August 23, 2012

Secretary Richard K. Sullivan, Jr.
EOEEA, Attn: MEPA Office
Holly Johnson, EOEA No. 14089
100 Cambridge Street, Suite 900
Boston, MA  02114

Subject:    Draft Environmental Impact Report for EOEA# 14594
Proposed (redundant) Well 9A – Westfield, Massachusetts

Dear Secretary Sullivan,

I am submitting comments on the Draft Environmental Impact Report (DEIR) for proposed well 9A in Westfield on behalf the Connecticut River Watershed Council (CRWC).  CRWC is the principal nonprofit environmental advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed.  The proposed new drinking water well will withdraw more than 100,000 gallons per day (gpd), therefore it automatically requires an environmental impact report (EIR).  We have the following comments on the DEIR.

1.    There still seems to be a discrepancy as to the purpose of the new well.  Section II(H) of the ENF form stated that, “The addition of the new well will provide for redundancy of supply to the City of Westfield in addition to increasing the capacity to serve future customers.”  At the ENF scoping meeting, and in some places of the DEIR, redundancy has been emphasized.  For example, the DEIR in section 1.4.4 says that “this is a request to place an additional groundwater well in service as a redundant/backup well for the City of Westfield.”  Nevertheless, in several places, growth and increased demand are mentioned, such as in Section 2.6 in which it says, “The City of Westfield anticipates that the current and future demand for water will place a severe burden on its current sources, especially if one or more of their sources become non-operational.”

Because of the ENF’s mention of growth, the Secretary’s Certificate on the ENF said that the DEIR should present information on unaccounted for water rate, seasonal water rates, and water usage statistics over the last decade.  It also said the DEIR should characterize how current and future needs have been projected, and specific information was requested.  Usage data provided included the years 2006 to 2010, not the last decade.  No information on project future needs was given, nor were conservation measures explained, other than drought restrictions for outdoor watering.  And in the draft summary of mitigation measures, it states in section 6.2.4 that no mitigation measures are anticipated in regards to water resources because the addition of the well will add redundancy without requiring an increase from their registration withdrawal total of 6.11 million gallons per day (MGD)  Based on data presented in Table 1 of the DEIR, I calculated that Westfield had been consuming 4.8-4.9 MGD during 2006-2009, and then the use went up to 5.4 MGD in 2010.  When was the conservation program mentioned in section 3.5 implemented?

2.    Alternatives Analysis.  The Secretary’s Certificate dated June 4, 2010 states that the DEIR should provide “additional discussion and documentation of each of these alternatives:  1) No Action, 2) Alternative Withdrawal Point, 3) Surface Water, 4) Leak Detection, and 5) Increased Conservation and Management.”  Section 3 of the DEIR provides an alternatives analysis, but it was cursory at best, and frequently did not include any documentation.
Alternative Withdrawal Point.  The DEIR states that $100,000 was spent on a comprehensive water supply exploration program but no information on what was considered was provided in the DEIR.  Existing water sources like the Tighe-Carmody Reservoir, the Montgomery Reservoir (Tekoa Reservoir), and the City of Holyoke’s water supply were dismissed as infeasible or too expensive, yet no information or data were provided.  The City of Westfield’s own website on the history of their water supply (http://www.cityofwestfield.org/?page_id=2050) indicates that the Montgomery and Tekoa Reservoirs were formerly used as a drinking water reservoir but were later phased out as the Granville Reservoir came online.  The website says those smaller reservoirs are on “emergency only” status, which suggests that the reservoirs are tied to the distribution system even though the DEIR says they are not.  The Pioneer Valley Energy Center, located in Westfield, is apparently going to draw water from the Tighe-Carmody Reservoir, and more information should be provided as to the costs and feasibility of providing water via that plant.
Surface water withdrawal.  The DEIR states that flow from the Granville Reservoir is “often severely restricted” “during drought conditions.”  No information as to how often that happens or what reservoir level triggers the restrictions was given.
Leak Detection.  The Water Management Act permit application provided in a CD attached to the DEIR indicates on page 4 of the Water Conservation Questionnaire that the last time a full-system leak detection survey was done was 20 years ago.  However, the DEIR says that the City spends $3,000 annually on leak detection and a system-wide leak detection is performed “routinely.”  Clearly, leak detection could be better and an estimation of the savings should be presented here.
Increased Conservation and Demand Management.  The DEIR mentions a Water Conservation Program, yet the Water Management Act permit application states that nothing is in place but that the City will initiate a water conservation program in FY2011 and the DEIR does not mention a new program.  Table 2 in the DEIR indicates that the residential use ranged from 82.5 to 90 gallons per person per day between 2007-2010, far exceeding the recommended 65 gallons/person/day.  In addition, total annual unaccounted for water ranged from 12.7% to 24.9%, exceeding the recommended guideline of not more than 10%.  I calculated that using 2010 figures from Table 2, if the City achieved 65 gallons/person/day that year, it would have saved 0.89 MGD, which is almost 50% of the flow needed in the proposed well.  No analysis or data like this was presented in the DEIR.  The WMA permit application also indicates that they do no water audits, have no consumer incentives for low flow water use devices, and have a flat rate for water billing.  July and August are the peak usage months as shown in Table 1, with those months typically being close to or as much as double the consumption of the low months of December and February.  The DEIR erroneously states in section 1.4.4 that “… the summer (July and August) water usage increases by up to 50% over the winter usage (January and December).  Doubling the usage is a 100% increase, not a 50% increase.  There is clearly room for improvement in cutting down water demand, yet the DEIR doesn’t even scratch the surface on what is possible and how much water that would save.

3.    The Secretary’s certificate requested that the DEIR clarify the analysis performed with regard to potential drawdown of Great Brook, and “discuss how the drawdown studies to date are indicative of water withdrawal impacts to the stream during potential drought conditions.”  The drawdown study was conducted in late December of 2007 through January 2008, a time of year during which rain and snowmelt occurred.  No explanation about how this was indicative of drought conditions was provided in the DEIR.

Though the DEIR went into much detail about how the stream is either a gaining or losing stream at various points, the key results of the stream flow measurements were never explained.  The results, taken from Table 8 in the BRP WS 19 application, are as follows.

Pumping test stage and dates Great Brook Streamflow Station 1 (upstream) cfs Great Brook StreamflowStation 3 (downstream) cfs Flow Difference
Antecedent (T-1)12/29/07-1/3/08

19.1

21.3

+2.2

Pumping (T-1)1/3/08-1/8/08

15.1

14.6

-0.5

Recovery (T-1)/Antecedent (T-2)1/8/08-1/10/08

20.4

23.9

+3.5

Pumping (T-2)1/10/08-1/21/08

28.9
25.2

26.3
23.0

-2.6
-2.2

Recovery (T-2)1/21/08-1/25/08

16.1

16.2

+0.1

Flow of the downstream station was consistently higher than the upstream station during non-pumping times and lower than the upstream station during pumping times.  No explanation of this phenomenon was presented in the DEIR.  To me, this does not indicate no impact.  Additionally, Figure 6 shows that all three piezometers, co-located at the streamflow stations, were affected by the pumping.  This indicates that the upstream and downstream locations were not necessarily truly upstream and downstream from the effects of the wells, and that all stations may have been impacted by the pumping.

Section 5.2.1 states that the Great Brook is a coldwater fish resource within the Westfield River watershed, and that the aquatic base flow for the stream must be maintained at all times.  The DEIR lists the ABF for Great Brook as 0.5 cfsm for summer, 1.0 cfsm for fall/winter, and 4.0 cfsm for spring.  The DEIR concludes at the top of page 28 of the DEIR that the effects of pumping from the aquifer on Great Brook appear to be minimal, and a decrease in the aquatic base flow (ABF) is not expected as a result of the groundwater withdrawals.  No calculation of ABF was provided in the DEIR, and no explanation about how the December-January pump test results would ensure that the summer ABF was maintained was provided.  Wells 3 and 4 both experience large increased withdrawals during the summer months.  Additionally, the SWMI interactive map viewer (http://www.mass.gov/dep/water/resources/swmi.htm) indicates that the lower Great Brook is a flow category 5 (heavily impacted) and a biological category 5 (heavily impacted).  It appears that adding a well to this sub-basin will further impact a heavily impacted coldwater stream.

In our opinion, the DEIR does not adequately demonstrate that the City has exhausted conservation means to make this well necessary, and has not demonstrated that the new well will not negatively impact a coldwater stream.  We thank EOEEA for the opportunity to comment on this project.  I can be reached at adonlon@ctriver.org or 413-772-2020 x. 205.

Sincerely,

Andrea F. Donlon
River Steward

Cc:

Duane Levangie, MassDEP
Kathy Baskin, EEA
Jim Bumgardner, MassDEP
Julia Blatt, Massachusetts Rivers Alliance
Margaret VanDeusen, Charles River Watershed Association
Steve Kaiser, Ellen Moyer, Anne Bingham