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July 23, 2019 Evan Lewis United States Environmental Protection

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July 23, 2019 Evan Lewis United States Environmental Protection BOARD OF DIRECTORS AND OFFICERS July 23, 2019 Officers Philip D. Guerin Evan Lewis President and Chairman United States Environmental Protection Agency Director, Water, Sewer, & 5 Post Office Square, Suite 100 Environmental Systems, Boston, MA 02109-3912 Worcester Department of Public Works & Parks Via Email: [email protected] Joshua Schimmel RE: City of Haverhill, Haverhill Water Pollution Abatement Facility-Comments on Executive Vice President and NPDES Draft Permit MA0101621 Vice Chairman Executive Director, Springfield Water and Sewer Commission Dear Mr. Lewis: Cheri Cousens, P.E. The Massachusetts Coalition for Water Resources Stewardship (MCWRS) is a Treasurer Executive Director, Greater nonprofit organization committed to promoting watershed-based policies and Lawrence Sanitary District regulations that effectively manage and conserve water resources. Members include municipalities; public agencies that transport and treat drinking water, wastewater Alan H. Cathcart and storm water; quasi-government agencies; and private organizations whose Secretary members are committed to the principles of stewardship and sustainability in Superintendent, Water and Sewer Division, Concord protecting the environment and public health. Find us at mcwrs.org. Department of Public Works MCWRS offers these comments on the City of Haverhill draft NPDES Permit Directors because the City of Haverhill is a long-standing member of our organization. We Robert A. “Brutus” Cantoreggi also find that many of the conditions contained in the permit have implications for Director, Franklin Department other communities in the Merrimack Valley and throughout Massachusetts. of Public Works Thomas M. Holder On June 24, 2019, MCWRS had requested from EPA Region 1 a 90-day extension Director, Wayland Department of the comment period for this draft permit. That request was denied and instead a of Public Works 15-day extension was granted. Given the complexities and far-reaching impacts of this permit, MCWRS again suggests that a comment period extension of an Jane Madden, P.E., BCEE Senior Vice President, additional 90 days would best serve the agencies and stakeholders. The additional CDM Smith time would allow further discussion of many issues and perhaps resolution of most. In lieu of an extension, EPA will have to reissue the draft permit as it needs to be David Michelsen, P.E. substantially modified to remain fair, accurate and consistent. District Engineer, South Essex Sewerage District MCWRS fully supports the comments submitted by the City of Haverhill. In Kent Nichols, P.E. particular, their request for a revised Draft permit should be heeded. As pointed out Vice President, by the City, there are a number of factual inaccuracies in the draft permit including Weston & Sampson 7Q10 flows and dilution factors. The City also makes a strong case for eliminating Kerry Reed, P.E. limits on aluminum based on recent clean sample testing rather than historic test Senior Stormwater & results that were questionable for this purpose. Environmental Engineer, Framingham Department of Public Works In addition to the City’s comments, MCWRS also suggests that EPA Region 1 is missing a wonderful opportunity to advance watershed–based permitting by Karla Sangrey, P.E. handling permits for Haverhill, Lowell and the Greater Lawrence Sanitary District in Engineer-Director and an isolated fashion. These three large communities are each situated on the Treasurer, Upper Blackstone Clean Water Merrimack River within a relatively short stretch of river. They all share the same issues of wastewater treatment, CSOs and aging water infrastructure. Through new language in a revised draft permit, EPA could allow and encourage collaboration c/o Regina Villa Associates | 51 Franklin Street, Suite 400 | Boston, MA 02110-1301 (617) 357-5772 | www.mcwrs.org | [email protected] between these communities in a way that advances river improvement while minimizing fiscal impacts and duplicative work. Some form of pollution trading or similar actions which allow a community to utilize its strengths and work with a neighboring system to share costs and implement beneficial improvements would be a great step forward in NPDES permitting in New England. Thank you for the opportunity to comment on this draft permit. MCWRS looks forward to working with EPA Region 1 and MassDEP to further advance environmental protection in a fiscally sound and effective way. Sincerely, Philip D. Guerin President & Chairman cc: Commissioner Martin Suuberg, MassDEP Robert Ward, Deputy DPW Director, City of Haverhill Commissioner Martin Suuberg, MassDEP Robert Ward, Deputy DPW Director, City of Haverhill Ellen Weitzler ([email protected]) Municipal Permits Section Chief Representative Lori Trahan, Massachusetts Third District, [email protected] Representative Seth Moulton, Massachusetts Sixth District, [email protected] Senator Diana DiZoglio, [email protected] Senator Bruce E. Tarr, [email protected] Senator Barry Finegold, [email protected] Representative Christina Minicucci, [email protected] Representative Linda Dean Campbell, [email protected] Representative Marcos Devers, [email protected] Representative Frank Moran, [email protected] Representative Tram Nguyen, [email protected] Mayor James J. Fiorentini Eric Worrall, MassDEP, [email protected] Michael A. Leon, Esq., [email protected] c/o Regina Villa Associates | 51 Franklin Street, Suite 400 | Boston, MA 02110-1301 (617) 357-5772 | www.mcwrs.org | [email protected] .
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