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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.
                         10

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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.
                                11

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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.
                            12

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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.
                               13

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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
                         14

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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,
                                15

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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.
                                16

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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.

                                17

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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.
                         18

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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
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V
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0
0
4
1
2
I
lity Location
•H
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1C
0
0
0
0
2
6
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-P
3:
O
e?
0
1
14
0
0
1
oric/Archaeologic
-P
CO
•H
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1
1
0
0
0
0
MATRIX
O
cx
C/3
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0)
o
2
0
1
0
0
0
tment Residual
(Tj
0)
EH
0
0
0
0
1
2
- DEIS
udicial Evaluation
Iternatives
'ft 
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                             TABLE 4
                 COMMENT/RESPONSE MATRIX - SDEIS









Issue



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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

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           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

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                   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

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      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

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                    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

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 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
***

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               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.

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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.

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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

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             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

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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

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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

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                   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

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                       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

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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

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                     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 •
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    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

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              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 •

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             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

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          APPENDIX B
  WRITTEN COMMENTS ON DRAFT
ENVIRONMENTAL IMPACT STATEMENT
              B-l

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                  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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                             -2-


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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                             -3-
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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                             -3-
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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                              -4-
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

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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.

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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/<

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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

-------
    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?

-------
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.

-------
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.

-------
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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                                             (3)

 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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                                          (4)

     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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                                     (5)

     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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                                      (6)

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




                                -2-

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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




                                -3-

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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




                                -4-

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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


                                -5-

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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




                                -6-

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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




                                -7-

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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

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 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.




                                -9-

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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.




                                -10-

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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.




                                -11-

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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.




                                -12-

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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




                                -13-

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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.




                                -14-

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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
                                -15-

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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




                                -16-

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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


                                -17-

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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




                                -18-

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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

                                -19-

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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




                                -20-

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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




                                -21-

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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




                                -22-

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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




                                -23-

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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




                                -24-

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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.




                                -25-

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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




                                -26-

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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,

                               -27-

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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




                      -28-

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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




                                -29-

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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.




                                -30-

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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




                                -31-

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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




                               -32-

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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




                                -33-

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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




                               -34-

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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




                                -35-

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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




                               -36-

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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




                                -37-

-------
 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




                                -38-

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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




                                 -39-

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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.




                               -40-

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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




                                -41-

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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




                               -42-

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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




                                -43-

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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.




                                -44-

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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




                                -45-

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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




                               -46-

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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




                                -47-

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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




                               -48-

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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




                                -49-

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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




                                -50-

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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




                                -51-

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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."




                               -52-

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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




                                -53-

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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




                               -54-
25

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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.




                                -55-

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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




                               -56-

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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.




                                -57-

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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

                                -58-

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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




                                -59-

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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




                               -60-

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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




                                -61-

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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




                               -62-

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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




                                -63-

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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

                               -64-

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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




                                -65-

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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


                                -66-

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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




                                -67-

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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-




                               -68-

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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




                                -69-

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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.




                                -70-

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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




                                 -71-

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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.




                               -72-

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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
                                 -73-

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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,




                               -74-

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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




                                -75-

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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


                                -76-

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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.




                                 -77-

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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.




                               -78-

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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




                                -79-

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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


                               -80-

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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




                                -81-

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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




                               -82-

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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




                                -83-

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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




                               -84-

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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




                                -85-

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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-




                                -86-

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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




                                -87-

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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




                                -88-

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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




                                 -89-

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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




                               -90-

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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.




                                 -91-

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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.




                                -92-

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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




                                -93-

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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.




                                -94-

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25
       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




                      -95-

-------
          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




                                -96-

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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




                                -97-

-------
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




                                -98-

-------
 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




                                -99-

-------
 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




                               -100-

-------
 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




                                -101-

-------
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




                               -102-

-------
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




                                -103-

-------
 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




                               -104-

-------
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




                                 -105-
19





20
24





25

-------
 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




                               -106-

-------
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




                                -107-
22





23





24





25

-------
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




                                -108-

-------
 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




                                 -109-
24





25

-------
  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




                                -110-

-------
 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.




                                 -Ill-

-------
 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.




                                -112-

-------
 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.




                                 -113-

-------
 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.




                                -114-

-------
 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




                                 -115-

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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




                                -116-

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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




                                 -117-

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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




                                -118-

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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



                                 -119-

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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.


                                -120-

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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.)


7


8


 9


10


11


12


13


14


 15


 16


 17


 18


 19


 20


 21


 22


 23


 24


 25
                                  -121-

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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




13




14




15




16




17




18




19




20




21




22




23




24




25





                              122
^  '^

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         APPENDIX F
ARCHAEOLOGICAL INVESTIGATION
                F-l

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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.
                               F-3

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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
                                    F-7

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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
                                   F-8

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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
                                     F-9

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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
                                   F-10

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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.
                                  F-12

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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.
                                    F-13

                    AUJS. GOVERNMENT PRINTING OFFICE: 1979 - A-1093/348

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