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Submission of the Commonwealth of Massachusetts

Project Summary

Summary of Project
Massachusetts is proposing to try an innovative approach to achieving water quality in the Assabet River, which is listed as impaired under section 303(d) for nutrients. Because the data obtained thus far in our TMDL process demonstrates that point source control alone will not be enough to achieve water quality standards, we are, along with a consortium of communities along the River, exploring alternatives to focusing exclusively on point source controls. These alternatives include dam removal, sediment removal/control, nonpoint source controls and groundwater recharge. The existence of a consortium of communities in the watershed, together with a well developed model established in connection with the preparation of a TMDL, make this an excellent candidate for a truly watershed based permit that is well outside the established box and that would provide a model for future watershed based permitting.

Applicant Information
Title Assabet Watershed Innovative Permitting
Applicant Massachusetts Department of Environmental Protection
Contact Douglas Fine
627 Main Street
Worcester, MA 01608
Phone: (508) 767-2727
email: Douglas.Fine@state.ma.us
Program This project is not being executed in cooperation with or funded by another Federal program.
Flexibility No regulatory flexibility is anticipated to be needed to implement this project
Support The Commissioner of the Department of Environmental Protection supports the submission of this project for the Commonwealth of Massachusetts.
Summary Budget Information
Amount The dollar amount requested from EPA is [REDACTED BY EPA]
State The dollar amount of voluntary leverage funding offered by the State is [REDACTED BY EPA].
Total The total project budget is [REDACTED BY EPA]

Pre-proposal Project Narrative

We are trying something new in the Assabet River: using watershed permitting, innovative incentives for the point source dischargers and creative solutions to get to water quality standards in ways that would not be possible with more traditional approaches.

The Assabet River is dominated by POTWs, both in flows and nutrients. The River is heavily impaired by aquatic vegetation caused by overloading of nutrients. During the summer, the POTW discharges account for 80-90% of the river flows. Models we have developed for different scenarios to achieve improvements in water quality indicate that dramatic reductions in phosphorus discharges from the POTWs will be necessary, but also show that POTW discharge reductions, even to zero phosphorus, do not achieve water quality, due to sediment flux and a series of impoundments, among other things. Making the point sources spend the money to get to the lowest possible (or even below what some argue is possible) phosphorus discharge will require very large expenditures of money that may ultimately be ineffective in achieving water quality standards, and will invite appeals and delay while the appeals are litigated.

Massachusetts proposes to substantially reduce the discharges of phosphorus from the POTWs and involve the towns in a search for more effective, and possibly less expensive, alternatives, such as control of nonpoint sources, removal of dams, removal and/or treatment of sediments, and groundwater recharge of wastewater and/or stormwater. We already have model results indicating that control of sediment flux combined with reductions in phosphorus discharge can be more effective in achieving DO standards than even more severe reductions of phosphorus from the POTWs alone. This holistic approach to the river is watershed planning in the best sense and it increases the likelihood of eventually achieving water quality through innovative permitting. Furthermore, it creates opportunities to address other watershed issues, such as diminished flow in the headwaters, and builds a partnership of river advocates, dischargers and local, state and federal levels of government.

We are now in the process of conducting additional model runs to determine what the best combination of options might be for achieving water quality standards. Our proposal is to use a grant to do a detailed investigation of the best options, with a goal of developing a final watershed permit at the end of 2003 or early 2004 that will include point source limitations and some combination of nonpoint source, dam removal and sediment control options. We are now in Phase 3 of the planning process (alternatives review) and that process will continue on its current schedule. This proposal would supplement, not shift or delay the planning process that is currently on going.

This approach will be transferable to other basins and other states not in its specifics - the combination of dam removal, point source control, sediment control etc - but in concept; it will provide a real life example of a holistic watershed approach to permitting that better achieves real and measurable environmental results through innovative approaches.

Project schedule and time frame
We are in the process now of doing additional runs of the modeling for this river to see which scenarios, and in what combination, appear to offer the greatest probability of achieving water quality standards and are most cost effective. The modeling to date has been encouraging for development of innovative permitting options; while straight NPDES point source reductions do not achieve water quality standards, point source reductions in combination with sediment control are very promising. We are now doing additional runs for dam removal, recharge and combinations of the above, to see which options look most promising, and should be investigated in detail to determine if they are feasible and how much they would cost.

This project is already well underway. A consortium of communities has been formed, has retained a contractor to do planning, and has produced two reports. Phase 1 considered the towns' likely needs for water and wastewater services. Phase 2 looked at treatment options, including some groundwater disposal, and preliminary costs associated with those options. In addition, we are well into the preparation of a TMDL for this River, including the development of a model to predict responses to various treatment and control options. In short, this is not a hypothetical exercise, but a project that is already on track and will be completed in a relatively near future.

We propose to continue the model runs over the next two to three months to identify the options, and combinations of options, that appear most promising for achieving water quality standards. [Note: we can provide much more detailed information on the model runs done to date, and the options under consideration if more background is needed.] While the communities investigate costs for POTW treatment options, we would propose to use these funds to have the contractor investigate feasibility and costs of the unconventional options. We would then hope to have detailed information on both feasibility and costs for the range of treatment and control options for purposes of writing the NPDES permits in late 2003 to early 2004. We note that the time to implementation of the selected options may vary. Although the funding is requested for the purpose of evaluating and selecting the best package of options, which should occur by 2003-2004, some options will take longer to implement than others. Until the options are selected, we cannot say what the implementation schedule in the permit might be.

Threshold factors
The proposal meets both threshold factors: 1) it is for research and investigation under the Clean Water Act section 104(b)(3) and advances the state of knowledge and leads to measurable results, and 2) it targets one of the priority areas (restore and maintain water quality).

Program criteria

Priority area. This project addresses a priority environmental area: restore and maintain water quality. It is being implemented through a close collaboration among Massachusetts, the six communities along the Assabet River, and the local watershed association, who are jointly looking for solutions that can achieve water quality standards. Some of the subbasins in this watershed are also stressed for water quantity, a factor that we are planning to take into consideration as we assess the best combination of options to achieve water quality standards.

Incentives. The Assabet River proposal tests an innovative incentive in permitting: allowing the towns to adopt a point source control strategy that is more cost effective while doing a better job at achieving the end point of water quality standards. Providing funding for exploration of the feasibility and costs of the alternatives, which is what is here proposed, would provide additional incentives to the communities to participate in this innovative approach.

Transferability. States are desperate for examples of real watershed permitting, especially ones that include point, non-point and innovative structural changes in one package that can be enforceable and results-driven. We are relatively close to permit issuance in this basin; providing funding to fully examine innovative alternatives prior to final permitting would allow us to craft a permit that could serve as a model elsewhere in Massachusetts and in other states.

Measures and accountability. The approach outlined here is designed to create measurable change in water quality for which the participants will be accountable through the permitting process in combination with commitments made by state and federal government. The short term result will be issuance of permits based on good science and carefully considered investigation of the options, which alone will be inspiring to other states experimenting with watershed permits. Over the longer run, we will achieve measurable improvements in water quality in the Assabet River and achieve compliance with water quality standards.

Proposal budget
Total Project Proposed State EPA

Costs    Leverage Funds    Funding


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