FINAL
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United States
Enviponmental
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER COLLECTION AND TREATMENT FACILITIES
TISBURY, WEST TISBURY, AND OAK BLUFFS, MASSACHUSETTS
This Final Environmental Impact Statement recommends
a proposed program for structural and non-structural
solutions to the wastewater problems and needs of
Tisbury, West Tisbury and Oak Bluffs.
Further information on this statement can be provided
by:
Mr. Robert Mendoza
Environmental Protection Agency
Environmental and Economic Impact Office
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
617-223-4635
-LEAD AGENCY-
U. S. ENVIRONMENTAL PROTECTION AGENCY
Region I
JFK Federal Building
Boston, Massachusetts 02203
Technical Consultant
Anderson-Nichols, & Company, Inc.
Boston, Massachusetts
Approved by:
R. Adams, Jr. Final Date by Which
Regional Administrator Comments on the Draft
v Environmental Protection Agency Must be Received
Region I
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TABLE OF CONTENTS
PAGE
CHAPTER 1 - FINAL EIS SUMMARY 1
1.1 OVERVIEW 3
1.2 DRAFT AND SUPPLEMENT TO DRAFT EIS 4
1.3 NEED FOR FACILITY 9
1.4 RECOMMENDED ALTERNATIVE 11
1.5 ESTIMATED COSTS 15
1.6 ENVIRONMENTAL IMPACTS 17
1.7 STATUS AS STEP 1 FACILITY PLAN 19
CHAPTER 2 - COMMENTS AND RESPONSES 21
2.1 INTRODUCTION 23
2.2 RESPONSES TO DRAFT ENVIRONMENTAL IMPACT
STATEMENT COMMENTS 27
2.3 RESPONSES TO SUPPLEMENT TO DRAFT ENVIRONMENTAL
IMPACT STATEMENT COMMENTS 40
APPENDIX A - EXHIBITS A-l
APPENDIX B - WRITTEN COMMENTS ON DRAFT ENVIRONMENTAL
IMPACT STATEMENT B-l
APPENDIX C - PUBLIC HEARING ON DRAFT ENVIRONMENTAL
IMPACT STATEMENT C-l
APPENDIX D - WRITTEN COMMENTS ON SUPPLEMENT TO THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT D-l
APPENDIX E - PUBLIC HEARING ON SUPPLEMENT TO THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT E-l
APPENDIX F - ARCHAEOLOGICAL INVESTIGATION F-l
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LIST OF TABLES
NUMBER
1
2
3
4
NIGHTSOIL FLOWS
TISBURY WASTEWATER FACILITIES - ANNUAL
CHARGE TO TYPICAL HOUSEHOLD
COMMENT/RESPONSE MATRIX - DEIS
COMMENT/RESPONSE MATRIX - SDEIS
PAGE
13
16
25
26
NUMBER
LIST OF FIGURES
1 TISBURY WASTEWATER COLLECTION/TREATMENT
FACILITIES
FOLLOWING
PAGE
12
11
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CHAPTER 1
FINAL EIS SUMMARY
This chapter summarizes the EIS process and documents the
recommendations of the Final EIS.
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1.1 OVERVIEW
This Final Environmental Impact Statement for wastewater
collection and treatment facilities serving the Towns of
Tisbury, Oak Bluffs and West Tisbury recommends the
following:
1.1.1 Town of Tisbury
A three phased program to provide wastewater
collection facilities (sewers) to the developed
areas of Vineyard Haven.
- Immediate implementation of Phase 1 to serve
the downtown commercial and waterfront area.
Implementation of Phases 2 and 3 only if
further problems develop.
Construction of a small 85,000 gallons per
day secondary wastewater treatment/nightsoil
composting facility on Site 1 located between
downtown Tisbury and Lake Tashmoo.
Immediate initiation of a strong program of
septic system maintenance measures to pre-
clude future problems.
1.1.2 Town of Oak Bluffs
Investigate nightsoil disposal options as
part of proposed facilities plan.
Initiation of further studies to develop
solutions to problems in the Circuit Avenue,
Clinton Avenue, Pennacock Avenue and Camp-
grounds area.
- Implementation of non-structural measures
similar to those proposed for Tisbury and as
recommended in the "Water Quality Management
Plan" for Martha's Vineyard".
1.1.3 Town of West Tisbury
Disposal of nightsoil at the Tisbury, Treat-
ment facility.
Implementation of non-structural measures as
proposed for Tisbury and Oak Bluffs.
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1.2 DRAFT AND SUPPLEMENT TO DRAFT EIS
During the past several years a number of studies and
reports have focused on the wastewater needs of the
Towns of Tisbury, Oak Bluffs and West Tisbury. The
first efforts were initiated in 1974 and have continued
to this date.
In 1975 an engineering report entitled "Tisbury,
Massachusetts, Sanitary Sewerage Study, Volume II
recommended:
A regional wastewater collection and treatment
system to serve Tisbury and Oak Bluffs.
A regional nightsoil (septage) treatment facility,
as part of the wastewater treatment plant, to serve
Tisbury, Oak Bluffs and West Tisbury.
The Town of Oak Bluffs decided not to participate in the
regional system after the report was issued.
The Town of Tisbury, however, at a Town Meeting on
July 13, 1976, voted to pursue the design of a waste-
water collection and treatment system to serve the Vine-
yard Haven section of town.
Subsequent to Town Meeting approval, Tisbury submitted
applications to the Commonwealth and EPA for grants to
assist in the final design and construction of the pro-
posed facilities.
During EPA's review of the grant application, it was
determined that because of local controversy, potentials
for significant environmental impacts, and concerns about
groundwater degradation at the proposed treatment and
land application site, it would be necessary to have an
environmental impact statement prepared.
1.2.1 Draft Environmental Impact Statement
Federal agencies such as EPA may order the pre-
paration of an environmental impact statement in
situations where the projects they may fund have
a potential for significant environmental impacts.
The impact statements are prepared pursuant to
various Federal regulations for implementing the
National Environmental Policy Act (NEPA).
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Tisbury's proposed wastewater collection and treat-
ment facilities plan falls under NEPA due to the
Town's wish to utilize Federal grants. Under the
provisions of the Federal Water Pollution Control
Act, EPA can provide a grant of up to 75 per cent
of the cost to cover major eligible portions of
the proposed wastewater system.
EPA, with the assistance of Anderson-Nichols,
initiated the preparation of a draft environmental
impact statement (DEIS) in the Fall of 1976. Pur-
suant to Federal guidelines the impact statement
process has included two steps - a DEIS followed
by a final environmental impact statement (EIS).
1.2.1.1 DEIS Process in Tisbury
The DEIS process for Tisbury and the adjoining
towns included several features not typical for
similar wastewater impact statements. These
included:
A detailed evaluation of wastewater needs
due to present or anticipated inadequacies
of on-site systems.
- Extensive surface and groundwater water
quality investigations.
Modeling of the potentials for groundwater
pollution due to land application of treated
effluent at several candidate sites.
The development of four potential alternatives
and the evaluation of four potential treatment
plant sites.
The conduct of an on-going public participa-
tion process including several workshops and
the issuance of a newsletter prior to the
completion of the DEIS.
1.2.1.2 Recommendations of DEIS
The four alternatives developed as part of the DEIS
process were carefully evaluated in terms of their
capacity for adverse or beneficial impacts on the
natural and man-made environment of Martha's
Vineyard.
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These alternatives and their major impacts are
summarized below:
Alternative 1 - No Action - continuation of
present policies.
There are no beneficial impacts associated with
this alternative. The adverse impacts are that
wastewater collection and treatment needs, which
are documented in the DEIS would not be addressed.
The continuation of unsafe and unsanitary dis-
posal of untreated nightsoil is an additional
adverse impact of no action.
Alternative 2 - Construction of nightsoil treat-
ment facility.
This alternative would have the beneficial effects
of providing a safe and proper method of nightsoil
disposal and creation of a nightsoil by-product
that would be useful as an agricultural resource.
The adverse impact of Alternative 2 is that it
does not address documented wastewater collection
and treatment needs in sections of Oak Bluffs and
Tisbury.
Alternative 3 - Construction of small scale waste-
water collection and treatment system.
Alternative 3 would have the beneficial impacts of
accommodating the wastewater collection needs of
Oak Bluffs, West Tisbury, and Tisbury. It would
provide an environmentally sound means for the
disposal of wastewater and a composted sludge by-
product that would be useful as an agricultural
resource. Adverse impacts associated with the
alternative include short-term construction noise
and permanent development of a presently open site
for the wastewater treatment facility.
Alternative 4 - Construction of centralized waste-
water collection and treatment
system as proposed in 1975 engine-
ering report.
This alternative would have the beneficial impact
of accommodating the wastewater collection and
treatment needs of Tisbury and West Tisbury. It
would have the adverse impacts of not addressing
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the wastewater collection and treatment needs
of Oak Bluffs. Additional adverse impacts in-
clude short-term construction noise and per-
manent development of a presently open site for
the wastewater treatment facility.
The DEIS did not include a recommendation for a
preferred solution or alternative.
1.2.1.3 Public Comments on DEIS
The DEIS was published on September 12, 1977.
Public comments were received as follows:
- At a workshop on October 1, 1977.
- At a public hearing on October 26, 1977.
- Through memoranda and letters received
during the review period which extended
to November 14, 1977.
Through a letter with a number of comments
from the Martha's Vineyard Water Quality
Advisory Committee which was received after
November 14, 1977.
Many of the comments raised significant concerns
about the alternatives under consideration. In
lieu of proceeding at once to the preparation of
a final EIS, EPA determined that many of the
issues should be addressed in a supplement to
the DEIS.
1.2.2 Supplement to Draft Environmental Impact Statement
The Supplement to the Draft Environmental Impact
Statement (SDEIS)was prepared during 1978 and
published on August 11, 1978. In addition to
responding to the issues mentioned above, the
SDEIS evaluated the feasibility of less than
secondary treatment prior to land application.
EPA regulations adopted after the completion of
the DEIS required such an investigation.
1.2.2.1 SDEIS Process
The SDEIS process placed major emphasis on the
dominant issue raised about the DEIS. "Is a
system of wastewater collection and treatment
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the most environmentally sound and cost-effective
means of solving the problems in Tisbury's down-
town commercial area ?"
EPA's review was assisted by an independent study
of the Special Sanitary Control District (the
area with a moratorium on new on-lot wastewater
systems) prepared by the Martha's Vineyard Com-
mission in cooperation with Tisbury's Board of
Health and Planning Board. The study's evalua-
tion of the 220 lots in the District noted the
nature of problems such as high water usage,
lack of room on small lots for on-site system
rehabilitation or reconstruction, and a high
water table in the Main Street to waterfront
area. The major concentration of problems was
found to include portions of Main Street, Union
Street, Beach Street and Lagoon Pond Road.
EPA concluded that the existing site constraints
in the above mentioned four street downtown/
waterfront area were such that sewering would be
required.
The second step in the SDEIS was to screen out
those alternatives not responsive to the iden-
tified needs for a small scale treatment and
collection system. Accordingly, Alternatives
1, 2 and 4 were eliminated from further
consideration.
1-2.2.2 Recommendations of SDEIS
The recommendations of the SDEIS are essentially
those presented in Section 1.1 above. Under
Alternative 3 two sites for a treatment facility
were evaluated and the feasibility of less than
secondary treatment was investigated.
Less than secondary treatment was eliminated from
further consideration due to the possibility of
odor problems.
The two candidate sites, identified as 1 and 3 in
the DEIS, were evaluated as to the level of treat-
ment required. At Site 1 it was found that the
land application of effluent treated to secondary
levels would not have any adverse impacts on ground-
water resources. Effluent applied at Site 3,
however, could contaminate the Oak Bluffs water
supply. This impact only could be mitigated by
advanced wastewater treatment.
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A cost-effective analysis revealed that the use
of Site 1 would be the least expensive option.
The SDEIS included an extensive discussion of
non-structural measures the Town of Tisbury
might take to preclude further on-site waste-
water problems in Phase 2 and 3 areas as well
as throughout the Town. These recommendations
have equal application to Oak Bluffs and West
Tisbury.
1.2.2.3 Public Comments on SDEIS
A public hearing on the SDEIS was held on October
12, 1978. Responses to the hearing comments as
well as the one written communication are in-
cluded in Chapter 2 of this final EIS.
1.3 NEED FOR FACILITY
At the SDEIS public hearing October 12, 1978, the issue
of documenting the need for a sewerage system in downtown
Tisbury persisted. The Tisbury Board of Health handed
out Newsletters No. 1 and/2 at the hearing (See Appendix
A). These had been prepared with the assistance of the
Martha's Vineyard Commission.
The Newsletters summarized the results of the study of
the Special Sanitary Control District mentioned in
1.2.2.1 above. Cost estimates were provided for three
options generally coinciding with Alternatives 2, 3 and
4 of the DEIS. Initiation of a strong septic system
maintenance system was recommended.
The basic thrust of the Newsletters as well as the
testimony given by several speakers was that the sewering
of the downtown area could be avoided.
1.3.1 EPA/State Review
EPA has recognized, in spite of original Town
Meeting action in 1976 to authorize design of
a substantial wastewater collection and treatment
system, there has been a change in the mood of
Tisbury. The local desire now is to avoid an
expensive sewerage system if possible or build
the minimum system necessary to meet present
needs.
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In consideration of Tisbury's concerns EPA con-
vened a joint meeting in December 1978 attended
by representatives of EPA, Anderson-Nichols, tne
Massachusetts Division of Water Pollution Con-
trol, and the Massachusetts Department ot bn
vironmental Quality Engineering. The meeting
included a detailed review of all available in-
formation on the wastewater problems in downtown
Tisbury.
On January 2, 1979, a letter summarizing the con-
census of the meeting was forwarded to the Tisbury
Board of Selectmen by the Massachusetts Division
of Water Pollution Control. (See Appendix A)
EPA, in a companion letter dated January 5, 1979,
concurred in the conclusions expressed by the
State (See Appendix A).
The joint conclusions were as follows:
Holding tanks are not acceptable to the
Department of Environmental Quality Engine-
ering as a long range solution.
The requirements of Title V of the State
Environmental Code must be met on all problem
sites. Only minor variances from the code,
on a case by case basis, will be allowed.
Some of the cost estimates for on-site
rehabilitation appeared to be low and the
definition of problem areas required further
clarification.
Continuing problems will persist due to the
projected failure rate.
A rehabilitation program for the downtown
area of Tisbury does not appear to be a
viable, environmentally sound, long-term
solution for solving wastewater disposal
problems.
1.3.2 Tisbury/Martha's Vineyard Response
There were three responses to the January 5th
letter from the State. These are reproduced in
Appendix A and noted below.
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16 January 1979 from the Chairman of the
Tisbury Board of Health.
17 January 1979 from the Chairman of the
Tisbury Waste Committee.
12 January 1979 from the Executive Director
of the Martha's Vineyard Commission (ad-
dressed to EPA).
Although there was no unanimity of opinion ex-
pressed, the general response was that the
problem area is relatively small and the final
decision on what steps should be taken lie with
the Town of Tisbury.
1.3.3 EPA Conclusions
EPA has concluded that the multiple problems of
high water table, small lots, high water usage,
Title V requirements and DEQE regulations pre-
clude satisfactory rehabilitation of on-site
systems and require the construction of a limited
wastewater collection system in downtown Tisbury.
Extensions beyond the limited service area,
identified as Phase 1, will be dependent upon
the Town's capacity to institute a combined
program of water conservation and septic system
maintenance.
EPA's conclusion is consistent with the recom-
mendations of the "Final Plan/EIS Water Quality
Plan for Martha's Vineyard" dated April 1978.
The plan states for Tisbury and Oak Bluffs:
- "In areas where rehabilitation of failing
sewage disposal systems cannot solve the
problem, provide a limited sewage collection
system"
1.4 RECOMMENDED ALTERNATIVE
The recommended alternative as described in Section 1.1
above and in the SDEIS includes the following elements:
1.4.1 / Service Areas
Three service areas are proposed and illustrated
in Figure 1 on the following page.
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C Phase 1 includes the area covered by the Tisbury
I Sanitary Control District and possibly several
1 adjoining properties near the waterfront where
' there is a combination of high water usage and
i a high water table.
Phase 2 includes the service area proposed under
Alternative 3 of the DEIS.
Phase 3 covers the area recommended in the 1975
Sanitary Sewerage Study prepared by Tighe and
Bond.
As previously noted, the need to extend sewers
, to Phase 2 and 3 areas will be dependent on the
effectiveness of the maintenance program dis-
cussed below in Section 1.4.3.
1.4.2 Treatment Facility
A combined wastewater and nightsoil treatment
facility is proposed at Site 1 (a 20 acre site
to the west of the service area). The plant
would have an initial average daily wastewater
flow under Phase 1 of approximately 70,000
gallons per day. There would be an additional
14,800 gallons per day (summer average flow) of
nightsoil from Tisbury and West Tisbury. This
nightsoil flow is made up of 4300 gallons per
day of septage (2700 from Tisbury and 1600 from
West Tisbury) and 10,500 gallons per day of
holding tank wastes (6700 from Tisbury and 3800
from West Tisbury). See Tablel.
A secondary treatment plant using rotating bio-
logical discs is proposed. This type of process,
although higher in initial cost, is:
- More amenable to variations in flow than
other systems (an important consideration
in a resort and recreation area).
Easier to operate.
- Has lower energy requirements.
For septage treatment, a bar rack, an aerated
holding tank, chemical rapid mix tank, and sedi-
mentation basin will be provided. The liquid
will then be pumped to the biological discs.
The plant could be expanded to handle Phase 2
and Phase 3 flows from the sewer service area,
if necessary. Further, with minor modifications
the plant could handle an additional 3,000 gallons
per day of nightsoil from Chilmark and Gay Head.
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tisbury • wastewater collection/treatment: facilities
final environmental impact statement
environmental protection agency
technical consultant -anderson-ntchoJs & co., inc.
200 400 600 meters february 1979
1000 2000 feet
figure 1
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TABLE 1
NIGHTSOIL FLOWS
Year 2000
Summer Average Design Conditions
(Gallons per Day)
Septage* Holding Tank** Total Nightsoil***
West Tisbury 1600 3800 5400
Tisbury 2700 6700 9400
Subtotal: 4300 10,500 14,800
Oak Bluffs 3900 9600 13,500
Total: 8200 20,100 28,300
*Septage flows based on peak summer population; 1000 gallon
septic tank pumped once every two years; 3.3 people per
septic tank; 365 days per year. Estimated design suspended
solids concentration 35,000 mg/£.
**Holding tank flows based on peak summer population; one
per cent of systems in a failure mode at any given time;
100 gallons per capita per day. Estimated design suspended
solids concentration 200 mg/£.
***These estimates assume a strong program of septic system
maintenance measures in Phase 2 and 3 areas as well as the
balance of the Towns of Tisbury and West Tisbury.
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All sludge remaining after settling and de
watering will be composted. The final product or
composting can be recycled for use as a soil
conditioner subject to approval of the n,ial-n_v
Massachusetts Department of Environmental uuaiity
Engineering.
1.4.3 Non-Structural Measures
The SDEIS in accordance with the request of the
Martha's Vineyard Water Quality Advisory Com-
mittee included an extensive discussion on non-
structural measures - (systems other than those
requiring extensive wastewater collection and
treatment). The topics covered included:
operation of on-lot systems; maintenance of on-
lot systems, rehabilitation of on-lot systems,
replacement of on-lot systems; holding tanks;
cluster and multiuser systems; dry toilet ap-
plications; regulatory controls; wastewater
generation (conservation); and Government sup-
port and funding.
The "Final Plan/EIS Water Quality Management
Plan for Martha's Vineyard" also includes an
exhaustive description of various inspection,
operation and maintenance programs to prevent
on-site system failures.
All of the elements of a successful program
have been presented to the Town of Tisbury,
Oak Bluffs and West Tisbury. One point is
evident - a successful program requires ex-
perienced and well trained personnel. It can
not be done on a volunteer basis by well in-
tended Boards of Health.
The "Water Quality Management Plan for Martha's
Vineyard" has recommended the creation of the
position of regional sanitary engineer. The
sanitary engineer would work with local Boards
of Health and their staff in a management pro-
gram of:
Septic system inspection
Septic system maintenance
Septic system pumping
Septic system rehabilitation
New septic system evaluation
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It is recommended that each of three towns
institute an aggressive management system
which, in the case of both Tisbury and Oak
Bluffs, may preclude future sewering beyond
initial phases, and in the case of all three
towns will assure that surface and ground-
water resources are adequately protected.
Due to the limited population on Martha's
Vineyard, the concept of a regional sanitary
engineer working in concert with local Boards
of Health and their inspectors has consider-
able merit.
1.5 ESTIMATED COSTS
The total cost of the proposed Phase 1 collection and
treatment system, as summarized in the DEIS, would be
approximately $2,197,000. Of this amount the Federal
share is estimated to be $1,097,250, the State share
$219,450 and Tisbury's share $880,300.
Table 2 presents the estimated annual costs of sewering
a typical single family home assessed for $20,000 under
several financing options during Phase 1.
All options assume that 100% of the Town's share of
constructing the treatment plant (not including any
septage handling facilities) and interceptor sewer will
be applied as an ad valorem tax against all property in
the Town. For a $20,000 property the tax will amount to
$6.00 assuming a $.30 tax increase.
All options meet the EPA requirement that all of the ooe^a-
tion and maintenance (O&M) costs for the sewerage system will
be charged against properties connected to the system.
These charges would be computed on the basis of equiva-
lent dwelling units. An equivalent dwelling unit has an
average daily flow of about 240 gallons for a typical
home. Under Phase 1 this would amount to an annual O&M
charge of $158 for our typical single family unit. For
any properties with flows exceeding 240 gallons the
charges would be proportionately higher (for example,
a business with flows of 1000 gallons would pay approxi-
mately four times as much).
Debt service charges covering the construction of the
collector sewers would vary depending on the extent to
which these charges were covered by user charges or ap-
portioned against all properties in the community. Table
1 shows three options including total payment by users,
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TABLE 2
TISBURY WASTEWATER FACILITIES
ANNUAL CHARGE TO TYPICAL HOUSEHOLD
PHASE 1
Portion of Collection System Cost
Recovered Through Taxes
Tax Increase Due to Interceptor and
Treatment Plant Debt Service
Phase 1 Annual Charges
i
3850 of Collector
Sewer - $173,200
Tax Increase
Debt Service Per Connected EDU*
O&M Charge Per Connected EDU
Tax Bill Increases for Typical
Home Assessed at $20,000
Total Annual Charge for
Typical Home:
Connected
Not Connected (plus cost of
septic system maintenance)
$0.30
$0.00
$55.70
$158.00
$6.00
$219.70
$6.00
50%
$0.30
100%
$0.30
$0.13 $0.26
$27.85 $0.00
$158.00 $158.00
$8.60 $11.20
$194.45 $169.20
$8.60 $11.20
*Equivalent Dwelling Unit. (240 gallons/day)
NOTE: In addition, each user will pay a one time tie-in cost of
approximately $300.
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50% payment by users and 100% payment by all property
owners. As in the case of O&M charges any charge to
cover the debt service would be based on the number of
equivalent dwelling units.
As summarized in Table 2 the typical home connected to
the sewer system would have an annual charge ranging
from $219 to $169 in Phase 1.
The costs to all property owners in the community would
vary in accordance with the financing method finally
selected by the community. The ad valorem tax against
a $20,000 home not connected to the sewer would range
from $6.00 to $11.20 during Phase 1. The above costs
do not include the additional charges for periodic
septic system pumping for properties not on a sewer
system. In Tisbury the average annual cost of biennial
pumping is about $25.00 for a single family home.
The extension of sewers to the Phase 2 areas would reduce
total annual charges for a typical connected home to a
range of $193 to $123. Typical annual charges to a home
not connected would range from $6.00 to $23.00 depending
on the method of financing.
1.6 ENVIRONMENTAL IMPACTS
The environmental impacts of the proposed alternative
have been evaluated in the DEIS and the SDEIS. Additional
discussion of some of the impacts is contained in Chapter
2 of this Final EIS.
The proposed project will have both beneficial and adverse
environmental impacts. None of the adverse environmental
impacts are considered to be of a significant nature.
The major impacts are as follows:
1.6.1 Hydrologic/Water Quality
Groundwater quality in the vicinity of Site 1
would be affected. This would have no impact
on the quality of public water supply because
public well points and groundwater withdrawal
zones are outside of the groundwater area af-
fected by Site 1.
Existing sources of private water supply would
be affected. However, prior to the time this
effect would be noticed all water users within
the affected area will be included in the public
water supply system, in accordance with existing
plans. The eventual inclusion of these water
users within the public water supply system will
be necessary.
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No detectable effects will be felt in Lake Tashmoo,
Vineyard Haven Harbor or any other surface water
body.
1.6.2 Odors
The release of odors by wastewater treatment plants
is a major consideration regardless of level of
treatment. This is especially true in populated
areas where residencies and businesses could be
affected by treatment plant odor.
The potential of odor generation under conditions
of secondary treatment at Site 1 are detailed in
Section V.F. of the DEIS and are summarized below.
Wastewater treatment (secondary) and nightsoil
composting at Site 1 can be operated under odor
free conditions. This assertion is based on the
assumption that, 1) facilities will be properly
maintained and, 2) transfer of nightsoil from
trucks to the processing facility will be made
by direct connection without exposure to the air.
The impact of odors generated by potential upset
conditions of faulty maintenance at Site 1 will
not be adverse. The potential worst case odor
condition could occur during the summer months
when prevailing winds are from the southwest.
The closest home along the southwest to north-
east axis is located more than 1200 feet from
the treatment and composting process. Since
odors tend to dissipate rapidly, the chance of
odor detection at any residence in the area is
extremely slight.
1.6.2 Neighborhood Impacts
Neighborhood impacts include effects on aesthetics,
real estate values and land use.
Site 1 is heavily vegetated. All treatment facili-
ties and mechanical apparatus will be isolated by
the natural buffer of existing and planted vegeta-
tion. From the standpoint of nearby residents, the
facilities at Site 1 will not cause noise, be un-
sightly or be the source of adverse odor impacts.
Accordingly, the facilities at Site 1 will not ad-
versely effect area aesthetics, real estate values
or land use.
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There will be slight increases in traffic due
to the movement of septic pumping trucks to and
from the treatment facility.
1.6.3 Community Growth and Development
The DEIS includes a detailed discussion of the
growth impacts of sewering portions of Tisbury.
The Phase 1 sewering includes portions of Main
Street, Union Street, Beach Street and Lagoon
Pond Road. This is an intensely developed area
with limited opportunity for the growth that
could be induced by a sewer. A review of Map 10
in the DEIS will confirm this.
The potentials for inducing additional growth
will expand if Phase 2 and 3 areas are sewered.
These impacts too are discussed in the DEIS.
The extent to which the Town opens up oppor-
tunities for Phase 2 and 3 sewering largely
rests with the Town itself. The non-structural
measures discussed in 1.4.3 above are seen as
one way the Town can control its growth destiny.
A lax system of septic system maintenance and
inspection, on the other hand, could lead to
further wastewater problems and a need for
structural solutions such as sewers.
1.7 STATUS AS STEP 1 FACILITY PLAN
EPA has determined that this Final EIS will meet all the
requirements for Step 1 facilities planning. If the Town
of Tisbury accepts the recommendations of this EIS, it
will be authorized to submit a Step 2 grant. See EPA
letter of December 18, 1978, to Tisbury Waste Committee.
19
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CHAPTER 2
COMMENTS AND RESPONSES
This chapter summarizes EPA's responses to:
Written comments on the Draft Environmental Impact
Statement dated September 12, 1977.
- Verbal statements presented at the public hearing
on the Draft Environmental Impact Statement held
on October 26, 1977.
- Written comments on the Supplement to Draft Environ-
mental Impact Statement dated August 11, 1978.
Verbal statements presented at the public hearing
on the Supplement to Draft Environmental Impact
Statement dated October 12, 1978.
21
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2.1 INTRODUCTION
The Draft Environmental Impact Statement (DEIS) was
published on September 12, 1977. During the period
allowed for public comments, September 12, 1977 to
November 14, 1977, EPA received 20 written statements.
These are numbered W-l to W-20 and are reproduced in
Appendix B.
At the public hearing held on October 26, 1977, state-
ments on the DEIS were made by 14 speakers. The various
speakers are identified as H-l to H-14. Appendix C
includes a listing of the speakers.
On August 11, 1978, EPA issued a Supplement to the
Draft Environmental Impact Statement (SDEIS). The
public commenting period was reopened for 45 additional
days. One written statement, identified as SW-1, was
received. It is reproduced in Appendix D.
A second public hearing was held on October 12, 1978.
The eleven speakers are identified as SH-l.and SH-11.
Appendix E includes a transcript of the public hearing
and a listing of the speakers.
2.1.1 Comment Matrix
The oral and written statements fall into a
number of fairly well defined categories or
issues. These may be summarized as follows:
Need for sewerage system
Location of treatment facility
Community growth and development
Historic/archaeologic resources
Open space preservation
Use of treatment residuals
- Prejudicial evaluation of alternatives
Costs
- Odors
Miscellaneous
- Corrections
23
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Table 3 summarizes, in terms of source, the
number of comments that focused on the above-
listed categories during the revxew period on
the DEIS.
Table 4 summarizes, in terms of source, the
number of comments during the review period
on the SDEIS.
It is important to note the following:
Many of the speakers and writers had similar
comments on certain issues.
Many speakers and writers covered more than
one subject.
A number of the questions raised about the
DEIS were responded to in the additional
documentation included in the SDEIS.
2.1.2 Response Procedure
In the sections that follow, EPA has prepared
responses to all of the comments received. Since
a number of commenters have raised the same issues
or questions, an effort has been made to provide
one response wherever possible.
Each general category or issue is introduced by
an overview of the major concerns of the commenters.
This is followed by a concise summary of the com-
ment or comments relative to the issue. The
summary includes an identification of the individ-
ual and/or agency making the written or public
hearing comments. As noted above in 2.1 the iden-
tity of the commenter is included in Appendices
A-D.
The responses are provided in two major sections.
The first section covers the DEIS. The second
section covers the SDEIS.
One of the functions of the SDEIS was to provide
answers to some of the comments on the DEIS.
Where the SDEIS has provided such an answer, EPA
directs the reader to the appropriate section of
the SDEIS.
24
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TABLE 3
COMMENT/RESPONSE
Issue
Written
Responses from
Federal Agencies
State Agencies
Regional Agencies
Local Agencies
Organizations
Individuals
•0
0)
V
Z
0
0
4
1
2
I
lity Location
•H
u
1C
0
0
0
0
2
6
X!
-P
3:
O
e?
0
1
14
0
0
1
oric/Archaeologic
-P
CO
•H
ffi
1
1
0
0
0
0
MATRIX
O
cx
C/3
C
0)
o
2
0
1
0
0
0
tment Residual
(Tj
0)
EH
0
0
0
0
1
2
- DEIS
udicial Evaluation
Iternatives
'ft
-------
TABLE 4
COMMENT/RESPONSE MATRIX - SDEIS
Issue
Written
Responses from
c
o
•H
-P
(0
o
o
K*"*
•p
•H
rH
T3 "H
0)
w >
•H
rH -P
-H C
O M
•H (U
-d -P
CD
M *W
CM O
CO
0
O
0)
a
fd
rH
rH
W 0)
-P JH 0
to O w
O T3 -H
U 0 S
£
O
•H
4J
O
CD
M
O
U
Federal Agencies 1
State Agencies
Regional Agencies
Local Agencies
Organizations
Individuals
Hearing 2i 100 21 308
26
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2.2 RESPONSES TO DRAFT ENVIRONMENTAL IMPACT STATEMENT COMMENTS
2.2.1 Need for Sewerage System
Many respondents wanted further evidence of the need
for wastewater collection facilities in Tisbury.
Some expressed doubts that the problems were as ex-
tensive as the DEIS suggested. Others expressed the
concern that a door to door survey of problems was
not undertaken and that conclusions were improperly
derived from a mailed questionnaire. The DEIS, ac-
cording to some of the respondents lacked the proof
required by Federal regulators to justify a wastewater
collection system.
Other comments in this section dealt with the proper
evaluation of alternatives which would be appropriate
for small communities. A number of respondents held
the belief that solutions other than wastewater col-
lection would effectively alleviate these problems.
2.2.1.1 Detailed Problem Evaluation
2.2.1.1.1 Comment: (W8, W10, W12, W19, H2, H4 , H5,
H6, H8, H9, H14)
The problems of on-lot disposal are not
adequately documented to support a waste-
water collection system.
Response: The DEIS conclusions on need for
wastewater collection facilities are based
on considerations of soil, land use, records
of problems, a questionnaire, site inspect-
ions and water quality sampling. The scope
of the needs investigation is limited by
budgeting constraints but is consistant
with Federal requirements.
The door to door survey of needs performed
by Martha's Vineyard Water Quality Program
after the issuance of the DEIS, goes beyond
the scope of the DEIS. Its conclusions and
recommendations are incorporated in the
Supplement to the DEIS.
Based on the findings of the door to door
survey, recommendations for wastewater col-
lection facilities in Tisbury are changed.
A three-phased system is now recommended.
As detailed in the SDEIS, an initial col-
lection system, to be restricted to the
central part of Tisbury is recommended for
27
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immediate construction. Phase 2 would
encompass the service area of DEIS Alter-
native 3 and would be implemented in the
future by the Town, if needed. Likewise,
Phase 3, which extends to the limits of
the initial facilities plan service area,
would only be implemented, if needed.
The implementation of Phase 2 will be
dependent upon the Town's ability to
institute a strong management program
for on-site systems.
Phase 3 may not be needed if the Town
pursues all recommended non-structural
procedures. However, allowances are made
in the capacity of collection and treatment
facilities so that these may either accom-
modate or be expanded to accommodate Phase
3 flows.
2.2.1.1.2 Comment; (W10, H2)
Conditions of water pollution in Tisbury
are inadequately documented and the results
of water quality sampling are inconclusive.
Response:
Water quality conditions in Tisbury are
adequately documented with conclusive
results from a comprehensive water quality
sampling program.
The DEIS does not document water pollution
conditions. Except for sporadic incidences
where localized contamination of the aquifer,
resulting from individual septic systems,
exist, the generalized ground and surface
water quality is regarded as good.
The DEIS water quality sampling program
does not document the needs for a townwide
wastewater collection facilities.
2.2.1.1.3 Comment; (W8)
Conclusions based on the needs questionnaire
are too far reaching given the sample size
and distribution of responses.
Response;
Conclusions on the need for wastewater col-
lection facilities are not based on the
questionnaire alone. There are many other
28
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important items which factor in the
decision, namely, existing records on
pumping of septic systems. The question-
naire is but one component of a larger
and more comprehensive analysis program.
The rate of response to questionnaires
mailed by EPA to Tisbury was disappointing.
The citizen's response to questionnaires
received by EPA does not, in and of itself
justify the construction of wastewater
collection facilities.
2.2.1.2 Alternatives Appropriate to Small Communities
2.2.1.2.1 Comment; (W8, W19, H5, H6, H9)
Non-structural solutions should be dis-
cussed in greater depth.
Response; The DEIS not only discusses
non-structural solutions but recommends
them as part of Alternatives 2 and 3.
The Supplement to the DEIS discusses the
non-structural solutions in greater depth
as well as their costs and application on
Martha's Vineyard.
2.2.1.2.2 Comment; (W10, H2, H5, H7)
The DEIS should provide a detailed feasi-
bility study on upgrading individual on-
lot systems in problem areas.
Response; The DEIS and SDEIS determined
the feasibility and cost-effectiveness of
upgrading individual on-lot systems in
problem areas. Information is also avail-
able on the number and location of on-lot
systems which cannot be rehabilitated. The
conclusions of EPA and DEQE as reported in
Section 1.3 are that rehabilitation in con-
formance with Title V is not possible in
the downtown area of Tisbury.
29
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2.2.1.2.3 Comment: (W19)
The evaluation of alternatives is not
consistent with EPA's guidelines related
to wastewater systems in small communities.
Response:
The DEIS recommends non-structural systems
as part of Alternatives 2 and 3 but does
not provide details on the application of
non-structural systems in Tisbury. This
information is provided in the SDEIS. The
Supplement and DEIS are consistent with all
EPA guidelines.
2.2.1.2.4 Comment; (W8)
A night soil treatment plant is all that is
definitely needed to alleviate problems.
The State Forest would be the best location
for this facility. The DEIS evaluation of
potential night soil treatment sites/ is
inadequate and an insufficient number of
sites are presented for evaluation.
Response;
At an absolute minimum, a night soil treat-
ment plant is necessary. However, the need
for wastewater collection facilities in
central portions of Tisbury has been ade-
quately documented.
A comprehensive site evaluation for both
wastewater and night soil treatment fac-
ilities was conducted. This included 26
potential sites but did not include the
State Forest.
2.2.2 Location of Treatment Facility
The comments primarily related to Sites 1 and 3.
Property owners in the neighborhood of Site 1 have
expressed concerns about the impact of a wastewater
treatment facility near their homes or property.
The existence of a suspected gravel lens under
Site 3 is claimed to pose a groundwater contamina-
tion risk if the site is used for a wastewater
facility.
30
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2.2.2.1 Comment; (W13, W14, W15, W16, W17)
A wastewater facility on Site 1 will
have an adverse influence on the
neighborhood.
Response;
See Sections IVB and IVC of SDEIS which
discuss odors and neighborhood impacts
of Site 1.
2.2.2.2 Comment;(W18)
A wastewater facility on Site 3 may pose
a considerable risk to groundwater con-
tamination due to a gravel lens under the
site.
Response;
The SDEIS in Section IVA acknowledges
the potential for impacts on groundwater
resources downgradient from Site 3. Pur-
suant to this determination, the SDEIS
has recommended advanced wastewater treat-
ment if Site 3 were to be used. Consequently
there would be no adverse impact on existing
or future groundwater resources.
EPA has no evidence of a gravel lens other
than the documentation submitted by the
writer. Since the preferred alternative
does not call for the use of Site 3, further
confirmation of its existence is not war-
ranted as part of the EIS process.
2.2.2.3 Comment; (Wll, W12, Hlf H2, H6)
There is an immediate need for a night soil
treatment facility site.
Response; The need for such a facility is
acknowledged. After considering a number
of night soil treatment alternatives in
the EIS process, including: a facility
in the State Forest and use of the Edgar-
town facility, the SDEIS recommends a
combined wastewater/septage treatment/
disposal facility at Site 1.
31
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2.2.3 Community Growth and Development
A common concern was the extent of development
which would be induced by any of the alternatives.
2.2.3.1 Comment; (W7, W8, W9, W19, H5, H6, H7,
Hll, H12)
The type and magnitude of growth requires
further explanation.
Response; Chapter V, Section A, of the DEIS
Include s~ a detailed discussion of the develop-
ment impacts of the several alternatives.
Under the SDEIS a three phase wastewater
collection area is proposed. The first
phaset proposed for immediate implementa-
tion, includes portions of Main Street,
Union Street, Beach Road and Lagoon Pond
Road. This is an intensively developed
area with limited opportunities for in-
duced growth. A review of Map 10 in the
DEIS will confirm this.
The extent to which the town will be
required to extend the wastewater col-
lection area beyond Phase 1 largely rests
with the town itself. Strong health code
maintenance and enforcement programs could
preclude the need for Phase 2 and 3 sewer
extension into adjoining areas where there
is a greater potential (see Map 10) to
induce development of vacant land or bring
about a conversion of under-utilized
properties to more intensive use.
Also, please refer to Response to Comment
Number 4 on Page B31 of the SDEIS.
2.2.4 Historic/Archaeologic Resources
Both the Massachusetts Historical Commission and
the Advisory Council on Historic Preservation
call for full compliance with Section 106 of the
National Historic Preservation Act of 1966.
32
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2.2.4.1 Comment: (W6)
The DEIS does not adequately evaluate
the eligibility of historic properties
in the project area for listing in the
National Register.
Response: The Massachusetts Historical
Commission notes that the Ritter House
on Beach Street, Tisbury, has been voted
eligible for the National Register and
the Williams Street Historic District
and the Oak Bluffs Methodist Campgrounds
District are eligible for the National
Register.
The Vineyard Haven commercial area along
Main Street has architectural qualities
which could make it eligible for listing
on the National Register. This area
presently is being inventoried.
2.2.4.2 Comment: (W5, W6)
The impact of the project on properties
eligible for listing on the National
Register requires a more thorough evaluation.
Response; The SDEIS proposes a limited
Phase 1 service area which would serve the
Vineyard Haven commercial district along
Main Street as well as Beach Street.
The only possible long range impact on
historic properties would be the potential
for additional development in accordance
with existing zoning regulations.
To maintain the area's unique scale and
architectural qualities, it may be ap-
propriate to establish a Main Street Local
Historic District similar to or as an ex-
tension of the adjacent William Street
Local Historic District.
The alternative of not sewering this con-
gested area could lead to solutions for
on-site mounding systems or holding tanks
which would not be appropriate for an
historic area.
A survey of Site 1 conducted by archaeologist
Dr. Charlotte Thomson revealed no evidence
of archaeologic sites of any importance.
33
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2.2.5 Open Space Preservation
Several comments questioned impacts on wildlife
habitat and recreation areas.
2.2.5.1 Comment:(W2, W3)
What will be impacts on recreation areas
and wildlife habitat areas?
Response; Pursuant to the SDEIS, Site 1
is proposed for a small wastewater/septage
treatment facility. There will be no
significant impacts on recreation areas
or wildlife habitat areas if this site is
used.
The nearest recreation area is a school
playground at the Tisbury School.
There will be slight increases in traffic
due to the movement of night soil haulers
to and from the treatment facility.
The closest wildlife habitat area of
any consequence is Lake Tashmoo. Section IVA
of the SDEIS points out that there will be
no detectable effects on Lake Tashmoo re-
sulting from the application of wastewater
to Site 1
2.2.6 Use of Treatment Residuals
A number of commenters expressed concerns about
using the by-products from the wastewater process
for agricultural and soil stabilization purposes
on the Island.
2.2.6.1 Comment; (Wll, W19, W20, H5, H9, H10,
H12, H13, H14)
Preservation of the Island's soil and
the recycling of waste products for
agricultural uses should be considered.
Response; Composting of all sludges
resulting from the treatment process is
proposed in the Supplement. The final
product can be recycled for use as a
soil conditioner subject to approval of
the Massachusetts Department of Environ-
mental Quality Engineering.
34
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Please refer to the various responses
to the December 27, 1977 comments from
the Martha's Veineyard Water Quality
Advisory Committee which are included
on Pages B-l through B-36 of the SDEIS.
2.2.7 Prejudicial Evaluation of Alternatives
Several commenters were of the opinion that EPA's
evaluation was prejudiced in its evaluation of
certain alternatives at the expense of other pos-
sible alternatives.
2.2.7.1 Comment; (W9, W19, W20, H5, H7, H8, H9,
H12)
Other alternatives such as non-structural
solutions, composting and anaerobic di-
gestion and an island-wide night soil fac-
ility should have been given more consideration,
Response; The SDEIS was prepared in partial
response to the above criticisms.
Please refer to the various responses to
the December 27, 1977 comments from the
Martha's Vineyard Water Quality Advisory
Committee which are included on Pages B-l
through B-36 of the SDEIS.
2.2.8 Costs
The comments covered a wide range of cost concerns
ranging from those directly related to the proposed
cost of alternatives to the cost implications of
not using our waste resources to aid agricultural
production in the United States.
2.2.8.1 Comment; (Wll)
EPA should fund a pilot night soil
composting project in Edgartown.
Response; Such funding is not the concern
of this EIS and should be handled by the
Town of Edgartown or the Martha's Vineyard
Cpmmission.
2.2.8.2 Comment; (W19)
The EIS ignores considerations of food
scarcity and cost implications of
composting.
35
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2.2.9 Odors
Response: Please refer to the response
to Comment Number 5 on Page B-31 of tne
SDEIS.
2.2.8.3 Comment: (H5)
The cost estimates included in the DEIS
were not complete and not figured at a
consistent and comparable base.
Response; The SDEIS provides a clear
discussion of the anticipated costs
of the preferred alternative.
2.2.8.4 Comment: (H8)
No low cost, easy, technological solutions
were examined or documented.
Response; As noted in the response to
2.2.1 above, sewering is the only solution
to the problems of the central commercial
area.
The extent to which the Town allows problems
to develop in adjoining areas which could
lead to expensive sewer system expansion
largely rests with the town itself. With-
out doubt the low cost solution in Tisbury
is to administer local health and develop-
ment codes in a manner which will preclude
future problems.
This is the responsibility of the Town of
Tisbury.
2.2.9.1 Comment; (W20, H9)
Odors are non-existent in a properly
operated anaerobic digestion system.
Response; As the commenter notes,
digesters operated by microbiologists
have no odor problems. Realistically,
any plant in Tisbury will be operated
by trained wastewater treatment plant
engineers - not microbiologists.
Given the skills available, problems of odor
would be a much greater potential problem
if anerobic digesters are used.
36
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2.2.10 Miscellaneous
A number of comments are not easily
categorized as above. These miscel-
laneous comments are discussed in this
section.
2.2.10.1 Comment; (W7)
The implications of the high nitrate
levels at Wells 3, 4, and 10 are not
included in the discussions of water
quality problems.
Response; Well 3 conditions are indica-
tive of the problems found in the center
of town.
At Well 4, it is believed that the well
inadvertantly intercepted the leachate
plume from the Tisbury School and is not
truly indicative of prevailing conditions
in the area.
At Well 10, the elevated reading occurred
at one test only. Since subsequent testing
revealed much lower readings the first
reading should be discounted.
2.2.10.2 Comment; (W7)
The Cape Cod and Island Santuary Act
rather than SA classification prohibits
new municipal wastewater discharges.
Response; We concur in this.
2.2.10.3 Comment; (W7)
The EIS should include a discussion of
the secondary impacts associated with
running a force main to Sites 3 and 4.
Response; Pursuant to the SDEIS, Site 4
is no longer under consideration.
Site 3 is not recommended due to the
expense associated with advanced waste-
water treatment at that site.
37
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2.2.10.4 Comment; (Wll)
The threat of groundwater pollution
should be eliminated by using tertiary
treatment in the form of spring
irrigation0
Response; As proposed in the SDEIS, rapid
bed infiltration following secondary treat-
ment has been found to be both cost-effective
and environmentally sound. "Tertiary" treat-
ment is not required to prevent groundwater
pollution at Site 1.
2.2.11 Corrections/Clarifications
A number of corrections in the DEIS were
recommended. EPA generally concurs with
these corrections.
2.2.11.1 Comment; (W4)
The mercury standard for shellfish should
be 0.5 ppm.
Response; We concur in this change
2.2.11.2 Comment; (W9)
The Martha's Vineyard Commission has
recommended corrections or clarifications
on the following pages and paragraphs (48-1)
(67-5) (69-3) (69-4) (69-5) (69-6) (70-1)
(70-2) (70-3) (71-72 Table 12) (72-2)(72-2)
(75-4) (76-2) (76-3) (76-4) (147-5) and
Table of Contents.
Response; We concur in the changes and
clarifications for the above pages.
2.2.11.3 Comment; (W9)
Define high density and industrial on
maps on Pages 59 and 77.
Response; High density represents housing
development with more than two units per
acre. Commercial and industrial are in-
cluded under the same use category for the
Land Use Map on Page 59.
The densities on the Zoning Map on Page 77
are as provided in the zoning regulations
of the several towns.
38
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2.2.11.4 Comment; (W9)
Define urban as used in Table 11.
Response; Urban includes densities
of 1.5 person per acre or higher as
well as commercial, industrial and
public uses such as schools.
2.2.11.5 -Comment; (W9)
Detail borings in service area as to
soil type, depth to water and "suit-
ability" for wastewater disposal.
•i
Response; Borings were not taken in
the service area.
2.2.11.6 Comment; (W9)
A map showing well locations in Appendix B
is required.
Response; See Figure 3 on Page 19 of DEIS
2.2.11.7 Comment;(Wll, H7)
Corrections in flora and fauna listings
on Pages 30 and 31 are required.
Response; We concur in the corrections.
2.2.11.8 Comment; (W19)
Change interpretation of public sentiment
of Workshop #2 as recorded on Page 187.
Response; We agree with the change.
2.2.11.9 Comment; (W19)
Changes in wording are suggested on
Pages 31, 176, 177-178 and 31.
Response; We concur with the proposed
changes and additions.
39
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2.3 RESPONSES TO SUPPLEMENT TO DRAFT ENVIRONMENTAL IMPACT
STATEMENT COMMENTS
At a hearing held on October 12, 1978, co™*^*™
received from ten speakers. As a unique feature of
hearing, the Deputy Regional Administrator of Region 1
of EPA encouraged responses by representatives from EPA,
the Massachusetts Division of Water Pollution Control and
Anderson-Nichols. The responses are incorporated in the
transcrips of the public hearing which has been repro-
duced as Appendix E. The comments below pertain to items
not fully covered in the verbal responses or not answered
under Section 2.2 above. In addition, a response is in-
cluded for questions raised in the one written document
received from EPA.
2.3.1 Need for Sewerage System (SHI, SH2)
There is a continuing concern that the small Phase 1
collection and treatment system is not necessary.
The responses to these comments have been covered in
Section 2.2 above and in Chapter 1.
2.3.2 Location of Treatment Facility (SH5)
This was not a major issue of the hearing although
it was mentioned that there still is a local con-
cern with Site 1.
The previous responses in 2.2 above cover this
subject.
2.3.3 Community Growth and Development (SHll)
Several speakers mentioned growth in general and
growth necessary to support a wastewater facility
as not consistent with local goals.
Please refer to Chapter 1 and Section 2.2.3 above
for a discussion of growth issues.
2.3.4 Historic/Archaeologic Resources
There were no comments on this topic.
2.3.5 Open Space Preservation
The one written submission had general application
to this subject area.
40
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2.3.5.1 Comment: (SW1)
What will be the impact on recreation
areas and wildlife habitat.
Response; See response to 2.2.5 above.
No threatened or endangered wildlife or
plants will be affected by this project.
Two species, out of fifteen, present on
a list compiled by the Massachusetts
Division of Fisheries and Wildlife, may
be visitors to the area, but the site is
not critical habitat. They are the Bald
Eagle (Haliaeetus/leucocephalus) and
Peregrine Falcon (Falco peregrinus). The
Bald Eagle also appears in the Federal
Register Volume 42,Number 135, pertaining
to "Endangered and Threatened Wildlife
and Plants".
The major impact of the project as it
relates to fish and wildlife is positive.
Sewering of the commercial area will pre-
clude any pollution of the harbor from
land based wastewater sources.
Site 1 is wooded and contains a small
open field. It has no unique character-
istics which would suggest it be preserved
for wildlife.
2.3.6 Treatment Residual (SH3)
The composting product from a holistic composting
system is said to have a much higher value than
the compost from a wastewater treatment plant.
EPA does not disagree.
2.3.7 Prejudicial Evaluation of Alternatives (SH-3)
There was a continuing claim that EPA had not
given an equal level of effort to other treatment
processes as required by EIS regulations.
Please refer to Section 2.2.7 above.
2.3.8 Costs
The questions were in two major areas as discussed
below.
41
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2.3.8.1 Comment: (SH-3, SH-4)
Clarify cost effective analysis and
for whom it is done.
Response;
EPA is concerned with the alternative
which provides a solution to a problem,
is environmentally sound and is most
efficient in its use of Federal, State,
Local and individual funds. The analysis
is done for the benefit of the community.
The limits of time and funds preclude an
exhaustive analysis of every possible
secondary cost.
2.3.8.2 Comment:(SH-1)
If the Town of Tisbury only wants a night-
soil facility but the EIS recommends a
collection and treatment system, will EPA
fund only a nightsoil facility?
Response;
EPA would approve such a facility only
upon the submission of convincing evidence
that the analysis reported in 1.3.1 and
the conclusions presented in 1.3.3 above
are incorrect.
2.3.9 Odors
There were no comments on this topic.
2.3.10 Miscellaneous
A number of miscellaneous comments or questions
are reported below.
2.3.10.1 Comment; (SH-3, SH-10, SH-1)
Clarify decision-making process.
Response;
Essentially the decision-making process
included a determination of needs; the
review and screening out of alternatives
42
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not responsive to the needs; an evalua-
tion of treatment methods and sites; an
analysis of environmental impacts; and
a cost-effective analysis.
The alternative selected was determined
to be responsive to local needs, in ac-
cordance with EPA and Commonwealth regula-
tions, environmentally sound and cost-
effective.
Chapter 1 of this EIS provides a summary
of the decision making process. The
screening process did not eliminate rec-
ommendations for non-structural measures.
2.3.10.2 Comment; (SH-6)
Draft EIS does not evaluate less than
secondary treatment.
Response;
An evaluation of less than secondary
treatment is contained in the SDEIS.
2.3.10.3 Comment; (SH-8)
Water conservation program is urged.
Response;
Water conservation is encouraged as one
of the non-structural measures of both
this EIS and the "Water Quality Manage-
ment Plan for Martha's Vineyard.
The SDEIS offers a number of water con-
servation proposals.
2.3.11 Corrections/Clarifications
Several corrections and proposed changes were
noted as follows.
2.3.11.1 Comment; (SH-1)
On Page 3 of the SDEIS there is a quota-
tion from the "Draft Water Quality Manage-
ment Plan for Martha's Vineyard". The
43
-------
quote is obsolete and the Final Plan
states: "Avoid need for sewerage through
rehabilitation or replacement of failing
septic systems".
Response:
The change is acknowledged.
2.3.11.2 Comment; (SH-1)
The SDEIS included several incorrect
interpretations of the Survey and Report
on the Special Sanitary Control District.
These are on Pages 8 and 13.
Response:
We concur in the revised interpretations.
2.3.11.3 Comment; (SH-1)
The Survey and Report on the Special
Sanitary Control District recommended
the inclusion of the residential area
along Lagoon Pond Road if a sewage col-
lection system is proposed.
Response:
As discussed in 1.4.1 of this EIS,
inclusion of this area is recommended.
2.3.11.4 Comment; (SH-1)
Commercial flows may average 3,000 gallons
per day but are probably much higher during
the peak summer months.
Response;
We agree.
2.3.11.5 Comment; (SH-3)
The SDEIS has conflicting times on the
period of operation of the Fort Devens
rapid infiltration facility.
Response;
The correct time period is 30 years.
44
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APPENDIX A
This Appendix Includes:
Tisbury Board of Health Newsletter #1
Tisbury Board of Health Newsletter #2
- Division of Water Pollution Control Letter
to Tisbury Board of Selectmen - January 2, 1979
- EPA Letter to Tisbury Board of Selectmen
January 5, 1979
- Martha's Vineyard Commission to EPA
January 12, 1979
Tisbury Waste Committee Letter to Division of
Water Pollution Control - January 17, 1979
Tisbury Board of Health Letter to Division of
Water Pollution Control - January 16, 1979
Tisbury Waste Committee Letter to EPA -
December 6, 1978
EPA Letter to Tisbury Waste Committee -
December 18, 1978
A-l
-------
TISBURY BOARD OF HEALTH NEWSLETTER #1
DEFINITION OF THE WASTEWATER PROBLEM
PLEASE SAVE FOR FUTURE SPECIAL TOWN MEETING
FOREWORD
Soon there will be -• special town meeting to select a solu-
tion to correct the sewage disposal problems in the Town. In
order to help you make the appropriate choice, over the next few
months the Board of Health will publish a series of fact sheets to
familiarize you with the issues. This newsletter describes the
problem. Subsequent letters will summarize the solutions available,
their costs and impacts on the Town. Copies of a more detailed
study of the problem are available at no cost at the Town Hall.
HISTORY
In 1973 the Town of Tisbury initiated an engineering study
of the need for a sewer service. The study recommended a sewerage
collection system which was to service a large portion of the Town
(see figure 1 - Tighe and Bond Phase I Service Area). An Environ-
mental Empact Statement (EIS) on this proposal was required by the
Environmental Protectio'n Agency (EPA) . The results of the EIS were
presented in September 1977, recommending a smaller sewerage ser-
vice area (see figure 1). At this time the Board of Health and the
Planning Board and the Martha's Vineyard Commission initiated a lot
by lot survey to define the number and location of problem sewage
systems and the potential for taking remedial action short of sew-
ering.
FIGURE 1
SEWERAGE SERVICE
Approximate E.I.S.
reduced service
Tighe & Bond Phase 1
Tighe & Bond Phase I
2000 A.D.
I Metcalf 8c Eddy
III11 proposed 1990 service
-------
THE PROBLEM
In the intensely built up and used parts of downtown, many
existing sewage disposal systems are inadequate to handle tne sew-
age they receive each day. Problems are caused by the volume of
sewage which must be disposed, the near surface water table, tne
small lot sizes or the age and condition of the systems. This
leads to a continual need for nightsoil pumpouts, with no accept-
able means of disposal. The information available from the 160
lots surveyed and the nightsoil pumpers records indicates there
are 27 problems systems which require corrective action. At
least 4 of these can be corrected by conventional means. If
the Town desired to use an alternative solution to sewers invol-
ving the construction of mounded sewage disposal systems, all
but 7 problems could be corrected. The majority of the problem
systems occur in two areas (see attached figure 2) . In Area 1,
including Main Street, the problems are both the intensity of
use and the lack of room for rehabilitation. In Area 2, the pro-
blem is primarily the near surface water table. Some ground
water contamination is indicated in both areas, however, there
are no threats to drinking water supplies because the Town Water
Company serves the entire area with water drawn from wells which
are outside the downtown area. Harbor water quality has also
not yet shown significant deterioration. Some of the seasonal
contamination may be from the many boats which use the Harbor.
Currently these problem areas are within a Special Sanitary
Control District designated by the Board of Health in November,
1977 (see figure 2). In this area, no new sewage generating
uses and no increase in existing uses are allowed in order to
control the problem until a solution is worked out. The impacts
of the solutions available will be discussed in a later fact
sheet.
TO SEWER
NOT TO SEWER
1 Downtown revitalization
1 Initial costs + increased taxes
Induced growth
-increased traffic
- hotels & restaurants
of downtown businesses
••Savings to Town
— Limited growth
-kiteshops & bookstores
— Possible harbor contamination
-------
SPECIAL
SANITARY
CONTROL
DISTRICT
PROBLEM AREA
PROBLEM AREA 2
1 INCH z 500 FEET
_ PROBLEM S
T CAN BE R
EMS THAT
BILITATED
PROBLEM SYSTEMS WITH
A HIGH WATER TABLE
PROBLEM SYSTEMS WITH
LIMITED ROOM TO
REHABILITATE
-------
FACTS WITH WHICH TO MAKE A CHOICE
Results of a door to door survey on sewage problems conducted
by the Tisbury Planning and Health Boards and the Martha s Vineyard
Commission. The data collected has been verified in June 1978, and
what follows is the most up to date information available.
LOTS REGULATED BY THE SPECIAL SANITARY CONTROL DISTRICT 220
LOTS SURVEYED ,,,,,,
SYSTEMS WITH A PROBLEM 27
USES WHICH HAVE A SEWAGE DISPOSAL PROBLEM:
STORES , » , , ,
STOREs'wJTH AT'LEAST*ONE'APARTMENT, , ,
RESIDENCES ,,,,,,
APARTMENTS
RESTAURANTS
HOTELS/MOTELS ,
GATHERING SPOTS (THEATRES, ETC,), , , .
NUMBER OF PROBLEM SYSTEMS WHICH CANNOT BE REHApILITATED 6
NUMBER OF PROBLEM SYSTEMS WHICH CAN BE REHABILITATED BY
CONVENTIONAL MEANS ,,,,,,,,, , ,4
NUMBER OF PROBLEM SYSTEMS WHICH CANNOT BE REHABILITATED BY
CONVENTIONAL MEANS (BUT COULD BE REPAIRED WITH ADDED COSTS
WITHOUT SEWERING), , , , , 16
PROBLEM SYSTEMS WHICH COULD BE REHABILITATED WITH ALTERNA-
TIVE SYSTEMS TO OVERCOME HIGH WATER TABLES ,,,,., 21 OUT OF 27
OTHER FACTS TO CONSIDER
COST OF MOUNDED SYSTEMS, ,,,,,,,, ,$3000 - $20000
INDIVIDUAL RESIDENCES
Except for four systems most residences in town have room to re-
place a failing system. We have not yet done an exhaustive survey
of the room available on residential lots.
FUTURE FAILURES
IN THE FUTUR.E WE EXPECT THAT ADDITIONAL SYSTEMS WILL DEVELOP
PROBLEMS AT A RATE BETWEEN 1 AND 7 PER YEAR,
FUTURE FACT SHEETS:
** POSSIBLE SOLUTIONS TO THE PROBLEM INCLUDING COSTS
** SOCIAL,POLITICAL AND ECONOMIC IMPACTS ON THE TOWN OF THE OPTIONS
This newsletter was produced by the Tisbury Board of Health wich the
assistance of William M. Wilcox of the Martha's Vineyard Commission.
***
PLEASE SAVE FOR TOWN MEETING
***
-------
TISBURY BOARD OF HEALTH NEWSLETTER #2 jo/78
OPTIONS AVAILABLE TO SOLVE THE SEWAGE
DISPOSAL PROBLEM AND THEIR COSTS
FOREWORD:
This is the second in a series of newsletters to inform Tis-
bury residents of the sewage disposal problems in their Town, the
remedies available and the costs. A future newsletter will discuss
impacts. Copies of more detailed studies of these problems are
available at the Town Hall and the Library. If you have not re-
ceived Newsletter 1, copies are available at the Board of Health
Office, Town Hall Annex.
THE PROBLEM:
In the first newsletter it was pointed out that there is a
sewage disposal problem in downtown Tisbury caused by intense sum-
mertime use and near-surface water tables. Of 161 lots surveyed
in the Main Street - Beach Road area, 27 had a problem and 7 of
these could not be corrected without a combination of solutions in-
volving holding tanks and decreased use. Some of the 20 which can
be rehabilitated would require the use of costly innovative systems.
The Town could expect an increasing rate of system failures in the
future.
Taking no action at all is not recommended. There is a demon-
strated health threat associated with continuing current practices
because there is no facility to treat the nightsoil pumped from
both failing and functioning septic systems. Nightsoil disposal
will always be required and a solution to the nightsoil disposal
problem requires priority attention.
OPTIONS AND COSTS:
OPTION 1. To Construct a Nightsoil Treatment Plant and Develop a
Septic System Maintenance Program for All Individual Residences and
Commercial Establishments
This maintenance program would include:
a. Regular pumping of all sewage disposal systems as a pre-
ventive measure when indicated;
b. Water usage controls especially in problem areas;
c. Continued correction of failing septic systems.
COSTS; There are Two Potential Nightsoil Treatment Facilities
Tisbury Facility*
Total Project: $531,250
Town's Share: $70,000
Annual Operation Costs: $27,500
Multi-Town Facility*
Total Project Cost: $605,000-$!,212,500
Tisbury's Share: $49,680-$61,884
Annual Operation Costs: $17,500
(Tisbury's Share)
*Costs for Option 1 are from Tighe & Bond (1975) and are updated
based on 1978 costs. These figures are only estimates and are not
interchangeable.
Regardless of which facility is selected there will be added
costs to rehabilitate each failing septic system. These costs are
now eligible for 75% federal funding.
Main Street - Beach Road Area $3,000-$20,000/system
Most Residences $500-$2,500/system
This newsletter was produced by the -TTlSbury Board of Health with the
assistance of William Wilcox of the Martha's Vineyard Commission and
Commission Members.
-------
0pTION 2. To Construct a Limited Sewage cm lection System
This program would include:
a. Installation of pipes to collect sewage from the down-
town area with or without Beach Road;
b. Sewage to be piped to a treatment plant;
c. Septage (nightsoil) from the rest of the Town to be
treated;
d. Approximately 370 systems connected; ,.,afiw«,
e. Consideration would be given to a variety of innovative
treatment systems including composting and spray irnga'
tion.
COSTS:
Total Project:
Town's Share:
Town Debt Service:
Operation Costs:
Average Annual Users Fee
For Residence:
Initial Hook-up Cost:
$2,000,000*
$889,000
$84,000. per year
$55,000 per year
$150-$250
$300 per unit
OPTION 3. To Construct a Large Sewage Collection System
This program would include:
a. Service to downtown area as well as surrounding residen-
tial areas;
b. Sewage piped to a treatment plant;
c. Septage (nightsoil) from remaining portions of Town would
be treated at this plant;
Approximately 770 systems connected.
d.
COSTS:
Total Project:
Town's Share:
Town Debt Service:
Operation Costs:
Average Annual Users Fee:
Initial Hook-up Cost:
$5,720,000*
$2,264,000
$214,000 per year
$87,000-$103,000
$400
$300 per unit
*Costs from Anderson Nichols (1977) EPA Impact Statement. These
costs are only estimates and are not interchangeable. The actual
number of connections will have the greatest influence on user costs.
An Environmental Protection Agency Public Hearing will be held
on October 12 at the Tisbury School at 7:30 p.m. Those interested
in participating and presenting their views are encouraged to attend.
This is not a Town Meeting and no votes will be taken.
Town of Tisbury, Massachusetts
FEET 0 2000 4000 6000 8000
OPTION 2
OPTION 3
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~&t0tAt0M of rfb/e/*
PKC OP THE DIRECTOR
January 2, 1979
Board of Selectmen Rej Tisbury
Town Hall Rehabilitation Program
Tisbury, Massachusetts for Downtown Tisbury
Gentlemen t
On October 12, 1978 an Environmental Impact Statement (EIS) Hearing waa
field in Tisbury to present the findings and receive comments on the
Supplement to the draft E.I.S. At the time of the hearing, Mr. Costa, Board
of Health Agent, and Mr. Vilcox, Martha's Vineyard Planning Commission, jointly
presented on behalf of the Town an additional option to the two alternatives
recommended in the E.I.S. The purpose of this letter is to present the results
and conclusions of our review as they relate to this option.
Before proceeding further, however, we would like to take this opportunity
to applaud the efforts of your Board of Health and the Martha's Vineyard
Planning Commission in conducting extensive field investigations and compiling
eaid data. It was obvious in a review that a considerable effort was expended
in completing these tasks.
The basic concept of this option is to avoid the sewering of downtown
Tiebury through a program of on-lot rehabilitation of subsurface disposal
systems coupled with a septic system maintenance program, water conservation,
and the construction of an In-town or Multi-town septage treatment facility.
Under the rehabilitation phase of this program, 20 of the 27 known problem
sites In the downtown area would be corrected through the use of mound
systems (16) and conventional upgrading (4). The remaining 7 problem sites
could not be corrected by conventional means and would require a combination
of solutions including holding tanks and decreased water usage.
In an effort to evaluate the acceptability of this option, a detailed
review was conducted together with Paul T. Anderson, D.B.Q.E., and EPA/Stat«
personnel. Our joint comments are as followst
1.) Holding tanks are not an acceptable long-range solution to DEQE*
2.) The requirements of Title V of the State Environmental Code must be
met, even with existing problem sites. Minor variances such as set-
backs from property lines, depth to groundwater (if groundwater is
already polluted), etc. may be made on a case-by-case basis.
However, installation of systems in fill or unsuitable material will
not be allowed, nor will requirements for reserve area or provision
for reconstruction be waived.
-------
Board of Selectmen - Tlsbury
January 2, 1979
Page 2
3.) The estimated costs for septage treatment are understated. The
treatment facility as proposed by Tighe and Bond in 1975 cannot
handle the amount of septage associated with a septic system
maintenance program.
4.) Of the 46 questionnaires submitted, 37 of them indicated problems
but only 27 of those have been defined as problem areas. Please
clarify.
5.) The proposed option forecasts an additional 1 to 7 new failures per
year. Using a median value of 4 and a period of 5 years, this
could result in 75/6 more problems arising than presently exist.
This would not appear to be in the best interests of a long-term
solution for your conmunity.
In light of the aforementioned facts, it is the opinion of EPA and the
State that the option of a rehabilitation program for the downtown area of
Tisbury does not appear to be a viable, environmentally sound, long-term
solution for solving your wastewater disposal problems. Unless additional
information is submitted in support of this option by January 17» 1979> the
EIS will be completed taking this option into account but not as a viable
alternative.
Should you wish to discuss any of the items contained in this letter,
please feel free to contact us.
Very truly yours,
Thomas C. MoMahon
Director
oo« Board of Health, Town Hall, Tisbury
Department of Environmental Quality Engineering, Lakeville State Hospital,
Middleboro
Department of Environmental Quality Engineering, 100 Cambridge Street.
Boston 02202
Tisbury Planning Board, Town Hall, Tisbury
Martha's Vineyard Planning Commission (P.O. Box 144?, Oak Bluffs 02557)
Anderson Nichols, Inc., 150 Causeway Street, Boston 02114
Environmental Protection Agency, Municipal Facilities Branch, John P.
Kennedy Building, Boston 02203
Environmental Protection Agency, Environmental & Economic Import Office,
John P. Kennedy Building, Boston 02203
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
vineyard Haven, '•ABS.ic-hut.ottt; 02biji'
Deer People:
We were pleased to participate in the review of the comments on the
Supplement to the Draft CIS which were cubmitted jointly by the Tisbury
Hoard of Health and the Martha's Vineyard Planning Commission. We were
joined, in this review, by our Municipal Facilities Branch, the Massachusetts
Division of Water Pollution Control and Paul ftnderson of Mass. DEQE.
This is to state our concurrence with the conclusions expressed in a letter
being prepared by the State.
In order to assure complete understanding in this matter, and to provide
assistance in submitting further information, if that is the desire of
the Town, this office will contact you by telephone early next week.
Please accept my appreciation for the efforts which have been extended by
your townspeople.
sincerely yours.
v/allace E. Stickney, P.F..
Director, Environmental & Economic
Impact Office
cc: Board of Health, Town Hall, Tisbury
Department of Environmental Quality Engineering,
L«keville State Hospital, Middleboro
Department of Environmental Quality Engineering,
100 Cambridge Street, Boston 02202
Tisbury Planning noard, Town Hall, Tisbury
Martha's Vineyard Planning CommiBsion
(P.O. Box 1447, Oak Bluffs 02557)
Anderson Nichols, Inc., 150 Causeway Street
Boston 02114
Environmental Protection Agency, Municipal
Facilities Branch, J.F.K. Bldg., Boston 02203
Division of Water Pollution Control
-------
THE MARTHA'S VINEYARD COMMISSION
1447
rOAK BLUFFS
MASSACHUSETTS
617-693-3453
January 12, 1979
Wallace E. Stickney, P.E.
Directorr Environmental & Economic
Impact Office
U.S. Environmental Protection
Agency - Region 1
JFK Federal Building
Boston, Massachusetts 02203
RE: ENVIRONMENTAL IMPACT STATEMENT - WASTEWATER COLLECTION AND
TREATMENT FACILITIES TISBURY, WEST TISBURY AND OAK BLUFFS,
MASSACHUSETTS
Dear Mr. Stickney:
This is response to your letters of January 2, 1979 and
January 5, 1979, and comments pertaining to the survey conducted
by the Martha's Vineyard Commission.
The Martha's Vineyard Commission did not submit an additional
option for inclusion in the Final EIS. The Commission, at the
request of the Town of Tisbury, conducted an exploratory study to
find and evaluate the facts of waste disposal more fully. The
survey objectives were to better define the nature, density, and
magnitude of the wastewater disposal problem in this area.
We would like to suggest that the solution (or solutions)
selected is up to the Town of Tisbury as are such real concerns
for the alleviation of growth impacts.
The Commission, in its role of A-95 Clearinghouse will review
facilities proposals with regard to the community's characteris-
tics, wishes, and needs.
The Tisbury Boards of Selectmen, Health, and Planning, to
whom the letters were addressed and/or distributed, will no doubt
advise you directly of their views. Considering, however, the
-------
past and present participation of the Martha's Vineyard Commission,
we feel that the Commission views and role should be made clear.
Thank you for your consideration.
.Sincerely,
Ronald H. Mechur
Executive Director
RHM/jr
cc: Board of Health, Town Hall, Tisbury 02568
Department of Environmental Quality Engineering,
Lakeville State Hospital, Middleboro 02346
Department of Environmental Quality Engineering,
100 Cambridge Street, Boston 02202
Tisbury Planning Board, Town Hall, Tisbury 02568
Anderson Nichols, Inc., 150 Causeway Street,
Boston 02114
Environmental Protection Agency, Municipal
Facilities Branch, JFK Building, Boston 02203
Board of Selectmen, Town Hall, Tisbury 02568
Division of Water Pollution Control,
110 Tremont Street, Boston 02108
-------
TOWN OF TISBURY
VINEYARD HAVEN, MASSACHUSETTS 02568
TELEPHONE
Town Offices 693-4200
Police Dspt. 693-0474
Library 693-9721
Boards of Health, Planning, Conservation
(Annex! 693-4205
Council on Aging 693-3032
17 January 1979
Thomas C. McMahon, Director
Division of Water Pollution Control
Water Resource Commission
110 Tremont Street
Boston, Massachusetts
02108
Dear Mr. McMahon:
In response to your letter of 2 January 1979, the Waste Committee met and
after discussion, it was determined that the additional study done by the
Planning Board in conjunction with the Board of Health and eventually
submitted to EPA was to have been considered additional information for
consideration.
The complete impact of an on-lot maintenance program in this area can only
be realized by setting up a tentative program and projecting cost for a
qualified inspector and plant for disposal of septage.
The cost factors mentioned were not identified, therefore, no comment can
be made regarding this item.
Further anticipation is that a fairly long range program will evolve and
that any regulations forthcoming from the Federal Insurance Administration
may have to be incorporated regarding installations, etc.
Probably the most important thing that has to be done now is to reemphasize
the total program to the residents of the town and to be cognizant of the
fact that many have fixed incomes - but the need for growth and the development
of the town is also important.
Hopefully we can move along fairly rapidly after the EIS has been published.
cc: Board of Health, Tisbury
Department of Environmental Quality
Engineering, Middleboro & Boston
Planning Board, Tisbury
Martha's Vineyard Planning
Commission
Anderson Nichols, Inc
Environmental Protection Agency
Division of Water Pollution Control
mab/bad
Very truly yours,
M. A. Bergstrom, Chairman
Waste Committee
-------
TOWN OF TISBURY
Office of
THE BOARD OF HEALTH
P. O. BOX 1239
VINEYARD HAVEN, MASSACHUSETTS 02568
January 16, 1979
693-9229
Thomas C. McMahon, Director
Division of Water Pollution Control
Water Resources Commission
11U Fremont Street
Boston, Massachusetts 02108
RE:- ENVIRONMENTAL IMPACT STATEMENT - WASTEWATER COLLECTION AND TREATMENT FACILITIES
TISBURY, WEST TISBURY, AND OAK BLUFFS, MASSACHUSETTS
Dear Mr. McMahon:
This is in response to the copy of your letter of January 2, 1979 which we received
on January 11, 1979, and your comments regarding the data from the survey of the
downtown area of Tisbury conducted for the Board of Health by the Planning Board and
the Martha's Vineyard Commision.
First we wish to inform you that there is no Mr. Costa connected with the Tisbury
Board of Health nor do we have a health agent.
The information supplied you by Mr. William Wilcox of the Martha's Vineyard Commission
was for your use in evaluating the situation in Tisbury and assessing the magnitude ^
of the problem of disposal of wastewater. Never was this intended to be an "option
or an "alternative" and was not presented as such.
In item three of your letter you state "estimated costs for septage treatment are
understated". We are not aware of what costs you are referring to as we have done
no detailed analysis of such costs.
We could go into a lengthy discussion of problems with septic systems indicated by
the questionaires, versus the results of actual on site inspections, but the main
point resulting from this survey we feel was that the number of problems are few,
falling between 25 and 50 and are confined to a limited area.
Again, the Board of Health did not intend this information to be used as an "option"
or "alternative", only to indicate the size of the problem and its location.
Thank you for your attention to these matters.
MIcW
Chairman
MEJ/rar
-------
Thomas C. McMahon, Director
Division of Water Pollution Control Pa9e
CC: Department of Environmental Quality Engineering, Lakeville State Hospital,
Lakeville, MA 02346
, Department of Environmental Quality Engineering, 100 Cambridge Street, Boston,
MA 02202
Tisbwy- Planning Board , Box 1239, Vineyard Haven, MA 02568
Martha's Vineyard Commission, Box 1447, Oak Bluffs, MA 02557
Anderson Nichols, Inc., 150 Causeway Street, Boston MA 02114
Environmental Protection Agency, Municipal Facilities Branch, John F. Kennedy
Building, Boston, MA 02203
Environmental Protection Agency, Environmental & Economic Import Office,
John F. Kennedy Building, Boston, MA 02203
i'isbury Selectmen
-------
TO\VN OF T1SBURY
\ IN I •( A U I) II A V !• N , .V \N V-\ (.1! I M I | S
I M I l'rU/,1
.,/ II I .'I., •' 1 'If I
I'tlln •: ' , '.I «. I/-I
I ,i. .,'.•.• I •
-------
2. If the Environmental Impact Statement is a Facility Plan, will it he
approved by the Massachusetts Division of Water Pollution Control and the
Environmental Protection Agency ? Since the E.I.S. was accomplished by a
division of the EPA which does not control the planning and construction
grants which are available for Water Pollution Control is the E.I.S., as a
Facility Plan worthless unless the grants people accept its finding .'
3. If the E.I.S. is not a Facility Plfaiu will there be state and federal
funding for the 1974 Engineering report as,. #ell as any new work that is required?
Also in tfiersame line, can or will the town recover some of it incurred expenses
so that additional work can take place ?
A point, relative to question # 3 our records show that the Town of Tisbury
has spent $37,129.20 on the water pollution control program of which $29,715.49
is eligible for state and federal reimbursement - so that when the town does
take positive action towards implementation of a water pollution control program
it should recover $26,743.94 of the money spent.
When the final E.I.S. is ready I would like to have sufficient copies for
our Waste Committee - 16 - also, if an executive summary is to be forthcoming
would like same number for individual distribution - I am most anxious to got,
this information disseminated and have sufficient time to consider alternatives
and the fiscal long term impacts, (other routine copies for distribution will
be above this 16) .
i
Also at the Waste Committee meeting, tihe Board of Health stated they
desired to keep the moratorium in place until a final decision and action takes
place. Do you see any foreseeable problem] with this as long as the uroblem is
actively being pursued?
Thank you for your assistance.
Very truly yours,
M. A. Berg strom
Chairman Waste Committee
-------
UNiTED STATiiS ENVIRONMENTAL PROTECTION AGENCY
Deccvnher 10, 197R
M. A. Bergstroni, Chairman
Waste Committee
Town Hall
Vineyard Haven, MR 0256R
Drer reimfcuJrWd if a cirant
(-deadline.
bnlTT
p*4«>f •
-------
UNITED STATES ENVIRONMENT At PROTECTION AGENO
M. A. Bergstrom
Page Two
December 18, 1970
Executive Summaries will be distributed with the Final EIS, and there
will be no problem in providing individual copies for the Waste Committee.
A3 to the static of the moratorium, I can only refer to the lecal opinion
oxprosned by our Assistant Regional Council. For your convenience, I
have enclosed a copy.
Thank you for your letter, and I hona that I have been abl« to clarify
none of your questions. If there are more, please keep in touch.
Sincerely,
Kenneth H. Wood
environmental Protection Specialist
Environmental & Economic Impact Office
Enclosure
-------
APPENDIX B
WRITTEN COMMENTS ON DRAFT
ENVIRONMENTAL IMPACT STATEMENT
B-l
-------
LIST OF WRITTEN COMMENTS ON
DRAFT ENVIRONMENTAL IMPACT STATEMENT
Comment No.
Wl
W2
W3
W4
W5
Source
FEDERAL AGENCIES
Department of Housing and Urban
Development
Department of Agriculture
Forest Service
Department of the Interior
Department of Health, Education
and Welfare
Advisory Council on Historic
Preservation
Date
10/18/77
11/14/77
11/18/77
11/23/77
12/8/77
W6
W7
STATE AGENCIES
Massachusetts Historical Commission
Executive Office of Environmental
Affairs, Coastal Zone Management
9/30/77
10/27/77
W8
W9
REGIONAL AGENCIES
Martha's Vineyard Commission
Water Quality Program
Martha's Vineyard Commission
Executive Director
10/26/77
10/27/77
W10
LOCAL AGENCIES
Town of Tisbury
Board of Health
10/26/77
B-3
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List of Written Coiranents on Draft Environmental Impact Statement
(continued)
Comment No,
Wll
W12
Source
Date
W13
W14
W15
W16
W17
W18
W19
W20
ORGANIZATIONS
Vineyard Conservation Society
Town of Tisbury
The Waste Committee
INDIVIDUALS
Virginia Oliveira
F. M. Silvia and Joseph E. King
Rose Marie King
Louise K. Whitney
Richard Flanders
J. Gordon Ogden, III
Michael Scully
Ed Pachico
10/27/77
10/28/77
10/24/77
10/25/77
10/26/77
10/26/77
10/26/77
11/7/77
11/14/77
12/5/77
B-4
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W-1
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
BOSTON AREA OFFICE
BULFINCH BUILDING, 15 NEW CHARDON STREET
BOSTON, MASSACHUSETTS 02114
John F. Kennedy Federal Building
Boston, Massachusetts 02203 IftlQ?? IN REPLY REFER TO:
1.1SE
TJ.S, Environmental Protection Agency
Environmental and Economic Impact Office
John F. Kennedy Federal Building - Room 2203
Boston, Massachusetts 02203
Subject: Wastewater Collection and Treatment Facilities
Tisbury, West Tisbury, Oak Bluffs, Mass.
Environmental Impact Statement
Bear Mra Adams:
The Draft EIS submitted to Region I Office of HDD was sent to the
Boston Area Office of HOD for review and comment,,
This office has reviewed the proposed Wastewater Treatment Facilities
within its area of expertise and finds no conflicts with HDD
objectives.
Thank you for giving this office the opportunity to review and
comment on the above statement.
_
DEPUT^Area Office Director
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W-2
UNITED STATES DEPARTMENT OF AGRICULTURE
FDREST SERVICE
NORTHEASTERN AREA, STATE AND PRIVATE FORESTRY
6B16 MARKET STREET, UPPER DARBY PA. 19DB2
(215) 596-1671
8430
November 14, 1977
Mr. William R. Adams, Jr.
Regional Administrator
U.S. Environmental Protection Agency
Region 1
JFK Federal Building
Boston, MA 02203
Refer to: Draft Environmental
Statement, Wastewater Collection
and Treatment, Martha's Vineyard, MA
Dear Mr. Adams:
According to Section C3, Terrestrial Ecosystems, the
greatest impact on woodland would be at Site 4.
Appendix F-3 states that this site is "eliminated from
further consideration because of a new development" .
Displacement of vegetation and wildlife habitat will
occur because of this development. This illustrates
the interrelationships among all actions involving land
use in their effect on natural resources.
Section H.I refers to common construction precautions to
minimize soil erosion. We should like the final statement
to show how revegetation with grass, shrubs, and trees is
used for that purpose and to improve appearance of the
construction area.
Thank you for the opportunity to review this draft
statement.
Sincerely,
*
DALE 0- VANDENBURG
Staff Director
Environmental Quality Evaluation
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W-3
United States Department of the Interior
OFFICE OF THE SECRETARY
Northeast RascS. -y«4u >''C
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MEMORANDUM
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
PUBLIC HEALTH SERVICE
FOOD AND DRUG ADMINISTRATION
T0
THRU
Mr. Donald Branum
Regional Environmental Officer
DATE: November 23, 1977
Region I, HEW
Dr. Norman Tufts
" '
.
*. t •»
FROM : Regional Shellf ish Specialist
Region I, BOS-FO
SUBJECT: EIS - Wastewater Collection and Treatment Facilities - Tisbury, Mass.
1. We have reviewed the Draft EIS, "Wastewater Collection and Treatment
Facilities, Tisbury, Oak Bluffs, and West Tisbury, Ma.", inconjunction
with our obligations under the NSSP on the classification of shellfish
growing areas. The purpose of the EIS was to assess- the environmental
impacts of various proposed alternatives for treating sewage from named
towns.
2. All of the proposed treatment facilities and approaches include the
application of any waste effluents to the ground either by surface
application or sand filter infiltration. There is no proposal for
any direct discharge of a treated sewage effluent to Estuarine waters.
3. The EIS seems well prepared with the protection of shellfish growing
areas being a principal consideration. It was noted, however, that
on page 26 under Marine and Estuarine Ecosystems that the mercury
standard for shellfish is incorrectly stated as being 1.0 ppm. The
correct standard is 0.5 ppm.
Darrell J. Schwalm
Regional Shellfish Specialist
Region I, BOS-FO
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W-5
Advisory Council on
Historic Preservation
1522 K Street N.W.
Washington, D.C. 20005
December 8, 1977
Mr. William R. Adams
Regional Administrator «...
U.S. Environmental Protection Agency tC I 9
Region I
JFK Federal Building, Room 2203
Boston, Massachusetts 02203
Dear Mr. Adams:
Thank you for your request for comments on the draft environmental
statement for the Wastewater Collection and Treatment Facilities,
in Tisbury, West Tisbury, and Oak Bluffs, Massachusetts. Pursuant
to Section 102(2)(C) of the National Environmental Policy Act of
1969 and the Council's "Procedures for the Protection of Historic
and Cultural Properties" (36 C.F.R. Part 800), we have determined
that your draft environmental statement appears adequate concerning
areas of historic interest.
However, the draft environmental statement mentions properties of
archeological significance and we need more information in order to
evaluate the effects of the undertaking on these resources. Please
furnish additional data indicating: compliance with Section 106 of
the National Historic Preservation Act of 1966 (16 U.S.C. 470f, as
amended, 90 Stat. 1320).
The environmental statement must demonstrate that either of the
following conditions exists:
1. No properties that may be eligible for inclusion in the National
Register of Historic Places are located within the area of environ-
mental impact, and the undertaking will not affect any such property.
In making this determination, the Council requires evidence of an
effort to ensure the identification of properties eligible for
inclusion in the National Register, including evidence of contact
with the State Historic Preservation Officer, whose comments should
be included in the final environmental statement. The State His-
toric Preservation Officer for Massachusetts is Elizabeth Amadon.
The Council is an independent unit of the Executive Branch of the federal Government charged »££e Act of
October 1J, 1966 to advise the President and Congress in the field of Historic Preservation.
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2. Properties that may be eligible for inclusion in the National
Register of Historic Places are located within the area of environ-
mental impact, and the undertaking will or will not affect any such
property. In cases where there will be an effect, the final environ-
mental impact statement should contain evidence of compliance with
Section 106 of the National Historic Preservation Act through the
Council's "Procedures for the Protection of Historic and Cultural
Properties" (36 C.F.R. Part 800).
Should you have any questions, please call Sharon Conway at
(202) 254-3967.
Sincerely yours,
Myry F. Harrison
Acting Director
Office of Review and
Compliance
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W-6
September 30, 1977
Mr. Williams R. Adams, Jr.
Regional Administrator
U.S. Environmental Protection Agency
JFK Federal Building
Boston, Mass. 02203
Re: Wastewater Collection and Treatment
Draft EIS, Tisbury, Oak Bluffs and West Tisbury, MA
Dear Mr. Adams:
The Massachusetts Historical Commission has reviewed the Draft EIS
for the above project pursuant to Section 102(2)(c) of the National
Environmental Policy Act of 1969.
The Draft EIS does not evidence compliance with Section 106 of the
National Historic Preservation Act or 36 CFR Part 800. The discussion
of historic and archeological resources (p. 32-36) identifies a number
of historic properties in the project area, but does not adequately
evaluate their eligibility for the National Register. Omitted is
the Ritter House on Beach Street, Tisbury, which has been voted
eligible for the National Register. The Williams Street Historic
District and the Oak Bluffs Methodist Campgrounds District are eligible
for the National Register. The National Register criteria (36 CFR
800.10) must be applied for the other historic properties which have
been identified and for any other historic properties such as in the
downtown commercial area.
The effects on eligible National Register properties discussed on page 164
are not particularly accurate. The effect of inducing additional resi-
dential development in the William Street Local Historic District
would not necessarity be adverse as the local design review board esta-
blished under the provisions of Chapter 40C, MGL, would provide archi-
tectural controls and design review. A more thorough evaluation of
the significance of the commercial area and the extent of effects on it
needs to be done.
0CT 4 87?
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page two
Mr. William Adams
September 30, 1977
Since no professional archeological investigations have been completed
for the proposed sites, we are unable to comment on possible effects
on significant archeological resources. Professional investigations
meeting the standards of 36 CFR 66, App. B should be conducted and
the survey reports submitted to our office for review before a deter-
mination of effect on archeological resources is made.
EPA or its consultant should contact our office directly to provide
us the additional information requested and to carry out the required
Section 106 Review.
Sincerely yours,
Elizabeth Reed Amadon
Executive Director
Massachusetts Historical Commission
State Historic Preservation Officer
ERA/MV/ed
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NOV 3 1977
91
W-7
e
COASTAL ZONE
MANAGEMENT
of GJnvwonmenta/ £$$0,^
#
MEMORANDUM
TO:
U.S. Environmental Protection Agency,
Environmental and Economic Impact Office
MEPA Unit,
Executive Office of Environmental Affairs
FROM: Eric E. Van Loo
DATE: October 27, 1977
;ctor, Coastal Zone Management
SUBJECT: DEIS, Wastewater Treatment Facilities - Tisbury,
West Tisbury, Oak Bluffs, Massachusetts
Staff of the Massachusetts Coastal Zone Management Program
have reviewed the above referenced document insofar as it relates
to the policies and criteria of the CZM Plan. In general, we find
the report's step by step analysis of alternatives and impacts
to be well researched and set forth. Specific comments on the
text follow.
pp. 97- The documentation of water quality problems is good.
108 However, no mention is made of the sampling results
cited earlier in the report (e.g., the high nitrate
levels at wells 3,4, and 10) and the implications
of those findings relative to the findings presented
in this section.
p. li6 We believe the statement that SA classification pro-
hibits municipal discharges is incorrect. (see
Mass. Water Quality Standards) The Cape Cod and
Islands Ocean Sanctuary Act, MGLA Chapter 132,
Section 15, however, does prohibit new municipal
wastewater discharges.
p. 145 CZM concurs with the report's statement that the
alternative service areas are consistent with the
State's Growth Policy, as well as wxth CZM Policy
35 (CZM Program, Volume I, March 1977) The
alternative 3 service areas appear to be most
consistent with the recommendations of the dratt
208 plan for Martha's Vineyard.
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October 27, 1977
Page 2
p. 158 Design of collection facilities in flood hazard areas
should ensure the risks of damage are minimized and
existing hazards are not exacerbated (CZM Policy 9).
p. 162 CZM concurs with the report's finding that some form
of local design review or architectural controls
should be investigated by the town to protect
visual character.
p. 181 The report should include a discussion of the secondary
impacts which may result from running a force main
to sites 3 and 4 and mitigating measures that can
be used should either of these sites be selected
for a waste treatment facility.
me
cc: Madeline Snow, DEQE
Dan Calano, CZM
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W-8
THE MARTHA'S VINEYARD COMMISSION
BOX 1447
OAK BLUFFS
MASSACHUSETTS
02557
617-693-3453
26 October 1977
TO: Environmental Protection Agency
Environmental Impact Office
FROM: Water Quality Program, Martha's Vineyard Commission
SUBJECT: Draft Environmental Impact Statement
Wastewater Collection and Treatment Facilities for
Tisbury, Oak Bluffs and West Tisbury
STATEMENT FOR OCTOBER 26 PUBLIC HEARING
This statement is entered into the record by the staff of the
Water Quality Program.
Nightsoil Treatment and Disposal
1. A safe nightsoil treatment and disposal facility is needed
for Tisbury, Oak Bluffs and West Tisbury and, in fact, such
a facility is needed for all Island towns. Regardless of the
implementation of any sewage collection and treatment alterna-
tives there will always remain the need for an adequate and
appropriate method of nightsoil treatment.
2. It is recommended that a single nightsoil treatment facility
serve the needs of all Island towns. The only site discussed
in the EIS which might be suitable is site number 4. A better
site might well involve the disposal of the effluent in the
State Forest. It is felt that the site analysis data is in-
sufficient and the exploration of alternative sites inadequate
to allow the selection of an appropriate site.
Wastewater Collection
1. There are no requirements for a municipal facility in West
Tisbury. Large lots, low densities and a minimum of problems
support this observation.
2a. Tisbury and Oak Bluffs have experienced significant prob-
lems in the safe containment and disposal of wastewater. This
situation is indicated by the frequent pumpouts and occasional
overflows of private sewage disposal systems. The most serious
problems occur in a few relatively limited areas rather than
throughout the towns.
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2b. Information presented in the EIS does not provide an ade-
quate definition of the problem. The survey of wastewater
problems in the towns does not provide adequate data nor does
the non-random sampling approach used justify the conclusions
reached.
2c. As indicated in the EPA memorandum for regional admin-
istrators regarding funding of sewage collection projects/ a
thorough evaluation of cost-effective alternatives is now re-
quired for 201 funds. The possible use of non-structural
solutions in the towns to limit the need for sewage collec-
tion systems must be explored in greater depth.
2d. Limited collection systems and small package treatment
plants could effectively meet the needs of the localized
problen areas so far defined. More thorough and conclusive
data is needed to determine the optimum size of the service
area and type of treatment system required.
2e. Any sewage collection system will have significant and dif-
ficult to predict induced growth impacts. This is of great
concern to the towns and should be more fully explored as to
type of growth, magnitude, locations and interpreted as to
the town's ability to cope with it.
Program Recommendations
The 208 program recommends that an Island-wide nightsoil
treatment facility be immediately planned, funded and con-
structed. The systems considered must be readily convertible
to an agriculturally beneficial process such as composting.
Such a facility should be conveniently located so that travel
times from all towns are minimized and so that a future Island
solid waste disposal program can be combined with the nightsoil
treatment process. Site 4 as described in the EIS meets many
important criteria: it is centrally located; it is adjacent
to the State Forest where effluent might be beneficially util-
ized; it has adequate depth to groundwater and is isolated from
groundwater supply wells.
The 208 program feels that two scenarios deserve more thorough
attention in the Final EIS. First, a program of non-structural
solutions to eliminate if possible the need for sewage collec-
tion systems in both Tisbury and Oak Bluffs should be more
fully explored in the Final EIS. There is an immediate need
to initiate this kind of program in both towns now. Any col-
lection systems recommended should be limited in area to those
portions of town which clearly cannot be handled by a non-struc-
tural approach. This program feels that the Final EIS should
address the costs and benefits as well as the added responsi-
bilities of such an approach. In what portions of the towns
could improved septic systems, reduced water consumption and
a regular pumpout and system maintenance program provide the
answer? The 208 program fully supports the town of Tisbury's
effort to obtain more detailed information to answer this question.
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Second, if it is conclusively demonstrated that limited col-
lection systems are required, they should be confined to the
area of need. Areas where steps can be taken to further re-
duce the Alternative 3 service areas should be thoroughly
identified and described. The use of compact, package treat-
ment plants to handle limited collection systems should be
carefully considered. The appearance, dimensions, operation
and maintenance costs of package systems should be detailed in
the Final EIS. Potential in town locations for these systems
include Ocean Park in Oak Bluffs and Legion Park in Tisbury.
William M. Wilcox
Water Quality Program Manager
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W-9
THE MARTHA'S VINEYARD COMMISSION
NOV 1 1977
BOX 1447
OAK BLUFFS
02557
:6 17-693-3453
27 October 1977
TO: William R. Adams, Jr.
Regional Administrator, EPA, Region I
FROM: Ronald H. Mechur, Executive Director, MVC
RE: Comments on Draft EIS, Wastewater Collection and
Treatment Facilities - Oak Bluffs, Tisbury and West
Tisbury
I submit the following for public record on the above referred
matter:
page paragraph
48 1
48-49
63
67
69
69
all
59,77 maps
Table 11
comment
the 3 towns do not all have growth policies;
the MVC has a draft growth policy and rate
enclosed please find MVC 208 population
forecasts
high density/industrial codes need number
clarification; what are the densities re-
ferred to?
define urban; inconsistent with Table 10
which identifies only residential types
(not urban, suburban etc.); identify sea-
sonal population fluctuations
there are many other state agencies which
have responsibility for state planning,
in conjunction with wastewater collection
and its impacts
the traditional planning powers of munici-
palities are reduced (or enhanced) in that
local communities cannot grant development
permits except upon approval by the MVC
with or without conditions, for referred
DRI 's
MVC planning work is now under the Executive
Office of Environmental Affairs (EOEA), not
Offite of State Planning (OSP)
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page paragraph
69 5
comment
69
70
70
70 2
70 3
71-72 Table 12
72
72
the growth policy report has been completed,
only West Tisbury submitted a draft; the
MVC has Draft Policies for Large Scale Resi-
dential Development and a summary checklist
for commercial developments; the State pre-
sently has a draft of all policies in the
state
DCPC's are not nominated by a town, but
by a board of selectmen, planning board,
board of health, or the conservation com-
mission
the MVC considers a nomination based upon
the following qualifications:
-drinking water
-fishing resource
-farming resource
-wildlife, natural, scientific, or ecological
resource
-cultural or historic resource
-economic or development resource
-major public investment
-hazardous district
MVC may adopt (impose is not the language
of C. 637) regulations, or amend and adopt
regulations; towns may come forth with
amended regulations
towns may adopt regulations, not must adopt
MVC designates districts, not adopts
the MVC has designated (not adopted) and
regulated 7 districts:
-Coastal -6 towns
-Island Road -6 towns
-Special Places -6 towns
-Sengekontacket Pond -Oak Bluffs
-Tiasquam River -Chilmark
-Dr. Fisher Mill -West Tisbury
-Dr. Fisher Road -West Tisbury & Edgartown
The Draft EIS in its present form maybe
identifying areas within the Districts.
both the DCPC and DRI processes focus on
the characteristics of the land and water
resources
type of development; rather than kind of
development
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page paragraph comment
73 3 the comment of induced impacts is sound;
however, this needs much more detailed
discussion on scope, magnitude and location
75 4 plans of development - the Open Space Plan
and Master Plan Processes are proceeding
in Oak Bluffs
76 2 plans for subdivision of land into two or
more parcels are normally (?) submitted
for approval to the Town Planning Board or
Board of Selectmen (?)
76 3 Commonwealth does not have enabling legis-
lation in the sense of the DEIS; reference
should be to C. 41, the Subdivision Control
Law; towns have cluster
76 4 the town of Oak Bluffs has enhanced sanitary
provisions in section 13, Coastal Regulations,
existing flood plain regulations, and in
the regulations adopted by the MVC (Tisbury
as well)
91 2 more in-depth discussion of where these
non-structural alternatives might be
effective and what options might be used
100 2 the location and density of these failures
is of vital concern in sizing the service
area
103 3 if over 60% favored the use of the Edgartown
facility this alternative should be examined
in detail in the Final EIS
108 2 please detail the borings in the service
area as to soil type, depth to water and
"suitability" for waste water disposal
115 3 the favored nightsoil treatment process,
composting, should be greatly elaborated
in the Final EIS; is it feasible to start
out with composting or should a more con-
ventional technique which is adaptible to
composting be initiated and what is required
in terms of equipment, manpower...?
123 2 A single nightsoil treatment plant should
be looked into. Would the savings on a
single plant warrant the added travel times
as a trade off for less manpower and equip-
ment. .. ?
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page paragraph
137 2
147 5
B-19-22
other
comment
it must be pointed out that zoning can
be changed and what role sewerage might
play in this change
past coliform data has revealed occasional
counts which are much higher than the
60/100 ml cited
site location maps are needed for these
sampling sites
table of contents not properly numbered
detailed maps showing collection system,
by street required
Ronald H. Mechur
Executive Director
cc: Oak Bluffs, Tisbury, West Tisbury Board of Health
ds j
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42
4.0 The Island's Human History, Population and Land Use
One of the most important elements in the crea-
tion of a water quality management plan for Martha's
Vineyard is the analysis of past, present and future
population and land use. These considerations are
vital to assure that the plan is consistent with the
nature of the community and its' needs.
4.1 History
There are several theories available to account
for the Island's name. According to one, Leif Ericson
discovered the Island and the name was derived from
"Vinland the Good". Others say, however, that
Bartholomew Gosnold, an English navigator, discovered
Martha's Vineyard in 1602. First settlements were
made in 1646. During the 19th Century, Martha's
Vineyard was famous as a whaling port. The towns
of Tisbury and Edgartown have many of the large white
whaling captains homes each facing the sea, not the
road. After petroleum was discovered in the 1850's
the whaling industry declined. Since then, the chief
Island industry has been summer tourist trade and
associated second home building. There is some fish-
ing and some lobstering, but the beaches and the
boating draw most of the income. The Vineyard has
six separate townships each supporting its own social
history as well as its own individual aesthetic char-
acter. From west to east, these include: Gay Head,
Chilmark, West Tisbury, Tisbury, Oak Bluffs, and
Edgartown.
4.12 Population
The major demands which are put on our resources
come from population growth which requires water for
drinking and disposal of waste. One of the most im-
portant determinants of water, population, varies
tremendously with the seasons and so too does the
water quality and quantity. Unfortunately, the great-
est demand for water supply comes at that time of
the year when the least amount of water is available
for consumption. The winter period of low demand
for water allows soils to recover and ground water
supplies to recharge. In the future,increasing con-
version of seasonal homes to year-round use may lead
to water-related problems.
4.21 Present Population
An analysis of Steamship Authority (SSA), other
private ferry, and air traffic statistics has lead
to the conclusion that the peak summer day population
for 1975 was 55,000 to 60,000 and the winter minimum
was 7,900. The summer figures include an estimated
15 to 25 percent day-trippers which are not part of
the overnight population. figure 5 indicates the
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seasonal variations in population based on this study.
Each curve represents the net. population when the 43
item indicated is added on. The curve reaches a
peak in August of some 47,000 people including the
year-round population. A study of the statistics
available from the Steamship Authority however indi-
cated this to be low. The figures available some-
times did not reflect weekend peaks in travellers.
They also do not include private boats and planes.
Corrections were made which resulted in the 55,000
to 60,000 peak estimate. A simple check of space
available for peak population can be used to sub-
stantiate these estimates.
It is estimated that there are presently 7,500
dwelling units on the Island of which roughly 40
percent or 3,000 are year-round and 60 percent or
4,500 are seasonal. If we assume 6 people per
seasonal house and 4.5 people per year-round house
during this peak day, we have a total of 37,800
people. Hotels can accomodate 4,500 people and
boats moored in our harbors 2,500 people. Campers
may add another 1,500 people for a total of 46,300
people when the year-round residents are included.
Ten thousand day-trippers from the Steamship Author-
ity, airlines and other boat lines would account for
56, 300 people. The two estimates agree closely on 50-60,000.
Population Projections
Projections of future year-round and summer over-
night populations are included below. Given the large
uncertainties in the driving forces and limiting factors
in the Island's population, two distinct projections
were made.
Table 3 Population Projections
1975 1980 1985 1990 1995 2000
year-round
low 7,900 9,000 9,800 9,400 9,400 9,400
high 7,900 9,600 10,900 11,800 12,400 12,800
summer 45,000 50,400 60,400 63,000 65,000 70,000
The 25 year growth in year round population is
projected at 1500 under the low growth scenario and
4,900 under the high growth scenario. Growth in both
year round and seasonal population depends on whether
the Island continues to be attractive for recreation/
second home/retirement and whether competing localities
might become more attractive or convenient. The most
volatile factor is the proportion of the feeder popu-
lation - eastern Massachusetts and the New York City
area - which wishes to recreate or retire here. Since
these factors can not be accurately assessed at this
time, these projections are considered approximate.
Figure 6 clearly demonstrates a decided increase in
rate of year-round growth. The overnight seasonal
figures in Table 3 based on a maximum projected growth
in housing. See figure 9 for high & low housing projections.
Growth in population nas serious water quality
implications. Each person added to our population
requires 45 to 75 gallons of water per day. This
is mainly used for human waste disposal or combined
with the waste in our disposal systems. It is par-
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44
Figure 5
POPULATION OF MARTHA'S VINEYARD 1974-1975
(ESTIMATED)
- txcujpiriQ
popuusnon or-
M ' ' t « L ' I ' ' ' t ' ' ' l^n ' 1 ' '.i-»-*-t-*-T=«=» i H xiM
JUTIL JULY
ocr
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45
13.000^
12.000 •
IIOOO 1
10.000-
< *'
/I
> L-4-
L-4
2OOO
-------
AP. tially treated and released to percolate in to the
46 ground water or piped to a sewage treatment plant as
in Edgartown only.
The 1,500 additional year-round people projected for
1995 would release an additonal L4 0.000 pounds of
waste into the environment each year. If there were
6,000 total new houses with an estimated 5 persons
per household during the summer, there could be
750,000 total pounds of waste to deal with. This
waste would be disposed with a total of 122 to 203
million gallons of water which must be supplied from
our aquifers. In addition the added seasonal visi-
tors associated with the 6000 new dwellings could
produce some 7000 tons of solid waste which must be
landfilled each year. Obviously there is a limit
to the waste which can be absorbed by our land and
waters. As we approach that limit, more and more
contamination problems will occur. It is one aim
of this program to define these problems and outline
a program to mitigate them.
4.3 Economy
Of the total Martha's Vineyard economy, over 95%
of the area's base economy, as indicated by total
receipts, is related, either directly or indirectly,
to the resort industry, vacation services and sales
or second-home construction and attendant services.
The resort industry, and thus the bulk of Martha's
Vineyard's economy, is dependent on two major factors:
the state of the nation's economy and the attractive-
ness of Martha's Vineyard as a resort community.
While the economy of the Island each year is be-
coming more tourist-based (Massachusetts Division
of Employment Security, 1977, Table 4) in spite of
a 20 million dollar per year input, tourism, when
combined with off-Island purchases, may cause a net
economic loss to the Island through establishing un-
favorable trade arrangements with other areas. In-
stead of Islanders providing goods and services for
each other, the Island provides tourist services for
outsiders and then uses that income for purchasing
goods and services from the outside.
During the 1976 tourist season, for example,
about 1,100 to 1,200 jobs were held by non-residents
earning 5.5 million dollars, most of which left
the Island when the non-residents went home (Mass-
achusetts Division of Employment Security, 1977).
Unemployment for residents averages 8.4% year-round
(1976). How much the Island has to spend on tourist
infrastructure—roads, sewers, landfills and police;
who benefits and who pays for services and what the
social impacts of a tourist based economy are must
be much better understood before large capital im-
provement programs are embarked upon.
For example, between 1950 and 1970 the Islands
population grew by 8%. The MacConnell aerial survey
indicated a growth in land uses by a constant 3 to 4%
each year. In the period 1971-1976, the Islands
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W-10
TOWN OF TJSBURY
VINEYARD HAVEN, MASSACHUSETTS 02568
Board of Health
October 26, 1977
Telephone
69-3,4-200
693 9229
To:
Proms
Subject:
Reference:
United States Environmental Protection Agency, Region 1
John F. Kennedy Federal Building
Government Center
Boston, Massachusetts 02203
Tisbury Board of Health
Box 1328
Vineyard Haven, MA. 02568
Draft Environmental Impact Statement,
Wastewater Collection and Treatment Facilities
October 26, 1977 Public Hearing on Draft EIS
The Tisbury Board of Health feels the extent of the problem of
pollution of the water and ground was inadequately documented in
the Draft Environmental Impact Statement. We feel the data pre-
sented on ha,rbor and ground water contamination v/as inconclusive.
At present the plans of the -Board of Health and the Planning Board
are to conduct a door to door survey of Business District I, Busi-
ness District II - east, Industrial District and some adjacent areas
to determine the type of septic systems, amount of usage and past
and present problemsj The results of this survey will be available
to the Wasts Committee and other interested parties.
In'1975 the JPown of Tisbury Board of Health instituted a moratorium
on new septic system installations or enlargement of existing
systems in the critical areas.
Based on our review of the Draft EIS Wastewater Collection and
Treatment Facilities and the Water Quality Management Plan for
Martha's Vineyards*208" data, combined with our current knowledge
of the status of the problem, we, .feel the following recommendations
would be the most appropriate t
i. 'CONTAIN the problem and PREVENT its future enlargement
by stringent enforcement of the moratorium, pending
: implementation of items #3. #^» #5- wfazk^iM/Aj^
2. REDUCE and CONTROL the size of the problem; monitoring
of individual systems regarding adequacy and possible
renovation or rebuilding.
-------
United States Environmental Protection Agency, Region 1 Page 2
3, PROVIDE a "NIGHT-SOIL TREATMENT PLANT" at an appropriate
site, possibly in the State Forest.
^. EVALUATE the minimum necessary LIMITED COLLECTION SYSTEM
and a small "PACKAGE TREATMENT PLANT" , based on our
landings of the survey to be conducted imminently.
5. SECUPxE the services of an INDEPENDENT SANITARY ENGINEER
to assist in proposal evaluation which would provide a
new and objective view based on all pertinent data,
We feel this plan would be feasible through implementation of
existing r\;les and regulations and development of such additional
ones as are deemed necessary to attain these solutions by the
Board of- Health and the Planning Board. Controlling the problem
would, decrease its magnitude and thereby the costs to the taxpayer,
Alfred v. l-'erro, Chairman
Evelyn Thomas
Michael Jacobs
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W-11
STATEMENT OF ROBERT E. WOODRUFF ON BEHALF OF
VINEYARD CONSERVATION SOCIETY
BEFORE E.P.A. HEARING HELD AT CORNELL HALL, VINEYARD HAVEN, MASS.
October 27, 1977
on draft EIS Wastewater Collection and Treament Facilities for
Tisbury, Oak Bluffs and West Tisbury
First, a general comment:
Overall we feel that the E.I.S. has generated a large amount of useful
data and has responded to the major questions and issues raised at the
public meetings. However, we feel the information has been presented in a
very confusing format which does not readily lend itself to an intelligent
comparison of alternatives.
Our specific recommendations are as follows:
•We are in full agreement with the several points made in the Water
Quality Advisory Statement of the 208 Committee.
•We concur with the E.I.S. finding that composting of nightsoil is a
feasible alternative to the pressing problem facing Island Boards of Health
and we urge that E.P.A. funding be made available immediately through the
E.I.S. process for a pilot nightsoil composting project to be located at the
Edgartown Wastewater treatment facility. The location of this at the Edgar-
town facility will enable the dewatering of nightsoil prior to composting,
which effectively eliminates the only major drawback to the composting method.
«We emphasize the need for more detailed study of the feasibility of
upgrading individual on site disposal systems in problem areas. This should
include costs, environmental impacts and effects on growth in the area as
contrasted with costs, environmental impacts and growth impacts generated by
a wastewater collection system. This data should be presented in straight-
forward tabular form for easy comparison by the residents of Tisbury.
oWhile a collection system may ultimately be found necessary for Beach Road,
we feel that the feasibility of upgrading individual systems in this area
ought to have more detailed study before a decision is made to launch into an
expensive collection system.
6Should a wastewater collection system be built, we feel it should be
limited to those areas which clearly cannot be served by any other alternatives.
»In order to eliminate the threat of groundwater pollution,any "secondary
treatment facility built should incorporate a "tertiary" treatment system as
well in the form of spray irrigation. As you know, this method is being used
successfully in many areas including Otis Air Force Base to remove nitrates
and phosphates, and its use here would enable consideration of sites which have
been found unfeasible because of possible contamination of the groundwater.
Specific corrections to the E.I.S.:
P.30. Flora. Several oak species are mentioned, but the two principal
tree species which occur on the Island have been omitted. These are Black
Oak and White Oak. TT , , .
P. 31. Fauna. Opossum, Shorttail weasel Mink Red Fox^Woodchuck
Snowshoe Hare, Red Squirrel and Beaver should be omitted. While all of them
occur in Southeastern Massachusetts, none have occurred here in recent times.
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W-12
TOWN OF TISBURY
TELEPHONE
VINEYARD HAVEN, MASSACHUSETTS 02568 Town offices 693-4200
Police Dept. 693-0474
Library 693-9721
Boards of Health, Planning, Conservation
(Annex) 693-4205
Council on Aging 693-3032
28 October 1977
TO: Environmental Protection Agency
Environmental Impact Office
FROM: The Waste Committee M.A. Bergstrom
Town of Tisbury Executive Secretary, Chairman, Waste
Committee
The Waste Committee reflects its opinion to this point as
being in a position of evaluating the Environmental Impact
Statement and at least at this time has a consensus that
Alternate 3 be considered, with provision of Alternate 2 or
combination of both.
The Board of Health members of the Committee have indicated
rather strongly that a more detailed survey be done in the business
and industrial area. Also, that the scope of solution be, if
indicated, a limited collection system and a contained treatment
plant located in the confines of the problem area.
The site for a night soil treatment plant, however, is the
prevailing problem so that the disposal of waste water from
pumpings can be processed. The location of such will still be
influenced by the source of supply.
The Waste Committee would still not consider the Site III "dead"
at this time.
A more detailed report of recommendations necessarily will be
forthcoming as the final E.I.S. is presented at the beginning of the
year.
Site location is still a prevailing problem.
Very truly yours,
For the Waste Committee
M.A. Ber^strom
Executive Secretary
MAB:eav
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W-13
33 Weaver Street
New Bedford, MA 02740
October 24, 1977
Chairman, Waste Committee
Town of Tisbury
Vineyard Haven, MA 02568
Dear Sir:
I am definitely opposed to the proposed sewerage
treatment plant being located on Site I—between Lake and West
Spring Streets. I have been looking forward to building a home on
the property I own on Lake Street but this news is most discouraging.
A plant of this type will certainly not enhance the property in this area.
I feel it is very unfair of your Committee to even suggest
such a location and I believe that if more thought and consideration were
given to this matter, you could come up with a site more acceptable.
Very truly yours,
r»-e (.'t-
Virginia Olive ira
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W-14
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W-18
DALHOUS1E UNIVERSITY
HALIFAX. NOVA SCOTIA
CANADA
DEPARTMENT OF BIOLOGY
November 7, 1977
U. S. Environmental Protection Agency
Region 1
J.F.Kennedy Federal Building, Room 2203
Boston, Mass 02203
Gentlemen:
In response to your invitation to comment on the Draft Environmental
Impact Statement for Wastewater Treatment Facilities—Tisbury, West
Tisbury, and Oak Bluffs, I appreciate the opportunity to express
grave reservations about the suitability of site 3 (Manter site) for
a wastewater treatment facility.
As I am sure you are aware the Lagoon-Duarte's Valley-Tashmoo axis
is a former pre-glacial drainage channel which marks the interlobate
area between the western or Vineyard lobe of the late Wisconsin ice,
and the eastern or Cape Cod-Nantucket lobe of the same ice. Down
wasting and retreat of this ice produced the outwash plain which
begins south of the Valley and which is broadly exposed at Goodale's
off the Vineyard Haven-Edgartown road. On the north side of the Valley
most basement excavations showed till, whose drainage characteristics
are probable suited for wastewater treatment and disposal. Nevertheless
some basements, as well as well logs in the area, suggest the presense
of gravel lenses and kame deposits similar to those flanking the east
and south sides of the Valley. The soils map (1925) indicates loamy
soils of similar composition on both sides of the Valley, including
the area chosen as site 3.
I consider it highly probable that a considerable risk of groundwater
contamination could occur from this site. An additional concern is
the slow flushing rate of both Lake Tashmoo and the Lagoon. I have
completed some studies (as yet unpublished) of the Lagoon and find that
tidal prism segments in the Lagoon indicate 7 to 9 days residence time
of water in the upper end of the Lagoon, an area already experiencing
eutrophication problems.
With a system volume of about 250 x 10 cu.ft. and a tidal prism of
about 47 x 10 cu.ft. (18 inch tide), system volume is roughly 6.3
times the tidal prism. It therefore follows that the Lagoon is a very
... 2.
•* 4 4''i""/% ?
NGM i'* is/<
-------
U. S. Environmental Protection Agency 2.
sensitive area. Although I have not completed calculations for Lake
Tashmoo, I anticipate the problem to be equally acute, since the
drainage area for Lake Tashmoo is smaller than that of the Lagoon.
I am including a copy of a short paper on Vineyard groundwater which I
prepared for the Felix Neck Naturalist as well as some water quality
measurements I completed a few years ago.
As a consultant to the Nova Scotia Department of the Environment, I have
completed a study recommending the spray disposal of treated effluent
in forested areas. I strongly support the concept of a treatment plant
in the State Forest, with spray disposal of effluent in the forest on
the outwash plain. Not only does this permit waste water renovation
by the "living filter" mechanism, but also ground water flow is directed
toward the south shore and away from municipal well heads.
Studies in Nova Scotia indicate that renovation continues even in winter
months, when tree root growth continues. Winter conditions are generally
milder on Martha's Vineyard than they are in Nova Scotia, so that storage
problems as a result of icing a minimized. I recognize that additional
force mains and piping would have to be installed to a site in the State
Forest, but it is my strong contention that the long-term benefits outweigh
both the cost and the risk involved in more central locations.
If I can supply any additional information, please do not hesitate to
contact me at the above address.
Very tru
>rdon Ogden,
jfessor of Bioiogy
JGO/ds
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IONIC CONTENT OF RAIN AND GROUND WATER IN THE OAK BLUFFS WATER SUPPLY WATERSHED
(Values in mg/liter)
Source
Precipitation
&
•
25.4 mm ppt
65. 8 mm
38.4 mm
Scotsman's Spring
Kame Pipe
0. B. Tap Waterc
Duarte's Pond
0. B. Reservoir
0. B. Reservoir
Crystal Lake
| Date
30 Aug.
30 Aug.
30 July
8 Aug.
30 Aug.
1 .Sept.
5 Aug.
30 July
9 Aug.
30 Aug.
1 Sept.
5 Aug.
"T O"
30 Aug.
20 July
9 Aug.
30 Aug.
30 Aug.
18 Aug.
30 Aug.
30 Aug.
18 Aug.
1
Sodium
1974a 1.05
1974
1975
1975
1975
1973
1974
1975
1975
1975
1973
1974
1974
1975
1975
1975
1974
1974
1974
1974
1974
.66
.76
.52
.63
7.43
7.63
7.1
6.5
5.5
6.93
3.54
7.30
8.30
7.70
5.80
6.45
5.61
33.0
632.
100.9
Potassium Calcium
.19
.19
.53
.34
1.06
.67
.51
.61
.63
.66
.64
.55
.69
.71
.78
.73
.59
1.02
1.59
25.0
3.9
•
*
•
•
•
1.
1.
1.
1.
1.
*
1.
1.
1.
1.
1.
2.
•
3.
30.
36
16
14
14
32
09
26
23
34
16
93
53
88
45
45
46
34
73
60
7
5.5
Magnesium Chloride
.23
.15
.18
.14
.21
.93
1.22
1.16
1.31
.88
.86
1.04
.97
.94
.92
.82
.88
.77
4.10
74.0
11.1
1.
1.
2.
1.
12.
11.
12.
11.
11.
10.
11.
11.
11.
10.
10.
56.
1249.
70
17
05
13
*
04
33
39
97
"
33
19
12
82
54
*•
19
05
,1
165.3
Sulfate
9.
.
2.
4.
""
5.
4.
5.
5.
*™
6.
6.
7.
5.
5.
M
4.
22
o o
28
30
22
86
99
18
57
05
14
10
76
38
t
61
4.99
15.4
169.
26.4
Notes: a - 1974 precipitation samples include first 30 min rain after 2 wk drought,
second sample coll. 2 hr after storm began.
b - Continuous exposure and collection from 17 July
c - coll. from tap near head of Lagoon
d - coll. near head dam, S end of reservoir, Head of Lagoon.
e - coll near causeway N end of reservoir, Head of Lagoon.
f - loc. East Chop drive 1 km W of E. Chop lighthouse
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GOOD TO THE LAST DROP?
by ]. Gordon Ogden, III
A common sense guide to the care and
feeding of Vineyard ground water.
Everyone knows the basic water cycle, or hydrologic cycle, if you want
to get technical about it. Water falls as rain, is stuffed into pipes or wells,
appears at the tap in clear (usually) form, and disappears down the drain
when you flush the toilet. It then goes somewhere and evaporates to form
vapor, which condenses into clouds from which rain again comes, and
you're back where you started.
Because of the more or less circular path that water takes in the hy-
drologic cycle, it is regarded as a "renewable resource." Somehow, between
the time it disappears down the drain and reappears as rain, it gets
"purified." What goes down the drain is bad, and what appears at your tap
is good, and obviously, something has happened in between. This set of ob-
servations has led us to think of water as something excellent to get rid of
things in, such as domestic waste, pulp mill effluents, and all sorts of solu-
ble and insoluble garbage.
My thesis, in the following paragraphs, is that water is neither as re-
newable a resource, nor as inexhaustible, as you may once have thought.
Let's begin by recognizing the uniqueness of this period in time, of this par-
ticular moment. The earth has never before tried to support 3.5 billion
people, with one billion added since 1950. The Vineyard's resident popula-
tion of approximately 7000 and a growing summer visitor population or
more than 40,000 represents an added burden on physically limited re-
sources.
The day you were born, you started screaming in a voice that insurance
companies tell us is likely to be heard for about 70 years, for 2,500,000 gal-
lons of water for yourself, to drink, bathe, and cook in. The products which
you will require during your life span will consume another 50,000,000 gal-
lons of water in processing. Last week's issue of the Gazette, for example,
required about 10pO pounds of newsprint. It required about 20,000 gallons of
water to process the 13 or 14 trees from which the pulp used to make the
newsprint was derived. You can convert those figures into a Sunday Press
run for the New York Times.
But let's return to the requirements that your existence implies: you will
consume more than 10,000 pounds of meat, 2100 gallons of milk and dairy
products, about 22,000 eggs, 9000 pounds of wheat and lots of other
goodies, including more than 200 pounds of peanuts. You expect 21,000 gal-
lons of gasoline and about $10,000 worth of school construction in your per-
sonal behalf. A 40 oz. loaf of bread requires more than 4000 gallons of water
41
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to grow the grain and process the flour. Similarly, 1 pound of hamburger
requires about 2,000 gallons of water for the grass and the animal's thirst.
Your existence has already committed a substantial chunk of landscape
to provide you with food and fibre. About 50-60 square feet of Martha's
Vineyard has to be set aside just to provide you with the oxygen you
breathe each day. You have committed the earth to receiving about 4
pounds of solid waste and up to 3 pounds of air pollution for you each day,
and finding a place for the 250 cans and 135 bottles or jars that you throw
away each year. And just since 1950, you have acquired one billion friends
who are screaming for exactly the same things.
The Vineyard is blessed with a remarkably pure and high quality water
supply. The quality of that water was not established by act of any board of
selectmen. Continued quality of the water, however, is very much in the
hands of each board of selectmen, and one wrong decision on their part can
irretrievably wipe out centuries of high quality water.
The only source of the ground water on Martha's Vineyard that is
"mined" for our water supplies is precipitation. There are no magical "un-
derground rivers" providing inexhaustible supplies of sparkling clear fresh
water. An Island is an Island in a ground water sense just as fully as it is in a
topographic or land sense. Salt water is heavier than fresh water. As shown
in Fig. 1, this means that fresh water floats on salt water. It also means that
if you are going to keep salt water from creeping in from the shoreline, you
must have an hydraulic "head" or gradient to balance the density difference
between salt and fresh water. In point of fact, it takes a "head" of about 40
feet of fresh water to displace one foot of salt water. While the hydraulics of
this problem are beyond the scope of our discussion, we should recognize
that in coastal situations, where the ground water level is near sea level,
overpumping of wells may result in irreversible salt water intrusion.
Let's take a look at the Oak Bluffs water supply watershed. A
watershed is defined as that area within which precipitation falling on the
ground has a preferred surface or subsurface gradient to some point. That
point can be defined as either a surface stream, a lake, or the water level of a
drilled well.
If we take the surface contrours of Martha's Vineyard as a point of de-
parture, we can define the surface watershed of the Oak Bluffs Lagoon sys-
tem to be approximately 1220 acres. Subsurface topography is not quite the
same, but for our purposes, it is close enough to use. The Vineyard receives
about 40 inches of rain per year. Since there are a little more than 27,000
gallons of water per acre-inch, it follows that the total system supply is
about 1325 x 106 gallons of water. What happens to this water? In the first
place, not all of it gets into the ground. Some of it evaporates before it ever
has a chance to get below the surface of the ground. Because of the porosity
of Vineyard soils, this value is relatively small, on the order of 2 acre-inches
per year. The soil itself is capable of holding water, rather like a sponge.
Various estimates place this value at about 4 acre-inches.
42
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Ground Water regime on Martha's Vineyard. (A) Precipitation (P) is the source of
ground water. Depth of ground water is approximately 40 times the height of tlie water table
above sea level datum. (B) generalized hydrologic cycle showing input (Precipitation), losses
due to evaporation, transpiration, runoff, and seepage. W.T. = Water Table. (C) Domestic or
industrial withdrawal may lower regional ground water table (C.W. 1 = natural ground water
level; G.W. 2 = lowered water table due to overwithdrawal). (D) Loss of ground water reserves
due to rising sea level (SL-1 to SL-2 permits salt water invasion from S.W. 7 to S.W. 2). (E)
Overwithdrawal by pumping coastal wells can cause salt water intrusion (S.W. 1 to S.W. 2).
-------
The largest loss, however, is due to the consumptive use of water by
plants. Although unquestionably greatest during the summer (when, inci-
dentally, the municipal requirement for water is at a maximum), many
plants continue to consume water throughout the year. A single corn plant,
for example, requires about 50 gallons of water from germination to maturity
in a 100-day growing season. This averages out to slightly more than 2
quarts a day through the growing season. An acre of corn plants, at a mod-
est planting density of 10,000 plants per acre requires 500,000 gallons of
water, or about 18 acre-inches of water! A single oak tree 30 feet tall, will
require in excess of 200 gallons of water a day during the growing season.
On the Vineyard, a combined figure of about 25 inches for
evaporation/transpiration is not unreasonable (evaporation is the loss of
water as vapor from an unconfined surface, such as a lake, and transpiration
is the water loss from plants) (Fig. IB). One other factor must enter our
equation, the loss of water to deep seepage. On the Vineyard, because our
water supply is essentially confined by the salt water around us, loss to
deep seepage is minimal, because most of it appears as fresh water springs
in the coastal area. As an estimate, I would propose about 2-4 inches per
year to this source. Parenthetically, I might mention, that where a coastal
spring fails, or becomes saline, this is prima facie evidence of over-
withdrawal of ground water upslope from the spring (Fig. IE).
Let us now add up all of the losses to the system. From an initial
"reservoir" of about 40 inches of precipitation, we may deduct about 2 in-
ches for immediate evaporation, and about 4 inches for soil storage. Since
we attributed two inches to evaporation, a figure of approximately 23 inches
for transpiration may be subtracted. Finally, we can expect at least two
inches lost to seepage. Our total system losses then are about 31 inches of
the original 40 inches of precipitation. In other words, more than 75% of the
precipitation falling on the watershed may be unavailable. A little 5th grade
arithmetic tells us that of the original supply of 1325 x 106 gallons of water
from precipitation, only about 330 x 106 gallons may be available for ground
water recharge to this system.
In 1971, total pumpage from the Town of Oak Bluffs Water Supply was
136.6 x 106 gallons, which is slightly more than 40% of the water theoreti-
cally available. It would be a comforting thought that we could more than
double our withdrawal of water from this system were it not for some un-
comfortable facts, so far not considered. The availability of water depends
upon the rate at which it moves through ground water strata to the well
head. Excessive withdrawal of water during periods of reduced precipitation
(as in summer, when water -demands are highest) can result in salt water
intrusion of coastal well fields, a consequence that is virtually irreversible
because of the greater density of salt water. (Note: During the dry summer
of 1971, pumpage values in excess of 750,000 gallons per day were recorded,
a pumping rate greater than 80% of the theoretical supply during this
period.
44
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As water demand on the Vineyard grows (at 60 gallons per person per
day), the threat of salt water intrusion into coastal water supplies will in-
crease. We must also recognize, that in placing increasing demands on
ground water, we are also requiring it to move faster through the system.
Unfortunately, this can mean that things put into ground water can also
move faster, or be removed from areas of deposition, such as septic tank
wastes and road salt.
Recognition of the increasing problem of road salt has prompted the
Massachusetts legislature to pass laws to curb oversalting of roads. While
public health recommendations permit 250 ppm of Chloride in water sup-
plies, no mention or standards have been set for the content of Sodium in
potable water. Yet medical authorities recommend less than 20 ppm of
Sodium in water for people with heart disease, hypertension, and fluid re-
tention.
At present, only one major road (Vineyard Haven-Edgartown) crosses
the main Oak Bluffs watershed lands. There is very little development, with
not more than 10 families in the 1,220 acre watershed. Development in the
axis of the Lagoon valley, which is a major part of this watershed, is quite
likely to degrade the remarkable water quality that history and geography
have made the responsibility of the present town fathers.
-------
Water is not the only substance to participate in the hydrologic cycle.
Studies in Nova Scotia show that the bulk of forest nutrients come from the
atmosphere. On Martha's Vineyard, there is little reason to doubt that our
sandy soils are replenished primarily by the same mechanism. While 0.19
ppm (milligrams per liter) of Potassium (an essential plant nutrient) does not
sound like much, it amounts to nearly 2 pounds per acre per year. Since
more or less than these amounts have been falling on Vineyard soils ever
since the last glacier ice melted, it follows that plants need merely to trap
some fraction of the incoming nutrients from the 2000 pounds or more per
acre that have fallen over the past 12-15,000 years.
It is important to note that plants do not have a significant requirement
for either Sodium or Chloride, and since Sodium is only weakly held by clay
minerals ( and Chloride not at all), the ratio of various minerals in input and
output is a fair measure of the ability of an ecosystem to sequester and retain
nutrients.
Input values from a single storm (30 Aug., 1974, Table 1) are not suffi-
cient to provide firm generalizations for the annual atmospheric nutrient
input to the Vineyard. More complete data from Nova Scotia indicate a far
higher input of Sodium and Chloride in coastal environments. Nevertheless,
we can observe that some substances are selectively stripped from input
precipitation. Table 2 shows that concentrations of sodium and chloride are
7-9 times higher in ground water output than incoming precipitation. The
lower ratios for Potassium, Calcium, and Magnesium (all essential plant nu-
trients) imply that these ions are selectively retained in vegetation and soil.
Sulfur is not considered here because of the numerous chemical forms
which sulfur may take, and only one form, sulfate, was measured.
The principal point in this argument is that Vineyard ground water is
only slightly concentrated rainwater, and is in a remarkably pure state. For
example, Oak Bluffs tap water (table 1) contains less than one-third the max-
imum amount of Sodium recommended by the American Medical Associa-
tion. Development activity in watershed lands is virtually guaranteed to in-
crease Sodium and Chloride levels in ground water. In the Halifax area,
ground water concentrations as high as 3000 parts per million of Chloride
have been measured, largely as a result of ice and dust control programs on
streets and sidewalks.
There is a standard engineering answer to such problems. It usually
runs, "tell me what quality you want, and I'll design a system to produce
it." It is appropriate to ask whether high-voltage treatment technology, pro-
ducing polished, treated, and filtered tap-juice is an improvement on a
natural protected system. Development of a major community at the Head
of the Lagoon promises severe encroachment on the Oak Bluffs Watershed
lands, just as development at the other end of the valley on the Vineyard
Haven-West Tisbury Road threatens that water supply. All of us have a
stake in the decisions that elected representatives must make. They have
been given responsibility for a resource they did not create, but whose con-
tinued quality is solely theirs.
48
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W-19
of
Won
M8LVIN H. KING
Representative
Committee on Natural
Resources & Agriculture
MICHAEL SCULLY
Legislative Assistant
home:
Box 1333 (State Road)
Vineyard Haven, 02568
Protection Agency
Impact Office
TOi tnviornaental
Enviornmental
FROMt Michael Scully
RE I Draft Enviornmental Impact Statement (D-EIS)t
"Wastewater Collection and Treatment Facilities for
Tlsbury, Oak Bluffs, and Tlsbury, Massachusetts.M
DATE I November 14, 1977 (hand delivered)
The following is hereby placed into the record of written
comments regarding the above D-EIS. These written comments
are intended to clarify, refine, and expand upon my very general
spoken comments at the October 26 E.P.A. hearing in Tisbury.
Please be advised that while I do not now speak officially
herein for this Committee on Natural Resources, the concerns
direct matter of concern to
this Committee in the coming
•icic*u i. v J. b ii i a WHIN iiL.ee uii nauuiaj. neswuiwgt, i.ue vunverna
raised here could well become a direct matter of concern to
this Committee in the coming months, particularly as relates
to state funding.
I urge the E.P.A. and its consultants to redraft the D-EIS
before a final EIS is written. Although I didn't call for this
at the October 26 hearing, the more I read the September D-EIS,
the more its gross Inconsistencies and grave omissions become
obvious* Many of these inconsistencies and emissions are in
direct violation of E.P.A. Directives and regulations, and have
denied the people of our Town* their right to fully weigh all
of their sewage and nightsoil options. Because of the extensive
nature of the D-EIS's omissions and misrepresentations, it
will be inadaquate to merely make adjustments In a final EIS,
after the end of the decision-making process. The D-EIS
should be redrafted entirely, and accordingly, E.P.A. ought
to keep the period for written comments on the September D-EIS
open indefinitely*
I address the SeptffctWfr D-EIS under two general catagoriesi
Collection, and Treatment*
NOVH 197?
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D-EIS, Nov. 14, 1977, p.2
COLLECTION of NIGHTSOIL (& Wastewater)
The "need" for a $2 million collection system in Tlsbury,
as favored by Che D-EIS, has not been established. I need not
elaborate on this to much detail much beyond pointing to the
unanimous consensus of our townspeople as expressed at the
October 26 hearing. But a few general observations are in order.
I greatly welcome our Board of Health's willingness to
conduct a door-to-door survey to establish the exact magnitude of
the sewage problem. This is something that E.P.A.'s consulting
firm should have done months ago*
How did Anderson-Nichols (E.P.A.'s consulting firm) come
to the conclusion that such a small town as Tisbury ought to
have such an enormous sewer system? This conclusion is based
mostly on their random mail surveyi over 1,000 questionares
were mailed out, only 163 were returned, and of these, only
22 unit owners said they have any sewage problems. This is
hardly adequate Justification of a massive $2 million sewering
of the Town. It is indeed a sorry spectacle to see the Town
Board of Health have to do a survey which this firm should
have done, considering the letter's |100,000 E.P.A. contract.
While the D-EIS fails to provide adeqate documentation of
the real scope of nightsoil problems, it also falls
to explore certain non-structural alternatives to sewering,
including) new or improved on-lot septic tanks, clustering
small problem areas with holding tanks and more frequent pumpouts,
prohibition of garbage grinders, and reduced waTer consumption
(as a means of reducing the wastewater "problem1*). Pursuant
to E.P.A. Directives and regulations, a redrafted D-EIS must
explore these potentials Individually and In combinations.
The redrafted D-EIS must do so in at least as much detail as
the September D-EIS discusses the "merits" of sewering.
A redrafted D-EIS must also thoroughly explore the longterm
consequences of Induced population and development growth that
sewering would bring to the Town. Sudden new development
usually means that more services must be provided by the Town,
which means higher local taxes. The redrafted D-EIS must
address these questions thoroughly.
The whole basic approach to wastewater and collection
should be thus* If we have a problem, let's deal with It In
least capital-intensive and energy-Intensive ways — ways
that minimize undeslreable growth, development, and disruption
Impacts upon the community. This consensus was expressed time
after time at your workshops, before the release of the D-EIS.
Nevertheless, the D-EIS seems Intent on selling an overdesigned
system to the Town.
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D-EIS, Nov. 14, 1977, p.3
I urge a redrafted D-EIS to focus particular attention
upon the potentials of water conservation as a means of reducing
the wastewater problem. This is especially Important if all
wastewater problems cannot be solved with on-lot solutions,
and we have to resort to having a few raultiunit cluster pipes
with holding tanks. By adopting a strict program of water
conservation in those clustered units, we would be able tot
minimize the required size of the holding tank(s);
reduce the frequencies of pumpouts; reduce the required size
of a wastewater treatment facility or spray-irrigator;
reduce the amount of wastewater to be treated; and better
ensure a proper water/solld/nightsoil tatio for a quality
by-product. In the event that any wastewater is included at
a treatment facility, water conservation will have to be required,
Finally, one specific "line item1* correction to the D-BISi
p. 187, last paragraph, bottom sentence. In reporting on public
workshop #2, you conclude,H...the participants agreed that the
wastewater treatment facility should be expandable to accommodate
unanticipated future needs, and that it should yield a by-
product usable for agricultural purposes."
You should strike out the first half of this sentence
completely. I recall that very few citizens agreed that there
should be a wastewater treatment facility at all, let alone that
it "should be expandable." You could say that most folks favored
having nightsotl treatment that must yield a usable by-product
for local food production.
TREATMENT of NIGHTSOIL and OTHER "WASTES"
In my letter to you of April 1977, I indicated a number
of critical criteria that must be included while evaluating
various treatment options. Besides water quality, these
holistic criteria includei whether the Towns can recover some
of the money they're spending by marketing a final product
(compost, fuel, or fertilizer); which type of treatment is most
contributive to the Island's longrange overall economy (jobs,
food savings and farm revitalization, new energy sources, etc.);
and which treatment will most support the Island's ability
to feed itself more through the next 10 - 20 years, in an
age of greater scarcity (via a local "energy self-sufficient
agriculture which is free from reliance upon dwindling petro-
chemical fertilizers", because we return wastes to the soil.).
The D-EIS largely ignores addressing these critical
longrange considerations to the Island's economic and food security,
in its approaches to the treatment of wastes. By ignoring many
of these centrally vital concerns, the D-EIS has also failed
to fulfill a number of ElS-procedural rules as specified in
various Administrative Directives, E.P.A. regulations, and
federal laws. First and foremost, the redrafted D-EIS must
take a holistic approach to nightsoil and waste treatment.
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D-EIS, Nov. 14, 1977, p.4
The D-EIS*s failure to take a holistic approach is especially
demonstrated by the D-EIS's focusing greatest attention and
detail upon Alternative #3 (for conventionally synthetic waste-
water treatment) without giving nearly as much detail to other
options. The D-EIS is legally required to give equal attention
to other options, including composting and anaerobic digestion
as potentially initial treatment stages of the wastes.
Though the D-EIS claims not to recommend any one Alternative
over another, its more favorable presentation of Alternative 3
is tantamount to making such a recommendation* This is probably
due to Anderson-Nichol's greatest familiarity with conventional
(overdesigned) resource-throwaway technologiest technologies
which inherently take a tubular rather than holistic approach.
When the D-EIS deals with composting at all, it relegates it
as being something that you might do with sludge after you've
chemicalized, Purifaxed, or RBD'ed the very best micro-organisms
and nutrients to death. This assumption shows that the writers
of the D-EIS lack a basic understanding of what microbial/bio-
logical composting processes are actually all about.
Well, the general idea is thisi we want to treat our nightsoil
in the most economical and resource-efficient ways. This means
maximizing the natural mlcrobic activities through renewable
inputs, while minimizing nonrenewable and synthetic inputs.
The value of compost primarily exists in its ability to become
living humus, and break down properly in farm soil. The less
that the beneficial elements are removed from the waste matter
(N,P,K, and the equally important "trace elements"), the more
will be available for soil and plants.
The quality of a compost product is of essential importance.
I will defer to Mr* Edward Pachico's statement of October 26
as a more detailed biological explanation of this centrally
vital concern* But suffice it to say that the D-EIS has not
fulfilled its public and legal responsibility to present the
composting process in its proper, most micobiologically-efficient
states.
Likewise, from what I have seen of successful anaerobic
dlgestors, the D-EIS grossly misrepresents (negatively) the
promising potentials of anaerobic digesting. Again, this
seems due to the consultant's lack of competence in micobiol-
ogical processes. The redrafted D-EIS must deal with anaerobic
digesting in a more balanced, objective, and equitable manner.
The taxpayers of these Towns will be paying for years to
come for the operation of a treatment facility. They are
fully entitled to be presented with all the facts relative to
less costly and revenue-generating forms of treatment. This
is directly pertinent to any projection of costs.
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D-EIS, Nov. 14, 1977, p.5
Because such data is not included in the D-EIS, the taxpayers
have been denied clearer information which sight have led
them to support one fora of treatment over another. Back in
Aprilj I called for you to conduct a market survey to determine
different demand (and possible prices) for different types of
compost products. I also requested you to look at other towns
and cities throughout the country who are successfully recovering
some taxpayer's money by recovering their wastes as fertilizers.
The D-EIS has utterly ignored these requests.
The failure of the D-EIS to address holistic concerns is
furthur demonstrated by its ignoring the promising potential
of treating solid wastes along with nlghtsoil. The D-EIS
states on page 173t "It is not possible to estimate the quantity
of refuse that will be used for this purpose (composting)..."
There is little excuse for the D-EIS's oralting a list of avail-
able components for treatment t the 208 Water Quality D-EIS
lists many, and you only needed to copy these figures.
I hasten to remind you, that Public Law 92-500 requires that
the 201 D-EIS fully consider the potentials of combining such
solid wastes as woodchips, fish wastes, garbage, and refuse,
along with nightsoil and wastewater for treatment.
One of the gravest omissions from the 201 D-EIS was that
of soil stability and soil erosion,consequences and concerns.
Certainly if you are going to talk about "Enviornmental Consequ-
ences of Alternative Approaches" as you start to in Chapter V,
you have got to discuss how various forms of treated by-products
will help the Island's soil stability. A D-EIS must take into
account the continuing depletion of our precious topsoils that
will result if no compost product is made available, causing
our topsoils to be increasingly subjected to petrochemicals.
Similarly, the D-EIS must account for groundwater pollution
caused by additional petrochemical applications, if a
substitute by-product is not rendered from nightsoil treatment.
Nor has the D-EIS adequately explored the possibility of
an Island-wide nightsoil treatment facility (including or
excluding Edgartown). Such a facility could probably offer
greater economies of scale, could more efficiently manage any
solid waste inputs, and by increasing the amount of available
nightsoil would render a greater volume of reusable compost or
gas. The 201 Water Quality staff as well as the State Depart-
ment of Enviornoental Quality Engineering have called for
Islandwide nightsoil treatment. The redrafted D-EIS must
thoroughly explore this possibility.
I am extremely disappointed in the D-EIS's near complete
avoidance of successful tartUry treatments in the form of spray
irrigation, to dispose of wastewater. This practice at Otis
Air Base and other places is inexpensive, meets federal and
state standards, and causes good crops to be yielded from other-
wise idle lands. I must question your projection on
p.117 (D-EIS) that spray irrigation would require 100 acres
each for Tisbury and Oak Bluffs. (Does this same figure hold
if we enact maximum on-lot upgrading and water conservation,
for instance?) A new D-EIS must evaluate the potentials of
•pray irrigating.
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D-EIS, Nov. 14, 1977, p, 6
Now, a few specific corrections and expansions in Che
D-EIS are suggested, regarding treatment!
On p. 31, the figures for Island farm acreage which you
chose to use are actually misleading. While it is true that
from 1951 - 1971 agricultural lands were reduced from 14% to
9%, the total agricultural land acreage has risen stedtly
since 1965 on the Island. These latter.figures give a more
accurate idea of a growing demand for a composted humus/fertilizer
product. I urge the redrafted D-EIS to use these figures
instead (Martha's Vineyard Commission survey, by Robert Woodruff,1976).
On p. 192 (under subsection VI.Et "Irreversible and Irret-
rievable Committments of Resources") you should add to that
listt "Reductions of available and future energy sources and
agricultural inputs, which could have impacts on fefee Island's
overall economy."
Similarly, on pp. 177-178 (under V.H.5("Economic Impacts")
the last paragraph needs expansion. Here you haven't accounted
for such secondary beneficial impacts from resource-recovery ass
Towns marketing the compost or fuel by-product; having a new
major factor to discourage any Island farm closings (which trans-
lates into our 10 - 20 year food security); and longrange consumer
savings on food and fuel needs, as imported nonrenewable energy
sources become mere scarce in coming years.
On p* 176 (under V.H.4t "Enviornmental Consequences*..Energy")i
you should replace the last sentence in the third paragraph
entirely by the following("There will be positive secondary energy
impacts associated with Alternative 2 and unassociated with growth.
These c«me especially in longterm petrochemical substitution
which can enhance food and fuel supplies on the Island,
while enhancing more stable consumer costs for these items."
Finally, the D-EIS has not Justified sewering and/or
wastewater treatment in real life-cycle costing terms.
Nor has it defined how close such facilities can come to paying
for their own replacement costs. The taxpayers are entitled
to see such comparative figures in a holistic format. And when
we begin to life-cycle cost treatment options, we will have a
clearer idea of how so-called "waste" can become an opportunity,
instead of a problem.
All in all, you've got a large amount of changes, additions,
and research to make in redrafting the D-EIS. We are hopeful
that you will be responsive in doing so*
MJSilh
cc's: (public)
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Memorandum
W-20
DEC i 5 1977
Anderson-Nijhols
I!. • I. P'I M.iv i I -i • II- li.'II 1
it.i/i M. i 'i
To
Ken Wood
13 December 1977
Burk Kotcham
EPA
From
Peter Murphy
I llVI1.lull
Plannincj
Subject; Comment on DEIS
Martha's Vineyard
JubNumb-i ?923~06
The attached comments on the Draft EIS were received by ANCo this
morning. We have Xeroxed a copy of this for our files and are
submitting the original to you.
ANCo has not received any other comments on the Draft EIS submitted
directly from the public.
PVM:nfg
Enclosure
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jr
.
r ^ to ±L lui (j^tJU-^ (jJ-8^4 ^0-°
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relating to the Draft Environmental Impact Statement(EIS) released Sept. 12, 1977
INTRODUCTION
The Final Regulations for Preparation of Environmental Impact Statements; Vol. 40,
Number 72, published Monday April 14, 1975, in the Federal Register outlines the procedures
and considerations to be taken by the Environmental Protection Agency(EPA) in preparing an
EIS. There are many inconsistencies within the Draft EIS Wastewater Collection and Treat-
ment Facilities for Tisbury, Oak Bluffs, and West Tisbury, Massachusetts; and the afore-
mentioned Federal Guidelines. These inconsistencies are so pervasive that the Draft EIS
should be redrafted before the Final EIS is written. An alternative to rewriting the whole
EIS would be to print an appendix that outlines the more environmentally sound alternatives
that were not given proper consideration during the Draft EIS process. The reason for a
request to redraft is due to the fact that many environmental values were not identified
and weighed from the outset. Simply accomodating these adjustments at the end of the
decision-making process will not give proper consideration to these environmental influences
and will not allow adequate public scrutiny before the Final EIS is issued. This consideration
of all environmental influences from the outset is required by the National Environmental
Policy Act (NEPA).
LEVEL OF DETAIL
The Draft EIS in the Executive Summary: Section 7. Conclusion states: "The Draft EIS
does not present a preferred solution to the problem of water resource pollution from among
the several alternatives." Chapter VI Identification of Environmentally Sound and Cost
Effective Alternatives also states that: " Public participation, which is the foundation
of the decision-making process in this EIS, has not produced a definite community preference
foe any one alternative. Accordingly, this Draft EIS cannot recommend a specific course of
action." In addition, it was reiterated many times at the Fourth Public Participation
Workshop that no decision had been made by EPA and the Draft EIS was only to allow the public
to weigh all the options.
However, after reading the Draft EIS it is clear that Alternative 3 is given the
greatest detail, while composting and anaerobic digestion are only breifly mentioned. In
Section 6.304 Body of EIS(1)(a) Background and description of the proposed action states:
"When a decision has been made not to favor an alternative until public comments on a
proposed action have been received, the draft EIS may treat all faesible alternatives at
similar levels of detail " This treatment of alternatives at similar leves of detail is
not at all done in the draft EIS. Much more detail is given to Alternative 3 than any other
treatment system. This does not allow an informed choice by the public. Instead, this seems
like an attempt to force one choice on the public, whether they want it or not. This level
of detail in assesing Alternative 3 is probably due to the familiarity of conventional waste-
water treatment facilities to EPA and Anderson-Nichols. These conventional wastewater treat-
emnt facilities were originally designed with only one thought in mind, destruction of the
(1) EPA Final Regulations Preparation of Environmental Impact Statements. Monday April 14,1975
Federal Register Vol 40 # 72.
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(2)
waste materials at any cost. When these plants were originally designed no need for waste
recovery was thought of. The reason for this approach is due to septage and wastewater
being seen as wastes and not potential resources.
ANAEROBIC DIGESTION
On page 115 and D-13, in the description of an anaerobic/aerobic treatment system the
EIS states:"the operation of this process could result in an odor and disease vector problem."
(page 115); and "odor is a prime concern."(D-13). It should be noted that odor is non-existent
in an anaerobic digestion system provided that the proper carbon/nitrogen(C/N) ratio and pH
are maintained. In any system of waste treatment odor is a prime concern when improper
operations are carried out. The Edgartown Treatment Plant should be noted here as an
Alternative 3 type system that is plagued with odor problems. Should we fund another "Rube
Goldberg" like that for Tisbury and Oak Bluffs? Why odor is singled out as a problem only
in the anaerobic system and none of the other systems is not known. Odor concern may be due
to previous improper operations and handling of anaerobic digesters by sanitary engineers
with very little knowledge of microbial processes. All digesters that I have seen operated
by engineers were plagued by odor problems because of improper consideration of the biological
constraints of microbial processes (eg.C/N ratio and pH). Digesters that I have seen operated
by microbioloogists have had no odor problems. We must remember that in all secondary treat-
ment plants, composting and anaerobic digestion we are working with microbial systems, yet
the engineers who design and operate these systems have very little knowledge of microorgan-
isms. This is like asking a plumber to repair or design a Swiss watch.
The biochemical transformations that occur in the breakdown of septage and solid waste
can be diverted from preferred paths so that the digested material may not be in the ideal
form for soil incorporation. The final quality of the effluent is completely controlled by
the environment(eg. temperature, light, aeration,etc.); types and quantities of microbes
present; biological succession of the decomposing material; original parent material; C/N
ratio; and pH. Under adverse biological conditions, the parent material may be decomposed
into a toxic recalcitrant molecule that is detrimental to the growth of plants, even though
the original material was non-toxic and highly degradeable. An example of this is an amino
acid or polypeptide containing a sulfur phenolic ring that in "whole form" is biologically
important in the sustenance of life. Under degredation by an organism in the presence of
nitrogen, the sulfur ring compound could become a sulfonamide or sulfanilamide with biocidal
properties. This process could occur by an amide of a carboxylic acid breaking down in the
presence of ammonia and then combining with available water to form a sulfanilamide. Farmers
who use ammonia in the more concentrated form, eg. anhydrous ammonia or ammonium nitrate are
creating these antibiotic compounds which kill life within the soil. This causes a shift
within the microbial populations which favors the development of phytopathogenic organisms
instead of beneficial organisms.
Likewise, materials under constant forced aeration, such as found in a secondary treat-
ment plant, can be broken down into oxides of different molecules. The sulfur groups present
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are transformed into sulfur oxides, the nitrogens into nitrogen oxides, and the heavy metals
into metallic oxides of different valences. In this oxide form the metals are more biologic-
ally active in plant nutrition and due to their increased availability tend to become incorp-
orated into the plant's living tissue in toxic concentrations. During the traditional
mineralization process in conventional treatment plants all of the soil-building value of
the materials are destroyed. To further compost these sludges would reduce the volume of
materials available for agricultural uses. The reason for the lost value is again due to
the original thinking of wastewater engineers, which concerned itself with the greatest
destruction and reduction of the material to the smallest volume. "Waste products" were
considered of no practical benefit. Based on this destroy at any cost mentality, we have
evolved a system of waste "recycling" of sewage and sludge that is not at all beneficial
to the soil. In fact, all of our previous "recycling" of sewage and sludge has not been to
to incorporate the material back into the soil, but to isolate the material from the prime
agricultural lands by either dumping it in sanitary landfills or burning it in incineration
units.
In a composting or anaerobic digestion system, the materials never get mineralized to
the oxidized form found in conventional aerobic wastewater treatment plants, hence there is
never the problem of heavy metals. The composted or anaerobically digested material contains
a higher humus content, than the mineralized "dirt" from a WWTP, and the humus chelates the
heavy metals so they are not as available and active. As this composted or digested
material is introduced back into the soil, the humus slowly breaks down and releases the
metals in low concentrations over a period of time, unlike WWTP residues which have metals
available immediately.
Metals are required by biological systmes in extremely low concentrations for the proper
functioning of enzymes in plants, animals, and humans. Humus by slowly decomposing releases
the metals slowly in nearly the exact levels required for adequate plant nutrition.
The quality of the finished materials is therefore of extreme importance. The quality
of the material should not be measured by Nitrogen(N), Phosphorous(P), and Potassium(K) ash-
analysis only. The biological form in which the N,P,K occurs is just as important in plant
nutrition. Large amounts of low quality residue will not have as positive an effect on
plant growth as small amounts of high quality residues. By reducing the amount of material
needed per acre for stimulating plant growth, we can allow greater access to the limited
amounts of materials and reduce the heavy metals problem at the same time. Other important
considerations in finished materials are: percent humus and organic matter; cation exchange
capacity; percent saturation of Calcium, Magnesium, Potassium, Sodium, trace elements, and
Jiydrogen ions; types and amounts of microorganisms present; percent stabilization; and pH.—
(2) For an idea as to the levels of heavy metals within WWTP's, see Testing of Certain Heavy
Metals Within the Westfield WWTP, a report submitted to Richard Cavagnero; NPDES Permits
Division, Region I. Report was prepared by the author of these comments.
(3) Donald Epstein- USDA soil physicist, private converstaion at Seventh Annual Composting
Conference held at DMass on May 5-7, 1977.
(4) See Humus by Selman A. Waksman.
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In addition, proper composting and especially anaerobic digestion residues contain
large amounts of mycolytic organisms, unlike conventional WWTP residues. These mycolytic
organisms destroy phytopathogenic organisms such as nematodes, Verticillium, and Fusarium,
reducing the amount of fungicides and nematocides needed by farmers, as well as reducing
crop loss due to these harmful organisms. This will increase the farmer's net profits
because less disease will occur, giving greater marketable yields, and less money will be
spent on these synthetic biocides. Therefore the cost per acre will decrease, while the
yields will increase giving the farmer a higher rate of return on investment per acre. The
use of these well composted or digested materials will also have a tertiary effect of less
demand for synthetic materials, reducing oil and natural gas consumption; and will decrease
the use of toxic compounds which affect all life, not just those organisms selected for by
the biocide.
This increase of quality fertilizers and resultant reduction of costs to farmers will
help increase farming on the Vineyard. The Vineyard Conservation Society reports that out of
the entire state of Massachusetts only Dukes County increased its agricultural production
from 1965 to 1976; this was incorrectly stated in the Draft EIS, which noted that agricul-
tural productivity had declined. This increased agricultural production has many side effects
not commonly associated with farming.
At the present time, Massachusetts inports 85% of its food from out of state, and 65% of
this imported food comes from California. By increasing local agricultural productivity we
will decrease the amount of imported food needed by the Vineyard, reducing air, truck, and
ferry transportation costs and saving many barrels of oil. In addition, local produce needs
to be neither processed, preserved nor packaged; reducing oil consumption and decreasing
solid waste on the Vineyard.
It is estimated taht before the year 2000, California will have no food to export
outside its state boundaries. Dust bowls reminiscent of the 1930's will also strike the
Midwest according to meteorologists, within the next 10 years. At the present time, Massachu-
setts as a whole has only 1-3 weeks of food on hand at any one time. Any disruptions in the
chain of events that delivers food to the Norhteast could cause food shortages in the near
future. Indications of this problem are already surfacing with the California drought problem.
Massachusetts' residents pay $ 3 billion dollars per year for their imported food and
nearly $ 300 million dollars(10%) is for transportation costs alone. Massachusetts and the
Northeast pays 10%-15% higher food prices than the rest of the nation. By using the Vineyard
as a model of increased food self-sufficiency, as stated in the Policy for Food and Agricul-
ture in Massachusetts, other areas can adapt our solutions to their own situations. This
increased food self-sufficiency will help "recycle" some of the $ 3 billion dollars presently
leaving the state, as well as provide increased jobs and an increased awareness of the
present problems in our food and agricultural industry. .
(5) Sanitation of Soil by Microorganisms by N.A. Krasilnikov, from Ecology of Soil Bacteria
(6) Massachusetts Department of Food and Agriculture.
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This increase in productive food land on the Vineyard will help
maintain and renew the Vineyard's previous history of food self-sufficiency.
At one point in time the Vineyard even exported food to the Cape and
Boston. It would seem that by increasing the quality of the residues
produced by waste treatment we will not only maintain but enhance the
quality of the Vineyard environment, as well as solve many of our pressing
food and unemployment problems. NEPA's goals are to not only preserve
but to also enhance the natural environment.
The goal of a high quality effluent or residual product, also seems
the most consistent eith the intents and goals of NEPA and P.L. 92-500.
In fact, the production of a high quality waste product as outlined
above, has so many beneficial side-effects that to consider a conventional
wastewater treatment plant for the Vineyard would be totally inconsistent
with the aforementioned Acts. Federal and state funding for a conventional
treatment plant would be a waste of taxpayer':s money and would tend to
deteriorate the Vineyard ecology as well as leave the Island open to
disruptions in its food supply.
To attempt to separate the problem of water quality from food
production and the other environmental effects in the Draft EIS, is
extremely short-sighted and narrow-minded. The goals of NEPA to consider
all environmental effects of a planned action, are being side-tracked by
the conventional "destroy at any cost" mentality of the EPA and the
consulting engineering firm. Anderson-Nichols' approach to the problem of
water quality on the Vineyard is a blatant example of decision-making
before all environmental aspects are considered, and is totally at odds
with the NEPA process. The remark of Peter Murphy that this is a waste-
water problem and is therefore not concerned with food production is as
narrow-minded as Gary Saxton's previous workshop comment that we can
always import ammonium fertilizers from Texas and therefore we should not
concern ourselves with the fertilizer value of the residue.
Yet a letter dated July 8, 1977 from Peter Murphy to Micheal Scully
states: "Your(Micheal's) interest in the agricultural productivity of
Martha's Vineyard and energy conservation are very pertinent to the
Environmental Impact Statement." Mr. Murphy further states: "You should
t>e assured that the evaluation of composting in the EIS will be entirely
objective and that no one alternative will receive preference." The letter
"as also sent to Ken Wood and Robert Mendoza of EPA. As previously noted,
the Draft EIS is extremely biased and does not detail all of the alternatives
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to the same degree. Mr. Scully's letter is a matter of public record as
part of the EIS process. However, after comparing the Draft EIS with NEPA
regulations and re-usable by-product requests such as Mr. Scully s, the
Alternative Energy Group, other interested residents and myself; I find
that the Draft EIS falls far short of its expectations and requirements.
I feel that in order to do justice to the alternatives, a comparison has
to be made in equal depth, along the same parameters, so that a direct
comparison and accounting of the costs, benefits, agricultural by-products,
jobs, etc. can be made by the public.
Conventional linear engineering approaches to unconventional cyclical
ecological problems has no place in the overall decision-making process. If
these conventional approaches continue to be presented in the Final EIS,
many of the citizens of Martha's Vineyard will be forced to file suit
against EPA and Anderson-Nichols for failure to follow Federal and state
regulations in regard to the EIS process. In addition, copies of this
and other sets of remarks will be forwarded to CEO and the EPA administrator
to insure that NEPA will be followed.
EIS and the LAW
Many federal laws pertain to the sewage and solid waste problems of
Martha's Vineyard. Public Law 92-500 Section 201(a) through(g) encourages
systems which treat all wastes generated within an area, which are revenue
producing in excess of capital and maintenance costs, and which recycle
potential sewage pollutants through agricultural production. The anaerobic
digestion and composting proposals are more consistent with this law than
a conventional sewage treatment plant. Many sections of P.L. 94-580(Resource
Conservation and Recovery Act), and P.L. 89-272(Solid Waste Disposal Act)
also apply to the Martha's Vineyard waste treatment process. Hopefully
these Acts will be taken into account when a final decision is made within
the Final EIS. Only those treatment systems that are the most consistent
with the laws should be considered for funding.
Al
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APPENDIX C
PUBLIC HEARING ON DRAFT
ENVIRONMENTAL IMPACT STATEMENT
C-l
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PUBLIC HEARING ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
On October 26, 1977, a public hearing on the Draft Environ-
mental Impact Statement was held at the Town Hall, Tisbury,
Massachusetts.
A transcript of the public hearing was prepared by EPA and
is available for review at the following locations:
Environmental Protection Agency
Environmental and Economic Impact Office
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
Selectmen's Office
Town Hall
Tisbury, Massachusetts
The transcript has not been reproduced in this document
because many of the questions raised at the hearing were
covered by the publication of the SDEIS. Nevertheless,
all pertinent comments raised at the hearing are responded
to in Section 2.2 of Chapter 2 of this document.
A list of those speaking at the public hearing may be found
on Page C-4.
C-3
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LIST OF PUBLIC HEARING SPEAKERS - DRAFT
ENVIRONMENTAL IMPACT STATEMENT
Comment No. Source
HI Marguerite Bergstrom
H2 Michael Jaccobs
H3 Susan Costes
H4 Robert Douglas
H5 Walter Renear
H6 Laura Brecht
H7 Robert Woodruff
H8 Lyle Brecht
H9 Edward Pachico
H10 Matthew Tobin
Hll Ron Mechur
H12 Michael Scully
H13 Charles Laws
H14 From the Floor
C-4
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APPENDIX D
WRITTEN COMMENTS ON SUPPLEMENT TO THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT
D-l
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SW-1
United States Department of the Interior tOCT 1 ? 1978
OFFICE OF THE SECRETARY
Northeast Region
15 State Street
Boston, Massashusetts 02109
ER-78/878
October 17, 1978
U.S. Environmental Protection Agency
Environmental and Economic Impact Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Dear Sir:
We have reviewed the supplemental draft environmental state-
ment for wastewater collection and treatment facilities for
Tisbury, West Tisbury, and Oak Bluffs in Dukes County,
Massachusetts, as requested in the letter of September 5
from Mr. Adams.
We find that our comments of November 18, 1977, on the draft
environmental statement regarding outdoor recreation have
not been addressed in the supplement. We suggest that a map
of any recreation areas located near the project site be
included in the final statement, along with a description of
any impacts the proposed project will have on those recreation
areas.
In regard to biota, the supplement simply states that the
alternative sites are wooded (p. 7). This information is
not sufficient to facilitate an adequate environmental
review. The final statement should describe the vegetative
cover at each site and the wildlife resources known or
suspected to inhabit the sites, and note the presence or
absence of any endangered species which have been listed or
are proposed for listing.
Although chapter IV summarizes the environmental impacts
expected to result from the project and addresses what steps
can be taken to avoid adverse impacts, it fails to discuss
.CONSERVE
1 ERICA'S
ENEROY
Save Energy and You Serve America!
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impacts to fish and wildlife and their associated habitat.
Such' a discussion should be included in the final statement.
Thank you for the opportunity to comment.
Sincerely,
William Patterson
Regional Environmental Officer
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APPENDIX E
PUBLIC HEARING ON SUPPLEMENT TO THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT
E-l
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LIST OF PUBLIC HEARING SPEAKERS
SUPPLEMENT TO THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
COMMENT SOURCE
SH-1 Bill Wilcox
SH-2 John Allen
SH-3 Edward Pachico
SH-4 Myron Thomas
SH-5 Jim Norton
SH-6 Cora Madeiras
SH_7 Isabelle West
SH_g Robert Douglas
SH_9 Harry Jones
SH-10 Michael Jacobs
SH-11 Ann Crosby
E-3
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PUBLIC HEARING TRANSCRIPT
E-5
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Volume _I
Exhibits
UNITED STATES OP AMERICA
ENVIRONMENTAL PROTECTION AGENCY
REGION I
A PUBLIC HEARING on the Supplement to the Draft EIS on
Wastewater Treatment and Collection
Facilities for Tisbury, West Tisbury,
and Oak Bluffs, Massachusetts, held at
Tisbury Regional School, Tisbury,
Martha's Vineyard, Massachusetts on
Thursday, October 12, 1978 commencing
at 7:00 P.M. before:
Rebecca Hanmer
Deputy Regional Administrator
Region I
Environmental Protection Agency
JFK Federal Building
Boston, Massachusetts
18 TREMONT STREET
BOSTON. MASSACHUSETTS O21O8
(617) 523-3068
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1 PROCEEDINGS
2 MS. HANMER. Good evening. My name is Rebecca
3 Hanmer. I am Deputy Regional Administrator of Region I
4 of the Environmental Protection Agency.
5 I have with me this evening some representatives
6 of EPA, the State Division of Water Pollution Control,
7 and Anderson-Nichols who are the consultants to EPA
8 responsible for the preparation of the supplemental
9 Draft Environmental Impact Statement. I'd like to
10 introduce them to you.
11 On our far left is Brian Jeans with the Massachu-
12 setts Division of Water Pollution Control. Next to him
13 is Paul Pinault who is a Project Engineer with the
14 Municipal Facilities Branch in EPA. Then we have
15 Sharon, our able stenographer. To my immediate left is
16 Bob Mendoza from the Environmental and Economic Impact
17 Office of EPA. I'm sure most of you have met him by now.
18 On my right is Peter Murphy who is the Project Manager
19 from Anderson-Nichols, or he was until about two weeks
20 ago.
2i We also have with us Burk Ketchum who is Vice
22 President in charge of Planning for Anderson-Nichols,
23 and we have Joe Zeneski who is the Project Engineer with
24 Anderson-Nichols.
25. Before beginning our discussion tonight, I'd like
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1 to thank you very much for this facility, for providing
2 us with the necessary place to have this public hearing.
3 i The subject of tonight's hearing, again as you
4 { all know, is the supplement to the draft EIS on waste-
5 i water treatment and collection facilities for Tisbury,
6 West Tisbury and Oak Bluffs, Massachusetts. I was
7 thinking this afternoon that this might become an annual
8 event since we -- or at least my predecessors -- were
9 j here a year ago last October.
10 This supplement to the draft EIS is EPA's response
11 to the requirements of the National Environmental Policy
12 Act which directs federal agencies such as EPA to pre-
13 pare Environmental Impact statements prior to commencing
14 any federal action which may have a significant impact
15 on the environment.
16 More specifically, this supplement to the draft
17 EIS was prepared to respond to the following issues:
18 In November, 1977, last November, EPA Headquarters issued
19 (T) a policy memorandum on land application of municipal
20 waste water which required that the _agency___cqnsider less
21 than secondary treatment prior to a land discharge,
22 so that was something that we had to reconsider after
23 our draft Environmental Impact statement had come out.
Also, EPA received very significant comments from
25 the local agencies regarding the projected wastewater
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1 flows and deliniation of the wastewater collection servic
2 area. The draft EIS published in October of 1977 did
3 not recommend a specific alternative for treatment.
4 It evaluated several alternatives without recommending
5 a proposed action.
6 The supplement contains a recommendation. It is
7 EPA's conclusion as to the most cost effective and
8 environmentally acceptable solution for Tisbury. The
9 supplement to the draft EIS was made available to the
10 public on September 5th and was filed officially with
11 the Council on Environmental Quality on September 8th,
12 1978. The forty-five day comment period on the supple-
13 ment draft impact statement ends October 30th, 1978,
!4 and the record of this hearing will be kept open until
15 that date to receive statements from anyone who cares
16 to make them.
17 Copies of the draft supplement were mailed to
18 everyone that we thought would be interested. Additional
19 copies are available at the Board of Health and the
20 Environmental Protection Agency Office in Boston. It
21 looks like that -- that's what it looks like.
22 Out agenda for this evening is to ask Peter Murphy
23 of Anderson-Nichols to summarize for us the principal
24 conclusions of the draft supplement. I will then ask
25 any state or local elected officials who care to speak
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1 to do so and then we'll move on to public comments.
2 To help the stenographer, I would ask that you give
3 your name before you make your statement when you come
4 up to the microphone.
5 i We are going to try tonight to answer any question:
6 | y°u have nere and now. Any questions that we can't
7 | answer tonight will be answered in the final Environmenta
8 Impact statement. Also, Bob or some of the other people
i
9 i here with me might want to ask you a question to get a
10 clarification of some comment you're making. I'm looking
11 forward to this and I thank you very much for coming, and
12 now I'd like to ask Peter Murphy to summarize for us
13 the conclusions of the supplemental draft EIS.
14 MR. MURPHY. Thank you. From a group of viable
15 alternatives presented to you in the draft Environmental
16 Impact Statement, the Environmental Protection Agency
17 has, with your assistance, selected a recommended course
18 of action. This course of action consists of a limited
19 three-phase wastewater collection system in Tisbury,
20 and a wastewater and night soil treatment facility to
2i be situated at a location referred to as site one in
22 the draft Environmental Impact Statement.
23 By selecting a course of action, EPA does not
24 dictate to the municipality which project may or may not
25 be constructed. Rather the decision of EPA is to select
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1 from several viable alternatives the most environmentally
2 sound and cost effective alternative which will be
3 eligible for federal funding.
4 Federal funding eligibility will extend to waste-
5 water collection and treatment facilities, night soil
6 facilities, and individual or grouped individual waste-
7 water disposal systems. In selecting a course of action
3 which is most appropriate to a small community, EPA
9 calls for the aggressive application of non-structural
10 measures to optimize the performance of septic systems
•)•! and an absolute minimum reliance on costly hardware.
12 The supplement to the draft Environmental Impact
13 Statement describes how EPA arrived at its recommended
14 course of action. It begins with a premise that present
1g wastewater disposal practices are unacceptable. At a
16 minimum it sees the necessity of providing safe and
17 sanitary night soil disposal.
18 It also evaluates the need for wastewater collection
19 facilities in Tisbury to alleviate existing adverse
20 public health and sanitary conditions and to protect
21 against future water quality degradation.
22 The need for collection facilities was determined
23 from two important sources. The water quality and
24 sanitary information compiled in the draft Environmental
25 Impact Statement, and the survey of sanitary conditions
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1 in Tisbury performed by the Martha's Vineyard Water
2 Quality Program.
3 j EPA determines that an area needs wastewater
4 , collection facilities when it is proven that there is
5 ; no feasible alternative, such as facilitating the opera-
6 ! tion septic systems. The draft Environmental Impact
7 | Statement concluded that a need for collection facilities
8 was established in this area of Tisbury now being out-
9 j lined. The implications of this conclusion were that
10 there were no feasible alternatives to the construction
11 of collection facilities in the area.
12 Last November, after the draft EIS had been
13 released, the Martha's Vineyard Water Quality Program
14 understood a survey in sanitary conditions in Central
)5 Tisbury. This survey, which involved house and business
16 unit interviews, went far beyond the normal EIS scope
17 of work.
18 It proved that the need for collection facilities
19 is limited to a smaller area of Central Tisbury, also
20 being outlined. This is where immediate phase one
21 construction is being recommended.
22 Future collection needs are addressed in the
23 supplement. The construction of a phase two collection
24 system should be initiated in the future not at the
25 direction of EPA, but as the Town sees fit. The limits
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1 of the phase two collection area are the same as the
2 recommended collection area in the draft EIS.
3 A phase three collection area is also planned
4 which coincides with the collection area recommended in
5 the facilities planned.
6 Let's outline the phase two collection area and
7 the phase three. Okay, this is the phase two collection
8 area-, and this is the phase three collection area.
9 (Indicating.)
10 With a reasonable effort to maximize the perform-
11 ance of septic systems, phase three will probably never
12 be needed. However, all facilities are to be designed
13 to accommodate or at least to be expandible to accom-
14 modate flows from phase three.
15 The draft EIS presented two viable siting options
16 for the Tisbury wastewater and septige treatment plant.
17 This are shown as site one and three.
18 Site one is now being recommended by EPA. Its
19 advantages over site three are several. By being
20 situated closer to the collection area, force main
2i length and cost will be reduced. Pumping costs will
22 also be less. Capital and operating costs will be
23 less for site one because a lesser level of treatment
24 is required.
25 Site three was the potential of contaminating
-------
1 ground water resources which are important to Oak Bluffs
2 water supply. An advance level of wastewater treatment,
3 | which is expensive to build and operate, is necessary to
4 avoid ground water contamination. The extra cost
5 | associated with site three makes site one more advan-
6 tageous.
7 EPA recognizes the community's concerns about the
8 impacts of the treatment facility on nearby residential
9 areas. Site one is situated in closer proximity to
10 residential areas than site three. The environmental
11 evaluation of site one focused on water quality concerns,
12 possible odor impacts, and aesthetic effects. The
13 evaluation was based on many years of experience in
14 observing the operation of facilities of the proposed
15 type.
16 It is the conclusion of EPA that a treatment
17 facility on site one will not cause adverse water quality
18 impacts, adverse odor conditions or unsightly conditions.
19 The total estimated cost of the phase one project
20 is approximately 1.8 million dollars. Federal and state
21 funds will absorb 1.3 million dollars of the total.
22 The balance of 500 thousand dollars will be Tisbury's
23 cost. A detailed breakdown of these costs and the annual
24 charges to a typical household are summarized in tables
25 51 and 52 of the supplement.
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1 Depending on the method of allocating costs
2 between users and the taxpayers in general, the annual
3 charge to a typical sewered household would range from
4 $170 to $220, and the annual cost of a typical unsewered
5 household would range from $6 to $11 per year. The
6 recommended course of action is response to the majority
7 of citizens that will continue to rely upon septic
8 systems.
9 The supplement to the draft EIS describes non-
10 structural measures to optimize the performance of septic
n systems and details the application of these on Martha's
12 Vineyard. It recommends a rigorous application of non-
13 structural measures particularly in unsewered portions
14 of Tisbury Center. The recommended course of action
15 calls for treatment of night soil in the wastewater
16 treatment facility and composting of the night soil and
17 sledge by-product.
18 The facility will be capable of handling all of
19 Tisbury's and West Tisbury's night soil. This will
20 eliminate the present unacceptable night soil disposal
21 practices. Oak Bluffs will be able to treat its own
22 night soil. Tisbury's wastewater and night soil treat-
23 ment facility will produce a composted material useful
24 to agriculture which will help minimize reliance on
25 petro-chemical fertilizers imported to the Island.
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1 Before concluding, it would be well to describe
2 the options which are open to Tisbury beyond the recom-
3 j mendations of the EIS.
4 ; First, EPA re-emphasizes that the town can choose
5 | to restrict the collection system to phase one without
6 ever building phases two or three provided that non-
7 structural measures prove to be effective.
8 Second, variations in the delineation of phase one
9 will be permitted, since variations could constitute
10 inclusions and exclusions based on future detailed
11 determinations.
12 Third, in recognition of advanced and progressive
13 technologies EPA will reconsider its elimination of
14 site three if it can be proved that a new treatment
15 technology would be environmentally sound and the total
16 cost -- excuse me - - and the total system more cost
17 effective than site one recommendation.
18 Fourth, the town may take any other reasonable
19 alternative without federal funding.
20 EPA will evaluate the testimony of this public
21 hearing, will respond to all comments on the draft EIS,
22 and supplement to the draft EIS, and will then finalize
23 its recommendations in the final EIS.
jne closing dates for receiving any written comment
25 is October 30, 1978. Thank you.
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1 MS. HANMER. Do we have any state or local elected
2 officials who would care to make a statement at this
3 time?
4 Okay then, we will receive comment from those of
5 you here who would care to make one.
6 MR. WILCOX. I'm Bill Wilcox from the Martha's
7 Vineyard Commission Staff. I'd like to read a letter
8 addressed to the EPA Environmental Impact and Economic
9 Impact Office, dated October 5.
10 This letter and its contents were adopted at a
11 Commission meeting on October 5th:
12 "Dear Sirs: The Martha's Vineyard Commission
13 requests that the following comments be entered into
14 the public record regarding the "Supplement to Draft
15 Environmental Impact Statement - Waste-Water Collection
16 and Treatment Facilities - Tisbury, West Tisbury, and
17 Oak Bluffs, Massachusetts".
18 First, we would like to comment on the Supplement
19 format. The selection of a single solution for detailed
20 discussion (the limited sewer service area option) and
21 the relegation of the maintenance program to the appendix
22 does not -- "
23 MS. HANMER. Excuse me. You can't hear him?
24 I was afraid of that. Could you stand a little closer?
25 MR. WILCOX. Sure. Okay.
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1 "First, we would like to comment on the Supplement
2 format. The selection of a single solution for detailed
3 j discussion (the limited sewer service area option)
4 ! and the relegation of the maintenance program to the
5 | appendix does not allow easy comparision of the two
6 j alternatives. By discussing the sewage system maintenanc
7 option in a "response to comment" fashion, the overall
8 program concept is disjointed and not presented in a
9 manner which makes that option clear. While we appre-
10 ciate the Supplement making a definite recommendation,
11 we feel that the considerations involved in eliminating
12 the maintenance program must be more fully explained.
13 Second, the Commission feels that the maintenance
14 program alternative has not been effectively eliminated
15 as an option. We feel that the data collected in the
16 door to door survey conducted by the Planning and
17 Health Boards and the Commission could have been more
18 effectively used to either rule out or clearly spell out
19 the consequences of a maintenance program solution. The
20 voters of the town must be educated to the possibility
21 of a solution short of sewering and the effects of that
22 choice on the town.
23 Third, the Commission recognizes that while site 1
24 is most attractive from the cost and pollution standpoint:
25 there is some strong opposition to the siting of a
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1 treatment facility in the proposed area.
2 Finally, we would like to offer the following
3 detailed comments by page.
4 Page 3. The supplement quotes a Draft 208 Water
5 Quality Report which has been substantially revised
6 At the time of writing of the Draft, from the data
7 available, a sewer system was recommended. Since
8 then additional information lead to the following
9 recommendation in the Final Report:
10 "Avoid need for sewerage through rehabilitation
ij or replacement of failing septic systems."
12 Page 6. The ruling out of alternative 2 (the
13 maintenance program solution) was completed by an
14 unidentified screening process. The presentation
15 of this process, its conclusions and considerations
16 is of vital importance.
-7 Page 8. (last paragraph) The Survey and Report
lg on the door to door survey of sewerage needs recom-
1Q mended a maintenance program as the highest
2Q priority. A reduced sewage collection system was
the second priority.
22 Figure 1, Page 11. The Survey and Report also
23 recommended the inclusion of the residential area
24 along Lagoon Pond Road in a sewage collection system,
2g if one is selected.
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I
1 paSe 15- (third paragraph) While the Survey and
2 Report does conclude "... that wastewate collection
3 | facilities are feasible in this area.", it also
4 ' recommends a maintenance and rehabilitation program
5 | as a first priority. The statement in this para-
6 graph is taken out of context.
7 Page 15. Flows from some commerical establishments
8 j range up to an average of 3,000 gallons per day
9 j and are probably much higher during the peak summer
10 months.
11 While the Martha's Vineyard Commission feels that
12 a sewer system can be an important addition to the town,
13 we feel that it is the responsibility of the EPA to
14 carefully explore the benefits and consequences of all
15 options. The staff of the Commission will be glad to
16 discuss these comments in detail prior to the issuance
17 of the Final EIS. We feel that an adequate response
18 will assist the local officials in guiding their town
19 to the best solution."
20 Maybe I could just offer a few quick comments.
21 I just want to make sure that it's clear that the Com-
22 mission really -- and the staff, I guess -- really doesn'
23 feel that a maintenance program is what has to be done.
24 i think what we really would like to see is the main-
25 tenance program explored in sufficient detail so that the
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1 town, come town meeting time, would be able to see very
2 clearly what the consequences of taking that choice would
3 be, and that they will understand the ramifications as
4 far as Board of Health responsibilities, as far as impact
5 on future growth and use of the downtown area and that
6 sort of thing.
7 I would like to see them a little bit more clearly
8 spelled out in the final.
9 MS. HANMER. Do any of you have any questions or
10 comments that you want to make?
n MR. MENDOZA. Bill, I have a copy of the final
12 Environmental Impact Statement on the 208 plan.
13 MR. WILCOX. Yes.
14 MR. MENDOZA. And on page 156 of that document
)5 there are two recommendations essentially for Tisbury.
16 One recommendation is what you had suggested in
17 terms of rehabilitation. The other recommendation and
18 I quote:
19 "States to provide a limited collection system
20 to collection sewerage and transport it to a small
21 treatment plant. For a thorough discussion of survey
22 techniques and their results, see survey and report
23 wastewater and sewerage disposal in Tisbury."
24 The question I have, Bill, is I'm not really sure
25 I understand what recommendation the 208 agency is
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suggesting in terms of implementation for Tisbury.
2 Could you elaborate on that?
!
3 MR. WILCOX. Yes. I would say that at the time of
4 issuing the final 208 statement, we felt that every effor
i
5 should be made to minimize the size of the serviced area
6 j necessary to take care of the town. At that time we
7 felt that a maintenance program and the small service
8 area sewer system were -- had equal potential in terms
9 I of remedying the problems that existed in the town.
10 I think that it's really a political decision for
n the town to make, and we try to hedge a little bit on
12 that, quite frankly. I think either option is reasonable
13 but I think the town really has to understand the con-
14 sequences of both and the effects of both.
15 MR. MENDOZA. I have another question. You sug-
16 gested that the supplemental draft Environmental Impact
17 Statement was fragmented in terms of its approach to
18 recommendations of both on-site rehabilitation or main-
19 tenance controls and a limited collection system.
2Q What suggestions do you have for tying the two
21 elements together?
22 MR. WILCOX. I would like to see something in the
23 final which would describe in some detail what kind of
24 a program the town could put together. Who would
25 participate? What kind of cost; what kind of people
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1 would be necessary to carry out the inspections necessar)
2 to have a maintenance program be effective?
3 What kind of solutions might be tried in different
4 areas in the downtown area to remedy the existing prob-
5 lems? I think it's important to present it in the
6 fashion that is not sort of -- that's down to earth,
7 that is meaningful to the town. Who would be involved?
8 Where would the money come from to implement it? What
9 options are available to do that? What types of solu-
10 tions might be tried?
11 MR. MENDOZA. You're suggesting that the draft
12 Environmental Impact Statement design an operation and
13 maintenance program specifically for Tisbury, is what
14 you're asking.
15 MR. WILCOX. Well, that would be ideal, but I
16 don't think we can expect you to go that far.
17 MR. MENDOZA. i'm trying to, in my own mind,
18 differentiate between how far the impact statement should
19 go versus how far the 208 program should go in terms
20 of these types of recommendations.
21 MR. WILCOX. Well, as you know, the 208 program
22 has now in process as our third year funding program,
23 an engineer whose primary goal is to work with the
24 towns to develop a maintenance program.
25 But I think it's not going to be developed before
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1 town meeting time, I have a feeling, and I think whatever
2 the final can do -- the final EIS can do -- to just
3 j describe that process in an understandable fashion, in
4 | a meaningful fashion, would really help in either select-
5 I in§ it or eliminating it at the town meeting.
6 j Ms- HANMER. When is the town meeting going to take
7 | place? Can somebody tell me?
8 MR. WILCOX. The second week in May.
9 | MR- MURPHY. I would like to re-emphasize that
10 what the supplement to the draft EIS is doing in making
H a recommendation is simply to establish the cost effec-
12 tiveness and the environmental soundness; that is, the
13 feasibility of constructing a limited wastewater col-
14 lection system and showing that this is more feasible
15 than depending upon on-site systems and doing it to the
16 extent that the federal government is satisfied and can
17 determine its grant eligibility.
18 As far as the implementation of the project is
19 concerned, this of course is a town meeting matter.
20 As far as the supplement to the draft EIS appearin
to be fragmented, some of that is unavoidable. We had
22 to aim at rather disparate concerns. One was an evalua-
23 tion Of less than secondary treatment. Another was the
inclusion of additional material on needs. Still another
was the consideration of questions from people that were
25
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1 transmitted to EPA that could not be adequately dealt
2 with in the final EIS. So it's not a document that
3 could be perfectly tied together as some may be.
4 MS. HANMER. I think it's safe to say on that
5 last request for information that we will go as far as
6 we can in the Environmental Impact Statement with the
7 information that we're going to have. We're going to
8 try to get the final Environmental Impact Statement out
9 in plenty of time, I'm hoping around the first of the year
10 Anyone else like to make a comment?
11 I guess we're going to talk tonight. That is not
12 an amplifying microphone, so you'll just have to speak
13 up.
14 MR. JEANS. Brian Jeans, State Division of Water
15 Pollution Control.
16 In the recommendations, as far as rehabilitation
17 of on-lot systems, it's indicated in here that some of
18 them will be -- four or so -- could be taken care of
19 by more or less conventional on-lot means.
20 In some of the other areas, though, we're getting
21 into recommendations which -- and I've worked quite
22 closely with Paul Anderson in the Lakeville Office over
23 the years, and I know as far as a mound system, although
24 it is approvable, you know, the wide spread utilization
25 of it to solve problems is not looked upon all that
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1 favorably. One question specifically -- Are the soils
2 adequate in the areas where a mound system is being
3 i recommended?
4 | MR- WILCOX. The soils in the area are primarily
5 beach deposits and fill material, so they have a very
6 high perk rate. The primary problem is the high water
7 table and after you get down about four feet or so
8 you run into peat and that can be a problem. But I would
9 j think that if you mounded the system up, there wouldn't
10 be -- I don't think there would be very much difference
11 in perk rate between the mound, the fill material brought
12 in for the mound and the existing old fill material that':
13 there. I don't think you'd have trouble with breakout on
14 the sides.
15 MR. JEANS. In looking at these various rehabili-
16 tation techniques, did you have a chance to go over some
17 of these mounding alternatives, et cetera, with the
18 Lakeville Office?
19 MR. WILCOX. No, we didn't. What we tried to do
in the survey was to look at the lot size and, as much
as possible, the configuration of the lot, where problems
existed to figure out if there was a solution short of
23 sewering, and it's my understanding that if the town
24 developed a program which they would sponsor, they really
25 wouldn't have to meet Title 5 requirements. I don't
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1 know whether I've got that exactly right or not.
2 MR. JEANS. As far as Title 5, I'm not within
3 DEQE of the Regional Office, et cetera. I do not
4 administer Title 5.
5 Let's be honest. We don't want solutions that
6 are going to take us through a year, two years, five
7 years -- We want a long range solution. We want to
8 be able to come out and have recommendations that the
9 town can live with, we can live with, and are going to
10 be implementable, are going to be cost effective, some-
n thing that -- you know, I don't want to come back in
12 five years and, say, have the breakout of mounds systems,
13 et cetera, that's why I'm very concerned with this
14 mounding aspect because it is used very cautiously.
]5 It's only used in situations particularly where
16 you have good soils, you have adequate land area avail-
17 able, it's just that the ground water table is high.
18 If there are any impervial soils down below, then those
19 have to be excavated out. Okay, that's enough on
20 mounds.
21 One other question I have -- What about the lots
22 which cannot be rectified or it indicated that there
23 are some problems there?
24 MR. WILCOX. Those seven or so lots, I think the
25 only option would be to either install a holding tank
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1 or continue with the existing system and let it turn into
2 a holding tank and pump them very frequently. I think
3 I on some of them if they did install holding tanks there,
4 j we looked at them and there would be somewhere between
5 | forty and fifty pumpings a month during the summer and
6 | these kinds of things have to be pointed out.
7 If we are going to continue with our existing
8 | water use levels and we're going to try and install hold-
9 i ing tanks for some of the bigger water users, it's going
10 to create problems in terms of just the cesspool pumper
11 truck traffic in the downtown area. Those are the kind
12 of things that I think would be really helpful to the
13 town in selecting an alternative.
14 MR. JEANS. It's just that I'm very much concerned
15 as far as the recommendations on rehabilitation of
16 existing systems where we are cognizant of severe con-
17 straints in terms of area availability, soils, high
18 ground water, very congested areas -- I'm just thinking
19 in my own mind -- could we be having difficulties if
20 some of these were implemented a relatively short distanc
21 down the road, timewise, and if any coordination.had
taken place before these recommendations were made
23 with the State Department of Public Health of DEQE.
24 I think it's very important.
25 MR. WILCOX. I would agree with you. In the
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1 newsletter that you have in front of you, I don't think
2 that we're trying to advocate a maintenance program.
3 That was intended to just get opinions --
4 MR. JEANS. But my own opinion, not division
5 opinion, you know, I read it as this appears the way to
6 go, it's listed as option one. You get into the green
7 sheet --
8 MR. WILCOX. Well, the facts really indicate that
9 there's a limited number of systems that have problems.
10 There's twenty-seven out of one hundred sixty-one that
1, we surveyed and that's --
12 MR. JEANS. What percentage of the flow does that
13 represent in the problem area? Isn't it about seventy-
14 five percent?
MR. WILCOX. That's a good question. I think --
I O
MR. JEANS. I think it's a significant portion
17 of the flow.
18 MR. WILCOX. I think it probably is, too.
19 MR. JEANS. I would like to make one general
20 comment. EPA has included for eligibility, rehabilita-
21 tion of on-lot systems. There are some provisos. It has
22 to meet certain requirements as far as being consistent
23 with state codes, et cetera. It is considered eligible.
24 Now there are a lot of things that are considered
25 eligible within the EPA program, but one specific thing
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1 that comes to mind is that of lateral sewers.
2 Now, although they are eligible, they do not
3 I have sufficiently high priority to be able to reach them
4 | for funding. Although your referencing at the bottom
5 ! on the Newsletter No. 2 assuming costs for rehabilitation
6 | of those systems, this is not hard and fast, okay?
1 | We are working in this direction. We have ruled -- are
8 passing on - - We've got a limited amount of money, and
9 | we have to prioritize the various elements of a water
10 pollution control program. I know there's a lot of
11 institutional arrangements and difficulties as far as
12 funding on-lot systems. I just don't think we could take
13 that as gospel, because at this point in time we don't
14 have everything in place and it is questionable how long
,5 down the road it might be before we could participate.
16 MR. WILCOX. We ought to let him write a section
17 of the final report. That's the kind of information
18 that I think would really help the town make a decision.
19 If it's questionable as to whether or not the
20 maintenance program would be fundable and if it's
21 questionable whether or not it would be fundable five
22 years from now, I think that's a really important con-
23 sideration.
24 MR. JEANS. I'm not throwing a damper. I mean, this
25 whole 92500 was modified under 95217 last December.
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1 There were a lot of amendments that came out. EPA is
2 in the process right now of writing regulations with
3 which -- well, actually, they've been more or less
4 finalized -- with which to implement the intent of that
5 legislation.
6 Right now the states are trying to gear their
7 program to modify our program sufficiently so that we're
B both in a parallel activity.
9 I'm not throwing a damper as far as the division
10 not participating in the 75 percent rehabilitation
n program. What I am saying is that there are some legal
12 and institutional problems that have to be overcome and
13 that the division is trying to keep its mind open as far
14 as being compatible with EPA's program, but I don't think
15 you can take it as a given fact that there will be
16 participation. Thank you, Bill.
17 MR. PINAULT. I would like to make some comments
18 in general. Brian and I both cover the southeastern
19 portion of Massachusetts. Brian at the state level, and
20 myself at the federal level, and we've run up against
21 this problem many times in other communities where we've
22 discussed this aspect with DEQE, with towns that want
23 to go to rehabilitating on-site systems.
24 In all cases the indications are that there would
25 be no waivers from Title 5 and that any rehabilitation
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must be in conformance with Title 5.
2 Just to give you an example. A typical home which
1
3 I has a good perk rate but the water table is less than
4 four feet below the surface, the only thing mounding does
5 j is raise the bottom of the system up to minimum of four
6 feet above the natural ground water level. In that case,
7 like I say if you did have good perking soil which Bill
8 says you do in this area -- for a typical home with
9 i 300 gallons a day, you might need 300 square feet of
10 leaching area which would be about approximately a 20 foo
H by 20 foot area.
12 Title 5 says that when you get into a mounding
13 condition, you must fill 25 feet around that in all
14 directions. So, therefore, you would have an area of
15 approximately 70 feet by 70 feet and that's for a typical
16 single family home. I know in the downtown area they
17 have a lot of those systems and are for a large water
18 user and that the areas will have to be much larger.
19 I also know that the amount of land available on
20 these sites is relatively small so I don't know which
21 ones -- you're questioning about mounding, but I would
22 have to go through each and every one of them and look
23 at that as far as land size, amount of flow coming from
24 it, and applied that to Title 5. But I just feel from
25 what I know about the area in the last couple of years,
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
that most of them could not satisfy Title 5.
Even if funds are available at the state and local
level to rehabilitate septic systems, they must meet
all federal and state regulations so, therefore, if you
couldn't satisfy Title 5 even if funds were available,
we
would not be able to participate in the cost for that.
That's one point I'd like to make.
The second point is -- Bill said that the EIS
should expand more on the septic system maintenance
program. The EIS has recommended a very limited sewer
system. Phase one is about thirty-odd connections,
phase two is up to 370, but that still leaves a large
portion of the Town of Tisbury on on-site systems. The
EIS goes on to recommend that in hand with this that
the town must implement a septic tank maintenance progran
In Appendix B, I think it's pages B17 through
B20, we summarize in a general way, and we extract from
the MAPC 208 study which was typical of different options
that a town could implement to develop a septic system
maintenance program. I think at the time we didn't
want to be too specific. We felt that it was a local
home-rule type decision. We tried to give you three
or four options -- that you could go out and contract
with the local company where they could do the inspect-
ions for you and do the pumpings for you and you could
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1 do it all on a local level with municipal people or a
2 combination of the two. It goes on and on. So I think
3 i what Bill's asking for is probably a more specific type
4 of thing and when we approached it, we wanted it to be
5 | general. If we can be of any help on -- say, for instanc
6 | a town would like to pursue one of the three alternatives
7 we point out for septic system maintenance program.
8 We'd all be glad to sit down with you to try to get into
9 j more detail on that, but at the time we issued the
10 supplement, we didn't feel we should do that, that we
n could be criticized for taking one of the three alter-
12 natives and going along with that when the local people
13 might feel, for instance, that they should do with town
14 forces instead of contracting it out to a private company
15 So, with that, we will be glad to work with you
16 in the next month or so in wrapping up this EIS to help
17 you define one of those alternatives or just further
18 discussing the ones that we have pointed out in the
19 draft. Thank you.
20 MR. MURPHY. We have really tried to delineate the
2i phase one service area to be limited to only those system
22 that absolutely require sewers. We firmly believe that
23 we have taken care of every unit, be it residence or
24 business that could be rehabilitated in accordance with
25 Title 5, but we feel that that's the key and probably
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1 the difference between what appears to be the conclusion
2 of the 208 report and what we're recommending here, and
3 ; in accordance with regulations that I understand we have
4 i to live by, there's no other conclusion that we can make.
5 MS. HANMER. Looks like we're doing all the
6 statement-making.
7 Would anyone else like to make a comment or ask
8 some questions?
9 i MR. ALLEN. I would like to ask a question.
10 I certainly don't want to make a comment.
11 MS. HANMER. Okay. Would you give us your name?
12 MR. ALLEN. My name is John Allen. I just live her
13 As I understand it, and believe me I don't, we are
14 talking about two possibilities. A maintenance system
15 or a collection system, or possibly a combination of the
16 two. Is this correct?,
17 MS. HANMER. Essentially, yes.
18 MR. ALLEN. These are primarily to serve downtown
19 business establishments. Is that correct?
20 MR- MURPHY. More specifically, we're definitely
21 talking about a limited wastewater sewer system for the
22 core portion of the downtown. We're definitely talking
23 about on-site system maintenance not just for the down-
24 town problem area, but as it may apply to the town as
25 a whole.
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1 MR. ALLEN. All right. I understand.
2 MR. MURPHY. So we're definitely talking about
3 a combination of the two elements that you referenced.
4 MR. ALLEN. So, if I can use my own stupid terms,
5 we need a night soil treatment plant. Is that correct?
6 MR. MURPHY. Yes.
7 MR. ALLEN. All right. Now, to get back -- so we
8 need the night soil treatment plant for all of the
9 people of Tisbury. Basically speaking, you've got to
10 pump out your cesspool or your system every several
11 years, so that is a requirement. Not a requirement,
!2 but it's well advised.
13 Now, to get back down to the downtown area, I ask
14 if there may not be a third alternative, recognizing
15 that a night soil treatment is advisable.
16 Is it not a third alternative that the Board of
17 Health, selectmen, whoever it may fall to as being within
18 the purview of their authority and responsibility, that
19 they can go to these downtown businessmen,all of whom
20 are intelligent, making money, and say, Mr. Downtown
21 Businessman, you are in a position where the possibility
22 of your polluting is imminent, and you must, therefore,
23 clear up your own act, and you do that by whatever
24 system is approved by EPA and the state sanitary code,
25 and it will not then become something in which the
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taxpayers are involved or participating.
2 I think what I'm saying is why should a taxpayer,
3 | who will never be connected to a collection system, sub-
4 ! sidize a profit-making entrepreneur. Can that question
5 I be answered by EPA? Will the town have the authority
6 j to say that to an entrepreneur?
7 I MR. ZENESKI. My name is Joe Zeneski from Anderson-
8 Nichols. I think I can respond in part to that question
9 i by reviewing with you this table from the draft or the
10 supplement to the draft EIS.
n You'll notice here for phase one, which as Peter
12 pointed out, would cost about two million dollars total,
13 and the town's share would be some 500 thousand. We have
14 a number of alternatives here within the alternatives
presented in the table and they are portion of collection
16 system cost recovered through taxes. When you talk of
17 the question of tax subsidy to the businessman, this is
18 the meat issue here. How much of that will be paid for
19 by the taxpayer in general, and as a result, there are
20 different tax bills associated with each of those alter-
21 natives and they vary according to the percent of the
22 taxes taking on the total cost.
23 The point is then that this is the town's decision
24 to make. The town decides whether the businessman,
25 as you say, will pay for the entire project himself or
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1 if the town will subsidize him to a degree by perhaps
2 paying half of the cost or whether the town will take it
3 upon themselves to pay for the total cost.
4 It's not for EPA or Anderson-Nichols to say. It is
5 up to the town to make that decision.
6 MR. MURPHY. In answer to the first part of your
7 question, sir, yes, it is an alternative to pump each
8 of the systems in the downtown area on a. more frequent
9 basis in order to prevent against the future possibility
10 of water pollution.
H We have established that this is not a cost effec-
12 tive way of going about the problem, and that it would
13 be more feasible to build a collection system, and that
14 this would be a more efficient and cost effective way
15 of carrying the wastewater away, and also more environ-
16 mentally sound way of handling it as well.
17 MR. MENDOZA. I think in trying to respond to one
18 portion of your comment, I think we've taken a real
19 hard look as close as we possibly can in terms of what
20 can we do with those particular areas downtown that are
21 having problems. Can we, in fact, rehabilitate those
22 areas in that they meet Title 5 requirements, and this
23 is what we were talking about earlier.
24 If the Board of Health were to place responsibility
25 back on the businessman or the owner to correct his
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1 problem, what are his options? Can he, in fact, correct
2 the problem so that it is consistent with the Title 5
3 ! requirements? I think that is where we have a difficult
4 problem because of constraints with the lot sizes,
5 | density of the area, ground water problems, and some of
6 the other constraints that preclude on-site rehabilitatioi
7 or the use of on-site systems.
8 I think it's good to put the responsibility in a
9 j sense back on the businessman, but what alternatives does
10 he have? That's a question.
11 MR. PACHECO. My name is Edward Pacheco. I'm a
12 citizen in the Town of Tisbury, and I would just like to
13 make a comment in response to Peter Murphy's comment that
14 pumping was found not to be as cost effective as con-
15 struction of a wastewater treatment plant.
16 That was a decision that, by reading the supplement
17 has just been arbitrarily made. Nowhere in the supple-
18 ment or in the draft EIS were cost figures presented
19 in which the townspeople could make their own comparisons
20 of these systems.
21 Instead, we are just told that such a system is
22 not as cost effective, and this is also in regards ,to
23 what Bill Wilcox was saying that these kinds of cost
24 comparisons are things that the townspeople need in order
25 to make a decision for themselves, and to arbitrarily
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1 eliminate things without any rationale or any method that
2 we can also follow your same decision-making process
3 doesn't tell us anything. It just tells us what you
4 want us to believe and doesn't allow us to make decisions
5 for ourselves.
6 Until these things are presented in a readable
7 form where direct comparisons can be made, we're just
8 going to be as lost as we have been since the first draft
9 Environmental Impact Statement was written.
10 So if this can be somehow corrected in the final
11 EIS, it would be greatly appreciated. This has been
12 called for since some of the original workshops. They
13 were covered in one workshop, and a lot of people felt
14 that the draft supplement was going to clear up some of
^5 these questions and instead it seems to present more
15 problems and not answers or possible solutions.
17 MR. MURPHY. We have not provided all of the
18 figures, all of our calculations and worksheets in the
19 determination of cost effectiveness, and we don't think
20 that that's appropriate to do so. All of this infor-
21 mation is part of the public record and is available
22 for inspection.
23 In terms of comments that we received that the
24 document is not provided in a readable format that's
25 not specific enough for us to respond to. We've had it
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before on the draft EIS and we've prepared a supplement.
2 I don't find it to be a helpful comment personally be-
3 ! cause I just don't know an effective way of responding
4 to it in order to make the document more readable or
5 I more understandable so that you or anyone else could
6 differentiate between the two service area alternatives
7 in question.
8 MR. PACHECO. But that seems to be what the regu-
9 i lations require that you present all the alternatives
10 and allow the citizens to make their own decisions and
11 that you also can come up with a recommendation.
12 Right now we just can't do that.
13 MR. MENDOZA. Ed, I think we do have information
14 with respect to the costs on pumping. I do believe that
15 was taken into the consideration of the cost effective
16 analysis.
17 Joe, do you have any information offhand. If we
18 don't have it here tonight, I know we do have it in the
19 office.
20 MR. ZENESKI. I'll just check to see if it was
21 in the draft EIS or not. I can't say at this time.
22 MR. MENDOZA. Because we were talking about that
23 issue prior to the release of the supplement, and we
24 were very concerned in terms of the cost relationship
25 of the user fees for the people in the downtown area
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1 versus how much they are now paying with respect to the
2 pumping particularly in the summertime which is a key
3 point in the year.
4 But I will indicate to you now that that informa-
5 tion will be included. We do have it and I don't see
6 why it can't be included in the final impact statement.
7 MR. PACHECO. Even a simple footnote at the end
8 of that statement in the supplement referring to the
9 set of figures that you had collected would have been
10 more helpful.
11 MR. THOMAS. My name is Myron Thomas.
12 You speak of being cost effective. Cost effective
13 for whom? I mean, according to the figures you give us
14 your cheatest alternative is going to cost the town
15 $135,700 a year.
16 Right now as far as I know, we're not paying any-
17 thing for this collection system and the stuff is being
18 collected. When you say cost effective, do you mean
19 for the town, the citizens or the people that are having
20 their sewers pumped?
21 MS. HAMMER. The cost effectiveness requirement
22 relates to the participation of federal funding. One of
23 the alternatives that Peter mentioned that you have
24 available to you was to implement any system that seemed
25 reasonable without federal funding. We make our cost
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1 effectiveness evaluation based on the reasonable alter-
2 natives that will meet the state and federal requirements
3 j then we take what appears in the aggregate to be the most
4 cost effective solution and that is the one that we can
5 participate in as far as federal funding is concerned.
6 There are some exceptions to that based on the
7 severity of environmental impact or between one alter-
8 native and another or based on new requirements under
9 the law that would allow us to pay a certain premium for
10 innovative and alternative technologies, but by and large
11 the cost effectiveness analysis is simply tied to the
12 participation of federal funding.
13 Do you want to speak?
14 MR. NORTON. I'm Jim Norton. I'm a resident of
15 the Town of Tisbury.
16 I seem to be hearing, and I share this feeling
17 that -- from my neighbors and myself -- that if we could
18 get away with alternative 2, in other words, if it would
19 be possible to provide a night soil facility and to
20 service that, that we would not want to leave any stone
21 unturned to assure ourselves that that is the --is not
22 possible or is not effective for us to pursue, and ,1
23 think, as I say, I share that concern, but my main con-
24 cern and I think the thing that has brought me to these
25 hearings and to some very early meetings is the concern
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1 with ground water and I think that I do want to express
2 some questions and concerns in this area.
3 Let me simply quote by way of -- as background
4 to this -- two sentences from a report on an international
5 conference on water resources that was held two years
6 ago. The statement says that the cost -- this was a
7 conclusion that was arrived at at that particular con-
8 ference -- the cost of effectively solving the world's
9 fresh water supply problems from now until 1990 is
10 estimated at about 80 billion dollars.
11 It goes on to say -- no one can say realistically
12 where this money is going to come from.
13 Water is a valuable resource for us and as we
14 don't have access to any handy icebergs, I think that
15 we are going to have to spend a good deal of time just
16 seeing what the impact, what the effect of anything
17 we do is on our ground water.
18 In light of that, I would like to raise a question
19 Specifically, this is just by way of gathering informa-
20 tion. It's on page 189 of the draft impact statement.
21 I have a question about site 2.
22 The question is why hasn't an alternative which
23 would call for the removal of the Tisbury public water
24 supply wells to site 3 or any other spot, for that
25 matter, and development of a wastewater treatment
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1 facility on the sanitary land-fill site been addressed?
2 It's the present dump.
3 Now, my questions with the response, this alter-
4 native is evaluated in the Environmental Impact Statement
5 | it is not recommended because land application of treated
6 wastewater affluent would result in the probable con-
7 tamination of private water supplies. In addition,
8 due to the complexity of the ground water hydrologic
9 environment, Environmental Impact's could not be stated
10 with confidence.
11 Now, my question -- it's really a kind of series,
12 that it's my understanding in reading both the supplement
13 and the original draft that there is going to be an
14 adverse effect on the ground water no matter where a
15 sanitary or a wastewater treatment facility is put, and
16 the question is -- Who or where is public water supply
17 going to be provided and able to overcome that?
18 In other words, in site 1 that is made acceptable
19 because the potential wells in that area or the private
20 water supplies in that area will or are planned to be
21 put onto a public system. Presumably, those in the area
22 that are still in private wells in the area of the dump,
23 it being the closest to the water tower, would presumably
24 also be cost effectively put on the public water supply
25 system.
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1 The same is true of the site 3 that there is
2 potential contamination for any development in that area,
3 and therefore, that is not acceptable for a primary or
4 a secondary treatment.
5 If that is correct, plus the long range and fairly
6 well documented impact of any wastewater treatment
7 facility on site 3 for the water sheds primarily of the
8 lagoon but also of Tashmoo i-n terms of the ground
9 water flow at that particular time, would an advanced
10 treatment facility at site 2 overcome or make that as
^ acceptable as site 3 would be acceptable in terms of its
12 environmental impact -- certainly it would be much more
13 cost effective and would the problem of site 2 in that
14 sense be overcome by replacing the same requirement on
15 it as on site 3?
16 The question, I guess, that precedes that is where
17 in the top of our water table, is the top of our water
18 table closer to site 2 or site 3, and the basic assumptioh
19 or basic question behind all of that is why are we talkin
20 about putting any adverse polluted land treated material
21 into the top of our water table or at the highest point
22 of our ground water rather than at some lower point?
23 MR. MURPHY. Let me see if I can remember them all.
24 First of all, we say that hydrologic impacts on site
25 or beneath site 2 cannot be stated with certainty because
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1 from our examination of the hydro-geology, we find that
2 we cannot define the direction of slope of the water
3 | table with as great a certainty as site 1 or site 3.
4 Now, concerning your question of whether we could
5 i implement advanced wastewater treatment on site 2 as
6 well as site 3, probably yes. I cannot say with cer-
7 tainty and I do not remember -- Excuse me.
8 I'm saying probably now. I can't say with cer-
9 tainty how far beneath the surface the water table is
10 beneath site 2. I've got it in my records, and it is
n not in my head, but I do think that that depth is fairly
12 substantial.
13 We did not evaluate the environmental impacts in
14 detail as we did with site 3, but in comparison to the
15 recommended alternative where a lesser degree of treatmen
16 is required, it's obviously more cost effective to
17 implement the lesser degree of treatment provided that
18 it will not result in environmental harm, and what we're
19 saying with a fair amount of certainty now is that if
20 we input wastewater onto site 1, then it will flow in
21 the direction of Lake Tashmoo by the time it reaches the
22 interface and actually affects Lake Tashmoo , it wi.ll be
23 at a concentration so low that we couldn't measure it
24 with our laboratories instruments, and we studied the
25 oceanographic regime of Lake Tashmoo and we find that
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1 the further mixing that would occur would certainly mean
2 that there would be no adverse impact.
3 In terms of whether we have any business accepting
4 a pollutant into the environment and then assimilating
5 it, such as we're doing at site 1, you may call that
6 a legitimate use of the environment or not and that's
7 a value judgment.
8 What we're saying is that we are not contaminating
9 any ground water resource that is presently or may in
10 the future -- that's the key phrase, may in the future --
11 may one day be used as a public or private water supply.
12 Now, did I miss anything, Jim?
13 MR. NORTON. Well, my mind was actually following
14 along with this idea of in the future and of the poten-
15 tial. One of the problems I see us caught in -- and just
16 sort of make this as on the side -- I do serve on the
17 school committee, and I had a conversation with a col-
18 league of mine from Edgartown on the school committee,
19 who was expressing some relief --a strange kind of
20 relief to me, I guess -- that thank goodness the heat's
21 off the school now because the sewer system costs more
22 than the school does, and it's taking up a larger portion
23 of the real estate tax.
24 I would not hope for that for Tisbury. I think
25 what I see happening is that if we do have the kind of
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1 cost commitment that what we are talking about requires,
2 we are going to have to develop all of the square inches
3 ! in the Town of Tisbury in order to get the tax base to
4 ! pay for it, and that no matter where we put it and
5 | particularly in that part of town that is going to have
6 | to have some kind of use in order to provide the income
7 that we need in order to pay for the system we have, and
8 I think Edgartown's example is a very timely and appro-
9 priate one here.
10 Does that make sense?
n MR. MURPHY. Well, do you mean that by implementing
12 a facility on site 1, we would preclude the possibility
13 for development downgrading it?
14 MR. NORTON. No. I'm saying that by putting it,
15 well really, in any clear potentially developal space
16 in town, that we're going to need that space as developed
17 in order to pay for it.
18 MR. MURPHY. That's an irretrievable commitment
19 of a resource.
20 MR. NORTON. Right, that's if we can avoid that,
21 if we can anticipate that, which is again I guess why
22 I think that alternative two is probably the one that
23 we will be nagging at and pulling at as long as we
24 possibly can, that any trace of suspicion that that might
25 work is going to continue to happen.
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1 It's my hope that when we suddenly decide that
2 it's not going to happen that we don't turn around at
3 that point and do something that is going to not go to
4 site 1 but go somewhere else which is going to adversely
5 effect our drinking water.
6 MS. HANMER. Would anyone else care to make a
7 statement or ask some questions?
8 MR. PACHECO. I stated earlier that my name was
9 Edward Pacheco. I'm a citizen of the Town of Tisbury.
10 The statement relating to the draft supplement
H EIS -- The draft supplement EIS was prepared and cir-
12 culated for two basic reasons.
13 One, federal policy now requires that additional
14 treatment alternatives be considered and evaluated and,
15 two, significant comments on the draft EIS were raised
16 at the October 1 Workshop, October 26th Hearing, and
17 within the written comments on the draft EIS.
18 These comments were so extensive that "EPA's
19 response to these comments should be subject to public
20 review and thus cannot be part of a final EIS." However,
21 within the summary, the draft summary states, "The
22 supplement responds to comments by the Martha's Vineyard
23 Water Quality Advisory Committee. All other comments
24 will be addressed in the final EIS."
25 Direct contradiction between page 1 and page 3
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1 of the draft supplement. This is just one example of the
2 many contradictions and inconsistencies with federal and
3 ! state law that the draft supplement contains as well as
4 the draft Environmental Impact Statement contained
5 ! initially.
6 The purpose of the draft supplement was to respond
7 to the comments, questions, and differences of opinion
8 between citizens and the EPA and to attempt to clear
9 them up. However, the draft supplement raises so many
10 more questions that it is almost necessary to write
11 a draft supplement supplement to answer these new
12 questions raised as well as finally answer the original
13 questions left unanswered from the workshops, the public
14 hearings and the written comments.
15 The draft supplement continues to recommend sewerinj
16 although significantly scaled down from Tighe and Bond's
17 original engineering Rube Goldberg of an environ-
18 mental unsoundness. The attitude of EPA and Anderson-
19 Nichols has been that citizens cannot make decisions
20 for themselves on any issue with permanent ramifications
21 on the environment and tax rate of Tisbury and the
22 Vineyard as a whole.
23 Since the first workshop, citizens have requested
24 information, technical data, and an explanation of the
25 rationale of EPA and Anderson-Nichols decision-making
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1 process in choosing a waste treatment system. Instead
2 EPA and Anderson-Nichols have chosen not to provide the
3 necessary information and technical data, and decision-
4 making process necessary to allow the citizens to make
5 an informed logical choice.
6 EPA and Anderson-Nichols have arbitrarily eliminate|d
7 all alternatives that were considered that did not result
8 in the construction of a wastwater treatment plant.
9 In addition, many alternatives such as composting
10 and digestion received little or no mention
11 and were inadequately evaluated and again arbitrarily
12 eliminated. This almost should be expected in light
13 of the quote unquote sweetheart relationship that exists
14 between EPA and Anderson-Nichols; wherein, the original
15 EPA contracts with one firm to provide environmental
16 impact statements for the region and in return Anderson-
17 Nichols, of course, hopes to pick up the contracts for
18 construction of the recommended treatment facilities.
19 In the past such a relationship was called graft.
20 Today it is called contracting out.
21 On the need for sewering --On Martha's Vineyard
22 the needs for sewering has not been fully established.
23 On the basis of a questionable wind-chill survey and
24 a mail-in survey with few respondents, the draft EIS
25 attempted to show the need for sewering. This resulted
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1 in a smaller area than that originally designated by
2 Tighe and Bond as needing sewering.
3 | The more in-depth survey by the Tisbury Planning
4 | and Health boards and the Martha's Vineyard Commission
5 | showed that of the 161 lots surveyed, 42 had problems,
6 j and of those 42 problem systems, all but 9 could be
7 repaired by either conventional means or by some repair
8 work at added expense to the homeowner. Again, we're
9 j not sure whether or not some of this added expense to
10 the homeowner will be reimbursable by EPA.
n If neighboring systems with problems could build
12 holding tanks to prevent further harbor pollution coupled
13 with water conservation measures and periodic pumpings,
14 these systems could possibly be eligible for funding
15 by EPA negating the need for a sewer system and the
16 construction of a secondary wastewater treatment plant.
17 However, the septic still has to be disposed of
18 in an environmentally sound manner which has been the
19 problem up until now. One solution to the problem is
20 the composting of the septage solid waste and a bulking
2i agent such as wood chips which was mentioned in passing
22 in the draft supplement. The system as stated in the
23 draft supplement has been used in Beltsville, Maryland,
24 Durham, New Hampshire, and Bangor, Maine.
25 Septage could be held within holding tank until
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1 needed for the composting operation preventing odors
2 by direct hook-up of the pumping truck to the tank.
3 The pile were maintained by drawing air
4 through the piles and into small scrubber pile which
5 effectively removes all odors.
6 The pile is covered with either an insulating
7 material of screened compost or a layer of wood chips.
8 The piles can also be windrowed without the forced air
9 ventilation system but will require turning once every
10 two weeks with the finished compost being ready in one
11 month.
12 The machine necessary to turn this compost can be
13 attached to a front-end loader and costs approximately
14 $50,000, much less than a secondary sewage treatment
15 plant. Comparing the cost of septage, solid waste
16 composting -- wait a minute. Comparing the cost of
17 a septage, solid waste composting operation, including
18 the cost of a holding tank versus the construction of
19 a wastewater treatment plant, we find that a holistic
20 composting system costs less than one-half the cost of
21 the wastewater treatment plant as stated on page 21 in
22 the draft supplement.
23 In addition, the quality of the finished holistic
24 composting system will be of much higher value than the
25 compost from a wastewater treatment plant. This is very
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I
1 important -- the quality differences between sledges from
2 a wastewater treatment plant and those produced in this
3 ! holistic environment -- in this more holistic manner.
4 i So for less than half the cost of a wastewater
5 I treatment plant, Tisbury can prevent further harbor
6 pollution, treat their septage in an environmentally
7 sound manner, reduce the volume of the materials entering
8 the sanitary land fill by treating the solid waste, and
9 produce a larger volume of agriculturally useful by-
10 products of a higher quality.
n The higher quality holistic compost versus the
12 compost of a wastewater treatment plant will mean that
13 a greater volume of useable materials will be available
14 for agriculturally useage on the Vineyard. If this
,5 system is combined with water conservation measures and
16 recycling of metals and glass, the life of our present
17 sanitary land fill will be extended by many years.
18 The technical details of this composting operation
19 would consume too much time to thoroughly discuss here
20 now, but other knowledgeable townspeople, consultants and
21 myself are willing to meet with EPA and Anderson-Nichols
22 to fully detail and document the process.
23 It should be noted that such a holistic composting
24 system is more in line with current federal regulations
25 concerning treatment of waste within designated 208
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1 areas and with the federal regulations concerning the
2 preparation of Environmental Impact Statements.
3 This document here which was sent to me by EPA.
4 (Indicating.)
5 This holistic composting system along with other
6 environmentally sound systems has not been given adequate
7 analysis or consideration within either the draft
g Environmental Impact Statement or the draft supplement
9 Environmental Impact Statement as request by citizens
10 at the October 1 Workshop, the public hearing and within
11 the written comments.
12 EPA's response to comments indicates that some
13 thought has been entertained, but that the system --
14 their composting system proposed is highly technological
15 with excess uses of energy and materials to accomplish
16 the same ends in the more simplistic holistic composting
17 system.
18 Night soil has basically the same characteristics
19 with primary treated materials without the need for
20 primary sedimentation or the construction of sewers.
21 The addition of lime to compost, as recommended in the
22 draft supplement to increase flocculation increases
23 the amount of ammonium formation within the composting
24 products, increases the odors of the compost, and de-
25 creases the nitrogen content of the final end product
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1 resulting in a greater need for more wastewater treatment
2 plant soil conditioners to produce results equivalent
3 ! to the lesser amounts of the more holistic compost.
4 i It has also been shown that the wastewater treat-
5 ! ment plant fails to kill many pathogenic organisms
6 ! within the sledges and may increase their concentration
7 within the treatment plant up to and over ten times.
8 This documentation is from the report by the Organic
9 Recycling Commission dated March, '77 entitled, "Feasi-
10 bility of Application of Municipal Sewage Sledge on
11 Agricultural Land in Massachusetts."
12 The report continues to -- The report states
13 "On the effect of sewage treatment, ova of intestinal
14 parasites are apparently not effected by the activated
15 sledge process, and, in fact the literature indicates
16 that activated sledge mixed liquor provides an excellent
17 hatching medium for the eggs.
18 Trickling filters, on the other hand, reduced
19 ova concentrations 62 to 76 percent but may produce
20 larva in the affluent when the filters slough off growth.
21 In general, activated sledge appears to be ineffective
22 in removal of both cysts and ova and while trickling
23 filters are somewhat more efficient, they still pass
24 significant portions of the in-coming pathogens out the
25 affluent."
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1 Similar results are found with respect to salmonelli
2 shagella and tubercle bacilli. Wastewater treatment is,
3 therefore, not without faults of its own in terms of
4 efficient, environmentally sound treatment.
5 The final regulations for preparation of Environ-
6 mental Impact Statements here, volume 40 no. 72 published
7 Monday, April 14, '75 and the federal register outlines
8 the procedures and considerations to be taken by the
9 EPA in preparing an Environmental Impact Statement.
10 Within the draft Environmental Impact -- oh,
11 wait a minute. Sorry.
12 Simply accommodating adjustments at the end of
13 your decision-making process will not give proper con-
14 sideration to these environmental alternatives which
15 have yet to be considered and will not allow adequate
16 public scrutiny before the final EIS is issued.
17 This consideration of all environmental influences
18 from the outset is required by the National Environmental
19 Policy Act, NEPA.
20 Now, getting into some of the specifics within
21 here, this has been documented once before at the last
22 October hearing since that time, again according to the
23 supplement, nothing's been done on this. Section 6.304
24 Odd-Even Environmental Impact Statement.
25 Background and description of the proposed action
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1 states that "When a decision has been made not to favor
2 an alternative until public comments on a proposed action
3 ! have been received, the draft EIS should treat all
4 | feasible alternatives at similar levels of detail."
5 | This treatment of alternatives at similar levels
6 of detail is not at all done in the draft EIS nor within
7 the supplement. Much more detail is given to alternative
8 three than any other treatment system. This does not
9 j allow an informed choice by the public. Instead, this
10 seems like an attempt to force one choice on the public
^ whether they want it or not.
12 This level of detail in assessing alternative 3
13 is probably due to the familiarity of conventional waste-
14 water treatment facilities to EPA and Anderson-Nichols.
15 These conventional wastewater treatment facilities were
16 originally designed with only one thought in mind, des-
17 truction of the waste materials at any cost.
18 when these plans were originally designed, no need
19 for waste recovery was thought of. The reason for this
20 approach is due to septage and wastewater being seen as
21 waste and not as potential resources.
22 Other sections within this final regulations on
23 preparation of Environmental Impact Statements, which I
24 feel has not been adequately done by EPA either in the
draft EIS or in the supplement, are section 6.304 Body
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1 of EIS, it states under the section b, Alternatives to
2 the proposed action. The EIS shall develop, describe,
3 and objectively weight feasible alternatives to any
4 proposed action including the options for taking no action
5 or postponing action.
6 The analysis should be detailed enough to show
7 EPA's comparative evaluation of the Environmental Impacts
8 commitments of resources, costs, and risks of the proposed
9 action in each feasible alternative.
10 For projects involving construction, alternative
11 sites must be analyzed in enough detail for reviewers
12 independently to judge the relative desirability of
13 each site. Again, as stated earlier, many of these
14 alternatives were just simply thrown out the window at
15 the beginning of the process.
16 "Primary attention should be given to those factors
17 must evidently effected by the proposed action. The
18 factors shall include, where appropriate, the proposed
19 actions, effects on the resource base including land,
20 water quality and quantity, air quality, public services,
21 and energy supply. The EIS shall describe primary and
22 secondary environmental impacts both beneficial and
23 adverse anticipated from the action.
24 The description shall include short-term and long-
25 term impacts on both the natural and human environments.
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These also, I feel, have not been adequately documented
2 in either the draft EIS or the draft supplement. Many
3 | times, especially in the draft EIS, certain things were
4 ; singled out within the alternative systems which were
5 ! not singled out in the wastewater treatment plant system
6 I One of these, of course, being odor which was
7 j hardly ever mentioned in the draft EIS but later in the
8 draft supplement, it was of major concern.
9 It is also important to look at, as Mr. Murphy
10 stated earlier, irreversible and irretrievable commitments
11 of resources to the proposed action should it be imple-
12 mented, and that you can look up in your own things, but
13 there are many irretrievable resources which would be
14 committed in the building of a wastewater treatment plant
15 that do not necessarily have to be committed in a com-
16 posting process.
17 Also, there's the question of the effect on prime
18 agricultural land and agricultural operations on the land
19 This is something that stated in here is very important.
20 This has not been done and yet should a composting produc
21 be available to farmers within the area, there are cer-
22 tain soil management techinques which, using the compost
23 and other mineral fertilizers, can significantly reduce
24 the amount of synthetic fertilizers, pesticides, and
25 other biocides necessary to farm here on the Vineyard
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1 and would also reduce the input costs as well as the
2 natural resources costs in terms of oil, petroleum, other
3 non-renewable resources.
4 This, by the way, has been done -- This type of
5 soil management systems has been done by myself as well
6 as Matthew Tobin now of Tilane Nursery, and we have found
7 over the past seven years that these systems do work.
8 We've been doing this for the past seven years, and we
9 have been able to do things agriculturally, both on
10 gardening and landscaping, without the use of synthetic
11 fertilizers, pesticides, or other biocides and still
12 getting excellent results, quality results, results we
13 can put a guarantee behind in writing.
14 And, finally, under Scope of EIS, it is the regional
15 administrator's responsibility to determine the scope
16 of the EIS. He should determine if an EIS should be
17 prepared on a facility's plan or section 208 plan and
18 which environmental area should be discussed in greatest
19 detail in the EIS. Once an EIS has been prepared for
20 the designated section 208 area, another need not be
2i prepared unless the significant impacts of the individual
22 facilities or other plan elements were not adequately
23 treated in the EIS.
24 The regional administrator should document his
25 decision not to prepare an EIS on an individual facility.
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1 Again, I feel, that there are many omissions and
2 missing details that have not been brought up in the
3 ! draft EIS or the draft supplement which should have been
4 ! brought up and, therefore in my opinion, the whole
5 j feasibility and the documentation is pretty inadequate.
I
6 In summary, I would just like to say that the price
7 of food keeps going up, the ground water pollution keeps
8 increasing, and these two problems here on the Vineyard
9 can be solved by a composting operation in which we in-
10 crease the quality of the soil, increase the exchange
n capacity of the soil, and hence increase its filtering
12 ability so that pollutants do not enter the ground water.
13 To attempt to separate the problem of water quality
14 from food production and other environmental effects in
15 the draft EIS is extremely shortsighted and narrow-
16 minded. The goals of the National Environmental Policy
17 Act to consider all environmental effects of a planned
18 action are being side-tracked by the conventional destroy
19 at any cost mentality of EPA and Anderson-Nichols.
20 Anderson-Nichols' approach to the problem of water
21 quality in the Vineyard is a blatant example of decision-
22 making before all environmental aspects are considered
23 and is totally at odds with the National Environmental
24 Policy Act process.
25 I'd also just like to state that when private
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1 conversations with Mr. Murphy, Mr. Mendoza, other people,
2 we have always been assured that evaluation of composting
3 and other alternatives will be entirely objective and tha
4 no one alternative will receive preference.
5 After reading the draft EIS and the draft supple-
6 ment, we can see that these promises were fulfilled.
7 Also, nowhere in the draft supplement or in the draft
8 Environmental Impact Statement have -- again, have costs
9 been put out for some of these alternatives which were
10 arbitrarily eliminated in which townspeople could take
H a look at these and compare them next to each other and
12 be able to get some kind of a decision.
13 Hopefully, these rules and regulations, as well as
14 some of the rules and regulations in public law 92-500
15 with respect to Title 2 construction grants funds will
16 be taken into account when a final decision is made
17 within the final EIS.
18 And I only can say that I hope that those treat-
19 ment systems that are the most consistent with the laws
20 should be those considered for funding.
21 Thank you.
22 MS. HAMMER. I'm sure that we have some specific
23 comments that Peter would like to make to that statement
24 I'd like to make one general one and perhaps I'm
25 presuming as an outsider, since I've only been here
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1 a year and I wasn't here when the Environmental Impact
2 Statement process began, but as I understand it, the
3 | Environmental Impact Statement process began in response
4 | to a facilities plan adopted here. This was evaluated
5 i and formed the basis, the starting point, for our analysi:
6 j Our analysis was not started by the general
7 proposition of doing facilities planning for this area.
8 We are going to try to be as informative, as fair as
9 possible, and as clear as possible in the information
10 that we give you for making your decision. However,
n there's a limit of detail which crosses over from the
12 Environmental Impact Statement process, which is a
13 federal process, into the facilities planning process,
14 which is one for which federal funding is available
15 but is essentially a local responsibility and a local
16 cost-sharing responsibility.
17 So I think that what you will see as lack of
18 details result from this fuzzy line. It's not always
19 clear to us as well. When we get into a situation in
20 which we are evaluating a proposal, how far do you go in
21 picking up all the possible alternatives and how much
22 detail do you give to the study of all of those possible
23 alternatives, is a matter for a lot of judgment -- It is
24 not cut and dry.
25 So, as I said, we will try to do as good a job as
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1 we can of presenting the information that we have. You
2 have given us some comments and other people have,too,
3 on the information that they don't think was presented
4 well enough, but we're not going to satisfy, I think,
5 all the facilities planning goals that you all might
6 have. Peter?
7 MR. MURPHY. Thank you.
8 The comment on EPA's relationship with Anderson-
9 Nichols, I think, is irresponsible and shows total lack
10 of knowledge of the federal contracting procedures and
H regulations on conflict of interest.
12 Anderson-Nichols is one of many EPA contractors.
13 Anderson-Nichols is restricted from performing an
14 Environmental Impact Statement on its own project and
15 if one of its own facilities planning projects do come
16 up, it's obvious and we declare conflict of interest --
17 EPA declares it and another contractor will do an
18 Environmental Impact Statement on it.
19 Anderson-Nichols is constrained in its partici-
20 pation on any project for which it has prepared an
2i Environmental Impact Statement. Anderson-Nichols --
22 MR. MENDOZA. What,a regulation?
23 MR. MURPHY. By contract -- by contract with a
24 consultant. I take that to be a regulation.
25 Anderson-Nichols interest is focused exclusively
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1 on the Environmental Impact Statement. It has no financi
2 interest in step one, planning. It has no financial
3 | in step two, engineering, and I see these comments as
4 being totally groundless.
5 I With regard to the comment or citation of federal
6 rules, regulations, and guide lines, we can only respond
7 that some consideration must be made of state and federal
8 sanitary requirements and what can be practically accom-
9 plished in an environmentally sound manner. The recom-
10 mended alternative is practical, environmentally sound,
^ meets all sanitary requirements and all federal require-
12 ments for evaluation of alternatives.
13 Finally, I don't know whether the commentor has
14 understood from the supplement to the draft EIS, and the
15 draft EIS, itself, that composting as a process is
16 recommended. We are recommending that as part of this
17 Environmental Impact Statement.
18 MR. PACHECO. In addition to the construction of
19 the wastewater treatment plant, correct?
20 MR. MURPHY. That's correct.
2i MR. PACHECO. What I am saying is that there is
22 n° need to build a wastewater treatment plan, that ,com-
23 posting is, by definition, a secondary form of treatment
24 and that it is a biological form of treatment, and that
25 we don't need a wastewater treatment plant. We can
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1 compost this material just as easily without going
2 through the construction of sewers and a wastewater
3 treatment plant, and at much less cost than a wastewater
4 treatment plant.
5 MR. MURPHY. And EPA is saying that you have to
6 collect the wastewater before you can compost it.
7 MR. PACHECO. And, as mentioned earlier, in a
8 holding tank system in the downtown area to prevent
9 harbor pollution and that this would then be done in
10 basically the same manner as in the supplement where the
11 truck would pull up to a holding tank, there would be
12 a direct connection made, and that from there on, your
13 composting process as outlined in the supplement, so
14 that you; would still have a collection system in a sense,
15 but it would be a truck and a holding tank.
16 MR. MENDOZA. Ed, I have a couple of questions.
17 As a person within EPA who is responsible for
18 completing the EIS process, I'd like to ask that in your
19 comments, and I assume that you will be sending us a
20 copy of your comments, that you be somewhat more specific
21 -- it will help us if you would be somewhat more specific
22 in terms of identifying exactly what are the contra-
23 dictions that appear within the supplement.
24 By simply making a statement that the draft
25 supplement consists of many contradictions doesn't help
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1 us with a decision trying to resolve that.
2 The other statement which you made relative to
3 | the draft supplement raises a number of additional
]
4 j questions -- if you could be more specific in terms of
5 i telling us what exactly are those questions so that we
j can try to deal with that in the final.
7 I wanted to just make a statement with regard to
8 our relationship with Anderson-Nichols from EPA's side.
9 I Anderson-Nichols has competed with a number of different
10 firms and are in the contract to us to prepare Environ-
n mental Impact Statements. They are one firm of many firm
12 who have the capability of preparing impact statements.
13 The responsibility for preparing an impact state-
14 ment is a federal responsibility. Anderson-Nichols are
15 acting as our staff in this relationship. There is
16 specific language within the contract that deals with
17 conflict of interest issues, such as being involved in
18 a community that they have done previous facilities
19 planning as well as any involvement that they may have
20 in a community after an impact statement is completed,
21 and I want to say that for the record because that's a
22 very key issue here and a concern that we have in our
23 office.
24 If you in your statements could be a little more
25 specific and tell us where the problems are, where the
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1 conflicts are, where the questions are, I think that
2 would be very helpful to us.
3 MR. PACHECO. I have a question on the process
4 between EPA and Anderson-Nichols. How many other firms
5 at the present time are preparing Environmental Impact
g Statements for EPA for the current year?
7 MR. MENDOZA. Okay, there were two other firms,
8 one has just recently completed an impact statement and
9 there is another firm that's in the process of working
10 on a completion of an impact statement in addition to
11 Anderson-Nichols, just in region one.
12 MS. HANMER. Would you come up to the mike and give
13 us your name?
14 MS. MADEIRAS. Cora Madeiras, a citizen in the
15 Town of Tisbury.
16 If I could read a couple of excerpts from the
17 letter that was sent -- It says, "The new guide lines
18 specify that a full evaluation of less than secondary
19 treatment plants processes is required. The draft EIS
20 does not address less than secondary treatments."
21 Then it says here that a public hearing on this
22 supplement will be held during the month of October,
23 1978. The final EIS will be issued during the month
24 of November, 1978.
25 My question is -- In a recent conversation with
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Mr. Adams, he stated that the guide lines haven't even
2 come out of Washington for the secondary treatment plant,
3 i so I was curious as to how a final EIS draft could be
4 i made without these guide lines?
;
5 j MR. PINAULT. 1 think you're talking about two
i
6 I separate things.
7 When the hearing was held last October on the
8 draft EIS, after it was typed, on October 3rd to be
9 exact, EPA issued a policy memo on the land application.
10 All that said, basically, was that it re-emphasized our
11 policy and said that before you can write-off a land
12 application system, you must show that less than secondar
13 treatment could possibly be acceptable. That was done
14 in this case and the conclusions were that primary
'5 treatment or secondary treatment at site one would be
16 equivalent in that the impacts on ground water quality
17 would be the same.
18 Tne final decision on what degree of treatment
19 would be necessary at site one was based upon above-groun
20 impacts and that being if you had a secondary treatment
21 plant at site one, you would have a less potential for
22 creating odors when you applied the affluents to the
f
23 sand beds- If y°u had a primary treatment, you would
24 have more solids in the affluent and when it went on to
25 sand beds, you could have a higher potential to create
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1 odors, so, therefore, our evaluation was complete.
2 It's true that the final what we call PRM, Program
3 Requirement Memorandum, has still not been issued. It's
4 been published in draft form on April 20th. All of our
5 analyses and everything that we've done to date are in
6 conformance with that draft. The people in Washington,
7 who have written the draft, evaluated the analysis by
8 Anderson-Nichols, and it was approved by them.
9 All this PRM that's going to be coming out shortly
10 is going to do is more or less just establish a detailed
11 step-by-step process on how this should be evaluated
12 and it doesn't effect that impact statement whatsover.
13 I hope I've answered your question.
14 While I'm here I'd like to make one comment on
15 Mr. Pacheco's comments and that has to do with the sep-
16 tage compost. I'm quite familiar with facilities that
17 he has discussed, Beltsville, Bangor, Maine, and I've
18 not been able, unfortunately, to get to either one, but
19 I've talked to a number of people who have been there
20 and this has been discussed in a number of projects as
21 an alternative, and I do know after reading all of the
22 reports and talking to these people who had the first-
23 hand knowledge that in each case these facilities were
24 run under very tightly controlled conditions. In other
25 words, when a load of septage came in, it was analyzed
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1 and it was truely septage, it wasn't for instance holding
2 tank waste.
3 i In cases where holding tank waste came in, it was
4 ! not allowed to go into the facility, because they wanted
5 i to try to control their operation.
6 In the case of Tisbury or any town on the island
7 that might be receiving septage at this facility, you
8 would be receiving some holding tank waste and, I think,
9 when you really look into the practicality of applying
10 one of those systems here or in any town on a large
11 scale system, it's going to be very hard to do that be-
12 cause if you get a tank of septage, truly septage that's
13 been in the ground maybe say six, seven years in a septic
14 tank, it's going to be very concentrated, or on the other
15 hand, if you get holding tank waste which is coming from
16 a restaurant or a laundermat which pumps out very fre-
17 quently, the concentration is going to be completely
18 different. It might have one-hundredth the concentration
19 If you dump this into your facility, it would re-
20 quire ten, twenty, thirty times and amount of bulking
21 agent, and it does cause problems, so I agree that com-
22 posting is a viable alternative in certain locations but
23 as far as Tisbury is concerned, I question that.
24 The other thing you were talking about was patho-
25 gens, and you noted that a typical, conventional treat-
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1 ment system does not destroy all pathogens. The same
2 holds true to compost.
3 At these facilities where the composting occurred,
4 like I say it was very controlled, they took temperature
5 measurements throughout the pile at different levels,
6 and even under those conditions they found that the
7 optimum thermophilic levels were only reached in the
8 center of the piles, and there was stratification
9 throughout the piles, and there was definitely not
10 total kill of pathogens, et cetera.
11 I just want to point that out that composting
12 does not kill all of these things.
13 The next problem that leads to is if you have this
14 mass distribution of this composting material, you're
15 distributing material which could have an adverse impact
16 to public health, and I think you would have a lot of
17 trouble satisfying state regulations to sell this
18 material.
19 All I'm trying to do -- You pointed out all the
20 good parts of composting, I'm just trying to point out
21 that there are a lot of side effects also which you
22 didn't mention that when the final analysis is made,
23 all of these things have to be taken into account.
24 MR.. PACHECO. the stratification that you mention
25 is true, however, that was one of the reasons in the
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1 draft supplement why you recommended turning the pile
2 upwards of ten times within the first week or something?
3 | MR. PINAULT. I forget the exact number.
4 | MR. PACHECO. But to help make sure that all
5 | sections of the compost were at this thermophilic level--
6 MR. PINAULT. But even when that is done, it takes
7 much more manpower and it's very labor-intensive and
8 the costs just go up.
9 j MR. PACHECO. For turning the pile?
10 MR. PINAULT. Turning the pile --
n MR. PACHECO. This machine can turn 150 tons of
12 compost per hour for $50,000, so compare that to - -
13 MR. PINAULT. I'm not here to argue. My only point
14 is that there is a lot involved in this type of thing.
15 A lot of the studies you refer to were done under ideal
16 conditions, very controlled, but when you get to the real
17 world and try to apply these new technologies, you could
!8 run into a lot of problems.
19 MR. PACHECO. That's why I suggested meeting with
20 EPA and Anderson-Nichols to discuss this in further
21 detail.
22 MS. HANMER. I'd like to give everybody here 'a
23 chance to speak first before we move to seconds.
24 Yes, ma'am. Your name, please?
25 MS. WEST. Isabelle West. I live in Tisbury.
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1 In the beginning we were told that there was fundi
2 available if we cooperated with other towns and now that
3 we seem to be going on our own, I'd like to know what
4 kind of funding might be available?
5 MR. MENDOZA. The question was -- What kind of
6 funding might be available with the recommendation of th.
7 town to construct the facilities recommended?
8 MR. JEANS. Without the other towns?
9 MR. MENDOZA. You are referring to the construct--
10 the funding that might be available for the construction
11 o£ the facilities that are recommended in the supple-
12 mental draft EIS?
13 MR- JEANS. The Division of Water Pollution Control
14 issued its draft priority list for fiscal year 1979.
15 On that priority list the Town of Tisbury was included
16 with information, you know, relative information not
17 definitive down to the penny -- monies were associated
18 for the Town of Tisbury on the main fundable portion of
19 the priority list, predicated upon the information which
20 had been developed in the supplemental draft to the
21 facilities plan, EIS.
22 The Division, before it could act on funding of
23 any work for the Town of Tisbury, would have to have
24 a completed application for, say, the step 2 or step 2/3
25 work. It will require a Town Meeting action and
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1 acceptance of the project by the town, and then the
2 submittal of the application with a myriad of other
3 I paperwork that goes along with it, but basically, it's
4 going to be a town decision.
5 | The Division is not going to take the EIS and give
6 a grant to the Town of Tisbury. It's going to be the
7 town that's going to take the EIS, digest it -- there's
8 a lot of information in there -- go to Town Meeting,
9 because the townspeople are the ones that are going to
10 decide which way they're going to go. It's not going to
11 be EPA or ourselves.
12 As far as the compatibility of having other towns
13 tie in, what the Division and EPA would be looking for
14 would be to have those other communities enter into
15 contractual agreements with the Town of Tisbury should
16 they so desire.
17 Now if some of these other communities do not
18 enter into it -- they don't want to, or they say, we
19 don't want anything to do with you, if it's a hands-off
20 type arrangement, we do not intend to punish the Town of
21 Tisbury because these other communities do not want to
22 come in. I think you are referring to this newsletter
23 with a reference -- Tisbury with other communities,
24 something like that -- No, we would not punish Tisbury
25 on that.
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1 MR. PACHECO. Would that preclude labor if perhaps
2 the Town of Oak Bluffs going after funds of its own for
3 construction of some sort of a waste treatment facility
4 separate from Tisbury?
5 MR. JEANS. I think it's going to depend on how,
6 j for example, the Town of Oak Bluffs would respond.
7 The Town of Oak Bluffs may want to come in -- Let's
8 hypothesize for a moment. Let's say Tisbury moves
9 forward on A Project -- I'm not even defining what it is
10 -_ Maybe five years down the road Oak Bluffs may want
n to come in with them. I think that would have to be
12 some mutual agreement at some point in the future that
13 would have to be worked out between the two communities.
14 It would not necessarily be slamming the door
15 closed, but if it appeared at this point in time to be
16 cost effective, then yes, they may have some trouble
17 five years down the road wanting to build their own
18 facility.
19 You can get off of the pie just so many times.
20 MR. DOUGLAS. My name is Robert Douglas, and I
21 live in Vineyard Haven.
22 i have attended all of these meetings and the
workshops, minus one workshop, so I'm somewhat conversan
with what we're talking about, and although it's a great
25 pile of information and decisions, I look at one
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1 particularly important problem and it bothers me.
2 This hearing indicates the sort of involvement
3 ! Vineyard Haven has with this problem -- they think it's
4 ! being taken care of for them. They think the Board of
5 j Health is doing their job. They think EPA is doing their
6 j job, the Environmental Protection Agency -- it sounds
7 good, I like this name, too.
8 Then I look at what has happened in this interven-
9 I ing year's time, and without making a very complicated
10 and long rerun of history, we've started out with a
11 system that Tighe and Bond envisioned, in good faith
12 it was put in front of the voters of the town, as that
13 is what we had to have -- It's gone considerably down-
14 hill from there -- Six million, seven million dollars
15 it was going to cost to begin with, and most of the town
16 would be sewered, and now we are seven systems that are
17 in trouble.
18 Each time we've taken a look at it, it's come down
19 to a smaller and smaller involvement and a smaller
20 collection system and smaller amount of money involved.
21 That's a very strange history to have our townspeople
22 sitting at home watching their televisions and thinking
23 that everything is going along fine, because I'm worried.
24 I've asked I don't know how many times as I haven't
25 kept very good track of this sort of thing, specifically,
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1 what sort of steps can us townspeople make in the way
2 of reducing our water consumption?
3 Page 20 or whatever it is here -- B21, it goes
4 about water and goes on -- and it just mentions that
5 they would be expensive or that it would be high cost
6 and doesn't talk about it very much, and I happen to
7 have been interested in this situation, and I've bought
8 two Aquafor tiolets and installed them. They reduce
9 the consumption of water by 90 percent.
10 I've put this low flow high pinpoint shower heads
11 on and this reduces the water flow by 75 percent.
12 I've taken care of the problem I had at the installation
13 I have down on the waterfront which is the marina in
14 operation.
15 We've talked about the cost, I've talked to Mr.
16 Murphy here one time, I asked him what did he think it
17 was going to cost the government to put up this total
18 impact statement, and he thought maybe two hundred thoussnd
19 dollars. Our planning board funded, I think, the study
2Q that Mr. Wilcox helped in and I think he said they
21 spent something under five hundred dollars.
22 I think you just mentioned this evening that the
23 information that this study produced was more involved
24 than we usually get into. Just last spring, I think it
25 was, the last hearing in the Catherine Cornell Theatre
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1 you gentlemen took a lot of flack. I think there were
2 ten people who got up with very solid statements that
I
3 asked a lot of questions that hadn't been satisfactorily
4 answered.
5 And mine was again at that time that I want to
6 see an alternative reducing the water flow. We've got
7 to put -- I think it's been mentioned rather clearly
8 by a gentleman here this evening that the amount of
9 j water we're putting in the ground is still going to be
10 dirty, no matter whether it's been treated or not or it's
n been removed from an area that may be more sensitive
12 than the place we're going to land it in.
13 I want to know, for instance, these seven systems
14 in the town that are not susceptible to ordinary modi-
, 15 fication, what happens if you reduce their water flow
16 by half, or seventy-five percent? It's never been told
17 to me what the situation is.
18 When we had-this sort of -- the windshield inspec-
19 tions and the sewers flowing in the streets interpreta-
20 tions -- those five little black dots near the front of
21 the Impact Statement which almost blow my mind, this was
22 the foundation for deciding to spend six million dollars
23 on the town. This is the beginning and now it's gone
24 down and down and down.
25 I'm not satisfied yet. I have serious reservations
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1 as to whether this town, in fact, has got to go the
2 sewers route. I haven't seen the fact yet. I think
3 Mr. Wilcox has gone further than anybody has -- I'm
4 not completely clear as to what the final detail was.
5 We talked about 21, there's 40 -- how many are
6 there? Well, just down to a handlable figure and the
7 one other thing that's at the top of my page, this is
8 what our Board of Health has produced for us townspeople
9 to look at.
10 Jf we go the limited sewer system, I trust their
11 figures are somewhat in line with what you've been talk-
12 ing about, we are going to require 370 systems to be
13 connected. We are not reducing water flow in the town,
14 are we?
15 Edgartown doesn't work well enough because not
16 enough people are hook up to it yet. I want to know
17 what seven systems are in trouble and how can they be
18 handled? How much water -- What's their problem, and
19 if you cut their tvater use by half or seventy-five or
20 eighty percent would that handle it.
21 I remember talking to someone and saying, gee,
22 we might have solved the whole problem of Vineyard Haven
23 if we'd given everybody with a problem an Aquafor
24 tiolet and not spent the 200 thousand dollars of Andersor
25 Nichols' study for our town.
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1 Now, those are specifics -- I think that's the
2 major problem. People in our town are happy that you
3 ! are working for us, they're happy that our Board of
4 | Health is handling the problem, and most people aren't
5 I here, but I don't think we're handling the problem.
6 I'd like to specifically know if we -- What the
7 picture will be if we take a massive water reduction
8 handle on downtown Vineyard Haven? Has that been
9 I handled? Has that been looked at?
10 I've asked that question before and I've never
11 gotten any answer, and I can't find an answer in here.
12 MR. MURPHY. I can try.
13 MR. DOUGLAS. I've asked that lots of times.
14 MR. MURPHY. First of all, EPA has spent a lot
15 less than 200 thousand dollars.
16 MR. DOUGLAS. You said a hundred up to where it was
17 at the town.
18 MR. MURPHY. I thought you just said two hundred
19 thousand.
20 MR- DOUGLAS. Well, the total you said was going
2i to go two hundred thousand.
22 MR. MURPHY. I honestly don't remember ever saying
23 that.
24 MR. DOUGLAS. You said they've already spent a
25 hundred.
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1 MR. MURPHY. As of this time, EPA has spent a lot
2 less than that, and I anticipate unless something drastic
3 happens that EPA will never come near spending that
4 amount of money on this project.
5 MR. DOUGLAS. What have you spent, roughly speaking
6 MR. MURPHY. Excuse me?
7 MR. DOUGLAS. What has EPA spent on the study
8 to date?
9 MR. MURPHY. I don't know exactly.
10 MR. DOUGLAS. Roughly?
11 MS. HAMMER. Roughly 120 thousand Bob says.
12 MR. MENDOZA. I guarantee it won't go more than
13 that.
14 MR. MURPHY. Now, with respect to \vater conser-
15 vation, first of all, the seven units in town that can-
16 not be rehabilitated is not EPA's number. That's the
17 number that was arrived at by the Martha's Vineyard
18 Water Quality Program which performed the survey.
19 EPA's number would be much larger because we
20 would have to consider the implications of the state
2i sanitary code when we talked about the grant eligibility
22 of improving on-site systems. So if that cannot be
23 done in accordance with minimum sanitary standards
24 such as -- Let's say that we have a lot that's so small
25 that we can't mound it up to a point that there'd be a
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minimum of four feet, then even with water conservation
2 you'd still have a potential sanitary problem because
3 _ you wouldn't be getting the renovation of the wastewater,
i
4 | in fact, the sanitary waste that would be emanating from
5 ; the house would be diluted less. So, water conservation
6 is critically important in the non-structural scheme
7 of things but as far as attenuating pollution is con-
8 cerned or sanitary conditions within the constrained and
9 i highly developed area, that's not going to be the be-all
10 and the end-all.
n It's just one important component.
12 MR. DOUGLAS. My specifics of reduction of water
13 use instead of putting 370 people on when you say seven,
14 or maybe ten, or you've got more than they've got but
15 your study of the town was minimal -- Would you buy that
16 compared to one that was produced here by the Board of
1? Health?
18 MR. MENDOZA. Let me respond to that. In just
19 about every workshop that I've attended or a hearing,
20 I recall that you have made some reference to the cost
21 of this study, and how much it has cost to prepare this
22 Environmental Impact Statement. Let me just say to you
23 that the majority of the cost that has gone into this
24 impact statement are not related to the identification
25 of water quality problems, but more towards the evaluatio
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1 of ground water impacts as a result of the application
2 of the wastewater onto the land.
3 A number of wells have been installed. A number
4 of soil samples have been taken. A number of ground
5 water samples have been taken, and as you know from
6 living on the island, the installation of wells, the
7 evaluation of soil conditions, analysis of ground water
8 samples, surface water samples is a very expensive
9 operation.
10 A great deal of the funds that have gone into
11 this Impact Statement have gone for that purpose, in
12 addition to establishing a ground water model to evalu-
13 ate the transportation of any pollutants as they enter
14 into the interface of the ground water and what the
J5 effect might be.
16 I'd like to throw the question back out to you
17 as a citizen of the town and any other local elected
18 officials here and to Bill Wilcox -- How does the town
19 perceive the idea of implementing a water conservation
20 program within the community? I mean, these really come
21 down to local decisions that the town would have to
22 make.
23 Bill, you've probably had some discussion with
24 the town with respect to water conservation. This was
25 an element of 208. What feeling do you have? Is this
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1 a real possibility?
2 MR. WILCOX. Boy, that's a good question. I think
3 ; the Tisbury Business Association was interested in the
4 ! possibilities of a solution short of sewering, so I think
5 i they're interested at least. They'd like to know what
6 | they're getting themselves into though, and I think that
7 is the kind of information that would help make the
8 decision.
9 i MR. DOUGLAS. The stand that the EP makes is going
10 i to be important, obviously. All you've been saying
•II right along and now it's we're going for and all the
12 reasons, and there are some reasons that you don't give
13 because they are too complicated, but you've come out
14 for the limited collection system, and for a lot of
15 people who aren't going to be interested in going into
16 the nitty-gritty and are going to take your expertise,
17 that's going to be important to them. Obviously, it
18 will carry a lot of weight and this is why if we don't
19 have the full details brought out in the open as I think
20 it's been suggested, well, I'm for one am not happy at
21 this point.
22 MR. MURPHY. By and large in the phase one col-
23 lection area, water conservation is not going to solve
24 the problem and the reasons for that are the elevation
25 of the ground water -- it is so close to the surface
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1 that the problem is that rather than the capability
2 of the soil. Now if we were in a different kind of
3 surfacial geologic situation where the soils had a
4 limited capability to perk away the waste water, then
5 water conservation would be most more critical.
6 But, in this case, we're talking about water con-
7 servation as an important component, but probably not
8 one that we think can solve the problem.
9 MR. DOUGLAS. Why couldn't you carry -- If you
10 could pinpoint the guys that have the problems, put them
11 a holding tank on top of the fact that they have water
12 conservation policy measures in their enterprise, those
13 fellows could carry the cost of doing business in that
14 area and not landing it on the whole community. We're
15 not talking about all the little items, about the cost
16 to the town, of the traffic in that area that you can't
17 get through now, et cetera, et cetera, but just for
18 itemizing the problem and taking care of the problem
19 and not passing the cost onto the whole community with
20 all the spinoff --
2i MR. MURPHY. Well, that can be done but then the
22 town would not be enforcing minimum sanitary codes and
23 so we would have to consider that not to be environ-
24 mentally sound.
25 MR. DOUGLAS. If there were only seven people
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1 that you could handle by pumping, against going for
2 two million dollars?
3 j MR. MURPHY. Well, we don't buy the number of
4 i seven.
5 | MR. DOUGLAS. There's the specifics that we are
6 talking about. This is the crowd that's been interested,
7 the Board of Health and the Commission have been very
8 interested in pinpointing the problems and these are
9 the facts that they've come up with, and they were dis-
10 satisfied with Anderson-Nichols' rendition of the
11 problem area. That's the basic core problem right there.
12 MR. MURPHY. Well, again, we are dealing with
13 two different kinds of definitions. One, we have
14 identified seven units which cannot be rehabilitated
15 under any reasonable circumstances and we're using a
16 different definition and saying, what are the units that
17 cannot be rehabilitated in accordance with sanitary
18 codes, and so you see our area has to be larger because
19 we're using the more conservative set of criteria.
20 MR- DOUGLAS. For instance, the Vineyard Villa
21 Motel on the waterfront, there's pumping every day up
22 until the spring. Does that look like a situation that
23 didn't have a recourse because they have so little area.
24 It's right in the middle of the U-shaped building.
25 They hired a firm who came down here, got inside
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1 and cleaned the place up, cleaned it all out with high-
2 pressure hoses or something or other, and they're back
3 in operation, and operating, I guess, with the full
4 compliance of the Board of Health.
5 Well, I mean I would like to see specifics where
6 these guys can't be straightened out, or these guys are
7 in violation of the state laws.
8 MR. MURPHY. I think they can be straightened out.
9 I mean, you're obviously describing a successful situatioji
10 from someone --
11 MR. DOUGLAS. Well, that looked to me like one that
12 was impossible, because there was no room to expand.
13 MR. JONES. I'm Harry Jones, a resident of Tisbury.
14 We seem to have our same can of worms that we've
15 had right from the beginning. It's some sort of a com-
16 munication problem. It's interesting to me listening
17 to you and to Bob talk. I listen to his side and I
18 understand it, and I listen to your side and I understand
19 it, but you're talking on two different subjects.
20 You're not talking to each other, you're talking
21 about one subject and he's talking about another. You've
22 got a communication problem. You, the general you,
23 whoever it is that is trying to help us get some in-
24 formation to solve a problem which the government says
25 we have. In other words, we've got to become legal
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1 I gather is the whole problem. We can't go on as we are.
2 I don't know whether it's the EPA or who it is,
3 ; but you out there somewhere are trying to get us some
4 information so that we can make a decision that you say
5 ! we have to make. Fine, good.
6 I kind of suggest that the stuff that's on this
7 green and this pink sheet that our Board of Health has
8 put out is a good starting point. There are simple,
9 meaty information here. There are some basic comparisons,
10 There is not reams and reams of more data. We don't
n want your scratchings, you know, that you mentioned a
12 little while ago, that you didn't see the point of giving
13 us. Darn right there's no point in giving us -- We don't
14 want all your engineering calculations, all the reasons
J5 why you came up with the decision.
16 But, on the other hand, in reacting to an idea
17 such as what about composting, we have a little trouble
18 when you say, well, we're afraid of that, and essentially
19 period.
20 MR. MURPHY. We recommended composting.
21 MR. JONES. Oh brother, did you ever do it with
22 your left hand though. As I read it, I didn't think it
23 was fairly done. When I read it, I felt, boy, I can see
24 what they felt. It didn't come across fairly to me.
25 I'm just looking for an answer. I don't know any-
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1 thing about this business, but your task is not easy.
2 Boy, I can recognize that. It's one of communication.
3 It's one of judgment, of trying to decide now what
4 factors are we going to mention because if we try to
5 mention everything, you'll boggle everybody's mind, and
6 nobody will take in anything -- much less, they probably
7 won't even read it.
8 So, you've got to keep it brief, but somehow you've
9 got to set out this information so we can compare it.
10 I think everybody who has spoken around here has said
11 give us something to make a decision with, or let us
12 compare, tell us a little bit about what is good and what
13 is bad about composting.
14 As fair as you can, let somebody write who is into
15 composting a little bit not against it. Then, let some-
16 body else write a thing who's for some other part of it.
17 There aren't all that many systems that really boil down
18 as possible candidates.
19 There are many systems, but I think we can throw
2Q out a lot right in the beginning. I was delighted when
21 these came around. I thought, oh boy, here are some
22 of the figures that we have come to one workshop after
23 another and asked for. It's only a few of them, maybe
24 it's some of the big ones, maybe twenty percent or
25 twenty-five percent, maybe something like that, but boy
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i that's a start. Give us a few more of this kind of thing
2 That's my comment.
3 ! MR. JACOBS. Michael Jacobs from the Tisbury
4 i Board of Health.
5 I I apologize for being late. I was dealing with
6 I similar problems at the hospital this evening. I think
7 we ought to get Blue Cross and Blue Shield to pay for
8 our sewers that's the only solution.
9 i I'm speaking now for the Board of Health, but you
10 will receive in writing a formal letter. I'll be very
11 brief and to the point.
12 We, with the Martha's Vineyard Commission, have
13 spent enumerable hours gathering the data for fact sheet
14 number one, which we forwarded to you, and together with
15 Bill Wilcox have spent enumerable hours preparing the
16 two fact sheets.
17 The reason we did this is we felt that most
18 citizens would neither have the time nor perhaps the
19 interest to wade through both statements that have come
20 out so far. That's not a criticism of your statement,
21 we just wanted to streamline some of the options.
22 The first one, as you are well aware of, we wanted
23 to at least get the facts and define the problem. What
24 I'm confronted with tonight in reading the supplement
25 is that I don't think it helps me to now make a decision
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based on the first fact sheet. It doesn't help me at
2 all, and I'll be honest with you and I don't mean to make
3 -- I don't want you to feel defensive. I do want you
4 to see how you can help the citizen with these fact
5 sheets which have, basically, the options that you have
6 --- All three of them, large scale sewer and small
7 scale, night soil treatment and small scale sewering
8 and night soil treatment plant with maintenance system
9 only, and what you need to do, I think, is to address
10 the fact sheet and say these are the facts that are
11 presented, okay, and we've reviewed them, and then you
12 have to address it and help the citizen with this fact
13 sheet go back and say -- he's going to go back to this
14 and say, now what are the experts going to say about
15 this.
16 So far I can find only two pages, pages 6 and 13,
17 which refer to the report and they say -- and you said
18 that the finders of the survey and the report conclude
19 that wastewater collection facilities are feasible in
20 this area. We tried not to conclude anything. We were
21 a little surprised with our facts, and I think it's
22 public knowledge that the Board of Health is not trying
23 to push the town one way or another. I certainly am
24 not and the rest of the Board is not.
25 I think it would be a misuse of our jobs to be
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1 going that and, frankly, I don't know the answer, and
2 if I don't know the answer, I don't know how Joe Citizen
3 | is going to know the answer because I've been reading
4 i more than the average person. So, I went to your supple-
5 | ment and I said, well, what are they going to do? Have
6 they looked our facts and have they verified them?
7 j There should be some statement in here as to the
8 220 lots and do you agree with the results of our survey.
9 j We made that survey effectively twice.Before we looked
1° and counted a problem, we went back to each individual
11 spot, so we've effectively done it twice. We came out
12 with 27 problems, and sitting down with Bill Wilcox
13 he suggested together with the Commission and the facts
14 that we knew that perhaps 21 of them could be corrected
15 by conventional means.
'6 All right, there are two facts with which you have
17 to work right there and address that in the report.
18 Is our data incorrect? Are there many more problems
19 than we cited?
20 And the second point is, are we wrong in assuming
21 that 21 out of 27 can be corrected with some innovated
22 system?
23 The third thing that we need to know is maybe the
24 data that we have is correct now, but our prediction of
25 future failures is way off and maybe you know that
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1 whatever small number of problems that we have now,
2 in five years ten more will fail each year, and we will
3 have thirty new problems. That's real data that I think
4 we need from you.
5 I don't want you to rubber stamp this. I really
6 don't. I'd be delighted if you'd prove me wrong if
7 that's the fact because I would hate the town to vote
8 on erroneous data. I really think then that it's
9 important that the supplement address the fact sheet or
10 address the survey that we handed you, and say we accept
11 this data in.which case one conclusion would be that
12 for the few systems that cannot be renovated, the
13 probability is that there will be very few future
14 failures; therefore, close them down and don't worry,
15 or something's wrong in your judgment, you're going to
16 have many more or the rehabilitated systems will fail
17 anyway.
18 Give us the hard data. I think we both want some
19 kind of cost effective environmentally sound solution,
20 and we have no one particular program that we would
21 favor more than the other, but I honestly don't feel
22 after reading this that based on this fact sheet and
23 the options, that you have guided me with your expertise
24 into making a decision.
25 That's all I wanted to say.
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1 MR. MENDOZA. I think we'd like to respond to at
2 least one comment that you raised with respect to the
3 i utilization of the data generated by the survey con-
4 | ducted by Bill in the latter part of last year.
5 ! Joe, could you quickly summarize what we did in
6 terms of utilization of that information and how we
7 applied it to the recommendations that are in the supple-
8 mental draft?
9 MR. ZENESKI. Quite basically, we used the data
10 to modify the phase one, the initial sewer service area
11 ] to include those problem areas and those individual
12 problems.
13 What is being requested here, I think, is a level
14 of detail beyond the scope of an EIS, that is, specifical
15 verification of a survey done in town by the town, commen
16 on whether we are going to accept the data and use it,
17 and it's just -- I think it's expecting too much.
18 MR. JACOBS. Let's assume that the data is reason-
19 ably correct. You need to say something about whether
20 we're way off base in thinking that 21 out of 27 can be
21 rehabilitated. Maybe that's where the point of contentio:
22 is, and you need to say something about what the antici-
23 pated failure rate is, because if we're left with seven
24 problems that cannot be rehabilitated, then the town,
25 reasonably, I doubt,will vote for a sewer system.
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1 If this data is wrong, you need to express it in
2 some way.
3 MR. MURPHY. You're asking us to verify your data.
4 MR. JACOBS. No. Accept the data. Let's assume
5 that it's probably ninety percent correct, then we're
6 saying -- we're concluding from those that we've pin-
7 pointed 21 out of 27 systems that could be rehabilitated,
8 are we right or wrong?
9 MR. MURPHY. How do I answer that question without
10 going out and conducting my own survey?
11 MR. JACOBS. We have the data. How can you come
12 to a seven million dollar conclusion without defining
13 the problem? I can't realize how you can go all the way
14 without looking at the basic data base. It doesn't make
15 sense to me.
)6 You can get any theoretical conclusion that you
17 want, but I'm not asking you to do your own survey,
18 we were glad to do that, but look at the data. We have
19 every bit of the ground water levels, you saw the
2Q questions. We have the size of the establishment, the
21 users, the system, the ground water table -- we have
22 every bit of information and if you assume that it's
23 ninety percent accurate, what you need to do is say,
24 yes, you can rehabilitate those systems or you can't,
25 or it's pie in the sky. Bill Wilcox and the Board of
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1 Health and the Commission really are having much greatly
2 expectations.
3 ; No one can accept anything until you at least work
4 with the data that we have. The whole reason it was done
5 ! was to define the scope of the problem before looking
6 for a solution.
7 It seems so obvious to me that I don't know how
8 to express myself any other way.
9 | MR. JEANS. I had made a couple of comments earlier
10 in the evening in regard to some of the alternatives and
^ some of the recommendations that were included in your
12 fact sheets.
13 One of the questions that I had asked was that of
«4 coordination with Lakeville, you know Paul Anderson or
15 Roland Dusso or some of the other fellows up there,
16 the reason being that I've worked with them on and off
17 over a period of the last ten years, and I know some of
18 the concerns that they have.
19 For example, on mound systems, on holding tanks,
20 on these types of approaches, they view very, very
21 dimly the concept of a holding tank as a last ditch "
22 effort when you've got nothing else left as far as-
23 alternatives.
24 If you go in the wintertime, you can have a holding
25 -- holding tanks are not cheap.
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MR. JACOBS. We only talked about mounded systems
MR. JEANS. Well, I had asked Bill. I said, you
know there are four or three or there's X number of
systems that you can't mound, you can't do this, you
can't do that -- What are you going to do with them?
The response was, we'll have to go with some form
of a holding tank .
MR. JACOBS. Forget it. We'll get rid of those
that we can't rehabilitate. No town is going to vote
for a sewer system for seven establishments -- that's
not the issue.
MR. JEANS. No, let me go through the various
things that I'm concerned about as far as those recom-
mendations .
As far as the recommendations on the rehabilitation
of systems, one of them was mounding. Now, the intent
of mounding is when you have an area that has good soils,
you have got sufficient land area, but the damn water
table is too high. Okay? This is the applicability
on a mound system. All those other requirements have
to be complied with in addition to towing the thing
out twenty-five feet around it.
Now, that can give you some fairly large --
Let me just finish --
MR. JACOBS. I just want to interrupt you because
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it's late for everyone.
2 You don't have to go through everything with me
3 ; now. What I'm saying is the statement should address
4 ' what's wrong with --or saying that there's 21 of the 27
5 ! can be --
6 ! MR. JEANS. I'm accepting that. Okay?
7 What I'm saying is that I'm accepting that there are
8 problems. You have found 27 problems, and what I'm
9 j saying is whether the number is 10 or 100 if we've got
10 27 problems, how do we get at a solution for those
1! 27 problems?
12 MR. JACOBS. And we have said that possibly 21 can
13 be corrected by some kind of innovative system without
14 sewering.
15 You should come back to us and say that's impracti-
16 cal for the following reasons or that's a good idea or
17 you can say that's practical do it, but you are --no one
18 has said what the failure rate is going to be.
19 You need to address the facts of it, and I don't
20 want to hear about systems tonight. You can write it
21 in your report.
22 MR. JEANS. The key element is this -- Anything
23 that is to be funded must be approved by DEQE, Okay?
24 It has to meet the state requirements, and all I'm
25 indicating is that there has to be coordination with
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1 DEQE as far as mound systems and let's try to take this
2 the next step further and if you don't mind what I would
3 like to do is within the next couple of days I will for-
4 \vard a copy of this and just ask DEQE's opinions on a
5 conceptual basis, not knowing all the numbers.
6 MR. JACOBS. That's what we're asking the EPA
7 to do, that's what we're asking your engineers to do.
8 That's exactly what we're asking.
9 MR. JEANS. I can see some problems because I've
10 worked with Paul on holding tank systems where they
11 have been involved in facilities planning work and also
12 on mounding systems, and I'm just raising that point,
13 and if you don't mind, I would just like to forward that
14 to them.
15 MR. MENDOZA. We will take the information that
16 you have provided us this evening and newsletter number
17 two, and both EPA and the state will evaluate this and
18 we will look at it and consider it in the final Environ-
19 mental Impact Statement.
20 I do want to ask you one question and I think
21 maybe Bill Wilcox is the person to answer it.
22 In phase one where we're talking about a float
23 projection of 70,000 gallons it's indicated in this
24 newsletter that 21 out of 27 systems could possibly be
25 rehabilitated on site. Now the six or seven remaining
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1 systems, Bill, can you tell me what that means in terms
2 of flow? Is that fifty percent of the 70,000? Is it
3 ; less? What is the relationship of flow projection to
4 ! the number of units that could not rehabilitated on site?
5 ! MR. WILCOX. I'd say it's somewhere between a third
6 and a half, maybe.
7 MR. MENDOZA. A third and a half?
8 MR. WILCOX. That's a ballpark figure.
9 i MS. HANMER. I thought you said three-quarters
10 earlier. I believe I heard that the seven represented
n three-quarters. Now, I don't know where I heard that.
12 MR. MENDOZA. I agree that there is a need for
13 further discussion on this, and I think it's important
14 for us, both EPA and the state, to sit down with you
15 and anyone else who might be interested, and try to
1C discuss these numbers in terms of what exactly do these
ID
17 rehabilitations mean and what are we talking about in
18 terms of flow projections for those who cannot be
19 rehabilitated on site.
20 MR. JACOBS. And then comment on that data so
2i that someone can pick up the supplement or the final
22 statement and thumb through it to make a decision and
23 that's your objective.
24 MS. HANMER. Let me say something again as a
25 general thing. We are talking at cross purposes to a
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1 certain extent because we're trying to do two different
2 things.
3 EPA is trying to decide and advise you on what we
4 could do in the way of federal funding for what kinds
5 of projects. We cannot make up your minds for you, nor
6 can we do your facilities planning for you. We can give
7 you our best judgments. We can make available informa-
8 tion that we have. We can tell you what we think about
9 things and we can get charges back that we're prejudiced
10 about things.
11 We will share everything that we have with you.
12 Again, I think that you are not going to be -- if you
13 expect this Environmental Impact Statement to give you
14 all the answers about the future decision you should
15 make, I am terribly afraid that you are going to be
16 disappointed. You already are disappointed.
17 MR. JACOBS. No, I don't think we expect that.
18 MS. HANMER. Well, the point we've just been
19 discussing is a case in point. In order for us to give
20 you a truly technical judgment, we'd probably have to
21 go in and do a survey ourselves, so what we're going to
22 give you is an opinion.
23 MR. JACOBS. Ita sorry. If you didn't do it
24 initially, then you couldn't have thought it important
25 enough to make your decisions on. I don't see how you
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1 can start --
2 MS. HANMER. The decision for us is not -- Are we
3 j going to force you to sewer. If our decision were to
4 force you to sewer --
5 I MR. JACOBS. No, the issue is whether we need it.
6 | MS. HANMER. May I finish. Our decision is whether
7 or not it's reasonable and we can participate in it from
8 a federal standpoint, and that is a slightly different
9 decision.
10 MR. JACOBS. But you first have to determine need.
11 MS. HANMER. Yes, you do.
12 MR. JACOBS. You have to agree that there is a
13 need, that's all.
14 MS. HANMER. Within the realm of reasonability,
15 that's right. But you all have got to make a choice.
16 MR. MURPHY. Mike, I think we're dealing with two
17 different base finds, and I know all of you -- everyone
18 else here has heard this -- but, what we are considering
19 to be a problem is on-lot improvements that can be made
20 to allivate a sanitary problem that may not be in accord
21 with sanitary codes and so that's why if I'm looking at
22 that kind of base and you're looking at the other base,
23 which is much more restrictive, then the number you are
24 getting has to be smaller than the number that we're
25 getting, but there is a rational criteria for evaluation
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1 of need and I think we're skimming over that a little
2 bit. I know we're not doing facilities planning, but
3 we have done a lot of work here and part of that has
4 been to examine all of the data that has been made
5 available to us including that of the water quality
6 program which makes this a better Environmental Impact
7 Statement.
8 MR. NORTON. I just have a very specific question
9 that, I,hope, will at least be clarified for me.
10 This is Jim Norton speaking.
11 It's really the meaning of the words advance
12 treatment in combination with environmentally sound, and
13 the question that I was specifically concerned about
14 is, Can I combine those or can we, as a town, combine
15 those to say that if advance treatment is done on the
16 present dump site, site number two, that that would be
17 environmentally sound, as is stated in site three, if
18 advance treatment is done there that is environmentally
19 sound? Is that transferable from one site to another?
20 MR. MURPHY. I can't say that it is. I think that
21 it may be. It seems reasonable that it would be if,
22 in fact, given the depth we have to ground water, and
23 the characteristics of advanced wastewater treatment
24 that you actually have changed the affluent into some-
25 thing of drinking water quality, then you probably would
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1 not have an adverse impact at site two even though your
2 sites are located in close proximity to the land disposal
3 ! operation. But then if we were to go into that, then
4 ! we'd have to also consider the cost effectiveness of
5 ! moving the wells and EPA still has to go back on this
6 | concern for the federal policy of that is they will not
7 participate in a project that will contaminate existing
8 public water supplies which it clearly is.
9 i MR. NORTON. For site three as well as for site two
10 meaning in both instances we're talking about contamina-
n tion?
12 MR. MENDOZA. Jim, one of the concerns that's been
13 raised here this evening is cost and the economics and
14 I think you all realize that if we start talking about
)5 an advanced waste treatment plant on site two from a
16 cost effective point of view, we're talking about a more
17 costly capital investment as well as a more costly
18 operational investment in relationship to what we have
19 proposed in terms of site one. You recognize that?
MR. NORTON. Yes, I do. I was just trying to get
21 some definition. Thank you.
22 MR. DOUGLAS. Specifically, here's my problem --
23 If you could reduce the water flow into X cesspool, so
24 that you didn't have any overflowing down the street,
25 we wouldn't have any particular problem because the
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1 whole town is taken care of by cesspool or leeching
2 fields, all right?
3 I had an operation whereby it could stand so much
4 water so I'd shut off the washing machine or shut off
5 the shower. I put showerheads and toilets in and I
6 solved the problem.
7 Why can't we take a look at that as a solution?
8 Say there's 20 or 30 places in town where there are
9 problems, find out what the water flow is and if we
10 could cut it in half, could the systems handle it then?
11 We haven't asked that question yet.
12 MR. MURPHY. Well, we have examined water con-
13 servation and we have considered the feasibility of
14 substantial reductions in water use and I know you've
J5 gone a long way with the installation of that toilet and
16 other measures.
17 MR. DOUGLAS. It's only $1200, that's all it costs.
18 MR. MURPHY. Yes, but still that's going a long
19 way and so we have examined the impact of that being
20 done on a wide scale without substantially changing
21 people's lifestyle, but still conserving a lot of water,
22 and what I'm saying again -- I've said it before --
23 We've found that this will not totally solve the problem,
24 that it can make an important contribution, but in this
•4. ,,-;ii nnt solve the problem, and
25 very small core area, it will not solve me P
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1 other non-structural measures will not solve the problem
2 either.
3 | MR. JACOBS. Because you've looked at all the
4 , specifics that tell you if you cut the water use by
5 • fifty or sixty percent that wouldn't handle the problem.
6 j MR. MURPHY. I don't remember what the percentage
7 cut-off point is, but there is some point, there is
8 reasonable water that has to be used for subsistence
9 j for domestic and business purposes. I don't remember
10 exactly what it is, but if a person is using seventy
n gallons per day maybe if he cut down to thirty-five
12 gallons per day, he'd really be drastically altering
13 his lifestyle, or maybe the kind of toilet you used is
14 not acceptable to him, or maybe he just does not have
15 the same level of environmental consciousness as you have
16 We're trying to come up with something reasonable,
17 realistic.
18 MR. DOUGLAS. You don't think that kind of toilet
19 is reasonable or realistic?
20 MR. MURPHY. Oh, I think it's completely reason-
21 able. If I were in the situation where water conserva-
22 tion was very important, I'd go to this, I really
23 would, but that's personal observation and we've found
24 in other studies in Environmental Impact Statements that
25 we've had a great deal of adverse reaction to anything
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1 but the typical American Standard fixture in the bath-
2 room.
3 MR. DOUGLAS. If we could have a study -- If this
4 impact statement could include this alternate in this
5 whole area, as to everybody uses this sort of a toilet
6 in that area, every kind of a showerhead in this area.
7 MR. MURPHY. We have concluded that for this centra
8 core area. What we are saying is that water conservation
9 and a rigorous application of non-structural measures
10 can possibly make the construction of phase two and
phase three unnecessary, but we think that phase one
is necessary immediately.
13 MR. DOUGLAS. But so many of the factors were
14 erroneous. The major, biggest circle on the chart as
)5 to even the Wilcox job showed the certain place which
16 I'm involved with as being pumped and so many gallons
17 a day were being pumped because somebody who was in
18
come and pump the whole thing, every truckload he could
take was designed to be pumped once a month for the
21 holding tank, the grease trap, we haven't pumped it
22 all summer long because it doesn't need it, and that
23 was the biggest, single gallonage pumped in Vineyard
Haven, and that was erroneous. Two other items down
there have now been changed because, these are also
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20
24
25
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1 little circles on that chart, all three of them are not
2 properly included.
3 I'm just using this as a basis in fact relationship
4 -- this is the problem and these are three specifics
5 I I know of that aren't the problem.
6 MR. MURPHY. I don't deny that there might be some--
7 MR. DOUGLAS. We should do a more careful job in
8 that area, that's the center core area we're talking
9 about.
10 Get the flows on every one. We still don't have
11 a handle on it.
12 MS. CROSBY. My name is Ann Crosby. I am a member
13 of the Martha's Vineyard Commission from Oak Bluffs,
14 and Mr. Douglas's comment kind of raised a question in
15 my own mind about another one of those little dots, or
16 large dots on the map that I happen to see that Mr.
17 Wilcox devised, and that is also the Tisbury Inn.
18 You mentioned earlier the facts and figures about
19 home use -- water use -- but do you have any facts or
20 figures about a large, a fairly large hotel that also
21 encompasses a swimming pool, the only indoor pool in the
22 island, which also is part of a health club where there
23 are many, many showers that are used continuously.
24 I would also add that I am a former aquatics
25 director at that particular place so I have a great
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1 source of information that possibly I could share with
2 you concerning the cesspool systems there and the back-
3 up and the number of times they have to be pumped through
4 out a year, and what times of the year might possibly
5 need it much more than other times, but I think the
6 suggestion that Mr. Douglas made of possibly just changin
7 in that place alone, just the showerheads not even con-
8 sidering toilet use, but simply showerheads in the hotel
9 and the health club area may, in fact, go a long way to
10 solving the problem there which would be another little
11 dot that could be crossed off the list.
12 Do you happen to have figures on hotel use?
13 As far as water use in a cesspool?
14 Well, anyway, I think Mr. Douglas has a valid
15 point and I think all of this information tonight is
16 bringing up other points that we really maybe should just
17 start pooling information and coming up with solutions
18 to the problems that we have. Thank you.
19 MR- WILCOX. I just have one last quick question.
20 If the final EIS recommends a limited sewer
21 service area and a sewage collection system secondary
treatment plant, but the town decides that 1hey only want
to go with a night soil treatment plant, will that be
fundable or will that be eligible for funding?
MR. MENDOZA. I know what I want to say, but I'm
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24
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1 not sure I represent EPA construction grants.
2 MR. PINAULT. At this point in time I can't give
3 | you a definite answer. All I could say is that if the
4 | town did go ahead with the recommendations of the EIS
5 j as Brian mentioned, they are on the priority list and
6 I it appears we could fund that without any problem.
7 You say what happens if the town decides just to
8 build a septage treatment facility? To my knowledge,
9 i and I've read the Tighe and Bond's study, and I've been
10 involved in this for the last couple of years, no one
n has ever fully evaluated constructing a septage treat-
12 ment facility only, and at this point in time I would
13 like to make some brief comments on your newsletter or
14 fact sheet.
15 A number of people have criticized EPA for a number
16 of things. On option one, that you show on this which
17 is the construction of a night soil treatment facility
18 only, I'd like to make a few comments, because I don't
19 think you have -- these aren't facts, at least I don't
20 think they are.
21 First of all, under option one, item A, you recom-
22 mend regular pumping of all sewage disposal systems as
23 a preventive measure when indicated. Then you go on
24 on your cost presentation and these numbers are taken
25 from the Tighe and Bond study and updated to present cost
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1 First of all, the Tighe and Bond proposal wasn't
2 designed to handle the amount of septage that would be
3 coming out of the system if you had a septic system
4 maintenance program where you would have much more septag
5 being involved, so therefore, this total capital cost
6 figure, I think, is way on the low side; it's going
7 to be much more.
8 Second of all, when Tighe and Bond did that study
9 they were recommending to put the septage facility --
10 I believe it was a bio-disc treatment facility which
11 this cost represents on the Manta property or site 3,
12 and that's one of the reasons we decided to do the EIS
13 anyway, because neither the septage disposal facility
14 or even the proposed wastewater treatment facility
15 for Vineyard Haven, which was supposedly to be sited
16 at site 3 was properly evaluated as far as impacts on
17 ground water quality and from memory reading that report,
18 the average concentration of biodene suspended cells
19 of the septage was about five thousand milligrams per
20 liter and with ninety percent removal, the affluent
21 coming out of that system was in the range of five hundre
22 milligrams per liter, which was twice as concentrated
23 as raw wastewater and we've concluded in the EIS on the
full evaluation of the Manta property, site 3, that even
if you had advance wastewater treatment and you were
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1 putting out one-one hundredth of that concentration,
2 you would be causing a problem downgrading it with the
3 ! water supplies in Oak Bluffs. So, I'd like to point out
4 j a couple of things:
5 Number one, you present these costs here -- I don*
6 think it's a true cost comparison. I think Mr. Jacobs'
7 comment that we try and go through and discuss what you
8 have put down here is a valid one. Unfortunately, this
9 | was just handed to me as I walked in tonight, and like
10 I say, these are just comments that came out of my head
11 in a quick review.
12 So, between now and the time that the final EIS
13 is prepared, we will be sitting down closely, going back
14 to the Tighe and Bond report, seeing what was put into
15 that, and try to come up with some critique of this
16 information.
17 Again, like I say, nobody has fully evaluated
18 a septage treatment facility only. The closest thing to
19 it was probably the Tighe and Bond study, and I just told
20 y°u a few reasons why that wouldn't be acceptable.
21 So before EPA or the state could find only a
22 septage disposal facility a lot more work would have to
23 be done, and that is truly facilities planning, and
24 something that EIS would not do.
25 MR. WILCOX. So that your answer to my
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1 | question about the eligibility of a septage treatment
2 plant only is that you're not really sure at this point.
3 MR. PINAULT. At this point in time I'm saying
4 that there's no way I can say -- I would say that we
5 would not preclude it at this time, you know, all I'm
6 saying is we don't have anything before us which we
7 could say yes, definitely, we would fund that, because
8 it hasn't been properly studied to my knowledge.
9 MR. MENDOZA. Bill, as far as the impact statement
10 is concerned, and the process of developing the draft,
11 when we began to recognize that there was in fact a need
12 for a limited collection facility, I think the emphasis
13 of the draft statement was directed more towards a
14 solution which could accommodate both the limited waste-
,5 water as well as the night soil facility. I think we
16 still believe that today. I think we still feel that
17 there is a need for a limited collection system. We
18 will be evaluating this additional information.
19 How that effects eligibility as Paul has indicated
20 further work would have to be done on a septage facility
21 site specific analysis would have to be done on the
22 location of the septage facility. We would be getting
23 into some of geo-hydrologic type work that we did as
24 part of the impact statement when we were looking at
25 land disposal of AWT or secondary or primary treatment.
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1 MR. WILCOX. One thing on the cost for the Tisbury
2 only facility, I used the Tighe and Bond cost figure
3 simply because the cost figure that you had in EIS was
4 so low for the composting facility that I felt that it
5 really wouldn't be a kind of valid comparison.
6 I think the project cost under the composting
7 facility was $133,000, and I was a little fearful of
8 putting a number in there that was that small because
9 I thought that I'd be kind of giving a false impression
10 in the newsletter. So I took a higher cost figure.
11 I figured if they went to a composting facility and with
12 that half million dollars they could probably put to-
13 gether a pretty good one.
14 MR. JEANS. I'd like to make two comments.
15 One of them as far as on the cost, we do have
16 some facilities planning work about to be ongoing and
17 there is some preliminary work that has already been
18 done, specifically on septage composting in southeast
19 Mass. Preliminary cost estimates are six to eight
20 hundred thousand dollars.
21 FROM THE AUDIENCE. What kind of flow rate?
22 MR- JEANS. I think on the order of twenty to
23 twenty-five thousand gallons a day. Now this is just
24 preliminary design but that's the order of magnitude
25 that I think is important here.
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1 One other comment you said could a septage facilit)
2 be funded? With the information that's been presented
3 | to date i£ a steP two application were to come into the
4 j Division tomorrow, the answer would be no. There is a
5 I lot of facilities planning work, additional work that
6 would have to be done as far as pursuing it on the septag
7 composting basis.
8 I think what's really important to the town is
9 rather than getting too far involved with composting or
10 septage treatment, whatever mode it happens to be, is
11 to coordinate with Public Health, and I will be at least
12 kicking the ball off in that regard, because I think
13 we're all looking for something that we can live with.
14 I think that one of the other things that hasn't
15 been brought up is that it's expected that there's going
16 to be future failures, you know, one to seven a year,
17 or that could be over a five year period, you know,
18 five to thirty-five, so I mean let's get things balanced
19 out and try to give as good a presentation as we can.
20 We've tried to give the costs and the EIS as
21 accurately as possible and the ramification, and let's
22 do the same on this other thing. Let's see -- Well,
23 those are my comments on that.
24 FROM THE AUDIENCE. I think that costs that we
25 put in here were done as accurately as possible.
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1 MR. JEANS. I'm just saying the level of effort,
2 I mean you couldn't spend many, many man-weeks just
3 ', doing that -- you've got a lot of other job duties to
4 ! do.
5 I FROM THE AUDIENCE. I took these costs from previou
6 documents, they were based on Tighe and Bond --
7 MR. JEANS. But, you know, different flows, dif-
8 I ferent times, you know.
9 FROM THE AUDIENCE. One other question.
10 I got the impression somewhere, and I can't put
11 my finger on where, that if the town applied on behalf
12 of a problem system, if they applied for funding from
13 EPA to remedy that system using an innovative approach,
14 using a mounding system, that because the town was
15 applying, because the town was sponsoring it, because
16 the town was going to be responsible for maintaining it,
17 that Title 5 really didn't become a limiting factor.
18 Do you know where I got that impression from
19 because I know that I read it somewhere?
20 MR- JEANS. I have attended several meetings with
21 Commissioner Stanley of late, and specifically, variances
22 and deviations from Title 5 that question was raised, ,
23 and the answer was basically no. It would have to
24 be in compliance.
25 MR. WILCOX. Well, that's good to know now.
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1 MS. CROSBY. Ann Crosby, again.
2 I'd like to maybe just make one comment, and I'd like
3 you to try to keep this in mind if you make any more
4 comments in writing.
5 It's that I couldn't help but be struck by some
6 of your, I guess maybe the attitude that I kind of got
7 from you concerning not so much alternatives to sewering
8 but what might, I guess it's off-island values when it
9 comes to lifestyle, how we happen to deal with something
10 as basic as septage, sewering, this kind of thing.
11 Martha's Vineyard, obviously, is different because
12 we're an island, but we are different in other ways, too,
13 and I think the basic difference whether we live in
14 Edgartown or Oak Bluffs, or anywhere else on this island,
15 is the fact that we're here for a reason because we
16 have a particular type of lifestyle that we really
17 enjoy living.
18 We're not in Boston, we're not in Washington, D.C.,
19 we're not elsewhere for that main reason, and I think
20 when it comes to offering us alternatives that are
21 going to automatically expect us to develop or allow us
22 to develop homes, many, many more homes than we really
23 need to have here, businesses that we have many, many
24 more than we really need to have here except that that
kind of takes care of itself anyway because we are an
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1 island, but I really want you to keep in mind that we
2 are not -- we don't really necessarily want to grow that
3 i much, okay? And when it comes to expanding facilities
4 | I for one don't really want to see that happening too
5 j terribly much here on the island, and I think Edgartown
6 is learning, hopefully is learning, from that kind of
7 decision that they made, and it's indicated to me even
8 though I don't live in Tisbury but I like this place
9 very much, that I don't really think that we need it
10 here. I don't think that Tisbury needs a full blown
H sewer system. I think we can probably handle the situa-
12 tions that occur not only now, but in the future because
13 we want to keep it fairly well organized, or at least
14 the numbers of people in the town and on the island
15 fairly well organized, and we really don't want to expand
16 too terribly much.
17 So, I know I would appreciate figures that address
18 more the other end of the spectrum.
19 MR. JEANS. I do have -- I'm responsible for the
_0 southeast area of Massachusetts, okay?
21 One of my projects has a service population of
22 sixty-seven people, so I can appreciate economy scale.
22 I'll be honest with you, we have to -- we have
24 a limited amount of money. Now, $133 million dollars
25 a year, that may sound like an awful lot of money, but
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1 you project that out over the next five years, so it's '
2 about $600 million dollars. We have requests into us
3 for well over a billion dollars. We have maybe three
4 fold times the number of requests as we have money
5 available so we have to try to be as selective as
Q possible.
7 The whole concept of needs and documenting the
8 needs for systems is one of the reasons that we have
9 through the EIS process, we have scaled down on the
10 project. We do not want to build sewers unless they
11 are necessary.
12 By the same token though we want the solutions
13 that are finally implemented to be those which you can
14 live with and not just for a year from now, but for
,5 five and for whatever the planning period is for this
16 project.
17 We don't want to be coming back here in five years.
18 I have other projects in my area where we are talking
19 basically looking at septage disposal and septage
20 treatment. They are not looking at major expansive
21 treatment systems. There's other facilities plans
22 that are on-going that sewers are not recommended, that
23 will probably be going along with so - - I try not to
24 -- I go from a New Bedford to in the scale,
25 and you have to try to develop some common ground to a
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certain degree as far as basically establishing need.
2 You've got to establish need whether it's
3 I whether it's Tisbury, Oak Bluffs, Yarmouth, whatever,
4 or if it's Fall River, Boston. You have to establish
5 ! the need first, and then you build from there, and I
6 think that's when the individuality of a municipality
7 starts to come into play as far as alternatives that are
8 acceptable to them.
9 MS. CROSBY. Okay, correct me if I'm wrong.
10 I thought you said that as far as -- in response to
n Bill Wilcox's comments about your question about whether
12 or not a septage treatment plant would possibly be
13 -- could be funded, and your answer to me, particularly
14 coming from Mr. Stanley --
15 MR. JEANS. We're talking two different things.
16 Now, the septage treatment or is it Title 5? Which
17 are you referring to?
18 MS. CROSBY. I guess it's simply septage treatment
19 as far as being eligible for funding, okay. Now, is
20 that Title 5?
2i MR. JEANS. Well, the only reason I say that is
22 because everything that has been documented has been
23 presented, okay? It is not solely on the septage
24 treatment issue alone.
25 In other words, you'd have to go back and do all
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1 the facilities planning work, the way the proposal would
2 be, say, solely a septage treatment facility, no waste-
3 water at all, but I think before we even get into all
4 those alternatives, let's coordinate and let's see if
5 we can get some answers through State Public Health and
6 these other agencies.
7 They're going to have to approve it or you're not
8 going to get it, so I think that's first base.
9 MS. CROSBY. Okay.
10 MR. JEANS. As far as Commissioner Stanley and
11 variances from Title 5, no, that's another issue and
12 basically that's the story on that.
13 MS. CROSBY. Okay, thank you.
14 MS. HANMER. We are going to lose -- I'm willing
15 to stay here all night, but everybody that's helping
16 me answer questions has got a plane that's leaving at
17 n p.m., so I think perhaps we can have about five more
18 minutes, but that will be it.
19 MR. PACHECO. I have two very brief comments.
20 One, as I pointed out earlier, is the apparent
21 contradiction between what is stated in section 2 here,
22 that these comments cannot be part of EIS.
23 In addition, section Al, you talk about Fort
24 Devens Project which is supposedly on page Al is 30 year
&T. i* onlv 6 years of operation
25 in operation, but on page A3, is only y
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1 Now that's a contradiction in itself.
2 And page B4, yeast and bacteria preparation would
3 i be flushed down the toilet -- these are generally not
i
4 | considered effective.
5 j Mr. Douglas mentioned the Vineyard Villa Motel
6 I which had a problem and the way they solved that was to
7 use a bacterial preparation which stabilizes septage
8 in there and was later pumped out.
9 There have been other reports in the literature
10 of yeast and bacteria preparation as being very effective
n The other thing is that the waste flows on page
12 13, which we talked about earlier -- the 70,000 gallon
13 figure is based on the fact that 35 commercial units
14 and 145 residential units would be connected to the
15 sewer systems. What happens if not that many people
16 are connected? What happens if wastewater flows are
17 reduced through water conservation measures? Does
18 sewering for the phase one area then become cost
19 effective? If not that many people tied in, you wouldn't
20 have as much water coming down the tubes.
21 There will be more and more clear ones in my
22 written comments -- more details.
23 MS. HANMER. Thank you very much.
24 MR. PACHECO. You haven't said who we can write
25 our comments to -- You said we could write comments.
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1 Could you give the address?
2 MS. HANMER. Yes, you can send your comments to
3 Bob Mendoza, Room 2203, John F. Kennedy Federal Building,
4 that's U. S. Environmental Protection Agency, Boston,
5 Massachusetts 02203.
6 (Whereupon, the hearing adjourned.)
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CERTIFICATE
UNITED STATES OP AMERICA
ENVIRONMENTAL PROTECTION AGENCY
4
5 This is to certify that the attached
6 proceedings held at the Tisbury Regional School,
7 Tisbury, Martha's Vineyard, Massachusetts on
8 Thursday, October 12, 1978 consisting of
9 pages 1 through 122 was held as herein appears
10 and that this is the original transcript thereof
11 for the file of the Environmental Protection Agency.
12
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122
^ '^
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APPENDIX F
ARCHAEOLOGICAL INVESTIGATION
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ARCHAEOLOGICAL INVESTIGATION
A copy of the Preliminary Archaeological Study for the pro-
posed treatment plant site on West Spring Street is repro-
duced on the following pages.
During Step 2 a "Determination of Effect" in accordance
with the National Advisory Council on Historic Preservation
procedures will be made by EPA.
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PRELIMINARY ARCHAEOLOGICAL STUDY
SEWAGE TREATMENT PLANT SITE
WEST SPRING STREET
TISBURY, MARTHA'S VINEYARD, MASSACHUSETTS
ENVIRONMENTAL IMPACT STATEMENT
TO BE PREPARED BY
ANDERSON-NICHOLS, TECHNICAL CONSULTANT,
FOR E.P.A. REGION I
CHARLOTTE W. THOMSON, PH.D.,
CONSULTANT IN ARCHAEOLOGY
P.O. BOX 615
NEWBURYPORT, MASSACHUSETTS 01950
FEBRUARY 2, 1979
F-5
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PRELIMINARY ARCHAEOLOGICAL STUDY
SEWAGE TREATMENT PLANT SITE
WEST SPRING STREET
TISBURY, MARTHA'S VINEYARD, MASSACHUSETTS
I. PROJECT
Archaeological research was done on the proposed sewage treatment plant
site in Tisbury, Massachusetts shown on the plan "Schematic Site Plan, Primary
Wastewater Treatment Plant, Alternative Site no. 1" by Anderson-Nichols datvd
February 16, 1978.
Lake and Spring streets lie to the north and south of the site. Pine Street
lies to the east and Lake Tashmoo, to the west. The precise bounds can be seen
in the above-mentioned plan, and on a sketch on the Vineyard Haven U. S. G. S.
sheet attached hereto (Map 1).
II. SETTING
The proposed sewage treatment plant site lies within the area covered in
the Pleistocene by the Martha's Vineyard moraine (C.A. Kaye 1966, 1977). The
soil is sandy till overlaying gray clays and fine to medium clean sands.
That the ice retreat was rapid around Lake Tashmoo is documented by numerous
kettle holes. These were formed by blocks of stagnant ice that became isolated
from the receding glacier and were partially or completely buried in till or
outwash. When these blocks of ice finally melted, they left the pits or depressions
called kettles that pock the land around Lake Tashmoo.
In the immediate project area, none of the kettles appears to have held water
F-6
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in recent times.
The sewage treatment plant site is partly in pasture, and partly covered by
secondary growth of pine and oak.
III. HISTORIC LAND USE PATTERNS
The large neck of land between Lake Tashmoo and Vineyard Haven harbor
was originally purchased by Isaac Chase, who died in 1728. It was then divided
into nine strips running East and West, which were the property of Chase's heirs
(J.H.K. Norton).
Original development was on the main north-south street running parallel
to the shore, and into the period of the 1790's, no buildings stood west of the
hilly land in the middle of the peninsula, the western extremities of the lots
being pasture or wood lots.
In the 1930's much of the Chase land was subdivided.
Thus no historic buildings would be found on the property under considera-
tion for the sewage treatment plant site.
IV. KNOWN AND EXPECTED PREHISTORIC SITES
The archaeology of Martha's Vineyard is relatively well-documented.
Excavations have produced a cultural sequence extending from the Late Archaic
to the Woodland Period (Byers and Johnson 1940, Huntington 1959, Ritchie 1969
and others).
Most of the Martha's Vineyard sites are coastal shellheaps or middens; but
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other sites lie above the coast in the moraine, near streams or swamps
(Richard Burt).
K the American Indians inhabited Martha's Vineyard before Late Archaic
times (3,000 - 500 B.C.), their sites may be 'drowned'sites offshore, habita-
tion areas inundated by the rising seas of the post-Pleistocene era.
The site proposed for the sewage treatment plant lies between fifty and
sixty feet above Lake Tashmoo. Formerly a fresh-water lake surrounded by
marsh grass and cat tails, Tashmoo was opened to the sea by the 1938 hurri-
cane which tore away the barrier beach. Subsequent dredging operations in
1941 kept the lake open to the sea (Craig Kingsbury).
Farther in the past, Lake Tashmoo was salt. Dredging operations in
Tashmoo in the 'thirties showed that the fresh water marsh and cat tails
grew on white sand. Seven feet down was a layer of paired clamshells, upright,
indicating a natural clam flat that had died and been covered by the white sand.
Thus the food resources to be gained at Lake Tashmoo would have been
different in the past, depending on the presence or absence of sea water:
season runs of spawning fish when the Lake was fresh, and clam flats (mya
arenaria) and possibly oysters when the lake was open to the sea.
These food resources certainly would have attracted the native Americans
to Lake Tashmoo. In addition, springs on the western side of Tashmoo would have
provided a pure water source. (Sheet seep, or seeping springs on the east side
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would have been less attractive to the Indians.)
Thus it is no surprise that Indian sites have been found at Lake Tashmoo.
Massachusetts-Historical Commission files show a site numbered "9" at Kuffies
Point. The site records are incomplete and no further information is given. This
may be the site known to locals as the one "near where Mia Farrow lives."
Local sources also mention a site at the mouth or inlet of Lake Tashmoo.
This site would have been at least partially destroyed during dredging operations.
Apparently it was a stratified midden with Mya arenaria in abundance and a few
oyster shells in the lower levels. In the upper, more recent levels there was
fish and duck bone, but no clam, implying that the Lake was fresh water (Craig
Kingsbury).
The specific site under study lies some 1300 feet to the east of Lake Tashmoo,
at elevations of fifty to sixty feet. This distance limits the expectation of finding
a site or midden, for the sewage treatment plant site is too far from the water
to be a likely habitation site.
That the site might have been utilized as a cemetery remains a possibility.
V. CONCLUSIONS
No historic sites would be expected in the area under study for a sewage
treatment plant in Tisbury.
There is minimal potential for archaeological sites because of the absence
of fresh water; and because locations at nearby Lake Tashmoo provided not only
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abundant food resources, but also spring water.
No known site eligible for the National Register of Historic Places is
present on the sewage treatment plant site. It is therefore expected that
the proposed sewage treatment plant in Tisbury would not have an impact on
prehistoric or historic archaeological sites.
H/.
Charlotte W. Thomson, Ph. D.
Consultant in Archaeology
Newbury, Massachusetts
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MOUTH
X
p
MAP 1
80
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LOCAL RESIDENTS INTERVIEWED
Margaret Bergstrom, Executive Secretary, Board of Selectmen, Tisbury.
William Wilcox, Agricultural Agent, Dukes County and Nantucket, USSCS-
Cooperative Extension Service.
Nembhard Culin, President, William Street Historic Society.
Dukes County Historical Society.
Priscflla Webb, resident, Pine Street, Tisbury.
Rod Backus, Landscape Gardener, Pine Street, Tisbury.
Ruth Redding, Collector and Excavator of Indian Artifacts, Barnes Road,
Oak Bluffs.
Craig Kingsbury, Chairman, Board of Selectmen; Former Shellfish Warden.
James H.K. Norton, William Street Historic District, Study Committee.
Richard Burt, President, Martha's Vineyard Archaeological Society.
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BIBLIOGRAPHY
(ANDERSON-NICHOLS, Technical Consultant) Draft EIS Wastewater Collection
and Treatment Facilities Tisbury, West Tisbury and Oak Bluffs, Massachu-
setts. September 12, 1977.
ATLANTIC BORING CO., JNC. Boring logs, off West Spring Street, Tisbury.
June 28-30, 1977.
BANKS, CHARLES EDWARD. The History of Martha's Vineyard, Dukes County,
Massachusetts. Edgartown: Dukes County Historical Society, 1966.
BYERS, DOUGLAS S. and FREDERICK JOHNSON. "Two sites on Martha's
Vineyard." Papers of the Robert S. Peabody Foundation for Archaeology 1 no.
1. Andover, Massachusetts, 1940.
HUNTINGTON, E. GALE. "An Archaeological Study from Martha's Vineyard."
The Dukes County Intelligencer 1 no. 2, Edgartown, Massachusetts, 1959.
KAYE, CLIFFORD A. "Outline of Pleistocene Geology of Martha's Vineyard,
Massachusetts." U.S. Geological Survey Professional Paper 501C, Geological
Survey Research 1964, c!34-39. Washington, D.C., 1964.
"niinoian and Early Wisconsin Moraines of Martha's Vineyard, Massachusetts.
U.S. Geological Survey Professional Paper 50 1C, Geological Survey Research
1964, C140-43, Washington, D.C., 1964.
The Pleistocene Geology of Martha's Vineyard, Massachusetts. Itinerary for
the Friends of the Pleistocene, 27th Annual Reunion, May 23 and 24, 1964,
Katama, Martha's Vineyard, Massachusetts. U.S. Geological Survey,
Boston, Massachusetts, (mimeographed)
OGDEN J. GORDON, III. "Forest History of Martha's Vineyard, Massachusetts.
Modern and Pre-Colonial *<"-<** " Th« American Midland Naturalist 66 no.
2, 417-430. Notre Dame, Indiana, 1961.
RITCHIE, WILLIAM A. The Archaeology of Martha's Vineyard. New York: The
Natural History Press, 1969.
SHEPARD, FRANCIS P. "Sea Level Changes in the
Archaeological Significance." Science. 143 no. 3606, 574-76, New York,
1964.
j r* «m~/-'T ccwnRTH The Geology of Cape Cod and the
T B and E. WIGGLfcbWUKin. _uie^jcui^x - ^ - -- -. —
ndMLg. Harvard Museum of Comparative Zoology, Memo.rs
52, Cambridge, Massachusetts 1934.
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AUJS. GOVERNMENT PRINTING OFFICE: 1979 - A-1093/348
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