UMASS/ AMHERST 3120bb 0276 mSl 7 PUBLIC COmENTS AND RESPONSES TO COmENTS AN APPENDIX TO THE WATER QUALITY MANAGEMENT PLAN FOR THE UPPER HOUSATONIC RIVER FINAL PLAN/ ENVIRONMENTAL IMPACT STATEMENT September 1978 Prepared By: The Berkshire County Regional Planning Commission 10 Fenn Street Pittsfield, Massachusetts 01201 U. S. Environmental Protection Agency Region I J. F. K. Federal Building Boston, Massachusetts 02203 Digitized by the Internet Archive in 2015 https://archive.org/details/publiccoininentsreOOunit TABLE OF CONTENTS PAGE FEDERAL Environmental Protection Agency, Region I 2 Department of Housing & Urban Development, Area Office 12 Department of Transportation, Federal Aviation Administration 13 Department of Agriculture, Forest Service 14 D^ artment of Agriculture, Soil Conservation Service 15 Department of the Interior, Northeast Region 16 STATE Department of Environmental Quality Engineering 26 Division of Water Pollution Control 31 Division of Water Supply 42 Department of Community Affairs 43 Department of Public Works 47 Executive Office of Environmental Affairs 50 Massachusetts Historical Commission 58 Department of Commerce and Development 59 Office of State Planning 62 Connecticut Department of Environmental Protection 66 LOCAL 75-102 FEDERAL 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203 May 26, 1978 RECEIVED JiJN 1 1978 Mr. Rick Holmes 208 Project Director Berkshire County Regional BERKSHIRE COUNTY KtWHiruieiiiucaiiMissiiM Planning Commission Ten Fenn Street Pittsfield, MA 01201 Dear Rick: Attached are my review comments on the Berkshire County RPC Draft Plan/EIS. Also attached are preliminary copies of the Regional review sheets which are separated by planning elements from the regulations. I have tried to cross reference the BCRPC chapters to the appropriate regulation numbers to ease your synthesis. I have received copies of comments from many State and Federal agencies but in talking with you, Bob Mendoza and Dave Terry it appears that none of us may have a complete set of comments. Therefore, we should probably get together soon to exchange information and discuss the transition requirements between the draft and final stages. I will be looking forward to meeting with you in the near future. Sincerely , William W. Nuzzo Water Quality Branch attachments cc: D. Terry R. Mendoza Water Quality Branch Review of BCRPC Draft Plan/EIS W.W. Nuzzo 5/26/78 1 . Typos, Corrections and Deletions A. Page B-15 mentions 25 cfs low flow augmentation. Figures G-4 utilize 22 cfs. B-5 and B. Page 1 of Town Summary — ...storms may clean the town of_ city streets C. .Table D-1 "Lake Conditions" should define conditions 1,2, 3,4. D. Page ^-13 "Control Measure" number 8 is not labeled. E. Page D-28 first and second paragraph refers to Table D-5. should probably be Table D-11. This 2. Land Use (Chapter C) Regulations: Inventories and Projections [131.11(c)] A. Page C-12 states that "NPS is not sufficient to justify controls...". Table J-1 indicates that erosion related NPS are significant with relation to sediments and coliform. Other sources identify P- loading from NPS as significant. Land use guidelines to reduce erosion should be proposed (e.g. buffer strips, slope guideliens, construction practices). B. PCP calls for identification of critical water quality impact areas on a scale of 1:24,000. Has this information been plotted and trans- mitted to the towns? C. PCP states that specific town by-laws will be drafted for each com- munity. Have these specific by-laws been drafted and transmitted to the towns? D. Individual town-by-town land use constraint maps are called for by PCP. Have these maps been prepared and submitted to the towns? E. The Land Use Chapter (c) states that low growth is expected except in less populated areas. What are specific recommendations to these less populated towns to avoid problems with on-lot disposal systems? (e.g. a sewer avoidance program in Connecticut). F. Since most land use change appears to be from farm land to light residential, are there any State farm preservation programs applic- able? Are any recommended by BCRPC? 3 -1' Municipal '.-.'aste Treatner.t !.eeds; Chapter G, Chapter F Regulations: Point Source Load Allocations 131.11(g); Total Maximum Daily Loads 131.11(f); Municipal Waste Treatment Needs 131. 11(h). A. :-!ousatonic River 1. Connecticut sent letters to EPA, Massachusetts and NEISWPCC strongly objecting to the Pittsfield by-pass of Woods Pond and requesting P-removal at Pittsfield and analysis of the results. 2. Connecticut just received a report from FMC on P-removal at Danbury. Conn. DEP is reviewing this report and will be making a decision soon on P-removal facilities at Danbury and Bethel. 3. A survey of the Housatonic is scheduled for the summer of 1978 by >roWPC and Connecticut DEP. Pittsfield is required by NPDES to provide P-removal May through September, 1978. ■4. Plan does not adequately assess the down stream affects of P.H*^- U discharge or Woods Pond by-\p3ss on P-loading in Connecticut portions of the Housatonic. Various P-removal alternatives and the cost comparisions should be included. Plan also needs additional analysis consideration of storage option. B. 1. Plan should include recommendations to MDWPC on funding priorities for 201 facilities grants. The grant condition was partially complied with during Phase I but recommendations were not finalized or presented. 2. Abatement dates and recommended schedules should be included. C . Stockbridge 1. There is a difference in the 201 and 208 recommendations on sewering Stockbridge Bowl. The resolution of the 201/208 conflict should be undertaken at the earliest possible time. 1. BCRPC has recently received additional information on septic tank failures in the Bowl area that may warrant revision of their plan. This data should be summarized in the final plan. D. Combined Sewers Regulations: 131(1) 1. Berkshire County's plan did not recommend complete sewer separ- ation in Great Barrington (GB) due to high costs of project. The recently completed 201 in GB shows cost figures substan- tially lower than BCRPC 's estimates. Therefore, it is likely that the 208 plan will be modified to incorporate the completed GB combined sewer report. 2. The Plan should contain a summary of the recommended approach for GB. 1| -3- S=:tic Tanks and Septage Management 1. Septic tanks have been identified in the plan as being an increasingly i-portant problem in BCRPC. The analysis of recommendations concerning the towns capabilities of managing septic tanks was not adequate. Plan lacks specific analysis of town's capabilities and the recom- -endations for alleviating the problems. 2. The concept of regional septage management district or specific intertown agreements to share sanitation services have been suggested on numerous occasions. Smaller towns would benefit from such institutional arrangements if fostered by 208. 3. -Septage management alternatives should be discussed in more detail. What are priorities and schedules for constructing the needed septage handling facilities? Have the inter-town arrangements been drawn up or recommended? Residual Sludge Disposal Rer-lations : 131. 11 (k) 1. I>o evaluation of capacities of municipal sludge disposal areas. The plan should provide specific recommendations for sludge disposal. Ir.--strial Waste Treatment (Chapter F and G) Rezjlations: 131.11(1), Residuals 131.11(k) A. 3AT as previously described was not recommended in the plan. New BAT requirements will necessitate revising BAT costs and recommenda- cions. B. Assessment of industrial pretreatment requirements and towns' sewer use ordinances were not provided as required by the PCP. C. Industries are filling up available sludge disposal sites. Plan lacks adequate assessment of current and future problems with sludge disposal. Plan should make specific recommendations for disposal practices and management agencies. D. Problems associated with PCB's from industrial landfills was not discussed. yor.-Point Source (Chapters D and J) Regulations: NPS Assessment [131.11(d)], NPS Control Needs [131.11(j)] A. Erosion sources (Table j-1 page J-4) have been judged to be a signifi- cant pollutants. Sources of erosion have not been adequately identified. The Plan states NPS are considered not consequential and only good housekeeping practices are recommended. 1. Good housekeeping will not control erosion sources. 5 -4- 2. Plan should identify sources and estbalish priorities. 5. BMP ' s for erosion control should be listed. Recommended BMP's and management agencies should be included. a. \4hat about construction practices? b. What about buffer strips? B. Chapter C presents a good assessment of the status of land use controls and description of potential land use controls, but does not propose specific land use by-laws for specific towns. C. 1. Chapter D attributes certain P-loads to livestock but no BMP's have been suggested. No agricultural BMP's or management agencies have been recommended. 2. Although the P caused by construction practices may be minimal, recommendations for the control of construction practices should be made to the towns. 3. Plan recommends stronger management of septic systems. It does not spell out who will carry this out and with what resources. 4. Land use control measures reviewed in Table C-4 indicates there are large gaps in management needs. Plan should strongly endorse or recommend land use control changes needed. 5. Lake clean up programs will rely heavily on 314 grants and voluntary compliance administered by towns. What about recommendations concerning various lake preservation associations or commissions. There is a need for inter-town agreements to manage the lakes bordered by more than one town. D . Groundwater Protection (Chapter E) Regulations: Nonpoint Source Control Needs 131. 11 (j) 1. The plan does not present site specific recommendations for dealing with present threats to aquifers, (e.g. What to do with existing landfills over aquifers). 2. Groundwater threat by PCB's not discussed. Even though PCBs were not required by PCP, plan should outline Berkshire County priorities of concerns. 3. Only limited PCB studies have been accomplished by the States and EPA. Plan should note that at the present no major studies are underway. E. Agriculture Related Regulation: Non Point Source Control Needs 131. 11 (j) 1. Assessment of agriculture related NPS was weak. Better 6 -5- identification of sediment sources and problem areas needed. Priorities need to be established and BMPs should be listed for each problem area. 2. No rural NPS control management agencies or practices were recommended in the plan. 3. To be eligible for financial assistance under the Rural Clean Water Program (Culver Amendmenet) the project must be included in an approved agricultural portion of the 208 plan. The agricultural portion of the 208 plan must: a. Show that significant agriculture NPS problem exists based on an adequate assessment; b. Contain a list, in priority, of the NPS problem areas and sources; » c. Identify the BMPs to control problems; d. Designate a management agency to implement agricultural section of 208. F. No target abatement dates were provided for the correction of NPS. 6. Urban Runoff (Chapter I) Regulations: 131.11(1) 1. BCRPC recommends a waiver of stream standards and general good house- keeping practices. No specific BMPs are recommended; schedules of implementation are not listed; planning and zoning recommendations were missing; no mention was made of buffer 'strips or green belts. 2. Plan should at a minimum evaluate the capabilities of recommended management agencies to carry out control programs. 7 . Legal, Institutional and Financial Arrangements (Chapter K) Regulations: 131.11(0) Management Agencies 1. The 208 plan is to identify 1) those agencies to construct and operate treatment works and 2) those agencies necessary to implement the regulator}' programs described. BCRPC seems to have concentrated on the requirements of the first type of man^^ment agency and, there- fore, unduly restricted its consideration of management agencies for NPS control to those that met the restrictions in page K-2. 7 The plan did not include an evaluation of the existing management systems as required by the PCP. Recommendations for management agencies for individual portions of the plan of tho pla w should be more specific than municipal government. Subunits of municipal government should be recom- mended to provide specific functions. Uliat are the resources and capabilities of subunits that are recommended? Recommendations for increasing eligibility of 201 and 208 funds are described in Chapter K are not likely in the near term. Cost associated with Federal and State actions should be adjusted to more closely follow current potentials (i.e. it is not likely that 208 funds will be available to hire septic tank inspectors as described on page k-23). Plan should show cost estimates using currently available funding resources and policies. BCRPC recommendations for State and Federal funding and policy modifications should be listed separately for easier understanding. Regulations: Water Quality Standards 131.11(e) The desirability of attaining f ishable/swimraable goals at all times on the Housatonic is addressed at numerous points in the plan. Documentation of BCRPC' s case should be strengthened and avail- able for presentation to MDWPC. Did BCRPC make an official state- ment during Massachusetts Standards hearing held during 1977-1978? a. Recommendations to relax coliform standards should have further backup information. What are the healLh risks to downstream users. Costs associated with meeting standards are presented; costs associated vti-th not meeting standards should also be present . b. Draft plan does not provide adequate data and analysis to recommend waivers of stream standards on non-compliance with 1983 goal of the Act. 8 SOURCE OF COMMENTS U. S. Environmental Protection Agency, Region I Water Quality Planning Branch, William Nuzzo RESPONSES - Numbering is the same as in the review comment letter. 1. Corrections have been made to the errors noted. 2. A. Page C-12 indicates nonpoint so\irce controls in four major areas is justified: near lakes and tributaries; over major groundwater sources; stormwater runoff, and, septic system management. Table J-1 indicates that erosion related sediment and coliform is a significant problem under high flow conditions. The question of coliform levels during storms is a complex one and is thoroughly reviewed in Chapters H, I and J and appropriate recommendations made. High flow sedimentation is a condition which is infrequent and brief, and aquatic species are believed relatively well adapted to brief sediment perturbations. For Isirge projects, erosion controlling construction practices are recommended in the stormwater runoff Chapter. (See I. 6.U). Other land use guide- lines are also recommended, including buffer strips around lakes and their tributaries, lake watershed slope guidelines, etc. The lake management Chapter provided an extensive analysis and control program for phosphorus loading that was contributing to lake eutrophi cation . 2.B. This data has been gathered and published at a scale of 1:^+8,000 so that it could be more widely disseminated to the towns and citizens as part of the report itself. Larger maps of critical areas have been provided as requested to communities which are planning to make them part of their local bylaws. 2.C. Both model and town-specific bylaws have been prepared. A number of selected model bylaws were sent to the towns. However, a full package of either model or specific bylaws was not sent to a town without guidance or advice because it would have been over- whelming and counterproductive. Instead the BCRPC has, and will continue to, work with each town in developing the specific bylaws it feels it needs. 2.D. A development constraints map has been prepared which shows each town at a scale of 1:U8,000. Though this map is not a reproduce- able , and was not sent to each town, its critical contents were incorporated into the development giiidelines map which was printed and more widely distributed through each town. 2.E. Though the rural areas are expected to have relatively more growth than the urban areas, their growth rate is not rapid. The three smallest towns (Monterey, Hinsdale and Stockbridge) will only average an annual growth rate of 1% over the next 25 years. More- over, these towns are sparcely settled and overcrowding should not be a problem. Improvements to septic system management practices for all towns are recommended in the expanded Section 3.0 of Chapter F. 9 2. F. Although the land use changes appear to indicate that agricultural land is being converted to residential, this is not really the case. The net effect of the land use changes is that residential rises and agricultural declines, but not one at the expense of the other. In effect, most abandoned farmland is reverting to forest. Although the BCRPC is concerned about the status of farmland in the region, farmland preservation measures are beyond the scope of this report. However, the BCRPC did not recommend "inanagement of manure", "manage crops per S.C.S.", or "locate livestock out of basin" in the lake management chapter in order not to impose additional costs on economically troubled local farmers . 3. A. Comments are addressed in Chapter G. 3.B.1 Construction grant priorities are described in Section 5«3 of Chapter F. 3.B.2 Schedules for sewer extensions are shown in Figures F-1 through F-T. 3.C. Changes have been made in Chapter F to resolve 201/208 conflicts. 3.D. Changes have been made in Chapter H to incorporate 201 report findings . 3.E. Septic system management and septage disposal program. Section 3.0 of Chapter F, has been expanded. 3.F. Sludge disposal recommendations have been clarified in Section U.2 of Chapter F. h.A. New BAT requirements are noted in Section 5.3 of Chapter F. h.B. Draft Plan/EIS provided requested information, see Section U.O of Chapter F. h.C. Same response as 3F above. h.D. See Section 11.0 of Chapter A for discussion of PCB's. 5. A. Best Management Practices for erosion control have been given further consideration in Chapter J. Specific recommendations for erosion control are contained in Chapters D, H and I. 5.B. Draft Plan/EIS provided requested information, see Section 8.0 of Chapter C. Also, see response to 2.C. above. 5.C.1 This comment is a correct assessment. There are some nutrients coming from livestock, but no controls are suggested at this time because other more superior measures are recommended. However, it is indicated in several places in Chapter D that agricultural-source controls may be needed in the future. 10 5.C.2 This comment appears to be a value judgement. Only the most cost-effective measures vith demons t rat able benefits vere recommended. Controlling construction practices has a cost- effectiveness inferior to several other measures. 5.C.3 The septic system management program in Chapter F has been substantially expanded. 5.C.I+ Table C-U is meant as a review of land use controls pertinent to water quality, not as a list of land use controls which all communities must have. This has been clarified in the Table . Land use guidelines and control measures pertinent to lakes have been developed and are part of the recommended management program.. (See Chapter D, Section 17.0(2), and Table D-I5). 5.C.5 This institutional question is reviewed in Section 2k. 1 of Chapter D and in the expanded Chapter K (Section 8.i+). In terms of specific institutional lake management mechanisms, they should be allowed to evolve at the local level, if they are to be locally accepted. The management structure will vary, depending largely upon the measures followed for each lake. 5.D.I Recommendations for site specific studies have been clarified in Section 5.0 of Chapter E. 5.D.2 PCB threat to groundwater was noted in Draft Plan/EIS; see Section h.O of Chapter E. 5.D.3 Same response as k.D. above. 5.E. Comments have been addressed in Chapter J. 5. F. Target date of I983 for "fishable-swimmable" water is assumed to apply. 6. Chsinges have been made in Chapter I regarding Best Management Practices; management agencies are addressed in Section 7.0 of Chapter I. 7. A.I Management agencies for regulatory programs are discussed in Section 2.0 of Chapter K. 7. A. 2 Existing water quality management system is discussed in Section 2.0 of Chapter K. 7. A. 3 Potential management agencies are discussed in Section 2.0 of Chapter K. 7.A.U Cost adjustments have been made throughout the report. 7. A. 5 Separate listing of state/federal funding policy recommendations is provided in Section 6.2 of Chapter K. 7.B. Recommendations for changes in water quality standards were initially transmitted to the Division of Water Pollution Control in May, 1976. 11 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT AREA OFFICE BULFINCH BUILDING, IS NEW CHARDON STREET BOSTON, MASSACHUSETTS 021 U '''tol-o^:^.1^J^\\Zi^^^^^^^^ . APR 1 8 1978 "'•^^ "^^^ 1.1SE William H. Adams, Jr., Regional Administrator U.S. Environmental Protection Agency Environment fill and Economic Impact Office J.P.K. Federal Building, ?vm 2003 Boston, I-Iassachusetts 02203 'DECEIVED Attn: Sobert E. Kendoza otHKSHlP.E CJi'jl'i'K Bear Mr. Adams: The Braf t EIS for the Berfcshire County Regional Planning Comm- ission Section 208 Vater Quality Management Plan has been re- viewed by the Boston Area Office of HUB. This agency concurs that a water management plan for all of the communities in this Region will result in preserving not oi;ily the quality of the ground and surface waters, but also the future sources of water for the area. In reviewing the BEIS this office finds no conflicts with HUB objectives. Thank you for the opportunity to review and comment on the Section 208 Plan for the BCHPC. Acting Area Office Birector 12 DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION APR 1 2 1978 NEW ENGLAND REGION 12 NEW ENGLAND EXECUTIVE PARK BURLINGTON, MASS. 01803 Tele: (617) 273-7321 Mr, William L. Kormanik, Chairman Berkshire County Regional Planning Commission 10 Fenn Street Pettsfield, MA 02102 Dear Mr. Kormanik: We have reviewed the Water Quality Management Plan for the Upper Housatonic River Draft Plan/ Environmental Impact Statement, December 1977, and are concerned with the indirect effect of the extension of sewer service west of the Pittsfield Airport. While a decline of population is indicated, its redistribution is not p recluded . Extension of sewer service west "of tFe Pittsfield Airport could encourage residential development incompatible with airport oper- ation. The Draft Plan discusses land-use but does not specify a par- ticular use for this area. Proper zoning prior to completion of this project to prevent incompatible land use near the airport is strongly recommended . Thank you for the opportunity to assess the effect of the Draft Plan on aviation interests. Sincerely, 'S.KDmm W. STONE Chief, Planning and Appraisal Staff keCEIVED APR 18 1978 BEEX2: Ifc CSONTY RESPONSE : Sewer service west of the Pittsfield Airport was constructed in the mid-1960' s. However, we share your concern for potential residential development which would be incompatible with airport operation, and believe your comments are well taJcen. Also, this area has been under study hy the Pittsfield Planning Board. 13 United States Department of Agriculture Forest Service northeastern area, state and private forestry P.O. AND Federal Bldg., 80 Daniel Street Portsmouth, n.H. D3BD1 (603) 436-7720 Ext. 765 3580 May 23, 1978 Berkshire County Regional Planning Commission 10 Fenn Street Pittsfield, Massachusetts 01201 Gentlemen : RECEIVED ''^Y 24 1978 BERKSHIRE COUNTY mmki ?imm commission I wish to comment on two aspects of your Water Quality Management Plan for the Upper Housatonic River Draft Plan/Environmental Impact Statement. First, the plan cites tree leaves as being a non-point pollution problem. Leaves would be a problem where they accumulate on paved or other impermeable surfaces. Within natural forest areas, leaf litter would be incorporated in the soil humus and improve or maintain infiltration of water into the soil. Second, your Land Use Guidelines would discourage silvi- culture on slopes greater than 15 percent. This finding is not consistent with National Standards for Best Management Practices for Silviculture, Also, the Guidelines for Silvi- culture are quite different than those for construction activities. I would not lump the two together. I would suggest that you work more closely with the Massa- chusetts State Forester, particularly since it appears your Guidelines will adversely affect the management and use of state forest lands. Sincerely, KENNETH /T./ J0HNSON Field Representative Area Planning Staff RESPONSE Leaf control is suggested only next to the lakeshore, not in the whole watershed. Where leaves coiad fall directly into the lake from adjoining trees, which is our concern, we are only suggesting that where trees are wanted, those with less-frequent leaf-drop (such as evergreens) he utilized. The 15 percent slope guideline is meant to indicate a potential problem area, which should be avoided if possible and, if not, that a special review and appropriate steps be made to reduce erosion and nutrient release. Ill UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE 29 Cottage Street^ P.O. Box 848, Amherst, Massachusetts 01002 Dear Mr. Hekler: Subject: INTERA - Water Quality Management Plan for the Upper Housatonic We have reviewed the Draft Water Quality Management Plan for the Upper Housatonic River and conmend you on its high quality. The analysis behind the Lake Eutrophication Control proposals is well presented and supports your conclusions. The following minor comments are offered for your consideration: 1. Page D-23, line 13 - change "Muskie" to "Musgrave"; 2. Page D-23, line 14 - change "SCS, Wishmeier" to "ARS, Wishmeier." Dr. Wishmeier was an Agricultural Research Service employee. 3. Page D-23, line 16 - change "conducted by SCS" to "computed by SCS from USGS measurements"; 4. Page D-38, line 22 - change "measured independently by SCS" to "computed by SCS from USGS measurements." Sincerely, Philip Ctiristensen Chairman USDA 208 Committee cc: Ronald Thompson RESPONSE : Corrections have been made as recommended. RECElVEftrch 1, 1978 Mr. Karl Hekler Director Berkshire County Regional WAR 3 T0;3 Planning Commission 10 Fenn Street Pittsfield, Massachusetts 01201 River Draft Plan 15 United States Department of the Interior OFFICE OF THE SECRETARY Northeast Region 15 State Street Boston, Massachusetts 02109 MAY 2 5 1978 ER-78/238 May 22, 1978 Mr. William R. Adams, Jr. Regional Administrator U.S. Environmental Protection Agency, Region I J. F. Kennedy Federal Building, Room 2003 Boston, Massachusetts 02203 Dear Mr. Adams: This is in response to your request for comments on the draft environmental statement and draft Section 208 Water Quality Management Plan for the Upper Housatonic River, Berkshire County, Massachusetts, prepared by the Berkshire County Regional Planning Commission. GENERAL COMMENTS The study makes positive strides toward achieving the man- dates of the 208 program but falls somewhat short of reach- ing the final goal. The study does not establish a schedule of priorities. Al- though certain programs receive greater emphasis than others, the final statement should include a clear outline for carrying out the plan recommendations. Incorporated in this outline should be the name of agencies presently in existence or soon to be formed, which will regulate and manage the different programs. The plan relies upon local communities to carefully zone and regulate construction practices in floodplains and lake basins. Such regulation has been inadequate in the past in protecting water quality. Greater emphasis should be given to setting zoning standards in these critical areas. Con- struction should be managed through local by-laws designed to reduce runoff and stream-bank erosion. 16 2 All of the plan recommendations will require public support to be effective. An education program should be designed to inform the public of their role in improving the water quality of the Upper Housatonic River Basin. Fish and Wildlife The study does not mention the lake and river fishery and the wildlife using the river basin. This information should be incorporated into the report along with a discussion of how the recommendations and alternatives will impact on these natural resources, both positively and negatively. This is especially important for consideration of the Woods Pond alternative. Wetlands Wetlands play a significant role in maintaining water quality as well as providing habitat, aesthetic values, floodplain protection, and low-flow augmentation. A cross the country :— a. nP»tJ^^Far^•^^•^^•e5 ^^ye. bg>ir>g Hpsj £m^^ , _ iiqi r>g ^JP^^flnf^g tnr-"Tprf-T_ ajry pue^Ltmeot. This report remains vague in its treatment of wetlands. In view of their significance for water quality protection, the study should be expanded to include a section dealing with wetlands. Surface-water resources Agriculture accounts for a significant input of nutrients and coliform to the river system through the use of fertili- zers and from runoff of manure in livestock feeding areas. The statement reviews alternatives for reducing this input in a very cursory manner. The Soil Conservation Service has promulgated recommendations for agricultural management which have been found to be cost effective in reducing lose of topsoil and fertilizer. These practices should be reviewed and efforts made to support them. More studies are needed to determine where significant levels of nutrients and coliform are coming from livestock areas. Even if this input is only storm related it is significant enough to require management. The study has found phosphorus to be a limiting factor in the eutrophication of most area lakes. Its reduction should significantly improve area water quality. A major source of this nutrient is from detergents used for cleaning clothing 17 3 and dishes. Several states including New York and Minnesota have enacted legislation limiting the sale of detergents containing high phosphate concentrations. This has resulted in a significant reduction of phosphates in their systems. This alternative should be examined as a potential means of attacking the phosphorus problem. Ground-water resources The Crane and Company location is suggested as one of the preferred sites for low-flow augmentation (p. G-5, G-20, G- 21) . The company would piamp 6 cf s of water from its wells tapping limestone aquifers and discharge it to the river. If data are available to indicate that the limestone aqui- fers are hydraulically completely isolated from the river and from the overlying shallow aquifers, this information should be discussed. Otherwise, the final statement should indicate whether the discharge from the wells will be moni- tored to assure that no distant or delayed hydraulic connec- tion between the cavernous limestone aquifers and the river becomes effective during the heavy p\jmping and that no recirculation will occur. Table E-6, a matrix showing the assessment of ground-water pollution threats, does not evaluate industrial activity as one of the possible sources, although elsewhere in the document the presence of PCB ' s has been traced to the General Electric Co. plant (p. J-15) . Perhaps, as suggested on page F-24, industries have controlled or will control contaminants so efficiently that no threat will exist; however, it appears that the matrix should present an evaluation as carefully con- sidered as that for every other potential source of pollutants. Mineral resources Berkshire County is one of the leading mineral producing counties in the State, producing sand and gravel, stone, and lime. According to recent records, there are 4 stone producers and 11 sand and gravel operations within the study area, many of which lie within designated recharge areas. Table E-8 indicates that mining should be limited to above water table areas and mining activities, should be located - -- away from recharge areas . The very nature of sand and - gravel deposits often requires extr'action in recharge areas. The restrictions listed in table E-8 could severely limit the mining of aggregate materials in the county. 18 -4- 'rhe plan and statement are not ^^acqusto v4.th rfgprd tc s:i5t=i.tti resources and operations. A plan which deals with development in an area over a 20-year period should discuss the impact of restricting the mining of aggregates; this plan does not discuss such impacts. Section 6 (espe- cially 6.3 of chapter E and sections 6.2, 6.4, and 6.6 of chapter K should be modified to discuss the impacts of the proposed plan on mineral resources and operations. Cultural resources Chapter K, Section 6.0, would benefit from an expanded- treatment . Only brief mention is made of impacts on historical and archeological sites. WE feel that this environmental statement should encompass, commensurate with other environmental aspects considered, a more detailed discussion of the probable existence of historical and archeological resources to be affected through physical implementaion of the proposed plan. Further, there should be a discussion of a systematic approach toward cultural resource preservation in line with the procedures found in 36 CFR Parts 63, 66, and 800 for the awareness and guidance of decision makers on this present planning action and for guidance in deciding upon physical actions to implement the plan in future years. At this point, we feel it is the Environmental Protection Agency's duty to exhibit its concern and responsibility for cultural resources pres- ervation as a part of any further support for the plan. SPECIFIC COMMENTS Specific comments on environmental impact statement Page A-1, par. 3. The rationale behind the last sentence In this para- graph is unclear. The statement should either be followed by a paragraph elucidating this point or the words "even greater" should be replaced by "significant." Page C-12, par. 7 . Chlorlnatlon is not the only answer for reduction of conform levels. Efforts should be made to attack the sources of the problem, for example by storm sewer management, and to provide sediment basins down- slope from livestock areas. Page C-13, par. 2. The sentence "These buffers appear to be useful ..." should be expanded to read "in most rural and urban areas." Page C-13, par. 3. Wetlands play a significant role in water quality management. They are our natural filtration system, trapping nutrients and sediments received from area runoff. Those nutrients that are not taken up in the system are discharged at reduced rates rather than peaked flushes which result in algal blooms. This paragraph should be altered to indicate the importance of wetlands. The Ottormark study is only one of many which have been done on wetlands, the majority of which expound upon the water qiallty benefits provided by wetlands. 19 -5- Page C-13, par. 4. Floodplain management has a significant direct impact on water quality. Construction in floodplains creates impermeable areas, increasing surface runoff and stream bank erosion. Utilization of cars, road salts, fertilizers and pesticides add to the pollutants entering the system. This problem deserves closer study. Page D-49, if 12. What institutional reasons exist which do not allow recom- mendations to be made for agricultural management? These reasons should be documented since agriculture is an important contributor of pollutants. Page D-49, #13. It is not clear why construction practices are not cost effective. Page G-8, 6(b). This alternative should receive further investigation. On- land disposal has been used in other areas such as Muskegon, Michigan, with positive results. Although local terrain may make it less feasible for a plant with the capacity of the Pittsfield facility, it should be studied as a possible solution to this problem for area plants having smaller capacities. Page G-14, if 5. The second sentence in this paragraph should discuss Alternative A, and not B. Page J-9, par. 2 . The report does not indicate where sufficient information was collected enabling the determination that coliform from livestock is less significant than coliform from humans. This information should be provided in the report. Page J-13, par. 3. Although these figures are interesting, they say little about the significance of the problem and what steps can be taken to control it. Page J-17, Table J-8. Erosion-related sources and livestock were two of the largest non-point contributors of pollution to Woods Pond, exceeding septic systems, and yet they appear not to be considered significant enough to draw recommendations. This is an important area in which the plan is lacking. Page K-13, par. 1 . The cold-water fishery remains in the Housatonic through- out the year; therefore, to change the river classification to "seasonal cold-water fishery" would be inaccurate. Perhaps temperature criteria could be established with seasonal rather than yearly ranges. Page 1-1, 2(3). Chlorination is not the only solution to these problems. Specific comments on the Supplement Page 3, par. 1. It is our understanding that relevant Federal law requires that industry meet the 1983 discharge standards. Costs are one factor in- fluencing at what level these standards are set, but it is only one factor. The Federal Water Pollution Control Act was enacted to restore and protect 20 -6- the nation's water quality and those vairable resources associated with it. At the time the law was established. Congress was aware that such efforts would be costly, but the determination was made that the long-range benefits would more than compensate for the costs. The statement appears to recommend a deviation from this mandate, one based solely on cost. If such a recom- mendation is permissible under the law then a much fuller explanation of its basis and validity appears to be obligatory. The current discussion is super- ficial at best. Page 15, par. 4 . The report states that the Lee Sewage Treatment Plant at present conditions will be reaching capacity in seven years. The extension of the sewer system to new areas will offset the reduction in flow achieved by repairing leaks in the sewer lines. Therefore, studies should be initi- ated to plan for Increasing the capacity of the facility. Page 26, Sewage Treatment . The Pittsfield Sewage Treatment Plant is a significant contributor of nutrients to the Housatonic River. Therefore, major alterations of the facility can be environmentally and economically significant. Movement of the plant's discharge downstream of Woods Pond will greatly affect the pond and the river, thus affecting the biota of the The study does not show sufficient data available, other than cost figures, on which to base such an important recommendation. Before this recom- mendation is accepted the following should be studied: (1) Effects on fish and wildlife in the pond if the discharge is moved downstream. (2) Effects on fish and wildlife in the river where the pipe would be diverted. (3) What, if any, treatment will occur in a four-mile pipe. CA) Environmental comparison between adding nutrient removal at the plant and moving the discharge downstream. Page 28, par. 4. Same comments as on Page 3, par. 1, above. Thank you for the opportunity to comment on the draft environmental state- ment and Water Quality Management Plan with Supplement. area. Sincerely, William Patterson Regional Environmental Officer 21 SOUECE OF COMMENTS U. S. Department of the Interior Office of the Secretary, William Patterson RESPONSE - Sections are the same as in the review comment letter General Comments : Schedules and priorities have "been given more attention in the Final Plan/EIS. The initial implementation program, including public participation^ is outlined in Chapter K, Section 8.0. The BCRPC agrees with the objective of this comment; for this reason it has set zoning and development standards for selected critical areas, and recommends improved construction standards for large projects. (See Section 6.k of Chapter l). Fish and Wildlife: Native fish and other aquatic life were considered in development of recommended water quality standards. See Appendix 1. Wetlajids : Several types of wetlands are recommended for protection in the report, including lakes, tributaries, groundwater and so on. "Non-critical" area wetlands were reviewed and a summary of that review is on page C-13. Although they have a relationship to water quality, the BCRPC feels it is so indirect as to not justify strong universal reg\ilatory constraints beyond the Wetlands Protection Act presently in force in Massachusetts. For example, wetlands are believed to be neither nutrient sinks or sources when viewed over an annual cycle. Nonetheless, the example in Table C-5 shows that wetland protection measures are incorporated on a case-by-case basis when appropriate. Surface Water Resources: As noted in the comment, more studies are needed to determine where significant levels of nutrients and coliform are coming from livestock areas. The real-world water quality data base for nonpoint sources should be greatly expanded before extensive agricultural management practices are implemented. We have recommended "use of non-phosphate detergents" for numerous lakes. A statewide ban was considered, but was not selected as the best approach. (See measure (h) of Section 15.1> Chapter D). Groundwater Resources : Low flow augmentation is not part of the recommended river manage- ment strategy. Groundwater pollution threats from various types of industrial activity are discussed in Table E-8. 22 Page D-U9. ^13 - A cost-effectiveness analysis of various meas\ires is provided in Table D-lk, which shows that controlling construction practices is not as cost-effective as several other measures. Page G-8. #6 (b) - This option for the Pittsfield sewage treatment plant was rejected primarily on the basis of poor cost-effectiveness smd potential adverse environmental impacts from construction of necessary effluent storage facilities. For smaller plants, no additional facilities construction is recommended. Page G-lU, ^5 - This correction has been made. Page J-9» Para 2 - Water quality data from previous studies was used as well as data collected during the planning program. Page J-I3, Para 3 - Control measures are discussed in Section 12.0 of the Chapter. Page J-1T» Table J-8 - Recommendations are provided in Section 12.3 of the Chapter. Page K-13, Para 1 - More information on water quality standards is provided in Appendix 1 of the report . Page 1-1 « 2 (3) - Coliform control is more fully discussed in Chapter H, I and J. Specific Comments on the Supplement The supplement was intended as a public informational document which briefly presents the plan's recommendations for each municipality. To summarize the voluminous technical material of the fxill report, some degree of simplification was necessary. Therefore, the supplement does not contain the full rationale and justification for each of the plan's recommendations, which can be found within the full report. 23 Mineral Resovirces : Mining is listed as a potential groundwater pollution threat because abandoned sand and gravel pits may be used as informal solid waste disposal sites. As noted in Section 5.2 of Chapter E, the protection strategies listed in Table E-8 should be considered in relation to the priority of the aquifer and the severity of the potential threat, using Table E-6 as a guide. Thus, restrictions on mining activities are not expected to be severe or widespread; impact of the plan on mining of aggregates should be minimal. Cultural Resources: The most significant construction-oriented aspects of the 208 plan are those related to wastewater treatment facilities and recommended sewer extensions. EPA regulations under the 201 construction grant program provide for project-level environmental assessments, including historical and archeological surveys. As a further step toward cultural resource preservation, future 201 grants must be consistent with the 208 plan and reviewed by the 208 agency. All potential impacts noted in Section 6.0 of Chapter K, including historical and archeological impacts, will be considered in the 201 grant review for 208 plan consistency. Specific Comments Page A-1, Para 3 - The words "even greater" refer to the fact that state/federal regulatory programs would not mandate lake eutrophi cation control or groundwater protection, yet these programs are included in the recommendations of the 208 plan. Page C-12, Para 7 - Alternatives such as storm drainage treatment were investigated and found to be of limited benefit and relatively expensive. The sources of the coliform go well beyond livestock, and downslope sediment basins thereto would resolve only a small portion of the problem. Page C-13, Para 2 - Addition made. Page C-13, Para 3 and Para k - We agree that wetlands and floodplains can be shown to have a relationship to water quality. However, we believe it is not a commanding enough relationship to dictate the establishment of development standards for these areas based on water quality considerations, per se. Instead, the management of these areas is more properly pxirsued through flood control and habitat preservation objectives. Moreover, wetlands and floodplains are well regulated in the area thro\igh the state Wetlands Protection Act and local zoning bylaws . Page D-U9 , ^12 - A clarification of "institutional reasons" has been made in the text. 2k STATE 25 DAVID STANDLEY Commissioner RECErVED "fiv 26 1978 BERKSiJRE COUNTY JDXIONAL PLANNING COMMISSIOII May 22, 1978 Mr. Rick Holmes Berkshire County Regional Planning Commission 10 Fenn Street Pittsfield, Massachusetts 01201 DEQE Synthesis: Draft Plan Dear Rick: The following state agencies have submitted comments on BCRPC Draft Water Quality Management Plan and these comments are attached for your information: No comments were received from any of the other state agencies on the draft plan distribution list. In reviewing the comments submitted to us, no major conflicts were noted between any of the agencies, * Therefore, this synthesis is intended to act as a summary of the major points contained within the comments which may require further action if individual plan elements are to receive full certification. The following points were raised and should be considered in the develop- ment of the final plan: 1) DWPC's concern regarding the lack of back-up information to justify not meeting certain federal and state goals and standards is certainly justified. While the plan recognizes that there are a number of prob- lems, (social, economic, and environmental) in meeting the 1983 goals of PL 92-500 and the states water quality standards, the recommendations seem to consistently favor least-cost alternatives with little documen- tation of the subsequent impacts. This fact has already been noted in EOEA's comments on the draft EIR. For example, on page 3 of that statement it is noted that "the full range of environmental impacts from proposals for low-flow augmentation of the Hoosatonic *The DWPC does differ slightly from DCA when it recommends the use of subdivision regulations as a tool to reduce runoff (DWPC comment #26.) DCA points out that if planning boards wish to amend subdivision regulations, the changes should be based on considerations of safety and adequate access, as opposed to being based solely on considerations of environmental soundness. DCA recommends that runoff control standards be inserted as part of a special permit process to the zoning by-law. DEQE DCA DWPC Water Supply 26 Page 2. Rick Holmes May 22, 1978 River must await more detailed future study." The statement recognizes the fact that the 208 process offers the designated planning agency the option of developing a plan based either on compliance with stand- ards or on a "realistic evaluation of costs and benefits." While your plan clearly follows the latter course, it does not always attempt to measure the impacts of this approach in a comprehensive fashion. DWPC comments 5,6,7 ,8, 9, and 11 should all be carefully considered in this light. 2) I am assuming that your recommendations regarding the Stockbridge 201 plan will be modified based on the additional information you indicated you received from the town. 3) While the DWPC is correct in noting that seasonal population projections have not been verified as requested (#13) , the impact of any potential variances to actual figures are unlikely to create any major problems for 201. Therefore, this lack of verification should not cause any problems with regard to cerif ication. A) Chapter B-4.2 - fails to note the costs of instituting a septic system management and disposal program at either the areawide or town level. 5) Chapter D should break out the costs of lakes management programs on a town-by-town basis rather than areawide (table D-16) . Methods of financing are also unclear. 6) Chapter E should also attempt to estimate the costs of implementation on a town-by-town basis since Chap. E-6.2 indicates that these costs will be a totally local expense. 7) A footnote in Chap. K, K-15 contends tbmt state funds can be used for the purpose of providing matching funds for areawide planning agencies. This statement is incorrect. The Commonwealth is providing the 25% match for 208 planning in "non-desipnated" areas because the Common- wealth has been designated as the lead planning agency in those areas. If the Commonwealth is designated as the continuing 208 planning agency for Berkshire County it will be required by law to match future federal funding. If BCRPC is designated as the continuing 208 planning agency for Berkshire County, it will likewise be required to match federal funding. 8) Both DCA and DWPC have raised an extremely valid point regarding the overall financing of actions required at the local level. The draft plan recommendations are based on the assumption that the costs of local administrative action can be matched by either the state or federal government on a 75%-25% basis. While this would obviously be desirable at the local level, current 208 regulations require that such actions be supported entirely at the local level. Therefore, the final plan should indicate that until the regulations change, towns should be prepared to carry the total financial burden of this element of the plan. 27 Page 3. Rick Holmes May 22, 1978 Furthermore, the socio-economic impacts of local financing should be clearly described. Finally, it appears that the chances of the BCRPC 208 plan being implemented are highly dependent on local acceptance of the plan. Any certification recom- mendations on the part of the Commonwealth will depend in large part on the results of the Final 208 Plan Review Questionnaire to be completed by the chief local elected officials at the end of the 30 day review period. Therefore, I urge you to do whatever you can to assist each community in the completion of the questionnaire. DT/ls CC: Bill Nuzzo, EPA Barry Jordan, EPA Dick Young, DWPC David Dronsick, DCA Paul Watson, Water Supply Attachments David Terry 28 Commissioner MEMORANDUM TO: Dave Terry FROM: Alan Van Arsdale DATE: May 15, 1978 SUBJECT: Lake Water Quality Management Sectlon- WQMP for the Upper Housatonic River I do not have any major problems with the LV/QM section of the Draft Plan of WQM developed by the BCRPC. There are the usual minor technical and typo errors, which in this case do not significantly detract from the substance, quality, or emphasis of the section. I would, however, like to comment on few points which should be brought forward. These comments concern nitrogen limitation in lakes, substituing coniferous trees for diciduous trees, and sewering entire, or portions of lake watersheds. Sewering . There is some concern expressed in the document over the potential long term affects of sewering entire or portions of lake watersheds. This is a good assessment. However I do not feel that statements in the docu- ment are sufficiently strong to promote necessary caution. Efforts to reduce current health problems or to eliminate sources of nutrient loading to the lake by sewering may increase the probability of causing future pollution prob- lems which are less susceptable to abatement efforts. It is therefore important to identify potential problems and methods of minimizing or eliminating these problems. I propose that information on the effects of development resulting from sewering on the water quality of lakes be gathered. The information should be used to develop guidelines which could be used in watersheds where sewering has been recommended . Biological substitution . Substituing coniferous trees for deciduous trees along shoreland areas of lakes in order to reduce nutrient loading and/or the build-up of sediment which supports macrophyte growth is not appropriate. Cultural sources of pollution should be abated first. Natural sources of nutrients should be addressed as a last resort, especially if major habitat perturbations are anticipated. Nitrogen Limitation . The question of nitrogen limitation in lakes is still one which is not yet completely answerable. It does appear, however, that in the absence of competing macrophy tes , nitrogen fixing bluegreen algae are selected for when nitrogen concentrations are depressed more than phosperous concentrations. The promotion of nitrogen fixing bluegreen algae may not, how- ever, be a serious problem in the lakes under consideration because a) macrophy tes 29 Page 2. Dave Terry May 15, 1978 may be sufficiently abundant to competively reduce algal productions, and b) phosperous loading to the lakes will be reduced more than nitrogen loading. Is RESPONSE : Sewering: We agree that information on the effects of development resulting from sewering on the water quality of lakes he gathered. However, it is beyond the level of specificity and resources of the 208 planning. We suggest that the most appropriate means for obtaining this data would be at the 201 facilities planning level, and its environmental impact statement. Biological Substitution: (The term "biological substitution", as used in the report, applies to the lake weeds, not the nearby trees; "Leaf Control" is the apparent subject of this comment). This comment appears to be a value judgement and there is no clear explanation as to why leaf control is "not appropriate". The BCRPC has recommended a package of measures for each lake which are oriented toward reducing the inflow or impact of nutrients in the most cost-effective manner, regardless of their source. No "major habitat perturbations are anticipated" as a result of this measure. In any case, there is no clear distinction between "cultural" and "natioral" sources of nutrients as this comment seems to indicate - if a person decides to plant a maple tree along a lake and its leaves fall in the lake is this a natural or cultural source? 0^xr leaf control recommendation would merely prefer to see an evergreen planted instead of a deciduous tree. Nitrogen Limitation: We agree that the promotion of nitrogen fixing blue-green algae may not be a serious problem, and we note that we have consistently recommended professional involvement in the lake management program which would be alert to this potential problem. 30 May 15. 197« 10 » Draft Envtrcn:.»cnti»l ItJ^nflct ?ft'itCT>cnt »vid fro^oscJ 2')' 'lat^r ^xmlity *'«aagoifirt of tli« af:»'^c>, TIi<4 rcoort ci>rt«ln» a >iOoJ ovcrvJLcv of t'li* liver* Ity of laouei v!ilcU for v'^it JH?*-^ to la do-.(i, 0?ir focint, of co'.irst?. Is utiiqfi^ 9a th« State a-c»r»cy -'.oat directly InvdvaJ vlth ti^a auhject a>>J cur r«vlaw tharafora nwro dotail orlaatodi, Fror. this point of yi?v too little backup v.ut«rlal haa bano !tm} au national avkr^vien vMch twy or ?2ay not rafioct Korkshlro County coeta. !'or« anrioua hove-vj'r is ch« lack of back up inforwatlow to Justify not reetln^ tUa 19S3 natlooal goal of rt92-500. Ottiar apacXf Ic co&Banta air* &a f»lIovst !• All c.uana ahoul.' be rocalculatt d «n^annrenent Plan for the Basin an^ therefore a broad statement rejecting the 19v^3 limits should be withheld until the exact effluent limits are determined, 7. It is a national p.oal to have, irficrever attainable by 1983, a ' vater quality which provi'Jos for the protection and propaj^atlon of fish, shell- fish, and wildlife and provides for recreation in and on thu water ' (?T,92-'5O0) . The ' 20;'" atul "iOf^Cc)' Water Quality '!aaaj.eraent Flan.3 therefore, vore Jcslpned to aiilress all cxi^tiuf: and potential sources of water pollution on the basis of what wust be done to achievo thin national 5?oal. The plan fails to accor.'plish this in rejiards to control of phosphorus in the discharges to the Housatonlc River. The "20'i" plan S'i?.p;e3t9 that phosphorus reiroval at the Tlttsflcld STP would be costly and would have questionable results since non point sources v/ould still exist, because of the uncertainties regarding the effects of phoaphorus renxjval, the plan rccorj-.ends that a pormanenc phosphorus reiwval facility not be built unless and uutll it can be demonstrated that phosphorus reiaoval can tna1;o a li^-^iflcant reduction In outrophlcatlon. Various reiaoval alternatives 'and ths costs coaparlsons should be iucluded to defend this recoT»wenr!atioa. 8* Since it has been detertrlncd that a eing below lirooda Pond should bo selectad if phosphorus renoval is requlrad at tha ; -^ Liu rotvj y f^^ n '-I t\\-\t V\n fo-^roavrt^al t'\ r^wrltft tho '-^iter 'hjnl Ity St.-folr.r 1i= tf> ral.Tr ItT colifom atnndflrdj* durlf\? storrr** vhlfn ^''^^'.nin the c pikasij on i:c';t r«-»l llaj'. coliforn durlnr. notruil perlocio, Ti.K." .St>Tf.c'a v>lti^^ ^viiLity rK>tnv!flrds (ai ct-ntlouc! a'.>ov-:') arc pr*»aently ^.■;c!..;ri » .TJ.'..tf: >i.-« Lao. vitc.rs vrill Vie raquiro.1 to provj ii* for tlip • rctrcLlon an ', •'rot n^' ntior of fliih, o'lallf i '5!\ , v-'uo.tl'* llfo .in * t.»il<«Hv<« txGll ca prl'. u-rv ci^itnct rccretit .i<*'n. To n.noc vitilnf Ion-; In th'^ Ciiliinrvi criteria rroul'l nof on^y rctjulrf a r.'u;u;c In t!io i.',-ro>lG"> th«^ b{;co:;u!»r? oi^c of provinfi t\\at f-ni'imlni t'tc^ nnr lntx^l vot«r qU'tilltv ; oal un«.s Ik not aCtainahle. rrospntly, this c?*". only Ho don-^ ! v provin? t!»e us© caviiot be attained because tiio imposition of controla aHove or in addition to tha technoloRy - based ritquiretpents of Best Available Technology Economically Achievable and B<%ot Practicable Wnato- v-jtcr rcnft'^nt '. .•'-c'laolo'ry ^'ouJ-I V.r' TVi\r,iA--i ,) v! ".>i.tl<.' rr^.-suLt Ip. '\ aubstantial ani vic>3proad advurHo Pconc::>ir .in ' '5oc?.il lr';i.Tct. 10, The Lakf» V7atcr Quality lanacorKjut j;« for study Inkce in the reKlon. Tho forrjulation and irplet«ent itloa oC pr^ctlcnl lanO isc r;itnnp,av,iont practices (lon.c- term iv.caMure) , coupl'^':' with r.echanical hnrvesLinr. of ujidcnirablo alantB (short-term neaaurc) in selected sections of so2ie lakes ai.p<»arc to bo a nost realistic approach towards restoring, t^c^ rccroatio:\al quollty of aor.w; of the watarbodics. Tha ecological implications urisin}^ from the substitution of Chara in place of other so-called 'nul«nac« ' aquatic plants should be further inves titrated, possibly througli laboratory and small scale field experiments. 33 'My 15. 1978 pagtt A 11* Rccoiranftaded control prograias for the region's non-point problems ara gnnsrally s«dr«d toward the laast cost altemativo rather than the uo8t cost affectlvQ solution. A looro cotnplatc discussion of the various feasible stratoAies and the asaociatad costs shoiild be included In the report. The use of "^.ood housekeftpln^" practices and progratns as suggested nay prove to be the tivoat cost effective, however, to prove this, loore has to be dona than simply stato that other alternatives are very expensive cotnpared to the benefits cained. One example Is the recofflmsndatlon to Accept violations of colifom standards based on the fact the area*s re3lr»ta are V7llli7>^ to aacraflce swlTrcino; la tli<» river durlnr an«1 lnK->Gdl.itoly after rstorn; events. Vloltttiono of the ccllform standirda not only renders the waters unswlnraahle , but since collform are an Indicator organism, tiljht also have an j^dvcrsc affect on aquatic orf^anlsrr.g ( ?. f f c e t a of gwaf e Tr ca t nant riant „E£f luontg on Jlloh f Chesapeake Hcacarch Consortlun) Incorporated) thus affect it fi9':<^blllty a« vrll. A vail 1 cost effective conparlson In this case can only hul.icion projections 3;>pcar roasonaHlo, If concurred with by Iccal accnclee. 13. Knnsoa.ll population projections have not bean verified as requested, Until they are verified, the nanbers can not bo accepted In a llnltln;^ acnee. 14. The potential problans of converalon of seasonal quarters has not been ad dm 8 sod, as requested. 15. Vltillc rrowth in land uce is tabulated. It has not been mapped geographically as requested. This prevents meaningful review ol service areas, adequacy of protective wechanlsins, etc, 16. Two alternative Rrowth patterns wore to liave boon examined; one, th« result of no refTulntory cnanv^os, the second agsumln;; frowth would be prevante*^ in envlronwiftntally critical areas. If this was done, »«hat ara tho dlfforcncos between the costs of the various elcncnts of the problen? 17. Wiile the portrayal of critical areas has been Improved by the pocket ttSi?-, it is obviously erroneous to conclude that all critical areas are shown. If slopes greater than 15X are critical to the selected lakes, are they less critical to other waters. Are the drinking water recharge areas the only critical wetlands? 31+ M^y'lS, 197S pa?:c 5 13. While the tabulation of land usa controls prescntad In Table C~^ la a worthy addition, the requested data oa budgets, staffing.' and programs is not provided. 19. Chapter :) is in tiany respects the best of the report, however it falls short of bein^ lDiple5rontahle since the agency to bo raspoasiblfi is not IdeutifletU Tills leaves unansv^ered t'ae questions, do they hava lep.al authority, nonay or willingness? Costs arc not stated clearly enough for an assesssient of iT^^plementability to be cade. Methods of financing appear to have received little thought other than grants. '!''\ v"li.jpt'?r T. app^-irn to J-c s cood start but costs and Inotitutiouol i'.ipacta are not clo."^rly cct forth. -1. Land I'so nuldo.llno.3 (Table E-7) should call for rproutlnp, rdaiU?^iy Jrninaj>e to surface witers dovnstrean of the water supply intake or Irke. 22. Willie the shoi^in^i of Ir.terceptore on the pocket nnp corplles vith our provlou'j request?, the l^jvol of .itndy nnd liintl f Icntion possible in this report do not allov? Acceptance In a final or llMitinp sanse. 23. On the 9r.w«-»r service nrai delincitlons ".lapn it 1« not possible to rilf f 3rr»ntiat'i vh?t'>fr th«! ftr/i, ^/^jj. MICHAEL S DUKAKIS GOVFRNOR RECEIVED WILLIAM G FLYNN SECRETARY MAY 1^ i9T3 May 10, 1978 WMl. KMNHIG COMlfl^lOli Mr. Richard Holmes Berkshire County Regional Planning Commission 10 Fenn Street Pittsfield, Massachusetts 01201 Dear Mr. Holmes: The Department of Community Affairs has received a copy of the Berkshire County Regional Planning Commission's draft plan/environmental impact state- ment, Water Quality Management Plan for the Upper Housatonic River , and has had the opportunity to review that document. We regret the delay in our review, which delay resulted from the Department's involvement with the Federal Disaster Assistance Administration through early April. Throughout the draft plan, it is emphasized that Federal Funding programs should be altered in order to better meet the water quality needs of the Upper Housatonic River Basin. The Department shares the Berkshire County Regional Planning Commission's concern that "a substantial increase in local funding may be required for implementation" of water quality measures and that "for those measures where state/federal aid is less [than] certain... the necessity for substantial local financing may be a major obstacle to implementation." Because Federal funding programs may not be altered, as the Planning Commission desires, we were disappointed that the report did not indicate the projected impact of its various proposals upon local tax rates in the 208 area. In addition, it is not clear what (if any) proportion of the costs of wastewater treatment will be borne by industrial pollutors directly through user charges. Wg feel documentation of this type would be useful to local officials in the 208 area and could assist the Planning Commission in its efforts to obtain the grant flexibility it desires. In its review of materials prepared by the State's 208 agencies, the Department has been concerned that the adoption of many of the land use controls for improving water quality discussed in those reports may make it more difficult to construct low and moderate income housing in Massachusetts . Because it is not clear what specific land use controls are being prepared for specific areas in the Berkshire 208 area, it is possible that communities might opt for the most stringent controls, in order to insure that there be no water quality problems anywhere within their boundaries. An Equal Opportunity Employer U3 -2- Therefore, we were pleased to note the Planning Comnission 's stated policy "not to advocate widespread application of land use controls when their effect on water quality can be demonstrated to be quantitatively inconsequential." We feel that this is especially significant, for such controls could be implemented by communities more inexpensively than could most other aspects of the water quality program outlined in the Berkshire County document. DCA wishes to em- phasize that the State's 208 agencies must recognize the relationship between land use controls and housing opportunities and must integrate their 208 proposals with their other policies and objectives as planning agencies. In this regard, we would like to note that the Planning Commission's report seems to focus pri- marily on corrective measures and/or does not give adequate attention to planning for future housing and related activities. For instance, the "minimum land use guidelines for future development near lakes" (Table D-15) rely entirely on density and setbacks, but do not consider whether a required 200 feet setback for a house on a lake is realistic. In addition, there is no discussion of the possible use of performance standards. With regard to one specific regulatory technique discussed in the Upper Housatonic River draft plan, we wish to emphasize that at present the State's Municipal Planning and Subdivision Legislation gives planning boards no expressed authorization to require environmental impact statements on new developments. It must be recognized that if planning boards are to amend subdivision controls in order to maintain water quality, those amendments must be based upon considerations of safety and adequate access, as opposed to being based solely upon considerations of environmental soundness. Further, we feel that a community does not have the authority to adopt a general by-law so as to require Environmental Impact Statements. Such a by-law would constitute zoning (see Chapter 40A, Section 1, definition of zoning) and, therefore, requires adoption in accordance with Chapter 40A, Section 5. - Also, such statements would have to be information that is requried during the special permit process. Finally, the Department is in agreement with the Planning Commission's recommendation that "recurring" inspections be a part of the region's septic system management program (however, a more exact description than "recurring" would be useful). The Department recognizes the importance of an on-going program and hopes that our recently printed report. Managing Seasonal Neigh- borhoods in Transition , will be of use to the Commission's 208 staff. Sincerely, cc: Robert E. Mendoza, EPA David Terry, DEQE William Hicks, MEPA Jerry Hayes, DCA Wayne Sherwood, DCA Administrator Division of Community Services kk S OUECE OF COMMENTS Commonwealth of Massachusetts Department of Community Affairs , John P . Sawyer RESPONSE Page 1, Para 2 Tax rate impacts are now included in the report, in Tahle K-3. The impacts are derived from the 208 program annual local costs to each municipality, developed on the "basis of cxirrent federal/state cost sharing programs . Industries will pay only a small portion of the costs of future wastewater treatment improvements for the following reasons : 1. The only discharges which are recommended for improvement are the Pittsfield and Stockbridge sewage treatment plants. 2. Stockbridge has no industrial soTirces , nor is it expected to have major industries within the 20-year timeframe of the plan. 3. As noted in Section k.O of Chapter F, only minor quantities of industrial wastes are discharged into the Pittsfield sewer system. Page 1, Para 3 (See also the response to the comments from the Massachusetts Department of Public Works, Office of the Commissioner). It is true that the plan primarily recommends structural measures to correct past problems. Future growth rates are expected to be slow, and not demand the installation of many new sewer facilities as this comment seems to suggest. Only minimiom land use guidelines for certain critical areas have been recommended which the BCRPC has tried to limit with clear specifications. The BCRPC has not recommended a 200 ft. housing setback from lakes as this comment asserts, but rather a 200 ft. setback of the nearest point of a leaching field to the lake. And, the recommended development guidelines themselves incorporate performance standards . Page 2, Para 2 This point is well tak.en; local environmental impact statements which are required by the subdivision control law must relate to considerations of public safety and safe access. Page 2, Psira 3 This point is also well taken; it can be a matter of legitmate debate as to whether local bylaws requiring environmental impact state- ments must be part of the local zoning bylaw. U5 It should be noted that the 208 plan does not make a priority out of either of the above two environmental review techniques which were listed only as potential land use controls. Page 2, Para U Description of the recommended inspection program has been included in the expanded Section 3.0 of Chapter F, Septic System Mnnngement and Septage Disposal. U6 May 2, 1978 ATTN: John F. Kennedy Federal Building Room 2003 Boston, Massachusetts 02203 U. S. Environmental Protection Agency Environmental and Economic Impact Office Robert E. Mendoza Dear Mr. Mendoza: We have completed a review of the Draft Plan/Environmental Impact Statement Water Quality Management Plan for- the Upper Housatonic River produced by the Berkshire County Regional Planning Commission (BCRPC) and the following comments are provided. It is assumed that this report is consistent with the approved Project Control Plan and that the land use and growth elements of the analysis are consistent with Massachusetts Chapter 807 growth policy statements . In making these assxamptions the Department expects com- patibility of land use and growth data and analyses and other aspects of the 208 Study with the same elements of the concurrent regional transportation planning study funded by the Department in a working partnership with the BCRPC. The Department recognizes the BCRPC as the agency responsible for all functional planning in the region and in this regard the BCRPC is f\inded to assure the level of coordination necessary to make transportation plans and programs compatible with other functional planning activities as elements of the comprehensive regional plan. It is on the basis described above that the statement in Chapter C, entitled Growth and Land Use , is accepted. This statement indicates that, though the regional transportation study began later than was expected resulting in the full input U7 -2- Robert Mendoza May 2, 1978 from the transportation plan not being available, preliminary data from the transportation effort has been incorporated and is considered adequate to meet the needs of the 208 plan. In other words, both the WQMP and the Transportation Plan are, or will be, based on the same comprehensive regional growth and land use assumptions and data. Finally, a concern is noted with this draft plan as an "Environmental Impact Statement" because there is no explicit statement of the impact of this plan for water quality on present and future transportation systems. It is felt that, although we assume the 208 plan to be consistent with other functional plans and systems, as an "environmental statement" it should explicitly note the impact it will have on trans- portation and other aspects of the environment — natural and manmade. Where structural solutions, which could permit or induce significant growth and land use change, are recommended there could be impacts on existing travel corridors which should be discussed. Very truly yours. PETER E. DONADIO ACTING COMMISSIONER cc : DEQE OSP BCRPC John Hurley U8 SOURCE OF COMMENTS Commonwealth of Massachusetts Department of Public Works, Peter Donadio RESPONSE It is a correct assumption that the report is consistent with local growth policy statements, as are all current BCRPC projections and functional planning programs. See also the review comment letter from the Massachusetts Office of State Planning. The water quality facilities proposed in the 208 report are not expected to have the very high growth inducing impacts often seen in other more rapidly- growing areas, where growth may gravitate to recently sewered areas and overtax other facilities such as roads. Recent sewer extensions have not been accompanied by rapid growth because the area has an almost stagnant growth rate, and the projection is for slow growth. Nowhere does the plan propose sewering as a means of accomodating growth, per se. Nearly all of the structural improvements in the plan relate to sewers and the correcting of existing problems. One exception is the Woods Pond Bypass, which if built would parallel the railroad line running south from Pitts field. In terms of non-structural recommend- ations, these relate to land use controls and usually entail the preservation of existing water quality (such as groundwater) or its restoration (such as in lakes). The BCRPC, as noted in the plan, has not recommended numerous land use controls to preserve water quality, but only those carefully selected controls which are of significant and effective benefit. Some of these land use guidelines can indirectly affect plans for other facilities. An example of this would be the salt guidelines for groundwater recharge areas and the affect these may have on high- way salting and housing construction. Neither, however, is precluded by the guidelines and in any case the "impact creating" force would not be the preservation of groundwater quality, but unsound highway maintenance and housing development. Any functional plan should follow sound environmental guidelines unless there is a critical overriding need which has been deemed necessary to meet. U9 LVPLYN F. MURPHY RECEIVED- Secretary MAY 30 1978 STAieiENT OF THE SECRETARY BERKSHIRE CmiHIT ON DRAFT ENVIRONMENTAL IMPACT REPORT The Secretary of Environmental Affairs herein issues a statement that the Draft Environmental Impact Report submitted on tlic below referenced project does adequately and properly comply with the Massachusetts General Laws, Chapter 30, Section 62 and the regulations governing the preparation of environmental impact reports. Environmental Affairs File Number: 02712 Submitted by: Department of Environmental Quality Engineering Date Received: March 15, 1978 Project Identification: 208 Wastewater Management Plan The Draft Plan/Environmental Impact Statement is herein reviewed as a state Environmental Impact Report. The comments are made with regard to consideration of environmental impacts, mitigation efforts and inclusion of alternatives as required pursuant to Cliapter 30, Section 62. This review does not include a review of the plan itself or of its adequacy for certification according to tlie established procedures of D.E.Q.E. for review- ing and certifying such plans. The Draft/En viro nmental Impa ct Statement for Water Quality Management for the Upper Housatonic River is an admirable document which seeks to combine analysis, planning and environ- mental assessment for a 9-municipality area into a single document. The task of coordinating regional planning and^ analysis with local participation and in many cases fairly well developed 201 plans presents a major challenge and undertaking. The organization of the report is excellent, although an index would have been helpful to readers not fully immersed in the study process itself. Graphical material is wey presented, although some technical material is inevitably difficult for the for the Upper Housatonic River (Berkshire County Regional Planning Commission) 50 ]ayninn. However, the text is generally well written and free of unnecessary technical jargon. As such, it meets the difficult assignment of serving as both a technical and a public document. Two issues which the report clearly addresses are the strictness of the standards established by P.L. 92-500 and the lack of sufficient capital funds at state and national levels to meet projected construction needs. The 208 process has the option of programming on the basis of strict compliance with the standards or with realistic evaluation of costs and funding availability. Since it does appear that sufficient funds for major construction programs will not be readily forthcoming in the foreseeable future, the low-funding option appears to be a reasonable and practical alternative for consideration in the Environmental Impact Report. In the matter of industrial discharges, there are also economic limitations. The report (pp. B-14 , 15) reccommends meeting 1977 guidelinns for indiistrial discharge, but not 1983 guides, on the basis of additional expense yielding only very minor improvements to river quality. This conclusion suggests that the law of diminishing returns is applicable to the 20B process. Would it be possible to develop a table or figure showing the trends in historical water quality over recent decades indicating recent year expenditures and improvements in water quality, including the projected 1977/1983 quality and cost information? The planning judgements which were considered use- ful in optimizing the trade-off of environmental improvement and cost would also be useful in evaluating the environmental impacts and mitigating measures proposed for the alternate programs. Because P.L. 92-500 concentrated on water quality issues, strict adherance to P.L. 92-500 may invlove some detrimental impacts on other aspects of the environment. To this extent, the EIR must, as an environmental planning document, consider a balancing of issues: the multiple dimensions of the environment, matters of energy, water supply, cost, construction vs. operation- al impacts, etc. The report is correct in addressing all environ- mental impacts associated with meeting the strict legal requirements. The complexity of choice is particularly evident when a proposed improvement to water quality will result in changes to the natural landscape, aesthetic modifications, and construction impacts. Because the report is primary a 208 plan, there is an understand- able emphasis on water quality issues. The 208 plan is commendable for seeking to take a now look at the water quality problem and respond to local concerns, and especially for the emphasis on addressing lake eutrophicntion, oven though there are no state or federal mandates to develop such plans. The high priority assigned to lake management Involves considerable courage. Improved manufacturing techniques and improvements to sewage treatment plants can assist fast flowing rivers towards rapid restoration of water quality, but the water quality of our lakes and the steady trends towards eutrophication are frequently (2) 51 more difficult to control. Human lifestyles, septage systems and agricultural habits have accelerated certain natural trends in changing of our fresh water lakes, so that any effort to stabilize the ecological condition of the lakes requires resistance against both man-made pollution and the forces of nature . Wliile the first priority of tlie 208 plan is lake eutrophication control, only $1.3 million - - all locally funded - - out of a total $52.7 million recommended program, is direct- ly targeted for lake management. By contrast, sewering programs involve $35.8 million in funds, of which $28.1 million is eligible for federal or state assistance. Another noteworthy funding assistance imbalance occurs in the area of sludge disposal. The EIR touches on a major difficulty in developing benefit/ cost analyses, because the special nature of certain federal assistance polices tends to favor large capital projects over smaller scale management or maintenance programs. A program may be cost-effective from a narrow consideration of the local sliare. If total costs including state and federal shares are considered, a different cost-effectiveness conclusion might he reached. There is a natural tendency for local officials to perceive federal funds as "free", whereas any local funding becomes a direct burden to be imposed on local taxpayers. Therefore, benefit/cost analyses can be severely swayed by the source of the funding. The draft report clearly and properly stresses the need to correct this inequity (page A-3) through reference to the experience of federal funding for transportation, whereby new policies are being implemented to provide for operational as well as capital programs. In view of the considerable advantages capital projects now have in terms of funding, public interest, and technological glamour, the 208 plan should make a special effort to emphasize non-capital or low-capital solutions and the • management techniques necessary for their successful implementa- tion. This issue is quite significant because projects involving low-capital, maintenance or management are not only often very cost-effective but also involve minimal disruption of the natural environment. Some sections of the plan are clearly at a more detailed stage of study and analysis than are others. Issues of lake eutrophication are very well developed, but the full range of environmental impacts from proposals for low-flow augmentation of the Hoosatonic River must await more detailed future study. The report clearly lays out the basic alternatives and discusses some of the major types of impacts associated with them. The creation of LFA concepts will involve major changes in dams, impoundment areas, and natural landscape ecology. Similarly, construction of the 4-mile Woods Pond bypass sewer line would involve construction impacts and possibly longer range aesthetic and vegetation impacts along the river. Furthermore, any proposals for structural changes to the (3) 52 Hoosatonic drainnge basin or the Pittsfield STP should consider the immediate and long range goals for Woods Pond. The report properly notes (p. G-8) that in nature tliere is considerable variation in the quality and stage of eutrophication of lakes, and that eutrophication can have advantages for certain environ- mental values. Already, Woods Pond is a special area for wild- life of interest to hunters and nature enthusiasts. Clearly, such land use is not compatible with other goals for swimmable waters. It would seem reasonable not to seek to maintain all waters as a uniform quality and instead to allow variations which meet the individual needs of man and nature. The Final Report should include a clearer presentation of the relationship between 201 and 208 plans, indicating which communities have approved 201 plans and which projects are in the various stages of design or construction development (The reference on page F-41 to section 1.0 should be Section 2.0). It should also seek a clearer distinction among the types septage systems failures. If a septage system fails visibly without significant damage to the environment and if prompt remedial action is taken, the incident should be recorded as an example of a "failsafe" system. If a septage system fails::and is not observed or cleared up and if the septage wastes threaten well fields, ponds or streams, we have a case of undersirable or unsafe failure. The magnitude of the real septage failure problem should be more clearly defined. It would be useful to have a clearer recognition of the relationship of municipal sewer and water system construction to water consumption and the impacts of such water use on sewage system loading. On the other side of the ledger, the possibilities of water conservation and recycling will tend to reduce STP loadings. Special management programs could be considered for Lee, Lenox and Stockbridge for periods of heavy concentrations of summer visitors. Accelerated programs of septic system maintenance might be consid- ered, as well as more extensive use of chemical or dry toilets. Sewer systems in themselves do not solve problems: they move them from one place to another. Often such- centralization allows for systemmatic processing of wastes, while at other times numerous small problems may be combined into a large, almost unmanageable task of dealing with high volume mixed wastes. Moreover, sludge disposal problems can become quite severe, with the potential of creating extensive leachate problems in future years . The sludge disposal practices for existing and future conditions (Table F-11 and F-15) should be made parallel, with consistent units for easy comparison. There should also be a specific listing of the nature of the sludge produced (sewage; industrial; mixed) and what are the significant organic and inorganic elements and their concentrations. The problem of PCBs , heavy metals and industrial . chemicals is sufficiently complex that a separate study might be warranted. It would be most useful to the overall planning effort If the 208 plan could provide direction in terms of issues which need more extensive study, such as PCBs, heavy metal^', sludge disposal, landfill sites, and operational techniques for landfills (4) 53 to minimize water pollution. It appears that the estimate of metallic wastes is based on general literature searches (p, I-t) , so there should be more emjihasis on evaluating current Hoosatonic sampling data for trace elements. Ideally, we should like to know what are the types of waste chemicals being discharged and in what quantities. Tn regard to the special question of PCBs , there still is a need for local and regional planning efforts to identify PCB impacts and assist in evaluating the problem and identifying possible solutions. It is hoped that as a result of the numerous community meet- ings and public comments that Chapter K on implementation of a management plan can become more detailed, possibly including a work program indicating how each element of the 208 plan would be reviewed and moved on to the next stage of development and implementation, l^fhereas a full strategy for implementation involves much complexity and uncertainty, it would be most useful to identify what is the immediate next step which should be taken beyond the 208 plan for the various key elements. The management plan must also address the critical issue of enforcement and avoidance of undesirable side-effects, such as the objective of preventing "illegal connection and dumping of pollutants into storm sewers". (p.B-20). It is clear that a major goal of the 208 study has centered on tlie difficult task of seeking accord and consensus on various plans affecting the 9 municipalities. Under the circumstances, it is impossible for the 208 plan to satisfy everyone, so that inevitable compromises must be reached in order that regional acceptability of the plan can be achieved. The plan must be responsive to local preferences and goals, yet inevitably is subject to stress wlienever adjacent communities disagree over problems and solutions. There is a natural tendency to recommend plans for a town which the town officials want, rather than the possibly diffenent proposals of adjacent communities. There must be a delicate balance of respect and disagree- ment among state officials, regional planners, local officials and citizens. Just as state officials often hear direct local criticism of state policy and thereby benefit from the exchange, so sliould local officials and citizens be more extensively presented with alternatives, provided, of course, that the comparisons do not become overwhelmingly complex or confusing. The regional planning agencies and the 208 plan should be able to assist in resolving local disputes - - such as the differing approaches between Lee and Lenox to the eutrophication of Laurel Lake - - in order that regional planning can have its special significance. If there are differences between area communities on issues, it would be well to give a fair discussion (5) 3h to tlie different perspectives. Thus can regional planning assist in resolving deadlocks between communities and consequent inaction. It is the ability of the 208 planning process to take a comprehensive look at regional water quality problems (and also to serve as a possible mediating influence between stalemated communities) which serves to make the 208 process something of special value. DATE EFM/SK/jmdi (6) 55 SOUECE OF COMMENTS CommonweaLLth of Massachusetts Executive Office of Environmental Affairs, Evelyn F. Murphy RESPONSE Page 2, Para 3 An accurate historical record of expenditures and improvements in water quality was not readily available for use in this report. However, improvements in the quality of the water quality limited segment in moving from 197^ to 19TT pollutant loadings are shown in Figiire G-3- Also, the subject of costs vs. benefits for I983 industrial discharge limitations was covered in the report of the National Commission on Water Quality. This has led, in part, to modifications of these requirements in the 19TT Clean Water Act. A necessary part of futiore 208 plan updating proced\ares will be to assess the impact of the 1977 Clean Water Act on the plan as it is now written. Page 3, Para 2 The report has been modified to point out more clearly that substantial lakeshore sewering is recommended. The total costs for six lakes is over $7.7 million; these costs are counted only once, in Chapter F. However, the nutrient reduction effects of this sewering have been incorporated into the overall lake management programs defined in Chapter D. Page 3, Para h Chapter G has been modified to include the recommendation that an Environmental Impact Statement be prepared concurrently irith the detailed 201 plan for the Woods Pond effluent bypass. Page U, Para 2 Chapter F has been re-organized to more clearly present the 208/ 201 relationships. (See Section 5-0 of Chapter F.) Septic system failures have been more fully described in the expanded Section 3.0 of Chapter F, Septic System Management and Septage Disposal. Page U, Para 3 Per capita water consumption figures for 1975 and 2000 are presented in Table E-1, enabling easy computation of reduced "additional capacity" needs for municipalities that initiate widespread water conservation programs. Water conservation to improve septic system operation is now included in the recommended management program (Section 3.h of Chapter F). 56 Page U, Para k The increased waste loadings and flows to the treatment plants due to sewer extensions were factored into the projections of future loads to the river, shown in Table F-13 in the Draft Plan/EIS . Sludge disposal is given further consideration in the Final Plan/EIS, in Section k.2 of Chapter F. Page U, Psira 5 Chapter F has been re-organized and expanded to present a more coherent disc\ission of sludge disposal (Section U.2 of Chapter F) . The question of PCB's and solution of PCB problems remains largely- unknown. The Draft Plan/EIS briefly discussed PCB's in the Introduction (Section 11.0 of Chapter A), the hapter on Groundwater Protection (Section h.O of Chapter E), and in the discussion of Nonpoint Soxirces affecting the river (Section 9-0 of Chapter J). The issue of PCB's was not part of the scope of this 208 plan, and is perhaps best handled throxigh specialized state and federal programs. Page 3-, Para 2 As noted throughout the report, wet weather sanipling data is generally lacking, although a limited amo\int of this type data was collected in the 208 program. Existing Housatonic sampling data is primarily from average summer flow and low flow periods and does not provide much insight into nonpoint source problems. Page 3, Para 3 Chapter K has been expanded to include a f\ill description and analysis of water quality management agencies and institutions. Also included is an outline of the recommended initial Implementation program, with figures displaying the proposed participation of local, regional, state and federal officials. Page 3, Para k Enforcement of controls to prevent illegal connection and dxamping of pollutsints iito storm sewers is expected to be within the existing legal/institutional structure, principally the Pittsfield Public Works Department (See Section 7-1 of Chapter l). Page 3, Para 3 and Para 6 Summaries of local meetings held during the Draft Plan/EIS review period are contained within this Public Comment Appendix. A description of the way in which public participation and intergovern- mental coordination was incorporated into the planning process is provided in Appendix 2 of the Final Plan/EIS . 57 /^/y^^/-cp^/^ RECEIVED PAUL GUZZI /// MEMORANDUM JUL 13 BERKSHIRE TO: lEQE 208 Planning Staff Regional Planning Agencies FROM: Patricia L. Weslowskiy State Historic Preservation Officer DATE: July 12, 1978 RE: Final 208 Water Quality Management Plan MHC would like to take this opportunity in commenting on the Final EIS for the 208 water quality management plans to remind EPA, EEQE, and the Massachusetts Regional Planning Agencies of their responsibilities under the National Historic Preservation Act of 1966 and E011593 to protect historic resources ;^^ich mi^t be threatened from federal undertakings. This protection extends to both properties listed in and eligible for listing in the National Register of Historic Places. As the 208 plans are inplemented and construction is planned, it may be necessary to survey the area of any proposed action in order to determine if NR listed or eligible properties migjit be affected. If properties mi^t be affected, the procedures of the Advisory Council on Historic Preservation must be inplemented (36 CFR 800) in order to protect historic resources. NfiC is available to provide information on historic and archaeological properties in the state, and can help develop appropriate scopes of work for field surveys. We should also be consulted during the process of Advisory Council review. If you have any questions, please don't hesitate to call. 58 Office of the Commissioner Government ^entef, 2Soifon. ty/^ 303(e) btuin plcLiU) fLZcommzndzd pho^phon.Li!> nzmovat i^on. ti\z C-itij of^ Pitt6(^izZd. Kt tIfxaX. tijn\z we 6u.pponX.zd tkO) nzcomnzndcution iincz ouA own anaZtj6i6 indicjUzd point 4oaA.ce n.zmovaJi ^nom PiXXAt^izLd and VanbuAy [Conn.] may ijnpfiovz ii\Z zonditioYitt Iyx LafecA IWUmniah, looA. and HouAaXonic. Thz^z lakz^ pfiz^zntly expe/u.ence dznA,z atgaz bloom duAXng tkz Aumnzn. monXiu, and uoiXhouX VizatxnznX, 6Zvznzly tbniX n.zcAza.tion oppon.tunAXA.Z6. ConnQcticuX' 6 Koa^aXotUz Rivzn lia^in Plan con^eAvaXixjcIy z6Xar)aXz6 thaX li% 0($ tixz total pko^phonuud load on LaJiz LilLinonah duAing tliz 4u»ineA monXJu onXglnaXz^ iKom ^oJitadrwUiZXXJi . JluA VcpoAXm^tiX ha^ naquAAzd advanczd u}a6tz tAza.tmznX (^on thz VanbuAy tAzaXmznX ptanX pZuA pho6pliona6 n.zm\j(Ll {^OA tiiz &un\mzA oi 19 77. OuA iiitznX iA to dc,t('Amit]z Lfi tkz combinzd pko6plionu6 nQiwval {^nom Vanbuny and Plttiftizld (muiLidtyxl tAza-tjiiZiit plant and GzncAol EIzcXaXc) Mill havz a significant bznz{^lcAJit -ui}]McX on thz thnzz Hou6atonlc lakzs. Qua com)Znt6 on tliz Uppzn Hou^atonlc 20S iilatzn QualiXy h\anagmznX Plan pn.zpaAzd by tkz Eznluivinz County Rzgional Plannlyig CornnOiAlon li, ctXachzd. We uAgz and 6apponX tkz Inclusion 0|$ p(w6phonu& nzmo\}al by tixz City o{) PiXXA>ilzld. stadXzs o(^ tkz zHzcX o{^ pho6plionas n.Qjr\o\jal on tixz zuXAopklc condition o{\ tixz Hou^aXotxic Lakzi do not dQ/noMtAoXz that a bznzf^iclaJL iinjxict can bz zxpzcXzd, we Mould zxpzct that thz n.zquAAmznX fon pho6phoALi6 n.zmoval coutd be. nzldKzd in thz iuXuAz. Sack studizJi oaz schzdulzd to bz iniXijaXzd in Hay tSxijb yzan.. We Moutd likz to mkz .fwo ipzciftic cuimwuti fnujandini] (hz phutphunu/i niijno\i(it Ac/ii'(/n('c (M (lie P { tt^ftU'i'tl I )('-'( iM(. / . 7/m' nCf nu'diM'C f^o'i AvitSoiini' d/ic'id ^.f cm (lie |i/i(»A))/i(;'i((A ,'(('iM«U<((i f^iU'.U'.Uif H]>iuinvil( I'll is bil\cd ctl (tw n Miiimpdun (liiit )i/i()A)>/io'(MA ill M'lii{n(\i'il dii'iini] lln' n>inU"t mcii/liA i/oCA un I nuilnibnlc A /f|ii' |i "'''ihM'i/ to ihz Uuusiiiunic' 6 zuX^ioplxioLtion p'tubldjui. We iOLungly hzcunmiznd iha,C Ikii ^aXz TO di&duinge.. Scconddj, wc i^eet that the P itt^f^icZd ^acAtiXij nu6t be opcKoutzd duJvinQ ApnJZ and Ma«/ a-* I'JcJtf. ai> Jmtc tii^(iii(]ti SeptembM hi undon tn minhnizv tUo ddvtluiMavt c/(J 6ummeA phytuptar^Uon blooms in LakiL& LiVUnuncJi, looJi, and HoiuaXionic, VeAy tAulij ijou/u, RobcAt U. J at I ton VvLdcAo'L o{\ WareA CumpUanco, and Hazardous SubstanczA RBT/SB/ow 71 STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION State Office Building Hartford, Connecticut 06115 April 18, 1978 Mr. Thomas C. McMahon Director The Commonwealth of Massachusetts Water Resources Commission Division of Water Pollution Control 1 10 Tremont Street Boston, Massachusetts 02108 Dear Mr. McMahon: We have reviewed the November 17, 1977 draft of the Massachusetts Water Quality Standards and offer the following comnents. 1) The Connecticut Water Quality Standards classify all waters which flow to or from the Commonwealth of Massachusetts as Class A except as follows: a) the main stem of the Housatonic River which is designated Class B (note - present Class D due to PCB contamination which precludes fishing for human concumption) . b) all tributaries of the Farmington River which flow to or from the Connionweal th of Massachusetts are designated as Class AA (existing public water supply) with the exception of streams tributary to Sandy Brook and Salmon Brook which are Class A waters. c) the main stem of the Connecticut River which is designated Class B (note - present Class C due to combined sewage overflows). d) an unnamed tributary of Muddy Pond and Roseland Lake, which tributary is located in the Town of Southbridge flowing into a Connecticut public water supply and is, therefore, designated as Class AA. e) the main stem of the Quinebaug River which is designated Class B (note - present Class C due to unacceptable water quality) All discharges except minor cooling and clean water are prohibited to Class A waters. Cooling water discharges must not impare cold water fish spawning and growth. .A procedure is described in the criteria which could result in an authorization for discharge, but only as a result of reclassi- fication ,to Class B subject to meeting tlie conditions of the Connecticut antidegradation statement. The Connecticut Class A designation seems relatively consistent with the Massachusetts Class B designation provided Regulation 4.3 is applicable. It does not appear that consistency is achieved for the Scantic River (Table 28). It is, therefore, requested that Regulation 4.3 be applied to the waters of the Scantic River Basin in Massachusetts. . > 72 Mr. Thomas C. McMahon - 2 - The above request is especially important since active plans exist to use the Scantic River above the Somersville Dam for public water supply in the future. When that plan is implemented or formalized in the Connecticut Water Resources Plan, the affected portion of the Scantic River and all tributaries will be designated Class AA effectively precluding all discharge. 2) With reference to the Housatonic River, it is requested that the main stem and tributaries be designated subject to Regulation 4.5. Connecticut has demonstrated that treatment of discharges to reduce phosphorus will result / in a commensurate reduction of the eutrophic conditions experienced in [y the Housatonic lakes on the main stem of the Housatonic River in Connecticut. Therefore, we feel that dischargers to the Housatonic River system in Massachusetts should understand that phosphorus removal will probably be required in the future to improve downstream water quality. 3) Although we understand, as a result of previous correspondence, that the Commonwealth of Massachusetts does not intend to permit discharges which would flow into Connecticut public water supplies, we see no provisions in the Massachusetts Water Quality Standards which provides that such could not occur or which clearly places an applicant for a discharge permit on notice that such restrictions exist. It is, therefore, requested that appropriate revisions be incorporated in the standards to insure the continued protection of Connecticut public water supplies which originate, in part, in Massachusetts. The waters affected by the above request are identified in paragraphs 1(b), 1(d), and, in addition, that portion of the Scantic River system where water supply development is planned as discussed in the last paragraph of Section 1 above. 4) Lastly, we would like to go on record as strongly endorsing the designation of the French and Quinebaug Rivers as Class B. As you are aware, the U.S. Environmental Protection Agency and our department have documented that a minimum of Class B quality must be achieved in the Massachusetts portion of the French and Quinebaug Rivers if water quality consistent with Class B is to be achieved downstream in Connecticut. Only through the installation of advanced waste treatment facilities at Dudley and Webster can the goal of meeting the adopted water quality class be achieved. We are aware that some opposition exists to the Class B designation you propose. We feel it would be totally inappropriate for the Commonwealth of Massachusetts to fail to pursue the goal of Class B water quality. Thank you for the opportunity to comment. Very truly yours, Robert B. Taylor Director of Water Compliance RBT/am and Hazardous Substances 73 SOUBCE OF COMMENTS State of Connecticut Department of Environmental Protection, Stanley J. Pac RESPONSE The results of the recently completed 201 combined sewer study for Great Harrington have been incorporated into Chapter H of the Final Plan/ Environmental Impact Statement. The plan recommends a partial sewer separation project which will eliminate combined sewer overflows, and an urban runoff control program to reduce the remaining stormwater impact on the river. The proposed Pittsfield STP effluent by-pass of Woods Pond should not be considered as a recommendation which would seriously compound the existing eutrophication problems in the Connecticut main-stem impoundments. As pointed out in section h.O of Chapter G, control measure (5), phosphorxis removal at the Pittsfield STP is not expected to significantly affect the Connecticut impoiondments , partly due to the attenuation of phosphorus in the river by sedimentation and biological uptake. The effluent by-pass would not utilize the trapping efficiency of Woods Pond (recognized in Section 5-0 of Chapter G) , but substantial attenuation is still expected to take place in the more than 100 river miles from the effluent by-pass outfall and the Connecticut lakes . The 1975 Connecticut 303 (e) Housatonic River Basin Plan, on page l6 , states that "During the summer months, point sources in Massachusetts account for 28% of the total phosphorus load to Lake Lillinonah" . The Basin Plan apparently overlooks the nonpoint sources of phosphorus in Massachusetts, since page 71 of the Basin Plan identifies this 28% of the total load to the lake as phosphorus "from Massachusetts". Failure to consider nonpoint phosphorus soiirces in Massachusetts may have lead to a false impression of the effective- ness of Massachusetts point source phosphorus controls. Until more work is done to quantify the impact of the Pittsfield STP on the Connecticut impoundments, phosphorus removal at the Pittsfield STP should not be considered as being a significant part of the solution to the Lake Lillinonah eutrophication problem. Chapter G of the 208 plan has been expanded to note that resolution of the Pittsfield phosphorus control issue is expected to take place following analysis of the water quality data collected during the summer of 1978. Ik LOCAL 75 PUBLIC COMMENTS - STOCKBRIDGE MEETING 1. James Kiley, Chairman, Board of Selectmen - made a statement saying that the Sele_i.frien have consistently supported the wishes of the town concerning discussions of the treatment plant issue. He then read the various town votes concerning the treatment plant issue. 2. Francis Pilling, Chairman, Board of Health - read the attached state- ment from the Tri-Town Health Department 3. Joe Kruger, President, Stockbridge Bowl Association - stated sewers are needed around the Bowl for health reasons. k. Nabih Nejaime - stated that it will be difficult to enforce the manage- ment of septic tanks and that the methods described are too short term. The town has a moral obligation to the lake residents. Sewers will provide a long term solution. He suggested a similar forum for questioning the other (201 program) side of the story. Now this project will only cost 1.8 million dollars, later it could be $18 mi 1 1 ion. 5. Al Schuler - The 1.8 million dollars is only for the treatment plant, not the whole system. 6. Mary Flynn - We as lay people are unable to make a decision. The Federal and State governments have funded 2 different studies (201 & 208) which appear to be 2 sides of the same coin. We should get BCRPC and Whitman and Howard studies together, form a comprehensive plan, and investigate funding for it. There are virtues in both the 201 and 208 plans. 7. Jack Spencer, Chairman, Planning Board - asked If the Town's 1\ acre zoning district around Stockbridge Bowl be endangered by a sewer line in the area. Asked about the growth impacts for the Bowl area and for the town In general. 8. Anthony Murad, Building Inspector - stated that he Is concerned with the adequacy of the sampling and research done. Rather than spending alot of money talking to people about an impressive looking report, more money should have been spent on basic data collection. He is concerned that cursory research and personal opinions appear in the report as conclusions. Feels that the report confused the towns- people by interjecting the sewer Issue to too large an extent. Report appears to be based on skimpy information. Town wants more sound, factual information. For the price of the study - go out and get the facts. Many of the conclusions are stock answers from the shelves of the Center for the Environment and Man, Inc. Feels that the town will not go for large scale growth with or without sewers. Stated that if phosphorus from septic tanks is not a major issue, then why do we need a phosphorus control program. Stated that the nutrient totals from agricultural appears too high because there is only one source. Stated that he sees not much fact finding about actual conditions near the lake. Feels that the report is not very substantial. 76 9. Don Davis - Asked for information on the number of houses in the Stockbridge Bowl area. Stated that Beachwood is a very big trouble spot for leaking septic systems. 10. Richard Derossier, Whitman and Howard - Questioned what information had BCRPC taken from Whitman & Howard reports with respect to costs. 11. Joe Nejaime - We need long term solutions. The cheap measures are what have caused our present problems. 12. Margaret Gray - concerned about the costs to the individual homeowner. Especially hidden costs not shared by the Federal and State such as maintenance, running the treatment plant, user fees, etc. No one is telling the voters how much this all costs. 13. Terry ? - Asked about the total, local and individual homeowner cost of 208 and 201 projects. ]k. Ray Brinker - Wanted to know what guarantees there are that 208 will work. Stockbridge Is not declining in population - it's growing. All small towns "around here" needed sewers 30 years ago. 15. Mary Flynn - 208 is valuable and necessary whether or not be build sewers. It covers environmental, peripheral areas that need to be addressed. 16. James Kiley, Chairman, Board of Selectmen - Selectmen agree with many (not all) aspects of the 208 plan. But town is on a court-mandated schedule to upgrade the existing treatment plant. The design must be approved by 8/15/78. TT .Railroad Street Telephone Lee 248-2100 Ext 41 TRI-TOWN HEALTH DEPARTMENT LEE - LENOX - STOCKBRIDGE Lee, Mass., March 28 , 19 Stoekbrldge Board of Health Town Hall Stoekbrldge, MA. 01262 Gentlemen} I apologise for not being present for the Stoekbrldge Sximnary of the 208 Water Quality Plan hearing. I am mable to cancel a previous conmitment. However, I do wish the Board of Health to read this letter dtiring the meeting. As Tri-town Sanitarian I believe that the 208 study does not address nor meet the needs of Stoekbrldge for two major reasons, as follows. I. The study states that health problems have not been doctanented I must totally disagree with this statement. Not only do we have documented health problems regaixiing failing septic sys- tems but it is common occ\irrence especially in the Beachwood area of Stoekbrldge Bowl. I might add that I do not recall anyone from the Ber4cahire County Regional Planning Commission requesting an appointment with me to discuss these problems. Last year alone I recorded at least fourteen (14) health hazsirds in and around Stoekbrldge Bowl that were a direct result of the septic systems not functioning, and this Department as well as the Board of Health are aware of many more that we just have not had the time to investigate. Of the fovirteen failing systems twelve (12) of these areas were unable to meet Title 5 of the State Environ- mental Code. (Minimum Requirements for the Substirface Disposal of Sanitary Sewage) Fo\ir of the known health hazards have not yet been repaired and all of the systems that were repaired or replaced resulted in extremely high costs to the owners due mainly to the severe limitations for subsurface sewage disposal. This leads me to the second objection I have regarding the 208 study. II. The study suggests or reeonmends that septic systems near the lake be strictly managed. I am not exactly sure vdiat they mean by this statement, but I. do know that the majority of areas surround- ing Stoekbrldge Bowl have such severe limitations that a feasible plan (economic/ physical) to maintain septic systems so as not to create a health hazard is nearly impossible. To give you an idea of the costs involved, the amount that only two (2) of the Stoekbrldge Bowl residents had to pay for only replacement or repair of their subsurface sewage disposal systems" was in the vicinity of eleven thousand dollars. ($11,000.00) This does not involve periodical punn- ing of the systems as one of the installations was a holding tank and the owner must keep p\anping the tank out. These prices are not exagerated and I am s\are the owners wovild verify the estimates. More over they are not iso- lated cases, we have many cases wher« owners h^ve had to pay extreme ainounts of capital to repair or replace their sewage systems ; Again this is mainly due to the fact that there are extreme limitations and Title 5 of the State Environmental Code must be canplied with. 78 Railroad Street Telepfaeiie Lm 248-2100 Ext 41 TRI-TOWN HEALTH DEPARTMENT LEE - LENOX - STOCKBRTOGE Lee, Mass., J^ro^lJj , , 19 78 Page 2 I was also able to obtain approximate figures from one area septic tank pumping codotpany that serviced the Stockbridge Bowl area orer the laist year. The figures for 1977 for three (3) of their routine eustoBsrs that have holding tanks and only seasonal use. The cost for pxaqping only was approx- imately seven hundred dollars. ($700.00) The nomal price for pumping septic tanks is approximately forty to fifty dollars, (f^O.OO - I50.OO) for the first 5OO gallons and two and one half cents (.02 1/2) per gallon for anything over that aaioiint. Also there is an additional fee for unoovertng the tank of six to eight dollars^ ($6.00- $8.00) This oooapany services the majority of the Beechwood area of Stock- bridge Bowl and punqpt the septic tanks a minimum of one or two (1-2) times per season. I oust also question the section in the report vdiioh suggests » "the building inspector should continue to make sure septic systems ar« designed and built to eonfora with state and local environmental codes" and that "A regular Inapeetion and pumping program should be established, and failed systems should be dsalt with on a ease by case basis". Is "tills a new responsi- blllty for the building Inspector ? I was totally unaware that septic systems and the operation and Installation thereof;: were under faiar Jurisdiction. However, I will Inform them that I as representative for "the Boards of Health for the towns of Lee, Lenox and Stockbridge have assxmed and performed the responsibilities as described above. I must also assume that the Berkshire County Regional Planning Coomlsslon does not totally understand the implications of Title 5 of the State Environ- mental Code. (Mnimum Requirements for the Substirfaoe Disposal of Sanitary Sewage) I w. attaching a copy of Title 3 in case thay do not have one avaiilable. Finally I Kould be happy to meet with anyone from 'the Planning Coonlssion tibo waj be In disagreement with any of the f aets in this letter. In fact I would gladly give a guided tour to anyone that questions our present health related problems <3as to falling septic systems. The State Department of Environmental Quality Engineering out of Ao^erst should also be allowed, to comment and make recomoendations regarding this report. They too are well aware of the glaring limitations for subsurface sewa^ di8x>osal at Stockbridge Bowl. Enclosed is additional infozvatlon that I hope will be of help and in closing I strongly suggest Investigating the use of water saving devlees( toilets, showerheads»urlnala» etc.) for sewered bm well as unsewered areas. PJKtnsw PUBLIC COMMENTS - GREAT BARRINGTON MEETING V3/78 1. Charles Castronova - Chairman, Board of Selectmen - Asked about funding for sewer separation project, eligible and ineligible costs. Wanted to know if 208 plan would provide additional funds for the town. 2. John Tul ler - Stated that town's engineering consultants recommended the opposite from the 208 study regarding septage disposal. The plant could not handle the wastes from other communities. Constructing additional facilities at the site would be very diffficult due to limited land area and possible neighborhood impacts. He then described the current septage disposal system in Southern Berkshire County (hauling and disposal in Connecticut) and asked what other septage disposal options had been investigated. 7 3. — • - Stated that it was very confusing to the laymen to have conflicting advice from different engineers. He said that this had happened in Stockbridge too and asked what could be done about it. k. John Mooney - The 208 study and Tighe & Bond do not appear to be that far apart about using the Great Barrington plant for septage disposal. Both agree that before it can be used as a regional facility, new construction is needed. Maybe after the sewer separation project, the plant would be better able to serve as a regional septage di sposal faci 1 i ty . 5. George Ladd - Planning Board - expressed an interest in the recommended ground- water protection guidelines. Would like more information about Section 203, mapping of aquifer recharge areas, and ways to include this in the town's zoning by-law. 80 PUBLIC COMMENTS - LENOX MEETING W78 1. George Wislocki - Berkshire Natural Resources Council - wanted to know if projects recommended by the plan would be exempt from additional environmental impact analysis. Especially concerned about the so-called Woods Pond By-pass. 2. Warren Archey - Chairman, Lenox Planning Board - asked if the loss of the natural attentuation and filtering properties of the Woods Pond area had been considered in evaluating the by-pass option. Asked about operating costs of river clean-up options and the status of the option for removing Woods Pond dam. 3. John Pignatelli - Lenox Selectmen - stated that Lenox has always taken its pollution clean-up responsibilities seriously. Believes that pollution problems can be solved and the river restored. Questioned the way in which data was collected for the study, especially for Stockbridge. k. Wayne Weatherhead - Lenox Sewer Building Committee - sludge handling costs are estimated at $300,000, not $30,000 as in the "208" report. Town's engineering report, completed 10 months ago concludes that it is not cost-effective to correct infiltration/inflow problems. Does not want the 208 plan's recommendations to correct it to show up as a requirement for the town. Also, questioned the need to spend a lot of money to do the last bit of water cleanup for a small stretch of the river (Woods Pond) . 5' -?~ Question about funding for collector sewers and 208/201 relationships. 6. George Wislocki - Woods Pond by-pass option lacks realism, improvements to the Pittsfield treatment would be better. 7. Sally Bell - Also concerned about the recreational and wildlife impacts of removing the Pittsfield treatment plant effluent from the river segment through Woods Pond. 8. Bill Enser - Lee Conservation Commission - asked about the additional treatment that would occur in the bypass pipeline. 9. George Darey - Lenox Selectmen - emphasized that land has been acquired for passive recreation along Woods Pond. He is very concerned about the environmental impacts of the bypass option, both on Woods Pond (reduced flow of water) and on downstream areas (shifting the point of effluent discharge). 81 10. Frances Paddock - President Housatonic River Watershed Association - asked how and where the pipeline construction would occur. Expressed concern about the construction impacts on the Woods Pond environment. 11. George Wislocki - Wanted to know if better management of the three existing impoundments (lakes) was considered as a way to obtain water for low flow augmentation. 12. Bill Enser - Asked about the changes in temperature gradients in Laurel Lake that would result from the proposed aeration system. 13. Edgar Hover - Mass. Division of Fisheries and Wildlife - Also concerned about possible impacts of bypass option on Woods Pond wildlife management area. No one is a greater advocate for clean water than he is, but maybe a little dirty water here and there might be a benefit in other respects. ]k. George Darey - Recreational use of Woods Pond bypass pipeline right of way would not be desirable, people like the area just the way it is now. 15- George Wislocki - agree with George Darey about the Woods Pond area, but other trunk line right of ways, especially in Pittsfield, should be made available for public use. 82 PUBLIC COMMENTS - MONTEREY MEETING 4/5/78 1. Fred Vorck - President, Lake Buel Association - asked about status of Monterey's application for harvesting equipment under Section 31^ of the Clean Waters Act and the status of the 314 program, 2. Richard Tryon - Monterey Selectmen - asked about how the aquifers on the map had been selected and if others, such as Gould Farm area, had been considered. Concerned about the possible water contamination from the town's landfill, especially PCB's. 3. Jed Lipsky - Monterey Planning Board - made a motion that the state issue a report on the PCB issue in the 208 area, and that specific data be collected in Monterey. h. Eugene O'Connell - Monterey Moderator - asked if the quarter mile or so between the landfill and the Konkapot was a safe distance in terms of PCB's, and what the cost of PCB studies might be. Also asked for more explanation of the lake drawdown technique. 5. Tony Reed - 6. Mark Mi 1 ler - 7. Margaret Vorck • 8. Fred Vorck - 9. Margaret Vorck ■ 10. Richard Tryon - Asked if it would be beneficial to clear out dead weeds and bottom muds when the lake is drawn down. Berkshire Eagle - Asked about the effects of drawdown on the fish population. Our hands are tied without state or federal help for lakes. Summer people may take drastic action, such as herbicides, to make the lake useable. The plan is wonderful, but we need funds to take corrective action, and soon. Lake association is losing patience with delays in getting solutions put into effect. Lake Buel needs a dam or some other way to control the water level because of flooding problems. An intensive letter writing campaign should be organized to inform Congressional appropriations committee about the need for lake management funding. 83 PUBLIC COMMENTS - LANESBOROUGH MEETING A/6/78 1. Ron Tinkham, Chairman, Board of Appeals - Add (to the sewer construction program) the cost of water line replacement which will be necessary as the streets are dug up to install the sewers. Asked if the Town would be better off with public ownership of the water system in terms of operation and obtaining grants. Expressed concern about the adequacy of the sewage disposal system for the Zucker Project. 2. Bert Robinson, Board of Selectmen - Questioned the septic system setbacks from lakes recommended in the plan (100' for cottages, 200' for houses.) Because of the conversion from seasonal to permanent use, one number should be applied to all dwellings. 3. Harley Phelps, Finance Committee and Chairman, Conservation Commission - The costs for harvesting appear to be only half ofthe true costs because of the problems of disposing of the harvested weeds. k. Walter Dojka, Health Inspector - Noted the decline in fishing and other adverse effects of the chemical treatment for weeds in Pontoosuc; discussed problems with sediment build up on the lake. 5. - ? - - Question about dredging benefits, costs and environmental impacts. 6. - ? - - Noted that the weed problem has developed only in the last 15-20 years, and asked about the reason for it. 7. Harley Phelps - Asked if the 208 plan reflects the 1977 Clean Water Act amendments, especially the sections dealing with authority for nonpoint source control . 8. James Darocha, Conservation Commission - Asked about biological control for weed problems, especially fish. 9. Bert Robinson - Wanted to know reasons for recent weed growth at Berry Pond, even though there have been no changes in the watershed. Felt that lake management specialists don't have all the answers, and we shouldn't go ahead with expensive control programs until we really know what's going on. 10. Ron Tinkham - Questioned the accuracy and adequacy of the aquifer recharge area mapping; the final plan should note this concern. 11. Raymond Hospot, Chairman, Finance Committee - Wanted to know what percentage of the $52 million areawide program would actually be implemented. 12. Mark Phelps, Planning Board - Wanted to know how or why the Town of Lanesborough would take action on restoration of Pontoosuc Lake when the lake is owned by someone else. 13. Norm Auger, Chairman, Board of Selectmen - Stated his concern about the continuing expense of lake management as well as the initial costs of the programs. ]k. Barbara Graham - Asked about the effects of erosion on the lake, especially from severe areas such as under the power lines near Secum Brook. Qk PUBLIC COMMENTS - PITTSFIELD MEETING 4/10/78 1. George Wislocki, Berkshire Natural Resources Council - Questioned the basic purpose of the so-called "Woods Pond effluent by-pass"; expressed concern about reducing the flow of water through Woods Pond; proposed better management of upstream impoundments (Onota Lake, Pontoosuc Lake, and Richmond Pond) to obtain water for the river during low flow conditions. Also stated that Woods Pond is acceptable as is to many environmentalists and further clean-up should be a low priority statewide. 2. Tracy Noonan - Asked about the downstream effects of the Woods Pond effluent by-pass . 3. Leo Daly, Mass. Division of Fisheries and Wildlife - Asked why the dissolved oxygen for Woods Pond is 5 mg/t when only warm water fish can live there and they require only 3 mg/t. k. Joel Gordon, Pittsfield Wastewater Treatment Plant - Asked about the additional treatment that would be required to meet water quality standards, and asked about the details of the effluent by-pass proposal. 5. George Wislocki - Spoke in favor of considering an increase in the Woods Pond dam elevation to offset the reduced flow resulting from the Pittsfield treatment plant effluent by-pass. 6. George Wislocki - Expressed concern about the Blythwood Drive sewer recommended in the 208 plan because of its potential for encouraging growth and the impacts of this additional growth on Onota Lake. 7. Al Turner, Pittsfield Planning Board Staff - Read a position statement on the Blythwood Drive sewer from the Pittsfield Planning Board. (Attached) 8. George Wislocki - Requested that the potential advantages of pressure sewers for situations like Blythwood be described in the final plan. 9. Lou Bolduc, Pittsfield Health Commissioner - Stated the Health Department's support for sewering, and clarified the City's policy for using Onota Lake as an emergency public water supply. 85 CONCERNS OF THE PLANNING BOARD ON THE SEWERING OF BLYTHEWOOD DRIVE 1. Sewering is not the most effective way of controlling the pollution or advanced aging of Onota Lake in the Blythewood Drive area. (B-4 "208") 2. Sewering of the Blythewood Drive area may actually increase the "non point' source of pollution to the lake by encouraging more development of greater densities (pg. 27 COM 1976 Red Book) (and pg . 37) 3. The report entitled. The Upper Housatonic "208" Water Quality Management Plan , Phase I, November 1976 indicates that sewering of most lake areas is the least cost effective method of phosphorous control which the report lists as the critical nutrient or pollutant of lakes. 4. The destruction of the shore line area during construction will cause erosions and siltation of the Onota Lake shore line into the lake which will reinforce the weed population. (Pg.36 Red Book) 5. Existing feasible alternatives to control phosphorous into the lake could accomplish as much as sewering at a fraction of the cost, use of non phosphorous detergents , erosion control, managing the use and disposal of manure, are examples of these alternatives , 6. Although the sewering of Blythewood Drive would eliminate any health problems in the Onota Lake area from fecal pathogenic organisms and bacteria leaking out of failing septic systems, sewering would not significantly control the flow of weed producing nutrients to the lake. 7. The "208" Phase I report and the Camp, Dresser and McKee , Inc. report both recommend the sewering of Blythewood Drive because of the possible health problems from leaking septic fields but also state that lake management techniques are needed to control weed growth. 8. The Blythewood Drive sewer depends on electric pumps that could fail mechanically or stop from a power failure in the area which would result in a possible overflow of sewage into the lake.(Pg. 35 CDM book) The latmst report of lake pollution entitled "The Upper Housatonic "208" Water Qualitg .Management Plan Phetse I Report dated November 1976 states that phosphorous is the critical nutrient for weed growth in Onota Lake. This report also states that Broaion, not septic systems as many believe is easily the principal cause of eutrophication which results in weed growth. Phosphorous supplied to the lake froa failing septic fields miat be ctmtrolled either by controlling development, by a septic system memagem&it program, or by sewering . Possible alternatives to sewering of Blythewwood Drive (Pg. B-11 '208') 1. Zoning to insure that future development is controlled to a density that the existing soil conditions can accomodate septic field. 2. uuilding permits issued only upon satisfying compliance with percolation standards and property conductor tests and a provisions for a second on site backing field t^itould the first fail. ul'ciu ring inspection of septic systems. 4. In the case of septic field failure have provisions for restrictive solutions in lieu of forced abandonment of the site. Other causes of eutrophication or weed growth (Pg. D~l "208") 1. erosion from etreas draining to Onota Lake via streams and brooks. This can be best demonstrated by the amount of weed growth in the northern part of the lake. 2. Sanitary waste from live stock ie dairy cows in the northern drainage area of Onota Lake. (Pg. 10 Red book) a. ) dedry caws produce about twenty times the sanitary waste of a human . b. ) a herd of 450 dairy cows is roughly equivelant to a town of 9000 people, 3. fertilazation of lawns and pastures . 4. domestic pets. 86 PUBLIC COMMENTS - LEE MEETING A/11/78 1. Jim Kuneman, Planning Board - Asked how the curves for dissolved oxygen in the river were developed. 2. John Herbert - Asked how the different phosphorus sources for Laurel Lake were identified. 3. Jim Kuneman - Wanted to know the reasons for a projected increase in erosion related phosphorus sources within the Laurel Lake Watershed. A. Ron Thompson, Soil Conservation Service - Advised caution in using the universal soil loss equation in calculating the amount of sediment delivered to the lake. 5. Frank Foley - Recommends sewering for Laurel Lake. 6. John Herbert - Has seen sewer pipes leading directly into the lake; most of cabins are in Lenox; and that sewage can be seen running into the lake. 7. Jim Kuneman - Questioned the calculations of effectiveness of lake manage- ment techniques, especially the septic system management program. 8. Joe Moynihan - Stated that the costs for the septic system management program are too low, based on recent costs of replacing septic systems in this area. 9. Frank Foley - Noted the 500' setback for septic systems from major water bodies in Lee. 10. Peter Scolforo, Public Works Department - Asked if the failing septic systems in Lenox had been considered in the sewering section of the pi an. 11. Bill Enser, Tri-Town Health Department - Expressed concern for the possibility of septic system failures in the future also. 12. George Wheeler, Public Works Department - The 208 plan should show sewering in the Lenox portion of the Laurel Lake watershed. 13. Frank Foley - Lenox should also adopt zoning by-law and subdivision restrictions around Laurel Lake that are similar to those adopted by Lee. ]k. Bill Murphy, Board of Selectmen - Wants to know what Lee can do to make Lenox eliminate its pollution sources that are affecting Laurel Lake. 15. Jim Kuneman - The 208 plan analyzes the lake on a regional basis (the watershed), but the implementation and management of the plan is left to the local governments. Regional implementation authority is needed. 16. Bill Enser - Spoke in favor of harvesting as a lake management technique for Laurel Lake. 87 17. Bill Powers, Chairman, Conservation Commission - Noted that the Orchard Street, Willow Creek, East Lee and South Lee sewer projects recommended in the plan are now under construction. 18. Frank Foley - Emphasized the need for regional approaches to lake management. 19. Jim Kuneman - Asked about the details of the recommended septic system management program. 20. Bill Enser - Stated that the cost for septic system management listed in the 208 plan are too low, 21. George Wheeler - Noted that the town had undertaken groundwater investigations in the Greenwater Brook aquifer and that a report would be prepared soon. 22. Jim Kuneman - Asked about the methods and inflation factors used to project future costs. 23. Bill Powers - Expressed concern about the safety of the Woods Pond effluent by-pass if there is a malfunction at the Pittsfield treatment plant. 24. George Wheeler - Pointed out that an engineering report has shown that the Lee landfill is not a threat to the Lenoxdale aquifer. The 208 plan should be changed based on the results of this study. 88 PUBLIC COMMENTS - DALTON MEETING 4/12/78 1. Fred Crane, Crane S Company - Although the recommended $6 million "Woods Pond bypass" appears to be the best of the options for the river, the money could be better spent where people will actually swim. Also, the area is an important wildlife resource in its present condition and further water quality improvements won't add much to it. (Also submitted written comments - attached.) 2. Mary Jacobsmeyer, Finance Committee - Asked if new dams proposed for flood control might have adverse effects on water quality, especially if stream flow is reduced during low flow periods. 3. Fred Crane - Does not believe that the technology now exists for Crane and Company to reduce discharges to meet the proposed federal limits for 1983. Curtailment of production appears to be the only way to meet the limit. Supports the 208 plan's findings that costs would be extremely large and benefits to the river would be extremely small. k. Tom Callahan, Board of Selectmen - Overall, very much pleased with the work done on the 208 plan. Also, wanted to know about the possibilities of funding for sewers in the Route 9 area (construction of the Wahconah Brook interceptor, from area west of Orchard Street to the Route 9 & Anthony Road intersection). 5. Cliff Green, Conservation Commission and Planning Board - Made corrections to sewer service map; existing sewered area should include: Housatonic Street from Depot Street to East Street, and the Tower Road and Sunnyside Drive area. 89 April 12, 1978 TO: Berkshire County Regional Planning Commission I would like to call your attention to an error in your report. In the references to the industrial waste from Dalton, the report states that Crane & Co. is expected to spend $1.5 million to meet the current standards. The actual conditions are that Crane & Co. has been meeting the current standards since December 1976. The evidence for this statement is in the monthly reports to EPA. Crane & Co. would appreciate the correction in this matter. F. G. Crane, Jr. 90 PUBLIC COMMENTS - HINSDALE MEETING V13/78 1. James QuMlard - Asked if the 1983 target date for sewering of Ashmere Lake and Plunkett Reservoir would mean that no work would start until I983. 2. Stephen Demski , Curran Associates - Explained the design status and funding status of the town's sewering projects. 3. Louis Carmel, Building and Health Inspector - Asked what effect the inclusion of the town's sewering projects in the 208 plan would have in terms of funding priorities. Also, asked about the effects on Woods Pond of the proposed Pittsfield treatment plant effluent by-pass, and expressed concern about the added costs to Hinsdale resulting from expensive programs such as phosphorus removal . h. Guy Weston, Plunkett Lake Association - Commented that the annual lowering of Plunkett Lake (6 '-8') has been very effective in controlling weed growth . 5. Louis Carmel - Asked for information on how the population projections were made and where within Hinsdale the growth was expected to occur. Commented that there is little developable land in Hinsdale. 6. Peter Blake, Board of Selectmen - Asked if the many dams on the river are an advantage or disadvantage in terms of oxygen in the river. 7. Winston Saville, Massachusetts Division of Fisheries and Wildlife - Wanted to know if the so-called "Woods Pond" by-pass would receive a high priority for state and federal funds. Stated that Woods Pond is an extremely important wildlife resource and environmental impacts of any activity should be carefully considered. In terms of alternatives for low flow augmentation, the planners should be aware that many potential impoundments sites are important wildlife management areas, especially the area known as the Hinsdale flats. Also, asked about the status of PCB studies. 91 liril 7, 1978 Berkskire Crunty Regional Planning C^imnisaion 10 Fenn St. Pittsfield, i.jisso 01201 RECEIVED ■ PR 10 1978 Attn: Richard Holmes: BERKSHIRE COUNn RE610HHL mmi COMMHW I wisk te wite ani l>e recorded as •ne whe disagrees and is dissap«inted in tke 208 Re?*rt and particularily tke Steckbridge Siimnary, (As presented in Public Hearing en Tuesday Varck30 th.) I am a resident •wner in the Beackvf^ed are* ef Stsekbridge Bowl, I have had a cottage there for thirty years. During this time I kave seen much grovrth and several changes. Cirrently I am President •f tke Lenstoek Association of ormers in that area. There kave been countless meetings over the years in which -we kave discussed weed control, road conditions, kealth itroblems due to leaking septic systems, etc. We kare used a variety of methods in our own area suck as weed cutting-barge system, pulling weeds by hand yrith hired divers etc. Most effective to date is tke chemical treatment, '»Te kare yet to kare successfully demonstrated tke plan of lake lowering and weed freezing, Tkis cannot ke dons due to lake controls at outlet and insufficient deptk, I know that any water tests tadcen during tke sunnier -^f 1977 were net properly done by the youtks employed etc, Kest residents agree thst it will be muck better to sup^^^rt and bear the cost of a sewerage system over the years - than to make heavy payments for annual storage and pumping of waste. The plan as presented ky your commission nans counter te the real needs of sewerage and kealtk precautions and I intend to promote as muck as possible the 201 sewerage plan. Beackwood cottage 238 Home or winter residence- 81 Appleton Ave, Pittsfield, 'ass. 01201 92 RECEIVED mmi mm rr'rr.". :i. .MISE^O^ Lenox, 01240 3 IV '78 Berkshire Co. Regional Planning Commission lOFennSt., Pittsfield, M. 01201 Attn. Richard Helms, Project rianager, DearSirs t At the Stockbridge Planning Board hearing on March 28th at Town Hall, those in attendance were asked for comments or questions at the conclusion of the presentatian. As past president, and long re-tread president of the Stockbridge Bowl Assn, owner of property on the lake, liember of the Growth Committee of Stockbridge, ^st Secre- tary of the Stockbridge Conservation Commission, and past member of the Sewer and other twwn committees, I had my hand up at the outset. It continued up until the end of the meeting, without success to seek an opporttiAmty to speak. It had been my intention to express appreciation of the new insights provided by your study and the attractive way it had been presented in printed form. I lad also waited to suggest the 201 and 208 studies seemed on parallel tracks without the real reason being given as to why, after nearly fifteen years of concern and discussions over the health problem, as distinct from the clear water of the lake issue, the town had finally strongly voted to have a serious st\ady made of the sewer problem. (At first it was limited to the Bowl, and to ikp- dating the antiquated central system. Then it was extended to include (£4endale and the Goodrich areas.) A. iify enclosed letter to the Sagle resulted after the astonish- ing discovery that contrary to the assurance I had recieved after the close of the meeting , your committee did not have. a copy of the limited written comment made by the Tri-town Sanitarian \dien he coiild not at- tend the meeting. It was read in part at the meeting by the /Chairman of the Board of Health. Maybe it had been the intention to get it later. 3. Reading the twelve page Stockbridge Siommary J^to the report since the meeting, however, I would also like to indicate that your study does not take into consideration the crowded conditions on the East side of the lake. I'lost of the summer houses — some now being winterized for year round use — and their sewer systems average well over 40 or 50 years in age. Most of the present houses and their septic systems are less than 50 feet from the lake edge. There are no areas around the lake edge for the suggested future developments. At high water each year, all the septic sy stems in the thickly buil^ Beachwood area in the South-east corner of the Lake, next the town bathing beach, are apt to be vinderwater. C. Our Stockbridge Bowl Association board members spent a great 93 - 2 - deal of time, some ten or fifteen years ago studying the weed control question. Records of the Association show that the harvesting plan which you advocate^ was considered among other p|ans at great Length, We found, as in the case of juake 3ueL where it had been tried, that that system was completely inadequate, D. loxir suggestion of Lowering the Lake to freeze the weeds was aLso considered. This is simply not possible. The nature of the outlet of the lake is such that unless a channel is dug the lake can not be lowered more than a probable two feet. A ditch would also run into difficulties where the two Tennessee Gai Lines cro^ the outlet and which are just below the s\irface o^^he channel bed. Five feet would not be adequ ajA, The success of such a piian carried out at eight to ten feet woufo^e uncertain as weeds will grow at a depth to vrtiich light can penetrate through the water to the bottom, (D, 1) Incidentally the height of the lake was established by court order, as reported by Prof, i-Iiddlebrook some years back in the^jEagle, in the early twenties after a very expensive legal battle between two milionaire owners of property on the lake. This question should be gone into with some care before iny attempt is made to tamper with the lake level for any pixrpose, E, 2egng||3£g^d|£i(|jjgu^Q^r£g|^|{j^ shrubs from the lake edge and its tributaries /wnxch were reported as a major source of the neutriment problem would be impossible. So would the suggested attempt to require people to give up detergents. No wonder Anthony >lurad, property owner, past president of the 3owl Association and Town BuiLding inspector was distiirbed (Eagle mr, 29th), It is a regret to me that those who worked in bringing out your report should not have fully explored the knowledge, experience, and judgement of not only the Tri-town Sanatarians, and the Caiairmen of the Board of Health of Stockbridge, bikt of many \iho have given this problem a great deal of concern and serious study over several decades, tbst sincerely, ^ ^ ^^-^^ John lavis Hatch cc I Chairman t Board of Selectmen, Stockbridge Board of Commissioners, Berkshire County Stockbridge Bowl Associationm 9U 7 U'£i ' lijih dit n-^ '^'^J 5 RECEIVED APR =i 1973 0 c r+i K^' )7Xa(Vv (^TJ'I^I, 3MALi 64.- CdVv^ b 0.5-5" CJ^: f-a ^ p tea r 4) ^^4/^ 95 riousatcnic River PRA Notice of Intent to File fiJQ EIS q ^ ^ ; | 3CRPC 208 Water Quality Uanagemant P^*^ Sandra G. Johnson PRA County Commissioners BerlishiJ^t Ron Thompson US SCS Robert E. B^endoza US EPA Ed Bogdan Qual Snv Ping Co A. Stracuzzi Pres Cncl Ptfd F. Chichetto Jr Cncl Safsty Ptfd G. Hamilton 3CC/HRWA Kathleen Green Berk Cy Ellt g^rl Hekler BCRPc p,ul Brindle Mayor Pittsfield Martin US Corps Engrs BtOjr* ^lurphy Mass. Env Affrs C-troy Chmn Cone Com Ptfd ft^^bowicz Cncl Cons Com Ptfd ^ Poyle cpv; p^^.^ ^ 0. Conte US Rep The enclosed response is "in eff art •^^^^^^^^^^^ correlate and extend specific parts of ' the ^^sw^'^'^^^^^ issued by pr;^^ BCRPc and the media public in! ^rmntlon Corps flood study. Also included are remari^^ to «:oaf3»* ^^^^ ta^.en by interview on the BCRPC Report by Bill lluaao ^'^Sgsstion to include some provision for the b^sttsrical Lon Kordeen 1£9 Danforth Av. Pittsfield, Ma. 01201 Z July, 1978 seekers to participate. 96 PP-A Notice of Intent to File EIS 1 June 73 Sandra G. Johnson The 1 Feb. 78 City Council meeting of the whole allocatea $54,000 for a dike on Turner Av., removing ledge ana sediment from the Telelec dam upstream to above Linden St. bridge and lovvering the spillway of the Telelec dam It feet. Presumably at or subsequent to the conference with Gerald S. Doyle THAT work nov; excludes the dike at Turner Av, and increases the lowering of the spillway at Telelec. Missing from the Intent Notice is the sediment removal at ?'15,000 ELSET/'HERE on the river and the $6,000 for general work also allo- cated at the 1 Feb. 78 Council meeting. Comments : The small dams are in fact oversized catch basins that exist. They act as back up beyond the storm drain catch basins. Pittsfield is rather unique in having several of them. They are closer to the accumulation of lead, phosphorous and other pollutants from the urban roadv