JULY 23, 2009 MEPA COMMENT LETTER RE FRAMINGHAM'S BIRCH ROAD WELLFIELD REDEVELOPMENT PROPOSAL
by Tom Sciacca
visits since 090727; last
updated 090727.
From: Tom Sciacca <tsciacca@comcast.net>
Date: Thu, Jul 23, 2009 at 7:39 PM
Subject: My final submission, FYI. See picture at end
July 23, 2009
Secretary Ian A. Bowles
Executive Office of Environmental Affairs – MEPA Office
100 Cambridge St.
Boston, MA 02114
Attn. Anne Canaday, MEPA Analyst
Via Email
cc. Marybeth Taylor (SEA Consultants)
John D. Viola (MADEP)
Steve Calichman (Wayland BOH)
Brian Monahan (Wayland ConCom)
Don Ouellette (Wayland DPW)
Wayland Selectmen
Wayland Water Division
COMMENTS IN RESPONSE TO DRAFT ENVIRONMENTAL IMPACT REPORT, BIRCH ROAD WELL SITE REACTIVATION, FRAMINGHAM
EOEA NUMBER 14197
Dear Secretary Bowles and Ms. Canaday:
These
comments are directed primarily to the impact of the proposed new
withdrawal on the Sudbury River adjacent to and downstream of the
location of the Birch Road wells, and on possible impacts to the
Wayland wells. In general, I believe that the proposed withdrawals will
have a devastating effect on the river which CANNOT be mitigated with
management strategies under the Water Management Act, as claimed by the
proponent.
To understand the scope and significance of this
proposal, it should be noted that the proposed withdrawals will exceed
the current average withdrawals from all of the towns downstream along
the Sudbury River to its confluence with the Assabet. Furthermore,
unlike in those towns, all of the water will be exported through the
MWRA sewer system out of the basin and lost to the river ecosystem.
The
impact of the withdrawals will begin at the confluence of Cochituate
Brook with the river in Saxonville, which normally carries most of the
outflow from Lake Cochituate to the river and will much more frequently
be dewatered as a result of these proposed withdrawals. Only
about 300 yards downstream is the beginning of the Wild and Scenic
segment of the river, federally recognized for its "outstandingly
remarkable" beauty, recreational value, and wildlife habitat. Removal
of flow from the river in the proposed location will have a radical
effect on river flow in dry periods at least to the point where the
next tributaries (Pine Brook and Hop Brook) enter the river near
Wayland Center several miles downstream. This area also encompasses the
beginning of the Great Meadows National Wildlife Refuge, nationally
significant wildlife habitat.
Table 7-11, showing AVERAGE flows
in the river and a withdrawal rate of up to 12% from the proposed
pumping, is interesting context but does not address the primary issue.
It is the effect during dry years that is of concern, not average years.
The
pumping test and vertical gradient table, 7-13, show conditions during
the spring when groundwater is highest; it is not surprising that
groundwater is discharging to the river in these conditions and this
data is again not relevant to the primary concerns. The potential
issues occur in the late summer when the groundwater level has dropped.
The
fundamental background is that groundwater is flowing toward the river
and all water removed by additional withdrawals is water that would
have flowed in the river. The critical element not discussed in the
FEIR is time: specifically the transit time of groundwater movement
over the significant distance from the wells to the river. In 7.7.1,
second paragraph, this is given as 2,500 feet, while in other sections
of the document it is specified as 1200 feet. The proponent should
accurately specify this distance, but in either case the time from any
change in pumping rate at the wells to an effect at the river will be
significant. The delineation of Zone 2, which is defined as the effects
of 180 days of pumping, as barely reaching the river oxbow, suggests
that the lag time between actions at the wells and effects at the river
are on the order of six months. The fact that the 21 day pumping test
appeared to have no influence on the levels at the oxbow as shown in
Figure 7-19 is further evidence of the long time lags involved.
Furthermore,
Cochituate Brook draining Lake Cochituate enters the river in
Saxonville slightly upstream of the segment of the river surrounding
the proposed new wells. The proponent states that one third of the well
withdrawals will be generated by induced recharge from the lake, and
shows a water budget for the lake with the vast majority of the outflow
occurring in the brook. Therefore one third of the well pumping rate
will be removed from the brook flow, and therefore from the river flow.
Yet, again, any reduced pumping at the wells will likely take months to
result in a reduction of lake infiltration into the aquifer and a
corresponding increase in brook flow, because the wells are
approximately equally far from the lake as the river.
In recent
years the flow at the Saxonville gauge has dipped under 5 cfs in the
late summer (4.6 cfs in September 2007). At 6.65 cfs (Table 7-11), the
effect of the proposed withdrawal exceeds 100% of those low
flows. The proponent suggests that under the Water Management Act
pumping could be reduced in such a situation. But to make such an
action effective it would have to have been initiated in the previous
winter, when conditions in late summer would have been pure speculation.
In
2007 the river flow dipped below 6 cfs for three months, August,
September, and October. The photo below shows the river looking
downstream from the Stonebridge Road bridge toward the old ruined
bridge in late August, when the Saxonville flow measured approximately
7 cfs. Half the riverbed is dry and only a few inches of water remain
in the other half. This appears to be the site referred to in the DEIR
as the ungaged "Sudbury River at Oxbow" site. Yet flows in late spring
and into July were normal. It would have been impossible to predict the
dry late summer conditions in time to take effective action under the
WMA.
River flows in 2001 showed a similar pattern, but dipped
even lower in August, September, and October to 5.3, 4.0, and 4.8 cfs
respectively. Yet in early July flows were well over 200 cfs. By late
July, however, flows were down to 7.0 cfs. Again, sub-month time scales
are much too short to allow effective mitigating action by adjusting
well withdrawals.
All river flow data are from the USGS website waterdata.usgs.gov.
It
is worth noting that the two lowest flow years in the online record
(since 1979) occurred in this past decade, perhaps as a result of
global climate change and watershed development. The river may now be
significantly more sensitive than when the Birch Road wells were last
active, suggesting the need for reduced pumping relative to historical
practices. This is the opposite of the proponent's desire to withdraw
at a rate nearly 40% higher than historical rates.
To aggravate
the situation, flows in the river can be altered on time scales on the
order of hours as a result of decisions made to alter dam releases,
including releases from Cochituate Brook to maintain the level of Lake
Cochituate, which will also be impacted by the proposed withdrawals. So
the scenario of low flow turning into even lower or zero flow
essentially instantaneously, while remedial actions from adjusting
pumping rates take months to be effective, leads to the almost certain
nearly complete dewatering of the river during dry years. Needless to
say, this is unacceptable.
If the proponent believes that
effective action could have been taken under a scenario of full use of
the Birch Road wells in 2001 and 2007 to prevent dewatering of the
river, it should delineate how such action could have occurred in
detail. This is necessary to meet the requirement on page 5 of the
Certificate that "The proposed wells should not be allowed to have a
significant impact on flows in the Sudbury River, which is already
depleted by other upstream withdrawals."
With regard to
interactions with Wayland wells, the proponent contends there is a
hydrological barrier between the recharge areas of the Wayland and
Framingham wells which precludes any effect on Wayland's wells from the
proposed new pumping. (see Figure 3-2). The impermeable barrier in all
probability exists along West Plain Street in Wayland to separate Lake
Cochituate from Dudley Pond, which lies about 10 feet higher. But the
extension of that barrier along the town line and extending to the
river is speculation. The supposed barrier would transect the pond in
Pod Meadow to the east of the proposed new wells, which would act as a
hydrological short circuit between the two sides of any such barrier;
Wayland's Happy Hollow wells are to the northeast. In fact, the data
shown for SG-3 during the pumping test is relevant to this claim.
Located in the pond supposedly outside the Zone 2 area, it documents a
pond drawdown of nearly a half foot to dry conditions during the test,
proving that the pond is bridging any groundwater barriers. To the
north of the new wells the river oxbow would again act as a
hydrological short circuit to any groundwater barrier; Wayland's
Meadowview well is to the north. Unless both of these surface features
are perched and isolated from the groundwater beneath them (no evidence
for this is presented in the document) the supposition that the
Framingham withdrawal will have no effect on the Wayland wells is
questionable.
It is also worth noting that while it may or may
not be true that the aquifer surrounding the Birch Road wells is
hydraulically isolated from the Wayland Meadowview and Happy Hollow
wells there will be a definite connection through the regulatory
process. Since the Wayland wells are adjacent to the river (in the
flood plain) a reduction in Wayland pumping would result in immediate
benefit to the river. State officials would be forced to restrict
Wayland pumping during low streamflow emergencies to make up for the
ineffectiveness of restrictions on the Framingham wells. Even so, while
reducing Wayland pumping might benefit the river in Wayland and further
downstream, the river from the oxbow to the vicinity of Wayland High
School (site of the Happy Hollow wells) may go dry. Wayland High School
is the approximate point at which the impounding effects of the
Billerica dam and Fordway bar are lost. Beyond that point the river may
not go dry even with a loss of upstream flow, but it may go stagnant.
Finally,
with regard to the Interbasin Transfer Act, the plain language of the
regulations, which provides that the well capacity must be useable
"without additional installation of facilities", seems clear. The new
treatment plant which is required to make the Birch Road water
"useable" is certainly a new "facility", eliminating any grandfathering
of withdrawals from these wells. Since the heart of the issues I raise
above is in fact the removal of water from the Sudbury River basin (if
all of Framingham were on septic systems, as are Wayland and Sudbury,
return of the well withdrawals to the aquifer providing the river base
flow would be automatic), permitting under the IBTA should provide a
process to resolve the questions.
As a result of the major
unanswered questions outlined above, it should be clear that this
document should be treated as a DEIR and not an FEIR, and the proponent
should respond to the issues raised.
Thomas Sciacca
Wayland Representative, Sudbury, Assabet, and Concord Wild and Scenic River Stewardship Council
Member, Wayland Wellhead Protection Committee
SB, MIT
31 Rolling Lane
Wayland, MA 01778
Sudbury River at Stonebridge Road (Oxbow site) Late August 2007
