To the Editor:
The following is the Edgartown Wastewater Treatment Facility (EWWTF) response to a Letter to the Editor of Sept. 12 (“Pollution from new development should be weighed”):
The Water Quality Monitoring and Assessment for Edgartown Great Pond Summary (2018), issued Jan. 22, 2019, states, “The addition of the 2018 monitoring results indicates that if sustained, Edgartown Great Pond may have achieved compliance with the USEPA/MassDEP TMDL issued under the Clean Water Act.” Mr. Guest has this report; I sent it to him. It indicates, contrary to his assertions, that nitrogen mitigation efforts have returned nitrogen levels there to below those in the 2004 Massachusetts Estuaries Project (MEP) Report, and that the full MVC watershed recommendations (sewer, fertilizer regs, pond openings and dredging, shellfish restoration) are having a beneficial effect: “If TN levels in 2019 and 2020 remain below the MEP threshold, that is a good indication that the opening schedule and the improved WWTP (ie; EWWTF) effluent are resulting in a stable TN concentration and that the improved management is having a sustained positive ecological response.”
The EWWTF committed to DEP to remove 300 residential septics from the watershed in 2004, and reserved 100,000 gal./day of the 750,000 gal./day plant capacity for that purpose. The Field Club line and Meshaket pump station (financed by same) enabled that sewer main to be used by Road to the Plains and Island Grove, and for over 320 parcels there in the EGP watershed to be eventually able to connect to sewer. Field Club is 32 parcels. The infrastructure in place now allows 569 parcels altogether to be removed from the watershed, of which 246 are presently customers. There are in fact hundreds of eligible parcels and residents out there in the watershed that have not elected to opt in yet, contrary to Mr. Guest’s assertion that the watershed is neglected in favor of developers.
Over the years there have been requests for connection that would increase the sewer envelope outside the watershed. EWWTF has declined to entertain these, for potentially cutting into the watershed reserve capacity. Recent approaches at Mullen Way and Oakdale/Cow Bay, privately financed, were turned away, nonetheless, for this reason.
Septage (2.3 MG/yr.) makes up 2.9 percent of the EWWTF’s 80 MG/yr. flow. At the historic facility treatment average of 2.8 parts per million of total nitrogen (TN), the septage contribution is 54 lb./24 Kg per year of the 1,868 lb./849 Kg/yr of TN now contributed overall by facility effluent at this flow. (The EWWTF is allowed 4,800 lb./2,200 Kg/yr. at an effluent TN of 7 parts per million as a permit limit before it exceeds the MEP threshold.) This 54 lb./yr. of TN is the equivalent contribution of 10 full-time residents on septic, using the Buzzards Bay Project per capita septic TN contribution of 5.95 lb./yr. (septic tank TN is 35 to 75 parts per million). Mr. Guest omits mention that in the dismissal of a suit he brought contesting the 2009 facility DEP permit, it was determined that the effluent plume originating from the facility is in fact diluting the contaminants emitted by downstream septic systems. The amount of nitrogen he referred to from Islandwide septage is within the seasonal variability for TN loading to the pond, as the contribution from rainfall (8-9 billion gal./yr.) and the atmospheric deposition of nitrogen via acid rain is a vastly larger amount. Until the other towns step up to serve their residents (and 90 percent of the Island is on septic systems), Edgartown provides this essential service, and reaps revenue to pay for capital improvements with negligible impact to the total nitrogen loading to the pond.
On outreach, the facility manager at EWWTF, in conjunction with the M.V. Water Alliance, MVC, and the New England Water Environment Association Small Communities Committee had a watershed awareness and nitrogen mitigation public outreach booth for four days at the 2019 Ag Fair. Mr. Guest refers to the 2005 Island Blue Pages, unaware there is an updated 2019 edition, which we distributed at the Ag Fair, which he needs to read, and which he can get from either EWWTF or MVC, or download at mvcommission.org/node/46152/attachment.
I do not usually respond to letters like the Sept. 12 one, but the opportunity to inform the public was compelling. The “deal” Mr. Guest so darkly hints at was this: The wastewater committee has been approached with versions of a subdivide at what is now Meeting House Place for seven years. In 2015 the committee went on record that “if” this property were to be allowed to be subdivided and developed, it would prefer that there be sewer, as the addition of this many septics would be a setback to the watershed mitigation plan. As the sewer line could go directly to the Meshaket Pump station across the street, it was possible to do so, and it would not be connected to any of the existing sewer networks, nor subtract capacity from any of them. Wastewater committee was emphatic that this was not an endorsement of development, but a way to keep more septic systems from going into the watershed, should the subdivide and any eventual residences gain approval elsewhere. That buildings could eventually go in there piecemeal as individual lots were sold off was a distinct possibility, along with individual septic systems. The availability of sewer would compel either the developer or the individual owners to pay for and connect to it. A motion to increase the watershed allocation was entertained, but given the underutilization of the present system by eligible residents, the high incidence of part-time occupancy there, the fact that the subdivide was not even approved, and that the minor amount of additional flow was within the daily variability of the entire watershed system, it was tabled for future review.
Build-out downtown, outside of the watershed but inside the present sewer envelope, continues apace. Abutters to the existing sewer continue to edge toward their allotted bedroom capacity. From a wastewater-treatment perspective, a 2,000-square-foot, five-bedroom house is the same as a 10,000-square-foot, five-bedroom house, based on per capita nitrogen. A pound of nitrogen in 2,000 gallons of wastewater is the same as a pound in 10,000 gallons. Either way, 95 percent of the nitrogen is removed, and the clean, disinfected water returned to the aquifer. The size of the house where it originates is not in wastewater’s purview, nor should it be, as long as it complies with the bedroom limits for the lot. It should not be placed at the feet of wastewater to decide how to parcel out capacity now under the guise of aesthetics or ill-defined future needs. Putting the onus on the wastewater facility to manage growth is not its function, treatment is. Planning, zoning, and conservation entities exist to define these needs, and have the regulatory power to devise tools to enforce them.
David Thompson, facilities manager
Edgartown Wastewater Treatment Facility
Well said Dave, unfortunately Mr. Guest and others will never understand the full dynamics around nitrogen, phosphorus or watershed planning. I know because I spent 20 years trying to get him to understand this complex issue and now you have spent your fair share of time trying to do the same.
The only constant I see is a few people who like to hear themselves and think that by putting their misconceptions into writing it somehow gives their erroneous beliefs more meaning.
Keep up the good work on behalf of the environment and rest assured those who write letters thinking they have all the answers are only fooling themselves.
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