In August 2024, the Massachusetts Department of Environmental Protection (MassDEP) and the U.S. Environmental Protection Agency (EPA) may issue a water quality variance for Alewife Brook to allow CSO sewage discharges to continue through 2029. Water quality variances for Alewife Brook have been issued for the last 25 years, since 1999.
Discharge of sewage into public waters is not permitted under federal and state water quality standards, with some limited exceptions. The proposed draft water quality variance has multiple flaws and must be improved to protect the health of our community.
Alewife Brook is a “Class B” waterbody. That means it should be safe for human contact. It should support healthy fish communities. There should be no untreated sewage in it. However, Cambridge, Somerville, and the Massachusetts Water Resources Authority (MWRA) dump untreated human and industrial sewage from their Combined Sewer Overflows (CSOs) into Alewife Brook during rainstorms.
Save the Alewife Brook’s comments letter
WHAT WE TOLD DEP & EPA IN OUR WRITTEN COMMENTS ABOUT THE VARIANCE:
Granting the variance would undermine Environmental Justice principles, which call for enforcement of environmental standards and protection of environmental justice neighborhoods from environmental harms.
MWRA, Somerville, and Cambridge should not be awarded a new variance if they have failed to meet the requirements of the current variance. MWRA fails to adequately maintain its sewers to prevent odors. Somerville’s combined sewer outfall (SOM001A) has failed to meet discharge and floatable controls requirements. Cambridge’s CSO behind the Alewife T parking garage (CAM401A) continues to fail to conform to the hydraulic models.
If MassDEP grants the variance, it must require the polluters to act now to address CSOs, and not allow them to delay action further, until the new Alewife CSO Plan is approved and implemented. MassDEP must also add add the following conditions to the Variance so that CSO discharges do not get worse:
1) A prohibition on new hook ups to the combined sewers in Cambridge and Somerville that contribute to the CSOs in Alewife Brook, as well as a prohibition on more than de minimis increases to current flows to those combined sewers.
2) Adequate notification of the presence sewage in and around the brook. People using the Alewife Greenway path and abutters of the brook require timely, clear warnings when CSOs are discharging into the brook, and for at least 48 hours afterwards (e.g., red light when discharging and for 24 hours after discharge ends, yellow light for 24-48 hours after discharge ends, and green light if no discharges for more than 48 hours).
3) Improve accuracy of CSO metering and modeling, so Cambridge can understand why their worst CSO, CAM401A is failing, and how they can fix it.
4) MWRA must implement an odor control program for all their Alewife sewer infrastructure.
5) Cambridge, Somerville, and MWRA must deploy Green Infrastructure to capture and clean stormwater, and prevent it from activating CSOs. The use of green infrastructure can enhance neighborhoods, especially those with little green space or trees.
6) Require Cambridge, Somerville, and MWRA to provide separate financial analyses from for their Alewife CSOs, and explore the use of subsidies for low-income households or a tiered-rate system to cap cost increases for ratepayers who might struggle to pay higher rates. This is consistent with longstanding Environmental Justice principles that Environmental Justice communities should not bear the burden or costs of pollution that are beyond their control.
7) Provide reports and online sewer maps to advocacy groups.
Mystic River Watershed Association’s comments:
The public using the Alewife Brook Greenway and abutters of the Brook need much clearer warning when there are active CSO discharges, and for at least 24 hours after a discharge has ended (e.g., red light when discharging, yellow light for 24 hours after discharge ends). Subscriber-based notifications are insufficient for those who may be using the greenway. It is imperative to add requirements for MWRA, Cambridge, and Somerville to enhance notification by installing warning beacons or similar, highly visible signage when the outfalls on the Alewife Brook are discharging… MassDEP should add a condition requiring Cambridge and Somerville to limit future increases in sewage flows to current combined sewers discharging to the Alewife Brook/Upper Mystic during the term of the variance. This could take the form of a prohibition on new hook ups to the combined system,… Save the Alewife Brook has documented instances of failures of floatable controls at SOM001A. Odor control has also been an issue at manholes along the Greenway Path. MassDEP and EPA must commit to better enforcement of these measures.
Charles River Watershed Association’s comments:
We are deeply concerned that the proposed variance is failing to protect a valuable natural resource and is not delivering continued, meaningful progress. As drafted, the Tentative Variance is inadequate as it allows for continued pollution without requiring substantive corrective actions during the variance period… We do not support the Tentative Variance as written… the ultimate goal should be nothing less than complete or functional elimination of the CSO discharges… The current financial analysis is inadequate for determining the economic feasibility of CSO elimination… Combined Sewer Overflow is an Environmental Justice issue. Environmental Justice (EJ) is a stated priority for the federal government and the Healey-Driscoll administration.
MWRA Advisory Board: Alewife’s not worth fixing.
In their comments to MassDEP, the MWRA Advisory Board make it clear that Fred Laskey‘s MWRA wants to avoid any investment to end dumping of untreated CSO sewage into Alewife Brook:
“…spending an additional $100 for a $1 incremental benefit would make no sense from a public policy view.”
“Performing [analysis needed for the updated Alewife Brook CSO Control Plan] would be extremely expensive and may ultimately be unnecessary.”
HEARING TESTIMONY
Cynthia Hibbard of Green Cambridge, provided at the 4/9/2024 hearing:
“CSO number CAM401A is right next to a small piece of property that is owned by Green Cambridge in the Alewife Reservation. And it’s also immediately adjacent to the MBTA property. We’re very concerned that encampments of unhoused people are being flooded during CSO events. There has been an unhoused person encampment next to the MBTA garage. We think that encampment was empty when it was flooded by the combined sewer overflow last week. However, there are many encampments in the Alewife Reservation that were occupied and possibly exposed. We would like to ask that the warning system that our partners have proposed includes an alert that be provided directly to the Cambridge Health Department, so that the Health Department could send people to the Alewife Reservation to move encampments before they are flooded by sewage outflows.”
Tori Antonino of Somerville Green & Open Space, provided at the 4/9/2024 hearing:
“We are smart people who have great resources. We have People Power in Somerville and we are not in compliance. Somerville needs to do a hard think about doing intense Green Infrastructure.”
David Stoff of Save the Alewife Brook, provided at the 4/9/2024 hearing:
“I’m an Arlington resident. My home abuts the Alewife Brook which has 6 Combined Sewer Outfalls dumping untreated sewage and industrial waste into the brook. I’m here today to testify in opposition to the proposed variance.
I’ve participated in regulatory actions about the Alewife for over 20 years. My expectation has always been that DEP would act to protect the health of our community and enforce the Alewife’s existing Class B water quality standard rather than waive it.
The law encourages consideration of site-specific conditions. The proximity of untreated sewage discharges to a densely populated and heavily used area – here on the Alewife and in the Charles at CAM 005 – and the evidence of routine contact with the discharges ought to be sufficient for DEP to use its best professional judgment and require dischargers to meet a water quality standard that protects safe human contact.
The waters of Massachusetts are held in trust for the citizens of the Commonwealth. Using them as sewers prioritizes short-term economic benefits for a few over their value to us all in the future.”