After what felt like years of: "We have no official position on dam removal", OARs executive director has finally taken a look at the real impacts of dam removal and has said:
The primary source of phosphorus is known to be the four municipal wastewater treatment plants that discharge into the river. In conjunction with the study, OAR convened two River Restoration Workshops to inform the community—and ourselves—about how dam removal could affect river water quality, river ecology, and the watershed as a whole. In these workshops we learned that although dam removal can have a positive impact on river water quality and provide better habitat by allowing free fish passage, among other benefits, it is an extremely complicated process and requires, at minimum, willing dam owners, a supportive river community, and lengthy regulatory review.
Given the great uncertainty in the cost estimates of the dam removals and accompanying site restoration, the lack of support of the largest dam owners, and objections by communities affected by some of the larger dams, OAR believes that removing dams, either singly or in combination, is not a viable option for achieving water quality standards for the Assabet River for Phase 2 NPDES permitting.
http://www.assabetriver.org/sites/default/files/OAR%20ACOE%20Comment%20Letter%2012-09.pdf
While we agree that removing these dams is not a viable option. We are concerned about OARs qualifications: "for achieving water quality standards for the Assabet River for Phase 2 NPDES permitting". We hope no one at OAR thinks, that based on everything that is now known about removing the Ben Smith Dam, that removing it might be a viable option at all, for the foreseeable future.
We do wholeheartedly agree that the wastewater treatment facilities must be made to clean up their own mess and not to continue to expect communities downstream to pay the price for their less than neighborly behavior.
"Based on results of this modeling effort, it was concluded that winter limits for the WWTFs, below the current planned limit of 1 mg/L would contribute significantly to the reduction in sediment phosphorus flux.” It goes on to state that: “If no other improvements were implemented, further reductions in summer P discharge limits, below 0.1 mg/L, would not contribute significantly to further reduction in sediment phosphorus flux. This is because the winter instream phosphorus concentration has such a strong effect on the P flux the following summer.” (CDM Report p. 6-7, emphasis added)
the CDM Report shows that lower winter phosphorus limits, in combination with the planned WWTF upgrades mandated by Phase 1 permits, would offer immediate and achievable water quality improvements. We believe that this approach would benefit the river, the wildlife that lives in and around the river, and the communities that have grown up along it.
http://www.assabetriver.org/sites/default/files/OAR%20ACOE%20Comment%20Letter%2012-09.pdf
Hear! Hear!
How do we make sure this is what really happens?
Monday, December 28, 2009
Saturday, December 19, 2009
We've Read the Reports, Have You?
The four WWTF are licensed to discharge 16M gal per day of improperly/incompletely treated effluent which is causing a Phosphorus loading problem in the Assabet River.
Why can’t we get an answer to the question of estimated impact of .1mgl discharge level vs. 1.0mgl during the winter months(Nov-March)?
Lowering the Assabet River level by 7.4 ft by removing the Ben Smith Dam resulting in a 25-30ft wide 1-2 ft deep river has hugh consequences including:
Loss of Public Safety water source for both towns of Stow & Maynard.
Loss of critical water source for orchards, farming, golf courses, etc.
Lowering the water table impacts ponds, wells, and perhaps the entire watershed.
Destroys year round recreational uses of canoeing, kayaking, fishing, motor boating, bird watching, etc..
Would destroy the most beautiful and scenic part of the Assabet River in exchange for a 25-30 ft wide stream with hugh “brown fields” of toxic materials quickly overgrown with loosetrife such that the river wouldn’t even be visible in 2-3 years.
Substantial negative impact on the value of the homes and property along the Assabet.
Reduction in impoundment volume(411acft =>22acft) or 95% would have enormous impact on 454 ac of impoundment area affecting wetlands, wildlife, and water recharge.
Exposing a 159 yr old toxic and trash dump site would result in hundreds of acres of “brown fields” with 5 metals exceeding RCS levels, and two, arsenic and lead which exceed acceptable landfill reuse. In addition , there is mercury, VOC’s & PCB’s, and who knows what else.
The study estimates clean up costs including sediment removal of 68kyd3 at $12M. It ignores the Sediment Study of The Assabet River estimate of 759kyd3 of sediment which could result in a cost of greater than $100,000,000!!! (759kyd3 is approximately 42,000 10 wheeler dump truckloads). Removing large amounts of material would create a lake or series of ponds or impoundment areas, Stow’s very own “Big Dig” and who would pay for it?
Errors/Omissions in the
Assabet River, MA Sediment and
Dam Removal Feasibility Study
Pg 19 Estimated Impoundment length is 2.15 mi. vs. 5.5mi length of Assabet River from Ben Smith Dam to Gleasondale Dam. This conflicts with Estimated Decrease in Average Water Surface Elevations Pg. 38 and Fig. 2 Assabet River Elevation Profile both of which clearly shows the Ben Smith Dam impacts the water level the entire 5.5 miles.
Pg 19 Impoundment Area from USGS Report is shown as 145.8AC. On Pg. 40 of the USGS Sediment Studies in the Assabet River, Central MA 2003 the Impoundment area is shown as 590,000M2 which is 19,065,597 ft2 or 454 AC an error of 3X.
Pg 10 “ Modeling limitations due to the complexity of sediment – phosphorus flux behavior meant that quantitative predictions of DO and biomass levels could NOT be made and the results of implementing different scenarios could only be qualitatively assessed.” Despite this disclaimer the study quantitatively estimated that removal of the Ben Smith Dam would improve P flux by 10%.
Pg 29 “The amount of open water increases after dam removal; from 20.8 acres to 70.2 acres.” Ridiculous. The present open water which in most areas is 200-400ft. and as broad as 600 ft. N of Crow Island is anticipated to become 25-30 ft. wide or a reduction from 70 + acres to 20 acres.
P.10 “CDM modeled six scenarios 1)…….6)reduction in phosphorus levels in WWTF discharges during the non-growing season”. Modeling just one variable lowering P levels to 1.0 mgl and .1mgl resulted in 60% reduction. Modeling a single variable of lowering P levels to .1mgl year around should be estimable and straight forward. But the study excludes the results even though it purports to have done the modeling. Elsewhere, in the study it states that “P in sediments put there during the winter can contribute over 50% of the summer P flux”. This would suggest that reducing winter P levels from 1.0 mgl to .1mgl(or a 90% reduction) could reduce winter contributions by 90% x 50% or 45 %.
The study estimates clean up costs including sediment removal of 68K yd3 @ $12.8M(Pg31&33). This does not include any legal, consultants fees, etc. The Sediment Studies estimated 580KM3(P.21) of 759K yd3 of sediment in the Ben Smith impoundment. Five of the 18 test sites in the Ben Smith impoundment showed incidences of toxicity of 50 or 100%. Toxic levels of arsenic and lead exceeded land fill levels, mercury and VOC’s were not evaluated and the study warned “incidences of toxicity presented in this report may be understated”.(Pg 39).
If the cleanup were to involve all 759Kyd3 of sediment the costs could exceed $100,000,000. The Corps of Engineers moderator commented this could be the biggest sediment removal project EVER! Larger even than the Boston Big Dig, and he doesn’t know where you could dispose of that much contaminated material.
The Bottom line - potentially $100,000,000 + of costs, annihilation of the Assabet & its surroundings and we’d be left with an even bigger impoundment!
CONCLUSION
Given that the estimate of a 10% P. Flux change by the removal of the Ben Smith Dam was based upon “phosphorus flux modeling which was too complex to handle specific combinations of dam removal, dredging and reduced levels of WWTF discharges”;(Pg 9) and given that there are numerous substantial omissions and errors in this analysis; and given that the catastrophic impacts on the Town of Stow and their residents have not been evaluated – “The removal of the Ben Smith Dam cannot be justified or recommended based upon this flawed report and the horrific impact on and costs to the town of Stow and its residents.” What is clear is the WWTF with their 16M gal/day discharge are directly responsible for the P flux problem and should be required to immediately move to a .1mgl level of discharge year round to determine if this will resolve the problem they’re creating. If after a 2-3 year “healing period” they may have to reduce their phosphorus discharge level even further to address the problem they are causing.
Anyone is free to use any or all of the above in their response.
Why can’t we get an answer to the question of estimated impact of .1mgl discharge level vs. 1.0mgl during the winter months(Nov-March)?
Lowering the Assabet River level by 7.4 ft by removing the Ben Smith Dam resulting in a 25-30ft wide 1-2 ft deep river has hugh consequences including:
Loss of Public Safety water source for both towns of Stow & Maynard.
Loss of critical water source for orchards, farming, golf courses, etc.
Lowering the water table impacts ponds, wells, and perhaps the entire watershed.
Destroys year round recreational uses of canoeing, kayaking, fishing, motor boating, bird watching, etc..
Would destroy the most beautiful and scenic part of the Assabet River in exchange for a 25-30 ft wide stream with hugh “brown fields” of toxic materials quickly overgrown with loosetrife such that the river wouldn’t even be visible in 2-3 years.
Substantial negative impact on the value of the homes and property along the Assabet.
Reduction in impoundment volume(411acft =>22acft) or 95% would have enormous impact on 454 ac of impoundment area affecting wetlands, wildlife, and water recharge.
Exposing a 159 yr old toxic and trash dump site would result in hundreds of acres of “brown fields” with 5 metals exceeding RCS levels, and two, arsenic and lead which exceed acceptable landfill reuse. In addition , there is mercury, VOC’s & PCB’s, and who knows what else.
The study estimates clean up costs including sediment removal of 68kyd3 at $12M. It ignores the Sediment Study of The Assabet River estimate of 759kyd3 of sediment which could result in a cost of greater than $100,000,000!!! (759kyd3 is approximately 42,000 10 wheeler dump truckloads). Removing large amounts of material would create a lake or series of ponds or impoundment areas, Stow’s very own “Big Dig” and who would pay for it?
Errors/Omissions in the
Assabet River, MA Sediment and
Dam Removal Feasibility Study
Pg 19 Estimated Impoundment length is 2.15 mi. vs. 5.5mi length of Assabet River from Ben Smith Dam to Gleasondale Dam. This conflicts with Estimated Decrease in Average Water Surface Elevations Pg. 38 and Fig. 2 Assabet River Elevation Profile both of which clearly shows the Ben Smith Dam impacts the water level the entire 5.5 miles.
Pg 19 Impoundment Area from USGS Report is shown as 145.8AC. On Pg. 40 of the USGS Sediment Studies in the Assabet River, Central MA 2003 the Impoundment area is shown as 590,000M2 which is 19,065,597 ft2 or 454 AC an error of 3X.
Pg 10 “ Modeling limitations due to the complexity of sediment – phosphorus flux behavior meant that quantitative predictions of DO and biomass levels could NOT be made and the results of implementing different scenarios could only be qualitatively assessed.” Despite this disclaimer the study quantitatively estimated that removal of the Ben Smith Dam would improve P flux by 10%.
Pg 29 “The amount of open water increases after dam removal; from 20.8 acres to 70.2 acres.” Ridiculous. The present open water which in most areas is 200-400ft. and as broad as 600 ft. N of Crow Island is anticipated to become 25-30 ft. wide or a reduction from 70 + acres to 20 acres.
P.10 “CDM modeled six scenarios 1)…….6)reduction in phosphorus levels in WWTF discharges during the non-growing season”. Modeling just one variable lowering P levels to 1.0 mgl and .1mgl resulted in 60% reduction. Modeling a single variable of lowering P levels to .1mgl year around should be estimable and straight forward. But the study excludes the results even though it purports to have done the modeling. Elsewhere, in the study it states that “P in sediments put there during the winter can contribute over 50% of the summer P flux”. This would suggest that reducing winter P levels from 1.0 mgl to .1mgl(or a 90% reduction) could reduce winter contributions by 90% x 50% or 45 %.
The study estimates clean up costs including sediment removal of 68K yd3 @ $12.8M(Pg31&33). This does not include any legal, consultants fees, etc. The Sediment Studies estimated 580KM3(P.21) of 759K yd3 of sediment in the Ben Smith impoundment. Five of the 18 test sites in the Ben Smith impoundment showed incidences of toxicity of 50 or 100%. Toxic levels of arsenic and lead exceeded land fill levels, mercury and VOC’s were not evaluated and the study warned “incidences of toxicity presented in this report may be understated”.(Pg 39).
If the cleanup were to involve all 759Kyd3 of sediment the costs could exceed $100,000,000. The Corps of Engineers moderator commented this could be the biggest sediment removal project EVER! Larger even than the Boston Big Dig, and he doesn’t know where you could dispose of that much contaminated material.
The Bottom line - potentially $100,000,000 + of costs, annihilation of the Assabet & its surroundings and we’d be left with an even bigger impoundment!
CONCLUSION
Given that the estimate of a 10% P. Flux change by the removal of the Ben Smith Dam was based upon “phosphorus flux modeling which was too complex to handle specific combinations of dam removal, dredging and reduced levels of WWTF discharges”;(Pg 9) and given that there are numerous substantial omissions and errors in this analysis; and given that the catastrophic impacts on the Town of Stow and their residents have not been evaluated – “The removal of the Ben Smith Dam cannot be justified or recommended based upon this flawed report and the horrific impact on and costs to the town of Stow and its residents.” What is clear is the WWTF with their 16M gal/day discharge are directly responsible for the P flux problem and should be required to immediately move to a .1mgl level of discharge year round to determine if this will resolve the problem they’re creating. If after a 2-3 year “healing period” they may have to reduce their phosphorus discharge level even further to address the problem they are causing.
Anyone is free to use any or all of the above in their response.
Friday, December 18, 2009
Letter to the DEP III
Massachusetts DEP
Division of Watershed Management
Attn: Alice M. Rojko
627 Main Street
Worcester, MA 01608
CC: Congresswoman, The Honorable Niki Tsongas, Massachusetts Fifth District; MA State Senator Mr. James Eldridge; MA State Representative Ms. Kate Hogan; Engineer Inspector General, US Army Corps of Engineers; Town of Maynard, Chairman Board of Selectmen, Mr. David Gavin; Maynard Town Administrator Mr. John Curran; Chairman Maynard Conservation Commission Mr. Fred King; Town of Stow, Chairman Board of Selectmen; Mr. Stephen M. Dungan; Chairman Stow Conservation Commission Mr. David Coppes;
RE: Assabet River Dam Removal and US Army Corps of Engineer draft report
December 18, 2009
Dear Ms. Rojko,
As abutters to the Ben Smith Impoundment and the Assabet River, the proposal to remove the historic Ben Smith Dam will have a direct impact on our family, our home, our community and the history that reminds us of who we are, and how and why we happen to be here in Maynard and Stow.
Our family has lived alongside the Assabet River for multiple generations as have many of our neighbors. We have seen great floods. We have seen the river run multi-colored from dyes that were dumped directly into the water. We have seen duckweed so thick you could walk on it. We have seen this river used as a dump site for household waste, tires, cars etc. We have made great strides over the years to clean up the river. However, the Assabet River's pollution problems are still here, just not as obviously as before. But should we throw out the baby with the bath water?
We believe that the negative impact of removing the Ben Smith Dam on the recreational value alone would be enough to oppose this plan. But the loss of history, culture, and community identity could not be remediated.
As we have researched more, we realize that the claims of environmental improvement will actually result in a loss of 100 acres of wetlands. In addition our entire neighborhood would have to be dug up for multiple years to remove sediment. All this so that waste water treatment facilities (WWTFs) can continue to pollute the Assabet River. No, thank you.
The Ben Smith Dam is in excellent shape. It is properly maintained and is not at risk of failing. However, removing it has many risks and consequences.
If this plan were to go forward it would mean the loss of water for recreation, agriculture and fire protection, and loss of critical water sources for area businesses such as orchards, farming, golf courses, etc. It would also cause a multi-year disturbance of hundreds more acres of our neighborhood – a plan that would require the removal of 42,000 truck loads of sediment, that can not be disposed of anywhere in New England. We also would loose the recreational value of the area for most, if not all, of the year. Canoeing, kayaking, and fishing will be greatly impacted if not outright lost. Additionally, shallow wells will obviously be affected by this drop in the water table, however people with artisian wells need also be concerned. The loss of hundreds of cubic acres of impounded water will have a significant impact on groundwater recharge as well as deep aquifer recharge.
In addition, the function of flood control can not be glossed over, as more and more development has occurred in historic floodplain areas protected by dam. All dams, even ones that have been converted to fixed weir, provide flood control. It is a natural consequence of restricting the river. Most of the Town of Maynard is down stream of the Ben Smith Dam. And therefore will be at greater risk of flooding if this dam is removed.
The historic mill complex and its associated structures, like the dam and the impoundments, are resources that must be protected. Without the physical reminders of our history, we will quickly fall victim to the allure of revisionist history. Tearing down buildings and changing the names of streets or removing the vestiges of industrialization besmirches the memory of all those hardworking people who made it possible. Out of sight is out of mind, and out of the history books.
This proposal and all it entails, will only allow WWTFs to continue to pollute the Assabet River. Dam removal only relocates the problem down stream. We are very concerned that this is the same water that ultimately finds its way into the Billerica public drinking water supply. And as if all that were not enough, this proposal does not meet the TMDL Phase II requirement of a 90 percent reduction in sediment phosphorus flux, and is repugnant to the myriad concerns acknowledged in the report.
We must fix this problem at the source. The WWTFs are the cause of the phosphorous issues in the Assabet. It seems clear that the best solution for all involved is tighter winter limits on phosphorous discharge, followed by a plan to discontinue the practice of surface water discharge entirely.
The current practice of discharging waste water into the river is unsustainable and it must ultimately be stopped. Phosphorous is only the tip of the iceberg - nitrogen, pharmaceuticals, etc., are also being dumped into our river. The towns operating these WWTFs are pumping water from ground and local surface sources and then dumping the majority of it out of the recharge areas of their water supplies. These towns need to keep their water local to recharge their local ground water sources.
Why is the Marlboro facility being allowed an increase of discharge into the river instead of utilizing groundwater disposal, like the Acton WWTF? While at the same time the current TMDL can not be met. Any increases in discharge are in direct contradiction to reducing total phosphorous levels in the Assabet.
The recommendation to remove the Ben Smith Dam must be stricken from the US Army Corps of Engineers' "Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study." The data in the report does not support the conclusion. The scope of this study was so limited as to exclude the obvious option of tighter winter limits. Fortunately CDM had to model this scenario anyway. It is the baseline condition for all of their models. Unfortunately we have not been given a straight answer as to what the appropriate winter limit is to get us the “magic” 90% reduction in P Flux. The recommendation to remove the Ben Smith Dam can not possibly be drawn from this report. There are so many contraindications to this plan that further study would be good money after bad. It is clear from the report that the conclusion must be tighter winter limits on phosphorous discharge.
This report and its executive summary must be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1mg/l must be mandated for any and all discharges into the Assabet River with no exceptions. Towns that are currently discharging into the Assabet River need to start allocating open space in their own communities for groundwater discharge sites or they will have to curtail their development plans.
The above abutter objections must be clearly outlined in the report, in the conclusion and in the executive summary.
Thank you. We are happy that our voices can be heard in this great democracy. We have faith that the peoples voices will be heard and reflected in the actions of our elected representatives.
Division of Watershed Management
Attn: Alice M. Rojko
627 Main Street
Worcester, MA 01608
CC: Congresswoman, The Honorable Niki Tsongas, Massachusetts Fifth District; MA State Senator Mr. James Eldridge; MA State Representative Ms. Kate Hogan; Engineer Inspector General, US Army Corps of Engineers; Town of Maynard, Chairman Board of Selectmen, Mr. David Gavin; Maynard Town Administrator Mr. John Curran; Chairman Maynard Conservation Commission Mr. Fred King; Town of Stow, Chairman Board of Selectmen; Mr. Stephen M. Dungan; Chairman Stow Conservation Commission Mr. David Coppes;
RE: Assabet River Dam Removal and US Army Corps of Engineer draft report
December 18, 2009
Dear Ms. Rojko,
As abutters to the Ben Smith Impoundment and the Assabet River, the proposal to remove the historic Ben Smith Dam will have a direct impact on our family, our home, our community and the history that reminds us of who we are, and how and why we happen to be here in Maynard and Stow.
Our family has lived alongside the Assabet River for multiple generations as have many of our neighbors. We have seen great floods. We have seen the river run multi-colored from dyes that were dumped directly into the water. We have seen duckweed so thick you could walk on it. We have seen this river used as a dump site for household waste, tires, cars etc. We have made great strides over the years to clean up the river. However, the Assabet River's pollution problems are still here, just not as obviously as before. But should we throw out the baby with the bath water?
We believe that the negative impact of removing the Ben Smith Dam on the recreational value alone would be enough to oppose this plan. But the loss of history, culture, and community identity could not be remediated.
As we have researched more, we realize that the claims of environmental improvement will actually result in a loss of 100 acres of wetlands. In addition our entire neighborhood would have to be dug up for multiple years to remove sediment. All this so that waste water treatment facilities (WWTFs) can continue to pollute the Assabet River. No, thank you.
The Ben Smith Dam is in excellent shape. It is properly maintained and is not at risk of failing. However, removing it has many risks and consequences.
If this plan were to go forward it would mean the loss of water for recreation, agriculture and fire protection, and loss of critical water sources for area businesses such as orchards, farming, golf courses, etc. It would also cause a multi-year disturbance of hundreds more acres of our neighborhood – a plan that would require the removal of 42,000 truck loads of sediment, that can not be disposed of anywhere in New England. We also would loose the recreational value of the area for most, if not all, of the year. Canoeing, kayaking, and fishing will be greatly impacted if not outright lost. Additionally, shallow wells will obviously be affected by this drop in the water table, however people with artisian wells need also be concerned. The loss of hundreds of cubic acres of impounded water will have a significant impact on groundwater recharge as well as deep aquifer recharge.
In addition, the function of flood control can not be glossed over, as more and more development has occurred in historic floodplain areas protected by dam. All dams, even ones that have been converted to fixed weir, provide flood control. It is a natural consequence of restricting the river. Most of the Town of Maynard is down stream of the Ben Smith Dam. And therefore will be at greater risk of flooding if this dam is removed.
The historic mill complex and its associated structures, like the dam and the impoundments, are resources that must be protected. Without the physical reminders of our history, we will quickly fall victim to the allure of revisionist history. Tearing down buildings and changing the names of streets or removing the vestiges of industrialization besmirches the memory of all those hardworking people who made it possible. Out of sight is out of mind, and out of the history books.
This proposal and all it entails, will only allow WWTFs to continue to pollute the Assabet River. Dam removal only relocates the problem down stream. We are very concerned that this is the same water that ultimately finds its way into the Billerica public drinking water supply. And as if all that were not enough, this proposal does not meet the TMDL Phase II requirement of a 90 percent reduction in sediment phosphorus flux, and is repugnant to the myriad concerns acknowledged in the report.
We must fix this problem at the source. The WWTFs are the cause of the phosphorous issues in the Assabet. It seems clear that the best solution for all involved is tighter winter limits on phosphorous discharge, followed by a plan to discontinue the practice of surface water discharge entirely.
The current practice of discharging waste water into the river is unsustainable and it must ultimately be stopped. Phosphorous is only the tip of the iceberg - nitrogen, pharmaceuticals, etc., are also being dumped into our river. The towns operating these WWTFs are pumping water from ground and local surface sources and then dumping the majority of it out of the recharge areas of their water supplies. These towns need to keep their water local to recharge their local ground water sources.
Why is the Marlboro facility being allowed an increase of discharge into the river instead of utilizing groundwater disposal, like the Acton WWTF? While at the same time the current TMDL can not be met. Any increases in discharge are in direct contradiction to reducing total phosphorous levels in the Assabet.
The recommendation to remove the Ben Smith Dam must be stricken from the US Army Corps of Engineers' "Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study." The data in the report does not support the conclusion. The scope of this study was so limited as to exclude the obvious option of tighter winter limits. Fortunately CDM had to model this scenario anyway. It is the baseline condition for all of their models. Unfortunately we have not been given a straight answer as to what the appropriate winter limit is to get us the “magic” 90% reduction in P Flux. The recommendation to remove the Ben Smith Dam can not possibly be drawn from this report. There are so many contraindications to this plan that further study would be good money after bad. It is clear from the report that the conclusion must be tighter winter limits on phosphorous discharge.
This report and its executive summary must be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1mg/l must be mandated for any and all discharges into the Assabet River with no exceptions. Towns that are currently discharging into the Assabet River need to start allocating open space in their own communities for groundwater discharge sites or they will have to curtail their development plans.
The above abutter objections must be clearly outlined in the report, in the conclusion and in the executive summary.
Thank you. We are happy that our voices can be heard in this great democracy. We have faith that the peoples voices will be heard and reflected in the actions of our elected representatives.
Thursday, December 17, 2009
What Can You Do? (12/17/09)
Its time to send your letters.
The comment period ends this Monday Dec 21st.
US Mail and email addresses are available to the right for the appropriate politicals.
Please take the time to send a letter or two and encourage your family, friends, and neighbors to do so as well.
It really is the only thing that will make a difference.
There are sample letters to the right, feel free to print and send or email them as is, if writing is not your thing.
The comment period ends this Monday Dec 21st.
US Mail and email addresses are available to the right for the appropriate politicals.
Please take the time to send a letter or two and encourage your family, friends, and neighbors to do so as well.
It really is the only thing that will make a difference.
There are sample letters to the right, feel free to print and send or email them as is, if writing is not your thing.
All Dams Provide Flood Control
"Maintain 'em or drain 'em" a motto adopted by the National Park Service Dam Safety Program, aptly expresses the dam owner's dilemma. Faced with the choice of repairing or upgrading a dam, or the less expensive option of draining a lake, many owners choose the latter course; however, where dams provide drinking water or flood control, dam removal may not be a viable alternative. The loss of a reservoir of any size often has negative economic and social impacts on local communities that have depended upon the impoundments created by dams for water supply, recreation and flood control.
The function of flood control has become increasingly important in recent years, as more and more development has occurred in historic floodplain areas protected by dams. As these dams deteriorate, they should be fixed or replaced, as dam removal leaves property in downstream floodplains highly vulnerable to flooding.
http://www.uswaternews.com/archives/arcpolicy/3362bil11.html
The Ben Smith Dam is in excellent shape. It is properly maintained and is not at risk of failing.
Most of the Town of Maynard is down stream of the Ben Smith Dam. And therefore will be at greater risk of flooding if this dam is removed.
All dams even ones that have been converted to fixed weir, provide flood control. It is a natural consequence of restricting the river. During most times the restriction is obvious in a static sense. The impoundment is visible as the pond behind the dam. In a dynamic situation where more water is added from rain, snow melt, and other run-off, the dam serves a second purpose, to attenuate the flow. The Dam acts as a restriction and allows less flow downstream than would have occurred without it. The additional flow is distributed over the large surface area of the impoundment causing only a minor change in the water level above the dam. This water is then retained in the impoundment and released more slowly, over time, than without the dam. However if this flow were allowed past the dam, because it was not there, then the level of the river below the dam would rise much much higher as its surface area is much much smaller than that of the impoundment. Homes and Property above the dam need not worry as the new flood plain will start 7 feet lower than it is right now.
But those below the dam need to be concerned as the river level below the dam will fluctuate more than it does now.
The function of flood control has become increasingly important in recent years, as more and more development has occurred in historic floodplain areas protected by dams. As these dams deteriorate, they should be fixed or replaced, as dam removal leaves property in downstream floodplains highly vulnerable to flooding.
http://www.uswaternews.com/archives/arcpolicy/3362bil11.html
The Ben Smith Dam is in excellent shape. It is properly maintained and is not at risk of failing.
Most of the Town of Maynard is down stream of the Ben Smith Dam. And therefore will be at greater risk of flooding if this dam is removed.
All dams even ones that have been converted to fixed weir, provide flood control. It is a natural consequence of restricting the river. During most times the restriction is obvious in a static sense. The impoundment is visible as the pond behind the dam. In a dynamic situation where more water is added from rain, snow melt, and other run-off, the dam serves a second purpose, to attenuate the flow. The Dam acts as a restriction and allows less flow downstream than would have occurred without it. The additional flow is distributed over the large surface area of the impoundment causing only a minor change in the water level above the dam. This water is then retained in the impoundment and released more slowly, over time, than without the dam. However if this flow were allowed past the dam, because it was not there, then the level of the river below the dam would rise much much higher as its surface area is much much smaller than that of the impoundment. Homes and Property above the dam need not worry as the new flood plain will start 7 feet lower than it is right now.
But those below the dam need to be concerned as the river level below the dam will fluctuate more than it does now.
Tuesday, December 15, 2009
Contact Your Representatives
Congresswoman, The Honorable Niki Tsongas,
Massachusetts Fifth District;
Washington DC Office
1607 Longworth House Office Building
Washington, DC 20515
Phone: (202) 225-3411 Fax: (202) 226-0771
1607 Longworth House Office Building
Washington, DC 20515
Phone: (202) 225-3411 Fax: (202) 226-0771
Acton Office
492 Main Street Acton, MA 01720
Phone: (978) 263-1951
Tuesday, Wednesday, Friday 9:00 AM - 2:00 PM
MA State Senator Mr. James Eldridge;
email: James.Eldridge@state.ma.us
State House
Room 213-A
Boston, MA 02133
Telephone: (617) 722-1120
Fax: (617) 722-1089
MA State Representative,
Ms. Kate Hogan;
State House
Room 33
Boston, MA 02133
Boston, MA 02133
Telephone: (617)-722-2060
Town of Maynard, Chairman Board of Selectmen
Mr. David D. Gavin;
email: bmosca@townofmaynard.net
Maynard Town Hall
195 Main Street
Maynard, MA 01754
Maynard, MA 01754
Phone: 978-897-1001
Fax: 978-897-8457
Maynard Town Administrator
Mr. John Curran;
email: jcurran@townofmaynard.net
Maynard Town Hall
195 Main Street
Maynard, MA 01754
Maynard, MA 01754
Phone: (978) 897-1001
Fax: (978) 897-8457
Chairman Maynard Conservation Commission,
Mr. Fred King;
email: conscom@townofmaynard.net
Maynard Town Hall
195 Main Street
Maynard, MA 01754
Phone: 978-897-0560
Town of Stow, Chairman Board of Selectmen;
Mr. Stephen M. Dungan
email: s.dungan@comcast.net
Stow Town Hall
380 Great Road
Stow, MA 01775-2127
Phone: (978) 897-4515
Stow, MA 01775-2127
Phone: (978) 897-4515
Fax: (978) 897-4631
Chairman Stow Conservation Commission;
Mr. David Coppes
email: conservation@Stow-MA.gov
Stow Town Hall
380 Great Road
Stow, MA 01775-2127
Phone: (978) 897-8615
Fax: (978) 897-4534
Fax: (978) 897-4534
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All official comments to the US Army Corps of Engineers report must be submitted in writing, preferably in an electronic format, and must be received by
December 21, 2009.
Comments should be submitted to:
E-mail: Alice.Rojko@massmail.state.ma.us
Or mail to:
MassDEP - Division of Watershed Management
627 Main Street
Worcester, MA 01608
Attention: Alice M. Rojko
Monday, December 14, 2009
Letter to the Editor II
As abutters to the Ben Smith Impoundment, the proposal to remove the Historic Ben Smith Dam will have a direct impact on our Family, our Home, our Community and the History that reminds us of who we are, and how and why we happen to be here in Maynard and Stow.
Our Family has lived alongside the Assabet River for multiple generations as have many of our neighbors. We have seen great floods. We have seen the river run multi-colored from dyes that were dumped directly into the water. We have seen duckweed so thick you could walk on it. We have seen this river used as a dump site for household waste, tires, cars etc. We have made great strides over the years to clean up the river. However, the Assabet River's pollution problems are still here, just not as obviously as before. But should we throw out the baby with the bath water?
We must make sure that the Army Corps of Engineers, and the DEP for that matter are not allowed to come into our towns and mandate the loss of water for recreation, agriculture and fire protection along with the loss of more than 100 acres of wetlands, and a multi-year disturbance of hundreds more acres. A plan that requires they remove 42,000 truck loads of sediment, that can not be disposed of anywhere in New England? We will loose the recreational value of the area for most if not all of the year. Canoeing, kayaking, and fishing will be greatly impacted if not outright lost. The Historic Mill Complex and its associated structures, like the dam and the impoundment, are resources that must be protected. This proposal and all it entails, only allows WWTFs to continue to pollute the Assabet River. Dam removal only relocates the problem down stream. We must attack this problem at the source. It seems clear that the best solution for all involved is tighter winter limits on phosphorous discharge!
The recommendation to remove the Ben Smith Dam must be stricken from the US Army Corps of Engineers "Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study". The data in the report does not support the conclusion. In addition this proposal does not meet the TMDL Phase II requirement of a 90 percent reduction in sediment phosphorus flux, and is repugnant to the myriad concerns acknowledged in the report.
This report and its executive summary must be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1mg/l should be mandated for any and all discharges into the Assabet River with no exceptions.
The deadline for comments is Monday Dec 21st.
Our Family has lived alongside the Assabet River for multiple generations as have many of our neighbors. We have seen great floods. We have seen the river run multi-colored from dyes that were dumped directly into the water. We have seen duckweed so thick you could walk on it. We have seen this river used as a dump site for household waste, tires, cars etc. We have made great strides over the years to clean up the river. However, the Assabet River's pollution problems are still here, just not as obviously as before. But should we throw out the baby with the bath water?
We must make sure that the Army Corps of Engineers, and the DEP for that matter are not allowed to come into our towns and mandate the loss of water for recreation, agriculture and fire protection along with the loss of more than 100 acres of wetlands, and a multi-year disturbance of hundreds more acres. A plan that requires they remove 42,000 truck loads of sediment, that can not be disposed of anywhere in New England? We will loose the recreational value of the area for most if not all of the year. Canoeing, kayaking, and fishing will be greatly impacted if not outright lost. The Historic Mill Complex and its associated structures, like the dam and the impoundment, are resources that must be protected. This proposal and all it entails, only allows WWTFs to continue to pollute the Assabet River. Dam removal only relocates the problem down stream. We must attack this problem at the source. It seems clear that the best solution for all involved is tighter winter limits on phosphorous discharge!
The recommendation to remove the Ben Smith Dam must be stricken from the US Army Corps of Engineers "Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study". The data in the report does not support the conclusion. In addition this proposal does not meet the TMDL Phase II requirement of a 90 percent reduction in sediment phosphorus flux, and is repugnant to the myriad concerns acknowledged in the report.
This report and its executive summary must be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1mg/l should be mandated for any and all discharges into the Assabet River with no exceptions.
The deadline for comments is Monday Dec 21st.
Sunday, December 13, 2009
What the Town Wants to Happen
Brian Nanos on Wicked Local writes:
Maynard - Joe Mullin, spokesman for Clock Tower Place, said that the facility’s owners would be willing to get rid of the Ben Smith Dam “if that’s what the town wants to happen.”............
...................All of these points leave Mullin assured that the town will not ask that the dam be removed any time soon.
“We would consider the town’s changing of position,” he said. “We would be open minded, but I don’t see any indication that they are going to change their minds.”
http://www.wickedlocal.com/maynard/news/x215397886/Dam-s-removal-called-unlikely
The deadline is approaching for Comment to the Army Corps of Engineers report.
MAKE SURE THE TOWN SELECTMEN AND THE WORLD KNOW WHAT THE TOWN WANTS
A new post will contain the contact information for some of the important people who should be cc'd on your letters.
Maynard - Joe Mullin, spokesman for Clock Tower Place, said that the facility’s owners would be willing to get rid of the Ben Smith Dam “if that’s what the town wants to happen.”............
...................All of these points leave Mullin assured that the town will not ask that the dam be removed any time soon.
“We would consider the town’s changing of position,” he said. “We would be open minded, but I don’t see any indication that they are going to change their minds.”
http://www.wickedlocal.com/maynard/news/x215397886/Dam-s-removal-called-unlikely
The deadline is approaching for Comment to the Army Corps of Engineers report.
MAKE SURE THE TOWN SELECTMEN AND THE WORLD KNOW WHAT THE TOWN WANTS
A new post will contain the contact information for some of the important people who should be cc'd on your letters.
Letter to DEP II
Massachusetts DEP
Division of Watershed Management
Attn: Alice M. Rojko
627 Main Street
Worcester, MA 01608
CC: Congresswoman, The Honorable Niki Tsongas, Massachusetts Fifth District; MA State Senator Mr. James Eldridge; MA State Representative Ms. Kate Hogan; Engineer Inspector General, US Army Corps of Engineers; Town of Maynard, Chairman Board of Selectmen Mr. David D. Gavin; Town of Maynard, Chairman Board of Selectmen, Mr. David Gavin; Maynard Town Administrator Mr. John Curran; Chairman Maynard Conservation Commission Mr. Fred King
RE: Assabet River Dam Removal and US Army Corps of Engineer draft report available at URL www.nae.usace.army.mil/projects/ma/assabetriver/assabetriver.htm
November 29, 2009
Dear Ms. Rojko:
I live directly on the Assabet River in Maynard, MA, 150 yards upriver from the Ben Smith Dam, the largest dam on the Assabet River. It has been brought to my attention that the US Army Corps of Engineers (ACoE) has recently completed a draft report in conjunction with your organization regarding the reduction of phosphate content in the Assabet River. The primary set of recommendations from this draft report includes the removal of dams on the Assabet River and sediment dredging and removal in an attempt to reduce phosphate levels. The removal of the Ben Smith Dam specifically has been identified as among the highest recommended items. My letter to you is intended to outline my concerns and requests regarding this report. I would be appreciative if you could please reply to my letter. In your reply, I would also appreciate understanding how these concerns are being tracked.
CONCERNS & QUESTIONS:
1. I have serious concerns about the integrity and credibility of the referenced report in question. If the objective of this report to improve the water quality of the river why is the report titled, “Assabet Sediment and Dam Removal Feasibility Study” vs. “Improving Assabet River Water Quality.” It appears that the answer to the question is assumed and not in question. What other alternatives were studied? Alternative methods were to improving water quality were not studied or researched to anywhere the same degree as dam removal.
2. There may be a conflict of interest in the ACoE submitting a report with recommendations if the ACoE will direct, supervise and/or participate in completion of the work to remove the dams.
3. As an abutter, I would like to better understand the relationship between the Massachusetts DEP and ACoE, as it is possible there is a conflict of interest here too. I also want to understand if MA DEP will direct, supervise and/or participate in completion of the work to remove the dams.
4. During public meetings held on 17 and 19 November 2009, nearly every picture of the river shown of the Ben Smith Dam shows duckweed and presents the river as “polluted” yet this condition exists for 3 weeks per year the past two years (I know as I live on the river and look at it every day). Yet, one would not know this if one did not live on the river. This drives misperceptions in communities.
5. The Ben Smith Dam removal only is, as of today, estimated at $13 Million but is likely to increase upwards of $50Million – especially if heavy metals and PCB’s are found in higher quantities than identified in sediments that were identified by samples taken by USGS in 2003, and this is likely given the river was heavily used during industrialization). We need to see an independent third party estimate and a study of the health effects on abutters from sediment removal with more samples taken given the impact the industrial heavy metals identified as being present (arsenic, cadmium, chromium, nickel and lead) and PCB’s. It is often safer to leave these substances where they are.
6. Phosphorous reduction of the river can be accomplished by requiring waste water treatment plants that currently discharge into the river to comply with already existing regulations of 0.1mg/l phosphorous discharge. I quote from the report on page 15, para. II, “The Primary issue is too much phosphorous input to the waterway.” Communities upriver from Maynard are being allowed to discharge above this rate during the winter months causing externalities downstream. If the recommendations of the report are followed, downriver communities will unfairly and unjustly pay for the externalities of these upriver communities and not just in dollar terms. The cost of treatment to reduce winter discharge rates at waste water treatment plants is never outlined in the report which calls into question the credibility of the report. I quote again from the report on page 24, para. II “field surveys found that waste water treatment plants contributed 88 to 98 percent of the biologically available phosphorous…”
7. How much would it cost for upriver communities, who have four point sources at waste water treatment plants, to improve waste water discharge compared to the cost of removal of dams at a today estimate of $42.7M (and this dam removal cost is very likely to be larger, potentially 5 to 8 times more)?
8. If the removal of aquatic vegetation up river from dams was accomplished, without removal of the dams, how much would dissolved oxygen be improved?
9. In 2005 several upriver communities visited Washington, D.C. in a search for monetary aid to clean up the Assabet River without success. Several upriver towns, due to budget constraints have imposed moratoriums on sewer connections. They know they are in violation of effluent discharge rates, and are discharging greater than 0.1mg/l phosphorous rate. It appears that their work with ACoE and their influence to get the report drafted will reduce moneys they otherwise would have had to spend to fully update their waste water treatment plants to meet the standard all year long. Why are these communities being allowed to discharge above the legal limit and why are they being given waivers? And why is there now a report from the ACoE to remove dams? It appears that the upriver community strategy today is for downriver communities to remove dams so upriver communities do not have to pay to improve phosphorous effluent (especially during the winter, which is where the highest quantity of phosphorous problem lies as outlined in the report).
10. Even if dams are removed, phosphorous would merely be moved downstream to more communities if upriver waste water treatment plants will not fully comply with legal limits. In other words, the source of the problem will not be fixed!
11. In the 330 page report, there is little mention of how abutters will be affected. There will be a 20 month construction period with significant noise and smells and traffic (at 67,600 estimated cubic yards of sediment to be removed from Ben Smith dam alone, traffic will be a factor) and loss of quality of life from construction, smells from muck at the bottom of the river, potential health effects and other effects. This work must be done during non-winter months further aggravating abutters’ quality of life. My back yard is the river. How will quality of life for abutters be compensated?
12. I live at a section of the river that is approximately 500 feet in width. If the Ben Smith dam is removed, the width of the river will be reduced to approximately 15 yards, an over 90% reduction in width (see page 58 of the report for a before and after computer generation of how the width of the river will be affected). This computer generation is likely to depict a season with maximum flow and hence width. During the summer, it would not be surprising to see the width to lessen to 10 feet or less and may be 1/3 the width of what is depicted when the dam is removed. It is hard to understand how recreationally valuable the river will be then.
13. The property value of the 18 homes located directly on the river (direct waterfront homes only counted) and upriver from the Ben Smith Dam to the White Pond Road Bridge, a distance of approximately 2000 feet, will be forever deleteriously affected. Who will pay for the serious and negative reduction in the value of me and my neighbor’s property and reimburse me for the incremental property taxes I have paid over 15 years from what my property was worth to what it will be worth if the Ben Smith Dam is removed? The market value of these homes will deeply decline.
14. When one reads the report, it is inferred that the Assabet as a highly polluted river, further inferring it has little natural beauty or recreational value. In the 330 page report, there is very little mention of how the public will lose this valuable and beautiful resource. As I live on this river, I know, because I see it every day, that this is a most beautiful, bucolic river. Every day there are walkers. Every day there are canoeists, kayakers and boaters and those who fish the river. The serious reduction in water quantity acreage will destroy this resource forever. Yes, there is some duck weed and algae that can be seen in August/September for two to three weeks, however this has been significantly improving as phosphorous levels in the past 10 years have improved and is getting better. Is this enough to radically and forever change this resource? We need a study done to determine the recreational value that the river has today, just as we need a study to determine how to reduce phosphorous loading other than just dam and sediment removal. For an example of a study that was undertaken for the Minnesota River reference http://ideas.repec.org/p/ags/umaesp/13771.html where recreational value is compared to phosphorous reduction cost.
15. It would appear that the ACoE is attempting to change the classification of wetlands upriver of the Ben Smith dam to open water (see page 165 of the report, under “Table 1, Estimated Change in Wetland Areas Following Dam Removal.”). Regardless, the loss of valuable wetlands will be significant to wildlife which we see on a daily basis. It is conservatively estimated that we will lose 125 acres of wetlands.
16. Dredging upriver from the Ben Smith Dam will leave a dirt pit at a size of 145.8 acres. What is the plan to revegetate these ~146 acres? How long will we be looking at a mud pit (and how long will it smell)? This is not addressed in the report. Also, the area size of 146 acres is in question and may be as large as 450 acres.
17. We are likely to lose most of the river trees behind my home and this will forever open my home up to views and we will lose privacy. This is not addressed in the report. Also not addressed is the fact that walking lanes are likely to open up behind my home that were previously not there, further impacting our privacy in ways that we could have never imagined when we purchased our home. It is also possible that homes could be built on what was previously river.
18. Current waste water treatment plants (WWTP) are just now beginning to come online after having spent approximately $100 Million. We need time to see the impact and effect of this monetary spending and resultant reduction in phosphate loading. The report uses as a base period the year 2000 for phosphate levels. Base lining phosphate levels in the river from the year 2000 (in order to reduce TMDL by 90%, the stated goal of the report) is misrepresentative at best and does not take into account the new WWTP’s coming online nor improvements from the past 9 years.
19. The participation and charter of the ACoE and MA DEP is not to make recommendations, which was clearly stated during public meetings, yet when one reads the report in question -- and if a policy maker reads the report -- it is clear that the recommendation is to remove dams, especially the Ben Smith Dam.
20. By the ACoE’s own admission, the “Simple Mass Balance Model” used to model hydrology and phosphorous loading of the river is a new model, just recently being published by a Tufts professor with no real world data behind it. This calls into question the credibility of the “recommendations” and calls for alternate data modeling at best.
21. Waivers of current WWTP’s discharging effluent into the river are wrongly being granted. WWTP’s should be held accountable for maintaining legal limits not greater than .01 mg/l year round. In addition, the report does not model what would happen if WWTP’s were required to do so as an alternative to the set of recommendations given (further hampering integrity and credibility).
22. The town of Wayland recently signed an agreement with the US EPA in August 2009, limiting discharge of effluent to not greater than .01mg/l phosphorous year round on the Sudbury River.
23. There are serious concerns about the health impacts from the removal of sediment from the river, 15 yards behind my house. The Assabet River was heavily used during industrialization and it is likely that sediments blocked by the dam will have high levels of heavy metals, such as cadmium, chromium, lead, arsenic, etc., and also PCB’s. What will happen to the safety and health of my family when exposed to these materials? The area behind my home will be turned into a brown field. Is that really what communities’ desire?
24. Citizens learned during open meetings that communities upstream who discharge effluent into the Assabet have allowed other cities to hook into their sewage treatment plants to discharge additional effluent into the river. This will have a significant impact on water quality, even if discharge rates are lowered and should be outlawed.
REQUESTS:
1. I request that a study be undertaken to better understand the health effects from removals of sediments from behind dams relative to exposure to heavy metals and PCB’s.
2. I request that the recommendation to remove the Ben Smith Dam be stricken from the US Army Corps of Engineers report “Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study.” The proposal in the report does not meet the TMDL Phase II requirement of a 90 percent reduction in sediment phosphorus flux.
3. I request that the report should be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1 mg/l should be mandated for any and all discharges into the Assabet River with no exceptions. Waste Water Treatment plants should not be allowed to discharge over legal limits.
4. I request that all abutter objections, including those in this letter, are clearly outlined in the ACoE report.
5. I request that a cost study be undertaken to understand the cost of upriver towns reducing phosphorous effluent to the legal limit of 0.1mg/l (especially during the winter when effluent discharge regularly is greater than 0.1mg/l), and that this be placed in the ACoE report for comparison to the cost of dam and sediment removal.
6. For the record, I want to know the relationship between the MA DEP and ACoE.
7. For the record, I want to know if the ACoE or MA DEP is going to manage, supervise and/or do the actual work for dam removal. It is important to understand this potential conflict of interest.
8. I request that a study of “human factors and considerations” and recreational value be undertaken such that all constituencies understand the human side of the loss of the river and its dams and that this be placed in the ACoE report or incorporated by reference.
9. I request that a study be done to determine the effectiveness of sediment deactivation as an alternative to dam removal, and that this study include sediment deactivation be done every 5 years and the cost of this compared to dam removal. In addition, the report should clearly outline other methods and combination of methods so that if decisions are made, trade-offs can be holistically understood .
10. I request that a study of real estate values for homes directly on the Assabet River upriver from the Ben Smith dam be undertaken, indicating pre and post dam removal values and that this be placed in the ACoE report or incorporated by reference.
11. I request that an independent comparison of costs to remove dams be undertaken and compared to an independent estimate of costs to reduce phosphate effluent from upriver communities and that this be placed in the ACoE report or incorporated by reference.
12. I request that a study be taken to determine the effects on abutter’s privacy from walking lanes that are likely to be opened up and trees that will be forever lost.
13. I request that all alternatives and solutions for reducing phosphorous in the Assabet River be included in subject report.
The ACoE report appears to be heavily one sided in the favor of removing dams on the river and little if any attention paid to represent competing views or alternatives. I can testify that this is a beautiful river worthy of keeping as is. Removing the dams, especially the Ben Smith dam, will significantly reduce water acreage (by at least 90%) and river width and depth. Those with whom I have spoken on my street, Taft Avenue in Maynard, agree with the view that it would be wrong to lose this resource. Please do not allow our way of life and the loss of a valuable recreational resource to be forever lost.
We welcome a dialogue and reply to these requests and concerns.
Division of Watershed Management
Attn: Alice M. Rojko
627 Main Street
Worcester, MA 01608
CC: Congresswoman, The Honorable Niki Tsongas, Massachusetts Fifth District; MA State Senator Mr. James Eldridge; MA State Representative Ms. Kate Hogan; Engineer Inspector General, US Army Corps of Engineers; Town of Maynard, Chairman Board of Selectmen Mr. David D. Gavin; Town of Maynard, Chairman Board of Selectmen, Mr. David Gavin; Maynard Town Administrator Mr. John Curran; Chairman Maynard Conservation Commission Mr. Fred King
RE: Assabet River Dam Removal and US Army Corps of Engineer draft report available at URL www.nae.usace.army.mil/projects/ma/assabetriver/assabetriver.htm
November 29, 2009
Dear Ms. Rojko:
I live directly on the Assabet River in Maynard, MA, 150 yards upriver from the Ben Smith Dam, the largest dam on the Assabet River. It has been brought to my attention that the US Army Corps of Engineers (ACoE) has recently completed a draft report in conjunction with your organization regarding the reduction of phosphate content in the Assabet River. The primary set of recommendations from this draft report includes the removal of dams on the Assabet River and sediment dredging and removal in an attempt to reduce phosphate levels. The removal of the Ben Smith Dam specifically has been identified as among the highest recommended items. My letter to you is intended to outline my concerns and requests regarding this report. I would be appreciative if you could please reply to my letter. In your reply, I would also appreciate understanding how these concerns are being tracked.
CONCERNS & QUESTIONS:
1. I have serious concerns about the integrity and credibility of the referenced report in question. If the objective of this report to improve the water quality of the river why is the report titled, “Assabet Sediment and Dam Removal Feasibility Study” vs. “Improving Assabet River Water Quality.” It appears that the answer to the question is assumed and not in question. What other alternatives were studied? Alternative methods were to improving water quality were not studied or researched to anywhere the same degree as dam removal.
2. There may be a conflict of interest in the ACoE submitting a report with recommendations if the ACoE will direct, supervise and/or participate in completion of the work to remove the dams.
3. As an abutter, I would like to better understand the relationship between the Massachusetts DEP and ACoE, as it is possible there is a conflict of interest here too. I also want to understand if MA DEP will direct, supervise and/or participate in completion of the work to remove the dams.
4. During public meetings held on 17 and 19 November 2009, nearly every picture of the river shown of the Ben Smith Dam shows duckweed and presents the river as “polluted” yet this condition exists for 3 weeks per year the past two years (I know as I live on the river and look at it every day). Yet, one would not know this if one did not live on the river. This drives misperceptions in communities.
5. The Ben Smith Dam removal only is, as of today, estimated at $13 Million but is likely to increase upwards of $50Million – especially if heavy metals and PCB’s are found in higher quantities than identified in sediments that were identified by samples taken by USGS in 2003, and this is likely given the river was heavily used during industrialization). We need to see an independent third party estimate and a study of the health effects on abutters from sediment removal with more samples taken given the impact the industrial heavy metals identified as being present (arsenic, cadmium, chromium, nickel and lead) and PCB’s. It is often safer to leave these substances where they are.
6. Phosphorous reduction of the river can be accomplished by requiring waste water treatment plants that currently discharge into the river to comply with already existing regulations of 0.1mg/l phosphorous discharge. I quote from the report on page 15, para. II, “The Primary issue is too much phosphorous input to the waterway.” Communities upriver from Maynard are being allowed to discharge above this rate during the winter months causing externalities downstream. If the recommendations of the report are followed, downriver communities will unfairly and unjustly pay for the externalities of these upriver communities and not just in dollar terms. The cost of treatment to reduce winter discharge rates at waste water treatment plants is never outlined in the report which calls into question the credibility of the report. I quote again from the report on page 24, para. II “field surveys found that waste water treatment plants contributed 88 to 98 percent of the biologically available phosphorous…”
7. How much would it cost for upriver communities, who have four point sources at waste water treatment plants, to improve waste water discharge compared to the cost of removal of dams at a today estimate of $42.7M (and this dam removal cost is very likely to be larger, potentially 5 to 8 times more)?
8. If the removal of aquatic vegetation up river from dams was accomplished, without removal of the dams, how much would dissolved oxygen be improved?
9. In 2005 several upriver communities visited Washington, D.C. in a search for monetary aid to clean up the Assabet River without success. Several upriver towns, due to budget constraints have imposed moratoriums on sewer connections. They know they are in violation of effluent discharge rates, and are discharging greater than 0.1mg/l phosphorous rate. It appears that their work with ACoE and their influence to get the report drafted will reduce moneys they otherwise would have had to spend to fully update their waste water treatment plants to meet the standard all year long. Why are these communities being allowed to discharge above the legal limit and why are they being given waivers? And why is there now a report from the ACoE to remove dams? It appears that the upriver community strategy today is for downriver communities to remove dams so upriver communities do not have to pay to improve phosphorous effluent (especially during the winter, which is where the highest quantity of phosphorous problem lies as outlined in the report).
10. Even if dams are removed, phosphorous would merely be moved downstream to more communities if upriver waste water treatment plants will not fully comply with legal limits. In other words, the source of the problem will not be fixed!
11. In the 330 page report, there is little mention of how abutters will be affected. There will be a 20 month construction period with significant noise and smells and traffic (at 67,600 estimated cubic yards of sediment to be removed from Ben Smith dam alone, traffic will be a factor) and loss of quality of life from construction, smells from muck at the bottom of the river, potential health effects and other effects. This work must be done during non-winter months further aggravating abutters’ quality of life. My back yard is the river. How will quality of life for abutters be compensated?
12. I live at a section of the river that is approximately 500 feet in width. If the Ben Smith dam is removed, the width of the river will be reduced to approximately 15 yards, an over 90% reduction in width (see page 58 of the report for a before and after computer generation of how the width of the river will be affected). This computer generation is likely to depict a season with maximum flow and hence width. During the summer, it would not be surprising to see the width to lessen to 10 feet or less and may be 1/3 the width of what is depicted when the dam is removed. It is hard to understand how recreationally valuable the river will be then.
13. The property value of the 18 homes located directly on the river (direct waterfront homes only counted) and upriver from the Ben Smith Dam to the White Pond Road Bridge, a distance of approximately 2000 feet, will be forever deleteriously affected. Who will pay for the serious and negative reduction in the value of me and my neighbor’s property and reimburse me for the incremental property taxes I have paid over 15 years from what my property was worth to what it will be worth if the Ben Smith Dam is removed? The market value of these homes will deeply decline.
14. When one reads the report, it is inferred that the Assabet as a highly polluted river, further inferring it has little natural beauty or recreational value. In the 330 page report, there is very little mention of how the public will lose this valuable and beautiful resource. As I live on this river, I know, because I see it every day, that this is a most beautiful, bucolic river. Every day there are walkers. Every day there are canoeists, kayakers and boaters and those who fish the river. The serious reduction in water quantity acreage will destroy this resource forever. Yes, there is some duck weed and algae that can be seen in August/September for two to three weeks, however this has been significantly improving as phosphorous levels in the past 10 years have improved and is getting better. Is this enough to radically and forever change this resource? We need a study done to determine the recreational value that the river has today, just as we need a study to determine how to reduce phosphorous loading other than just dam and sediment removal. For an example of a study that was undertaken for the Minnesota River reference http://ideas.repec.org/p/ags/umaesp/13771.html where recreational value is compared to phosphorous reduction cost.
15. It would appear that the ACoE is attempting to change the classification of wetlands upriver of the Ben Smith dam to open water (see page 165 of the report, under “Table 1, Estimated Change in Wetland Areas Following Dam Removal.”). Regardless, the loss of valuable wetlands will be significant to wildlife which we see on a daily basis. It is conservatively estimated that we will lose 125 acres of wetlands.
16. Dredging upriver from the Ben Smith Dam will leave a dirt pit at a size of 145.8 acres. What is the plan to revegetate these ~146 acres? How long will we be looking at a mud pit (and how long will it smell)? This is not addressed in the report. Also, the area size of 146 acres is in question and may be as large as 450 acres.
17. We are likely to lose most of the river trees behind my home and this will forever open my home up to views and we will lose privacy. This is not addressed in the report. Also not addressed is the fact that walking lanes are likely to open up behind my home that were previously not there, further impacting our privacy in ways that we could have never imagined when we purchased our home. It is also possible that homes could be built on what was previously river.
18. Current waste water treatment plants (WWTP) are just now beginning to come online after having spent approximately $100 Million. We need time to see the impact and effect of this monetary spending and resultant reduction in phosphate loading. The report uses as a base period the year 2000 for phosphate levels. Base lining phosphate levels in the river from the year 2000 (in order to reduce TMDL by 90%, the stated goal of the report) is misrepresentative at best and does not take into account the new WWTP’s coming online nor improvements from the past 9 years.
19. The participation and charter of the ACoE and MA DEP is not to make recommendations, which was clearly stated during public meetings, yet when one reads the report in question -- and if a policy maker reads the report -- it is clear that the recommendation is to remove dams, especially the Ben Smith Dam.
20. By the ACoE’s own admission, the “Simple Mass Balance Model” used to model hydrology and phosphorous loading of the river is a new model, just recently being published by a Tufts professor with no real world data behind it. This calls into question the credibility of the “recommendations” and calls for alternate data modeling at best.
21. Waivers of current WWTP’s discharging effluent into the river are wrongly being granted. WWTP’s should be held accountable for maintaining legal limits not greater than .01 mg/l year round. In addition, the report does not model what would happen if WWTP’s were required to do so as an alternative to the set of recommendations given (further hampering integrity and credibility).
22. The town of Wayland recently signed an agreement with the US EPA in August 2009, limiting discharge of effluent to not greater than .01mg/l phosphorous year round on the Sudbury River.
23. There are serious concerns about the health impacts from the removal of sediment from the river, 15 yards behind my house. The Assabet River was heavily used during industrialization and it is likely that sediments blocked by the dam will have high levels of heavy metals, such as cadmium, chromium, lead, arsenic, etc., and also PCB’s. What will happen to the safety and health of my family when exposed to these materials? The area behind my home will be turned into a brown field. Is that really what communities’ desire?
24. Citizens learned during open meetings that communities upstream who discharge effluent into the Assabet have allowed other cities to hook into their sewage treatment plants to discharge additional effluent into the river. This will have a significant impact on water quality, even if discharge rates are lowered and should be outlawed.
REQUESTS:
1. I request that a study be undertaken to better understand the health effects from removals of sediments from behind dams relative to exposure to heavy metals and PCB’s.
2. I request that the recommendation to remove the Ben Smith Dam be stricken from the US Army Corps of Engineers report “Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study.” The proposal in the report does not meet the TMDL Phase II requirement of a 90 percent reduction in sediment phosphorus flux.
3. I request that the report should be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1 mg/l should be mandated for any and all discharges into the Assabet River with no exceptions. Waste Water Treatment plants should not be allowed to discharge over legal limits.
4. I request that all abutter objections, including those in this letter, are clearly outlined in the ACoE report.
5. I request that a cost study be undertaken to understand the cost of upriver towns reducing phosphorous effluent to the legal limit of 0.1mg/l (especially during the winter when effluent discharge regularly is greater than 0.1mg/l), and that this be placed in the ACoE report for comparison to the cost of dam and sediment removal.
6. For the record, I want to know the relationship between the MA DEP and ACoE.
7. For the record, I want to know if the ACoE or MA DEP is going to manage, supervise and/or do the actual work for dam removal. It is important to understand this potential conflict of interest.
8. I request that a study of “human factors and considerations” and recreational value be undertaken such that all constituencies understand the human side of the loss of the river and its dams and that this be placed in the ACoE report or incorporated by reference.
9. I request that a study be done to determine the effectiveness of sediment deactivation as an alternative to dam removal, and that this study include sediment deactivation be done every 5 years and the cost of this compared to dam removal. In addition, the report should clearly outline other methods and combination of methods so that if decisions are made, trade-offs can be holistically understood .
10. I request that a study of real estate values for homes directly on the Assabet River upriver from the Ben Smith dam be undertaken, indicating pre and post dam removal values and that this be placed in the ACoE report or incorporated by reference.
11. I request that an independent comparison of costs to remove dams be undertaken and compared to an independent estimate of costs to reduce phosphate effluent from upriver communities and that this be placed in the ACoE report or incorporated by reference.
12. I request that a study be taken to determine the effects on abutter’s privacy from walking lanes that are likely to be opened up and trees that will be forever lost.
13. I request that all alternatives and solutions for reducing phosphorous in the Assabet River be included in subject report.
The ACoE report appears to be heavily one sided in the favor of removing dams on the river and little if any attention paid to represent competing views or alternatives. I can testify that this is a beautiful river worthy of keeping as is. Removing the dams, especially the Ben Smith dam, will significantly reduce water acreage (by at least 90%) and river width and depth. Those with whom I have spoken on my street, Taft Avenue in Maynard, agree with the view that it would be wrong to lose this resource. Please do not allow our way of life and the loss of a valuable recreational resource to be forever lost.
We welcome a dialogue and reply to these requests and concerns.
Thursday, December 3, 2009
Fish Ladders
We have been told that Anadromous Fish require the removal of the Ben Smith Dam.
Anadromous fishes are those that spend all or part of their adult life in salt water and return to freshwater streams and rivers to spawn. We have been lead to believe these fish can not get past man made impoundments.
So what should we do?
We have been told that these fish are not currently able to get past Billerica but we should remove the Ben Smith Dam so that we will be ready when they get here.
Sounds like a good plan, right?
Currently in Lawrence there is what is known as a fish ladder. This fish ladder allows anadromous fish to navigate around the 32 foot high dam.
These "proposed" fish, will be provided a fish ladder at Powder Mill Dam should they ever arrive there.
Better Plan!
A fish ladder should be provided at the Ben Smith Dam as well.
Anyone who is actually familar with the Ben Smith Dam can tell you that there is already what amounts to a natural fish ladder.
In the lower left of this picture you can see some of the natural outcropping of rock that rises from the river basin almost to the crest of the dam. I've seen anadromous fish jump much higher than this dam. I know I've been tempted to take my kayak right over it when the water is high.
I think were our anadromous friends here, they would be able to get past the Ben Smith Dam already. The American Eel can.
However, if the situation ever arises and they can't, a couple well placed rocks will solve the problem.
Thursday, November 19, 2009
Upstream Downstream a Contemporary Fable
It was many years ago that the villagers of Downstream recall spotting the first body in the river. Some old timers remember how spartan were the facilities and procedures for managing that sort of thing. Sometimes they say, it took hours to pull 10 people from the river, and even then only a few would survive.
Though the number of victims in the river has increased greatly in recent years, the good folk of Downstream have responded admirably to the challenge. Their rescue system is clearly second to none: most people discovered in the swirling waters are reached within 20 minutes-many less than 10. Only a small number drown each day before help arrives - a big improvement from the way it use to be.
Talk to the people of Downstream and they'll speak with pride about the new hospital by the edge of the waters, the flotilla of rescue boats ready for service at a moment's notice, the comprehensive plans for coordinating all the manpower involved, and the large numbers of highly trained and dedicated swimmers always ready to risk their lives to save victims from the raging currents. So it cost a lot, say to the Downstreamers, but what else can descent people do except to provide whatever is necessary when human lives are at stake.
Oh, a few people in Downstream have raised the question now and again, but most folks show little interest in what's happening Upstream. it seems there's so much to do to help those in the river that nobody's got time to check how all those bodies are getting in the river in the first place. That's the way things are sometimes.
Though the number of victims in the river has increased greatly in recent years, the good folk of Downstream have responded admirably to the challenge. Their rescue system is clearly second to none: most people discovered in the swirling waters are reached within 20 minutes-many less than 10. Only a small number drown each day before help arrives - a big improvement from the way it use to be.
Talk to the people of Downstream and they'll speak with pride about the new hospital by the edge of the waters, the flotilla of rescue boats ready for service at a moment's notice, the comprehensive plans for coordinating all the manpower involved, and the large numbers of highly trained and dedicated swimmers always ready to risk their lives to save victims from the raging currents. So it cost a lot, say to the Downstreamers, but what else can descent people do except to provide whatever is necessary when human lives are at stake.
Oh, a few people in Downstream have raised the question now and again, but most folks show little interest in what's happening Upstream. it seems there's so much to do to help those in the river that nobody's got time to check how all those bodies are getting in the river in the first place. That's the way things are sometimes.
Strength in Numbers
There is strength in numbers. No this is not about boring calculations.
It is about our ability to get our voices heard. We can be more effective as a group than as unorganized individuals.
Along this line we are thinking about a community group to represent the interests of those along the Ben Smith Impoundment and elsewhere along the Assabet River. Other Community Action groups have been very successful at influencing public policy.
If you would like to be a part of the new "Ben Smith Consortium" Please take the time to send your contact information to riversideobserver@gmail.com or follow the permanent email link to the right.
Together we can make this happen.
It is about our ability to get our voices heard. We can be more effective as a group than as unorganized individuals.
Along this line we are thinking about a community group to represent the interests of those along the Ben Smith Impoundment and elsewhere along the Assabet River. Other Community Action groups have been very successful at influencing public policy.
If you would like to be a part of the new "Ben Smith Consortium" Please take the time to send your contact information to riversideobserver@gmail.com or follow the permanent email link to the right.
Together we can make this happen.
Wednesday, November 18, 2009
Wayland has to Hold 0.1mg/l Year Round
In an agreement between US EPA and the Town of Wayland signed in August of 2009
"A year-round total phosphorous effluent limit of 0.1mg/l for the discharge to either the wetland or the Sudbury River"
http://yosemite.epa.gov/oa/EAB_Web_Docket.nsf/Filings%20By%20Appeal%20Number/99D5A78F9B0E16D38525761100522905/$File/EPA%20R1%20Wayland%20Fourth%20Status%20Report%20-%20Exhibit%201%20settlement%20agreement...69.1.pdf
Sounds like its not as impossible as the "consortium" would like you to believe.
Make sure the DEP understands that the Assabet is just as important as the Sudbury.
"A year-round total phosphorous effluent limit of 0.1mg/l for the discharge to either the wetland or the Sudbury River"
http://yosemite.epa.gov/oa/EAB_Web_Docket.nsf/Filings%20By%20Appeal%20Number/99D5A78F9B0E16D38525761100522905/$File/EPA%20R1%20Wayland%20Fourth%20Status%20Report%20-%20Exhibit%201%20settlement%20agreement...69.1.pdf
Sounds like its not as impossible as the "consortium" would like you to believe.
Make sure the DEP understands that the Assabet is just as important as the Sudbury.
What Can You Do? (11/18/09)
Attend the meeting this Thursday in Stow, see post below for info.
http://assabetriver.blogspot.com/2009/11/what-can-i-do-nov-9-2009.html
If you are writing a letter please bring it and read it aloud, so that others can hear your concerns and include them in their letters to the DEP.
After attending the first meeting Tuesday night, we were amazed at the difference between this meeting and meetings we have attended that were sponsored by OAR, the Organization for the Assabet River. There was open and fair dialogue, and we were told that if the DEP received comments in writing (preferably by email), those concerns would be included in the report.
Don't drop the ball, make sure you send your letters!
http://assabetriver.blogspot.com/2009/11/what-can-i-do-nov-9-2009.html
If you are writing a letter please bring it and read it aloud, so that others can hear your concerns and include them in their letters to the DEP.
After attending the first meeting Tuesday night, we were amazed at the difference between this meeting and meetings we have attended that were sponsored by OAR, the Organization for the Assabet River. There was open and fair dialogue, and we were told that if the DEP received comments in writing (preferably by email), those concerns would be included in the report.
Don't drop the ball, make sure you send your letters!
Monday, November 16, 2009
Letter to the Conservation Commission
Dear members of the Conservation Commission,
We need your help,
Many property owners abutting the river and elsewhere in town are concerned about the Army Corps of Engineers proposal to remove the Ben Smith Dam in Maynard. As you know this will affect hundreds of acres of wetland in Stow and Maynard. While we understand that wetlands protection is not the only mandate of the Conservation Commission, we are very concerned about this impact. We are also concerned about the impact to agriculture recreation and open space.
"Today many Conservation Commissions spend the bulk of their time hearing and conditioning wetlands cases. While this responsibility is vital, it often leaves inadequate time for open space protection and other matters. " - Mass. Assoc. of Cons. Coms.
http://www.maccweb.org/about_commissions.html
The resource value created by the Ben Smith Dam goes far beyond the wetlands issue.
We the people are very concerned that when a property owner wishes to build a shed, remediation and landscaping plans that are "invasive" to our lives and privacy are required. However when large government agencies plan to modify hundreds of acres of wetlands, that they don't even own, as a limited project, the Conservation Commission is strangely silent.
What is the Conservation Commission doing to make sure that the Army Corp of Engineers and the DEP for that matter are not allowed to come into our town and mandate the loss of water for agriculture and fire protection along with the loss of 100 acres of wetlands, and a multi-year disturbance of hundreds more acres? This disturbance will likely cause contaminated sediment to be dislodged and transported down stream effecting plants animals and people. Irrigation and drinking water sources will be disrupted by changes in water level or by dislodged contaminates (Billerica?). We will loose the recreational value of the area for most if not all of the year. Canoeing kayaking and fishing will be greatly impacted. The Historic Mill Complex and its associated structures, like the dam and the impoundment, are resources that must also be protected. And what really bothers us is that - all this is so other towns can save a few bucks and continue to pollute our river. We have paid for Title V septic systems sometimes more than once. We have been forced to put in new wells to accommodate increasingly complex septic systems that take up more space in our yards -- why shouldn't the WWTFs in these other towns have to do the same?
We the People would like the Conservation Commission to represent the will of the people in our town and stop this from happening.
Make sure the Army Corp of Engineers is clear that we will not go forward with this plan. And that those objections are recorded within their report.
Let the DEP know we will not allow other towns to continue to pollute the Assabet River. These WWTFs must be made to hold their phosphorous discharges to 0.1mg/l all year long.
If the Conservation Commission is unable or unwilling to do so we will take our issues directly to the selectmen.
Thank you,
The People who live here.
We need your help,
Many property owners abutting the river and elsewhere in town are concerned about the Army Corps of Engineers proposal to remove the Ben Smith Dam in Maynard. As you know this will affect hundreds of acres of wetland in Stow and Maynard. While we understand that wetlands protection is not the only mandate of the Conservation Commission, we are very concerned about this impact. We are also concerned about the impact to agriculture recreation and open space.
"Today many Conservation Commissions spend the bulk of their time hearing and conditioning wetlands cases. While this responsibility is vital, it often leaves inadequate time for open space protection and other matters. " - Mass. Assoc. of Cons. Coms.
http://www.maccweb.org/about_commissions.html
The resource value created by the Ben Smith Dam goes far beyond the wetlands issue.
We the people are very concerned that when a property owner wishes to build a shed, remediation and landscaping plans that are "invasive" to our lives and privacy are required. However when large government agencies plan to modify hundreds of acres of wetlands, that they don't even own, as a limited project, the Conservation Commission is strangely silent.
What is the Conservation Commission doing to make sure that the Army Corp of Engineers and the DEP for that matter are not allowed to come into our town and mandate the loss of water for agriculture and fire protection along with the loss of 100 acres of wetlands, and a multi-year disturbance of hundreds more acres? This disturbance will likely cause contaminated sediment to be dislodged and transported down stream effecting plants animals and people. Irrigation and drinking water sources will be disrupted by changes in water level or by dislodged contaminates (Billerica?). We will loose the recreational value of the area for most if not all of the year. Canoeing kayaking and fishing will be greatly impacted. The Historic Mill Complex and its associated structures, like the dam and the impoundment, are resources that must also be protected. And what really bothers us is that - all this is so other towns can save a few bucks and continue to pollute our river. We have paid for Title V septic systems sometimes more than once. We have been forced to put in new wells to accommodate increasingly complex septic systems that take up more space in our yards -- why shouldn't the WWTFs in these other towns have to do the same?
We the People would like the Conservation Commission to represent the will of the people in our town and stop this from happening.
Make sure the Army Corp of Engineers is clear that we will not go forward with this plan. And that those objections are recorded within their report.
Let the DEP know we will not allow other towns to continue to pollute the Assabet River. These WWTFs must be made to hold their phosphorous discharges to 0.1mg/l all year long.
If the Conservation Commission is unable or unwilling to do so we will take our issues directly to the selectmen.
Thank you,
The People who live here.
Sunday, November 15, 2009
Assabet River Sunset
The neighborhood is a buzz with talk of the river's future
But on a night like this we long for days that move at the speed of the river
Is it so wrong to move slowly?
The Assabet is in no rush, perhaps we should heed its lesson
Letter to the DEP
Ms. Rojko
As abutters to the Ben Smith Impoundment in Maynard MA, the proposal to remove the Historic Ben Smith Dam will have a direct impact on our family and our home. We believe that the negative impact on the recreational value alone would be enough to oppose this plan. But the loss of history, culture, and community identity could not be remediated. As we have researched more we realize that the claims of environmental improvement will actually result in a loss of 100 acres of wetlands. In addition we are to have our entire neighborhood dug up for multiple years. All this so that WWTFs can continue to pollute the Assabet River. Dam removal only relocates the problem down stream. It seems clear that the best solution for all involved is tighter winter limits on phosphorous discharge.
We request that the recommendation to remove the Ben Smith Dam be stricken from the US Army Corps of Engineers "Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study". We feel that this proposal does not meet the TMDL Phase II requirement of a 90 percent reduction in sediment phosphorus flux and is repugnant to the myriad concerns acknowledged in the report.
We request that instead the report should be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1mg/l should be mandated for any and all discharges into the Assabet River with no exceptions.
We also request that the above abutter objections are clearly outlined in the report and in the conclusion.
Thank you,
We'd like to see more sample letters keep them coming.
As abutters to the Ben Smith Impoundment in Maynard MA, the proposal to remove the Historic Ben Smith Dam will have a direct impact on our family and our home. We believe that the negative impact on the recreational value alone would be enough to oppose this plan. But the loss of history, culture, and community identity could not be remediated. As we have researched more we realize that the claims of environmental improvement will actually result in a loss of 100 acres of wetlands. In addition we are to have our entire neighborhood dug up for multiple years. All this so that WWTFs can continue to pollute the Assabet River. Dam removal only relocates the problem down stream. It seems clear that the best solution for all involved is tighter winter limits on phosphorous discharge.
We request that the recommendation to remove the Ben Smith Dam be stricken from the US Army Corps of Engineers "Assabet River, Massachusetts Sediment and Dam Removal Feasibility Study". We feel that this proposal does not meet the TMDL Phase II requirement of a 90 percent reduction in sediment phosphorus flux and is repugnant to the myriad concerns acknowledged in the report.
We request that instead the report should be altered to recommend that, based on the CDM modeling results, phosphorous discharge levels of no greater than 0.1mg/l should be mandated for any and all discharges into the Assabet River with no exceptions.
We also request that the above abutter objections are clearly outlined in the report and in the conclusion.
Thank you,
We'd like to see more sample letters keep them coming.
Saturday, November 14, 2009
Nothing in this Hand....Where did those wetlands go?
From the Corps of Engineers report.
http://www.nae.usace.army.mil/projects/ma/assabetriver/feasibilitystudy.pdf
"* MADEP classified a significant portion of the Ben Smith Impoundment area as Deep Marsh ~100 acres. However if this classification were changed to open water then the change in wetlands would be as shown in parentheses in the above Table."
Why would the Corps want to change the classification of these wetlands?
Wouldn't it be nice if every time we ran across a problem in life we could just change the rules and make that problem go away?
"The term “freshwater wetlands”, as used in this section, shall mean wet meadows, marshes, swamps, bogs, areas where groundwater, flowing or standing surface water or ice provide a significant part of the supporting substrate for a plant community for at least five months of the year; emergent and submergent plant communities in inland waters; that portion of any bank which touches any inland waters. "
"The term “marshes”, as used in this section, shall mean areas where a vegetational community exists in standing or running water during the growing season and where a significant part of the vegetational community is composed of, but not limited to nor necessarily including all, of the following plants or groups of plants: arums (Araceae), bladder worts (Utricularia), bur reeds (Sparganiaceae), button bush (Cephalanthus occidentalis), cattails (Typha), duck weeds (Lemnaceae), eelgrass (Vallisneria), frog bits (Hydrocharitaceae), horsetails (Equisetaceae), hydrophilic grasses (Gramineae), leatherleaf (Chamaedaphne calyculata), pickerel weeds (Pontederiaceae), pipeworts (Eriocaulon), pond weeds (Potamogeton), rushes (Juncaceae), sedges (Cyperaceae), smartweeds (Polygonum), sweet gale (Myrica gale) water milfoil (Halcragaceae), water lilies (Nymphaeaceae), water starworts (Callitrichaceae), water willow (Decodon verticillatus). "
http://www.mass.gov/legis/laws/mgl/131-40.htm
"The term "marshes," as used in this section, shall mean areas where an emergent vegetative community exists in standing or running water during most of a normal growing season and where a significant part of the vegetative community is tolerant of sustained partial submergence. Deep marshes have near continuous standing water and are dominated by aquatic plants with floating leaves."
"The term "wetland succession," as used in this section, shall mean the following generalized sequence in wetland evolution. For freshwater wetlands the sequence is pond, to deep marsh, to shallow marsh, to shrub swamp, to forested swamp, to bog."
http://www.mass.gov/legis/bills/senate/st00/st00515.htm
That sure sounds a lot like the Ben Smith Impoundment.
Don't let the DEP reclassify your wetlands out of existence.
http://www.nae.usace.army.mil/projects/ma/assabetriver/feasibilitystudy.pdf "* MADEP classified a significant portion of the Ben Smith Impoundment area as Deep Marsh ~100 acres. However if this classification were changed to open water then the change in wetlands would be as shown in parentheses in the above Table."
Why would the Corps want to change the classification of these wetlands?
Wouldn't it be nice if every time we ran across a problem in life we could just change the rules and make that problem go away?
"The term “freshwater wetlands”, as used in this section, shall mean wet meadows, marshes, swamps, bogs, areas where groundwater, flowing or standing surface water or ice provide a significant part of the supporting substrate for a plant community for at least five months of the year; emergent and submergent plant communities in inland waters; that portion of any bank which touches any inland waters. "
"The term “marshes”, as used in this section, shall mean areas where a vegetational community exists in standing or running water during the growing season and where a significant part of the vegetational community is composed of, but not limited to nor necessarily including all, of the following plants or groups of plants: arums (Araceae), bladder worts (Utricularia), bur reeds (Sparganiaceae), button bush (Cephalanthus occidentalis), cattails (Typha), duck weeds (Lemnaceae), eelgrass (Vallisneria), frog bits (Hydrocharitaceae), horsetails (Equisetaceae), hydrophilic grasses (Gramineae), leatherleaf (Chamaedaphne calyculata), pickerel weeds (Pontederiaceae), pipeworts (Eriocaulon), pond weeds (Potamogeton), rushes (Juncaceae), sedges (Cyperaceae), smartweeds (Polygonum), sweet gale (Myrica gale) water milfoil (Halcragaceae), water lilies (Nymphaeaceae), water starworts (Callitrichaceae), water willow (Decodon verticillatus). "
http://www.mass.gov/legis/laws/mgl/131-40.htm
"The term "marshes," as used in this section, shall mean areas where an emergent vegetative community exists in standing or running water during most of a normal growing season and where a significant part of the vegetative community is tolerant of sustained partial submergence. Deep marshes have near continuous standing water and are dominated by aquatic plants with floating leaves."
"The term "wetland succession," as used in this section, shall mean the following generalized sequence in wetland evolution. For freshwater wetlands the sequence is pond, to deep marsh, to shallow marsh, to shrub swamp, to forested swamp, to bog."
http://www.mass.gov/legis/bills/senate/st00/st00515.htm
That sure sounds a lot like the Ben Smith Impoundment.
Don't let the DEP reclassify your wetlands out of existence.
You Want to Dig up What???
Proposed Dredging from Dowtown Maynard a mile upstream past Crow Island
Not sure how hydraulic dredging equipment at Rt 117 will be able to dredge a mile upstream.
Why would the schedule for Gleasondale be 35% longer for less than half the dredge volume? It seems like the sediment removal for the Ben Smith Dam was glossed over in the 20 month schedule presented.
Only $13M, but wait that just leaves us with a 150 acre dirt pit. How much is the effort to revegitate with non invasive species going to cost?
BTW how much for the great new park that will bring more dogs and visitors, with their associated waste, litter and poop, into our back yards?
How much did we really end up spending on the Big Dig? 4X overruns are pretty common place these days. So that $13M is quickly going to end up being $50+M. And where is this money coming from?
I'd like to talk to these guys with the deep pockets. I'm sure they have a good reason why we can't spend this money to address the root cause of this problem, excessive phosphorous levels caused by these WWTFs. Its time to stop playing the games and make these facilities clean up their acts.
If DEP wants to spend $50M the right place is on these WWTFs not on dam removal.
Why is the Corps of Engineers Involved?
Back in 2005
FEDERAL FUNDS SOUGHT FOR CLEANUP -- A recent trip to the nation's capital yielded no commitments but ''cautious optimism" about the possibility of getting aid from the federal government for the cleanup of the Assabet River, according to Paul Blazar, town executive assistant. Blazar met with aides to several Massachusetts senators and congressmen to ask for help with the multimillion-dollar cleanup required by state and federal environmental agencies. Blazar represented a consortium of affected communities -- Hudson, Marlborough, Maynard, Northborough, Shrewsbury, and Westborough. With him were two representatives of the private Organization for the Assabet River. While the congressional aides promised to look for funds, one likely source, the Army Corps of Engineers, has had its budget slashed for next fiscal year. ''Any cautious optimism is tempered by that reality," Blazar said. -- Connie Paige
http://www.boston.com/news/local/massachusetts/articles/2005/03/06/community_briefing_1161199104/
Paul Blazar is the executive assistant for the Town of Hudson.
http://www.townofhudson.org/Public_Documents/HudsonMA_Exec/index
Back in 2001
"recognizing that impending environmental regulations will probably restrict the town's current waste-water discharge into the Assabet River, Hudson, Massachusetts' officials are considering imposing a moratorium on new sewer connections"
http://waterindustry.org/New%20Projects/hudson.htm
I guess Paul or some others came up with a better plan...........
Why not get the Corps of Engineers involved, then somebody else can pay to clean up this mess.
I guess some of us are still confused as to how this plan, of taking down dams and letting this phosporous, which is acknowledged as "bad", flow further down stream, fixes the problem?
http://www.boston.com/news/local/massachusetts/articles/2005/03/06/community_briefing_1161199104/
Paul Blazar is the executive assistant for the Town of Hudson.
http://www.townofhudson.org/Public_Documents/HudsonMA_Exec/index
Back in 2001
"recognizing that impending environmental regulations will probably restrict the town's current waste-water discharge into the Assabet River, Hudson, Massachusetts' officials are considering imposing a moratorium on new sewer connections"
http://waterindustry.org/New%20Projects/hudson.htm
I guess Paul or some others came up with a better plan...........
Why not get the Corps of Engineers involved, then somebody else can pay to clean up this mess.
I guess some of us are still confused as to how this plan, of taking down dams and letting this phosporous, which is acknowledged as "bad", flow further down stream, fixes the problem?
Letter to the Editor
Dear Editor:
Advocates of removing the Ben Smith Dam on the Assabet River in Maynard note two primary problems with the Assabet River: (1) the discharge problem wherein wastewater treatment plants upstream of Stow discharge wastewater including phosphorus into the Assabet River which causes the growth of algae and duck weed and (2) the impoundment problem wherein the phosphorous settles in the slow moving water behind the Ben Smith Dam and continues to cause the growth of algae and duck weed.
Remove the dam, these advocates assert, and the impoundment problem goes away.
The truth is, the impoundment problem pales in comparison to the discharge problem caused by wastewater treatment plants upstream from Stow discharging phosphorus into the river. Removing the dam has nothing to do with the discharge problem. But, if the discharge problem were eliminated, the impoundment problem would be corrected as well.
Many communities including several on the Assabet River, others in Massachusetts, and across the nation do not discharge wastewater into rivers. Numerous technologies exist for wastewater treatment other than discharging wastewater into our nation’s rivers. Restoring the Assabet River to its “natural” state is a fiction so long as wastewater treatment plants continue to discharge wastewater into our river.
We, the home and property owners on the Assabet River who look at and interact with the river every day by kayaking, boating, fishing, hunting, and the like urge our local, state, and federal officials to seriously consider the real impact of removing the Ben Smith Dam. We would much rather deal with the duck weed and algae in August of each year than an unsightly one foot deep impassable narrow stream, the loss of wetlands, and our way of life.
Leave the dam alone.
Sincerely,
Letters like this need to be read by the people making these decisions.
If you have written or are about write a letter, and you would like to share it with others who might not be skilled writers, please let us know. We will start a new post for your letter, so that others will be able to see and comment on what you think.
Advocates of removing the Ben Smith Dam on the Assabet River in Maynard note two primary problems with the Assabet River: (1) the discharge problem wherein wastewater treatment plants upstream of Stow discharge wastewater including phosphorus into the Assabet River which causes the growth of algae and duck weed and (2) the impoundment problem wherein the phosphorous settles in the slow moving water behind the Ben Smith Dam and continues to cause the growth of algae and duck weed.
Remove the dam, these advocates assert, and the impoundment problem goes away.
The truth is, the impoundment problem pales in comparison to the discharge problem caused by wastewater treatment plants upstream from Stow discharging phosphorus into the river. Removing the dam has nothing to do with the discharge problem. But, if the discharge problem were eliminated, the impoundment problem would be corrected as well.
Many communities including several on the Assabet River, others in Massachusetts, and across the nation do not discharge wastewater into rivers. Numerous technologies exist for wastewater treatment other than discharging wastewater into our nation’s rivers. Restoring the Assabet River to its “natural” state is a fiction so long as wastewater treatment plants continue to discharge wastewater into our river.
We, the home and property owners on the Assabet River who look at and interact with the river every day by kayaking, boating, fishing, hunting, and the like urge our local, state, and federal officials to seriously consider the real impact of removing the Ben Smith Dam. We would much rather deal with the duck weed and algae in August of each year than an unsightly one foot deep impassable narrow stream, the loss of wetlands, and our way of life.
Leave the dam alone.
Sincerely,
Letters like this need to be read by the people making these decisions.
If you have written or are about write a letter, and you would like to share it with others who might not be skilled writers, please let us know. We will start a new post for your letter, so that others will be able to see and comment on what you think.
These Measures Are Inadequate
"Phase 2 of the TMDL required additional projects be implemented to continue to decrease total phosphorus loading to the river. The phosphorus TMDL indicated that to achieve water quality standards a 90 percent reduction in sediment phosphorus flux was needed in addition to decreasing the WWTFs effluent to 0.1 mg/l. Measures suggested to achieve the 90 percent sediment phosphorus flux reduction included dam removal and dredging. If these measures were determined to be inadequate in achieving the desired reduction in phosphorus loading to the river then further decreases in discharges of phosphorus from the WWTFs would be required."
http://www.nae.usace.army.mil/projects/ma/assabetriver/Assabet-ExecSummary2009.pdf
Based on the CDM study, Removal of the Ben Smith Dam plus the summer limits of 0.1mg/l are projected to create a 70% reduction. 60% of that is reduction from the summer limits.
It is pretty clear -- and it has been for some time now -- that this proposal does not meet the TMDL requirement.
In addition this proposal does not address the "root cause" of this issue. "Consortium Towns" are dumping too much phosporous into the Assabet River. Taking any dams out will only allow this pollution to float further downstream and become someone elses problem.
Please, as abutters and stakehholders, make sure the Mass DEP understands: We the citizens of Maynard and Stow are tired of having our home used as a dumping ground so others can save a few bucks. If the DEP feels that there is an extra $13-$50 million of state and federal money floating around to remove our dam, then lets spend it to really fix the problem.
I'm still waiting for an answer: Why can't these new wastewater treatment facilities (WWTF) hold 0.1mg/l in the winter? Even if the 0.1mg/l winter limits are only half as effective as the summer limits that still makes the 90% reduction mandated.
The new Co-Mag systems that these WWTF are installing can do it in the summer.
http://www.cambridgewatertech.com/technologies.html
http://www.nae.usace.army.mil/projects/ma/assabetriver/Assabet-ExecSummary2009.pdf
Based on the CDM study, Removal of the Ben Smith Dam plus the summer limits of 0.1mg/l are projected to create a 70% reduction. 60% of that is reduction from the summer limits.
It is pretty clear -- and it has been for some time now -- that this proposal does not meet the TMDL requirement.
In addition this proposal does not address the "root cause" of this issue. "Consortium Towns" are dumping too much phosporous into the Assabet River. Taking any dams out will only allow this pollution to float further downstream and become someone elses problem.
Please, as abutters and stakehholders, make sure the Mass DEP understands: We the citizens of Maynard and Stow are tired of having our home used as a dumping ground so others can save a few bucks. If the DEP feels that there is an extra $13-$50 million of state and federal money floating around to remove our dam, then lets spend it to really fix the problem.
I'm still waiting for an answer: Why can't these new wastewater treatment facilities (WWTF) hold 0.1mg/l in the winter? Even if the 0.1mg/l winter limits are only half as effective as the summer limits that still makes the 90% reduction mandated.
The new Co-Mag systems that these WWTF are installing can do it in the summer.
http://www.cambridgewatertech.com/technologies.html
Thursday, November 12, 2009
Who Would Want to Take Down Our Dam?
From the Blog "Shrewsburied," Thursday, November 15, 2007
(Shrewsburied covers issues of concern to residents of Shrewsbury)
"Sewer fees up 70% in 2010"
"Much of the revenue from the higher fees will fund a $19.5 million upgrade of the treatment plant. Specifically, a new phosphorus-removal system will reduce the amount of phosphorus discharged from the plant into the Assabet River. Presently each day the plant discharges about 28 pounds of phosphorus dissolved in 4.4 million gallons of treated water; by 2010, that will drop to about 4 pounds in 4.65 million gallons. The state and federal governments want less phosphorus in the Assabet River because phosphorus fertilizes algae growth in the river during late summer."
"The state encouraged the town to build the treatment plant, and the state approved the location, design, and operation of the plant. The state also specified the standards that the treated water must meet before it can be discharged into the Assabet. But when the state decided that the plant was polluting the Assabet, Shrewsbury -- not the state -- had to pay to correct the problem. Tens of millions of dollars that could have been spent on Shrewsbury's schools, police, and other departments will instead be spent to clean a river that doesn't even flow through Shrewsbury."
http://shrewsburied.blogspot.com/2007/11/sewer-fees-up-70-in-2010.html
The Assabet does flow through Stow and Maynard and that's where some of the sewerage that these towns are dumping is ending up. Beyond that, in order to be able to continue dumping in our yards these towns would like to take down the Ben Smith Dam because it will save them tax dollars, and BTW its not their town.
I would like to give the good people of Shewsbury, Northboro, Westboro, Marlboro, Hudson and even Maynard, the benefit of the doubt here. I'm sure they are not aware of what the "Consortium" is doing in their names.
I am a bit concerned that the "Consortium" proposes that it is OK to continue polluting the river, so long as it flows away quickly. If it doesn't pool up and linger too long in front of anyone important's home, then its OK. I wonder what the people of Billerica think about all this.
Here's a picture of the water intake station for the Town of Billerica Drinking Water Plant along the Concord River......Guess where what we dump into the Assabet ends up?
The Assabet River is not a magic conduit. Things that are dumped into the river do not magically disappear. They end up somewhere else. And when they do somebody has to clean up the mess. Taking down these dams will just move the problem somewhere else.
I personally do not feel that my community should have to pay the price so that people in these "Consortium" towns can avoid paying to clean up their own mess.
(Shrewsburied covers issues of concern to residents of Shrewsbury)
"Sewer fees up 70% in 2010"
"Much of the revenue from the higher fees will fund a $19.5 million upgrade of the treatment plant. Specifically, a new phosphorus-removal system will reduce the amount of phosphorus discharged from the plant into the Assabet River. Presently each day the plant discharges about 28 pounds of phosphorus dissolved in 4.4 million gallons of treated water; by 2010, that will drop to about 4 pounds in 4.65 million gallons. The state and federal governments want less phosphorus in the Assabet River because phosphorus fertilizes algae growth in the river during late summer."
"The state encouraged the town to build the treatment plant, and the state approved the location, design, and operation of the plant. The state also specified the standards that the treated water must meet before it can be discharged into the Assabet. But when the state decided that the plant was polluting the Assabet, Shrewsbury -- not the state -- had to pay to correct the problem. Tens of millions of dollars that could have been spent on Shrewsbury's schools, police, and other departments will instead be spent to clean a river that doesn't even flow through Shrewsbury."
http://shrewsburied.blogspot.com/2007/11/sewer-fees-up-70-in-2010.html
The Assabet does flow through Stow and Maynard and that's where some of the sewerage that these towns are dumping is ending up. Beyond that, in order to be able to continue dumping in our yards these towns would like to take down the Ben Smith Dam because it will save them tax dollars, and BTW its not their town.
I would like to give the good people of Shewsbury, Northboro, Westboro, Marlboro, Hudson and even Maynard, the benefit of the doubt here. I'm sure they are not aware of what the "Consortium" is doing in their names.
I am a bit concerned that the "Consortium" proposes that it is OK to continue polluting the river, so long as it flows away quickly. If it doesn't pool up and linger too long in front of anyone important's home, then its OK. I wonder what the people of Billerica think about all this.
The Assabet River is not a magic conduit. Things that are dumped into the river do not magically disappear. They end up somewhere else. And when they do somebody has to clean up the mess. Taking down these dams will just move the problem somewhere else.
I personally do not feel that my community should have to pay the price so that people in these "Consortium" towns can avoid paying to clean up their own mess.
Wednesday, November 11, 2009
Not all Dams Should be Torn Down
From American Rivers Inc. , an organization that "protects and restores America's rivers for the benefit of people, wildlife, and nature":
"While hundreds of dams have been removed, that does not mean that all dams should be torn down. In fact, very few of all documented dams in the United States are even being considered for removal. The removal of 400 dams represents just over one-half of one percent of the more than 75,000 dams over six feet tall existing across the country. Many dams continue to serve important public or private functions such as flood control, irrigation, and hydropower generation. In some cases, changing the way a dam operates will provide enough ecological improvements to the river to justify the continued benefits of the dam. In other cases, removing a dam could have adverse ecological effects – such as the release of contaminated sediments – that are too costly to mitigate. And in some cases, dams are retained because they represent a significant aspect of the community’s history."
http://www.americanrivers.org/assets/pdfs/dam-removal-docs/Exploring_Dam_Removal-A_Decision-Making_Guide6fdc.pdf
"Making a final decision, once all of the information is collected, will be affected by many factors, including:
• The ecological circumstances surrounding the case;
• The economic circumstances surrounding the case;
• The complexity of the issues;
• The legal and political context in which a decision must be made;
• The impetus for considering dam removal (e.g., fisheries restoration goal, dam safety concern);
• The identity of the decision makers (e.g., dam owner, state agencies);
• The amount of controversy surrounding the decision; and
• The number, identities, and strength of various stakeholders."
Some who have and continue to hold one sided meetings pushing the agenda of Dam Removal would like these bottom two issues not to exist.
And if we remain silent they won't exist.
Take the time to let these people know that there is a hugh amount of controversy surrounding this; and as abbutters and citizens of the towns affected by this plan we are stakeholders and our strength is growing. We must enter our concerns into the public record NOW.
Send a letter or two, to those decision makers. Other posts will show you how.
"While hundreds of dams have been removed, that does not mean that all dams should be torn down. In fact, very few of all documented dams in the United States are even being considered for removal. The removal of 400 dams represents just over one-half of one percent of the more than 75,000 dams over six feet tall existing across the country. Many dams continue to serve important public or private functions such as flood control, irrigation, and hydropower generation. In some cases, changing the way a dam operates will provide enough ecological improvements to the river to justify the continued benefits of the dam. In other cases, removing a dam could have adverse ecological effects – such as the release of contaminated sediments – that are too costly to mitigate. And in some cases, dams are retained because they represent a significant aspect of the community’s history."
http://www.americanrivers.org/assets/pdfs/dam-removal-docs/Exploring_Dam_Removal-A_Decision-Making_Guide6fdc.pdf
"Making a final decision, once all of the information is collected, will be affected by many factors, including:
• The ecological circumstances surrounding the case;
• The economic circumstances surrounding the case;
• The complexity of the issues;
• The legal and political context in which a decision must be made;
• The impetus for considering dam removal (e.g., fisheries restoration goal, dam safety concern);
• The identity of the decision makers (e.g., dam owner, state agencies);
• The amount of controversy surrounding the decision; and
• The number, identities, and strength of various stakeholders."
Some who have and continue to hold one sided meetings pushing the agenda of Dam Removal would like these bottom two issues not to exist.
And if we remain silent they won't exist.
Take the time to let these people know that there is a hugh amount of controversy surrounding this; and as abbutters and citizens of the towns affected by this plan we are stakeholders and our strength is growing. We must enter our concerns into the public record NOW.
Send a letter or two, to those decision makers. Other posts will show you how.
Monday, November 9, 2009
An Additional Finding
Also in the Army Corps of Engineers Sediment and Dam Removal Feasibility Study....
"An additional finding of the CDM analysis was that phosphorus discharge in the winter is an important part of the annual phosphorus budget in the Assabet River. This finding appears to indicate that lower winter limits on WWTFs discharge of phosphorus may contribute significantly to reducing sediment phosphorus flux and might be another control measure for DEP and stakeholders to consider to control phosphorus loading to the river." Page ES-2
http://www.nae.usace.army.mil/projects/ma/assabetriver/feasibilitystudy.pdf
Although this sounds like a much simpler and farther reaching solution, the Army Corps of Engineers has decided that The Ben Smith Dam should be removed because it would provide "a 2.8 lbs/day decrease in P loading". How many extra pounds per day are being dumped into the river from November to March?
And BTW, if the Million Dollars per Decrease in Impoundment River Mile(DIRM)M$/DIRM is half as much for Allen Street, why has the Ben Smith Dam been selected. I think it's pretty clear that this recommendation was based on DPO, that's Dollars (to the Corps) per Option.
Well since we are talking "Metrics", here's one: Cost per Page (CPP) at 330 pages and one million dollars this report has a CPP of $3,030/page. Is that good? Is that bad? Well, we could compare that to the CPP of other government reports but that's not really very useful is it? Maybe we should look at non government reports as well.....
What is the Value per Dollar or VPD for each of our options here. Is the VPD of this report greater than the VPD of Upgrading Waste Water Treatment Facilities? Is it greater than operating these facilities so that they do not pollute in the winter as well as in the summer?
I guess it all depends on who you ask. I'm sure the people doing the dumping will have a much different opinion than those getting dumped on. I guess my family should just be thankful our drinking water does not come from the river.
Is it just possible that there are better things to spend our taxpayer dollars on than enabling municipalities to continue to pollute. What's the VPD for just doing what's obvious: a year round limit of 0.1mg/l?
(math geeks please note the VPD for doing nothing is infinite)
"An additional finding of the CDM analysis was that phosphorus discharge in the winter is an important part of the annual phosphorus budget in the Assabet River. This finding appears to indicate that lower winter limits on WWTFs discharge of phosphorus may contribute significantly to reducing sediment phosphorus flux and might be another control measure for DEP and stakeholders to consider to control phosphorus loading to the river." Page ES-2
http://www.nae.usace.army.mil/projects/ma/assabetriver/feasibilitystudy.pdf
Although this sounds like a much simpler and farther reaching solution, the Army Corps of Engineers has decided that The Ben Smith Dam should be removed because it would provide "a 2.8 lbs/day decrease in P loading". How many extra pounds per day are being dumped into the river from November to March?
And BTW, if the Million Dollars per Decrease in Impoundment River Mile(DIRM)M$/DIRM is half as much for Allen Street, why has the Ben Smith Dam been selected. I think it's pretty clear that this recommendation was based on DPO, that's Dollars (to the Corps) per Option.
Well since we are talking "Metrics", here's one: Cost per Page (CPP) at 330 pages and one million dollars this report has a CPP of $3,030/page. Is that good? Is that bad? Well, we could compare that to the CPP of other government reports but that's not really very useful is it? Maybe we should look at non government reports as well.....
What is the Value per Dollar or VPD for each of our options here. Is the VPD of this report greater than the VPD of Upgrading Waste Water Treatment Facilities? Is it greater than operating these facilities so that they do not pollute in the winter as well as in the summer?
I guess it all depends on who you ask. I'm sure the people doing the dumping will have a much different opinion than those getting dumped on. I guess my family should just be thankful our drinking water does not come from the river.
Is it just possible that there are better things to spend our taxpayer dollars on than enabling municipalities to continue to pollute. What's the VPD for just doing what's obvious: a year round limit of 0.1mg/l?
(math geeks please note the VPD for doing nothing is infinite)
What Can You Do? (11/9/09)
READ the reports - Follow the link to the Army Corp of Engineers Reports:
http://www.nae.usace.army.mil/projects/ma/assabetriver/assabetriver.htm
ATTEND the public informational meetings!!! Bring your questions & comments.
Two public informational meetings will be held to present the analyses and findings of the planning study:
Date: Tuesday – November 17, 2009
Registration at 5:30 p.m. with presentation from 6:00 to 8:00 p.m.
Best Western Royal Plaza Hotel and Trade Center - Salon E
181 Boston Post Road
Marlborough, MA 01752
Date: Thursday – November 19, 2009
Registration at 5:30 p.m. with presentation from 6:00 to 8:00 p.m.
Hale Middle School
55 Hartley Road
Stow, MA 01775
And more importantly:
WRITE a letter - Make sure the DEP knows what the people who live here think.
MassDEP will consider all comments on this draft report and it will be revised as appropriate.
All comments must be submitted in writing, preferably in an electronic format, and must be received by December 21, 2009. Comments should be submitted to:
E-mail: Alice.Rojko@massmail.state.ma.us
Or mail to:
MassDEP - Division of Watershed Management
627 Main Street
Worcester, MA 01608
Attention: Alice M. Rojko
The Army Corps of Engineers Report - First Impression
I would like to say that although I have not completed the entire 330 pages (I have read about half of it so far), I would like to say that I am quite impressed with the level of detail covered by this report.
I am also a bit disappointed that most of it was a mere footnote to the recommendation in the conclusion. I guess I'm a little unclear on the purpose of the report vs the propaganda it's being used for. Was the purpose of the report to tell us which Dam to take down or should it have better addressed whether we should take these dams down at all? I'm pretty sure I can argue for the feasibility of anything so long as I can disregard all the contra-indicators.
http://www.nae.usace.army.mil/projects/ma/assabetriver/assabetriver.htm
I am also a bit disappointed that most of it was a mere footnote to the recommendation in the conclusion. I guess I'm a little unclear on the purpose of the report vs the propaganda it's being used for. Was the purpose of the report to tell us which Dam to take down or should it have better addressed whether we should take these dams down at all? I'm pretty sure I can argue for the feasibility of anything so long as I can disregard all the contra-indicators.
http://www.nae.usace.army.mil/projects/ma/assabetriver/assabetriver.htm
What is this Blog About
As you may or may not know there is a movement afoot to change our river and our community. People have been spending our tax dollars studying how to best change our river and directly effect our lives and property. The Army Corps of Engineers has completed a study and has issued their draft report recommending the removal of the Historic Ben Smith Dam, which will require dredging from the millponds in downtown Maynard past Crow Island.
How will removing the Dam affect our river?
For those of you who are not aware, the Ben Smith Dam is part of the historic mill complex in Maynard. It is responsible for the current geography of the river from Maynard to Gleasondale. Removing the Dam will result in the water level dropping 7 feet – turning the river into a shallow narrow stream, severely curtailing if not eliminating it's viability for Canoeing Kayaking or Fishing, not to mention destroying its current beauty and aesthetics along with 100+ acres of wetlands. Ask your conservation commission if this really qualifies as a "Limited" project.
Why would anyone want to remove the Dam?
Some would like you to believe that the Dam is the cause of our river not meeting state and federal clean water standards. On the other hand some believe that removing the Dam will only allow towns upstream to save their local tax dollars and continue to pollute our river. A consortium of towns who dump their wastewater into our river have decided that it is better to remove our dam then for them to simply conform to the same clean water standards in the winter that they are already required to comply with in the summer.
Why, after the enormous capital expenditures these towns have undertaken to upgrade their wastewater treatment plants to hold a 0.1 mg/l phosphorous discharge level in the summer, do they still balk at the incremental cost to maintain this level in the winter? It is stupefying that they would rather ruin the profound natural beauty of our neighborhood, the recreational value, and the wildlife habitat – as if dumping their waste into our yards was not insult enough.
Are there other solutions?
How far could the million dollars spent on this study – or the proposed $13 million (More like $50M) that it would cost to remove the Ben Smith Dam – go towards winter operating costs? But that's state and federal money instead of their town money so that makes it better for them but unfortunately it is at our expense.
How will removing the Dam affect our river?
For those of you who are not aware, the Ben Smith Dam is part of the historic mill complex in Maynard. It is responsible for the current geography of the river from Maynard to Gleasondale. Removing the Dam will result in the water level dropping 7 feet – turning the river into a shallow narrow stream, severely curtailing if not eliminating it's viability for Canoeing Kayaking or Fishing, not to mention destroying its current beauty and aesthetics along with 100+ acres of wetlands. Ask your conservation commission if this really qualifies as a "Limited" project.
Why would anyone want to remove the Dam?
Some would like you to believe that the Dam is the cause of our river not meeting state and federal clean water standards. On the other hand some believe that removing the Dam will only allow towns upstream to save their local tax dollars and continue to pollute our river. A consortium of towns who dump their wastewater into our river have decided that it is better to remove our dam then for them to simply conform to the same clean water standards in the winter that they are already required to comply with in the summer.
Why, after the enormous capital expenditures these towns have undertaken to upgrade their wastewater treatment plants to hold a 0.1 mg/l phosphorous discharge level in the summer, do they still balk at the incremental cost to maintain this level in the winter? It is stupefying that they would rather ruin the profound natural beauty of our neighborhood, the recreational value, and the wildlife habitat – as if dumping their waste into our yards was not insult enough.
Are there other solutions?
How far could the million dollars spent on this study – or the proposed $13 million (More like $50M) that it would cost to remove the Ben Smith Dam – go towards winter operating costs? But that's state and federal money instead of their town money so that makes it better for them but unfortunately it is at our expense.
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