MWRA CSO Report is Unfair to Alewife’s Environmental Justice Populations
On December 30, 2021, the Massachusetts Water Resource Authority (MWRA) published its anticipated Final CSO Performance Assessment, as part of a series of regulatory reports that have been submitted to the U.S. Environmental Protection Agency (EPA) and the Massachusetts Department of Environmental Protection. These reports are a requirement of the landmark Boston Harbor Cleanup Case. Here, the MWRA has attempted to demonstrate that it has achieved the levels of Combined Sewer Overflow (CSO) control, “including as to frequency of activation and as to volume of discharge specified in its Long-Term CSO Control Plan” as stated in the court ruling.1
What the MWRA Final CSO Performance Assessment Report Says:
The Boston Harbor Cleanup has been extremely successful for the Boston Harbor.2 There really has been a miraculous transformation in the Boston Harbor that everyone involved can be proud of.
SOM001A, Somerville’s Alewife Brook CSO is not in compliance3 and there is no plan proposed to get SOM001A into compliance4. SOM001A is the Tannery Brook CSO, which discharges combined sewage from Davis Square.
What the MWRA Final CSO Performance Assessment Report Doesn’t Say:
The report does not provide actual CSO discharge volumes in the Alewife Brook. It only includes measured 2021 CSO discharge volumes for the first half of the year. For the second half of 2021, the MWRA used modeling, rather than actual measured discharge volumes.5
Based on modeling, rather than real data, the report claims that there were a total of 6.26 million gallons of CSO discharge in the Alewife Brook in 2021.6 The reality is that in 2021 there was a total of 50 million gallons of sewage water discharge into the Alewife Brook. The true data is eight times worse than the modeled data.
Cambridge, Somerville, and the MWRA have reported the actual measured data for the entire year on their CSO Activations reporting websites.7 Given the disproportionate health impact that the CSOs have on our most vulnerable Environmental Justice populations in the Alewife area, it is not equitable to publish untrue, modeled data. The true numbers demand that more work is done to control the CSOs. If the true data is used, this report can be used to better improve the community health problems of hazardous sewage-contaminated floodwater that enters the homes, yards, and parks of Alewife area neighborhoods.
The report basically evaluates modeled performance of the CSOs for a “typical” year which was determined over twenty years ago based on historical data. It is this modeled data that is then used to evaluate compliance. The “typical” year assumption needs to be re-evaluated and likely updated to represent current conditions including the effects of climate change.8
The actual data is used for model calibration but not for assessing compliance. This is a potential disconnect between what is actually happening and what the model is saying.
The Final CSO Performance Assessment report says nothing about the effects of Climate Change and its continual increase in precipitation.9 It says nothing about how Climate Change’s increase in wet weather will result in an increase in CSO activations. The report makes no mention about the fact that future conditions will be even worse not only because of the increase in precipitation, but also because of sea level rise, and more frequent and dramatic storm events.
Missing from the MWRA’s Final CSO Performance Assessment report is any information whatsoever about the Alewife Basin’s topography and how that makes the area prone to flooding. It says nothing about how close to sea level the Alewife is. And it says nothing about the number of people who live within the Alewife’s 100-year flood plain and how hazardous sewage-contaminated flood water enters the homes, yards and parks of the area’s most vulnerable, Environmental Justice populations. The report says nothing about how unsafe it is to live near the Alewife Brook because of the CSO sewage water that floods neighborhood homes.
And, alarmingly, although it does list other pathogens, the CSO Final Performance Assessment report says nothing about COVID-19 in the CSO sewage water and what health risk the Alewife’s hazardous COVID-19 contaminated flood water carries when it enters residents’ homes, yards, and parks. The MWRA is already doing an amazing job of testing their wastewater for COVID-19. That data should be included in their CSO report.10
The Boston Harbor Cleanup has been a great success for the Boston Harbor. The Alewife Brook is a small waterbody by comparison, but it should be treated it as the unique tributary that it is. It deserves special attention, which should exceed the EPA & MWRA’s 85% improvement goal as part of the Boston Harbor Cleanup case. Here’s why: The flat topography of the low-lying Alewife watershed ensures that any CSO discharges that remain will have a disproportionate impact on the folks living in this flood-prone area. A review of FEMA flood maps reveals there are an estimated 1200 East Arlington residents, 3500 Cantabrigians, and 300 Belmont residents living in the Little River – Alewife Reservation’s 100-year flood plain. Because of flooding, the CSOs make the Alewife Brook an unsafe place to live near. The neighborhoods around the Alewife include the area’s most diverse and vulnerable populations, which makes this an Environmental Justice issue, since these are Environmental Justice populations.11
The great achievements from the first Long Term Control Plan that closed half the CSOs in the Alewife Brook are losing ground to Climate Change, with its wetter rain season, and more frequent and dramatic storms. What we once thought would be an 85% reduction in CSO discharges is now completely eclipsed by the effects of Climate Change, in addition to other factors such as the increase in impervious surface. In 2021, there have been 50 million gallons of sewage-contaminated water discharged into the Alewife Brook. This is the same volume of sewage contaminated stormwater discharge as for the base year of 1997, which is the year that the MWRA chose as the design year in its original Long-Term CSO Control Plan.
The MWRA’s CSO Performance Assessment provides no path forward towards solving the critical community health problems that Alewife Brook CSOs present. As an example, there is currently no plan for compliance of Somerville’s SOM001A CSO. For this CSO, which MWRA has flagged as being out of compliance, there should be a plan that includes (1) full sewer separation and elimination of the SOM001A CSO, (2) gray infrastructure that includes an underground stormwater tank at Dilboy Park, (3) another Pumping Station to convey sewage out to Deer Island, and (4) green infrastructure that includes a stormwater wetlands to clean Somerville’s stormwater, bioswales and rain gardens, (5) Alewife Brook restoration, and (6) possible daylighting of the Tannery Brook.
Somerville, Cambridge, and the MWRA will all benefit in the future when the CSOs are no longer polluting the community surrounding Alewife Brook. By closing the CSOs, they will prevent unsafe, contaminated discharge into Alewife Brook and into the flood water that enters neighborhood homes. Half of the CSOs have already been closed, now is the time to close those that remain.