Re: Falmouth South Coast Watersheds Comprehensive Wastewater Management Plan CCC - #ENF14154 Attn: Aisling Eglington, MEPA Unit

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1 Secretary Ian A. Bowles Executive Office of Energy and Environmental Affairs MEPA Office 100 Cambridge Street, Ste. 900 Boston, MA Re: Falmouth South Coast Watersheds Comprehensive Wastewater Management Plan CCC - #ENF14154 Attn: Aisling Eglington, MEPA Unit Dear Secretary Bowles: The Cape Cod Commission (Commission) has received an Environmental Notification Form (ENF) for Town of Falmouth Comprehensive Wastewater Management Planning Project for the South Coast Watersheds including the Needs Assessment Report and Alternatives Screening Report for Little Pond, Great Pond, Green Pond, Bournes Pond, Eel Pond and Waquoit Bay (EEA #14154). The ENF was noticed in the Environmental Monitor on December 24, The Needs Assessment Report identifies wastewater needs within a study area comprised of the estuary watersheds, while the Alternatives Screen Report reviews the potential technologies to address the identified needs. The Needs Assessment Report and Alternatives Screening Report provide the basis for the development of a draft comprehensive wastewater plan that will be filed with MEPA as a Draft Environmental Impact Report. A subcommittee of the Commission has reviewed the ENF including the two reports and recommends that the town proceed to the preparation of a Draft Comprehensive Wastewater Management Plan/DEIR. The Needs Assessment and Alternatives Analysis represent significant progress in addressing the identified water quality problems in the listed estuaries. During the preparation of the Draft Plan, the Commission looks forward to continuing to work closely with the town to ensure that the Draft Plan is consistent with the goals of the Regional Policy Plan (RPP) and that the wastewater infrastructure that is designed and constructed for the study area accounts for the unique aspects of linked groundwater and surface water system that characterizes Cape Cod. In order to facilitate this consistency, Page 1 of 6

2 the subcommittee has the following comments on the ENF and the accompanying reports that can be used in enhancing the resulting Draft Plan: 1. Work to comprehensively identify all wastewater needs A needs assessment report is the key document for establishing the foundation of a comprehensive wastewater plan. It identifies all the water quality issues and wastewater disposal issues within a study area. For several decades now, scientific study and citizen observations have identified worsening water quality in our coastal waters. These impacts are due to on-site systems that contribute excess nitrogen to these sensitive water bodies. The South Coast needs assessment is a major step by the town of Falmouth to address the water quality problems that have been documented by the Massachusetts Estuaries Project for Little Pond, Great Pond, Green Pond, Bournes Pond, and East Waquoit Bay. The MEP Technical Reports indicated that each of these estuaries is currently receiving excessive nitrogen loads, developed nitrogen thresholds that would restore these systems, and determined potential nitrogen reduction scenarios that allow these systems to meet their thresholds. The MEP nitrogen thresholds were subsequently adopted by Massachusetts Department of Environmental Protection as Total Maximum Daily Loads (TMDLs) under the federal Clean Water Act. While the nitrogen loading issues facing the estuaries are a well-established need and the focus of the Project, the corresponding needs of the other resources impacted by the same loading sources should also be identified to holistically manage the aquifer system they all share as envisioned in the Regional Policy Plan. Within the Needs Assessment study area are six public drinking water supply wells, 19 freshwater ponds, and three rivers. The needs report (pg. 5-7) mentions that 6 of the 7 freshwater ponds sampled during the 2001 Pond and Lake Stewardship (PALS) Snapshot exceeded the regional phosphorus threshold. Commission staff have met with town staff and consultants to review the status of these other resources following the public hearing. In order to help the town address drinking water impacts, Commission staff reviewed historic water quality data from the public water supply wells in the study area and found all of them have average nitrate-nitrogen concentrations well below the RPP limit of 5 ppm and the state drinking water standard of 10 ppm. In addition, none of the wells displayed any significant trends; groundwater concentrations tended to fluctuate in a fairly constrained range below 1.5 ppm. The results indicating that the drinking water supplies in the study area do not have any current concerns from wastewater-derived nitrogen is not surprising given the long range efforts of the town to acquire lands within the Zone IIs and to establish local regulatory means to protect them. It has been recommended to town staff that evaluation of future impacts from buildout, shifts in seasonal occupancy, and/or occupancy rates should be considered as a supplemental project that is not a part of the DEIR. Commission staff are available to assist the town in this effort, if desired. Page 2 of 6

3 Commission and town staff also discussed the status of the freshwater ponds with the study area and throughout the town. Staff recommended to town staff that the town consider beginning a monitoring program to better establish the water quality issues associated with freshwater ponds. This program could be coordinated through the town, but largely rely on volunteers, much in the same way that the successful coastal monitoring program has generated data. A pond-monitoring program could start this summer through the use of the PALS Snapshot, which provides free laboratory services through SMAST, and run for a number of years, taking advantage of the time that will be required to begin installing sewer lines to address estuary issues. This data could also be combined with water quality data collected as a result of various monitoring activities at the Massachusetts Military Reservation. If pond water quality issues are identified through a review of the collected data, these can be addressed through subsequent inpond and or watershed management, strategies. Commission staff are available to assist the town in the development and implementation of a pond-monitoring program. Commission and town staff also discussed river water quality and areas with high septic system failure rates. Town consultants noted that no wastewater related eutrophication concerns have been brought to their attention and that conversations with town health agents had not indicated any areas with regular septic system failures. 2. Clarify evaluation of all available information Water quality scenarios have been completed by the MEP Technical Team for sewering and inlet enhancement within the study area (Howes, et al., 2005) and for options within the West Falmouth Harbor study area (Howes, et al., 2007). The Great, Green, and Bournes MEP Technical report showed that the combination of sewering areas in the study area that were selected by the town, treating and discharging the collected wastewater at the Falmouth Country Club, and enhancements to the Bourne Pond inlet would allow each of these estuaries to attain their nitrogen thresholds. The MEP Technical Report (Howes, et al., 2006) and the scenarios runs that followed for West Falmouth Harbor indicate that the improvements in effluent nitrogen treatments at the town wastewater treatment facility (WWTF) will allow the Harbor TMDL to be met. We understand that the South Coastal Project is not looking to revise the findings of the 2001 Facility upgrade Final EIR that incorporated these findings. Theses findings include the scenario results that showed that if sewering within the Harbor watershed does not occur, total flows from the WWTF should be limited to less than 0.5 million gallons per day to meet the TMDL. The scenario completed in the Technical Report indicated that if sewering within the Harbor watershed is implemented, it creates capacity for additional WWTF flows and accompanying nitrogen loading from outside the watershed. Clearly these results have important implications as constraints for wastewater solutions in the Needs Assessment study area. If these findings and results are problematic to solutions for the South Coastal Project, then the Draft Comprehensive Plan should address these results. Page 3 of 6

4 3. Clarify status of planning and analysis for Waquoit Bay Waquoit Bay was one of the first estuaries on Cape Cod identified as having excessive nitrogen loads and a number of significant, highly publicized events have reinforced that it is clearly an impaired system. Because appropriate water quality data must still be gathered in the Bay, a nitrogen threshold for the main portion has not been developed by the MEP Technical Team. Thresholds have been developed for the easternmost portions of the system and these thresholds have been approved as final nitrogen TMDLs by USEPA (2007). Although the main portion of Waquoit Bay has not been analyzed by the MEP Technical Team, the Needs Assessment assigns the same percentage reductions assigned to Bournes Pond with the acknowledgement that they may need to be changed in the future (pg. 5-4). During the meeting of Commission and town staff, it was agreed that assigning a preliminary percentage reduction to the main Waquoit Bay subwatershed is understandable for planning purposes and that the required reduction from the MEP is critical for finalizing the CWMP. This discussion noted that because the proposed discharge site at the Falmouth Country Club is partially located within the main Bay watershed and this is one of the preferred wastewater discharge alternatives, additions from the Country Club site will have to be compensated by removals from the watershed. The town s consultants indicated that the draft CWMP is planned for May Since Waquoit Bay is not scheduled for completion of its MEP analysis until at least 2010 or 2011, quantification of the appropriate nitrogen load to the Bay and Eel Pond will not be available for the draft CWMP. It is recommended by the Commission that the draft CWMP proceed with the acknowledgement that modifications in its findings and resulting implementation may be required once the Waquoit Bay nitrogen threshold is available from the MEP Technical Team. 4. Documentation of groundwater modeling and impacts from proposed treatment plant discharge The Needs Assessment indicates that average annual wastewater flows of 2.9 million gallons per day (MGD) will be generated in the study area. The Alternatives Screening Analysis Report has selected three alternative discharge sites for more refined analysis: 1) wastewater treatment at the municipal Falmouth Wastewater Treatment Facility (WWTF) with effluent recharge at the WWTF and the Falmouth Country Club, 2) wastewater treatment at both the existing WWTF and a proposed WWTF at the Falmouth Country Club with effluent recharge at both, and 3) wastewater treatment at both the existing WWTF and a proposed WWTF at the Massachusetts Military Reservation with effluent recharge at both the WWTF, MMR and at Falmouth Country Club. The key factors in all these scenarios is the location of the recharge, the nitrogen load associated with the recharge, and the capacity of the water resource receptors to accept the nitrogen load from the recharge. The Commission agrees that the alternative to evaluate the MMR as a potential new facility and separate recharge site is warranted. The Commission will continue to work Page 4 of 6

5 with Falmouth, MMR and other surrounding towns to evaluate the opportunities for regional wastewater management. As mentioned in #3 above, the Falmouth Country Club is located on the boundary between the Waquoit Bay and Bournes Pond watersheds. Since all of the estuary watersheds are defined by groundwater elevations, the addition of a large volume of effluent on one side or another of the watershed boundary has the potential to shift the boundary and the nitrogen loads from the effluent and other nearby sources toward one system or the other. The reasonable way to evaluate the potential impact is to create a subregional groundwater model. This model can be used to track where flows and the associate nitrogen loads are discharged. The town has recently been awarded a contract for groundwater modeling from the Cape Cod Water Protection Collaborative to refine the regional USGS groundwater model to evaluate potential regional impacts from recharge at the Falmouth Country Club site. The project scope project calls for coordination of modeling activities with the Commission, USGS, and MassDEP and includes the tracking of where effluent nitrogen loads recharged at the Country Club site are discharged into the estuaries and other downgradient resources, such as freshwater ponds and drinking water supply wells. The results of this work is to be incorporated into the CWMP. If expansion of discharge at the West Falmouth Harbor WWTF beyond what has already been evaluated is proposed in the draft CWMP, it is recommended that similar modeling to justify that increase be completed. In addition, it is also recommended that the revision of nitrogen loads resulting from these proposals be evaluated using the MEP water quality models to ensure that the TMDLs are attained. CONCLUSION The Commission strongly supports the Town of Falmouth s goals to address the excessive nitrogen loading to the Little Pond, Great Pond, Green Pond, Bournes Pond, Eel Pond and Waquoit Bay estuaries. The South Coastal Watershed Needs Assessment and Alternatives Screening Analysis are significant steps toward realizing these goals. Throughout the subsequent Comprehensive Wastewater Management Planning process, the Commission will continue to work with the town and its consultants to insure that the solutions developed create sustainable water quality for all the wells, ponds, and estuaries in the study area. Commission staff are available to assist with the recommended steps and analyses that will clarify wastewater and water quality management issues addressed in these comments. Page 5 of 6

6 Thank you for the opportunity to comment on this project. Sincerely, Brad Crowell Subcommittee chairperson cc: Robert Whritenour, Town Manager Ray Jack, DPW Jerry Potamis, DPW Jay Zavala, CCC, Falmouth Brian Dudley, DEP, SERO Ron Lyberger, DEP/BMF Brian Howes, UMASS-D, SMAST Tom Fudala, Planning, Mashpee David Mason, Health, Sandwich Nate Weeks, Stearns and Wheler Brian Nickerson, MMR, NGB Mark Rasmussen, Coalition for Buzzards Bay References: Final Wastewater Facilities Plan and Final Environmental Impact Report, Stearns and Wheler, Feb. 5, 2001 Certificate from the Secretary of Environmental Affairs on the Final EIR, March 22, Howes B., J.S. Ramsey, S.W. Kelley, R. Samimy, D. Schlezinger, and E. Eichner Linked Watershed-Embayment Model to Determine Critical Nitrogen Loading Thresholds for Great/Perch Pond, Green Pond, and Bournes Pond, Falmouth, Massachusetts. Massachusetts Estuaries Project, Massachusetts Department of Environmental Protection. Boston, MA. 205 pp. + Executive Summary, 11 pp. Howes B., S.W. Kelley, J. S. Ramsey, R. Samimy, D. Schlezinger, and E. Eichner Linked Watershed-Embayment Model to Determine Critical Nitrogen Loading Thresholds for West Falmouth Harbor, Falmouth, Massachusetts. Massachusetts Estuaries Project, Massachusetts Department of Environmental Protection. Boston, MA. Howes B., R. Samimy, J.S. Ramsey, S.W. Kelley, and E. Eichner. February 22, Scenario Runs of West Falmouth Harbor MEP Linked Model. Memorandum to Korrin Petersen and Mark Rasmussen, Coalition for Buzzards Bay. School of Marine Science and Technology, UMASS Dartmouth. United States Environmental Protection Agency. November 7, Approval of Quashnet River, Hamblin Pond, Little River, Jehu Pond, and Great River in the Waquoit Bay System TMDLs for Total Nitrogen. Letter of Approval from Stephen S. Perkins, Director, Office of Ecosystem Protection to Laurie Burt, Commissioner, MassDEP Page 6 of 6