October 23, 2017


Arthur S. Johnson

Massachusetts Department of Environmental Protection

Division of Watershed Management

8 New Bond St.

Worcester, MA 01606


Subject:       Proposed Massachusetts Year 2016 Integrated List of Waters

Dear Mr. Johnson,

I am submitting comments on the proposed Massachusetts Year 2016 Integrated List of Waters on behalf of the Connecticut River Conservancy (CRC), formerly known as the Connecticut River Watershed Council.  CRC is the principal nonprofit environmental advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed.  The Connecticut River and its tributaries (including the Deerfield, Millers, Chicopee, Farmington, and Westfield River basins) take up approximately one-third of the land area of Massachusetts.

Overall comments

It has now been a decade since MassDEP has written a TMDL that had anything to do with impairments in our section of the state (the most recent being the Northeast regional mercury TMDL in 2007).  Table 4 on page 35 lists long-awaited Bacteria TMDLs for the Connecticut, Deerfield, Westfield, Chicopee, and Millers basins coming in FY2017-2018.  We note that the 2014 Integrated List promised these TMDLs were coming out in FY2015-2016.  CRC hopes that whenever these TMDLs do get drafted, the “TMDL Count” column will be updated to include the newly impaired segments proposed in 2016.  Below is a table that compiles the river segments proposed for inclusion in category 5 in 2012 vs. proposed in 2016.  We are using the proposed 2012 numbers because that is when we last tallied up the pathogen impairments by basin; five years ago we prepared a comment letter for the 2012 Integrated List requesting that DEP prepare bacteria TMDLs for our water bodies.  Now, except for the Farmington and Millers basins, the number of impaired river miles for pathogens is greater.

Appendices 2 and 3 do not provide any data and not enough rationale for us to evaluate proposed additions or removals to categories 4 or 5.  We recommend MassDEP review the New Hampshire Department of Environmental Service’s equivalent document (online at https://www.des.nh.gov/organization/divisions/water/wmb/swqa/2016/index.htm).  In many cases, NHDES provides graphs of actual data points and explains its rationale for listing or delisting in detail.  With MassDEP no longer publishing water quality assessment reports, CRC recommends that DEP consider overhauling the way it presents information in the Integrated List.  Data and rationale should be presented in a way that the public can understand what data MassDEP is using and the rationale for changes in the list.  The source and year of data should be included for all assessment listings.

CRC includes a list as an attachment to our letter with the global request that the data or rationale for listing or delisting be provided in detail.  We did not have time to look up all the monitoring data that is available online, but even if we did, the information is not available in one place.

Chicopee River Basin comments

MassDEP appears to be slipping further behind in assessing water bodies of the Chicopee basin.  There are 9 segments that were formerly assessed in some way in the 2014 Integrated List, but are now in category 3.  Three of them are tributaries that drain into the Quabbin Reservoir, which is the Commonwealth’s largest drinking water supply.  Does the Department of Conservation and Recreation (DCR) conduct water quality monitoring of streams that drain into the Quabbin Reservoir, and does DCR share data with MassDEP?  Nine segments in category 2 lost uses attained, potentially due to lack of water monitoring data.  Eight segments are newly listed in category 5 and three impairments were added to already impaired waters.

Connecticut River Basin comments

MassDEP proposes to remove the total suspended solids impairment for segment MA34-05, the CT River downstream of the Holyoke Dam to the CT state line.  A look at the DEP water quality database indicates no sampling in this stretch of river.  There is a station in Suffield, CT, which was sampled on three dates in 2008.  Is MassDEP basing its assessment on a sample that lies outside of the segment that is being delisted?

MassDEP proposes to remove the E. coli impairment for the Mill River, Northampton, segment MA34-28.  CRC has conducted weekly E. coli sampling for 19 weeks of the year since 2012 at a location along the Mill River a bit upstream of Paradise Pond on the Smith College campus.  This site has frequently not met water quality standards.  We have worked to find the bacteria source and think we have identified the general area of one, and have been in touch with the Northampton DPW.  We have not had the time to format the data into DEP database format, but the data is readily viewed and downloadable online at http://www.connecticutriver.us/site/node/18?city=Northampton&state=MA&status_red=1&status_yellow=1&status_blue=1&status_white=1&status_gray=1&search=1.  We do not agree that this segment be delisted for E. coli.

West Brook has been added as a new segment to this year’s list and is in Category 3.  MassDEP may be interested to hear that the USGS Conte Anadromous Fish lab has been conducting a multi-year brook trout study on this water body and may have water quality data.  A brief intro to the study and contact names can be found online at http://felek.cns.umass.edu:4444/indTagViz/WB/dev/wbTagVizSplash.html.

CRC requests that the description of Barton Cove (MA34122) include information to indicate that this is the section of the Connecticut River that is just upstream of the Turners Falls Dam.

CRC requests that the description of Log Pond Cove (MA34124) include information to indicate that this is a cove of the Connecticut River that is just upstream of the Holyoke Dam.

CRC notes that Sugarloaf Brook, which flows through Deerfield and Whately and discharges into the CT River near Herlihy Park, is still not listed in the Integrated List as a water body.  We recommend that DEP add it to the list and include it in your monitoring strategy.  Sugarloaf Brook is impacted by groundwater withdrawals from Chang Farms, may be used for irrigation water from other farms, and formerly received illegal discharge from Chang Farms wastewater until the USEPA required Chang Farms to get a NPDES permit and discharge to the Connecticut River.  CRC sampled Sugarloaf Brook a few times in 2010 and 2011, and never found a bacteria problem.  Temperature readings met coldwater standards during the summer we sampled.

Spelling corrections:

Sodom Brook, MA34-53, “Westampton” should be “Westhampton.”

Unnamed Tributary, MA34-60.  “Willamanett Brook” should be “Willimansett Brook.”  CRC confirms that this water body is known as Willimansett Brook.

Deerfield River Basin comments

MassDEP has added 100 new river segments in the Deerfield basin to the 2016 Integrated List that have not been listed before.  All new segments were assessed for the fish and aquatic life use only.  It would be helpful if DEP provided more information on what data was collected during this large effort to assess much of this watershed.  Of the 100 newly listed segments, four are considered impaired.  There are seven segments previously listed that are newly considered impaired, and 2 impairments added to already impaired water bodies.  Two impairments are proposed to be removed.

The Deerfield River Watershed Association conducted a water quality program in the Deerfield basin in 2017.  Data are preliminary, but samples in several tributaries and the Deerfield mainstem were tested for E. coli, total phosphorus, total nitrogen, total suspended solids, chloride, and volunteers took temperature readings during sampling events.

Spelling corrections:

Creamery Brook MA33-46, “Steady Line Road” should be “Steady Lane Road.”

Fuller Brook, MA33-118, “Debuque State Forest” should be “Dubuque State Forest.”

“Katley Brook”, MA33-99 should be “Kately Brook.”

South River, MA33-07 and MA33-101.  “Emments Road” should be “Emmet Road.”

Farmington River Basin comments

MassDEP has added 23 new river segments in the Farmington basin to the 2016 Integrated List that have not been listed before.  Most new segments were assessed for the fish and aquatic life use only.  It would be helpful if DEP provided more information on what data was collected.

Millers River Basin comments

This basin contains numerous additions and removals of impairments.  Several segments are being delisted for “fecal coliform” with the rationale in Appendix 3 explained as “Applicable WQS attained; due to change in WQS.”  This sounds to us like there has been no recent sampling for E. coli now that the state water quality standard has changed from fecal coliform to E. coli.  However, the MassDEP database indicates that Beaver Brook (MA35-09) was sampled on six separate dates in 2011 for E. coli and all samples tested low.  If recent data are available, DEP’s rationale should possibly be based on water quality standards now being attained.

In Appendix 2, it would be useful to refer people to page 28 of the Integrated List document to better understand the rationale behind the new segments listed for PCB in fish tissue.

Westfield River Basin comments

MassDEP has added 25 new river segments in the Westfield basin to the 2016 Integrated List that have not been listed before.  Water temperature and E. coli bacteria seem to be the most common new water quality impairment.  It would be helpful if DEP provided more information on what data was collected.

Thank you for the opportunity to comment.  I can be reached at adonlon@ctriver.org or (413) 772-2020 x. 205.


Andrea F. Donlon

Massachusetts River Steward


Attachment:  List of segments that CRC is requesting data/rationale to be fully explained