The Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900

Boston, MA 02114 Charles D. Baker GOVERNOR Tel: (617) 626-1000 Karyn E. Polito Fax: (617) 626-1081 LIEUTENANT GOVERNOR http://www.mass.gov/eea Kathleen A. Theoharides SECRETARY

June 12, 2020

CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT

PROJECT NAME : Auburn Water District Interconnection with City of Worcester PROJECT MUNICIPALITY : Auburn PROJECT WATERSHED : Blackstone and Nashua EEA NUMBER : 16070 PROJECT PROPONENT : Auburn Water District DATE NOTICED IN MONITOR : April 22, 2020

Pursuant to the Massachusetts Environmental Policy Act (MEPA; M.G.L. c. 30, ss. 61- 62I) and Section 11.08 of the MEPA regulations (301 CMR 11.00), I have reviewed the Draft Environmental Impact Report (DEIR) and hereby determine that it adequately and properly complies with MEPA and its implementing regulations. The Proponent may prepare and submit for review a Final Environmental Impact Report (FEIR).

Project Description

As described in the DEIR, the project consists of an interconnection of the Auburn Water District (AWD) system to the City of Worcester (Worcester) water system. The interconnection will provide a maximum daily transfer of 750 gallons per minute (gpm) for 12 hours per day, for a total of up to 0.54 million gallons per day (mgd) or 197.1 million gallons per year. Approximately 34.1 percent of the Worcester water supply is from the Blackstone River Basin and 65.9 percent is from the Nashua River Basin. Because wastewater from Auburn is discharged into the Blackstone River Basin, the project will involve an interbasin transfer from the Nashua Basin to the Blackstone Basin of 0.36 mgd (65.9 percent of the proposed water transfer). EEA# 16070 DEIR Certificate June 12, 2020

The supplemental water supply is proposed to improve the reliability of the water system. The AWD is permitted to withdraw up to 1.37 mgd from 12 groundwater wells. The system has adequate capacity to meet the average daily demand of 1.16 mgd. However, the AWD would experience water shortages if two or more wells become inoperable during periods of high demand. Several major highways are located near the AWD wells. The roadways present potential sources of contamination from fuel spills and use of road salt, which results in sodium and chloride loading. According to the AWD, the wells have not been contaminated by a fuel spill; however, if one were to occur in this area, the AWD would have to take one or more wells off-line for several weeks while potential impacts to water quality are evaluated. Increasing levels of sodium and chloride in groundwater have forced the closure of one well and could impact others. Protection of the water supply was identified as a top priority in Auburn’s Community Resilience Building Workshop Summary of Findings (2019).

The project will include the following activities:

• Installation of approximately 450 feet (ft) of 12-inch diameter ductile iron water main from the capped end of Worcester’s water main at the municipal boundary to a proposed pressure reducing valve (PRV)/metering station on Southbridge Street in Auburn; • Construction of the above-referenced 230-square foot (sf) PRV/metering station on a parcel owned by the Massachusetts Department of Transportation (MassDOT) on Southbridge Street; • Installation of 2,650 ft of 12-inch diameter ductile iron water main from the PRV/metering station south along Southbridge Street to Sword Street; • Installation of a 200-ft section of 12-inch diameter ductile iron water main from Southbridge Street to a 10-inch diameter water main in Sword Street using pipe jacking under Kettle Brook and the railroad tracks; and • Installation of a 420-ft long, 4-inch diameter pipe in Sword Street to provide temporary water service during the construction period

All construction will occur within the rights-of-way (ROW) of Southbridge Street and Sword Street or within an existing 30-ft wide sewer easement under Kettle Brook. It is anticipated that the project will be constructed in six months starting in Fall 2020.

Project Site

The site of the proposed interconnection to the Worcester system is located in a mixed-use area near Auburn’s northern border. The PRV/metering station will occupy an approximately 1,540-sf portion of a small (less than 0.1 acres) parcel owned by MassDOT. The PRV/metering station site is located just south of the Auburn-Worcester municipal boundary and is bordered by Southbridge Street to the east, railroad tracks to the west and a commercial property to the north.

Installation of the water main under Kettle Brook will take place at the southern end of the project area on Sword Street. Wetland resource areas associated with Kettle Brook include Land Under Water (LUW), Bank and Riverfront Area. According to the Federal Emergency Management Agency’s (FEMA) Flood Insurance Rate Maps (FIRM) (No. 25027C0802E,

EEA# 16070 DEIR Certificate June 12, 2020

effective July 4, 2011), the land adjacent to Kettle Brook, including a portion of Sword Street, is located with the 100-year floodplain (Zone AE) with a Base Flood Elevation (BFE) of 488 ft NAVD 88.

According to the Natural Heritage and Endangered Species Program (NHESP), the Pine Hill Reservoir, Quinapoxit River and Asnebumskit Brook, which are components of Worcester’s water supply system, contain habitat for four Species of Special Concern, including the Common Loon (Gavia immer), Wood Turtle (Glyptemys insculpta), Brook Snaketail (Ophiogomphus asperses) and Eastern Whip-poor-will (Anstrostomus vociferous). In addition, Asnebumskit Brook and the Quinapoxet River are habitat for 14 warm and coldwater fish species, including five that are listed in the Massachusetts State Wildlife Action Plan (SWAP) submitted to the U.S. Fish and Wildlife Service in 2015. The SWAP identifies the 570 species of greatest conservation need in the Commonwealth, the 24 types of habitat that support these species, and the actions necessary to conserve them.

Environmental Impacts and Mitigation

The project involves an interbasin transfer of water from the Nashua River Basin to the Blackstone River watershed in which the Town is located. Direct environmental impacts are primarily associated with the construction period, including installation of water mains, pipe jacking beneath Kettle Brook and a limited amount of land alteration associated with construction of the PRV/metering station. The transfer of water from Worcester’s system will support AWD’s ability to maintain a safe and reliable drinking water supply. The project will minimize impacts to wetland resource areas by jacking the water main under Kettle Brook and includes construction-period mitigation measures to minimize sedimentation and erosion and dust and noise impacts. In accordance with the Scope below, potential impacts to rare species will be analyzed in the FEIR.

Jurisdiction and Permitting The project is subject to a mandatory EIR pursuant to 301 CMR 1 l.03(4)(a)(2) of the MEPA regulations because it requires Agency Actions and involves a New interbasin transfer of water of 1,000,000 or more gpd or any amount determined to be significant by the Water Resources Commission (WRC). It requires approval in accordance with the Interbasin Transfer Act (ITA) (M.G.L. c.21 ss. 8B-D; 313 CMR 4.00) from the WRC, Approval of Distribution System Modifications for more than 3,300 People from the Massachusetts Department of Environmental Protection (MassDEP) and a Non-Vehicular Access Permit and an easement from MassDOT. The project may require a Conservation and Management Permit (CMP) from NHESP. It is subject to the MEPA Greenhouse Gas (GHG) Emissions Policy and Protocol (GHG Policy).

The project will require an Order of Conditions from the Auburn Conservation Commission or, in the case of an appeal, a Superseding Order of Conditions from MassDEP.

The Proponent has received Financial Assistance from MassDEP through the Water Management Act (WMA) grant program and the project requires an easement from MassDOT for the key portion of the project site required for construction of the PRV/metering station.

EEA# 16070 DEIR Certificate June 12, 2020

Therefore, MEPA jurisdiction is broad in scope and extends to all aspects of the project that may cause Damage to the Environment, as defined in the MEPA regulations.

Review of the DEIR

The DEIR was generally responsive to the Scope included in the Certificate on the ENF. It described existing conditions and provided an updated description and plans of the project. The DEIR included an expanded alternatives analysis and identified the project’s impacts and proposed mitigation measures. It provided information requested by the WRC regarding the condition and operation of the AWD and Worcester water supplies, expected conditions under which supplemental water may be needed, stream flow conditions and water conservation measures. The DEIR provided a Response to Comments and Draft Section 61 Findings.

Alternative Analysis

The DEIR included an expanded alternatives analysis. In addition to reviewing the No Action, Church Street Replacement Wells and Silver Street Wells alternatives identified in the ENF, the DEIR evaluated an alternative that would use an existing interconnection with Worcester’s water supply (Existing Interconnection Alternative) and reviewed other potential sources of water that would avoid an interbasin transfer (Other Sources Alternatives).

The No Action, Church Street Replacement Well and Silver Street Wells alternatives would avoid an interbasin transfer of water. The No Action Alternative would not satisfy the purpose of the project to improve the resiliency of the AWD system when wells are off-line due to maintenance activities or emergencies, and during periods of high demand. The Church Street Replacement Well Alternative would replace one of the three wells at the Church Street site, which was taken out of service due to sodium and chloride contamination from nearby roads, with a new well. A test well has been installed at the site and has undergone a preliminary series of tests. Construction of a new well would cost between $0.75 million to $0.90 million and would remain vulnerable to contamination from increased sodium and chloride in groundwater; if all three wells were to become contaminated and require treatment, this alternative would cost between $12.5 million and $13.9 million. According to the DEIR, the addition of a treatment system to remove sodium and chloride would significantly increase the cost of the alternative. The Silver Street Wells alternative would involve the construction of three wells that have already been permitted for a combined capacity of 390 gpm to offset the loss of the Church Street well. This alternative would require that the AWD purchase land within the Zone 1 water supply protection area and construct a treatment system to address high levels of manganese, low pH and potentially other contaminants. This alternative would cost between $6.2 million and $7.6 million and was rejected due to its cost and concerns regarding water quality.

The Existing Interconnection Alternative would involve construction of a permanent connection of one of two existing temporary interconnections between the AWD and Worcester’s system at Burnett Street in northwest Auburn or Washington Street in the northeastern corner of Auburn. A connection at either location would result in the same interbasin transfer, would require a PRV/metering station and would have similar construction impacts as the Preferred Alternative. According to the DEIR, Worcester’s system has adequate

EEA# 16070 DEIR Certificate June 12, 2020 flow and pressure at either location to supply AWD with a supplemental water source. Construction of a permanent interconnection at either location would cost between $725,000 and $1,020,000, which is considerably less than the cost of the Preferred Alternative. However, because of their relatively remote location, the alternative interconnections would be less efficient in providing water to AWD’s storage tanks.

The DEIR evaluated the potential for the AWD to receive supplemental water from the bordering towns of Leicester, Milbury and Oxford. Since Oxford is located within the French River Basin, the purchase of water from that source would also involve an interbasin transfer. The Other Sources Alternative would involve a connection to water supply systems in either Leicester or Millbury. Leicester is served by three water districts, one of which is entirely supplied by Worcester and the use of this source would also involve an interbasin transfer. The other two water districts in Leicester are within the Blackstone River Basin and could potentially provide water to AWD without an interbasin transfer; however, neither district has sufficient capacity to provide the necessary volume of water to AWD. Millbury receives most of its water from sources within the Blackstone River Basin, but supplements its water supply with a connection to Worcester. One of the water sources in Millbury was recently closed due to elevated levels of per- and polyfluoroalkyl substances (PFAS), which further restricts its water supply capacity. For these reasons, the Other Sources Alternative is not feasible.

The Preferred Alternative will cost $2.0 to $2.4 million for construction and approximately $260,000 to purchase water on an annual basis. The interconnection is proposed at a location within Worcester’s system that has adequate capacity and pressure to provide the water to AWD without impacting service to Worcester residents. The Preferred Alternative will provide a reliable source of clean water for the AWD.

Interbasin Transfer

The DEIR provided a detailed description of the AWD system and its operation, the need for a supplemental water supply, water usage data, and the location and condition of its water supply and wastewater discharge basins. It described the Worcester water supply, documented that adequate supply exists in the system to provide supplemental water to AWD, and reviewed potential environmental impacts associated with increased use of water from Worcester’s reservoirs.

According to the DEIR, the AWD and Worcester have discussed the details of the proposed water transfer and expect to finalize a 10-year agreement after MEPA review has concluded. The AWD will be responsible for operating, maintaining, monitoring and inspecting the interconnection. Worcester does not anticipate the need for any operational changes to its system.

AWD System

The AWD is the largest of three water service providers in Auburn and serves 75 to 80 percent of the Town’s population. The AWD system includes 4,570 connections, 70 miles of water mains, two pressure zones, three water storage tanks and 12 drinking water supply wells.

EEA# 16070 DEIR Certificate June 12, 2020

The AWD’s drinking water wells currently have sufficient capacity to provide drinking water to the residents of Auburn. However, the wells are threatened by contamination from salt and potential fuel spill associated with roadways in the vicinity of the well fields. One well was taken offline in the 1990s due to high sodium levels. Most of the remaining wells exceed MassDEP’s drinking water guideline for sodium of 20 milligrams per liter (mg/L) and three wells exceed the Secondary Maximum Contaminant Level (SCML) for chloride of 250 mg/L. According to the DEIR, AWD is concerned that two wells may need to be taken out of service if sodium and chloride levels continue to rise. The DEIR identified four wells that are particularly at risk of temporary or permanent closure due to potential fuel spills from nearby roadways. Water from seven wells is currently treated for iron, manganese, radon and/or arsenic. The supplemental water is needed to make the AWD system more resilient to potential contamination, drought conditions and increased demand.

The average day demand of the AWD system has decreased from 1.33 mgd in 2010 to an average of 1.05 mgd over the last five years; the decrease is attributable to water conservation measures and lower demand. The AWD’s unaccounted-for water (UAW), which is a measure of the system’s accounting for water pumped into its distribution system based on metering data, has increased over the last 10 years but does not exceed the 10 percent threshold identified in the WRC’s Water Conservation Standards. Over the next 15 years, projected demand in the AWD system is expected to slightly decrease from the current average of 1.05 mgd to 1.02 mgd to 1.03 mgd. According to MassDEP, a Water Needs Forecast prepared for AWD by the Department of Conservation and Recreation (DCR) in 2009 projected water usage of up to 1.28 mgd through 2029. The FEIR should address MassDEP’s comments and clarify the basis of the estimate of future water demand used in the DEIR.

Worcester Water Supply

Worcester’s water supply sources have a combined safe yield of 29.1 mgd and a permitted withdrawal of 27.86 mgd. In addition to the City of Worcester, the system provides water to portions of Holden, Paxton, Leicester, Auburn (the Elm Hill and Woodland water districts), West Boylston and Millbury. Worcester’s average day demand peaked at 22.9 mgd in 2012 and decreased to less than 21 mgd in 2018. Worcester’s average day demand is projected to increase to 22.0 mgd by the year 2035. According to MassDEP, Worcester’s WMA permit includes a baseline withdrawal volume of 9.85 mgd from the Nashua River Basin. The baseline withdrawal volume has been exceeded in recent years and requires Worcester to implement mitigation measures such as removing impervious area or improving aquatic habitat. The FEIR should address any baseline volume exceedances in Worcester’s system and identify potential mitigation measures.

Worcester’s reservoir system has a storage capacity of approximately 7.4 billion gallons and includes streams and reservoirs in Holden, Paxton, and Leicester. Seven of the eleven reservoirs are located in the Blackstone River Basin. Reservoirs located within the Nashua River Basin, including Asnebumskit Pond, Pine Hill Reservoir, Kendall Reservoir, and Quinapoxet Reservoir, provide approximately 65.9 percent of the total storage capacity. Water from these reservoirs is transferred by gravity or pumps to Kendall Reservoir, then conveyed by gravity water mains to Holden Reservoir #1, which is located in the Blackstone River Basin. According

EEA# 16070 DEIR Certificate June 12, 2020

to the DEIR, Worcester operates its system of reservoirs to maintain the reservoirs at a high capacity that exceeds demand. When the capacity of a reservoir is exceeded, water is released into either Asnebumskit Brook or the Quinapoxet River.

Streamflow Conditions

Discharges from the Nashua Basin reservoirs join at the confluence between the Quinapoxet River and Asnebumskit Brook. The DEIR included an analysis of instream flows at this location and potential impacts to instream flow resulting from the proposed interbasin transfer. Streamflows under proposed conditions were compared to three scenarios:

• Existing streamflow estimated using StreamStats Tool developed by the United States Geological Survey (USGS) and flow data from a stream gauge near the confluence; • “Natural” streamflow conditions (“unimpacted median monthly streamflow” or UMMS) based on the USGS Massachusetts Safe Yield Estimator, which reflect conditions that would be present without dams, reservoirs and other alterations in the watershed; and, • Extreme low flow estimated representing 7-day, 2-year and a 7-day, 10-year low flow scenarios.

Proposed streamflow conditions were based on the maximum withdrawal rate of the proposed transfer to AWD and a 0.41 mgd transfer to the Cherry Valley and Rochdale Water District approved in 2015. The median streamflow at the confluence of the Quinapoxet River and Asnebumskit Brook was estimated to be 26.6 cubic feet per second (cfs). Based on the maximum potential transfer rate of 1.19 cfs, the median streamflow under proposed conditions would be 25.4 cfs. The DEIR included flow exceedance curves for existing and proposed streamflows over an entire year. According to the analysis, the difference in streamflow would be negligible under high natural stream flow conditions but more significant al low flows. Under extreme low flow conditions, the project may cause an increase in the frequency of severely low streamflows of 3.3 percent, which may result in impacts to aquatic habitat. Releases from overcapacity reservoirs are expected to decrease in frequency by 0.2 percent under proposed conditions.

Rare Species

According to NHESP, rare species habitat and important fisheries resources are located upstream of the confluence of the Quinapoxet River and Asnebumskit Brook where streamflow impacts were evaluated. As detailed in the Scope, the FEIR should provide additional information to characterize streamflow upstream of the confluence under existing and proposed conditions.

Wetlands

A water main will be installed under Kettle Brook using pipe jacking to avoid impacts to the brook. A jacking pit will be excavated on one side of the brook and a receiving pit on the other side, and the pipe will be pushed from one pit to the other. Excavation of jacking pits will temporarily impact approximately 12,400 sf of Riverfront Area. According to the DEIR, the

EEA# 16070 DEIR Certificate June 12, 2020 jacking pits will be excavated in paved roadways. Riverfront Area impacted by the project will be restored upon completion of construction. According to the FIRM, a portion of the route of the water main near Sword Street is within the 100-year floodplain of Kettle Brook. The FEIR should confirm whether any part of the project will impact the and identify mitigation measures.

Climate Change

The DEIR reviewed existing and future storm and flooding conditions and described design features to improve resiliency to the effects of climate change. It provided an analysis of stationary- and mobile-source GHG emissions and identified measures to mitigate the project’s GHG impacts.

Adaptation and Resiliency

The DEIR reviewed potential risks and vulnerabilities of the project to projected climate conditions, including more frequent and longer periods of drought and more frequent and intense precipitation events. As noted above, the use of water from the Worcester system will not significantly impact the water supply under drought conditions. The project is not expected to be vulnerable to increased flooding because most of its components are underground. The section of water main under Kettle Brook will be encased in a casing that will offer further protection from high surface or groundwater levels. According to the DEIR, the PRV/metering station is not likely to be impacted by floodwaters because it is 30 ft above the current 100-year flood elevation.

Greenhouse Gas (GHG) Emissions

The project is subject to the MEPA GHG Policy, which requires project Proponents to analyze energy use and\carbon dioxide (CO2) emissions and identify measures to avoid, minimize or mitigate such emissions. During the construction period, measures to minimize GHG emissions will include limiting idling of construction vehicles and the use of heavy equipment meeting the EPA’s Tier 4 emission standards. Use of energy associated with operation of the project is limited to an electric heater and electronic controls and meters in the PRV/metering station. The heater will be used to maintain a temperature of 55 degrees Fahrenheit (F) in the PRV/metering station to prevent freezing of equipment in the winter. Small amounts of electricity will also be used to transmit data from meters and control systems. The PRV/metering station will have no energy-intensive components such as pumps or motors. According to the DEIR, Worcester will not have to add pumps or otherwise significantly change its operations or energy use to direct water to the AWD.

According to the DEIR, GHG emissions from the PRV/metering station will be minimized by using electric heat rather than propane. The DEIR included evaluations of the use of a rooftop solar photovoltaic (PV) system on the PRV/metering station or an in-line turbine to generate electricity. Due to the small size of the PRV/metering station, the maximum capacity of a rooftop PV system would be 2.6 kiloWatts (kW). This would not be sufficient to provide the estimated 12kW-hours of electricity per day needed to power the facility in the winter and would not provide a sufficient payback to offset the costs of installing and maintaining the PV system.

EEA# 16070 DEIR Certificate June 12, 2020

An in-line turbine would need to be installed in parallel with the PRV, which would require a larger building that could not be accommodated on the small parcel proposed as the site of the PRV/metering station. In addition, water is not expected to flow through the facility on a regular basis; the in-line turbine would not be generating power for long periods of time, which would not justify the cost of the system.

Construction

The DEIR identified the following construction period mitigation measures:

• Install and maintain erosion and sedimentation controls around work areas; • Revegetate disturbed areas; • Develop and implement a Traffic Management Plan detailing the use of signage, police details, detours and barricades; • Maintain access on roadways for vehicles, pedestrians and bicyclists at all times; and, • Minimize noise generated by construction activities by using mufflers and enclosures to dampen sound from generator, compressors and other equipment and limiting construction activities to daytime hours.

Conclusion

The DEIR described the project and associated environmental impacts and mitigation measures consistent with the. Scope included in the ENF Certificate. According to the WRC, the DEIR was generally responsive to the information requirements of the seven regulatory criteria outlined in the Interbasin Transfer Act regulations and additional information can be provided in the FEIR. Based on a review of the DEIR, consultation with State Agencies and a review of comment letters, I have determined that the DEIR is adequate and properly complies with MEPA and its implementing regulations. The Proponent may proceed to filing of an FEIR in accordance with the limited Scope below.

SCOPE

General

The FEIR should follow Section 11.07 of the MEPA regulations for outline and content and additional information and analyses required by this Scope. The FEIR should clearly demonstrate that the Preferred Alternative includes all feasible measures to avoid Damage to the Environment, or, to the extent it cannot be avoided, to minimize and mitigate Damage to the Environment to the maximum extent practicable.

Project Description and Permitting

The FEIR should describe any changes to the project since the filing of the DEIR. If necessary, it should include updated plans for existing and post-development conditions at a legible scale. The FEIR should identify mitigation to offset construction-period and long-term environmental impacts. It should include a list of required State permits, Financial Assistance, or

EEA# 16070 DEIR Certificate June 12, 2020 other State approvals and provide an update on the status of each of these pending actions. The FEIR should provide a brief description and analysis of applicable statutory and regulatory standards and requirements, and a description of how the project will meet those standards. The FEIR should clarify whether any part of the project will temporarily or permanently impact the 100-year floodplain and, if necessary, identify mitigation measures. As detailed below, the FEIR should include analyses requested by NHESP and identify any impacts to rare species habitat.

Interbasin Transfer

The DEIR should provide the information requested in the WRC’s comment letter, which is incorporated by reference herein. Documentation and analyses requested by the WRC includes:

• Sources of funding to maintain the AWD system, including any financial agreements with the Town of Auburn; • Explanation of the current rate structure, including how it encourages water conservation, and a review of recent rate changes; • Description of the AWD’s leak detection program; • Results of any water audit conducted by AWD on its system; • Description of the extent of metering of users within the AWD; and, • Provide further clarification about whether all water users are metered and the extent of metering within the District; and • A comprehensive water conservation plan consistent with the 2018 revisions of the Water Conservation Standards; as noted by MassDEP, the AWD has prepared much or all of the necessary information in connection with its Water Management Act (WMA) permit.

The WRC has also requested additional analysis, detailed below, of potential impacts of reduced streamflow on rare species and aquatic habitat in the Quinapoxit River, Asnebumskit Brook, and stream downstream of the Quinapoxit, Pine Hill and Kendall Reservoirs. I encourage the Proponent to consult with the WRC prior to filing the FEIR.

Rare Species

The FEIR should provide the additional streamflow analysis identified in NHESP’s comment letter, which is incorporated herein by reference. As noted above, the DEIR provided flow exceedance curves for existing and proposed streamflows over an entire year that appeared to document the project’s minimal effects on streamflow. The FEIR should include revised analyses of streamflow that compare UMMS, existing flows and proposed flows using monthly, rather than annual, statistics. In addition, the analysis of extreme low flows should include conditions form the drought of 2016 and the results should be expressed in terms of the duration of extreme low flow conditions. In addition, the streamflow analysis should be expanded to evaluate impacts upstream of the confluence of Asnebumskit Brook and the Quinapoxet River. Based on the analysis method described by NHESP, the FEIR should evaluate the impact to streamflows below Asnebumskit Reservoir and the Quinepoxet Reservoir and an exceedance curve and hydrograph should be provided separately for each reservoir.

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The analyses requested by NHESP will be used to determine whether the project will result in a Take of any state-listed rare species or impact fisheries resources in the Nashua River Basin. I recommend that the Proponent consult with NHESP prior to filing the FEIR. If the results of the analyses are sufficient for NHESP to make a preliminary determination that the project will result in a Take, the FEIR should address the performance standards for the issuance of a CMP pursuant to 321 CMR 10.23, including proposed mitigation measures.

Water Supply

As requested by MassDEP, the FEIR should provide updated information on the AWD’s permitted volumes and projected water demand and Worcester’s water withdrawals. It should identify any mitigation Worcester may be required to implement and any potential contribution by AWD.

Mitigation and Draft Section 61 Findings

The FEIR should include a separate chapter summarizing proposed mitigation measures, including GHG and construction period mitigation. This chapter should also include draft Section 61 Findings for each permit to be issued by State Agencies. The FEIR should contain clear commitments to implement these mitigation measures, estimate the individual costs of each proposed measure, identify the parties responsible for implementation, and a schedule for implementation.

Responses to Comments

The FEIR should contain a copy of this Certificate and a copy of each comment letter received. In order to ensure that the issues raised by commenters are addressed, the FEIR should include direct responses to comments to the extent that they are within MEPA jurisdiction. This directive is not intended to, and shall not be construed to, enlarge the Scope of the FEIR beyond what has been expressly identified in this certificate.

Circulation

The Proponent should circulate the FEIR to those parties who commented on the ENF and/or DEIR, to any State Agencies from which the Proponent will seek permits or approvals, and to any parties specified in section 11.16 of the MEPA regulations. Per 301 CMR 11.16(5), the Proponent may circulate copies of the EIR to commenters in CD-ROM format or by directing commenters to a project website address. However, the Proponent must make a reasonable number of hard copies available to accommodate those without convenient access to a computer and distribute these upon request on a first-come, first-served basis. The Proponent should send correspondence accompanying the CD-ROM or website address indicating that hard copies are available upon request, noting relevant comment deadlines, and appropriate addresses for submission of comments. The FEIR submitted to the MEPA office should include a digital copy

EEA# 16070 DEIR Certificate June 12, 2020 of the complete document. A copy of the FEIR should be made available for review at the Auburn and Worcester public libraries.1

June 12, 2020 ______Date Kathleen A. Theoharides

Comments received:

06/03/2020 Water Resources Commission (WRC) 06/05/2020 Worcester Department of Public Works 06/05/2020 Natural Heritage and Endangered Species Program (NHESP) 06/10/2020 Massachusetts Department of Environmental Protection (MassDEP)/Central Regional Office (CERO)

KAT/AJS/ajs

1 Requirements for hard copy distribution or mailings will be suspended during the Commonwealth’s COVID-19 response. Please consult the MEPA website for further details on interim procedures during this emergency period: https://www.mass.gov/orgs/massachusetts-environmental-policy-act-office.

Charles D. Baker Kathleen A. Theoharides Governor Secretary

Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner

June 10, 2020

Secretary Kathleen A. Theoharides Executive Office of Environmental Affairs 100 Cambridge Street, 9th Floor Boston, MA 02114

Attention: MEPA Unit – Alex Strysky

Re: Draft Environmental Impact Report (DEIR) Auburn Water District Supplemental Interconnection with City of Worcester Auburn EEA #16070

Dear Secretary Theoharides:

The Massachusetts Department of Environmental Protection's (“MassDEP”) Central Regional Office has reviewed the DEIR for the proposed Auburn Water District (the “District” or the “Proponent”) Supplemental Interconnection with the City of Worcester in Auburn (the “Project”). The Proponent proposes to connect its public water supply system to the City of Worcester water supply system for a permanent supplemental interconnection to improve redundancy and increase capacity. Currently, the District’s water supply system is at risk of contamination from numerous major highways nearby. If one or more wells are taken off-line due to a spill or from excessive road salt, the remaining wells may not provide sufficient water supply or pressure to the system.

The Project includes the installation of 3,400 linear feet of underground water main along Southbridge Street from the Auburn/Worcester line to Sword Street and the construction of an above ground Pressure Relief Valve (PRV) water metering facility. The Project also includes an interbasin transfer because the City of Worcester draws its water from both the Blackstone and Nashua Basins, while the AWD is located almost entirely in the Blackstone Basin.

This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751. TTY# MassRelay Service 1-800-439-2370 MassDEP Website: www.mass.gov/dep Printed on Recycled Paper

MassDEP Comments – EEA# 16070 Page 2 of 4

The Project will cause temporary construction impacts to 20,200 square feet (sf) of buffer zone to Bordering Vegetated Wetland (BVW) and 12,400 sf of Riverfront Area (RA), and will permanently alter seven cubic yards (cy) of Land Under Waterbodies and Waterways (LUWW).

This Project is under MEPA review because it meets or exceeds the following review thresholds:

• 11.03 (4)(a)(2) – New interbasin transfer of water of 1,000,000 or more gallons per day (gpd) or any amount determined significant by the Water Resources Commission.

The Project requires the following State Agency Permits:

• MassDEP - Water Distribution System Modification Permit (BRP WS 32) • MassDEP- Wetlands Permit Application Notice of Intent (BRP WPA Form 3) • Massachusetts Department of Transportation - Application for Permit to Access State Highway

MassDEP offers the following comments:

Water Supply

The DEIR states that the Proponent does not have a Water Conservation Plan because its Water Management Act (WMA) Permit was not renewed. However, all WMA Permits in the Blackstone River Basin were renewed in 2010. A Water Conservation Questionnaire was submitted as part of the WMA Permit application, and the WMA Permit includes a special condition for water conservation requirements. MassDEP accepts the Questionnaire and the special condition in the Permit as a Water Conservation Plan.

The WMA Permit for the District was amended in 2012 to add the Silver Street Wells to the AWD system. The Permit volumes in Table 3-1 of the DEIR reflect the 2010 WMA Permit rather than the 2012 WMA Permit Amendment, which reduced the total authorized volume to 1.37 million gallons per day (MGD) plus a conditional 5% buffer of 0.07 MGD for a total of 1.44 MGD upon approval by MassDEP, as long as the Proponent meets certain water conservation standards. Table 3-1 should be updated to reflect the correct number of 1.44, instead of 1.52. In the description above Table 3-1, the text should be changed from “In Period 4, it increases to 1.52 mgd” to “In Period 4, it increases to 1.44 mgd." The volumes will be revised in the next permit review.

On May 21, 2009 the Massachusetts Department of Conservation and Recreation (DCR) prepared a Water Needs Forecast (WNF) for the Proponent. Using the Performance Standards of 65 Residential Gallons per Capita per Day and 10% of Unaccounted for Water, the WNF predicts water usage of up to 1.19 MGD through 2024 and 1.22 MGD (plus a 5% buffer of 0.06 MGD for a total of 1.28 MGD) through 2029. The Proponent has stated it might be able to provide DCR with a more accurate residential population number, which could significantly change the WNF. The Proponent committed to working with the Auburn Board of Health and the Auburn Assessor's Office to develop a final population served estimate to be provided to MassDEP Comments – EEA# 16070 Page 3 of 4

DCR with a request for a revised WNF. The final WMA Permit issued March 1, 2010 required that by March 1, 2014, the Proponent submit documentation in accordance with the "Policy for Developing Water Needs Forecasts for Public Water Suppliers and Communities and Methodology for Implementation.” To date, the Proponent has not provided the documentation to DCR in support of a revised WNF. The Proponent should seek a final WNF from DCR prior to finalizing the volume to purchase from Worcester.

The City of Worcester is regulated through the WMA Program to withdraw an annual average volume of 29.5 MGD. Actual withdrawals from 2016 through 2018 ranged from 20.54 to 23.56 MGD. The WMA Regulations promulgated in November 2014 include requirements for WMA Permittees to mitigate water withdrawals over a baseline volume. Worcester’s baseline volume in the Nashua River Basin is 9.85 MGD and for the total system is 24.33 MGD. Worcester’s Nashua volumes from 2016 through 2018 were 9.40 to 15.3 MGD, therefore mitigation is required. Examples of mitigation projects suitable for the WMA program are those that return developed land to an undeveloped state (e.g., removing impervious surfaces) or otherwise improve surface water habitat. Stormwater improvements that exceed standard requirements and culvert replacements that meet stream crossing standards can also be considered as mitigation for WMA. The Proponent should work with the City of Worcester to assist in developing and/or funding mitigation projects.

Worcester's volume withdrawn from the Nashua River Basin in 2016 is 15.34 MGD and not 13.1 MGD as referenced in Table 3-6. The total volume transferred from Kendall Reservoir in the Nashua River Basin was reported on Worcester's 2016 Annual Statistical Report as 5,599.63 million gallons per year or 15.34 MGD. Additionally the "Annual Water Usage" volumes presented in Table 3-9 are Worcester's reported finished water volumes and MassDEP uses raw water volumes to assess compliance and to determine if mitigation is required.

The Secretary’s Scope on the ENF stated that the DEIR should include a review of well closures due to emergencies or water quality impacts. No review was included in the DEIR.

The Project includes a PRV metering system. The Proponent is required tosubmit the design for this system as a BRP WS32 Distribution Modification Permit.

Wetlands

The Project will temporarily alter 12,400 sf of RA as well as 20,200 sf of Buffer Zone within existing roadways. The Project will also require removal of 7 cy of soil from beneath LUWW at the location of subsurface pipe installation beneath Kettle Brook, a perennial stream. The Proponent will use pipe jacking to install the pipe at a depth of at least 5 feet beneath the brook without impacting the streambed, Bordering Land Subject to Flooding, BVW or Bank. Wetland impacts proposed by the Proponent in the DEIR are identical to those proposed in the ENF. MassDEP Comments – EEA# 16070 Page 4 of 4

On or about May 14, 2020 the Proponent submitted a Notice of Intent (NOI) for the proposed work to the Auburn Conservation Commission (the “Commission”) and MassDEP. The NOI includes a Stormwater Narrative that describes the Project's compliance with the Massachusetts Stormwater Standards along with a stamped and signed Stormwater Checklist. Upon review of the NOI filing, MassDEP may provide project specific comments to the Commission and the Proponent as part of the File Number Issuance Notification Letter.

MassDEP's ENF comments mentioned temporary wetland resource area impacts from exploratory test borings needed to determine the properties of soils beneath Kettle Brook and to verify whether pipe jacking will be feasible. The Proponent advanced an exploratory boring on July 17, 2019 upgradient from BVW and Bank adjacent to the brook. Based on the boring location shown on plans included in the DEIR, MassDEP assumes that the Proponent conducted this activity under 310 CMR 10.02(2)(b)(1)(g), which allows temporary activities with negligible impacts to proceed in Buffer Zone and RA without the filing of a NOI.

The DEIR concludes that the impacts from the interconnection on streamflows within the Nashua River watershed and on the ability of impacted streams to sustain aquatic life will be minimal. The Proponent proposes no mitigation for impacts to streamflow in the Quinapoxet River and Asnebumskit Brook, and the DEIR states that "flow augmentation provisions, flow protection thresholds and other instream flow protection measures will not be required." Figure 3-3 in the DEIR estimates that, due to the proposed interconnection, streamflow at the confluence of the Quinapoxet River and Asnebumskit Brook will drop below 1 cubic foot per second for 11 days per year, and that the streams will potentially have no flow for several days each year. Currently, flow at this confluence is estimated to be less than 1 cubic foot per second fewer than four days per year. The loss of or increase in duration of perennial flow may qualify as an alteration to the Quinapoxet River and/or Asnebumskit Brook. MassDEP requests that the Proponent provide additional documentation to confirm whether these streams are currently dry on an annual basis and estimate the length of no flow conditions following the construction of the interconnection. The Proponent should also analyze whether an increased likelihood of intermittent flow will have adverse impacts to aquatic life or will change the jurisdictional status of portions of the Quinapoxet River and/or Asnebumskit Brook as perennial streams under 310 CMR 10.58.

MassDEP appreciates the opportunity to comment on the Project. If you have any questions regarding these comments, please do not hesitate to contact JoAnne Kasper-Dunne, Central Regional Office MEPA Coordinator, at (508) 767-2716.

Very truly yours,

Mary Jude Pigsley Regional Director cc: Commissioner’s Office, MassDEP

June 5, 2020

Kathleen Theoharides, Secretary Executive Office of Energy and Environmental Affairs Attention: MEPA Office Alex Strysky, EEA No. 16070 100 Cambridge St. Boston, Massachusetts 02114

Project Name: Auburn Water District Interconnection with City of Worcester Proponent: Auburn Water District Location: Transfer of water from Worcester (Nashua basin) to the Auburn (Blackstone basin); water main & pressure relief valve (Southbridge Street, Auburn/Worcester) Document Reviewed: Draft Environmental Impact Report EEA No.: 16070 NHESP No.: 15-34071

Dear Secretary Theoharides:

The Natural Heritage & Endangered Species Program of the Massachusetts Division of Fisheries & Wildlife (the “Division”) has received and reviewed the Draft Environmental Impact Report for the proposed Auburn Water District Interconnection with the City of Worcester (the Project) and would like to offer the following comments regarding freshwater fisheries as well as state-listed species and their habitats.

The Project is proposed in the Blackstone Basin outside of Priority and Estimated Habitat. However, stream flow alterations will primarily be in the Nashua Basin, specifically Asnebumskit Brook and the Quinapoxet River, which are within Priority and Estimated Habitat for the following state-listed species:

Location Taxonomic Scientific name Common Name Group State Status Pine Hill Reservoir Gavia immer Common Loon Bird Special Concern

Asnebumskit Brook & Quinapoxet River Glyptemys insculpta Wood Turtle Turtle Special Concern

Quinapoxet River Ophiogomphus asperses Brook Snaketail Odonate Special Concern Antrostomus vociferous Eastern Whip-poor-will Bird Special Concern

The species listed above are protected under the Massachusetts Endangered Species Act (MESA) (M.G.L. c. 131A) and its implementing regulations (321 CMR 10.00). State-listed wetland wildlife species are also protected under the Wetlands Protection Act (WPA) (M.G.L. c. 131, s. 40) and its implementing regulations (310 CMR 10.00). Fact sheets for most state-listed rare species can be found on our website (www.mass.gov/nhesp).

DEIR, Auburn/Worcester, page 2 of 3

Asnebumskit Brook and the Quinapoxet River are habitat for the following warm and coldwater fish, several of these fish are listed on the Massachusetts State Wildlife Action Plan (SWAP, 2015,*).

Location Common Name Asnebumskit Brook Blacknose Dace*, Bluegill, Brook Trout, Chain Pickerel, Common Shiner*, Fallfish*, Golden Shiner, Largemouth Bass, Longnose Dace*, Pumpkinseed, White Sucker, Yellow Bullhead, Yellow Perch Quinapoxet River Blacknose Dace*, Bluegill, Brook Trout*, Chain Pickerel, Common Shiner*, Fallfish*, Golden Shiner, Landlocked Salmon, Largemouth Bass, Longnose Dace*, Pumpkinseed, White Sucker, Yellow Bullhead, Yellow Perch

The purpose of the Project is to construct a permanent supplemental drinking water interconnection between the City of Worcester and the Auburn Water District. Although the pipeline interconnection work is being conducted in the Blackstone Basin (DEIR, Figure 2-3), stream flow alterations resulting from the Project will primarily be in the Nashua Basin, specifically Asnebumskit Brook and the Quinapoxet River (Figure 3-2). The Proponent is seeking approval for use of up to 0.54 million gallons per day (mgd) peak use from the proposed interconnection and up to 197.1 million gallons annual use. This equates to 750 gpm, 12 hours a day, for 365 days of the year. This transfer rate was selected to offset any losses from the Proponent’s largest producing well while providing an additional margin of safety should another source go down simultaneously.

After reviewing the DEIR, which described the donor basin in greater detail than the ENF, the Division discussed details of the DEIR on May 18, 2020 with David Roman (Comprehensive Environmental, Inc.) to better understand potential impacts state-listed species as well as fisheries resources. Mr. Roman agreed to provide the following clarifying information to aid in the Division’s review of the Project:

1) The DEIR presents information on monthly flows (Table 3-12) as unaltered flow estimates but compares them to exceedance data based on the annual curve (Figure 3-3). This methodology makes is difficult to determine if impacts to stream flows and habitats are more significant in certain months relative to others. Therefore, Table 3-12 must be revised to: a) make all comparisons among unregulated flows, existing regulated flows, and proposed regulated flows (including the proposed transfer) using monthly statistics; b) include conditions from the drought of 2016 in the extreme low flow analysis; and c) provide an estimate of the increase in the duration of the extreme low flow statistics (e.g. the average low flows typically last 3.5 days, but under the propose withdrawals will increase to 4.1 days, excluding data from the drought of 2016).

2) The existing evaluation point is downstream of the confluence of all the impoundments, at the confluence of Asnebumskit Brook and the Quinapoxet River. To determine if there is a more serious impact at any point upstream (within the Asnebumskit and Quinapoxet individually), Figure 3-4 should be independently created for both Asnebumskit Reservoir and the Quinepoxet Reservoir. Flow impact should be calculated below each reservoir using the weir equations discussed on page 28 of the DEIR, and each reservoir should have its own exceedance curve (not pooled into the exceedance for the entire suite of reservoirs) and hydrograph. Any estimates or measurements of seepage from dams, if available, should also be included.

The Division requires this information to determine if the project will result in a Take (321 CMR 10.18) of state-listed species in the Pine Hill Reservoir, Asnebumskit Brook and or the Quinapoxet River. After receiving this information, the Division will review the proposed Project for compliance with the state-listed species provisions of the WPA and the MESA. The Division may request additional information to understand the

DEIR, Auburn/Worcester, page 3 of 3 potential impacts of the proposed Project on state-listed species and their habitats. Projects resulting in a Take of state-listed species may only be permitted if they meet the performance standards for a Conservation and Management Permit (CMP; 321 CMR 10.23).

As both Asnebumskit Brook and the Quinapoxet River are listed as Coldwater Fish Resources under 321 CMR 5.00 and are important recreational fisheries, the Division also requests this information in order to evaluate potential impacts to fisheries resources in the donor basin.

If you have any questions about state-listed species associated with this letter, please contact Misty-Anne Marold, Senior Endangered Species Review Biologist at [email protected]. If you have questions about fisheries associated with this letter, please contact Todd Richard, Assistant Director of Fisheries at [email protected]. We appreciate the opportunity to comment on this project.

Sincerely,

Everose Schlüter, Ph.D. Assistant Director cc: David Roman, Comprehensive Environmental Inc. MA DEP Central Regional Office, Wetlands

From: Guerin, Philip D. To: Strysky, Alexander (EEA) Cc: Kenneth Smith; David Roman ([email protected]) Subject: RE: Comment Period Extension- EEA 16070 Auburn Water District Interconnection with City of Worcester Date: Friday, June 5, 2020 4:50:43 PM

CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe. Comments: EEA # 16070-Auburn Water District Supplemental Interconnection with the City of Worcester

Alexander,

The City of Worcester Department of Public Works & Parks is pleased to offer its support for the Auburn Water District’s intended interconnection with Worcester’s public water system. Auburn has been plagued by groundwater contamination issues for many years and has lost use of multiple sources as a result. The City of Worcester is well positioned to provide assistance to the District in the form of a safe and reliable water supply that will help offset peak demand and be available during emergencies.

Water use by the Worcester system (Worcester and various surrounding towns and districts) has been on the decline since the late 1980’s. Over the past year, record monthly low consumption has been recorded in seven months based on a data set of over 70 years. Average daily demand, which once exceeded 27 MGD in the late 1980’s, is now below 22 MGD and continues to decline. Maximum daily use, once approaching 40 MGD, rarely exceeds 30 MGD. All of this is happening while the City population grows and new development rolls out.

Auburn Water District’s supplemental needs can easily be supplied and frankly, will scarcely be noticed from a supply, distribution and environmental perspective. Auburn residents will benefit from having a reliable source of water to meet their critical needs while Worcester will benefit from the added revenue from water sales which would be rolled into additional water system infrastructure improvements like source protection, water supply land acquisition, water treatment improvements and the replacement of old, leaking water mains and services. This proposal has nothing but positive outcomes.

Thank you for the opportunity to comment. Please let me know if you have questions.

Philip D. Guerin Director of Water & Sewer Operations Worcester Department of Public Works & Parks 18 East Worcester Street Worcester, MA 01604

Telephone: 508-929-1300 x2109

THE COMMONWEALTH OF MASSACHUSETTS

WATER RESOURCES COMMISSION

100 CAMBRIDGE STREET, BOSTON MA 02114

June 3, 2020

Kathleen Theoharides, Secretary Executive Office of Energy and Environmental Affairs Attention: Alex Strysky, MEPA Office EOEEA #16070 100 Cambridge Street Boston, MA 02114

Dear Secretary Theoharides:

The Water Resources Commission (WRC) staff has reviewed the Draft Environmental Impact Report (DEIR) for the Auburn Water District’s Supplemental Interconnection with the City of Worcester. The Auburn Water District, which has its distribution system in the Blackstone River Basin, is proposing to purchase water from the City of Worcester, which has sources in the Nashua River Basin and the Blackstone River Basin. As this action represents an increase in the transfer of water across a river basin boundary (from the Nashua to the Blackstone) it triggers the Interbasin Transfer Act (ITA).

In this letter, we request additional information needed to evaluate compliance with Criteria 1 through 7 of the Interbasin Transfer Act regulations as outlined in 313 CMR 4.09 (3) (a through g). Our comments may be addressed in the Final Environmental Impact Report (FEIR), if one is required, or directly with the WRC through a follow-up letter to the WRC Staff, if an FEIR is not required. Once the MEPA process is complete and the WRC has all the information requested herein, the WRC will review and vote to accept the Auburn Water District’s application as complete. The WRC staff will then schedule the required public hearings in accordance with the ITA, Chapter 21 Section 8D.

Criterion 1: Compliance with MEPA This criterion will be met upon the issuance of the Secretary’s Certificate on the DEIR, or FEIR if one is required. No further information is needed.

Criterion 2: Viable Sources The DEIR does a good job of documenting that all reasonable efforts have been made to identify and develop all viable sources in Auburn. No further information is needed.

Criterion 3: Water Conservation This criterion requires that all practical measures to conserve water have been taken in the Receiving Area (Auburn Water District).

With regard to water pricing and rates: 1) Provide documentation to evaluate whether there are sufficient sources of funding to maintain the system, including listing the major cost categories covered by the rate. At a minimum, please specify whether the rates cover the cost of operation, proper maintenance, proposed capital improvements, debt service (if applicable), source protection, and water conservation activities. Also address whether there are elements of the water supply program whose costs are not covered by rates and specify how those elements are funded.

2) Provide clarification of the current rate structure(s). In the DEIR Section 3.6.3, there is a narrative description of current rates, which is corroborated by Table 3-10. However, these rates differ from those shown at the bottom of the sample bill provided in the DEIR Appendix D. Please clarify. If there are different rates for different sectors/customer classes (e.g. residential, commercial, etc.), please describe them all. Also, provide a sample bill from a non-vacant property.

3) Describe whether the water supply district is financially self-contained or whether it has financial or accounting agreements with the town of Auburn. If the latter, please provide details.

4) Provide the date and a description of the most recent rate change and the rationale for the change.

5) Provide documentation describing how the current rates encourage water conservation. Specifically, this should include: a) a description of the rationale for the base allowance volume (600 CF) and the tier 1 volume (5000 CF); b) the number and percentage of customers that fall into each tier, on average (if there are different rates for different customer classes, this breakdown should be provided for each customer class); and c) if available, the results of any evaluations of whether the rates have been effective in promoting water conservation.

6) Provide any other information that you feel would assist in the evaluation of the strength of Auburn’s price signal in promoting efficient use of water.

With regards to Water Loss Control 1) Provide information about whether Auburn Water District conducts a full leak detection program of the distribution system every three years. If no, let us know the last time when a system-wide leak detection was performed. Were all the leaks identified during the latest survey repaired? How often is a 100% leak detection survey of the distribution system completed? 2) Provide information about and document whether the Auburn Water District has performed a water audit of the system.

3) Provide further clarification about whether all water users are metered and the extent of metering within the District.

With regards to a written Water Conservation Plan 1) We understand the District does not currently have a written water conservation plan, although they are implementing components of a program and their current Water Management Act Permit includes water conservation requirements. The District should provide a plan that includes comprehensive documentation of current and future water conservation efforts in one place and reflects the 2018 revisions of the Water Conservation Standards for the Commonwealth of Massachusetts. Please contact WRC staff for further guidance.

Criterion 4: Forestry Management Program This criterion requires that a comprehensive forestry management program has been implemented on any watershed lands with surface water sources serving the receiving area (Auburn Water District) and under the control of Auburn Water District. All of Auburn’s supplies are groundwater. Therefore, this criterion is not applicable and no further information is needed.

Criterion 5: Reasonable Instream Flow Worcester’s Reservoir system is a highly engineered system, complex in its operation, and does not include streamflow releases as part of its existing management. Per direction from WRC staff, the DEIR provided flow analysis data at the confluence of the Quinapoxit River and Asnebumskit Brook, as this was the most upstream point at which to capture potential flow alterations from all of the above reservoirs in the Nashua Basin. Flow data from a downstream USGS gage were transposed based on the slightly smaller upstream drainage area at the confluence. Based on comments we have received from the Department of Fish and Game as part of this review, we are now aware that there are some fisheries resources and rare and endangered species habitat upstream of this confluence point on both the Quinapoxit River and Asnebumskit Brook. Therefore, we are requesting some additional information to better characterize flows in the two reaches upstream of the confluence and below the Quinapoxit and Pine Hill Reservoirs as well as below the Kendall Reservoir.

Please characterize flow below Quinapoxit, Kendall, and Pine Hill reservoirs using the weir equations discussed on page 28 of the DEIR for each reservoir. Each reservoir should have its own exceedance curve and hydrograph. Include a narrative description of seasonal flow characteristics (both non-spill and spill periods) downstream of the reservoirs under current and proposed operating conditions. Describe any changes in the frequency, duration, and timing of uncontrolled releases at each of the reservoirs. If estimates/measurements of seepage from dams are available they should also be included. This analysis should include the number of days that dry or near dry conditions will persist and the frequency with which they will occur in the affected reaches of river. Additionally, the analysis should also include an assessment of the impact of the proposed transfer on low flow conditions in a drought year (2016). We understand that the proposed increased withdrawal will need to be apportioned across the reservoirs to

complete this analysis and that it may likely be an estimate. Please contact WRC staff to discuss how to proceed with these estimates.

Criterion 6: Impacts of Groundwater Withdrawals The donor basin (Worcester) sources are surface water supplies. Therefore, this criterion is not applicable and no further information is needed.

Criterion 7: Cumulative Impacts No further information is needed.

In conclusion, WRC Staff needs some additional information before proceeding with the ITA review. The ITA Chapter 21 §8D (3) specifies that all required information has to be provided and that the MEPA process must be complete before the WRC can move forward with accepting the application as complete, and scheduling its public hearing and decision-making process. We hope that Auburn Water District will use the FEIR to fully respond to our request for additional information, so that the ITA process can commence once the final EIR certificate has been issued on this project.

Thank you for the opportunity to comment.

Vandana Rao, PhD Executive Director, MA Water Resources Commission

cc: Water Resources Commission Erin Graham, DCR Anne Carroll, DCR Duane LeVangie, DEP Michelle Craddock, DFG Todd Richards, DFW Ken Smith, Auburn Water District David Roman, Comprehensive Environmental Inc.