Meetings with EPA & DEP & MWRA

Last week, the Charles River Watershed Association, the Mystic River Watershed Association, and Save the Alewife Brook had meetings with the federal Environmental Protection Agency and the Massachusetts Department of Environmental Protection to discuss our recent letter to the regulators. This comes at a time when new plans are coming due to eliminate combined sewer overflow (CSO) sewage pollution.

We came away from the meeting with the EPA and their awesome new Regional Director for New England, David Cash, with a sense that the agency is compassionate toward the Environmental Justice populations in the Alewife flood plain. The EPA and DEP seem sincerely concerned about the hazardous health risks that area neighbors face, as the heavily polluted and flood-prone Alewife Brook is so densely settled. 

Keep in mind that some of the folks from Save the Alewife Brook worked on the CSO problem 20 years ago. Back then, we wrote letters, letting everyone know about the illnesses we experienced after Alewife flooding brought sewage-contaminated flood water into our homes. And no one was talking about Environmental Justice back then. Save the Alewife Brook is happy to report that the regulatory agencies indicated that they are concerned about the health of the people and want to protect us. They care about the families who live along the Alewife Brook. We are so grateful to have been met with open ears and warmth from the EPA and MassDEP.

We also had a meeting with MWRA on Thursday of last week. There were many there from MWRA as well as from our advocacy groups. There was an open discussion with a frank exchange of views.  However, a big disappointment was that MWRA did not want to update their modeling to reflect future climate change impacts.

New Draft Scopes for CSO Elimination Work

Friday, April 1st, 2022 was a big day in the Alewife CSOs regulatory timeline. It was the day that Somerville, Cambridge, and the MWRA were required to submit draft scopes for their new Long Term CSO Control Plans to the federal Environmental Protection Agency and the Massachusetts Department of Environmental Protection.

You can download the scopes here:
Massachusetts Water Resources Authority
Somerville
Cambridge

The initial takeaway from the MWRA’s scope is that they do not want to consider Climate Change in their plan! 

The MWRA’S Climate Change Denial

We are very concerned about the climate change denial in the MWRA draft scope proposal. 

Climate Change threatens to exacerbate the problems in the Alewife, with wetter rain seasons, more frequent and more severe storms, and sea level rise, all of which lead to more flooding.

But flooding is not the only problem that Climate Change will present. Climate Change also makes the sewage discharge problem exponentially worse.  The volume of discharge is exponentially greater with increase in rainfall. This is why climate change effects must be included in MWRA’s modeling and CSO Plan. 

What is the MWRA’s “Typical Year Model?”

There is a legal, regulatory requirement that the MWRA assess the performance of the CSOs in their system, and report back to the regulators. This allows the court and the government to ensure that their obligations to make improvements are being met.  

The benchmark for this modeling is a Typical Year, which represents rainfall for average conditions. The Typical Year that they are now using is based on historical data that goes back as far as 1949!  To truly represent current and future conditions, the model must be forward-looking and take into account the effects of climate change. The Typical Year approach also does not capture the fact that, when rainfall is above average, CSO discharges exceed in frequency and volume the limits set for a Typical Year, as discussed below.

The MWRA claims that they have reduced the amount of sewage pollution in their system by 85%, as part of the Boston Harbor Cleanup. This may be true for the Boston Harbor and its East Boston and South Boston beaches and the Boston waterfront. Truly, the MWRA deserves an enormous amount of credit for the miraculous, magical work they’ve done improving Boston Harbor water quality with use of the Deer Island Treatment Plant.

But a review of the actual volumes of combined sewage discharge in the Alewife shows that, in the last four years, the system has not met the Long Term Control Plan goals. And, frighteningly, the volume of discharge is increasing exponentially since 2016, and is exponentially worse with increase in rainfall.

Here is a chart from the MWRA that shows the actual annual amounts of combined sewage discharge (the gray bars), the aspirational modeled amounts of discharge (navy blue bars), and the required goal (the straight horizontal orange line). Up top, you can see the actual annual rainfall (light blue bars):

MWRA’s ‘Calendar Year’ metered [actual] data (gray bars) vs. modeled [hypothetical] data (navy blue bars), with LTCP goal (horizontal red line), actual rainfall (light blue bars), and modeled rainfall (horizontal yellow line). Note that:  
In the last four years, Alewife CSOs failed to meet the LTCP goal, except in drought year 2020.
There is an exponential upward trend of actual CSO discharge volume since 2016.


The MWRA has been employing a model that uses historical storm data from before 1993, going backwards over 4 decades to 1949! The actual volumes of sewage discharge, in the gray bars, show that, since the last CSO improvements were completed in 2015, we are experiencing an exponential increase in sewage discharges. The hypothetical model, in the navy blue bars, obfuscates that alarming fact, by suggesting that the Alewife CSOs are performing well and generally below the LTCP goal. The 50 Million Gallons volume of sewage discharge in 2021 is the same amount of sewage discharge that the Alewife was receiving back in the 1990s, before any improvements were made!

If the MWRA does not acknowledge Climate Change in its new plan, we are likely to see a much worse situation in the future.

This is why the EPA and DEP must require the MWRA to adopt a forward-looking model that includes Climate Change projections and also properly considers large storm events.

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The Typical Year is a series of storms (93 storms with total precipitation of 46.8 inches) developed by the Authority in 1992 from a 40-year rainfall record (1949-1987 plus 1992) and approved by EPA and DEP that has served as the basis for development, recommendation and approval of the Authority’s LTCP, establishment of the Court-mandated levels of control, and assessment of system performance.
P. 3, Footnote 1 from MWRA BIANNUAL COMPLIANCE AND PROGRESS REPORT AS OF JUNE 14, 2019

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