HomeMy WebLinkAboutEarth Tech Response to Phase I comments_201401230912023057NANTUCKET, MASSACHUSETTS
CWMP/EIR – PHASE II REPORT
1.0 RESPONSE TO PHASE I COMMENTS
A. GENERAL
The Town of Nantucket submitted an Environmental Notification Form (ENF) to MEPA on
October 1, 2001. The 30-day public comment period for the ENF ended on November 1, 2001
and on November 16, 2001 the Executive Office of Environmental Affairs (EOEA) determined
that the project required an Environmental Impact Report (EIR) and established a special
procedure for review of the required EIR.
The MEPA Certificate (EOEA No. 12617), issued by the Secretary of Environmental Affairs to
the Town of Nantucket, requires the preparation of a Comprehensive Wastewater Management
Plan (CWRMP/EIR) for the island and establishes a special procedure for review of this project.
The special procedure is a phased review during which the scope for future phases is based in
large part on the results of the preceding phase. A summary of the Phase I scope was included in
the MEPA certificate. The Phase I scope is the “Need Analysis”. The Phase II scope is the
“Alternatives and Site Identification and Draft Environmental Impact Report” and will be
finalized upon the completion of Phase I. The Phase III scope is the “Final CWMP and EIR” and
will be finalized upon the completions of Phase II. Each phase of this project will be distributed
for review according to MEPA regulations. Therefore, there will be opportunity for the
appropriate public comment period for all interested parties to contribute to the outcome of this
project.
Below is a list of letters received by the MEPA Office during the public comment period for the
ENF.
• Department of Environmental Protection
• Coastal Zone Management
• Division of Marine Fisheries
• Department of Food and Agriculture
• Massachusetts Historical Commission
• Nantucket Planning & Economic Development Commission
• Nantucket Conservation Commission
• Nantucket Land Council, Inc.
• Nantucket Community Association
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• Sylvie O’Donnell (2)
Each letter includes a variety of issues and concerns, which are summarized in the paragraphs that
follow. A response to the comments and issues immediately follow each item. The complete
MEPA certificate with the comment letters is attached in Appendix A.
1. November 9, 2001, Letter from Sharon Stone, SERO MEPA Coordinator, Southeast
Regional Office, Department of Environmental Protection.
This letter includes comments concerning the Phase I Report and the CWRMP/EIR
Scope.
Phase I Report
• The Phase I report should include a discussion of the current and projected
water supply and demand situation in the town, and discuss the status of the
town’s Water Management Act (WMA) limits and whether there are or will be
exceedances of the WMA limits.
Section 2.F of the Phase I Report discusses the current water supply. The scope
of work approved by the Department of Environmental Protection did not require
a discussion regarding the status of the Town’s Water Management Act (WMA)
limits since the entire island is a sole source aquifer.
• The Phase I Report should present an analysis of the current and projected flows
at the Surfside WWTP, as well as a presentation of the wastewater treatment
plant facilities and an evaluation of the capabilities and deficiencies of the
treatment plant units and operations. The report should also describe the
existing wastewater collection system and evaluate its condition and deficiencies.
The Phase I Report discusses the current flows in Section 3.E and existing
conditions in Section 2. Projected flows for the existing service areas and
identified “need areas’ is also presented. Phase II of the report will identify and
analyze alternatives including their potential impacts at the Surfside Wastewater
Treatment Facility. In addition, the Phase II report will present an evaluation of
the capabilities and deficiencies at the facility.
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• In the Needs Analysis section of the report, there needs to be a clearer
presentation of the two-step methodology used for the rating of the individual
needs areas. It is not clear what the threshold level from the first step means in
terms of the actual degree of Title 5 compliance, and how the second step of the
process resulted in the conclusions for given areas to be designated for further
analysis or not.
Earth Tech, Inc. revised the descriptive matrix language per DEP’s suggestion
and forwarded a copy to DEP for comment and approval on January 11, 2002.
Follow-up calls to DEP produced no additional comments or edits so the
document was considered approved. A copy of the descriptive matrix language
is included in Appendix B.
• The DEP does not recommend using a Special Procedure that would have the
next MEPA filing be the Draft CWRMP/EIR. There should be a filing of the
revised Phase I Report.
As discussed in the scoping session for the ENF, the first section in the Phase II
report will include updates of specific information, which are relevant to future
phases of the report.
CWRMP/EIR Scope
• The scope for the CWRMP/EIR should include a task to evaluate alternative
wastewater treatment and disposal options that may need to be considered in
order to maintain nitrogen levels below the target levels established by the
DEP/SMAT Status of Nutrient Sensitive Embayments in Coastal Areas
Evaluations.
The scope of this CWMP/EIR has already been approved funded and
appropriated accordingly. Based on the unavailability of any actual data, specific
nitrogen levels from the Estuaries Project to date, this project must proceed
accordingly. Earth Tech has met with the Estuaries Project group and realize that
any actual data from Nantucket Harbor, which is included in the second round,
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will not be realized until late 2003, assuming all necessary funding is available.
Madaket Harbor is currently not even on a list and could not be promised it
would be in the near future. As acknowledged by the Estuaries Project group,
there is sufficient water quality testing data available for Nantucket harbor for
this CWMP/EIR Process to proceed using current standards and guidelines.
In addition to the study areas identified in the Phase I report as need areas based
on the two stage rating criteria, other study areas located adjacent to Nantucket
Harbor were identified as areas of need.
Based on the above and the lack of sufficient Estuaries Project real data currently
available, this CWMP/EIR cannot commit to a non-existent guidance. Earth
Tech, through Patty Kellogg, has requested to become involved in this planning
process and therefore will keep abreast of this progress.
• A scope of work for any hydrogeological evaluations should be prepared and
submitted to DEP for review and approval prior to any fieldwork being
conducted at the potential disposal sites.
A discussion regarding the hydrogeological evaluations is included in the scope
of work for the Phase II report and is as follows: Field testing is required in order
to evaluate the feasibility of siting satellite or centralized wastewater treatment
facilities and/or groundwater discharge sites in Nantucket. Up to three (3) sites
will undergo hydrogeologic evaluation. The field testing at these sites will
include soil borings with subsequent installation of groundwater monitoring
wells, test pits to groundwater to confirm soil classifications, percolation testing
and double ring infiltrometer testing. In addition, mounding analyses will be
conducted using the U.S. Geological Survey Modular Three-Dimensional Finite
Difference Groundwater Flow Model (MODFLOW). This information will be
used to predict groundwater mounding under the full projected loading
conditions. Baseline water quality, Zone II and DEP basin impacts will also be
assessed as part of this sub-task. If the final scope of work for the hydrogeologic
evaluation were greater than three (3) a scope change and cost increase would be
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required. The Town will be responsible for all costs associated with obtaining
access to the sites and assume all costs regarding property damage, temporary
easements and the like in order to perform the hydrogeologic evaluation and
performing all test pits.
After identification of the short listed sites, the hydrogeological evaluation will
be reviewed and revised based on actual filed condition. The revised evaluation
procedure will be submitted to DEP for review and approval prior to proceeding.
• An evaluation of the existing and potential erosion at the disposal bed area at
Surfside should be conducted in order to determine the useful disposal area that
may be available at that site.
The use of existing erosion studies will be utilized during the Phase II document
for alternatives, which utilize the existing wastewater disposal basins at the
Surfside Wastewater Treatment Facility.
• The CWRMP/EIR should include, as part of the recommended plan, a plan for
ongoing collection system operation-and-maintenance program, including a
program for Infiltration and Inflow (I/I) control.
The Town currently maintains an aggressive operation and maintenance program
system wide and depending on the recommended outcome of this CWMP/EIR
will continue to do so. The Town undertook an Infiltration/Inflow Analysis and
sewer system survey on in February 1991, which was approved by DEP on
February 25, 1992. As part of that reports recommendation, the Washington
Street interceptor was replaced Spring 2001.
The Town is also undertaking evaluation and mapping project of the entire
wastewater collection and drainage system on the Island. The first two out of
three phases have been completed to date and consisted of a complete inventory
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and visual inspection of all structures. The final phase will consist of field
survey to locate all structures and provide the Town with invert and rim
elevations. All of this data will be used by the Town for future system evaluation
and capital improvement planning.
• The Department has reviewed the separately submitted detailed scope of work
for the purposes of the SRF program, and the above comments should be
addressed in a revised scope that should then be submitted to DEP for review
and approval.
A revised scope of work is included in Appendix C of this document.
2. October 29, 2001, Letter from Tom Skinner, Director, Office of Coastal Zone
Management (CZM).
CZM feels that the evaluation criteria could be modified to make them more
comprehensive and inclusive. CZM also comments on the scope for the CWRMP/EIR.
They suggest that the DEP’s nitrogen loading model be considered in the CWRMP/EIR.
• CZM recommends that the criteria for rating sites adjacent to fisheries resources
be reevaluated. Other studies have suggested that sites greater than 1000 feet
downstream from a source of wastewater discharged to the ground or a surface
water body can experience decreased water quality and decreased habitat for
shellfish and juvenile finfish. The CZM suggests that the proponent include
proximity to shellfish beds in the fisheries screening criteria and reconsider
labeling these sites as “No Constraint” in relation to siting wastewater
discharge facilities. The fisheries criteria currently only takes into account
stocked fish. CZM suggests that shellfish be included into this definition.
This screening criteria will be added as part of the screening of alternatives in the
Phase II document.
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• CZM recommends that shoreline change data be added to the screening criteria
for facilities siting. CZM is finalizing updated historic shoreline change data to
ensure that flooding or erosion will not threaten the Town’s investment. Another
example of information that could be useful to the Town is the beach profile data
collected by the Sconset Beach Preservation Association.
This screening criteria will be added as part of the screening of alternatives in the
Phase II document. Earth Tech requests that CZM provide their updated historic
shoreline change data for use in this criteria.
The Phase II document will indicate that the wastewater disposal problems in the
Siasconset study area are currently being addressed by the construction of the
Siasconset Wastewater Treatment Facility. As part of the planning for this
facility a shoreline erosion study was conducted. Earth Tech will request beach
profile data collected by the Sconset Beach Preservation Association but
anticipates that this data is only specific to the Siasconset beach area and
therefore not be useful for other areas of the island.
• CZM recommends that, when the DEP nitrogen modeling effort is complete, the
data be considered in the CWRMP/EIR process and the proponent consider the
nitrogen assimilation capabilities of the waterbodies downstream of the proposed
effluent disposal siting in its screening process.
The scope of this CWMP/EIR has already been approved funded and
appropriated accordingly. Based on the unavailability of any actual data, specific
nitrogen levels from the Estuaries Project to date, this project must proceed
accordingly. Earth Tech has met with the Estuaries Project group and realize that
any actual data from Nantucket Harbor, which is included in the second round,
will not be realized until late 2003, assuming all necessary funding is available.
Madaket Harbor is currently not even on a list and could not be promised it
would be in the near future. As acknowledged by the Estuaries Project group,
there is sufficient water quality testing data available for Nantucket harbor for
this CWMP/EIR Process to proceed using current standards and guidelines.
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In addition to the study areas identified in the Phase I report as need areas based
on the two stage rating criteria, other study areas located adjacent to Nantucket
Harbor were identified as areas of need.
Based on the above and the lack of sufficient Estuaries Project real data currently
available, this CWMP/EIR cannot commit to a non-existent guidance. Earth
Tech, through Patty Kellogg, has requested to become involved in this planning
process and therefore will keep abreast of this progress.
3. November 5, 2001, Letter from Paul J. Diodati, Director, Division of Marine Fisheries.
The Division of Marine Fisheries commented on the siting criteria and suggested that
shellfish and specific water quality standards be included in the criteria.
• The Division requests that land containing shellfish be added to the screening
criteria, and that a complete review and assessment of environmental impacts to
fishery resources be submitted prior to the issuance of permits or the Secretary’s
Certificate.
This screening criteria will be added as part of the screening of alternatives in the
Phase II document.
• The Division recommends that all future phases of wastewater treatment and
discharge plan not result in any degradation below the SA classification, which
is the highest standard for marine water quality. Currently, all the Nantucket
waters are classified SA, except for western Nantucket Harbor, Polpis Harbor,
and Madaket Harbor.
Any recommended discharge plan will be accordance with current rules and
regulations with discharge limits being set based on site location and
environmental considerations.
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• The Division requests that consideration be given to water in the areas currently
impacted by fecal coliform pollution (western Nantucket Harbor, Polpis Harbor,
and Madaket Harbor) for remediation to the SA standard of not exceeding a
geometric mean most probable number (MPN) of 14 organisms per 100
milliliters (ml) with no more than ten percent of the samples exceeding a MPN of
28 organisms per 100 ml.
Any recommended discharge plan will be accordance with current rules and
regulations with discharge limits being set based on site location and
environmental considerations.
4. November 8, 2001, Letter from Marica Starkey, EOEA Department of Food and
Agriculture (DFA).
The DFA made several suggestions regarding agricultural resources and the scope of the
Phase II EIR.
• The DFA requests that the Phase II EIR identify agricultural resources on the
island and discuss their preservation as related to wastewater infrastructure and
related water quality and supply.
Agricultural resources are screening criteria that are part of the screening of
alternatives in the Phase II document.
• The CWRMP/EIR should also examine consistency of the recommendations to
current land use, existing infrastructure and Nantucket’s Community Plan.
State land use codes were used in the Phase I document to delineate study areas
and used for future projections of wastewater flows from study areas identified as
areas of wastewater disposal need. All current approved planning documents
were used during the phase I document preparation.
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• The proponent should also be aware that the provisions of Executive Order 193
and the Agricultural Lands Mitigation Policy apply to state assisted wastewater
projects which transverse for front unprotected agricultural parcels thereby
encouraging their conversion, and that land classified under Chapter 61A or
under an agricultural preservation restriction may not be assesses betterment
fees.
The Town acknowledges and understands the requirements of Executive Order
193 and Chapter 61A.
5. October 26, 2001, Letter from Brona Simon, State Archaeologist, Deputy State Historic
Preservation Officer, Massachusetts Historical Commission (MHC).
The MHC commented due to the fact that the entire island of Nantucket is listed in the
National and State Registers of Historic Places and a historic district and is designated a
National Historic Landmark. Also, Nantucket has one of the highest densities of Native
American archeological sites in the Commonwealth.
• The MHC requested that an archeological reconnaissance survey be conducted
for the project.
The scope of work for Phase II includes a review of existing information
regarding Archaeological and Historic Resource. The Massachusetts Historical
Atlas/Register will be reviewed for pertinent information on each potential site.
At this time, a Step 1 archaeological survey is not included in the scope of work
or associated fee for this project. A Step 1 archaeological survey for any sites,
which may be of Archaeological and/or Historic significant, based on the existing
information, will be conducted.
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6. November 8, 2001, Letter from Alvin S. Topham, Chairman, Nantucket Planning and
Economic Development Commission (NP&EDC).
The NP&EDC has several specific comments regarding the relationship to the Nantucket
Comprehensive Community Plan, the Nantucket Harbor Watershed District, Madaket
Harbor Watershed Definition, the data not being current, and solution for the growth
inducement potential.
• The CWRMP/EIR can be a valuable tool for directing growth, ensuring the
health of our community, and for planning Nantucket’s future capital needs.
The goal of the CWMP/EIR is to identify areas of the island where current on-
site systems cannot be utilized for long term wastewater disposal. Growth issues
will be identified for study areas that are identified as need areas. Growth control
measures are not a part of the CWMP/EIR planning process and therefore
secondary impacts associated to growth should be directed by local zoning,
potential special legislation, and Town bylaws.
Relationship to Nantucket Comprehensive Community Plan
• The CWRMP/EIR should reference the final approved Nantucket Comprehensive
Community Plan, not the draft released in January of 2000. The official title of
the final document is “Charting the Future: The Nantucket Comprehensive
Community Plan.”
The future phases of the CWRMP/EIR will refer only to approved sections of the
final plan, “Charting the Future: The Nantucket Comprehensive Community
Plan.”
• The Comprehensive Plan advocates the definition of Town and Country as a
means of defining areas where development might be encouraged, within the
constraints of infrastructure and growth management measures (“Town”), while
discouraging growth and the extension of infrastructure in other areas
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(“Country”). The boundary between Town and Country was conceived of as a
sewer and water service area. The NP&EDC found that the CWRMP/EIR
defined Somerset as Country and the Comprehensive Plans shows Somerset as
Town.
The Phase I Report was a result of a two-stage rating matrix developed by Earth
Tech to identify areas that are sustainable with on-site wastewater disposal
systems and those that are not and not by definition of The Comprehensive Plan.
Page 3-23 of the Phase I Document clearly outlines the analysis approach utilized
in this comprehensive process.
• The CWRMP/EIR scope should mention that it is in coordination with the
Comprehensive Community Plan.
The CWRMP/EIR is written with coordination with the Town of Nantucket
Comprehensive Community Plan among other existing planning documents.
Implementations of future CWMP/EIR recommendations will need to consider
existing Town rules and regulations and the Comprehensive Community Plan
with final approval coming from Town Meeting actions.
Nantucket Harbor Watershed District; Madaket Harbor Watershed Definition.
• The watershed boundary identified in the CWRMP/EIR and related references in
the text are not consistent with the Horsley, Witten, Heggeman, Inc. report
“Nantucket Water Resources Plan”.
The watershed boundary presented in the CWMP/EIR report was obtained from
the Town of Nantucket, which was based on the Horsley, Witten, Heggeman,
Inc. report “Nantucket Water Resources Plan”.
• The commission believes that the relationship of the Harbor Watershed District
should be included in the study. Specific mention of the inclusion of the Harbor
Watershed District in the following study areas should be added to the narrative:
Town, Town (WPZ), Monomy, Shimmo, Polpis, Pocomo, and Wauwinet.
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Section 3,”Results of the Needs Analysis Assessment” defines this as a criteria
parameter, indicates in any or all of the study area is located within the Harbor
Watershed District, and indicates the approximate number of on-site systems
located within the Harbor Watershed District.
• When discussing Madaket and the effects on its harbor use the Horsley, Witten,
and Heggeman definition of that watershed as a frame of reference for planning
purposes.
The watershed boundary presented in the CWMP/EIR report used as criteria not
only in Nantucket Harbor and Madaket but the entire Island as well was obtained
from the Horsley, Witten, Heggeman, Inc. report “Nantucket Water Resources
Plan”.
• The commission recommends that the location of any CWRMP/EIR study area
within the Nantucket Watershed District, the Madaket Harbor Watershed, and
within the Wellhead District be an important determining factor in the
establishment of qualifying criteria for needs areas. If such consideration were
made, Pocomo, Shimmo, and Monomy would likely be evaluated to areas of need
on the basis of their importance to maintaining or improving the water quality of
Nantucket Harbor.
The location of a study area within the Nantucket Watershed District, the
Madaket Harbor Watershed, and within the Wellhead District is currently part of
the criteria in identifying areas of wastewater disposal need. An extensive two-
stage rating criteria analysis was used to identify areas of wastewater disposal
need. The first stage rating criteria matrix includes: (1) actual failures compiled
from Board of Health records, (2) categorical failures based on current Title 5
regulations; (3) systems that are at risk for failure/noncompliance {which are
septic systems that: (a) have severe groundwater limitations; (b) have severe soil
limitations; (c) have septic systems that were built before 1978; (d) have a lot
size of one-half acre or less; and/or (e) have two or more septic tank pump-outs
occurring within a calendar year}; and systems that have health/water quality
issues {which are systems that are located: (a) in a study area with a density of
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septic systems greater than two per acre; (b) within 100 feet of a surface water
body; (c) within a 100 year flood plain; (d) within a Zone II aquifer recharge
area; and (e) within Nantucket Harbor watershed line or 3,600 feet of Madaket
Harbor.
The second stage rating criteria matrix includes an evaluation of each Study Area
based on soil classification, groundwater levels, and a combination of system age
and lot size or in total “reality data”. The three qualifying criteria are: (1) 50
percent or more of the lots within the Study Area meeting the age/lot size criteria
(built before 1978 and a lot size of one-half acre or less); (2) 30 percent or more
of the Study Area having severe soils limitations (hardpan, bedrock, slope,
flooding and wetness); and (3) 20 percent or more of the Study Area having
severe groundwater limitations (seasonally high water table at the surface to 2
feet deep). If two of these three criteria are met, then the Study Area is
determined to be a need area.
A thorough side by side comparison of the results of the two evaluation methods
is made to determine: (1) if a given Study Area shows consistent need; and (2)
areas where there is a conflict in need (e.g. areas that shows a need in one
evaluation approach and no need in the other) which are then further evaluated in
order to identify the real need. This comparison identifies small Sub-Study
Areas, which are evaluated based on the second stage criteria, which include soils
classification, groundwater levels, and a combination of system age and lot size.
Utilizing these two steps provides a comprehensive approach to determine not
only areas that require something other than the current on-site system but also
those areas that can sustain with their current on-site systems as a long-term
wastewater solution.
Although the two-stage extensive two-stage rating criteria analysis did not
identify Pocomo, Shimmo, and Monomy as areas of wastewater disposal need it
did recommend them as need areas based on their location to the Nantucket
Harbor in Section 3,”Results of the Needs Analysis Assessment”.
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• The commission recommends that the Harbor Watershed be included as a
screening criterion.
This is a criteria used in the Phase I Document as indicated in the previous
responses.
Data is not Current
• Much of the data in the Report is based on information provided by the
NP&EDC in 1997, and there is now more current data available, including the
preliminary 2000 census information.
The 2000 census information was unavailable at the time of the Phase I
publication. The 2000 census will be used in future phases of the CWRMP/EIR.
• Use current Nantucket GIS for land use extrapolation.
At the time the report was prepared, land use extrapolation was used based on the
Nantucket GIS system.
• The report states that the percent of open space on the island is 42% while
elsewhere in the document it is cited correctly as 44%
Information for socioeconomic and land use pattern data was derived from
various sources, which would account for the variations. The percent of open
space on the island will constantly change over time.
• The report represents the population density as 180. The report should reflect
that the actual density per the 2000 census is now 190.
The 2000 census information was unavailable at the time of the Phase I
publication. The 2000 census will be used in future phases of the CWRMP/EIR.
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• Cite District maps approved at the 2000 and 2001 Annual town meetings.
Future phases will reflect current data where appropriate.
• Update academic years to include the years 2000 and 2001.
Future phases will reflect current data where appropriate.
• Use 2000 Census count for housing units, which is now 9,210.
This information was not available at the time of the ENF filing nor Phase I
document filing. The new census information will be used in future phases of the
project where appropriate.
• Update building permit and building cap information through the year 2000.
Growth control measures are not a part of the CWMP/EIR planning process and
therefore secondary impacts associated to growth should be directed by local
zoning, potential special legislation, and Town bylaws.
• Cite average household size as noted in 2000 census of 2.37, and average family
size of 2.90.
This information was not available at the time of the ENF filing. The new census
information will be used in future phases of the project.
• Use latest HUD Median Household Income Statistics. For family of 4, the
Median Household Income per HUD was $75,900 for 1999.
This information was not available at the time of the ENF filing. The new HUD
statistics will be used in future phases of the project where appropriate.
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Solutions Have Growth Inducement Potential
• Nantucket should be distinguished from most, if not all, mainland Massachusetts
communities, because the entire Island is a National Historic Landmark, and it
contains vast area of rare heathland habitat.
All of Nantucket’s resources will be taken into account when developing the
Island’s wastewater treatment alternatives.
• The Nantucket Comprehensive Plan’s “Town and Country” concept would direct
growth to areas where infrastructure already exists and away from areas where
disperse patterns of development have begun to take hold.
Implementations of future CWMP/EIR recommendations will need to consider
existing Town rules and regulations and the approved Comprehensive
Community Plan with final approval coming through Town Meeting actions.
Growth control measures are not a part of the CWMP/EIR planning process and
therefore secondary impacts associated to growth should be directed by local
zoning, potential special legislation, and Town bylaws.
• The CWRMP proposes wastewater solutions in areas defined as “Town”. A
solution to public health threats in these areas my have secondary effects, such
as growth. Existing lots that are now undevelopable under Title V or the
Nantucket Health Code may be developable in the future with sanitary sewers or
package plants.
Implementations of future CWMP/EIR recommendations will need to consider
existing Town rules and regulations and the Comprehensive Community Plan
with final approval coming from Town Meeting actions. Growth control
measures are not a part of the CWMP/EIR planning process and therefore
secondary impacts associated to growth should be directed by local zoning,
potential special legislation, and Town bylaws.
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• The CWRMP/EIR should quantify the numbers of dwelling units that could
potentially be created as a consequence of the wastewater solutions, so that the
Commission can gage the consequences of this additional growth.
In Section 3 of the Phase I Document, buildout analysis projections for the study
areas identified as needs areas were presented. The analysis was based on
current rules and regulations, including zoning and state land use codes, in effect
at the time the report was prepared.
• Two Area Plans are now underway, with boundaries that have been defined by
both the Commission and the Work Groups. They may be used as a means for
calculating the population density for these areas.
In Section 3 of the Phase I Document, buildout analysis projections for the study
areas identified as needs areas were presented. The analysis was based on
current rules and regulations, including zoning and state land use codes, in effect
at the time the report was prepared. Earth Tech will make the necessary
arrangements to obtain copies of these for use in future phases of the
CWMP/EIR, where appropriate.
• The report states that the newly established Multi-family Overlay District
boundaries are designated “to reduce the environment impacts of development”
– which is not the intent of the establishment of this District. The report should
also acknowledge the existence of the Neighborhood Employee Housing and
Dormitory Overlay Districts, with the common goal of “creating affordable
housing opportunities on the Island”. These boundaries should be depicted on a
map accompanying the report, because they represent the potential for higher
density in these areas.
The goal of the CWMP/EIR is to identify areas of the island where current on-
site systems cannot be utilized for long term wastewater disposal. Growth issues
will be identified for study areas that are identified as need areas. Growth control
measures are not a part of the CWMP/EIR planning process and therefore
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secondary impacts associated to growth should be directed by local zoning,
potential special legislation, and Town bylaws. Earth Tech will make the
necessary arrangements to obtain copies of these for use in future phases of the
CWMP/EIR, where appropriate.
• On Nantucket, there are significant sanitary sewer facilities that are under
private control. The CWRMP/EIR needs to quantify the miles of public sewer
versus private. The CWRMP/EIR should also designate which private sewer
systems are priority areas for acceptance by the Town, on the basis of public
health needs, or because these private sewers are the gateways to logically
providing sanitary sewer service to other areas.
An analysis of the private sewer systems is not part of the scope of work for the
CWMP/EIR project since public funds cannot be utilized for private property
purposes. Any alternatives identified in the Phase II document that would benefit
the Town by accepting private sewers as public sewers will be considered.
• The report describes the Town – WPZ Area as having a relatively low density.
Because of the characteristics on this mixed-use zone, there are certain areas
within the zone that are low density, but others are quite high, due to the 5,000
s.f. minimum lot size (Naushop is an example). The area also contains several
Multi-family Overlay Districts that can permit up to double the underlying zone
density.
A description of a study area is based on the predominate land use is either high
or low density and not an exclusion of land use classifications.
• The report uses the average rating as a threshold for determining whether a
needs area would receive priority consideration. On what basis is the average
the determinant of need?
To define how the “average rating “ was determined, one first needs to
understand how all the ratings were arrived at. A Town-wide needs analysis was
performed to determine whether or not conventional Title 5 septic systems will
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be effective in disposing of wastewater within a given Study Area throughout and
beyond the 20 year planning period. A comprehensive two stage approach was
utilized in the analysis consisting of: (1) a rating criteria matrix created to
establish or eliminate a Study Area as a need area (community provided data);
and (2) an evaluation of each Study Area based on soils classification,
groundwater levels, and a combination of system age and lot size (reality data) to
confirm or eliminate a Study Area as a need area. During the first stage, a rating
criteria matrix was developed which consists of four levels of criteria that are
assigned rating points. The information gathered in this first stage is the
“Community” information or data on file within the community such as Board of
Health Records (Title 5 reports, system repairs, system pumping records, perc
test information etc.), Assessor records (lot size, age, density of properties, resale
records, locations to wetlands and surface water bodies, etc.) and Water
Department records (aquifer protection districts, proximity to wellheads, billing
records for water use, etc.). The more comprehensive the data is which exists on
file in the community, the more detailed the first stage analysis becomes and vice
versa.
The highest rating is be given to actual failures compiled from Board of Health
records. The second highest rating is given to categorical failures based on
current Title 5 regulations. The third highest rating is given to septic systems
that are at risk for failure/noncompliance, which are septic systems that: (1) have
severe groundwater limitations; (2) have severe soil limitations; (3) have septic
systems that were built before 1978; (4) have a lot size of one-half acre or less;
and/or (5) have two or more septic tank pump-outs occurring within a calendar
year. The fourth highest criteria is given to septic systems that have health/water
quality issues associated with septic systems located: (1) in a Study Area with a
density of septic systems greater than two per acre; (2) within 100 feet of a
surface water body; (3) within a 100 year flood plain; and (4) within a Zone II
aquifer recharge area. This “Community” data was compiled for each delineated
Study Area and a rating number was established based on the sum of this
information from the matrix normalized based on the number of developed lots
which exists within the given Study Area. The average rating number for all the
Study Areas represents the average conditions within the community. The
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largest “breakpoint” in the rating numbers is determined from the range of all the
Study Area “rating numbers”. Study Areas which have “rating numbers” greater
than the “breakpoint” are flagged as “indicators” that the Study Area requires a
closer look. The closer look consists of applying a second stage analysis or an
additional set of criteria to evaluate.
During the second stage of the analysis, each Study Area is evaluated based on
soil classification, groundwater levels, and a combination of system age and lot
size or in total “reality data”. The three qualifying criteria are: (1) 50 percent or
more of the lots within the Study Area meeting the age/lot size criteria (built
before 1978 and a lot size of one-half acre or less); (2) 30 percent or more of the
Study Area having severe soils limitations (hardpan, bedrock, slope, flooding and
wetness); and (3) 20 percent or more of the Study Area having severe
groundwater limitations (seasonally high water table at the surface to 2 feet
deep). If two of these three criteria are met, then the Study Area is determined to
be a need area.
A thorough side by side comparison of the results of the two evaluation methods
is made to determine: (1) if a given Study Area shows consistent need; and (2)
areas where there is a conflict in need (e.g. areas that shows a need in one
evaluation approach and no need in the other) which are then further evaluated in
order to identify the real need. This comparison identifies small Sub-Study
Areas, which are evaluated based on the second stage criteria, which include soils
classification, groundwater levels, and a combination of system age and lot size.
Utilizing these two steps provides a comprehensive approach to determine not
only areas that require something other than the current on-site system but also
those areas that can sustain with their current on-site systems as a long-term
wastewater solution.
• The report makes statements concerning the percentage of soils in the needs area
that have specific limitations. Each needs area should be profiled on the basis of
how much of the needs area is preserved as open space; how much of the
developed portion of each needs area has soils with limitations; and finally how
much of the undeveloped land has soils with limitations.
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Soil interpretations were based on developed lots in each Study Area and not on
the undeveloped land.
• Clarify whether the household size for the peak season is applied to both year-
round and seasonal residences for the summer months. The higher household
size seems appropriate given the pattern of seasonal employee rentals and
houseguests for much of the year round population throughout the peak season.
The analysis was applied to both round and seasonal residences for the summer
months.
• Why were the Innovative/Alternative (I/A) systems dismissed as feasible options
to serve the wastewater needs of the needs areas removed from sewered areas?
This conclusion unfairly dismisses the fact that there are a diversity of soil
conditions and lot sizes throughout each of these needs areas, and that I/A
systems may be feasible on some lots, while conventional Title V solutions may
be the only option on others.
The Study Areas presented in the Phase I document were evaluated for
wastewater need based on the two-stage rating criteria matrix. Utilizing these
two steps provides a comprehensive approach to determine not only areas that
require something other than the current on-site system but also those areas that
can sustain with their current on-site systems as a long-term wastewater solution.
A Study Area identified as an area not to have a wastewater disposal problems
indicates that a majority of the study area can utilize on-site wastewater disposal
systems. Some lots within the study area may need to utilize
Innovative/Alternative (I/A) systems to address their individual problems but it
would be financially cost prohibitive for the Town address these random lots.
This would involve a lot-by-lot analysis for these area that would involve an
extensive and costly analysis which was not included as a part of the scope for
this CWMP/EIR. This type of analysis may be useful as implementation under a
Septage Management Plan under the jurisdiction of the local Board of Health.
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• Why has only passing mention been given to Solar Aquatics Technology as a
possible solution for neighborhoods with relatively small discharge volumes?
Solar Aquatics Technology was rated along with 13 other technologies and was
not considered to be feasible for the Town based on a number of criteria. The
rating criteria included Technical Factors, Environmental Factor, Institutional
Factors, and Economic Factors. This discussion began on Page 7-1.
• The CWRMP/EIR should acknowledge the Nantucket’s trash composting facility,
which accepts sludge from the existing Surfside plant.
The Phase II document will acknowledge that residuals generated at the Surfside
Wastewater Treatment Facility are processed at the Town’s Municipal
Composting Facility during the discussion of residual disposal for the wastewater
disposal alternatives.
• The CWRMP/EIR should acknowledge that the Town has designed and is
considering constructing a sanitary sewer extension in the Monomoy needs area.
At the time the Phase I report was prepare this was not a consideration.
However, the Phase II document will present the expansion of the wastewater
collection system into the Monomoy study area as the alternative for the study
area.
7. November 8, 2001, Letter from Michael Glowacki, Chairman, Town of Nantucket
Conservation Commission.
The Conservation Commission’s comment letter supports the phased CWRMP/EIR
approach and includes some concerns about coordination, additional alternatives and
public participation.
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• Coordination with other town boards and agencies, particularly with the
Nantucket Harbor Watershed Working Group, the Conservation Commission,
etc. needs improvement with respect to Phase II efforts, so that necessary
technical information and community awareness information may be
incorporated.
Earth Tech and the Town recognize this and has made efforts in the past to
include stakeholders. Public participation is a very important part of the planning
process, which includes the public as well as regulatory agencies, Town boards
and committees, and other interested parties. It is critical during preparation of
the Phase II document that all of the stakeholders be involved in order to present
a recommended plan which is cost effective, technically sound, economically
feasible, environmentally receptive, and publicly acceptable. This also allows a
sharing of information that ultimately provides a cost savings to the Town. For
example, the CWMP/EIR project provided the Harbor Watershed Group for
Madaket harbor a significant amount of data that should save hours of time and
money as well.
• Information relative to “alternatives for wastewater disposal” needs to be
updated to incorporate performance based innovative/alternative system data
now available with respect to onsite sewage disposal design, and evaluated to
characteristics specific to Nantucket as the Phase II EIR proceeds.
The Phase II document will incorporate updated information for alternatives that
result in the use of innovative/alternative systems.
• Expand the public participation program to effectively reach out to the 12
geographic area identified, and to all relevant local regulatory agencies.
The Town agrees with this statement and has included a Public Participation
program throughout the entire planning process. Public participation is vital to
the project. All meetings are open to the public being either posted and/or
advertised. Public forums and public meetings will be held during each phase of
the planning process. Public depositories will be established at three locations in
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the Town. These depositories provide the public with a complete summary of the
project and include a sign-up sheet for any interested party wishing to be placed
on a mailing list. Public participation is welcomed and encouraged at any point
in the process.
8. November 7, 2001, Letter from Cormac Collier, Ecologist, Nantucket Land Council, Inc.
The Nantucket Land Council’s comment letter is supportive of the CWRMP/EIR, but
does list specific concerns with the effects of sanitary solutions on future growth, the
inclusion of watershed delineations, and alternative technologies.
Effects of Sanitary Solutions on Future Growth
• Existing lots that are now undevelopable under Title V or the Nantucket Health
Code could be developed if a functional sanitary solution is found. It is therefore
necessary for the CWRMP/EIR to quantify the number of lots that would be made
developable by the proposed sanitary solutions. What would be the associated
costs to the municipal budget for maintaining the infrastructure that supports
such development, i.e., street and sewer maintenance, schools, fire, police,
landfill, municipal offices, etc.
The goal of the CWMP/EIR is to identify areas of the island where current on-
site systems cannot be utilized for long-term wastewater disposal. Growth issues
will be identified for study areas that are identified, as need areas. Growth
control measures are not a part of the CWMP/EIR planning process and therefore
secondary impacts associated to growth should be directed by local zoning,
potential special legislation, and Town bylaws.
The Phase II document will provide a cost effective analysis for the alternatives
present to address that areas of wastewater disposal need.
• How would an increase in buildout affect the already unacceptable nutrient
loading numbers when it comes to fertilizer leaching and stormwater runoff?
What are the thresholds each area can withstand if additional lawns are created
and additional roads are constructed?
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A nutrient analysis will be performed during the preparation of the Phase II
Document based on current DEP rules and regulations.
Inclusion of Watershed Delineations
• The Nantucket Harbor Watershed District was established by a vote at the 2000
Annual Town Meeting. The individual areas of need within the Harbor
Watershed District should be expanded to include the entire district. By looking
at the entire Harbor Watershed District as an area of need, every sanitary system
could be analyzed and thus all wastewater inputs to the harbor could be
evaluated. The same watershed framework could be used when performing a
needs analysis in the Madaket harbor area.
Section 3,”Results of the Needs Analysis Assessment” defines this as a criteria
parameter, indicates in any or all of the study area is located within the Harbor
Watershed District, and indicates the approximate number of on-site systems
located within the Harbor Watershed District.
• According to the CWRMP/EIR Needs Analysis, several areas have criteria
ratings below the threshold number including the areas of Cisco and Miacomet
and surrounding portions of “Other “ study area. However, these areas are
significant because they make up large sections of two separate watersheds, the
Hummock Pond and the Miacomet Pond watershed. Both ponds have elevated
nutrient levels most likely in part due to surrounding septic systems. It is
important to evaluate the health of the waterbodies as directly correlating to the
number and type of septic systems in each watershed. The projected affect on the
corresponding water bodies under buildout conditions must be estimated and
discussed.
This issue was raised during a public meeting held July 29, 1999. A reevaluation
of existing Board of Health data revealed that Cisco and Miacomet were not
areas of wastewater disposal need.
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Alternative Technology
• The CWRMP/EIR mentions that I/A systems may be a solution for some needs
areas, but when they are assessed as a whole the I/A systems are discouraged as
treatment options. Recommended solutions for each need area should, combine
a variety of options, including on site I/A systems, communal wastewater
treatment systems, and Conventional Title V systems. An assemblage of systems
may be the best long term goal for some of these areas because hydrological and
soil conditions vary widely throughout individual need areas.
The Phase I document has only identified areas of wastewater disposal need
beyond on-site Conventional Title 5 systems. Specific language included in
Section 3 states, “On-site innovative alternative systems, local or satellite
wastewater systems are all presently viable alternatives for effectively addressing
the wastewater needs in this study area”. This will further be analyzed during the
Phase II, Screening of Alternatives for each study area identified as an area of
need in the Phase I document.
• The Phase I document discusses the potential of aquaculture, constructed
treatment wetlands, and solar aquatic technology as potential wastewater
treatment solutions. However, they were discounted based on screening for
technical, environmental, and institutional factors. It appears that the screening
criterion for these options is based on a generalized view of each need area and
not on a lot-by-lot or neighborhood basis. Neighborhoods with smaller
discharge volumes might be conducive to such systems. A greater consideration
and more site-specific analysis should be employed to determine the feasibility of
their use.
The CWMP/EIR is not based on a lot-by-lot analysis. Further consideration of
these alternatives is not cost effective for the Town for addressing long-term
sustainability. The goal of this planning process is to present a recommended
plan which is cost effective, technically sound, economically feasible,
environmentally receptive, and publicly acceptable.
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9. November 12, 2001, Letter from Dale G. Stoodley, President, Nantucket Community
Association (NCA).
The NCA is concerned about several issues relating to the CWRMP/EIR. The comment
letter includes comments concerning the Nantucket Comprehensive Community Plan,
growth issues related to wastewater alternative, most recent data, failure rates of proposed
alternatives, the CWRMP/EIR schedule, and the Nantucket Island Historic District.
• The CWRMP/EIR should be developed in conformity with the Guidelines
established in the Nantucket Comprehensive Community Plan approved at the
Nantucket Town Meeting of January 5, 2001.
Town records indicate that only Article 5 relating to “Customary Home
Occupation” was approved at the Nantucket Special Town Meeting of January 5,
2001. The implementation of the “Town and Country Overlay District” concept
was not approved at the Nantucket Special Town Meeting of January 5, 2001.
• One or more of the technologies proposed as possible solutions could lead to the
inducement of problematic growth on the Island. The use of one or more of the
technologies cited would permit building on a number of currently unbuildable
lots. The CWRMP/EIR should estimate the number of lots which could be built
upon resulting from the use of such technologies as well as any correlated
impacts such as increase in traffic on the Island, increase in school population,
etc.
The goal of the CWMP/EIR is to identify areas of the island where current on-
site systems cannot be utilized for long-term wastewater disposal. Growth issues
will be identified for study areas that are identified, as need areas. Growth
control measures are not a part of the CWMP/EIR planning process and therefore
secondary impacts associated to growth should be directed by local zoning,
potential special legislation, and Town bylaws.
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• The CWRMP/EIR should note that the current building cap, which has dampened
some growth in the past, expires on January 1, 2002. The effect of the removal of
the cap on the future Island wastewater needs should be explored.
Growth control measures are not a part of the CWMP/EIR planning process and
therefore secondary impacts associated to growth should be directed by local
zoning, potential special legislation, and Town bylaws.
• The CWRMP/EIR should use the most recent data, such as the U.S. census data
and interim data developed by consultants such as Howard/Stein-Hudson
Associates, Inc. and RKG Associates’ Optimal Carrying Capacity of Nantucket,
Year 2001 Update.
The Phase I document used information fromvarious socioeconomic data sources
including but not limited to the 1990 U.S. census, MISER, Massachusetts DOR,
Massachusetts DLS. The 2000 U.S. census was not available at the time of the
ENF filing nor the CWMP/EIR Phase I filing.
• The data, which supports the annual rainfall assumptions for the groundwater
recharge on Nantucket, is dated 1941-1970. The basis for this data should be
reviewed to determine if more recent information from that or other sources is
available.
This will be a consideration for future phases where appropriate.
• In light of the significant failure rate of septic systems on Nantucket, the
CWRMP/EIR should set forth information on expected failure rates of any
proposed alternative wastewater treatment systems. In Phase II, the
CWRMP/EIR should include a cost benefit analysis for each proposed system as
an aid in system evaluations.
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The Phase II document will present a recommended plan, which is cost effective,
technically sound, economically feasible, environmentally receptive, and publicly
acceptable. All proposed alternatives will include a cost benefit analysis
throughout the 20-year planning period.
• A schedule should be established for completion of each phase of the
CWRMP/EIR. Taking into consideration public participation, consultant
activity, regulatory review, time for acquisition of land and construction lead
time, it might be reasonable to estimate that the final EIR would not issue until
2006-2007. The NCA suggest that consideration be given to extending the
planning horizon to a more realistic date.
The Phase II document will present a recommended plan, which will include A
schedule for implementation of the recommended plan will be presented. This
schedule will detail the design and construction of the recommended wastewater
facilities and will also include any plan to phase construction of these facilities.
• The CWRMP/EIR should include, as part of the cost-benefit analysis, a complete
evaluation of the impacts of construction on the Nantucket Island Historic
District including historic properties, architecture and other features.
The Phase II document will present cost estimates for the alternatives and will
take into consideration the impacts of construction on the Nantucket Island
Historic District including historic properties, architecture and other features.
• The NCA is concerned that the increasingly serious health and environmental
risks to Nantucket residents are expected to extend for many more years. An
interim study should be immediately undertaken as part of Phase I to determine
more precisely what growth control measures are needed to be put in place
promptly to protect against any dangers to the Island’s aquifer, groundwater and
other public health related concerns.
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The goal of the CWMP/EIR is to identify areas of the island where current on-
site systems cannot be utilized for long term wastewater disposal. Growth issues
will be identified for study areas that are identified as need areas. Growth control
measures are not a part of the CWMP/EIR planning process and therefore
secondary impacts associated to growth should be directed by local zoning,
potential special legislation, and Town bylaws.
10. September 14 2001 and October 23, 2001, Letter from Sylvie O’Donnell, Nantucket
Resident.
Ms. O’Donnell’s comment letter addresses the Nantucket Municipal Landfill. She feels
that the CWRMP/EIR should address the impact of the municipal landfill on water
quality in the Madaket area.
• For the past three years, chemically treated sludge from the Surfside sewage
disposal facility has been disposed of in the landfill. During those three years,
the Nantucket Marine Department Superintendent has noticed a significant
deterioration of water quality in Long Pond. The Nantucket landfill is adjacent
to Long Pond in the southeastern boundary of the Madaket areas. Long Pond
flows into Hither Creek and Madaket Harbor through Madaket Ditch. Hither
Creek is classified in the Phase I as an area of “high concern”. Any proposal
that attempts to remedy the problems of Hither Creek and Madaket Harbor
without looking at the impacts of the landfill and the boatyard cannot be an
adequate long-term plan for Nantucket.
The Phase II scope of work will identify alternatives to study areas of wastewater
disposal need and will evaluate their impact based on various screening methods
and conducting hydrogeologic testing. The impacts from the Nantucket landfill
will be considered if any wastewater disposal sites are identified in the area.
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