ALTON • ASHLAND • BELMONT BROOKFIELD • CENTER HARBOR- FRANKLIN -GILFORD •
FINAL PLAN/EIS F
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PUBLIC COMMENT
APPENDIX
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LAKES REGION
WATER QUALITY
MANAGEMENT PLAN
SEPTEMBER 1978
WOLFEBORO • WAKEFIELD • TUFTONBORO-TILTON • SANDWICH-SANBORNTONOSSIPEE
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PUBLIC COMMENT APPENDIX
LAKES REGION WATER QUALITY MANAGEMENT PLAN
Table of Contents
A. Local Letters of Endorsement
B. Comments
1. Local and Regional 19-57
2. State 58-73
3. Federal 74.35
C. Response to Comments 86-96
Introduction
This report has been printed as an Appendix to the Final Lakes Region
Water Quality Management Plan/EIS.
Contained in this report are: (1) letters of support from communities
within the 208 planning area indicating their willingness to work towards
implementation of the recommendations made in the Plan; (2) all written comments
received as a result of the distribution of the Draft Plan/EIS; and (3) a res-
ponse to comments section which indicates the effect each comment had upon the
content of the Final Plan.
A great many verbal comments were also received on the Draft Plan, both
from the general public and, more particularly, from local officials in the
communities involved. Meetings were held with each community to review the
content of the Draft Plan/EIS and to receive comments. It would have been
impossible to list all the verbal comments in the comments section of this
report. However, each comment was considered and has been reflected in the
content of the Final Plan/EIS.
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A. Local Letters of
Endorsement
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Alton Conservation Commission
Alton, New Hampshire 03809
June 6, 1978
Mr. John L. Dickey
Lakes Region Planning Commission
Main Street
Meredith, New Hampshire 03253
Dear Mr. Dickey:
The three members of the Alton Conservation Commission who attended
your presentation in Alton June 1 of the Draft Lakes Region Water
Quality Management Plan were astounded at how much the local community
can do to protect our water quality.
At our regular monthly meeting, June 5 we agreed that we would like to
have you, or another representative from your office, meet with our
commission with an eye towards either drafting some environmental
ordinances for Alton and/or working on an index of priority areas
in the town.
Since we feel that to have anything valid for the next March town
meeting we should start our work now, we would appreciate having from
you one or two possible dates for meeting either the end of July or
the first part of August.
Looking forward to hearing from you.
J$ne F. Sanders (secretary)
]*br the Conservation Commission
cc
/jt
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i/zfand
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OFFICE OF SELECTMEN
BELMONT. NEW HAMPSHIRE 03220
TELEPHONE 267-B14S
September 20, 1978
Mr. Michael P. Holan
Lakes Region Planning Commission
Humiston Building, Main St.
Meredith, NH 03253
Dear Mr. Nolan:
Concerning your comprehensive Water Quality Management
Plan as discussed with the Board of Selectmen on June
12, 1978, this letter will serve to inform you that the Town
basically concurrs with your findings and these recommen-
dations will provide us with long term guidance as we
address these problems.
The Board of Selectmen have indicated a genuine concern
of these problems and we anticipate presenting some of them
to the voters in March.
Sincerely yours,
a'ilip M. Tarr
Administrative Assistant
PMT/pah
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PLANNING BOARD
BROOKFIELD, N.H.
03872
August 30, 1978
Mr. Daniel E. Martin
Executive Director
Lakes Region Planning
Commission
Main St.
Meredith, N. H.
Dear Mr. Martin,
I nave received your letter of the
23rd and the final recommendations for Brookfleld under
the Commission's 208 Water Quality Management Project.
When Mr. Nolln attended one of our meetings In the
early summer the Board was In agreement that these re-
commendations were desireable goals.
We have taken steps to accomplish some of the tasks;
at the present time we are in the middle of adopting
a health ordinance including local control and approval
of septic system design and Installation. We recommend
that the Plan be adopted by th EPA.
.< .-•
x2obtert Hi-kjharnock
Chairman
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CENTRE HARBOR PLANNING BOARD
BOX 140
Centre Harbor
N. H.
03226
October 3, 1978
Mr. John Dickey
Lakes Region Planning Commission
Humiston Building
Meredith, New Hampshire
Dear Mr. Dickey,
On behalf of the Planning Board, we would like to express our support
for the Lakes Region Water Quality Management Plan and particularly to
those sections relating to the Town of Centre Harbor. We believe the
work to develop the plan was well done and we will attempt to implement
the Centre Harbor recommendations as soon as possible.
Very truly yours,
k
Centre Harbor Planning Board
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CITY OF FRANKLIN, NEW HAMPSHIRE
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03235
OPFICC Of PLANNING BOARD
August 23, 1978
Lakes Region Planning Commission
Main Street
Meredith, NH 03253
ATT: Mr. John L. Dickey
Regional Planner
Dear 'John:
The Franklin Planning Board voted at its regular'
meeting of August 22, 1978 to approve the draft 208 Water
Quality Management Plan including the changes arrived
at during the June 28, 1978 meeting of the Board and
yourself.
The Board again stressed the importance of construc-
tion of a sev/er around the area of Webster Lake as a
prime concern to the area's water quality.
Sincerely,
Erank Sdmunds
Vice Chairman
FE/kal
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..^•A
Gilmanton Planning Board 1
Box 152
Gilmanton, W.E. 03237
June 9, 1978
Lakes Region Planning Commission
14ain Street
Meredith, New Hampshire 03253
Jear S irs i
At our regular monthly meeting on June 8th, Planning
Commission member John Dickey reviewed with us the recommendations
and goals for our town as stated in the Lakes iiegion Water
quality Management Environmental Impact Plan.
Many of the recommendations are ones with which we will
be concerned in the work towards the formulation of a Master
Plan for Gilmanton, an undertaking which we are just now
beginning. Consequently, it was the consensus of the Board
that we support the concept of your plan and will be willing
to try to work towards its objectives.
Sincerely,
Anne H. Onion
Secretary, Gilmanton
Planning Board
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8
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HOLDERNESS, NEW HAMPSHIRE O3245
August 2?thf 1978
Mr. John Dickey
Lakes Region Planning Commission
Huniston Bldg
Meredith, K.H. 03253
Dear Mr. Dickey:
I have to humbly apologize for the tardiness in writing to you to thank you, and
make comments, as you requested, on your presentation when you came to Holderness
several weeks ago* I have a "back" that on occasion puts me absolutely flat
in bed, and is exceedingly painful to the least movement* Such has been the fact
for much of the summer, and it is only now that I am able to sit at my desk to
"push a pencil" and see an occasional emergency patient. My desk is filled with
overdue correspondence, etc, so that I scarcely know where to begin.
The group did enjoy your presentation, and though our group is not talkative,
displaying enthusiasm, etc* I am sure that there was practically none other than
unanimous agreement that the #2 alternative is the path for Holderness to follow,
that of making a study of our needs, and busy ourselves with plans and measures
to control growth in our town and in the region, and thus preserve and protect the
beautiful assets that nature has bestowed upon this lake and mountain region.
There are a few who seem to be of an attitude of "letting George do it1* , or it is
0 K to make sure that ray neighbor abides by the regulations that have been
promulgated, but would like to perhaps pull the shades and "let me*1 by if it is
my property that is involved*
Largely it is a matter of education that is our greatest need. So I am sure that we
will be glad to be directed and have the privilege of consulting the Commission, and
with some guidance start "tolling the bellllmore rapidly and efficiently.
I am sure that there are but very few who wants to "do nothing", and in conversation
with many, find them not desirous of municipal sewage, and a dwelling on every small
plot of land.
I wonder if the Commission has any guidance data that shows the successful pursuit
of other communities who have succeeded in the control of growth, etc* that has
proved advantageous (for these communities). Most communities are different,
yet have similar problem situations that can be guided in one manner or another.
Once again my apologies for this delayed message . I hope to be back "in the ball
game" shortly, '
Since
Lawrence M* Staples, D*M*D«
Chairman, Holderness Planning Board IMS/ows
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^Planning
HOl,DERNESS, NEW HAMPSHIRE 03245
August 30th, 1978
Mr. John Dickey
Lakes Region Planning Commission
Humiston Bldg
Main St-
Meredith, N H 03253
Dear Mr. Dickey:
I just read over the carbon copy of the letter that I wrote you a day or two ago,
and I wrote that there was unanimous agreement that the Plan # 2 alternative was
the path that Holderness would wish to follow, when I should have written # 3
I think I did, in the next line or two, go into a/bit of detail by saying that
making a study of our needs, and busying ourselves with plans and measures to
control growth, etc. which I believe was listed as # 3 alternative and not #2
Count us in the # 3 category, and not # 2
I certainly was not in favor of a municipal sewage system, etc*
Sincerely,
___
Lawrence'M Staples, D-M.D.
Chairman, Holderness Planning Board
P.S. I neglected to state in my recent communication that Holderness Solid
Waste Problem was "cared for" early last simmer or late spring. A compactor
system has been installed, and the container is changed as often as necessary.
L»M«S»
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10
CITY OF LACONIA, NEW HAMPSHIRE 03246
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OFFICE OF: PLANNING DEPT.
September 15, 1978
Mr. John Dickey
Lakes Region Planning Commission
Box 302
Meredith,-New Hampshire 03253
Dear Mr. Dickey:
RE: 208 Water Quality
The Laconia Planning Board wishes to thank you for your kind
offer of assistance concerning the proposed ordinances for
208 Water Quality Study. The Board was impressed with the
data compiled in your report and has instructed me to examine
the proposed ordinances and make whatever modifications I
feel necessary to make them applicable for the City of
Laconia.
In the past, we have shared a feeling that many of these
regulations are necessary, however, lack the supporting
information to justify their existence. Through your work,
we have been supplied with the necessary data and so can press
forth.
Again, thank you very much for your cooperation.
Very truly yours,
^Peter BTHance
PBH:rh Director of Planning
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Telephone | |
603-279-4538
TOWN OF MEREDITH
MUNICIPAL OFFICE BUILDING
MEREDITH, N.H. 03253
June 15, 1978
Mr. Michael Nolan
Lakes Region Planning Commission
Humiston School Building
Meredith, New Hampshire 03253
\
Dear Mike:
I would like to take this opportunity to express the gratitude
of the Town of Meredith for the effort expended in development of
the Lakes Region Water Quality Management Plan and Environmental Im-
pact Statement.
I feel that the Plan more than adequately reflects the potential
needs of the Town of Meredith for the next seven to ten years and will
serve as an invaluable planning tool in addressing the challenges of
the future. There is little doubt in my mind that the Board will in-
corporate many of the suggestions made regarding Ordinance development
in 1979 and 1980.
Again, thanking you for your cooperation in this matter^ I remain
Very/EnfcLy yours,
JUTTON
Town Manager
DRJ/md
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NEW HAMPTON PLANNING BOARD
NEW HAMPTON, NEW HAMPSHIRE O3256
September 14, 1978
Mr. Daniel E. Martin
Executive Director
Lakes Region Planning Commission
Dear Mr. Martin
We have received and approved the final draft of
the chart on the recommended Local Actions to
Protect Water Quality as presented to the
Planning Board.
Yours truly,
NEW HAMPTON PLANNING BOAHD
Secretary
cc: The New Hampton Planning Board
ecj
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13
OSSIPEE PLANNING BOARD
CENTER OSSIPEE, NEW HAMPSHIRE 03814 '
June 30, 1978
Mr. Michael P. Nolin, Proj. Dir.
Lakes Region Planning Commission
Meredith, New Hampshire
Dear Mr. Nolin:
We wish to express our thanks and appreciation
for your attendance at the combined meeting of the Lakes Region
Planning Commission/Conservation Commission/ and the Ossipee
Planning Board which proved to be most beneficial to all
concerned.
Also, on behalf of the Ossipee Planning Board
we would like to congratulate all persons connected with your
excellent publication "Lakes Region Water Quality Management
Plan & Environmental Impact Statement - January 1978". Not
only have we found this booklet to be most helpful in our
present Planning Board endeavors, but also please be advised
that we fully approve the plans and concepts put forth
in you booklet.
Again, let me express our thanks and appreciation
for a job well done.
Very truly yours,
, Peter D. Billings, Chra.
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juu.
SANBORNTON PLANNING BOARD
Box 220B, R.F.D. #1
Laconia, N. H. 03246
July 17, 1978
DF/78/055S
Mr. John Dickey
Lakes Region Planning Commission
Humiston Building, Box 302
Meredith, New Hampshire 03253
Dear John:
On behalf of the Planning Board, we would like to
express our support for the Lakes Region Water Quality
Management Plan and particularly to those sections relating
to the Town of Sanbornton. We believe the work to develop
the plan was well done and will attempt to implement the
Sanbornton recommendations as soon as possible.
Very truly yours,
SANBORNTON PLANNING BOARD
t
Donald P. Foudriat, Mr.
DPF/rs
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15
Sandwich Planning Board
Center Sandwich, N.H. 03227
June 5, 1978
Michael P. Nolin, 208 Project Director
Lakes Region Planning Commission
Main Street
Meredith, New Hampshire 03253
Dear Mr. lNolin:
I am pleased to inform you that the Town of Sandwich
Planning Board endorsed in concept the 208 Water Quality
Management Plan prepared by the Lakes Region Planning
Commission. We will continue to participate in the imple-
mentation of the Plan's recommendations.
Sincerely,
Chairman
Sandwich Planning Board
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Selectmen's Office
CENTER SANDWICH • NEW HAMPSHIRE 03227 (603) 284-7701
June 5, 1978
Michael P. Nblin, 208 Project Director
Lakes Region Planning Commission
Main Street
Meredith, New Hampshire 03253
Dear Mr. Nolin:
We are please to inform you that the Town of
Sandwich endorsed in concept the 208 Water Quality
Management Plan prepared by the Lakes Region Plan-
ning Commission. We will continue to participate
in the implementation of the Plan's recommendations.
Sincerely,
Earie C. Peaslee
Almon G. Evans
Robert N. Burrows
Board of Selectmen
Town of Sandwich
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TOWN OF WOLFEBORO
Post Office Box 629
Wolfeboro, New Hampshire 03894
J-sJ'X
Board of Adjustment
Town Planning Board
July 20, 1978
Michael P. Nolan, 208 Project Director '
Lakes Region Planning Commission
Main Street "\
Meredith, N.H. 03253
Dear Mike:
On behalf of the Wolfeboro Planning Board, I would like
to thank you and John Dickey of the Lakes Region Planning
Commission for meeting with the Planning Board to review the
208 Water Quality Management Plan prepared by the Commission.
The management plan contains may recommendations that will
be of great assistance to the Board as we carry out our land use
planning responsibilities in Wolfeboro. The Board endorses in
concept the 208 Management Plan and will continue to participate
in the implementation of the plan's recommendations.
Siiunsrely yours,
Roger P. Murray, 3rd, Chairman
Wolfeboro Planning Board
* * * The Oldest Summer Resort in America
* * *
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TOWN OF WOLFEBORO
Post Office Box 629
Wolfeboro, New Hampshire 03894
Office of the Selectmen
Guy L. Krapp, Town Manager
June 1, 1978
Mr. Michael P. Nolan, 208 Project Director
Lakes Region Planning Commission
Main Street
Meredith, New Hampshire, 03253
Dear Mr. Nolin:
I am pleased to inform you that the Town of Wolfeboro endorsed
in concep.t the 208 Water Quality Management Plan prepared by the Lakes
Region Planning Commission. We will continue to participate in the
implementation of the Plan's recommendations.
Very truly yours,
-\**r i / '., -w
iuy y. Krapp .
Townr Manager v"
GLK/pw
* * * The Oldest Summer Resort in America * * *
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B. Comments
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Oilman's Corner
Jslton, New Hampshire
To: Mike Nolin
Prom: Marcia Keller
Re: Local input for final Water Duality Management Report
To follow-up our conversation of the other evening, 1 offer the following
suggestions for your consideration.
There does not appear to be any slack period in local affairs, but summer
tends to be a busier than usual time for many communities and their officials.
In order that local board and committee members have time to provide comments
for the final report, it might be heloful to notify them, in writing, of
the approaching deadline. Sufficient time sh6uld be allowed to evaluate any
comments and refer back to the board or individual for clarification,
if necessary. <.
Telephone contacts may also be needed to prompt comments where they might have
been expected, but were not received.
You might also consider general publicity for the deadline to reach any
interested "public participants" who might wish to read the draft and comment
on it.
Every effort should be made to check and double check all information regarding
a specific community dealing with current regulations, restrictions, practices,
etc. to insure accuracy. Unfortunately, implementation can only be hindered by
even minor mis-statements which can tend to cast doubt on the remainder of the
report in the minds of those inclined to be critical.
I am not familiar with the form a final report should take, but urge that it be
as brief as possible, listing additional references available, as necessary.
An abreviated, tabulated summary for widespread public dissemination might be
considered.
I would be glad to talk furthe'r with you about any of these suggestions.
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"^^ CITY Of fRANKLIN, NEW HAMPSHIRE
_., i.i.- ^.ii,i 03235
OfflCE Of city Manager
May 2, 1978
Mr. Michael Nolin
208 Project Director
Lakes Region Planning Commission
Main Street
Meredith, New Hampshire 03253
Re: Draft - "Lakes Region Water
Quality Management Plan
Environmental Impact Statement",
Dear Mr. Nolin:
Your presentation on the above plan was valuable to the City of
iPranklin. Some areas need comments. The following comments are made
with the understanding that they are not all inclusive but generally
pertinent to the current situation.
The "alternatives for Water Quality Management":
1. Sewer Ordinance; has tentatively been ok'd by
the City Council. We are currently awaiting
approval by New Hampshire Water Supply & Pollution
Control Commission and the Environmental Protection
Agency.
2. Sub-Division Amendments (Lot size - Soil/Slope): The
Iranklin Planning Board is currently revising and
updating sub-division regulations. It will be recomm-
ended that they review for possible inclusion into the
regulations the lot size - soil/slope provisions.
'• Wetland Conservation Ordinance; It is felt that more
in-depth information is needed before any action is
taken.
4. Hood Plain Ordinance; It is felt that more in-depth
information is needed before any action is taken.
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5. Other Proposed Ordinances^ It is also felt that
more information and expertise will be needed before
firm consideration or recommendations will be given
on: "Aquifer Protection Ordinance" and "Sub Surface
Disposal/Health. Ordinance " .
6. Future Sewers; It is generally felt that consideration
should be given to the following areas as a "Future/
Study Area":
A. Salisbury Road (Shaw Road) east of the existing
sewered area (South Main Street) (US Route #3).
B. The US Route #3 south of the existing sewered
area to the Industrial Access Road.
It is believed that the Anderson-Nichols Engineering Firm has made
specific and similar recommendations to the State of New Hampshire, Water
Supply and Pollution Control Commission for this area.
There are several other areas that should be brought to your attention:
1 . Webster Lake ( Sewer Line Installation ) should dictate
a much higher priority then currently indicated in the
study. Because of the current conditions of Webster
Lake action must be taken now, not by 1995.
2. Your map, page 24 of the report, includes legend for
existing sewers on Prospect Street farther than we
actually have sewers. The area in question should be
reduced by some two thousand feet.
3. The City may wish at some time in the future to restrict
the amount of horsepower of powerboats on Webster Lake.
The above reflects some of the City's immediate concerns and we would
hope to work closely with the Commission on these matters, which will result
in the over all improvement of Franklin's and Lakes Region's Water 'Quality.
Sincerely,
JAM/b
Jame s - £' '~Mc Swe ene'y * ~Ci tV ^Manager ,
for the Mayor -and City Council
c.c. Mayor & City Council
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22
To: Steve McCabe
from: Town Engineer
Date: July 12. 1973
Re: Sewer System
Dear Steve,
I am very sorry that I an not able to attend this very Important Meeting.
but previously planned comnltments could not be changed. This Meeting was to
cover three areas and I will comment on each.
I. Lakes Region Hater Quality Management Plan
A. I feel that a sewer system for Governor's Island, Gunstock Acres,
Gilford Village, School house Hill Road and Pheasant Ridge are pre-
mature and will cause considerable growth.
B. An erosion control ordinance would be very beneficial.
C. I feel that requiring mandatory recycling 1s very costly and
not appropriate.
D. The use of more sand 1s not appropriate because sand does not melt
1ce and the wind will blow sand off of Ice. Additional sand will
Just end up 1n ditches and streams which 1n turn will require
additional roadside ditching, which In turn, Increases silt and
sand 1n streams. A well controlled salting and sanding program
will give the best dollar value, least harm to the environment
and passable road conditions. The Town of Gilford presently
utilizes approximately one-third (1/3) of the amount of salt
which the State of New Hampshire uses per lane mile of highway
E. The sewer to the Gunstock Sk1 Area could cause considerable
secondary growth damage.
II. Property Acquisition
I have discussed the policy of a town purchasing land as a conservation
measure with the Town of Hellsley, Massachusetts. On an average, the
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Steve McCabe -2- July 12, 1978 23
Town of Wellsley appropriates $50,000 per year for land purchase with
the Intent to keep open space and preserve resources. Hellsiey has
found that a secondary product has been the control of growth and
stabilization of the tax rate.
A review of the town Mp Indicates that there are still some very
large parcels of wild land 1n the Town of Gilford.
I would recoMnend the purchase of the Powell land and the Klnball
Castle property as seen as possible.
I would also recomend an Investigation Into the possibility of acquiring
the land or rights to land of the following properties 1n order of 1«port
ance.
1. Jacova
2. torn
3. Richardson
4. Lorlng
5. Curry
6. W1111 MIS
7. Keith
8. Booth
9. Portion of Weeks property, Town of Gilford
Land and Bel knap County Land.
10. Bownar
11. Pierce
12. Edgecoab
13. Jewett t Saab
14. Holmes
It might be possible for the town to purchase the development rights
and the right for public access and the landowner could keep the owner-
ship of the land.
I would also recommend that a large land acquisition package be contemplated
and a bond Issue floated so that future residents who will be using the
public land can share 1n the cost.
HI. Growth Management
I feel that growth MnageMnt should be Instituted because the ability
to provide services Is not keeping pace with the need for the services.
Also. If growth could be directed towards 1ndustr1.il -iiul commercial,
which has a *1nlMl effect on the school systen.the tax baso could be
broadened.
Sincerely,
0. Joseph April, P.t.
Town Englnmtr
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HOLDERNESS, NEW HAMPSHIRE O3245
August 29th. 1978
Daniel E. Martin
Executive Director,
Lakes Region Planning Commission
Humiston Bldg, Main St.
Meredith, N.H. 03253
Dear Mr. Martin:
I am sorry that my comments to your chartnrecommendingtl local action to protect
water quality, as per the 208 project, for the Town of Holderness, is reaching
you at this late date. However, the communication was late reaching me, and
also it found me a victim of a very painful lower back area, which has kept me
horizontal for the past several weeks* I am, 1 hope, on the upland road, having
been able to attend the Lakes Region meeting in Ashland last evening.
Many or most of the Town of Holderness ' known needs were listed on the chart
which you sent to me. The Town did present a Zoning Ordinance at the 19?8 Town
Meeting, which unfortunately was not accepted. The formulation for the Ordinance
was not the work of the Planning Board, but rather a "Special Committee"
chosen by the Selectmen. The Lakes Region Planning Commission was consulted,
and a member of the Commission met with the Zoning Committee several times .
The ordinance was given little or no publicity, otherwise I believe it would
have drawn the added votes necessary to . pass. Unfortunately I understand that
the Selectmen are planning to present the same ordinance again next March.
Holderness was one of those communities (in the 1970 era) who received a promise
of Federal funds under the 701 plan, and the Town made the required matching
appropriation, to evaluate and set up a Master Plan, with the aid of a Boston
concern. However, just at that time the Feceral Government ceased such funding
and although the appropriation of the town would have been helpful, we were not
allowed to keep and use the money because it was specifically appropriated to
"go with" the Federal funds. Hence the money could not be used otherwise.
I am indeed in accord with your list of charted items requiring attention, and I
would hope that we can make some of them Town of Holderness Ordinances -
It has been difficult to get the Holderness Planning Board to meet more often than
once a month. In reality we should meet once a month for the "routine" planning
board business, and schedule another meeting to evaluate some of the much needed
growth measures. Amending the town's Subdivision Regulations is one of the "musts"
that we had planned to give attention to in the near future. ' '
/ I
The Lakes Region Planning Commission and both Dave Scott and Jim Rollins have been
very helpful on numerous occasions when certain problems "have arisen"
In discussing certain town ordinances etc. with the Planning Board members and with
the citizens of the Town, it is often valuable to be able to ^view" r«sa5Sle»
e
or a measure which has been adopted by some other eoamunities . Are there anv such
samples as a "comprehensive plan" of some of the Lakes Region towns that is in the
Commission library for viewing or that could be had for "study" at a plannine Board
meeting. * «««-«
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To: Mr. Martin
From time to tine some of the old on-site sewage systems in town are being replaced
by new ones. The Towns' Solid Waste problem was cared for in the early summer.
A compactor apparatus is working quite efficiently, the container being replaced
by an empty one when necessary.
The Lakes Region Planning Commission chart will come in for discussion at the
September 14th Planning Board meeting, and I am sure that we will be contacting
and calling at the Commission office more often than /in the future.
Do I understand that the current data has been sent to the Selectmen?
There could be better communication between their office and the Planning Board??
Sincerely,,
M. Staples, D«M*D*
Chairman, Holderness Planning Board IMS/ows
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26
CITY OF LACONIA, NEW HAMPSHIRE 03246
vvfa, on tine
OFFICE OF: CITY MANAGER
September 5, 1978
Mr. Daniel E. Martin, Executive Director
Lakes Region Planning Commission
Main Street
Meredith, New Hampshire 03253
Dear Mr. Martin:
Re: Final Draft Water Quality Management Plan
Please include the enclosed memo, dated August 31, 1978,
from Frank DeNormandie, director of Public Works, in the addendum
to be submitted to EPA.
I strongly concur with his recommendations concerning
Item 5: Road Salt.
Very truly yours,
D!" Boehner
City Manager
Enclosure
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27
MEMORANDUM
TO: City Manager
FROM: Prank DeNormandie, Director, Public Works Department
SUBJECT: Comments on Final Draft Water Quality Management Project
DATE: August 31, 1978
£
1. Land Use Controls:
Items 1-5 are as contained in original draft. Items 2-5 are covered by state
law and should be so annotated, in any event with a state law in effect on ordinance
becomes almost superfluous.
*
2. Point Source Controls:
Items 1-5,7,9,10 are as contained in original draft.
Item 1A is new, no comment.
Items 6 and 7 contain a new item which is a date. The 1985 date used in 6 is for
Step II design not Step III construction. The 1990 date used in 9 is completely in
error as this construction is now contained in the State FY-80 program. In any
event no dates should be used, they tend to lock us in concrete once printed.
Items 9 and 10 are not in concert with the City's approved plan, in fact a portion
of the northern end of White Oaks road is due for accomplishment at the same time as
the Gilford Interceptor is installed. The significant pollution abatement far out-
weighs the problem of growth.
It's suggested that the costs shown be listed as preliminary planning costs only.
3. Non-Point Source Controls:
1. New item about non-water toilets (usefa to call such things outhouses) no
comment. ^
2. Item 2 same as before.
3. Item 3 has added one specific Marina. If a Marina is to be named, all with-
out pump-out, facilities should be included.
Item 3^same as before and just as invalid as it was previously. The investigation
took place several years ago and has been expanded and recycling thus far—proves to
be a myth as far as saving funds are concerned.
Item 5 has been changed to delete "and more sand" thus "depletion of sand and
gravel supplies" is now out of context. High priority should be changed to low
priority as minimization has been in effect for several years.
A new item has been added; "eliminate practice of dumping plowed snow into
Winnipesaukee River " added. Impact: "salt contamination of the river minimized."
Wrong impact, as frequently point out by. WS & PCC salt in snow has no deleterious
affect upon river.
Frank DeNormandie
FRD/sam
cc: City Planner
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28
SEP. 7 1978
SANBORNTON P L.A NNING BOARD
Box 220B, R.F.D. #1
Laconia, N. H. 03246
September 6, 1978
DF/78/063S
Mr. John Dickey
Lakes Region Planning Commission
Humiston Building, Box 302
Meredith, New Hampshire 03253
Dear John:
The Planning Board reviewed the LRPC "recommended
local actions to protect water quality" which is part of
the 208 Plan. We approved the plan with the exception of
Item 1A under non-point source controls. The Board feels
that using the interceptor sewer line route recreational
trail system would create serious public relations problems
with the lake shore dwellers and that accordingly, it would
be unwise for the town to take this recommended action.
Very truly yours,
SANBORNTON PLANNING BOARD
Donald P. Foudriat, Jr.
Chairman
DPF/rs
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29
Bo&ut
Center Tuftonboro, New Hampshire 03816
June 24, 1978
U.S. Environmental Protection Agency
John F. Kennedy Federal Building - Room 2203
Boston, Mass. 02203
Gentlemen:
The following is a brief analysis of your recommendations for Tuftonboro contained
in "Water Quality Management Plan - Environmental Impact Statement Draft" dated
January 1978.
«
Alternative 1
The Town of Tuftonboro presently has both subdivision and zoning regulations
in effect. The subdivision ordinance was effective as of March 5, 1971, was re-
vised effective July 19, 1974 and is currently being revised again. Zoning was
enacted September 12, 1972, amended March 3, 1975 and amended further March 14,
1978. A continuation of curxvv.t trends - no plan of action? Hardley.
Continued growth and development of the Town is inevitable. We, the
Planning Board, are, as in evidence above, continually active in the area of
growth control and restriction.
We do not have now, nor do we feel we will have in the future "strip
development*. We Jo have open space requirements. Due to rising land values,
taxes and inflation, we do have potential for losing agricultural land to
development.
Alternative 2
Providing public wastewater collection or treatment facilities for the Town
would serve as a catalyst for intensive development of the Town, particularly
the shorefront areas. Furthermore, the cost to install such facilities would be
prohibitive unless we promoted extensive development, which we have no intention
of doing. Therefore we see no need to designate the lakefront as future study
areas for this purpose.
Alternative 3
We are always in the process of reviewing and revising our regulations, we
have lot size requirements to insure that each building lot is capable of support-
ing water supply and sewage disposal. We have steep slope ordinance, wetland
conservation ordinance and a shoreland ordinance.
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Center Tuftonboro, New Hampshire 03816
June 24, 1978
U.S. Environmental Protection Agency
John F. Kennedy Federal Building - Room 2203
Boston, Mass. 02203
The New Hampshire Water Supply and Pollution Control Commission handles our
needs with regard to subsurface disposal. We do approve of non-water toilets.
We will consider an erosion and sedimentation ordinance as well as an
aquifer protection ordinance.
As for boating regulations, the idea that power boating may be a problem
in Helvin Pond is so absurd that consideration of a regulation is unnecessary.
The size, depth and/or inaccessibility of Copp's Pond, Lower Beech Pond and Dan
Hole Pond naturally regulate the use of these water bodies.
Additional pump-out facilities on the lake shore should be promoted.
Tuftonboro has its own sanitary land fill site although separation for
recycling is not in effect. The Planning Board would support recycling.
More than twenty years ago the townspeople voted not to use salt on town
roads. The only roads in Tuftonboro that are salted are State Highways salted
by the State.
sincerely yours.
Paul Appleton, Chairman
cot Lakes Region Planning Commission
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31
Chairman
Vice-Chairman
Secretary
Treasurer
PLANNING
COMMISSION
Benjamin K. Ayers
Warner AA. Plummer
Joan Squires
Randy Lyman
Moultonboro
Meredith
Laconia
Ossipee
Main Street Meredith, New Hampshire 03253
Telephone 279 8171
MEMORANDUM
TO: John Dickey, Regional Planner
FROM: Mary Guariglia, Community Planner
RE: Comments from Sub-Regional Meetings to Review the Draft
Lakes Region Water Quality Management Plan*
DATE: August 31, 1978
The comments which follow have been simplified and paraphrased from those
actually made at the meetings. General discussion and questions and answers
have not been included.
Franklin - April 27. 1978 (included communities of Tilton, Northfield, Sanbornton,
Franklin, New Hampton)
Person
Jim Walker, Tilton
Comment/Question
(1) The recommendation for sewering the Tilton shoreline
of Lake Winnisquam and Silver Lake should show priority
areas and not be made as a blanket recommendation.
(2) The Plan should state that the LRPC encourages not
approves waterless toilet systems.
(3) The Plan avoids dealing directly with the more diffi-
cult and controversial areas where a solution is not
in sight at this time.
(4) A good number of septic systems approvals are granted
through the WSPCC's waiver policy regardless of the
problem conditions encountered. The Plan should
recommend that this policy be reviewed.
(5) Heavy metals are not dealt with in detail. Why
weren't the results of the tract metal study (con-
ducted by Normandeau Associates) discussed in the
Plan
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32
- 2 -
Franklin - April 27. 1978 (continued)
Jim Walker, Tilton
Dick Flanders, WSPCC
Jim Davis, Tilton
Don Foudriat,
Sanbornton
(6) Is there any discussion in the Plan regarding water
weeds and the chemicals used to kill them?
(7) The report should recommend that dumping of plowed
snow into water bodies be stopped.
(8) There should be some flexibility in septic tank pump-
out regulations as opposed to the suggested three-year
pump-out regardless of condition of the tank.
(9) The recommended licensing septage pumpers (pg. 173) is
already a fact.
(10) Power boating should be prohibited on Sondogardy Pond
in Northfield.
(11) The use of herbicides was not addressed in the Plan.
(12) What standards were used as a basis for the recom-
mendations to limit power boating?
(13) Mountain Pond in Sanbornton is a public water supply
and is already restricted.
Center Harbor - May 3, 1978 (included communities of Center Harbor, Moultonborough,
Meredith, Ashland, Holderness, Sandwich)
Person
Kim Ayers,
Moultonborough
Harold Wyatt,
Meredith
Elzora Eldridge,
Meredith
Rawson Wood,
Center Harbor
Comment/Question
(1) Moultonborough is not in the Flood Insurance Program.
(2) What do you consider porous pavement?
(3) How do you feel about using salt for dust control?
(4) It is hard to evaluate the potential importance of
recommendations on the matrix. Is ther any way to
set up standards to assist the communities to improve
their existing ordinances?
(5) In recommending setbacks on the shorefronts, how did
you arrive at these figures (i.e., septic systems/,
buildings, etc.)?
Dick Flanders, WSPCC (6) Does the LRPC support chemical weed control measures?
William Montgomery,
Center Harbor
(7) Will you describe the subsurface ordinance for Center
Harbor?
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- 3 -
33
Ossipee - May 4, 1978
Person
Dick Priebe,
Ossipee
Wayne Shipman,
Wolfeboro
Ted Newman,
Wolfeboro
Wayne Shipman,
Wolfeboro
Richard Phillips,
Ossipee
Norman Royle,
Brookfield
(included communities of Brookfield, Ossipee, Tuftonboro,
Wakefield, Wolfeboro)
Comment/Questi on
(1) Perhaps the Lakes Region Planning Commission can
encourage legislation that would answer the question
of compensation for loss of value when wetlands and
other sensitive areas are restricted to conservation
uses.
(2) Are there some aspects of the recommended Health Ordi-
nance which deal with a solution to a crisis situation?
(3) To limit the horsepower for boating on Sargent Pond is
not appropriate due to'the fact that it is too small a
water body to use power boats.
(4) Recommendation for limiting power boating on Upper
Beach Pond is also not appropriate because it has been
a Town reservoir for a long time.
(5) Has the LRPC written any legislation on septic regula-
tions?
(6) The recommendation to appoint the local Health Inspector
should be carried out.
(7) As far as pumping out septic tanks, there are no regu-
lations and standards as to where these operators may
dump septage.
(8) Where is the information which backs up the minimum
lot size recommendations based on soils and slope
conditions?
Gilford - May 9, 1978 (included communities of Alton, Belmont, Gilford, Laconia,
Gilmanton)
Person
Frank DeNormandie,
Laconia
Conment/Question
(1) Based upon past experience, documents that go to the
EPA get locked in concrete. What is EPA supposed to
do with the Plan?
(2) It is premature to talk about recommendations for solid
waste until the State has formulated a State Plan.
(3) Using more sand as suggested in the Plan is more costly
than salt.
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34
- 4 -
Gilford - May 9, 1978 (continued)
Person
Frank DeNormandie,
Laconia
Joe April, Gilford
Bill Clough, Alton
Bob Cruess, WSPCC
Comment/Question
(4) Amount of salt used in Laconia does not increase
permissible levels (125 ppm/yr.).
(5) It has been documented that reduction of salt on
roads results in an increased accident rate.
(6) The impact of sewers in stimulating secondary
growth should gain more attention, particularly
in Gilford.
(7) Adding more sand to roads fills ditches, increases
sedimentation and causes more problems than it
solves.
(8) Mandatory recycling is a critical issue because
the towns can't afford this higher cost for
solving their solid waste problem.
(9) Solid waste recommendations should not be deleted
from the report, but should be utilized as a basis
for development of the State level solid waste
management plan.
(10) The Plan should reflect the fact that the Gunstock
Recreation Area will be required to tie into the
Gilford Interceptor by 1983.
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35
I «.V> Wolfi-lntm. Y H. O.MWI
.liimhJ. Hiirghnnli. Kiliiar
KrniHili W. Wrbh. Mnininiiifi Kiliinr
12 July 1978
Mr. Michael Nolin
Lakes Region Planning Commission
Meredith, N.H. 03253
Dear Mike:
You asked for my comments some time ago on the V/ater Qaality
Management Plan, but correspondance hasn't been one of my
strong points of late, Hope these* comments will reach you before
the final report is completed.
I didn't try to consider the report page-by-page, a function which
will undoubtedly be served by those with expertise in the fields
you consider: rather, I'd like to make some overall observations
on the report from the aspect of the general reader.
First, you are to be complimented on the quality of the prose.
In general, the report can be read and understood by the average
reader, which is more than I can say for some other planning
reports I've plowed through. The problem isn't so much the
complicated or technical nature of the subject, although this
is frequently a factor, as it is the jargon used in the writing.
If the writing of such reports isn't obscure or stilted, it can
also suffer from being excessively vague or general. To give
an example, I recently read the Governor's Advisory Committee
report and found it to be a lengthy rehashing of the obvious:
"Goal 8. The agricultural, forest, water, and other natural
resources within the state should be managed wisely to assure
their long term availability, production, and utilization. "
Boiled down, I suppose everyone would agree with the statement,
"Land should be used wisely," but I don't see how it really
contributes to state planning.
For the most pqrt, I think you've avoided these pitfallsj this
is absolutely necessary if the report is not, like so many others, to be
simply put on the shelf and never used.
The emphasis on land capability rather thaa the intensive
development encouraged by centralized sewer and water systems
is 4tf 4«NM» a major feature of the report, and seems to be the
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36
appropriate course for the region, possibly excepting the cities
of Laconia and Franklin. The emphasis on implementation by towns
also seems appropriate, if for different reasons. I see.no evidence
at the moment that the state is prepared to take a stronger role
in enforcing anti-pollution legislation or regional planning and other
cooperative efforts (witness the state Board of Education's
extreme reluctance to do anything abbut reorganizing school dis-
tricts, a critical need in this area). Thus it will probably
be at the town level that the immediate impact of your proposals
will be felt. I'm curious to know how your meetings with locals
officials have gone.
As for possible additions to the report, I think there are two
things which might be included: more specific attention to the
upper Moultonboro Bay area and some accounting of Water Supply's
recent o rders concerning surface water supplies. For Moultonboro
Bayy I realize you are trying to formulate general recommendations
for communities around the lake, but the weed problems seem
pressing enough to require some specific attention in your report.
4t this point the water supply question is just being raised,
but I imagine you could at least include suggestions of how towns
should begin planning for possible improvements.
Most land use planning involves extensive use of mapping, and
your maps are excellent- clear, well-drawn, and accurate; I make
use of them often. The land capability plan map has been occupying
a place on the wall in the office here, and even casual observers
comment that it's beautiful^
I've heard some criticism of your soil modelling/water testing
data in regard to its accuracy, and while I'm in no position to
judge the merits of that argument, I wonder if you might want to
include a discussion of a plus or minus factor to your observed
results. In some case, you do include thin, but a background
discussion or explanation might be valuable as well.
One obvious statement about the rpport which bears repeating is
that it's the largest collection of information ever presented
on this region, and for that reason alone,along with many others,
of course, it will remain a valuable guide to planning.
Regards,
Douglas Rooks
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MEMORANDUM
TO: 208 Project Director
FROM: William R. Clough
SUBJECT: Lakes Region Water Quality Management Plan and Environmental
Impact Statement, Draft #1, January, 1978
DATE: May 26, 1978
These comments are presented as a member of the 208 Steering Committee,
rather than as an alternate representative from the Town of Alton. Consequently,
the comments will be general in nature, rather than specific to the Town of Alton.
Comments relative to the Town of Alton will be based on observations made during
the review and not based upon the detailed analysis from the Alton viewpoint.
(\\ For example, on Pages 3 and 6 the report recommends the elimination of power boat-
ing on several small ponds in Alton (Bear, Gilman and Knights Ponds). I believe
this has already been done and based on the sub-regional meeting held in Gilford
on the 9th of May, I believe that John Dickey has realized this and corrected his
charts to reflect the status.
Chapter 1, Page 89, the last sentence in the third paragraph states, "This
option will effectively remove control of the intensity of future development
from local government and will have a devastating effect on local budgets". I
don't believe this is necessarily so. It is a likely result, unless there is
definitive action by the community. It certainly will remove the crutch that is
now being used and will force towns to face up to the whole problem, but I am not
sure that its the inevitable result and, as a matter of fact, I think this whole
report tends to point toward something else and I suggest that this sentence be
(2) rewritten to reflect the fact that it will effectively remove control unless the
government or the town does something about it, but not necessarily as a result of
existing and planned sewerage disposal systems. In the last paragraph on Page 89
the report says that "the Commission views 208 as an excellent opportunity for the
twenty-one communities involved to meet the 1983 National Water Quality Standards".
I suggest that we say something about its applicability to the remaining eleven
towns. For example, those around Newfound Lake, Barnstead which has the Suncook
Ponds, and Tamworth which has White Lake and many of the things that are in this
report and applicable to the Winnipesaukee Watershed are equally applicable to
these other bodies of water and somewhere I think we should say so.
Chapter 4, the number 3. at the top of Page 116 is incorrect. Considerable
stress is placed throughout the report on floodplains and flood hazard areas and
there should be some mention, at least a recognition, of the responsibility of the
, Corps of Engineers to determine the 100-year floodplain elevations and identifiea-
(.*) tion of those areas, if any, within the region where this has already been donei
At the sub-regional meeting in Gilford on 9 May, John Dickey stated that the
aquifer protection ordinance was listed as a low priority item for the Town of
Alton because of the relatively small area which contained aquifers. I wonder if
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47
- 2 -
protection of a small, rather limited area is not of higher priority than would
be a greater one or larger one. On Page 127 under Lakefront, shoreline develop-
ment was identified to a distance extending 500' back from the shore. This
appears inconsistent with Section 2 of Appendix H. Minimum Shore!and Zoning
Ordinance, which applies to all land areas within 250', horizontal distance, of
any pond, lake or river.
Chapter 4. Part 2. the last sentence in the first paragraph on Page 140
states, "The burden on taxpayers is increasing at an^alarming rate". If this
statement is true and I do not question its validity^ it certainly warrants some
statistics to support such a sweeping statement. Page 141, the last sentence in
Part 2, Paragraph A, what does this mean? In the sixth assumption on Page 144,
do we mean energy or energy resources and if we mean energy resources, what are
energy resources? Part 2. Paragraph C. l.-b. on Page 145, this statement "that
taxes generated by new development will not cover the cost of providing municipal
services and subsequently municipal tax rates will rise", appears inconsistent
with the 4th assumption on Page 144. Page 146, Table 3-*0 should be Table 4-0.
The List of Tables of Page v should be corrected to show the correct title 4-0.
The second paragraph on Page 148 appears to be somewhat contradictory to the
option on Page 89, which I commented about earlier in this Memorandum. Page 149,
3.-a. (1), prevent strip development. I find this hard to reconcile with Appendix
H which as I see it is strip development and strip control. Is strip development
per se bad or are some strips bad and some strips the best solution? Table 4-0,
what is the significance of line E?
Recommended Future Land Use Plan, Page 153, the whole report is pointed
toward Alternative 3 as being the best solution for the region and the guts of
Alternative 3 is the Regional Land.Use Plan. The first sentence in the second
paragraph on this page states the real output of the 208 Project which can be
! implemented by the involved communities and it seems as though this is fairly
well hidden and in some manner or other this ought to be brought up and high-
lighted earlier in the report. If I am correct that this is the payoff line, it
shouldn't be buried on Page 153. If this is not the payoff line, then whatever
is should be emphasized up front.
Recommended Land Use Controls starting on Page 156, the last paragraph on
G. this page should be updated to the 1979 Town Meeting.
Municipal compacts, Pages 157 and 158. Alton has a Town Engineer who is
also the Health Officer and Building Inspector. The requirements of the Health
and Building jobs are so time consuming that he has insufficient time available
to do the engineering that should be done for the Town, his engineering output
is confined to only those projects which must be accomplished. Consequently, it
- appears that the work load in Alton precludes sharing the Enforcement Officer
'-1 with any other town. Table 4-1, I think the Table requires a footnote for the
Town of Alton with respect to the mobile home column. I realize that if there
is a regulation governing mobile homes, it has to be shown as existing and that
the column in the format is under Subdivision Regulations, however, the Mobile
Home Ordinance is an exception in the rural zone as established by the Zoning
Regulation and a footnote to explain this would be appropriate. Comments on
Table 4-2 will be incorporated with those on the recommended ordinances as will
any comments relative to the corresponding paragraphs in Part 3. B.
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48
- 3 -
Chapter 2 - Water Quality Sampling and Analysis - It is interesting to note
that with the exception of the Introduction, Chapter 2 is the smallest of the
chapters, even though it was the most expensive contractual effort. This is not
by any means necessarily bad, but I find it interesting. I am aware of the
editorial problems involved in a large report of numbered pages, when some changes
in a portion of a report would result in a renumbering of the entire report, how-
ever, I suspect that this may be inevitable in a report of this size and is one of
the occupational hazards of the trade. Fully organized, it appears to not only
have relied on the contractor's report, which it should, but it doesn't seem to
have been recast from an LRPC standpoint. For example, there are two key sentences
which describe the object of this effort and the fundamental approach to it which
are buried at the end of the third paragraph on Page 92 and are not highlighted and
not emphasized and one has to search to find what it is all about and where it is
stated. On Page 97, the lastsentence of the second paragraph, states that the
Phase 2 diagnostic sampling should continue at its initial frequency. This appears
to be one of the major recommendations, but it is not highlighted, it is not
separated and there is nothing that says how the LRPC feels that this continued
diagnostic sampling should be implemented. The last sentence of the fourth para-^
graph on Page 97 says we have recommended. I suspect that this is copied out of
the contractor's report because the past tense seems to indicate that this has not
been revised to reflect the LRPC recommendation. If it is the LRPC recommendation,
and I'm sure it should be, then.we probably ought to say so. The same sort of
comment applies to the last sentence of the paragraph on Page 100. At the top of
Page 100, the next to the last sentence in the continued paragraph, may be the most
important sentence in the whole chapter."None of the sampled LRPC 208 area lakes
are seriously eutrophic and none of the sampled tributaries are seriously polluted".
By god, if this is so and I believe probably it is, it shouldn't be buried. So, I
recommend that this chapter be revised. Maybe the only revision necessary is some
editorial work on the sentences that I have discussed and then listing of the con-
clusions and recommendations on Page 100. I think this is necessary. I think it
must be done.
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49
-k -
Chapter 3 - Water Quality Modeling This Chapter is better than Chapter 2
in that it has identifiable conclusions throughout and summary conclusions at the
end. I am disappointed that it doesn't include two things and urge you to take
another look at it to see if these cannot be properly included.
From the outset Jim Moore emphasized that this model would solve for phos-
phorus and phosphorus alone. However, it was my understanding that the model
would have the capability to be used or at least to be adapted to the study of
other elements if such use of it were desirable. If I am correct, I think this
an important point to be included in the report. The other thing which I am
sure that my memory is not faulty, that at the very outset I asked Dr. Rice
whether the model had the capability of synthesis and he assured me that it did.
As a matter of fact, I got the impression that such capability was so fundamental
that my question almost bordered on ignorance and I believe it is important that
this capability for synthesis be included in the report. I think somewhere in
this chapter there needs to be a statement that the mdflel is available for use
not only by the region or portions of the region, but also for other State
agencies. We put this work into the development of a model and we ought to
emphasize somewhere that the damn thing is available and can be used and wasn't
a one-time show. Page 105, the sentence at the end of or rather following 2-d,
there is something wrong with this sentence. We found that relative contribu-
tions were found and weren't we lucky. On Page 106 the next sentence in the
third paragraph, as a result of these findings, the LRPC directed, this needs
to be edited to put it in the LRPC context rather than the contractor viewpoint.
The same thing applies to the first sentence in Section3.
Page 109, I suspect that the last conclusion needs some amplification some-
what. That the implementation of this conclusion either is already cranked into
the recommended ordinances or should be considered by communities when adopting
one of the ordinances. The big technical effort of the 108 Project was in the
Water Sampling and Modeling, as opposed to the administrative effort in the
Land Use Mapping and Control work done by the staff. If the intensive sampling
was to feed the model and the model comes up with five curves which can be
applied to land use controls, this probably is a minimum payoff liine for a maxi-
mum expenditure and should be emphasized.
Section E on Page 115 shows what can be done with the model without exten-
sive sampling and probably deserves some mention from the implementation viewpoint.
Chapter 5. Non-Point Source Controls - The introduction on Page 172 used
the best yet at least insofar as Part 1 is concerned. It defines non-point
sources, identifies eight of them, stacks them up, states the purpose of Part 1
and says where to look for the recommendations. It does pretty well on Part 2
except that it falls a little short of a better part by not commenting on the
recommendations. Many of the things in this paragraph I have commented on pre-
viously in other chapters or in the Appendices. I will try to avoid redundancy,
but because this is tape rather than written, I can't readily refer to what I
have said before.
Part 1, A-l. this should not be a condition of sale and I refer you to my
comments on Appendix 1. It is impractical. Let me suggest an alternative which
can be practical and which can be policed. The Water Supply and Pollution
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50
,
(I2/
Control Commission is presently considering a regulation to require designers
to notarize the plans submitted to the Commission. The purpose being to try
to improve the reliability of the data submitted on these lands and to provide
some teeth for legal action. It is not uncommon in the construction industry
for the builder to be required to provide a set of as built drawings to the
sponsor upon the completion of construction. Such a procedure could be enacted
by regulations by the Commission, where the builder of the system or the one
' * who constructs the system would be required to furnish the Commission with a
I * copy of the design plan showing the necessary as built data including ties to
the significant parts of the system, such as pump-out ports and distribution
boxes. On this copy could be the statement that a similar copy had been provided
to the owner. This would provide the policing factor because a permit for opera-
tion could be made contingent upon the receipt of the as-built drawings. It
might administratively complicate things, but I believe it would be more practi-
cal and more enforceable than would the handing over a copy of the plan to a
subsequent buyer by an owner who may have had it on file for 40 years.
Part 1, A-3, this section does not recommend that the Water Supply and
Pollution Control Commission do the same as it recommends the towns do. Con-
sequently, it doesn't support the recommendation in Table 5-1 that the State
revise criteria for approval. The recommendation that research be conducted to
devise new methodology to replace or improve the percolation test is a good
recommendation, but it does not belong under an overall recommendation that
towns do something about this business. This is beyond the scope of capability
of towns and certainly is an appropriate thing for the State and if it is, it
probably ought to be included in Table 5-1. Along the line of research would
it not be appropriate to recommend that the EPA combat or if they have already
started, accelerate research on something to replace the septic system for
individual residential disposal. It must exist all over the country, it is not
unique to the Lakes Region. The State of the Art hasn't progressed significantly
since the first septic tank was designed. Part l-A-4, I think I understand what
you mean when you speak of legal tools, but I suggest that this sentence needs to
be expanded and perhaps what's required here are a few simple tools with which to
identify malfunctioning septic tanks and which will be legally sufficient to
support enforcement action. The recommendation at the end of the second paragraph
brings in the septic leachate detector out of the clear and probably should refer
to Part 2. The recommendation that the Water Supply and Pollution Control Commis-
sion revise its approach to defining pollution is not reflected in Table 5-1 and
it should be. On Page 179 under Efficacy, the first couple of sentences appear to
* be redundant, repeating what has been said before and really have nothing to do
(P; with the efficacy of the thing. It's not as good in this paragraph as previous
ones- Part 1- A- 5', see my comments on Appendix 1. Part l-A-6, this is presented
without recommendation and perhaps the parenthetically numbered paragraphs are
recommendations and probably (2) and (3) really are. I think this needs some
editorial direction. Part l-A-7-a-(3Kthese systems are new to me and plea'se I
believe that I have refrained from comment only with some restraint. Part l-A^S,
I doubt if we dug far enough on this one. I seem to remember that a few years'
back in what I have called the year of the environmentalist, a number of towns
adopted phosphate detergent bans. I know that the Town of Alton did, I know' it
has never been enforced and I doubt very much if it's done, has been rescinded
and I wonder how many more of these that are suspected. Alton lacks the will be
cited here. If this is a valid course of action, only historical disregard for
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51
- 6
it should be emphasized. I guess all I've said here fits in with l-A-9. Part
l-C-2, the recommendation in this paragraph says be adopted by towns either in
the form of a police power ordinance and I realize that ordinances which are
.jo,, adopted by the town are authorized under the general police powers of the town,
"' but it seems like a "red flag" term and it is the only time you have used it so
far in the report that I have seen and I suggest that the police power be deleted
and just call it an ordinance.
Part l-C-4, the parenthetical note at the end of the paragraph says, as
noted in recommendatfon #1. This is fine, I went back to recommendation #1,
•>\ when I finally found it, I found that it then was talking about Appendix M and
it would certainly be just a little bit of help to the reader in the review of
this report if he could be directly referred to Appendix M.
Part 1-D. Boating, I don't believe that this problem is unique to the Lakes
Region. I am well aware of the fact that the word unique can be qualified, I
j/Y think how can it.be particularly unique. How can anything be, but I don't think
that this is so. Important, yes; unique, no.
Recommendation #1. This is a reiteration of the continual Water Supply and
Pollution Control Commission complaint that they don't have enough people to do
.,* their job. I recommend that the LRPC suggest that both the Department of Safety
^' and the Water Supply and Pollution Control Commission coordinate their inspection
and enforcing activities into a cooperative unilateral effort.
Recommendation #2. I doubt that if mandatory legislation should be confined
to the Lakes Region. I think it is equally applicable throughout the State. I
• j\ think it's a good recommendation and I think it's an unpopular one. I think it
• J has taken a little courage to make this recommendation in view of the big dollar
investment in motors and the boating industry in the Lakes Region.
Recommendation #3. I think the staff has done insufficient study on this
one and consequently has come up with a Table which is incorrect and possibly the
staff now knows this because I think John's Dickey's briefing at Gilford was at
variance with the Tables on Pages 195 and 196. I am very sure that I am correct
that Bear, Gilman and Knights Ponds in Alton already have the no power boating
regulation by the Department of Safety. I believe Saltmarsh Pond in Gilford,
those are not permitted. I know that this is true for Little Pond in Sandwich
- and there may be others. I think you.need to take a good look at this one. I
&i have one suggestion with regard to the Town of Alton, I believe and I have not
searched this out that there is on the Merrymeeting River in the impoundment from
the dam at Alton back through and into New Durham, a speed limit and at the time
that this was established, the local conservation officer expressed displeasure
that a speed limit had established because of the practicable impossibility of
enforcing it and that a limitation on horsepower would be far superior if this
turns out to be true, it might be a recommendation that the limit should be
changed to a restricted horsepower regulation in the impoundment.
Recommendation #4. The additional pump-out facilities at Alton Bay were
W) the recommendation, the implementation of this one is going to be difficult.
I expect there will be more comments on solid waste than any other portion
of the report, however, here are some brief ones on l^E. I believe the monitoring
(5J* of groundwater at all sanitary landfill sites is necessary and that the instaVla-
^ - tton of a minimum number of monitoring wells should be a requirement established
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52
7 -
by the State for two purposes: (1) To alert the town and, in turn, the State
to the failure of a site, and (2) to provide data brought out in this report
for the refinement of sanitary landfill criteria. In this regard, I think that
once the capital investment has been made by the community, the additional cost
should be only in taking the periodic samples and supplying them to the State
for analysis. These analyses of specific samples and then the border analysis
or correlation of these analyses with soil data and other information which
would go toward determining the adequacy of criteria or for the refinement of
criteria should be a State agency function and I think that it might be well if
the LRPC recognized that and identified it as such in this report. In the
matter of mandatory separation of recyclable materials, the dollar value of
recyclable materials today does not make recycling economically feasible unless
it is subsidized. Subsidized both by the originator of the rubbish in man hours
.r.". and other effort and by the community in the handling of the separated and
£*• segregated materials and experience has indicated that the sale of these materials
won't even reimburse the community for its handling of those which have been
segregated by the originators. There is not reason to believe that the value of
these recyclable materials will outstrip the rate of inflation until shortages of
the materials become greater than they are now and that means that any equation
which justifies the recycling has to be based on an value of the
strategic importance of these things to the country in the long run. I think that
one can safely say that if such materials are not separated at the point of
origin by the originator, the cost of separation at the municipal disposal site
is so great that it wouldn't even be considered and would probably preclude
incineration as one of the options on rubbish.
Part 1-F, Septage - The recommendations appear to have been taken from the
contractor's report and haven't been edited to change the verbs. I am sure
Recommendation #1, for example, should say that the Lakes Region Planning Commis-
sion will cooperate with the Department of Public Health and in #2, it will
cooperate, #3 - it will seek technical assistance. You said it in #4. Recom-
mendation #5 ought to read that licenses should be required and they should be
. „«. issued by either the towns or the State whatever is appropriate. I believe that
'•£!• the utilization of private dumping sites is already forbidden when the State
Board of Health directed that all communities provide a public place. I may be
wrong in this. #6 - Here again, Lakes Region Planning will examine the feasibility.
What happened to Recommendation #7. Under the estimated costs, apparently the
Table is in the contractor's report and this is the first time I have seen in this
plan that we have.made reference to one of the contractor's reports as back-up
data and so forth on file in the offices and, if we are not going to include the
septage treatment and disposal option table in this report, then we ought to state
that it is available in the Commission offices for those who wish to take a look
at it. Part 1-G, Forest Practices - I wonder why the LRPC even has to get into
this. Somehow I get the impression that here we are looking for work that it ;
/2g) doesn't need to take on. If the Forestry Department of the State of New Hampshire
^ and the people interested in the preservation of New Hampshire forests can't
publicize those, I don't know how effective publicizing by the Lakes Region Plan-
ning Commission would be. If in your renumbering of your pages you need some
space, maybe you can gain a little on this one by leaving it out completely.
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53
Part 1-H, Road Salt - Something's gone wrong here I guess because in one
of the recommendations we have a discussion paragraph. This technique appeared
,..„•, in the previous Part G, but there was only one sentence of not great significance.
-2"/' Here, the whole discussion chunk probably belongs up ahead of recommendations and
certainly that portion of it which repeats what's up above, belongs up there.
Part 1-H Well, we got through 206 pages before we came to an impact state-
A;) ment and maybe this is soon enough to have it appear. I have no experience in
impact statements and, consequently, I am eager to believe that this is adequate.
Chapter 5, Part 2 - This part of Chapter 5 is disappointing. The approach
was out last resort in examining this very complicated problem and the results
cast about in retrospect of the advisability of starting it in the first place.
I don't think we expected the leachate detector to find every single trace of
pollution as it went along. I do think we expected that every one it found would
be a real one and traceable to some source. This understanding seems to be borne
out by the results obtained, although it appears that the leachate detector picked
up only a very small number of the polluting inputs that the model indicates should
be present. In either case the statement that if the predominant pattern of septic
plumes along the shoreline are dispersed in the groundwater system and do not
appear as discrete or readily identifiable plumes, then detection is at or near
the limits of the present survey methods. It would seem then to follow that there
needs to be a survey method determined which will be more sensitive and more
reliable. Our decision to try the leachate detector was pretty thoroughly reviewed
both by the Water Supply and Pollution Control Commission, and EPA and I'm sure
1; that had there been a more reliable device, they would have urged us to use it.
So I wonder if the LRPC doesn't come out of this thing with some conclusions and
recommendations over and above those prepared by the contractor. These are that
the leachate detector tried to fill a need and it is unsuccessful in completely
filling the need and that there is a real need and, consequently, EPA or State of
New Hampshire should finance research to advance the state-of-the-art in detection
survey methods. With regard to seepage meters, from this report I conclude that
either seepage meters are no where near as good a test device as we were led to
believe or that our contractor was so completely incompetent in the use of these
that they might well have been left ashore at all times. And so from this I come
to the conclusion that the LRPC ought to decide which or both of these things is
true and come up with some recommendations either for an improved meter which is
reliable and/or some operating procedures which can be depended upon.
While the main pitch on Page 218 seems to indicate that the survey methods
tend to detect less pollution than the model indicates should be there and that
examination of the model by the model maker indicates that the model probably is
better than the detection survey techniques. When I go back to Page 217, I find
that in three of the sites the phosphorus retention showed up considerably in
excess of that estimated by the model and I wonder if I misunderstand what is
being said or if the conclusion that the detection devices were more than adequate
in this respect would be an invalid conclusion. The conclusion that I do draw is
that the model maker wrote the report.
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- 9
Chapter 6. Point Source Controls, under 6-A, Ashland, is the statement
that the plant meets best practicable treatment criteria. This term is only
used for Ashland. It is capitalized, it has some significance, but the
significance is not evident. If it is a significant term and Ashland is the
J!>i. only plant within the region which does meet these criteria, it might be well
to say so. Equally, some thought should be given including a statement on at
least the Laconia and Wolfeboro facilities as to whether or not they do meet the
best practical treatment criteria.
Nowhere in this Chapter 6-A through 6-B is there mention of the fact that
in the Town of Alton the Water Supply and Pollution Control Commission approved
[35) design plans for a collection system suitable for connection to any future dis-
posal arrangement.
Chapter 6-E, the last paragraph on Page 236, recommends that testing programs
be initiated, but does not recommend who should be responsible for this initia-
tion. Chapter 6-G onPage 238, under land use patterns, the statement, "areas
previously protected by natural constraints open to development". I do not under-
stand what this means. I understand that it has been said previously and else-
where about the administrative restraints imposed by Water Supply and Pollution
Control Commission on the leach field construction being removed by the installa-
tion of sewers and the resulting pressure to reduce lot sizes, but I don't under-
stand what this statement means. I have taken the Tables at face value and have
not analyzed them.
I am pleasantly surprised by Chapter 7, Institutional Planning. These
forty pages constitute, in effect, an operating official's reference manual,
rather than a planning document. However, in my knowledge this hasn't been done
before and it is a valuable piece of work. I suggest that some provision be
made to extract this Chapter, make it available as is with a cover and a cover
page or introductory page which states that it has a great deal of use as an
operating reference manual. My only specific comments are on Page 248 where the
third and fourth paragraphs appear to be inconsistent with Appendix B and, in
fact, appear to be more consistent with my comments on Appendix B. The fourth
paragraph on Page 249 is a surprise and somewhat disappointing. I had been
impressed by those Appendices which utilize the overlay concept and made comments
to that effect on each of those to which it were applicable. Now I find that
maybe it ain't necessarily so. I recommend that the best legal opinion be sought
in this matter and in this regard would suggest that they get the Office of Com-
prehensive Planning to request the Attorney General for an interpretation and try
to determine short of a court case whether the things are or are not legal. If
the opinion is that they are, then fine. If the opinion is that they are not,
then the Commission should initiate some action to get them legalized even though
the inherent risk stated in this paragraph exists. Altogether too much emphasjis j
is put on these overlay type ordinances and their importance to the land use plan'
to permit something like this to jeopardize their implementation. It is a dis-
turbing thought and it must be highlighted and there must be some action taken on
it.
Chapter 8, Public Participation - This Chapter doesn't contribute anything
to the Water Quality Management Plan, but it certainly provides adequate evidence
that the Plan has not been written in either an ivory tower or a vacuum. This
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10 -
Chapter states rather clearly that the public has been represented in the
formulation of the Plan from the very outset and that it had the opportunity
to participate quite early in the process right up to the present moment. The
public, in the broad sense, has had an opportunity to be aware of the fact
that the 208 Project was going and it also had the opportunity to know that its
participation was solicited and I can only conclude that the public participated
to the degree that it shows. If it were possible without a hell of a lot of
effort to put a dollar figure on the amount of money that has been spent by the
Commission in trying to foster and encourage and use participation by the public,
this would probably be an interesting figure to include in this Chapter. I
think this is a pretty damned objective comment on this Chapter by me if you
recognize that I am a firm believer in the J. P. Morgan thesis, the Public Be
Damned.
This is an addendum to the comments on Chapter 4-1, Land Capability Mapping.
We entered into a contract with BCI to do some satellite mapping of an area to
show land use. I remember that we were impressed with the map at the time and I
have forgotten it and lost track of it. I think we ought to mention it and there
is probably room on Page 137 that we took a cut at this technique and it did or
did not correlate with the maps that we finally came up with, that it does or
does not have a potential for relatively cheap, quick and dirty approach to an
area before the highly extensive detailed work that was finally accomplished is
entered into and I don't even know whether the technique was adapted from the
Federal data by BCI or whether the technique is available and doesn't require
the BCI to produce it. What I am trying to say is that we ought to
say something about this and if the technique is available, we ought to say that
the Commission can tell interested areas and communities how to go about to use
it.
Comments on the whole report: There are occasional references to reports
from which this has been prepared. I suggest that an Appendix N be added which
would list all the detailed reports that are on file in the Commission offices
and available for examination by those who require more specific information
than is contained in this Plan.
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AUG. 2 9 1976
WILLIAM R. CLOUGH
BOX 11?
ALTON, N.H. 03809
Lakes Region Planning Commission 26 August 19?8
Humiston Building
Meredith, N. H.
Subject: Lakes Region Water Quality Management Plan.
Draft - January 19?8
1. Reference our conversation, this subject, on 25 August 19?8.
2. As a member of the "208" Steering Committee, I submitted exten-
sive comments on the subject draft. These comments ranged from
editorial to philosophical.
3. It is understood that EPA requires that all comments be published
in the final report together with B statement of their effect on the
report. It is further understood that my comments, dictated on tape.
resulted in 13 pages of transcription. Inclusion of this transcrip-
tion and a critique of the comments would be ridiculous.
J|. Please extract or summarize only those comments which vou consider
worthy of discussion. Use or reject such others as you may choose.
William R. Cloug:
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AMERICAN BAPTIST CHURCHES OF NEW HAMPSHIRE
EIGHTY-NINE NORTH STATE STREET
CONCORD, NEW HAMPSHIRE 03301
Associate Executive Minister <^&-t-JSffi& Address reply to P. O. Box 796
REVEREND DOCTOR ARTHUR N. FOYE CfT^Hm!! Telephone . Area Code 603 225-3316
November 22, 1977
Mr. James Rollins
Lakes Region Planning Commission
Main Street
Meredith, N.H. 03253
Dear Jim:
I have been asked to write on behalf of the Board of Directors
of the New Hampshire Baptist Youth Guidance Foundation.
We are concerned that Dan Hole Pond remain a non-polluted
lake for the recreational enjoyment of the camps and property owners
along its shores. Therefore we highly support any effort of your
planning commission to restrict the size of outboard motors used on
the lake to less than five horse power. We at our camp have urged
that folks camping with us utilize sailboats or canoes or rowboats
rather than to bring motors that add to the congestion of the lake
and the pollution of its waters.
We would be glad to confer with you further if there is any
additional need for support in the decisions that you make as a
planning commission.
Cordially,
Dr. Arthur N. Foye •"
Associate Executive Minister
ANF:bs
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58
inh
^1 •• • University of New Hampshire Durham, New Hampshire 03824
College of Life Sciencei
and Agriculture
Department of Botany and Plant Pathology April 25; 1978
Neimith Hall
U.S. Environmental Protection Agency
Environmental and Economic Impact Office
John F. Kennedy Federal Bldg. Itoom 2203
Boston, Massachusetts 02203
Attention: Robert E. Mendoza
Dear Mr. Mendoza:
After a cursory review of the Draft EIS for the New Hampshire Lakes Region,
I would like to leave with you two thoughts for possible inclusion:
1.) p. 100 - The report suggests to the reader that only 'one possible concern1
has been recognized, with regard to the water quality status of Lake
Winnipesaukee, that being inordinately high trace metals in biota and
sediments. This is clearly misleading, and omits the well known pro-
blems of Water Milfoil growth in several locations in the basin, and of
blooms of Cyanophyeae (blue-green algae) in Wolfeboro Bay and elsewhere
during the past few years. To conclude that L. Winnipesaukee is oligo-
trophic is unfortunate, and suggests an oversimplified approach to modell-
ing.
In addition, the Draft EIS fails to mention the reason for the
abundance of phytoplankton and aquatic vascular plant profusion in the
lake, which must include the problem of recycling of Phosphorus and
Nitrogen from enriched sediments. Studies now in progress under my
direction on this campus could be enriched by recognition by E.P.A.
of this problem, and appropriate funding. I submitted an executive
summary to EPA Boston two years ago, and was told that studies of
internal recycling • are not yet listed as goals of EPA. • The omission
of any mention of this problem in the Draft EIS convinces me that
nothing has changed the list of goals. This is unfortunate, as I know
we could proceed much more successfully with your backing.
2) p.102 - The description of the phosphorus - budget models would be more
complete, if you would simply include the three equations used for class
1, 2, and 3 lakes.
Sincerely,
Assistant'Professor
ALB/lk
CC: j/MT. M. Nolin
Mr. Wm. Adams, Jr.
Prof. Gordon Byers
Mr. Kenneth Kimball
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59
OFF:CF OF COMPREHENSIVE PLANNING
STATE OF NEW HAMPSHIRE
~~~~""CflJOO6JBBSGHXX CONCORD 03301
26 Pleasant Street
(603) 271-2155
May 11, 1978
Mr. Michael Nolin
208 Project Director
Lakes Region Planning Commission
Humiston Building
Meredith, N. H. 03253
Re: DEIS Lakes Region Water Quality Management Plan
!
Dear Mike:
It is particularly good to see this document in printed form. Doubly
so because it follows the intent and contains the material originally envis-
ioned in the original Project Control Plan. My general comments are«well
done. The report should provide a wealth of clear, concise information to
local officials which should translate into a good Implementation experience.
There are two immediate and specific comments which should be addressed.
First, the basis for the Land Use Task was work prepared and developed as part
of LRPC's HUD 701 program. It would appear to me that such a statement should
be made, possibly in the preface on page ii. You may recall that EPA was less
than enthusiastic about the detailed Land Use Planning. Acknowledging the
HUD contribution would strengthen both programs. At the same time, the con-
tribution of Russ Thibeault particularly with regards to the Land Use
(Industrial and Commercial) and related demographic and economic support was
very important to that aspect of the program.
The second comment relates to 'Land Capability. The map included should
be called just that, Land Capability Map, not a Plan.
Beyond the above comments, the report appears to cover the point included
in the work program, and provides sufficient meterial for an extended imple-
mentation program. I'm sure detailed concerns will be expressed by local
officials. My previous review of the recommendations for my home town of
Gilford resulted in no problems.
Good luck with your Implementation program.
Co
Javid G. Scott
Director, Regional Planning
DGSram
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60
STATE OF NEW HAMPSHIRE
DEPARTMENT OF PUBLIC WORKS AND HIGHWAYS
JOHN 0. MORTON BUILDING
May 2k, 1978 CONCORD, N.H. 03301
JOHN A. CLEMENTS. P.E.
COMMISSIONER
Mr. Benjamin K. Ayers, Jr., Chairman
Lakes Region Planning Commission
Main Street
Meredith, New Hampshire 03253
Dear Mr. Ayers:
This is in reference to the January 1978 Draft of the Lakes
Region Water Quality Management Plan and Environmental Impact Statement
submitted by the Commission to Region I of the Environmental Protection
Agency.
We have reviewed a Draft copy with interest and offer comments
concerning road salt use as described under Section 5, Non-Point Source
Controls, on pages 205, 206, and 210. Within this section concern is
expressed for potential environmental and health problems related to the
use of road salt for winter highway maintenance.
The Department has for many years been concerned with the use
of calcium and sodium chloride for snow and ice control while attempting
to operate within that cost-benefit region which optimizes economic-
ecologic cost against economic-safety benefits. Certainly the cost-
benefit of human health concerns is a legitimate component of the salt
use decision process.
Nationwide concern for the effects of deicing salts on the
environment has prompted research and analysis results of which may
assist with an understanding of- the New Hampshire situation. Attached
for your reference are report copies of three recent research efforts
entitled:
1. Benefits and Costs in the Use of Salt to Deice Highways
by Robert Brenner and Jack Moshman for the Institute for
Safety Analysis, published November 1976.
2- Economic Impact of Highway Snow and Ice Control. September
1976 Interim Report by Bob Welch et al for the Federal
Highway Administration, U. S. Department of Transportation.
"LIVE FREE" OR DIE"
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61
Mr. Benjamin K. Ayers, Jr. - 2 - May 2U, 1978
3. Economic Impact of Highway Snow and Tee Control, December 1977
Users Manual by J. C. McBride et .al. for the *>erieral Highway
Administration, U. S. Department of Transportation. Also
**eoutive Summary for this Report as authored by J. C. McBride.
To provide oroper perspective of the Department1s "Pare Pavement"
Policy also ^nclosed is copy of a paper prepared by State Maintenance
Engineer Robert A. Hogan describing the criteria which guide our personnel
in the conduct of winter highway maintenance. Also included is copy of a
February 6 letter to the Chairman of the New Hampshire House of Representatives
Committee of Science and Technology concerning a legislative proposal to
study the use of salt for winter maintenance of highways. It summarizes
current efforts and statistics concerning the winter maintenance function.
The Department is continuously striving to reduce the quantities
of road salt used by seeking increased mechanization of our dispensing
vehicles, frequent calibration of spreading devices, conducting employee
seminars on all aspects of salt use, utilizing improved roadway and bridge
design and increasing our permanent covered storage capacity. There is
room for improvement and we are steadily progressing as time and funds
allow. Generally the same can be said for the winter maintenance efforts
of cities and towns.
During 197^- an experimental one mile section of porous (open
graded) asphaltic concrete pavement was constructed on 1-93 in Concord
on both north and south bound lanes from Exit lU northerly. The pavement
did reduce the level of vehicle tire noise and reduce the spraying of
moisture during wet periods. However, during freezing weather conditions,
we found the water or brine solution remained in the porous pavement voids,
not draining with the lateral pitch of the roadway as with conventional
pavement surfaces. As a result vehicle tires contacted the moisture and
tracked or spread it over cold pavement surfaces which caused icing conditions
within the limits of the porous pavement and on the adjacent conventional
pavement for a considerable distance.
To provide safe pavements we found it necessary to apply
additional quantities of salt to remove the icing no-*-ed above. The
quantity used was more than double that applied to adjacent conventional
pavement. Based on this finding we consider further installation of
porous pavements as contrary to the publics interest; other states have
reported premature stripping or wear of aggregate from the pavement and
filling of voids by sand used for winter maintenance. Initial benefits
of porous pavements seem to be out weighed by subsequent deficiencies
and functional failure.
Hopefully this information may be of assistance in finalizing
the report. If additional assistance is desired at any time, please
feel free to contact us.
yours
''John A. Clements,
JAC/LSK/gj
P.S. Have sent attachments "ur^er separate cover"
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62
NEW HAMPSHIRE DEPARTMENT of RESOURCES and ECONOMIC DEVELOPMENT
6EORGE OILMAN
COMMISSIONER
June 20, 1978
U. S. Environmental Protection Agency
Environmental and Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Attention: Robert E. Mendoza
Dear Mr. Mendoza:
This letter is in response to the March 27, 1978 letter of Mr. Adams,
Jr., requesting comments on the Lakes Region Planning Commission Section
208 Water Quality Management Plan Draft EIS. The Recreation and Resources
Planning Office in this Department has reviewed the Draft and makes the follow-
ing comments.
The Recreation and Resources Planning Office is responsible for the
preparation and implementation of the New Hampshire Outdoor Recreation Plan.
The Plan identifies the lack of coordination among State agencies as a major
problem. It is a goal of the Plan to obtain the most recreational benefits
with the limited amount of available funding. Projects which combine water
clean up with recreational uses would help satisfy this goal.
The primary purpose of the Clean Waters Act is to make our waters fish-
able and swimmable, to make them fit for recreational use. Recent amendments
to the Act mandate the identification of and planning for recreational op-
portunities generated by cleaned up waters. The amendments apply specifically
to the planning phases of both Section 201 and Section 208 of the Act and may
apply to the Lakes Region Draft Plan.
It is evident in reviewing the Lakes Region Draft Plan that little atten-
tion has been given to the direct relationship between the cleaned up water and
resultant recreational benefits. A separate planning section outlining the
recreation potential and recommended actions should be included in the final
plan.
P.O. f BOX 856 .. .CONCORD. Nil. OCi:iOI TELEPHONE BOl
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63
- 2 -
If you have questions or need further explanation please contact David
Hartman at the Recreation and Resources Planning Office, Telephone 603-271-2175.
Sincerely,
GG/DH/k ^ Geofge Gilman
Commiskioner
cc: Michael Nolin, 208 Project Director, Lakes Region
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64
1£t\t jblate of ^Ncfo JMamp»l|ire
COMMISSIONERS
P ollution fflontro1
WAYNE E. ROBINSON, Chairman &+»+» Tnlinrninrn XitJli4i»tn
WILLIAM E. ARNOLD ^ta« Moorafnre Emitting
ALBERT E. BARCOMB, M. D.
LUTIE BRADEEN JMazeit Brtut (Eonrord 03301
STACEY W. COLE, Vice Chairman *•
WALLACE EMERSON Dennis RTTundervi 1 1 e
GEORGE E. FREESE, JR. ^fet 603-271-2281 *X))WS*){J(XlX)(M»X8H»
HOWARD NORTHRIDGE IShnteal Secretarv
DOUGLAS PHILBROOK -, . ,,9 Techn.cal Secretary
' |£
July 11, 1978
Mr. Michael P. No!in
208 Project Director
Lakes Region Planning Commission
Main Street
Meredith, New Hampshire 03253
Dear Mr. Nolin:
I have reviewed a copy of the draft report entitled "Lakes Region Water
Quality Management Plan & EIS for Impact on Air Quality". My review indicates
that there are no direct impacts. To the extent that the implementation of the
plan affects land use, then there could be some resulting indirect impact in
the form of changes in the air pollution emission patterns and densities.
Very truly yours,
^S^s^AWVU* W O Wyy^LaAAj §Xj^_
Dennis R. Lunderville
Director
Air Pollution Control Agency
TMN/pv
cc: Bill Fuller - Water Supply & Pollution Control Commission
"Live Free or Die"
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21
ROBERT E.WHALEN
COMMISSIONER
STATE Of NEW HAMPSHIRE
DEPARTMENT OF HEALTH AND WELFARE
DIVISION OF PUBLIC HEALTH SERVICES
61 S. SPRING STREET
CONCORD 03301
f\t\
1
t"
MAYNARO H. MIRES, M. D.. M. P. H.
DIRECTOR OF PUBLIC HEALTH SERVICES
July 19, 1978
Robert E. Mertdoza
U.S. E.P.A.
Environmental and Economic Impact Office
J.F.K. Building Room 2203
Government Center
Boston, MA 02203
Dear Mr. Mendoza:
In reviewing the Lakes Region Water Quality Management Plan and
Environmental Impact Statement dated January, 1978 I can find nothing
which is contrary to State plans or policy with the TO I lowing exceptions;
1
the plan suggests the licensure of septic tank pumpers. The fact is
it is already State law that the pumpers be licensed as well as
their disposal sites for the pumpings.
The plan suggests the phasing_out of private septacue sites. This_Js
not a good idea. The Towns are not providing sites as they are re-
"0711 i red to do and the private sites are the difference between havfng
a real serious problem and just a problem. In addition I do not
believe it is necessary or wise to interfere with private enterprise
who frequently do a better job than publicly owned or operated
facilities.
The other major area of interest is the suggested grouping of Towns
and indication that they should try to regionalize. A large number
of these Towns are already in cooperjtive_efforts^an'djL)i!3 plan"!
"slioTTTd have acknowledged those exlstTngToQpe^tives and adcied the
o-chers "aT they didZT ' "
If you have any questions, please feel free to contact me.
Sincerely,
— —/'/ / >''
Thomas L. Sweeney, Chief
Bureau of Solid Waste Management
TLS/sl
"Live Free or Die"
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56 m 11978
Sty* £>tai? of Nfui ^amjtjsifir*
COMMISSIONERS /^IH^
ROBERT J. HILL. Chairman lESSl WILLIAM A. HEALY. P. E.
lloHf^a-jjrfiwBI Executive Director
HERBERT A. FINCHER, Vice Chairman ^s|isr;3§3^
DONALD C. CALDERWOOD, P. E. ^^^^^ THOMAS A. LA CAVA. P. E.
CHARLES E. BARRY Deputy Executive Director
RICHARD M. FLYNN fflaltr Ihipplg att& Jlfllliitifltt Cttmttrnl tfnmmiraimi and Chi8f
ELMER L. JOHNSON
_„. T LINDSAY M. COLLINS, P. E
GEORGE M. McGEE, SR. «
JAMES E. MINNOCH P.®. B«« 35-105 EflUfclltt 1R0a& Mu°cipCa'0Se°vices
MAYNARDH. MIRES, M. D., M. P. H. Qkmmrb 03301
WAYNE L.PATENAUDE
ROBERT M. SNOW J '
JAMES VAROTSIS
Mr. Michael Nolan
208 Project Director
Lakes Region Planning Commission
Box 302
Meredith, NH 03253
SUBJECT: REVIEW OF DRAFT: LAKES REGION WATER QUALITY MANAGEMENT PLAN
& EIS - JANUARY 1978, TASK 9F-2.
Dear Mike:
We have reviewed the above project document and note that the material
incorporates several of our recommendations made in our February 8, 1978
letter concerning the LRPC WQMP/EIS Summary.
We have held off commenting upon this document pending conclusion of
your series of public workshops on the plan/EIS, so that we may, in addition,
comment on questions pointed out during these meetings. We offer the follow-
ing:
Franklin Workshop
1. It was pointed out that the Town of Belmont has recently passed an ordinance
prohibiting composting toilets. Since this is just opposite from your
recommendations based upon your areawide 208 program, you may want to
note this change in the final document and perhaps expand the discussion
of this in the text.
2. We recommend that the final document also discuss in more detail LRPC's
recommendations on the use of herbicide application for macrophyte '
control as well as recommendations based upon the heavy metal analyses /•
fish and sediment. There appears to be overriding concerns by the public
that these areas are not assessed sufficiently.
3. There were several misconceptions regarding septage handling and disposal
practices that should be clarified. There are np_ existing state laws or
"Live Free or Die'
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67
Mr. Michael Nolan -2- May 26, 1978
regulations requiring that septic tanks be pumped out every three years.
We at the Commission do recommend that a good operation and maintenance
practice is to pump out tank solids every 3 to 5 years. Table 5-1, on
page 173, recommends that septage pumpers/haulers be licensed. They are
already via the Bureau of Solid Wastes, with annual license permits being
mandatory. Likewise, the recommendation that the State incorporate septage
provisions in treatment plants is already addressed by RSA 149-6:11,
amended in 1977, effective August 26, 1977. Apparent exxeptions to this
law (for example, refer to the letter by Dickey to Rist-Frost Assoc.
regarding the Bay District facility plan and apparent lack of septage
considerations) are due to contract limitations and the grandfather!ng
of projects already in the works prior to the effective date of the 1977
law. See item 4 on page 203 which conflicts with the aforementioned
table.
Also, under item 5, you recommend phasing out private septage dumping
sites. We see no discussion on this point in the text. Please justify.
Center Harbor Workshop
It was stated that the WS&PCC is the regulatory authority for septage
disposal. In fact various regulatory functions are now shared between
WS&PCC and the Bureau of Solid Waste, as pointed out on page 278. While
we are on the subject, refer item 8 on page 204, "considerations should
be given to disposal of septage by lime stabilization". "Lime" stabili-
zation is a chemical treatment, not a disposal method per se. Also you
suggest that "a filtrate could be discharged to the ground or a receiving
stream". Existing WS&PCC regulations require secondary treatment before
discharge to a surface water. No new discharges to tributaries to a lake
would be allowed.
Gilford Workshop
LI IJJl U..:j|L...JtJLJlL.JL-JL-JL-JL-JL-JL-JL-JL-JL-JL-JL-JUI ILII - I II III II.......IT... }
The point source recommendations should be revised to accommodate the
need to eliminate the discharge from the Bel knap Recreation Area prior
to 1983.
Other Points in Text:
1. Page 230. Item 2. Ossipee does not have a facilities plan completed
as of yet. The "planned facilities" described on page 231 for Ossipee
have not, in fact, been agreed on.
2. Page 244. Footnote 2. "O&M costs must be paid entirely by the towns."
It should be noted, however, that the towns must collect those costs only
from the users.
3. Page 119. Color coding of legend is not clear. It is difficult to
distinguish, for example, between "wetlands" and "Sand and Gravel", and
"Hardpan" and "Flood Plains".
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68
Mr. Michael Nolan
-2-
May 26, 1978
4. Pages 120 and 121. It is difficult to read the green overlays. Perhaps
orange or red overlays would show up more clearly.
Should you have any questions or comments, please contact us at your con-
venience.
Very truly/yours,
Robert A. Cruess, P.E.
Director, Permits and Surveillance
RACrcaj
cc: Ron Manfredonia, EPA
Karen Kelly, EPA
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69
of
COMMISSIONERS /g^sl^ STAFF
ROBERT J. HILL, Chairman I^^^M WILLIAM A. HEALY. P. £.
HERBERT A. FINCHER, Vice Chairman IdSSBUH Executive Director
DONALD C. CALDERWOOD, P. E. ^||feS§f
CHARLES E. BARRY ^*^£*r RICHARD P. GROSSMAN. P. £.
RICHARD M. FLYNN j^ ^^ ^ $^1** €flntrni <&flmmtaHi0n °~% St?K£ror
ELMER L. JOHNSON
GEORGE M. McGEE.SR. fJttJSrfltt flttrfc LINDSAY M. COLLINS. P. E.
JAMES E. Ml NNOCH $I.<0. SflX 35 — 105 UllUllUtt K0H& Director of
MAYNARDH.MIRES.M.D..M.P.H. CflttTnrh 03301 Municipal Services
WAYNE L. PATENAUDE
ROBERT M. SNOW September 29, 1978
JAMES VAROTSIS
PAUL T. DOHERTY
Mr. John L. Dickey
Regional Planner '
LRPC - Humiston Building
Meredith, NH 03253
SUBJECT: REVIEW OF FINAL PLAN/EIS - LAKES REGION WATER QUALITY
MANAGEMENT PLAN SEPT. 1978
Dear John:
We have reviewed the above document in some detail, and, as you
know, provided an informal page-by-page personal review. For the record,
we would like to document some of our previous comments.
1. INTRODUCTION - 4th Para. The first treatment facility in the Lakes
Region was one in Wolfeboro in 1936, not in Laconia.
2. Figure 1-1. Under "Implementation" for WS&PCC, the phrase "carry out
and enforce the recommendations in the plan" is ambiguous. In the
Rules and Regulations under 40 CFR 131.20(h), it is noted that certifi-
cation of the LRPC "208" plan implies that the plan "will be implemented
and used for establishing permit conditions, the nonpoint source controls,
schedules of compliance and priorities for awarding grants for construct-
ion of municipal treatment works pursuant to Section 201(g) of the Act,
..." In this way the WS&PCC will support certain recommendations in
the LRPC plan under existing programs, i.e., the construction grants,
and clean lakes programs, given the constraints of a priority list and
existing funding. We would certainly be in no position to "enforce"
such recommendations as the 150 foot minimum distance from the leach
field/dry well to surface water suggested for adoption at the town
level. The towns right to more stringent regulations does not require
the WS&PCC to "enforce" these local regs.
"Live Free or Die"
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70
Mr. John L. Dickey -2- September 27, 1978
3. In the town-by-town summaries, it should be noted that the "priority
of recommendations" is a home rule issue, and that via the documented
public participation process, it incorporates local review. Certifi-
cation of the plan by the Governor does not, in fact, set the priority
of recommendations in concrete, nor infer a priority timetable for
implementation dictated by the State.
4. In the town-by-town summaries, it is recommended that easements for
recreational trail systems along interceptor sewer lines be negotiated
"with the WS&PCC". In no instance does the Commission control such
above-ground rights. These would have to be negotiated with the indi-
vidual towns and with the Public Utilities Commission (State-owned
railroad rts-of way)l We suggest deleting "with WS&PCC" under the
"cost" column.
5. In the summary for Center Harbor, it is recommended that no local
connections be permitted along the interceptor (to be State owned).
Several issues need to be addressed here. The first is that this
recommendation is not strictly a point-source control and perhaps
should be listed under "land use controls". Secondly, this portion
of the proposed interceptor would in fact be a force main, which in
itself is going to constrain the number and costs of tie-ins. Thirdly,
local zoning controls may be necessary to minimize such potential
strip development, in itself a separate recommendation.
6. In the summary for Gilford, a correction is required on the map,
designating the Gunstock Ski area as "existing sewerage". Delete
additional words in legend "noted on plan (Gilford Sewer Precinct).
7. In the summary for Gilmanton (and other towns) there is no associated
cost suggested for the individual homeowner who regularly pumps out
his or her septic tank per your recommendation. We suggest that an
average real cost for this service averages $40-$50.
8. In the map for Meredith, the final recommended route of the Meredith
to Center Harbor interceptor should be shown.
9. Under the recommended local actions for Moultonborough, under point
source controls, we recommend that the text state "utilize municipally-
owned small community wastewater systems to serve clusters of existing (
homes"; the underlined as required by the Clean Water Act amendments f
of 1977. We also suggest that the impact of such a recommendation would
be of "equal or greater cost than for construction of sewer lines",
not "considerably less than" as stated. O&M costs to users would also
be significant (the N/A for "not available" in the cost column is
ambiguous, and also may be interpreted to mean "not applicable").
10. In the written summary forWakefield, the text should more accurately
reflect the negotiated plan of study for the existing, on-going facilities
study. Only Sanbornville and Union will be studied in detail, with
the remainder of the town of Wakefieldjjiven no in-depth review. We
would suggest that text might indicate that the remainder of the town
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71
Mr. John L. Dickey -3- September 27, 1978
would be studied in detail in the future as needed". We also recommend
the Plan B map for Wakefield be revised to emphasize the current
detailed study areas of Union and Sanbornville.
11. In Part 2 - Water Quality Sampling and Analyses. The discussion
leading up to Tables 2-3 and 2-4, refers to "goals and standards"
for each water quality parameter. We can reasonably support certain
of the recommended levels for certain parameters as State-wide goals,
but certainly would have difficulty supporting these suggested criteria
as part of our water quality standards. As a single example, the
proposed "permissible level" for total phosphorus of 0.025 mg/1
may possibly be "more stringent than generally observed water quality
criteria in other parts of the country". However, we would be quite
disturbed if such a level were routinely found in our inland lakes
during the summer months, as such a level may be indicative of an
algal problem. On the other hand, levels higher than these are typical
in the receiving zones below secondary treatment plant outfalls during
the summer months. Incorporating such a standard would require more
than sec. treatment, and this approach to advanced treatment schemes is
certainly not the trend of the future. We, in fact, feel that our
existing standards are more stringent by not allowing any new point
sources of nutrients into lakes or their tributaries to lakes. We
recommend that the source of the information in Tables 2-3 and 2-4
be noted (NAI, date, output title).
12. Following pages. The scientific name for water milfoil should be
cited as follows: Myriophyllum heterophyl1 urn or italics.
13. In Part 3, nonpoint source controls, Table 3-1. Under Boating, the
elimination of oil and gas discharges should reference the WS&PCC for
implementation, not Safety Services. Under septage disposal, we
recommend dropping the recommendation regarding abandoning use of
private disposal sites, due to lack of strong supporting data.
14. In the discussion of the recommended Mandatory Septic Tank Guarantee,
we would like to note, for the record, several real-world impracti-
calities in the approach. Issues that might arise (and did arise when
a similar suggestion was acted upon [in the negative] by the Commission)
include: would the builder (installer) of a system be liable for some-
one elses faulty design? Could the installer modify the design at the
time of construction to meet his perceived responsibilities? Since
intensity of use may be a significant factor in system longevity, would
the responsibility for system viability of a seasonally used system
compare equally to a continuously used one? Are the homeowners willing
to pay the added costs of installer liability insurance?
15. Under the discussion of Community Treatment Systems, item 4, it is
suggested that effluent might be discharged to a stream "or other body
of water". As noted above, no new point sources of nutrients can be
allowed into lakes or tributaries to lakes. As applied to certain towns
in the Lakes Region, i.e., Moultonborough, such a restriction makes a
discussion of extended aeration and physical chemical package treatment
schemes a moot point. Another factor to consider is that the Clean
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72
Mr. John L. Dickey -4- September 27, 1978
Water Act amendments of 1977 do not allow second homes to be treated
similarly to year-round homes in determining eligibility costs for
municipally-owned small community systems. Specifically, the law
does not consider second homes to be eligible for Federal construction
grants funds. The effect of this in the Lakes Region is that any
area having a significant proportion of vacation homes would most
likely be forced to spray irrigation or to regional sewers out of
the watershed as the most cost effective solution.
16. In the discussion of vacuum systems for waste conveyance, some mention
should be made of the high energy cost of maintaining continuously
operating equipment.
17. Under Boating, enforcement. It should be noted that the WS&PCC has
two enforcing officers.
18. In the list of pump-out facilities, the following should be added or
changed.
Meredith Meredith Marina (not Winn. Cruiser Sales)
Moultonboro Trexler's Boat Yard (not Moultonboro Marina)
Wolfeboro Bay Goodhue & Hawkins Navy Yd - Portable
19. Under Septage Disposal - Recommendation 1; The recommendation to
include a reporting system to document disposal sites used, volumes
of septage pumped and disposal locations is already being implemented
under the statewide "208" program "Leachate component" in cooperation
with the Bureau of Solid Wastes.
Recommendation 2: Suggest rewording to state "municipalities must
provide carefully located septage disposal sites." Delete reference
to phasing out private sites.
Recommendation 3: A change in emphasis is suggested. Instead of
recommending municipal or multi jurisdicionally-owned septage hauling
services that would eliminate private businesses, we would recommend
a list of intermunicipal combinations for regional septage disposal
sites to take advantage of existing planned wastewater facilities.
20. In Part 4 - Point Source Controls - under "Cost to Connect from Each
House to the Sewer line", we recommend clarification of the ledge
removal costs (need for "less-than" symbol). Additionally in Tables
4-1 and 4-2, we suggest a more reasonable first year OSM cost for the
Alton Bay Extension to be $40,000 instead of the $207,000 indicated
by Hoyle, Tanner, & Associates, Inc. based on revised WS&PCC estimates.
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73
Mr. John L. Dickey -5- September 27, 1978
If there are any questions concerning any of the above, please contact
us at your convenience.
Yours truly,
Robert A. Cruess, P.E.
Associate Sanitary Engineer
RACrcaj
cc: Mr. Ron Manfredonia
Mr. Kim Ayers
Mr. Dan Martin
Mr. Warner Plummer
Mr. Richard A. Flanders
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DEPARTfaEBT OF TRANSPORTATION <^e AVW
FEDERAL AVIATION ADMINISTRATION
NEW ENGLAND REGION
12 NEW ENGLAND EXECUTIVE PARK
BURLINGTON. MASS. 01803
MAY 0 8 1373
U. S. Environmental Protection Agency
Environmental and Economic
Impact Office
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
Attn: Robert E. Mendoza
Dear Mr. Mendoza:
We have reviewed the Draft Environmental Impact Statement for the Lakes
Region Planning Commission Section 208 Water Quality Management Plan and
have some concern with development that may be encouraged by installation
of proposed sewerage systems.
The Plan specifies planned sewerage extensions in the vicinity of Laconia
Airport and notes the impetus this gives to strip development. We would
caution that planning include adequate controls to prevent land-use develop-
ment incompatible with noise from airplanes using the airport. Coordinat-
ion of planning efforts with the Airport Master Planning process recently
initiated would be helpful.
Thank you for the opportunity to review the proposal for any impact on
aviation interests.
Sincerely,
Wit
RA'XMOfND W. STONE
Chie4, Planning and Appraisal Staff
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE: AugUSt 7, 1978
SUBJECT: comments on Lakes Region 208 Plan
75
FROM:
-CEIV
EPA
Allsup, Public Participation Office
. }
1978
TO: Ron Manfredonia, Water Quality Branch
The plan was prepared within the letter and the spirit of the public
participation requirements. Particular strengths appear to be: wide-
spread publicity, effective workshops and good working relationships
with the towns. The process itself was Impressive because it offered
decision makers a clear choice between no action, structural and non
structural approaches. Since a major problem with many other 208 plans
has been a lack of issue definition, securing early support for the
environmental or non structural alternative is a significant accomplish-
ment.
My concern is whether this plan will stand the test that the "old yankee"
constituency is likely to put it to in each town. More detailed documenta-
tion of local consultation which supports town by town recommendations
might have been valuable to those who have not followed plan development.
Reaching the "old yankee" constituency is not easy. Probably it was
injudicious, if not impossible, to focus on this group during 208 planning.
Facilities planning, however, will bring new and skeptical participants
out to discuss zoning, taxes and sewers. Implementation of 208 recommenda-
tions would be furthered if the Lakes Region Planning Commission could
take a lead role in initiating public participation in any 201 planning
which is concurrent with the third year funding period.
In conclusion: One of the best public participation efforts we are
likely to see; Let's see whether it is possible to continue public partic-
ipation in third year with emphasis on 201.
cc: Mike Nolin, Lakes Region Planning Commission
EPA Focn. 1320-4 (Roy. 3-761
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76
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE: June 12> 1978
SUBJECT: Draft 208 Flan for Lakes Region Commission
FROM: Clara Chow, Sanitary Engineer, Water Supply Branch/j^f
T0: Ronald G. Manfredonia, Northern New England Planning Section
Water Quality Branch
Having reviewed this draft 208 management plan, it can be seen that
there were no formal water supply considerations. The plan, however,
did acknowledge the need to protect aquifer recharge areas so that
future water supplies may be protected as well as avoiding ground-
water pollution. The recommendations for carrying out these protec-
tion measures were satisfactory, but they lack substance and cohesive-
ness, because there was no previous water supply information, such as
inventory data, to indicate the need for the recommendations nor were
there any relationships between water supply and water quality problems
to demonstrate the importance of those recommendations. Neither the
Project Control Plan nor this draft 208 plan emphasize the subject of
water supply, but in the summary chapter of the 208 program, several
towns stated aquifer protection as a high priority item. This would
require an indepth study of water supply in order to comprehensively
address the problem.
In the alternatives for water quality management, Alternative #2 pro-
poses the construction of sewer lines. Sewering can open up a new
series of point and nonpoint source pollution problems especially in
sensitive land areas like aquifer recharge zones. More impact evalua-
tion of this proposal is needed particularly when some of the planned
sewered areas in Chapter 4 overlap potential high yield aquifers.
The LRPC should establish a continuous program to update and integrate
their management plans with water supply programs as more information
is obtained. Constant improvement of a management plan is a good
strategy for pollution abatement and environment protection.
EPA Form 1320-6 fRev. 3-76)
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Federal Building, Durham, New Hampshire 03824
May 25, 1978
Mr. Michael Nolin
Lakes Region Planning Commission
Main Street
Meredith, New Hampshire 03253
Dear Mike:
We have reviewed the draft of the Lakes Region Water Quality Management
Plan and Environmental Input Statement, and offer the following comments:
1. Suggest listing sources of detailed technical information on the land
capability plan map. This will help clear up potential confusion
among users.
2. Suggest stronger consideration be given to accomplishing non "urban"
controls through educational and technical assistance, and cost
sharing accomplished through existing voluntary programs. This is
generally better accepted in rural areas. The agricultural community
and rural landusers are, and have been, carrying on programs that
accomplish a certain amount of non-point pollution control for many
years through this approach. Several parts of the text fail to
recognize this.
As you are aware, Section 35 of the Clean Waters Act of 1977 (P. L.
95-217) provides for cost sharing through long-term contracts for
installation of certain non-point pollution control practices on rural
lands. We suggest that this be considered as the planning process
continues.
3. All references to "SCS Soil Survey" should be changed to "National
Cooperative Soil Survey".
4. Page 91 — We suggest including County Conservation Districts in the
chart under "Local".
5. There appears to be some miscoloring of soil maps on pages 119 and 122.
6 Page 150 — There should be strong emphasis on what rural communities
will need for fire fighting capability and road design requirements
to service cluster developments.
7. Pages 187 and 188 — The relationship between storm water runoff and
erosion appears unclear. Suggest you handle what comes off of
developed areas (streets, roofs, etc.) separately from "rural runoff
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78
8. Pages 189 - 192 and Appendix I — Memorandum of Understanding was
signed between the Lakes Region Planning Commission and County
Conservation Districts in October, 1977. These Conservation Districts
will be the prime source of technical assistance.
9. Page 250 - Table 7-1 — Conservation Districts and the State Conservation
Committee do have statutory authority. See Revised Statutes, Annotated -
Chapter 430-B, inserted by 1967 366:1.
The Soil Conservation Service also has statutory authorities.
10. Page 266 — The Soil Conservation Service provides on-site technical
assistance in erosion control and agricultural waste management problems
through the County Conservation Districts. The Soil Conservation Service
also administers a program for cost sharing in high priority areas
(P. L. 95-217).
Technical assistance on cost sharing is also provided to communities
for certain project type work through the RC&D program.
11. Page 266 — The relationship between good erosion control and keeping
fertilizers, pesticides, etc., on the land should be emphasized.
12. Page 352 - Section 12 A-l — Manure spreading guidelines adapted to
New Hampshire are on file in County Conservation District offices.
13. Page 395 — 9th line — Change the word "Commission" to "Service".
Thank you for the opportunity to review this draft. If you wish clarification
or further explanation of comments, feel free to contact me.
Sincerely
L. J. Porter
State Resource Conservationist
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE: May 25, 1978
SUBJECT: Draft-Lakes Region Water Quality Management Plan and EIS (1/78)
Nonpoint Source Controls
FROM-. William L. Lucas
Resource Conservationist
TO: Ronald F. Manfredonia
Northern Hew England Planning Section
Comments: On page 189, Section C - Erosion and Sedimentation - Improper
agricultural and timber harvesting activities are listed as erosion and
sediment problems of significant magnitude. On page 266, under heading
(\] Participating Agencies; fourth paragraph describes in a general way the
agricultural water quality problems then states that agriculture does
not appear to be a significant .problem. This needs clarification as it is
contridictory to statement on page 266. Fourth paragraph might be included
in other section rather than under Participating Agencies.
Agricultural section might be further described in the plan, even though
the assessment indicates that it is not a significant source of nonpoint
source pollution, the fact that it has been recognized as a contributing
/«\ NFS merits more consideration. The on-going Voluntary-Incentive programs
*• ' for the control of agricultural pollutants can be recommended in the Plan.
Consultation with the various agricultural agencies, i.e. Soil Conservation
Districts, Soil Conservation Service, Agriculture Stabilization and Conser-
vation Service would be of valuable assistance in the development of the
agricultural NFS section of the Water Quality Management plan.
Other NFS of pollution, except surface mining, have been addressed and the
proposed implementation programs are spelled out. It might be mentioned
that surface mining is not a significant Water Quality problem.
i,,\ The Water Quality Management plan as written would not be eligible for the
**' Rural Clean Water Program.
Recommendation: Conditional approval based on above comments.
William L'. Lucas
EPA Porn. 13?0 t,
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
JUN 13 1978
NORTHEAST REGION
15 State Street
BOSTON, MASSACHUSETTS 02109
ER-78/343 June 12, 1978
U.S. Environmental Protection Agency
Environmental and Economic Impact Office
John F. Kennedy Federal Building - Room 2203
Boston, Massachusetts 02203
Attention: Robert E. Mendoza
Dear Mr. Mendoza:
This is in response to the letter of March 27 from
Mr. Adams requesting comments on the draft environmental
statement for the Section 208 Water Quality Management
Plan for the Lakes Region, New Hampshire.
GENERAL COMMENTS
It is stated in the beginning and reflected throughout the
draft statement that the region's "heavily recreation based
economy...is dependent upon the quality of the lakes and
streams." Nevertheless, the only recreation activity dis-
cussed is boating. Power boating and the pollution pro-
duced are the major emphases given in the management plan
to recreational concerns. We are concerned, however, with
all recreation activities and with promoting the planning
and facilities to meet the needs of residents and non-
residents, presently and in the future. The New Hampshire
Outdoor Recreation Plan (NHORP) should be. the guide for
the implementation of state recreation objectives and
local objectives, particularly where the use of the Land
and Water Conservation Fund may be anticipated. The plan
under review does not reference the NHORP and it does not
stress that municipalities must coordinate their planning
for recreation facilities with the state program.
The absence of local and regional plans or plan elements
in comprehensive plans on the Lakes Region indicates the
low priority being given to recreation planning and thus
indicates the major interest in the region is to protect
the economy of the region rather than improve recreational
expenditures. The NHORP recommends as a minimum that each
community prepare a recreation plan that includes the
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81
appropriate map and current update from the inventory of out-
door recreation facilities and a brief statement of goals and
objectives of the town toward providing outdoor recreation
opportunities. The draft statement indicates only Laconia
has a park and recreation plan. Recognizing recreation's
crucial role, there should be more emphasis given to recre-
ation planning, which in turn would influence 208 planning.
The absence of a regional map (indicating the data shown
separately by towns) makes evaluating the impacts difficult
except at the town level. Whether individual town plans
will produce a coherent regional plan is questioned. Also,
without recreation plans or recreational data for the region,
it is impossible to assess the impacts on recreation, other
than to say that the environmental'improvements expected
should improve the quality of some recreational activities.
The plan should discuss in greater detail the potential for
multiple-use opportunities including recreation, education,
and conservation which can be offered or made available at
waste-water treatment plants and supportive facilities in
accordance with the Regional "Statement of Coordination"
between the Northeast Regional Office of HCRS and Region I
Office of EPA, and in accordance with requirements of the
Federal Water Pollution Control Act Amendments of 1977.
Mining, minerals, and geology (other than water-related)
apparently have been accorded little thought in the prepa-
ration of this DEIS. There is no mineral resources inventory,
no identification of presently mined sites, no bedrock or
surficial geologic maps, and no identifiable input from the
State Geologist or any other mining or mineral-resource
specialists.
All impacts discussed in the document are environmental.
There is no quantification of possible adverse or beneficial
economic impacts. Mining and mineral resources development
are mostly referred to as "extractive industries"" and then
given no further analyses as to unique problems, needs, or
the economic contributions they make. The report should
also point out that mineral extraction is usually a tempo-
rary and interim use of land. In New England, most mined
lands find rapid subsequent use; they are not left derelict
or abandoned, they end up as parks, hospital sites, shopping
centers, industrial parks, housing sites, forest land, etc.
In their desire, and it is a commendable one, to direct growth
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away from "environmentally sensitive areas," the authors
seem not to realize that mineral extraction occurs where the
mineral is located and, except for a few common varieties of
mineral deposits, economically viable alternative production
sites are not always available.
Agriculture accounts for a significant input of nutrients
and coliform to the river-lake system through the use of
fertilizers and from runoff of manure in livestock feeding
areas. The statement reviews other nonpoint sources of
nutrient input but fails to address the agricultural impacts
on water quality. Since the area does support a significant
amount of agriculture, a discussion of its impacts should be
incorporated in the final document.
The study has determined that phosphorus is an important
contributor to the eutrophication of most area lakes. A
major source of this nutrient comes from detergents used in
the cleaning of clothing and dishes. Several States, in-
cluding New York and Minnesota, have enacted legislation
limiting the sale of detergents containing high phosphate
concentrations. This has resulted in a significant reduc-
tion of phosphates in their systems. This alternative
should be examined as a potential means of attacking the
phosphorus problem.
SPECIFIC COMMENTS
\J . <• >«.
Page 61: The major Casipee Aggregates pit is not shown on
this map, nor is it shown in gray as an "existing develop-
ment—preempted area" on the accompanying Land Capability
Planning Area. The same appears true for the TiltqX Sand
and Gravel Company.
Page 84, 86: The use of a spray irrigation facility for
disposal of effluent is planned for the community of Wolfeboro,
The statement should indicate the type of effluent involved
and evaluate the effects of the spray irrigation system on
ground water.'
Page 9.1: Figure 1-1 states that for "Other Federal Agencies"
the Lakes Region Water Quality Management Plan/EIS would
serve "as a guideline for assessing local priorities, and as
a basis for awarding grants." For Land and Water Conservation
Fund grants, the NHORP is the plan against which grants must
be justified. For Implementation/Action as stated in the
NHORP, "Planning, acquisition and development priorities for
use of Land and Water Conservation Fund money will be
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83
established based on the inventory, demand, needs and special
studies." The recreational land uses identified in this
report are primarily privately operated as commercial enter-
prises (golf courses, driving ranges, ski areas, campgrounds,
racetracks, and amusement parks).
100: No consideration has been given to the anomalous
zinc and lead as possibly being the result of submerged
mineral deposits.
Page 133: Reference to sand and gravel in aquifers fails to
ftf\ rec°Snize that sand and gravel can be mined from some locations
\!>, without damage to the aquifer, and under some circumstances
mining can even increase recharge potential and concomitant
water productivity.
Page 152: It is 'difficult to understand the matrices in tables
4-0, 4-3, and 5-2 indicating expected impacts, and the process
\(e> for determining whether these impacts were beneficial or ad-
" ' verse is not stated. The definition of recreation as it. is
listed in these matrices is critical in this analysis and
should be included.
(7j Page 152: Table 4-0 should consider extractive industries.
Page 172-225 and 226-245: Monitoring measures for non-point
control sources (p. 172-225) and point control sources (p.
fg\ 226-245) should include consideration of the quantity and
' quality of surface-water sources of the project area. Such
data would be helpful in evaluating long-term effects of
waste-treatment processes on surface-water resources.
Page 199-202: This solid waste plan contains several ques-
f , tionable statements. Schiller Station has no rail transfer
(7 | facilities. It is supplied with oil by water and would
probably not be an economically viable candidate for conver-
sion to burn coal-trash mixtures.
r <\ The "Dover" metal recycling plant is in Madbury instead of
v i Dover, and it takes only junk auto bodies.
rtj) It is easier and cleaner to separate ferrous metals prior to
burning and easier to sell the product.
,.. Page 211: Under the adverse impacts from less use of road
'• ' salt, the draft statement identifies sand and gravel as a
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84
critical resource in itself. If it is a critical resource,
it should be accorded the same consideration given to other
critical resources .
Page 235: Industrial and commercial pollution sources are
not specifically identified in this document so no judgment
of costs and effects could be made.
Page 245: Table 6-6 should consider extractive industries.
Page 333: No statutory authority is cited giving the
U.S. Department of Agriculture "secondary authority" over
sand and gravel. This section should also make it clear
that reclamation of lands mined for sand and gravel is not
the same as authority over sand and gravel development.
Page. 3/1: Table 4-1 should consider extractive industries.
Page 388: Table 7-2 should consider extractive industries
as a separate and unique problem.
Appendix A: The "Model Zoning Ordinance'1 reports on page
308 that "obnoxious uses" are prohibited in .all zoning
districts. As defined, all extractive industries could be
defined as "obnoxious" even though extraction of sand and
gravel or stone is permitted in rural districts or industrial
parks if such use meets all other existing town ordinances.
Any other mining activity would require specific amendment
of the ordinance by a legal town meeting.
Appendix D: The "Steep Slope Conservation District Ordinance'
does not include sand and gravel or any other mineral extrac-
tion as a permitted use for owners or agents. Ice-contact
sand and gravel deposits frequently exhibit steep natural
slopes in part.
f ^ Appendix G: The "Model Aquifer Protection Ordinance" should
^ ' include peat harvesting under permitted uses on page 331.
Appendix K: The "Draft Model Ordinance, Erosion and Sedimen-
tation Control" includes all mining as "earth-disturbing
ifO activity," but under "Standards and Criteria and Plans" it
ignores mining and includes specific regulations that are
inappropriate for mining.
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85
The draft statement should consider the cumulative effects of all these
ordinances on mining. The Lakes Region itself has no minerals production
f22-} except construction aggregates, but it includes potential resources of,
or is geologically favorable in places for peat, dimension stone, clay,
nepheline, lead-zinc-silver, uranium, thorium, beryllium, and tin.
Thank you for the opportunity to comment.
Sincerely,
William Patterson
Regional Environmental Officer
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C. Response to
Comments
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s-
o
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J_ E
3 E
33
Alton -
Marc i a Keller
Franklin
Jim McSweeney,
City Manager
Gilford
0. Joseph April
Public Works
Director
Holderness
Dr. Lawrence
Staples
Laconia -
Frank
DeNormandie,
Public Works
Director
X
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19
20-21
I
22-23
24-25
26-27
Effects of Comments on the Final Lakes
Region Water Quality Management Plan
Opportunity for further comment given to all communities
prior to printing; all information checked for accuracy;
final plan condensed.
(1) recommendation for adoption of sewer ordinance deleted.
(2) (3) (4) (5) further information provided to the Planning
Board, no change in the final plan.
(6) additional future study areas added.
1. sewers for Webster Lake changed to high priority
2. map revised
3. Webster Lake added to the list of water bodies where
horsepower restrictions recommended
I. A. Gilford Facilities Plan recommends sewers for Gilford
Village, Pheasant Ridge & Governor's Island - no
change in the final plan
• draft plan recommended only future study for Gunstock
Acres & School house Hill Road with emphasis on other
actions to preclude sewer construction - no change in
final plan.
B. no change in final plan
C. recommendation changed to "consider recycling"
D. recommendation changed to "minimize the use of road
salt"
E. sewer to Gunstock Ski Area required to eliminate dis-
charge to Poorfarm. Brook - no change in final plan
Reference to "problem with current solid waste disposal
site" eliminated
t
1. no change in final plan
2. dates deleted from summary chart
• White Oaks Road recommendation clarified, no conflict
with approved City Facilities Plan
• Costs listed as preliminary planning costs
3. Name of specific marina deleted
• recommendation for mandatory recycling deleted
• impact "depletion of sand and gravel supplies" deleted,
priority changed to low
• impact changed to "contamination by extraneous
material"
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Effects of Comments on the Final Lakes
Region Water Quality Management Plan
88
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£ •«->
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ta o a
Q. o -r-
Effects of Comments on the Final Lakes
Region Water Quality Management Plan
(0
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Freedom -
Doug Melzard
36-45
2 (a) aquifer protection recommendations already made
for all communities no change in final plan
(b) no change in final plan
(c) recommended that septic leachate detector be used
to identify polluting systems
(d) model health ordinance in draft plan contains
provision requiring reinspection of septic systems
when frequency of use changes (i.e., seasonal to
year-round) - no change in final plan
(e) recommendation that practice of permitting raised
leach fields be reviewed contained in draft plan -
no change in final plan
(f) flood plain conservation measures already made
for all communities - no change in final plan
(g) no change in final plan
(h) recommendations for basing lot sizes on soil type
and slope to ensure adequate area for subsurface
disposal already incorporated in plan no change
in final plan
(i) recommendation for monitoring landfill leachate
incorporated in draft plan - no change in final
plan
(j) regular pumping and inspection procedures included
in model health ordinance in draft plan - no
change in final plan
87
Alton
William dough
46-56
(1) recommendations for boating controls on Bear,
Gilman & Knights Ponds deleted
(2) wording changed to "will remove one of the reasons
to limit & control future development"; introduction
expanded to note that many recommendations are appli-
cable to the Lakes Region towns outside the 208
area
(3) aquifer protection ordinance for Alton changed to
high priority
(4) Table 4-0 deleted from final plan; text of Chapter 4
greatly condensed in final plan - sentences commented
upon do not appear
(5) introduction to report indicates that land use con-
trols are the most effective means to control water
pollution
104
2
7
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Alton -
William Clough
(continued)
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(6)
(7)
(8)
(9)
(10)
(U)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
(23)
(24)
(25)
(26)
(27)
Effects of Comments on the Final Lakes
Region Water Quality Management Plan
change made to reflect 1979 Town Meeting
recommendation for Alton to share enforcement
personnel deleted
language revised to reflect LRPC viewpoint,
summary section added
modeling chapter condensed to several summary
paragraphs, reference to draft plan and technical
reports must be made
no change in final pi air
no change in final plan
'summary Table 3-1 directs recommendations for
revising criteria and developing replacement for
the percolation test to the State level
language revised
recommendation reflected on Table 3-1
redundancy eliminated
numbered paragraphs all constitute one. recommenda-
tion and reiterate model ordinance - no change in
final plan
no change in final plan
reference to "police powers" deleted
recommendation l-C-4 deleted; already accomplished
wording changed to "particularly important"
cooperative enforcement effort recommended
recommendation changed to reflect statewide
orientation
Table completely revised based upon comments and
upon new information
no change in final plan
no change in final plan
recommendation changed to read ""consider recycling
as one alternative"
wording of recommendations revised to reflect LRPC
viewpoint; licensing already required, wording changed
to "require more stringent licensing procedures";
availability of reference report noted.
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57
59
C A fl
60-61
62-63
(28)
(29)
(30)
(31)
(32)
(33)
(34)
(35)
(36)
(37)
(38)
(39)
•
(1)
(2)
.
•
•
Effects of Comments on the Final Lakes
Region Water Quality Management Plan
no change" in final plan
format of recommendations revised
no change in final plan
part 2 of non-point source chapter deleted from
final plan; reference to draft plan and technical
reports necessary
no change in final plan
reference to previous studies appears in Alton
summary
recommended that NHWSPCC initiate testing program
deleted from final plan
institutional planning chapter deleted from final
plan; possibly reprinted as separate document
public participation chapter deleted from final plan
land use chapter condensed to present only recommenda-
tions no change in final plan
list of reports available included in introductory
pages of final report
recommendation to restrict horsepower on Dan Hole Pond
retained in final plan
acknowledgements listed in draft plan expanded in
final plan
land capability map not reprinted in final plan,
change will be made when map is reprinted
recommendations restructured to emphasize minimization
of the use of road salt rather than increased use of
sand
recommendation relating to trial use of porous pavement
del eted
recommendations for implementation of specific recrea-
tion-based activities included in town-by-town section
of summary report
i^
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112
—
_— _
—
8
124
—
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104
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113
1 1
li '
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v'5-70
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•§*£
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(O O C
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Effects of Comments on the Final Lakes
Region Water Quality Management Plan
to
<4- U- (U
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92
N.H. Air
Pollution
Control
Commission,
Dennis
Lunderville
no change in final plan
N.H. Dept. of
Public Health
Thomas Sweeney
65
(1) recommendation to license pumpers changed to read
"require more stringent licensing provisions"
(2) recommendation to phase out private disposal sites
deleted
(3) ,recommendation #7 lists intermunicipal cooperative
arrangements
110
111
111
N.H. Water
Supply &
Pollution
Control
Commission,
Robert Cruess
66-68
Franklin Workshop
(1) Belmont ordinance does not prohibit composting
toilets - no change in final plan
(2) recommendation that mechanical harvesting be
utilized to control water weeds added; acknowledged
that more work needed in trace metals
(3) draft plan did not cite state law requiring septic
tank pumping; recommendation to license septic
pumpers changed to "require more stringent licensing
procedure"; LRPC will cooperate with WSPCC to insure
septage provisions in new treatment plants; recom-
mendations to phase out private septage dumping
sites deleted
Center Harbor Workshop
lime stabilization discussion changed to reflect no
discharge to receiving stream
Gilford Workshop
revision made in Gilford recommendations
Other Points
(1) text revised to reflect facilities plan in progress
for Ossipee
(2) change in wording reflected on all town summary charts
(3)(4) maps not reprinted in final plan
79
110
111
25,27
118
5-70
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Effects of Comments on the Final Lakes
Region Water Quality Management Plan
to
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Table 4-1 not reprinted in final plan - extractive
industries not significant in the Lakes Region
(17) Table 7-2 not reprinted in final plan
(18)(19)(20)(21)(22) model ordinances not reprinted in
final plan, will be revised and made available from
the Commission offices - appropriate changes noted
in text
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