Monday, December 28, 2009

OAR Takes a Position

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?

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.

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.

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.

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.

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

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;

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
Telephone: (617)-722-2060

Town of Maynard, Chairman Board of Selectmen
Mr. David D. Gavin;

Maynard Town Hall
195 Main Street
Maynard, MA 01754
Phone: 978-897-1001
Fax: 978-897-8457

Maynard Town Administrator
Mr. John Curran;

Maynard Town Hall
195 Main Street
Maynard, MA 01754
Phone: (978) 897-1001
Fax: (978) 897-8457

Chairman Maynard Conservation Commission,
Mr. Fred King;

Maynard Town Hall
195 Main Street
Maynard, MA 01754
Phone: 978-897-0560

Town of Stow, Chairman Board of Selectmen;
Mr. Stephen M. Dungan

Stow Town Hall
380 Great Road
Stow, MA 01775-2127
Phone: (978) 897-4515
Fax: (978) 897-4631

Chairman Stow Conservation Commission;
Mr. David Coppes

Stow Town Hall
380 Great Road
Stow, MA 01775-2127
Phone: (978) 897-8615
Fax: (978) 897-4534
.
.
.
.
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:
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.

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.

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.

Thursday, December 3, 2009

Fish Ladders

We have been told that Anadromous Fish require the removal of the Ben Smith Dam.

Why?

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.