Final
Environmental
Impact Statement
WASTEWATER COLLECTION AND
TREATMENT FACILITIES
Cranston*  R.I
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FINAL

ENVIRONMENTAL IMPACT STATEMENT

on the

PROPOSED TREATMENT AND COLLECTION SYSTEM
for the
CITY OF CRANSTON,  RHODE ISLAND


DATE:      June 1. 1977	
 Prepared by:

      U.S. ENVIRONMENTAL PROJECTION AGENCY
      Region 1
      JFK Federal Building
      Boston, MA 02203

      CITY OF CRANSTON
      City Hall
      Cranston,  Rhode Island

 With Technical Assistance by:

      CE MAGUIRE,  INC.
      Architects  Engineers  Planners
      Providence Waltham  New Britain
 Responsible Officials:
John A. S. VfcClennon ^   // ***''     /James L. Taft,
Regional Administrator                 ^ Mayor
Environmental Protection Agency          City of Cranston, Rhode Island
Region 1

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                     CONTENTS OF FINAL EIS
EXHIBIT   DESCRIPTION
  A

  B
   E

   F
SUMMARY SHEET FINAL

ISSUES RAISED IN RESPONSES TO THE
DRAFT EIS
THE DRAFT EIS
Published October 18, 1976

PUBLIC HEARING SUMMARY

LETTERS OF COMMENT ON THE DRAFT EIS
SECTION
PAPER COLOR

Yellow

White
           ERRATA & ADDENDA, THE DRAFT EIS,        Green
           SIGNIFICANT TO UNDERSTANDING OF ISSUES
Gold & Yellow


White

White

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         EXHIBIT A


         SUMMARY SHEET
   Draft or Final:
          FINAL

   Agency:
          ENVIRONMENTAL PROTECTION AGENCY
          REGION I

7.  Action:
          Administrative

2.   Description:
          Includes consolidation, improvement and expansion of wastewater
          treatment facilities in the City of Cranston, a portion of Providence
          County in the State of Rhode Island

3.   Anticipated Impacts:
          Principal effects include:
              a.   improved water quality in the Pawtuxet River,
              b.  expansion of economic base and housing supply, and
              c.   elimination of odor nuisance.

          Adverse effects include:
              a.   small  increases in fuel  use in, and air pollution from, solids incineration,
              b.  accelerate conversion of 7 square miles of forest and farm land to
                  urban uses, and
              c.  accelerate creation of substantial increases of traffic and traffic noise
                  in the once rural areas.

 it.  Alternatives Considered:
           Alternatives considered included:
              a.  alternative methods of wastewater treatment,
              b,  alternative methods of treated effluent disposal including land
                  application in western  Cranston and piped discharge into the
                  ocean, i.e.  the Providence River estuary,
              c.  alternative methods of  solids  disposal including sanitary landfills
                  and pasteurization and land application as a soil conditioner/fertilizer,
              d.  the alternative of not extending the sewer system into now rural
                  lands, and
              e.  the alternative of more aggressively extending the system.

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5.   Agencies from which Comments on  this Draft Statement have been  Requested
            Advisory Council on Historic Preservation
            American Littoral Society
            Appalachian Mountain Club
            Aquidneck Island Ecology
            Audubon Society of Rhode Island
            AWARE. Inc.. Nashville. Tenn.
            Blackstone River Watershed Association
            Conservation Law Foundation
            Cranston Historical Society
            Ciba-Geigy Corporation
            City of Cranston
            Cranston City Council
            Cranston Today
            Coastal Resources Management Council
            Council on Environmental Quality
            Town of Coventry
            Ecology Action for Rhode Island
            Environmental Council of Rhode Island
            Governor's Council on Environmental Quality
            Historic American Engineering Record, Rl
            Town of Johnston
            League of Women Voters of Cranston
            League of Women Voters of Rhode Island
            National Wildlife Federation
            New England Interstate Water Pollution Control Commission
            New England Interstate River Basins Commission
            City of Providence
            Providence Journal - Bulletin
            Rhode Island Association of Conservation Commissions
            Rhode Island Governor's Office,  Policy and Program Review Section
            Rhode Island Historic Preservation Commission
            Rhode Island Department of Health
                  Division of Air Pollution Control
                  Division of Solid Waste Management
                  Division of Water Quality and Pollution Control
            Rhode Island Department of Natural Resources
            Rhode Island Department of Community Affairs
            Rhode Island Department of Transportation.  Planning Division
            Rhode Island Office of the Attorney General
            Rhode Island Statewide Planning  Program
            Rhode Island "208"  Program
            Rhode Island Department of Administration,  Budget Division
            Rhode Island State Association  of Conservation Districts
            Rhode Island TB and RD Association
            Rhode Island Water Resources Board
            Save the Bay, Inc.
            Town of Scituate

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          Sierra Club. New England Chapter
          City of Warwick
          Town of West Warwick
          U. S. Environmental Protection Agency
          U.S. Department of Health, Education and Welfare. Regional Environ-
          mental Officer
          U. S. Coast Guard. First District
          U.S. Department of Housing and Urban Development, Regional Admini-
           strator
           U.S.  Department of Interior, Northeast Regional Coordinator
           U. S.  Department of Interior, Assistant Secretary for Program 6 Policy
           Bureau of Sports,  Fisheries & Wildlife, Northeast Regional Administrator
           National Parks Service, District Chief
           Federal Aviation Administration
           Federal Highway Administration, Regional Administrator
           Farmers Home Administration
           United States Geological Survey. Boston
           U. S. Army, Corps of Engineers, N. E, Region
           U.S. Department of Agriculture. State Conservationist
           U.S. Department of Agriculture, Agricultural Stabilization and Conserva-
           tion Service
           National Oceanic and Atmospheric Administration, Office of Ecology and
           Environment Conservation
           U.S. Department of Commerce,  Deputy Assistant Secretary for Environ-
           mental Affairs
           Honorable John O. Pastore
           Honorable Claiborne deB .  Pell
           Honorable Fernand J . St. Germain
           Honorable Edward P. Beard


6.   Agencies  which  have Contributed to  the Formation  of this Statement:


           Rhode Island Department of Health
                 Division of Water Quality and Pollution Control
                 Division of Air Pollution Control
           Rhode Island Department of Natural Resources
                  Division of Fish and Wildlife
                  Division of Forest Environment
                  Division of Planning and Development
            Rhode Island Statewide Planning Commission
            Rhode Island Historic Preservation Commission
            Historic American Engineering Record, Pawtucket. Rhode Island
            U.S. Department of Agriculture. Soil Conservation Service, West Warwick, Rl
            City of Cranston
                  Department of Public Works
                  Planning Commission
                  Sewer Department
                  Conservation Commission
            Cranston Historical Society, Mrs. Gladys Bray ton
            Mr. Kenneth M. Mowry, Sr.,  resident of western Cranston
             Mr. JohnT. Sollars, resident of Cranston
             Ciba-Ceigy Corporation

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7.     Public Input to this Statement:
             Prior to preparation of the Draft EIS a public workshop was held
             at Cranston City Hall on 1/20/76.  Issues discussed included:

                   a.     odor problems in the Pontiac Avenue area,
                   b.     sludge transportation problems,
                   c.     extension of sewers into adjoining areas of Warwick,
                   d.     coordination with regional and statewide planning, and
                   e.     extension of the urbanization problem analysis beyond
                          the area of proposed sewerage extension.

             After publication of the Draft EIS a public hearing was held at the
             Hugh B. Bain School in Cranston on 11/18/76.  Issues raised at
             the hearing are described in Exhibit E, appended below.

             Letters received in response to the Draft EIS are appended  below
             in Exhibit F.
      WRITTEN COMMENTS RECEIVED ON DRAFT EIS
                                                 Issues Raised
     U.S. Environmental Protection Agency

     U.S. Department of Housing e Urban Development

     U.S. Department of the Interior

     U.S. Department of Agriculture

     U.S. Department of Transportation

     U.S. Department of Commerce

     R.I. Statewide Planning Program

     R.I. Historical Preservation Commission

     Cranston Conservation Commission

     Cranston League of Women Voters

     Ecology Action for  Rhode Island

     Concerned Citizens for Cranston's Future

     Robert A. Flynn, Sr., Cranston, Rhode Island

     Ciba-Ceigy Corporation
1 . Water Quality
*





*
*



*



2. Loss of Farm Productivity




*




*
*
*



3 . Population Forecasts
*
*





•





*


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    EXHIBIT B

    ISSUES RAISED IN RESPONSES TO THE DRAFT EIS

B.I INTRODUCTION

    The public and interagency  responses to circulation of the Draft EIS raised
    a number of issues whose significance appears to warrant discussion beyond
    that offered in the Draft EIS. These issues include:

    a.    Water Quality Classification:  Is the degree of treatment proposed for
          Cranston's wastewater justifiable both environmentally and economically?

    b.    Farms  and Farm Productivity:  Would the loss of farmland be more ad-
          verse than the effects described in the Draft EIS?

    c.    Population Forecasts: A number of questions including requests for
          specific numbers for specific future dates, differences in the size of fore-
          casted increases, agreements in the size but differences in the reasons,
          and, perhaps most importanct, the question of whether it is the purpose
          of the proposed action to serve inevitable  growth or to attract growth?

    d-    Land  Use: A number of questions about the land uses assumed in the
          assessments of impacts and in the  proposed mitigating actions.  Perhaps
          the most important issue here, in an environmental  planning sense,
          albeit not so as a matter of public discord, is whether "open space"
          should be provided in urbanizing  areas in a manner other than proposed
          in the Draft EIS.

    e.    Archeological  Resources:  The Rhode Island Historical Preservation Com-
          mission pointed out the need to follow up on protection of possible arche-
          ological resources in the design and construction phases of the project.

    f.    Institutional Problems:  The Draft EIS proposed a number of mitigating
          actions that could be taken to offset some of the adverse impacts of the
          proposed project.  A number of correspondents questioned how the miti-
          gating actions might be accomplished.

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B.2  WATER QUALITY CLASSIFICATION

     The existing condition of the Pawtuxet River in the worst reach below the
     Cranston Wastewater Treatment Plant is Class "E".  (See Chapter III of the
     Draft EIS for definitions, locations, and criteria).  The proposed condition
     of that reach, and its next adjoining reach upstream, has been classified by
     the State of Rhode Island as Class "D". This classification was the ostensible
     goal of the Cranston proposal. However, just prior to publication of the
     Draft EIS, a computer model of water quality in the Pawtuxet was completed.
     That model appears to indicate that Class "C" may be "attainable" in the worst
     reaches if all the discharges on the river are raised in quality to that proposed
     for Cranston's.

     This most recent revelation raises a number of questions including:

     1.    Should the river classification in the reaches below the Cranston dis-
           charge be raised from Class "D" to Class "C"?

     2.    Should the Cranston treatment process be required to be even more
           effective than that proposed to achieve Class "C"?

     3.    Would Class "D" be attainable with a less elaborate and presumeably
           less costly treatment plant for Cranston?

     4.    And finally, as a frame of reference, is Class "E", the existing condition,
           adequate for the uses to which the river is to be put, or should the river
           be improved to Class "B"?

     Taking these questions in reverse order:

     1.    on reclassification as Class "B": -- Reclassifying to Class "B" is not
           possible without eliminating all industrial and municipal waste discharges
           into the river.  This does not appear to be economically or institutionally
           feasible for the foreseeable future.

     2.    on reclassification as Class "E":  —The Pawtuxet River flows through both
           residential and historic neighborhoods.  The odors that would arise from
           time to time from Class E waters would be unacceptable.

     3.    on maintaining Class "D": — The principal foreseeable recreational and
           habitat use of the  river is for the seasonal passage of anadromous fish.
           Since these fish would normally use the  river during high to moderate
           flow conditions, the annual low flows that are used for calculating classes
           "C" 8 "D" are not particularly relevant,  or said differently, there is  little
           difference between these classes so far as the highest likely use of the
           river is concerned (see Table B-l) .

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                                                                        Table B-1
Class!-  Minimum Dissolved  Said to be
fication  Oxygen in once in   Suitable
        10/yr.             for	
         7 day low flow

   A    5 mg/1 or more    drinking
                                               ENVIRONMENTAL EFFECTS OF WATER QUALITY CLASSIFICATIONS
                                                                           Duration of Actual Suitability for
                                    Drinking
Swimming1  Non-Migratory
           Fish Habitat
                                  at all times except for    at all times* at all times*
                                  one in 100 year draught
Migratory
Fish Passage
                                                                                              at all times*
 Odor
 Condition
                                                                                                                            no odors   *
         5 mg/l or more    swimming
                                           with treatment
                                                                  at all times* at all times*
                                                                                                      at all times*
                                                                                                                                    no odors
   C     <* mg/l
                 non-migratory    never**
                 fish habitat
  never **    except for extreme
              drought periods
 every year except for
 extreme drought
 periods
                                                                                                                                     normally no odors
   D     2 mg/l
                 migratory fish     never**
                 passage
  never**     except for drought
              periods
 every year except
 during low flow periods
 which usually occur
 between June 1 £ Oct. 31.
only at times of
extreme drought
   E     1 mg/l
   E-
                          nuisance
less than 1 mg/l   nuisance
                                           never"
                                            never
                                                •**
                                                          never**    unlikely
                                                                   never**    unlikely
                           * No effluent discharge in Rl in Class A 6 B
                          ** No water supply or swimming in Class C or lower
                                       most or every year
                                       except during low flow
                                       periods which usually
                                       occurs between June 1
                                       6 October 31.
                                       most years except
                                       during low flow periods
                                       which usually occur
                                       between June 1 6 Oct. 31,
                                occasional odors from
                                June 1 to October 31.
                                frequent odors from
                                June 1 to October 31

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H     on attaining Class "D"  less expensively: - The proposed improvements
      at Cranston  (specifically the ammonia removal system) are essential to
      meeting the standards of Class "D" no matter what effluent quality is at
      tained at other discharges on the river.

5     on attaining Class "C"  by better treatment at Cranston alone: — It is
      not possible to achieve Class  "C" by further improving treatment at Cranston
      without similar improvements at all other large discharges along the river.

6.    on  reclassifying as Class  "C": — Reclassifying to Class "C" would not
      change  the proposed action at Cranston, i.e. the proposed actions are
      necessary to meet Class "D" and further improvements to the process
      of Cranston would be both very costly and ineffectual.

 In summary,  the proposed project in Cranston is consistent with achiev-
 ing the highest water quality "attainable", the water quality classifica-
 tion of the river cannot be met with any significantly less costly process,
 and reclassifying the river to Class "C" would  not change what is  "at-
 tainable" .  Essentially the issue of changing the classification from "D"
 to "C"  is irrelevant to the proposed action.

 The basis for these conclusions is outlined in Exhibit C, ERRATA  & ADDENDA,
 as "Addendum to Chapter III."

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B.3   FARMS & FARM  PRODUCTIVITY

      B.31  INTRODUCTION

            A number of responses to the comments on farms and farm productivity
            in the Draft EIS disagreed with the scope and conclusions of the Draft
            in that area.  The Draft EIS concluded ".. .the project will convert
            a relatively large amount of rural land to urban use, about 7 square
            miles,  but this is not expected to reduce long-term productivity.
            At the present time most  of this land is in small holder forest and farm.
            The forest is used only for firewood for  the most part, with the actually
            farmed lands declining year by year.  In general, the high labor costs,
            small field size, shallow  stony soils, irregular topography, excessive
            nutrient leaching, etc. limit long-term commercial agricultural value.
            Conversion to house lots, while  eliminating its commercial farming
            value, will not reduce its value for home garden crops, home fruit
            trees,  flowers and microclimatic modifiers (shade and windbreakage)
            in residential areas.  If and when this land is ultimately needed for
            food production in the very far  future, (emphasis added) the large
            populations living on it might be able to supply the intensive labor,
            presumably as a hobby,  necessary for high yields."

            The disagreement with the conclusions were not substantiated but were
            expressed as doubt of the Draft's conclusion.  The disagreement with
            the scope pointed out that CEQ has recently directed agencies to  include
             in EIS's consideration of impact of projects on "prime" and "unique"
            farmlands. Each of these issues as well as a brief note on the history of
             this issue are discussed seperately below.
       B.32 AGRICULTURAL PRODUCTIVITY

            As stated  in  the Draft EIS, preservation of lands for agriculture  is a
             complicated  issue.  Fear of hunger and  dramatic photographs of  starv-
             ing  children have exerted powerful influences on rational analysis
             of the issue.  Mathematical extrapolations of world population and food
             supplies,  from Thomas Malthus in An Essay on the Principle of Popula-
             tion  in 1798 to Jay Forrester in World Dynamics in 1971 have "proved"
             thaTdisaster lies not far into the future. The Reverend Malthus  argued
             the  logic that since populations  grow geometrically and that since
             food supplies grow arithmetically, the population of the world must
             ultimately outrun its food supply while  Professor Forrester used the
             full computer capabilities of the Massachusetts Institute of Technology
             and a very much more complex  set of extrapolative assumptions  to reach
             the  same conclusions.

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Taking these one at a time, Malthus's logic was impeccable but his as-
sumptions are not, i.e. population growth rates appear to vary  inversely
with the economic prosperity of a society (as countries become industrial-
ized and wealthier and their life expectancies increase, their birth rates
decline) and food production growth is not arithmetic but appears to be
allometrically"related to population growth with its rate varying from
somewhat less than that of population in more primitive societies to
one substantially greater than that of population in more technological
societies. The proof that Malthus was wrong  however is quite simple,
i.e.  the much larger population of the world now than in 1798 and
on the much higher food production per capita now as compared to
then.

Forrester, however, cannot be so easily dismissed since his "future"
has not yet occurred and his assumptions are much more complicated,
but he and others like him have, fortunately,  provoked much serious
scholarly examination of his thesis, much of which is included in Scientific
American's  special issues on "The Human Population" published in
September, 1974 and "Food and Agriculture" published in September,
1976, parts of which are quoted below and all of which are included
herein by reference.

In the keynote article of the 1976 issue,  which attempts to encompass
the whole of the  issue. Sterling Wortman, Vice President, Rockefeller
Foundation, first isolates food shortage as a problem of lesser developed
countries in contrast to food sufficiency or surplus in more developed
countries...  "By the end of World War II the less developed countries
had  lost their surplus... the export of grain from the developed world
to the less developed one rose from 4,000,000 tons a year in  1948 to
25 million in 1964... Since then the flow of grain... has continued
to rise... If the trends continue, the  food grain deficit (in underdeveloped
countries) will be 100 million tons per year by 1985..." He concludes
that ".. .the problem is centered in the developing (non-industrialized)
countries..."  but he also notes  that ".. .there are developing countries
that export food and a few, such as China, that are virtually self-sufficient.

As a solution for the food problems of those developing countries and
elsewhere, Wortman submits with a caution, "...  the first objective
must be to increase food production,  but more food is not enough..."
That ".. .hungry people do not have money — in the developing countries
or in the U.S. or wherever else people are hungry..." that "... there are
two components to the solution of the food problem:  increased production
of food, primarily in the developing countries, and widespread increases
in family incomes, particularly  among the poor..."

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Wortman continues that "... the higher incomes will have to come primarily
from increased productivity..., from the development of industry (.. .parti-
cularly in the ... areas where most people live) ,  from employment in con-
struction and public works, and from the generation of diverse services..."

On the expansion of food production specifically,  he warns  "... Let me
mention three nonsolutions ... that are often proposed.

1.    "Larger harvests in  ...  the U.S., Canada and Australia...," these
".. .are not a solution. . .it  (would) simply allow (undeveloped nations')
governments to put off the tedious and unglamorous task of helping their
own people help themselves".

2.    "The advent of synthetic foods ...,  " these  "... will  not be a
solution. .. they have to be bought before they can be eaten.  The
hungry have no money and the manufacture of novel foods does not
provide any increase in income for the poor..." and

3.     "The introduction  into developing countries of Western-style,
large-scale mechanized farming is also not a solution. Such methods
may be appropriate for thinly populated areas...  (but) perhaps most
important, most large scale agriculture is  less productive per unit
area than small-scale farming can be."

Continuing from this third  point, he ultimately concludes "... the only
real solution to the world food problem is for poor countries to increase
production of crops and animals — and incomes — on millions of small
farms  ..." that "...  the farmer on a small  holding can engage in  intensive,
high-yield gardening systems such as intercropping  (planting more than
one crop in the same field), multiple cropping (planting several crops
in succession),  relay planting (sowing a second crop between the rows
of earlier maturing crops)  or other techniques that require  attention to
individual plants. The (key) point is that mechanized agriculture  is
very productive in terms of output per man-year, but it is  not as produc-
tive per unit of land as highly intensive systems  are."

Note that these techniques are in fact gardening techniques, not small
farming as practiced in Rhode Island, that they are appropriate to lots
up to one acre and that they would not be necessary for  food production
in the United States for many generations or centuries or possibly never.

Note also that Wortman was concerned with food production  only, not the
totality of agricultural production described in the Draft EIS which
proposed as also having  value, "microclimatic modifiers" (shade trees
and windbreakage) .  That such non-food product of the land has value

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      to the American people was ignored by the critics of the Draft EIS.
      but that it does  in fact have such value, is attested to both by the vast
      sums spent annually for garden and lawn plants, fertilizers, tools,
      etc., and also by the society's literature which describes as a golden
      age,  a Utopian state, in I Kings 4, that there was "...  peace on  all
      sides round about.  And Judah and Israel dwelt safely, every man under
      his vine and under his fig tree..."

B.33  PRIME LANDS

      In the opinion of the State Conservationist, Mr. Austin Patrick,  the Soil
      Conservation Service's Class I and II soils should be considered prime
      agricultural lands in Western Cranston. Class I soils  are those having
      few limitations on their use for agriculture while Class II soils have moderate
      limitations including risk of erosion if cultivated,  wetness that interferes
      with  cultivation, and stoniness.

      Measurement by CE Maguire, Inc. of Soil Conservation Service  maps of
      western Cranston reveals only 130 acres of Class I soils with only 30 of
      these in the proposed sewered area and 3160 acres of Class II soils with
      only 1050 of these in the proposed sewered area.  A city-wide analysis
      by the Soil Conservation Service indicates that 65% of Cranston's Class II
      soils tend toward wetness, 25% tend toward susceptibility to erosion,
      and the balance tends toward stoniness.

      Aerial photo analysis of the proposed sewered  area, shown in Figure B-l
      reveals that, of a total of 2500 acres of presumptively  buildable land, only
      1080 acres are Class I and II combined and that, of these, about 75 acres
      are already used for housing, about 220 acres are in forest and about 260
      acres are cleared but not tilled.  This leaves a net of Class I and  II soils
      to be served by sewer of about 525 acres.

      It might also be noted of the socio-economic milieu and the land  marKet
      that surrounds  this  land  that most of this actually used "prime" land is
      within the city's existing industrial zone;  that, in the area of western
      Cranston not proposed to be sewered, there are 880 acres of Class I and II
      soils in  forest and 170 acres in golf course;  that, according to  the Statisti-
      cal Abstract of the United States, only one and one half percent of the
      United States' total land area is used for all urban purposes, and that,
      according to the Scientific American, September 1976, only 51% of North
      America's total  arrable land is actively in productive use.

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              B ~
   CLFI55 I  SOILS.  HOT FORESTED OR USED
                  FOR URBfltl PURPOSES

   ClflS5 It  50IL5,  NOT FORESTED OR. USED
                  FOR URBF1N PURPOSES

   CLR5S I^I^OILS.  FORESTED OR. USED FOR
                  URBHM PURPOSES

— flPPROXIMFITE LIMIT OF  PROPOSED SEWERED F1REFI

RIME RGRICULTURnt  LflND5
     0\ooo' iooy'     <\ooo'  I mi I*.

          map:

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 B . 34 HISTORICAL CONTEXT

      The decline of southern New England's agriculture and the issue of foster-
      ing agriculture or manufacturing is almost as old as New England itself.
      In "A History of Livestock Raising in the United States, 1607-1860,|| James
      W. Thompson for the US Department of Agriculture points out that ". . .agri-
      culture in Massachusetts was visibly declining in the first half of the eigh-
      teenth century, and the same was true of Rhode Island and Connecticut...
      Wheat was imported from New York. . .Trade, manufacturing and fisheries
      grew much more than agriculture." Further, he notes that theses on the
      relative merits of agriculture versus manufacturing were presented at
      Harvard College in 1742, 1751, 1753,  1773, 1785,  and 1787.


B.35  CONCLUSIONS

      The conversion of farmland to suburbia in western Cranston does not appear
      to pose, other than in  a very narrow, culturally-relative esthetic sense,
      any significant adverse environmental impact.  In the short term there is
      no absolute need for this land for food production and in the long term
      (generations or centuries away) the proposed action may actually increase
      it food production value.  As for the esthetics, the loss of the ability to
      enjoy an occassional scenic drive through the farm fields appears to be
      more than made up for by the ability to enjoy daily trees and flowers
      (and birds)  at one's  own doorstep.

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        Exhibit  B-1
           Boston  Globe, April 30,  1977
On   feeding    the   world
Specialist forecasts 5-fold increase in crops
By Loretta McLaughlin
Globe Staff
   NEWPORT, R.I.—After decades  of
predictions that famine would sweep the
world, mankind has won a respite from Roger
Revelle, head of Harvard's Center for Popula-
tion Studies.
   An  astounding  turnabout in  food
production "brings the overwhelming hope
that the world population can now taper off
and  be amply supported by  presently
foreseeable resources," according to Revelle, a
world authority on the demographics of food
" supplies.
   He told a Tufts Medical School alumni
meeting  here yesterday  that  sufficient
arable land has been identified to increase
world crops to five times the amount now
reaped annually.
   The yield will be enough, he said, to feed
a world population that is expected to grow
from  its present four-plus  billion to 10
billion by the year 2050.
   Moreover, in the years ahead, Revelle
 said, areas of the world that have had to beg
 the greatest quantities of  food to forestall
mass starvation will  become the  new^
 breadbasket nations..
   "The southern Sudan, the great plains of
 Central Africa," he said, "could grow enough
 food to feed the present world population all
 by itself. And the Ganges plains of India
 turn out to be one of the most fertile regions
 on earth, capable of producing as  much
 food—400 million tons of grain per year—as
 all of the US wheat lands."
   The amazing improvement in food supply
 is  largely the  result of the  "Green
 Revolution" that  bred richer and hardier
.strains of corn, new fertilizers and scientific
 :rop rotation.
   Though  a half-billion of the world's
 leople still "go through life without ever
 laving a square meal" and are tortured by.
                                        "The southern Sudan, the great
                                     plains of Central Africa could grow
                                     enough food to feed the present
                                    . world population all by itself."
                                                      - ROGER REVELLE
chronic hunger,  Revelle  emphasized  that
developing nations are stepping up  food
production and bringing their populations
under control.
   "Incomes are going up
world," he reported, "and
                                                             all  over the
goes up rapidly as income  goes uj.
'increase in income also seems to be the
                                                                      An
                                                                    e key
to populationjxjntrQi
   "When
                                          hen there is enough  food,  it
                                         e nope"tITaT if theyJKmit their f.
                                        r things wtirgeTEetter for them."
                                        Within the span of a single generation,;
                                     Revelle said, at least 12 of the  hungriest
                                     nations of the world have brought their birth
                                     rates down rapidly. Among them are China,
                                     Chile,  Korea, /Taiwan,  Hong Kong and
                                     Egypt.
                                        Revelle's statements followed by a day a
                                     warning from World Bank president Robert
                                     McNamara that  the world  population
                                     explosion is a greater threat to global tran-
                                     quility than anything save thermonuclear war.
                                     He spoke at MIT.
                                        While  the total world population
                                     continues to expand relentlessly at a 2
                                     .percent pace per year, Tufts University
                                     president  and nutrition authority Jean
                                     Mayer pointed out, nowhere in the world is
                                     the birth rate rising any more.
                                     '   This gain, however, is offset somewhat by
                                     a decline in the death rate and a lengthening
                                     .of the average life span, Mayer said.
   Sri Lanka (Ceylon) was cited as the
 "most beautiful example" of new food self-
 sufficiency. The nation's birth rate is 50
* percent lower than in neighboring Pakistan
 and  Bangladesh,  life expectancy is more
 than 65 years and 80 percent of the populace
 are literate. Everyone in the country gets a
 small ration of food and two cents a week to
 purchase additional food for their household.
,  World supply exper^  Edwin Martin,
 former US ambassador to Argentina, warned
 that continued improvement in food supplies
 is dependent on other international factors.
   "If we hope to  be able to truly feed the
 people of the world globally," he said, "then
 we cannot permit the world economy to
 break down, nor can we have  any major
 political upheavals to divert our manpower
 and disrupt supplies."
   Martin and international food supply
consultant Kenneth Schlossberg, a trustee of
-the American Freedom  from  Hunger
'Foundation,  urged creation of an American
and a world reserve of grain to stabilize the
price of food and to fill in when bad weather
destroys crops.

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DO
SI
 X
UJ
    City  dwellers   quit  good  lite
    for  farming  —  in   backyard
     By TONY L10CE
     Journal-Bulletin Slaff Writer
  PROVIDENCE - Five years
ago, Edward Neri "didn't know
anything  about  vegetable gar-
dens and cared less. I'd work at
my job all day fixing oil burners
and then I'd go for four or five
beers and  I'd come home and
that was it."
  These days, though, Neri gets
up every morning at 5 so he can
spend two hours out behind his
house at  173 Windmill St., tak-
ing care of  his garlic plants,
parsley, Romaine lettuce and ice-
burg lettuce, onions and mustard
greens  before  he leaves for
work.
  When he gets back home in
the late afternoon,  he spends
another hour or so in the garden.
And on weekends, he's out there
10 or 12 hours a day.
  "It's his fault," he jokes, point-
ing to his  next door neighbor,
Ernest Capaldi,  a  69-year-old
foundry worker who has been
"raising up" vegetables  in his
backyard  since moving  here
from  his family's farm in Italy
53 years ago.
  "He got me started," says
Neri,  52. "I told him I was going
to put a lawn back here. Put a
little  piece of garden in, he told
me,  just a little  piece.  So I
planted some seeds on a 12-by-
12 foot plot.
  "Now look. I'm  up to 40-by-
80. I'll be planting peppers, egg-
plant, tomatoes, string  beans,
celery and • basil  in the next
couple of weeks. And you see all
that empty land behind the yard?
I just bought that. I want to put
potatoes  and corn back there.
  "I'd like to  turn  this whole
thing into a real farm. A farm in
the middle of the city."
  Neri is only one of many city-
dwellers who  in recent years
have put down beer cans and put
aside the TV set for a hoe, a rake
and a bag of seeds.
  Yesterday, in Neri's neighbor-
hood around Charles Street, sev-
eral people weren't even think-
ing about the Celtics or the Red
Sox. They were in  their back-
yards, wearing old clothes and
gloves, down on their haunches
with their hands in the dirt.
  Some of them started garden-
ing when the prices at the super-
market vegetable counters start-
ed rising. But  you  don't keep
getting up two hours early every
day, and giving up your whole
weekend every week, just to
save a couple of bucks.
  "Ernest and  I end up giving
most of the stuff away to friends
and relatives," says Neri, "so it's
not like we're  out  here for the
money. It's fun. It's even better
than fun.
  "It's hard to explain, but it's
really something to start with a
29-cent package of seeds —
  me of the seeds  are so small
 rou can hardly  even see them —
and end up with  100  quart
bottles full  of tomatoes  pre-
served for the winter. I'm really
proud of my vegetables. I really
am."
  "You learn an awful lot," said
Neri. "For instance, I bought this
book  about  tomatoes just  the
other night, and some of  the
stuff in there is amazing. If you
do a  certain thing  at a certain
time, it makes all the difference.
I know about how the agricul-
tural  lime gives the plants  the
calcium, all sorts  of things I
never knew before."
  He pauses and smiles  again.
"Imagine, me,  buying  books
about  tomatoes."  He  laughs.
"That's really  something, huh?
But I'm telling  you, I love these
plants of mine and this garden
here. In the  morning, it's so nice
out here, you can't believe  it."
  He invites a visitor to return in
a few months, when the toma-
toes will be  ready, and his pride
knows no  bounds. 'Til  take
those tomatoes right off  the
plant, and  make up a tomato
salad, and  you can't  get  any
fresher than that.
  "I was really lucky last year,
and the year  before, too. The
very  first year, in fact, people
were flabbergasted. Me, too. The
plants were coming up  extra-
large. It was a real abundance.
This  year, I'm hoping to have
good luck again.
   "How'm I doing, Ernest?," he
shouts to the yard  next door.
   Ernest stops raking his own
garden and  looJts over. "You're
doing fine," he smiles. And they
both go back  to work.
                                                      -Joumjl-Bullelm Pholo by ANESTIS DIAKOPOULO^-
                RlrL I'lrrl /?n»/J/tn/\v*
                                           in liiV tl/i*rt/-fn

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B-4   POPULATION  FORECASTS

      B.41  INTRODUCTION

            The Draft EIS stimulated a number of questions and comments on the
            population forecasts in the Draft, including differences among forecasts.
            requests for specific numbers for specific dates, and the question of
            whether it is the purpose of the proposed action to serve inevitable growth
            or to attract growth.

      B.42  DIFFERENCES AMONG FORECASTS

            On the  matter of what the future holds, and why, as stated in the Draft EIS,
            Section 1.4, the future is inherently unknowable and planning for it,
            other than with due regard to the uncertainty, is self-deluding. As
            an example. Figure B-2  shows the population of the United States from
            1790 to 1970 (on a semi-logarithmic scale) and the worst past popula-
            tion projections of the U .S .  Census Bureau (Statistical Abstract of the
            United  States, 1943 & 1965) .   Note that these were the best available
            projections by the most expert demographers, note that  in 1970 the
            U.S. had 30% more people than was forecast for that d'ate in 1943,
            and note that in 1965 the Bureau expected twice as many people in
            the U.S. by the year 2000 as it did in 1943.

      B.43  FORECASTS USED IN THE FACILITIES PLAN

            For the purpose of selecting size of facilities and for economic compari-
            sons of alternatives, the Wastewater Facilities Plan for Cranston by
            Universal  Engineering Corporation used 96.700  people in 20 years and
             119,000  people in 50 years.

      B. 44  GROWTH OBJECTIVES OF THE PROPOSED ACTION

            On whether it is the purpose of the proposed  action  to serve inevitable
            growth or to attract growth  from other areas, it is the objective of the
            proposed action to (1) attract and  support jobs and tax base to meet the
            economic needs of the people of Cranston and to (2)  provide for the
            future  housing  needs, so far as  possible, of Cranston's children.

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  POPULATION  OF  THE  UNITED  STATES,  1790  TO  1970
                                                      ; Population Projection!
                                                        1965
                                                        U.S. Census Bureau
                                                        Population Projection
                                                      t- 1943
1M
       1800  20    40   60   80   1900  20    40    60   80  2000
   Figure B-2

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B.5   LAND USE
      B.51  INTRODUCTION

            Land use questions raised in the comments on the Draft EIS included
            whether open space should have been considered as a special problem
            seperate from the noise and streamflow buffering problems, whether the
            land zoned for industry along the Plainfield Pike should be used for
            industry, and whether offices, apartments or neighborhood convenience
            shopping should be provided in new urban growth areas.

      B.52  OPEN SPACE

            The Draft EIS suggested that open space for recreation,  etc. in new
            urbanizing areas could be provided by providing adequate noise buf-
            fering space along  needed new roads and adequate stream  flow buffering
            impoundments in all new  land development projects.  These two actions
            were expected to systematically provide recreation of a variety of
            types throughout the urbanizing areas with good physical  continuity,
            optimum spatial distribution and maximum esthetic values  at minimum
            cost to the community without relying on arbitrary standards of open
            space adequacy.  (The anticipated effectiveness of the proposed linked
            open space/environmental mitigation program,  if implemented, in this
            case, depends on the conversion of almost entirely rural land to urban
            use so  that the mitigations can be required universally throughout
            the urbanizing area.  This solution would probably not work in areas
            already heavily urbanized.)  It does not apear that any seperate urban
            open space program would be as effective either as open space or as
            an environmental buffer between traffic noise and housing.

      B.53  INDUSTRIAL ZONING

            Several residents of western Cranston questioned whether industry
            should be allowed in western Cranston as shown in the Draft EIS.  The
            areas shown to be developed for industry  in the Draft EIS are also so
            shown  in the State  of Rhode Island's Statewide Land Use Guide Plan,
            the City's Master Plan and the City's land use zoning ordinance.  The
            need for industrial growth in explored in the Draft from several view-
            points  (Chapters II & III)  and the comments appear to offer no new data
            bearing on this issue.

      B.54  OFFICE, APARTMENTS & CONVENIENCE SHOPPING

            The Draft EIS indicated, as a concept only, two land uses changes in
            western Cranston (see Figure VI-26), an office building site and a
            neighborhood commercial center, that became the object of strong objec-

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tion by neighboring residents,  the Mayor and an opposition-party
city council member.  The land use changes were submitted as part of
the environmental buffering of a new roadway suggestion, also submitted
as a mitigating action necessary to avert adverse environmental effects
of urban growth.  The key concept behind the submitted land use changes
is that housing has no place along main thoroughfares, that the noise
likely to be generated at night on such streets is disruptive of sleep
and that  the traffic itself is a potentially lethal hazard to the  residents,
particularly children.  As alternative to housing along main  streets
(the level between expressways and sidestreets) the Draft submitted
that all lands along such streets be either dedicated open space or
used for commercial or industrial purposes with proper traffic access
controls.  (From an environmental  safety and welfare point-of-view either
open space or commercial/ industrial land use is acceptable.)

Unfortunately (as  it turned out)  the City's zoning ordinance, as presently
worded,  permits apartment buildings  in office zones  and both the neigh-
boring residents and city officials took the suggestion of office use (build-
ings where 3 AM traffic noise would be unobjectionable) to be a recommenda-
tion of apartment use  (buildings that would be very sensitive to 3 AM traffic
noise)  .

Compounding this confusion was the coincidence that the City's most recently
published  "Master Plan" (1975) recommends apartment use for the area in
question for reasons quite different from those that were the basis of the
Draft EIS suggestion.  So far as the EIS is concerned no recommendation
for  apartments was intended and the conclusion that lands along major
thoroughfares not be  residential is still valid.

On  the neighborhood commercial zone suggestion, it is not clear whether
the neighboring residents and local officials object to this suggestion specifically
or because it was indicated concommitently with the office use suggestion.
This suggestion was made in part as a land use  alternative to open
space for traffic noise buffering  and in part to reduce traffic and fuel consumption
by intercepting some shopping trips from future residential areas
in western Cranston to commercial  areas in eastern Cranston.  Again
the  confusion about this suggestion was  compounded by a recommendation
in the City's Master Plan for commercial use in  the subject area which
appears  in this case to be  based on similar  reasoning.  Further, it
might be noted that the subject site is  already used for commercial
purposes,  i.e. a dairy products retail delivery  company and a data
processing service, and so its ultimate use may already have been
determined.  So far as the EIS  is concerned and the responsibility
of EPA to offer advice on restoring,  maintaining, and enhancing the
environment this suggestion is also still valid.

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           During the time the Draft EIS Statement was being prepared, the City
           Planning Department and City Planning Commission were making pre-
           liminary proposals and holding public hearings to amend the zoning
           ordinance. As a result of its continuing  revisions,  the Planning Com-
           mission's latest recommendations do not include office building sites
           or commercial sites.  The latest proposed zoning ordinance is designed
           to achieve the same results by providing open space along main streets
           by means of increased setbacks, permitting and encouraging cluster de-
           velopment and other techniques. Consequently, the reference to the
           office building site and neighborhood commercial center indicated on
           Figure VI-26 (Pg.  176) should be deleted.

           This alternative of using open space and deleting apartments, offices
           and commercial uses is receiving the support of the Mayor, the Planning
           Commission  and those members  of the City Council who have spoken on
           the issue.
B.6  ARCHEOLOGICAL RESOURCES

     As pointed out by the Rhode Island Historical Preservation Commission, the
     apparently very significant resources of the Furnace Hill Brook vicinity must
     be carefully protected both from the direct impacts of sewer construction and
     from the concurrent or following secondary urbanization.

     To do this, so far as the direct effects go, plans of the proposed sewers will be
     submitted to the Commission when they are developed and the State Archeologist
     will be invited to monitor the necessary excavations as they occur.  For the
     other effects,  EPA has called the problem to the attention of the Federal Regional
     Council for New England with the suggestion that that agency convene an inter-
     agency committee including the Federal  Highway Administration, the Department
     of the Interior, the Department of Housing and Urban Development, the Environ-
     mental Protection Agency, the Mayor of Cranston and the relevant state agencies
     to jointly plan the development of this very special (and in some ways very normal)
     problem.

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B.7  IMPLEMENTATION OF MITIGATING ACTIONS

     B.71  INTRODUCTION

           The Draft EIS proposes a number of mitigating actions that could be
           taken to offset some of the adverse impacts of the proposed project.
           Comments on the Draft EIS raised the question of how these actions
           would be implemented.

           Review of the proposed mitigating actions indicate that some of them can
           be implemented by the City of Cranston as administrative actions as part
           of the proposed project with EPA and State financial assistance;  some
           can be implemented by the City of Cranston as legislative actions of the
           local government without outside assistance; and  still others can be
           implemented with substantial assistance from State and Federal agencies
           other than EPA.  To accomplish the mitigating actions, EPA will  require
           the City to  include within the proposed project those actions which can
           be included within that project, it will require the City to amend its
           land subdivision and building  codes to control the quality of storm water
           runoff, and it will  urge the City to undertake to  accomplish the rest of
           the actions, insofar as  it is within the City's power to do so, as a condi-
           tion of the EPA grant for construction of the proposed action.  Actions
           beyond the City's capabilities, outside the scope of EPA's programs,
           and not being provided for by  other agencies are called to the attention
           of the Council of Environmental Quality for further consideration.

     B.72  MITIGATING ACTIONS TO BE INCLUDED WITHIN THE PROPOSED PROJECT

           A number of diverse mitigating actions will be included within the scope
           of the proposed project including:

           1.    reduction of chlorine content of effluent discharges to levels not
                 inimicable to anadromous fish;

           2.    reduction of night noise levels in the vicinity of Cranston waste-
                 water treatment plant to those acceptable for sleep as specified in
                 the City's current zoning ordinance;

           3.    rehabilitation of areas now or formerly used for sludge disposal
                 in  the vicinity of the Cranston wastewater treatment plant as de-
                 scribed on pages 92 and 93 of the Draft EIS;

           4.    relocation of new pipelines in western Cranston away from areas
                 of  special resource value in the vicinity of Furnace Hill Brook
                 ravine; and

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      5.    submission of design drainage for sewer construction in western
            Cranston to the Rhode Island Historical Preservation Commission
            and inspection of such sewer construction by the State Archeologist
            as required.

B.73  MITIGATING ACTIONS TO BE REQUIRED OF THE CITY

      One action that will protect water quality  that can be accomplished by
      the City,  primarily as  legislative action of the  local government, will  be
      required as a condition of EPA's grant, i.e. amendment of the City's
      building and land subdivision  codes  to require that land developments of
      10 or more acres be so designed  that peak stormwater  runoff after develop-
      ment  (for peak runoff likely  to occur in one year out of one hundred years)
      not exceed that which existed  before development,  calculation of both  to be
      by the method referred  to in the  Draft EIS.

      Note that this requirement is consistent with the intent and the specific
      wording of the State's Wetlands  Act, that such calculations are usually
      required by the State's Department of Natural Resources if the project
      directly impacts on  a wetlands (other than by changing runoff character-
      istics) ,  and that a universal requirement, except for  very small devel-
      opments, would be in the interests of the City as a public  works mainten-
      ance agency, of all downstream  abuttors, and of land developers in that
      it would insure equal treatment  of all developers.

B . 74  MITIGATING ACTIONS TO BE RECOMMENDED TO THE CITY

      Two actions that can be accomplished by the City as administractive actions
      to enhance the City's future environmental quality, but that are not be-
      lieved to be required by any statute or regulation are recommended to the
      City, i.e.:

      1.    agreement by the City that any public development  projects by the
            City of Cranston in areas  served by the proposed project will be
            subject to the same cultural resource protection proceedures as
            are required  of EPA under Executive  Order 11593. and

      2.    adoption by the City of Cranston of a  Master Plan for western Cranston
            showing both the proposed land use and a network  of roads aeequate
            to provide for future traffic, safely and without congestion, with ade-
            quate provision for keeping residential buildings away from traffic
            noise levels that would  interfer with sleep or with normal daytime
            use of the buildings.

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      Notice that this last point is not an imposition of any specific land use or
      transportation plan on the City of Cranston but rather a recommendation
      that the City have an internally consistent plan for balanced and orderly
      growth,  similar to what HUD would call a "workable program", but with
      the elements of the program designed to satisfy current environmental
      standards.

B.75  MITIGATING ACTIONS PROBABLY BEYOND THE CITY'S FINANCIAL CAPA-
      BILITIES £ OUTSIDE EPA's JURISDICTION -- N.B. CEQ

      A number of mitigating actions identified  in the Draft EIS appear to be
      beyond the financial capabilities of the City of Cranston and outside the
      scope of EPA assistance authorizations, specifically construction of new,
      acoustically-attenuated, control led-access. limited-speed roadways in
      the urbanizing fringe.

      Possibly these actions can be accomplished by interagency cooperation
      with the Bureau of Outdoor Recreation and the Department of Transporta-
      tion, and EPA has brought the problem to the attention of the Federal
      Regional Council for New  England to try to arrange such cooperation.

      Further, since the problems for which the proposed mitigations are
      suggested exist in many urbanizing areas and the proposed mitigations
      are suggested exist in many urbanizing areas and the proposed mitiga-
      tions may be a widely  effective remedy, the attention of the Council on
      Environmental Quality is specifically directed to this problem. Note
      that, while under NEPA, Section  102(2)F, EPA is required to "make
      available to municipalities advice and information useful in restoring,
      maintaining, and enhancing the quality of the environment," under
      Section 204 it is the duty of the CEQ "to review the programs of the
      Federal Government for the purpose of determining the extent to which
      such programs are contributing to the achievement of the policy (set
      forth in title I of NEPA) - and "to develop and recommend to the Presi-
      dent national policies to foster and promote the improvement of environ-
      mental quality."

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EXHIBIT C

ERRATA £ ADDENDA, THE DRAFT EIS, SIGNIFICANT TO UNDERSTANDING THE ISSUES
Under the pressure to examine a great variety of environmental effects,
simultaneous with the planning of the project,  and to produce the EIS in a
timely fashion, a number of errors and ommissions were made in the Draft.  In general
these errors are typographical and do not change the sense of the analyses
or the conclusions that were drawn.  This section is included to clarify only
those parts of the Draft EIS where the errors (or unclear information) are
believed to be significant to understanding the issues.

Page 218 - The debt service costs shown in Table VIII-1  include both the costs
      of enlarging and Improving the wastewater treatment plant and of ex-
      tension of sewers into western Cranston as shown in Figure 1-4. The
      1980  debt service  cost   to the City of Cranston of the treatment plant
      alone was  estimated  in the Draft Wastewater Facility  Plan by Universal
      Engineering Corporation, dated September, 1976, to be $380,000 with
      that of the sewer extension estimated to be $810,200.
 Page 177 - Figure VI-26  should be entitled "Possible Future Development of
      Western Cranston:  A Concept for a Program Suggested for the Adequate
      Mitigation of the Adverse Environmental Impacts of Sewering Western
      Cranston."  The note "Office  Building Site (Proposed Zoning Change)"
      should  read "Park Buffer or Non-Residential Building Site," the note
      "Neighborhood Commercial Site (Proposed Zoning Change)" should
      read "Park Buffer or Non-Residential Building Site," and the note
      "Signalized Intersection" should read "Signalized Intersection and/or
      Traffic  Circle."
 Other errors included:

 Preface - The 3rd paragraph should read "CE Maguire, Inc. was charged with
       the task of independently reviewing the Facilities Planner's efforts as_
       they relate to environmental impacts, performing..."

 Page 2 - Item 1  should read "enlargement of the City's wastewater treatment
       plant, consolidation of existing seperate industrial and institutional waste-
       water discharges into the city facility and increase the  efficiency of the
       city's plant,"

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Page 3 - The 1st paragraph should read "The purposes of the proposed action are
      to forestall immediate overloading of the existing treatment plant when Ciba-
      Geigy, the State Institutions at Howard and the Howard Industrial Park are
      tied into the Cranston Sewer System, to eliminate existing nuisance conditions
      (both air and water) in and near the lower reaches of the Pawtuxet River,
      to meet new water quality classification of the reaches of the Pawtuxet below
      the municipal treatment plant, to comply with NPDES  permit requirements
      of EPA, and to provide a public utility which will be adequate for the
      future planned needs of the community."

Page 5 - Mitigation item 5  should be amended by deleting the word "neglect" and
      substituting the word "failure" so that the item reads ...  "5-  Destruction of
      areas of special resource value by failure to  rehabilitate areas partially de-
      stroyed by operation of the existing Cranston wastewater treatment plant.
      Recommended mitigating actions include regrading the subject areas to
      restore their values esthetically and as wildlife habitat."

Page 7 - The 2nd paragraph should read "The water quality improvement will in-
      clude overall upgrading of the entire river below the outfall of the treatment
      plant to the officially designated classification including:"

Page 19 - Issue #1 of Chapter II  should be  redefined ... "1. Given that an ultimate
      purpose of the proposed project is to provide a public utility to accommodate
      orderly urban growth,  is continued urban growth really necessary?"

Page 42 - The end of the second paragraph should read "... the 'tofts' of
      'toft and croft' agriculture." (In feudal agriculture, a toft was the
      fenced house lot of a tenant peasant  on an estate while the croft was
      the peasant's share of the estate's physically unsubdivided fields.)
      Note  that the agriculture productivity issue is discussed further in
      Exhibits of this Final EIS.

Page 45 - The list of "givens" that describe the existing physical and programmatic
      circumstances  that surround the proposed action should be expanded to in-
      clude. .. "5. and that there does now exist a portion of the Pawtuxet River
      in which 'nuisance' conditions can exist from time to  time during most years
       (see page 50) ."

Page 45 - The list of issues, or questions, proposed to be treated  in Chapter III -
      WATER QUALITY should be amended toread..."1.  will the proposed action
      be effective in improving water quality to the adopted water quality classifi-
      cations,  2. will the proposed action violate any presently proposed minimum
      water quality standards,  and  3.  will the proposed action tend to preclude
      any preferable longer-term alternatives or tend to commit the river to less
      than optimum quality in the  long term?"

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Page 50 - On figure 111-3, the section of the Pawtuxet River east of the Ciba-
      Ceigy Corporation, index no. 171 on the map, is Class E.

Page 51 - The last sentence should  read .. ."The more polluted condition further
      north in the estuary, the Class 'SD1 area, reflects much  larger pollutant
      loads discharged by the City of Providence's sewage treatment plant and
      by its combined sewer overflows."

Page 58 - The following corrections should be made  in Table II1-3:

            98% should read 92%
            305 should read 1305
            30111 should read 30222

Page 65 - In the first paragraph, the parenthetical phrase "and possibly Class C"
      should be deleted.

Page 67 - At the end of the discussion of dechlorination alternatives, the following
      sentence should be added:  "The final Facilities Plan will recommend Sulfur
      Dioxide dechlorination."

Page 70 - It should be noted of the discussion of solid wastes to be generated  by
      the proposed facility, that while large amounts of sludge will be generated
      within the process,  this sludge is only an intermediate product.  Incineration
      of the sludge, a integral part of the proposed  action, will reduce the volume
      of the solid  material by over  90%, so that considerably less solid will remain
      for ultimate disposal in the future (after  the proposed action) than at present.

Page 87 - The last paragraph should  be deleted and  the following substituted ...
      "Existing sludge that is excavated for  construction of the proposed treatment
      plant additions will  be disposed of  in a State approved sludge disposal site".

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Addendum #1: Chapter III WATER QUALITY, Section 3.1 BACKGROUND,
      Sub-Section 3.11 THE PAWTUXET RIVER
A.    Introduction

      Since publication of the Draft EIS there have been three changes in its
      programmatic milieu:

      1.    The computer model of the Pawtuxet River has been completed,

      2.    Consideration of revising upward the goals for water quality in
            the Pawtuxet River has been initiated, in part because the computer
            model results indicate that higher qulaity conditions are possible, or
            said otherwise, technologically "attainable", with advanced waste-
            water treatment (AWT) or NH  removal (see figure Addendum-!), and

      3.    EPA national policy toward funding AWT is being reviewed as a re-
            sult of criticism by the United States General Accounting Office (GAO)
            that, in many cases, AWT has been expensive compared to secondary
            treatment and that without reliable data and sound plans, these AWT's
            may not be the most effective and efficient means for achieving water
            quality goals.

 B.    The Computer  Model

      As part of the Water Quality Classification study, amodel (a computer simu-
      lation) of the Pawtuxet River was prepared. This model was briefly referred
      to in the Draft EIS but it was substantially refined after publication of the
      Draft. The model, called RECEIV-II, dynamic hydraulic and water quality
      model for the Pawtuxet River Basin, was developed  by the Raytheon Company
      as part of the New England River Basins  Modeling project funded by EPA,
      The effort was coordinated by EPA and the rhode Island Department of Health.
      The model was based upon water quality studies of the Main Stem of the
      Pawtuxet River conducted in 1968, 1971, 1973. and  the time of travel studies
      and sediment oxygen demand studies conducted  in 1975 and 1973 respectivly.
      EPA and the State both believe that it does represent the river hydraulics
      and the dissolved oxygen (DO), Biochemical Oxygen Demand (BOD), Nitro-
      gen and Coliform Bacteria characteristics of the  river.

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Figure Addendum  -  1
                             COMPUTED WATER QUALITY
                                     AT LOW FLOW
              PAWTUXET RIVER - WEST WARWICK TO PAWTUXET COVE
5

9

I
5
                                                               I
                                                               u

                                                at
                                                2
                                                u
                                                         u
u
U
X

I
         Existing Conditions
         Design Year Flows
           with secondary treat-
           ment at all plants
           with ammonia re-
           moval at Cranston
           with ammonia re-
           moval at Cranston
           Warwick
           with ammonia re-
           moval at Cranston,
           Warwick &W. Warwick

c
c
c
c
c C

c
c
c
c
c
1 '

c
c
c
c
t —
E-
0
0
c
         C - conforms to the minimum standards of Class C at 7 day, 1 in! 0 year low flow
         D - conforms to the minimum standards of Class D at 7 day, 1 in 10 year low flow
         E - conforms to the minimum standards of Class E at 7 day, 1 in 10 year low flow
         Source:  EPA Region I

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      Using the model, various "wasteload allocations" were developed for
      point source discharges to the river based upon the total Oxygen Demand  (TOD)
      This procedure allowed both the computation of the effect on the receiving
      stream of any given set of discharges and also an "allocation" of a maximum
      amount of discharge to achieve any given water quality.

C.    Results of the Computer Model

      Figure Addendum-! shows the water quality conditions that will obtain at
      low flow at a number of hypothesized  wastewater treatment discharges.
      In summary, it indicates that less effective treatment than that proposed
      at Cranston, (i.e. AWT with ammonia removal, and secondary treat-
      ment at Warwick and West Warwick) will preclude  achievement of Class D
      in the lowest reaches of the river, and it also indicates that Class C is pos-
      sible throughout the river if all three treatment plants include ammonia removal.

      Further the model points out that without ammonia  removal at all three treatment
      plants, at high summer temperatures  and low flow  conditions,  the ammonia
      concentrations in the river would violate the ammonia criterion in EPA's
      Quality Criteria For Water. It is important to note of this ammonia problem
      that the "Rationale" accompanying the criterion, explaining the setting
      of the criterion level states:  "Levels  of un-ionized ammonia in the range
      of 0.20 to 2 mg/l have been shown to be toxic to some species of freshwater
      aquatic life. To provide safety for those life forms not examined, 1/10th
      of the lower value of this toxic effect range results in a criterion of 0.02 mg/l
      of un-ionized ammonia.  This criterion is slightly  lower than that recommended
      for European inland fisheries..."  and it is also important to note that
      the maximum concentration  expected at  low flow in the Pawtuxet would
      be about 0.026 mg/l or about I/8th of the  lower value of the toxic effect
      range.

D.    Revisions  of Pawtuxet River Classification
      The Water Pollution Control Act Amendments of 1972  (P.L. 92-500),
      the law which governs EPA in this area, specifically states as a national goal
      the highest water quality "attainable" (without defining that term) . The
      Century Dictionary, An Encyclopedic Lexicon of the  English Language de-
      fines attainable as being capable of being attained and then goes on to dif-
      ferentiate attain from some of its synonyms as follows: "attain involves  the
      idea of considerable effort, obtain does not necessarily imply effort at all,
      and procure only a small degree of it.  Thus we may obtain by inheritence,
      procure  a book by purchase, but we can attain an end only by exertion."
      Just how much effort is "considerable"  remains a matter of judgement, but
      just as clearly the concept connotes more than simply achieving the best
      water quality for the money, the best "procurement" as it were.  Similarly,
      and also  implicit in the word "attain" and its definition is that there be  a
      valid  "end" to be achieved, in  this case say, a substantive improvement
      in the environment rather than a change in  letter grade on a regional  map.

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      Said otherwise, relating the issue to the Pawtuxet River, the question is not
      whether the change from Class D to Class C is attainable, but rather whether
      a real improvement in the habitat for fish, and in the opportunity for fishing,
      can be attained.

E.    Economic Constraints on Attainability

      It is important to note that just as all parts of the environment are inter-
      related, so all parts of the economy are interrelated. Just as the Draft
      EIS describes the linkage of sewer construction to population growth,  of popu-
      lation to traffic increase, of traffic increase to noise, and of noise to sleep
      interference, so labor, materials and credits spent to excess in any one area
      will limit the supply available in other areas, which shortage in turn could
      lead to lower maintenance of other components of the environment.

      A recent study by  the Government Accounting Office  (GAO) for the Congress,
      has questioned the propriety of spending large amounts of Federal funds for
      AWT facilities merely to achieve paper classifications of water quality.  It
      is inescapable that treatment levels  beyond secondary treatment are extremely
      costly per unit of pollutant removed.  GAO is recommending to Congress
      that the Federal Water Pollution Law be amended in such a way as to pre-
      clude funding of AWT unless  satisfactory justification of the cost vs. benefits
      can be made.  This policy is  not in effect at this time, it is not known when or if
      it will go into effect, but the point has been made and is noted.

F.    Applicability to the Pawtuxet River and the Cranston Wastewater Treat-
      ment  Plant

      Resolution of the preceding conflict, so far as Cranston's ammonia removal
      system is concerned,  must take into account the following facts:

      1.    That the State of Rhode Island, after hearing and considering the argu-
            ments for and against the various possible upgradings of the river's
            quality, has selected and adopted Class D for the  reach of the river
            between the Pocasset River junction and Pawtuxet Cove.

      2.    That EPA must, under  Executive Order 11593  (see Chapter VII of
            the DEIS), if it is "prudent and feasible", insure that there will be no
            nuisance conditions (Class E) at the Pawtuxet Village Historic
            District.

      3.    That Class E with a dissolved oxygen  level of less than 1 mg/l at low
            flows is not  avoidable without ammonia removal at the Cranston Waste-
            water Treatment Plant.  Therefore elimination  of odor and nuisance condi-
            tions in the  1.5 mi  reach of the Pawtuxet above Pawtuxet Cove cannot be
            achieved, at low flows, without the ammonia removal capabilities.

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Clearly these facts admit no alternative but to include ammonia  removal at
Cranston as part of the proposed project.

To go further, and look into the question of changing the State's water quality
classification for the entire river to Class C, however,  is a seperable issue.
The facts that bear on it include:

1.     That reclassification would require no further upgrading at the Cranston
      treatment plant.

2.     That the  reaches of the river that are Class D are of little value to
      fish other than as a migration route for anadromous fish (shad &
      herring)  in spring and early summer, according to State game managers.

3.     That Class D standards met at low flow during the late summer will
      generally create quite adequate water quality conditions for shad and
      herring during most of their seasons of migration.

U.     That while restoration of the migratory fish suitability in the lower
      Pawtuxet will have very large and visible, beneficial impacts on
      the environment, including opening the entire river system to
      migratory fish, creating a beneficial food chain effect in the adjoining
      waterbodies,  eliminating odor nuisance, etc., upgrading the river
      further to Class  C will only add a relatively very  small number of
      rather small fish to a relatively  very short reach of the river.

5.     That the  Pawtuxet River, in its  lower reaches, is a sluggish stream with
      limited reaeration opportunities, running through a heavily urbanized
      region, with storm drains discharging  street dirt from  a multitude of
      high density land uses (with limited opportunity available for treatment
      or settlement of the storm drainage)  and with a substantial part of the
      headwaters runoff diverted for public water supply purposes.

6.     And finally, that achieving Class C standards apparently would require
      ammonia  removal at both the Warwick and West Warwick treatment plants.

In summary,  the question of whether the lowest reaches of the Pawtuxet should
be Class C or Class D cannot be answered  here,  it is beyond the level of analysis
included in the Cranston Wastewater Treatment Plant's investigations,
and it appears that it might require careful analysis of just what real benefits
would be achieved.    The only certain thing that can be said  of it is that it
is not relevant  to the decision to be made at Cranston since Cranston
would require about the same degree of ammonia removal for  either classification.

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Addendum #2: Chapter III WATER QUALITY, Section 3.2 PROPOSED ACTION
      FOR WASTEWATER TREATMENT AND DISPOSAL. Sub-Section 3 22—
      ALTERNATIVES  	              '   '
The costs and evaluations of the alternative wastewater disposal strategies and
treatment processes considered in the facilities plan are shown in Tables A-1
and A-2.

Table A-1 shows among the costs, the Present Worth of Future Operations and
Maintenance  (O + M) .  This figure is equal to the sum of money that would have
to be invested today to produce income adequate to pay for future annual 0 + M
costs.  It is used herein to permit addition of construction costs  (a one time cost)
and O + M costs (a recurring annual cost) so that the alternatives can be compared
fairly.

Table A-2, taken directly from the Facilities Plan report, is an attempt to compare
all the characteristics of the various alternatives.  It should be noted of this com-
parison that it is not,  and cannot be, a rigorous economic or scientific  method,
but rather is an attempt to combine in one figure a very diverse  set of economic,
environmental and engineering evaluations.

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                                          Table A-1


                                     SUMMARY OF COSTS
                      ALTERNATIVE WASTEWATER TREATMENT METHODS
                                                      2nd Q,  1977       Present Worth
TREATMENT ALTERNATIVE                          Construction Cost    of O 6 M	     Tota!	


Secondary/Discharge to Providence River               $38,797,320       $20,476,360     $59.273,680

Secondary/Land Disposal of Effluent                      36,583,450         31,331,960       67.968.040

Single Stage Biological Nitrification (1)                    26,815.000         22,722,700       49.537,700

Two Stage Biological Nitrification                         28,335,000         21.620,830       49,955,380

First Stage Biological.Fixed Film Nitrification  (2)          26.114,290         21,467,430       47,581.720

Physical-Chemical                                       32.780,000         27,791,220       60,571,220

          *  Recommended Alternative

          (1)    Single Stage Biological Nitrification Alternative:  not selected although
                slightly less costly than  recommended alternative for the following reasons:

                a.    This alternative does not provide protection against toxic sub-
                     stances in the wastewater which would hinder the nitrification
                     process.  It was felt that, with considerable industrial flows of a
                     variable nature in the Cranston system,  there was a high prob-
                     ability of such toxic substances being transmitted to the plant.
                     The selected alternative provides good protection against most
                     toxicants.

                b.    This alternative has only moderate stability of operation whereas
                     the selected alternative is a stable operation.

                c.    This alternative has considerably less flexibility of operation
                     than the selected alternative and savings in operational costs
                     may be realized by the selected alternatives.

          (2)    First Stage Biological. Fixed Film Nitrification Alternative:  not selected
                although slightly  less costly than recommended alternative for the follow-
                ing reasons:

                a.     No performance records are currently available for a facility of this
                      size in operation.  Loading rates used to develop cost estimates may
                      be higher than what can actually be achieved for a plant of this size.

                b.     Bench scale studies conducted at Cranston showed difficulty In
                      achieving biological growth at 15°C (59°F) .  Nitrification is to be
                      required during period of June 1 thru October 31 for the Cranston
                      facility, therefore it was concluded that reliability of this alterna-
                      tive was not favorable.

                c.     This alternative is less controllable and has less flexibility of opera-
                      tion than the selected alternative.

                d.     This alternative does not achieve as high a degree of ammonia re-
                      moval efficiency as the selected alternaive. Although this alterna-
                      tive would  theoretically be able to achieve required ammonia removals
                      necessary to meet effluent standards it was concluded, based upon
                      above factors, that this alternative may  in fact have some difficulties
                      in achieving the effluent standards whereas the selected alternative
                      was more fully capable of achieving the  standards.

          Sources:    Universal Engineering Corporation
                      EPA Technology Transfer  Process Design  Manual, Nitrogen Control
                      EPA Advanced Wastewater Treatment Laboratory, Cincinnati, Ohio

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                            Table A-2
                 SUMMARY EVALUATION MATRIX OF

             WASTEWATER TREATMENT ALTERNATIVES


O
o£
3 j
UJ 3
53
IT WITH
ENT

r^l
SECONDARY TRE
LAND DISPOSAL I
in
•K LU
^™ UJ
*^ O
Llf *•" 1
11
SECONDARY TRE
DISCHARGE TO Pi
5

o
3
o
SINGLE STAGE Bl
NITRIFICATION

<
U
5
o
TWO STAGE BIOL
NITRIFICATION
z

M
FIRST STAGE BIC
FIXED FILM NITR
UJ
<

gi
PHYSICAL-CHEMI
WITH EFFLUENT
CONSTRUCTION COST      1/3     55      33      3     4

OPERATING AND
MAINTENANCE COST       1/2     52      33      3     4

ENVIRONMENTAL EFFECTS  1/3     32      22      3     3

PERFORMANCE RECORD
AND RELIABILITY         1       323242

OTHER FACTORS*         1/4     33      32      2     2
WEIGHTED TOTAL
                                8.9   6.1
6.9   5.7    8.0    6.8
      Integers of:        1 represent the most favorable rating
                       5 represent the least favorable rating
      •Includes:

           Ability to degrade wastewater;  handle industrial wastes and shock loads
           Flexibility, simplicity and expandability of operation
           Disruption to existing system;  ease of implementation
           Ability to meet future standards
           Protection of nitrifiers against heavy metals, shock
                 loadings, biological interference

      Source:  Universal Engineering Corporation

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DRAFT

ENVIRONMENTAL IMPACT STATEMENT

on the

PROPOSED TREATMENT AND COLLECTION SYSTEM
for the
CITY OF CRANSTON, RHODE ISLAND
 DATE:
October 18. 1976
 Prepared by:

      U.S. ENVIRONMENTAL PROTECTION AGENCY
      Region I
      JFK Federal Building
      Boston, MA 02203

      CITY OF CRANSTON
      City Hall
      Cranston, Rhode Island

 With Technical Assistance by:

      CEMAGUIRE, INC.
      Architects • Engineers • Planners
      Providence • Waltham • New Britain
Responsible Officials:
    L. ai
l±onal. Administtfjltor
Environmental Protection Agency
Region I
                              fes L. Taft, Jr.
                            jayor
                            :ity of Cranston, Rliode Island
                                                         /f  /

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    Draft or Final:
          DRAFT

    Agency:
          ENVIRONMENTAL PROTECTION AGENCY
          REGION I

7.   Action:
          Administrative

2.   Description:
          Includes consolidation, improvement and expansion of wastewater
          treatment facilities in the City of Cranston, a portion of Providence
          County in the State of Rhode Island

3.   Anticipated Impacts:
          Principal effects include:
              a.   improved water quality in the Pawtuxet River,
              b.   expansion of economic base and housing supply,  and
              c.   elimination of odor nuisance.

          Adverse effects include:
              a.   small increases in fuel use in, and air pollution from, solids incineration,
              b.   accelerate conversion  of 7 square miles of forest and form land to
                  urban uses, and
              c.   accelerate creation of substantial increases of traffic and traffic noise
                  in the once rural areas.

4.   Alternatives Considered:
          Alternatives considered included:
              a.   alternative methods of wastewater treatment,
              b.   alternative methods of treated effluent disposal including land
                  application in western Cranston and piped discharge into the
                  ocean,  i.e. the Providence  River estuary,
              c.   alternative methods of solids disposal  including sanitary landfills
                  and pasteurization and land application as a soil conditioner/fertilizer,
              d.   the alternative of not extending the sewer system into now rural
                  lands,  anc
              e.   the alternative of more aggressively extending the system.

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5.   Agencies from which Comments on this Draft Statement have been Requested:
        Advisory Council on Historic Preservation
        American Littoral Society
        Appalachian Mountain Club
        Aquidneck Island Ecology
        Audubon Society of Rhode Island
        AWARE, Inc., Nashville, Tenn.
        Blackstone River Watershed Association
        Conservation Law Foundation
        Cranston Historical Society
        Ciba-Ceigy Corporation
        City of Cranston
        Cranston City Council
        Cranston Today
        Coastal Resources Management Council
        Council on Environmental Quality
        Town of Coventry
        Ecology Action for Rhode Island
        Environmental Council of Rhode Island
        Governor's Council on Environmental Quality
        Historic American  Engineering Record, Rl
        Town of Johnston
        League of Women Voters of Cranston
        League of Women Voters of Rhode Island
        National Wildlife Federation
        New England Interstate Water Pollution Control Commission
        New England Interstate River Basins Commission
        City of Providence
        Providence Journal - Bulletin
        Rhode Island Association of Conservation Commissions
        Rhode Island Governor's Office, Policy and Program Review Section
        Rhode Island Historic Preservation Commission
        Rhode Island Department of Health
               Division of Air Pollution Control
               Division of Solid Waste Management
               Division of Water Quality and Pollution Control
        Rhode Island Department of Natural Resources
        Rhode Island Department of Community Affairs
        Rhode Island Department of Transportation,  Planning Division
        Rhode Island Office of the Attorney General
        Rhode Island Statewide Planning Program
        Rhode Island "208"  Program
        Rhode Island Department of Administration, Budget Division
        Rhode Island State Association of Conservation  Districts
        Rhode Island TB and RD Association
        Rhode Island Water Resources Board
        Save the Bay, Inc.
        Town of Scituate

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        Sierra Club, New England Chapter
        City of Warwick
        Town of West Warwick
        U. S. Environmental Protection Agency
        U.S. Department of Health, Education and Welfare, Regional Environ-
        mental Officer
        U. S. Coast Guard, First District
        U.S. Department of Housing and Urban Development, Regional Admini-
        strator
        U.S. Department of Interior,  Northeast Regional Coordinator
        U.S. Department of Interior,  Assistant Secretary for Program 6 Policy
        Bureau of Sports, Fisheries & Wildlife, Northeast Regional Administrator
        National Parks Service,  District Chief
        Federal Aviation Administration
        Federal Highway Administration, Regional Administrator
        Farmers Home Administration
        United States Geological  Survey, Boston
        U. S. Army, Corps of Engineers,  N. E. Region
        U. S. Department of Agriculture, State Conservationist
        U.S. Department of Agriculture, Agricultural Stabilization and Conserva-
        tion Service
        National Oceanic and Atmospheric Administration, Office of Ecology and
        Environment Conservation
        U.S. Department of Commerce, Deputy Assistant Secretary for Environ-
        mental Affairs
        Honorable John O.  Pastore
        Honorable Claiborne deB .  Pell
        Honorable Fernand J. St. Germain
        Honorable Edward  P. Beard

6.  Agencies which have Contributed to the Formation of this Statement:

        Rhode Island Department of Health
              Division of Water Quality and Pollution Control
              Division of Air Pollution Control
        Rhode Island Department of Natural Resources
              Division of Fish and Wildlife
              Division of Forest Environment
              Division of Planning and Development
        Rhode Island Statewide Planning Commission
        Rhode Island Historic Preservation Commission
        Historic American Engineering Record, Pawtucket,  Rhode Island
        U.S. Department of Agruculture, Soil Conservation Service, West Warwick,  Rl
        City of Cranston
              Department of Public Works
              Planning Commission
              Sewer Department
              Conservation Commission
        Cranston Historical Society, Mrs.  Gladys Brayton
        Mr.  Kenneth M. Mowry, Sr.,  resident of western Cranston

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        Mr, JohnT. Sollars,  resident of Cranston
        Ciba-Ceigy Corporation
7.   Public Input to this Statement:

         Consequent to advertisements placed in the Providence Journal, 4/13,
         the Cranston Herald Today, 4/14, and the Evening Bulletin, 4/15, an
         open public meeting was held to discuss the proposed project at the
         Cranston City Hall on 4/20/1976. Questions discussed included:

               a.    odor problems in the Pontiac Avenue area,
               b.    sludge  transportation problems,
               c.    extension of sewers into adjoining areas of Warwick,
               d.    coordination with regional and statewide planning, and
               e.    extension of the urbanization problem analysis beyond
                     the area of proposed sewerage extension.

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PREFACE
This Environmental Impact Statement (EIS) is the product of the cooperative and
concurrent efforts of

      7.    U.S.  EPA, Region I
      2.    City of Cranston, Rhode Island

and their consultants

      1.    Universal Engineering Corporation
      2.    CE Maguire.  Inc.

Universal Engineering Corporation is the "Facilities Planner" for the proposed
project and was charged with the responsibility to investigate the City of
Cranston's wastewater problems and treatment needs and to develop a program
for solving those problems and satisfying those needs, including identifica-
tion and analysis of all environmental constraints and influences and of all
reasonable alternatives to that program.

CE Maguire, Inc.  was charged with the task of independently reviewing the
Facilities Planner's efforts, performing additional investigations where neces-
sary, identifying and describing the environmental impacts of the proposed
program, formulating a program of supplementary actions to mitigate adverse
impacts of the proposed wastewater program, and to prepare a  "Draft" of the
EIS.

This concurrent effort is referred to,  in in-house government jargon, as
"piggybacking," and this EIS is the first use of piggybacking by Region 1.
Its advantages are acceleration of the planning and review process and that
it makes the environmental reviews available to the Facility Planner earlier
than would otherwise be possible, hopefully broadening environmental
sensitivity and reducing adverse effects.  Its disadvantages include some
degree of inconsistency in detail as the proposed action was repeatedly modi-
fied to satisfy  the most recently identified environmental problems.


In addition it should be noted that this is also a Draft EIS and that some of
the mitigating actions suggested in this Draft are likely to be incorporated
into the proposed project prior to completion of the project planning and of
the Final EIS, reducing thereby the need to explore both the adverse effects
to be obviated by  the mitigating actions and the mitigating actions them-
selves within  that Final EIS.

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 For detailed exposition of the proposed project and its characteristics (other
 than environmental impacts and mitigating actions) the reader is referred to
 the Facilities Plan by Universal Engineering Corporation.  Copies of the
 Facilities Plan and additional copies of this EIS can be reviewed at
            Public Works Department
            City Hall                        All Cranston Libraries
            Cranston, Rhode Island
and
            U. S. Environmental Protection Agency
            Region 1, Room 2203
            John F. Kennedy Federal Building
            Boston, Massachusetts  02203
A public hearing on the proposed project, as described in the Draft EIS and the
Draft Facilities Plan will be held at:

            Hugh B.  Bain School           ON:   November 18, 1976
             135 Cansett A venue
            Cranston, Rhode Island              at 7: 00 p.m.
Public comment on all aspects of the proposed project is invited both at the
public hearing and by mail to EPA Region 1 at the address above.

All public comments will be included in the Final EIS,  will be used in revising
the proposed project as  described in the Draft EIS and Draft Facilities Plan,
and will be answered, as appropriate, within the Final EIS.  Copy of the
Final EIS will be mailed to everyone who submits a comment on the Draft.

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                      TABLE OF CONTENTS



CHAPTER I:      INTRODUCTION & SUMMARY

1.0  INTRODUCTION                                        1

1.1  SUMMARY OF SIGNIFICANT IMPACTS                     6

     1.11  REQUIREMENTS OF SECTION 102(2) (C) of NEPA        6
     1.12  REQUIREMENTS OF SECTIONS 102  (2) (D) 6 102(2) (F)   11

1.2  RESULTS OF THE ENVIRONMENTAL  IMPACT ASSESSMENT   16

1.3  SCOPE OF THIS STATEMENT                           18

1.4  NOTE ON THE  CONSISTENCY OF DATA  AND ON
     INTERPRETATION OF FORECASTS                       23


CHAPTER II:      THE NEED FOR GROWTH AS AN ISSUE

2.0  INTRODUCTION                                       25

2.1  NATIONAL GROWTH NEEDS                             25

2.2  SUITABILITY FOR URBANIZATION, RHODE  ISLAND
     & CRANSTON                                         28

     2.21  RHODE ISLAND VS.  UNITED STATES                28
           2.211 As a Social Issue                          28
           2.212 As an  Ecological Issue                      28
                2.2121  Air Quality Resources                29
                2.2122  Water Supply  Resources              30
                2.2123  Climate                            32
           2.213 As a Geographic Phenomenon                35
     2.22  CRANSTON VS. OTHER COMMUNITIES IN
           RHODE ISLAND                                  35
           2.221 As a Social Issue                          35
           2.222 As a Social Ecological Phenomenon            36
           2.223 As an  Environmental Resource  Use Issue       40
           2.224 As an  Economics/Jobs/lndustrial De-
                velopment Issue                            43

2.3  SUMMARY & CONCLUSION                              44

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CHAPTER III:     WATER QUALITY

3.0   INTRODUCTION                                         45

3.1   BACKGROUND                                          46

      3.11  THE PAWTUXET RIVER                             46
      3.12  WASTEWATER DISCHARGE                           58

3.2   PROPOSED ACTION FOR WASTEW ATE R TREATMENT
      & DISPOSAL                                            60

      3.21  THE PROPOSED ACTION                             60
      3.22  ALTERNATIVES                                    62

3.3   ANTICIPATED ENVIRONMENTAL EFFECTS                   64

      3.31  WATER QUALITY IMPACTS                           64
           3.331 Long-Term Water Quality Impacts -
                Oxygen Levels                               64
           3.312 Long-Term Water Quality Impacts -
                Other Parameters                             65
           3.313 Short-Term  Construction Impacts               65

3.4   MITIGATION  OF IMPACTS                                66


CHAPTER IV:     THE IMPACTS OF SLUDGE & DISPOSAL

4.0   INTRODUCTION                                         69

4.1   BACKGROUND                                          70

      4.11  SOLID WASTES                                    70
      4.12  EXPECTED AIR EMISSIONS                           74
      4.13  AIR EMISSION REGULATIONS                         75
      4.14  AIR ENVIRONMENT                                76
           4.141 Meteorology & Topography                     76
           4.142 Dispersion of Pollutants                       78
           4.143 Ambient Air Quality                           80
      4.15  RESIDUAL SOLIDS                                  84
      4.16  ADJACENT DISPOSAL SITE                           84
      4.17  ALTERNATIVE DISPOSAL SITES                      86

4.2   PROPOSED ACTION FOR SOLID WASTE TREATMENT
      S DISPOSAL                                            87

      4.21  THE PROPOSED ACTION                             87
      4.22  ALTERNATIVES                                    88

4.3   ANTICIPATED ENVIRONMENTAL EFFECTS                   90

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4.4   MITIGATION OF IMPACTS                              92
CHAPTER V:     NEIGHBORHOOD NUISANCE IN THE VICINITY OF
               WASTEWATER TREATMENT FACILITIES

5.0  INTRODUCTION                                      95

5-1  BACKGROUND                                       96

     5.11  CIBA-GEIGY NEIGHBORHOOD                      96
     5.12  CRANSTON TREATMENT PLANT NEIGHBORHOOD       98
     5.13  PAWTUXET VILLAGE                             9 8
     5.14  AMBIENT ODORS AT CIBA-GEIGY                  100
     5.15  AMBIENT ODORS AT CRANSTON TREATMENT PLANT  101
     5.16  AMBIENT NOISE AT CRANSTON TREATMENT PLANT   105

5.2  PROPOSED ACTIONS TO CONTROL NEIGHBOR-
     HOOD NUISANCE                                   110

     5.21  THE PROPOSED ACTIONS                        110
     5.22  ALTERNATIVES                                111

5.3  ANTICIPATED ENVIRONMENTAL IMPACTS               111

5.4  MITIGATION OF ADVERSE IMPACTS                    114

     5.41  WETLANDS ODOR CONTROL                      114
     5.42  NOISE CONTROL                               115
 CHAPTER VI:    GENERAL ENVIRONMENTAL EFFECTS OF SECONDARY
               URBAN GROWTH RESULTING FROM SEWERING NON-
               URBAN AREAS

 6.0  INTRODUCTION                                     117

 6.1  SETTING

     6.11   CITY-WIDE FRAMEWORK                         118
     6.12   PHYSIOGRAPHY                               120
           6.121 Topography                             120
           6.122 Watersheds                              122
     6.13   TRANSPORTATION                             126
     6.14   WILDLIFE                                     128

 6.2  PROPOSED ACTION                                 130

     6.21   THE PROPOSED ACTION                         130

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      6.22  ALTERNATIVES                                     132
           6.221  No Action Alternative                          137
           6.222  Sewers But No Zoning Change Alternative       140
           6.223  Zoning Change But No Sewer Alternative        140
           6.224  The Proposed  Action  Repeated to Fully
                 Intensive Urbanization                         141

6.3   ANTICIPATED  IMPACTS                                   142

      6.31  LAND  SURFACE CHANGE EFFECTS                     143
           6.311  Streamflow S Croundwater Depletion             143
           6.312  Water Quality                                 146
           6.313  Esthetics                                     148
           6.314  Wildlife Habitat                               149
      6.32  POPULATION CHANGE EFFECTS                       150
           5.321  Traffic & Traffic Fatalities                      152
           6.322  Noise                                        158
           6.323  Air Quality                                   161
           6.324  Municipal  Costs S Revenues                    162
                 6.3241 Future  Projections                      163
                 6.3242 Concurrent Population Changes           164
                 6.3243 Patterns of Development and Cost
                       of Sewering                            166

6.4   MITIGATION  OF IMPACTS      .                          167

      6.41  TRAFFIC EFFECTS                                  168
           6.411  The Institutional Problem                       176
      6.42  STREAMFLOW EFFECTS - FLOW QUANTITIES            178
      6.43  STREAMFLOW EFFECTS - RUNOFF QUALITY             182
      6.44  APPEARANCE & WILDLIFE HABITAT                    183
CHAPTER VII:    SITE - SPECIFIC PROBLEMS OF SEWERING
                WESTERN CRANSTON

7.0   INTRODUCTION                                         185

7.1   SETTING                                               186

      7.11  PHYSIOGRAPHY                                    187
      7.12  ESTHETICS 6 HABITAT                              192
      7.13  ARCHEOLOGICAL VALUE (ABORIGINAL)               194
      7.14  HISTORICAL VALUE                                196
           7.141 Seventeenth  Century                          198
           7.142 Eighteenth Century                           200
           7.143 Nineteenth Century                           208
      7.15  PROTECTION REQUIREMENTS                        209

7-2   PROPOSED ACTION                                      210

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7.3   ANTICIPATED IMPACTS                                212




7.4   MITIGATING ACTIONS                                 214






CHAPTER VIII:    OVERALL IMPACTS ON THE CITY AS A WHOLE




8.0   INTRODUCTION                                       217




8.1   SETTING                                            218




8.2   ALTERNATIVES                                       220




8.3   IMPACTS                                            223

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                        LIST OF ILLUSTRATIONS
Figure

  1-1        Urbanized Areas of the United  States                        1
  1-2        Cranston & the Providence-Pawtucket-Warwick
            Urbanized Area                                             2
  1-3        Location of Proposed Action                                 3
  1-4        Location of Proposed Sewer Extensions                       5

 11-1        United States Population by Age, 1970 - 1990               26
 II-2        Days of High Air Pollution Potential  Forecasted,
            Nationally                                                 29
 II-3        Anticipated Water Shortages in  the United States            30
 II-4        Basic  Resource Availability                                31
 II-5        Population Changes in  the  Providence Urbanized
            Area,  1930 - 1970                                         36
 11-6        Cranston and the Providence Urbanized Area                38
 M-7        Surficial  Geology in the Providence
            Urbanized Area                                            39
 11-8        Status of Agricultural Lands in the State of
            Rhode Island                                              40
 11-9        Cleared Lands                                             41

 111-1        Location:  Pawtuxet River  Basin                            47
 III-2        Principal Features:   Pawtuxet River  Basin                  49
 III-3        Present  Water  Quality Condition                            50
 III-4        Water  Quality Standards                                    53
 IH-5        Flood  Control Considerations                               55
 III-6        Croundwater Resources                                    57
 111-7        Proposed Treatment Process                                61
 IM-8        Future Enlargement for Out-of-Basin Discharge              61

 IV-1        Topography  and Wind Rose for Providence Area             77
 IV-2        Contours of  24-Hour TSP Dispersion                         78
 IV-3        Contours of  24-Hour SO2 Dispersion                         78
 IV-4        Contours of  3-Hour SO2 Dispersion                         79
 IV-5        1974 Annual  Average TSP Concentrations                    82
 IV-6        1985 Annual  Average TSP Concentrations                    82
 IV-7        1974 Annual  Average SO2  Concentrations                    83
 IV-8        1985 Annual  Average SO2  Concentrations                    83
 IV-9        Lowlands Adjacent to Cranston  Treatment Plant              85
 IV-10       Proposed Expansion of Treatment Plant                      85
 IV-11       Alternative Solid Waste Disposal Sites                       86

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                        LIST OF ILLUSTRATIONS  -   (Continued)
Figure

  V-1       Ciba Ceigy, Site and Surrounding Area                     97
  V-2       Cranston Treatment Plant,  Site and Surrounding Area        99
  V-3       Cranston Treatment Plant,  Odor Survey                    103
  V-4       Cranston Treatment Plant,  Noise Survey                    107

 VI-1       City of Cranston, Schematic  Land Use                      118
 VI-2       Generalized Physiography, City of Cranston                119
 VI-3       Topography                                               121
 VI-4       Watersheds                                                123
 VI-5       On  Site Sewage Disposal Suitability                         125
 VI-6       Existing  Road Pattern                                      127
 VI-7       Wildlife Habitat                                            129
 VI-8       Future Land  Use, Existing Zoning                          133
 VI-9       Future Land  Use, 1975  Master  Plan                         134
 VI-10      Future Land  Use, 1975  Master  Plan without
            High Density                                              135
 VI-11      Future Land  Use, Full Urbanization                         136
 VI-12      Future Saturation Population  Distribution,
            Existing  Zoning           .                                 138
 VI-13      Lands Difficult to Develop, Western Cranston               139
 Vl-14      Future Saturation Population  Distribution,
            1975 Master Plan                                           140
 VI-15      Future Saturation Population, Fully Urbanized              141
 VI-16      Historical Growth of Selected Suburban
            Communities,  1920 - 1970                                  151
 VI-17      Principal Traffic Flows  Expected, Existing Zoning           152
 VI-18      Principal Traffic Flows  Expected, 1975 Master Plan         153
 VI-19      Principal Traffic Flows  Expected, Fully Urbanized          154
 VI-20      Capacity of Roads,  Vicinity of  Furnace Hill Brook           157
 VI-21      Growth  in  Housing  and  Population, 1960 - 1970             164
 VI-22      Growth  Rates  in Housing and Population,  1960 - 1970       165
 VI-23      "Wythenshawe"                                            171
 VI-24      Relationship between Traffic  Volumes
            and Accident Rates                                         173
 VI-25      Accident Rates Likely as a Result of  Urbanization           175
 VI-26      Environmentally  Buffered  Development Concept              177
 VI-27      Land Development Characteristics                          179

 VI1-1       Physiography, Western  Cranston                           189
 VII-2       Topography in Vicinity  of  Furnace Hill Brook              191
 VII-3       Photographs, Vicinity of Furnace Hill  Brook                192

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                        LIST OF ILLUSTRATIONS  -  (Continued)
Figure

 VII-4      Furnace  Hill Brook and Vicinity, Cultural  History          197
 VM-5      View of Furnace Hill Street,  Earth  20th Century            199
 VII-6      Proposed  Interceptor                                       211
 VI1-7      Impact of Installation of Interceptor on
            Sidehill Site                                               213
 VII-8      Proposed  Alternate Location,  Interceptor                    215

VI11-1      Comparison of New Sewer Costs to  Existing
            City Budget                                               219
VIII-2      Property Values, City of Cranston                          221
VI11-3      Ratios  of  Property Values to  Population
            and School  Enrollments                                     222
VII1-4      Projections  of Property Values and  Population               223
VIII-5      Projections  of School Enrollments                           221
VIII-6      Ratio of Future Property Values to  Future
            School  Enrollments                                         225

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                            LIST OF TABLES
            Principal  Characteristics of Existing  6
            Proposed  Wastewater Treatment Plants                    4
   1-2       Summary  of- Costs and Proposed Sharing of Costs          4
   1-3       Environmental Assessment Summary,
            Cranston  Facilities Plan                                 17

  111-1       Key to Water Quality Classification                      51
  1 1 1-2       Key to Point Source Discharges                         51
  111-3       Existing Wastewater Discharges - Lower Pawtuxet River    58
  1 11-4       Expected  Future  Increases in Wastewater Discharges     59
  111-5       Total Residual  Chlorine Concentration                   66

  IV-1       Solid Wastes Produced                                  71
  IV-2       Analysis of Existing Sludge                             71
  IV-3       Analysis of Sludge from Pilot Plant                     73
  IV-4       Expected  Air Emission Rates                            74
  IV-5       Applicable Air Emission Limitations                     75
  IV-6       Anticipated Maximum Degradation  in  Ambient
            Air Quality                                            79
  lV-7       Anticipated Maximum Ambient Air Pollutant Concentration 81
  IV- 8       Anticipated Maximum Air Quality Impacts                91

  V-1       Ambient Odor Measurements,  Cranston  WWTP           102
  V-2       Noise Impact & Community Response                     105
  V-3       City of Cranston Noise Code                            106
  V-4       Ambient Noise  Measurements, Cranston WWTP           108
  V-5       Night Ambient  Noise  Levels                            109
  V-6       Night Noise Impact of Incinerators                      113

  VI- 1       Furnace Hill Brook, Runoff @ Elevation 50              144
  VI-2       Average Annual Stormwater Runoff Pollutant
            Concentration                                         146
  VI-3       Summary  of Saturation Population  Distribution
            Alternatives                                           151
  VI-4       Traffic Characteristics, Vicinity of
            Furnace Hill Brook                                    155
  VI-5       Peak Hour LIQ Traffic Induced Noise                   159
  VI-6       Peak Hour LBQ Traffic Induced Noise                   160
VIII-1       Costs 6 Revenues  -  Proposed Sewer System  Expansion  218

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Choker  1    INTRODUCTION   4   SUMM^V
1.0 INTRODUCTION

   The proposed project consists of improvements to and enlargements of the waste-
   water collection, treatment,and disposal system of the City of Cranston,  Rhode
   Island.

   The City of Cranston is a fairly steadily growing community of about 73,000
   people  (1970) and 28.6 square miles within the Providence-Pawtucket-Warwick
   urbanized area.  Figures |-1 and 1-2 show the urbanized area's location within
   the United States and the city's location within the urbanized
                                                                 ^
Tk*
                                     of

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THE T'tC'VIDEWdE -
            A1S.EA
  F.WdI-2
The specific improvements and enlargements of the project include:

1 •   enlargement of the city's wastewater treatment plant and consolidation of
    existing separate industrial and institutional wastewater discharges into
    the municipal facility,

2.   extension of the city sewer system into primarily  rural lands in western
    Cranston to allow for future growth of the  city,  and

3.   reduction of storm water inflows and ground water infiltration into the
    existing sewers to eliminate costly waste of treatment plant capacity.

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The purposes of the proposed action are to forestall forecasted,  future overloading
of the existing treatment plant, to eliminate existing nuisance conditions (both
air  and water) in and near the lower reaches of the Pawtuxet River, to meet new
water quality classification of the reaches of the Pawtuxet between the municipal
treatment plant and these lower reaches, and to facilitate the orderly and balanced
growth of the community.

Figure 1-3 shows the location of the treatment plant, the industrial and insti-
tutional discharges to be eliminated, the existing extent of municipal sewerage
within Cranston and the area of the city into which  sewerage extensions are
proposed.
                                                             Industr'ia! Treatment
                                                             ?|ant (To be abandoned )
                                                Stuage Treatment
                                                     To be En breed)
                                              InStitutionsTreatmtnt Plant
                                          ( To be abandoned )
       Figure 1-3  LOWTlON  OF T^090SEO -ftCTlON
                            Cransfon

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                     The principal  characteristics of the existing and proposed wastewater treatment
                     plants are shown  in Table  1-1.
                                                             Table 1-1

                                            PplNf:iPAI.J_llARACTJRISTICSJJfJXISTINC AND
                                            Tjfoi :osTi> wAsY|^\yAl]jiXRr^.yr/NT_pLAN/I s_
                                  Extent of trpjilmrnt
                                                                     Existing

                                                                     secondary
                                  Plnnl rapacity                        H.tmgd

                                  Limiting water quality condition downstream Class E

                                  Population served                     68.000

                                  Sludge disposal method                 anaerobic
                                                                     digestion t
                                                                     on-sito
                                                                     stockpiling
       Proposed

       secondary and
       ammonia removal

       23.0 mgd

       Class D

       93,000

       Incineration with
       on-site ash dis~
       posal
                      The major elements  of the cost and  proposed sharing of costs is shown in
                      Table 1-2.
                                                         TABLE. .1-2

                                                 OF COSTS AMD  PROPOSED SHARING OF COSTS
                                                     Wastewater    Sewers for
                                                     Treatment     Western
                                                     ? \a_nt	    Cranston

                                Total Cost, not
                                including oo
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1.1  SUMMARY OF SIGNIFICANT  IMPACTS



            The section below presents in summary form:

            1.     In Section 1.11, the environmental impacts of the project,

            2.     In Section 1.12, a program of mitigating actions that should
                  be explored and, where appropriate, implemented concur-
                  rently with the wastewater treatment facilities improvements
                  included in  the proposed action.
  1.11   REQUIREMENTS OF SECTION 102 (2) (C) -OF THE NATIONAL ENVIRONMENTAL
        POLICY ACT OF 1969

        The National Environmental  Policy Act of 1969, pursuant to which this state-
        ment has been prepared, specifies in section 102(2) (C)  that every recommenda-
        tion for major Federal actions significantly affecting the quality of the human
        environment include a detailed statement on:

         (i)   the environment impact of the proposed action,

         (ii)   any adverse environmental effects which cannot be avoided....

        (iii)   alternatives to the proposed action,

         (iv)  the relationship between  local short-term uses of man's environment
              and the maintenance and  enhancement of long-term productivity,  and

         (v)  any Irreversible and irretrievable commitments of resources which
              would be involved in  the proposed action	

        In general,  this statement attempts to do this for the significant, long-term
        impacts of the proposed set of actions, with the scope and detail of each
        effect tailored to the specific nature of the effect.  The sections below sum-
        marize all the included analyses and expositions of the statement within the
        framework of the statutory items (i) to  (v) above.

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(i)  THE ENVIRONMENTAL IMPACT OF THE PROPOSED PROJECT

    The proposed project is expected to have three principal environmental
    effects:

           1.  significantly improve the water quality of the Pawtuxet River,

           2.  expand the economic base and housing supply of the City of Cranston, and

           3.  eliminate an odor nuisance in and near a residential area.

    The water quality improvement will include:

           1.  upgrading of the conditions of a short but critical section on the
              lower reaches of the river so that the entire river system will
              be reopened to anadromous fish,

           2 .  upgrading of conditions of a short but critical section of river
              just below the outfall of the treatment plant to allow migration
              of the indigenous fish between the main stem of the river above
              the treatment plant and a major tributary, the Pocasset River, just
              downstream, and

           3.  preclusion of nuisance conditions in the urban areas through
              which the river flows including the Pawtuxet Village,  a  major
              17th century settlement listed in the National  Register of Historic
              Places.

       The expansion of economic base and housing supply will result from
       expansion of the wastewater system's capacity and from extension of
       sewers into  undeveloped  lands.   This expansion is expected to have
       the following effects:

           1.  significantly increase the supply of fully serviced industrial
              land in the Providence metropolitan area, an  area with sub-
              stantial and persistent unemployment, and

           2.  significantly increase the supply of fully serviced land available
              for housing in the City of Cranston, again a clearly needed
              addition.

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                       The impact of these effects will include increased sewage flows, change
                       of rural land to urban uses, possible increase in stormwater runoff,
                       increased traffic and traffic noise, possible increase In traffic accidents,
                       increased air pollutant emissions, increased employment, increased
                       Incomes and Increased local tax base.  It Is not expected that the proposed
                       actions or their effects will generate so much new employment or incomes
                       as to induce a net in-migration into the region or to cause population
                       growth in excess of the region's natural increase.

                       The elimination of odor nuisance in and near a residential area will be
                       accomplished by shutting down an inadequate existing industrial waste-
                       water treatment plant and consolidating the industrial wastewater into
                       the expanded upgraded municipal treatment plant.
                   (H) ADVERSE EFFECTS WHICH CANNOT BE AVOIDED

                       The adverse effects which cannot be avoided include:

                           1.   those related to disposal of solid wastes resulting from the waste-
                               water treatment process,  and

                           2.   those related to urban growth.

                       The unavoidable adverse  effects of solid wastes disposal include:

                           1.   a small  increase of total suspended particulates  (TSP),  sulfur
                               dioxide (SO2 ) and lead (Pb) in the air at concentrations believed
                               to pose  only a negligible impact on public health, and

                          2.   increased use of fuel for solid wastes incineration.


                        The unavoidable adverse effects  of urban growth include:

                          1.   short-term generation of noise, vibration, dust, stream siltation,
                              and traffic congestion during the construction period both, on a
                              small scale, at the treatment plant  site and, on a much larger
                              scale, generally throughout the city, as growth occurs.

                          2.   permanent loss of rural  lands, mostly forest with some farms,
                              to urbanization but not necessarily resulting in permanent loss
                              of the agricultural productivity of the rural lands, and

                          3.   long-term generation of traffic, traffic noise, and increased  air
                              pollution emissions.
8

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(iii)   ALTERNATIVES TO THE PROPOSED ACTION

      Alternatives to the proposed action that were studied and evaluated included:

          1.   alternative methods of wastewater treatment,

          2.   alternative methods of treated effluent disposal,

          3.   alternative methods of solid waste disposal,

          4.   the alternative of not extending the sewer system and rezoning
              now rural lands for urban use, and

          5.   the alternative of more aggressively extending the sewer system
              and rezoning now rural land for  urban use .

      The alternative methods of wastewater treatment included:

           1.  single stage biological nitrification,

           2.  two stage biological nitrification,

           3.  first stage biological, fixed film  nitrification,

           4.  high rate biological, fixed film nitrification,

           5.  physical-chemical treatment, and

           6.  biological-physical  treatment.

      The alternative methods of treated effluent disposal included:

         1.   land application  in western Cranston after secondary
             treatment and

         2.   discharge directly into the Providence River estuary after
             secondary treatment.

      The alternative methods of solid waste (sludge) disposal included:

         1.   off-site disposal in a sanitary landfill,

         2.   pasteurization and land application,  and

         3.   incineration and off-site disposal of the ash in a sanitary landfill.

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                    (iv)  RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIR-
                         ONMENT-AS PROPOSED IN THE PROPOSED PROJECT - AND THE MAtNTENANr
                         OF LONG-TERM PRODUCTIVITY                                      ~—

                         The proposed project is not expected to sacrifice the long-term produc-
                         tivity of the environment for short-term benefits. In the water environ-
                         ment, the project initially will improve the quality of the Pawtuxet River
                         benefiting the general  welfare by enhancing the surrounding neighbor-
                         hoods' esthetics and recreation opportunities including restoration of
                         the anadromous fishery, a significant productivity gain of itself.  In
                         the longer term, the proposed action will not preclude further improvement
                         of water quality in the future, since it leaves open the possibility of
                         upgrading the plant, of future pumping of the effluent to the sea, to
                         land irrigation use,  or even back to the headwaters  reservoir with
                         further treatment for complete recycling.  This is in contrast to one
                         of the alternatives that was considered, lesser treatment with discharge
                         into Narragansett Bay, an alternative that would tend to preclude reuse
                         of the water or deepwater discharge in the future.

                         On the land environment, the project will convert relatively large amounts
                         of  rural land to urban  use, about 7 square miles, but this is not expected
                         to  reduce long-term productivity.  At the present time most of this
                         land is in small holder forest and farm. The forest is used only for
                         firewood for the most part, with the actually farmed lands  declining
                         year by year.  In general the high labor costs, small field size, shallow
                         stony soils,  irregular  topography, excessive nutrient leaching, etc.,
                         limit long-term commercial agricultural value.  Conversion to house lots,
                         while eliminating its commercial farming value, will not reduce its value
                         for home garden crops, home fruit trees, flowers and microclimatic
                         modifiers (shade and windbreakage) in residential areas.  If and when
                         this land is ultimately  needed for food production in the very far future,
                         the large populations living on it might be able to supply the intensive
                         labor, presumably  as a hobby, necessary for high yields.


                    (v)  IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES

                         The proposed project requires a commitment of money, manpower
                         and materials for its construction;  of money,  manpower, chemicals and
                         fuel for  its operation;  and of land, in very small amount,  for the treat-
                         ment plant and,  in fairly large amounts, for urban growth.
10

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1.12   REQUIREMENTS OF SECTIONS 102  (2) (D) and 102  (2) (F) OF THE NATIONAL
      ENVIRONMENTAL POLICY ACT OF  1969

      Section 102(2} (D)  requires that all agencies study, develop, and describe
      appropriate alternatives to proposals which involve conflicts concerning
      uses of resources, and section 102(2) (F) requires  that all agencies make
      available to states, municipalities, individuals, etc, advice and information
      useful in restoring, maintaining, and enhancing the quality of the environment.

      This statement  includes such alternatives, advice and information. Specific
      attention is called  to the analysis of the difficulties  of accepting "no-growth"
      as an alternative to the proposed action in the chapter titled "Need For Growth"

      Advice and information on maintaining and restoring  environmental quality
      is included as proposed "mitigating actions" wherever there appears  to be
      a possibility of avoiding an adverse environmental  effect by implementation
      of the mitigating action.  These potentially adverse but avoidable effects
      and the mitigating actions that appear to be most likely to either obviate or
      soften their adverse effects, include:

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Runoff related effects - western Cranston:


   ].   Increased stormwater runoff and runoff pollution resulting from increased
       paving of urbanizing areas.

             Recommended mitigating actions include:

             a.  requirement by the City of Cranston that all development permitted
                under either a building permit or a land subdivision permit be
                designed to store enough of its runoff waters on-site so that the
                developed stormwater runoff will not exceed the undeveloped runoff, and

             b.  construction by the City of Cranston of stormwater impoundment
                reservoirs on the main streams of the major tributaries,  where
                feasible, to supplement the on-site run-off regulation measures
                described above.

             Collateral adverse effects of these mitigating actions would include:

             a.  increased cost of land development, and

             b.  possible loss of cultural (archeological) resources at the main
                stream dam sites.

             Second stage mitigating actions would include:

             a.  compensatory relaxation by  the City of Cranston of zoning and
                building requirements  not essential to precluding adverse
                environmental and/or performance characteristics of proposed
                developments, and

             b.  submission by the City of Cranston to the same cultural resource
                protection procedures in planning and design of stormwater impound-
                ment reservoirs  as are required  of EPA under Executive Order 11593.

             Collateral benefits of all these mitigating actions are expected to include:

             a.  enhancement of the appearance of the future urbanization by in-
                creasing its visual variety and preserving open and/or wooded
                spaces, and

             b.  enhancement of the wildlife habitat values of the urbanizing area by
                providing a greater variety  of size and type of habitat areas than
                would otherwise be likely  to occur.

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Traffic related effects - western Cranston:
     2.   Increased traffic congestion, traffic accidents and traffic noise resulting
         from increased urbanization.
              Recommended mitigating actions include:

                  construction of a new acoustically-attenuated, controlled-access,
                  limited-speed roadway westward from the end of Route 37 through
                  western Cranston to serve the urbanizing area.

              Collateral adverse impacts of the mitigating action include:

                  commitment of substantial land areas to the roadway and to its
                  acoustical buffer zones,  reducing municipal tax base and urban
                  growth areas.

              Mitigation of this collateral adverse impact would include:

                  intensification of land use  (by rezoning by the City of Cranston)
                  along the proposed new  roadway and its buffer zones where con-
                  sistent with adjoining land uses.

              Collateral benefits of these mitigating actions include:

              a.  enhancement of the appearance of the future urbanization by
                  preserving  significant, and readily  visible, unbuilt areas,

              b.  enhancement of the recreation opportunities, i.e. bicycleways,
                  bridle trails, streamways, etc. of western Cranston by preserv-
                  ing significantly large and continuous unbuilt areas, and

              c.  enhancement of the future wildlife habitat of western Cranston
                  by preserving significantly large and continuous unbuilt areas.
                                                                                  13

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Impacts on special resource values - western Cranston:


    3.   Destructionof areas of special resource value (cultural, historical,
         ecological, esthetic, geologicaljby construction of pipelines through
         the resource site

              Recommended mitigating actions  include:

              a.   identification of the areas of  special resource value to permit
                  appropriate state and local agencies to plan their programs in
                  such manner that the special areas can be protected,

              b.   relocation of the proposed pipelines away from the areas of
                  special resource value, and

              c.   acquisition of all or  key portions of the special areas as public
                  reservations.

     4.    Destructionof areas of special resource value (cultural, historical,
          geological, esthetic and ecological) by inducing increased stormwater
          runoff and traffic through the resource site as a consequence of urban
         growth.

              Recommended mitigating actions  include all the actions recommended
              to mitigate similar adverse effects in non-special  resource value areas
              as described in items 1 and 2 above.

              Collateral benefits of the entire set of mitigating actions could lead
              to establishment of a new park that:

              a.   protects and sets forth  the rather complete evolution of man's
                  changing relationship to his environment from pre-colonial days
                  to the present as attested to  by the special resource areas of
                  Western Cranston,  and

              b.   sets a tone of quality for the inevitable urbanization of the
                  surrounding areas.

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Impacts on vicinity of Cranston wastewater treatment plant:


     5.  Destruction of areas of special resource value by neglect to rehabilitate
         areas partially destroyed by operation of the existing Cranston waste-
         water treatment plant.


             Recommended mitigating actions include regrading the subject areas
             to restore their values esthetically and as wildlife habitat.
     6.  Reduction in value and in utility of residences in the
         vicinity of the proposed treatment plant improvements
         by noise likely to be generated by the sludge incinerators,
              Recommended mitigating actions include monetary compensa-
              tion, receptor building soundproofing, and erection of noise
              barriers.
Impacts on water quality in the Pawtuxet River below the treatment plant:

       7. Creation of residual chlorine concentrations in excess of those ap-
         propriate to the water quality classifications of the river as a result
         of chlorination of the treated effluent.

               Recommended mitigating actions include use of alternative
               disinfectants or dechlorination of the effluent.
                                                                                   15

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             1-2    RESULTS OF THE ENVIRONMENTAL IMPACT ASSESSMENT  IN THE "FACILITIES
                   PLAN"

                   As part of the development of their "Facilities Plan1) the master plan for sewerage
                   for the City of Cranston,  the proposed actions for which this  statement has been
                   prepared, a comprehensive survey of Cranston's physical, social and cultural
                   environment was compiled and analyzed in a systematic, interdisciplinary manner
                   by the facilities planners, Universal Engineering Corporation of Boston, Mass-
                   achusetts, as required by the National Environmental Policy Act, section 102
                   (2) (A).  This systematic analysis identified all the expected impacts of the
                   proposed action, negative and positive, short-term and long-term, major and
                   minor.  The results of this analysis are shown in Table 1-3.   Note that the
                   impacts described,  in detail,  in this Environmental Impact Statement are those
                   identified in Table 1-3 as negative, major, and long-term.
16

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1.3   SCOPE OF THIS STATEMENT


      The preparation of any Environmental Impact Statement requires its authors to
      establish some middle ground between:


           *   compilation of an encyclopedic analysis of all possible areas of
               environmental impact, comprehensible only to patient experts, and


           *   oversimplification into a summary that does not allow its readers
               to fully appreciate the consequences of the proposed action,


      and between:


           *   analysis limited to those few parts of the environment traditionally
               within the scope of the proposing agency, omitting consideration
               of other important parts of the environment,  and


           *   analysis of the  impact of the project on all parts of environment
               however trivial, with the  result that important impacts might be
               obscured.


      The Council of Environmental  Quality has, over the years, sought to identify
      the middle ground,specifyfng  in its Guidelines for Preparation of Environmental
      Impact Statements, Section 1500.8 (6) that


           "... agencies should make every  effort to convey the required information
           succinctly.. .giving attention to the substance rather than form.."


      Further, in its most recent annual report, CEQ noted that


           V, .too many statements have been deadly, voluminous and obscure...
          with toe much space devoted to unnecessary description rather than to
          analysis of impacts and alternatives..."


      And finally, in its Memorandum For Head  of Agencies  on EIS's dated February
      10, 1976, CEQ stated


           "It is the Council's position, therefore, that descriptions of the existing
           environment and the proposed action should be  included in an EIS only
           to the extent that they are necessary for a decisionmaker to understand
           the proposal, its reasonable alternatives,  and their significant impacts.
           The EIS should explain how the scope of the statement and its level of
           detail have been carefully delineated in accordance with the significant
           environmental issues and problems foreseen by  the agency. Data and
          analyses in an EiS should consequently be commensurate with the impor-
          tance of the impact as determined by the agency's environmental analysis.
           Less important material should be summarized,  consolidated or simply
           referenced."

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The major issues foreseen by the agency, EPA Region I, and identified in its
Notice of Intent to Prepare an EIS and in its agreements with the City of
Cranston included, but were not limited to;

    1.   discharge to a water quality limited stream,

    2.   possible adverse air quality impacts of sewage sludge incineration,

    3.   possible violation of environmental laws,  regulations or standards
         resulting from development of presently undeveloped areas as a
         result of the proposed project,

    4.   odors  related to wastes of the Ciba-Ceigy Company, and

    5.   possible impacts on properties eligible for listing in the National
         Register of Historic Places.


In analysis of each of the above issues,  regardless of the desire for succinct-
ness, it still  remains necessary to comply with the requirements of the National
Environmental  Policy Act to evaluate the alternatives to the proposed action
(Section  102  (2) (D)), to consider the trade-offs between  the short-term effect
of the proposed action and its long-term, irreversible effect (Section 102 (2)
(C) (iv)  &  (v)), to identify supplementary actions that might mitigate adverse
effects (Section 102 (2)  (F)),  and to do all the above in an interdisciplinary
manner utilizing not only  the natural  sciences but  also the social sciences and
the design arts (Section 102 (2) (A))  .

Given the complexity of the above objectives, given the broad range of issues,
and given the variance in scale and scope of analysis required within each
area of issue, this statement has been organized to treat each issue (or problem)
separately, in turn, with  each issue treated at a scale and level of detail appro-
priate to  itself, each as an independent  statement.
    a.    Chapter No. II
          Title:  Need for Urban Growth as an Issue

        Issues:

          1.  Given that an ultimate purpose of the proposed project is orderly
              urban growth,  is continued urban growth really necessary?

          2.  If it is, should  some of it be in Rhode Island rather than in other
              places?

          3.  If it should be in Rhode Island, should some of it be in Cranston
              rather than in other communities?
                                                                            19

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b.    Chapter No. Ill
      Title:  Water Quality

    Issues:

      1.   Will disposal of treated wastewater into the Pawtuxet River, a
          water quality limited stream, violate present minimum water
          quality standards?

      2.   Will the proposed action, designed to meet the present mini-
          mum water quality standards within the timeframe specified
          in current law, tend to preclude alternative actions that may
          be desirable in the long-term  (but not feasible immediately)
          or will it tend to commit the Pawtuxet River,  the Providence
          River Estuary,  the Pawtuxet Village Historic District and the
          surrounding urban areas,  in an irretrievable manner, to
          less than optimum quality ?

    Alternatives:

      1.  Effluent discharge into the Providence River Estuary,  into
          Narragansett Bay, or into Block Island Sound.

      2.  Regionalization of sewerage.

c.    Chapter No. IV
      Title:  The Impacts of Sludge Treatment and Disposal

     Issues:

       1.   Is incineration  of sewage sludge the best method for dis-
           posing of Cranston's sludge?  Evaluation of this can be
           considered from at least two points-of-view, i.e., possible
           violation of clean air standards and comparison with alter-
           native disposal methods.

       2.   Will  the proposed action tend to preclude  more desirable ,
           alternative disposal methods that might be developed in the
           foreseeable future either as a result of changing technology
           or changing political or administrative institutions?

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    Alternatives:

      1.  Landfill, on or off treatment plant site.

      2.  Coincineration in a future regional resource recovery system.

      3.  Land application as a composted soil conditioner, as a fertilizer,
          or as a component of a substitute for natural topsoil.

d.    Chapter No. V
      Title:  Neighborhood Nuisance

    Issues:

      1.  Will there by any adverse effect upon the surrounding neighbor-
          hoods as a result of odor or noise?  at the treatment plant?  at
          sludge disposal sites? along the river downstream from the
          treatment plant?

      2.  Are there alternatives that would preclude  nuisance?

      3.  Are there actions that can be taken to mitigate nuisance?

      4.  If adverse impacts are unavoidable, are the adverse impacts
          justified by the anticipated benefits?

e.    Chapter No. VI
      Title:   General Impacts of Urban Growth

    Issue :
                                              i
      1.   What effects would urban growth  in western Cranston have
          on the environment, physically, socially, esthetically?

      2.   What alternative growth patterns or standards are available
          to preclude adverse effects?

      3.   What alternative growth patterns or standards are available
          to mitigate adverse effects?
                                                                      Z\

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f.     Chapter No. VII
      Title:  Specific Problems of Urban Growth in Western Cranston

    Issues:

      1.   Will the proposed action and its associated secondary effects
          have any adverse impact on any specific sites, facilities or
          locations of special  cultural, historical, social, esthetic or
          ecological significance?

      2.   Are there prudent and feasible alternatives that preclude the
          adverse impacts?

      3.   Are there prudent and feasible actions that might be taken to
          mitigate the adverse impacts?

g     Chapter No. VIII
      Title:  Overall Impacts on the City as a Whole

    Issue

      1.   What effect will the set of actions proposed have on the city
          as a whole in the long term,  given the city's overall socio-
          economic  milieu?

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NOTE ON THE CONSISTENCY OF DATA AND ON INTERPRETATIONS OF
FORECASTS

And finally, it is important to note at the outset, that the data, forecasts
and assessments of impact presented in this statement, in the Facilities
Plan, and in the various city and state planning reports were derived
from a variety of sources, by a number of agencies and individuals, with
varying experience,  fields of expertise, and points of view, at different
points in time.  As a  result there are discrepencies between this state-
ment and other planning reports.  These discrepencies should not be
construed as evidence that any of the documents  are in error or have
not been researched  and prepared by competent professionals, but
rather they should be taken as evidence of the rapid development of
the environmental sciences, their data resources, and analytical techniques.

On the matter of discrepencies between forecasts,  it should be noted that the
future is inherently unknowable, that unforeseen conditions can and do occur
with distressing frequency and regularity, and that to act on the assumption
that the future is indeed known is probably one of the surer courses to error.
It is  suggested that the reader upon coming to such a discrepancy in forecasts
not take the discrepancy as evidence of error, but rather as a caution  on
accepting any forecast at face value.

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CKoDtir  B    THE  NEED  FO^  61)0101*1
                  -AS  ^N  issue
 2.0   INTRODUCTION

       The proposed action includes both pollution abatement and capacity expansion.
       It is assumed that pollution abatement is not a controversial environmental
       issue but that capacity expansion can imply some fundamental  environmental
       issues including that:

            there is a need to expand, and

            the proposed expansion would be best served in the proposed manner
            at the proposed location.

       As a basis for evaluating these assumptions, as applied to the proposed project,
       the following subjects are briefly explored below:

       1.  National growth needs.

       2.  Rhode  Island's fitness for urban growth in comparison with other
          geographic regions of the nation.

       3.  Cranston's fitness for urban growth in comparison with other regions
          of Rhode Island.

       The growth alternatives that might be adopted,  their probable  impacts,
       and actions that might be taken to mitigate those impacts are explored below:
 2.1    NATIONAL GROWTH NEEDS

       As the birth rate of the United States continues to decline for the 20th
       consecutive year, from a peak of about 25 births per thousand persons
       per year in 1957 to something under 15 at the present time, the questions
       of whether any new utilities are indeed required, and if so, on what scale,
       do appear to be legitimate.

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The answers to these questions, paradoxically, are, yes,  new utility
expansions are necessary somewhere in the nation, and they are necessary
on a  large scale in the near future.
The basis of the answers can be found in analysis of the totality of the nation's
demographic characteristics and primarily  in the phenomenon that as the
nation's population of children is declining, its population of adults in
increasing.  Simply viewed, as the post-World War II "boom babies"
mature, the adult population will increase rapidly for some time into the
future regardless of what happens to the birthrate.  Figure 11-1 United
States Population by Age,  1970-1990, from the U.S, Bureau of Census,
shows the broad outline of the anticipated maturation of the population.
                     1970
                             Age Span
                          1990
                              75
                              70-74
                              65-69
                              60-64
                              55-59
                              50-54
                              45-49
                              40-44
                              35-39
                              30-34
                              25-29
                              20-24
                              15-19
                              10-14
                               5-9
                               0-4
                           0         0
                          Millions of People
                                I
                                10
20
UNITED
                                 1WULATI0M  t*>Y

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Tht elements of this maturation will  include:


a.   Decrease In the number of teenagers In the population,


b.   Substantial  increase in both the percentage and absolute number
     of young adults, say from 25 to 34 years old,


c.   Decrease in the percentage of people 45 to 54 years old,


d.   Significant increase in the percentage and absolute number of
     senior citizens, say people over 65 years old, and perhaps most
     interestingly,


e.   Significant increase in the number of younger children resulting
     from the ultimate reproduction of the post World-War II boom-babies,


The social and economic consequences of this prospective change are
well described in "Population and the American Future",  the Report
of the Commission on Population Growth and the American Future,
submitted to the President and Congress of the United States in
March 1972:

         "Now, as the youth cuuure or tne sixties evolves into the
         young adult society of the seventies, the Impact is being felt in
         the housing and job markets.  In the two decades before 1965,
         about 48 million Americans reached the age of 20. Between 1965
         and 1985, over 78 million will cross this important threshold.

         *As those born during  the baby boom move off the campus
         or leave their parents'  homes, we can expect a 33-percent jump
         in annual  household formation by the end of this decade. Between
         1950 and 1966, the number of households grew at a relatively
         steady rate of around 900,000 per year.  After that, the rate
         began to climb, and last year we added well over one million
         households.  Our research shows that the rate will increase to
         almost 1.5 million households added each year by the end of the
         seventies, and will remain at that level until about 1985. These
         figures understate future demand for the construction of new
         housing,  since additional new housing units will be required to
         replace part of the older housing stock.


         "Alonp with increased housing demands will come greater
         demand for employment opportunities. The highest rates of
         joblessness are found among the young.  Consequently, one
         factor to be considered, irrespective of the state of the economy
         Itself, Is the sheer increase in the numbers of young people
         seeking work. The Bureau of Labor Statistics tells us that we
         can expect about 3 1/2 million persons to make their initial
         entry Into the labor force each year during the 1970's.  This
         level of prospective job seekers exceeds the annual average
         for the 1960's  by about 700,000 persons a year.  Here again, we
         can attribute the large numbers to a heavy influx of new job-
         seekers who were born during the baby boom.

         "In sum, it should be evident that, even if the recent unex-
         pected drop in the birthrate should develop into a sustained
         trend, there Is little cause for complacency. Whether we see
         It or not -  whether we like It or not - we are in for a long period
         of growth, and we had best prepare for it."

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             2.2   SUITABILITY FOR URBANIZATION, RHODE  ISLAND  & CRANSTON

                   If one grants, based on the foregoing analysis, that new housing and work-
                   places will be needed in large amount in the near future,several new questions
                   arise, i.e. should part of the growth occur in Rhode Island; if in Rhode Island,
                   should it occur in Cranston; and if so, how much. The section below explores
                   the first two of these, i.e.  the issue of Rhode Island's suitability for growth
                   vs. other parts of the United States, and the issue of Cranston's suitability
                   vs. other areas of Rhode Island.  The question of how much growth is
                   appropriate for Cranston is largely a matter of what environmental impacts
                   various amounts of growth would generate, the subject of Chapter VI.

                   2.21     RHODE ISLAND VS. UNITED STATES

                          The issue of whether Rhode Island should play a continuing  role in
                          supplying the growth  needs of the nation can be viewed  as a social
                          or moral  issue, as an  ecological issue, and as a geographic phenomenon.

                         2.211   As a Social Issue

                              In a moral sense,  (or alternatively as an issue of social justice,
                              social equity, social stability, or protection of the general wel-
                              fare) it has long been a tenet of the culture of the overwhelming
                              majority of the population of the United States that they are, to
                              some extent, their brothers' keepers,  that they have been
                              brought up to feel an obligation to provide for both their own
                              individual progeny and for their neighbors'.  They do tax
                              the employed to feed the unemployed; they do tax the childless to
                              pay for the schooling of their neighbors' children; and they
                              do require, under penalties prescribed by law, fathers to support
                              their  children.  The post-war "boom babies" are,  in part, their
                              own children and their neighbors' children and it  can be said
                              the society will feel an obligation to insure that their children
                              can find both jobs  and housing in the reasonably near future.

                        2.212   As  an Ecological Issue

                              In an ecological sense, comparisons can be made between
                              Rhode Island and the rest of the United States as a suitable
                              urban habitat,  specifically with regard to their relative potential
                              for high air pollution, their relative availability of water, and
                              their  climate.
2.8

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2.2121  Air Quality Resources

        Figure II-2, Days  of  High Air Pollution Potential
        Forecasted taken from THE NATIONAL  ATLAS of United
        States of America  published by the United States Geolo-
        gical Survey,based on data provided by the National
        Center for Air Pollution Control, shows the relative
        susceptibility of the various parts of the country to air
        pollution problems, or the relative difficulty of con-
        trolling air pollution  concentrations in those areas.
                                                    RHODE ISLAND
                         teO 
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                            2.2122  Water Supply Resources

                                   Figure 11-3, Anticipated Water Shortages in the
                                   United States taken from POPULATION AND THE
                                   AMERICAN FUTURE based  on a paper on "Future Water
                                   Needs and Supplies" by Ronald C, Ridker for the
                                   Commission on Population Growth shows the relative
                                   availability of potential water supply in excess of demand
                                   in the United States.
                                        rut  UWIT&D
                                         on
                                                        , 1172..
                                   Note that Rhode Island is well into the zone of excess
                                   potential supply over demand and note also that the
                                   regions of impending shortage include some of the
                                   fastest growing states in the nation.

                                   Figure II-4, Basic Resource Availability simply super-
                                   imposes Figures  II-2 and  II-3.  Note that the regions
                                   of low forecasted air pollution potential and abundant
30

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Cvtr (0O Jay* ff( hmlv an- p0lluiti0«1 pffltntigl ptt y/ar
C^tr 40 Jay* a( hi^K. 3«r fffllulicx.  potential per yt&r
Ovtr tO dty* fff htqk. 3ir pcnutie*. poitrtitl ftr
O - 2.0 di\i$ of kijk t\r pffllu+iffn  paitKti&l fir
W*ty  2.000
      dtfie.d by
  en
water include  only eastern Maine, Southeastern New
England, the Carolina Capes, central Florida, the upper
Mississippi Valley and the western Ozarks.
The major urbanized  areas of these favored regions include
Bangor, New Bedford/Fall River/Providence, Tampa/St.
Petersburg, Palm Beach/Ft. Lauderdale/ Miami, Minneapolis/
St. Paul, Cedar Rapids/Des Moines,  and Tulsa/Ft. Smith.
                                                              31

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2.2123  Climate
        Rhode Island enjoys a relatively moderate and even climate,
        tempered by its location on the seacoast, surrounded by the
        ocean on two sides.  Its temperatures range from a normal
        minimum for January of 20.6° F to a normal maximum for
        July of 81.1°F with record peaks of -15°F in winter and
        +100°F  in summer. The moderation that this range in tempera-
        ture represents can,  perhaps, be best grasped by noting
        that of the 70 major cities whose climate is reported on  in the
        Statistical  Abstract of the United States  (at least one in  each
        state),  33  had lower winter record temperatures than
        Cranston and 57 had higher summer record temperatures.

        This moderation in temperatures  is reinforced by Rhode
        Island's relatively low relative humidity,  averaging 74%
        at 7: 00 a.m. and 55% at 1:00 p.m., for the year.  This
        compares well for comfort with the rest of the 70 cities,
        57 of which exceeded Rhode Island's 7:00 a.m. relative
        humidity and 46 of which  exceeded its 1:00 p.m. relative
        humidity.

        Rainfall is both  ample and well distributed throughout
        the  year.  The average annual precipitation is 42.75
        inches  with no month normally having less than 2.65
        inches  and none having more  than 4.52 inches.  The number
        of days of some rain per month ranges from 8 to 12 with
        6 months averaging 11.

        Sunshine is similarly well distributed throughout the
        year but is limited to occurring only 56% of the time,
        somewhat  less than 60% that is the median of the 70 cities.

        The state is well-ventilated with  an average annual
        wind speed of 10.9 miles per  hour, well above the median
        of 9.3 miles per hour of the 70 cities and exceeding the
        annual average of 58 of them.  The region's winds are
        well distributed through the year and range from a monthly
        peak of 12.6 mph  in April to a low of 9.7 mph  in July,
        August, and September.

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2.213    As a Geographic Phenomenon

       Looking at Rhode Island's relative suitability for growth in
       terms of classical economic geography  (or,  alternatively,
       social ecology),  note, as introduction,  the words of
       Preston E. James in A Geography of Man:
            Most parts of the earth's surface are empty of human Inhabi-
            tants.  Vast areas are only very thinly peopled, with small
            communities separated by many miles of empty land. In
            southeastern Asia, on the other hand, about half of all the
            people In the world are crowded into less than a tenth of
            the world's habitable area.  In Europe a little  less than a
            fifth of mankind is occupying an area which amounts to
            less than one twentieth of the habitable world.

            Yet to draw the conclusion that a great movement to the
            empty lands of the world is about to take place would be quite
            wrong.  People are concentrated in certain parts of the world
            because these parts offer greater opportunities for the support
            of human life than other places. These opportunities are in
            part the result of the resources  of the earth itself, and in
            part are man-made.  But the tendency today, as always, is
            for people to move fronvareas of lesser to areas of greater
            economic opportunity. The population in areas of concen-
            trated settlement is becoming more concentrated; the population
            of thinly peopled areas is becoming thinner.
       Rhode Island historically has been an area into which people
       have moved,  for hundreds of years,  despite its economic ups
       and downs, despite its limited mineral resources, despite its
       limited agricultural resources, despite its limited fuel.   Pre-
       sumeably, compared to other areas, it has nonetheless been
                                                                              33

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                                    an area of greater economic opportunity,  and it appears to
                                    offer as its  major development resource, its social infrastruc-
                                    ture and its existing urban services nucleus.  The importance
                                    of these kinds of resources was noted by Richard L.  Morrill
                                    in his introduction to The  Spatial Organization of Society
                                    in 1974:
                                        Geography has traditionally pointed out that certain areas
                                        are more useful or attractive than others. They might be
                                        favorable for specific economic activities, or they might be
                                        focal  points for trade factors	as the abstract characteristics
                                        of space (for example, distance and accessibility), and the
                                        variable quality of the earth's surface	and upon other
                                        factors that are not strictly geographic... .including economic,
                                        political, and cultural determinants	Perhaps the most
                                        Important determinant of all  is the sheer force	of past
                                        patterns of development.
                                    On the mechanism by which the past pattern operates he pointed
                                    out:
                                         Economically, production efficiency is increased by associ-
                                         ations of related industries,  such as the clustering of small
                                         subcontractors around large automotive and aircraft complexes.
                                         Distribution efficiency is gained by grouping the buyers and
                                         sellers of goods and services in such  places as fairs,  the
                                         market town, and the shopping center.  The proximity of
                                         various shops stimulates impulse-buying, thus increasing
                                         business turnover and regional consumption in the area.
                                         Not only does agglomeration  reduce the total distance that
                                         people travel, satisfying a geographic goal, but it enables
                                         them to satisfy many purposes with little effort.
                                    On the size of city that does this most effectively he pointed out:
                                         Not until a city reaches a size of 250,000 to 350,000 people
                                         does it attain a threshold that can provide some self-sufficiency
                                         In central place services,  support high-quality cultural and
                                         educational amenities, and also attract modern industry. It
                                         Is not surprising, then, that as transportation improves,
                                         larger places ar^ the locus of most net growth.  Places from
                                         about 200,000 to  perhaps two million appear most attractive
                                         at the present time,  evidently because they can support
                                         a very wide range of services and activities, are rather
                                         self-sufficient, and can support an efficient internal transport
                                         system without the severe social costs and congestion of
                                         the giant metropolis.
                                   Note that the Providence Metropolitan Area falls right in the
                                   center of Merrill's optimum  size range.
34-

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2.22    CRANSTON VS. OTHER COMMUNITIES IN RHODE ISLAND

      The issue of whether Cranston, or more precisely, western Cranston,
      should play a significant role in accommodating the growth of population
      of Rhode Island is, in some senses, similar to the issue of whether
      Rhode Island should do so  with regard to national growth. The social/
      moral  issue and the geographic phenonema are similar to  the larger ones
      that apply when one considers Rhode Island with respect  to the nation,
      the resource use factors, in contrast, are not so clear cut and militate
      both for and against development  in western Cranston, and  the economics/
      jobs/industrial development issue achieves special significance.

      2.221   As  a Social  Issue

            This issue is virtually identical to that of the Rhode Island
            growth issue and need not be separately discussed.

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2.222    As a Social Ecological Phenomenon

      As a social phenomenon, American cities historically have
      grown by accretion of new development, mostly housing,
      around their perimeters with gradual change of the older
      core to non-residential services.  The extensive urban re-
      newal activities of the 1950's and 1960's did not reverse this
      trend and in fact may have accelerated it.  Figure 11-5,
      Population Changes in the Providence Urbanized Area, 1930-1970,
      show this tendency quite clearly.
.Figure n- 5  fl?FULATi0N
                                                   rwe

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In the future,  it does not appear reasonable to expect so long-
standing a phenomenon to change.  The Commission on  Population
Growth and the American Future agrees and stated in its report:
      "A third problem lies in the expanding periphery of
       metropolitan areas. During the rapid expansion of
       suburban areas since World War II, we failed to plan
       for anticipated growth, instead, we allowed it to
       spread at will.  Whether or not we arc past a popula-
       tion explosion,  it is clear that the land use explosion
       of "spread  city' is currently in full blcom. In the
       1970's and 1980's the baby-boom generation will marry,
       have children, and set up house in the suburbs creat-
       ing a tremendous demand for the conversion of rural
       land to urban use."

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                              Exactly where this conversion of rural to urban land will
                              occur in the Providence region is part of the decision implicit
                              in the proposed project, i.e. should this conversion occur
                              in western Cranston or elsewhere.  Figure 11-6, Cranston
                              and the Providence Urbanized Area, shows the relationship
                              between Cranston and the Providence Urbanized Area as defined
                              by the United States Geologic Survey in its 1: 250,000 map series.
                              Note that western Cranston lies quite close to the center of the
                              urbanized area and suggests that urbanization of western Cranston
                              would minimize urban sprawl and its associated costs.
                                                           A.WP TME. "P&7VIPEWCE,
38

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Figure 11-7, Surficial Geology  in the Providence Urbanized  Area,
in contrast, shows the patterns of urbanization and relative
soil developability for the same areas. Note that past urbanization
corresponded closely with easy to develop soils, that western
Cranston is mostly hard to develop soils, that there is an abun-
dance of easy to develop soils in other suburbs, as  in Coventry and
North Kingston, and, finally, that there is a close correspondence
between the suburbs whose growth has accelerated  most dramat-
ically in recent years, see Figure 11-5, and the large areas of
easy to develop soils.  All these taken together suggest that with-
out overcoming Cranston's soils problems,  i.e. installing public
sewers, urban growth in Rhode Island would tend to spread even
further out into more distant  rural areas.

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                          2.223   As an Environmental  Resource Use  Issue
                                The principal resource-use issues that bear on the development
                                of western Cranston vs. other Rhode Island suburbs centers
                                on  the preservation of productive and attractive farmlands.
                                Figure 11-8,  Status of Agricultural  Lands in  the  State of
                                Rhode  Island, from the state's -Land Use Policies and Plan
                                indicates that western Cranston contains some of the best
                                agricultural  land in the state and certainly the best near the
                                urbanized areas; and Figure 11-9, Cleared Lands,  shows the
                                extent of lands either farmed or pastured, now or  in the
                         M*ss*cHusrns
40
                                               .^

                                \J  -KvuNSTOfJ \^-'

-------


                                                LUooded lands

                                               Cleared Lands

                                                E-q
                                          SOURtt: U.S. GtOiflGlCAl
                                                             Cranston
x.
                   fairly recent past, in western Cranston as indicated on re-
                   cent U,S, Geological Survey maps.  Whether these lands
                   should be preserved for agriculture is a complicated
                   issue and can be viewed in many ways including as infringe-
                   ment on private property beyond the business of the state,
                   as an irreplaceable productive resource, as a component
                   of the state's economic  base, as an esthetic resource, etc.

                   The agricultural lands  in question are privately owned
                   and the owners generally cannot be deprived  of their
                   rights to develop,  subject to the same limitations placed
                   on other lands, without compensation.  In part,  it can
                   be assumed, that some  of this land has been kept in
                   agricultural use only for the purpose of generating cash
                   flow while the development market has been ripening.

                  The question of preserving the agricultural land as
                  a needed food production resource for that time in
                  the distant future in which the world's population will
                  be pressing sorely upon the world's productive capa-
                  city can be viewed  from at least two viewpoints,  i.e.,
                  the question of whether Rhode Island's total agricul-
                  tural  land or output is meaningful when compared to
                  its food needs and the question of whether residential
                  development really precludes food production.

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                                On whether Rhode Island's agricultural lands or food
                                production is statistically meaningful, the U.S.  Census
                                Bureau's County and City Data Book,  1972 indicates
                                that Rhode Island as a whole included only 1/15000th of the
                                nation's farmland and produced only 1/3000th of its total
                                retail food purchases. Looked at another way, Rhode
                                Island's retail food purchases were about $325 million
                                per year in the late 1960's while its annual commercial
                                agricultural output was only about $15 million.  Adjusting
                                these figures for the spread between farm and retail
                                prices to allow for distribution costs,  Rhode Island's
                                production amounted to only about 10% of its purchases.

                                On whether residential development will permanently
                                preclude food production it is important to note that the
                                large-scale agriculture of the American Mid-west is oriented
                                toward low-cost production  in an  economic {return on
                                investment)  sense and not on highest yield per acre.
                                High yields usually are achieved  by intensive  care, a
                                condition that can exist in backyard gardens,  or as they
                                used to be called,  the"tofts of croft" agriculture.
                                          v
                                Comparison of the value of Rhode Island's agriculture
                                with that of its other basic production industries, from
                                the County and  City Data Book,  1972 shows commercial
                                agricultural output at about $15 million, mining output at
                                about $5 million  and  manufacturing output at about one billion
                                three hundred and fifty million, all  per year  in the late
                                1960's.  Of these basic production industries,  agriculture
                                in Rhode Island constituted only 1%.  Adding the service
                                industries, i.e.  trade, construction, finance,  education,
                                repair, etc., to  the total, agriculture would constitute less
                                than 1/2 of 1% of Rhode Island's total economy.

                                And finally while much of the farmland in western Cranston
                                is visually attractive, it must be noted that farmland, and
                                the specialized structures usually associated with it, is not
                                always attractive and that urban development, if properly
                                designed in an esthetic sense,  with sufficient  preserva-
                                tion of vegetation and open spaces,  can be fully  as attractive.
                                In the final analysis, beauty is in the eye, and in the
                                cultural heritage, of the beholder.
42

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2.221   As an Economics/Jobs/Industrial Development Issue

      Key points to note with respect to economlcs/jobs/lndustrlal develop
      ment issues are:

      1.  Rhode Island currently has, and has had for some time,
          one of the worst unemployment problems in the nation and
          In the developed world, with about 1 out of every 8 people in
          the active labor force out of work and countless others either
          working fewer  hours than they would elect or not seeking work
          because they have no hope of finding it.  In all, about 50,000
          people in the state are or have recently been out of work and
          actively seeking jobs.

      2.  The potential annual increase in labor force of Rhode Island
           (youths leaving school minus retirees) is now larger than
          it ever was before as a result of the maturation of its own
           youth, about 5,000 to 10,000 new potential job seekers
           each year.

      3  The environmental costs of the income foregone as a result
          of unemployment are extensive including, as a result of:

           a.  increased crime and violence:

               1)  increasing flight of the middle-class from the
                   cities  to the suburbs,

               2)  urban neglect and decay, and

               3)  increased commuting and consequent air pollution;

           b.  reduction  of revenue to cities and states, in turn reducing:

                1)  capital expenditures for parks, recreation areas,
                   and isewage  treatment plants, and

                2)   housekeeping functions such as street and park
                    maintenance, etc.

        4   Cranston, particularly in the areas along its  expressways, at
            their interchanges, (given the city's excellent accessibility
            and  its public services, i.e. sewers, water, police and fire
            protection, etc.) is one of the best locations in Rhode Island
            for  new industrial, commercial, and services growth with
            such growth  likely to result in minimum aggregate commuting
            cost and minimum increase in public service costs.
         5.
The industrially zoned areas of Cranston,  developed with the
I,nd of industry typical of southern New England in recent
ylars  could provide about 10.000 to 15,000 new jobs.

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               2.3   SUMMARY & CONCLUSION

                     In sum, In answer to whether there should be growth in Rhode Island and
                     to whether some of it should be allowed to occur in Cranston, it appears that:

                     1.   such growth is inevitable, i.e. the children born during the boom of
                          the 1950's and early 1960's will mature and take their places in adult
                          society,

                     2.   the United States as a society accepts the responsibility of each genera-
                          tion to provide for its successors,

                     3.  Rhode Island, in general, and Cranston,  in particular, are more suitable
                          for urban growth than most of the rest of the United States,

                     4.   the loss of farmland in Cranston is not likely to lead to a significant
                          loss of long-term productivity in any large sense,

                     5.,   urbanization of western Cranston can be viewed as the "least sprawl"
                          alternative of the feasible growth choices available,  and

                     6.   the economic benefits, direct and indirect, immediate and long-term,
                          that would be generated by the proposed  growth  supporting action,
                          are sorely needed by Cranston and the State of Rhode Island.

                     The answer ultimately lies in the question of alternatives, i.e. is there
                     a responsible alternative to urban growth, generally, and to urban
                     growth in Cranston, specifically?
44

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            1     UWT«]   QUAUTV
3.0  INTRODUCTION

     The proposed action includes continued discharge of treated waste-
     water into the Pawtuxet River at the site of the existing  (and proposed)
     wastewater treatment plant.  Given:

     1.    that it will be necessary to expand Cranston's wastewater dis-
           charges to serve the orderly and balanced growth of the community.

     2.    that the water quality of the river must be improved to meet
           adopted water quality standards,

     3.    that the low flows of the river are relatively small compared to the
           wastewater discharges, and

     4.    that there are substantial pollution discharges into the river over
           and above those from the facilities directly related to this project,

     the following questions arise:

     1.    will the proposed action violate presently proposed minimum
           water quality standards.

     2.    will the proposed action tend to preclude any preferable longer-
           term alternatives or tend to commit the river to less than optimum
           quality in the long term?

     The sections below describe the river system into which wastewaters
     are to be discharged, the wastewaters, the proposed treatment process,
     alternatives that have been considered, and the effects of the treated
     wastewater discharge on the river.
                                                                             45

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3.1   BACKGROUND

      This section includes a description of the river environment into which
      the wastewaters will be discharged, both present and future,  and of the
      wastewaters to be discharged, quantitatively and qualitatively, at the
      present time and over the design life of the proposed plant.
     3.11  THE PAWTUXET RIVER

           The Pawtuxet River, the stream that receives the treated waste-
           waters of the City of Cranston and most of its industries now, and
           that is proposed to continue to receive them in the proposed pro-
           ject,  is a relatively small river in central Rhode Island, lying in
           large part within the Providence Standard Metropolitan Statisti-
           cal Area and including along its lower reaches a substantial por-
           tion of the Providence urbanized area.

           Figure 111-1 shows the extent of  its watershed reaching from the
           uplands  along the Connecticut state line in  the west, to the Provi-
           dence River estuary,  an arm of Narragansett Bay, on the east.
           The City of Cranston lies along the lowest reach of the Pawtuxet
           on its north side, the City of Warwick lies across the river to the
           south, the City of Providence lies just outside the Pawtuxet water-
           shed to the northeast.

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      LEGEND

ffi MMM ol 100,000 «r
                                                 9r ovidinci ,
-------
Figure 111-2 shows the principal water bodies within the watershed
including:

1.     the Scituate Reservoir system, the water source of the cities
      of Providence, Cranston and Warwick, on the North Branch
      of the Pawtuxet,

2.     the North Branch itself,

3.     the South Branch with a series of smaller industrial and
      flow  augmentation reservoirs,  and

4.     the "Main Stem"  of the Pawtuxet.

Attention is called to the Pocasset River System in eastern Cranston,
the Meshanticut River in central and  western Cranston, to Furnace
Hill Brook, the major tributary of the Meshanticut, and to the pro-
posed Big River Reservoir on the South Branch, an expansion of the
Scituate Reservoir system.

The overall area of the watershed is 232 square miles of which about
120   square miles is or will be intercepted by the Scituate Reservoir
system.

The flow of the river, measured just  above the Cranston treatment
plant, has averaged 406 cubic feet per seond (cfs)  or 262.5 million
gallons per day (MCD)  with a record maximum of 3,110 cfs and a
record minimum of 22 cfs. The one-in-ten year seven-day low
flow, the minimum weekly flow that is likely to occur once in ten
years, the  flow used in calculating compliance with water quality
standards, is 74.93 cfs or 48.4 MGD.  Note that this low flow is
only 5 times Cranston's existing wastewater  discharges (all out-
falls) and 2i times the  project average annual design flow, both
relatively small supplies of effluent dilutant. (The reader's at-
tention is called to the  fact that, in general,  the more the flow in
the waste receiving stream, the more, or dirtier,  effluent that may
be discharged without  lowering stream quality below any set quality
limit).

-------
of ti&Hk, -piy. *f Water 7*Hirt\on
, if 75".
              49

-------
                         The existing quality of water in the stream and the nearby bay
                         is shown in Figure 111-3, along with the location of the "point
                         source" polluters,  i.e. municipal sewer and industrial discharges.
                         The key to the water quality condition is shown in Table 3-1 and
                         to the point sources in Table 3-2.  The readers attention is called
                         specifically to the lowest reach of the river  (to the right) which is
                         Class "E", a potentially malodorous, nuisance condition; to point
                         source discharge #171, the Ciba-Geigy Company; #13, the Cranston
                         municipal treatment plant, to #234,  the Warwick municipal  plant,
                         and to the Meshanticut and Furnace Hill Brooks (in central and
                         western Cranston)  which are Class "B",  suitable for bathing,
                         fishing, and, if treated, for water supply.  Note also that the
                         portion of the Providence River estuary (to  the right), into
IE -3
                                                      WATTE*.  QUALITY  C0NPIT10IU
                                              of Health,  VM+ien of Water tfeilution  Control, I975-
50

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                                TABLE  111-1

                      KEY TO WATER QUALITY CLASSIFICATION
        Class A   Suitable for water supply,
         Class B   Suitable for bathing,
                 acceptable for public
                 water supply with
                 appropriate treatment.

         Class C   Suitable for fish habitat.

         Class D   Suitable for Industrial
                 processes and migration of
                 fish; good aesthetic value.
         Class E   Nuisance; unsuitable for
                 most uses.
Class SA
Class SB
Suitable for shellfish
harvest for direct human
consumption.

Suitable for bathing and
shellfish harvesting for
human consumption after
depuration.
Class SC  Suitable for habitat.

Class SD  Suitable for Industrial
        cooling and migration of
        fish; good aesthetic
        value.

Class SE  Nuisance, unsuitable for
        most uses.
      Wat«r Duality  Cla»*e*
   ©
   ©
   ©••*
   ©
Pollution
   Discharge
   Number

     13

    132

    153

    168

    171

    213

    228

    234

    315


    331

    414

    493

    525
                                                                       TABLE HI-2

                                                                 KEY TO POINT SOURCE DISCHARGES
                                        Name

                           Cranston STP

                           American Hoechst Corporation

                           West Warwick STP

                           Brlarcllffe Nursing Home SrP

                           C1ba-Ge1gy Corporation

                           Leesona Corporation

                           Falvey Linen Supply

                           Warwick STP

                           Providence STP and combined sewer
                           overflows

                           Narragansett Village STP

                           United Wire & Supply Corporation

                           Narragansett Electric Co.

                           Hope Sanitary D1st. Sewer
                       which the Pawtuxet discharges, is Class "SC", a good recreational
                       fish and wildlife habitat (but not for bathing) despite  the Pawtuxet
                       River discharge, an abrupt upward jump in class attributable
                       in part to the massive aeration of the  river as it passes over
                       the Broad Street dam just above tidewater and in part to the
                       much  larger volume of the estuarine waters.  (The  more
                       polluted condition further north in the estuary,  the Class "SD" area,
                       reflects much  larger pollutant loads discharged by  the City of Provi-
                       dence's sewage treatment plant) .

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Figure 111-4 shows the water quality standards that have been adopted
by the State of Rhode Island for the future.  The proposed project Is
required by law not to preclude attainment of these conditions.  Note
that the Class "E" reach at the east end of the Pawtuxet is to be up-
graded to Class  "D" and the Class "D" reach from the Warwick treat-
ment plant to the mouth of the Pocasset River is to be upgraded to
Class "C".

The objectively sensible results of these proposed changes  would
include elimination  of nuisance potential In Pawtuxet Village
and  improvement of the river as an aquatic habitat.  Abatement of
nuisance conditions generally can be considered desirable for the
public welfare, but. In this case, given that the entire neighbor-
hood around the mouth of the Pawtuxet River, Pawtuxet Village,
Is listed on the National Register of Historic Places,  such abate-
ment cannot be precluded by any  Federal action by law (Executive
Order 11593, see Chapter VII below).

The  aquatic habitat  changes called for would result In restoration of
anadromous fish, e.g. shad and herring, to the entire Pawtuxet
River System and connection of the Class "C" and better waters of
the Pocasset with similar waters of all the Pawtuxet system above
the Warwick treatment plant creating a condition that could lead to
the growth of "lunker" sport fish, e.g. big bass and pickerel. In
both rivers but particularly In the Pocasset.

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   Water Duality
© • • •
Water Duality
®
®\\\
   /,
                            DUALITY
        \<,\&rvL P&frt. of H«alth, VM*i0n tf Water Pollution Control, 1075.   53

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                          Flood control on the river is provided as a by-product by Its many
                          dams but urban encroachment along the lower reaches including the
                          existing treatment plant has created economic justification for a
                          Corps of Engineers project for further control. Figure 111-5 shows
                          the actions that are currently being considered for such control.
                          Note particularly the "Natick Diversion" just upstream from the
                          Warwick treatment plant.  This diversion would divert peak flows
                          out of the river directly to the bay, but would not alter low flows,
                          so necessary for effluent dilution, at all.

                          Other water quality  related projects being considered for the river
                          include the section "208" planning program  (Sec. 208 of the Water
                          Pollution Control Act Amendments of 1972) which will analyze all
                          the water related  problems of the Pawtuxet River in an intergrated,
                          basin-wide manner.  Key elements of this program, as related to
                          the specific proposals herein,  include evaluation of regionalization
                          of the wastewater facilities  in the basin and analysis of basin-wide
                          non-point source  pollution of the river including the effects of agri-
                          culture, sanitary land fills, on-slte sewage disposal, drainage from
                          street gutters, boating, etc. Chapter VI of this report does further
                          describe a part of this problem, I.e. drainage from street gutters In
                          the areas proposed to be sewered in western Cranston as part of this
                          project, including a discussion of the paucity of research that has
                          been done  In these areas.
54.

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                                                               WARWICK
                                                            LOCAL PROTECTION
                                                      iORv/bgo.
                                                   LOCAL PROTECTION
                                                StlKlia MHutrt of Major H&U*,!
                                                miUa H* Wtltrill* tnf
 FLOOD   CONTROL   CONSlD£U^T|OKIS
Ar-my C^r^ ^ grnfiiitff*»
                                                                   55

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On ground water, it should be noted that while there Is a theoreti-
cally massive, local natural  resource on the order of yield of 100
million gallons a day. It has been essentially cancelled out by total
urbanization of the aquifer's permeable surface.   Figure 111-6 shows
the urbanized area superimposed on the surficial  geology.  The
areas of outwash Include all  the principal aquifers of the locality,.
and, in all the areas downstream from the various parts of the
proposed project, these areas are all served by public (out-of-
locallty based) water supplies.   Note further that there are no
known, significant bedrock aquifers In the  vicinity of Cranston.

And finally, on public water supplies, it should be noted that the
Scituate Reservoir System of the Providence Water Supply Board
is both the principal withdrawer of the Pawtuxet River's waters
and the principal supplier of potable water  in the eastern portions
of the river's watersheds. The Scituate Reservoir's safe yield Is
estimated to be 84 MGD, of which 12 MOD must be discharged to
maintain the river,  leaving 72 MGD for public water supply purposes.
By 1974 actual usage had reached 66 MOD leaving a surplus of only
6 MGD, without assuming restrictions on lawn  irrigation. The pro-
posed addition of the Big River Reservoir on the South Branch is
expected to increase the safe withdrawal by 26 MGD creating a total
surplus of 33 MGD,  exactly 50% over existing demand  (again without
assuming usage restrictions), an ample provision for the foreseeable
future.

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                  Art*  of  irrfifttiv*






                  ArtU  of Till f
BE-
                                                              57

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                  3.12   WASTEWATER

                        Table III-3 shows the present annual average waterwater dis-
                        charges Into the Pawtuxet River from the City of Cranston, In-
                        cluding from the Clba-Ceigy Chemical Company and the State of
                        Rhode Island Institutions , and from the Warwick and West Warwick
                        municipal treatment plants.  The data in the table shows the total
TABLE 1 11-3
EXISTING WASTEWATER

LOWER
PAWTUXET
DISCHARGES
RIVER



(Average of one sample per month for calendar year 1975)
(Weekdays)
Untreated

Cranston
C1ba Gelgy
R.I. Inst.
Sub-Total
Warwick
W. Warwick
Total
Source! R.I. Dept.
•Weighted averages
MOD
10.04
1.2S
1.13
12.42
.84
2.74
16.00
of Health,

BOOc
«ig/T
179
305
173
292*
340
168
273*
Division

BOD;
Ib/day
14988
13604
1630
30111
2382
3839
36443
reduction
X
98X
SOX
62X
72X*
85X
79S
73X*
Treated
BODc
mg/T
14
653
66
83*
51
35
73*
BODc
Ib/day
1172
6807
622
8601
357
800
9758
of Pollution Control.

•,


                       wastewater discharge from each source in millions of gallons per
                       day, the ^strength" of wastewater both before and after treatment in
                       terms of milligrams of BODs Per liter, the total BOD5 (the most
                       significant index of "pollution") and the percentage of BODs re~
                       moved by the various treatment facilities.  (BOD = biological oxygen
                       demand  - the weight of oxygen that could be absorbed from a water
                       body by biological decomposition of the organic compounds dissolved
                       or suspended in the water.  BODs is the amount of oxygen that could
                       be absorbed in the first five days of decomposition at 20°C.)  Usual
                       current  standards for such discharges include 85% to 90% removal
                       of BODs  with treated effluent discharges not to exceed 30 mg/l
58

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In any case.  In the case of water quality limited streams,  streams
with relatively low low flows when compared to their pollution
loads, as Is the case for the Pawtuxet,  these standards would
be increased to meet the characteristics of the stream, in this
case assumed to require treatment to 15 mg/l of BOD5 as well
as including removal of inorganic chemicals (ammonia compounds)
that also combine with oxygen in water.

Inspection of the table suggests that the City of Cranston is in fact
doing an excellent job of treating its wastes, that Ciba-Geigy is
doing the least adequate job, and that the State of Rhode Island's
institutions are doing only slightly better.  Further it appears  that
improvement of the Ciba-Geigy discharge would be the single big-
gest improvement to the system  as a whole followed by improvements
at the state institutions and West Warwick.

In the future, as Cranston's wastewater flows increase, as a result of
both industrial and residential growth, and allowing for some growth
of Ciba-Ceigy and the state Institutions, the total of Cransto.n's out-
put will increase substantially as shown in Table 111-4.  Note that
wastewater output is expected to increase faster than population and
that BOD5 content is expected, to increase faster than wastewater
volumes.  Both these effects reflect Cranston's continuous shift from
rural to suburban to urban land uses, in turn a reflection of the
spread of the Providence urbanized area.
                            TABLE IIt-4

               EXPECTED FUTURE INCREASES IN WASTEWATER DISCHARGE

                             CRANSTON

                             (Weekdays)

                  Wastewater Flows: MGD             BODs CONTENT: Ibs/day

                  1975   2000   Increase          1975  2000  Increase
                              MGD   *                    BODs  %

        Cranston     10.04  20.1  10.06 100         15,000 38,200 23,200 155

        C1ba Gelgy    1.25   1.8   .55  44         13.600 20,000  6,400  47

        R.I. Inst.    1.13   1.1    -    -         1.630  1,840   210  13
                  12.42  23.0  10.61  85         30,230 60,040 29,810  97


        Source;  Universal Engineering Corporation.

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            3.2   PROPOSED ACTION FOR WASTEWATER TREATMENT AND DISPOSAL

                  3.21   THE PROPOSED ACTION
                        To abate existing excesswafte discharges Into the Pawtuxet River,
                        to provide for anticipated Increases In waste flows likely to be
                        generated in Cranston, and to provide for near future orderly
                        and balanced growth of the City of Cranston,  residentially and
                        industrially, all without creating undue constraints for future
                        improvements of water quality in the Pawtuxet or for additional
                        future growth of the City of Cranston or for Incorporation Into a
                        regional wastewater system, it is proposed to:

                        1.    discharge the now inadequately treated wastes of the Ciba-
                             Celgy Chemical Company and the State  of Rhode Island's
                             institutions into the municipal wastewater treatment and dis-
                             posal system and

                        2.    enlarge and Improve the existing municipal wastewater
                             treatment plant to adequately treat the resulting increased
                             waste flows.

                        The specific treatment process proposed for the enlargements and
                        improvement, two-stage biological nitrification, was selected because
                        it will:

                        1.    over the design  life implicit in the plant capacity,  about twenty
                             years, permit very effective removal of oxygen demand from
                             the wastewater flows so that direct discharge of those flows
                             into the Pawtuxet River will not violate its proposed water
                             quality classification,

                        2.    beyond its design life, if and when future flows exceed the
                             capacity for which it will provide adequate oxygen demand
                             removal  for direct discharge into the Pawtuxet,  permit the
                             plant to be economically converted into a much higher capacity
                             plant (say 40 MOD) producing an effluent adequate for dis-
                             charge into a larger, less limited receiving water  body such
                             as the Providence River estuary or Block Island Sound rather
                             than into the Pawtuxet, and

                        3.    provide the most economical method for achieving  the pro-
                             posed effluent quality.
GO

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                      t
The location and extend of the proposed actions are shown in
Figures 1-3 and 1-4.  Figures III-7 and 111-8 show the proposed
treatment process both for its design life and for  its future possible
conversion to a larger,  secondary plant for out-of-basin discharge.
                    3.4lidS_.
  Fi'gune  JI-7
  JCHftMAT.C
        ff)g«TVIeMT l^aCE
Pijurf HI- *
SCHEMATIC
       SflSIM
                                                                                   a\

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                  3.22  ALTERNATIVES

                        Alternative waste disposal strategies considered and discarded
                        included:

                        1.    improvement of wastewater treatment at the Ciba-Geigy
                              Chemical Company

                        2.    adding a second municipal treatment plant in western
                              Cranston to provide for future user increases In that area

                        3.    limiting treatment at the enlarged municipal plant to second-
                              ary treatment only  and discharge of the effluent, by gravity
                              pipeline, to the Providence River estuary

                        4.    limiting treatment to secondary and using the effluent for
                              irrigation in western Cranston,  and

                        5.    injecting treated influent into the underlying geologic structure

                        Alternative treatment processes for the readying of effluent for dis-
                        discharge to the Pawtuxet River included:

                        1.    single stage biological nitrification

                        2.    alternative methods of two stage biological nitrification,
                              the proposed process

                        3.    physical-chemical treatment,  and

                        1.    biological-physical treatment.

                        Ail would achieve similar effluent quality and some would be slightly
                        less costly than the proposed process, but they were discarded be-
                        cause they are not believed to be as consistently reliable as the pro-
                        posed process and because they do not offer the future expansion
                        flexibility.
62

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Of the alternative strategies, the reasons for discard included:

1.    for improvement of treatment at Ciba-Ceigy:

      a.    lack of land for expansion in the surrounding, con-
            gested neighborhood;

      b.    persistent odor nuisance in the surrounding neighbor-
            hood as a result of the treatment processes used for
            the concentrated  industrial wastes, and

      c.    probable inability to achieve the same degree of BOD5
            removal  from the concentrated industrial waste.

 2.    for a separate treatment plant for western Cranston:

      a.    duplication of personnel

      b.    inadequate  receiving waters

      c.    probable inability to achieve the same consistent
            degree of treatment as would be likely at a single larger
            plant

 3.    for secondary treatment and effluent discharge to the Providence
      River estuary:
       a.     excessive costs

       b.     environmental disruption all along the proposed pipe-
             line

 4.    for irrigation use of the effluent:

       a.     very limited agriculture in Rhode Island

       b.    limited prospect that the existing agriculture will
             survive for the design life of the project

 5.    for deep-well injection of the effluent:

             unsuitable bedrock geology
       a.

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3.3   ANTICIPATED  ENVIRONMENTAL EFFECTS

      The proposed actions are expected to have a variety of effects on the
      environment Including, but not necessarily limited to, those on water
      quality, on flood storage, on air quality, on neighborhood liveability,
      on growth of the city, on cltywide environmental resources, and on the
      city's long term fiscal well-being. The sections below describe the pro-
      ject's impacts on the water quality of the Pawtuxet River both long term
      and short term.

      The impacts on air quality and on the adjoining floodplain as a result of
      proposed solid waste disposal are described in Chapter IV; the impacts
      on the surrounding neighborhood's liveability. I.e. noise and odor are
      described in Chapter V; the general environmental impacts of urban growth
      are described in Chapter VI; impacts on specific valuable natural and
      cultural resources that would be threstened by additional urban growth are
      described In Chapter VII;  and the long-term impacts on the municipal
      fiscal position are described  In Chapter VIII.

      3.31   WATER QUALITY IMPACTS

            The sections below  describe  the impacts of the  proposed  project
            on the water quality of the Pawtuxet River including:

            1.     long-term dissolved  oxygen levels,  the most general indi-
                 cator of water quality,

            2.     long-term quality Impacts other than oxygen levels, and

            3.    short-term construction effects

            3.311 Long  Term Water Quality Impacts - Oxygen Levels

                 Analysis of dissolved oxygen levels  in the Pawtuxet River
                 was made by  the Rhode Island Dept. of Health,  Division of Pol-
                 lution Control, in the summer of 1976. using a computer
                 model developed by the Raytheon Company for EPA. This
                 model relates effluent discharges, water reaeration rates,
                 initial river dissolved oxygen concentrations, biological
                 oxygen demand concentration and rates of oxidation of that
                 demand, ammonia concentrations and rates of oxidation of
                 that ammonia, temperature, flow of the river, etc. to dis-
                 solved oxygen likely to obtain all along the river, assuming
                 that non-point source pollution remains constant.

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      The results of this analysis indicated that:

      1.    if the proposed action is completed in Cranston and
            if both the Warwick and West Warwick treatment plants
            are Improved to discharge not over 30 milligrams of
            BODs per liter at their current discharge rates of
            1.0 and 2.8 MOD respectively,  then the dissolved
            oxygen in the river would meet the proposed water
            quality classifications, i.e. no  less than Class D
            ( and possibly Class C) in its lower reaches, and

      2.    if the proposed action is  completed in Cranston and
            if both Warwick  and West Warwick treatment plants
            are improved to discharge not over 15 milligrams of
            BODs arid the equivalent 3 milligrams of ammonia
            oxygen demand  per liter at future discharge rates  of
            5.0 and 7.5 MGD respectively,  then the dissolved
            oxygen in the river would also  meet the proposed
            classifications,  i.e. Class D.

3.312 Long Term  Water  Quality Impacts -  Other  Parameters

      Beyond protecting the  public health and abating nuisance
      conditions,  the objectives of water quality standards es-
      tablished for the Pawtuxet River include creation of
      suitable habitat for migratory fish in its lowest reaches.
      The proposed action is expected to generate chlorine con-
      centrations substantially in  excess of  those that would permit
      such fish to survive.  The maximum chlorine residual toler-
      able by fish is about 0.01 milligrams per liter for most
      fish expected in the river (and 0.003 for salmonid fish).
      Table 111-5  shows the chlorine residuals expected for the
      river at low flow.  Note that for the effluent design
      at low river flows, the chlorine residual  will be 85 times
      greater than the toleration level (for non-salmonid  fish) and
      that,at average river flows, the exceedance  will still be over
      15 times greater than the toleration level.

3.313 Short Term Construction Impacts

      During construction, it is expected that excavation and grad-
      ing will create a potential for severe erosion of soil particles
      into the river. This  impact  is only a small part of a much
      larger construction impact that could result from the contin-
      uing growth of the city. This larger problem and methods
      recommended for its mitigation are discussed in Chapter VI.
                                                                    65

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TABLE I I 1-5



TOTAL RESIDUAL CHLORINE (TRCl CONCENTRATION
SITUATION
Existing
Dechlorlnatlon
Cranston Only
WEST WARWICK

2.74
2.0
2.74
2.0
Dechlorlnatlon 2.74
Cranston, Warwick, 0.0
West Warwick
Design Flow
Dechlorlnatlon
Cranston Only
5
2.0
5
2.0
Dechlorlnatlon 5
Cranston, Warwick, 0.0
West Warwick
*Due to sources
ASSUMPTIONS: '
_«««M««^M^— ^» ,
,
upstream of the Main
WARWICK
DISCHARSJ-
0.8S
2.0
0.85
2.0
0.85
0.0
5
2.0
5
2.0
• 5
0.0
Stem.
) Discharge TRC concentration maintained
:'\ Complete mixing of discharge and river
i) TRC does not decrease with time.
.) Cranston gage low flow value Includes
CRANSTON 6A6E
(LOW FLOW)
48.4
0.148
48.4
0.148
48.4
Trace*
54.81
0.365
54.81
0.365
54.81
Trace*

CRANSTON
D(SCHAR6
12
2.0
12
0.0
12
0.0
23
2.0
23
0.0
23
0.0

at 2 mg/1.
at calculated end result.
existing flows from Warwick and
END RESULT
[ (CALCULATED)
60.4 Flow (MGD)
0.52 TRC (Kg/1)
60.4 Flow
0.119 TRC
60.4 Flow
Trace* TRC
77.81 Flew
0.85 TRC
77.81 Flow
0.257 TRC
77.81 Flow
Trace* TRC

West Warwick.
Source; CE Magulre, Inc.
            3.4   MITIGATION  OF IMPACTS

                  The only expected adverse impact on river water quality resulting from
                  the proposed action, not included elsewhere in this statement, is increase
                  in chlorine concentration in the river.  This chlorine, added to disinfect
                  the effluent, will make the river unsuitable for restoration of both anadro-
                  mous  and sedentary fisheries, a significant part of the purpose of the
                  existing water quality goals, and should be removed or  eliminated.

                  Two basic strategies for accomplishing this are evident:

                  1.    substitution of non-chlorine using disinfection techniques, or

                  2.    removal of residual chlorine after disinfection.

                  Specific methods for these include:
66

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Alternatives to Chlorination:

       (1)    Ozone:  used for sixty years to treat water supplies in
             Europe and Canada.  Its application to wastewater is
             limited to pilot plants.  Ozone  is produced by applying
             an electrical discharge across oxygen or air.  Research
             is still required to find a parameter for controlling the ozone dosage.

       (2)    Ultra  Violet Irradiation:    requires a high quality effluent
             so that the energy dose can reach the organisms.  Low pressure
             mercury lamps emit most of their energy  at the proper wave-length
             for a good bactericidal effect.
                                                                   \
       (3)    Bromine Chloride:   similar to chlorine  in its germicidal
             qualities.  An advantage is that bromamines are far superior
             to chloramines in bactericidal  and virucidal activity yet are
             less stable in water.  Existing chlorination facilities would
             require only minor modifications to convert from chlorine to
             bromine chloride.

Dechlorination Alternatives:

       (1)    Sulfur Dioxide:   available commercially as liquified gas
             and applied to the chlorinated effluent with equipment very
             similar to that used for chlorination.  Because the reaction
             of sulfur dioxide with both free and combined chlorine is
             almost instantaneous,only rapid and complete mixing is
             required rather than contact chambers.   Research indi-
             cates that sulfur dioxide dechlorinated effluents have no
             adverse effects on fish.  However,  carelessness of appli-
             cation could cause an overdose of sulfur dioxide and a sub-
             sequent decrease in dissolved  oxygen. Therefore, reaeration
             is sometimes required to  increase the dissolved oxygen con-
             tent of the dechlorinated effluent.

       (2)    Activated Carbon:   can be used for dechlorination. The
             technique is a physical process of adsorption although there
             are some chemical reactions  between the  carbon and residual
             chlorine producing carbon monoxide and dioxide. The opera-
             tion of a carbon column does not require  the safety precautions
             required with chlorine or sulfur dioxide  use.  However, de-
             chlorination with activated carbon is the  most costly of the
             alternatives.

And finally, it should be noted that mitigation measures for the reduction of
 residual chlorine from Cranston  must also be applied to the discharges from
Warwick and West Warwick treatment plants as well to be effective.
                                                                           67

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Clwptir  IV    TH6  IM1WTS    OF
 4.0   INTRODUCTION

      Any wastewater treatment plant will generate large volumes of solid
      wastes, ultimately the pollutants removed from the wastewaters, which
      solid wastes in turn have ultimately to be put «omewhere.  The solid
      wastes from this proposed wastewater treatment plant will primarily be
      in the form of sludge which is proposed to be incinerated both to reduce
      its volume and to kill all pathogens, and the resulting ash  is to be
      buried in a sanitary landfill adjacent to  the treatment plant.

      The questions implicit in this proposed  action, given that the surround-
      ing Providence Air Quality Maintenance Area appears not to meet air quality
      standards and that incineration will unavoidably increase air pollution
      emissions, include:

      1.    will incineration preclude improvement air quality ?

      2.    are there better alternatives to  incineration? and

      3.    will the proposed action  tend to preclude more desirable, alterna-
            tive disposal methods that might be developed in the foreseeable
            future?

      The sections below include a description of the materials to be discharged,
      the air environment into which incinerator emissions are proposed to be
      discharged, the areas in which residual  solids are to be  stored, the
      proposed methods of solid waste disposal, alternatives that have been con-
      sidered and reasons for selecting the proposed disposal  methods, the
      probable environmental effects of the proposed method, and finally a strategy
      for mitigating the unavoidable adverse effects.

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             4.1   BACKGROUND

                   This section includes a description of the solid wastes to be disposed of,
                   quantitively and qualitatively; the existing and future air environment
                   Into which Incinerator emissions are to be discharged, and the areas In
                   which residual solids are temporarily or ultimately to be stockpiled both
                   adjacent to the treatment plant and elsewhere in the vicinity.

                   4.11  SOLID WASTES

                         The solid wastes to be disposed of at the treatment plant will con-
                         sist in part of raw solid materials separated from the incoming waste-
                         water flows and in part of microorganisms grown within the treatment
                         process to absorb suspended and dissolved chemicals from the waste-
                         waters. The proposed  enlarged and more effective plant is expected
                         to generate larger amounts of both types of solids than are generated
                         in the existing, in part because of the increased wastewater flows to
                         the  plant,  in part because of the higher concentration of pollutants
                         within the wastewater,  and in part because of the higher degree
                         of pollutant removal.  Overall  the solids are expected to increase
                         from 470,000 cubic feet  per year  (1974-75) to 1,521,000 cubic
                         feet per year at peak plant capacity, with the bulk of increase to
                         consist of the secondary microorganisms grown in the plant pro-
                         cesses .

                         Table IV-1 shows the overall amounts and composition of the solid
                         wastes, existing and future.  The screenings include primarily
                         cloth fragments, branches and other course materials that are
                         mechanically screened out of the wastewaters; the grit in sand,
                        foodwastes such as eggshell, bone, coffee, etc. and other dense
                         substances that can be quickly settled «ut of the wastewater; the
                        grease includes fats, oils and other floatable materials that can be
                        easily skimmed off the wastewaters, with the  "sludge" including
                        everything else.

                        At the existing plant the sludge includes primary sludge, the particles
                        in the wastewaters which can be settled out in one to two hours,
                        and  secondary sludge, microorganisms grown in the plant's aeration
                        tanks to decompose and  absorb the organic materials  in solution or
                        In suspension. Both are then processed through digestion tanks to
                        further decompose the solids (about 50%),  to reduce odor, and to
                        kill the bulk of the pathogens,  about 97%, with the resulting di-
                        gested material dewateredon a vacuum filter-  Chemical analysis
                        of this dewatered digested sludge, still 84% water, indicates, as
                        shown in Table IV-2, that, after complete drying, the sludge con-
                        tains about 58% of its dry weights as combustible materials, mostly
                        organics with some ammonia compounds and about 41% incombustible
                        ash.
70

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                            TABLE IV - 1
                     -_     _-_-_--_
                 Cranston Mastewatcr  treatment Hant

                        Existing and Proposed
                        (cubic feet per year)
COMPONENT
Screenings
Grit
Grease
Sludge
Total
Ash
PRESENT
2,200
4,400
42.000 (Skimmings]
422,000 (2)
470.600
0
FUTURE
32.000 (1)
11,000
28.000 (Concentrated)
1.450,000 (3)
1,521,000
118,000
(1)  Due to smaller (1")  screen  size  of new bar-screen  resulting  In greater
     screenings  capture

(2)  Avg.  moisture content  -  84.35!

(3)  Avg.  moisture content  *  65.OX
Source:   Universal  Engineering Corporation
           TABLE IV - 2

    Analysis of Existing Sludge
Cranston wastewater iroatment  nant
                                                     Constituent
                                                     I.    Combustibility Analysis (% by wt. of dried sludge):
                                                           Ash                                                  41.47
                                                           Combustible Solids                                   58.53
                                                           Calorific Value, BTU/lb                              6,566
                                                     II.   Elemental Analysis of Combustibles (X by wt.  of
                                                               total dried sludge):
                                                           Carbon                                               35.2
                                                           Hydrogen                                              5.9
                                                           Nitrogen                                              4.03
                                                           Sulfur                                                0.76
                                                           Oxygen, by difference                                12.64
                                                     III.  Heavy Metals Analysis (mg/kg of dried sludge):
                                                           Mercury                                             0.1158
                                                           Lead                                               197.642
                                                           Z1nc                                               202.358
                                                           Cadmium                                             9.9875
                                                           Copper                                            1050.6R6
                                                           Nickel                                             446.206
                                                           Arsenic                                              2.C83
                                                           Chromium                                            90.822
                                                           Manganese                                          303.458
                                                     *Source:  New York Testing Laboratories, Inc.
                                                                                                                              71

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Metals in the sludge that might, in sufficient concentration pose a
hazard to health or environmental quality, are also shown in the
table as milligrams per kilogram of dried sludge or parts per mil-
lion.  The concentrations found In the existing Cranston sludge are
consistent with that of other similar areas and do not of themselves
appear to pose any special environmental hazards if so placed as
to not have ready, concentrated entry to the food or water supply
chain.

Current disposal practice for this digested sludge consists of stock-
piling in the lowlands adjacent to the treatment plant with removal of
a corresponding volume of soils to maintain the floodplain volume.
With the passage of time however,  this stockpile shrinks considerably
(75%) in weight and volume as its moisture content gradually evaporates.
At the proposed plant the sludge will include the same kind of primary
and secondary sludges plus a tertiary sludge derived from micro-
organisms grown in the plant's aeration tanks to decompose and ab-
sorb the ammonia compounds dissolved in the wastewaters. Unlike
the present process, these materials will not be digested but will
be pressure filtered to  reduce  their water content to about 65% and
the resultant mass will  be burned,  autogenously, in an incinerator
to reduce its volume and to kill all  the pathogens. The proposed
incineration process and  its environmental impacts are described
below in section 4.2 and 4.3.   The  composition of the raw sludge
expected to be generated  by the proposed treatment plant is de-
scribed in the next paragraph  in this section, the expected air
emissions are described in Section  4.12 below and the residual
ashes are described in  Section 4.14.

Table IV-3 shows the chemical  composition of sludge from a pilot
plant for the proposed wastewater treatment process.  Comparison
with the existing sludge analysis shows the much smaller percentage
of mineral materials, ash and metals, and a higher percentage of
oxygen, differences that can be attributed to the lack of digestion,
to the addition of Ciba-Ceigy's wastes to the city sewage and to the
higher percentage of secondary sludge components.

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                            TABLE IV - 3

               Analysis of Sludge From Pilot Plant for
            Proposed Cranston Hastcwater Treatment riant
Constituent

I.    Combustibility Analysis (X by wt.  of dried sludge):

      Ash
      Combustible Solids
      CaloHfle Content (BTU/lb)
 Quantity
   21.31
   78.69
   7942.
II.   Elemental Analysis of Combustibles (% by wt.  of total
          dried sludge):

      Carbon                                                 43.2
      Hydrogen                                                6.5
      Nitrogen                                                4.43
      Sulfur                                                  0.75
      Oxygen by D1ff.            .                            23.81
III.  Heavy Metals (mg/kg of dried sludge):

      Mercury
      Lead
      Zinc
      Cadmlurn
      Copper
      Nickel
      Arsenlc
      Chromium
      Manganese
  0.0755
194.278
177.990
  3.0754
412.537
131.048
  2.4^8
121.450
 97.943
IV.   Pesticides  (mg/kg of dried sludge):

      alpha BHC
      beta  BHC
      Total BHC
      Undane
      Heptachlor
      Aldrln
      Heptachlor  Epoxide
      P, P' DDE
      Dleldrin
      Endrln
      0. P1 TOE
      P, P1 TOE
      0, P' DDT
      P, P1 ODD
      Total DDT
      PCB's
*Not Detected
Source:   New York Testing Laboratories,  Inc.
 0.062
     *
     *
 0.080
     *
 8.471
                                                                               73

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4.12  EXPECTED AlR EMISSIONS

      Incineration of the proposed treatment plant's solid wastes are ex-
      pected to generate large volumes of carbon dioxide and water vapor,
      relatively small  amounts of sulphur dioxide,  (S02) and suspended
      particlates (TSP) and only  traces of mercury vapor.  The carbon
      dioxide and water vapor are not considered to be atmospheric pol-
      lutants except in a global climatoligical sense, and they would be
      the ultimate end product of the solid wastes proposed to be incin-
      erated anyway,  no matter how disposed of.  The sulphur dioxide,
      particulates and mercury vapor in contrast are significant air pol-
      lutants,  even in small amounts.

      At maximum capacity it is expected that the proposed incinerator will
      produce the emission rates listed  in Table IV-4.
                                   TABLE 1V-4

                             EXPECTED AIR EMISSION RATES
              Sulfur dioxide (S02)

              Particulates (TSP) (Maximum)

              Mercury Vapor

              Lead

              Other emissions


              Source: CE Magulre, Inc.
6.89 gin/sec.

0.29 gin/sec.

0.000053 gm/sec.

0.0089611 gm/sec.

Negligible
       Note that these are "worst case" emission rates, and they assume
       that all the sulfur and mercury and 10% of the lead in the sludge will
       be emitted into the air.  The complex organics in the sludge,
       the pesticides and the polychlorinated  biphenol's(PCB's), are
       expected to be almost totally destroyed within the incinerator
       or intercepted by the stack scrubbers  and so not to be emitted
       into the air.

       Note also that the particulate emission  rate is the minimum perform-
       ance standard required by EPA regulation based on  the dry weight
       of the  materials to be incinerated and that the incinerator will not
       be accepted from Its  vendor unless it meets  this performance stand-
       ard.

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4.13   AIR EMISSIONS REGULATIONS
       Emissions of pollutants  Into the atmosphere are regulated by a veri-
       table plethora of standards including emission rate limitations from
       specific new sources for some pollutants, maximum ambient air con-
       centrations that are allowable for various periods of time at various
       frequencies calculated by  various methods for various pollutants,
       and maximum increments to ambient air concentrations that are al-
       lowable for various conditions for various pollutants.  Table IV-5
       shows the applicable standards.
                                        TABLi: IV-5
                               APPLICABLE AIR EMISSIONS LIMITATIONS
                                             Sulfur Dioxide
1.  New source emission rates
2.  Maximum ambient air pollutant
   concentration
      annual average, primary3.
      annual average, secondary*
      2nd worst day/yr., primary
      2nd worst day/yr., secondary
      2nd worst 3 hr./yr.,       1
      secondary
                 3.  Maximum degradation in ambient air quality
                    (Increase in pollutant concentration)    5
                      annual average             15ug/m3-
                                               BOug/m3-
                                               365Ug/m3-
               Particulates   Mercury
             .295g/sec.l   .0266g/sec.?

               75ua/m35
                      2nd worst day/hr.
                      2nd worst 3 hr./yr.
100ug/m3-
700ug/m3?
              260ug/m3-
              150ug/m3-
                                            10ug/m3§
                                            30ug/m3-
                 1  @ 1.3 pounds/ton of dry solid waste.
                 Z  equal to 2,300 g/day.
                 2  primary:  standard set to protect the public health.
                 4  secondary:  standard set to otherwise protect the public welfare.
                 5  arithmetic mean.
                 6  geometric mean.
                 Z  maximum
                 g/sec, • grains per second.
                 ug/m3 * micrograms per cubic meter.
                                                                                        T5

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                  4.14  AIR ENVIRON ME NT

                        To determine whether the proposed air emissions will exceed the
                        standards for maximum increments in ambient pollutant concentra-
                        tions it is necessary to calculate the probable dispersion of air pol-
                        lutant emissions into the.surrounding atmosphere, and for similar
                        determination for maximum total ambient pollutant concentration it
                        is further necessary to add the anticipated increments to the exist-
                        ing conditions.  The probable dispersion of pollutant emissions is
                        a function of the surrounding meteorology , topography, and of the
                        incinerator stack parameters,  while the existing conditions,
                        the product of the interaction of the totality of the surrounding
                        region's natural and economic environments, can only be approximated
                        by statistical analysis of very limited field sampling. The sections
                        below describe the meteorology and topography of the surrounding
                        region, the resulting patterns of dispersion of pollutants in
                        the air, and the available data on ambipnt air quality, existing
                        and future.

                        4.141 Meteorology and Topography

                              Cranston lies within one of the windiest regions of the United
                              States, with calms of less than 1.5 meters per second (3.4 mph)
                              occurring less than 4% of the time  and with the most commonly
                              occurring wind speed class centering on 4.47 meters per sec-
                              ond (10.1 mph) . Figure 11-2  shows how the region compares
                              with the windiness for the rest of  the contiguous United States.

                              In general these winds prevail from the west with northwest
                              winds typical of the winter, with southwest typical of the summer
                              with the summer winds added to by strong southerly sea breezes
                              in fair weather, and with northeasterly winds common in storms
                              throughout the year.  Figure IV-1, the wind  rose for Provi-
                              dence used in air pollutant dispersion calculations  in this sec-
                              tion is based on the period 1964 to 1973.

                              The topography of the region is quite limited with the high-
                              est hills not over 500 feet above sea level and with no pro-
                              minences at all in the vicinity of the proposed incinerator or
                              between the incinerator and the bulk of the urban area.
7G

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         NNW
                     NNE
WNW
                              ENE
wsw
    sw
IV- 1  T0906
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4.142 Dispersion of Pollutants

      Short time period ground level concentrations of sulfur
      dioxide and partlculates were calculated by C.E. Maguire,
      Inc.  from  the meter eo log I cat parameters,  i.e. wind speed
      and direction, atmospheric mixing height and ambient air
      temperature and from proposed incinerator stack parameters,
      i.e.  height and diameter, gas exit speed and  temperature,
      and other  factors,  using proposed peak emission rates and the
      PTMAX model  (developed by EPA). Those concentrations
      are the maximum levels likely to occur at the  worst meteorolo-
      gical conditions as a result of the proposed action. The re-
      sults of the calculations are shown in Figures IV-2 through
      IV-4.  Note the rapid decrease in concentrations as the dis-
      tances from the incinerators increase and note that the symmetry
      of the pattern reflects the flatness of the terrain.
              WARWICK
    J5J—««» «• «••>
   A- 	 ««1 aiMUTV HKITM
   ^     '  1 — 1  1

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TABLE IV-6
ANTICIPATED MAXIMUM DEGRADATION IN AMBIENT


AQNA
Receptor
3
S
22
23
24
25
26
V
29
0 = Less thin 0.
1 maximum
2 maximum
IN AND NEAR CRANSTON
ANNUAL AVERAGE INCREASES
MICROGRAMS PER CUBIC METER
No. Location TSpl
56 Eddy Street 0.
46 Eddy Street 0.
Cranston Police 0.
Cranston Hospital 0.
State Office Building 0.
Westminster Street 0.
Dyer Street 0.
Providence Police 0.
National Weather Service 0.
Warwick
S
allowable = 10 mlcrograms per cubic
allowable •= 15 micrograns per cubic
AIR QUALITY


S022
1.
1.
0.
0.
0.
0.
0.
0.
0.

meter.
meter
Source: CE Magulre. Inc.
          MONIT^
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                        4.143 Ambient Air Quality

                              Figures IV-5 through IV-8,  reproduced from "Technical Sup-
                              port to the State of Rhode Island <^n Development of Air Quality
                              Maintenance Plan" by Welden Research Division  of Abcor, Inc.
                              for EPA. published September, 1975, (hereinafter called the
                              Walden Report),  show the ambient:

                                    1974 annual average SOj concentrations for Rhode Island
                                    1974 annual average TSP concentrations for Rhode Island
                                    1985 annual average SO2 concentrations for Rhode Island
                                    1985 annual average TSP concentrations for Rhode Island

                              The 1985 TSP levels are based on the assumption that all gaso-
                              line will be unleaded by that time while the 1985 sulfur dioxide
                              levels shown assume that power stations will be  allowed to use
                              fuels contining 2.2% sulfur rather than the 1.0% sulfur fuels
                              used in 1974. a most probable condition for TSP  and a worst
                              assumption for S02-
80

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In addition, probable frequencies of 24 hour SOj and TSP
concentrations were calculated for two of the monitoring sta-
tions, the Cranston Police Station and the Cranston Hospital,
using the limited available data.  Table IV-7 shows the key
ambient air parameters using two different statistical tech-
niques currently used in calculation of such parameters.
Note that by one of the techniques it could be said that the
air quality at the police station is in probable violation of
one of the standards,  i.e. 2nd highest day, TSP.
Note also that the difference between results of the two methods
is greater than the purported amount of violation and that all
of these highs and 2nd highs are extrapolations, extensions of
mathematical curves beyond actual measurements,  i.e.  no
such violations have actually been measured.
TABLE IV-7
ANTICIPATED MAXIMUM AMBIENT AIR POLLUTANT CONCENTRATION
AT SELECTED! RECEPTORS IN CRANSTON
HICROT.RAHS PER CUBIC METER
1. Cranston Police Station 2. Cranston Hospital

Pollutant Applicable Maximum Anticipated Existing 1975 Anticipated Max? Existing 1975 Anticipated Max?
Parameter Allowable Increase A B A B ABA
TSP Annual average 602 0.0 52 52 52 52 45 45 45
2nd worst day/yr. 150? 3.1 137 163 140 166 102 124 105
$02 Annual average 80 1.0 14 17 15 18 30 36 31
2nd worst day/yr. 365 71.4 82 74 154 145 142 182 214
2nd worst 3 hr/yr.1300? 239.7 MA NA NA NA NA NA NA
NA Data not available.
1 Closest air quality monitoring stations to proposed Incinerator.
2 Assuming no Improvement In ambient air quality through the air quality maintenance plan.
3 Non-health related.
A Larson Analysis
B Least Squares Method
Source; CE Magulre, Inc.
B
45
127
37
253
NA







                                                               81

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     Figure IV-5 shows assumed 1974 annual average TSP.  Note
     that the proposed incinerator is outside the zone of standards
     violation, the striped zone.

     Figure IV-6 shows what is expected to happen by 1985 to
     this average annual TSP if all gasoline  is  unleaded.  Note
     that this action alone will  result in  lower TSP levels even with
     larger populations, eliminating the area of violation.
                                                      ,iVB'»*m (
i  «,">  /"-       ;V
      1  MKWO"** '     L -- "
i «.«'« V         ,  ,   u
          ,  ,Mti, ,   umi
        TSP CONCENTRATION
                     «VPJfl3S

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    IQu     20""IU1T '30
                        PijufCIV-7
                        !0i CONCEHTHAT10NS
Mimet: uuuatN U9*a«CM
                       Figure IV-7 shows assumed 1974 annual average SO2 concen-
                       tration distribution.  Note that there is no area of standards
                       violation.

                       Figure IV-8 shows what would happen by 1985 to this annual
                       average if major fuel users were allowed to use 2.2% sulfur
                       fuel.  Note that the zone that would violate S02 standards is
                       well away from the proposed incinerator.
                                                                                      83

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4.15  RESIDUAL SOLIDS

      At the design capacity of the plant,  the solid residuals remaining
      after incineration of the sludge,  screenings, grit, etc. are expected
      to amount to about 5300 tons or 4400 cubic yards per year.  This
      residual will be composed principally of ash containing some nitrate,
      phosphates and other mineral materials.  The ash will be biologically
      inert but will contain some toxic chemicals.  Physically it will be
      finely divided material with sufficient moisture added to it to control
      dust and wind erosion.

      In addition to this annual increment, physical expansion of the treat-
      ment plant will require excavation of about 15,000 cubic yards of
      old (at least 10 years), digested sludge which was deposited years
      ago in the areas into which the plant expansion is proposed.  Biologi-
      cal pathogens  are unlikely to be present within this material but,
      like the ash that will constitute the balance of the solid waste resi-
      duum toxic chemicals may have persisted within  the sludge mass
      protected from leaching and weathering.
 4.16  ADJACENT DISPOSAL SITE

       Ultimate disposal of solid waste residuals from the Cranston waste-
       water treatment plant has always been, in now, and is proposed
       to be in the floodplain just north of the plant.  (In the past and
       at the present time this residual has been in the form of biological-
       ly digested sludge while in the future it is to be incinerator ash).
       Figure IV-9 is a map of the floodplain showing the existing use of
       the area with Figure IV-10 showing the area proposed to be developed
       for expansion of the plant itself.

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Industrial  -Arta
                                                                               Cranston Utosfciuater
                                                                             Tfafacnt "Plant
                                                                               lV-9   LOWLflNOS  OOJflCBNT TO
                                                                                      CMNITM
/
 Industrial  -Area
                                               '"""' n?C^'*i^:"~j..    / f    /~~^-s-~\
                                                  />
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                   4.17  ALTERNATIVE DISPOSAL SITES

                         There are a large number of potential alternative solid waste dis-
                         posal sites within reasonable proximity of the Cranston waste-
                         water treatment plant since the plant lies next to one of the major
                         highway intersections of the State of Rhode Island.  Figure IV-11
                         shows the location of these alternative sites and the type of disposal
                         considered for them.

                         Two of the sites, the two golf courses, were considered only for
                         surface application of the sludge as a soil conditioner and/or
                         fertilizer;  two of the  sites, the Briggs Farm  recreation area
                         and the grounds of the state institution were considered both for
                         such surface application and for sanitary landfill  type disposal
                         of sludge or ash;  and the other three, two commercial sanitary
                         landfills and a partially worked out quarry, were considered for
                         burial of sludge or ash.
                                                             A1/PIM6 COUHTilVeu»,L«WD f.!»!»UCHTlON
                                                             CfJflNSTON    "
                                                                      SITES
                                                                LOCATION OIIT-M 1TES9ECT
                                                                TO 7JOfl3S 4 LPfO  USE-
86

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4.2   PROPOSED ACTION FOR SOLID WASTE TREATMENT AND DISPOSAL

      4.21  THE PROPOSED ACTION

            Proposed residual solids disposal actions include steps to dispose
            of both the large volumes of fresh sludge that will be generated
            steadily by the enlarged  treatment plant and the old sludge that
            will have to be removed for construction of the new additions to
            the plant.

            To dispose of the large volume of fresh solid wastes to be steadily
            generated by the proposed enlargment of the treatment plant,
            it is proposed to incinerate the solids and dispose of the residual
            ash in specially designed cells on the floodplain just north of
            the treatment plant.  Facilities for the incineration are to be
            provided by reconstruction of the existing incinerator to meet
            current clean-air standards and by  construction of a new incinerator
            to provide needed additional capacity.

            The special cells for the ash will be similar to those currently
            used for general domestic solid waste, except that they will
            be lined and drained back into the treatment plant to prevent
            ground water contamination and surrounded by dikes to protect
            them from flooding.   In addition, it is proposed to  surround
            the cells with monitor wells so that contamination of the ground
            water can be detected if it should occur despite the proposed
            precautions.

            The old excavated sludge that will have to be removed for con-
            struction of the new additions tothe treatment plant will similarly
            be disposed of in the on-site cells except that it will not be  incin-
            erated and it will be similarly monitored for ground water effect.
                                                                                 &7

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                  4.22  ALTERNATIVES

                        Alternative solid waste disposal strategies other than incineration
                        considered and discarded included:

                        1.    continuation of the present practice of biological digestion
                              and on-site stockpiling on the floodplain.

                        2.    biological digestion of sludge, dewatering and off-site land
                              application with landfill of screenings and grit.

                        3.    thermal conditioning, and off-site landfill of sludge, screen-
                              ings, grit and grease.

                        Alternative solid waste disposal strategies,  that include incineration,
                        considered and discarded included:

                        1.    incineration of all  solids with off-site disposal of ash.

                        All the alternatives were discarded because they were expected
                        to be excessively costly, or could not be fully explored either
                        for total program cost or total environmental effect or both,
                        within the time allowable under Ciba-Geigy Chemical Company's
                        court ordered clean-up schedule.

                        Specific reasons for discard of the alternatives included:

                        1.    for continued digestion and stockpiling on the floodplain:

                              a.    expected sharp increase in sludge generation rate when
                                    the Ciba-Geigy wastes are added to the municipal plant

                              b.    limited knowledge of the environmental effects of the
                                    existing stockpiling practice and inadequate time for
                                    research

                              c.    increasing value of floodplain for flood storage as the
                                    watershed urbanizes and flood peaking increases.
88

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2.    for digestion and disposal off-site for land application (agri-
      culture, lawns, recreation areas) as a fertilizer and/or soil
      conditioner:

      a.    excessive cost if no cash value is assumed for its organic
            fiber (60% of dry weight) and nitrogen  (4.4% of dry weight)
            content.

      b.    limited knowledge of the market for the digested  sludge
            and  inadequate time for research.

      c.    limited knowledge of the environmental effects of land
            application and inadequate time for research.

      d.    possibility of creating unsafe highway conditions  if
            trucks track sludge and dirt back onto roads after
            discharging their loads.

3.    for thermal conditioning of sludge and disposal  in an off-site
      sanitary landfill:

      a.    excessive costs

      b.    possibility of creating unsafe highway conditions if
            trucks track sludge and dirt onto pavements after
            discharging their loads.

4.    for incineration of sludge on-site with off-site disposal  of
      ash  in a sanitary landfill:

      a.    less control by the City of Cranston of the costs and
            operation of the sanitary landfill.

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            4.3   ANTICIPATED ENVIRONMENTAL EFFECTS

                  The proposed actions are expected to have a variety of effects on the
                  environment including but not necessarily limited to those on air quality,
                  on water quality, on flood storage, on neighborhood liveability, and on
                  wildlife habitat.

                  The impacts on the neighborhood are likely to be mixed, a trade-off of
                   odor elimination, if the plant performs as expected, and the effects of a larger
                   plant impinging on its surrounding. See Chapter V for a more detailed
                   description.


                  The impacts on wildlife will be continued elimination of wetlands with the
                  ash disposal  cells being proposed for the wetlands not yet spoiled by sludge
                  dumping. Further, it should be noted that the proposed action does
                  not include any steps to restore the loss of wildlife habitat that resulted
                  from the stockpilina of diaested sludge on the wetlands in the first
                  place.

                  The loss of floodplain,  although an adverse environmental effect, is not
                  a serious loss and can be made up by compensentory enlargement of flood
                  storage in a number of places, both on and off site.

                  The water quality impacts may be significant and include passage of
                  chemicals leached out of the ash through the treatment plant and into
                  the river in the plant's effluent stream.  The degree of solubility  of the
                  ash, and as a result the concentration of solutes in the leachate, are
                  not known.  No federal standards for such discharges  have as yet been
                  established,  but are scheduled to be so established in  the near future.

                  And finally,  the emission of pollutants into the atmosphere, while
                  the proposed action will increase the amount of pollutants  in an absolute
                  sense, the percentage of change will not be large and the amount
                  of change will not violate clean-air standards, assuming a very small
                  ambient improvement as a result of the state's air quality maintenance plan.
                  Sulfur dioxide emissions, not over 7 grams  per second, will  increase aver-
                  age annual SO2 concentrations by up to 1 microgram per cubic meter, an
                  increase of only 2 or 3% over existing conditions, about 7% of the allowable
                  increase in present regulations, and a total ambient well under (less than
                  65% of) the ambient standards.

                  The short term  impact of this emission rate under stagnant air condi-
                  tions will amount to maximum day ground lev«l SO2 concentrations at the
                  treatment plant site about 3/4 of the allowable increment or about 1/5 of
                  the allowable second worst day per year ambient standard.  The maximum
90

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three hour S02 concentration similarly will amount to about 1/3 of the al-
lowable Increment or about 1/5 of the allowable second work 3 hour period
per year ambient standard,

Total suspended partlculate emissions,  not over 0.3 grams per second,
wHI increase average annual TSP concentrations by less than one half of
1 mlcrogram per second, a negligible effect.  The short term  impact of
this emission rate under stagnant air conditions will amount to maximum-
day ground level TSP concentrations at the treatment plant site about
1/10 the allowable increment or about 2% of the allowable second worst
day per year ambient secondary standard  (non-health realted) or about 1%
of the allowable second worst day per year ambient primary standard
(health related).

Mercury emission rates, about 0.00005 grams per second are  about
2/10 of 1% of the allowable emission rates.

Table IV-8 shows this data in tabular form
           Pollutant


           S02
           TSP
           Mercury
                                 TABLE IV-8

                      ANTICIPATED MAXIMUM AIR QUALITY IMPACTS

                           MICROGRAMS PER CUBIC METER
Applicable
Parameter
Maximum
Allowable
degradation
  worst hour/yr   No Standard
  2nd worst 3 hr/yr  700
  2nd worst day/yr   TOO
  annual averane     15
ambient concentration
  2nd worst 3 hr/yr 1300

  2nd worst day/yr   365
Anticipated
Maximum Impact
                                                  285
                                                  240
                                                   71
                                                    1
                                                           5.5% increase/
                                                               ambient
                                                          20.0% Increase/
                                                               ambient
emission rate
degradation         solids
  worst hour/yr.   No Standard
  2nd worst day/yr.   30
  annual average      10
ambient concentration
  2nd worst day/yrl  260

  2nd worst day/yr?  150
  1.3 Ibs/ton of 1.3 Ibs/ton of solids
                                                   12
                                                    3
                                                    0
                                                           1.25! increase/
                                                               ambient
                                                           2.It increase/
                                                               ambient
emission rate
.0266 grams/sec. .00005 grams/sec.
           1  Primary Standard, health related.

           2  Secondary Standard, non-health related.



           Source:  CE Maguire, Inc.
                                                                                    91

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4.4   MITIGATION OF IMPACTS

      The principal adverse environmental effects of the proposed solid waste
      disposal about which something could be done include:

      1.     the possibility that incineration of the solid wastes is waste of a
            useful natural resource, i.e. a soil conditioner/fertilizer,

      2.     further loss of virgin wetlands to solid waste disposal, and

      3.     the neglect to restore or rehabilitate the wetlands that were smothered
            by the current sludge disposal methods.

      On the matter of the possibility that a useful  resource may be wasted be-
      cause there is inadequate time to study the economics and environmental
      safety of its use as a result of clean-up deadlines within present legislation,
      it may well be that short-term delay of present environmental goals will
      produce long-term environmental benefits that transcend present goals.
      On the loss of even more naturally vegetated wetlands to solid waste
      disposal even though there are many acres of wetlands at the site now
      covered by only a fairly thin mantle of old sludge,  it appears further
      study of the feasibility of reusing the already filled and denuded areas
      ought to be made.

      On the matter of restoration (or lack thereof) of the existing sludge dump,
      field reconnaisance of the site indicates that the unspoiled remnants of the
      area are rich in both flora and fauna and are exceedingly beautiful both
      as small separate  landscapes and  in the aggregate.

      Given that the area is a floodplain, that it is well separated from most resi-
      dential areas, that it already has a bountiful  wildlife and that it could be
      restored as a productive wild park in its entirety for relatively little cost,
      it would appear prudent to do so as soon  as the alternative solid waste dis-
      posal procedure  is operable.

      The only work that appears necessary to accomplish  this includes

      1.     Picking up of the debris (household rubbish, tires, etc.) which
            have been thrown down the bluff along the northwestern edge of
            the site.

      2.    Scraping the old sludge up from its blanket like position across the
            site into piles, exposing the underlying mineral soil wherever pos-
            sible. Note that while the sludge when fresh contained 85% water
           and hence could only be placed as a blanket on the ground but that
           with aging the sludge has dried and become relatively solid.

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3.     Possibly covering the sludge pi les with some of the underlying
      mineral soils.

Beyond this point, nature will take its course, the mineral soils, especially
if poorly graded to include puddles and pools, given their lowland loca-
tion will be covered with volunteer native vegetation within a few years.
The mineral cover on the sludge piles will provide a roothold for plants
completing the rehabilitation. The wildlife, the bird watchersand
the hunters will come back quietly and do their thing.

If a more publicly recognizable park is desired a meandering walkway and
patrol road could be incorporated with landscape planting installed prior
to the park's "opening", presumably with a restriction on hunting re-
quired by the more open access.

Implementation will require a survey to identify landforms, vegetation, and,
possibly, archeological sites to be protected.   Presumably rearrangement
of the old, weathered and washed siudge will  not required detailed en-
vironmental impact assessments.
                                                                            93

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94.

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                                                               IN  T-H&
                   VICINITY   OF  UJASrStWlTB^
                                          WCIUTI65
5.0   INTRODUCTION

      The proposed action, described in Chapters III and IV, will impose a set of
      short-lived nuisances in many parts of the City of Cranston (and adjoining Warwick)
      during the various construction phases included in or expected to result from
      the proposed action. Such short-term impact areas will include the vicinity
      of the treatment plant, the routes of new pipelines and the areas of western
      Cranston that are expected to urbanize as a result of the proposed action.
      These short-term impacts are expected  to include noise, dust and traffic
      disruption,  including increased risk of traffic accidents, despite the inclusion
      of all current mitigating procedures within the various construction permits
      and contracts.  However, a fieldreconnaissanceof the sites of all this construc-
      tion indicated no especially sensitive land use or resource areas immediately
      adjacent to any of these expected short-lived impacts except as noted in Chapters
      VI and VII.

      Similarly, the proposed action will impose a set of long-term effects on the
      environment, which effects, simply because they are long-term, must be viewed
      quite carefully.  The principal areas in which these effects are expected are
      the neighborhoods surrounding the wastewater treatment plants and the river,
      while  the effects that appear to be the most serious are odor and noise.
      The key elements of the background of this neighborhood  nuisance problem
      include:

      1.   that while there have been nuisances at both the  municipal treatment
          plant and at the Ciba-Geigy treatment plant, there has been a substantially
          greater history of public complaint at the Ciba-Ceigy  plant and;

      2.   that the proposed action will bring the Ciba-Ceigy wastes to the municipal
          plant for treatment in the future because of:

          a.  lack of land for improvement of the Ciba-Ceigy treatment plant at
              its present location,

          b.  greater sensitivity of the Ciba-Ceigy neighborhood to odor because
              of its closer location to the treatment plant, and

          c.  the likelihood of more efficient,  more effective treatment of the
              combined wastes than of the Ciba-Ceigy wastes alone.


                                                                              95

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The principal questions that arise include:

      1.   will there be an adverse odor or noise effect on the neighborhood of the
          Cranston treatment plant as a result of the proposed action?

      2.   are there alternative actions that could preclude the nuisances?

      3.   are there any actions that can be taken to mitigate the nuisances? and,
          perhaps most importantly,

      4.   if adverse impacts on the neighborhood of the Cranston treatment plant
          are unavoidable, are these environmental  losses justified by the environ-
          mental benefits?

The sections below describe the neighborhoods for which nuisance is a concern, the
nature of the nuisances to which they are  now subjected, the  proposed changes in
plant that might change nuisance conditions,  and their resulting environmental  impacts.
5.1   BACKGROUND

      This section includes a description of the neighborhoods around the Ciba-
      Ceigy wastewater treatment plant, the City of Cranston treatment plant and
      the lower reaches of the Pawtuxet River and of the relevant, ambient odor and
      noise in each neighborhood.

       5.11    CIBA-GEIGY NEIGHBORHOOD

              Figure V-1 shows an aerial photograph of the neighborhood around
              the Ciba-Geigy wastewater treatment plant, the area from which
              most of the complaints of odor have originated, and a "windrose"
              which shows the distribution of wind duration  in the region.
              Note the proximity of the treatment plant to the residential area
              and that the area  of complaint lies closely adjacent to the plant.
              Note also that the windrose shows the annual distribution of the
              winds, and that,  in the  summer when windows tend to be open
              and people tend to be out-of-doors, southerly winds are most
              common.  And finally note the scarcity of undeveloped land
              in the vicinity of  the treatment plant.

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    a
A
«?
             =s
             g
  0-5  4-7  8-12  13-IE 13-24  23 +
        MILES PER  HOUR
                                                           LEGEND :
                                                               OBSERVED  LIWIT OF  ODOR
                                                               ( (000*
                                      *=l%  OF OBSERVATIONS
FREQUENCY OF V.'iMD FROM WESTERN CUADRANTS iS 55.6%
FREQUENCY OF \V;S'D FROM EASTERN) QUADRANTS IS 72.9%
WERA3E  WIND  SPEEO FDOM WESTERN QUADRANTS IS  ii,t> M.P.H.
AVERAGE  WIND  SPEED F^O.V. EASTERN OUA'jR.'-iTS  '.3  iCPM.P.H.
OVERALL  AVERAGE: \VIND  SPEED, INCLUOING  CALMS, is IOJM.V.H.
                              Y^INDROS^  FC3
                          FROVIOEIJCt. RK'JSr. lELAHn
                                                               OF  MOST SIGNIFICAfsJT
                                                       AND  CONSTANT
   a:; CLIMATOGRAPHY  OF THt UNITED
   fr; NO.p?.-37  S'JMVi.'-DY OF HO'.JKLY
ODSEllVATlONS- I 'r GRCEN A'.RPCIU ,
l9Slr-l9GO
Clftfl-  GEI6V  C01?9.  UKUIT/P.
SITE  ^UD  SU^OUSJDiMG
ODOTJ  survey-  p;9ure  v-i

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                5.12    CRANSTON TREATMENT PLANT NEIGHBORHOOD

                        Figure V-2 shows an aerial photograph of the neighborhood around
                        the City of Cranston's treatment plant, and the  location where the digested
                        sewage sludge (from both the City of Cranston's sewage and Ciba-
                        Geigy's)  Is dumped.                   Note:

                         1.  that, in the proposed project,  the use of the sludge dump
                            will  be discontinued,

                         2.  that there are almost no residence, within 800' of the plant
                             (not Including the sludge dump).

                         3.  that the prevailing southerly summer winds will tend to waft
                            odors out over the site of the existing  sludge dump,

                         4.  that the balance of the common winds do blow out over route 95
                            for quite a long distance as measured along the road, and

                         5.  that most of the land near the treatment plant (other than
                            disposal area to be abandoned and highway) is commercial
                            or industrial.

                 5.13     PAWTUXET VILLAGE

                         The only other area in which nuisance is believed to be of concern
                         is the lower reaches of the Pawtuxet River, an older residential
                         neighborhood that includes the Pawtuxet Village  Historic District, a
                         neighborhood listed on the National Register of Historic Places.  Note
                         that this district includes a substantial portion of the river itself within
                         the "place" listing.

                         Attention is drawn to this place for the following reasons:

                         1.  EPA is compelled by Executive Order 11593 to protect all areas
                            so listed (or eligible for such listing)  from environmental
                            degradation resulting from any of its actions (or non-actions)
                            if at all prudent and feasible.

                         2.  Without effective  removal of pollutants from the lower reaches
                            of the Pawtuxet River in the relatively near future, it is likely
                            that the river will,  again in the relatively  near future,  become
                            anaerobic during low  flows creating a serious and extensive
                            odor problem  in the Pawtuxet Village Historic District.
                            The result is that any EPA assisted, or licensed, project on the
                            Pawtuxet River must be adequate to prevent any nuisances that can
                            prudently be prevented.
98

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Ci^HSTON UJ.U/.T.P. PROCESSING UNITS

   LEGEND :
   SUIT 4 G^GASE REMOVAL UNITS
   ELUTRJATION TANKS
   MAIN OFFICE BLDG. 4 VACUUM FILTER EQUIPMENT
   SLUDGE DlGESTOR, TANKS
   PRIMARV CLARIPIGRS
   S6CONDARV  AERATIOKJ
   FINAL CLARIFIERS
   fttOlUER 6QUIPMENT
   CHLORINE CONTACT TANK
C^NSTON
T1]BflTMENT 9WNT
SITE  flND  SU^OUNDINQ
D€SC1]I9T]ON'   Pigure  V-Z

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                 5.14    AMBIENT ODORS AT CIBA-GIECY

                         The Ciba-Ceigy treatment plant  (including two one (1) million
                         gallon equalization tanks, trickling filters, and a final clarifier)
                         was built in 1970, and since then residents just north of the treatment
                         facility have complained of odors from that plant. The majority of the odor
                         complaints from those residents started in 1971, immediately following
                         the completion of the facility. The source of the odor emissions
                         seemed to be from the trickling filter systems, so that Ciba-Ceigy,
                         responding  to the complaints and the presumed cause, installed
                         corrective equipment, a nutrition (ammonia acid) holding tank to
                         feed the trickling filter and eliminate the low pH and anaerobic condi-
                         tions.  Unfortunately the corrections did not work, complaints were
                         still received, and so, in the summer of 1974, an odor counteracting
                         system was installed around the  trickling filter. This system masks
                         the unpleasant odor by blowing a sweet-smelling chemical around
                         the circumference of the trickling filter.  This still was not satis-
                         factory and in July 1974,  in a further experiment to eliminate the
                         odor emissions  from the treatment facility, Ciba-Ceigy temporarily
                         turned off the forced draft fans under the trickling filter.  The effect
                         of this action was to reduce the stripping of volatile solvents from
                         the wastewater.  This appears to have worked,  as there have been very
                         few odor complaints since.  (It should be noted  that while this action
                         appears to have been effective in reducing odor, it did not noteably
                         effect the efficiency of pollutant removal  from the wastewater. )

                         Concurrent with this experimentation, and based on the same com-
                         plaints, public hearings were held in March,  1975, which hearings
                         led to establishment of a formal odor control program. The program
                         consisted of daily surveys of the  surrounding neighborhood, as well
                         as actual air monitoring measurements.  In the period of May through
                         June 1975, Ciba-Geigy, under the inspection of representatives of the
                         State Department of Health, tested the air to determine if the hydro-
                         carbon emissions associated with the odor were of sufficient quantity
                         to adversely effect the health of the nearby residents. These tests
                         were undertaken with the trickling filter forced draft fans on.  The
                         tests were negative,  indicating no health hazard in the area at the time
                         of testing.

                         On July 23,  1975, the forced draft fans were again turned off
                         (reducing solvent removal by air stripping), and remain off to
                         this date.  The odor complaints have virtually stopped as a result of
                         this action and no_official complaints  have been  recorded at the Rhode
                         Island Department of Health since discontinuing use of the forced draft
                         fans.  Since that time several field visits were conducted during the
                         preparation of this statement to further evaluate the odor climate in
                         the area.
too

-------
        Currently there are no significant odor emissions from the trickling
        filters at the plant, due most probably to the shut-off of the forced
        draft fans and to the odor masking system.  The wastewater at
        the Ciba-Ceigy plant has,  by past record,  however, been shown
        to be odorous when exposed to aeration treatment (trickling filters).
        The extent of the area impacted by the odors when they were emitted
        is shown on Figure V-1 based on records of odor complaints.
5.15    AMBIENT ODORS AT CRANSTON TREATMENT PLANT

        Odors at the Cranston  treatment plant, while plainly evident and
        objectionable,  have not been the object of the sustained and strong
        complaint experienced at the Ciba-Geigy treatment plant.  To
        help determine whether the proposed action will abate or create
        odor,  a survey was made of existing odor conditions as part
        of the preparation of this statement.  It should be noted of this
        survey (made  through April and May of 1976) that residents and
        workers in the effected area have indicated that odors on some occasions
        may have been substantially more severe than those found during the
        survey period. However, it should also be noted, that the source
        of these more severe odors are likely to have been the same as
        the  sources of the less severe odors  identified in  the survey (same
        sources,  worse conditions) and that the odor mitigating actions
        incorporated in the proposed project will probably be effective for
        all of them.

        In measuring the existing odor emissions within the Cranston
        project area and evaluating odor conditions,  there were a number
        of established  approaches  which theoretically could have been
        utilized,  with  the  varying approaches broadly categorized
        as either analytical or sensory. The analytical approaches
        measure  concentrations of known odor substances in the air,
        while the sensory approach evaluates  the human  response to
        the  odor.

        Since this particular area  has so many varied and compounded
        odorous substances and since there  is no instrument or means of
        chemical analysis presently available  that can replace the function
        of the nose in  its ability for the detection and intensity rating of
        complex odors, the sensory approach was selected  for this survey.

        The measuring instrument used consisted of a judging panel
        randomly selected  to be representative of the general population.
        Three judges were used, a number identified in the literature
        as being  both  convenient and accurate for general ambient odor
        measurements of the type undertaken.  (Comments were also
        sought from local residents in order to obtain a more complete identi-
        fication of any odor problem in the area.)
                                                                            101

-------
                           The measuring procedure was by direct exposure of the panelists
                           to various odors in and surrounding the site.  The investigative
                           format was to record date,  time, location, weather conditions
                           estimated source of odor, strength of odor, acceptability of odor, and
                           any comments. Comparative and quantitative standards were set
                           for  strength and acceptability of the odors.   The strength measure-
                           ments were rated 0 to 5,  ranging from no odor to strong.  The accent-
                           ability measurements were also rated  0 to 5, with a range of Very
                           Pleasant to Very Unpleasant.

                           Site visits were scheduled  to obtain a broad range of weather,  wind,
                           and treatment plant conditions. The resulting average odor measure-
                           ments at the station locations are shown in Table V-1.   The average
                           of the readings was calculated in order to account for both the  changes
                           in the actual conditions as well as variations in the odor-perception
                           characteristics of the several  judges and in the same judge from
                           day to day.  In spite of the uncontrollable human  factor in this
                           sensory testing, the number of measurements and the attention
                           to detail are considered to  have yielded reliable and meaningful
                           results.
IOZ
                                         Station
                                           1


                                           2


                                           3


                                           4


                                           5


                                           6


                                           7


                                           8


                                           9


                                           10
                                                                TABLE V-1

                                                      CRANSJpNJJA'-.T' V.'ATfR IRPATMl'M PI AMT
                                                            iKHT (;:/>m Mt/wihn;! iifs   '
?
     Location             Strength**
(Estimated Spurt p nf Odor)*   Averages

WWTP
(final clarifier tankr.)
WWTP
(secondary aerition tanks)      2

WWFP
(elutriation tanks)           4

WWTP
(sludge disposal  area)         3

Residential Area
(swompy area below)           1

WWTP
(sludge disposal  area)         3

WWTP
(sludge disposal  area)         3

HWTP
(swampy wetland,  North)        2

WWTP
(perched water east of fence)    4

WWTP
(secondary aeration luiiks)
Acceptability
 Averages	


    3


    3


    4


    3


    2


    4


    4


    2


    5
                                         *For location of Station, see Flour" .'in. V-3
                                         **Sti v-n'.ith ranges iYuin 0 to E>, isc odcr to very strong; acceptability ranges from
                                          0 to 5, very plenrant to very unple,i;,ant.
                                            _?1  CE Magiilro, Inc.

-------
                       Pika


                                                                                                       V-?
 /    *•* •

  0-?  4-7  8-1?.  13-18 19-2-5 25 +
         M!L£S PEK HOUR
                                             Cr C3SERV5TIONS
  L66&HD  :
           SORVev  STATIOW NUMBER
           MEASU^eM£H7S IWTA&CE l)
 X"  lOOo' RA-DIOS  CIHCLE ((JftSe^VCD LIMIT OP
FREQUENCY OF WIND FROM WESTERN QUADRANTS IS  556%
FSHOUENCY OF WIND FROM EAS1ERM Q'JADRAIv'TS IS  22.9V,
AVERAGE  Wi'iD  S = E!ID  FRC'/l  '.VESTERN CU^CR4MT3 IS II.R M.P.H.
AVERAGE  V/IND  SFif.ED  FROV  EASTERN  CUADn..:;TS  :3 10.3 M.P.H.
OVERALL  flVESAGC  WIND SPEED , INCLUDING  CALM:;, IS I0.7M.RH.
SOURCE: CLIVATOGRAPHY  OF THE ''M'TED         WNDS05E HCP
STATED NO 02-37  S'lfWY OF HO"~'Y       PROVIO'NCE. FHO^r. ISL&IJD
OBSERVATIONS-T.'F. GREEN AIRPORT,""
1951-1960.
      AREA  OF MOST SIGNIFICANT  AND
      CONSTAWT
C^PHSTON
SIT6   AHO  SU^OUNDING
                          Figure   V-3

-------
                     Site visits and measurements during the survey period showed that both
                     the treatment plant and adjacent sludge landfill appear to be major
                     odor sources in the area.  In particular, the eiutriation tanks and
                     secondary aeration tanks were observed to be major sewage
                     treatment components emitting generally unpleasant odors. The
                     severity of the odor emissions for these sources varies from day
                     to day.  In general, on some warm days,  the secondary aeration
                     tanks overload beyond their oxidation capacity, become anaerobic
                     and emit a strong detergent-sewage type odor.

                     The eiutriation tanks,  adjacent to the west side of the main office
                      building, emit a constant background and occasionally strong
                      sewage  (digested sludge) type odor.  These odors are for the most
                      part localized around the eiutriation tanks themselves, because of
                      the wind-screen afforded by the main office building.

                      The sludge disposal area almost contantly emits an easily noticeable
                      "farmy" type odor. Warm days and puddling of rain on the surface
                      of the sludge accent the sharpness of these odors presumeably due
                      to increased microbiologic activity.

                      Strong odors were also found just east of the fenced-in treatment
                      plant, and were emitted from small  ponds of water in the winter dis-
                      posal area of the primary sewage grit.The algal formation on the
                      surface of the water-grit interface is the  probable cause of these
                      odors.

                      Other less significant sources of odor at the treatment plant are:

                      1)    primary and final clarifiers which are occasionally over-
                            loaded  and form a surface scum;

                      2)    the septic tank pumpings which are delivered by trucks several
                            times a day to the grit and grease  removal area of the plant; and

                      3)    the swamp north of the sludge landfill which on warm days
                            evaporates the stagnant water.

                      The observed sources of odor at the site, ranked from worst to best
                      according to strength and frequency of odor occurrence include:

                                  1.    Secondary aeration tanks
                                  2.    Sludge dump
                                  3.    Eiutriation tanks
                                  4.    Primary clarifiers
                                  5.    Final clarifiers
                                  6.    Septic tank pumpings ("septage")
                                  7.    Swamp north of sludge dump
104

-------
      The odors perceived at the receptor stations west and north  of the
      plant, the commercial and residential areas respectively, were found
      to be minimal at times of observation, although occasionally when the
      treatment plant was emitting high odors at the source and the wind
      direction was towards these several receptor stations, odors could
      be detected.  Comments from residents and workers in the commerical
      and residential areas west and north of the plant revealed that on
      intermittent occasions, the odors from the treatment plant may be much
      higher than those detected in the survey. Frequent strong  "sewage"
      type odors are also reported from travelers on Route 95, east of the
      site.  The descriptions and times of occurrence of these odors seems
      to indicate that they are strongest on warm days, and are more
      frequent at this location because of the prevailing wind direction
      from the west.

5.16  AMBIENT NOISE AT CRANSTON TREATMENT PLANT

      Noise impacts are evaluated by:

      1.    comparison of total noise levels resulting from addition of
            ambient noise levels to anticipated increases  with acceptable
            total  noise levels for the proposed land  use or activity, and

      2.    comparison of incremental total  noise levels resulting from
            subtraction of ambient noise levels from anticipated total
            noise levels with acceptable noise level increments.
                              TABU j-2

                    NOISE IMPACT AND COMMUNITY RESPONSE
        Noise Increase

        Less than 5 (IB (A)

        5-15 dB (A)


        More than 15 dB (A)
Degree of Impact

Slight

Moderate


Severe
Conniunity Reaction

None

Occasional
complaints from
Individuals

Frequent
complaints from
Individuals and
group action likely
        Source:  Parrock, H.O. "Community Reaction to Noise", Ch. 36, Handbook of Noise
        	  Control, td. C. M. Harris.  McGraw-Hill, 1967.
                                                                              105

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                         Table V-2 shows the likely social reaction intensity of various noise
                         increments while Table V-3 shows  the more detailed noise standards
                         in the City of Cranston's zoning code.  Special note should be made
                         of the desireability of maintaining sleeping noise levels at about
                         32dB(A) indoors (or 47 dB (A) outdoors allowing for 15 dB shielding
                         of an open-windowed structure).


                           To establish the  existing daytime ambient noise levels at the treat-
                           ment plant, a  survey was made in April,  1976, with a general pur-
                           pose sound level meter.  At each of the measuring stations, the
                           minimum noise level  (L min.), the maximum noise level  (L  max.)
                           median noise  level (L 50) and the level of noise exceeded 10 percent
                           of the time (L 10) which provides an average upper limit of the range
                           of noise experience were determined.  From these the equivalent
                           sound level (Leq), considered by EPA to  be the best descriptor of
                           environmental noise, were calculated.  The location of the sampling
                           point locations are shown in Figure V-4 and the results of the survey
                           are shown in  Table V-4.
                                                         TABLE V-3

                                                  CITY OF CRANSTON NOISE CODE


                                           Muxmmm -permissible sound-pressure levels ut specified
                                         points at measurement tor noise radiated continuously from
                                         a facility between the hour* of 11:00 P. H. and 7:00 A. M
                                         Frequntey Baud;        Sound Pnuurt Ltvtl:
                                         Cycles per second             Decibles*
                                            20-75                   76
                                            75-160                   70
                                           ISO - SOO                   62
                                           300 - 600                   55
                                           600 -1200                  49
                                           1200-2400                  48
                                           2400-4800                  37
                                           4800 -10000    .             36
                                           •Accordinc la lh« following furmuU:             If
                                           Sound PnutiH Uv«l In Decibels tansls 10 lot ——^—
                                                                    0.0002 dyn«./«q. cm.
                                           U the noise 'a not smooth and continuous or is not radiated
                                         between the  hours of 11:00 P. H. and 7:00 A. H., one or
                                         more of the corrections in Table 2 below shall be added to or
                                         subtracted from each of the decibel levels  given above in
                                         Table 1.
                                                         TAHLE2
                                         Tm* of Operation or                Correction in
                                          Character of Noise          '       Dteikttt
                                         Daytime operation 7:00 A. M. to 11:00 P. M.   plus 5
                                         Noise source operates leas than
                                         20% at any one-hour period             plus 5"
                                         Noise source operated less than
                                         5% of any one-hour period              plus 10*
                                         Noise source operated leas than
                                         I'/, of any one-hour period              plus U*
                                         Noise of impulsive character
                                         (Hammering, and BO forth)              minus 6
                                         Noise of periodic character
                                         (Hum, screech, and so forth)             minus 6
                                           •Apply on* Hi thm wrnctloiu only.
106

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LEGEND :
NOISE MONITORING  STATION
      WINSTON UJ£STeiUaT€^ T^EA7M£NT PLANT
      SlTe 4 SltfffiOUNDlNS  ^M
      woise  survey-  Figurev-4

-------


TABLE
V-4




AMBIENT NOISE MEASUREMENTS
Station
Ho.*
1

2
ft


4

5

6

7

8

9

10

(Weekdays, Working Hours)
Land Use Distance from L (min) Ljn
(Location! Source of Noise dDA __ dBA
WWTP
(Blower Building)
WWTP
(Blower Building)
WVITP
(Final Settling)
WWTP
(E. Fence)
WWTP '
(£. Fence;
WWTP
(Digester)
Commercial
(Glen Road)
Residential
(Eddy St/Cel1st1a)
WWTP
(Sludge Landfill)
Commercial
(?eUaconsett Ave)

25'

2'

5'

150'

ZOO1

20'

10'

10'

400'

10'

65

74

67.5

53

62

69

52

53

45

52

67

76

67.5

61

63

70

53

53

48

64
MO
JiBA.

67

76

67.5

67 .

63

71

53

53

52

75
L (max)
dBA

63

7g

67.5

70

63

72

53

54

57

90
Leg.**

67

76

67.5

G4*

63

70

53

53

50 •

76
*See Figure V-4 for Map Locations of Stations.
**Note:

Source:
The Leq values are calculated
would most likely be lower.
CE Maguire, Inc.
from daytime


readings


only; values


for 24


hour period





                       The readings show a fairly wide spread of sound levels throughout
                       the study area.  Within the treatment plant site the highest noise
                       emissions are at the blower building and the digesters, with the
                       blower building emitting a low frequency humming noise, the sound
                       level of which drops off rapidly within a few feet, and with the digester
                       air pump emitting  a high  pitched hissing sound, which was still de-
                       tectable over 50 feet distant.  The general noise level at the plant
                       was approximately 65 dB(A), ten (10)  feet from the water processing
                       tanks (water splash) .  The key condition to note however is that existing
                       noise levels beyond the site boundary areas were not affected by,
                       nor were noises heard from, the Cranston Wastewater Treatment Facility.

                       Outside the treatment facility, the commercial area just to the west had
                       a quite high noise level of Leq=76dB(A) . This high noise level is mostly a
                       result of truck  and commerical traffic which produces peak noises
                       close to 90 dB (A) . The ambient noise  level in the commercial area,
                       without the traffic influence,  as measured at station 7 is Ueq= 53dB(A).
108

-------
Nightime ambient noise levels (except at the plant) are expected to
be primarily a function of the traffic on  Route 95 and have been
calculated from average hourly traffic characteristics on that road.
Table V-5 shows these ambient noise levels both at a point TOO1
from the highway and at the nearest residential area at the end of
Eddy Street.

TABLE V-5
NISHT AMBIENT NOISE LEVELS
db (A)


Typical Noise Levels
Typical
Traffic
Time Flow!
10-11 3000 vph
11-12 2400 vph
12-1 1?00 vph
1-2 1200 vph
2-3 900 vph
3-4 400 vph
4-5 300 vph
5-6 300 vph
6-7 700 vph
7-8 3300 vph
1 vehicles per hour.
2 assumes 10% trucks
100' from 1-95
Lsa L10g
71 77
69 76
66 74
66 74
64 73
58 NM
56 NM
56 NM
62 NM
75 82

.
* exceeds recommended Indoor sleeping noise level
KM not statistically
Source: CE Maguire.
meaningful.
Inc.
1600'
LBO
54*
52
49
49 '
47
41
39
39
45
58*


by over


from 1-95
LIO
56*
54*
52
52
50
44
43
43
48
61*


5 dB.


                                                                  109

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           5.2   THE PROPOSED ACTIONS TO CONTROL NEIGHBORHOOD NUISANCE

                 5.21  THE PROPOSED ACTIONS

                       To preclude the probability that continued growth of pollutant dis-
                       charges into the Pawtuxet River (without abating actions being
                       taken) will create an odor nuisance, all along the  lower reaches of
                       the River but particularly at the Pawtuxet Village  Historic District,
                       a neighborhood listed in the National Register of Historic Places,
                       to abate pollutant discharges into the river without creating an odor
                       nuisance at the Ciba Ceigy treatment plant neighborood, and to
                       abate odor nuisances in the areas surrounding the Cranston wastewater
                       treatment plant,  it is proposed to:

                       1.    . substantially increase Cranston's capability of reducing pol-
                             lutant discharges into the river including adequate capacity
                             for improved treatment of the city's current discharges, of
                             Ciba-Ceigy's current discharges and of the future growth
                             of both,

                       2.    close down Ciba Geigy's existing treatment  plant and add
                             its discharges to the city wastewater system,

                       3.    improve (as well as enlarge) the city's wastewater treatment
                             plant to eliminate odor formation, and

                       4.    change waste treatment processes  to eliminate odor forming
                             processes including specifically:

                             a.    substitution of solid waste incineration for digestion
                                   and dumping eliminating odors stemming from elutriation,
                                   from sludge dumping and from grit dumping, and

                             b.    provision of special facilities for handling septage receipts.
110

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     5.22  ALTERNATIVES

           Primary alternative overall waste treatment strategies that might
           alter neighborhood nuisance potentials, that were considered and
           discarded included:

           1.     as alternatives to wastewater discharge into the river,  to
                  protect the river's quality and the quality of neighborhoods
                  along the lower reaches of the river, direct discharge into the
                  Providence River by effluent pipeline.

           2.     as alternatives to incineration  of solid wastes to protect neigh-
                  borhood and regional air quality:

                  a.    burial of sludge  in a controlled  landfill on- or off-site
                        and

                  b,    application of treated sludge on land as a soil conditioner
                        or fertilizer.

           The alternative of direct discharge of effluent to the Providence River
           was discarded both because it appeared to offer little or no better
           quality in the lower reaches of river than the proposed action and be-
           cause it would be more costly.

           The alternatives of non-incineration of solid wastes were discarded
           primarily because they might create neighborhood  odor problems,
           would not materially improve air quality, and, for  the off-site dis-
           posal alternatives, create a potentially life-threaten ing vehicle safety
           hazard if the off-site materials handling were sloppy enough to allow
           trucks to track sludge back onto public highways.
5.3   ANTICIPATED ENVIRONMENTAL IMPACTS

      The proposed action is expected to:

      1.     preclude creation of nuisance conditions along the Pawtuxet River,

      2.     eliminate odors from the vicinity of the Ciba-Geigy treatment
            plant.
                                                                                III

-------
                 3.     eliminate odors from the vicinity of the Cranston treatment plant
                       except for the odors generated by decay of seasonal algae blooms
                       that occur in the old oxbow and adjacent wooded swamp along the
                       bluff at the western edge of the lowlands,  and

                 4.     create noise problems of unknown severity in the residential
                       area just to the west of the site near the end of Eddy Street.

                 The odor elimination effect, other than the algae decay problem, is ex-
                 pected to be designed into the project and hence is dependent on the
                 quality of design, of operation, and of maintenance of the facility.  The
                 decaying algae odors however are not expected to be significantly  ef-
                 fected by the proposed treatment plant improvements, and a discussion
                 of how this might be eliminated is presented in Section 5.4 below.

                 Noise, in addition to that inevitably generated during construction, is
                 expected to effect the nearby neighborhood, almost up to Pontiac Avenue,
                 particularly at night.  The noise is expected  to be caused by the
                 sludge incinerators which must be operated continuously to provide
                 economical and fuel-efficient autogenous combustion , and as a result
                 will be constant and  will continue through sleeping hours,  even when
                 traffic dies down   on the nearby Route 95.  Table V-6 shows the probable
                 noise  levels through the night hours for existing conditions and for
                 incinerators that would generate 75 and 80 dB(A) measured out-
                 side the enclosing structure. Note that the actual noise levels
                 that will be generated will depend on the detailed design of the
                 facility and that the 75 and 80 dB(A)  impacts are illustrative.

                 The key features of the table are:

                 (1)   that ambient conditions probably do not exceed  over 5 dB above
                       EPA recommended sleeping levels between 11 PM and  7 AM except
                       for not over 6 minutes of peak between 11  PM and  midnight,

                 (2)   that with a 75 dB{A) incinerator, this short duration peaking ex-
                       ceedance period would be extended to 2 AM,the median noise level
                       would not fall to the 5 dB exceedance until midnight, and from
                       3 AM to  6 AM the median noise  level would be increased by about
                       7dB, and

                 3.     that with an 80 dB(A)  incinerator, the peaking  exceedance period
                       would be extended to 3 AM, the median  noise level would not fall
                       to the 5  dB  exceedance until 2 AM, and from 3 AM to 6 AM the median
                       noise level  would be increased by 10 or 11 dB.
112

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TABLE V-6
NIGHT NOISE IMPACT OF INCINERATORS AT
EAST END OF EDDY STREET FOR
VARIOUS INCINERATOR NOISE LEVELS
(dB (A))
Hour Existing If 75 dB at Incinerator
Ambient Increment at Resultinq
1-50 LYn Eddy Street Ambient
L50 Mo
10-11 P.M. 54 56 46 55 56
11-12 52 54 46 53* 55
12-1 A.H. 49 52 46 51 53*
1-2 49 52 46 51 53*
2-3 47 50 v 46 50 51
3-4 41 44 46 47** 48
4-5 39 43 46 47** 48
5-6 39 43 46. 47** 48
6-7 45 48 46 49 50
7-8 58 61 46 59_ 61
Existing exceeds EPA recommended sleeping level of 32 dB
open window shielding by over 5 dB.
'Resulting will exceed EPA recommended sleeping level by over
"More than 5 dB increase over existing.
***Hore than 10 dB increase over existing.
Source: CE Maguire, Inc.


If 80 dB at

Incinerator
Increment at Resultinq
Eddy Street

50
50
50
50
50
50
50
50
50
50
indoor plus
5 dB.



Ambient
LSO Mo
55 57.
54* 55
53* 54*
53* 54*
51 53*
51** 51**
50***51**
5Q***51**
51** 52
59 Gl
15 dB




The significance of these noise increments is hard to evaluate, particularly
since there are no firm criteria or standards at this time and since human
toleration of noise apparently depends on  a large number of factors, not the
least of which is quality of sound (soothing hum, shrill whine, clanging
cowbell, gurgling brook,  etc.), a parameter not included in the forego-
ing analysis.  Further there is the question  of whether a  small increase
in noise level  is a  negligible change or the straw that breaks the pro-
verbial camel's back. The impacts of the  assumed 75 dB (A) incinerator
do not seem to be particularly severe,  especially when the relatively
small  geographic area of impact is considered in comparison with the
very large scale objectives of the project. This is not to  say however
that this is no impact and that no mitigating actions are called for.

An 80 dB (A) incinerator would be quite another thing and, according
to the literature,can, rather certainly, be expected both  to be upsetting
to people and to lead to nuisance complaints  unless effective mitigating
actions are included in the project.

-------
           5.4   MITIGATION OF ADVERSE IMPACTS

                 The only expected long-term adverse impacts of the proposed action
                 specifically effecting the surrounding neighborhoods (not including
                 those impacts discussed in Chapters VI and VII) include an odor
                 problem, probably stemming from rot of algae in the wetlands between
                 the existing sludge disposal area and the nearby residential area, and
                 the night noise problems at houses in the vicinity of Eddy Street. Actions
                 for mitigating these effects are described below.

                 5.41  Wetlands Odor Control

                       It is believed that the odor rising from the wetlands is the result
                       of seasonal decay of algae bloom that occurs as a result of nutrient
                       runoff from the sludge dump  into almost stagnant,  seasonally inter-
                       mittent water bodies.  Elimination of the odor appears to require
                       elimination of the algae bloom,  which  in turn would  require:

                       1.    elimination of the wetlands by draining or filling,

                       2.    elimination of the nutrient supplies by removal of all sludge
                             from the watershed of the wetlands, or

                       3.    dilution and leaching away of the nutrients by diversion of
                             a significant stream through the wetlands.

                       The first of these alternatives appears to be in contrast with the
                       State of Rhode Island's present wetlands conservation policy
                       but not with the City of Cranston's zoning ordinance. It should
                       be noted however, that either filling or draining would be both
                       expensive and be likely to be resisted by the State which could de-
                       lay or deny required permission.

                       Elimination of the nutrient supply by sludge removal would be
                       expensive, pose a problem of alternative disposal of the old
                       sludge, and, possibly not work anyway.

                       The third route, dilution and leaching by diversion of a signifi-
                       cant stream through the wetlands, in  this particular  case, appears
                       to be both simple and economical, to be a return to a condition which
                       pre-existed the construction  of the existing  treatment plant, and
                       to almost be necessitated by the proposed plant expansion. At-
                       tention is called in Figure IV-10 to a stream which flows between
                       the existing plant and the sludge disposal area and to the plant
                       expansion which requires relocation of the stream.  It should be
                       noted:
114-

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      1.     that this is a sizeable stream which drains about 400 acres
            of Cranston including, fortunately for its flow stability,  much
            land within the undeveloped grounds of various state
            institutions, and

      2.     that old maps of Cranston show that the stream originally did
            discharge into the subject wetlands.

       It appears appropriate at this time to more fully explore this
      particular algae bloom control strategy especially in its relationship
      with the problems of restoring or rehabitating the existing sludge
      dumps as described in Chapter IV.

5.42  Noise Control

      The strategies that will be appropriate to control noise  in the vicinity
      of the Cranston treatment plant will depend  in large measure on the
      final design of the facility and the resulting noise but it does
      appear that the following actions might be required:

      1.    to quiet the noise (and visual blight)  of the construction
            near the residential area near the end of Eddy Street,
            construction of a landscaped earthen barrier (dike),
            say 5*  to 10' high between the residential area and  the
            construction area.

      2.    to quiet the incinerator noise at the residences.

            a.     if the noise level just outside the incinerator is over
                   85dB(A),

                   1)    offer to relocate the residents in the closest
                        residential areas including acquisition of their
                        property at fair market value plus compensation
                        for the costs  and hardships of relocation and for
                        the higher mortgage interest payments their re-
                        location is likely to impose upon them, and

                   2)    offer to sound-proof the homes next closest  to
                        the plant  (where this is technically feasible)
                        including double paned windows and central v
                        air conditioning plus compensation equal, at
                        the least, to the present worth of future op-
                        erating and maintenance costs   (adjusted for
                        future fuel cost savings).
                                                                          115

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                              b.    if the noise level just outside the incinerator is less
                                    than 85 dB (A) and over,  say, 73 dB (A), offer to sound-
                                    proof the impacted houses as described above.

                              c.    if the noise level outside  the incinerator is  less than
                                    73 dB (A), it appears that no receptor soundproofing
                                    will be required.

                        Determination of specific actions for the residential soundproofing
                        will require detailed  information on the design of the proposed
                        facility improvements, detailed survey of the local environments,
                        and detailed analyses of the effects.

                        Special note should be made of the fact that silencing the key noise
                        sources, the incinerators, is likely to be both less costly than paying
                        the above itemized costs and  also a great deal  less disruptive socially.
                        Requirement by EPA that the proposed plant either meet both the above
                        described 73 dBA outside the incinerator and the city's existing code
                        at the residential property lines or that the above described financial
                        compensation and soundproofing program be included in the project,
                        will be a positive incentive for the designers to do everything possible
                        to quiet the noise sources.
IIG

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Chapter  VI    GENH(Al   iNVI^ON MENTAL  EFFECTS
                   OP   SECOND^
                   {]6$UIT)N6
                   NON
 6.0   INTRODUCTION

       The extension of public sewers into the rural areas of western Cranston,
       regardless of the specific location of the facilities, can be expected to
       contribute to a wide ranging set of environmental effects in those areas
       including:

       *    those effects  related to changing the surface quality of the land,
            i.e. the effect of paving, loss of farmland, etc.

       *    those effects  related to changes in population, i.e. increased
            traffic, increased air emissions, etc.

       The surface effects  can be expected, depending on the design of the
       urban development  and its effects in changing storm-water runoff, to
       alter  the quality, extent, depth and frequency of flood and low flows
       of the streams draining from the urbanizing area with consequent im-
       pacts on land use capabilities,  economy, wildlife habitat, cultural re-
       sources, and esthetics.

       The population changes can be expected,  depending on density, to alter
       traffic flows, air quality, noise, costs of some municipal services, pro-
       perty values, etc.

       The sections below  set forth a brief description of western Cranston;
       its future, as proposed in the city's master plan, including the proposed
       sewering; some alternative futures;  the anticipated impacts of the pro-
       posed plan;  some alternative actions that could be substituted to avoid
       anticipated adverse impacts; and some mitigating actions that could  be
       substituted to lessen or ameliorate adverse  impacts.
                                                                          117

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           6.1   SETTING
                 6.11  CITY-WIDE FRAMEWORK

                       Figure Vl-l, City of Cranston,  Schematic Land Use, from the
                       City of Cranston, City Planning Commission's Land Use Analy-
                       sis:   1974, shows the sharp division between urbanized eastern
                       Cranston and rural western Cranston.  Note that the "low" and
                       "medium11 density residential areas include lots as small as 6000
                       and 8000 square feet.  Note also that the sharp demarcation be-
                       tween urban and rural lands that occurs in Cranston is very
                       unusual in southeastern New England where gradual transitions
                       are typical.
     RESIDENTIAL
                           COMMERCIAL ond INDUSTRIAL
           low

           Ruicl
                                Community SuwMlt C«nMri
                                                    RECREATION and OPEN SPACE
                                                         Slon of K.l
       1C-I
   City  »f  Crontton

SCHEMATIC LAND t/S£

     prtM'*«  If
  City Planning Commission

 8000  Q   ZOQQ  4000
118

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 Figure VI-2, Generalized Physiography,  City of Cranston, shows
 the concurrence of a sharp change in bedrock geology, soils and
 topography along the edge of the urbanized area, a similarly unusual
 congruence in southeastern New England.  Presumeably the sharply
 defined physiographic edge has had some impact on the location and
 clarity of definition  of the urban edge.
                      C ify
Further, it should be noted that nearly all of eastern Cranston
is served by both public water and public sewer, that there are
currently no public sewers in western Cranston, and that new
public water services have only recently been installed in por-
tions of western Cranston.  All public sewers in Cranston are
provided by the City of Cranston while public water in lowland
eastern  Cranston  is provided by a low pressure system operated
by the neighboring City of Providence's Water Supply Board, and,
in upland western Cranston, by a high pressure system operated
by the City of Cranston.
                                                                   119

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               6.12  PHYSIOGRAPHY

                     6.121 Topography
                           The principal topographic feature of western Cranston is
                           the scarp running generally North-South through the middle
                           of the City and  it is particularly well defined in the south-
                           ern half of the City where the land rises from an elevation
                           (above mean sea level) of about 50 feet on the east to an
                           elevation of 200 to 250 feet on the west in a relatively short
                           distance. The  area east of the scarp is generally quite flat
                           (with the exception of Sockanossett Hill and Rocky Hill),
                           while the area to the west of the scarp is  a series of hills,
                           the highest  of which. Bald Hill, has an elevation of about
                           500 feet.  The slopes of the land in western Cranston ranges
                           from about 2% to greater than 15%, with the average about 4%.
                           Figure VI -  3 depicts the topographic  features of Cranston.
120

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             6.2   PROPOSED ACTION

                   6.21   THE PROPOSED ACTION

                         The proposed action, improving and expanding the sewerage
                         system of the City of Cranston, includes the extension of muni-
                         cipal sewers into western Cranston to facilitate urbanization of
                         that area both for industrial and  residential growth.  This action
                         is consistant in  location and density with the City of Cranston's
                         1975 Master Plan and, in general, in amount of population, with
                         the State Land Use  Policies andj^lan.

                         The specific action includes:

                         1.     extension of sewers into the eastern portions of western
                               Cranston, i.e. the lower reaches of the Furnace Hill Brook
                               watershed, areas to the north of that watershed up to
                               and along Scituate Avenue  and the Plainfield Pike, and
                               a small urban cluster south of the Furnace Hill Brook water
                               off Phenix Avenue, including  two major new industrial are
                               one  off Plainfield Pike and the other off Phenix Avenue, botl
                               near I-295 (Figure I-4) and

                         2.     rezoning the residential portions  of the sewered area from
                               minimum lots of 80, 000 sq.  ft. to something on the order of
                               8,000 sq.  ft., possibly with some  limited areas zoned for
                               apartments and neighborhood commercial.  (Figure VI-9)
130

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It should be noted that while the proposed action corresponds in
its geographic extent to the proposed sewered area described
in 1. above and in Figure 1-4, that the capacity of the pipelines
proposed in each watershed basin has been designed for intensive
urbanization (i.e. about 3 dwelling units per gross acre) of that
entire watershed. This should not be construed as a plan for
future zoning changes or for future sewer extensions,  nor does it
preclude sewer extensions into or zoning changes within other
watersheds that are not included within the proposed action. The
decision to size the pipes within any watershed as though the entire
watershed  is to be sewered is a  standard and prudent engineering
practice which is based on the phenomena that:

1.    it is only very little more costly initially to install a larger
      pipe than a smaller one.

2.    that the maintenance costs of larger pipes tend to be  less
      than those of smaller ones,

3.    that increasing a pipeline's capacity after installation re-
      quires duplication of the entire pipeline at even  higher
      cost than the original installation.
                                                                    131

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                   6.22  ALTERNATIVES

                        By varying the assumptions of whether or not the sewers will be
                        extended,  or whether or not the zoning will be changed,  it is pos-
                        sible to generate a large number of alternative futures that might
                        result from the proposed action and, from them, to generate alter-
                        native environmental impacts.

                        The alternatives include, at the least:

                        1.     no action including no sewers and no zoning change (Figure VI-8),

                        la.    a "partial action" alternative,  i.e.  sewers by no zoning change,

                        1b.    a second "partial action"  alternative, i.e. no sewers but with
                               minor zoning change, from 80,000  sq. ft. lots to, say, 40,000
                               sq. ft., predicated on public water service,

                        2.     the proposed action,  i.e.  intensive urbanization in the
                               sewered area and rural-residential development in the rest
                               of western Cranston  (Figure VI-10),  and

                        3.     the proposed action,  repeated  in the future until all of western
                               Cranston is sewered  and  intensively  urbanized (Figure VI-11)
                               in essence a "worst case".
132.

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6-221 No Action Alternative

      The city does have the option of not sewering western Cranston
      and not changing the zoning to facilitate residential growth. This
      action, while probably precluding high employment and high
      tax paying industry,  will nonetheless allow continued residential
      growth  in western Cranston,  and hence will not lead to no growth.

      It must be noted with  regard to this residential growth that:

      1 -     Denial of the reasonable use of property, without
            compensation, is generally unconstitutional.

      2.     Acquisition, for compensation, of western Cranston
            (orof its development rights) is certainly beyond the
            financial means of the City and probably beyond that
            of the State of Rhode Island.
            (8,000 acres @ say $2500/acre = $20,000,000.)

      3.     Most of the undeveloped (and developable) land in
            western Cranston (8000 acres) is zoned  residential,
            albeit at 80,000 square  foot lots.

      4.     Recent changes in the Rhode Island expressway
            system. Route 1-295 and 37, have moved western
            Cranston from being relatively inaccessible to being
            the most accessible,  undeveloped area in the State.

      5.     Recent extension of public water onto the western
            Cranston plateau by means  of a high-pressure booster
            system, has changed provision of water  supply for
            housing in that area from being  a "crap-shooter's"
            search for uncontaminated cracks in the underlying
            bedrock at $2000 per shot to being a routine extension
            of public water mains.

      6.     Despite the fact that on-site sewerage in western
            Cranston is difficult because of soil conditions, it is,
            none-the-less,  possible and is happening in compli-
            ance with applicable  state and local regulations.

     7.     Technological changes in solid waste disposal, such
            as the "clivus multrum" an  in-house solid waste com-
            posting system, recyclable mineral oil toilet systems
            as are used on  aircraft, or vacuum toilet systems,
            coupled with irrigation  use  of wash waters, on indi-
            vidual sites, could overcome soils permeability limi-
            tations.
                                                                  137

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               8.     As development costs in "good locations" in large por-
                     tions of large metropolitan areas rise, effectively squeez-
                     ing out lower-cost development (and tower-Income
                     people), development in such areas can be attracted by
                     the increase  In snob value.

               Putting these all together, the no-action alternative would
               lead, ultimately, at the least,  to the total development of
               western Cranston, with  large lots, ranging from about an
               acre at the lower end of  the scale  in the better soil areas to
               several acres in the poorer soil areas .

               This alternative could lead to  a total population of up to
               16,000 people in about 5000 dwelling units distributed as
               shown in Figure VI-12 .  (These figures were calculated by
               applying the present zoning standards to the land areas in
               each zone after areas of  steep slope, (over 15%), shallow
               soils or poor drainage as reported by the U.S.  Geologic
               Survey, and public reservations were deleted, see Fig-
               ure VI-13).  The rate of growth would probably be slower
               than would occur under  the other  alternatives, but it would,
               nonetheless, occur.
                  VI • A FUTURE  SATURATION  909UUTION  DISTRIBUTION
                       Vfotern  Crjn«+on
                       according to &x'i»iir»$ Z-oning *
                      (The N
Source :  CE Majuire, Inc.
* *dju»t«d -fo
  development
                                                                    land

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                                                      TOTAL
                                                                .
                                                             :  £4 (tOO
VI -14- FUTURE
                                                       POPULATION
                                    accordi'ng  fo CHq  1975 barter 9bn *
                                  (ThelVoDOfled 4c4-ion )
             Source:  C& Maguire. Inc.               * iwijusted io assumed land development constrsj
                         6.222 Sewers But No Zoning Change Alternative

                               Conceivably the city could install sewers in parts of western
                               Cranston to alleviate present sewer problems without chang-
                               ing the zoning, or with only very limited zoning change.
                               Note that this  is really only a theoretical alternative with
                               the high sewer cost per resulting dwelling  unit tending to
                               preclude its happening.

                               This alternative would  be similar in population,  etc. to the
                               no action alternative in most respects except that the eastern
                               areas of the plateau would grow very rapidly.

                         6.223 Zoning Change But No-Sewer Alternative

                               Conceivably the city could reduce lot size requirements in
                               western Cranston to about 40,000 sq. ft.  on the strength of
                               extension of public water service.  Presumeably  if a lot is
140

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      not sufficiently permeable and well drained to be acceptable
      for on-site sewerage at 40,000 square feet, it will not be ac-
      ceptable at 80,000.  Further, it is possible such a change could
      result from court action overturning  the existing large  lot
      pattern as discriminatory, arbitrary, or an unwarranted
      infringement on property rights..  This alternative would be
      similar in general to the no action alternative except  that
      the ultimate populations would be doubled.

6.224 The Proposed Action  Repeated to Fully  Intensive Urbanization

      Conceivably the city could implement the proposed action lead-
      ing to intensive urbanization of the proposed sewered area
      and deterring low-density development beyond that area
      for, say, a decade, and then the city could make a similar
      decision again,  to extend its sewers  and change its zoning.
      Sufficient repetition would lead to total intensive urbaniza-
      tion of all of western Cranston.

       This alternative is not believed to be a likelihood, but  rather
       it is a  possibility and it does pose the "worst-case" set of
       environmental  impacts.  Figure VI-15 displays the population
       distributions implicit in  this alternative.
                                             , 10O
                                      <\OO
          vi - IS P'/lVfE  S47U?ATlCN  9CDUW710M
                    Cranston
               Pullq Urbanized at 8,000 to 12,000 w.f*. Lots overall  *
               (The Worst Case -A Iterative)
Source: CC  MaSu.rc,lnc.              « adjusted to assumed land development constraints
                                                                      141

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            6.3   ANTICIPATED IMPACTS

                  Decision to implement the proposed action (extension of sewers into,
                  and zoning change in, western Cranston) or to follow any of the alterna-
                  tive courses of action outlined above,  including taking  no action at all,
                  will lead to a broad set of significant environmental  impacts in western
                  Cranston and to a narrower set in the  surrounding region.  The mechan-
                  isms by which the impacts of the decision will be exerted will be through
                  urbanization of presently rural lands with the urbanization both changing
                  the character of the land surface and the numbers of people.  The changes
                  in land surface could lead to:

                  1.    quantitative changes  in stream flow (flooding,  etc.)

                  2.    qualitative changes in stream flow (pollutants,  etc.)

                  3.    esthetic changes

                  4.    wildlife habitat changes

                  The changes in  population could lead to:

                  1.    changes in traffic  flows

                  2,    changes in air quality

                  3.    changes in noise

                  4.    changes in municipal operating costs & revenues
(42

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6.31  LAND SURFACE CHANCE EFFECTS

      All  the  alternatives  will lead to changes in the land surface
      including substitution of pavement and building  roofs for vege-
      tative surfaces, substitution of paved,  roofed or vegetative sur-
      faces for  plowed surface,  substitution of drain pipes  for surface
      runoff, and alteration of the  vegetation including  mostly clearing
      of forest for housing but also reforesting  (with shade,  orna-
      mental, and  fruit trees)  existing field and  farms.

      The most serious effect of these changes, with the  details depending
      on the specific alternative, will be changes  in stream flow and water
      quality with impacts on esthetics, microclimate and wildlife habitat
      being relatively inconsequential.
      6.311 Streamflow and Groundwater Depletion

            Urbanization under any of the proposed alternatives will
            lead, to some degree,  by  virtue of the changes in sur-
            face permeability and the  increased smoothness of the
            drainage ways (e.g. pipes substituted for surface run-
            off) , to increased floodflows and to reduced groundwater
            recharge and  low stream flows in western Cranston, The
            increased floodflows could  lead to destruction of down-
            stream streambank properties, the need to replace culverts
            and bridges,  increase erosion, and broadening of down-
            stream floodplains. particularly when the increased flood-
            flow from western Cranston is added to that from other
            tributary areas of the Pawtuxet River and Meshanticut
            B rook.

            The decreased groundwater and low-flows would result
            from the stormwater being  rapidly shed before it could in-
            filtrate  into the ground, the ultimate source of low flow in
            streams. These two decreases would have adverse effects
            on wildlife habitat, esthetics and,  taken together with similar
             losses in other tributaties, theoretically lead to  reduction in
            the  volume of water available downstream for effluent dilution

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                                  To quantify these impacts and to compare the various al-
                                  ternatives, the peak runoff was calculated for Furnace
                                  Hill Brook at Furnace Hill Street for storms of various
                                  severities for the various alternatives.  Table VI-1 shows
                                                  TABLE VI-1
                                                FURNACE HILL BROOK
                                       RUNOFF 0 ELEV. 50 IN CUBIC FEET PER SECOND
                                                      LAND USE ALTERNATIVE - WESTERN CRAMSTON
                                                PRE-URBAN*
                             RUNOFF
                             EVENT
                             FREQUENCY
                             (YEARS)
                               2
                               5
                              10
                              25
                              50
                              100
  190
  345
  545
  825
1,050
1,300
 250
 460
 730
 900
1,340
1,520
 315
 575
 795
1,155
1,440
1,755
  4B5
  B60
1,100
1,555
2,305
                             *Pre-Urban = Condition likely to have existed before any suburben development.

                             1 - Existing Zoning - fully developed.
                             4 - Master Plan - fully developed,
                             5 - All of western Cranston urbanized.

                             Source: CE Magulre, Inc.
                                  the results of these calculations.  The pre-urban column
                                  shows the conditions as they would have been prior to
                                  any suburbanization, alternative 1 shows the effect of
                                  the proposed action and alternative 5 shows the effect of
                                  total urbanization.  Alternative 2 would be the same as
                                  alternative 1  while alternative 3 would be similar to alter-
                                  native 4.
(44

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The method used for the calculation was that described
in the U.S. Soil Conservation Service's Technical Re-
lease No.  55, Urban Hydrology for Small Watersheds,
Chapter 2, a technique which entirely eliminates the need
for "engineering judgement" on surface permeability,
roughness of surface, etc. but rather relates runoff to pre-
cisely determineable watershed characteristics such as
soil type, dimensions, percentage paved, etc.  The various
runoff events, from 2 to 100 yearrecurrenceperiods re-
flect the phenomenon that more severe storms are likely to
recur less frequently then less severe storms.

Inspecting the resulting changes in flood flows, several
kinds of observations could be made including:

1.    that the impact of urbanization, the increase in
      flood flow, is significant and deserving of ame-
      lioration, but is hardly an ecological disaster (except
      for the worst case,  i.e.  total urbanization),

2.    that aj_[ the alternatives will  have a significant impact
      including "no-action", and

3.    that the proposed action is not much more adverse in  this
      respect than no-action and is considerably less adverse
      than the worst case.

And finally, it must be noted of these conclusions, for their proper
evaluation and subsequent decision making:

1.    that the soils and  topography of Furnace Hill Brook are such
      that the impact of urbanization on streamflow is minimized
      and that similar urbanization in other  parts of the  Pawtuxet
      watershed, or in other watersheds may be much more ad-
      verse in its effect, and

2.    that relatively slight changes in the pattern and design
      detail of the development could entirely obviate and/or
      mitigate the adverse impacts.
                                                               145

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6.312 Water Quality

      In addition to changing the rates and volumes of storm-
      water runoff, urbanization will change its quality through
      a number of interrelated processes involved in converting
      farm and forest to street and lawn, including unpaved
      land runoff effect construction effects and pavement run-
      off effects.

      As farmland is changed to paving, lawns, etc. there should
      be a very large reduction in pollution of runoff carrying
      suspended solids, phosphates and nitrates from cultivated
      fields, while as woodlands are so changed,  an opposite
      effect should occur. Table VI-2 taken from the Corps of
      Engineers, Omaha District, "Regional Wastewater Management
      Study",  October, 1974, shows those effects quantitatively for
      long-term average conditions.

TABLE VI-2

Average Annual Stormwater Runoff Concentrations of Pollutant
Lan>1 Use
Residential (2-5 ppa)**
Residential (5-3 ppa)
Residential (8-12 ppa)
Residential (12-15 ppa)
Residential (Combined Sewer Overflows)
Commercial and Industrial
Agricultural (Adequate Controls)
Agricultural (Needing Control)
Rural (Adequate Controls)
Rural (Needing Control)
*Corps of Engineers, Omaha District, "
**Persons per acre.
Suspended
Solids
(«nq/l )
300
340
380
420
250
500
3,000
40,000
500
5,000
Regional Wastewater

BODs
(mg/ll
20
22
24
26
100
30
20
25.0
0.3
3.5
Management Study

Parameters*
Phosphorus
P (mg/1)
0.70
0.66
0.62
0.58
4.00
0.50
" .20
2.80
.002
.04
", October 1974.

N1 trogen
as
N (mq/1)
3.1
2.9
2.7
2.5
10.0
2.2
5.0
65.0
1.0
8.0



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During the urbanization process extensive areas of land
will be torn up.  reshaped and ultimately resurfaced,
creating  intensive but short-lived erosion and silt runoff
in a checkerboard pattern all over the city. At worst,
the erosion could reach and exceed the worst suspended
solids runoff loadings of the worst agricultural  areas
listed in  Table VI -2, but it would be limited in any one
location to one construction year and, unlike agricultural
runoff, not be repeated in the same place year after year.

The worst effects are likely from pavement runoff.with
severe pollution likely to occur after the urbanization
process is completed, as an erratic but endless series
of short-lived events, when short duration but  intensive
storms follow  long dry periods (e.g. summer thunderstorms
following periods of drought) .  Such storms would wash
the dirt, dust, litter, vehicle drippings and rust, lawn
clippings, etc. that accummulate in street gutters into
the streams through the storm drain systems, and,  in
the case  of the low stream flows caused by  the proceeding
drought and low runoffs caused by the short duration
of the storm, create  high pollutant concentrations for
brief periods.

Techniques for the quantification of this effect,  in terms of
calculation of concentration of pollutants, duration of
concentration, and frequency of occurrence, are only
now  being developed while methods for evaluating the
acceptability of various concentrations for various durations
at various frequencies are even less advanced. In consequence
no quantifications of the effect have been prepared for
this  statement.  It should be noted however that a statewide
study of this problem is about to be undertaken by the
Rhode Island Statewide Planning Program under the Section
208 planning assistance program of the Water Pollution
Control Act Amendments of 1972, and that the Rhode Island
Department of Natural Resources appears to have  adequate
authority to enforce any necessary mitigating action that
may evolve from the 208 study under the Rhode Island
Wetlands Act.
                                                               I47

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                       6.313 Esthetics
                             Bearing in mind:

                             1.     that beauty is ultimately in the eye of the beholder, and

                             2.     that impacts of the project on specific areas of esthetic
                                   speciality are discussed in Chapter VII,

                             it must be noted that all of the alternatives,  including no-
                             action, will lead to significant changes in the appearance of
                             western Cranston.

                             At the present time western Cranston is a fairly  random
                             mixture of fields and forests with scattered houses and
                             agricultural buildings of highly varied qualities. The net
                             impact is judged by most observers to be highly attractive
                             for the most part.  All  the alternative actions described
                             above will lead, in the long run to the almost total replace-
                             ment of the pattern of fields and forests with urban  land uses,
                             but with some qualitative differences between the alternatives.

                             The no-action alternative, no sewers and large lots, because
                             of the varied suitability of the soil for on-site sewerage, would
                             lead, at least in the early phases, to scattered, low density
                             growth that would be likely to preserve significant  amounts of
                             forest throughout the area,  and  presumably result in a rela-
                             tively non-urban landscape.

                             The proposed action and the other sewered alternatives are
                             likely to lead to a fairly uniform coverage of the land with
                             houses with relatively little forest area preserved undevelopedf
                             and all  presumably will result in a quite urban landscape
                             in the sewered areas.

                             The esthetic quality of resultant development, however, is
                             likely to be more dependent on the quality of design, the
                             zoning standards and the subdivision regulations than on
                             the decision of whether or not to sewer the area. The
148

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      key factor in whether the results are likely to be attractive
      or not probably will depend on whether adequate trees are
      preserved in the original development phases of the wooded
      areas and whether adequate space is provided for future
      growth of trees in the cleared areas.  Devices for providing
      such space include adequate lot sizes, "cluster zoning", and
      "planned unit development".
      (Cluster zoning is a variant of zoning in which a developer
      is allowed smaller lot sizes than would otherwise be applicable
      in any zone, but the total number of such lots is usually
      limited to the number of "normal" size lots otherwise appli-
      cable.  The resulting undeveloped land  is usually placed in
      some sort of open space trust or is held  in common by all
      the lot-owners in the development.  Planned unit develop-
      ment is similar to cluster zoning but development is not
      necessarily limited to the land uses otherwise applicable
      in the zone, i.e. dwelling units can be placed in apartment
      buildings rather than in detached houses and commercial
      activities are sometimes allowed in residential zones if
      designed into a large development.  The specifics of both
      devices  tend to be highly variable and to be tailored
      to the character and  attitudes of the community that elects
      to adopt such zoning.)

6.3U Wildlife  Habitat

      Bearing in mind that the principal habitat value of western
      Cranston (except for occasional deer which will be driven
      away by  urbanization no matter what alternative is selected)
      is for small animals and birds,  it appears:  1) that the pro-
      posed action and other sewered alternatives,  at the proposed
      zoning standards, will lead to a substantial loss of wildlife
      habitat,  2)  that the no-action alternative, because it will
      result in fragmented development and preservation of
      varying size wooded areas, will substantially maintain
      the numbers and  variety of wildlife (but with substitution
      of some species for others), and 3) that relatively slight
      changes in the pattern and detail of the development,
      i.e. cluster type zoning, etc. could entirely mitigate
      the adverse effects of the proposed action.
                                                                    143

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                  6.32  POPULATION CHANGE EFFECTS

                         All the alternatives will lead to changes in population,  and the
                         changes in population, in turn, will effect the environment. The
                         most serious of the effects,  with the details depending on the specific
                         alternative, will be Increases in traffic flow and increases in noise.
                         In addition, the alternatives could contribute to significant changes
                         in the balance of municipal  operating costs and  revenues and to some
                         change in air emissions.

                        Table VI-3 and Figures VI-12,  14. S 15 show the amounts and
                        distribution of population in western Cranston for the principal
                        alternatives.  Note that these are saturation populations and
                        that it will probably take some time for these amounts to be
                        reached.  Various studies done by the city and state planning
                        agencies have forecasted residential population  growth on the
                        order of 15,000 new people  in twenty years in Cranston, with
                        the city's forecast allocating half of this growth  to the eastern
                        half of Cranston.

                        It must be noted in this regard:

                         1)     that forecasts are, in the final analysis, educated guesses
                               and that while they are usually right, they can be very
                               wrong;

                        2)     that population growth in suburban areas  can be explosive,
                               inundating once rural land with buildings at unreasonable
                               densities before adequate planning for open spaces and
                               other public facilites  can be accomplished;

                        3)     that western Cranston is at or very near the center of ac-
                               cessibility in the metropolitan area;

                        4)     that Cranston is a socially prestigious location within the
                              metropolitan area, a very important factor considering
                               that in the real estate selling profession every salesman
                               recounts the old saw that "the three most  important factors
                              controlling the desireability of  real property are location,
                               location,and location;"

                        5)    that the adult population is growing very  rapidly (as a re-
                              sult of the maturation of the post war boom-babies, actually
                               1946-1962) despite the slow growth of the total population;

                        6)    that normal growth of families and housing in recent years
                              has been severely retarded  by the recession and historically
                              unprecented, high interest rates, creating a backlog of
                              potential marriable people and potential housing  demand.
\50

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lt,0» -,
                        /Win/id-
                     t
y/v
         //
               S  /nf«ftrnC/*nfoK
           „---"  / (ivufr 145-I4M
   fti I/**1 1^0—afe—ite—i%-
                                                          TABLE VI-3

                                           SUHHARY_QFSATURATION POPULATION DISTRIBUTION ALTERNATES

                                                         WESTERN CRANSTON
                                                                          1975        Fully
                                                                          Raster-Plan   Urbanized
                             Northwest Quadrant
                               north of aqueduct
                               west of proposed zoning change   S.ztrj

                             Southwest Quadrant
                               south of aqueduct
                               west of proposed zoning change   5,500

                             Lower Furnace Hill Brook Watershed
                               proposed area of zoning change   4,900

                             Natlck Avenue Strip
                               between Natick Avenue and I-Z95  2,700
                                      Total
                                      Source;  CE Maguire, Inc.
                                                               16,200
 2,800


 3,900


15,300

 2.600

24,600
17,500


24,000

17,300


 2,600

61,900
    VI -16
                                , \<\W-
                  Figure Vll-16,   Historical Growth  of Selected Suburban
                  Communities,  1910 to 1970 shows "how quickly areas similar in
                  their location with respect to metropolitan centers have grown in
                  times past. Such growth could occur again in the future and it
                  very well could  occur in western Cranston if public sewers are
                  provided.

                  In the following  analyses, therefore, the saturation populations
                  implicit in each  alternative are used as a basis for impact estima-
                  tion.  In general, partial development will generate partial im-
                  pact.  Note however that since the development will tend to grow
                  from urban edge out into the countryside, the areas where public
                  spaces should have been  reserved or mitigating actions  should
                  have been taken are likely to be among the first developed, pre-
                  cluding their ultimate provision. In  essence a mitigating action
                  or ultimately needed public  faciltiy whose planning is delayed may
                  be an action or facility that is denied.

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                    6 .321
                     Traffic 6 Traffic Fatalities
                                Urbanization of western Cranston, under any of the proposed
                                alternatives, will lead to very substantial changes  in traffic volume
                                and, as a further consequence, to increased accidents.

                                In general, in  the northern part of western Cranston,  the
                                road network appears to be more-or-less readily adaptable
                                to traffic increases, but in the southern part of western Cranston,
                                the increased traffic is likely to lead to a virtually complete
                                breakdown of the transportation system, including the proba-
                                bility of impairment of public safety services (police, fire,
                                ambulance, etc.), reduction in property values,  frustration
                                induced auto accidents,  including needless fatalities and crip-
                                plings, and road-widenings whose design will be more guided
                                by desperation than by concern for environmental quality.

                                The most critical point of this transportation failure will be
                                between the intersection of Route 37 and Natick Avenue, on
                                the east,and the intersections of Phenix Avenue with Hope
                                and  Olney Arnold Roads,on the west, with all the streets in
                                the surrounding areas impacted to variously adverse degrees
                                by the various alternatives.
                                                                           9.000
                                                                           2.100
                                                                   -Piuiiiu.il a*d'<,' 900
                            VI -17  IfllNCfML TRAFFIC FLOWS EXPECTED TO BE  6ENKWE)
                                   "  	  SATURATION  	"
\52
o       PCM!     according t» Exifhng Zoninq
Source :  It Maguina.lnc.  /• —u, ufl  *-1'-- « IJ-T__J.- .- "\

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                The no-action alternative will ultimately generate some 26,000
                trips per day on the two key streets, Wilbur-Conley Streets
                and Phenix Avenue just west of Natick Ave.  The combined
                capacities of', these roads is about 7,000 trips per day, at
                the densities recommended for safe operation by the USDOT,
                and 21,000 trips per  day,totally congested.
                                                              100,000
                                                             acate: r-100,000 n)rM/o«v
                                                   /---
                                                   ( f-pjily T/>fV  7,
                                                   *• j ibfiiJft<0w'   Z.
                                                    (.•p,./cll:i"| U*^-
                                   :.feoo
                                    qoo
         Pigurt  VI -18
Source.: CE Magu.Ve, Inc.
      TilAFPIC  PLOWS  EXl>ECTeD TO UE GENERATED
FUTURE SflTUHATlON "DEVELOTSMENT *
                Ma*TTfc>- '/Man
             )
                       according io
                       The
                 The proposed action would generate some 45,000 trips per
                 day on these two streets and alternative 5, the worst case,
                 with public sewerage and 8.000 to 12,000 square foot lots throughout
                 western Cranston, would generate some 90.000 trips per day.
                                                                                153

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                                                ' 92,000
                                                              (2,000
                                                               3900
                                                               1,300
                                                  4.1.000
                                            iu  >••   '1,400
                                         I F ] V.VJ .V..; u'mA: 4.500
                                         S"«,
           •gurt VI  • »  9^INCl1idL T^flFFlC FLOWS EXPECTED TO BE G6Ntf}flfTED
                       15V FUTURE SATURATION              *
Source. :  C f.
              Fullq Urbanized ^ $,000 t» rt(OW s^.fi lota
             (The Worst  Coac
                       Clearly any of these futures ought not to be accepted and
                       cannot be ignored. The no-action alternative, no sewers
                       and 80.000 square foot lots will not avoid the problem, and
                       will ultimately  compel the straightening and widening of most
                       of the streets in the area to their esthetic and cultural resource
                       and mi croclimatic, detriment.  The proposed action, limited
                       sewers  and 8,000 and 12,000 sq . ft. lots, would have an even
                       greater impact  and require not only widespread straightening
                       and widening,  but also a new roadway of at least 4 lanes west-
                       ward  from the end of Route 37.  The worst case alternative,
                       sewers  and 8,000 and 12,000 sq . ft. lots throughout western
                       Cranston would ultimately require extension of Route 37 or
                       something  very similar across the area to Hope.
                       In the northern areas, along the Plainfield Pike, the various
                       alternatives will have similar quantitative impacts but the
                       environmental costs would be substantially less as the areas
                       most affected are industrial.

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Figures VI-17, 18, 19 show the principal traffic streams likely
to be generated by the various alternatives based on trip
generation tables of the Institute of Traffic Engineers,  the
terrain I imitations, and assumed destinations. Figure VI-20
shows the capacity of the roads in the most severely impacted
areas based on a parametric analysis of the roads as per the
USDOT's Highway Capacity Manual. Table VI-4 shows the
existing traffic on these roadways based on counts by CE
Maguire, Inc., their existing capacity at safe densities,  their
existing capacity at worst conditions,and their expected future
load for each alternative.

TABLE VI-4

TRAFFIC CHARACTERISTICS
Safel !
Capacity
Maximum? ?
Capacity
Total Congestion
Existing Conditions
Existing Zoning
Fully Developed
Master Plan
Fully Developed
Master Plan
20 Year Development
Western Cranston
Fully Urbanized
1 U.S. FHWA "Level
? U.S. FHWA "Level
2 Peak hour equals
Source: CE Maguire
VICINITY OF FURNACE
Wilbur/
Conley St.
2,600
6,900
3,300
13,000
23,000
11,000
45,000
of Service B".
of Service F".
HILL BROOK
Furnace Hill Hope St. Phenix Ave.
Street (West of
Phenix)
3,200 3,900 4,550
6,000 9,200 13,900
1,450 1,800 2,300
9,000 14,000 13,000
14,000 22,000 25,000
7,000 11,000 13,000
23,000 40,000 45,000


7.75! of average daily flow
, Inc.

 In particular, it should be noted that this forecasted transporta-
 tion failure is more than inconvenience and loss of comfort
 and time, it is loss of limb and of life itself. Automobile caused
 fatalities are the fifth leading cause of death in the United States,
 the third leading cause of years-of-life-lost to people under
 65 years of age, and the leading cause of death and disablement
                                                             155

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to young people.  Adding to this the disablement of otherwise
economically productive young people with otherwise long life
expectencies, this particular environmental problem could
well be considered the nation's and Cranston's primary en-
vironmental problem.

The causes of automobile related accidents have been much
discussed and attributed to a variety of causes including
vehicle failure and irresponsible drivers, but all they do
have in common  an action of a driver with respect to the
roadway, driving faster than the roadway allows,  not turn-
ing when the roadway turns, and entering an intersection or
passing without being  able to see oncoming traffic. Presumably
if these drivers had not been impatient,  if they had not been
acting  unwisely or had not been  easily frustrated,  in short, had
not been human, they or the persons with whom they
collided would not be dead (or maimed).  Equally if they
were driving in an environment with no sight-distance
limitations,  no surprise turns, no slow-moving trucks
simultaneously blocking lightly used roads and obscur-
ing oncoming traffic  (or children playing in the streets
ahead), the accidents may well have been  averted.
However, regardless of presumed cause, statistical
analyses of  highway accidents have indicated the
following:

1)     that divided, limited-access, grade separated
       expressways have far fewer accidents than all
       other roads,

2)     that the number  of accidents on any roadway,
       except on winding two-lane roads, is propor-
       tional to the traffic density except for extremely
       light  or extremely  heavy traffic,

3)     that on two-lane winding roads the number of
       accidents increases as the square of the traffic
       density , and

4)     that at very low  densities, accident rates are
       very  high and that at very high densities,
       accident rates are very low.

In general,  these relationships are easily explainable,
with expressways precluding cross-traffic and vehicles
backing  into the roadway, pedestrians fenced out,  etc.;
with more traffic on most roads creating greater oppor-
tunity  for accidents; with very low densities allowing

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                                   the reckless to achieve unreasonable speeds; and with
                                   very high densities binding all traffic into a slow lock-
                                   step.  The accidents on two lane winding  roads,  the
                                   type characteristic of western Cranston, is somewhat
                                            •CALl
VI -20 WMCITV OP T4I6
:6EMD :  11,600 VPD • S«F6 CAPACITY IN V6HICLSS P67? T)AV,
      U.3.0EPT.OP TnAMS9O17TATIOM LEVEL OF Se^VICE  '&"
     (21,000 VPD)-Ai)SOLUTe CflPflCITV IN VEHICLES . ...
      U.S.DE'PT. Of TRAM6PORTATION L6V6L  OP 8ERVIC6  "F
r.BIUE MAP 15 ENL«neeD u.s.a.s. TOPOGRAPHIC
   : CC MOCUIAC, INC.
                 CONTOUR IHTSVAL 10 P££T
                                     'Phuix 4vtnut
                                       6,700 VPD
                                IN THE  MOST
                                   more complicated.  On these roads at low densities
                                   drivers frequently approach curves  and intersections
                                   at speeds such that they could not stop if the roadway
                                   were occupied by an on-coming vehicle, but since the
                                   density is low, the probability that such a vehicle will
                                   be approaching at the same time is also  low.  As the
                                   density of traffic increases, the likelihood that a vehicle
                                   will be approaching a blind spot too  fast increases simul-
                                   taneously from both directions and as a  result the likeli-
                                   hood of a  collision increases even faster.

                                   It should be noted that increased traffic  density and
                                   accidents will be an unavoidable adverse impact of the
                                   proposed  project, but that the hazards inherent in
                                   increasing the use of the existing roadways can and
                                   should be mitigated.
                                                                                             157

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                      6.322 Noise
                            The principal noise effect expected to be created in the urbani-
                            zation of western Cranston will be from traffic, generated
                            primarily by local traffic, particularly trucks serving the resi-
                            dential areas.

                            It should be noted that the principal roads in the southeastern
                            portion of western Cranston are probably already subjecting
                            the residential areas adjoining them to noise levels well in
                            excess of USDOT Federal Highway Administration standards
                            and EPA recommendations, and that all the alternative actions
                            will increase these noise levels significantly over varying
                            time periods.  Table VI-5 shows the noise expected to be gene-
                            rated on Wilbur Avenue  and Conley Streets for the existing
                            conditions, based on recent traffic counts, and for future condi-
                            tions likely to be created by the various alternative actions. The
                            calculations were performed according to the National Cooperative
                            Highway Research Program Report #117 and took into account
                            traffic and site conditions. The standards are from the most re-
                            cent edition of the US FHWA Policy and Program Memorandum 90-2.

                            The first line indicates the maximum allowable peak hour noise
                             level established by the  Federal Highway Administration for out-
                            door activities where special quietness is not required and  in-
                            cludes residential areas, schools, hospitals, recreation areas,
                             etc.  (The peak hour LJO noise level is the level that will be ex-
                            ceeded 10% of the time at peak hour) .  In general a peak hour,
                             outdoor Llo noise level of 70dBA will insure noise levels in-
                            doors, with windows open, that do not interfere with normal
                             functions such as conversation, radio listening, etc. most of
                             the time, and, in areas with no through trucking, do not inter-
                             fere with sleeping.

                             The second line is a calculation of existing conditions at a
                             number of locations in western Cranston.  Note that these
                             figures are somewhat uncertain because of the relatively low
                             volume of truck traffic now using these streets and the nature
                             of LIO as a statistical parameter.
                             The third, fifth and sixth lines represent the three alternative
                             futures used earlier in this chapter and the fourth line represents
                             the "proposed action," i.e. limited sewering and zoning change.
158

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PEAK HOUR L,n TRAFFIC
(dl
Maximum Allowable
Noise -1
Existing Condition
Existing Zoning,
fully developed
Master Plan,
fully developed
Master Plan,
20 yr. development
Western Cranston.
fully urbanized
TABLE Vi-5

INDUCED NOISE LEVELS FOR SELECTED LOCATIONS
JA. 50' feet
Wilbur/
Conley St.

(78-85) 2
81-91
84-91
81-91
85-92
'rom edge of
Furnace
Hill St.
road)
Hope St.
(west of
Phenix)
Phenix Ave,
70
(8<»)2
90
90
90
91
(75-82) 2
81-88
81-88
81-88
82-89
(78-82) 2
84-88
84-88
84-88
85-89

a.    Assumes 10% of ADT at peak hour and 5% trucks.

b.    Reduction of peak hour to 5% and trucks to 2}% would reduce noise *~
     levels about 6 dBA

c.    First figure is noise level for the best sections,. 2nd figure is for worst
     sections.
1    Federal Highway Administration

2    ( ) indicates uncertainty because of low truck volumes.

Source:  CE Hagulrc, Inc.
Note that all the noise levels along all the main streets are in
excess of the standards.  In part, in the worst locations, this
is a result of the steep grades and poor alignments of the
existing streets and in part,  in all areas,is a result of heavy
traffic volumes.  In a sense,  this is a technical confirmation
of the common observation that heavily traveled main streets
are poor places on which to live.

Note also that these noise levels are quite insensitive to even
large changes in traffic volume.  Essentially human percep-
                                                                   153

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                                 tion turns off louder noises so that twice as much energy
                                 generates only 3 dB more perceptible sound, an amount so
                                 small most observers would not notice it.  Table  VI-6 shows
                                 a similar analysis based on the median conditions likely to
                                 exist at peak hour.
                                                          TABLE VI-6

                                  PEAK HOUR Ig0  TRAFFIC INDUCED NOISE LEVELS FOR SELECTED LOCATIONS

                                                   (cJBA. 50' feet from edge of road)

Maximum Allowable
Noise
f'xisting Condition
Existing Zoning.
fully developed
Master Plan,
fully developed
Master F'lan,
20 yr. development
Western Cranston,
fully urbanized
Wilbur/
Conlcy St.
Furnace
Hill St.
Hope St.
(west of
Phcnix)
Phcnix Avp.
60
61-64
72-75
75-78
72-75
79-82
63
74
77
74
81
58-61
69-72
72-75
69-72
76-79
61
72
75
72
79
                                   a .    X"i sumps 10% of ADT at pt'sk hour and 51 trucks.
                                   b.
                                        Rfduction of peak hour to 5°s and trucks to 2j% would reduce noise r
                                        levels about 6 dBA

                                        T'i'st fiqure is noise Ir-vcl for the host sections, 2nd figure is for worst
                                        •.' • i ions .
                                   1     45 dB interior of building plus 15 dB shielding ctf oper window val,l.


                                   Source:  CE Maguire, Inc.
160

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6.323  Air Quality

      Urbanization of western Cranston, in accord with any of the
      alternatives described,  assuming no expecially fuel-intensive
      industries in the industrial zones, is not expected to exceed
      either the ambient or the non-degradation air quality standards
      set by EPA, based on emission  rates for various fuels and
      atmospheric pollutant dispersion models specified by EPA.

      In the areas of intensive development there will be some
      small degradation of air quality, but this will be well within
      allowable limits for areas not specially protected by law
       (Class I areas, i.e. national park, etc.).  Outside these
      development areas themselves,  e.g. in the already urbanized
      areas of eastern Cranston and in Providence, the proposed
      development of western  Cranston  will  have a negligable ef-
      fect, i.e.  equal to, or less than, one microgram of particulates
      or sulfur dioxide per cubic meter of air at ground level.
                                                                  Ifel

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6.324 Municipal Costs £ Revenues

      Additional urban growth, under any of the alternatives,
      will lead to both additional municipal costs and revenues.
      The costs will include not only the annual costs of con-
      structing the sewers, and their operations and maintenance,
      but will also include the costs of schools, street improve-
      ment, police and fire  protection, social services, etc.  The
      revenues will  include not only the benefit charges and user
      fees assessed on the land to be sewered but also the real
      estate taxes on the value of the developed land, industrial
      and commercial, as well as residential.

      The larger part  of the costs will  be for operation of schools,
      police and fire protection, etc.,  costs not associated with
      the sewer program, while the larger part of the revenues
      will be from real estate taxes.

      On the cost side, almost all the increments to the municipal
      budget will be more-or-less proportional to the number of
      additional people served and, to a lesser degree, to the miles
      of roadway added to the community. The area of land de-
      veloped is unlikely to effect costs significantly.  On the
      revenue side, taxes collectible will be  proportional  to the
      value of the developed real estate, not  to the number of
      people served.  Hence to get the greatest revenue at the
      least cost, ignoring the social values and objectives, one
      would strive to create the greatest real estate value at the
      least population. Classical city planning strategies to this
      end include industrial/commercial land use wherever pos-
      sible and large lot residential for the balance. The industrial/
      commercial areas in New England are usually sewered while
      the large lot residential  areas may or may not be.

      In the case of evaluating the impact of the alternatives for de-
      velopment of western  Cranston on municipal costs and revenues,
      a number of conditions make quantitative analysis of  these
      western Cranstom  impacts,  very difficult, including that fore-
      casting the future at the level  of detail  required for firm answers
      is not really possible, that the social forces creating a market
      for large - scale population change in western Cranston will
      simultaneously create a similar one for eastern Cranston, and that
      the costs of sewering  are not necessarily related to  population
      densities.

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The only reasonably certain difference among the impacts of
the various alternatives is that all the alternatives that include
extending  sewers to the industrial areas off Plainfield Pike
and Phenix Avenue will yield significant gains to the tax base,
ultimately  over $100,000,000 in Industry alone, while without
the sewers very little new industrial  real estate value is likely
to be created.  Chapter VIII explores this subject quantitatively
in a city-wide context, while the sections below describe some
of the variables that must be considered  in any such quantitative
estimation,

6.3241 Future Projections

      Forecasting the future, particularly with any detail,
      is a manifest impossibility.  Beyond the likelihood
      that the youth of today will  grow older, assumptions
      that they will marry and reproduce at any particular
      rate  are no more than guesses.   Political, military,
      economic and social forces of varying strength and
      duration could delay, retard,or modify  natural
      tendencies so that effects that should occur over
      decades might occur in a few years, with the  effects
      of the bunching having more impact than the effects
      of the total pattern of growth.

      In recent years,  in the face of the rising maturity of
      the post-war baby boom described  in Chapter II, in
      the face of rapid  increase of the population between
      20 and 30 years of age, the marriage rate, the rate of
      homebuilding,and the rate of formation of new jobs
      have all declined precipitously, all without forewarn-
      ing of the agencies whose functions include such fore-
      casting.  For the future will these  rates rebound to
      the forecasted trends, will they continue to lag, will
      the deficits  of the past few years be made up over a
      long  period of time or will they be made up in a
      short and furious jobs/marriage/housing boom in one
      or two years?

      In terms of impact, this is not an academic concern.  If
      the current jobs/marriage/housing recession continues
      yet a few more years and then is corrected in  a short
      time period, the impact on municipal services and
      costs could be severe, requiring design and staffing to
      a peak of demand with consequent waste after the peak
      subsides.

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                              6. 3242 Concurrent Population Changes
                                    In gauging the impact of future growth in western
                                    Cranston, it is important to bear in mind that sub-
                                    stantial changes in population size and composition
                                    are likely in eastern  Cranston over the next two de-
                                    cades whatever happens in western Cranston.  The
                                    modal age in almost all of Cranston's census tracts'
                                    population is about 55 years and the average number
                                    of people per dwelling unit,  in 1970,  was 2.7 or less,
                                    for 10 out of 16 census tracts.

                                    Note that these characteristics are not inconsistent
                                    with other areas that  experienced large growth in
                                    the 1950's, that do not contain educational or military
                                    institutions, and that have not  grown very rapidly in
                                    the recent past.  Note, also that as the modal group
                                    in these housing units ages, as their children mature
                                    and leave home, as the current inhabitants move to
                                    apartments and institutions, or simply  pass away,  they
                                    will tend to be replaced by young families who will be
           ,i  •• i TT; ^B^ ^p	r
  WS^T^S^^^Y-" fe^.A  E
        r^H^^^-rf^ c
                     i
                     LJL
                           • increase
                           ©decrease
                           # insufficient data
                                   5000 housing units

                                   2500
                                   1000
§ increase
decrease
   r	25,000 people
                                  -ll ^E£>bJTH irt
IC.4

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...^	u.^.7^r   #
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                               leaving their current apartments in search of more
                               spacious quarters. This population replacement, without new
                               construction and without adding substantial, new tax base,
                               could increase Cranston's total population by about  15%
                               and it could increase the school population by several
                               times that increase. This particular population change
                               would have a  more serious impact on the city's financial
                               condition than any change that might result from the pro-
                               posed project in western Cranston, in that it will  repre-
                               sent increased costs without increased tax base.

                               Figures VI-21 and VI-22 show the relationship between
                               growth of population and of housing units for the com-
                               munities of the metropolitan area both in absolute terms
                               and as percentage change.  Note  that none of these
                               characteristics is rigidly tied  to any of the others, that
                               Cranston did add more dwelling units between 1960
                               and 1970 than any other community  in the area except
                               Warwick but that its rate of population growth was
                               among the lowest.

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                                6.3243 Patterns of Development and Cost of Sewering

                                      Patterns of development, i.e. zoning densities, front-
                                      age and setback requirements, subdivision regulations,
                                      clustering etc.  effect both the likely value of de-
                                      velopment and its cost.  In general low density require-
                                      ments tend to attract development of high value per lot
                                      while large frontage and inflexible subdivision regula-
                                      tions, especially jn a sewered area, tend to generate
                                      high costs per unit.  It is possible to mix these in a
                                      variety of ways and by selecting the proper mix to
                                      generate  relatively high values without expecially
                                      high development costs.

                                      The key point to note is that development costs are
                                      closely tied to frontage requirements  rather then to
                                      density, since most of the cost of a finished subdivi-
                                      sion lot is the cost of street and utilities and not of
                                      raw land.  To maximize value while minimizing develop-
                                      ment costs, a combination of low density and limited
                                      frontage requirements would be optimum.  This could
                                      take the form of traditional zoning with large area lots
                                      and smallish frontage, of traditional zoning but with
                                      minimum  lot width measured across the building site
                                      rather than at the lot line or minimum setback line,
                                      or it could take the form of cluster type zoning or
                                      planned unit development.
IGG

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6.4   MITIGATION OF  IMPACTS

      The most serious adverse environmental impacts of urbanizing
      western Cranston, whether  as  the proposed action, i.e.  limited
      sewering and  zoning  change, or any of the alternatives, includ-
      ing no-action, will  be:

      1.     Increased  traffic including congestion,  increased accidents
            and increased noise,  and

      2.     Increased  flood flows on the  streams.

      Lesser impacts will include reduction  of air quality and changes in
      appearance and  wildlife  habitat.

      Impacts that cannot be clearly  identified because they require fore-
      casts  of complete social  and economic  conditions include changes in
      demand for municipal services and changes in the tax base.

      Some  of these anticipated impacts can  be totally avoided by ade-
      quate mitigating actions  while  others can only be softened;  some
      can be accomplished  by  changes in regulations (zoning,  building
      codes, subdivision  codes)  or law while others require major public
      works improvements;  some  are merely modifications of current land
      development practices while others would  require  fundamental change
      in  the mix  of  public and private responsibility in  land development
      practice.  The sections  below  describe these mitigating strategies
      in  order of the  severity  of  the impact to be mitigated and/or their
      difficulty of accomplishment.
                                                                              JG7

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                 6.41  TRAFFIC EFFECTS

                       The control of congestion, accidents, and noise in areas of
                       urban growth in most places  in modern times has been  a
                       catastrophic failure/generally unobserved  because it ordinarily
                       takes place over so  long a time span.   (The difference  be-
                       tween ordinary  urban growth and what is  likely in western
                       Cranston is primarily one of  likely  speed  of development.)
                       Usually urbanization  takes place slowly with rural roads
                       gradually becoming  residential, then with subdivisions filling
                       in on the farmland  and forests behind  the pioneer houses.  As
                       traffic congestion and  noise grow,  the streets are widened
                       and the pioneer houses are converted to businesses adding
                       further to the traffic.  Gradually the businesses in the
                       houses are  replaced, here and there,  with  commercial buildings,
                       and the end result is a commercial strip through a residential
                       neighborhood  with the noise,  glare,  fumes, vibration,  and
                       views of the business trip impinging upon  the adjoining houses,
                       sowing  the  seeds of later urban decay.

                       Some people lay the blame for the end result on planning
                       boards and city councils  for "caving in" to  the requests to re-
                       zone from residential to business, but usually by  the time
                       this happens, the lands along the onetime rural  roads  are
                       already too noisy for residential use.

                       Some people lay the blame on automobiles and propose that new
                       development be designed along public transit lines despite:

                       1.    that, even in places like eastern Cranston,  built  up
                             when public transit was a common mode,  only 10% of the
                             population now use transit to commute, and even fewer
                             use it for other purposes,

                       2.    that the density of new development isgenerally less than
                             the density of older development, and that higher rather than
                             lower densities would be required to make transit feasible,

                       3.    that  in the pioneer stages of development,  when  pat-
                             terns of  use are being  determined and habits of the
                             residents are  being shaped,  the densities are very
                             much lower, and

                       4.    that  transit agencies are usually interested  in eliminating
                             service rather  than adding it.
168

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Some people blame the builders and developers, but they are
usually totally  locked  into their patterns of behaviour by zon-
ing and subdivision codes and by  the need to stage their de-
velopments  to minimize the capital  investment requirements.

The builders,  in their turn will  cite the development codes,
but the codes were justifiably established to prevent the
worst kinds of development abuses by the worst kinds of builders.

And finally, some people will place the blame on growth  it-
self, without recognizing that the young people seeking  homes
were born a generation before, that they were  not  party  to the
decision to  be  born,  and that they only want a decent environment
for their own families.
Where then  does the problem lie and what can be done about it?
                                                                  169

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                       Most likely the answer is in the classical city design
                       literature,  in the works of Ebenezer Howard,  Frank Lloyd
                       Wright, LeCorbusier, Clarence Stein, etc.,  i.e. that main
                       streets are inherently  unfit  for residential use, indeed  that
                       they ought not  be used other than  for transportation, for open
                       space, and, in special areas  with special safeguards, for
                       industry and commerce.

                       Figure VI-23, ,a master plan for Wythenshawe,  City of
                       Manchester, (prepared  about 1931)  shows what a new  residential
                       area adjoining an existing city should look like.  Note
                       first that Wythenshawe  in many  ways was just like western
                       Cranston,  it adjoined a large metropolitan center, was incor-
                       porated within the city  limits, and had been  precluded  from
                       earlier growth by a  physiographic  boundary (in this case  the
                       River Merse);  second,  that  the  need for  additional housing in
                       the Manchester area  had led the city to bridge across  the
                       river;  and finally, that the  two main new roadways were  proposed
                       to  be buffered by a  park strip, 200' wide, on both sides,  all
                       along their length.

                       In  a similar response to the  same kind of problem,  the City
                       of  Cranston's 1959 Development  Plan  for Western Cranston
                       called  for  extension  of Dean  Parkway to Hope Road  atBriggs
                       Farm  along a line just north of the Gammino quarry,  and
                       showed the proposed road with  a line about 300 feet wide.
170

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WyjHENSHAWE
                            \x—

    vi-zs
      WITH ACKNOWLEDGMENTS TO BARRY PARKKE, F.R.I.B.A., I'.P.T.P.l.
                                                    171

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                       Analysis of the  traffic volumes,  safety problems,  and noise
                       impacts of urbanization of western Cranston,  using more
                       recently developed techniques and contemporary noise control
                       standards suggests that the same approaches are still  fundamentally
                       valid but that, at the least,  the following standards be applied:

                       1.    Noise buffering of 15dB consisting of park  lands 225'
                             wide where the roadway is depressed 15' or more below the
                             height of  land  between the road and  residential areas,
                             250' wide where depressed 10', 300'  wide where depressed
                             5', 500' wide where flush with residential areas and 400'
                             wide where elevated above residential areas.

                       2.    Control of access to eliminate  all driveways and un-
                             controlled  street  intersections.

                       3.    Consistent curvature  limitations, both minimum and maximum,
                             to both limit speeds and avoid  blind spots.   >Jote, this
                             recommendation is at some variance with  current road de-
                             sign practice which calls for minimum radius  standards
                             only. The minimum radius ensures adequate sight distance
                             at the design speed of the road.  Unfortunately in areas
                             where the roadway has less curvature than required many
                             drivers will accelerate beyond the posted speeds to that
                             speed physically comfortable, a speed not safe in the areas
                             of minimum curature.   Establishment of a maximum curvature
                             and maximum tangent length will tend to  keep all traffic  bunched
                             within a closer range of speeds, and hence will tend to reduce
                             accidents.
                             (This principal  was applied to the design  of the Westchester
                             County parkway system in the  1930's1)

                       4.    Limited maximum grades to eliminate segregation  of trucks
                             and autos  by speed on upgrades and to limit truck noise
                             generation.

                       5.    Travel  way widths and intersection approaches consistent
                             with the anticipated traffic volumes.

                       To illustrate  the safety improvements that might be achieved,
                       note the  relationships between accident rates and traffic
                       volumes for various  kinds of roads  shown in  Figure VI -24.
                                Personal communication. Prof. Norman T. Newton, Emeritus
                                Harvard Graduate School of Design.
172

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                                                     til «! MOICO 
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Figure VI-25    shows the future  accident  rates likely  on the
major streets  of western  Cranston both with and without this
proposed  mitigation program.   Note,  that at the levels  of
traffic expected  as a result of the  proposed actions, miti-
gation programs can be expected to eliminate 85% of all  auto-
mobile accidents on the major road network in  the  mile  just
west of the end of Rt. 37. Put another way, in  the design  life
of the treatment plant, 20 years, it is likely that there will
be about  1500 accidents including 2 or 3 deaths and  60 personal
injuries as a  result of the proposed action  in the critical
mile described above without the suggested mitigation,  while
with the proposed mitigation only  about 200 accidents would be
likely with no deaths and only about 10 injuries.

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H CONGESTION
                                                              SYSTEM
                                                  2 LANEV NO MEDIAN, NO ACCESS CONTROL


                                                   LANES, NO MEDIAN, NO ACCESS CONTROL
                                                   LANES MEDIAN, FULL ACCESS CONTROL
                        3  0   T   Jo    1') I iO 50  60  HO TOO  I    MO IJlOOJOO]510 6(10  Wl 1,10(1
 AVERAGE DAILY TRAFFIC (HUNDREDS)
                                                                                    OF
                                                                             £XP€Cr£D TRAFFIC LOADS
                                                                                        C^GNSTON
15 ACCIDENT HATES IIKEIY TO «
   U1ITH  4  IDlTttOUT  'pqO'POSED
                                                         43 * RESULT OP
                                                                                                  175
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                 P7?QM NATIONAL COOl5£t? ATIVB
                                                                                               41

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                        Figure VI-26   shows in a conceptual way,  how these might be
                        applied to the impacts  of the No-Action Alternative and of the
                        Proposed Action.   Note that the lands along the main roads are
                        either park or commercial  (with controlled access).

                        Note  also, and note it particularly- that this is a concept only,  not
                        a  proposal or a recommendation for immediate action but for thorough
                        study of the concept and all  its safety and environmental ramifi-
                        cations.

                        6.411  The Institutional Problem

                              Implementation of the  above suggested mitigating  action
                              appears to be  constrained both by  lack  of any govern-
                              mental agency clearly responsible for such actions  and by
                              lack of general awareness of the problem by the  general
                              public.  Generally the federal and  state transportation
                              agencies focus their activities on intercommunity trans-
                              portation and city planning  agencies focus on intra-
                              development transportation (subdivision plans) with no
                              agency focusing  specifically, with meaningful resources,
                              on   intracommunity  or interdevelopment transportation.

                              Looking to the past,  some tentative  efforts were made by
                              the state  in this  area,  notable locally in the Dean
                              Parkway in Cranston, but in recent years state attention
                              in  this  area  has  tended to apply  interstate solutions to
                              local  problems, e.g. extension of Rt. 37 into  western
                              Cranston.  The end result of present policy often con-
                              sists of winding, twentytwo  foot wide streets serving as
                              the link between thirty foot  subdivision  streets and
                              seventy mile per hour expressways.

                              The cause of this gap. does not appear to be in the agencies,
                              state  or local,  but rather  in  public  attitudes with the
                              business community limiting its demand for  transportation,
                              understandably,to intercommunity needs and to access to
                              industrial and  commercial  zones;  with most inhabitants  of
                              individual  residential  areas  primarily interested,  again
                              understandably,  in preserving their own microcosms; and
                              with significant segments of the more outspoken intel-
                              lectual  leadership of the society  tending to condemn the
                              system  rather  than attempting to find workable solutions.
!7G»

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                          2.    That on-site control  of runoff from land development and/
                               or building projects is consistent both with the state
                               wetland  act which treats the dumping of increased  runoff
                               into streams and wetlands  in the identical manner with
                               which it treats dumping of fill  into such areas and also
                               with  the power  of municipalities  to regulate drainage de-
                               sign  as part of  subdivision control and  building codes.

                          3.    That the methods  of runoff calculation and control de-
                               scribed in the newly published Soil Conservation Service's
                               Urban Hydrology  For Small Watersheds  (technical release
                               No.  55),Chapters  2 and 7,allow simple, effective, and
                               impartial analysis and design without reliance on "engineering
                               judgement",  a pitfall of earlier attempts at such regulation.

                         4.    That onsite runoff control appears feasible with use of
                               as little as 10% and  not more than 25% of any site or
                               tract of land  for runoff storage.

                         5.    That on-site runoff control I  transfers the costs to the
                               developers  at the time of development and hence neither
                               places any  burden  on the taxpayers nor does it require
                               any investment in  expensive physical improvements prior
                               to actual  use.

                         6.    That on-site runoff controll  will require the City to
                               establish  a  proceedures and standards manual,  based on
                               the SCS method, to  insure consistent application to
                               all subdivision, all buildings,and all other land devel-
                               opments as part of its subdivision and building codes.

                         7.    That while runoff control will be generally effective, it
                               is not the whole answer, that some  areas have already been
                               developed, that there will be special cases for which it is
                               not applicable,and that there are some special needs unre-
                               lated to the general problem, i.e. protection of the antique
                               industrial area in the Furnace Hill Brook ravine and com-
                               pensatory flood storage for loss of floodplain elsewhere
                               in Cranston along the Pawtuxet River System.

                         8.    That two of the old  mill pond sites south of Phenix Avenue
                               on Furnace Hill Brook could  be used very effectively and
                               very efficiently as a multiple-use flood control, recreation,
                               habitat protection,  archeological site protection, noise buf-
                               fer, scenic area,  etc. project, IF PROPERLY DESIGNED.  These
180

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      two sites alone would not nearly resolve the increased
      runoff problem without an on-site control program, but they
      could quite adequately supplement such a program.

In consequence of the above, both an on-site runoff control program
and exploration of restoration of the two mill ponds as appropriate
mitigating actions appear desirable .although both these actions
in turn will have adverse impacts.

In the on-site runoff control program, it should be noted that
the mitigating action will impose a new layer of constraints on
land developers and, under the existing zoning format in Cranston,
reduce the number of units allowable on any tract of land in con-
travention of the number clearly authorized inthe  City's zoning
ordinance.  To offset these adverse effects, the City could alter
its zoning approach, reducing its dimensional requirements,
i.e. setbacks, lot size, dwelling units per building, etc. and
substituting density and  spatial distribution (in terms of ratio
of setback distance to number of dwelling units per development
cluster, etc.) Note that this is not a recommendation for "cluster"
zoning or "planned unit development" as they are ordinarily
conceived, but rather a recommendation for  zoning based on
environmental performance, i.e. amount of traffic likely to be
generated, noise (generated by screaming kids) and kids likely
to impinge upon  neighbors,  protection and enhancement of
the microclimate, etc. Further, it should be noted that  such
an approach oriented toward environmental performance criteria,
IF PROPERLY DESIGNED, could simultaneous protect the economic
interests of developers and the quality of life of the community
(both the developers, their  neighbors,and the city as a whole), that
it would tend not only to  control runoff but it would enhance
the community's appearance, microclimate,  habitat value for song-
birds and small  mammals,  recreational  opportunities,  etc.

Similarly, in the restoration of the two mill ponds, extreme
care and careful coordination  will be required  to protect the
archeological  and esthetic values of  the sites, conceivably
requiring structural forms not ordinarily used in small  flood
control structures, perhaps restoration of the  old stonework
or perhaps  thin  reinforced concrete  walls carefully set just
upstream of the remnants of the old  dams. In  any case this
work  ought to be done under  the  direct control  of the Rhode
Island Historical  Preservation  Commission.
                                                                  181

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                  8.43  STREAMFLOW EFFECTS - RUNOFF QUALITY

                        Control of the quality of urban stormwater runoff, like control of its quar
                        has only recently been recognized as a necessary environmental pro-
                        tection objective.

                        Methods for such quality control include frequent sweeping of streets
                        to pick up pollutants before they enter the stream system,  trapping
                        the settlable materials in catch basin sumps as the runoff enters the
                        drainage system, collection and conventional sewage treatment plant
                        type treatment along with sanitary sewage (or  in a parallel system)
                        as  the runoff leaves the drainage system, settlement of the runoff
                        waters in sedimentation basins between the storms drain outfalls
                        and the natural streams, and filtration of the street runoff  waters
                        by overland flows through grassy or weedy open swales between
                        the pipe outfalls and the natural streams.

                        Selection among these alternatives will depend in any particular case
                        on the interplay of costs among operations, initial construction, and
                        land.  In this case, given the recommendation made previously for
                        mitigating the quantitative changes in streamflow  (retarding runoff
                        waters on-site in all urbanizing areas) and given  the almost complete
                        likelihood that the methods that will  be used to retard runoff (broad
                        and shallow water storage reservoirs and substitution of open drain-
                        age swales for drainage pipelines) will almost certainly include sedi-
                        mentation basins and overland flow filters, the choice of runoff quality
                        control methods appears to be quite  simple.

                        Implementation of this particular environmental quality protection
                        objective, in this case, will required the City to include in its run-
                        off control program described in Section 6.42 provisions:

                        1.     for construction erosion protection:  - construction of peak/
                               flow/sedimentation  basins and drainage ways to them as a
                               first stage of all projects that  require extensive grading,  and

                        2.     for post construction, street drainage pollution control: -
                               design of drainage  systems to provide the maximum  feasible
                               surface swale drainage (rather than piping) and sedimentation
                               basins between all street drain outfalls and all  wetlands and
                               streams.

                        The effects of these actions will be similar to those described in
                        Section 6.42; they will add no substantial further  burdens to developers;
                        they will required no further secondary mitigating actions, and final-
                        ly they will, similarly, not burden the City's taxpayers.
182

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6.14  APPEARANCE 6 WILDLIFE HABITAT

      The rural beauty and the wildlife habitat value of western
      Cranston in large measure stem from the variety of sizes of
      spaces and blocks of woodlands characteristic of most New
      England rural areas.  With urbanization, the larger spaces and
      forests are broken up into a uniform pattern of small lots and
      buildings which when applied  over  miles of landscape without
      adquate parks, open spaces, topographic features,  etc. can be-
      come visually and ecologically  dull, sterile,and  monotonous.

      Classical remedies to this  esthetic monotony and ecological
      sterility of urbanization  have included  the parks, parkways,
      and wilderness reservations  proposed by Frederick Law Olmsted
      and Charles Elliott,  (reflected  in Roger Williams Park in
      Providence and the extensive metropolitan  park system in
      nearby Boston) and  the  agriculture  belts of Sir Ebenezer
      Howard (reflected in the design of Greenbelt, Maiyland).  More
      recent attempts to cope with  this problem have included  "cluster
      zoning" and "planned unit development."

      All  these remedies have  had their difficulties.  The parks,
      reservations, and agricultural  zones all pose major economic
      problems, basically  that their  costs must be borne years,
      decades,  even generations,  before  their benefits are experienced,
      while the cluster  zoning  and  planned unit development approaches
      have the drawbacks   of newness,  lack  of widespread  public con-
      fidence and acceptence, and,  to some degree,  lack of critical
      testing of environmental  impacts  on the general physical
      environment, on  the community as  whole and on the adjoining
      residents and property holders.

      It is believed that the remedies suggested hereinbefore,  under
      traffic  impact control and streamflow impact control are
      consistent with  the general line of these traditions and that
      these same remedies  will probably do much to mitigate both
      the  esthetic and wildlife  habitat impacts of the coming urbanization.
      We have noted in those  remedies,  that  they must be properly
      designed to have the desired effects.   It  is not a matter of
      "good" land uses vs. "bad", (houses vs. sewage treatment
      plants), of "good " public facilities and  services vs.  "bad"
      (parks vs roads),but rather  a  recognition  that our culture is
      extremely complex requiring  many kinds of land use and many
      kinds of services,and that all of these have impacts that
      must be weighed and  properly handled, essentially that planning,
      in the words of the National Environmental Policy Act, "...
                                                                        183

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                       utilize a systematic, interdisciplinary approach which will
                       insure the integrated use of the natural and social sciences and
                       the environmental design arts..."  Note that this is not a call
                       for adversary relationship among the disciplines, it is not a
                       call for a sequential approach, it does not set one discipline above
                       any others,  but that it does call for cooperation with, and sensi-
                       tivity to, the needs and viewpoints of others in developing
                       programs for the future. It appears that in developing
                       western Cranston, with better management of the environment
                       than has been done heretofore, Cranston will be pioneering
                       new ground and that it will need to develop new forms, new
                       procedures  and new types of regulation.  Whether the result
                       will obviate all the environmental problems is not known, but
                       it appears that the National Environment Policy Act does point
                       the way.
184

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            VII       SIT6    SPECIFIC   WWL&M3   OF
7.0   INTRODUCTION

      The extension of public sewers into western Cranston, in the manner im-
      plicit in the proposed project,  could have sentus adverse impact on areas
      of significant cultural, historical, geological, esthetic and ecological value.

      Western Cranston is rich in such resources, particularly in the area
      through which the proposed sewer truck lines must pass and upon which
      the secondary effects of urbanization,  i.e. increased flooding,  traffic con-
      gestion,  noise, etc. will probably be focused.

      This coinciding of areas of probable impact and resource location is a
      consequence of the unusual physiographic constraints of western Cranston.
      This chapter describes:

      1)     constraints that lead to the problem.

      2)     the resources that appear to be threatened,

      3)     whether there are prudent and feasible alternatives that preclude
            any potential adverse impacts, and

      4)     whether there are prudent and feasible actions that can be taken
            to mitigate any potential adverse impacts.

      Of special importance are:

      1)     the requirements of the Advisory Council  On Historical Preserva-
            tion,  established in pursuance to Sections 1 (3) and 2(b)  of Execu-
            tive Order 11593, which order insures that no Federal action may
            adversely impact any property eligible for inclusion in the National
            Register of Historic Places if there is any prudent and feasible
            alternative,

      2)     that there is reason to believe that the proposed action would
            impact areas so eligible, and

      3)     that there do appear to be prudent and feasible alternatives which
            would avoid and/or reduce the adverse impacts.
                                                                             185

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           7.1   SETTING
                 Western Cranston contains a graat number of areas with special interest
                 culturally (in an anthropological sense), historically, geologically, estheti-
                 cally and ecologically,  In general, these areas vary in their specialness
                 from being commonplace to being probably unique or nearly unique within
                 the State of Rhode Island and within the United States as a whole, and they
                 also vary in their size, quality of setting, and degree of preservation.
                 from being unremarkable to  being extraordinary.

                 A reconnaissance survey and preliminary literature search by a C.E.
                 Maguire, Inc.  team,including people skilled in urban planning, landscape
                 architecture, civil engineering, geology, geography and photography, sup-
                 plemented by the State of Rhode Island's Archeologist, Mr. John Senulis,
                 and the Curator of the Slater Museum and Supervising Historian
                 for the Historic American Engineering Record, Mr. Gary B. Kulik,  (all start-
                  ing  with data provided by State and City historical preservation agencies and
                  by the Audubon Society)  identified an area of western Cranston, primarily
                 along Furnace Hill Brook as:

                  1)     having special values in all five senses, i.e. culturally,  historically,
                        geologically, esthetically, and ecologically,

                  2)     having settings that are sizeable, well preserved,and appropriate
                        to the original cultural or historical land use,

                  3)     probably being eligible for inclusion in  the National Register of
                        Historic Places.

                  4)     being threatened by the proposed action, both by the action directly
                        and by the effects of urbanization.

                  The key point to bear in mind is that all of these come together  in one fairly
                  small area,  the area through or near which not only the sewer main but also
                 1 the impacts  of urbanization, i.e. traffic and stcrmwater runoff, must pass.
                  The sections below describe this special area along the Furnace Hill Brook
                  in some detail, including the physiographic conditions which in great measure
                  lead to the locational conflicts, a description of the site including its history,
                  and a summary of applicable portions of the  historic preservation regulations.

                  Other areas of western Cranston, not described below, were believed not
                  to be both likely to be adversely impacted by the proposed project and
                  either eligible for inclusion  in the National  Register of Historic Places or other-
                  wise of exceptional environmental value.
186

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7.11  PHYSIOGRAPHY

      Physiographically, Cranston is mostly a flat outwash plain in the east
      and a rolling glaciated upland in the west.  Between the two is a granitic
      scarp which forms a distinct north-south topographic division.  At
      about the midpoint in the scarp is a zone, somewhat lower in elevation,
      that is somewhat softer, being composed of sedimentary materials.
      This central soft spot is physiographically both the ultimate source of
      a variety of natural and cultural resources and the cause of a set of
      resource impacts resulting from the proposed sewer extension by re-
      stricting possible sewer and road locations.
      Furnace Hill  Brook,  the largest stream in western Cranston, runs
      through this central  zone in a deep ravine,

      1)     exposing interesting geology and topography,

      2)     creating a special microclimate.

      3)     providing an unusual habitat containing, at one time, anad-
             romous fish, and

      4}     acting as the stage of a long history of human use.

      The proposed extension of sanitary sewers into western Cranston
      would not only place the main interceptor pipeline directly in the
      ravine, but it would also  induce lateral sanitary sewers,  storm drains
      and additional roadway improvements, necessary to accommodate
      the resultant urbanization,  in the vicinity.
       Figure VI-2, in the proceeding chapter, shows the generalized
       physiography of Cranston;  Figure VI-3 shows the topography of
       western Cranston;  Figure VI-4, the watershed structure, and
       Figure VI-6,the road system.  Note,on Figure VI-4,that Furnace
       Hill Brook is the only major stream that crosses from western Cranston
       to eastern Cranston across the central scarp, and,on Figure VI-6 •
       that there are only four streets that cross the scarp and that two of
       these lie close to Furnace Hill Brook.
                                                                         187

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Figure VII-1, Physiography of Western Cranston, shows the bedrock
geology of western Cranston superimposed on its topography.  The
plutonic materials are the basis of the western Cranston upland, being
composed of hard,  erosion resistant materials,  while the softer sedimentary
rocks of the Rhode  Island Formation underlie the  lowlands.  The Black-
stone Formation which occurs in a few small  spots along their boundary
zone contains a considerable variety of metamorphic materials including
some with little resistance to erosion and/or chemical weathering
such as steatite and marble so that  this formation tends to underly
tho major streams and valleys leading out of the uplands,  and as
result, the major,  older roadways.

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                       In the vicinity of the Furnace Hill Brook, the strike of the bedrock
                      strata is generally east-west and their dip is quite steep so that,
                      where the river runs east-west,  steep ravines and gorges have
                      formed, notably south of PhenixAvenue between Furnace Hill Street
                      and Olney Arnold Road and north of Hope Street between Phenix
                      Avenue and Pippin Orchard Road. Where the stream runs across
                      the strata, small falls and rapids have developed below the more
                      sistant materials, with a number of these falls having been used as
                      power sources in times past.  Figure VII-2, shows the topography of
                      the vicinity of Furnace Hill Brook in an enlargement of the United
                      States Geological Survey topography maps including the river and
                      ravines.

                      And finally, it ought to be noted  of the geology that the Blackstone
                      Formation includes significant deposits of hematite and closely re-
                       lated minerals, which have been of economic value both, with cer-
                      tainty, as a major bedrock mine and, probably, as an ultimate source
                      of iron for bog iron deposits in the Meshanticut Valley just to the.east.
190

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                7.12  ESTHETICS AND HABITAT

                      The distinctive and unusual topography of the Furnace Hill Brook
                      ravine and gorge stand in quite striking contrast visually and ecological-
                      ly from the surrounding areas. The general comment of members of
                      C.E. Maguire's reconnaissance team and of various state and federal
                      officials who surveyed the area was that they found it hard to believe
                      that areas so scenic could exist, first, in Rhode Island, and second,
                      so close to the city.

                      Ecologically, the contrast is most evident in the vegetation which
                      differs from that of the surrounding area. On the north facing slopes,
                      i.e. the microclimatically colder ones, the vegetation includes Moun-
                      tain Laurel (Kalmia latifolia) ,  Canada Hemlock (Tsuga canadensis),
                      American Beech (Fagus grandifolia) and Yellow Birch (Betula lutea)
Figure VII -3a
I92
                       Furnace -Mill ^ropK just above Furnace fjjll Street, note
                       ruins  in ui>|>ef right  half of picture  with mortared,
                       uncoursed  f ield stone  walls on tmmortared ,uncour5ed,
                       squared fleldstone  foundations.

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                                                       Figure VII- 3 b,  Quins of
                                                       uncoursed  rubble dam
                                                       -pacing judf u-pe+reom
                                                       from  null ruind.
     r ^/  ^4,:^
es«¥»*SE£
                all which do not normally jf.cn in the surrounding region's oak-
                hickory forest but are typical of the forests of centra) New England .
                Undoubtedly this  change in forett composition is both indicative cf
                otb->r microclimatic effects such as lowered water temperatures in
                th.: brook and  also contributive to the variety of birds sad small
                animals that are likely to inhabit the area.  The water—temperate
                lowering-effects of the gorge and  ravin?, combined with the rapid
                aeration of the falls and rapids, do create a substantially different
                (even though small scale) stream  habitat from those typical of the
                rather flat surrounding region, and the greater vegetation range
                of the ravine is likely, to some degree, to increase, diversify, and
                extend the season of, food and shelter availability of that region.
                                                                                193

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                   7.13  ARCHEOLOCICAL VALUE (ABORIGINAL)
                                                                                  ' *f '
                         The valley of the Furnace Hill Brook is believed to have been of
                         special value to the pre-colonial inhabitants of Rhode Island, in
                         part because of its  value as an anadromous fishery and in part
                         because of part of its mineral composition, most specifically, its
                         steatite.
                                                                                 ••i '.'•
                         As a fishery, the ravine does offer an excellent location for netting,
                         smoking,and drying the spring run of anadromous fish (fish that
                         breed in fresh water and mature at sea), presumably shad, and for
                         establishing a corn crop in the surrounding fields using fish wastes
                         as fertilizer while the fish were smoking and drying.

                         The steatite, a not  too common, soft, easily carved mineral, quarried
                         not far from the ravine, would have been used by the Indians for
                         mortars in which to grind corn, and as such would have been an es-
                         sential raw material  for the  Indian economy.
                         Placing the two resources,food and minerals, together  in close
                         proximity would have created a component of human  habitat of
                         very special value  to a food-gathering society of stone-working
                         technology, and the vicinity  of the Furnace Hill Brook  probably was
                         a major seasonal encampment of such a people for countless centuries.
                         As such it would have been a center,  not only of the  aboriginies'
                         economic activities  but also of their social, educational, artistic, poli-
                         tical and religious activities, and  hence the site probably has quite
                         special archeological value.

                         The preliminary reconnaissance of the site by the  state archeologist,
                         undertaken as part of this statement, did uncover, along the south-
                         ern lip of the ravine, stone chips so formed that they were, very
                         probably, deliberately fashioned as tools, presumeably for splitting
                         and cleaning fish, and thereconnaissancedid confirm the existence
                         and location of the steatite quarry.

                         Unfortunately, from an archeological point of view, the most likely
                         sites of the camps and cornfields in the uplands immediately adjoining
                         the ravine have since been plowed and have even, in places, had their
                         topsoil stripped, while the most likely sites of the fish traps, the rapids
194

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Figure VII-3c -  Ouins of coursed, rtfughJif  squared and rqn^ed stone
                  dam  oHth concrete fo^course further upstream just
                         meander in  ravine.
                 in the bottom of the ravine became the site of a series of mills and dams
                 in colonial days.  Both of these actions probably have spoiled those
                 specifically effected areas in a aboriginal archeological sense (but not
                 its historical archeology) .

                 Fortunately, from the same point of view, there are still substantial
                 areas in  (what at one time were)  the mill ponds that would have been
                 well protected  from "development" by their impounded waters and in
                 slopes that were not plowed, and so do constitute a possibly significant
                 cultural resource  and hence are probably eligible for protection from
                 federal action as an historic site.

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7.14  HISTORICAL VALUE

      The valley of the Furnace Hill Brook in western Cranston contains
      the remains of a chain of industrial activities that began in the middle
      of the 17th century, reached its heyday in the late 18th century, faded
      through the 19th century, and has remained substantially unchanged
      through the 20th century, so far.

      The principal features of those remains Include:

      1)    that the remains have been relatively undisturbed for a long
            period of time (about a century).

      2)    that the remains are relatively well isolated from adjoining
            land, and adjoining human activities, existing and probable
            in the future, by the rough topography of the area.

      3)    that the surrounding lands have changed little in the last
            century  (although this is likely  to change rapidly In the
            near future).

      4)    that the remains appear to show the historical evolution of
            industry  in New England up to the mid 19th century, all in
            one nearly contiguous setting.

       5)     that at least part of the remains  can be related to historical-
             ly important persons, technological developments,and political
             events.

       6)   that the remains might, through archeological  exploration and
            historical research, contribute to resolving a major historical
             debate, i.e. the cause of the American Revolution, economic
             vs. ideologic, through its relationship with persons intimately
             involved historically in both the economic and ideologic events
            that led to the revolt.
       Figure VI1-4 shows the principal remains superimposed on an aerial
       photograph of the area.

       The history of the area is synopsized below.

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                      7.141   Seventeenth Century

                            Industry came to the colonies quite early in their development
                            and included milling of grain, sawing of lumber, various
                            steps in the manufacture of textiles, and the smelting and fabri-
                            cation of metals, particularly of iron.  The iron industry dates
                            back  as far as the  1620's in Virginia and the 1640's across Nar-
                            ragansett Bay from Cranston in what, at that time, was the
                            Plymouth Colony.

                            The resources on which the industry was based were wide-
                            spread through southern New England,  i.e.  bog iron ore
                             (a post-glacial sedimentery deposit that occured in most
                            ponds, swamps, and rmarshes of the region as a result of
                            seasonal chemical  reactions within such water bodies that
                            change the soluble iron salts that leach out of the mineral
                            matter of the adjoining uplands to insoluble salts which pre-
                            cipitate out of the water onto the wetland bottoms), charcoal
                             (readily manufactured from the extensive hardwood forests
                            —oak-hickory—of the region), and power for forcing air
                            through the furnaces (also readily developable from the many
                            rapidly falling streams of the region).

                            At Furnace Hill Brook, the brook would have been adequate
                             (by 17th century standards)  for power, charcoal would also
                            have  been easily obtained, and iron should have been even
                            more readily available in the Meshanticut Valley than else-
                            where in the region, given the rich iron deposits of the
                            Furnace Hill Brook Valley upstream.

                             Indeed, comparison  of the Furnace Hill site with other
                            areas of the Narragansett Basin can easily show  that the
                            Furnace Hill site is one of the better small waterpower sites
                             in the region that, simultaneously, is close to extensive wet-
                             lands, i.e.  eastern Cranston, hence a good  17th century site.

                             Inspection of the site does indicate an old dam and mill founda-
                            tion just west of what is now called Furnace Hill Street, and
                            a sluiceway between the two, now filled, is  recalled by several
                            people to have only  recently been filled. Whether these are
                             17th  century is not known but an old photograph of the area
                            from  an unknown source mailed to CE Maguire, Inc. is cap-
                            tioned "Est.  1662."
198

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   M'-.*V..V- ..  •   '
     -•,    v  .-   .
' '^i'.Vtf*' A/,1,  '
    F.st.
          C.ourU'sy  C.IMIOUV  L. Holmes
   Figure  VII- 5    View of  FURNACE  -HILL  ST^tfiT
AN
                                       COPV )
                   Figure VII-5 is a copy of the photograph.  It was taken along
                   the brook, from east of Furnace Hill Street and south of the
                   brook looking westward.  Note:

                   1)    the sparse forest indicating the photograph was taken
                         some time ago.

                   2)    the proximity of the main building to the street, or rather
                         that the street was  part of the industrial complex.
                                                                             199

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                                The photo, shows the ruins somewhat more intact than today
                                but still only a ruins but with a large wood building to the
                                right of the ruins,  now demolished.  The whole complex,
                                connected to the house now standing at the corner of Phenix
                                Avenue, has the appearance, from its simple and direct
                                architectural lines, of a colonial period structure.  It is locally
                                recalled that the wood second story of the building now gone
                                was entered from the uphill grade through a wide doorway.
                                Chimneys, separate from the main structure, were on the
                                lower grade and on the upstream side of the building.  In  the
                                period prior to its removal this building is said to have been
                                used as a foundry with shipping/receiving/storage in the
                                wooden second story, casting and forging at the chimneys
                                and shaping and finishing in  the basement.

                          7.142  Eighteenth Century

                                In the eighteenth centnry, the western Cranston iron industry
                                moved  from being one of many similar local industries of no
                                special note to what may have been a central role in bringing on
                                the American Revolution.  Whether it actually was, is near the
                                focus of a major historical debate on the causes of that revolution
                                and that debate in turn is part of a wider intellectual debate
                                on the  causes of history itself.

                                Ignoring the wider debate and looking to the debate on the
                                causes of the revolution, the issue is well defined in John
                                C. Walke's THE CAUSES OF THE AMERICAN  REVOLUTION
                                 (D.C.  Heath S Co., 1973)  which puts it thus:
         Not so very long ago Americans were taught
         that the American Revolution came about
         solely and simply because all colonists
         hated tyranny and loved freedom; because
         all colonists resented a foreign govern-
         mant's denying their right to share in
         governing themselves; and because all
         colonists, therefore, rising in heroic
         resistance to the government vhich oppressed
         them, determined to  make America an
         independent nation founded on the principles
         of political liberty and equality.  The
         persistence of such  a simple, black-and-white
         picture of the revolutionary struggle is re-
         flected in the widely held belief that the
         chief point at issue between colonies and
         mother country was the. Tightness or wrongness
         of the principle that "taxation without
         representation is tyranny.
 Lstorical research and analyses by
 iholars of the past two generations,
 awever, have made it impossible to
 elieve quite so surely that  the Re-
 olution was no more, and no  less,
 han a conflict produced by verbal
 isagreements between a people united
 .n the cause of freedom and a regime which
 •efused to accept freedom as  the
 lecessary basis of all governments.  The
 reappraisal of the colonial and revolu-
 :ionary era, begun by such scholars as
 Jharles M. Andrews, George Louis Beer,
 Herbert Levi Osgood, and others has
 nade It clear that to see selfless devotion
 of the patriots to political  ideals as the
 sole cause of the Revolution  might well be
 a national tradition, but it  is hardly sound
history.  Significant facts which today
200

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seem obvious - for example,  the extreme
tardiness of the patriot  leaders in
formulating the demand  for  independence, or
the apparent lack of unity  among the colonists
concerning what they wanted, why they wanted
it, and how they proposed to get it - were
long overlooked by the  traditional expla-
nations of why the revolutionists fought.
Beginning in the 1890's, historians directed
their  attention more closely to the revolu-
tionary use of the political ideals of
freedom and equality, independence and self-
government; they carefully considered the
influence of economic interests, the accidental
conjunctures of men and events, and the per-
sonal  ambitions and prejudices of revolu-
tionary leaders or members of Parliament;
they looked more closely  into the everyday
attitudes and  activities  of working men, poor
farmers, and other hitherto neglected 'lesser
folk,1 as well as the historic actions and
pronouncements of historically preeminent
figures; and they  sought  to establish more
precisely the  actual, as  well as the abstract,
logical connections  between each step In the
conflict.  As  a  result, it is generally
recognized  today  that to  understand why the
Revolution  was fought,  one must do more than
cite  at  face   the  familiar political slogans
and catchwords.  The historian must consider
the actions and  the  motives of diverse
individuals,  groups,  sections, and classes;
and he must be aware of the relationship  of
the British-American conflict to British
Imperial problems In general and to larger
problems  of world affairs.  There is
no longer  any  doubt that the causes of  the
American Revolution were complex and deep-
seated.

Despite  general  agreement that the question,
'What  caused  the American Revolution?' has
no simple and  easy answer, historians are
still  far from agreeing about the relative
merits of different  answers.  Now, more than
ever,  their works  present an array  of diverse
often  contradictory  and conflicting inter-
pretations,  ...

Historians' disagreement  about the causes of
the American Revolution involve much more,
than a difference  in historical philosophy
between  'materialists'  and Idealists.'  There
are crucial disagreements about matters of
fact as well =s  about the interpretations
to be  put upon the  facts; and there are dis-
agreements  about  the  values and standards by
which  historians  should choose and evaluate
facts  and about  the meaning of such terms as
"explanation1  and  'understanding.1
The first group of historians propose  the  so-
called 'economic interpretation.' a general
name given to a number of related but  by no
means identical explanations, all sharing
one common, central conclusion:  that  it
was the conflicts between colonial and
British economic interests - mercantile,
industrial, and landed - which led to  the
Revolutionary War, and that the economic
motivations generating those conflicts
were the basic driving forces underlying
other, more superficial conflicts of poli-
tical ideas and ideals.  Louis M. Hacker
offers the clearest possible statement of
the viewpoint:

  'The stuggle was not over high-
   sounding political and consti-
   tutional concepts; over the
   power of taxation or even, in
   the final analysis, over natural
   rights.  It was over colonial
   manufacturing, wild lands and
   furs, sugar, wine, tea, and
   currency, all of which meant,
   simply, the survival or collapse
   of English mercantile capitalism
   within the imperial-colonial frame-
   work of the mercantilist system.'

Other historians around the turn of the
century, not persuaded that economic
Interpretations satisfactorily explained
why the Revolution came about, but equally
concerned to push beyond stereotypical
generalizations were also moved to inspect
•ore closely the details of pre-Revolutionary
history.  To a number of these writers it
seemed that, whatever the facts about
economic and related conflict earlier in
the colonial period, the decade or two
immediately preceding the outbreak of open
hostilities was crucial.  They contended
that the course of events leading from that
point to the war itself was not preordained
or deterministically dictated by some
economic or other underlying force.  It was,
in fact, shaped by the specific political
decisions taken during this period by
governments and politicians on both sides
of the Atlantic.  Some writers placed
particular emphasis on what they saw as
stupidity, folly, and irresponsibility on
the part of George III and his court, who
were seen as surmounting the principled
opposition of Parliamentary Whigs and
forcing decisions which violated rights and
interests dear not just to American colonists
but to British liberals as well.
                                                                                                   20)

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                         Relating this debate to western Cranston and its potential
                         historical and archeological significance it should be noted:

                         1)    That Stephen Hopkins, signer of the Declaration of
                               Independence,  nine times governor of Rhode  Island,
                               member of the Continental Congress,  Chief Justice
                               of the Rhode  Island Superior Court, advocate of
                               colonial union as early as 1752  (two years after pas-
                               sage of the Iron Act of 1750, which prohibited a
                               number of iron finishing operations in the colonies),
                               publisher, pamphleteer, agitator,  industrialist,
                               merchant, rum runner,  entrepreneur, smuggler,
                               college president (Brown), slave trader, brother
                               of the first Commander-in-Chief of the U. S. Navy,
                               wearer of the hat on the back of the two dollar bill,
                               etc. owned, operated, and got a state subsidy for
                               an iron mine  in western Cranston in the  Furnace
                               Hill Brook Valley.

                         2)    That Stephen Hopkins was much concerned about the
                               colonies'  economy,  particularly their  balance of trade,
                               or as Hopkins himself put it (from Walke; op.  cit.):
By the best computation I have seen,  the
quantity"of flour made in these colonies
yearly Is such,  that after all the English
inhabitants, as  well of the continent as
of the islands,  are fully supplied, with as
much as  they can consume with the year,
there remains a  surplusage of at least one
hundred  thousand barrels.  The quantity of
beef and pork remaining after the English
are in like manner supplied is very large. •
The fish, not fit for the European market,
and the  lumber produced in the northern
colonies, so much exceed the market found
for them in the  English West Indies,  that
a vast surplusage remains that cannot be
used....  From the money and goods produced
by the sale of the surplusages, with  many
others of less consequence,  sold by one
means or other to  the Spaniards, French,
and Dutch in America, the merchants of those
northern colonies  are principally enabled
to make their remittances to the mother
country for the British manufactures con-
sumed in them....

Supposing this Intercourse of the colonies
with the Spanish,  French, and Dutch entirely
stopped, the persons concerned in producing
the surplusages will of course change the
manner of their industry, and improvement and,
compelled by necessity, must set about making
those things they  cannot live without, and
now rendered unable to purchase from their
mother country (i.e., manufactures).
                        3)    That there appears to be a noteworthy coincidence
                              of interest in the iron industry among the otherwise
                              diverse signers of the Declaration of Independence.
                              John W. W. Sullivan of the American Iron and Steel
                              Institute (Encyclopedia Americana) raises the possi-
                              bility that the widespread distribution of the iron
                              industry through the colonies  (probably the world's

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                 major iron producer of the time of the revolution)
                 and the ironmongers' common grievance with the
                 Iron Act of 1750 may have done much to unify the group
                 of quite separate colonies with little else in common.
                 Sullivan lists as signers with interests in the iron
                 industry:

                       John Carroll of Carrollton , Maryland
                       Stephen Hopkins,  Rhode Island
                       Philip Livingston, New York
                       George Ross, Pennsylvania
                       James Smith, Pennsylvania
                       George Taylor, Pennsylvania

                  In addition, he notes as  revolutionary officers with
                  iron interests,  Ethan Allen,  Nathanial Greene of
                  Potowomut and Coventry, Rhode Island, Daniel
                  Morgan, and one George Washington.
Vfl
-3d ,   Site of old -firkins min* just west of 9henix -Avenue
                                                                        103

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      Figure VII ~3e.  Remains of former stream diversion channel  used to
                      deioater  flo^Kms mine site. Mote the bowed tree
                       characteristic  of streambank  vegetation.
                            4)    That Sullivan (op. cit.) also notes that while the Iron
                                  Act of 1750 specifically prohibited construction of
                                  new steel furnaces (among other processes) and
                                  while the consequent British census of the colonial
                                  iron and steel industries listed no steel furnaces in
                                  Rhode Island in 1750, that there was  one in oper-
                                  ation by 1776 in that state,  location not noted.

                            Physically, the mine area that was owned by Governor Hopkins
                            is in good condition having been little changed  since the 19th
                            century, although some  land surveyors' clearings in the pit
                            have been made just this year.  The remains of this operation
                            include:
204

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                    1)     stream relocation works to dewater the excavation
                          including a 12 foot high,  TOO foot long, earth backed,
                          stone diversion dam angled across the valley at about
                          45°, at least two man-made stream channels, one now
                          dry but clearly discernible, and with part of the di-
                          version channel blasted out of solid bedrock,

                    2)     an earthen plateau with vegetation strikingly atypical
                          of the surrounding woods,  apparently a spoil bank for
                          mine wastes ,

                    3)     several ponds that may have been part of an early
                          strip mine or water supply reservoirs for the mine
                          operation, and

                    4)     several minor stone constructions, including small
                          dams, foundations, etc.
Fiqure VII-3f,  9ari of stream diversion dam upstream of-Hopkins
  0      "   "     mine,  Male tuellands vege-M-ion in  foreground.
                                                                              tos

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                                                                           V
         Figure 711-35. V'eu> °f ^T^ins stream Aversion dam from uplands.
                             Locationally, the Hopkins mine is quite close to the presumed
                             17th century furnace just to the east and is also at the end
                             of "Hope Road," a road that runs directly to Hope Furnace,
                             a major supplier of Revolutionary War armaments, also owned
                             in part by Governor Hopkins, in southeastern Scituate on
                             a fall of the Pawtuxet River, 3 1/2 miles away.

                             Preliminary literature searches  by CE Maguire, Inc.  and
                             by Mr. Kulik, revealed the following interesting points about
                             the site:

                             1)     An old map published by John Reed of New York
                                   (otherwise not identified) entitled "The State of
                                   Rhode Island. From  the Latest Surveys,  1796,"
                                   which shows what  appears to be all the major in-
                                   dustries of the state, notes the ore beds of western
                                   Cranston  (along the Furnace Hill Brook) but no
                                   others.
206

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                      2)    Mr. Kulik's researches led him to conclude that the
                            site ". . .saw the first use of steam power in Rhode
                            Island.  A Newcomen engine,  built by James Brown,
                            was constructed here in 1780.  It pumped water from
                            a well (shaf*) 80 feet deep and °3 feet wide.  Accord-
                            ing to one description, the engine had a cylinder two
                            feet in diameter and a beam four feet  in diameter and
                            20 feet long . . .  This was probably one of the first
                            two successful Newcomens (steam pumps) built in
                            the United States.   Elijah Ormsi ee, who later went
                            on to develop a steamboat  with David  Wilkinson,  worked
                            here and received his first int. oducticn to sleam power.
                            The ore was dug by black slaves. . . ."
Fiaure VII- 3h. -Ancient  Oak  at -Hopkins mine. Note -Hie broad  shape
                 indicates -Hits tree once grew  iri
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                             3)    Other references indicated that Governor Hopkins was
                                   intimately involved with both weapons and technology
                                   and was chairman of the Continental Congress committee
                                   which supervised the construction and use of David
                                   BushneM's "Turtle," the first submarine.  Hopkins'
                                   reputation as a reliable and competent technical man
                                   is attested to in the matter of the "Turtle"  in a letter
                                   written by John Hancock to  George Washington on
                                   October 20,  1775 which stated "Captain John Macpherson
                                   having informed the Congress that he had invented a
                                   method by which with their  leave he would take or
                                   destroy every ministerial armed vessel in North America,
                                   they (the Continental Congress) appointed Governor
                                   Hopkins. Mr. Randolph, and Mr. J. Rutledge to confer
                                   with him on the subject, for he would not consent to
                                   communicate the secret to any but a committee and you.
                                   These Gentlemen (Hopkiris committee) reported that
                                   the scheme in theory appeared practicable and that,
                                   though its success could not be relied on without
                                   experience, they thought it  well worth attempting..."
                       7.143 Nineteenth Century

                             The ore bed ceased operation as a mine sometime in the
                             early 19th century and the subsequent use of its area is
                             not known.  At the lower Furnace Hill Brook site there is
                             record in 1831 of a "Union  Dye House," located at the ruins
                             area on Furnace Hill Street, and presumably the stream
                             was then used for both power and washing.  By 1855 a
                             "Cranston Furnace" appears to have supplanted the dyehouse
                             and the water power could have been applied to operate
                             furnace bellows.  A "Cranston Foundry"  appears  in the
                             records around 1862. Whether the furnace and foundry
                             were the same business, whether they coexisted with the
                             dyehouse, whether the dyehouse was preceded by an earlier
                             forge, etc.  are not knows.
2.08

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7.15  PROTECTION REQUIREMENTS

      Cultural and historic resources of national significance are pro-
      tected by law (Executive Order 11593) from adverse effects
      of any federal action unless there is no prudent and feasible
      alternative to the proposed action, and, where there is no prudent
      and feasible  alternative, that every prudent and feasible action be
      taken to mitigate the adverse effects of the proposed action.

      Such mandated protection  is  limited to properties eligible for listing
      in the National Register of Historic Places.  The criteria for such
      listing are that the properties both:

      A.    possess integrity of location, design, setting, materials,
             workmanship,  feeling and association,  and

      B.    that one of the following apply:

             1.     be associated with events that have made significant
                   contributions to the broad patterns of history, or

             2.     be associated with persons significant in our past, or

             3a.    embody the distinctive characteristics of a type of
                   construction, or

             3b.    represent the work of an  artist, or

             3c.    possess  high  artistic value, or

             3d,    represent (as a group) a significant and distinguishable
                   entity whose  several components may lack distinction
                   indjvkjuaMy, or have yielded or may yield information
                   to/in prehistory or history

      Adverse effect includes, but is not limited to:

             1.     destruction or alteration of all or part of a property.

             2.     isolation from or alteration of its surrounding  en-
                   vi ronment,

             3      Introduction of  visual, audible/or atmospheric elements
                   that are out of character or alter the setting, and

             4.     creation of conditions which would lead  to neglect of
                   the property.
                                                                           £09

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            7.2   PROPOSED ACTION

                  The proposed action,  so far as impacts on areas of special value and a
                  result of extension of  sewers  into western Cranston is concerned, in-
                  cludes:

                  1.    extension of interceptor sewers as a federally aided project

                  2.    construction of a system of lateral sewers (not federally assisted),
                        and

                  3.    intensification (and probably acceleration)  or urbanization in a
                        portion of western Cranston pursuant to the city's 1976 Master Plan.

                  The alternatives that have been advanced for the interceptors are major
                  pipelines 18" to 30" in diameter, run both in streets and open country, and,
                  for the vicinity of Furnace Hill Brook are shown in Figure VII-6.

                  The laterals are smaller pipelines generally laid in existing streets.

                  The urbanization generally will be private home development on all field
                  and forest lands in western Cranston except for public reservations , which
                  some of the wetlands.
2IO

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7.3   ANTICIPATED IMPACTS

      The proposed action, extension of sewerage into western Cranston via
      the Furnace Hill Brook Valley and change in land use as shown on the
      city's 1976 Master Plan, with or without the proposed apartments, is
      expected to cause, or lead to, the following impacts.

      1.    direct destruction and alteration of areas of great value culturally,
            historically, geologically, esthetically and ecologically, by physical
            construction,  i.e. gaining access to, storing material for, excavating
            for, and stockpiling earth from, the proposed interceptor sewer in
            the valfey,

      2.    increase in flood volumes and frequencies through the archeological
            and historic areas by  increase in land development and paving in
            the watershed upstream from the areas of special environmental
            resource value causing increased and accelerated erosion of the
            sites,

      3.    increase in traffic and traffic noise within the areas of special
            resource values,

      H.    possible wfdening and reconstruction of roadways within the re-
            source areas in response to growing traffic and traffic congestion,
            and

      5-.    changes in the settings as a result of land use changes.

      The no-action alternative, i.e. no sewer and no zoning change, would avofd
      the first of the effects and to some degree lessen the others.

      The worst case alternative,  i.e.  total  sewering and zoning change to 8,000
      and 12,000 square foot lots throughout western Cranston would create
      all the effects of the proposed action but to a substantially  more severe
      degree for most of the adverse effects.

      The mechanism by which the last four of these effects would come about
      is described in Chapter VI, GENERAL EFFECTS OF SEWERING NON-URBAN
      AREAS.

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The mechanism and magnitude of the first impact, disturbance of the land
surface, can best be gauged by considering that sewer construction will
require, at the least, clearing of an access road along the pipelines,  stor-
ing pipes (up to 30"  diameter), manhole materials, and pipe bedding (crushed
gravel, etc.) along the access roadway, excavating a trench at least 5' wide
along the trench, and then pushing (or scooping up) the backfill materials
back into the trench. In all,a swath at least 25' wide will be severely dis-
turbed on flatter lands,with even greater widths required on hillsides.
Figure VI1-7 shows such a hillside situation.
Figure Vlt • 7
fMMCT Of
OF i
         sire
                                                              ON
Specific areas threatened include the ravine between Phenix Avenue and
Natick Avenue by the proposed action and the old iron mine west of Phenix
Avenue by future extensions along the brook.

Elsewhere in western Cranston no major adverse impacts are expected in
areas with special resource value.
                                                                          2.13

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Ch»!*rviii     OYE^LL    IMTOCTS    ON THE
                    CITV   as  £   UHWlfr
 8 0   INTRODUCTION

      The set of proposed actions, enlargement of the municipal wastewater
      treatment plant, consolidation of other existing wastewater treatment
      facilities into the municipal plant, rezoning western Cranston, and
      extension of municipal sewers  into western Cranston, particularly to
      the areas zoned for industry, in addition to having the specific environ-
      mental impacts in the specific localities described herein before, can
      be expected to effect the City of Cranston and its residents and taxpayers,
      all taken together,  in a manner that can be called significant, originally
      only financially, but since this  financial impact will ultimately affect
      all other environmental aspects, it can be concluded that the proposed
      action will ultimately  affect the City's total being.

      The proposed actions will require a substantial investment of city funds,
      of state funds (to which the people of the city are major contributors)
      and of federal funds (to which the people of the city also contribute} for
      its construction and financing and it will require an on-going commit-
      ment to maintain and operate.  In addition the proposed actions will
      lead  to increased populations and increased municipal services to those
      increased populations.

      Counterbalancing these costs will be  increased revenues, in small part,
      from sewer use charges but predominatly from increased property taxes
      from the newly developed areas, while, overriding both the costs and
      revenues attributable to the proposed actions, will be changes in  munici-
      pal costs for services to, and revenues from taxes levied upon, existing
      properties as a result of changes in the city's socioeconomic milieu.

      The financial impacts  of the growth of western Cranston and its relationship
      to the City's socioeconomic milieu are described  in Chapter VII, Section
      7.32U "Municipal Cost and Revenues".

      The sections below attempt to set forth the significance of the financial
      impacts of the proposed actions by comparing them both with the overall
      city budget and with historic trends in costs and revenues.
                                                                           2.17

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             8.1    SETTING
                   The proposed action will result in a direct increase in the municipal
                   budget to cover the financing of the local share of the treatment plant
                   construction and, more important, its operation and maintenance. These
                   direct costs are expected to be on the order of well over a million dollars
                   per year, a not inconsiderable sum.  Figure VIII-1 shows how this new
                   sewer debt service and operation and maintenance cost compares
                   with the City's overall  operating costs and revenues.   Note that
                   the sewer maintenance budget does not include any existing sewer debt
                   service.  Note also the far greater importance of school, police, fire and
                   public works costs and of property taxes to the city as a whole, than the
                   sewer costs and revenues.
TABLE VIII-1
ANNUAL DIRECT COSTS AND

A. COSTS
1 . Debt Service hy City
(T. 20 yr.)
2. Operation and Maintenance
Sub-Total
B. REVENUES
1. Ciba-Geigy Estimated
2. Other User Charges
Sub-Total
C. NET ANNUAL DIRECT COST
REVENUES OF SYSTEM EXPANSION
1980 1990

$1,191,000 $ 843,000
1,720,000 2,780,000
$2.911.000 S3, 623, 000

S 403,000 $ 543,000
1,295,000 1,657,000
51,698,000 $2.300,000
$1.212,000 $1,323,000
1992

$ 531 ,000
4,400,000
$4,931,000

$1,023,000
2,019,000
$3,042,000
$1,888,000
Source: Universal Engineering Corparation
213

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Figure M- 1
         OF NEW 3£WE^ COSTS TO EXISTING  CITY BUDGET
                            Ssuer Use
                                      •Additisno! Sttytr
         Gt^OSS qt;VEHU5S  1*17^
             33,oco,OOO

Sewer Maintenance-
                                                Debt 3e«'vicft
           School  Operation*

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           8.2   ALTERNATIVES

                 Each of the alternatives described herein before, the no action alterna-
                 tive (no sewers and no zoning changes), the proposed action  (enlarge-
                 ment, upgrading and extension of the sewer system,  and a limited zoning
                 change) and a worst case alternative (intensive sewering and urbaniza-
                 tion of all of western Cranston), will have a likely specific impact on
                 Cranston's school enrollments and tax  base and on its relative financial
                 condition  as a result, within a rather broad range of magnitude  and time.
2ZO

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   Figure VI 1-2 shows the trends in property tax base for the city as a
   whole includmg  its assessed values, its supposed full value based
   on estimates of the Rhode Island State Reports on Tax Equalization, and
   the constant dollar values for the assessed and full values based on the
   United States Department of Commerce's Implicit Price Deflator. (The
   dip in full values about 1965, not based on a decline in assessed value,
   is believed to be an inconsistency in tax equalization estimation techniques,
   and hence is ignored in the analyses below.)
Figure M - 2
9flO?fcTTV  V4LU&5
CITV Or-
                     BOO
                     700
                     600
                    500
                    400
                    300
eoo
                     100
                   A
                                                Pull Value	
                                                Pull Value
                                                    r.ht  t)
                                                •Asses?
                                td Yil
                                 £d Value
                           /?55   1760
                                                   /9BO  I
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                                      SttU.tr'
                            * ^000,000,000 aofloc.ooo 1,000,000
                             100,000000  >,f>so:ooo 100,000
                                            9-
                                   4/OOOOO  10 OOO
                                     '/P,000 IflOO
                                                   /RS5
                       Figure VIII-3
                       fyPTIOS  OF 9ifO(i>E'iVrV  VALUES TO 90f5ULATIOW -AND
                       SCHOOL  ENROLLMENTS , |
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8.3    IMPACTS
       Figure VI11-4  displays  Cranston's  probable population and full, constant
       dollar property values for the various alternatives.  These extrapola-
       tions should be taken as descriptive  rather than as forecasts  and they
       are based upon ultimately reaching saturation  population after the turn
       of the century and upon experiencing the  most rapid  growth  rate (the
       steepest  slope on  the  semi-logarithmic graph)  about 1990 as a result
       of a  roll-over  of old  dwelling units from elderly couples to young
       families.  This roll-over would occur as the elderly couples,  now
       between  50  and 60 years old, reach 65 to  75 years, and as the large
       number of  young  people born in the  1950's and 1960's marry  and
       have children.  The  lowest  line in each set shows what would hap-
       pen if there were no new growth at all, the population  will increase
       anyway because of the roll-over and  the property  values will  decline
       because of wear and  obsolescence.
           SCAl!"
   *lXiiOSf>Oi'-*iiC30,Oco,tOQ,ecc I
        -/xooo --/a. ceo
             !


         tfyOOV- 1,000
j
I




L


































1
v

	 v—
Pi3ureVlil"4   ?^OJECTIOSS  OF-
                                                V V4LU&S
                                                                               2/23

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Figure VII1-5 displays the number of students for each alternative and
the ratio of students to total population.  The decline in total school en-
rollments which only recently has become apparent is the result of the
decline in births since 1961 and it should continue for some time.  Look-
ing to the future however,  it is unlikely that the birth rate will  not in-
crease as the post-war boom-babies in turn reproduce, say after 1980
and create a new peak in enrollments about 2000.
    SOALt'
   '10,000*-1,000
                /«xs    tno    nes   mo   iri-s   iieo
           FijureVllf- 5   91?OJ£CTION3  OF- SCHOOL

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      Figure VII-6 shows the ratios  of property  value  to school enrollments
      for each alternative and for the effect of no growth at all.  The result is
      striking and it appears that the following conclusions can be drawn:
      (1)
      (2)
      (3)
        that, without growth,  in about a generation Cranston will begin to
        experience the kind of shrinkage of tax base and increased demand
        for services that has severely injured older cities,

        that the impact of the differences in school enrollments among the
        alternatives is quite small compared both to that of the  differences in
        tax bases of the various alternatives and also to that of  changes  in
        age-composition-of-the-population  on all of them,

        that so long as schools are primarily paid for by local property tax,
        so long as new buildings are worth more than old buildings, and so
        long as old buildings decline in value with age, that cities that
        eschew growth will ultimately be required to accept substantially
        higher tax rates.
Tlflta,000,000r-
 *rxoocax^ /fOOO,l>o&
                                                                                ,-on
Figure VIII -<5  'itfTIO OF  FUTURE
                                            VALUES TO FUTUTJ5  SCHOOL ENROLLMENTS
                                                                               225

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Implicit in these conclusions are that no matter what Cranston does, it
will eventually exhaust its capacity for adding new growth when it
exhausts its land resources, and that ultimately, as Cranston becomes
old and obsolescent, it will decline in value and become increasingly de-
pendent, as have now older cities, on federal and state aid. Presumably
if Cranston develops its remaining resources wisely, with proper atten-
tion to preventing the causes of obsolescence (congestion, offenses to
the eye, nose, and ear, loss of its  natural assets, etc.) as suggested in
Chapters VI and VII, it will forestall and hopefully obviate, its ultimate
decline.

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EXHIBIT E

PUBLIC HEARING SUMMARY
A public hearing on the proposed action was held on November 18,  1976, at
7:00 p.m. in the auditorium of the Hugh B. Bain  School. 135 Cansett Avenue,
Cranston, Rhode Island, before Mr. Wallace Stickney, EPA Region I.

At the outset of the meeting the Mayor of the City of Cranston, the Honorable
James L. Taft, Jr., addressed the hearing, endorsing the proposed project;  he
cited the benefits to the city and  its  industries, clarified some of the annual cost
figures, and pointed out that some of the detailed land uses shown in the Draft
E1S, taken from the previous year's city Master Plan, were no longer city policy
and should be corrected in the Final EIS.

Presentations of the proposed action, of its anticipated impacts, and of the im-
portance of studying actions that might mitigate expected adverse impacts, were
made by Mr. Domenic V. Tutela and Dr. John J.  Cochran of Universal  Engineer-
ing Corporation, the project's planners, and by Mr. Daniel   Bubly of CE Maguire, Inc.,
the project's environmental impact assessment consultants.

On opening the meeting to public comments, a questions was raised on the avail-
ability and distribution of the Draft  EIS. Mr.  Stickney announced in response
that additional copies would be mailed out  immediately on request and that EPA
would extend the deadline for public comments to December 17, 1976.

Questions on the content of the Draft EIS, on the proposed action and on its
environmental impacts included:

1.    Is industrial development in fact beneficial to local tax bases?

2.    Could the wastes from the treatment plant be used as a fertilizer?

3.    Could the waste heat from the incinerator of the treatment plant be used
      in the neighboring state institutions?

4.    Is the roadway shown in the Draft EIS as a possible mitigating action
      for congestion that would stem from  population growth supported by the
      proposed action  an adequate solution?

5.     Is there a need for additional  land for industrial development?

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6.     Is the agricultural productivity of western Cranston underplayed in the
       Draft EIS?

7.     Are the statements in the Draft EIS about agricultural productivity true?

8.     What would be the effects of the project on water quality?

9.     What environmental  problems would arise from the sludge?  from the ash?
       and finally ...

10.    Should an  EIS address the morality and social equity of government actions?


Speakers at the hearing included:


      The Honorable James L. Taft, Jr.. Mayor of the City of Cranston
      Domenic V. Tutela, Universal Engineering Corporation
      John J. Cochran,      "         "         "
      Daniel Bubly, CE Maguire,  Inc.
      Anthony DeLuca, Cranston City Coundil
      Joseph Martelli. Concerned Citizens for Cranston's Future
      Senator Raymond Durfee
      Edward Lannon
      Dan Bolton
      Robert Flynn
      Alena Calderone, Cranston Conservation Commission
      Steve OiMaio
      Mr. Cray, Cranston
      Joan Ciampietro, League of Women Voters
      James Shaw
      Fred Vincent, Cranston City Planning Staff
      Robert Riley

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EXHIBIT F


LETTERS OF COMMENT ON THE DRAFT EIS


1.    EPA - OFFICE OF WATER PROGRAM OPERATIONS

2.    US DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

3.    US DEPARTMENT OF INTERIOR

4.    US DEPARTMENT OF AGRICULTURE

5.    US DEPARTMENT OF TRANSPORTATION

6.    US DEPARTMENT OF COMMERCE

7.    RHODE ISLAND STATEWIDE PLANNING PROGRAM

8.    RHODE ISLAND HISTORICAL PRESERVATION COMMISSION

9.    CITY OF CRANSTON, CONSERVATION COMMISSION

10.   LEAGUE OF WOMEN VOTERS OF CRANSTON

11.   ECOLOGY ACTION FOR RHODE ISLAND, CLEAN WATER COMMITTEE

12.   CONCERNED CITIZENS  FOR CRANSTON'S FUTURE

13.   ROBERTA. FLYNN, SR.

14.   CIBA-GEIGY  CORPORATION

15.   COMMENTS OF UNIVERSAL ENGINEERING CORPORATION TO THE
     LETTERS OF COMMENT

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                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

   DATE; DLC ;,  1976

 SUBJECT:   Cranston. R.I.; Wastewater Collection and
          Treatment Facilities,  Draft EIS

   FROM:   Kenneth E. Biglane. Director
          Division of Oil and Special Materials Control (WH-548)

     T0:   Regional Administrator
          Region I

          Attn: Robert Mendoza
              The comments from the Office of Water Program Operations
          concerning subject document are enclosed. If any of the issues
          raised in these comments require clarification, please contact
          John M. Hill, Chief,  Environmental Evaluation Branch on
          245-3054.

          Enclosure
EPA Fran, 1370 t, 'Rev. 3 7f>\

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             Office of Water Program Operations
                       Comments on
                  Cranston,  Rhode Island
       Wastewater Collection and Treatment Facilities

                         Draft EIS

                      November 1976
1.   It is noted that the consultant (C.E. Maguire, Inc. ), in
    preparing this EIS on behalf of the Region, has complied with
    the recommendations of the CEQ memorandum to the Heads
    of Agencies dated February 10, 1976 and the recent CEQ
    annual report by preparing an  "issue Oriented" EIS.  Both
    the Region and the consultant are  commended for this action.

2.   An EIS should be "...  an essentially  self contained instru-
    ment,  capable of being understood by the reader without the
    need for undue cross reference. " [40 CFR 1500. 8(b}]
    Particular care should be exercised when referencing material
    in other  documents which are not  readily available to the public.
    In the case of this EIS, reference is made to the applicant's
    Facilities Plan which is available only in the Regional Office or
    Cranston City Hall.  ^Frequently public participation arises out-
    side of the immediate  area of the  project and the burden should
    not be placed upon the reader to locate information necessary
    for the basic understanding of the EIS.  Therefore, pertinent
    data should be extracted from the Facility Plan as necessary
    to support statements  in the EIS.

3.   It is  stated, pg.  44, that "... urbanization of western Cranston
    can be viewed as the 'least sprawl' alternative of the feasible
    growth choices available... "  This statement was not substan-
    tiated by the preceding discussion. Further  discussion should
    be provided on this subject.

4.   On page  54, it is stated that urban encroachment along the lower
    reaches  of the Pawtuxet River, including the existing treatment
    plant, has created economic justification for a Corps of Engi-
    neers project for further flood control.  Further discussion of this
    issue should be provided,  particularly concerning any relation-
    ship  of the proposed treatment facilities to the requirements of
    the Flood Disaster Protection Act (P.L.  93-234).  On page 87,
    it is  indicated that the cells for storing the ash from the sludge

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    will be surrounded by dikes to prevent them from flooding.  The
    discussion should also address the protection provided for the
    treatment plant and the level of such protection in relation to
    the 100 year flood.  (See page  8 of EPA Technical Bulletin,
    EPA-430-99-74-001, Design Criteria for Mechanical,  Electric
    and Fluid System and Component Reliability).  Additional infor-
    mation concerning the flood protection requirements may be
    found in Program Requirement Memo 76-5 dated August  16, 1976.

5.  The discussion of alternatives should be detailed enough to show
    EPA's comparative evaluation of the impacts [40 CFR 6.  304(b)].
    The statements indicating the reasons for  rejection (page 63) do
    not indicate a weighing of beneficial and adverse impacts to arrive
    at the conclusion to accept or reject an alternative.  Some of the
    statements are not substantiated.   Thus, the reader cannot make
    an independent evaluation and appraisal.  (Example: One  of the
    reasons for rejection of the alternative for secondary treatment
    and effluent discharge to the Providence River estuary was
    "excessive costs". No cost estimates of the alternatives,
    including the proposed action,  were given for comparison. )  It
    is suggested that these alternative evaluations could be made in
    tabular form to reduce volume.

 6.  The EIS indicates, page 131, that the capacity of the interceptor
    from the western Cranston area was based upon intensive urbani-
    zation at the rate of  3 dwellings per gross  acre. This method
    provides for development so as to saturate the available space.
    It is noted, however, that development into this area has been slow
    because of the natural barrier formed by the granitic scarp, pages
    118-120.  Experience also indicates that as population density
    increases, there is a tendency to seek relief from crowding by
    spreading to other undeveloped areas.  Therefore, the  saturated
    condition for pipeline capacity may not be achieved for  many years.
    In accordance with the Cost Effectiveness Guidelines contained
    in Appendix A of the Construction Grant Regulations (40 CFR 35)
    the planning period is limited to 20 years and the service life
    for pipelines is 30 to 50 years.  The EIS should provide population
    projections and capacities for these periods.  Where feasible,
    phased construction should be considered.

7.  Figure VI-1 shown on page 118 shows the same symbols for
    residential, commercial and industrial, and recreation and
    open space.  Since the discussion of land use relies upon
    interpretation of this  map, it is difficult to distinguish any
    pattern of land use.

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                  DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                   BOSTON AREA OFFICE
                           BULFINCH BUILDING, 15 NEW CHAROON STREET
                                BOSTON,MASSACHUSETTS 02114
John F. Kennedy Federal Building              December 1  1 Q7fi
 Boston, Massachusptts 02203                    •*«=*. J, j.3> /o                      tN REPLY REFER TO:
                                                                           1.1SE


      Mr. John  A.S.  McGlennon, Regional Administrator
      U.S. Environmental Protection Agency
      Region  I,  J.F.K.  Federal Building
      Boston, Massachusetts  02203

      Dear Mr,  McGlennon:

      Subject:   Draft Environmental Impact Statement
                 Wastewater Collection and Treatment  Facilities
                 Cranston, Rhode Island

      The Draft EIS  submitted to the HUD Regional Office was sent to
      the Boston Area Office for review and comment.  The following
      comments  are offered for your consideration in the preparation
      of the  Final EIS:

         1.   As noted in the DEIS, Federal Highway Administration standards
      were used in the statement to determine existing ambient noise  levels
      as well as the projection of future levels of  noise.  The median sound
      level,  L50-the sound level which is exceeded 50% of the time, indicates
      that noise is  a problem now and will be a problem in the future.   It is
      important to note that noise levels in excess  of those established in
      HUD standards  (1390.2) for residential areas could present a problem
      if financial assistance by HUD is sought.  Where HUD assistance is. planned
      or used in the development of residential areas, those areas with unaccept-
      able noise exposure will generally be discouraged for approval.   Therefore,
      it is important that studies for the control and abatement of noise be
      considered in  the design of the treatment plan.  Ameliorative measures
      should  also be pursued for the control of noise in  future development  of
      the western area of Cranston.

      2.  This  office concurs that predictions of a  future activity in any
      detail  "is a manifest impossibility."  However, expansion of a  waste
      water facility will increase the undeveloped land into lands that can
      be developed,  thus urban growth.  Urban growth, the shifting of social
      priorities without redressing the lack of open spaces and recreational
      development, has led to the erosion of open space.  There is no discussion
      on the  present outdoor recreational resources  and the future planning  of
      outdoor recreational plans and open space.

          Recreation and open space are a part of our society-  The public
      today and in years to come will have more leisure time to enjoy and yet

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in densely populated areas or in areas that could be densely populated,
the problem of providing recreation opportunities, especially in urban
areas, is not addressed.  Conservation and land use management should
be identified, discussed and give consideration.

We hope that these comments are helpful.   Thank you for giving this
office the opportunity to review and comment on the DEIS.
Sincerely,
Ac

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              United States Department of the Interior

                          OFFICE OF THE SECRETARY
                             NORTHEAST REGION
                       JOHN F. KENNEDY FEDERAL BUILDING
ER 76/1018                     ROOM 2003 M & N
                          BOSTON, MASSACHUSETTS  02203
                              December 17, 1976
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
JFK Federal Building, Rm. 2203
Boston, MA   02203

Dear Mr. McGlennon:

We have reviewed the draft environmental statement for wastewater
collection and treatment facilities proposed for Cranston,  Rhode Island,
and offer the following comments.

General Comments
The draft statement is an admirable attempt at covering  a  very broad
topic, but its organization and layout makes comprehension difficult.
Analyzing the impacts is difficult because the statement lacks a complete
description of the project and area.  We suggest reorganizing the final
statement to a more standard format, beginning with a complete description
of the project area, followed by the proposed project, the project's impact,
etc.

Generally, the statement does a good job of enumerating  the various impacts
which the proposal will probably cause.  While it comments on the variations
of these impacts and the rapidity with which they could  occur, it says
little about what will probably occur given the distinctive socio-economic
and environmental setting of Cranston.  Considering EPA's  experience with
such projects, a prediction of the probable progression  of secondary
impacts, i.e., development, public service costs, etc.,  in terms of kind
and time should be possible.  Properly qualified such a  prediction of the
most probable scenario of events would be an appropriate addition to the
environmental statement.

The final statement should more fully describe and map the recreational
areas which may provide public access to the watercourse.  Public access
planning becomes increasingly important as the Pawtuxet  River quality
continues to improve.

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                                  -2-

We recommend that the Pawtuxet River Authority be consulted in regard to
current and proposed recreational activity along the river.  The final
statement should contain evidence of consultation with that Authority,
including their views of river recreational use and access.

In general, the impacts of the proposed project on water resources have
been adequately discussed.  The statement would be improved, however,
by including more specific data on frequency and magnitude of flooding
at the project site and by evaluating infiltration and exfiltration
effects for both the proposed collector system and the existing sewers.

The environmental statement lists many suggestions and recommendations
as to how adverse effects of the proposal can be mitigated or eliminated.
However, most of these are beyond EPA's scope of authority and/or
responsibility to act upon.  While EPA cannot deal with all of these
positive measures it is not stated by whom or how they ever could be
implemented.  Lacking such clarification, the credibility of the
recommendations is markedly diminished.  To remedy this deficiency would
improve the statement's adequacy.

Section 6.411, The Institutional Problem, is an unusually well raised
point and one not often seen.  Unfortunately, this valid point of
consideration is found to occur only in that part of the statement dealing
with transportation impacts,  It seems to follow from the concerns expressed
in the preceding paragraph that a section on Institutional Problems should
accompany the discussion of all major elements and impacts associated with
this proposal.

Specific Comments

Page 7:  This section should include all impacts, not just positive ones
or those that cannot be avoided.  A concise description of the wildlife
resources (a biological inventory) in the project area is needed in order
to understand exactly what is being affected.  If there are no fish
and/or wildlife resources within the area, the statement should say so.
The project impact section should cover the effects on aquatic life,
including fish and invertebrates, and wildlife, including wetland and
terrestrial habitat.

Chapter II:  This section attempts to develop a rationale for development
in western Cranston which is based largely on availability of water and a
fairly high level of air quality.  Whatever the merits of such an approach
may be, it cannot be said to be complete or comprehensive.  Other factors

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                                  -3-

of equal relevance would be the area's suitability in terms of geological
and soil considerations.  In the case of the area soils suitability for
building foundations, Figure VI-5 shows that most of the area has "Severe
Limitations" in this respect.  This suggests that all development will be
at inflated costs to the public as well as the private investor.  Considera-
tions such as this are believed to have a legitimate place in determining
an area's development potential.  It is suggested that Chapter II be
revised to reflect such points.

Page 66:  We read with interest the discussion on the chlorinated discharge
resulting from the project.  The Pawtuxet River may well contain Class D
water.  Still, the purpose for sewage treatment is to help improve water
quality, enabling fish life to return to rivers that have become lifeless.
We recommend that either the chlorine be eliminated from the discharge or
an alternative to the chlorine treatment be adopted.

Page 90:  This section contains the first mention of wetlands.  More
information is needed, such as how many acres, the type of wetlands,
and wildlife usage, if any.

It also notes that floodplain losses can be mitigated ". . .by compensatory
enlargement of flood storage in a number of places, both on and off site."
This comment establishes that the proposal will create the necessity for a
second round of structures, costs to the public and environmental impacts.
While an adequate degree of specificity may not be achievable at this time,
these points should be addressed in as great a degree of detail as is
possible.

Page 114:  Not only would draining the wetlands be expensive, but disastrous
to any wetlands-related wildlife utilizing the area.

Page 128:  Figure VI-7 should denote wetland areas also.

Page 149:  How much wildlife will be lost?

Page 192:  Throughout the statement, one receives the impression that
the project area is rather desolate in terms of wildlife and habitat.  As
mentioned earlier, this subject should be clarified.  This section could
also contain the information on wetlands.  Another point is that the loss
of any of the remaining "undisturbed" habitat might be a negative aesthetic
and educational impact for Cranston's people.

Page 194-216:  Chapter VII makes clear that certain cultural resource
values will be seriously affected by the proposal.  Figure VII-8 (page
215)  indicates that a number of areas eligible for inclusion in the

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                                  -4-

National Register of Historic Places are subject to adverse effect.  Such
effect is also indicated in section 7.3 (page 212).  Eligibility status
should be cited in the environmental statement as being confirmed by
consultation with the Director, Office of Archeology and Historic
Preservation, National Park Service, Washington, D. C.

Section 7.15 indicates awareness of protective procedures, yet section
7.4 states that certain requirements "might be considered."  The
Environmental Protection Agency should be advised that upon a determination
of eligibility of historic sites or areas for inclusion in the National
Register of Historic Places further requirements of 36 CFR Part 800 will
be applicable.  We note this draft statement is being provided to the
State Historic Preservation Officer and the Advisory Council on Historic
Preservation for their respective reviews and commentaries.  We would
expect to find their responses displayed and discussed in the final
statement.

In regard to specific concern given to the protection of archeological
values, we note discussion of a reconnaissance by the State Archeologist
(page 194), which suggests that further evaluation should be given to
such values.  Because of the anticipated impacts (sec. 7.3.1 and 7.3.2),
we suggest that further evaluation be accomplished soon so as to provide
sufficient material for a complete and adequate discussion of impacts and
presentation of mitigating measures in the final environmental statement.

Thank you for the opportunity to review the draft statement.

                                  Sincerely yours,
                                  toger Sumner Babb
                                  Special Assistant
                                   the Secretary,

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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE	
     Quaker Lane,  West Warwick, Rhode  Island—07S9T
                                                   January 14, 1977
 Mr.  John McGlennon
 Regional Director
 U.S.  Environmental Agency
 JFK Federal  Building
 Boston, Mass.   02203
 ATTENTION:   Robert Mendoza

 Dear Mr.  McGlennon:

 This is a late comment on the Environmental Impact Study for
 Western Cranston which we have reviewed.

 One question was alluded to but not  really addressed is that
 of prime agricultural  land.

 We believe  the time will come within the lifetime of most of
 the people  living today when food will be very critical.  In
 fact, if we consider world  needs right now, we barely have
 enough.

 Therefore,  it behooves us to identify those lands which are and can
 be readily  available or retrieved for food production and work
 toward its  preservation for that purpose.  This includes lands
 currently forested.

 The Environmental Impact Study mentions that if the land is used
 for residential  purposes, it can still be gardened.  That is true,
 but there are few individuals who are both capable and willing to
 produce all their lot  can.   Then too, a good percentage of the space
 is lost due to the houses,  roads, and esthetic effects.

 We, therefore, suggest development be encouraged on other than prime
 agricultural land.
 Sincerely,
 Austin  L.  Patrick,  Jr.
 State Conservationist

 cc's:
 C.  Rath (C.E.  McGuire)
 W.  Bascombe
 A.  DelSesto

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^<2J£i
               U. S.  DEPARTMENT OF TRANSPORTATION
                     FEDERAL HIGHWAY ADMINISTRATION
                               REGION ONE
                     Suite 250, Federal Bldg & USPO
                             Exchange Terrace
                     Providence, Rhode Island 02903
                                                          IN REPlY REFER TO;

                                                        November 18, 1976
  Mr. John A. S. McGlennon
  Regional Administrator
  U.S. Environmental Protection Agency
  J.F.K. Federal Building
  Boston, Massachusetts  02203

  Dear Mr. McGlennon:

  Subject:  Draft EIS - Wastewater Collection and Treatment
            Facilities - Cranston, Rhode Island

  Our Regional Federal Highway Administrator has furnished the
  subject report to our office for our review and action.

  We have no significant comments on the factual data relating
  to Federal-aid highways that is contained in the report.

                                          Sincerely yours,

                                          Gordon G. Hoxie
                                          Division Administrator

  cc *
  Mr  Kirby, 01-OO.U, FHWA
                                          Mario H. Tocci, Assistant
                                          Division Administrator

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December 17, 1976
                           UNITED STATES DEPARTMENT OF COMMERCE
                           Th« Assistant Secretary for Scisnes and Technology
                           Washington. O.C. 20230
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
Region 1
J. F. Kennedy Federal Building
Boston, Massachusetts   02203

Dear Mr. McGlennon:

This is in  reference to your  draft  environmental  impact
statement entitled "Proposed  Treatment  and Collection
System for  the City of  Cranston,  Rhode  Island."   The
enclosed comments  from  the National Oceanic and
Atmospheric Administration are forwarded for your
consideration.

Thank you for giving us an opportunity  to provide these
comments, which  we hope will  be of  assistance to  you.
We would appreciate receiving eight copies of the final
statement.

Sincerely,
 Jidney R.  (JailerI
Deputy Assistant Secretary
for Environmental Affairs
Enclosure
Memo from Mr. William G- Gordon
          Regional Director, FNE

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                                  U.S. DEPARTMENT OF COMMERCE
                                  National Oceanic and Atmospheric Administration
                                  NATIONAL MARINE FISHERIES SERVICE
                                  Northeast Region
                                  Federal Building, 14 Elm Street
                                  Gloucester, Massachusetts 01930
DATE  :   November 17, 1976
TO    :   Director, Office of Ecology and Environmental Conservation, EE
       A      fcjJdbL.S&^z^DEc 0*1976
THRU  Aw Acting Asst. Director for Scientific and Technical Services, F5

       V*                               ~     '    ^
FROM  : T]William G. Gordon
          Regional Director, FNE

SUBJECT:  Draft Environmental Impact Statement—Wastewater Collection and
          Treatment Facilities, Cranston, R.I.—EPA--DEIS #7610.40
The draft environmental impact statement for Wastewater Collection and
Treatment Facilities, Cranston, Rhode Island that accompanied your
memorandum of October 29, 1976, has been received by the National Marine
Fisheries Service for review and comment.

The statement has been reviewed and the following comments are offered
for your consideration.

General Comments

The proposed action described in the subject DEIS does nob suggest which
alternative, if any, of those listed wJ.ll be implemented to reduce or
eliminate chlorine from the discharge effluent.  Presently, there are no
anadromous species in the Pawtuxet. River because of river obstruction
and poor water quality.  It is our understanding that the State of Rhode
Island is investigating the possibility of restoring anadronious species
to the Pawtuxet River.  The wastewater treatment facility, once in oper-
ation, will improve water quality; however,  the introduction of chlorine
to the effluent discharge will reduce restoration possibilities.  Unless
measures are taken to greatly reduce or eliminate chlorine from the dis-
charge effluent, the effort to restore anadromous species will bo
jeopardized.

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STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
Department of Administration
STATEWIDE PLANNING PROGRAM
265 Melrose Street
Providence, Rhode Island 02907
                                         December  16,  1976
Mr. John A.S. MeGlennon
Regional Administrator
U.S. Environmental Protection Agency
John P. Kennedy Federal Building
Government Center
Boston, Massachusetts  02203

Dear Mr. MeGlennon:

     We have completed our review of  the  "Draft  Environmental
Impact Statement on the Proposed Treatment  and Collection
System for the City  of Cranston, Rhode Island"  (October  18,
1976).  It addresses all of the important aspects  of  this
project in a clear and thorough manner.   The well  illustrated
format is a refreshing change from  conventional  engineering
reports and environmental impact statements, and is easily
readable.

     We do have a few comments on the draft EIS  which we  feel
should be addressed before the final  report is completed.

     1) Our first comment concerns  the extent of the  proposed
        expansion of the wastewater collection system as
        shown on Figure 1-4 (p.5).  We question  if it is
        necessary at this time to construct laterals  as far
        west on Scituate Road, and  as far north  and west  on
        Pippin Orchard Road and Hope  Road,  as is shown on
        this figure.  Presently, there is little development
        in these areas and any use  other  than open space  such
        as agriculture, woodland, or  open land would  be in-
        consistent with the recommended land use patterns in
        the State Land Use Policies and Plan.  In  addition,
        the 1975 Master Plan for the  City of Cranston pro-
        posed that Scituate Road west of  Wildflower Drive be
        zoned rural density residential,  which would  not
        require sewer service.  While we  agree that western

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                       -2-
   Cranston  is  an  attractive  location  for  future  urban
   growth  we do have  some  reservations about  the  extent
   and speed with  which  this  development will take
   place.  It is our  feeling  that  the  laterals should
   not be  extended to these two particular areas  until
   the need  for them  has been definitely established.

     In conjunction with this, we  do not totally  agree
   with your analysis of the  future growth and develop-
   ment of Rhode Island, extrapolated  from national
   trends.  Rather, we feel that growth within the
   state will stabilize  in the years ahead, and that
   intrastate shifts  of  population will account for
   most of the  development pressures In western Cranston.

2) p.10, Par. 1, last sentence:  I do  not  understand why
   a discharge  into Narragansett Bay at this  time would
   preclude  reuse  of  the water or  deepwater discharge  in
   the future.

3) p.8, Par. ii:  Another  adverse  impact which cannot
   be avoided appears to be the noise  from incinerators,
   and it  should be listed here.

4) p.52, Par. 1, 1.5: The preliminary draft  of the
   Pawtuxet  River  basin  water quality  management  plan
   will be revised to indicate that the Class E reach
   at the  east  end of the  Pawtuxet is  to be upgraded to
   Class C.   Based on results achieved with the mathe-
   matical water quality simulation model, it is  felt
   that this classification can be attained with  ad-
   vanced  treatment at municipal plants along the
   Pawtuxet.  However, this classification will not be
   the legal classification of these waters until a
   formal  public hearing is held  on the reclassiflcation.
   The Department  of  Health will  hold  this hearing in
   late spring  or  early  summer.

5) p. 54,  Par.  1,  1.3:  This  agency does  not  agree that
   economic  justification for the  entire  Natick diversion
   project exists.  In fact,  the  margin of benefits  over
   costs of  this project as  estimated  by  the  Corps of
   Engineers is too small to  justify  its  construction.

-------
     6) p. 8?:  ¥111 the leachate collected from the ash
        disposal cells be pretreated before being drained
        back into the treatment plant?  If not, won't this
        increase the level of metals discharged to the
        river?  If pretreatment is required, how will the
        pretreatment sludge be disposed of?

     7) Some of the suggestions for mitigating impacts of
        the project are good, particularly the recommended
        re-routing of the interceptor near the historic
        area and the suggested traffic improvements for
        western Cranston.  Who is responsible for deciding
        if these mitigating actions will be adopted?

     Thank you for the opportunity to comment on the EIS.
If you have any questions on our comments please contact
Mr. Thomas Brueckner at the letterhead address or at 277-
2656.
                                     Very^truly yours,
                                     Daniel W.  Varin,  Chief
                                     Statewide  Planning
DWV/abg
cc:  Carleton Maine
     Daniel Bubly, C.E.Maguire

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STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS




 HISTORICAL PRESERVATION COMMISSION
 Old State House
 150 Benefit Street
 Providence, R. I. 02903
 (401) 277-2678


 December 6, 1976
 Mr. John A. S. McGlennon, Administrator
 U.  S.  Environmental Protection Agency - Region  I
 J.  F.  K. Federal Building
 Government Center
 Boston, Mass.  02203

 Dear Mr. McGlennon:

 This office has reviewed the draft Environmental Impact
 Statement of the Proposed Treatment and Collection
 System for theCityof Cranston, R. I.,and offers the
 following comments.

 In  general, the consultant has prepared an excellent
 statement with regard to historic and cultural  resources.
 The level of historical research  conducted and the extent
 of  consultation with specialists of various disciplines
 is  far above that found in other comparable impact state-
 ments.  A preliminary historical and cultural survey was
 conducted as a part of the impact study; we note, how-
 ever,  that further field investigation will be  necessary
 when final plans are made and prior to construction in
 order  to avoid adverse impact on cultural resources.

 Regarding primary impact on cultural resources, we concur
 with the impact statement's recommendation for relocating
 the interceptor originally planned for placement within
 the Furnace Hill Brook ravine.  The ravine area is being
 recommended for nomination to the National Register of
 Historic Places as an archaeological district, since it
 possesses a valuable and unusual blend of historic and
 prehistoric sites.  The ravine also has great natural
 and scenic value, as noted in the report.

 With regard to the possible use of two mill ponds on
 Furnace Hill Brook for the control of increased storm-
 water  run-off caused by expanded road surfacing, we
 concur with the recommendation of the impact statement
 that any such action be undertaken only under the super-
 vision of the Historical Preservation Commission.  We

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Mr. John A. S. McGlennon   page 2   December 6, 1976
urge the city to rely on on-site run-off controls; these
have the advantage of avoiding impact on sites eligible
for the National Register.

It is the implication of the impact statement that
without the proposed wastewater treatment improvements
the Pawtuxet River may become anaerobic during low
floods, creating a serious odor problem in the Pawtuxet
Village Historic District.  The report also notes that
the village could be affected by the loss of floodplain
further ur»-river.  Because a portion of the river itself
is within the National Register district, and is im-
portant to the district, we urge concern for the flow
level of the Pawtuxet.

The increased volume of traffic in Western Cranston will
have a significant effect on the environment.  The al-
ternatives of over-congested existing streets or the
extension of a four-lane Route 37 are not attractive.
Either will mean a degradation of the visual and audible
environment of the Furnace Hill Brook historic site.
The extension of Route 37 will dramatically extend the
frontier of urban sprawl and thereby impact Oaklawn
Village and possibly Hope Road, both of which are areas
eligible for National Register nomination.

The general problem of secondary impacts resulting from
new sewers in Western Cranston has been thoroughly
addressed in the impact statement.  It should be recog-
nized that providing new services will not only satisfy
projected growth requirements but will permit and
accelerate growth, thus altering existing historical
and natural landscapes.  Our concern is that, as a part
of the general growth process, the cultural resources
of the city will be adequately considered in community
planning and protected during construction projects.
Frederick C. Williamson
State Historic Preservation Officer
FCW/mm

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  L. TAFT. JR
  MAYOR
                        CONSERVATION COMMISSION
                              FXFCUTIVE OFFICE
                               CITY HALL

                        CRANSTON, RHODE ISLAND 02910

                             PHONE 461-1000
MRS EI.ENA CALDARONF. CHRMN

ANTHONY J RODI. VICE CHHMN

   ANIHONY VENrFIUOl O

   f HFDFRICK J VINC'.rNI

   HAYMONU F HOHHTHI

   .1 ROBERT WAHI H|-H(,

    JAMfS A SHAW
                                          December 14, 1976
Mr. John S. McGlennon
Regional Administrator
U. S. Environmental  Protection Agency
Region 1, Room  2203
John F. Kennedy Federal  Building
Boston, Massachusetts    02203

SUBJECT:  Comments on the  Draft Environmental Impact Statement
          Wastewater Collection and Treatment Facilities for the
          City  of Cranston,  Rhode Island

Dear Mr. McGlennon:

     This Commission is  in favor of improvement and enlargement of the
sewerage treatment plant to prevent overloading of the existing plant
and to improve  the water quality of the Pawtuxet River.

     If western Cranston is more intensively urbanized, we have a
great concern with the runoff-related effects in this area; and we
are very much in favor of  the  mitigating actions, as presented under
"Runoff Related Effects-Western Cranston" pg. 12, section 1.12 of
the Draft.  However, the important Table VI-I on page 144 needs
some refinement.  If alternative 1 "shows the effect of the proposed
action"  (intensive urbanization in the sewer area) it could not be
in the same column with  the existing zoning, where most of the area
is zoned A-80  (80,000 s.f.)

     The Conservation Commission also endorses the mitigating
actions included under "Traffic related effects-western Cranston"
pg. 13.  It notes especially the concept of a control access parkway.
This concept merits  further study.

     Those mitigating actions  listed under "Impacts on special
resource-values" sections  #3 and #4, pg. 14 and section #5 under
"Impacts on vicinity on  Cranston waste water treatment plant" pg.  15,
are also endorsed by the Commission.

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Mr.  John S.  McGlennon           -2-           December 14, 1976


     Questionable judgment was expressed about paragraph II of the
Summary of Significant Impacts.  Under "The unavoidable adverse effects
of urban growth," the report, point 2, includes the "Permanent loss
of rural land, mostly forest with some farms, to urbanization but
not necessarily resulting in permanent loss of the agriculture product-
ivity of the rural lands."

     This Commission suggests including the loss of prime agricultural
land not in paragraph IV, but in paragraph V, "Irreversible and
Irretrievable Commitments of Resources."

     Pages 41 and 42 deal with agriculture in a superficial manner.
There are only two viewpoints pursued:

     1.  Whether Rhode Island's total agricultural land or output
is meaningful when compared to its food needs, and

     2.  Whether residential development really precludes food
production.

     The statistics quoted in the first point, from the 1972 U. S.
Census Bureau's County and City Data Book show the small percentage
of the nation's farmland that survived in Rhode Island.  However, it
produced double this percentage in Rhode Island's total retail food
purchases.  The 1960's statistics are meaningless in this decade of
accelerating energy costs which are reflected in the high costs of
food brought in from out of state.  We can only assert the growing
popularity and success of vegetable and fruit producers in western
Cranston in the last few years.  Both the residents and non-residents
of this area benefit by the purchase of the fresh produce grown here.
It is very meaningful in this metropolitan area.

     We cannot find any substantiation of the Draft's second point
that the residential development wouldn't preclude food production.
Intensive urbanization certainly prevents agricultural use of the
same land.

     There was no thought given in this Draft to the enhancement of
the present agricultural production in western Cranston and no
exploration of the agricultural belts of Sir Ebenezer Howard  (reflected
in the design of Greenbelt, Maryland) mentioned only in passing on
page 183.

     We have to consider seriously the impact on farmlands.  The
Council on Environmental Quality recently asked heads of Federal
Agencies to include in the Environmental Impact Statements they
prepare an analysis of the effects of proposed actions on prime and
unique farmlands,  Environmental Impact Statements should evaluate the
irreversible effects not only from direct construction activities,
but also from urbanization or other changes in land use that might

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Mr. John S. McGlennon            -3-           December  14,  1976


be induced by the federal action.  The Department of Agriculture
plans a major new emphasis on reviewing and evaluating all
federal draft environmental impact statements with respect to
impact on prime and unique farmlands.

     Should the proposed action suggested in this Draft  be adopted
i.e. intensive urbanization in the sewered area, the Conservation
Commission does not feel that enough attention is given  to the
restoration of the land.

     The rephrasing of the sentences using the word "mitigate" is
suggested.  For example, the statement (pg. 149) " . . .  zoning,
etc. could entirely mitigate the adverse effects of the  proposed
action" does not make sense when mitigate means to make  less severe,
to moderate.  The same reasoning should be applied to the last column,
page 167: "Some of these anticipated impacts can be totally avoided
by adequate mitigating actions while others can only be  softened. .  ."

     The Cranston Conservation Commission is listed on the Summary
Sheet as an Agency which has contributed to the Formation of this
Statement.  We did not help in any way to prepare this Draft and,
therefore, ask to have the Conservation Commission deleted from
the Summary Sheet.

                                         Sincerelv yours,
                                          (Mrs.) Alena Caldarone
                                         Chairperson
AC: si

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                       UiAGUli  Ol<  WOMIiN VOTERS
                               OF CRANSTON, RHODE ISLAND
                                     Affiliated with ihe
                               LEAGUE OF WOMEN VOTfRS OF THE
         17, 1976                     UNIIED SIA'ES

 OS Environmental Protection Agency
 Region 1, Room 2203
 John F. Kennedy Federal Building
 Boston, HA   02203

 Rei Draft - EIS Waste Water Collection & Treatment Facility, Cranston, RI

 Dear Sin
 Basically we agree that the Cranston Waste Water Treatment Plant should be Improved
 and enlarged to serve the present and future needs of the City,  The EIS does make a
 good case for Cranston as especially suitable for urban growth.  However, development
 should only be allowed after the Installation of sewers, a public water supply and
 solid waste disposal are provided.
 One of the unique characteristics of the Western Cranston area is the large amount of
 prime farm land, according to the January 1975 State Land Use Policies Plan.  The EPA
 regulations on preparation of EIS Statements do say (Fed Reg, Volume jfaQt#72t page 1681*0
 "Protection of prime agricultural land...has become an Important concern as a result
 of the need to further increase food production from domestic sources., .and the con-
 tinuing need to preserve the diversity of natural resources for future generations."
 Did you seriously consider this in your study or did you ignore the EPA's regulations?

 Cranston's forest land is valuable because it provides many benefits including water
 shed protection, recreational values, esthetics, wild life habitat and forest products.
 The rural character of this section must be preserved.  Somehow we must reach a
 balance In the development of this section.  Land should be set aside for future
 recreational areas excluding land already owned by the state.

 Development cannot progress with the current "Cow Path Roads/' we support your Idea of
 a limited access parkway with the widest possible buffer zones.
 At all  cost the areas of special resource value must be protected and preserved.
Sincerely,
        Ansty, President           (/Joa,n G&mpieliro, Land Use Chairman
  y"""*rt"iilJSridi ^JWtffP' RT  02920   20 Hibiscus Dr., Cranston, RI  02920

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                                             12/22/76
     To:   Environmental Impact Office, EPA - Region I, JFK Federal
          Building, Boston, Mass. 02203 (att'n;  Bob Mendo2a)
     From:  Clean Water Committee, Ecology Action for Rhode Island, 286
            lhayer Street, Providence, H.I. 02906 (401-274-94-29)
            (prepared by Linda Silversmith, chairperson)

     He:   Cranston, R.I., Environmental Impact Statement, V.'astewater
          Collection and Treatment Facilities — Draft
          (Comments due Dec.17, 1976; 10 day extension requested)

     Copies to:  C.E.Maguire, Universal Engineering, Cranston Conservation
                 Commission, Mayor Taft's office

          The commentary of the Clean Vfater Committee will be divided
     into two parts:  a section with general comments and a section with
     page by page notations.

A.  General Coonents:
     1.  Water quality goals:  it is not entirely clear in this document
         that the water quai-i-ty ^oals for the Pawtuxet River will be at
     least C classification; it is reasonable to assume -chat the D goal
     will be changed, to _C in an early revision by the state and with
     strong public support.
     2.  Land use plans:  Nowhere is there a discussion of the discre-
         pancies between Cranston's proposals for western Cranston and
     the proposals (mostly open space) of the State Guide Plan for land
     use.  Since federal monies are not supposed to be granted for pro-
     jects conflicting with the state guide plan, some discussion of the
     differences here and methods for mediating these should be included.

     3.  Public -participation;  7/as there sufficient public participation ;
         according to guidelines for P.L.92-500 in the preparation of     ;
     this 213 draft?  Note (1) the lev; number of citizens' comments con-  '
     tributed to the draft, and (2) the short notice of only 1 week for
     the April 20 meeting.  V»hat was the attendance at that meeting?
     4.  Coordination with other -plans:  It is obvious that this EIS
         draft was preparsa on a constrained timetable.  For instance,
     a revision should'include expansion on the topics of related studies
    1 and how Cranston's plans fit"with these:  in particular, aore atten-
     tion could be paid to (a) the 208 studies projected for tha Pawttucst
     basin, (b) the'Pawtuxet River Basin's Water Duality Llanagenent Plan,
     and (c) the Corps of Engineers' most recent proposals for flood
     control in the basin.  Areas where plans agree or disagree should
     be stressed.
     5.  Sewer ordinance, pre-treatment, pass-throughs, etc:  It appears
         to this coriuiittee tnat tnese topics are relevant for consider-
     ation in an SIS since the way in wnich each is handled can affect
     the environmental impact of the overall project.
     g.  Para lands:  The committee assessment is that the discussion of
         loss of agricultural lands ignores completely the cumulative
     effect of small changes.  2ach local  change in environmental  quality
     should not be treated as an isolated  impact, but as  part of an

                                                        see next page

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   CHANSTCN EIS/  CWC / p.2       12/22/76

t. General comments,  continued, #6...

   overall picture:  thus,  the  loss  of a supposedly small percentage
   of R.I. and national  farm land should "be treated in terms of overall
   trends, not just as a small  incident.  Additionally, no mention is
   made in this BIS of other studies existent in H.I.  concerning the
   national trend (problem?) towards loss of agricultural lands°and
   recommendations for ways (e.g., via tax structure)  to encourage
   maintenance of H.I. farm land.

   ?•  Flood plain disposal of  asht   While the recommended disposal
       method for incinerator asn suggests a design to protect" ash from
   contact with ground water, it is  not clear lay what  means the ash will
   "be protected from contact with flood waters.

   8.  Soil surveyst   It would  be useful to have surerimposed on one
       map all the  information  on topography,  slopes,  water tables,
   drainage, etc. with the  Soil Conservation Service's interpre-cations
   also summarized  in  the one place  for what is buildable,  usable for
   aeptic disposal, etc.

   9.  Commendations;  the  committee appreciates- the thorough, handling.
       of jthe_j?urnace  .drooK: area ana the points .stressed concerning
   matching ~rin'sp"6rta.tion  (and' surrounding open space corridors) to
   p^pala^i6n^r33}jth""'±n  western Cranston.

   10.  Coordination v.'it'a other  federal agencies;   Begirding the
       proposal I'or open space  corriacrs adjacent to transportation
   netv«orks (and  to sewer networks?), what kinds of consultation have
   taken place or will take place with the federal Department of
   Transportation and  the Bureau of  Outdoor Hscreation concerning
   coordination with SPA water  quality programs?  (Seniinder:   30R and
   2egion I Z?A have a memorandum of understanding concerning coordi-
   nating recreational and  water quality programs;.

R.  Page-by-p3ge notations:   commentary begins on next page—page  3«

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    CBAHSTON EIS/ CV/C / 12/22/76 - page 3


B.  Page-by-page notations;

    1.  page backing list of tables:  While an occasional  small  sketch
        enlivens this report, it does not  seem right that  the U.S.  tax-
    payers should have to pay for full-page sketches like  this one.
    2.  p.l - These maps are so poorly legible as to be a  ridiculous
        waste of paper.     (also true on page 2)
    3.  p»3» line 1:  doesn't some overload already occur  at peak flows?
    4«  P«3, Pig.I-3:  (a)  the state institutions are already tied  in;
        (b) Ciba-Geigy should not be listed as "to be abandoned" since
        some pretreataent will be necessary.
    5.  p.4, Table 1-1:  Proposed water quality  condition  downstream
        should  be  changed  to class Cf.
    6.  p.4, +  later  section on incineration:  how will incineration by
        Cranston fit  in ^ith regional 208  planning?
     7.
p.5, Fig.1-4:  How does this compare with (1) Cranston zoning;
\2) State <*uide Plan; a map with superpositions for'comparison
     would be useful.
     8.  p.7:  (item 3 re Pawtuxet Village)  Doesn't  the  Pawtuxet  Village
         have some septic or nonpoint  discharge problems?
     q.  p.7, item 2 at bottom:   again,  what is the  consistency of growth
         plans with state and local planning?
    10.  p. 9:  why doesn't this  listing include mention of regional
         alternatives  (a» does  p.20).
    11.  p.10, paragraph 2, bottom:  is this really realistic to  consider
         home crops as a hobby as significant?
    12   T> 12  item 1:  will this include r
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   CRANSTON SIS / 
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 CHANSTCN EIS/CYtC/ 12/22/76 — page 5

34.  p.69:  what ia the projected lifetime for the landfill for the ash

35.  p. 71, Table IV-2:  what happens when the heavy metals are in-
     cinerated—what products (to they form?
36.  p.72, parag.2:  won't flooding renew moisture content in
     this sludge?
37.  P«74» Table IV-4:  is there no way to decrease these emissions
     further?
38.  p.75» Table 17-5:  footnoes 3 and 4 need clarification to draw
     a distinction for the reader between primary and secondary
     standards.
39:.  P*76, part 4.141:  "windiest region" is based on what standards?
     Also how consistent are these wind figures with the air pollution
     data presented earlier for H.I.?
40.  p.82, parag.2:  this assumption of all unleaded gas by 1985"
     does not seem valid, given the lifetime of some of the older
models of automobile in ownership by poorer families.
41.  p.84:  continuing a policy of using the floodplain seema crazy
     unless there is 10O# guarantee of floodproofing.
42.  p.86:  what is the cost of these alternatives vs. using the
     floodplain?
43.  p.87:  parag.2 - please clarify what these specially designed
     cells are.  Parag»3 - what will be the lining, of the cells?  To
what flood level will the dikes protect?  What will the monitoring
be for?(be mare specific).
44.  p.88:  re incineration and off-site disposal:  can the time
     element be considered a valid excuse in an SIS?
            re bottom item 1-c:  good point
45.  p.89:  item 4-a., bottom?  this may be inconvenient but is it
     a valid reason for discarding an alternative?
46.  p.90, parag.4:  is there a more specific proposal on.this "com-
     pensatory enlargement of flood storage"?
47   p.92:  item 3, top - why is this being neglected?  Also - lower
     parag. re park:  could BOH help in establishing this park?
48.  p.95:  please note that the Ciba-Geigy treatability study still
     did not deal with company wastes untreated by the test procedure,
     i.e., what is passing thrpugh untreated?  How might this affect
     Pawtuxet water quality?
4C   p.100:  since the July 1975 studies did show that turning off
     the fans did decrease efficiency of pollutant removal from
     wastewater, it is entirely unlikely that the last sentence  in
     paragraph 1 can be true for July 1974.  Solvent not removed
     by air stripping must be retained in  the water.
50   TJ 110, item 4-b: good idea;  should  be standardly included  in
   *  design of sewage treatment facilities in areas  also  having
     septage.
                                         more  on page 6

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   GRAN STOW EIS/OTC/ 12/22/76 — page 6

B.  51.  p.112, middle parag. on noise:  it would be useful  to refer here
        to future discussion (p.115) of ways to alleviate  noise

   52.  p.118:  is there a reference for the statement that "gradual
        transitions  are typical" in southeastern New ingland?

   53-  P«H9:  how  is the drainage in western Cranston without sewers?
   54.  p.120:  Fig.VI-3 and description of topography would be more
        useful in conjunction with parallel work indicating slopes and
        SOS interpretation key re utility at various slopes for*land use.

   55•  p.122i  given the conditions of parag.3, is it logical to worsen
        these runoff conditions by more pavement and urbanization?

   56.  p.124:  here is where superposition of the various limitations
        of soils to  give a total picture (septage,slope, runoff,etc.)
        would be useful.

   57.  p.124, bottom line:  who should be answering this Question—
        is that a job for the city of Cranston?

   58.  p.128:  even if the forest area has limited direct value for
        wildlife, it would be useful to see forests indicated on a map.

   59.  p.131s  bottom of paragraph - is this engineering practice for
        sizing of pipes also a standard and prudent practice for control
        of urbanization?

   60,  p. 137:  Figures V-8 through V-ll should be compared v/ith the
        State Guide  Plan for Land Use.

   61.'  p.137:  item 6:  are there any data concerning the effects of
        on-site sewerage in western Cranston — e.g., wet basements,
        backed up septic tanks, etc.?

   62.  p.137:  item 7:  are these alternatives seriously evaluated here?
        (or is the fact that R.I. does not allow some of these preventing
        serious consideration as to whether they are viable solutions?)

   63.  p.141:  last parag. - an explanation should be offered why this
        alternative  is "not believed to be a likelihood".

   64.  p.143, top:  is there any correlation in studying these effects
        with the "208" study in this area?

   65.  p.145, bottom:  should calculations be extended to. the ether
        watersheds where effects might be more adverse (item 1)?  In
        item 2 - "relatively slight changes" - such as?  where are these
        discussed further? - should be referenced here.

   66.   p«146:  earlier the consultants on this report implied that farm-
        land as such is a minor, usage; it Is inconsistent for this to
        be a minor usage in one place and contribute to runoff signifi-
        cantly in another (as parag.2 here) — which is more accurate?

   67.   p.147:  what kind of authority is being referred to in the bottom
        paragraph?  whose legal opinion is it that this authority
        exists? Is this,, jumping tiie^gun on the legal-institutional
        study of the 208 program and its future recommendations?

                                           more on page 7

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    CRANSTON EIS/CV/C/ 12/22/76 - page 7

B.  68.  p.159, Table VI-5:  should the lines for the master plan, fully
         developed and 20 yr.development be identical as in the table?

    69.  p.168:  bottom * item 1:  but where does the transit go vs.
         where people want to go?  item 2:  is this relevant when you
         are recommending cluster zoning?  item 4:  this is very opini-
         onated - perhaps who wrote this should be stated here.

    70.  p.176:  6.411 section:  is this an area where an agreement
         is needed between DOT and EPA?
    71.  p.178, parag.l - not recognizing a problem does not mean it
         did not exist earlier, although admittedly severity has increasei

    72.  p.178, parag.2 - we agree that channelization is not a good
         approach.
    73.  p.178, parag.3 - in general isn't the small reservoir approach
         better than the large one?  Can the pro's and con's of large
         vs. small impoundments be spelled out here?
    74.  p.181, middle parag.:  to whom are these "adverse effects"
         supposed to be adverse? to developers? to tax rate?  this should
         be spelled out.  Also - concerning the recomnendation to base
         zoning on environmental performance - shouldn't this ideally
         always be a basis for zoning?
    75.  p.194:  parag.2 is the first place in which anadromous fish
         are defined; yet, they are mentioned several times earlier in
         this report.
    76.  p.210, bottom:  spme words or phrases are missing here.

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                                                     218 Oaklawn Avenue
                                                     Cranston, R.I.  02920
                                                     November 19, 1976
U.S. Lnvironmental Protection Agency
Attention:  Mr. Stickney
Environmental Policy Coordination Office
Room 2203
John F. Kennedy Federal Building
Boston, Ma.  02203
Dear Mr. Stickney,

     The E.P.A. Hearing which was conducted last night in Cranston was
most informative.  Our worst fears were realized relative to the adverse
environmental effect that would ensue should the industrialization of
western Cranston become a reality.

     The first draft did specify the many disadvantagesi .e. overcrowding,
traffic congestion, complete change in the character of the area, noise
pollution, visual pollution - to mention just some.  These are exactly
the environmental destructions that good planning and good zoning are
required Lo not allow to happen.

     The people retained to prepare this report admit the detrimental
impact of urbanization of this area but argue that this is the price
the citizens of Cranston should be willing to pay because "You are your
brother's keeper."

     Those of us who have great concern about the continual destruction
•..••" our environment have an opposite view.  We feel that we have a duty
to futurp generations to start reversing this process of destruction of
Liie planet Earth.  Western Cranston has the potential like some adjacent
areas, to develop into one of the best residential areas in the New
England area.  The City of Cranston can be proud that many residents
are genuinely interested in preserving the good characteristics of our city
and by sensible planning extend these advantages to the undeveloped
areas.

     We would at this time, request an extension of time to file detailed
comments.   Especially due to the proximity of the holidays this additional
time would be most helpful.

     Do not construe our objections to some portions of this plan as an
objection  to a new water treatment plant for Cranston,  This seems
necessary even if there were a zero growth situation, which seems
unlikely.

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     I would assume that your agency was established by the government
to protect the environment.  I would strongly urge the E.P.A.  to examine
the information already compiled.   The only conclusion that can be
arrived at as a result of such a study would be a conclusion that the
urbanization of our rural areas would have a most adverse effect on our
environment.

     I would appreciate your reply regarding an extension of time to
file written comments.
                                                   incerel
                                                  Vice President
                                                  Concerned Citizens  for
JFM/mja                                           Cranston's Future
C.C.:

Mayor James Taft
Planner - Anthony DelSesto
Providence Journal-Bulletin
Cranston Herald Today
Cranston Mirror

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                                   28 November, 1976


U.S. Environmental Protection Agency
Region I, Room 2203
John F. Kennedy Federal Building
Boston, Massachusetts 02203

          Subject:  Comment on Draft EIS
                    on the
                    Proposed Treatment and Collection System
                    for the
                    City of Cranston, R.I. dated October 18,1976

Gentlemen:

The following comment is offered for your consideration prior
to issuance of the Final EIS.

*•  GENERAL;   The considerations on which the DRAFT EIS are
               based appear to be identical to those upon
               which the City of Cranston Comprehensive Land
               Use Plan was predicated - i.e. a projected
               growth in the population of the City of Cranston
               and maintenance of current population at the
               R.I. State Institutions which are both unsub-
               stantiated and contrary to current trends.

               The writer has, over the past year, called
               the matter of the need for more substantiated
               population projections to the attention of both
               the Cranston School Committee and the Cranston
               City Council.  Since the projected population
               figures are the basis for City, State, Federal
               and Ciba-Geigy participation in up to 52 million
               dollars in expenditures, it is felt that reso-
               lution of the basic question - "Is expansion of
               Cranston's Treatment and Collection System re-
               quired to accommodate or create a population
               growth to extent projected in the comprehensive
               land use plan and the Draft EIS?"

               At the 18 November, 1976 Public Hearing, the EPA
               representative admitted the "97,000 by 2000"
               population projection differed from the StaTe
               Planning Commission projection of 93,400 by 2000"
               but dismissed it as unimportant.  The writer
               suggests a difference of over 20% in population
               increase is significant enough to warrant review
               prior to committment of 52 million dollars of
               taxpayers or stockholders funds.   (Current trends
               and basic time-series analysis suggest more con-
               servative projections.)

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II.  SPECIFIC; Table 1-1 P.4 and Table 111-4 P. 59 comparison


                                 1975                 2000

Pop. Served                      68,000               93,000
Pit. Capacity                    11.4 MED             23,0 MGD
Waste Water Flows
      Cranston                   10.04 MGD            20.1 MGD
      Ciba-Geigy                 1.25 MGD             1.8 MGD
      R.I.S. Inst.               1.13 MGD             1.1 MGD

BODc Content                     1,630                1,840  13% inc.
               Why a 46% increase in per capita wastewater
               discharge?(Based on 68k at 10.04 and 93k at
               20.1 MGD, or from 14.7G GPP to 216 GPP.  Re-
               ference is also made to the R.I. Development
               Council, Fenton Keyes Associates, pp. 25-27
               estimate of 155 GPP/day).

               P.5 map: - has adequate consideration been given
                          to servicing the Phenix Ave-Natick Ave.
                          Brgokfield Hills areas of Cranston by
                          the new expanded West Warwick Pollution
                          Control Facility?   Where pollution
                          control facilities have been heavily
                          federally-funded should not geographical
                          rather than municipal boundaries be
                          given prime consideration?

               P.7,
               P.43-44    "The expansion of economic base....
                          significantly increases the supply of
                          fully serviced industrial land....
                          substantially persistant unemployment.
                          The writer submits that the Providence
                          area has experienced substantial and
                          persistant unemployment not because
                          of a lack of fully serviced industrial
                          land but in spite of the same.  The
                          Howard Industrial Park is notably un-
                          successful following considerable in-
                          vestment of R. I. taxpayers dollars.
                          Should we spend more dollars to compete
                          with ourselves?

                          Testimony before the Cranston City
                          Council within the last month has given
                          specific reasons why more preferred
                          industrial locations lie beyond the
                          city limits.   (Leesona, Brown & Sharpe,
                          and BIF did not opt for available sites
                          in Cranston.

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                The current efforts of the State of
                R. I. to develop surplus government
                facilities  appear to offer best results
                at minimum investment of taxpayer monies.
                The relocation of minor industries within
                the state to Western Cranston would not
                represent a net economic gain.  The need
                for more fully serviced industrial land
                should be substantiated - not assumed -
                in the Final EIS.

P-8 (ii)        Adverse effects can be avoided if their
                causes are not created unnecessarily.

P.10 (iv.)      The last sentence of the second paragraph
                "If and when....for high yeiids" is cited
                as an example of non-essential and
                non-contributory comment which will
                hopefully be eliminated from the Final EIS.

P.28-34         The general tenor of the "Suitability for
                Urbanization" section is expressed in the
                last paragraph of P.33 and first paragraph
                of P.34.  The optimistic statements in
                these sections ignore such realities as:

                1.  The 1970 Census ranks R.I. 46th of 50^
                states in % population growth since 1920.
                (only W.Va., Penn., Ala. & Me. fared worse).

                2.  Conference Board projections through
                1985 drop R.I. to 38th based on a 12.3%
                growth rate from 1970 on - however -

                3.  The U.S. Bureau of the Census now
                reveals R.I. as one of 2_ states which
                have lost population since 1970.

                4.  R. I. has a chronic, but carefully
                calculated, unemployment problem.  It will
                not be solved by creating industrial sites
                at taxpayer expense in rural areas which
                hold little hope of occupancy.

                5.  R. I., is limited by remoteness from
                markets, natural industrial resources,
                fuel prices and rail and highway systems
                in the types of industry it could attract.

                6.  The only strong point made is one of
                ample water supply which might attract
                industries requiring high water usage
                (e.g. textile, paper or chemical such as
                Ciba-Geigy).  We note the expansion capacity

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             of the proposed facility would be hard
             pressed to accommodate a high water
             usage type industry.

P.43-44      Again the EIS conclusions defy published
             projections of the U.S. Bureau of the
             Census/ the R. I. Statewide Planning
             Commission, the Conference Board and
             actual history.

             The writer suggests the Cranston has not
             been viewed as a "least sprawl alternative"
             by industry or population.

             It has been noted that between the last two
             U.S. Census periods, when 5 of R.I.'s older
             cities lost population, Cranston ranked
             32nd of 34 remaining communities in %
             growth (out ranking only Burrilville and
             New Shoreham  (Block IslandyT

             Current porjections (cited at the 18 Nov.,
             1976 hearing) indicate the R.I. State
             Planning Commission does not share the EIS
             optimism.

P. 50-53     (Maps) - we note
             1.  The towns of Coventry and West Warwick
             meet water quality standards downstream of
             the outflows of the American Hoechst Corp.
             chemical plant and the West Warwick Pollu-
             tion Control Facility.  Why is this quality
             lost in Cranston?   (Note:  American Hoechst
             maintains and paid for a separate facility) .

P. 59
Table III-4
             1.  To amplify earlier comments  (above) we
             feel no substantiation is given for a 100%
             increase in cranston Wastewater flows.

             2.  The total present population of census
             tracts 145 and 146  (which are to be not
             100% sewered in the expansion) is only
             slighly in excess of 10% of the city's
             population.  Even your most optimistic
             projections of forced or created growth
             would make  (or hope to make) the total
             population of these two tracts 11,856

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                         by the year 2000.  A less than 20%
                         addition to the present load.  Granting
                         this improbability and expanding it
                         into your unsubstantiated projection
                         of service to 36.7% more people, we
                         seek clarification of the 100% projected
                         wastewater flow increase.

                         3.  The R.I. State Institution projection
                         is incbnsistant with its population trends
                         and projections.

                         Current thinking and policies of involved
                         social agencies seek alternatives to in-
                         stitutionalization.  A R. I. State Insti-
                         tution Population Projection should be
                         included in the FINAL EIS.

           P. 86         Alternative Disposal Sites - it would appear
                         that the use of the Gammino Quarry as a
                         landfill site could restore the city's major
                         eyesore to an area of foliage similar to
                         reclamation of southern strip-mined areas.

           Chap. VI      The recent history of "progress" in Western
                         Cranston has been one of disregard for en-
                         vironment - e.g. - the soil-stripping_c)f__
                         acreage between Natick Avenue—and Interstate
                         295 to transform recent farmland to a
                         motorcycle and mini-bike pit - the land
                         filling of the brook bounding Cranston and
                         West Warwick (which was purported to be a
                         Green Acres protected area with area tree
                         cutting prohibited).

                         The present creation of a plat between
                         Natick-Wilbur and Rte. 295 in an area
                         purported as not suitable for homes which
                         an attempt was made earlier this year to
                         re_zone as an apartment site.

           P.150-6.32
           to quote 6.32 I)"....they can be very wrong".  Table Vl-3
                         proves the statement.
SUMMARY:
     1.    Rejuvenation of the present facility is necessary and
          desirable.

     2.    Retention of the Ciba-Geigy plant is essential and should
          be accommodated on an equitable basis.

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     3.    Absorption of the T.I. State Institution facility should
          be state funded based on realistic projections of insti-
          tutional population.

     4.    It should be the purpose of the EIS FINAL REPORT to
          suggest a facility to cope with an expected requirement;
          it should not be the purpose of the report to create~"a
          situation which would justify the expanded facility."

     5.    It is requested that the FINAL EIS be witheld pending
          new and more realistic projections of city and insti-
          tutional populations.  These projections would form the
          basis for both the expansion of Wastewater Collection and
          Treatment Facilities and a new Comprehensive Land Use
          Plan.

It is hoped the above comment will receive consideration and action
prior to issuance of the FINAL EIS.  Thank you for the opportunity
to offer comment.

Very truly yours,

/s/ Robert A. Flynn, Sr.


Robert A. Flynn, Sr.
605 Natick Avenue
Cranston, Rhode Island 02920

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Cranston Plant
CIBA-GEIGY Corporation
P 0. Box 2055
Providence. R.I. 02905
Telephone: 4O1 941 3000

Shipping Address:
180Mill Street
Cranston, R.I.
CIBA-GEIGY
                                    December 16,  1976.
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
Region I, J. F. Kennedy Building
Boston, Massachusetts.  02203

RE:  Cranston, R. I. Wastewater Collection & Treatment
     Facility Plan, and Environmental impact Statement.

Dear Mr. McGlennon:

         The draft Environmental Impact Statement  (EIS)
prepared by C. E. Maguire, Inc. and the draft Wastewater
Facility Plan for the City of Cranston prepared by Universal
Engineering, Inc. have been reviewed by CIBA-GEIGY Corporation.
We wish to compliment each group for the quality and  timeli-
ness of its efforts in completing this phase of the project on
schedule.

         The recommended treatment alternative in  the facility
plan based on the two-stage activated sludge nitrification
process with effluent filtration has been piloted  by  CIBA-GEIGY
in a six month study costing nearly four hundred thousand dollars
The results of the pilot demonstration show that effluent from
this system will meet all anticipated discharge requirements.
We, therefore, concur with the conclusion of Universal Engineer-
ing and recommend that the two-stage activated sludge nitri-
fication process with effluent filtration be approved.

         Approval of this project is in the best interest of
the people of Rhode Island, the City of Cranston and  local
business and industry.  First, the water quality of the
Pawtuxet River will be protected by a new, highly  efficient
effluent system.  Secondly, the City of Cranston will have the
new system it requires at the lowest possible cost since

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Mr. John A. S. McGlennon
(continued)
-2-
industries like CIBA-GEIGY will pay their share of the
expansion and the operation of the plant.  In addition,
local jobs will be protected and expanded as business
and industries find the cost-effective wastewater
treatment alternatives they require.

         Thank you for the opportunity to comment on
these draft reports.  We welcome any comments you have
concerning our responses and we will be happy to answer
any questions you may have regarding them.
                                    Sincerely yours,
                                      m Simas
                                   Plant Manager
 js/jcv
cc:  C. E. Maine, Assistant Director
     Environmental Health
     R. I. Department of Health

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               UNIVERSAL    ENGINEERING    CORPORATION
                             100   BOYLSTON  .STREET
                               BOSTON,  MASS. 02116
                                MEMORANDUM
 From:__._Pi.E. ________ _ _____ _ __   Date:
            E1S Comments fron» EPA office of Water Program Operations
      The below responds  to  the comments of the EPA Office of Water Program Operations
dated 12/3/76 on the EIS to the Cranston Facility Plan but only as these  comments
relate to the Facility Plan itself.

      1-3.  No comment necessary

        4.  The relationship of the existing treatment plant and the expansion
            proposed in the  Facility Plan to the 100 year flood area are discussed
            in the Facility  Plan on pI-45.  Briefly, the plant is protected from
            the 100 year  flood.

        5.  Part V of the Facility Plan discusses the weighing and selection of the
            most beneficial  alternative.  Part III discusses costs of the various
            alternatives  including the discharge to the Providence River estuary.

        6.  City growth management policy for western Cranston has outlined that
            development be confined as much as possible to contiguous urban areas.
            The configuration of interceptors shown in EIS Fig. 1-4 is based on
            this policy.  Population projections developed preliminary to the
            Facility Plan indicates that the basins immediately west of  1-295, those
            to be sewered, will be saturated or nearly so well within the 30-50 year
            horizon for interceptor pipelines.

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             UNIVERSAL   ENGINEERING    CORPORATION
                           100   BOYLSTON  STREET
                             BOSTON, MASS. 02116
                             MEMORANDUM
TO'___Jii«	   Job:

 From:.Jl:£'	   Dotr

 Subtact  EIS Coiranents from HUD


     The below responds to  the comments of the U.S. Dept.  of Housing and Urban
Development (HUD) dated 12/3/76 on the EIS to the Cranston Facility Plan but only
as these comments relate to the*Facility Plan itself.

     1.  Noise abatement measures will be incorporated in  the design of the
        treatment plant.

     2.  As mentioned in the Facility Plan (p,IV-18) the City is aware of the
        potential need for recreation and open space land in western Cranston.

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             UNIVERSAL    ENGINEERING    CORPORATION
                           100   BOYL3TON  STREET
                             BOSTON,  MASS. 02116
                              MEMORANDUM

                             ........   Job:	,„
From;	D.JJ	

              Comments from RI Historical  Preservation Commission
    The below responds  to the comments  of the R I Historical Preservation
Commission dated 12/6/76 on the EIS to the Cranston Facility Plan but only as the
comments relate to the Facility Plan itself.

    The City is in the  process of conducting a drainage, erosion and sedimentation
control study.  One of the purposes of this study is to propose methods to minimize
off-site impacts of storm runoff.  The protection of the Furnace Hill Brook ravine
is a concern in this study.  The interceptor shown in the Facility Plan as placed
within the ravine will be relocated outside it to minimize harm to this scenic and
historic area.

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              UNIVERSAL    ENGINEERING    CORPORATION
                             100   iOYLSTON  STREET
                               BOSTON, MASS. 02II«
                               MEMORANDUM
To= ____ Jilsa. _________________   Job:
 From: ___ D.E. __________________   Date: ______ L2Z2JZ7.S
        '   EIS Comments b7 the Cranston Conservation Commission
     The below responds  to  the comments of the Cranston Conservation Commission
dated 12/14/76 on the EIS to  the Cranston Facility Plan but only as these comments
relate to the Facility Plan itself.

     The City is in the  process of conducting a drainage, erosion and sedimentation
control study.  One of the  purposes of the study is to propose regulations to minimize
off-site storm runoff.  Another is to recommend structural methods to attentuate  storm
runoffs to downstream areas,

     Regarding the concern  for urban development vs agricultural uses, it is a matter
which transcends local boundaries and involves forces existent without the proposed
project.  It is also not an either/or situation.  Land use control mechanisms are
being developed whereby  agricultural land can be conserved and urban development
can still take place. Sewering a portion of western Cranston does not necessarily
mean the death-knell of  agriculture throughout western Cranston.  By sewering a
portion of western Cranston,  urban sprawl otherwise more consumptive of rural land
is concentrated closer to existing City services,  tending to relieve growth pressures
on outlying areas.  About half of western Cranston will not be served by sewerage until
after the year 2000.  Certainly long before that,  mechanisms can be implemented to
conserve agricultural land  worthy of such protection,

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              UNIVERSAL   ENGINEERING     CORPORATION
                             100   BOYLSTON  STREET
                               BOSTON,  MASS. 02116
                                MEMORANDUM

TO'	"£1.	   job:	7516	

From:	.DiE«	   Date:	l*L2*!21.
               Comments  from Ecology Action
     The below responds to the comments of Ecology Action for Rhode Island, Clean
Water Committee, dated 12/22/76 on the EIS to the Cranston Facility Plan, but only as
these comments relate to the Facility Plan itself.

     A.  General Comments

         1.  No comment
         2.  The Facility Plan treats these points in Part II Section B, Land Use.
         3.  No comment
         4.  No comment
         5.  The City's sewer use ordinance is currently under study and a new
             ordinance is being prepared.  Pre-treatment will be  required of certain
             industries.  (Pass throughs ?)
         6.  The striking of a balance between urban development  and agricultural
             land transcends local boundaries and until of late,  was not generally
             thought of as a serious problem.  Several mechanisms are possible, for use
             today, others are still evolving, but many- are not possible in Rhode
             Island due to lack of enabling legislation.  The State itself does not
             strongly address this issue in the State Guide Plan.

         7.  Fig V-7 of the Facility Plan shows protection of the incinerator ash
             disposal cells from flooding.  Disposal will be done inside of embank-
             ments, the tops of which are above 100 year storm flood levels.

      8-10.  No comment

     B.  Page-By-Page Notations
                                          t

       1-2.  No comment
         3.  Some overloading particularly during high groundwater does occur.
       4-5.  No comment
         6.  208 has not begun its sludge management planning studies.
         7.  It is not clear that comparisons with existing zoning would show any
             meaningful relationship since the basins adjacent to 1-295 are to be
             rezoned for uses consistent with the City's Comprehensive Plan.
             A comparison with the Comprehensive Plan shows coterminous urbanized
             and sewered areas contiguous to existing urban development.  The State
             Guide Plan is not fine grained enough at the intra-conmunity level  to provide
             for a meaningful comparison for the area to receive  sewerage in Cranston.
         8.  Dwellings on Pawtuxet Neck do not receive City sewerage service.

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    9.   See A2  previous.
    10.   Regionalization as  an alternative is implied.
    11.   No comment
    12.   If the  City of Cranston were to construct  such impoundments,  it would of
         course  assume maintenance for same.   No locations have been proposed by the
         Facility Plan,
13-14.   NO comment.
    15.   Multiple use of interceptor right-of-ways  will be considered.
         Undisturbed right-of-way between the mowed safety zone and right-of-way
         fence does act as a habitat for many wildlife  species,
    16.   No comment
    17.   Sludge  or ash disposal would not have more than a local impact  by any
         parameter.  Direct  environmental impacts such  as leaching,  odors etc.
         could be effectively dealt with.   Indirect impacts such as  trucking  to
         a particular site could be minimized but might in certain cases be an
         adverse traffic or  noise impact of a local nature centered  on the disposal
         site  itself.
 18-21.   No comment
    22.   In 1975, it had been reported that the State of Rhode  Island had actually
         lost  population since 1970.  It is quite likely that this was due to  the one-
         time  "shock" withdrawal of military  and support  personnel and their
         dependents which left the State with a net-emigration  for the 1970-75 period.
23-29.   No comment.
    30.   Yes.
    31.   Out-of-basin discharge to the Providence River estuary eliminates the need
         for tertiary treatment.   Maintaining advanced  treatment serves  no purpose for
         discharge to the Providence River,
    32.   In view of the project's time frame  and need for a committed effluent dis-
         charge  (not one based on proposals),  the use of treatment plant effluent
         as agricultural irrigation in Cranston or  anywhere in  Rhode Island is not
         realistic.
    33.   NO Comment
    34.   The ash landfill will be sufficient  to the year 2000.
    35.   Incinerated heavy metals become oxidized.
    36.   NO Comment
    37.   The emissions  given in Table  IV-4 meet EPA regulations,  It would  be a
         questionable use of scarce resources  to further  attempt to  reduce emissions.
38-41.   No comment
    42.   The Facility Plan analyzed costs of  solids  handling and disposal  and  the
         data is  contained in  Tables III-30 to  33.
    43.   Part V of  the  Facility Plan p. V-47 and 48   contain the  information desired.
    44.   The entire project  is  geared  to a particular time  schedule.  Alternatives
        which most cost  effectively achieve  the desired  standards within  the time
         schedule with  minimum adverse  environmental effects shall be selected.
    45.   Selection  of an off-site  sanitary landfill  may subject  the  City to uncontrolled
         cost escalations , and uncertainties  if the landfill violates  the conditions
        of its license.
    46.  No comment.  This is  a proposal of the EIS.
    47.  No Comment
        In reference to the proposed park, this is  a matter  for the City  to pursue.
    48.  No Comment
49-58.  No comment
    59.  Decisions  to provide utilities and the placement  thereof  are "standard
        and prudent" tools  to manage urban development.
   60.  No comment.

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   61,   See Facility Plan Part I Section A9 Water Resources,  specifically
        p,  1-50, the second paragraph.
   62.   See Facility Plan Part III Section C Alternative Waste Treatment Systems.
63-76.   No comment.

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               UNIVERSAL    ENGINEERING    CORPORATION
                             100   BOYLSTON  STREET
                               BOSTON,  MASS. 02116
                                MEMORANDUM
                                              Job:

                                              Date;
 SubitCt>Robert F1ynn Comments on EIS
     The following responses  reply to the comments of Robert  Flynn on the EIS.

I General                      ,
     Mr. Flynn overemphasizes  the difference between the Facility Flan (EIS)
population projection for the  year 2000 and the R I Statewide  Planning Program (RISPP)
projection by saying that there  is a "difference of over 20% in population increase."
What also must accompany that  statement is that the "20% difference" equals only
3000 people.  Considering that the base by that year is almost 100,000 people
(93,400 vs 96,757), this is  quite acceptable.  Thus the discrepancy is actually 3%.

II Specific

     The calculated  increase  in per capita wastewater discharge is incorrect.  A
correct version of the table would be:
Pop Served
Pit. Capacity
Waste Water Flows
            Cranston
            Ciba-Geigy
            R.I.  S.Inst.
            Howard Ind. Park
1975
68,000
  11.4 MGD

  11.5*MGD
     0  "
     0  "
     0  "
2000
93,000
   23.0 MGD

   18.7 MGD
    1.8  "
    1.1  "
    1.4  "
1975 per capita wastewater  =11.4 MGD/68,000 = 169 gpd
2000 per capita wastewater  =  18.7 MGD/93,000 = 201 gpd

This is a 19% increase.
*Note that the plant   design  capacity is exceeded by the flow generated by the 1975
population.

Tables II-7  and II-8  in  the Facility Plan contain the wastewater  flow projections upon
which the above figures  are based.

     Mr. Flynn must be aware  that the per capita wastewater discharge figure includes
development  of the Howard Industrial Park, other industrial growth  and domestic flow
increase, all on a design flow basis.  It is not knov.-n whether tho  cpi"pnrison flTiirc
he quotes is a design flow  figure or an average flow figure.
     West Warwick was  consulted and expressed an interest only  in  sliu'.go

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     The Howard Industrial Park has lacked sewerage service until recently.

     It is not known why Leesona, Brown and Sharp and BIF did not locate  in
Cranston.

     Cranston had a low rank  in percent increase in population because of its  large
base, (second only to Warwick of  the  communities that gained population between  1960
and 1970).  While five of RI's other  cities may have lost population according to
Mr. Flynn, Cranston continues to  grow faster  than the State since 1900 and faster
than the Providence SMSA since 1950 and will  soon become RI's third largest  city
behind Providence and Warwick. Only  Middletown, Warwick, and North Kingstown  gained
substantially more than Cranston  in absolute  terms between  1960  and 1970.  Cumberland
gained slightly more.  In other words, of  the large communities  in R I with  a  large
population increase, only Warwick surpassed Cranston.
      (Re:  page 4 of letter)  The expansion of the wastewater treatment plant
 increases the capacity for industrial wastewater from 2.2 MGD to 7.7 MGD (design
 flow.)   This capacity could service some high water-usage type industry.

      The Gatnmino Quarry can be re-used in a more suitable manner than as a
 landfill, with its visibility from and access to an Interstate highway.

      The instances cited in "disregard for the environment" cited by Mr. Flynn in
 Western Cranston are regulated by the City's Zoning Ordinance, R I Freshwater Wetlands
 Act and the City's Subdivision Regulations respectively.
                                                  Routing
Initial
Copies
                                                D, E. N.
                                                VV. A H.
                                               JRJ1. M.
                                                n. • n.
                                               J.A.Z.

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61.  See Factlity Plan Part I Section A9 Water Resources, specifically

     p. 1-50, the second paragraph.


™*  wee Facility Plan Part I" Section C Alternative Waste Treatment Systems
76.  No comment.

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               UNIVERSAL    ENGINEERING    CORPORATION
                             100   BOYLSTON  STREET
                               BOSTON,  MASS. 02116
                                MEMORANDUM
To= —
 From-.
us

 Flynn Comments on EIS
                                              Job:
                                              Dote;
     The following responses reply to the comments of Robert Flynn on the EIS,

I General                      »
     Mr. Flynn overemphasizes the difference between  the Facility Plan (EIS)
population projection for  the year 2000 and the R I Statewide Planning Program (RISPP)
projection by saying that  there is a "difference of over 20% in population increase."
What also must accompany that statement is that the "20% difference" equals only
3000 people.  Considering  that the base by that year  is almost 100,000 people
(93,400 vs 96,757),  this is quite acceptable.  Thus the discrepancy is actually 3%.

II Specific

     The calculated  increase in per capita wastewater discharge is incorrect.   A
correct version of the table would be:
Pop Served
Pit. Capacity  x
Waste Water Flows
            Cranston
            Ciba-Geigy
            R.I.  S.Inst.
            Howard Ind. Park

1975 per capita wastewater
2000 per capita wastewater
                                 1975
                                 68,000
                                   11.4 MGD

                                   11.5*MGD
                                      0  "
                                      0  "
                                      0  "
                                                                 2000
                                                                 93,000
                                                                    23.0 MGD

                                                                    18.7 MGD
                                                                     1.8  "
                                                                     1.1  "
                                                                     1.4  "
              11.4 MGD/68,000 =  169 gpd
              18.7 MGD/93,000 =  201 gpd
This is a 19% increase.
*Note that the plant   design capacity is exceeded  by  the flow generated by the 1975
population.

Tables II-7  and II-8  in  the Facility Plan contain  the wastewater flow projections upon
which the above figures  are based.

     Mr. Flynn must be aware that the per capita wastewater discharge figure includes
development  of the Howard Industrial Park, other industrial growth and domestic flow
increase, all on a design flow basis.  Tt is not known whether the comnnrison figure
he quotes is a design flow figure or an average flow  figure.
     West Warwick was  consulted and expressed an interest only in sludge disposal.

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     The Howard  Industrial Park has lacked sewerage service until recently.

     It  is  not known why Leesona, Brown and Sharp and BIF did not locate in
 Cranston.

     Cranston had a low rank in percent increase in population because of its large
 base,  (second only to Warwick of the communities that gained population between 1960
.and 1970).   While five of RI's other cities may have lost population according to
 Mr.  Flynn,  Cranston continues to grow faster than the State since 1900 and faster
 than the Providence SMSA since 1950 and will soon become RI's third largest city
 behind Providence and Warwick.  Only Middletown, Warwick, and North Kingstown gained
 substantially more than Cranston in absolute terms between 1960 and 1970.  Cumberland
 gained slightly more.  In other words, of the large communities in R I with a large
 population increase, only Warwick surpassed Cranston.
       (Re:   page 4 of letter)   The expansion of the  wastewater  treatment plant
  increases  the capacity for industrial wastewater from 2.2 MGD  to  7.7 MGD  (design
  flow.)   This  capacity could service some high water-usage type industry.

       The  Ganunino Quarry  can  be  re-used  in  a  more suitable manner than as a
  landfill,  with its visibility from and access to an Interstate highway-

       The  instances cited in  "disregard  for the environment" cited by Mr. Flynn in
  Western  Cranston are regulated by the City's  Zoning Ordinance, R  I Freshwater Wetlands
  Act and  the City's Subdivision Regulations  respectively.

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   61.   See Facility Plan Part I Section A9 Water Resources,  specifically
        p. 1-50, the second paragraph.
   62.   See Facility Plan Part III Section C Alternative Waste Treatment Systems.
63-76.   No comment.

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              UNIVERSAL    ENGINEERING    CORPORATION
                             100   BOYLSTON  STREET
                               'BOSTON.  MASS. 02116
                                MEMORANDUM
TO:	

 From-.. J£_* J«s	

 Subi§Ct-R°kert F^ynn Comments on EIS
Job:
Dote: _____ Jte££Bt££.2Q— 1326. ---
     The following responses reply to the comments  of Robert Flynn on the EIS.

I General                      ,

     Mr. Flynn overemphasizes the difference between the Facility Plan (EIS)
population projection for  the year 2000 and the R I Statewide Planning Program  (RISPP)
projection by saying that  there is a "difference of over 20% in population increase."
What also must accompany that statement is that the "20% difference" equals only
3000 people.  Considering  that  the base by that year is almost 100,000 people
(93,400 vs 96,757), this is quite acceptable.  Thus the discrepancy is actually 3%.

II Specific

     The calculated  increase in per capita wastewater discharge is incorrect.  A
correct version of the table would be:
Pop Served
Pit. Capacity
Waste Water Flows
            Cranston
            Ciba-Geigy
            R.I.  S.Inst.
            Howard Ind. Park
  1975
  68,000
    11.4 MGD
    11.5*MGD
      0  "
      0  "
      0  "
2000
93,000
   23.0 MGD

   18.7 MGD
    1.8  "
    1.1  "
    1.4  "
1975 per capita wastewater =  11.4 MGD/68,000 = 169  gpd
2000 per capita wastewater =  18.7 MGD/93,000 = 201  gpd

This is a 19% increase.
*Note that the plant   design  capacity is exceeded by  the flow generated by the 1975
population.

Tables II-7  and II-8  in  the Facility Plan contain the wastewater flow projections upon
which the above figures  are based.

     Mr. Flynn must be aware  that the per capita wastewater discharge figure includes
development  of the Howard Industrial Park, other industrial growth and domestic flow
increase, all on a design flow basis.  It is not known whether tho compnrison figure
he quotes is a design flow figure or an average flow  figure.
     West Warwick was consulted and expressed an interest only in sludge

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     The Howard Industrial Park has lacked sewerage service until recently.

     It is not known why Leesona, Brown and Sharp and BIF did not locate in
Cranston.

     Cranston had a low rank in percent increase in population because of its large
base, Second only to Warwick of  the communities that gained population between 1960
and 19^P .  While five of RI's other cities may have lost population according to
Mr. Flynn, Cranston continues to  grow  faster than the State since 1900 and faster
than the Providence SMSA since 1950 and will soon become RI's third largest city
behind Providence and Warwick.  Only Middletown, Warwick, and North Kingstown gained
substantially more than Cranston  in absolute terms between 1960 and 1970.  Cumberland
gained slightly more.  In other words, of the large communities in R I with a large
population increase, only Warwick surpassed Cranston.



      (Re:   page 4 of letter)  The expansion of the wastewater treatment  plant
 increases the capacity for industrial wastewater from 2.2 MGD to  7.7  MGD (design
 flow.)  This capacity could service some high water-usage type industry.

       The  Gammino Quarry  can be  re-used  in  a more  suitable manner than as a
 landfill,  with its visibility from and access  to an Interstate highway.

       The  instances cited in "disregard  for the  environment"  cited by Mr. Flynn in
 Western Cranston are regulated by the City's Zoning Ordinance, R I Freshwater Wetlands
 Act and the City's Subdivision Regulations  respectively.

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