To read a Boston Globe Editorial on this issue, click here.
To visit the MWRA website click here.
Ellen Roy Herzfelder, Secretary
Executive Office of Environmental Affairs
251 Causeway Street, Suite 900
Boston, MA 02114
Attention: MEPA Office, Arthur Pugsley
Project: Fort Point Channel CSO Control Project NPC
Dear Secretary Herzfelder:
Great progress has been made over the course of the past decade in improving the water quality of Boston Harbor. Much of this can be attributed to the invaluable efforts of the MWRA. Tremendous benefits to the public and the Commonwealth have resulted from this work and investment: active waterfronts; swimmable beaches; improved fishing and a rebound of aquatic life; and substantial continuing investment to redevelop properties along the entirety of Boston Harbor. Where once Boston Harbor’s condition made us the object of national ridicule, it has now become one of our greatest attractions and motivator of the regional economy.
We are dismayed to learn that the current plans of the MWRA for the Fort Point Channel, which has long lagged the rest of the Harbor in its water quality and renewal, will not only not be improving with the remainder of the Harbor, but will actually see its water quality decline. This is an unacceptable reversal of an otherwise unparalleled success.
Fort Point Channel, the last remnant of the great South Bay, separates South Station, the Leather District and the Financial District from the emerging Fort Point neighborhood and Seaport district of South Boston. It is crossed and appreciated daily by tens of thousands of people, including those on the newly rebuilt wharf of the Children’s Museum. This area has already received significant public investment through the Central Artery/Tunnel project and the MBTA’s Silver Line, which will result in more people being able to use the waterfront, including the South Bay Harbortrail and completion of prominent stretches of Boston’s Harborwalk. Additional billions of dollars of private investment are anticipated in the coming years as both sides of the Fort Point Channel are rebuilt in recognition of the value and importance of this location.
The City of Boston last year completed its Fort Point Channel Watersheet Activation Plan, where the fundamental goal and focus was to bring many more people to, and out onto, the waters of the Channel for recreation, education and enjoyment. Key elements of the plan include boating, fishing, and other occupancies in close proximity to the waters of the Channel.
Two existing water dependent users, Gillette and James Hook and Co., rely upon the water quality of the Fort Point Channel for the continued viability of their operations. Hook suffered a catastrophic die-off of five thousand (5,000) lobster nearly one and a half years ago when improperly treated water from a construction site entered the Channel and entered Hook’s water intake pipe. This resulted in a substantial fine being levied against the responsible party by the Boston Conservation Commission. These businesses must have clean water for their needs, and a decline in quality could prove the cause for them to close or relocate away from Boston. The goal for water quality in the Fort Point Channel must be the same that we hold for every other portion of Boston Harbor: this water must continually be clean, able to be swum in and fish caught here to be edible. While this is not the case today, the only acceptable course of action is to provide the infrastrucure, management and enforcement which will bring rapid and increasing levels of cleanliness and health to the waters of Fort Point Channel.
The sewer separation projects which the MWRA has been conducting have provided much value, and overall have assisted in the Harbor clean up. However, the quality of the remaining discharges into Boston Harbor, whether stormwater, ground water or non-point sources must be free from contaminants which degrade water quality. Anything less represents a violation of the public trust and the express purpose of establishing the Authority. The MWRA should not be absolved of its responsibility to carry out the mandates of the Clean Water Act and other legislation which require our waters to be clean and safe.
While the effort required to properly treat or remove pollutants from stormwater prior to its release into the Fort Point Channel carries some cost, it does not represent and inordinate price, nor does it require particularly new, exotic or costly facilities. What is being sought merely represents adequate housekeeping responsibilities which ought to be undertaken as a matter of course.
We ask that the obligation of the MWRA, under 40 CFR 131.20, to conduct a public review of water quality standards on the Channel every three years be enforced, and that sufficient public notice, hearings and opportunities to review the relevant documentation and make comments on all proposed activities be required.
It is a matter of right that our citizens be able to use and enjoy the public waters and waterfront without worry of contracting illness or disease. It is also crucial to the health of the Commonwealth that the enormous public and private investments in this area not be jeopardized by a retreat from the existing goals and accomplishments of the Harbor clean up.
We ask that MEPA deny the MWRA’s request for a Notice of Project Change, and further require the Authority to reexamine, analyze and the publish their plans to control the discharge of sewage, storm-water, and combined sewer overflows into the Fort Point Channel.
We would also ask the Secretary to instruct the DEP to immediately begin the required, overdue, tri-annual review of the water quality standard on the Fort Point Channel, so that the public can be heard on these critical issues before any new plans are approved.
Jon Seward, on behalf of
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