SAND has responded to a recent update filed by the Massachusetts Water Resources Authority regarding sewage outflow issues in the South Boston waterfront.

Mr. Bob Durand, Secretary
Executive Office of Environmental Affairs
100 Cambridge Street
Boston, MA02202
attn.: Mr. Douglas Vigneau, MEPA Unit
Dear Mr. Vigneau,

SAND appreciates work to date by the MWRA to reduce CSOs and improve water quality. The magnitude of the problem we've inherited and the remarkable improvement in Harbor water quality to date can hardly be overstated, and deserves our grateful recognition. However, we are concerned that the current plan will create a condition where the Reserved Channel can never approach the water quality or swimmability of Dorchester Bay.

We would prefer to be discussing a proposal which made the elimination of all CSOs throughout the region, and maximized water quality throughout the Boston Harbor basin, an absolute priority. There is no level of filtration or treatment which is a successful substitute for the avoidance of CSOs altogether.

We want to encourage all efforts to eliminate surface runoff to Boston Harbor, with CSOs receiving priority attention. Substantial reductions in volumes of both should be readily achievable with aggressive attention towards minimizing water use and increasing the amount of porous ground surfaces, to reduce impacts at their sources. Efforts spent in this regard can be recouped in the avoided costs of new and upgraded services.

SAND is concerned that the new outfall from the Convention Center will combine with existing lines which contribute CSOs to the Reserved Channel. Though the proposed Convention Center will not itself generate new CSOs (as stated in its EENF), its contribution to a conduit of existing CSOs (which should be attenuated) will result in additional CSO introductions to Boston Harbor. These CSO occurrences of at least once a year, rather than in 5 year storms as per Dorchester Bay outfalls, is clearly inappropriate. When seen in the lesser ability of the Reserved Channel to both dilute and flush CSO introductions at its furthest reach, this Project Change, though an improvement over the prior proposal, still appears to be unacceptable and in need of substantial upgrading in terms of storage and treatment., at a minimum

We encourage employment of alternate methods to reduce stormwater mixing into CSO lines, in addition to separate lines. Grey water systems, percolation to ground, irrigation of plantings, fountains and pools would all be creative approaches. We would advocate all methodologies that would prevent new stormwater from increasing flow demand in a line which will include CSOs at any time. We would also appreciate discussion of the potential for installation of separators and the water quality benefits that could be derived.

The greater the volume of stormwater that can be removed from CSO conduits, the greater the storage capacity, and lesser likelihood, frequency and severity of CSOs that will be introduced to the waterway. Consideration should be given towards increasing the capacity of the stormwater outfall of the proposed Convention Center and routing all local roof and surface flows that cannot otherwise percolate into the soil to that line.

SAND would like to see the elimination of any sewage interconnections upstream of outfall BOS076, removing it as a source of CSOs to the Reserved Channel. Any reconstruction of that conduit should permit the extension of the existing South Boston street grid out into the South Boston Waterfront, as called for by SAND, the Boston Society of Architects, and the Boston Redevelopment Authority, among others. Proper installation of infrastructure will encourage future development to be supportive of the continued growth of the existing community and its reclamation of the waterfront. There may additionally be a need to clarify some of recommended action as neither figures 6 nor 9 identify the location of RE076/3-3, as noted on page 30.

We appreciate the proposed location of the odor control facility away from residences and away from immediate waterfront. The waterfront should available to be used for its maximum recreational and open space potential, unencumbered by noxious odors.

We prefer all work to be done in a manner that will preserve and reinforce the existing street grid, impact the existing community to the minimum extent possible, and preserve and maximize the opportunities for future evolution and expansion of the residential community and local industry. Coordination of the precise alignment should be made with the community, appropriate City agencies and landowner(s) to ensure that any alignment and easements form the basis for future rights of way.

Specific transportation management plans should be required for each area and phase of work, developed with community and BTD input, to minimize the impact of diverted traffic onto local residential streets, particularly in areas where there are concentrations of children.

SAND would like to see BWSC set a specific and aggressive timetable for the full separation of all existing and future sewers in this district, in concert with MWRA initiatives. We would suggest that this is the appropriate moment to make these plans, before individual development projects restrict opportunities to make system-wide improvements. By providing ample capacity, particularly for separated stormwater conduits, new and appropriate development in the district will be facilitated and accelerated.


Jon Seward
on behalf of
The Seaport Alliance for a Neighborhood Design

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