Letter - Implementation of Comprehensive and Targeted Wastewater Management on Cape

from Dr. David Dow, East Falmouth

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I recently submitted comments to the Massachusetts Department of Environmental Protection on the Town of Falmouth’s Notice of Project Change for the South Coast Embayments and West Falmouth Harbor Comprehensive Wastewater Management Plan (CWMP)/Targeted Wastewater Management Plan (TWMP).  This is the first phase for restoring habitats (eelgrass beds; oyster reefs; salt marshes) for marine biota and improving water quality (reducing Nitrogen loading from septic systems and improving water transparency) for 13 watersheds within the town boundaries and the Waquoit Bay Watershed which includes Falmouth; Mashpee and Sandwich.

Since I live in the Waquoit Bay Watershed and have been engaged as a grassroots environmental activist in the Superfund/Safe Drinking Water Act cleanup at Joint Base Cape Cod for over 20 years, I am concerned about the drinking water and wastewater challenges where I live.  In addition, perfluroinatei chemical contamination of private and public drinking water wells from the Ashumet Valley Plume has created concerns about toxic chemicals in our drinking water.  Thus I accepted an invitation to join the Cape Cod Advisory Committee for the University of Rhode Island’s STEEP (Sources, Transport, Exposure, Effects of PFAS) grant which has been measuring the levels of PFAS chemicals in private drinking water wells on Cape Cod. Ma. DEP is developing a maximum contaminant levels for 6 PFAS chemicals of 20 parts per trillion (down from the current hazard warning level of 70 ppt).

During my time working as a marine scientist at the Fisheries Lab in Woods Hole, I served as the recreational fisheries coordinator in the Northeast; participated in the New England Fishery Management Council’s Habitat Plan Development Team (which helped develop Omnibus Habitat Amendment 2 which was published in 2018); served on the Environmental Protection Agencies Waquoit Bay Watershed Ecological Risk Assessment project; and participated in the EMaX (Energy Modeling and Analysis Exercise) research project which developed a food chain carbon flow model from the Northeast Continental Shelf Ecosystem.  Thus I have a concern on the effects of the CWMPs/TWMPs on Cape Cod on both habitat restoration critical to marine biota and water quality (both excess nutrients and toxic chemicals).  I support the US Water Alliance’s One Water concept of addressing both drinking water and wastewater from a watershed perspective.  The Cape Cod Commission; Ma. DEP and EPA Region 1 have adopted a watershed perspective for the CWMP/TWMP for the > 50 “N” impacted embayments here on Cape Cod.

Some of my concerns on the Falmouth Notice of Project Change ( EEA # 14164) include: 

* Essential Fish Habitat in coastal embayments are effected by warming waters and ocean acidity; shifting ranges of managed fish species from the Mid-Atlantic region or migrating further offshore/into the rapidly warming Gulf of Maine (i.e. Summer Flounder moving in and American lobsters migrating out of Nantucket Sound); microplastics contamination from stormwater and wastewater treatment plants (wwtps); contaminants  of emerging concern (cecs) bioaccumulating in the marine food chain; seasonal hypoxia (low dissolved oxygen levels win bottom waters of Cape Cod Bay) in addition to eutrophication (“N” loading from septic systems).

* The primary solution to be employed by the Town of Falmouth is upgraded or new wwtps with ocean outfalls for treated swage effluent (which likely will contain cecs) and disposal of sewage sludge which likely contains PFAS chemicals.  This is likely to be a costly approach to implement without government grants covering 50% of the infrastructure costs and close down costs for residents to connect to sewers/close down their septic systems. There has been discussion of the Town of Barnstable taking over the former wwtp at JBCC and expanding it to serve the Upper Cape towns.  Thus the cost of this component of the project is poorly understood.

* The NPC doesn’t discuss environmental justice concerns that would include seniors on fixed incomes and service industry employees living paycheck to pay check and how they would pay for these expensive infrastructure improvements. Some type of socioeconomic analysis is required which would be accompanied a community outreach program.

* Finally an ecosystem based approach for management of marine biota and their habitats is required to address the reality that we live in rapidly changing marine environment which is not at a steady state. equilibrium condition (underlying concept for CWMP/TWMP watershed plans).  The Waquoit Bay ERA project examined the interaction between bay scallop fishery collapse and loss of eelgrass beds/excess nitrogen loading. 

Others may want to offer additional comments on the strengths and weaknesses of the CWMP/TWMP watershed approach here on Cape Cod to address both our drinking water and wastewater challenges. The comment period on EEA # 14164 extends until January 13, 2020.

Dr. David Dow

East Falmouth, Ma. 

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