with the growing number of requests for new private docks, and particularly rowing docks, along the river. However, if every school in the area were allowed to have its own dock, the river would look far different and the public’s enjoyment of the river considerably lessened.  The Dexter School should consider possible alternatives to constructing a new rowing facility in this area and alternative dock configurations that minimize water sheet encroachment and riverbank habitat loss.

Draft Policy Water Needs Forecast - June 6, 2007
CRWA feels the Policy Statement should draw a distinction between true water “need” for public health and development, and “want” for nonessential purposes.  MA Department of Conservation and Recreations's Office of Water Resources (OWR) should ensure that the draft policy is consistent with the DEP’s WMA Policy and Guidance.  In addition, it should be made clear that interim allocations must be used sparingly.

Daniels Village, Environmental Notification Form - May 16, 2007
Although the project does not exceed a mandatory Environmental Impact Report (EIR) threshold, CRWA believes that an EIR should be required because the project fails to avoid, minimize or mitigate damage to the environment.  A critical component of this project should be to reduce stormwater runoff and associated pollutants while maximizing groundwater recharge.

CRI, Chapter 91 License Application - April 6, 2007
Over the years, CRWA has developed a strong working relationship with CRI. We are familiar with its programs and efforts to involve the public, particularly children, in rowing on the Charles.  We support CRI’s new boathouse.  However, because this is such a large project, the public benefits offered by the project should be significant and made part of the Chapter 91 license.

Prospect Point, Environmental Notification Form - February 2007
Without the proper stormwater runoff controls, CRWA is concerned that the proposed development will have negative impacts to the draining water bodies.  The draft EIR should contain a detailed stormwater management plan, complete with drainage maps, results from stormwater models estimating expected water quality and quantity from the site and effectiveness of proposed mitigation. 

Chestnut Hill Square, Final Environmental Impact Report - January 5, 2007
CRWA recognizes the need for redevelopment at this site, and acknowledges the mitigation efforts towards transportation and water and sewer infrastructure improvements.  However, we suggest that the project design needs further refinement to increase the available open space, reduce site imperviousness, include BMPs and stormwater management designs that will reduce the discharge of pollutants of concern, including nutrients and bacteria, and reduce the overall volume of stormwater discharge from the site.