FINAL
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER COLLECTION
AND
TREATMENT FACILITIES
NEW MILFORD,
CONNECTICUT
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UNITED STATES
ENVIRONMENTAL
PROTECTION AGENCY
REGION 1
JOHN F. KENNEDY FEDERAL BUILDING • GOVERNMENT CENTER
BOSTON, MASSACHUSETTS 02203
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER COLLECTION AND TREATMENT FACILITIES
NEW MILFORD, CONNECTICUT
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region I
JFK Federal Building
Boston, Massachusetts, 02203
Technical Consultant
Anderson-Nichols & Co., Inc.
Boston, Massachusetts
Environmental Protection Agency
Region I
Prepared by
Approved by:
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SUMMARY AND RECOMMENDATIONS
Final Environmental Impact Statement
U.S. Environmental Protection Agency
Region I
Boston, Massachusetts
1. NAME OF ACTION
Administrative (x)
Legislative ( )
2. SUMMARY
Since the circulation of the Draft Environmental Impact
Statement in early January, the Environmental Policy Coor-
dination Office of the Environmental Protection Agency has
received considerable public input through workshops, a
public hearing, and comments submitted during the formal
review period. The purpose of this document is to respond
to the public comments and make the final recommendations
for the New Milford project.
The recommended project is basically that which was pro-
posed in the Draft EIS as ALTERNATIVE IV, with several
conditions.
The project calls for construction of a 4.0 MGD
treatment plant.
In light of the concern that was expressed by some, the
size of the plant was reviewed along with several alterna-
tives. Only this size plant will accommodate the anticipated
needs of New Milford and Brookfield over the next twenty
years.
The collection system will be expanded to the north along
the East Aspetuck River to the area of Hipp Road, north
along the west bank of the Housatonic River to Candlewood
Lake Road North, and south along Route 7 and the Pickett
District Road to the treatment plant site. An interceptor
is also to be constructed to the Lanesville area for future
connection with Brookfield.
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The basic elements of the collection system are
shown as Stage I construction on FIGURE 12 of the
Draft EIS.
One item that should be noted is the capacity of the East
Aspetuck Interceptor. The conclusion of the Draft EIS that
there are no present or anticipated sewerage needs north of
Hipp Road is maintained. It should be noted, however, that
one statement of the Draft EIS concerning the physical
dimensions of the line is incorrect. Sizing of the inter-
ceptor to serve only the area south of Hipp Road will result
in the reduction of the pipe size due to the elimination of
about 1 MGD of anticipated flow from north of Hipp Road.
The process that was originally proposed for the New Milford
treatment plant was reviewed in terms of its reliability,
adaptability, and general suitability for serving the area's
wastewater treatment needs.
The Carrousel process is recommended as an appro-
priate secondary level treatment process that can
be adapted for phosphorus removal if this becomes
necessary.
Since the publication of the Draft EIS, additional informa-
tion has been secured on the process which verifies the
original analysis of this process.
Ultimate sewerage needs exist in the Stage II and Stage III
areas, as designated in the Draft EIS. The degree of need
varies, however, and prioritizing of these additional
elements should be done. In BrookfieId in particular,
where public debate has been generated over the town's
development plans, areas of existing need were identified
which should be served by the New Milford system. At this
time, however, no routings within Brookfield have been
formalized by application for EPA grants.
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EPA approval of future funding for Stage II and
Stage III expansions of New Milford's and Brookfield's
collection systems will be contingent upon the de-
velopment and coordination of land use and sewer plans
in a growth management program in the two towns.
This EIS gives approval only to the proposed 4.0 MGD treatment
plant and Stage I interceptor sewer construction. It is
repeatedly emphasized in the responses to many growth related
questions that any sewer extensions beyond Stage I must be
in accord with development and growth management plans of
both New Milford and Brookfield. To ensure compliance, EPA
will as part of its contract with the Town of New
Milford for the construction of Stage I facilities,
require that coordinated land use and sewer plans be developed
for both New Milford and Brookfield before any grant funds
will be advanced for Stage II or Stage III interceptor con-
struction.
The phosphorus removal process has been reviewed both in
terms of its need and its adaptability to the Carrousel
process.
Phosphorus removal at the New Milford plant is not
recommended at this time.
The whole phosphorus problem is under review on a basin-wide
basis by Connecticut DEP, the legally responsible agency.
The results of the Danbury pilot project will put the agency
in the best position to make an enlightened decision regard-
ing the most effective approach to the phosphorus problem
of the Housatonic River.
Since the publication of the Draft EIS, the Housatonic River
has been studied by the Bureau of Outdoor Recreation to
determine its eligibility for designation as a Wild and
Scenic River. The study concluded that the area from the
Boardman Bridge in New Milford to the Shepaug Dam at the
southern end of Lake Lillinonah does not qualify due to
existing development and its restricted flow. However,
the agency may assist the region and local towns in deve-
loping land management plans.
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The New Milford treatment plant will be constructed
to conform with the BOR recommendations regarding
aesthetic screening from view from the river.
EPA and BOR, and the Town of New Milford consultants have
met to discuss the actual redesign requirements that will
be necessary.
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TABLE OF CONTENTS
Section
Title
Page
GENERAL INTRODUCTION
1
1.00
NEED
7
1.10
INTRODUCTION
7
1.20
DETAILED PROBLEM EXAMINATION
7
1.21
Septic System Problems
7
1.22
Evidence of Pollution
14
1.23
Route 7
16
1.24
Growth Projections
16
1.25
Small Scale Alternatives
17
1.26
Present Zoning
17
1.27
Housing
18
1.28
Orders
19
2.00
SIZE OF PLANT
23
2.10
INTRODUCTION
23
2.20
DETAILED PROBLEM EXAMINATION
23
2.21
4.0 MGD Plant Capacity
23
2.22
Smaller Scale Alternatives
25
2.23
Future Industrial Flows - Nestles
26
2.24
Service Area
27
2.25
Brookfield-Danbury Connection
28
2.26
Exact Plan
29
3.00
INDUCED GROWTH
31
3.10
INTRODUCTION
31
3.20
DETAILED PROBLEM EXAMINATION
32
3.21
Character of Town
32
3.22
Agriculture
33
3.23
Schools
34
3.24
Other Services
35
3.25
Lack of Planning
36
3.26
Route 7
37
3.27
Amount of Growth Induced
37
3.28
Who Determines Growth
38
3.29
Population Projections
39
3.30
Industrial Development
40
3.31
Down-Zoning
40
3.32
Developers
42
3.33
House Prices
43
i
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Section
Title
Page
4.00
COSTS
45
4.10
INTRODUCTION
45
4.20
DETAILED PROBLEM EXAMINATION
46
4.21
Connection Costs
46
4.22
Tax Burden
46
4.23
Validity of Cost Estimates
47
4.24
Cost Apportionment
47
4.25
Ability to Pay
49
4.26
Secondary Costs
49
4.27
Funding and Eligibility
50
4.28
Carrousel Costs
50
4.29
Tertiary Treatment
51
4.30
Cost Effectiveness
51
5.00
TECHNICAL
53
5.10
INTRODUCTION
53
5.20
DETAILED PROBLEM EXAMINATION
53
5.21
Land Application
53
5.22
Phosphorus Removal/Level of
Treatment
59
5.23
Carrousel Process
63
5.24
Nestles
76
5.25
Plant Site
7 8
5.26
Flooding
79
5.27
Air Pollution
81
5.28
Nitrates and Nitrate Removal
82
5.29
Solid Waste
84
5.30
I/I and Separation of Sewers
86
5.31
Energy
88
5.32
System Reliability
89
5.33
Sewers in Watershed
89
5.34
Odor
92
5.35
Groundwater and Water Supply
93
5.36
Noise
97
5.37
Construction
98
6.00
MISCELLANEOUS
99
6.10
INTRODUCTION
99
6.20
DETAILED PROBLEM EXAMINATION
99
ii
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Section
Title
Page
6.21
Wild and Scenic Rivers Study
99
6.22
PL 92-500 Compliance
101
6.23
Candlewood Lake as Water Supply
103
6.24
Lake Tahoe Study
104
6.25
Archeology
104
6.26
Industrial Pollution
106
6.27
New Fairfield Options
107
APPENDIX A Second Round of Workshops
APPENDIX B Public Hearing
APPENDIX C Written Comments
iii
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LIST OF TABLES
Table No. Title Page
1 Comment/Response Matrix 5
2 Soil Types of Areas of
Existing Need - New Milford 10
3 Soil Types of Areas of
Existing Need - Brookfield 12
4 Soil Types in the Candlewood
Lake Club Area 14
5 Soils in the Route 7 Area 15
6 Estimates of Flows 24
7 Carrousel Experience 65
8 Comparison of Secondary
Treatment Methods 7 3
9 Components of Nestles'
Wastewater 78
10 Guidelines for Groundwater
Exploration Program 95
11 Housatonic River BOD Loading 102
IV
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GENERAL INTRODUCTION
The purpose of this document is to summarize the written
comments that were received after circulation of the
Draft Environmental Impact Statement and, as required by
the regulations published April 14, 1975 in the Federal
Register, to report on the analysis which has taken place
as a result of the review process, and to make a definitive
Final Environmental Impact Statement of the project which
is recommended by the Environmental Protection Agency.
After publication of the Draft Environmental Impact State-
ment for the New Milford project in early January 1977,
over 400 copies were circulated to citizens and groups that
had requested them, and to local, regional, State, and
Federal officials and agencies. The official date of sub-
mission to the Council on Environmental Quality was on Jan-
uary 21, 1977. The official review period during which
written comments could be submitted to EPA lasted 45 days,
until March 7. This comment period was extended fifteen
days at the request of the Bureau of Outdoor Recreation.
Formal notice of a public hearing, held in New Milford on
February 15, was published in the New Milford Standard
Times.
Also, the second set of workshops were scheduled in the
local communities on the following dates:
Washington - January 31
New Milford - February 1
Brookfield - February 2
New Fairfield - February 3
Notice of these workshops appeared in local newspapers
during the preceding week. The workshops provided citi-
zens with the opportunity to disucss their reactions to
the Draft EIS informally, and to discuss the implica-
tions of the recommended project on the individual communi-
ties. It also provided a forum in which to discuss re-
lated local events which had occurred during the final
stages of writing the EIS which might affect the even-
tual outcome of the final report.
In Washington, the workshop was only lightly attended by
perhaps a half dozen residents. Those present, however,
included members of town commissions who were knowledge-
able in terms of the activities of the town. They con-
curred with the EIS findings that the villages of New
1
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Preston and Marble Dale should not be included in a sewer
construction plan. They also informed EPA that the "up-
zoning" of the Marble Dale section had already occurred
and that a general up-zoning based on soil capabilities
had been prepared for acceptance at Town Meeting. Other
concerns expressed were the potential water quality prob-
lems at Lake Waramaug and the feeling that the New Mil-
ford project would have impacts on their community even
if they were not directly included.
In New Milford the workshop was attended by about sixty
residents. In general the participants felt that the ser-
vice area of the proposed project was too large. They
felt that both existing and future needs were overstated.
They continued to question whether Brookfield and Nestles
should participate. They felt that the growth-desire of
the community had been overstated. It was also felt that
subsurface disposal problems could have been avoided by
stricter enforcement of existing health codes.
Opinion was mixed regarding the value of additional
planning work prior to Stage II construction. Some felt
it should definitely be done while others repeated their
concerns about the possibility of down-zoning. No sup-
port for linking sewer development to industrial or com-
mercial development was expressed. Some wished to limit
such activity to the existing service area so long as it
did not harm "town character." Others expressed a de-
sire for "clean" industry only.
The majority favored additional independent study of land
application for a reduced service area. Some voiced con-
tinued skepticism of the Carrousel process in terms of its
newness, its adaptability for phosphorus removal, and the
general question of why the process was chosen.
The second Brookfield workshop was also attended by about
sixty people. In general, those present objected to the
format that had been planned and pressed instead for ans-
wers to a multitude of questions. Without a systematic
focus for which the format was intended, the discussion
became antagonistic both toward EPA ( and its consultants) and
among local citizens and officials. Some of the confusion
could possibly be attributed to release of a consultant's
report several weeks earlier which recommended an alter-
native to the plan submitted in the EIS of serving areas
of immediate need in Brookfield by transport of sewage to
Danbury. This recommendation conflicts with the findings
of the Draft EIS.
2
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During the general discussion, which included consider-
able argument among local residents, a number of issues
were raised. A sizable group of residents from the shore
area of Candlewood Lake questioned the need for sewering
the area. They felt that none of the studies done, in-
cluding the recently completed Draft EIS and the indepen-
dent Albertson, Sharp & Backus study, could prove that
sewer needs exist.
Many questioned the compatibility of state and local plann-
ing goals for development of Route 7 with current com-
munity desires. Considerable hostility toward local
officials concerning future plans for the community was
expressed.
In New Fairfield, the second workshop was attended by
about twenty local residents. Those present generally
agreed with the recommendations of the Draft EIS. All
reported that they saw no need in New Fairfield for a sewer
system in the foreseeable future and that local planning
and sanitary code enforcement would be adequate to cope with
future wastewater treatment needs. While all were firm in
their evaluation of no sewerage need, they agreed if it
were found that western areas of New Fairfield developed
a need for sewerage system then connection with nearby towns
in eastern New York should be explored. Most felt that the
local codes were adequate for their future needs. Some
felt that enforcement could be more rigorous. Two com-
ments concerning technical analysis contained in the EIS and
future implications of the EIS recommendations were read
by individuals and submitted as written comments.
On February 15, 1977 the formal Public Hearing was held in
the High School Auditorium in New Milford. Approximately
three hundred people attended. After brief comments by
representatives of EPA, a summary of the Draft EIS was
read into the record. Twenty-eight people read statements
which were entered into the official record of the hearing.
In accordance with EPA regulations contained in the April
14, 1975 Federal Register, the comments have been summarized
and the issues that have been identified will be responded to
on a point-by-point basis. The major issues that were raised
are the main section headings in the preceding outline. They
are:
(1)
(2)
(3)
Need for Sewerage
Size of Treatment Plant
Growth Predictions and Implications of Growth
3
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(4) Costs
(5) Technical Questions
(6) Miscellaneous
TABLE 1 summarizes,, in terms of source, the number of
comments that focused on these major categories. As an
example, of the individuals who responded from New Milford,
twenty-five raised questions related to "Growth". In the
sections that follow, within each major category, specific
questions will be stated, their source identified, and a
response made. For example, under the major section "Need,"
a number of individuals raised questions concerning the ex-
tent of septic system failures. In Sub-section 1.21
the sense of the questions is stated followed by source or
sources, appearing as coded numerals. The list that cor-
responds to the code is contained at the beginning of AP-
PENDIX B and C. Following the question is the reply.
This supplement, in combination with the Draft Environmen-
tal Impact Statement constitutes the Final Environmental
Impact Statement for this project. The basic environmental
inventory is contained in the Draft EIS. In the course of
the environmental review the basic recommended alternative,
ALTERNATIVE IV, the Local Regional Alternative, has been
retained. Because of the geographical scope of the pro-
ject area, the number of issues identified, the breadth of
controversy, and the degree of public envolvement, it was
decided that the separate printing of the responses
would enable an individual to find those specific issues
which are of interest to him without having to search through
a large volume of unrelated material.
In the sections that follow sources are identified by coded
numbers which are representative of the comments that were
received. While an attempt was made to identify all the
sources of each comment, some individuals may have been in-
advertently ommitted. The sections are, however, representa-
tive of all the comments received.
4
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TABLE 1
COMMENT/RESPONSE MATRIX
NEW MILFORD
rH
(0
Issue
0
.,-1
-P
w
c
T3
N
o
CQ
0
CD
S
•H
CO
u
0
u
0
Eh
-P
Q
Federal Agencies
0
0
2
0
6
5
State Agencies
0
0
0
0
1
1
Regional Agencies
0
0
0
0
0
0
Local Agencies
New Milford
0
0
0
0
1
0
Brookfield
1
0
0
0
0
0
Other
0
1
0
0
3
0
Organizations
New Milford
2
1
0
2
4
0
Brookfield
6
2
6
5
5
1
Other
1
3
5
0
10
2
Individuals
New Milford
12
15
25
22
31
2
Brookfield
4
4
5
5
8
1
Other
1
1
9
3
14
5
Hearing
10
7
11
8
26
4
Source: Environmental Protection Agency,1977.
5
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1.00 NEED
1.10 INTRODUCTION
Many respondents wanted further evidence of the basic need
for the proposed project. Some expressed doubts fch&t the
problems were as extensive as the Draft EIS suggested, while
others demanded "proof" the septic failures were prevalent,
given their belief that water quality in the area was "ex^
cellent." In the following sections, the methodology that
was used to arrive at the definition of problem areas is
discussed.
Other questions in this section dealt with the documenta-
tion of future needs, especially when the local population
projections have been the subject of considerable public
controversy. Some referred to the fact that the fate of the
proposed Route 7 extension was uncertain at this time.
Some questioned the need to provide service for expanded
housing opportunities.
A number of people held the belief that solutions other
than the sewerage plan would effectively alleviate their
problems. However, pumping of systems was usually thfe
only method that was recommended. An explanation of why
this approach was considered inadequate follows:
1.20 DETAILED PROBLEM EXAMINATION
1.21 Septic System Problems
a Comment: (R19, R23, R30, R39, R47, R51, H6, H21, H26)
Septic system problems are not serious or wide spread.
Problems can be solved without sewering.
Response:
The basic methodology that was used for the identifica^
tion of problem areas was the comparison of soil
types with existing and proposed development. This
information was supplemented with histories of spe-
cific areas as recounted by Town Sanitarians and work-
shop participants. In addition, several field exam-
inations of areas throughout the towns were conducted
by the EIS consultants. Finally, the problem had
been discussed in the towns previously, and had been
reported in a variety of forms which had to be inte-
grated into a final evaluation.
7
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In New Milford, the degree of the septic system prob-
lem was represented by the three phases of proposed
sewering. In the Stage I area, the basic problem
areas were the East Aspectuck: River Valley and the
Sunny Valley area. In these areas there is existing
small lot development and apartment development on
soils that have significant limitation for septic
system use. Initially, by comparing the soils suit-
ability (which is represented by FIGURE 5 in the
Draft EIS) with the Existing Land Use Map (Technical
Planning Associations 1971), and the Zoning Map of
New Milford (TPA 1974), it became obvious that the
density of large areas of existing development greatly
exceeded the recommended densities based on soils
suitability. On FIGURE 5 of the Draft EIS, the recom-
mended densities are Class I—1 family per acre,
Class II—0.75 families per acre, and Class III-'-
0.5 families per acre. Thus, the dark brown color
represents the best soils; the white indicates the
worst. Much of the existing development consists
of 8,000 square foot lots on Class II and Class III
soils. Included are the following areas: Mountain
View Drive, Russeling Ridge, Avery Road, Park Lane
West, and Taylor Terrace.
Because many of these specific areas are on muncipal
water, the classification of soils capability that
was adapted from the Updating Plan of Development
(above) is not totally representative. Therefore,
the original SCS soils publications for New Milford
(Litchfield County) and Brookfield (New Fairfield
County) were consulted. In the East Aspetuck Valley
area, numerous soil types are found but their use is
limited. For example, considerable areas are Paxton
soils. These are characterized by a hardpan layer
which severely limits the use of septic systems.
Even with municipal water and sewer, the lot size
recommended by SCS for this soil type is 25,000 to
30,000 square feet. This soil type constitutes
about 60% of that found in the Park Lane area and is
prevalent elsewhere in the general area. Farmington
soils, on the other hand, are severely limited due
to shallowness. In the Mt. View Drive.area, 50%
of the soil is Farmington.
Throughout the East Aspetuck River area similar con-
ditions are found. The fact is that under SCS guide-
lines for even the best soils, 20,000 square feet is
8
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the minimum lot size for septic system use even where
public water supply is available. By this standard,
8,000 square feet lots would be judged to be un-
reliable for continued septic use. The actual soil
types and their limitations for this purpose is
given in TABLE 2. The basic problem in the Stage
I areas is that of intense development, both single family
and apartment building, which cannot rely on septic
systems indefinitely. APPENDIX A in the Draft EIS
discussed the minimum lot size under zoning regula-
tions that would conform to current standards of the
Connecticut Department of Health Sanitary code.
With on-site water 20,000 square foot lots are not
adequate even on good soils. With public water,
20,000 square foot lots would be suitable for septic
disposal only on good soils. Using these current
guidelines, it is readily concluded that the sewering
of these areas contiguous to the existing sewer sys-
tem would be the most logical long-term answer to
waste disposal problems.
The areas mentioned in the previous paragraphs were
also described by both the Town Sanitarian and by the
public at the workshops. The apartment units were
frequently cited as problems although excess flows,
rather than soil limitations, were blamed as the culprit.
In many instances steps have been taken at specific
lots to remedy acknowledged problems. These steps
included building up leaching fields where soils
are thin and placing curtain drains where ground-
water is high. While these renovations may improve
septic operation on a particular lot, they do not
mean that the area's problems no longer exist. On
most soils, problems will be encountered within a
twenty-year period from construction due to eventual
clogging (Hill, 1974). In the case of pre-1970 de-
velopments, many do not have any reserve area in
which to build another leaching field. In these cases
replacement of soil in the existing leaching field
would be necessary.
In Brookfield, the area of immediate sewerage need is
along the shore of Lake Candlewood. Specifically,
the developments of Candlewood Shores, Arrowhead
Point, Pleasant Rise, and Meadow Brook have been
repeatedly described as areas of septic system prob-
lems. These areas have been identified by the Town
Sanitarian as areas that have frequent septic failures.
9
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TABLE 2
SOIL TYPES OF AREAS OF EXISTING NEED
-NEW MILFORD-
Area
Type
Limitation
SCS Rating
Russeling Ridge
Mt. View
Park Lane
High View
Taylor Terrace
Sunny Valley
Farmington
50
bedrock
severe
Kendara
15
high water table
severe
Amenia
15
hardpan
severe
Dover
20
none
favorable
Paxton
50
hardpan
severe
Farmington
15
bedrock
severe
Merrimack
15
none
favorable
Leicester
10
high water
table
severe
Woodbridge
10
hardpan
severe
Paxton
70
hardpan
severe
Amenia
20
bedrock
severe
Dover
10
none
favorable
Paxton
50
hardpan
severe
Farmington
20
bedrock
severe
Dover
10
none
favorable
Tisbury
20
high water
table
moderate
Paxton
60
hardpan
severe
Ridgebury
10
hardpan
severe
Borrow
30
~'
variable
Dover
15
none
favorable
Hartland
15
hardpan
.severe
Hero
5
high water
moderate
Farmington
5
bedrock
severe
Copake
20
slope
moderate
Raynham
5
high water
severe
Windsor
15
none
favorable
Groton
5
slope
moderate
Gravel Pits
15
-
-
Source: U.S. Soil Conservation Service, Soils Survey of
Litchfield County, 1970.
10
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In addition to the soils information that will be
discussed in the next paragraph, these problem areas
have been verified by other recent studies includ-
ing an actual field inspection at the Candlewood
Shores by the Town Sanitarian.
The areas previously mentioned consist of extensive
small lot development on mostly Class II and Class
III soils as shown on FIGURE 5 in the Draft EIS. On
the protrusion of land where Candlewood Shores is lo-
cated there are over 500 homes, most of which are
built on 7,000 square foot lots. As in New Milford,
the direct comparison of the 1.5 to 2.0 acre lot re-
quirements of the classification system, is not totally
legitimate since the homes are on a central water
supply system. However, on the Shores, the source
for the water supply is within the development.
When the detailed soil types are analyzed it is
readily apparent that those lots are far too small
to support acceptable subsurface disposal systems.
The whole area is comprised of Paxton and Woodbridge
soils, both of which have serious limitation for
septic system use due to a hardpan layer. Even
with municipal water, the soil limitations are rated
as very severe by the SCS. The soil types for other
general areas are given in TABLE 3.
In addition to the soils information concerning the
shore area, other sources point to the immediate needs
that exist in that area. In 1975 a visual inspection
by the Town Sanitarian revealed that 17.4% of the sys^
tem had some type of visual problem, 50% of which were
considered to require extensive repair.
An additional aspect is the "proof" of septic system
problems in the study area. Because of the incomplete-
ness of local records it is necessary to rely on the
recollections of individuals such as the Town Sani-
tarian to collaborate local history with the analysis
of soils. The records that do exist usually go back
less than ten years and only distinguish between new
constructions and repairs. No information on con-^
yersions of summer homes to year round residences
(a reason commonly cited as the one-time cause of
"problems') is readily available. Finally, the
existing records are probably only the "tip of the
iceberg"; many actual problems are likely not to ap^
pear in the files because "repairs" may be done without
11
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TABLE 3
SOIL TYPES OF EXISTING AREAS OF NEED
-BROOKFIELD-
Area
Type
Limitation SCS Rating
Candlewood Shores
Pleasant Rise
Paxton 70
Woodbridge 15
Ridgebury 5
Borrow 5
Hollis 5
Paxton 50
Woodbridge 35
Hollis 15
hardpan
hardpan
hardpan
bedrock
hardpan
hardpan
bedrock
severe
severe
severe
variable
severe
severe
severe
severe
Meadow Brook
Hollis
Borrow
Hinckley
35
25
25
bedrock
Farmington 15 bedrock
severe
variable
moderate
severe
Source: U.S. Soil Conservation Service, Soils Survey of
Fairfield County, 1976.
permits and enforcement is enacted only in the most
flagrant cases.
The local records are not unusual in their inability
to provide conclusive "proof" of septic system prob-
lems. They typically show the date and location of
new construction as well as significant reconstruction.
They are usually cross-referenced with a file which
may contain "as built" sketches. The official record
does not, however, record pumpings, indicate complaints,
or describe the nature of the problem that may have
occurred. Most likely this is the result of a short-
age of manpower and unwillingness to be too harsh on
the part of the town boards of health, as well as a
general lack of interest on the part of the public in
the past.
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The lack of complete and comprehensive data which
will "prove or disprove" the need for sewers has led
some to conclude that, therefore, there is no problem.
The advocates of this view demand a level of detail
which does not exist, and in some instances serve
only to create a stalemate. In the absence of complete
data, reasonable judgements must be made from par-
tial data sets.
• Comment: (R2 0)
Candlewood Lake Club is in no way a problem area that
would require sewering.
Response;
Sewering in the area of this development was not in-
cluded as part of Stage I at the New Milford pro-
ject. However, because of the number of homes on
small lots, on poor soils, and the proximity of the
whole development to Candlewood Lake, it has been
included within the proposed Stage II service area.
No time schedule has been proposed for this expan-
sion of the system. Connection of the area could be
effected by the ultimate route of the system to
Brookfield. Given the uncertainity of the direction
that the interceptor will take to Brookfield (the
town has not submitted a Step I Plan) and the recom-
mendations that expansions beyond Stage I be reviewed
in terms of priority it could be twenty years before
this area is sewered. At this point only capacity in
the main trunk elements is being provided as part of
the proposed project.
The basis for the determination of need is similar
to that used elsewhere in New Milford and Brook-
field. The area consists of several hundred existing
homes on small lots. Despite the additional land
holdings at the club; house lots—the actual site
for leaching fields—are small. While some lots are
larger than 20,000 square feet, many are under 10,000
square feet. The soils are predominantly Paxton
and Woodbridge which are poorly drained (See TABLE 4).
These same soil types coupled with steep slopes
also make the use of community septic systems im-
practical .
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TABLE 4
SOIL TYPES IN THE CANDLEWOOD LAKE GLUB AREA
Type
Percent
Limitation
SCS Rating
PbB (Paxton)
35
Hardpan
Severe
PbD (Paxton)
35
Hardpan
Severe
PeC (Paxton)
10
Hardpan
Severe
WxB (Woodbridge)
10
Hardpan
Severe
WzC (Woodbridge)
10
Hardpan
Severe
Source: U.S. Soil
Conservation
Service, Soils
Survey of
Litchfield (1970) and Fairfield (1976) Counties.
The soils identified above are representative of the
other shoreline area that was included as part of
Stage II at the New Milford project. Because of exist-
ing development in these areas, eventual sewering
was recommended.
• Comment: (R48, R49, R51)
Sewers are not needed in the Route 7 area of Brook-
field because of lack of development and the good soils.
Response:
The existence of only limited areas of existing need
in the Route 7 corridor has been stated in the Draft
EIS. Ultimately, however, if the area is to be in-
tensively developed as suggested by the General Pur-
pose Zone, then sewering will be necessary.
The soil types are described in TABLE 5. While some
have only limited problems with percolation, these,
too, could present potential pollution problems due
to improper treatment due to rapid drainage.
1.22 Evidence of Pollution
• Comment: (R19, H5)
The water quality in Candlewood Lake is excellent#
Therefore, there is no need for sewers.
Response:
The reply to the question is complicated by demands
of "proof" noted earlier. Water quality is only sampled
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TABLE 5
SOIL TYPES IN THE ROUTE 7 AREA
BROOKFIELD
Type
Percent
Limitation
SCS Rating
Agawam
5
Slight
Hinckley
2
-
Moderate
Hinckley-Windsor
5
Slopes
Severe
Hollis
30
Bedrock
Severe
Rockland
10
Shallow
Severe
Charlton
1
Slope
Severe
Farmington
25
Bedrock
Severe
Windsor
1
-
Slight
Merrimac
1
-
Slight
Borrow
5
-
Variable
Gravel Pits
15
—
Variable
Source: U.S. Soil Conservation Service, Soils Survey of
Fairfield County , 1976.
at a limited number of points during a portion of
the year, several times a month. Therefore, con-
clusive evidence that a specific area is causing
massive pollution cannot be found. However, con-
sideration of several facts leads to the reasonable
judgement that intensive lake shore development is
polluting the lake.
Water quality in Candlewood Lake is far superior to
that at the Housatonic and Still Rivers. It is,
however, not pristine; the data that does exist shows
that coliform levels are occassionaly high. To ar-
gue that no pollution is occurring when septic
systems fail at a high rate on soils where it has
been demonstrated that their useful life is five to
ten years is not reasonable. On soils such as the
Paxton type where hardpan and steep slope result in
rapid travel directly to the nearby lake, intensive
year-round development is obviously degrading water
quality.
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1.23 Route 7
• Comment; (R14, R19, R22, R51, Hi, H5, H15)
Sewering is endorsed in the Route 7 corridor for
both economic and environmental reasons (to protect
water resources) and questioned because impacts are
not "addressed adequately."
Response:
The Draft EIS does not formally endorse sewering
in the Route 7 corridor in New Milford and Brookfield.
The planning and zoning for the Route 7 corridor in
both New Milford and Brookfield, however, calls for
development which either will require sewering or will
be attracted to the two towns by the availability of
sewers. These include industrial and commercial develop-
ment in New Milford and industrial, commercial, and
multi-family development in a General Purpose Zone in
Brookfield.
The Route 7 corridor area would be served by Stage
II and III of the proposed interceptor sewer system
as presently designed for New Milford. Plans for the
routing of interceptor sewers to serve need areas in
Brookfield have not as yet been finalized.
As subsequently noted in Section 3.25, re-examination
of planning for Stage II and III is necessary be-
fore any sewer extensions are approved in the Route 7
corridor.
EPA will, as a part of its contract with New Milford
for the construction of wastewater treatment and
collection facilities, require that coordinated land
use and sewer plans be developed for both New Milford
and Brookfield before any grant funds will be advanced
for Stage II or III interceptor construction.
1.24 Growth Projections
• Comment: (R51)
Rationale for a sewerage system is based not on current
needs but on projected needs which are presumed to be
based on outdated population projections.
16
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Response;
The proposed system is designed to serve both exist-
ing needs and future needs as contained in the plan^
ning and zoning documents of New Milford. and Brookfield.
As subsequently noted in Section 3.29, the population
projections have been developed in recognition of re-
vised estimates of growth for both the New York re-
gion and the State of Connecticut. The Danbury re-
gion, however, is one of the growth areas of Connec-
ticut and is located in the peripheral environs of
the New York metropolitan area where growth is ex-
pected to continue.
1.25 Small Scale Alternatives
• Comment: (R18, R19, R20, R24)
Problem areas can be eliminated by means other than
sewering.
Response:
The comment would be more appropriate in solving iso-
lated problems of individual homes. When considerable
numbers of homes have been built under more casual
standards of the past, the short-term solutions that
are commonly recommended (such as pumping, which only
temporarily alleviates severe chronic problems) are
inappropriate. On the other hand, small scale struc-
tural solutions in a number of large areas of develops
ment would be difficult to manage and would not guaran-
tee long-term water quality protection. This general
topic is discussed also in Section 2.22.
1.26 Present Zoning
» Comment: (39, R4 6)
Raises concerns that zoning should be revised to con-
form to the proposed plan for sewering.
Response:
Several comments refer to a statement on page 211 of
the Draft EIS, "that the Updating Plan of Development
be revised to match residential densities with pro-
posed sewer service areas". The intent of this state-
ment has been misunderstood.
17
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In concert with a number of recommendations in the
Draft EIS it is recommended on page 219 of the Draft
EIS that "The Plan of Development, rather than a sewer
facilities plan, should be the guide for any growth
subsequent to Stage I". Down-zoning is suggested as
an option for one or two areas in New Milford where
it may be necessary to extend sewers through land now
zoned for large lots to serve sewer need areas. Such
options are suggested for consideration. They are
not recommendations of the Draft EIS.
Problems of extending sewers to need areas are com-
plicated by the fact that much of New Milford's develop-
ment occurred prior to the fairly recent enactment of
zoning. This led to some scattered small lot develop-
ments which will require sewer service.
1.27 Housing
e Comment: (R29, R54)
Sewers are not necessary to serve housing for the
elderly and other types of multi-family housing.
Response:
Sewer service to multi-family housing is consistent
with the objective of the Updating Plan of Development
to concentrate new housing development near New Milford's
town center. It is also consistent with the following
quotation from page 8.12 of the Updating Plan:
"Because of their major impact on development
patterns, the location and staging of sewer
extensions are integrally linked to the work
of the Planning and Zoning Commissions. An ex-
ample is the location of future multifamily de-
velopments. The Land Use Plan anticipated 25%
of new residential construction to be multiple
units. As these will require water and sewer
connections, appropriate areas are designated
on the Plan within the proposed sewer service
area. However, extension of utilities will be
a gradual process over the next twenty years so
that zoning designation of the multifamily areas
will be phased with the availability of utilities.
Close coordination and exchange of information be-
tween the Commissions will, therefore, continue to
be essential."
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1.28 Orders
• Comments: (R19, R22, R48, H18, H24, H26)
The State of Connecticut Department of Environmental
Protection pollution abatement orders are vague and
without basis.
Response;
The actual orders themselves, which were issued to
New Milford and Brookfield in 1967, and have been re-
vised several times since then, do not clearly and
totally reveal the whole DEP process which developed
out of the mandate of the Connecticut Clean Waters
Act of 1967. In order to develop an understanding of
the relationship of the State Order and the New Milford
project, it is necessary to reconstruct almost ten
years of discussions, issues, and events that have
occurred among the communities of Washington, New
Fairfield, New Milford, Brookfield, their consultants,
and the State DEP. That history must be gleened from
published reports and discussions as well as the ac-
tual orders themselves.
The original orders were issued to the Towns of New
Milford and Brookfield because they were found to be
municipalities "within which a community pollution
problem exists". No specific problems or evidence of
pollution is mentioned in these orders. These initial
orders, for the most part, are also general in their
language with respect to what steps the towns were
to take to provide for wastewater treatment. Only
in Brookfield was a specific requirement stated.
A sewage treatment facility was to be constructed and
sewers were to be planned for the southern-most sec-
tion of Route 7 with discharge to Danbury. The gist
of these two orders was that the towns were to provide
a plan for sewerage needs that would provide for future
needs. These plans were required to give special
attention to specific areas within the individual town
and to provide capacity for areas outside the town
which might be logically served. To understand the
proposal project one must dig more deeply into the
matter.
From conversations with the Connecticut DEP, the follow-
ing understanding of the "orders process" was derived.
First, the original orders were deliberately vague in
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terms of their actual requirement for the towns so
that the communities could develop their own plans.
The reason for the orders was that in the judgement
of that agency, based on its familiarity with the area
and its responsibilities under the Clean Waters Act,
that there were water quality problems in these com-
munities. It is the Department's position that they
have the legal power to issue the order, and that fail-
ure of the local community to appeal these orders in
the prescribed time period constitutes acceptance.
Thus, the validity of the original orders is more a
legal question than a scientific or engineering ques-
tion, and as such, cannot be resolved in the EIS.
The development of subsequent specific orders is based
on the following reasoning by DEP. After the initial
orders, the towns engaged engineering firms to
analyze their local problems and develop plans. Ac-
ceptance of the town's plan by the State means that
the plan becomes the basis for further orders which
commit the towns to a timetable for implementation
of specific steps of the plan. In some instances the
DEP construed their orders to be "friendly orders,"
a mechanism by which the desires of the towns could
be formalized in a contractual arrangement.
Thus, subsequent orders were developed to implement the
recommendations of the towns' consultants. In this
light, the series of orders that relate to the New
Milford project appear as logical refinements and
timetable revisions and not the seemingly contra-
dictory "orders-counter orders" situation described
by some project objectors. The only order that was
drastically changed was that which would have had
New Fairfield participate in a financing arrangement
with Brookfield and New Milford. This order was re-
scinded, presumably because it was basically a
"friendly order" based on future need.
While the history of the project sketched out in the
preceding paragraphs provides a reasonable descrip-
tion of the "orders" process, it does not capture the
subtleties of the decision-making process that has
taken place over the span of ten years. It cannot
reveal the values, prejudices, or motivations of
numerous individuals. It cannot resolve differing
political philosophies of governmental role in decision-
making, either directly through fiat or indirectly
through funding. The basic judgements made in the
20
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course of the development of the New Milford-Brookfield
project (the determination of problem areas and the
regional arrangement) were made according to existing
engineering practice.
21
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2.00 SIZE OF PLANT
2.10 INTRODUCTION
Many people have questioned the 4.0 MGD capacity of the recom-
mended treatment plant. Most of those who raised the issue
felt that the proposed plant is too large for New Milford's
needs. They frequently cited the fact that the present plant
capacity is only 0.5 MGD, and felt that the expansion to 4.0
MGD was unreasonable. In fact, a petition expressing a pref-
erence for construction of a 2.0 MGD plant has been sianed by
over 1,000 New Milford residents.
Other issues which residents directly related to treatment
plant size were the potential capacity of the rehabilitated
old plant. Somewhat related were general comments that
sewers were not the only remedy for local wastewater prob-
lems. Some felt that the service area was excessively large
while others stated that the participation of Nestles was the
major factor in determining the treatment plant size. Fin-
ally, the recent recommendation of a consultant to the Brook-
field Sewer Commission recommending the treatment of Brook-
field's problem areas via Danbury, left some people with the
impression that Brookfield's participation in the project
was uncertain.
2.20 DETAILED PROBLEM EXAMINATION
2.21 4.0 MGD Plant Capacity
e Comment: (R23, R29, R30, R32, R34, R45, H2, H24, H26)
The proposed 4.0 MGD plant is too large for New Mil-
ford's existing and anticipated needs. A 2.0 MGD plant
is more appropriate.
Response:
The 4.0 MGD plant is properly sized when all the rele-
vant facts are taken into consideration. Of relevance
are the following: since 1967 when expansion of the
present plant was first considered, the population of
the town has increased by about 40%; the Stage I
sewer expansion of the recommended plant is basically
the same as that proposed in the 1967 sewerage plan and
the 1972 Plan of Development; and by contract, 1.30 MGD of
the total capacity is reserved for Brookfield's flows.
After serving existing need within the Stage I service
area, about 25% of the capacity will remain for future
development with New Milford.
23
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The anticipated flows from existing and proposed resi-
dential development are based on conventional engineer-
ing practice which assumes saturation of housing of the
drainage basin within the service area, as governed by
existing zoning. The number of houses is then mul-
tiplied by an_ average number of individuals per
household (about 3,1) times the average per capita water
usage which was estimated to range from 71 gcd (1972)
to 100 gcd (2000) over the life of the project. For
industrial and commercial flows, values of 2,500 and
1,500 gallons per acre per day were used. Allowances
were also made for institutional flows and infiltra-
tion. While the overall flows are, therefore, estimates
of average types of development rather than actual
house counts and water usagethe method represents
standard engineering practice.
The breakdown of the eventual 4.0 MGD flow is given in
TABLE 6.
TABLE 6
ESTIMATES OF FLOWS
Present New Milford Flow
Initial New Milford Stage I Connections
Initial Brookfield Connections
Reserved for Brookfield Future Connections
Future New Milford Flows
TOTAL
Source: Anderson-Nichols & Co., Inc., 1977.
These flows would result from the immediate sewering
of New Milford's Stage I area, sewering of existing
problem areas in Candlewood Shores and Route 7 in
Brookfield, and modest residential and commercial/in-
dustrial development in both communities. The 4.0 MGD
plant is expected to have a design life of about twenty
years.
Public comments that the plant is simply too large and
a 2.0 MGD plant is adequate, do not reflect the reality
of the situation.
0.5 MGD
1.3
0.4
0.9
0.9
4.0 MGD
24
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2.22 Smaller Scale Alternatives
• Comment: (R18, R19, R20, R34, R35, H22)
In individual developments, options other than the con-
struction of the sewer plant exist. The downtown area
can be served by expansion of the existing treatment
plant built in 1958.
Response:
The first part of the comment was usually made by the
resident of a particular development. Consideration
of town-wide problems, over a twenty year planning
period, makes the use of individualized solutions less
practical than a centralized sewer collection system.
Potential problem areas in existing developments have
been identified throughout the Stage I, II, and III
areas. Although those in Stage II and Stage III areas
are more isolated areas, those in the Stage I area are
contiguous to the existing collection system. While
an alternative approach such as composting toilets may
provide simple sanitary waste disposal for new construe^
tion, particularly in remote areas, its application in
established year-round residences, with large wastewater
flows from sources other than toilets, is of limited
value. Also, while regular annual or bi-annual pump-
ing of septic tanks should be a part of an active mainten-
ance program for septic systems, frequent pumping re-
flects basically poor conditions for wastewater disposal
due to the inability of soils to allow percolation of
the wastewaters. Similarly, water conservation may
solve disposal problems where excess flows are involved,
or may allow one to "limp along" with a marginal system,
but is not a long-term solution that will ensure high
area~wide wastewater treatment levels. Consistent treat-
ment levels for wastewater in these extensive areas can
be best assured through centralized treatment. In
most of the small lot development, the only potential
non-sewer option would be for completely engineered
systems utilizing fill from off-site. This type of
solution would be more expensive, less reliable, and
possibly aesthetically less attractive than the sewering
alternative.
Rehabilitation of the existing plant usually is not
discussed independently of reductions of anticipated
flow. When the existing plant was studied by the town's
consultants in 1967, it was concluded that expansion to
25
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1.55 MGD was feasible, but above that level, a new plant
should be constructed. With an anticipated initial
flow of 2.2 MGD, rehabilitation of the old plant is not
practical.
2.23 Future Industrial Flows—Nestles
• Comment: (R21, R22, R23, R30, R35)
The comments that have been received can be summarized
in four statements: Nestles, not the town, is the real
polluter of the Housatonic River; the project has been
enlarged significantly to handle Nestles flows; Nestles
is gaining benefit at a cost to the town; Nestles is
going to build their own treatment plant.
Response:
Nestles presently has three discharges which are con-
trolled by the State of Connecticut Department of
Environmental Protection under National Pollution Dis-
charge Elimination System permits. Of these, two are
primarily cooling, water (although in-rplant studies have
shown traces of contamination from process water). The
third permit allows for the temporary discharge of 0.13
MGD of process water, which presently is only treated
by a settling basin, until the municipal treatment
plant is built. Although the waste is a strong organic
waste and is presently discharged with minimal treat-
ment, future treatment has been assured by explicit
deadlines in the State orders which call for compliance.
Of the 4.0 MGD capacity in the proposed New Milford
plant, about 0.2 MGD is reserved for Nestles. (0.13
MGD reported in 1967 but 0.23 MGD cited in 1973 Nestles
report.)
Nestles participation in a joint municipal-industrial
treatment plan is governed by Environmental Protection
Agency industrial cost recovery regulations which re-
quire that industry pay for any specific treatment
units which may be required in a municipal facility to
treat their waste. A user charge which is proportional
to the strength and quantity of its flows is also
levied. In addition, overall consistency of treatment
and economies of scale can best be obtained by combining
compatible industrial and domestic wastewater flows
for treatment.
26
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In the past Nestles has studied alternative methods of
treating its wastes. The company has concluded that
the best alternative is to treat their wastes at the
proposed New Milford treatment plant. This conclusion
has been stated in the consultants October 1973 report,
in the press, and in direct contact with Dr. Carey,
Nestles Manager of Environmental Services.
2.24 Service Area
0 Comment: (R15, R25, R28, R44, R50, H2, H4, H12)
These comments were actually mixed with some persons
asking why the service area was "so large" and others
asking why specific areas were not included.
Response;
The service area was defined in terms of existing and
potential need in areas contiguous to the existing sys-
tem in New Milford. The determination of "need" was
discussed in Section 1,00. In general, the Town of
Washington was excluded because of the lack of evidence
of extensive problems and future development poten-
tial , and its remoteness from existing development in
New Milford. New Fairfield also has been excluded be-
cause of lack of extensive septic disposal problems and
the availability of treatment options for potential
problem areas other than connection with New Milford
across Candlewood Lake. Within Brookfield, the western
portion of town, where areas of intensive development
exist and where industrial development is anticipated,
will be included with the service area. In New Milford,
the Stage I service area consists of extensions of the ex-
isting service area to the north and south of areas
of existing development. Stage II elements consist of
necessary connections to Brookfield through land slated
for development and some extensions through sparsely
settled land to pick up problem areas.
Draft EIS has noted that this second stage of construc-
tion should be re-evaluated in terms of current prio-
rities. Stage III construction extends the sewer
system to areas of ultimate need in the Candlewood
Shore area. It is anticipated that the timing of this
construction is probably twenty years in the future
and will enable the town to plan for the controlled
development of this valuable area.
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2.25 Brookfield-Danbury Connection
Comment: (R21, R49, R51, R54)
Basically these comments were related to the Albert-
son, Sharp & Backus report which recommended the initial
servicing of the Candlewood Shores areas through the
existing interceptor to Danbury and later service of
the Route 7 area by construction of an additional in-
terceptor to the Danbury treatment plant. The comment
stated that this was the better option for Brookfield.
Response:
The report which recommended this option was considered
by the Brookfield Sewer Commission, but in the final
analysis, connection with New Milford was endorsed by
both the Commission and the Selectmen. This report, by
itself, does not enable one to make a conclusive eval-
uation of the alternative. While it did propose to
serve the area of greatest need immediately, it did
not address the actual administrative feasibility of
the approach, the long-term economic consequences of
future connection with Danbury*s tertiary treatment
plant, or the environmental impact of treatment at Dan-
bury .
While a capacity of 0.5 MGD average flow may currently
exist in the interceptor that links the southern Route
7 area with Danbury, this capacity was intended for
development in this southern business district. At
present 0.2 MGD is already utilized. The remaining 0.3
MGD reserve would not totally accommodate areas of ex-
isting need and would preclude any more development
that has been planned in the southern Route 7 area. To
use this capacity for another area would not be con-
sistent with the intention for which the State and EPA
committed funding for the original construction. In
addition, the short-term impacts of constructing a de-
tention facility in this area, which would be necessary
to feed flows to Danbury in off-peak hours, were not
discussed. Finally, the fact that this would lead to
higher wastewater loadings on the already over-loaded
Still River, and the expense of tertiary treatment that
would be required, was not addressed.
28
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2.26 Exact Plan
• Comment: (R33, R48)
Some felt that the Draft EIS should have shown all ele-
ments of the proposed sewer system.
Response:
The maps in the EIS were designed to permit the reader
to compare the major elements of a regional study.
Consequently, a map scale had to be chosen which would
cover the area but still be manageable in size. Also,
the fact that a number of figures would be necessary
to depict alternatives imposed economic constraints
on graphic design. Finally, the basic information that
is sought, the delineation of the sewered area, is de-
picted by the colored areas. All homes within the
colored areas would eventually be served with sewers.
The actual elements of the sewerage plans have been
published in the past as part of the individual Facility
Plans (see FIGURE 8 in New Mil ford's- Environmental Assess^
ment). The approach utilized in the Draft EIS, of ne^
cessity, was to analyze the basic elements for which
the communities sought State and Federal funding.
29
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3.00 INDUCED GROWTH
3.10 INTRODUCTION
The impact of the proposed wastewater treatment and collec-
tion facilities on the growth of the New Milford region has
been a persistent concern throughout the EIS process. Al-
though sewerage systems are.only one element of the growth
equation, the EIS process has provided a single focus for
those concerned with the character, location, timing, and ex-
tent of new growth. This is in contrast to the myriad of
town, regional, and state agencies whose cumulative actions
may have a far greater impact on growth in the region, but
are not, in most cases, required to provide a detailed analy-
sis of the consequences of their decisions.
In many instances the questions that have been raised could
be directed at other agencies with a prime responsibility for
growth. As emphatically stated on page 4 of the Draft EIS,
"The EIS is not a comprehensive or growth control plan for the
respective communities",
The preceding is not intended to belittle the many serious
and concerned questions raised at the workshops, at the public
hearing, and in written comments on the Draft EIS. As indi-
cated in the Draft EIS, sewers will have an impact on growth,
and those questions which relate to growth induced by sewers
require a thorough response. The apparent sense of frustration
with governmental agencies at all levels is more difficult to
handle. In the area of growth it may indicate two possible
solutions:
A need for a better and more visible growth control
mechanism developed with the cooperation of the pub-,
lie at large. The almost negligible funds expended
on planning activities in the respective communities
appears to bear no relationship whatsoever to the
growth concerns raised during the preparation of the
Draft EIS.
A certain sense of frustration or appeal to higher
authority pervades many of the comments. The inabil-
ity to deal with the "growth octupus" at the Town or
State level beseeches appeals for the Federal govern-
ment to step into the breach. Local planning, how-
ever, is not a Federal function.
Detailed impact studies may be more appropriately
conducted in concert with the planning of wastewater
31
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collection and treatment facilities. This would tend
to mitigate against the rather rigid positions that
develop in the pro and anti sewer camps. The EIS
process can be a means for conflict resolution, but
most desirably such conflicts should be resolved in
an open planning process.
3.20 DETAILED PROBLEM EXAMINATION
3.21 Character of the Town
• Comment: (R23, R24, R38, R45, R48, H3, H23)
The proposed facilities will induce growth which will
destroy the area's rural character and quality of life.
Response;
It is acknowledged in the Draft EIS that additional
sewering can be one of the influences which changes
the rural environment (VII. B. 1, b. 2)... In cooperation
with strong growth controls, however, sewering can con-
centrate development into prescribed areas and limit
sprawl tendencies. Sprawl is a less dramatic but per-
sistent destroyer of the rural atmosphere of the out-
lying areas of the New York region.
The areas proposed for sewering in Stage I in New Mil-
ford are consistent with needs for sewers and the pol-
icies identified in the 1972 Updating Plan of Develop-
ment . Its first policy on residential development is
as follows:
"As much development as possible should be con-
centrated in the adjacent to the town center to
prevent continuous sprawl over all the rural areas
and the eventual costly extension of utilities."
The Draft EIS is very specific (VII.B.e.h.3) in stating
that the Updating Plan of Development should be revised
as a basis for guiding any sewer extensions after Stage
I. The Draft EIS notes further that the Plan of Develop-
ment should be the guide for any growth subsequent to
Stage I. Thus the extent to which New Milford controls
its planning, zoning, and future sewer extensions will
be the major basis for preserving the rural qualities
of the community.
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In Brookfield the areas proposed for sewering are in
accord with the present planning and zoning policies
of the town. These policies have been under review
for the past year and have not as yet been resolved.
The Draft EIS, in recognition of the unresolved nature
of planning in Brookfield CVIIYB.3.h.4) calls for a
revised Plan of Development to provide a coordinated
guide for future development. As in New Milford, the
adopted land use plans which establish sewer need areas
become the guides to thwart a destruction of rural qual-
ities .
It is not the function of the EIS to dictate how a com-
munity should develop or preserve its rural qualities.
That is the function of the planning, conservation, and
legislative boards of that town.
3.22 Agriculture
• Comment: (R21, R27, R29f R32)
The proposed facilities will increase land values and
will encourage the conversion of farm land to other
types of development.
Response:
Urbanization will, in fact, result in the conversion
of farmlands to other types of development. As noted
in the Draft EIS (VII.B.1.a.3a), the urbanization con-
templated will be in accord with present zoning and
planning policies of New Milford and Brookfield.
New Milford's Updating Plan of Development calls for the
continuation Qf seyeral areas of farming and grazing
land wherever possible. Although these areas are not
identified, it must be presumed that such areas are
zoned for low density development which was not proposed
for sewering in the Updating Plan of Development. Since
"the not to be sewered" areas covered by the proposed
facilities plan are similar to those in the Updating
Plan of Development, it is assumed that the farmland
which will be eliminated (Route 7 for example) has
been slated for such conversion by local town policies.
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3.23 Schools
Comment: (R18, R21, R34, R57)
The induced growth resulting from the proposed facil-
ities would place a severe strain on community facili-
ties including schools.
Response:
The alternative recommended in the Draft EIS calls
for the implementation of Stage I improvements
in New Milford. A coordination of local planning and zon-
ing with Stage II and III sewer facilities planning is
recommended in the Draft EIS.
It has been estimated in the Draft EIS (VII.B.3.d)
that Stage I development in New Milford will induce a
population growth of approximately 1,350 persons includ-
ing 700 in apartment units awaiting sewers and 650
in single family homes.
In 1975 the Housatonic Valley Council of Elected Offic-
ials estimated that 25% of New Milford's population (or
4,296 pupils) was school-age children. The average
daily school membership for that year was 4,08 0. This
would indicate that 94% of the school-age children are
enrolled in the public school system.
Assuming that 25% of the new population to be induced
will be of school age (a conservative estimate due to
the high percentage who will be living in apartment
units) and 95% will attend public schools, a population
growth of 1,350 as a result of Stage I sewers could
bring 320 new school children to New Milford.
The New Milford School Department has estimated that
new pupil costs for the 1977-197 8 school year will be
$1,426. Approximately 75% of this amount or $1,070
will be raised from local property taxes.
Thus, the local costs of educating 320 additional
school children would be approximately $342,400.
Revenues to pay for those increased school costs will,
in part, be derived from new construction. It is esti-
mated that the increased population will be housed in
approximately 450 units (average of three persons per
unit, four for single family, and two for apartments).
34
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Assuming an average assessed value of $20,000 per unit,
total revenues at a mill rate of 35.0 will be $315,000.
Approximately 70%, or $220,500 of locally collected tax
revenues are applied to school costs.
The school cost-revenue comparison for Stage I induced
growth is a net loss of $12i,900. Where a higher pro-
portion of single family units will be induced, as in
Stage III, it is generally safe to predict that school
costs for new construction will also exceed the revenue
to be derived.
3.24 Other Services
• Comment; (R18, R21, R34, R57)
The induced growth resulting from the proposed facili-
ties would place a strain on all town services—"Town
will go bankrupt".
Response:
The fiscal impact of new development upon services other
than schools is more complicated due to the greater
number of revenue and expenditure variables. No studies
of municipal costs to service various types of land use
in New Milford are available.
Cost-revenue impact studies generally have indicated
that industrial, commercial, and high density uses
provide a net revenue benefit to a community; moderate
density apartments of the type allowed in New Milford
are a break-even situation and low density single-family
housing costs greater than the tax revenues they provide.
Variations, of course, occur under special occupancies
for low-income or senior citizen families.
For all services, including schools, it can be general-
ized that commercial and industrial development and high
density housing will generate revenues in excess of costs.
Moderate density housing will have revenues approximately
equal to costs to service. This is balanced in the
typical suburban community by the costs in excess of rev-
enues to serve single-family housing.
Stage I and II induced growth in New Milford which will
include a balance between apartment and single-family
housing, is expected to be deveoped at a slight tax loss to
the community. If senior citizen apartment units predom-
inate in either stage, a net tax gain would occur.
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Stage III induced growth consisting entirely of single
family homes along with some industrial and commercial
growth would generate a tax loss.
It should be noted, however, that the Draft EIS calls
for a re-examination of all land use and sewer ex-
tensions beyond Stage I with full investigation of the
impacts of any land use changes.
3.25 Lack of Planning
• Comment: (R18, R19, R21, R48, H23)
Sewer plans are being developed in absence of a Master
Plan, particularly in Brookfield.
Response;
In Brookfield the Draft EIS has identified existing
problem areas and recommended connection with New Mil-
ford as the logical choice. While the latest sewer
routing that was proposed by the town's consultant was
shown in the Draft EIS, the actual routing has .not..been
finalized and will not be until a Stage I Facility Plan
is approved. The present commitment by Brookfield is
for capacity in the New Milford plant and the Lanesville
interceptor.
The lack of concurrence between community plans and pro-
posed sewering plans is recognized in the Draft EIS. In
particular (page 219) the Draft EIS notes that planning
in Brookfield was in a state of flux throughout the prep-
aration of the EIS. It appears that this is still the
case.
It is not the function of a Federal Agency such as EPA
to prescribe the type and location of growth in a com-
munity. EPA can, however, prescribe a,nd require regu-
lations if they conclude environmental harm by result
of a federally-funded project. Many of the comments at
the workshops, at the hearing, and in the letters re-
ceived imply or state that the communities, particularly
New Milford and Brookfield, do not have adequate plans
or the plans do not reflect the true feelings of the com-
munity.
The planning functions in New Milford and Brookfield
are carried out by the Planning and Zoning Commissions
with limited clerical assistance and no technical
staff. The level of funding for professional planning
36
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services, too, has been relatively low. The KVCEO is
staffed to provide only limited1 technical assistance to
its member towns,
The Draft EIS is very explicit in its recommendations
to both New Milford and Brookfield that there be
coordinated land use and sewer planning for any sewer
extension beyond Stage I (see pages 219 and 229 of Draft
EIS) .
3.26 Route 7
9 Comment: (R29, H5, H15)
Sewering of Route 7 is both favored by Brookfield
Sewer Commission and questioned by others as a politi-
cal decision to advance industrial growth in Brookfield.
The prospect of extending Route 7 as a limited access
roadway through New Milford is doubted.
Response:
Proposed sewering of the Route 7 corridor is in accord-
ance with present plans for industrial development in
New Milford and for commercial, industrial, and resi-
dential uses in Brookfield. Th*.
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as a result of the preferred alternative. The secon-
dary impacts of such growth also are noted (pages 216-
217) .
The basic problem appears to be wide-spread sentiment
that even through the stated opinion's of many key public
officials and the various adopted development plans
and zoning regulations are generally consistent with
the areas proposed for sewering, such opinions, plans,
and zoning do not reflect the true mood or desires of
the people. The opinions expressed at workshops,
hearings, and in written comments on the Draft EIS
all convey such a message.
Due to such concerns as consistently expressed through-
out the EIS process, the Draft EIS recommended that all
sewer extensions beyond Stage I be consistent with local
land use plans. As noted on page 219, The Plan of Develop-
ment rather than a sewer facilities plan, should be the
guide for any growth subsequent to Stage I. Similar
recommendations were made for Brookfield and are in
the process of being implemented.
The EIS is not a growth strategy. Such a strategy is
the responsibility of the community.
It is recommended that the Planning and Zoning Commiss-
ions of New Milford and Brookfield be provided with ade-
quate funds to develop "consensus plans" and regula-
tions which reflect the mood expressed to EPA. Plan-
ning in a growth area is a complex situation requiring
funding commensurate with the public's interest and
the often unsatisfactory consequences of reacting to,
rather than guiding, development pressures.
3.28 Who Determines Growth
• Comment: (R41, R57)
Local stategy has been presented at workshops sponsored
by EPA and EPA should present proposals in keeping with
town needs.
Response:
As noted above in Section 3.27, EPA has heard the con-
cerns expressed at the workshops, the hearing, and in
written submissions. It is the Agency's opinion that
the proposal for sewering only Stage I areas at this
38
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time is consistent with sewer needs and the growth
strategy expressed in the 1972 Updating Plan of Develop-
ment.
It is EPA's position, however, that the evident con-
flicts regarding growth in Brookfield and New Milford
must be resolved in Brookfield and New Milford before
Stages II and III can proceed.
3.29 Population Projections
e Comment: (R22, R34, R56, R57)
Population projections are too high or based on obso-
lete projections for region.
Response:
The Draft EIS includes a significant discussion of
major land development influences and growth trends in
the New Milford area. Various state and regional
sources were reviewed and/or contacted.
At the regional level, although population stability is
predicted for the New York region by the New York Re-
gional Plan Associations, March 1975 report on "The
State of the Region," the same report projects that
there will be an increase in new households, most of
which will be located in rural lands near the periphery
of the region. New Milford and environs is located in
this peripheral area. The same report notes that such
a trend would be balanced by a population drop near
the core. The RPA report notes the significant social,
economic, and environmental consequences of such a trend
and cites the need for fundamental policy changes to
redirect growth away from spread development. Although
energy concerns may be altering spread development
trends, there appears to be no regional source which
will predict policy changes which in fact would alter
the move to peripheral areas.
At the state level, significant population projection
revisions have been made by the Connecticut Department
of Planning and Energy policy during the past year for
each region and community in the state. These estimates
were reviewed and, where appropriate, modifications
were made to reflect the more detailed analysis of
development factors conducted as part of the Draft EIS.
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Small area population forecasting is not a precise
science and subject to a number of variables as noted
in the Draft EIS. The estimates for growth without
the sewer project as well as the growth to be induced
by the project have considered the known variables.
This provides a reasonable basis for determining impacts
in a broad sense as dictated by applicable laws and
administrative regulations.
3.30 Industrial Development
® Comment: (R19, R4 4 , R4 9)
The State is using the project to attract industry which
can, in turn, bring other problems to the affected
communities.
Response;
It is true that the State of Connecticut has a program
to attract industry to create needed jobs for present
and future generations. The Connecticut Plan of Con-
servation and Development designates the Route 7 cor-
ridor in New Milford and Brookfield as an area suiable
for urban development including industry. The State
plan is consistent with the zoning plans of both
New Milford and Brookfield which encourage industrial
growth in the Route 7 corridor.
Although most industry is generally conceded to provide
more tax revenues than it costs to service the industry,
demands too are generated for housing for employees
which in turn require additional services.
A stated goal of the Town of New Milford is to provide
a balance of industrial and residential growth.
3.31 Down-zoning
• Comment: (R12, R29, R46)
Sewers and growth induced by sewers will bring about
down-zoning with consequent adverse impacts to the
community.
Response;
During the past several years, a number of significant
land use and zoning case decisions have been made by
Federal and State courts throughout the United States.
40
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Some of the more significant court actions which have
applicability to the New Milford area are:
(1) establishing the right of a community to con-
trol its growth
(2) invalidating local zoning that produces
"discriminatory effects"
(3) requiring a community to provide opportuni-
ties for an appropriate variety and choice
of housing for all categories of people who
may desire to live there including a "fair
share" of the present and future need for low-
and moderate-income housing.
(4) approving the cutoff of Federal funds for
failure by a community to comply with govern-
ment anti-discriminatory policies
(5) requiring policy consistency between local
zoning and comprehensive plans
(6) allowing time phasing of residential develop-
ment in conjunction with the extension^ of util-
ities
(7) requiring zoning and comprehensive plan com-
pliance with environmental standards.
As the above summary will indicate, the whole issue
of land use and zoning litigation is exceedingly com-
plex. It is impossible to state that a down-zoning
suit, if brought, will be successful. What the courts
appear to be saying is that communities can control
growth if:
(1) The growth control stategy is based on thorough
and well documented public planning which
clearly and unequivocally establishes its
public purpose, and
(2) The growth control strategy does not have the
effect of discriminating against any group
of people who might be expected to want to
live in a locality because of its proximity
to jobs and other opportunities.
Very few communities in the United States have adopted
effective growth management plans. New Milford's 1972
Updating Plan of Development is a first step toward a
growth management plan.
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Without the initiation of planning programs, New Milford
and Brookfield may be subject to successful down-zoning
suits.
With intelligent planning, particularly as it relates
to coordinated sewer and land use plans beyond Stage I,
the communities would appear to have a good chance to
guide their own growth and to thwart any down-zoning
challenges they wish to contest.
3.32 Developers
9 Comment: (R30, R39, R57)
Outside developers will benefit from project.
Response;
Two economic philosophies appear to apply today in the
United States. At the national level, the emphasis is
on greater economic growth to stimulate business and
reduce unemployment. At the local level, major
efforts in a great number of communities are under way
to slow or stop growth. In many respects national ef-
forts to promote growth are being countered by local
efforts to restrain it.
From a national as well as local perspective, the poten-
tial for making a profit on land development in the re-
gion should not be viewed with alarm. It is an incentive
which is basic to the American way of life.
When such profits are extracted at the expense of the
local environment or of the community's ability to pro-
vide services, they should be discouraged.
As long as a community retains a reactive stance to
developments and developers as they may come along,
there is a prospect for profit at the expense of the
community.
A much more tenable stance from both the national eco-
nomic perspective as well as local objectives is to
encourage development which will be consistent with a
local growth strategy.
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3.33 House Prices
• Comment: (R5 6)
Selling prices of houses are not the same as asking
prices of a house.
Response:
On page 102 of the Draft EIS, statistics on the average
asking prices of housing from a 1975 study by the Hous-
atonic Valley Council of Elected Officials were noted.
It is agreed that the actual selling price of these
houses undoubtedly was less than the asking price. The
data was used to show general comparisons between hous-
ing costs in New Milford and areas to the southc The
generally lower housing costs in New Milford are pre-
sumed to be a basis for "leap frogging" development
which will seek more remote, lower cost land for the
construction of lower cost housing with a wider mar-
ket appeal.
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4.00 COSTS
4.10 INTRODUCTION
Many respondents voiced concern over cost issues. Generally
their questions can be categorized as (1) difficulty of inter-
pretation of the tables contained in the Draft EIS, (2) the
determination of eligibility for funding for certain items
and the resulting impacts, (3) the concept and application
of cost effectiveness analysis, (4) exact costs for house-
holds, (5) the payment of a patent fee for the Carrousel
process, and (6) the secondary costs that might result from
induced growth.
In the first case it was recognized that some difficulty
might be encountered in interpreting the tables of costs in
the Draft EIS due to the difference in terminology and pre-
sentation that was used in the original engineering work of
the town's consultants. It was recognized, however, that a
completely new anlaysis using the same design and assump-
tions would only be redundant. An effort was made in the
Draft EIS to further clarify these tables by the use of
footnotes. Additional explanation is given in the follow-
ing sections where shortcomings in the original Draft EIS
were found.
Some respondents speculated on the relationship between
eligibility for funding and the actual costs that would be
required from the individual homeowner. In most cases the
confusion arose from failure to read the tables correctly.
The term "cost-effectiveness" has been used often by resi-
dents throughout the course of the New Milford project.
In the following sections the analysis that was done will
be explained according to the more constrained use of the
term as defined by EPA guidelines.
The request for exact costs is met by the response in Sec-
tion 4.21. The patent fee, a well-known bone of contention,
has been recognized as a legitimate cost. This is dis-
cussed in more depth in Section 5.23. Lastly, the "costs"
of secondary growth are discussed and references to other
sections of this report which deal with closely related
questions.
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4.20 DETAILED PROBLEM EXAMINATION
4.21 Connection Costs
e Comment: (R2 0, R4 8)
What will be the cost of the actual house connection
to the sewer?
Response:
The one-time charge for the actual piping from the
house to the sewer is estimated to be about $10 per
foot, measured from the house to the curb. Thus, in
addition to the assessments and user charges shown
in TABLES 4 and 6 of the Draft EIS, there would be a
connection charge of about $500. In some communi-
ties, home owners have bargained collectively with
plumbing contractors and have lowered the rate by as
much as 50%.
Some individuals stated the cost of pumps for homes
below grade was not included in cost computations.
Although Brookfield has yet to develop an actual de-
sign for the collection system, (the town has not sub-
mitted an actual Step 1 Facilities Plan) the costs of
home pumps, if required, could range from $1,000 to
$3,000. They may be grant eligible according to EPA
guidelines.
4.22 Tax Burden
• Comment: (R39, R44)
The secondary costs of growth will create financial
problems for homeowners as well as large land holders.
The proposed system should be biased toward industrial
development.
Response:
The secondary costs of development induced by the
wastewater collection and treatment facilities was
previously discussed under Sections 3.23 and 3.24.
It is not anticipated that Stage I induced growth will
have any significant financial impact on the community
of New Milford as a whole. Stage II and III growth
could occur at a net tax loss resulting in increased
taxes throughout the community. For this and other
reasons it has been recommended that revised community
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planning, with a complete evaluation of the fiscal
impacts of Stage ii and III growth be carried out.
Such planning could, if desired by the community, bias
future sewering to encourage industrial growth.
4.23 Validity of Cost Estimates
• Comment; (R18, R19, R20, R34, R49, R41, R44, R42,
H13, H23, H28)
Costs are out of date; no index has been used to update
them.
Response:
The costs that were presented in the Draft EIS were
documented in terms of their source and were updated
to Fall 1976 with an ENR Index of 2450. The sources
from which the original capital cost estimates were de-
rived differed both in format and in detail. In the
Draft EIS an effort was made to show those costs in
similar detail in a common time-frame.
The exact source used for the New Milford capital costs
was the Verbatim Transcript at the Public Hearing of
June 19, 1975 and the accompanying handout. These cost
were described as 1975 dollar value. The ENR Index at
that time was 2119. An Index at 2450 was used as rep-
resentative of Fall 1976 costs so that a factor of
1.1562 was used to update the New Milford capital costs.
The estimated costs of the Brookfield components were
adapted from the CG Engineering report, North and
Central Areas, Study of Alternative Routes, April 1975.
Costs in that report were originally estimated to be
1976 costs by increasing the amounts by 9% The figures
given in this report were brought back to 19 75 by
subtracting 9% and projected by use of the ENR Index as
in the case of New Milford.
4.24 Cost Apportionment
• Comment; (R18, R19, R20, R34, R41, R44, R38, H23, H28,
HI 3)
The cost to the homeowner cannot be determined from the
data in the Draft EIS.
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Response:
TABLES 4 and 6 in the Draft EIS are modifications of
the estimates made by the towns' consultants. Since
local apportionment of costs can be done in a number
of ways, the strategy that was followed was to use
the original assumptions of the local engineering
reports but to state them explicitly. Nonetheless,
apparently some confusion did arise among those
who reviewed the Draft EIS.
TABLE 4 in the Draft EIS shows the yearly cost for
the start-up year (1978) for those on the existing
sewer system, those who will be connected on the new
system, and those who will remain on septic systems.
The general assessment is shown to decrease through
time until the debt is paid. Although the user
charge decreases through time, there will always be
a charge for operation and maintenance of the facility.
The benefit assessment is a yearly charge that will be
paid off during the length of the bonding period (as-
sumed here to be twenty years). After this period
this charge would not continue.
The cost apportionment for Brookfield, labeled TABLE
6 in the Draft EIS, requires further explanation. In
Brookfield the proposed plan was borne entirely by
the users. Only the major items such as interceptors
are to be paid from general taxation. It is antici-
pated that the increase in the tax rate will be about
$1.00 per $1,000 assessed valuation. TABLE 6 in the
Draft EIS was intended to show representative charges
to individuals living in different areas within the
proposed service area. The text of the draft report
failed to properly identify their locations. They are:
Shores Area #1 - Sunset Drive
Central Area - West of Route 7
Shores Area #2 - Laurel Drive
In TABLE 6 the costs were presented somewhat differ-
ently than those of TABLE 4. The annual charges
shown in TABLE 6 include both the user charge and the
general assessment. The Capital Assessment is similar
to the Benefit Assessment of TABLE 4 but is shown as a
one-time charge. The actual payment of this amount
would in all likelihood be financed over time and
would resemble the yearly benefit payment shown in
TABLE 4 for the twenty year repayment period.
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4.25 Ability to Pay
® Comment: (R34, R37, R39, R40)
The Town of New Milford as well as the individual
worker and home owner will be hard pressed to pay
the required costs.
Response:
Stage I sewering is largely in response to serving
immediate sewer needs in and adjacent to New Milford's
town center. It is not anticipated that Stage I
sewering will have a significant tax impact as a
result of the development to be induced. As previously
discussed Stage II and III land use and sewer planning
can be coordinated to encourage growth in a manner
which will not burden the town or individual property
owners.
In the face of documented needs and State orders for
sewering, the community as well as the individual
must consider the consequences of having to provide
sewers without the substantial federal and state grants
now available. The costs of financing these needed
facilities without outside grants would indeed put a
serious strain on the community and its hard working
home owners.
4.26 Secondary Costs
• Comment: (R18, R23, R25, R30, R34, R41, R42, R46, H27)
New development will require increased facilities such
as fire and police, new bridges, and expanded school
capacity. There should be local self-determination of
growth.
Response-
The previous answers under Sections 3.23, 3.24, 4.22,
and 4.25 cover the question of secondary costs. Sev-
eral further comments are in order. Concentrated
development as would be encouraged by sewering generally
has been less costly to service than the sprawl en-
couraged by scattered large lot development. This has
been recognized in New Milford's Updating Plan of
Development.
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We concur with the principle of local self-determination.
The proposals of the Draft EIS for better local plan-
ning emphasize that the towns, rather than state or
federal agencies, should guide future growth.
4.27 Funding and Eligibility
• Comment; (R18, R19, HI, H22, H28)
Cost figures are incomplete and misleading because
lateral sewers are ineligible for funding.
Response:
This interpretation is incorrect. In TABLE 1 of the
Draft EIS, the cost of Stage I laterals in New Milford
is shown as a "Non-eligible" item. In TABLE 5 the
cost of lateral (collecting sewers) in Brookfield is
shown as an "ineligible item". All that this means
is that this particular item will not be reimbursed by
grants. It does not affect the overall project cost.
The Connecticut DEP has made several changes in their
funding eligibility policies since the issuance of
the Draft EIS. At this time some portion of the pro-
posed laterals may be eligible for State funding. This
would not change the total project cost in any way.
The cost to the residents of New Milford and Brookfield
would, however, be lowered.
4.28 Carrousel Costs
• Comment: (R26, R58)
Will the Carrousel process with phosphorus removal be
cost effective?
Response:
Phosphorus removal from either, the Carrousel or a con-
ventional activated sludge treatment plant would be
accomplished by the same method of the alum addition.
Consequently, the additional requirement for phospho-
rus removal would increase the capital and operating
costs of both facilities by the same amount. This
would have no significant effect on the outcome of
cost effective analysis. The cost effective concept
is discussed in Section 4.30.
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4.29 Tertiary Treatment
9 Comment: (R26)
The cost comparison of the Carrousel and land treat-
ment fails to compare the Carrousel with phosphorus
removal. Since land treatment provides tertiary
treatment a proper comparison would include the costs
of tertiary treatment with the Carrousel.
Response:
The requirement of the Connecticut DEP for secondary
treatment, and their funding support for secondary
treatment, established the basic design criteria for
the treatment facility. Designation by DEP in the
303e River Basin Plan of the Housatonic River in New
Milford as an "effluent limited segment" by defini-
tion requires only secondary treatment to meet and
maintain applicable water quality standards. (This
segment of the river is classified B.) Within the
constraint of a specified flow of 4.0 MGD and treatment
to secondary levels, cost effectiveness was applied
to a number of processes in APPENDIX B of the Draft
EIS. Other questions dealing with the cost effective-
ness of the Carrousel system are found in Section 5.2 3
of this document.
4.30 Cost Effectiveness
• Comment: (R48)
The project is not cost effective compared to other
plant sizes.
Response;
The point that was made in the Draft EIS is worth re-
peating; cost effectiveness anlaysis is a matter of
distinguishing between significant differences in
cost of similar size projects. You must compare
apples to apples. In this case the given is a 4.0
MGD secondary treatment plant.
o Comment: (R58)
How can the project be described as cost effective when
the recommended alternative is shown as $60,000 more
costly than a conventional secondary treatment plant?
51
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Response;
The cost effectiveness anlaysis of the Carrousel pro-
cess in the Draft EIS was done independently of earl-
ier work. The work was done objectively and the dollar
results were reported. The reality is that the indi-
vidual elements are estimates made at a certain point
in time. The difference in cost between the Carrousel
and other processes cannot be judged as significantly
different given the nature of the estimation process.
See Section 5.23 for additional information.
52
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5.00 TECHNICAL
5.10 INTRODUCTION
The Draft EIS contained a great wealth of technical informa-
tion relating to the physical environment of the study area,
the proposed system of sewage collection and treatment, and
the impacts resulting from the construction of the project.
An attempt was made in writing the Draft EIS to present all
technical data from which a subsequent conclusion was drawn.
Questions and comments on technical issues in the Draft
EIS covered a broad spectrum of topics. Comments ranged
from very specific questions which were definitively ans-
wered to broad, open-ended questions to which there are no
simple answers or to which an answer is beyond present tech-
nical knowledge. In response to such questions an attempt
was made to draw reasonable conlcusions from existing know-
ledge and, thus, to set a reasonable course for future ac-
tion.
5.20 DETAILED PROBLEM EXAMINATION
5.21 Land Application
0 Comment: (R16, R31, R57, H17, H20)
Land application is an environmentally sound method
of wastewater treatment with definite ecological bene-
fits. In addition it complies fully with the spirit
of PL 92-500. Why is land application, therefore,
not recommended?
Response:
The Environmental Protection Agency and Anderson-
Nichols & Co., Inc., both agree that land application
of wastewater has very significant ecological benefits
and the use of such systems of wastewater treatment
should be encouraged where possible. Spray irrigation
(or any other method of land application) of partially
treated wastewater from the Towns of New Milford and
Brookfield is, however, not a feasible solution for a
number of reasons:
(1) At the treatment plant design capacity there,
simply stated, in not enough suitable land
to effectively accomodate the expected flow
of 4.0 MGD. At a hydraulic loading rate of
53
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two inches per week suggested by Hill (Spec-
ial Soils Bulletin #32) as the maximum per-
missible loading rate for Litchfield County
soils and with a spray season of 150 days,
a total spray field of almost two square
miles (1250 acres) would be required. This
perfect case is, however, not possible. If
nitrogen loading of the soil is used as the
selection criteria rather than hydraulic
loading, considerably more land would be re-
quired—almost eight sqaure miles (5,000
acres). The total area of land with soils
suitable for spray irrigation within the
study area would accommodate a flow of only
2.34 MGD if hydraulic loading is used as the
limiting factor and 1.64 MGD if nitrogen
loading is used as the limiting factor.
In addition to the larqe land area reauired
for the sprav irricration areas significant
areas would have to be reserved for waste-
water treatment and storaae laaoons. Assum-
ing that 200 davs of storaae would be re-
auired between sprav seasons and that ponds
would be ten feet in depth, an area in ex-
cess of 200 acres would be reauired for
wastewater storaae laaoons. This is approx-
imately the size of Marqerie Lake Reservoir
in Danburv and New Fairfield.
(2) Secondary treatment of wastewater is all that
is required by law in the study area. Be-
cause of this, neither the State of Connecti-
cut nor the Environmental Protection Agency
are permitted to fund any treatment beyond
the secondary level. Tertiary treatment by
a system of spray irrigation would not,
therefore, be eligible for state or federal
funding and such a system would have to be
funded locally by the Towns of New Milford
and Brookfield.
(3) Any system of land application of effluent
in New Milford cannot be cost effective be-
cause of the widely scattered nature of
suitable spray sites, their costs, their
distance from suitable wastewater treatment
facility sites, and their elevation (average
of 800 feet) above the treatment facility
site.
54
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(4) Spray irrigation of Sunny Valley Farm was
rejected because of possible elevation of
nitrate concentrations in the underlying
aquifer. This aquifer, designated in the
State of Connecticut Plan of Conservation
and Development as a "high priority aquifer,"
is a water supply source in New Milford and
already has nitrate concentrations in ex-
cess of EPA drinking water standards.
Comment: (R22, R23, R29, R36)
Would land application work as a part of a scaled-
down system of wastewater collection and treatment?
Could land application be used for a portion of New
Milford's wastewater flow?
Response;
The question of land application being utilized in a
scaled-down wastewater collection system is moot be-
cause there is a strong need for a treatment capacity
of 4.0 MGD within the next twenty years (see Section
2.21). In addition, present need (2.11 MGD) sig-
nificantly exceeds the loading capacity of all feas-
ible land application sites in New Milford even if nitrogen
loading is used as the limiting factor.
A portion of New Milford and Brookfield's wastewater
could be utilized in a land application system, but
such a system could not be cost effective. All of
the wastewater would have to be treated to secondary
levels no matter whether it was disposed of in the
river or applied to the land. It is quite obvious
that land costs, irrigation equipment costs, and main-
tenance in the land application system would be addi-
tional costs beyond those of river disposal. In
addition, the state and federal governments cannot
participate in the funding of this additional treat-
ment capacity leaving the funding burden on the towns.
Comment: (R22, R25, R26, R36)
Are there other possible land application sites within
the study area?
Response:
In the four town study area possible land application
sites in Washington and New Fairfield were rejected
55
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out of hand because of costs associated, with their
remoteness from the proposed centralized collection
and treatment system and because of potential political
problems associated with application of wastewater
effluent in towns other than those in the collection
area.
Potential sites in Brookfield were not seriously con-
sidered because of the generally high residential den-
sity of the town and the general unsuitability of
soils and topography (as indicated on FIGURE 5 of the
EIS). An initial overview of the town indicated that
the large areas of suitable soils and topography coin-
cided with developed areas. There may be, however,
some few small areas (less than fifteen acres) suitable
for land application of effluent that are not shown
on FIGURE C-l of the Draft EIS.
The entire town of New Milford was studied in detail
for potential land application sites. Primarily
utilizing Soil Conservation Service and Geological
Survey mappings of the town along with the site selec-
tion criteria enumerated in APPENDIX C of the Draft
EIS, twenty-five sites, illustrated on FIGURE C-l,
were found to be suitable for spray irrigation of
wastewater. These sites represent all suitable areas
in New Milford with an area in excess of approximately
fifteen acres. Sites smaller than fifteen acres were
eliminated because of the high unit costs associated
with site development, maintenance, and monitoring.
• Comment; (R26, R29)
What would be the cost of a system of land application
for the designated flow? Why isn't this the most
cost effective solution?
Response:
Land application in New Milford has never been costed
out in full by Metcalf & Eddy, Anderson-Nichols, or
the Environmental Protection Agency for a 4.0 MGD sys-
tem. The reason for this is quite simple—one need
not progress very far in the cost estimate of such a
system before it quickly becomes more expensive than
any conventional form of treatment. Both capital
and operation and maintenance costs are higher.
56
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Major items responsible for the greater cost of
a spray irrigation system are the following
items would be required in addition to the collec-
tion system which would be common to both systems:
(1) Secondary treatment of the wastewater
would still be required, although a
cheaper treatment process such as aerated
lagoons or stabilization ponds might be used.
(2) Storage ponds would have to be constructed
to store wastewater which could not be
sprayed when the ground was frozen or sat-
urated. This would require the acquisition
of 200 to 250 acres of land.
(3) A system of piping and pumps to transport
the treated wastewater to the irrigation
sites. The average distance to the po-
tential spray sites shown on FIGURE C-l is
about eight miles and they average eight
hundred feet above any centralized collec-
tion point.
(4) Approximately 5,000 acres of land, ex-
cluding buffer areas, would have to be ac-
quired for spray irrigation areas in order
to ensure protection of groundwater.
Comment; (R16, R17, R25, H20)
What is the impact of land application on the under-
lying aquifers and, therefore, on water supply? What
is the impact (and importance) of nitrates in this
water?
Response;
A properly designed land application system will
have beneficial impacts on the underlying aquifer.
If the system is designed and operated within para-
meters dictated by the hydraulic and/or renovative
capacities of the soil and associated biota, a high
(drinking water) quality water will percolate to
groundwater.
Nitrates in wastewater are commonly the most critical
chemical which dictates the permissible application
rate, and thus size, of a land application system.
While most chemicals, heavy metal ions, and biological
57
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organisms are readily physically/chemically complexed
with soils, nitrates percolate to groundwater and
surface water with virtually no removal. Often
times nitrate concentrations in the percolate are
higher than in the effluent applied because nitrates
and ammonia in the effluent are converted to nitrites.
Nitrate removal is accomplished primarily through
crop intake and the ultimate harvesting of the crop.
If the crop nitrate uptake equals the wastewater
effluent nitrate applied, then there will be no im-
pacts on groundwater supplies. In New Milford, spray
sites totaling 5,000 acres (or 15% of the town's un^-
developed area) would be required to prevent nitrate
breakthrough to groundwater (this assumes 60% wood-
land and 40% forage crop uptake).
Comment: (R21, H7)
Has clearing forest land to make crop land been con-
sidered as a way to increase nitrate removal ca-
pacity in a system of land application of wastewater?
Response:
The environmental impacts of clearing up to 3,000
acres of woodland in New Milford would be significant,
and such a scheme has not been given serious consid-
eration as a result.
Comment: (R16)
What is the position of the State of Connecticut in
regards to land application?
Response:
The Connecticut DEP evaluates proposed systems on a
case by case basis and has no special policy toward
land application, i.e., it is viewed only as the so-
lution to a problem—if land application is techni-
cally and economically the best solution, use it—if
not, use an alternative solution.
Reference is made (Document #R16) to land application
in Litchfield. At no time has DEP or DPH ever recom-
mended a land application system for effluent from
Litchfield's secondary treatment facility (0.78 MGD).
Mr. Woodhull's comments as reported in the Danbury
Sunday News (February 27, 1977) are not a recommenda-
tion for any such system. What he said is that if the
5R
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Shepaug River (from its confluence with the Bantam
River to its mouth) is to be used as water supply then
its classification must be changed from B to A. In
order to do this under present law, the effluent dis-
charge of the Litchfield treatment facility would have
to be removed from the Bantam River. Land application
would be the only alternative.
Land application of New Milford's effluent would not
result in an upgrading of the Housat6nic River; to A
(drinking water) because of the large number of other
municipal and industrial discharges.
A spray irrigation system in Litchfield has recently
been approved by DEP for the Connecticut Junior Repub-
lic School for Boys. This small system (6,00-10,000
gallons per day) was approved in order to eliminate
effluent discharge to Bantam Brook (A) and because
soils suitable for a subsurface disposal system were
not available.
5.22 Phosphorus Removal/Level of Treatment
9 Comment: (R2, R3, R48, H10, H26)
Exactly how much phosphorus will be added to Lake
Lillinonah by the proposed system of wastewater collec-
tion and treatment in New Milford?
Response:
On an annual basis Lake Lillinonah receives a total of
592,970 pounds of phosphorus from all point and non-
point sources in the upper Housatonic watershed.
Slightly less than half of this total phosphorus load
on the lake is attributable to discrete point sources
such as industrial or municipal wastewater treatment
facilities. At the present time, the New Milford
Wastewater Treatment Facility contributes 10,130
pounds (1.7%) of phosphorus per year to Lake Lillinonah
(based on a flow of 550,000 gallons per day with a
phosphorus concentration of 6 mg/1).
At the design capacity of 4.0 MGD, the proposed New
Milford treatment facility by 1995 will annually con-
tribute approximately 73,100 pounds (11.1%) of phos-
phorus to Lake Lillinonah. All other things remaining
equal, this will increase the total yearly phosphorus
load on Lake Lillinonah to 655,940 pounds, a 10.4% in-
crease.
59
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Comment: (R16, R21, R30, R49, R51, R52, R57)
What will be the impact of this change in phosphate
concentration on Lake Lillinonah?
Response;
The relationship between phosphate concentration
and algae production is direct: all other things
being equal, a 10.4% increase in phosphate loadings
(see preceding response) on Lake Lillinonah will result
in approximately a 10% increase in algal biomass. This
condition would not occur, however, until the treatment
facility reached its design capacity of 4.0 MGD some
twenty years from the time of completion.
The above is a worst case speculation, as it assumes
no phosphorus removal capability will be added to any
facility on the Housatonic River. In fact, however,
two major sources of phosphates are soon to be allev-
iated. In Pittsfield, Massachusetts, the General
Electric Corporation is planning to alter several pro-
cesses and eliminate phosphorus from their wastewater.
At present GE annually disposes of 62,780 pounds of
phosphates in the Housatonic River. In Danbury,
Connecticut, phosphate removal facilities are cur-
rently being tested. The Danbury/Bethel Treatment
Facility contributes 154,300 pounds (26%) of phos-
phates annually to Lake Lillinonah. Removal of phos-
phates to the 90% level from these two sources should
reduce phosphate concentrations, and therefore algal
production, by approximately 30%. This reduction will
more than offset the increase in phosphate load attri-
butable to the proposed New Milford facility—the re-
sult will be a reduction in the algal biomass of Lake
Lillinonah.
Comment; (R3, R21, R25, R45, R55, H9, H26)
In light of Danbury's required treatment to tertiary
levels, why is phosphate removal not recommended at
the proposed New Milford Wastewater Treatment Facility?
Response;
In the controlled environment of the laboratory it
has been shown that a 10% reduction in the phosphate
concentration of Lake Lillinonah's water will result
in a 10% reduction in algal production. What will
60
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happen in the real world situation, however, is not as
clear. A 99% reduction in the phosphorus concentra-
tion of the Danbury/Bethel Treatment Facility effluent
should reduce the phosphate load placed on Lake Lilli-
nonah by some 25%. Theoretically this should reduce
algal production by 25% but this is only a logical
speculation. The vagaries of biological processes, of
absorption/desorption of phosphates in bottom sediments,
of water currents, of temperatures and thermal strati-
fications, and of other unknown variables makes the
evaluation of the actual impact of these phosphates
tenuous.
Because of these large unknowns (and the expense of
phosphorus removal vs. the lack of guarantee of results)
the State of Connecticut has opted to conduct phosphate
removal experiments at the Danbury Facility and to
monitor the resultant changes in algal production in
Lake Lillinonah. This is to occur during the summer
of 1977. The Commonwealth of Massachusetts is contem-
plating the same type of program at the Pittsfield
Treatment Facility to measure the impact of phosphate
removal on Woods Lake in the summer of 1978. Until
the results from the Danbury pilot project are obtained
and results are guaranteed, no installation of phos-
phate removal facilities are contemplated at any
treatment plant on the Housatonic River. This is the
reason phosphorus removal has not been recommended in
New Milford at this time.
Although phosphate removal is not recommended in the
Draft EIS, this does not mean that it is precluded.
The Carrousel Process, as all secondary treatment pro-
cesses, removes only an incidental amount of phos-
phorus in the treatment process. It is amenable, how-
ever, to the addition of either alum or ferric chloride
type phosphorus removal processes. The final decision
on whether, or not to.require phosphorus removal at
the proposed New Milford facility is ultimately con-
tingent in large part upon the results of the Danbury
pilot phosphate removal project.
Prudent fiscal policy dictates that the sources of the
phosphate problem be addressed in order of significance.
For this reason, Danbury is unquestionably the point
of highest priority.
61
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Comment: (B8)
Aren't industrial sources a major contributor of
phosphorus to the river?
Response:
The only maior industrial source of phosphorus on
the Housatonic River is the General Electric Corpo-
ration in Pittsfield, Massachusetts. Over the last
several years phosphorus effluent levels have been
reduced, but approximately 63,000 pounds of phospho-
rus are disposed of annually in the river by G.E. Be-
cause of bioloqical uptake and absorption by river
sediments, it is not known how much of this phosphorus
load reaches Lake Lillinonah. Within the next year
General Electric expects to make manufacturing process
changes which will completely eliminate all phosphorus
discharges.
Comment: (H3, H8)
Aren't the EIS and the Housatonic River Basin Plan
in conflict on the issue of tertiary treatment?
Response:
No. The Housatonic River Basin Plan states that (page
72):
"At the present time, the load from New Milford
without phosphorus removal (27.8 lbs/day) is
small in comparison to the average daily load
(492.6 lbs/day) of the Housatonic mainstream
However, the expected increase in this load to
219 lbs/day^ by 1990 will add significantly to
the P load on Lake Lillinonah. Serious con-
sideration should be given to requiring P removal
at the New Milford plant."
^Ed. Note #1—does not include Ten Mile River or Still
River.
2Ed. Note #2 — 4.0 MGD.
"7. the projected 1990 load from the New Milford
STP may add significantly to the phosphorous
loadings in Lake Lillinonah and may require phos-
phorus removal sometime in the future."
62
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The EPA concurs with the above statements. Confusion
may arise from the fact that phosphorus removal is
not recommended and the decision on its desirability
at New Milford is deferred until the results from the
Danbury pilot plant are available. It is not implied
by this statement in the Draft EIS that, phosphorus
removal is precluded at New Milford. In fact, care
has been taken in the process selection and design of
the plant for easy addition of phosphorus removal
equipment.
® Comment: (R23, R26, R48, R57, H7, H9, H26)
Continued dumping of wastewater in the Housatonic
River is an environmentally unsound principle which
is in direct contravention of the spirit of PL 92-500
Response:
See Section 6.22.
0 Comment: (R26, R57, H9)
Is phosphate removal compatible with the Carrousel
Process?
Response:
See Section 5.23.
a Comment: (R48)
Won't the continued dumping of wastes into the Housa-
tonic River contaminate drinking water sources?
Response:
No towns downriver of the proposed New Milford Treat-
ment Facility outfall utilize water from the Housatonic
River as a source of drinking water.
5.23 Carrousel Process
• Comment: (R19, R44, R55, H25)
Will the proposed Carrousel System work? What ex-
perience is there in the United States with the process?
63
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In Europe? How reliable is the equipment used and
the equipment suppliers?
Response:
As of May 1975, there were 79 Carrousel plants in
operation throughout the world. There were an addi-
tional 59 plants under construction or design.
In an attempt to determine the reliability, compati-
bility, and performance characteristics of the tech-
nique, questionnaires were sent out to eighteen operat-
ing facilities in Europe and South Africa. Informa-
tion, including plant performance data was received
from the following facilities: Almelo-Sumpel, Enter,
Losser, Ootmarsum, Westerhaar, Winterswijk, Lichten-
voorde, Apeldoorn, Hoensbrook, all in the Netherlands,
Copeja in Portugal and BASF in Germany. TABLE 7 pre-
sents the raw wastewater and effluent characteristics
at the various treatment facilities. Salient points
are summarized below:
Effluent Quality
BOD5, COD and various forms of nitrogen are the most
frequently monitored parameters in the Netherlands.
Sampling is normally conducted by the local regula-
tory agency and the pollution dischargers are levied
a fee according to the BOD5 content of their effluent
wastewater. In the area under the jurisdiction of
Waterschap Regge en Dinkel, there are seven Carrousel
treatment facilities. Records were submitted from
five of these facilities; the Rijssen and Hellendoorn-
Nijverdal facilities for which no records were received,
are relatively recent installations and apparently
records are not readily available. The design popula-
tion equivalents for these five facilities ranged from
6,000 to 115,000 persons; process trains at these
facilities are similar to those employed in the United
States in conventional activated sludge systems except
that the aeration basins are comprised of endless
channels, as opposed to rectangular concrete basins.
The BODc concentration in the raw wastewater ranged
from 277 mg/1 at Enter to 560 mg/1 at Almelo-Sumpel.
The effluent BOD5 ranged from 3 mg/1 at Losser to
15 mg/1 at Westerhaar. The BOD5 removal efficiency
ranged from 99.1% at Almelo-Sumpel to 96% at Westerhaar.
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TABLE 7
CARROUSEL EXPERIENCE
Facility
Flow
(MGD)
BOD 5
Removal
(%)
TKN
Removal
(%)
Total N
Removal
(%)
Almelo-Sumpel
2.
30
99.1
92.5
56.
5
Enter
0.
18
97.1
76.0
56.
5
Losser
1.
04
99.0
94.1
80.
0
Ootmarsum
0.
50
98.7
92.7
54.
6
Westerhaar
0.
122
96.0
92.0
71.
8
Winterswijk
4.
1
98.2
93.4
81.
0
Lichtenvoorde
-
99.5
97.3
-
Apeldoorn
13.
35
93.5
59. 0
-
Hoensbrook
9.
25
96. 0
88.9
-
Capeja (Portugal)
0.
6
98.8
Source: Anderson-Nichols & Co., Inc., 1977.
These treatment facilities are not designed to achieve
denitrification but a degree of denitrification appears
to be prevalent at most of these facilities. In an
activated sludge process, nitrogen removals on the
order of 10% to 20% can be expected. The Carrousel
instalations described above achieve nitrogen rei-
movals ranging from 56.5% at Almelo-Sumpel to 80% at
Losser.
The Winterswijk treatment facility is designed for a
population equivalent of 77,000; the influent BOD5 and
TKN concentrations are 343 and 59.4 mg/1 respectively.
The facility falls under the jurisdiction of Oostelijk
Gelderland Sewerage Authority. The denitrification
potential of the Carrousel process was examined at this
facility by the developers of the process. The first
eight months of operating results during 197 4 at the
facility, revealed that a 77.6% nitrogen depletion
efficiency can be achieved; the BOD^ removal efficiency
averaged about 98%.
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Xt may be concluded from the above that the Carrousel
facilities easily achieve BOD,- removal efficiencies
in excess of 90%; the process also appears to have an
inherent capacity to deplete the nitrogen content of
the wastewater.
Operating Problems
The Carrousel installations that fall under jurisdic-
tion of Waterschap Regge en Dinkel regulatory agency
do not experience any solids deposition related prob-
lems in the aeration basins. The average channel ve-
locity away from the aerating device is on the order
of 1 ft./sec. There has not been any need to dewater
the aeration basins because of.aerator failure^orr
other aerator-related problems. Surface mechanical
aeration-related problems such as excessive splashing
and spraying are prevalent in most of these installa-
tions and provisions to counter these, such as pro-
viding splashplates, have been made. The weather con-
ditions in the Netherlands have been mild over the
past several winters and the performance of the mechan-
ical aerators under winter conditions cannot be es-
tablished. Icing near and on the aerators is common
during winter conditions at many of these installations
in the Netherlands. Several measures that have been
practiced to counter this include providing shrouds,
heaters, etc. At most of the fixed platform type
aerator installations in the United States icing re-
lated problems, although prevalent, have not drastically
impaired the efficiency of the aeration devices.
Excessive mixed liquor concentrations (greater than
4,000 mg/1) are not normally employed and the ability
of the device to mix at concentrations in excess of
4,000 mg/1 cannot be established. The aeration capa-
city is normally controlled by mechanically varying
the depth of immersion of the aerator impeller which
in turn is controlled by D.O. probes. This practice
is not prevalent in the United States where the
depth of immersion is normally varied by adjusting
the effluent weirs. The practice of controlling
the aeration capacity by mechanically varying the depth
of immersion appears to be satisfactory at the Euro-
pean installations and have not created any insur-
mountable problems.
66
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The facility located at Apeldoorn also reports similar
results. At this facility there have not been any
odor or aeration basin related problems. The splash-
ing and spraying-induced problems at this facility
are countered by washing down the walls of the basins
at regular intervals. Icing-related problems have
occurred at this facility, but nothing severe enough
to hinder the performance was reported. The operating
data at this facility reports mixed liquor concen-
trations of 6,000 to 8,000 mg/1 during a few months
but the operator reports no solids settling in the
aeration basins. The operator at this facility, how-
ever, has experienced some reservations regarding the
efficiency of the aerators. The manufacturer proposes
to increase the impeller speed from the existinq 26.5
rpm to 29.5 rpm to achieve the oxygenation capacity
guaranteed earlier. Bulkinq sludqe conditions have
been prevalent at this facilitv. This condition may
be induced bv a 65% industrial wastewater contribu-
tion to the plant, mainly from paper makinq and laun-
dry works.
The Hoensbook facility has been in operation since
1974. The operator reports adequate mixing veloci-
ties, tolerable noise levels, and non-excessive
splashing. Icing on and near the aerator has been
prevalent but has not affected the performance of the
device. The operator feels that some of the inherent
advantages associated with the process include extremely
high removal efficiencies and relative insensitivity
to fluctuating loadings.
At this time, experience with the Carrousel system is
somewhat limited in the United States. As of May
1977, the Carrousel Process is being contemplated
for use in some twenty to thirty municipal and indus-
trial applications. There are six systems in some
stage of design, and one system in operation. This
system is located in Winchester, NH at the A. C.
Lawrence Tannery. It has a design flow of 380,000
gallons per day and is currently operating at 325,000
gallons per day. The Carrousel system is preceded
by alum addition and dissolved air flotation designed
to remove much of the high oil and grease content of
tannery wastewater. Effluent entering the Carrou-
sel basin from the flotation chambers has a BOD^. of 350
to 40 0 mg/1 and a TKN of 40 to 50 mg/1 (approxi-
the Carrousel has a BOD- of 15 to 20 mg/1 (approxi-
mately 95% removal) and a TKN of 25 mg/1 (approximately
50% removal).
67
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The wastewater from the tannery is very warm and dur-
ing the past winter the temperature in the Carrousel
rarely dropped below 50°F. No odor, noise, splashing,
or sludge settling problems have been encountered
to date. In summary, the plant appears to be operat-
ing very efficiently with minimal problems since it
went on line in December 1976.
Several comments implied that because the Carrousel
Process was of foreign design and utilized foreign
equipment, that it was a less than reliable process.
European wastewater treatment technology is among the
best in the world. Virtually all major waste treat-
ment techniques were devised in Europe.
Virtually all plant components are commonly manufac-
tured in the U.S. If any foreign equipment is used
in plant construction it must meet the same strin-
gent specifications under which all equipment is
purchased. In short, the proposed Carrousel system
should be completely reliable from an equipment and
a process standpoint.
• Comment: (R26, R57, H9, H25)
What is the adaptability of the Carrousel system to
phosphate removal? Nitrate removal? Has this been
done anywhere? What would the capital cost be?
Operation and maintenance cost?
Response;
In the Carrousel facilities in the Netherlands all
phosphate removals are incidential to the process.
The basis of the Dutch anti-pollution law is to deplete
the oxygen demanding pollutants from wastewaters.
BODg and Total Kjeldahl Nitrogen are the most fre-
quently monitored parameters.
Nitrification (i.e., conversion of ammonia and organic
nitrogen into nitrates) is prevalent at most Carrou-
sel installations. Nitrification, however, is also
prevalent in the more conventional aeration basins,
and it is not unique to Carrousel installations.
68
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As far as removal of nitrogen goes (i.e. transforma-
tion of all nitrates to nitrogen gas), the development
and quantification of the parameters is in its infancy
at this stage—see preceding comment. As was delineated
in the preceding response, nitrogen removal efficiency
of 77% has been achieved at some of the existing
Carrousel installations; in conventional activiated
sludge systems nitrogen removal efficiencies on the
order of 20% can be expected.
The Carrousel version of the activated sludge pro-
cess appears to have a potential for accomplishing
some degree of nitrogen removal in the same basis;
denitrifcation is normally achieved in the United
States in a separate basin or contactor which
is more amenable to control. More process develop-
ment work is required before the design parameters
can be established.
Addition of nitrification-denitrification equipment
to the proposed New Milford facility to achieve ni-
trogen removals to the 90+% level would require a
capital investment of approximately $920,000 and an
annual operation and maintenance cost of $86,000.
Phosphate removal is normally not practiced in Europe
and none of the investigated plants appear to have
phosphate removal in their processes trains.
Phosphate removal process additions have been dis-
cussed in the Draft EIS.
Addition of phosphorus removal equipment to the proposed
New Milford facility to achieve 90+% removal effic-
iency would require a capital investment of approxi-
mately $830,000 and an annual operation and maintenance
cost of $195,000. If phosphorus removal were accom-
plished utilizing the Carrousel basin (instead of add-
on equipment) capital equipment costs would be reduced
to approximately $210,000 while operation and mainten-
ance costs would be changed little. This system of
phosphorus removal, although less expensive, would
preclude the addition of nitrogen removal facilities.
(Similar alum addition in any conventional treat-
ment facility would also preclude nitrogen removal.)
69
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• Comment; (R54, R57)
Why is the Carrousel Process specified if it has no
inherent advantages?
Response:
Analysis by EPA and Anderson-Nichols & Co., Inc., has
shown no great technical advantages to be gained
through the use of the Carrousel Process at New Mil-
ford. At the same time, this analysis has discovered
no specific disadvantages inherent in the process nor
has it shown any other process to have significant
technical advantages.
Analyses of the cost effectiveness of the Carrousel
Process by both EPA and Anderson-Nichols & Co., Inc.,
has shown it to have no overwhelmingly significant
economic advantages or disadvantages. Present
worth cost anlaysis showed the system to be of present
worth comparable to other systems. In the Draft EIS
(APPENDIX B) the Carrousel system was shown to have a
present worth of $12,124,000 which is $56,000 (0.46%)
more than the "most cost effective solution". It
should be realized, however, that because of the crude
nature of the cost effectiveness calculations that
present worth values within ±10% of each other are
considered to be comparable. Thus, the Carrousel
system can be said to be a cost effective solution
in New Milford.
Metcalf & Eddy views the following as inherent ad-
vantages of the Carrousel Process (R60):
"a. The lesser number of aerators required in
the Carrousel vs. complete-mix. Although
essentially the same installed horsepower
is required in either process, the mixing
requirements of complete-mix systems re-
quire mor© aeration units. We believe the
reduced maintenance on fewer required units
is an inherent advantage.
70
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b. In the New Milford design, it will only be
necessary to operate one of the two aerators
(per basin) to maintain adequate channel ve-
locities. Shutting off half of the aerators
in a complete-mix basin would result in in-
adequate mixing (at least in an extended
aeration design). We feel the ability to
operate at reduced power levels and resul-
tant lower costs, during low loading periods,
is an inherent advantage.
c. The Carrousel design may be effective in accom-
plishing denitrification without additional facil-
ity construction or methanol addition. We feel
that this is an inherent advantage.
d. Lastly, we believe that the inherent combin-
ation of complete-mix and plug-flow zones
will result in more reliable effluent quality
than would result with use of a conventional
complete-mix process."
Comment; (R19, R55, R58)
Why is the Carrousel process specified if it has only
secondary treatment capabilities?
Response:
There are two answers to this question: (1) secon-
dary treatment capabilities are all that are required
by and funded by the State of Connecticut and the En-
vironmental Protection Agency for New Milford at this
time, and (2) no biological treatment system is cap-
able of treatment beyond secondary levels (BOD, COD,
and solids removals in excess of 90%). Tertiary
treatment (PO^, NO, removal among others) is accom-
plished in any conventional treatment system only
through the addition of various physical/chemical pro-
cesses after the wastewater has been treated to secon-
dary levels.
Comment: (R44, H25)
Why are primary settling tanks not included in the
design?
71
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Response:
The purpose of primary settling tanks is to remove
solids and BOD through the sedimentation of particulate
solids. In a treatment facility treating average do-
mestic wastewater, BOD^ removals of up to 20% can be
achieved. (B0D5—Biochemical Oxygen Demand—is that
quantity of oxygen required to decompose waste or-
ganic materials). In the case of New Milford, how-
ever, an abnormally high percentage of the BOD- is in
a soluble form and removal efficiencies in primary
settling tanks would be low. In a cost analysis,
Metcalf & Eddy determined that, because of the low
primary BOD removal efficiencies, the BOD would be
more economically removed by increasing the aerator
capacity in the aerated basins. Final effluent qual-
ity will not be altered.
• Comment: (R55)
What impact will wastewater from Nestles have on the
operation of the Carrousel system? What impact will
it have on the effluent character?
Response:
Because of the high NO^ content of Nestle's wastewater,
certain design modifications h aye been made in the
Carrousel system. (Similar alterations would be re-
quired no matter what treatment system employed.)
Inclusion of Nestles1 wastewater will not alter nor-
mal operation of the treatment facility nor will it
alter the quality of the effluent except for its nitro-
gen content which will be increased above that of munic-
ipal sanitary wastes alone.
• Comment: (R44, R55, H20, H25)
How susceptible is the Carrousel Process to upsets?
Why is such a sensitive system recommended? What
would be the impact of such upsets or failures?
Response:
The Draft EIS unfortunately left the wrong impression
regarding operation of the Carrousel system (page
283). EPA and Anderson-Nichols agree with Metcalf &
Eddy's response (Document R60);
72
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"You note that close control of the biological
process is essential in order to consistently
meet effluent limitations. This is true, of
course, of any activated sludge process, par-
ticularly where short aeration tank detention
times and high secondary settling tank overflow
rates are employed. At the New Milford plant
the design overflow rate at the peak flow of 11.88
MGD is 7 56 gpd/sf. This relatively low over-
flow rate along with return sludge pumping cap-
ability 100% of average flow should assure the
stability of the process when considering that
the average aeration tank detention time is 24
hours."
In a recent study by EPA Region VII (Winter Perfor-
mance of Secondary Wastewater Treatment Facilities)
of 226 secondary treatment facilities only oxidation
ditches (of which the Carrousel process is an improved
modification) averaged secondary treatment or better.
When compared to other biological secondary processes
(covered and uncovered trickling filters, conventional
activated sludge, aerated lagoons, and package plants)
removal efficiencies in oxidation ditch facilities
were consistently higher. A summary of the survey
shows:
TABLE 8
COMPARISON OF SECONDARY TREATMENT METHODS
Removal Efficiency (%)
Plant Type
No.
BOD 5
COD
SS
NH^-N
P04
Lagoons
80
76.3
48.2
66.8
54.4
41.3
Activated Sludge
41
78.0
65.3
77.7
35.2
32.1
Trickling Filter
89
82.1
76.5
82.2
53.5
15.3
Package Plant
9
73. 6
69.5
70.0
55. 0
28.2
Oxidation Ditch
7
93.1
90.7
94.1
76.8
28. 8
73
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Because of the great similarities in „ the ^oxidation ..ditch
and Carrousel process, it can be conlcuded that the
Carrousel system proposed for New Milford will be a
highly reliable system, perhaps more reliable than
other conventional treatment processes.
Comment; (R23)
Is there really an energy savings to be gained by
employing the Carrousel system?
Response:
This question is open to discussion and is primarily
dependent upon the total number of aerators in the
aerator basins. It is argued by the proponents of
this concept that pacing the oxygenation capacity by
D.O. probes and switching off aerators during low
oxygen demand period should result in lower power
costs. While it is true that these benefits will be
realized by implementing the above control measures,
they are not unique to the Carrousel version of the
activated sludge process, and the same advantages can
be realized by proper design of conventional basins.
In extended aeration processes, such as the one pro-
posed at New Milford, some power savings may be real-
ized during certain periods of time when the power
required to meet the oxygen demand exceeds that re-
quired to keep the contents of the aeration basin
mixed. It is doubtful if power savings can be achieved
by switching off the aeration devices at New Milford
since the aeration basin contains only two aerating
devices, and it is unlikely that adequate mixing can
be achieved by operating one aerator.
In summary, some power savings can be achieved by op-
timum operation of the aeration devices; however,
these savings are not unique to the Carrousel Process.
Comment; (R19, R23, R55, R57, R58, H25)
Is the Carrousel system cost effective? How were cost
figures derived? Are royalties/patent fees included
in cost figures?
Response:
The Carrousel system is a cost effective solution to
wastewater treatment in New Milford. Analysis by
74
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Metcalf & Eddy, Anderson-Nichols, and EPA Construction
Grants Section has shown this to be so (see third com-
ment in this Section). Cost effectiveness was computed
in the manner prescribed by EPA in the Federal Register,
Vol. 39, No. 29--Monday, February 11, 1974 (as amended).
Construction costs were calculated using standard engi-
neering cost factors (such as those contained in Building
Construction Cost Data) and updated in proportion to
the ENR cost index.
EPA has determined that patent fees and royalty costs
associated with the Carrousel sysem are allowable cost
items as long as they are part of a cost effective
solution. These costs have been included, therefore,
in the cost effective analysis (see page 288 of the
Draft EIS).
Comment: (RIO)
What would be the impact of viruses, toxic metals,
and carcinogenic hydrocarbons in the effluent from
the Carrousel system?
Response:
The effluent from the proposed New Milford treatment
facility will be of the same quality with respect to
these chemicals, no matter whether the Carrousel sys-
tem or any more conventional treatment process is used.
Comment: (R26)
What will the aerosol impacts of the Carrousel sys-
tem be?
Response:
Relatively little study has been conducted on aerosol
dispersion of bacteria and viruses by conventional
wastewater treatment systems. Research has shown,
however, that treatment facilities do produce biolog-
ical aerosols and that, depending on meteorological con-
ditions, these bacteria and viruses may remain viable
for varying distances downwind of the plant. Although
virtually every component of a conventional treatment
facility has been identified as an aerosol source,
aerator equipment is the overwhelmingly major source.
75
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Aerators (no matter whether in a trickling filter,
activated sludge, oxidation ditch, or Carrousel type
facility) produce splashes and bubbles in the process
of wastewater aeration. Bacteria and viruses are en-
trained in these water particles and are carried down-
wind. The vast majority of these organisms carry
no farther than the limit of any spray, but signifi-
cant numbers of bacteria have been collected hundreds
of feet from the treatment facility. Beyond this dis-
tance desiccation (drying out) destroys the organisms.
(In order to put this all in perspective it should
be noted that there is a significant concentration of
airborne bacteria and viruses that is naturally occur?
ring.) Limited epidemiological research has, however,
not shown the incidence of disease that might be
traced to a treatment facility to be any higher among
plant operators and residents of adjacent neighbor-
hoods than among the general population (Hickey, J.L.S.,
and Reist, D.C., Health Significance of Airborne Micro-
organisms from Wastewater Treatment Processes, Journal
of the Water Pollution Control Federation , December
1975).
Because of the relatively low speed and largely sub-
merged configuration of the aerators of the Carrousel
system proposed for New Milford it would seem probable
that aerosol production would be lower than that of an
oxidation ditch (with rotary brush aerators) and tricks-
ling filters. Both of these systems are used extensively
with no known adverse health effects. The distance
of the New Milford facility from the nearest homes
(about 500 feet) is further insurance that biological
aerosols will not be a matter of concern.
5.2 4 Nestles
e Comment: (R21, R54, R55)
What is the impact of Nestle's wastewater on the Carrou-
sel Process? Are they compatible ? What would be the
impact on the proposed New Milford treatment facility
if Nestles effluent were eliminated?
Response:
See Section 5.23.
76
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• Comment.; (R22, R23, R30)
How important is Nestles as a source of pollution
in the Housatonic River? What is the "strength" of
Nestles wastewater? Could they build their own treat-
ment facility?
Response:
Nestles is a significant wastewater contributor
to the Housatonic River in the New Milford area. At
this time Nestle's wastewater is discharged to the
river with very little treatment. The concentrations
of materials discharged and the consequent loading on
the Housatonic River are listed below. Process
water wastes amount to approximatley 250,000 gallons
per day and cooling water wastes amount to 600,000
to 700,000 gallons per day.
The most significant constituents of Nestle's wastewater
are the high nitrate and organic loads placed upon the
river. Organic loads (both solids and dissolved chem-
icals) are decomposed by bacteria in the river. This
decomposition process requires large amounts of oxygen—
resulting in reductions in dissolved oxygen concen-
trations downstream. Construction of the Dronosed 4.0
MGD facility at New Milford (with inclusion of Nestles)
will reduce daily oxygen demand loading on the river
to approximately 1,300 pounds per day. This is a very
significant reduction from the current loading of
11,600 pounds per day from Nestles alone—and includes
an addition of more than 2.7 MGD of domestic sewage.
High nitrate loading on the river from Nestles is also
responsible, in small part, for high nitrate nutrient
concentrations in Lake Lillinonah. Evidence gathered
by the EPA (Nutrient—Algal Relationships in Lake Lil-
linonah, EPA—300/2—75-009, November 1975) suggest
that nitrates are responsible for early summer blooms
of green algae Selenastrum. Nestle's contributes
approximately 150,000 pounds (2.5%) of nitrates an-
nually to Lake Lillinonah, which has a total annual
load of approximately 6.6 million pounds of nitrates.
Nestles has made several studies of the technical
feasibility and cost of building their own treatment
facility. Such a treatment facility would present
no major technical problems. At this time, however,
Nestles is operating undr NPDES Permit No. CT 0000850
and Order No. 520 Modified which orders the company to
77
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TABLE 9
: ?
COMPONENTS OF NESTLES WASTEWATER
Waste Constituent Strength Loading
Total solids
3,870
mg/1
8,000
lb/day
Total volatile solids
2,070
mg/1
4,300
lb/day
Suspended solids
84
mg/1
175
lb/day
Suspended volatile solids
65
mg/1
134
lb/day
Oil and grease
54
mg/1
113
lb/day
Asnoonia j.nitrogen
77
mg/1
161
lb/day
Organic nitrogen
126
mg/1
265
lb/day
Total kjeldahl nitrogen
204
mg/1
427
lb/day
Total phosphorus
26
mg/1
53
lb/day
Chemical oxygen demand
3,260
mg/1
6,800
lb/day
Biochemical oxygen demaind
2,300
mg/1
4, 800
lb/day
Source: Metcalf & Eddy, Inc., Report to the Nestles
Company, Inc. Upon Process Waste Characteristics
at the Maggi Division Plant, New Milford
discharge its process wastewater to the Town of New
Milford municipal sewer system. Compliance with this
order is dependent upon construction of a new treat-
ment facility.
5.25 Plant Site
• Comment: (Rl, R21, R23, H26)
What is the impact of siting the treatment facility
over an aquifer? In a floodplain? In a wetland?
On vegetation?
Response:
Situating the treatment plant over an aquifer will
have no impact on the aquifer or the treatment plant.
The facility will be impermeable to the infiltration
of groundwater and the exfiltration of wastewater.
78
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Only a small portion of the proposed treatment faci-
lity will be located on land designated as wetland.
This land is now used for agricultural purposes and
is not a unique wildlife habitat in any way. Con-
struction of the facility on this wetland area will
have no impact on the plant or the wetlands for
reasons stated in the preceding paragraph.
Impacts on vegetation at the treatment facility site
are discussed on page 2 00 of the Draft EIS.
Floodplain impacts are discussed in Section 5.26 of
this document.
5.26 Flooding
• Comment: (R21, H7, H10)
Growth induced by the recommended project will change
runoff characteristics in New Milford. How will this
impact flooding potential in New Milford?
Response;
It is true that development of a natural area will
increase stormwater runoff from that area. The
resulting impact on potential flooding is, however,
impossible to accurately assess without extensive
detailed knowledge of the entire hydrologic basin.
Such work is beyond the scope of this EIS. A general-
ized scenario of possible impacts on flooding is
presented below.
Maximum residential development induced by the pro-
posed project would be in the range of 2,000 to 2,500
homes. A large portion of this development will
certainly not be of the "urban" type: significant
natural area will remain and will be capable of ab-
sorbing much of the increased roof and paved area
runoff. Increase in the amount of precipitation
from these areas which will reach nearby watercourses
as runoff will, therefore, be relatively small. In
the "urbanized" downtown areas where induced develop-
ment will be primarily of the "filling in" type,
relatively more will reach watercourses.
79
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Although runoff will increase somewhat, the resulting
impact is not necessarily negative. The runoff rate
will increase as the runoff volume increases. De-
pending on the hydrologic characteristics (primarily
time of concentration) of a given drainage basin, an
increased runoff rate may result in decreased flood-
ing height downstream.
On the other hand, flood height downstream may be
increased. Such an increase in New Milford, however,
would probably be small. The area of induced growth
(and increased runoff) is only a very small proportion
of the total watershed areas of the Aspetuck, Still,
and Housatonic Rivers. The increased runoff induced
by the proposed project will be readily absorbed by
these streams.
0 Comment: (R3)
How will flooding in the Housatonic River valley impact
the proposed treatment facility?
Response:
Under EPA guidelines, any wastewater treatment facility
must meet the following criteria in order to be eligible
for funding:
(1) It must be able to operate during a 25-year flood.
(2) It must be protected from a 100-year flood. (A
100-year flood is a flood of that magnitude which
has an expected frequency of occurrence of once
in 100 years).
In the vicinity of the proposed New Milford Treatment
Facility, the Housatonic River has a 100-year flood
height of 212+ feet. The elevation of the lowest com-
ponent of the proposed treatment facility (chlorine
contact tank exit weir) is 212.34 feet and the eleva-
tion of the top of the tank is 215.20 feet. The treat-
ment facility is therefore, protected from damage and
upsets resulting from flooding of the Housatonic River
by its elevation above the river.
30
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5.27 Air Pollution
• Comment: (R9, R21, R25, R57, H7, H10)
Growth induced by the proposed project, will induce
more traffic. How will this impact air quality,
especially with respect to ozone and photochemical
oxidant concentrations?
Response:
Ozone and photochemical oxidant concentrations cannot
be attributed to, or analyzed as, local micro-scale
sources or conditions. Instead, they lend themselves
more legitimately to a regional analysis. These are
very few direct sources of ozone and photochemical
oxidants themselves. They are produced (and destroyed)
in a complex series of chemical reactions dependent
upon sunlight, meteorological conditions, and concen-
trations of man-made precursors. Important ozone
precursors include hydrocarbons and oxides of nitrogen.
The rate of reaction varies according to fluctuations
in the above parameters. As a result, ozone and photo-
chemical oxidant concentrations may be higher many miles
from the source than they are at the source.
Ozone concentrations commonly violate State and Federal
ambient air quality standards across the entire State
of Connecticut. This condition is attributed by the
Connecticut DEP to the state's position relative to the
New York-New Jersey-Connecticut metropolitan region:
predominantly downwind in the summer when solar inten-
sity is greatest and oxidant production is highest. As
a general rule, the frequency of ozone standard viola-
tions decreases traversing the state from west to east.
There is little direct correlation between oxidant con-
centration and population concentration; the rural town
of Morris had one of the highest incidences of ozone
standard violation in 1975 while Windsor had one of
the lowest violation incidences.
Growth, induced by the proposed project (8100 people
by 2000), will probably result in an increase of 3000
to 3500 cars in Brookfield and New Milford. In a regional
analysis of ozone and photochemical oxidant levels,
these few cars are clearly inconsequential. In addi-
81
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tion, full implementation of the Federal Automobile
Emissions Standards will result in a 90% reduction of
automobile hydrocarbon and oxides of nitrogen emissions
by 1990. This clearly, more than offsets the slight
increase in traffic from natural growth and growth
induced by the project.
The impacts of increased particulate and sulfur dioxide
concentrations resulting from the proposed project
are discussed in the Draft EIS.
5.28 Nitrates and Nitrate Removal
• Comment: (R26, R49)
What will effluent nitrate contributions to Lake Lilli-
nonah be under the proposed project? What will be the
impact on the lake?
Response:
At the present time, Lake Lillinonah is subjected to
a nitrate load of 6,617,470 pounds per year. The com-
bined flows of the present treatment facility and
Nestle's constribute 182,600 pounds (or 2.8%) of
nitrate annually to the lake. In the future, a 4.0 MGD
treatment facility, which would include treatment of
Nestle's waste (assume 50% nitrogen removal), would
contribute 199,500 pounds (or 4.8%) of nitrate annually
to the lake.
Evidence gathered by the EPA (Nutrient - Algal Rela-
tionships in Lake Lillinonah, EPA 300/2-75-009.
November 1975) suggests that excess nitrates are
responsible for early summer blooms of the green algae
Selenastrum. A 2% increase in nitrate loading on the
lake, attributable to the New Milford treatment facility,
may result in approximately a 2% increase in Selenastrum
production.
• Comment: (H20)
What is the potential impact of nitrates in drinking
water on human health?
Response:
From .Water Quality Criteria (McKee & Wolf 1973)
82
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"Until 1962, the USPHS Drinking Water Standards
did not have a requirement for nitrates. At
that time, however, a:.recommended limit of
45 mg/1 as nitrates was established. The WHO
European Drinking Water Standards have a re-
commended limit of 50 mg/1 as nitrates. No
limit has been set for the WHO International
Standards. These limits were established
because of the relationship between high ni-
trates (or nitrites) in water and infant meth-
emoglobinemia. No cases of such poisoning have
been evident in the U.S. when the water con-
sistently contained less than 45 mg/1 of ni-
trate as NOg or 10 mg/1 as nitrogen.
Infant methemoglobinemia, a disease character-
ized by certain specific blood changes and cya-
nosis, may be caused by high nitrate concen-
trations in the water used for preparing feed-
ing formulae. Since the disease often does
not occur even where the water is very high in
nitrate content, however, it seems likely that
not all infants are susceptible to nitrate
poisoining but that some are predisposed to it
by physiological conditions such as low gastric
acidity or other unknown factors. Many well
waters, containing over 500 mg/1 of nitrate nitro-
gen, have never been linked with reported cases.
Most cases, however, have been associated with
the use of water contining 50 mg/1 or more of
nitrate nitrogen. While it is still impossibl-
to state precise concentration limits, it has
been widely recommended that water containing
more than 10 mg/1 of nitrate nitrogen should
not be used for infants."
The use of sodium nitrate (and the subsequent formation
of nitrosamines) as a meat preservative in bacon, hot
dogs, and bologna, has been linked with stomach cancer.
EPA is currently investigating, as a part of the National
Primary Drinking Water Standards Program, the signifi-
cance of these substances as carocinogenic agents in
drinking water supplies.
83
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• Comment; (R26)
What would be the capital cost of adding nitrate removal
capacity to the proposed Carrousel System? What would
the operation and maintenance costs be?
Response:
See Section 5.23.
5.29 Solid Waste
• Comment: (R52, H26)
Won't sludge from the proposed treatment facility
aggravate current solid waste disposal problems?
Response:
Construction of the proposed treatment facility will
have two impacts on solid waste disposal:
(1) The addition of sewage sludge to the SCA land-
fill will represent only a small additional
increment in waste disposed at that site
(2) Construction of septage handling facilities
at the proposed plant will eliminate the land
area currently reserved at the landfill for
septage disposal. The combined impact of
these two factors will result in approximately
a 1% reduction in the useful life of the land-
fill.
• Comment: (R23, H26)
How can the Draft EIS recomend sludge disposal at the
SCA (McNulty) Landfill when no agreement has been
reached with SCA?
Response*
The SCA Landfill is a logical and suitable site for
disposal of sludge produced by the treatment facility.
No study prior to the Draft EIS has ever seriously
considered any other disposal site. Legal agreement
for the use of the landfill is a matter which must be
resolved by SCA and the Town of New Milford.
84
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Comment: (R26)
How will sludge disposal impact the aquifer underlying
the landfill?
Response;
Proper disposal of stabilized sewage sludge in a
sanitary landfill will not affect underlying ground-
water and is an EPA approved method of disposal.
Elimination of raw septage disposal at the landfill
site will benefit the aquifer by eliminating poten^
tially harmful leachates. The aquifer beneath the
landfill is not the same one as beneath Sunny Valley
Farm.
Comment: (R26)
What would be the impact on solid waste production of
chemicals added to the treatment process for phosphate
removal?
Response:
Addition of alum to New Milford's removal system as a
phosphorus removal method would significantly increase
sludge volumes produced by the plant. Without phos-
phorus removal, the 4.0 MGD Carrousel Plant is expected
to produce 7980 pounds (dry weight) of sludge per day.
If phosphorus removal to the 90% level were accomplished
as a post aeration step (after the final clarifier), an
additional 2940 pounds of sludge would be produced per
day. If phosphorus removal were accomplished by alum
addition to the raw wastewater in the Carrousel basin,
an additional 7610 pounds of sludge would be produced
per day.
The impact of this additional sludge production would
be most pronounced at the disposal site. At the SCA
landfill site, sludge from the facility (without phos-
phorus removal) would be expected to diminish the use-
ful life of the facility by about 1%. With the addi-
tion of phosphorus removal capabilities, the total
volume of waste disposed at the landfill will be in-
creased to 1.35% or 1.95%, depending on the removal
technique employed.
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5.30 I/I and Separation of Sewers
• Comment: (R3, R25)
How much I/I is currently treated? Where does it come
from? Will it be eliminated? How much will come from
the new system?
Response;
Metcalf & Eddy completed a study of infiltration and
inflow to the New Milford sewerage system in 1973.
A summary of the results of that report follows:
Findings
1. The average wastewater flow rate for the study
year (1973) from the Town of New Milford collec-
tion system was 415,000 gpd (gallons per day).
2. The average water consumption in 1973 within the
collection system was 558,000 gpd, or 132 gcd
(gallons per capita per day).
3. The portion of the average water consumption in
1973 that may have reached the sanitary collec-
tion system was 347,000 gpd, or 82 gcd.
4. The total average infiltration/inflow rate is
approximately 137,000 to 157,000 gpd, and the
total maximum infiltration/inflow rate is
1,747,000 gpd.
5. The average and maximum inflow rates are 15,300
gpd and 1,605,000 gpd, respectively.
6. Fifty-four percent of the infiltration enters
through the East Branch and Great Brook trunk
sewers. Construction of the proposed East Shore
Interceptor and Great Brook Trunk Sewer will
eliminate 36% of this infiltration (3% of the
total maximum infiltration/inflow).
7. Sixty-two percent of the maximum inflow enters
the sewer system through vented manhole covers
located along the East Branch and Great Brook
trunk sewers. Construction of the proposed East
Shore Interceptor and Great Brook Trunk Sewer
will eliminate this inflow (57% of the total
maximum infiltration/inflow).
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Conclusions
1. Several inflow sources were identified in the
course of the study. Their elimination, conse-
quently, does not require an Evaluation Survey.
Removal of these inflow sources will eliminate
17% of the total maximum infiltration/inflow.
2. An Evaluation Survey will be required prior to
elimination of inflow sources such as connected
roof drains, catch basins, area drains and other
miscellaneous sources. It has been estimated
that up to 19% of the total maximum infiltration/
inflow could be eliminated in this manner.
3. Rehabilitation of those sections of the East
Branch Trunk Sewer to remain in use, laterals
and service connections, would eliminate 3% of
the total maximum infiltration/inflow. It has
been found that elimination of these sources of
infiltration is not cost-effective.
4. It has been estimated that if the recommendations
made herein are implemented, up to 94% of the
existing total maximum infiltration/inflow (42%
of the total average infiltration/inflow) could
be eliminated from the system.
Recommendations
1. Replace eight vented manhole covers with solid,
gasketed manhole covers.
2. Eliminate yard drain adjacent to the Agway Store.
3. Conduct an Evaluation Survey to define a program
for the elimination of connected roof drains,
catch basins, area drains and other miscellaneous
sources.
4. Construct the proposed sewerage system facilities
with sufficient capacity to transport and treat
the uneliminated infiltration/inflow.
Sewer reconstruction and/or replacement as a result of
of this study has not been accomplished as of this
writing but still remains an important part of the
Facilities Planning process in New Milford.
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In the construction of new gravity sewers, it is not
possible to eliminate all infiltration (this is not
the case with force mains). Inevitably, some small
amount of groundwater will infiltrate into the system
through the joints between the pipes. Typically, a
design allowance of 200 gallons per inch of pipe
diameter per mile of pipe per day is made for infil-
tration. In the New Milford system, infiltration
will total 150,000-200,000 gallons per day.
« Comment: (R3)
What will be the impacts of infiltration on the
water table? Exfiltration?
Response:
Infiltration of groundwater is in such minor amounts
that there will be no measureable impact on groundwater
level. Exf iltration (if any) is. even a smaller consid-
eration and will similarly have no impact on the water
table.
5.31 Energy
• Comment: (R36, R49)
Why, in light of present energy concerns, is an energy-
intensive project recommended in the Draft EIS?
Response:
Energy is only one concern in a myriad of considera-
tions resulting in the decision to build a treatment
facility. In New Milford, water quality, groundwater
protection, public health, and development pressure
concerns overrode energy considerations.
This does not mean, however, that the design of the
proposed wastewater collection and treatment system is
oblivious of the present energy situation. Gravity
sewer lines are utilized where possible, in order to
reduce the need for pumping. In addition, the utiliza-
tion of the Carrousel system may realize some small
energy savings over other conventional systems (see
Section 5.23).
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5.32 System Reliability
• Comment: (R20, R36, R54)
What will be the impact of an electrical failure?
Of a pump failure? Of a pipe failure?
Response:
The treatment facility and all of the pump stations
will be equipped with emergency electrical generators.
These generators will come into use automatically in
the event of power failure and will be provided suffi-
cient electrical power to maintain normal treatment
plant and pumping functions. In addition, all critical
operating equipment is redundant, i.e., standby equip-
ment is designed into the system. The possibility of
a failure resulting in raw sewage discharge to a
stream or waterbody is extremely slight.
5.33 Sewers in Watershed
9 Comment: (R12, R39, H4)
How does the Draft EIS recommendation to sewer portions
of Paper Mill Road and East Aspetuck Road in the
East Aspetuck River watershed reconcile with the
policy stated in the Connecticut Plan of Conservation
and Development discouraging extensive residential
development in such watershed areas? How does the
Draft EIS reconcile its recommendation for sewers
in the Sunny Valley area with similar water management
policy concerning the underlying aquifer?
Response:
For purposes of reference, a summary of pertinent
policies from the State of Connecticut Plan of Conser-
vation and Development is reproduced below. Note that
there is no State policy relating specifically to
residential development as stated in Documents R12
and H4.
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POLICY NO. 1
Establish and protect sufficient water supply sources
to meet future water supply needs.
la. The future water supply needs of the state
should be met, in part, through those water
supply reservoirs, diversions, and high priority
underground sources (aquifers) depected on the
Water Use Policy map.
lb. As a general principle, water supply should
be obtained from groundwater resources before
resorting to the creation of new impoundments.
lc. The state should develop mechanisms to protect
and preserve the 91 water supply sites identi-
fied. Although future studies may show some
of these sites to be less desirable than others,
all should be protected.
lc. Until the water yield obtainable from high pri-
ority underground sources (aquifers) identified
on the Water Use Policy map, all uses of the
land above these aquifers should be limited to
present activities.
le. The watersheds tributary to the water supply
reservoirs delineated on the Water Use Policy
map should be managed to ensure the quality of
the impounded waters for their intended pur-
poses .
If. Continue the practices of not permitting direct
waste discharges into streams tributary to
public water supplies and not constructing
water supply facilities which would be fed by
wastewater receiving streams.
lg. Limit the discharge of liquid wastes to those
"wastewater receiving streams" identified on
the Water Use Policy map.
lh. Lands which are presently maintained in an open
state for the purpose of protecting a public
water supply should be continued to be main-
tained in that state.
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POLICY NO. 6
Encourage urban development to be at sufficient densi-
ties for the economic provision of services.
6a. Encourage the provision of both public sewer
and water service in all new development where
either service will be needed.
6b. Encourage residential development in those
areas identified as Suitable for Urban
Development to be at densities of one
dwelling unit or more per half acre of
residential land.
POLICY NO. 7
Promote staged, contiguous development within
areas Suitable for Urban Development.
7a. Stage the construction of sewer lines in
such a manner as to discourage sprawl.
7b. Encourage larger scale, innovative pri-
vate development projects which provide
opportunity for greater variety and choice
of lifestyle and economy in the provision
of public services.
7c. Urban development should be staged in ac-
cordance with the criteria and priorities,
as reflected in the Urban Development
Opportunities and Limitations map.
7d. Certification of availability of sewer and
water service should be obtained prior
to approval of any new construction in
sewer and water service areas.
The area of the East Aspecuck River watershed that is
recommended for sewering on the Draft EIS is not one
of the ninety-one water supply sites identified on
the Water Use Policy map as a protected area (Policy lc).
This area of the East Aspetuck "River watershed is, in
fact, designated as potential urban area on the Plan
of Conservation and Development Land Use Policy map.
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The Water Use Policy map does, however, indicate an
area immediately to the west in the West Aspetuck River
watershed as a protected area. This area is not re-
commended for sewering. The potential reservoir site
in the East Aspetuck River watershed shown in FIGURE 3
of the Draft EIS is so designated by the HVCEO and not
the State, and is not included as a part of the Plan
of Conservation and Development. No state policy is
violated.
The Plan of Conservation and Development contradicts
Ttself in the matter of sewers in the Sunny Valley
area. The Water Use Policy map shows the area to be
underlain by a "High Priority Aquifer" and, therefore,
under Policy Id, all uses of the land above this aquifer
should be limited to present activities until a thorough
investigation of the aquifer has been made. On the
other hand, much of this same area is shown on the Land
Use map as Potential Urban Area, complete with sewer
and water supply systems. The Draft EIS recommended
sewering of the Ferriss Pond Apartments and Sunny
Valley Acres areas on the basis of the inadequacy of
the soils to adequately support even present sub-
surface disposal systems (see Section 1.21).
5.34 Odor
• Comment; (R54, H25)
How will the lack of primary settling tanks to remove
scum impact the probability of odor problems in the
system? Basin size? Retention time? Plant site?
Response;
Scum can pose a serious odor problem when it is allowed
to decompose in an anaerobic environment. Such problems
are not uncommon in primary settling tanks which, of
necessity, are not aerated. The system proposed for
New Milford does not have primary settling tanks and
as a result the wastewater goes directly to the aeration
basins. In the basins, any scum will, to a large extent,
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be mixed by the aerators with the body of the waste-
water. In the basins all of the scum will be in an
aerated environment. Biological decomposition of the
scum in such an environment does not result in the pro-
duction of odors. No odor problems are, therefore,
foreseen arising from the lack of primary settling tanks
at the proposed New Milford Treatment Facility.
The relatively large size of the treatment basins and
the relatively long retention time of the wastewater
similarly will not effect the odor production potential
of the facility. As long as the basins remain oxygen-
rich (which is the purpose of the aerators), decompo-
sition of the wastewater will be by aerobic organisms.
Odors do not result from this type of decomposition.
5.35 Groundwater and Water Supply
• Comment: (R22, R23, R25, R36, R48, R50 , R54, R58,
H9, H10, H12, H19, H26)
How will the disposal of 4.0 MGD of wastewater into
the Housatonic River (instead of through subsurface
disposal systems) impact groundwater supplies?
Response:
Attempts to answer this important question in a
quantitative manner require several assumptions;
e.g. what portion of precipitation and subsurface
disposal waters reach the groundwater supply. The
criteria and assumptions used to calculate the impact
of the loss of 4.0 MGD to the Housatonic River follow:
- 40" precipitation/year
- 10% of precipitation to groundwater
- 50% of septic system water to groundwater
- 85 square mile total area (New Milford and
BrookfieId)
- 4 MGD of wastewater treatment facility effluent
The next step in the quantitative analysis was to calcu-
late the normal contribution of precipitation and septic
systems to groundwater recharge in the study areas.
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Total Annual Precipitation
85 mi2 x (5'2^?2ft- x ft/yr = 1.1 x 1012ft3/yr
1.1 x 10'1'2ft3/yr x 7.5 gal/ft3 = 8.5 x 1012 gal/yr
11
@ 10% recharge = 8.5 x 10 gal/yr to groundwater
Total Annual WTF Loss
6 9
4 x 10 gal/day x 365 day/yr = 1.4 x 10 gal/yr
g
@ 50% recharge = 7.3 x 10 gal/yr to groundwater
The ratio of these two inputs is a measure of the
importance of septic systems to groundwater recharge
WTF loss = 7.3 x loj* = n nae-
Total precip 8.5 x 10^
Because only 0.08% of the present recharge of ground-
water is attributable to water from septic systems,
it can be stated that the elimination of this ground-
water input will have no discernable impact on ground-
water supply.
e Comment: (R19, R13, R25, R58)
Will growth induced by the project aggravate already
serious water supply problems?
Response:
"Normal" population growth in the two towns (10,900
people in New Milford and 5,000 people in Brookfield
by 2000) will require the development of an additional
2.0 MGD supply of water. Growth beyond "normal" growth
induced by the proposed project (6,500 people in New
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Milford and 1,600 people in Brookfield by 2000) will
require the development of an additional water supply
of about 1,0 MGD by that date. With or without the
induced growth accompanying the proposed project,
significant efforts must be made in the next twenty-
five years to develop the water supplies of the area.
At the present time, investigation and conceptual
design work has been carried out on potential reservoir
sites in the HVCEO management area. Search for ground-
water supplies is, however, lagging. For the HVCEO
region (New Milford, Brookfield, Bridgewater, Newtown,
Bethel, Redding, Ridgefield, Danbury, New Fairfield,
and Sherman), the following summary of water need and
supply was made in their Water Management Study,
Phase II, Interim Report (May 1974) :
TABLE 10
GUIDELINES FOR GROUNDWATER EXPLORATION PROGRAM
Ultimate Supply Needed (2030 saturation population)
Average Daily Demand 40 MGD
Safe Yield Required
(1.4 x Avg, Daily Demand) 56 MGD
Safe Yield from Present Sources 14 MGD
Estimated Safe Yield from
Potential Reservoirs 37 MGD
Apparent Deficit (1.4 x 40) -
(14 +37) 5 MGD
Aquifers to be Investigated 25 MGD
This suggests that there is not a lack of water in
the area, but rather a lack of development of water
resources. In addition, it would appear that the
region has extensive options in the development of
groundwater and/or surface water sources.
The impact of population induced by the project on
water supply (1.0 MGD) will be slight to negligible -
approximately 2% of the total.
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• Comment; (R58)
How do the recommendations of the EIS coincide with
the recommendation in the State Plan of Conservation
and Development that development of groundwaters for
water supply be given priority over the development of
surface waters?
Response:
The State water supply policy (in part) as proposed
in the Plan of Conservation and Development is as
follows:
DETAILED POLICIES RECOMMENDED
la. The future water supply need of the state
should be met, in part, through those
water supply reservoirs, diversions and
high priority underground sources (aquifers)
depicted on the Water Use Policy map.
lb. As a general principle, water supply should
be obtained from groundwater resources before
resorting to the creation of new impound-
ments.
In suggesting that potential surface water reservoirs
could nearly fulfill the region's water needs, the
EIS was reporting the status of current planning as
reflected by the HVCEO Interim Water Management Study.
For its part, the state is not attempting to halt
the development of surface water supplies but rather
to encourage the development of groundwater supplies
because they are generally cheaper, more easily con-
structed and managed, and generally of higher water
quality. In developing a state-wide policy for water
supply, it would seem obvious that there will be local
exceptions to the general policy because of the great
variability of conditions across the state. In the
HVCEO region potential surface water supplies are
greater than potential groundwater supplies and will,
in all likelihood, be developed to a greater extent
than elsewhere in the state.
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Comment: (R16, R58, H20)
How would land application of treated effluent impact
groundwater levels and public water supplies?
Response:
If a land application system were utilized in New Milford
it would have a beneficial impact on groundwater levels.
It is extremely important to realize, however, that
groundwater quality must also be protected. In order
to assure sufficient nitrate removal by the soil/crop
complex, an extremely large land area would be required
for land application of the wastewater. Although land
application would have a beneficial impact on groundwater
levels in an absolute sense, it would provide only a
small percentage of the water available in the study
area for recharge. Using the same logic utilized earlier
in this section (effluent applied as a proportion of
precipitation), spray irrigation of 4.0 MGD would supply
less than 0.1% of the water available for recharge in the
study area.
The use of underdrains to alleviate potential ground-
water nitrate problems (as suggested at Sunny Valley
Farms), would negate any potential benefits.
5.36 Noise
« Comment: (R7)
What will the quantitative increases in noise levels
associated with the treatment facility be?
Response:
Under normal operating conditions noise produced by
mechanical equipment at the proposed treatment faci-
lity will not be measurable at the nearest residence.
In addition, noise levels as measured at the property
line will probably not be affected by mechanical
operating equipment.
A small increment in noise levels will result from
the additional traffic generated by the treatment
facility on Pickett District Road. This traffic will
consist of the several automobiles of plant operators
and several trucks per day. This amount of traffic is
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insignificant "> n relation to existing volumes and will
not change hourly Ljq dBA averages, (That noise level
which is exceeded 10% of tne time).
Emergency power generation at the treatment facility
will impact noise levels to a very small extent.
5.37 Construction
• Comment; (R3)
What is the total length of sewer line to be installed?
What are the diameters of these pipes? How much exca-
vation is involved?
Response:
In the Town of New Milford Stage I sewer construction
will be approximately 37,300 feet of interceptors and
41,300 feet of laterals. Sewering of the ultimate
service area as depicted in FIGURE 12 of the Draft EIS
will involve a total of approximately 89,000 feet of
interceptors and 221,000 feet of laterals.
Pipe diameters will vary from eight inches to thirty
inches. This will involve the excavation of some
300,000 cubic yards of material.
e Comment: (Rl)
What will be the impact of disruption caused by con-
struction?
Response:
Undeniably, sewer construction within the roadways of
the study area will disrupt traffic flow somewhat.
With proper construction planning and scheduling,
however, delays and detours can be minimized.
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6.00 MISCELLANEOUS
6.10 INTRODUCTION
Because of both the number of comments that were received
and the breadth of topics that were raised, it was inevitable
that some questions would be raised by a few individuals
which did not fall into the general categories that have
been previously discussed. As noted at the beginning of
this report, in order to reduce the large number of questions
to a manageable size and retain some logic to the response
document, some aggregation was necessary. However, the
sources of the comments were still identified. In this section,
those comments which were not covered elsewhere will be dis-
cussed .
6.20 DETAILED PROBLEM EXAMINATION
6.21 Wild and Scenic Rivers Study
• Comment: (Rl, R3, R6, R21)
What impact will the proposed project have on the
Bureau of Outdoor Recreation1s study of the Housatonic
River under the Wild and Scenic Rivers Act (PL 90-542)?
Response:
The Bureau of Outdoor Recreation has studied the
Housatonic River from the Massachusetts/Connecticut
border downstream to the Shepaug River to determine
the eligibility for protection of the river under
the Wild and Scenic Rivers Act. BOR has determined
that the forty-one mile segment of the river from the
Massachusetts/Connecticut border to Boardman Bridge
in New Milford is eligible to be classified as of
scenic or recreational importance and is thus eligible
for protection. They cited the generally free-flowing
natural condition of the river, its high water quality,
its capability to support water-related recreation,
its archeological and historic value, and its value
as fish and wildlife habitat as reasons for eligibility.
BOR found, however, that the ten mile segment of the
river between Boardman Bridge and the Shepaug River
not to be eligible under the act. They cited the
present condition of the river including the presence
of industrial and other structures in New Milford and
the extensive impoundment of waters in Lake Lillinonah
as reasons for the ineligibility of this river segment.
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The proposed wastewater collection and treatment
project in New Milford has no bearing on the designa-
tion of the Boardman Bridge to the Shepaug River
segment as ineligible. Eligibility under the Act,
however, does not mean that the designation is in-
evitable. Designation can occur only after an accept-
able management plan has been prepared and submitted
to the Secretary of the Interior by the Governor of
Connecticut, along with a request to receive desig-
nation as a National Wild and Scenic River. In this
study, the local towns and/or the State of Connecticut
would be responsible to carry out this process, with
assistance from the Bureau of Outdoor Recreation.
This plan must be approved by Congress.
A moratorium is currently in effect to protect the
entire study segment until such a management plan can
be formulated, submitted, and either approved or dis-
approved. This moratorium prevents the construction
of federally funded water resource projects which
adversely effect the entire fifty-one mile study
segment until the Congress makes a decision on the
recommendation. Under this moratorium, the Secretary
of Interior (Document R2) has made suggestions to
revise the proposed wastewater treatment facilities
in New Milford. EPA reaction to these suggestions
are included as the following Comments and Responses.
• Comment; (R2, R21, H7)
How will the degree of treatment of New Milford's
wastewater impact on the Housatonic River's potential
designation under the Wild and Scenic Rivers Act?
What will be done to ameliorate any possible adverse
impacts?
Response:
Extensive discussion of water quality and the level
of treatment (particularly phosphate removal) to which
New Milford's wastewater will be subjected is included
earlier as Section 5.22. It has been determined that
the inclusion of phosphorus removal capabilities is
not warranted at this time and that phosphates in
New Milford*s wastewater will not exert adverse impacts
on the Housatonic River while phosphate removal capa-
bility is implemented at Danbury and the resultant
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impact on Lake Lillinonah studied. The New Milford
facility, as designed, can easily have phosphate
removal process equipment added to it.
& Comment: (Rl, R2, H7)
How will the physical appearance of the proposed treat-
ment plant impact the Housatonic Rivers potential
designation under the Wild and Scenic Rivers Act?
What will be done to ameliorate any possible adverse
impacts?
Response:
The design of the treatment facility has been re-
evaluated in light of the expressed concerns of its
appearance from the Housatonic River. It is believed
that only the operating building and lift station will
be visible from the river. Provisions have been made
to screen these structures from view through the use
of landscaping and plantings. No adverse impacts are,
therefore, anticipated.
6.22 PL 92-500 Compliance
e Comment: (R23, R26, R57, H17)
The project proposed in the Draft EIS is not in
compliance with the mandate of PL 92-500 to reduce
the wastewater loads placed on our nation's rivers
and to encourage the recycling and reuse of such
waters.
Response:
The Draft EIS is in error on pages 191 and 223 when
it states that the BOD load placed on the Housatonic
River will increase. It is true that the BOD load
from the proposed New Milford treatment facility
will ultimately be almost eight times the BOD load
emanating from the present treatment facility. This
is because the flow will be increased by a factor of
eight.
At the present time, however, wastewater from Nestles
is discharged with minimal treatment to the river.
Under the proposed project this waste would be
treated at the New Milford facility. As a result,
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the BOD load from the treatment facility and Nestles
combined would be reduced from 4,985 pounds per day
at present to 1,330 pounds per day (See TABLE 11).
This is a 73% reduction in BOD load on the river.
TABLE 11
HOUSATONIC RIVER BOD LOADING
BOD Load on River
Source (lbs/day)
1977
New Milford Treatment Facility 185
Nestles 4,800
TOTAL 4,985
2000
New Milford Treatment Facility
(including Nestles) 1,330
TOTAL 1,330
Source: Anderson-Nichols & Co., Inc., 1977.
The Draft EIS is correct in its statement that nitrate
and phosphate loads on the Housatonic River will be
increased in an absolute sense. The New Milford
facility will be a relatively minor contributor of
these nutrients. Phosphate and nitrate concentrations
are a recognized problem in the Housatonic River lakes
and at present nutrient removal experimentation is in
progress at the Danbury treatment facility. Whether
or not New Milford adds tertiary nutrient removal
capabilities in the future is in large part dependent
on the results of the Danbury pilot program. Addi-
tion of nutrient removal capabilities is compatible
with the Carrousel treatment process proposed at
New Milford.
The Draft EIS included an extensive study of land
application of New Milford's wastewater as mandated
by PL 92-500. This study was not intended to be
a design study but rather a feasibility study. This
study showed that land application of 4.0 MGD of
wastewater effluent in New Milford was not technically
or economically feasible. Land application of a
lesser amount of water and discharge of the remaining
portion to the river was found not to be financially
feasible.
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6.23
Candlewood Lake as Water Supply
® Comment: (R22, R54)
No sewering should be permitted within Candlewood
Basin because of the likelihood of future use of
the lake as water supply.
Response;
This issue is clouded by a number of explicit and
implicit contradictions. While a few individuals
have expressed grave concern over the unlikely
occurrences of a pump station failure which theore-
tically might discharge a day's flow of dilute sewage,
they seem unaware of the apparent regular
overflows of septage during rainy periods. Also,
while objections are raised about the presence of
lateral sewers near the shore in Brookfield, some
persist in retaining an option to connect with New
Milford in the future because it may be a less ex-
pensive solution for New Fairfield. Such a con-
nection would require a large submerged force main
which would utilize the same pumping technology as
used for the laterals in Brookfield. Behind the
expressed fear of the "loss" of Candlewood Lake as
water supply appears to be resistance to any more
development within the basin.
The primary concern with the use of unprotected water
sources as water supply is the possibility of wide-
spread disease transmission from bacterial and viral
contamination. Sewering will lessen the likelihood
of this occurrence by the controlled treatment of
the shoreline sewage at the point distant from the
lake. This is in contrast to the situation which
now exists whereby little control is exercised over
thousands of individual septic tanks or cesspools.
If Candlewood Lake is to be an integral part of the
future water supply of the area, then serious con-
sideration would have to be given to drastically
reversing the use of the lake area as a residential
and recreational resource. The concept of no sewering
within the basin to ensure its future quality as a
secondary water supply is without foundation. It is
not anticipated that water quality deterioration will
result from the project. Rather, significant pro-
tection against uncontrolled malfunctioning septic
system use will result.
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6.24
Lake Tahoe Study
• Comment; (R54)
Recommends that EIS recommend study of Candlewood
Basin similar to mandated study for Lake Tahoe under
PL 92-500 and development of the basin be suspended
until such a study is completed.
Response:
The need for such an extensive study does not appear
to be warranted. The findings of the Draft EiS con-
clude that the water quality of Candlewood Lake could
be protected by both the structural and non-structural
measures proposed in the preferred alternative for the
several study area towns bordering Candlewood Lake.
6.25 Archeology
® Comment: (R4, RIO)
Advisory Council Procedure, 36 CFR 800 should be
applied to the Pickett District Cemetery, the arche-
ologic site located at the proposed treatment site
on Pickett District Road, and the final routes of the
East Aspetuck and Southerly Interceptors.
Response:
The letter to EPA from John W. Shanahan, Connecticut's
State Historic Preservation Officer and dated
February 28, 1977, states in part:
"In the opinion of the State Historic Preserva-
tion Officer, this project will have no impact
on historical and architectural properties
listed on the National Register of Historic
Places or eligible for the National Register
of Historic Places. However,.... this project
may have an impact on archeological resources
which may be eligible for the National Register
of Historic Places, and Advisory Council Pro-
cedures 36 CFR 800 should be applied."
Pursuant to the National Historic Preservation Act,
Executive Order 11593, and NEPA, the Advisory Council
on Historic Preservation published procedures
(36 CFR 800) to assist agencies in complying with
104
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the legislation. These procedures call for close
interaction among the State Historic Preservation
Officer (SHPO), local Federal agency officials and
the Advisory Council.
The procedures of 36 CFR 800 have and will be applied
to the archeologic site located at the proposed treat-
ment site and the final routes of the East Aspetuck
and Southerly Interceptors as noted in the Draft EIS,
The first step of the Advisory Council procedures is
the identification of those properties both listed
and eligible for listing in the National Register.
The State Historic Preservation Officer in Connecticut
is consulted for assistance in the identification pro-
cedures .
Once the historical and archeological resources are
identified, a determination of effect of the project is
made, again in consultation with the SHPO. If there is
no effect, the agency keeps documentation and the pro-
ject proceeds. If a determination of no adverse effect
is made, adequate documentation must be prepared by
the Federal agency and submitted to the Advisory Council
for a 45 day review.
In some cases a determination of no adverse effect can
be made where a Federal undertaking will result in the
recovery of data from an archeological property on or
eligible for the National Register of Historic Places.
Such a determination is possible when the Federal agency
and the SHPO have determined that:
(1) the property is not a National Historic Land-
mark, a National Historic Site in non-federal
ownership, or a property of national histori-
cal significance so designated within the
National Park System
(2) in-place preservation of the property is not
necessary to fulfill purposes set forth in
the State Historic Preservation Plan
(3) the property has minimal value as an exhibit
for public understanding and enjoyment
(4) the property is not known to have cultural
or historic significance above and beyond its
scientific value
(5) currently available technology is adequate to
retrieve the significant information from the
property
105
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(6) funding and time have been committed to adequately
retrieve the data
Documentation supporting this determination and satis-
fying the data recovery requirements can be submitted
to the Advisory Council for its review. Given a
favorable review, the project can proceed.
In the case of a determination of adverse effect, a
preliminary case report must be prepared by the Federal
agency and submitted to the Advisory Council for review
and comment. After consultation among the SHPO,
Federal agency and the Advisory Council, a memorandum
of agreement is written which details measures to avoid
or mitigate adverse effect to the property or properties
in question.
If no agreement is reached after these series of con-
sultations , the case must be presented to a full meet-
ing of the Advisory Council and their comments secured.
The Federal agency must consider this statement of
the Advisory Council in the final decision, and must
submit a written report to the Advisory Council de-
scribing agency actions subsequent to these procedures.
6.26 Industrial Pollution
® Comment; (R58)
What type of industry will be attracted to the area
by the presence of a treatment facility? What will
be their waste products? How will their wastewater
impact the treatment facility? The Housatonic River?
Response;
It is expected that the industry attracted to New
Milford and Brookfield by the proposed sewer project
will be primarily light manufacturing, commercial,
and office. The major wastewater contribution of
these facilities will be domestic sewage. The treat-
ment facility has been designed to accommodate the
wastewater flows from projected industrial develop-
ment .
106
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These types of industries do not generally produce
significant quantities of process wastewater. That
which is produced is generally compatible with the
biological treatment processes at the proposed faci-
lity. Substances which are potentially toxic in the
treatment processes or to the Housatonic River will
be excluded from the system by the Sewer Use Ordinance.
Industries will be required to either treat such sub-
stances in their own specialized facility or other-
wise dispose of these substances in an environmentally
acceptable manner.
6.27 New Fairfield Options .
• Comment: (H2)
If New Fairfield is not to be included in the New Milford
project, then New Fairfield should be aware of the future
consequences.
Response:
In the Draft EIS, it was concluded that New Fairfield
should not participate in a regional system with New
Milford. This conclusion was reached after analysis
of existing and anticipated land use, soil types, and
current and proposed wastewater management practices.
While poor soil is found in New Fairfield as elsewhere
in the region, there are few extensive contiguous year-
round residential areas. If the town's current aggres-
sive wastewater management program fails to provide
for water quality protection, then solutions other than
a town-wide sewer system would be more appropriate.
At the workshops in New Fairfield, residents were in
agreement that strenuous enforcement of a strict sani-
tary code should be pursued, even if this meant con-
demnation of property. The implications for the town
might be a painful but necessary program of requiring
expensive sanitary disposal systems at individual homes
and the use of takings as an enforcement tool. The ul-
timate possibility of a town-wide system being required
that would have to discharge to Danbury might be more
costly than connection to a New Milford system, depending
upon the difference in treatment costs due to different
treatment levels.
107
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• Comment: (R15, R54)
There is no need for sewering in New Fairfield now and
perhaps never, but the option to connect to New Milford
ought not be precluded because it was found to be more
cost effective.
Response:
This statement that was articulated by only two indi-
viduals appears in contradiction with other views
they also expressed. These responses to the Draft EIS
emphatically oppose any sewering within the Candlewood
Basin, yet support retaining as an optional plan which
calls for the construction of a force main beneath
Candlewood Lake. Other engineering solutions to pumped
sewerage, such as deep rock tunnels, are mentioned although
no consideration of their economic feasibility is given.
As stated in the preceding question, no sewering in
the near future is anticipated by those who participated
in the EIS process, and a firm commitment to accept the
responsibility for widespread use of growth limiting
non-structural solutions has been stated.
108
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APPENDIX A
SECOND ROUND OF WORKSHOPS
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A \
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
% PRO^
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203
January 5, 1977
TO: All Interested Agencies, Public Groups, and Concerned Individuals
The following Draft Environmental Irrpact Statement (EIS) for the
Wastewater Treatment and Collection Facilities for New Milford,
Connecticut is hereby submitted for your review and content. This
statement has been prepared in compliance with the National Environmental
Policy Act of 1969 (P.L. 91-190) and implementing regulations promulgated
by the Council on Environmental Quality and the Environmental Protection
Agency.
Comments should be sent to this office no later than 45 days from
the date that this EIS is published in the Federal Register by the
Council on Environmental Quality. All comments received will be
considered by EPA in the preparation of the Final Environmental Impact
Statement for this action.
In order to receive public ccitments, the Environmental Protection
Agency, Region I, will sponser four workshops and a public hearing
on the Draft EIS. The workshops are scheduled for the following
dates:
Town of Washington
January 31, 1977
7:30 p.m.
Town Hall
Town of New Milford
February 1, 1977
7:30 p.m.
Cold Lunchroom - John Pettibone School
Town of Brodkfield
February 2, 1977
7:30 p.m.
New Brodkfield Public Library
Town of New Fairfield
February 3, 1977
7:30 p.m.
New Fairfield Library
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- 2 -
The formal public hearing for all ccsimunities within the study area
will be:
February 15, 1977
7:30 p.m.
Sunny Valley High Auditorium
New Milford, Connecticut
All interested parties are invited to participate and express their
views at all of the proposed workshops and the public hearing.
Persons wishing to make Garments may discuss them at the workshops
or submit them in writing at the public hearing.
I encourage each of you to participate in the decision making process
with respect to this Draft EIS. Our proposed workshops will provide
a forum for exchange of ideas and information and will focus an the
major issues of critical concern which have been addressed in this
Statement.
If you cannot attend the workshops or public hearing, please send
your written comments or testimony to:
Environmental Protection Agency
Attn: Environmental Policy Coordination Office
Room 2203
John F. Kennedy Federal Building
Boston, Massachusetts 02203
2G1<
jional Adminis'
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Memorandum
CORPORATION
Anderson-Nichols
150 Causeway Street
Boston, Massachusetts 02114
(617) 742-3400
To:
New Milford Files
Date:
February 7, 1977
Copies for: EPA, B. Ketcham, P. Lees client:
EPA
W. Murphy
Division:
Planning
Subject: Washington Workshop
Job Number: 2880 - Phase V
The second New Milford EIS Workshop was held at the Town Hall in
Washington on January 31, 1977 at 7:30 p.m. Representing
Anderson-Nichols were W. Murphy and P. Lees. No state or federal
representatives were present. The workshop was attended by eight
people, four of whom were Washington residents, three of whom were
from the press, and one New Milford resident.
Because of the small number of participants, a discussion format
was substituted for the workshop format. The discussion was
centered around the questions on the attached agenda.
Comments;
1. Those in attendance thought that poor notice was given
concerning the meeting and that this probably accounted
for the low attendance.
2. They agreed with the Draft EIS finding that sewering of
Washington is unnecessary.
3. They are finalizing a revised zoning map which they
expect to become effective this spring.
4. "Up-zoning" of the Marble Dale section has already
occurred, which will minimize future wastewater
problems in that area.
5. They are rigorously inforcing health code.
-------
To: New Milford Files February 22, 1977
From: W. Murphy Page 2
Subject: Washington Workshop
2880 - Phase V
6. They continue to see Lake Waramaug as a potential
water quality problem and are now in the process
of studying the lake through the 208 program.
7. Some are still concerned that the New Milford system
will have growth impacts on Washington even though
the system itself will not be extended to the town.
They feel that this growth will be accelerated at
any time by the construction of Route 7 which "could
begin tomorrow" if someone at the State level decides
so.
ANDERSON-NICHOLS & COMPANY, INC.
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WORKSHOP NO. 2
AGENDA
1. Statement of Purpose
2. Summary Presentation
3. Instruction to Workshop Participants
4. Table Discussions
5. Reports of Table Chairman
6. Closing Remarks
-------
WORKSHOP NO. 2
WASHINGTON, CONNECTICUT
GROUP DISCUSSION QUESTIONS
1. The recommended alternative does not include the extension
of sewers from New Milford to Marble Dale and New Preston.
Please briefly state your reactions to this.
2. Prevention of water quality problems along the East
Aspetuc.k and throughout the town in general will necessi-
tate the adoption of soil/slope zoning.
What are your reactions to this? What do you feel the
implications of this will be?
3. Prevention of water quality problems in general may
require a more intensive program of septic system inspec-
tion which would probably require increased funding.
What are your feelings concerning this type of on-going
program?
4. With respect to lake shore property, do you feel that
existing or proposed methods {like those mentioned in 2
and 3 above) of controlling septic system use are adequate?
What else would you recommend?
5, Please conclude with discussion of any other questions
of major interest to table participants.
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Memorandum
Anderson-Nichols
150 Causeway Street
Boston, Massachusetts 02114
(617) 742-3400
To: New Milford Files
Date:
February 7, 1977
Copies for: EPA, B. Ketcham, P. Lees Client:
EPA
From:
W. Murphy
Division:
Planning
Subject: New Milford Workshop
Job Number: 2880 - Phase V
The second New Milford EIS was held at the Pettibone School in
New Milford on February 1, 1977. Representing Anderson-Nichols
were B. Ketcham, W. Murphy, P. Lees and G. Sansoucy. Bob Mendoza
represented EPA at the workshop. About 60 local residents were
in attendance.
The workshop was conducted in accordance with the attached
outline. Initially, some participants objected to the format,
saying that they would prefer to ask direct questions. It was
pointed out, however, that the questions would form the core
of a systematic discussion which would be more fruitful than
random questioning.
The following responses were elicited:
Question 1
In general the participants felt that the service area of the
proposed project was too large. They felt that both existing
and future needs were overstated. They continue to question
whether Brookfield and Nestle's will participate. They feel
that the growth desire of the community has been overstated. It
was also felt that problems could have been avoided by stricter
enforcement.
Question 2
Opinion was mixed regarding the value of additional planning
work prior to Stage II construction. Some felt it should definitely
be done while others repeated their concerns about the possibility
of down-zoning.
-------
To:
From:
Subject:
New Milford Files
W. Murphy
New Milford Workshop
February 7, 1977
Page 2
Question 3
No support for linking sewer development to industrial or
commercial development was expressed. Some wished to limit
such activity to the existing service area so long as it did
not harm "town character." Others expressed a desire for
"clean" industry only.
Qustion 4
The majority favored additional independent study of land
application for a reduced service area.
Question 5
Some voiced continued skepticism of the carrousel process in
terms of its newness, its adaptability for phosphorus removal,
and the general question of why the process was chosen.
ANDERSON-NICHOLS & COMPANY, INC.
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WORKSHOP NO. 2
AGENDA
1. Statement of Purpose
2. Summary Presentation
3. Instruction to Workshop Participants
4. Table Discussions
5. Reports of Table Chairman
6. Closing Remarks
-------
WORKSHOP NO. 2
NEW MILFORD, CONNECTICUT
GROUP DISCUSSION QUESTIONS
1. The E.I.S. indicates that Stage I of the proposed
limited regional sewer system will serve existing
and potential concentrations of septic system prob-
blems and will be in accord with existing town zoning
and planning.
What are your reactions to the areas of wastewater
treatment needs indicated on the map? What are your
reactions to the need for sewers in these areas? What
alternatives do you suggest?
2. The EIS suggests that an in -ceptor system expansion
or treatment plant expansic vayond Stage I be carried
out, if necessary, after th.. completion of revised land
use and zoning studies for potential sewer service areas.
What are your reactions to this approach? Do you have
any other recommendations?
3. What are your feelings concerning the use of sewering
to promote or facilitate the following types of develop-
ment: Industry, commercial, housing for elderly, low or
moderate income housing, dense single-family neighborhoods?
4. The E.I.S. analysis indicates that land treatment is not
feasible due to inadequate areas of suitable soils.
Do you favor any additional independent studies of this
ap oach? How should this be accomplished?
5. Please conclude with discussion of any other questions of
major interest to table participants.
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Memorandum
CORPORATION
Anderson-Nichols
150 Causeway Street
Boston, Massachusetts 02114
(617) 742-3400
To: New Milford Files
Date:
February 7, 1977
Copies for: EPA, Ketcham, Lees
Client: EPA
From:
W. Murphy
Division: Planning
Subject: Brookfield Workshop
Job Number: 2880 - Phase V
The second New Milford EIS Workshop was held at the Public
Library in Brookfield on February 2, 1977 at 7:30 p.m.
Representing Anderson-Nichols were B. Ketcham, W. Murphy
and P. Lees. Bob Mendoza of EPA also attended. About 60
local residents attended.
After a brief summary of the project by W. Murphy, B. Ketcham
attempted to proceed with the planned workshop session.
Numerous individuals objected to the planned format and con-
tinued to interrupt the process through outbursts. After
about an hour, during which time a number of questions were
directed both at EPA (and Anderson-Nichols) and at local
officials, the official workshop was declared closed.
During the general discussion, which included considerable
argument among local residents, a number of issues were
raised. These included:
1. A sizable group of residents from the shore area
of Candlewood Lake questioned th need for sewering
that area. They felt that none of the studies done,
including the recently completed Draft EIS and the
independent Albertson, Sharp & Backus study, could
prove that sewer needs exist.
2. Many questioned the compatability of state and local
planning goals for development of Route 7 with
current community desires.
3. Considerable hostility toward local officials
concerning future plans for the community was
expressed.
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WORKSHOP NO. 2
AGENDA
1. Statement of Purpose
2. Summary Presentation
3. Instruction to Workshop Participants
4. Table Discussions
5. Reports of Table Chairman
6. Closing Remarks
-------
WORKSHOP NO. 2
BROOKFIELD, CONN ECTICUT
GROUP DISCUSSION QUESTIONS
The E.I.S. indicates that areas of existing development
and areas of proposed development along Route 7 shown on
the accompanying map have wastewater treatment needs
that cannot be adequately served by conventional on-site
septic systems.
Please summarize your reactions to this recommendation
for both types of treatment needs.
The E.I.S. indicates that the wastewater treatment needs
cited above can best be served by construction of a
sewerage system.
Please summarize your reaction to this recommendation.
The E.I.S. indicates that connection of the sewerage
system with the New Milford system for treatment in
New Milford is the most practical alternative for
Brookfield.
Please summarize your reaction to this recommendation.
The E.I.S. indicates that the sewerage needs of proposed
development in the Route 7 corridor would best be served
by connection to a sewerage system carrying wastewater to
New Milford.
What are your feelings concerning the relationship of
sewering to industrial and commercial development, and
multifamily housing opportunities?
The Brookfield Sewer Commission recently completed a study
which identified similar existing needs and future needs,
but reached different conclusions, and recommended connec-
tion with Danbury and phased construction, which gave lower
priority to sewering the Route 7 corridor.
What are your reactions to this study, and its relationship
to the E.I.S.?
Please conclude with discussion of any other questions of
major interest to table participants.
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Memorandum
00^1
corporate
Anderson-Nichols
150 Causeway Street
Boston, Massachusetts 02114
(617) 742-3400
To: New Milford Files Date: February 7, 1977
Copiesfor: EPA, B. Ketcham, P. Lees Client: EPA
From: W. Murphy Division: Planning
Subject: New Fairfieid Workshop Job Number: 2880 - Phase V
The second New Milford EIS Workshop was held at the New Fairfield
Library on February 3, 1977 at 7:30 p.m. Representing Anderson-
Nichols were B. Ketcham and W. Murphy. Representing EPA was
R. Mendoza. No state representatives were present. The workshop
was attended by about 20 local residents.
The workshop was conducted in accordance with the attached outline.
At the end of the meeting several statements were read and submitted
for the record. A summary of the workshop questions and the state-
ments follow.
Question 1
All the groups reported that they saw no sewerage in the foreseeable
future and that local planning and sanitary code enforcement would
be adequate to cope with future wastewater treatment needs.
Question 2
While most groups felt that the existing code and enforcement
were adequate for the future, one group felt that the code and
enforcement should be strengthened.
Question 3
All felt that the sanitary code should be enforced.
Question 4
All groups restated their belief that sewering would never
be needed. If it were found that western areas developed a
sewer need then connection with New York State should be explored.
-------
To: New Milford Files February 7, 1977
From: W. Murphy
Subject: New Fairfield Workshop
Question 5
Two groups utilized this time to read prepared statements.
One statement was that of Prof. James S. Mellett of New York
University which expressed his disagreement with the EIS with
respect to groundwater impacts.
The other statement was read by John Fairchild, First Selectman
of New Fairfield. His statement contained two points. First,
he expressed concern if the EIS recommendations were followed
and New Fairfield were forever eliminated from the New Milford
system, since this connection was shown to be the least costly
for the town. Second, he does not anticipate any sewering of
New Fairfield in this century, or perhaps forever, and conse-
quently objects to any sewering within the Candlewood Basin.
ANDERSON-NICHOLS & COMPANY, INC.
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WORKSHOP NO. 2
AGENDA
1. Statement of Purpose
2. Summary Presentation
3. Instruction to Workshop Participants
4. Table Discussions
5. Reports of Table Chairman
6. Closing Remarks
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WORKSHOP NO. 2
NEW FAIRFIELD, CONNECTICUT
GROUP DISCUSSION QUESTIONS
1. The recommended alternative for New Milford makes no
provision for sewer service to New Fairfield. How
does this affect the Town's long-term wastewater treat-
ment needs?
2. Do you feel that the present inspection and enforcement
program to prevent water pollution through proper mainte-
nance and/or replacement of septic systems will provide
for long-term needs? What changes or alternatives would
you suggest?
3. If the inspection program shows some septic systems to
be chronically failing, what course of action should the
Town pursue?
4. Ultimately additional wastewater problems such as septage
treatment or sewering of the western areas of intense
development may require Town action. What do you think
the Town should do to prepare for these eventualities?
5. Please conclude with discussion of any other questions of
major interest to table participants.
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APPENDIX B
PUBLIC HEARING
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LIST OF PUBLIC HEARING SPEAKERS
Comment #
HI
H2
H3
H4
H5
H6
H7
H8
H9
H10
Hll
H12
H13
HI 4
H15
H16
H17
H18
H19
H20
H21
H22
H23
H24
H25
H26
H27
H28
Source
Merrill Walrath
Robert Taylor
Joseph Martinkovic
Oscar Rogg
William Tappan
Donna Elms
Peter Hearn
Mary Gaudet
Samuel M. Chambliss
Dr. Donald Groff
Carl Dunham
Dr. Karl Zehrung
Jean Garvey
Clifford Chapin
Barbara Obeda
Howard Kemmerer
Leonard Stevens
Fred Standt
Dr. James Mellet
Peter Pratt
Laurence Rose
Vincent Foley
Miesse Mauget
John E. Crawford
Frederick Benedict
Ira Meinhardt
Paul Marguard
Ernest Seinfield
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1
2
3
4
5
6
7
8
9
10
1 1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
ENVIRONMENTAL PROTECTION AGENCY
Public Hearing
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER COLLECTION AND TREATMENT FACILITIES
NEW MILFORD, CONNECTICUT
New MilforcL High School Auditorium
New Milford, Connecticut
Tuesday, February 15, 1977
Panel Members:
WALLACE STICKNEY, Environmental Protection
Agency
BURK KETCHAM, Anderson-Nichols
EDWARD McSWEENEY, EPA Chief of Engineering
for Rhode Island and Connecticut
ROBERT MENDOZA, Project Officer for the
Environmental Impact Statement
TONY CIIICORELLA, Connecticut State Coordinator
WALTER MURPHY, Anderson-Nichols
PETER SILVERMAN, Anderson-Nichols
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2
3
4
5
6
7
8
9
10
11
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13
14
15
16
17
18
19
20
21
22
23
24
25
INDEX
SPEAKERS: PAGE
Merrill Walratii, First Selectman, Brookfield 27
Robert Taylor, Director of Water Compliance and 31
Hazardous Substances of Dept. of Environmental Protection
Joseph Martinkovic, Brookfield Conservation Comm. 43
Oscar Rogg, New MiIford Planning Commission 43
William Tappan, Brookfield Sewer Commission 53
Donna Elras 54
Peter Hearn, Housatonic Valley Association b'7
Mary Gaudet, Lake Lillinonah Authority CI
Samuel 11. Chambliss, Land, Air and Water Society 65
Doctor Donald Groff, Land, Air and Water Society 70
Carl Dunham, Economic Development Committee, New
MiIford Chamber of Commerce 72
Dr. Zehrung, Director of Health, New Milford 74
Jean Garvey 73
Clifford Chapin 30
Barbara Obeda 31
Howard Kemmerer 32
Leonard Stevens 84
Fred Standt 91
Doctor James Mellett 36
Peter Pratt 99
Lawrence Rose 103
Vincent Foley 106
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1
2
3
4
5
6
7
8
9
10
1 1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2a
SPEAKERS: (Con't.) PAGE
Miesse Mauger 103
John E. Crawford 110
Mr. Benedict 117
Mr. Meinliardt 129
Paul Marquarcl 143
Ernest Seinfeld 147
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3
4
5
6
7
8
9
10
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13
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17
18
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22
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3
proceedings
MR. 8TICKNEY: My name is Wallace Stickney. I'm
Director of the Environmental Policy Coordination Office of
EPA, Region One in Boston. With me this evening, on the
panel, are Mr. Edward McSweeney, who is the EPA's Chief of
Engineering for Rhode Island and Connecticut; Mr. Robert
Mendoaa who will flit down front shortly as soon as he's
finished with the cards out back and who is our Project
Officer for the Environmental Impact Statement; and Mr.
Burt Ketcham who is in charge of the activities of
Anderson-Nichols, EPAVs Contractors for the Environmental
Impact Statement. We've also brought with us Mr. Tony
Chicorella who is our Connecticut State Coordinator and we
have, also, Mr. Walter Murphy and Mr. Peter Silverman of
Anderson-Nichols, all of whom have had an important role in
the preparation of the Environmental Impact Statement.
The hearing has been convened to receive comments
on the Draft Environmental Impact Statement for the waste
water treatment and collection facilities in New Milford,
Connecticut. This EIS has been prepared pursuant to the
National Environmental Policy Act of 1969 as amended and
pursuant to the Environmental Protection Agency Regulations
which appear at 40 CFR Part 6. The National Environmental
Policy Act provides that prior to commencing a major Federal
action which may have a significant effect on the
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1
2
3
4
5
6
7
8
9
10
1 1
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13
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15
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4
environment, a Federal Agency must prepare an Environmental
Impact Statement. The major Federal action in this case, of
course, is the partial funding of the project. The decision
to prepare an EIS is based on the criteria outlined in the
Regulations as compared to the characteristics inherent in
the project. It does not represent, and I wish to emphasize
this, it does not represent an attempt to discredit or
second-guess decisions which were — which have already been
made over the years and nor must it represent a lack of
confidence in those who participated in that decision-making.
It, simply, is an independent Federal review of the project
and the alternatives available to abate water pollution, as
required by law. It is no more and it's no less than that.
The EIS was available to the public early in
January. The official filing date with the Council on
Environmental Quality or the time that the clock started, in
other words, on the comment periods and times was January
21st. The required forty-five day comment period ends on
March 7th and the record of this hearing will remain open
until March 7th as well. There has been a significant effort
to provide all interested parties the opportunity to
participate in the drafting process through the eight
workshops which already have taken place. This is a formal
end to that informal process but I hasten to add, it is not
a mere formality. A stenographic record is being taken.
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1
2
3
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Copies of this record will be available in the local area as
soon as they can be prepared. But, in any event, the
Final Environmental Impact Statement must respond to all
responsible comments entered into this record or submitted in
writing within the comment £)eriod.
We've asked that you indicate on a registration
card whether or not you wish to speak. If you wish to speak
and have not submitted a card, please take the time to do so
and I believe we can do a better job at scheduling.
We recognize that this Environmental Impact
Statement is a substantial document and you all may not have
had an opportunity to read and digest it completely.
Therefore, we've asked Mr. Ketcham to provide a brief
summary and relate the principal findings of the report, so
we'll all be starting from a common ground. After that, we
will move on to statements, your statements, the real reason
that we're here and, in the interest of allowing everybody
an opportunity to speak, we must request that you limit your
verbal presentation to a summary of your remarks and you
will have the opportunity, if it's not prepared tonight, to
submit a full text for the record. So, right now, I'd like
to turn the hearing over to Mr. Ketcham for the summary of
the project and the Environmental Impact Statement.
MR. KETCHAM: The Draft Environmental Impact
Statement, Wastewater Collection and Treatment Facilities,
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New Milford, Connecticut, was prepared as a result of the
Federal Environmental Protection Agency's determination that
the project for which the Town of New Milford sought
construction funds was the subject of serious controversy.
The purpose of the Impact Statement was to review the project
that was proposed by the Town and all feasible alternatives,
to evaluate their environmental impacts, and to recommend
a plan for the Town's wastewater treatment needs. More
specifically, the Notice of Intent required that the
Environmental Impact Statement evaluate the following issues:
The project's potential for secondary effects on
land use and distribution of population densities; an
evaluation of the total population projections and the design
capacity of the facility, the level of treatment required,
including the need for phosphorus removal; potential social
and economic impacts on residents of the town; and the
impact of the facility on properties eligible for inclusion
in the National Register of Historic Places.
As the project progressed, it became evident that
a number of other issues were the subject of local debate.
These included the demonstration of existing sewerage need,
the goals of local residents for the development of their
communities, the technical suitability of the treatment
process selected by the Town and the desirability of
sewering lakeside development.
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The report was prepared within the guidelines of
the Federal Register of April 14, 1975, in terms of format
and content. At the same time, it also focused on issues
in proportion to their local importance. The Impact
Statement attempted to reconcile the problem of planning for
a large and unique geographical area, while coping with
numerous and complex issues, by the use of an open and
objective process which invited citizen input, and applied
reasonable judgements to arrive at its conclusions.
The basic process of the environmental impact
evaluation included five elements: The development of an
environmental data base; the formulation of alternative
approaches for the solution of area-wide wastewater
treatment problems; the screening of all alternatives; the
selection of a recommended project; and the in-depth
environmental evaluation of the proposed project.
A data base was developed for the study area after
consultation with Federal, State and local Governmental
agencies, private organizations, citizen groups and numerous
publications. The result is an extensive compilation of
physical, biological and social data on existing conditions
and the identification of future trends.
The range of conceptual alternatives that were
initially identified for the New Milford project was
determined by the extreme of "no action" to a complete
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regional aev/er system serving New Milford, Brookfield, New
Fairfield and portions of Washington. The former
alternative is a specific requirement of EPA guidelines
while the latter represented, essentially, the plan that was
proposed by the Town, with its future implications.
Within the broad range described above, two other
types of conceptual alternatives were considered. One of
these approaches to local wastewater management has been
labelled "non-structural solutions". This alternative
consists of a collection of techniques, such as centralized
community planning and de-centralized individual technical
solutions at the homeowner level which might satisfy the
particular water quality problem of a town. Another type of
conceptual alternative that might have been of interest to
residents of a particular community was the construction of
their own individual plant. Finally, other regional or
intermunicipal arrangements might be available to individual
communities.
The number of conceptual alternatives that can be
developed from a theoretical standpoint is formidable. When
the basic elements of the project, four towns and four basic
types of action, were considered in combinations, an
unwieldy number of alternatives resulted. This complexity
was clearly beyond the scope of any meaningful analysis. To
reduce this number of conceptual alternatives to a set of
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preliminary feasible alternatives, a preliminary screening
of alternatives, in conformance with EPA guidelines was
conducted.
A rational set of criteria was utilized which would
permit the identification of a set of preliminary alternatives
The following were used:
The set of preliminary alternatives should permit
the comparison of actions that address separable issues that
have been identified in the project.
The individual alternatives must be reasonable,
physically, with respect to the location of settlement,
topography, water bodes and water quality problems.
The essential element of any preliminary alternative
must have some basis in fact. It should have been
considered in some preliminary engineering planning work or
have been utilized in some similar situation.
The only alternatives that would be examined in
detail would be those that relate to New Milford's
alternatives. An evaluation of the environmental impact of
an action by another town, done independently of New Milford,
is more properly the content of an environmental assessment
of the facility plan of that community.
The alternatives that were evaluated consisted of
the following:
Alternative I was the so-called "No Action"
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Alternative consisting of a projection of present anticipated
trends against existing environmental conditions. As such,
it described the environmental impact of taking no positive
action in the maintenance of water quality.
Alternative II was called the "No-structural"
Alternative and included positive steps to alleviate existing
and future water quality problems without a centralised
collection system and treatment system.
Alternative III, and we have the screen on that,
was called the Local New Milford System and represented,
essentially, the 1967 plan for upgrading the Town facilities
and expanding the existing service area to include
extensions to the north along the East Aspetuck River and
west across the Housatonic River.
Alternative IV was called the Limited Regional
System I. This alternative considered the participation of
New Milford with Brookfield in a collection system with a
single treatment facility in iSTew Milford. It v/as derived
from "Report to Sewer Commission, Town of New Milford,
Connecticut, Upon Sewerage Needs, October 25, 1968, Revised
June, 1969". This alternative conformed to Orders Numbers
81 and 4 of the Connecticut DEP.
The service area of this alternative is shown on
the screen. The area within New Milford was expanded in
the 1968 report to include the Candlewood basin and the
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southerly portion of New Milford which abuts Brookfield.
The other area added in the 1968 New Milford report, the
northeastern part of New Milford near the Washington town
line, was excluded from this alternative so that the
elements of a New Milford-Brookfield interraunicipal system
could be explored independently of Washington. The
Brookfield portion of the service area was that described in
the 1969 Brookfield report. Within this are are actually
two sub-areas, the Still River area and the East Shore area,
that have been studied independently in the past. In this
evaluation of alternatives, they were addressed together
since this would be the likely configuration under a
regional scheme with New Milford.
Alternative V was designated as Limited Regional
System II. This alternative considers the participation of
New Milford, Brookfield and New Fairfield in a joint
collection system with treatment in New Milford at the site
previously mentioned in Alternative IV. It was derived from
previous engineering considerations for these communities.
It also represented the substance of Connecticut DEP Orders
Number 81, 4, 874 and 1243, the first three of which required
the individual communities to look at their own problems,
and the last which required that they participate in the
funding of a regional system. While the order to New
Fairfield to participate in this joint scheme was rescinded,
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in
Xij
the eventual participation of New Milford was still assumed,
inasmuch that capacity was still being provided for the town
in the Brookfield and New Milford systems. Consequently,
the inclusion of New Fairfield in this preliminary alternative
permitted an evaluation of the environmental impact of this
dimension of the project.
Alternative VI was labeled Limited Regional System
III. This alternative would provide service to New Milford,
Brookfield and the New Preston and Marble Dale sections of
Washington. The origin of the New Milford-Brookfield
connection was discussed earlier. Eventual connection with
the New Preston and Marble Dale sections in Washington would
be anticipated. The conclusion was suggested by the "Report
on Pollution Abatement, Town of Washington, Connecticut,
February 29, 1963" and by Connecticut DEP Order Number 98.
The service area was largely the same as that in
the preceding alternative except for expansion of the New
Milford system in the northeast along the interceptor which
will service portions of Washington.
Alternative VII was described as the "Full
Regional System". This alternative was derived from a
composite of engineering reports for the four towns of the
study area, the eventual study area anticipated in the New
Milford engineering reports and the substance of Connecticut
DEP Orders Number 81, 4, 874, 98 and 1243.
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The seven alternatives were first screened in
terms of a number of environmental criteria which included
water quality, water quantity, air quality, biology, State
and local land use policy. The principal basis for
elimination of alternatives turned out to be long-term water
quality protection and compatibility with State and local
planning. The alternative selected was Alternative Number
IV, the "Limited Regional System" involving the towns of
New Milford and Brookfield. The project that is recommended
is the construction of the Stage I service area and a new
4.0 mgd treatment plant on the west side of the Housatonic
River. Future connection with Brookfield is anticipated in
the plant design. Ultimate expansion within New Milford to
include Stages II and III is also anticipated. The total
cost estimates contained within the report relate, however,
only to Stage I construction and have been updated to
reflect recent inflation. The costs to individuals have also
been updated from previous reports, utilizing the
apportionment assumptions of the earlier reports.
Alternative IV, the proposed project, was evaluated
in terms of its environmental impact. The short-term,
beneficial, direct impacts included relief of widespread
septic system problems and improvement of water quality in
the Housatonic River through better industrial treatment.
Indirect beneficial impacts would include the opportunity
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for construction of a variety of housing types for various
ages and income groups.
Short-term detrimental impacts would result from
construction activity in the form of dust, noise and traffic
congestion. Also, the proposed project would initially
result in marginal increases in phosphate in the Housatonic
River until such time as phosphorus removal might be required,
An indirect impact would be the probable acceleration of
growth in Mew Milford and Brookfield that would accompany
the construction of the sewer system.
Long-term beneficial impacts would include a genera]
improvement in the protection of water quality in the area,
including Candlewood Lake and an assist to the desired
economic growth of the area. Indirectly, the project would
permit development in conformance with local, regional and
State plans while concentrating development within the
central valley area. A detrimental side effect would be the
conversion of agricultural and open space lands within this
area to more intensive uses.
The collection and treatment of wastewater in
portions of New Milford and Brookfield, as conceived in New
Milford's application for funding,is the most reasonable
means of insuring protection of water quality in the area.
The overall benefits of the project far outweigh the mostly
short-term adverse environmental impacts of the project.
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Specific conclusions include:
Conclusion Number 1: The project was designed in
response to existing and future needs within the communities
and in consideration of national water quality goals. It
was not a simple upgrading of an existing facility.
On March 13, 1967, New Mllford's sewer consultants
recommended expansion of the existing plant to 1.55 nagd,
based on extension of service to areas of need north and
west of the existing service area for a total of 9.1 per cent
of the Town land area. It identified, but did not include,
needs of the Candlewood Lake area and possible future
development along an improved Route 7. It's industrial needs
were based on the 1959 Plan of Development. In July, 1967,
the Town received an Order from the State of Connecticut
Water Resources Commission to provide a plan for town-wide
service needs, giving special attention to existing and
future growth within the Town, but outside of the service
area previously recommended, with provisions for future
service to areas outside New Milford and consideration of
treatment of industrial wastewater. In October, 1967, the
Town consultants recommended construction of a new plant
based on the assumption that a joint venture with another
town and industry would be developed.
While the proposed project is considerably larger
than the present collection system and treatment plant, it
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is reasonable, when viewed from the fifty-year planning
perspective which is required for public facilities. Since
the construction of the central downtown system in 1958, the
population of the town has more than doubled. Since the
1967 study of sewerage needs, which delimited a service area
essentially the same as Stage I of the recommended project,
the population has increased by about forty per cent. Most
of this development has occurred within the proposed study
area which is about twenty-two per cent of the total area of
the town. Much of this development was on lots of one-half
acre or less. That's the end of Conclusion Number 1.
Conclusion Number 2. The Stage I service area
primarily will accommodate existing needs that are contiguous
to the present central collection system.
Existing needs were not determined from any single
data source, but, rather, from a synthesis of several sources
including: Historic problem areas; existing lot sizes
compared with soils capability information; and a general
consideration of existing standards for leaching areas.
While specific problems may have been eliminated
temporarily, by repair work, the long-term capabilities of a
number of areas to provide adequate septic system operation
is doubtful. Developments on very small lots cannot be
regarded as adequate over the planning period. Under State
Department of Environmental Protection, Department of Health
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Codes and Local Zoning Requirements, it is apparent that no
R-8 or smaller zone can meet existing standards of safety.
Presently, about four thousand people live on these lots and
rely on septic systems for wastewater treatment. There
simply is not enough roorn on these lots to allow for
drainage fields that meet the area and spacing requirements
of existing codes even where good soil conditions can be
found.
There is no possibility of additional area for
reserve on lots this small, thus their long-term inadequacy
is increased.
About fifty per cent of the half-acre development
cannot meet State Codes, including one hundred per cent
reserve, due to soils with moderate to severe limitation for
septic system use, even where public water is available.
Thirteen hundred people live on lots with this limitation.
The circumstances described demonstrate considerable
need, both actual and potential, based on the existing
development, over the long timeframe of the project. While
problems within these areas may not have been officially
documented or may have been temporarily alleviated, it is our
judgement that they should not remain in perpetual use
without the benefit of sewering.
In addition to need based on existing development,
future needs also define the recommended service area. The
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anticipated population growth of New Milford from seventeen
thousand to thirty-two thousand by the year two thousand will
also have wastewater management needs. VJhile some may build
homes outside the study area, it is reasonable, ia view of
past trends, to assume that many will settle within the
general boundaries of the service area. Some will require
modest housing on smaller lot sizes that will best be
served by sewers. Others will require multi-family housing
which cannot, over the long run, rely on septic systems.
Another reasonable anticipated future need will be
generated by industrial and commercial development. If New
Milford fulfills their development plan for industry along
Route 7, then it should ultimately be included within the
service area.
While the service area definition is based on the
timeframe of the long planning period, its actual expansion
should take place gradually over time.
Conclusion Number 3, The 4.0 mgd flow is a
reasonable estimate of the corsnxunities' needs at this time.
This statement is based on the following assumptions:
Service will be provided to Qrookfield as
described in the intermunicipal agreement between the two
towns; the growth rate will continue at present trends;
sanitary sewer service will be provided to commercial and
industrial development; within the twenty-year planning
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period of the plant, problems outside the Stage I service
area will be served.
Upon completion of Stage I construction, without
complete saturation of the Stage I service area, the average
daily flow from New Milford is expected to be 1.69 mgd while
Brookfield's will be .72 mgd.
Thus, it can be seen that relative to the initial
flow of 2.11 mgd, the ultimate capacity of 4.0 mgd is not
inordinately large. In fact, by agreement, a total of 1.3
mgd is reserved for Brookfield. Therefore, of the 1.33 mgd
that remains after Stage I, only about 1.00 mgd or twenty-
five per cent, is available for future expansion of service
to remaining problem areas and future industrial and
commercial development.
Conclusion Number 4. Land treatment of
anticipated flows is not feasible due to lack of a suitable
land area capable of accommodating a 4.0 mgd flow. All
suitable land in New Milford, in combination, could only
accommodate about 2.0 mgd.
In this study, a two-level approach was utilized
to evaluate the feasibility of land disposal. At a large
scale, the overall general New Milford area was re-examined
to evaluate the assumptions and conclusions of the prior
study done by the Town's consultants. At a smaller
geographic scale, the specific site that was offered by the
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Sunny Valley Preserve Proposal, was also examined to identify
its inherent advantages and limitations. The site
characteristics that were identified were then compared to
the specific requirements of the New Milford wastewater
management project to arrive at an evaluation of the site's
potential for further, more detailed study that would normally
be required when land disposal is proposed as part of a 201
Facility Plan.
A detailed description of the fact gathering
effort and the subsequent analysis is found in Appendix C
of the Impact Statement. The results of that analysis are
briefly described here. Certain assumptions must first be
stated in order for a first-pass evaluation to be made. At
a second stage, these assumptions or constraints may then
be relaxed in order to examine the flexibility that exists
within the system, that may be utilized to effect the
desired end. The assumptions were the following:
The first stage design flow of 4.0 mgd must be
accommodated; a loading rate of two inches per week could not
be exceeded; pretreatment in lagoons, in proximity to the
spray site would be a logical accessory to land application;
buffer zones and reserve space in the lagoons should be
required.
At the general level, it was concluded that adequate
land area for acceptance of the anticipated flows, was not
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readily available in contiguous locations. The centralized
location of treatment facilities is important if
reliability of treatment levels is to be assured and
operation and maintenance, a principal expense, costs are
to be minimized.
The examination of the data collected, concerning
the Sunny Valley Farm, revealed some serious limitations,
independent of the entineering analysis. The farm's location
on an aquifer, presently used by the New Milford Water
Company, and identified by "Connecticut's Plan of
Conservation and Development" as a high priority aquifer,
raises a possible conflict at the outset. Findings of
excessive nitrate concentrations in the groundwater in
proximity to the farm, attributed by Connecticut Department
of Health, to the farm's use of fertilizer, cases even
greater doubts on the general utility at the site.
A general engineering assessment of the site found
that the land area at the farm was far less than that which
would be required by the project. Our analysis concluded
that the capacity of the farm under best conditions would be
.397 mgd and under less favorable conditions, only .165 mgd.
When viewed over the planning period, the site could not
accept the expected flows. Assumptions that flows could be
significantly reduced by reducing individual consumption,
while desirable, cannot be relied upon for design purposes.
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It is the conclusion of this statement, that the
site limitations that have been identified, are basically
insurmountable and that further study of the site, to
accommodate the New Milford project requirements would not
change this conclusion and is, therefore, not warranted.
Conclusion Number 5. Revised plans of development
for New Milford and Brookfield should be the guide for any
sewer extensions subsequent to Stage I. The development
proposals, as expressed in planning documents and zoning
regulations of the two towns, are the adopted growth
policies of the two towns. Thes policies, however, appear
to be at variance with the no growth views expressed at the
workshops conducted during the preparation of the EIS. The
apparent controversies should be resolved. Revised
development plans, rather than a sewer facilities plan,
should be the basis for each town's growth strategy.
Conclusion Number 6. The Carrousel variant of the
activated sludge treatment process is a technically
acceptable secondary level treatment process which can be
adapted, if necessary, for future removal of phosphorous.
When compared to other equivalent conventional treateraent
processes, the differences in the estimated costs are not
significant given the level of accuracy of cost effectiveness
analysis. Consequently, the choice of the process is a
matter of the engineers' prerogative.
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Immediate requirements for phosphorous removal are
not recommended. In light of the small contribution of the
New Milford plant, the on-going studies of phosphorous
removal at the large Danbury facility and the uncertainty
of the effects of non-point sources, phosphorous removal at
New Milford should be deferred.
Conclusion Number 7. The 4.0 mgd New Milford
Treatment Plant will have a design life in excess of ten
years. A more specific plan should be developed, however,
for extensions beyond the Stage I service area.
If only Stage I is constructed in the near future,
the 4.0 mgd plan will remain adequate indefinitely. With
full development of industry, commerce and residential
saturation, the remaining capacity would be 0.75 mgd. If
all of Stage II construction occurs at once, then the five
thousand existing residents would utilize an additional
0.4 mgd, leaving only 0.35 mgd for industry, commerce and
future populations. These connections could utilize an
additional 1.8 mgd and would require plant expansion.
Stage III sewering would produce an immediate need
for an additional 0.2 mgd and another eventual 0.15 mgd,
creating a 2.15 mgd deficit in terms of treatment capacity
at the 4.0 mgd plant.
Construction of Stage I and only the Southerly
Interceptor of Stage II, in the immediate future, would
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accommodate saturation in the Stage I area, existing^,
population in the Route 7 area and fifty per cent development
of vacant industrial and commercial land.
From the preceding analysis, it can be seen that
the life of the 4.0 mgd plant can be prolonged by selecting
priority elements for Stage II construction while deferring
other elements.
While future needs of future development comprise
a large part of the anticipated flow beyond Stage I, and
thereby allow for some flexibility in the actual timing and
extent of service area expansion, certain existing land uses
will ultimately require future service.
The Candlewood Lake shore area cannot rely
indefinitely on on-site disposal. Small lot development,
conversions of seasonal homes to year-round use, and the
inherent concern that exists for the long-term protection
of water quality require that this area be sewered.
Sufficient safeguards exist in normal construction and
operation procedures that the minimal risks associated with
such a system are far outweighed by the environmental
protection benefits that would be realized.
Conclusion Number 8. The development of an
extensive collection system in New Fairfield in the foreseeabl
future is unwarranted.
The Town, like many others in the area, was
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required to assess its present and future sewerage needs.
In its 1973 report, the Town indicated that its problem
areas of highest priority were the Candlewood-Hollywyle and
Ball Pond neighborhoods. No specific timetable was
recommended, however. Because of extremely high costs, the
Town was cautioned to explore other alternatives, primarily,
non-structural town-wide growth controls.
In recent years, New Fairfield has pursued an
aggressive role in managing its wastewater problems. It has
adopted relatively large lot zoning and stated its future
objective of retaining its rural character. With respect to
previous construction, the Town Sanitarian has obtained,
through questionnaires, information on the type, size and
location of lakeshore systems. Septage pumpers are renuired
to file a report on each system pumped regarding its
construction and performance. On new shorefront construction,
engineered plans are required, as well as multi-step permit
processes that include wetland permits, building permits,
well permits and septic system permits.
The steps which the Town has taken to control and
manage future development would appear to conform to the
recommendation made in its earlier engineering report. At a
minimum, these actions would seem to increase the time period
before which sewering might be necessary. Local residents
gave their concurrence to this conclusion at the workshops.
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Should the need to sewer eventually materialize in
the western sections of town, connection of that limited
area with Northeast New York should be explored.
Conclusion Number 9. The extension of service to
Washington in the foreseeable future is not warranted.
Existing development is too sparse to justify sewering. In
addition, the small number of past problems have been
alleviated. Most recently, zoning changes have occurred
which minimize future problems in the Marble Dale section.
In the intervening New Milford area, between the Stage I
service area and the Washington town line, existing
development is light and future development will be controllec
by large lot zoning.
Conclusion Number 10, which is our final
conclusion. Brookfield's existing and future wastewater
treatment needs will be most logically served by participation
in the New Milford system. The greatest existing need is
along the shore of Candlewood Lake, but large future needs
are foreseen based on present zoning, for the Route 7
Corridor. From a general consideration of existing need,
development goals, anticipated costs and environmental
factors, the New Milford-Brookfield regional system is most
appropriate. Recently, an independent study has reached a
different conclusion. This new development will be more
closely scrutinised in the preparation of the Final Impact
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Statement.
That concludes my statement, Mr. Stickney.
MR. STICKNEY: Thank you, Mr. Ketcham. To set
forth some rough ground rules, we'll need to break at about
9:30 for five minutes or so, so that we can rewind the tape
recorder. We're not sure whether or not another break will
be needed after that but we would like to get through the
testimony this evening, if possible. If you really wish to
speak, stick around. We'll let you know if and when we feel
that we'll have to adjourn to another evening but, right
now, we'd like to press on and get through tonight, if we
can. We have about sixty people who have indicated they
wish to speak so far. We'd like to ask that you summarize,
if possible, and present written information for the record.
The record will remain open until March 7th and we also have
to ask that you come down front and use these mikes so that
the Stenographer will pick up your remarks.
We've loosely grouped the people wishing to speak
as local and State Officials, representatives of groups and
individuals. I'd like to begin now with Mr. Merrill Walrath
who is First Selectman in Brookfleld and we'd like to
follow him with Mr. Joseph Corey and after that, Mr. Taylor
frail the DEP.
MR. WALRATH: Thank you, Mr. Chairman. My name is
Walrath and I &m the First Selectman of tne Town of 3rookfield
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I appreciate your willingness to let me sit. I still have
some difficulty with suspending the leg, especially in the
latter part of the day.
I want to express the gratitude of the Town of
Brookfield to the Town of New Milford and to its Officials
for letting us come to this auditorium in your Town tonight.
I spoke with Selectman White on the phone this morning. Our
two Towns have had very amicable relationships for many years
and I hope those will continue. We do appreciate, very much,
all of us from Brookfield, regardless of which side of the
question we may be on, the opportunity to come here.
The planning for the eventuality of sewers has been
a reality for ten years, since 1967 when the State Water
Resources Commission issued orders to Brookfield to develop
sewerage plans and to install such parts, "as are presently
necessary giving special attention to those areas where
pollution is presently occurring". My judgement is that the
Town of Brookfield should honor the agreement signed with the
Town of New Milford in 1972 and that both Towns should
proceed to pursue the clauses of that agreement. In the
interest of clarification and the public's right to know, we
have used every means possible to make sure that the need
for sewers does exist. Studies on the problem date back, as
I said, to 1967. Each and every one of these investigations
has shown that we have areas of great concern. If we are to
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preserve the waters of Lake Candlewood, we cannot ignore the
warnings put forth in these studies.
We must face the fact, also, that the future may
call for a public water system. Lake Candlewood and the
underground waters of the Still River Valley, are our two
local resources, if we guard them now. The Community
Development Action Plan, the CDAP Report of 1972 for the Town
of Brookfield, recognized the need for and endorsed the
construction of sewers in the southern portion of Brookfield
and for the shore's residential section. This CDAP Report
also recommended that the Brookfield Sewer Commission
investigate what action should be taken to facilitate
construction of sewer lines along Route 7.
I have, in my file, a draft copy of a section of
the updated plan of development prepared for the Brookfield
Planning Commission by the engineering firm of Flaherty and
Gioverra. It is entitled "Sanitary Wastewater Disposal
System", and it is dated February, 1977. Let me quote:
"This plan of development recognizes iimiediate need for
sewers in the following areas: (1) Candlewood Shores;
(2) Pleasant Rise; (3) Meadowbrook Manor; (4) U.S. Route 7
Corridor." The installation of sewers, as proposed by the
agreement between our two Towns and as proposed, specifically,
within the Town of Brookfield, by the resolution of our
Sewer Commission, will serve a twofold purpose.
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First and foremost, of course, is the protection
of our water resources, both surface and underground.
Second, it will allow us to pursue a program of economic
development, thus, bringing to the taxpayer much needed
relief from a spiraling tax rate. Our original plan of
development recognized the Still River Valley as the logical
place for light industry. But — and this is confirmed by
the Kingsmark Environmental Study done in this area this
year at my request — the Still River Valley is an
environmentally sensitive area which must be protected, not
.just developed. In short, I believe that every avenue has
been taken to insure that needs exist and every effort has
been made to inform the public of these needs. It would seem
that we shall have arrived at this major decision at a very
good time.
We no longer have to fear that the individual user
along the sewer route will have to bear the total cost,
apparently. Seventy-five per cent of the cost of lateral
sewers will be borne by the Federal Government if we act
promptly this spring. We shall eliminate the need for septic
tank and field replacement. We shall eliminate the need for
and expense of septic tank cleanings and we shall
substantially increase the resale value of the homes
involved. If we procrastinate, it is possible that individual
users may have to bear the total cost, instead of one-quarter
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of the cost of lateral sewers. If we procrastinate, we will
limit our ability to pursue the economic development which
would broaden our tax base.
I, therefore, wish, in behalf of the Brookfield
Board of Selectman, Selectman Grant, Selectman Murphy, to
publicly support the resolution passed by the Brookfield
Sewer Commission which recommends the route from Brookfield's
northern border to the shores area, across Elbow Kill and up
the Route 7 Corridor to New Milford. In so doing, I believe
that the best interests of all the people of the Town of
Brookfield will be served and we shall have taken a step
forward toward preservation of our precious resources. We
will have made a conscious effort to make Brookfield's Still
River Valley an area of planned growth, rather than a
hodgepodge design.
Thank you, Mr. Chairman.
MR. STICKNEY: Thank you, Mr. Walrath. Next, Mr.
Corey, please; Mr. Joseph Corey, C-O-R-E-Y. (No response.)
Okay. Mr. Robert Taylor.
MR. TAYLOR: Thank you, Mr. Stickney. My name is
Robert Taylor, Director of Y/ater Compliance and Hazardous
Substances of the Department of Environmental Protection.
The Draft Environmental Impact Statement, which is
the subject of this hearing, was prepared by the
Environmental Protection Agency to resolve a variety of
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issues which have been raised relating to the sewerage
project proposed in the Town of Milford. The decision by the
Environmental Protection Agency to prepare an Impact
Statement was, apparently, made because these issues had
become controversial as a result of the interaction among
Federal, State, regional and local Officials as they
responded to the public at large, to specific interest
groups or to individuals. The Impact Statement will,
therefore, serve its purpose, its intended purpose, only if
it does resolve or at least terminate the controversy.
Therefore, comment on the Draft Statement should be aimed at
insuring this purpose will be achieved in the Final
Statement, especially if it has not been achieved in the
Draft.
The basic method used in the Draft Statement to
resolve controversial issues was to evaluate the
environmental impact of seven defined alternatives on the
basis of eight parameters. Significant impact was
identified for only three of the eight parameters, namely,
water quality, State land use policy and local land use
policy. I will confine my specific comments to those areas
as they relate to proposed sewer construction, recognizing
that others might still find cause for concern with respect
to the conclusions of the Draft Statement on the design of
the proposed New Milford sewage treatment plant. I would
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find cause for further comment if I presumed that the
conclusions of the Draft Statement on the plant design might
not be confirmed in the Final Statement.
Before commenting on the details of the Draft
Statement, I would like to comment, generally, on the
recommended alternative. My purpose is to insure that there
is no misunderstanding of my overall intent, due to the fact
that my detailed comments will take the form of criticism
which, I hope, will be accepted and used to improve the
accuracy, clarity and quality of the Statement in final form.
My understanding of the recommended alternative is that
provision should be made in the presently proposed project in
New Milford described as Stage I in the Draft Statement, to
sewer the Still River Valley and the Rocky River Valley,
Lake Candlewood area, in both New Milford and Brookfield and
to sewer the East Aspetuck River Valley in New Milford.
It would appear that the deletion of Stage III
sewers in the Rocky River Valley area, depicted in figure
twelve, the recommended alternative, is intended to infer
some limitation in the area to be sewered, since the service
area depicted is the same as the alternatives depicting
Stage III sewers. It is further my understanding that the
recommended alternative proposes no sewer service to the
upper reaches of the East Aspetuck River Valley in New
Milford ana no sewer service to the Towns of Washington or
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New Fairfield.
I can fully endorse the choice of the recommended
alternative as the goal of the sewerage program provided.
Appropriate contingency planning is included in facility
design and/or the public fully understands the potential
impact of the choice of the alternative. I find that I have
considerable difficulty concurring with the environmental
impact evaluation of the "no action" alternative described in
the Draft Statement. In fairness to the authors of the
Draft Statement, I feel that the differences in our attitudes
is a matter of perspective with respect to time. To my mind,
no action means a continuation of the trend which was evident
more than ten years ago when the project was initiated, and
when raw sewage discharges were common along the upper East
Aspetuck River and the Still River in the Ironworks area of
Brookfield.
During that period, local control over sub-surface
sewage disposal was poor and local planning and zoning
controls were quite different from those which exist today.
The State land use plan referenced in the Draft and
embodied in the plan of conservation and development, did not
even exist. The Draft Impact Statement assigns specific
adverse impact with respect to Town land use policy in New
Milford, and with respect to both Town and State land use
policy in Washington for alternative six and seven. These
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are the only alternatives which include sewerage service in
the Upper East Aspetuck River Valley.
The Draft Statement is, however, completely silent
on the only essential issue on which a decision must be made
in the Stage I project. That issue is whether or not the
Stage I construction in New Milford should accommodate the
contingency needs for sewers in the Upper East Aspetuck River
Valley. That contingency need has been accommodated in the
existing design in the alignment and hydraulic capacity of
the East Aspetuck interceptor sewer. I feel very strongly
the design should not be altered for the express purpose of
precluding future sewer service in the Upper East Aspetuck
River Valley.
There is a similar issue with respect to the Stage
I construction in New Milford and the Town of New Fairfield.
The only impact that the potential sewage needs of New
Fairfield has on the Stage I construction in New Milford is
with respect to the hydraulic capacity of the Southerly
interceptor sewer. As is obvious from analysis of alternativ
five and seven, however, the issue is more complex since it
also affects the design of Stage II construction. It should
be noted that although the routing of the potential
interconnection of the New Fairfield sewerage system to the
New Milford-Brookfield systems shown in the Draft Statement,
was among the alternatives suggested for study by the State
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Order to New Fairfield, it was not among the alternatives
which were considered in detail in the New Fairfield Report.
It would appear, therefore, that the authors of the Draft
Statement have either made a drafting error on figures
thirteen and fifteen or have chosen to reject the
recommendations of the consultants to New Fairfield.
I am very concerned that the Draft Statement shows
a routing for the potential New Fairfield sewer connection
which infers the need for capacity for New Fairfield in a
sewer routing which now appears to best serve Brookfield's
needs, namely, sewering the East Shore area via Elbow Hill
Road to the Still River interceptor. I feel that figures
thirteen and fifteen should be modified to show tThe
connection to the Candlewood interceptor in a manner
recommended by the consultants to New Fairfield.
There are other references to the recommendations
of the consultants to New Fairfield in the Draft Statement
which must be considered erroneous. Although it is accurate
that the consultants to New Fairfield did recommend a
connection to the Danbury sewerage system in the body of the
New Fairfield Report, in the amendment printed with the
Report, they concluded that "should advanced treatment
facilities be added to the Danbury plant, the above
conclusion would not hold." The advanced treatment facilities
are required at the Danbury plant and have been ordered by
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the State.
Continued reference to a Danbury connection when it
is known that such a connection would not be cost effective,
is misleading. The alternative of a Danbury connection may
be reasonable only if the potential sewage needs of New
Fairfield are not accommodated in the proposed sewer
construction in New Milford. If the recommended alternative
is adopted and capacity is not provided in the New Milford
sewers for New Fairfield, it should be recognized as a
positive decision to avoid sewers in New Fairfield. Neither
the construction of relief sewers in New Milford nor a future
connection to Danbury can be considered cost effective when
compared to the opportunity available in the proposed
construction in New Milford to provide such capacity now.
Therefore, if the need for sewers in New Fairfield
becomes sufficient to result in construction, a decision to
construct the New Milford facilities without means to serve
those needs, will have to be considered an error. The
decision of the State to require New Fairfield to study its
needs embodied in Order Number 374, was specifically
addressed at providing a means by which New Fairfield could
be sewered if and when the need was recognized. The State
approval of the engineering report prepared for New Fairfield
expressed concurrence with the recommendations of the
consultants to New Fairfield, that the Town act to avoid the
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need for sewers and the cost for sewers and that the Town
act to reach an agreement with New Milford for the acceptance
of sewage from New Fairfield. New Fairfield acted on both
recommendations by authorizing their consultants to represent
New Fairfield in negotiations with the Town of New Milford,
apparently, to insure that a sewage construction in New
Milford provided for the New Fairfield needs. And, by
implementing local programs, to avoid the need for sewers.
Order Number 1243 was issued by the State solely to
schedule the financing.design and construction of the
Candlewood interceptor in New Milford for the joint needs of
New Milford, Brookfield and New Fairfield as defined by their
respective consultants.
Much of the controversy that has, apparently,
resulted in the decision of the Environmental Protection
Agency to prepare an Impact Statement, seems to result from
public recognition and concern that real provisions were being
made in the New Milford Stage I and Stage II construction for
New Fairfield. The flame of concern over the provisions to
accommodate the sewerage needs of New Fairfield in the New
Milford project and the future cross-lakes sewer by which
such a connection would be made, were fanned into a raging
fire by those who viewed these provisions as a means by
which a local and unpopular development called Water's Edge,
could be realized. I have grown weary of the efforts of some
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outspoken opponents of this sewerage project to imply
collusion between the developer and various State Official
involved in considering sewerage proposals.
I have, personally, been subjected to derogatory
commentary in the press and in public meetings, requests to
my superiors that I be discharged; a State Police
investigation of charges; requests for Legislative
investigation and, most recently, proposed legislation to
make my job in State Government an appointment by the
Governor, rather than a Civil Service position, for the
express purpose, according to the press inquiry of one of
the sponsor's reasons for filing the bill, of getting rid of
me because of my involvement in these issues in the Lake
Candlewood to Fairfield area.
As I have stated previously, I can fully endorse
the choice of the recommended alternative as the goal of
the sewerage program, provided appropriate contingency
planning is included in the facility design and/or the public
fully understands the potential impact of the choice of the
alternative.
With respect to New Fairfield, I feel that every
effort should be made to avoid or delay the need for sewers.
However, I also feel the phenomenal expenditure required to
provide the means by which the probable need for sewers in
New Fairfield could be accommodated is appropriate. If the
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Final Impact Statement confirms the implied conclusion of
the Draft Statement that such provision should not be made in
the New Milford project, I will accept that conclusion.
However, I suggest that conclusion be explicitly drawn and
that the potential effects be clearly enunciated.
I believe the effects have been enunciated by the
consultants to New Fairfield in a section of their report,
entitled "Existing Waste Disposal", wherein they state
"In many areas, soils are so impervious that required
minimum percolation rates cannot be achieved and property
owners are faced with a nuisance of malodorous and
unsanitary conditions, frequent pumping and the inconvenience
of expensive rehabilitation of systems. In the older areas
of Town where development does not conform to present zoning
regulations, lots are too small to permit duplicate systems
and soils are not of such a quality to permit continuous use
for sub-surface sewage disposal. There are many small lots
which have well water and on-site disposal systems in close
proximity which provides a potential health hazard. These
conditions are especially prevalent in the older, seasonal
lake shore developments." Further, in the discussion section
of the report, the consultants advised that sources of
pollution or nuisance be dealt with locally by directing the
expansion, rehabilitation or abandonment of on-site systems.
They further state that should abandonment be deemed
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appropriate a tank or tanks of suitable size could be
provided to hold all household discharges for pumping and
disposal at the Town lagoons. Should all else fail, as a
last resort, an individual household causing pollution could
be declared a public nuisance or a danger to public health
and the premises ordered vacated.
It is my conviction that the alternatives of
holding tanks or abandonment are means of pollution control
which will have to be implemented in presently developed
areas of New Fairfield if the alternative of sewers is, in
effect, precluded. This causes me to advocate making
provision for the contingency of New Fairfield sewers in the
New Milford project.
In further reference to the potential sewerage
needs of New Fairfield, I would like to identify what I
consider to be a major deficiency in the Draft Impact
Statement: the inclusion of the determination of sewerage
need in section six of the Draft Statement inherently
excludes considering areas outside of New Milford and
Brookfield. I suggest that if the reasoning applied in that
narrative, the narrative of that section, were applied to
the even more densely populated areas of New Fairfield
adjacent to Lake Candlewood, Ball Pond and Putnam Lake, the
insignificant adverse impact assigned to water quality under
alternatives two, three, four and six, would have to be
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altered to be consistent with the impact evaluation assigned
to water quality under alternate two in both New Milford ana
Brookfield.
I regret that I must conclude the Draft Statement
was not — has not been objectively prepared relative to
potential sewerage needs in New Fairfield. It \vould seem
that the popular opposition to sewers has prevailed over a
serious analysis of the facts. The narrative discussion on
water quality relative to alternate five, states that the
significant adverse impact would be of two types: those
related to the construction of an interceptor sewer beneath
Lake Candlewood and possible risks associated with the
long-term operation of this interceptor. It is then stated
that while good engineering could minimize the danger of
problems associated with the operation of an interceptor
beneath the lake, a certain amount of risk, future pollution
incidents, remains. And, further, that while it appears that
present technology makes chances of both permanent and
reserve power failure very slim, the concerns of the
community cannot be dismissed lightly.
I cannot concur in the assignment of significant
adverse impact to the construction of a cross-lakes sewer,
especially since the assignment of significant adverse impact
by definition, eliminates an alternative for further
consideration. I feel that the short-term impact of
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construction could be mitigated by reasonable engineering
design. I would further point out that the alternative of
sewering of Fairfield to Danbury, mentioned in the Draft
Statement and implied to be a reserve option, also involves
a cross-lake sewer.
In closing, I would suggest that the environmental
over-view charts be eliminated from the Final Statement.
They seem superficial to the content of the Statement, are
difficult to correlate with the text and, therefore, tend to
detract from rather than add to the document.
Thank you, Mr. Stickney.
MR. STICICNSY: We'd next like to call on Mr.
Joseph Martinkovic, H-A-R-T-I-N-K-O-V-I-C.
MR. MARTINKOVIC: Good evening, Ladies and
Gentlemen. My nar/ie is Joe Martinkovic. I'm a resident of
the Town of Brookfield. I live on Old Bridge Road. I'm a
landowner that borders the Housatonic River in that region
which is Lake Lillinonah and I'm also a member of the
Brookfield Conservation Commission, being Chairman of that
body. Tonight I would like to speak to you and discuss some
of the things that have been brought up about this EIS, some
of my own viewpoints, too, as an individual who is concerned
about development in the area.
I would like to make some remarks about my views
on the environment. When I was a boy growing up on the
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family farm in South Georgia, ray friends and I, whenever we
could escape from our chores and our schoolwork, lived in
the woods and swamps. We fished, hunted, camped on the
banks of several creeks, gather wild fruits and nuts, dug
honey out of bee trees and hunted for arrowheads in the
field. We still do these things but, as children, we took
the environment, the outdoors we called it then, for granted.
By the time I entered public life, however, I realized that
was no longer possible. I learned that powerful special
interest groups were willing to bulldoze and pollute and
destroy our priceless and irreplaceable streams and rivers,
forests and fields, marshes and coastlines, for their own
personal gain.
Also, too many agencies are insensitive to
environmental concerns. Agencies which should be serving
the public interest are, instead, serving narrow, special
interests. They must either be gotten back on the right
track or abolished. In the years just ahead, we must meet
many challenges if we are to maintain and improve the
quality of our natural environment. One is the control of
pollutants.
We must vigorously enforce the pollution control
laws that are already on the books. We must enforce the
water pollution control act and reach our goal of making our
lakes and streams suitable for swimming and fishing. Much
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of the environmental damage which now occurs can be prevented.
The additional cost is low compared to the cost to society
and future generations if we fail to act. We need far more
research to find environmentally sound ways to achieve
economic goals without unacceptable pollution damage. We
have never put the best brains in this country to work in a
concerted effort to find ways to live in greater
environmental harmony.
Pollution control does not prevent economic
progress. We must have employment and a decent environment.
Now, I'd like to get into the present situation as
I see it in the region.
MR. STICKNEY: I would appreciate it if you could
reference it directly to the Impact Statement.
MR. MARTINKOVIC: I will. I will make all of this
relevant in my summary, sir.
Bob Taylor's unit produced, not too long ago, a
report called the Housatonic River Basin Plan. It is one
report which I find, among many, that gives conflicting
evidence from professionals, scientists, engineers and so
on, and I'm kind of upset that there's so much controversy
coming from so many minds as to what we should be doing, how
it should be done and when. The EIS has made a statement in
its conclusions that the significant defects of the
phosphorous that will come into the river basin from the new
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plant are not important. But, yet, the Housatonic Basin
plan claims and it substantiates this with facts from testing
that they have done — Mr. Taylor is aware of the tests —
it shows how same of the most important sources of
phosphorous pollutants which contribute to the algae problem
in the lakes come from the Danbury, the Bethel, the New
Milford and the Pittsfield, Massachusetts sewer treatment
plants. So, I wonder why the EIS, in its conclusion says
that when this new plant, if and when it comes downstream,
is not going to increase the algae problem significantly in
the Housatonic. There are other conflicting parts of the
two reports that I mentioned but I won't get into them now
in detail.
I think it's obvious that there is a need to
correct some problems which now exist. I've written a letter
to Mr. Taylor that I'd like to make a part of the official
record as follows: "I would like to be assured the proposed
wastewater collection and treatment facilities for the Town
of New Milford, Connecticut will decrease the amount of
pollutants currently entering the Housatonic River. I make
reference to the Draft EIS. As a layman, much of EIS is
hard for me to interpret so I am asking your help, Please
tell me what the quality of the water in the Housatonic will
be after the plant is in operation. Also, will the
anticipated water quality be better than, the sawe as or
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worse than the quality that now exists. In other words,
upon completion of the proposed plan, can I expect to see
water of better quality than now exists in the Housatonlc
along the Brookfield shoreline?" And Ird like to submit
this letter.
If we are going to have sewage treatment facilities
built, whether they serve New Milford and Brookfield and
Danbury and New Fairfield, doesn't really matter to me at
this point in time. I am very much concerned that we don't
get onto the wrong track and that we do come to a meeting of
the minds as to where we're going in this region in regards
to such things as industrial development, residential growth,
sewers, open space and so on. I am concerned about the
quality of life, as I have mentioned before and, again, it
disturbs rae that we have conflicting reports from various
scientists and engineers as to how we ought to go on these
matters.
In closing, I'd like to say that we have some
tough decisions here to make. I don't know, exactly, what
these gentlemen will propose when they corae up with the final
EIS. I hope it takes into consideration some of the
conflicts that I've mentioned and if they would read sorae of
the reports, I imagine they have, they will know what
conflicts I'm talking about. I'd like to see the area grow
and grow properly. I'd like to see the planning commissions
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of the area listen to, more carefully, by the administrative
bodies of the towns involved and then we can all grow
together and enjoy the quality of life here that we now have.
Incidentally, as a part of the public record, what
I had said, were my views on the environment, were actually
excerpts taken from a speech prepared by President Carter
before he became President of the United States and I'm going
to submit those, also, as a matter of public record because
they happen to be printed in the Environment News
publication for February, 1977 from the U.S. Environmental
Protection Agency, Region One. I'm going to give this copy
to our First Selectman. Thank you, very much.
MR. STICKNEY: Thank you. I thought those sounded
like familiar words. Mr. Rogg, the New Milford Planning
Commission.
MR. ROGG: My name is Oskar Rogg. I'm Secretary
of the New Milford Planning Commission. In the absence of
our Chairman, I've been asked to express the feelings of the
Hew Milford Planning Commission to this public hearing. The
New Milford Planning Commission, contrary as to what might
have been the impression in the paper, in principle, has, in
the past and does at present, support an extension of the
sewage treatment facility for New Milford and Brookfield.
Our reservations of the proposal, as they stand
now, is based on facts that are existing in 1977 rather than
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in 1971 and '72 when a great many of the plans, orders and
proposals for the sewer system were, really, formulated. We
have, for example, we are proposing to put a major trunk
sewer along the East Aspetuck and, according to the statement
Mr. Taylor just made before, tnere is one good reason for it
but there is also, again, a State study which analyzes the
drinking water needs of this region for the next fifty or so
years. The East Aspetuck, in a study prepared by the State
of Connecticut and, in a study prepared by the Housatonic
Valley Council of Elected Officials, contains one major
reservoir site which holds, roughly, forty per cent of the
reservoir capacity identified in the Housatonic Valley
Council of Elected Officials' study.
A statement in the State Environmental water
management study, — State of Connecticut Plan of
Conservation and Development, and I quote now, "It is State
policy that sewering which might encourage extensive
residential development not be permitted in those areas."
Now, I feel that we are entitled, as long as we've spent
taxpayers' money, that we are entitled that all the
different bodies of the State get together and decide what
they want us to do. One organization of the State tells us
that we should sewer. Another one spends another hundred
thousand dollars of our money to make a big water study and
tells us where our drinking water is going to come from and
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tells us what they're going to do and the left baud doesn't
know what the right hand is doing.
So, we feel that —
(Applause.)
We feel that the plant — we have no argument with
the plant whatever. It can be argued from here to doomsday
that it is more cost effective to rebuild the old plant and
a few other things but I remind you that in 1958, we're going
to have a plant that's going to be a model for all sorts of
people and it was done poorly. If it had been done right
then, then we wouldn't be here at all. I do feel that the
plant, per se, there is no argument. The argument is with
the emphasis on which areas should be sewered. At this
moment, to sewer the large area of New Milford and the
easterly side of the river, in addition to the existing sewer
area, I do not see the amount of justification for it.
There are such statements which say — generally alludes to
the second type of a problem. Interviews with Town
Sanitarians almost always expressed similar concerns,
especially where small development exists.
If we really have such a terrible problem expressed
by our Sanitarians, then why did we have not one request in
seven years to update the State Sanitary Code which is the
Town of New Milford Sanitary Code? If we do have a problem,
then let's make a Sanitary Code that will stick and let's
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enforce a Sanitary Code that we all can live with. And that
can be done. So, justify simply because there are some
twenty houses that we have to sewer, no, this doesn't hold.
A sewer system can be rebuilt. It costs money, yes. It can
be excavated. It can be rebuilt. It can be made to work.
The question, just automatically, because it's there, no.
So, we have one more reason why it's got to be
looked at again. In 1971, the Planning Commission assumed,
on the basis of, again, data submitted by the State of
Connecticut, that Route 7 would go into New Milford and
terminate up in the Wellsville area. The assumption was that
the combination of an increased sewer network which will
encourage residential development, clearly, and the advance
of a super 7, so to speak, into the heart of New Milford,
would also encourage commercial development at a roughly
balanced scale. So, therefore, we, the Planning Commission
and our consultants, felt that, on balance, our overall tax
structure would be maintained. Now, in 1977, where we are
told that we might have an extension of the road past
Brookfield maybe by 1990, maybe not at all, this changes our
position.
And, I've got to say, again, too, the Anderson-
Nichols did a very good job in this big document. It didn't
— sometimes might not seem to you by going through it one
time. I had to go through it several times. All of the
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information is there. They did not whitewash anything. If
you wish to look for it, it's all there. I quote, in
conclusion, as far as our position that residential
development, the induced residential growth needs to be
limited in order to bring this project in conformance with
the New Milford Plan of Development. The population increase
predictions for Danbury versus the chart increase predictions
for Danbury, for example, they have an increase in Danbury's
population of roughly tagged at eleven per cent while their
potential job increase by two thousand is twenty-two per cent.
New Milford, before sewers, had roughly a sixteen per cent
increase in both jobs and population. If we then take the
induced residential development which would come because of
this sewer project as it is now, as far as sewer areas are
concerned — not the sewer plant. The sewer plant doesn't
induce. The sewer area will. Then we have, in New Milford,
roughly, a forty-eight per cent increase in population by
two thousand while we probably — I'm taking now the
statement of the consultants, the industrial or commercial
development which will balance our tax base does not improve
appreciably. And I quote a statement made in the EIS "By
providing sewers to serve housing areas, New Milford may be
able to serve such needs but at a great distance from jobs
and a tax base deficit which may not be balanced by its own
economic growth."
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We feel that the proposed sewer areas — we oppose
the conclusion drawn by Anderson-Nichols that phase one
serves or satisfies existing and past needs. That's just not
so. I have yet to see, in the last seven years, one order of
abatement. I have yet to see a Sanitarian issue one order to
seme of those apartments where we know there are problems, to
say fix it, stop it or vacate part of your section. Some of
those apartment have been built since we have the Sanitary
Code. I feel, yes, we need a sewer. Yes, we need a plant.
But, where the sewers are to go, that's another story and I
do feel that the proposed sewer area should conform,
clearly, with our water resources as we have them in New
MiIford, probably fifty years from now, to serve and provide
a great deal of the drinking water for the New Milford,
Danbury and Brookfield area and we should preserve it.
Thank you.
(Applause.)
MR. 3TICKNEY: Next, if you please, Mr. William
Tappan and after Mr. Tappan, Ms. Donna Eras.
MR. TAPPAN: It was previously announced, the
Brookfield Sewer Commission, at our meeting last Wednesday,
passed a resolution to sewer the shores area via Elbow Hill
Road, the Route 7 Corridor, to New Milford and I'd like to
pass the resolution over to the firm conducting the SIS
study.
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MR. STICKNEY: Thank you, very much. Ms. Elms,
please.
MS. ELMS: Thank you. I think that the Anderson-
Nichols firm did an excellent study and I think that our
prime concern should be water quality. They state, in fact,
many times, in every section of their study that the water
quality of Candlewood Lake is excellent. I do not see why
there is any reason why that water quality cannot stay
excellent if we have sanitary health enforcement. The
gentleman just stated a few moments ago that there's none in
New Milford. There's none in Brookfield either. We have
asked, repeatedly, where the so-called septic problems are
and if they exist, how many orders have been issued to clean
them up. There have never been any answers given because
they don't want to give answers, they only want to give us
sewers. And, I do not feel that that is the answer.
(Applause.)
Thank you. It's nice to know there's a few of you
out there that feel about it like I do. I moved from a
large town in a big state, used to be the largest, but I
don't want to live in a large town again and I don't think
any of you want to live in a large town.
(Applause.)
MR. STICKNEY: Ladies and Gentlemen — excuse me —
we appreciate your enthusiasm but we're cutting into the
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speaker's time as well. So, would you please refrain from
outbursts?
A VOICE: The other speaker took forty-five
minutes to say nothing. Let her speak.
(Applause.)
A VOICE: I can say the same thing in three seconds
flat what he said.
MR. STICKNEY: You'll be recognized, sir, if you'd
like to be, later on. What I'd like to say is that the
applause is cutting into everybody's opportunity to speak
and we would appreciate it if you could let everybody speak.
MS. ELMS: As I was stating, I moved from a large
town and I don't want to live in another one. There was a
study done by a Government agency called the Council for
Environmental Quality and in that study, it was conclusive
that more than eighty per cent of sewer interceptors were
installed, not because of need, but to promote growth. That
is what is going to happen in this area if we have — and
Anderson-Nichols relates to that in their study, they say
that we will have growth. Nov/, that is not going to only
affect us for a short time. It's not going to be a short-
term environmental impact, it's going to be a long-term
environmental impact, and we better think about that and we
better get people involved and attend meetings.
If the people that are for it would get as
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involved as the people who are against it, it seems to me
that the people in this area don't want sewers, that it's
mostly the politicians that are pushing and I think that as
long as the quality of our water is good, that there is no
argument for sewers. In our area, we live in a private
development with four hundred and thirty homes, there is
absolutely no water drainage there. Anderson-Nichols did not
investigate that. They did not address themselves to it.
Neither did the study in Brookfield that was done by the
Albertson, Backus and Sharpe group. They didn't even know
that we were a private area, that we had water wells that
were already inadequate. Many people are without water.
Neither did Anderson-Nichols address themselves to that.
They didn't realize that we had private water. Also, many of
you must also live in private areas. It has still never
been proven to any of us that we will be, in fact, able to
receive Federal funds or State funds. So, the figures that
they are quoting for prices could be way off base and don't
let anybody tell you that hurry up and get on the bandwagon
and let's sewer quick while this Federal money is here.
That's a bunch of bull.
(Applause.)
That's a poor argument. Let's prove the need for
sewers and then, if there is a need, let's pursue it in a
planned, organized manner. If we do not have master plans of
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development in our towns, approved by our voting population,
there will be unscrupulous growth and unscrupulous building
and it will destroy the rural image that all of us moved to
this area to enjoy and raise our children in. Thank you.
(Applause.)
MR. STICKNEY: The next card is from Mr. Peter
Hearn, Housatonic Valley Association.
MR. HEARN: Thank you, Mr. Stickney. In the
interest of brevity, I will not read the statement that I
prepared. I'll merely summarize it. The purpose of the
Draft is to elicit criticism and I have some criticism. I'll
deal with the shortcomings of the Draft. I won't mention
the points about the Draft that represent a lot of good work
by competent people.
The shortcomings I want to talk about are plant
capacity, protection of water resources, mode of treatment,
secondary effects and the need for the plant. Since
Anderson-Nichols was commissioned to do this, tv/o developments
have occurred in the area which should be addressed in the
final version as Mr. Walrath referred to earlier. One is
that the Brookfield consultants have recommended that the
Town of Brookfield not join the New MiIford plant. The other
is that the public and the press have speculated that the
Nestle's facility might construct its own plant rather than
tie into the New Milford Town plant. Both of these, the
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Housatonic Valley Association would like to see looked at in
the final version from the standpoint of the impact on water
quality of both of these decisions and, also, the cost
effectiveness of these decisions for the Town and the Nestle's
Company.
In regards to protection of water quality, it's
taken man hundreds of years to realize that emptying the
chamberpot into the river is no improvement over emptying it
into the street and, at a minimum, phosphorous removal
should be required at the New Milford plant and we would like
to see this discussed in more detail in the final version.
Changing New Milford from a town that dumps half a million
gallons of secondarily treated sewerage into the Housatonic
to a town that dumps four million gallons of secondarily
treated sewerage into the Housatonic is really an example of
primitive thinking that has no place in the nineteen
seventies.
Also, the Housatonic River has, recently, been
designated for a study for inclusion in the National V7ild
and Scenic Rivers system. The current Draft EIS makes no
mention of this designation, this possible designation as a
river with national scenic significance. We would like to
see the final version address itself to this in regards to
siting of the plant, size of the plant and degree of treatment
mentioned earlier.
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Under mode of treatment, the topic of land
treatment was discussed in the Draft version. The version
identified areas in the Town of New Milford that had
capacity for land treatment and it was determined that these
areas could handle 1.6 million gallons per day of sewerage.
Some of the land was open fields, forage, crops. They
absorb about three hundred pounds of nitrogen per acre per
year. The other area was forests which absorb about fifty
pounds per acre per year. No consideration, however, was
given to the possible conversion of the forest land to fields,
if the forest land could be, if the soils would permit it,
if the forest land could be converted, all of the forest land
designated, could be converted to cropland, that would
increase the land treatment capacity to 3.2 million gallons
per day which, in combination with the current New Milford
plant, should be adequate to meet the Town's needs.
We'd like to see that addressed.
Also, we'd like to see a more in-depth discussion
of some of the secondary impacts of sewerage treatment, just
for the sake of the people in Town so that they fully
understand what sewer installation will mean. The issue of
storm water runoff was not really addressed. As you develop,
you pave over areas that used to absorb water. Then you
create flooding problems. That could create a demand for
flood control measures. It could also create a demand for
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storm sewers which would increase the needed capacity in the
plant. We'd like to see that discussed. As you develop, you
increase the number of people who move in. Consequently,
the number of automobiles; consequently, air pollution. The
Draft version did not discuss auto-induced air pollution.
We'd like to see photochemical oxidants discussed in more
depth in the final version.
We'd also like to see the final version address the
question of open space. The Town plan of development has
allowed for the preservation of open space. We would like to
see an analysis of whether sewer-induced development will
cause a decrease in this open space; will it threaten the
open space and, if so, how can the open space areas be
preserved. And we'd also like to see more in-depth
discussion of the increased demands on transportation,
health services, schools and domestic water needs.
Lastly, as a result of these public hearings, it
seems that enough citizen opposition within the Town of New
Milford has surfaced, that possibly the Town, itself, should
re-examine its plan of development in light of the issues
that have been raised due to this Impact Statement.
Thank you.
(Applause.)
MR. STICRNEY: I'd just like to say, regarding the
Wild and Scenic Rivers Act, the project is subject to the
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provisions of the Act. We are coordinating with the
Department of the Interior and formal clearance by Interior
will be required as part of the project approval. By the
way, it's not an unusual situation. This is precisely why
the Impact Statement process — one of the reasons it was
developed so that, as they say, once in a while the left
hand gets to know what the right hand is doing before it's
all done. I'd like to declare a five-minute break so we can
rewind the tape and begin with Mrs. Gaudet.
(Whereupon, a short recess was taken.)
MR. STICKNEY: And, after Mrs. Gaudet, Mr.
Chambliss, please.
MS. GAUDET: My name is Mary Gaudet and I live in
New Town and I'm speaking as the Vice Chairman of the Lake
Lillinonah Authority. There are many issues involved in this
proposed treatment plant in New Milford but we will comment,
mainly, on the phosphorous removal question and on water
quality in the Housatonic, touching on the growth of New
Milford only as it relates to water quality in the river.
Just as background, as you may know, Lake Lillinonah
suffers from eutrophication which involves the nuisance
alga bloarns during the summer months. The lake has been
identified as being phosphorous limited meaning that the
very sources of phosphorous which reach the lake are
responsible for the blooms of the bluegreen algae which
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greatly decrease the recreational and aesthetic values of
the lake. We strongly object to the fact that the proposed
project does not include phosphorous removal at the time of
construction. The argument used against phosphorous
removal at the treatment plant seems to revolve around the
fact that such removal would not solve all the lake's
problems and I quote from the Impact Statement, page Roman
numeral five, and I quote, "Complete removal of all
phosphorous from all treatment affluent would not eliminate
eutrophication problems". And, on page 143, quote, "Even
the effectiveness of complete phosphorous removal from point
sources in stopping eutrophication is open to question." End
of quote.
The statements may, possibly, be accurate but
before we eliminate eutropnication or stop eutrophication,
why isn't it a reasonable goal to decrease the problems that
eutrophication causes?
In essence, the Impact Statement is saying, we
have a sick lake here but cleaning up this one small source
of pollution isn't going to completely cure it. So, let's
increase our pollution because it really doesn't matter what
we do. In short, there are degrees of eutrophication and
the Lake Authority is seeking to reduce the algae problem and
improve the character of the lake. If there were a cure-all,
a way to completely solve the lake's problems, we would
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certainly pursue whatever course of action that might entail.
But, realistically speaking, every small improvement is a
victory and if we add up enough small improvements, some day
vre may have a very desireable lake.
We feel that phosphorous removal at the tfew ;«iilford
plant would be one such small victory. Doctor Charles Frank,
Chief of the Department of Soil and Water at the Connecticut
Agricultural Experiment Station tells us that the
relationship between phosphorous concentrations and algael
growth is a lineal relationship. In other words, if the
phosphorous is reduced by X-per cent, then the algael blooms
will also be reduced by that same X-per cent. And, I have
enclosed a copy of a letter from Doctor Frank in which he
discusses the lineal relationship between phosphorous and
algael blooms.
Thus, phosphorous removal at the New Milford plant
should reduce some improvement in the lake. On the other
hand, the new treatment plant, without phosphorous removal
will actually increase algael growth. The Impact Statement,
itself, admits that the new plant would increase the
phosphorous level to Lake Lillinonah from one point seven
per cent to six point five per cent initially. And that is
initially. That is before any of the induced growth takes
place. And that represents a three and a half fold increase.
The resultant algael blooms will tend to further deteriorate
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water quality by decreasing the amount of dissolved oxygen
available for fish and plant life. As fish and plant life
die off, even more oxygen is consumed for decomposition. It
becomes, then, a downward spiral.
Concern about the increased phosphorous load to the
Housatonic is expressed in the Housatonic River Basin Plan
which Mr. Martinkovic talked about earlier which v/as
prepared by the Department of Environmental Protection. On
page 72 it states, and I quote, "The expected increase in
this load to two hundred nineteen pounds per day by 1990
will add significantly to the phosphorous load on Lake
Lillinonah. Serious consideration should be given to
requiring phosphorous removal at the New Milford plant."
End of quote.
These new sources of phosphorous include many
septic systems in New Milford which are now, apparently,
functioning perfectly well. Because of the soil's almost
limitless ability to absorb phosphorous, these septic systems
are handling this wastewater problem in a very environraentally
acceptable manner. Now, what we will have instead is a
collection system to funnel all of this wastewater to a
plant which will turn the phosphorous into a form more
readily utilised by plant life and discharge it almost
directly into the lake. The whole question of growth
involves not only increased phosphorous to the lake through
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the collection system but also the secondary growth resulting
from the increased services that will be necessary for an
increasing population. It certainly is not our intention to
interfere with the planning and zoning functions in New
Milford, but we have learned that land use and water quality
are so very closely related that we cannot ignore development
in any of the towns bordering the lake. We are not against
growth but feel that it must be planned for so that it will
take place in an orderly and environmentally sound manner.
We feel that an eight-fold capacity increase in a
sewage system places tremendous pressures on local planners,
more pressure than any one town should be expected to cope
with. It does open the door for rapid and, perhaps, shoddy
development which, eventually, may have a negative impact on
the Kousatonic.
In conclusion, then, if New Milford is to have a
new sewage treatment facility, let it be of a reasonable size
commensurate with the needs of the Town and of a treatment
level which will not compromise the integrity of the
Housatonic River and its impoundments.
(Applause.)
MR. STICKNEY: Mr. Chambliss, please. And then
after Mr. Chambliss, Doctor Groff.
MR. CHAMBLISS: I am Samuel M. Chambliss of Richfiel
I am presenting these comments in behalf of the Land, Air and
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Water Society. LAWS is a non-profit corporation organized
for the purpose of promoting sound environmental practices in
all matters dealing with the land, air and water in
southwestern Connecticut. My comments will be of a general
nature and I will be followed by our Scientific Water
Coordinator, Doctor Donald W. Groff.
The preparers of the Draft EIS have labored long
and hard. In this instance, they have brought forth,
perhaps not a mouse but a document that asks more questions
than it answers. LAWS will address itself to the two of the
more important.
The Draft EIS inadequately assesses the environmenta
impact of the continued discharges of phosphorous and
nitrogen into the waters of the State. It would appear, from
our reading of every portion of the Draft EIS, pertaining to
the question of eutrophication, that while it is admitted
that the phosphorous input will be increased four-fold by
the facility, the Statement takes the position that (a) this
is marginal; (b) not doing it will not solve the
eutrophication problem and (c) provision can be made later
for tertiary treatment of phosphorous and nitrogen. This is
inadequate. A four-fold increase is not marginal.
Presumeably, the future activities of the State
and Federal Government in connection with the Federal Water
Pollution Control Act amendments of 1972 will mean that other
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sources of nutrient input into the Housatonic River will be
controlled. Even if this were not the case, it has never
been acceptable environmental planning to take the position
that one continues to degrade the natural resource because
others are already doing so more seriously.
Finally, the matter of subsequent tertiary
treatment is likely to be a snare and an illusion as we shall
subsequently point out. There are a number of industrial
point source discharges in the service area of the proposed
waste treatment facility which were granted MPDES permits on
the condition that these discharges be tied into and receive
treatment at this proposed facility. These very industries
are largely responsible for the nutrient loading of the
water in the area sought to be served by the proposed facility
but it now appears, from the Draft EIS, that such treatment
is not to be included in the proposed facility.
The impact of this failure is rather cavalierly
dismissed as being negligible. In point of fact, it totally
ignores the strictures of the Federal Y/ater Pollution Control
Act that the best practicable technology be utilized to
eliminate these pollutants. The same reasoning is applied —
if the same reasoning were applied to similar polluters
along the entire course of the river, it would totally negate
the mandate of this Act. Furthermore, we question the
statement that appropriate measures can be added to the
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proposed system at a later date, should it prove necessary.
In the first place, it's necessary now. But, be that as it
may, the Draft EIS is totally silent on the capacity or the
capability of the Carrousel system to be adapted to the
necessary tertiary treatment to accomplish this. We suggest
the Carrousel system is not adaptable and, in point of fact,
we find no application of it which makes provision for this
type of treatment.
Further, there is no assessment in the Draft EIS
in terms of cost benefit of the subsequent addition. We
suggest that if the sum of five to seven thousand dollars per
household for hooking up to the present proposed system is
likely to be unpopular, then the addition of the substantial
additional such cost, may prove sufficiently unpopular so
that it will not be made even if it is technologically
feasible. In other words, the decision not to provide this
type of treatment at the present time may well be, in point
of fact, the final decision not to do so.
The second point to which LAWS addresses itself is
the inadequacy of the Draft EIS to consider the long-range
effects of the induced growth which the proposed system will
impose upon the region. The planners recognize a considerable
degree of induced growth is predictable from the facility as
proposed. Such projects are, in their very nature, self-
justifying. That is, the only way to justify a project which
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is designed for a larger capacity than it presently has, is
to create a demand for the total capacity.
The planners recognizing this as a political
consideration for the communities refuse to assess it, saying
it is not for them to decide whether or not the communities
in the area wish this growth. To this, we say that these
communities better make the decision now because it will be
too late to do anything about it once the facility is
constructed.
An inadequacy of the Draft EIS is the failure to
provide the communities with the facts and the data upon
which to adequately consider the long-term effects of such
growth. For instance, whatever can be said for such a
facility in terms of water quality, it does nothing to
enhance water quantity. In fact, it may aggravate this
problem by eliminating a substantial amount of ground water
recharging which takes place from individual sub-surface
sewage disposal systems. This, coupled with the induced
growth, may lead to long-term water quantity problems in the
area. As to this, the Draft EIS is, at best, ambivalent and
certainly lacking in any depth or breadth of scientific
analysis of the problem.
In conclusion, we submit that this project appears
to have been conceived in the spirit of mid-twentieth
century progress and should be reconsidered both by its
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proponents and by those communities which are to be the
recipients of its rather dubious virtues. Thank you.
(Applause.)
MR. STICKNEY: Doctor Groff, please.
DOCTOR GROFF: I am Donald Groff from Brookfield,
Connecticut. I am here representing not only myself as a
citizen but the Land, Air, Water Society from Richfield.
That's a non-profit, public service organization. They
promote sound environmental practices.
As I examined the Draft Impact Statement, I found
that it was many things. First, it was an encyclopedia. As
one who has authored many such studies, I must respect and
appreciate the pains that the organization went through in
preparing such a statement. Yet, I am left with many questior
and many concerns. I think they've offered a large number
of sweeping generalities, especially as it applies to the
natural history of the terrain that they have analyzed.
Many statements are made with respect to soils.
They tend to group them and they do not, they have not,
tried to analyze, for example, the ability of the ground to
absorb — the ability of the ground to accept precipitation
for recharge. They have not anticipated the amount of ground
water drawdown as a result of a lack of recharge, especially
in the carbonate valley of the Still River. As mentioned
before, they have inadequately, I think, planned for the
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removal of the phosphates and they have, I think, grossly
understated the effect of an increase of four hundred per
cent of phosphates in Lake Lillinonah. When you go from one
point seven to six point seven, that's four hundred per cent
increase.
The statements on eutrophlcation, I wouldn't call
that marginal. When they make reference to eutrophication
in BOD, I'm afraid that some of the statements are, pernaps,
not as detailed as they should be. The Carrousel system is
not a guaranteed thing. I would like to know one domestic
user, one U.S. user that says it will work. Some of the
statements, I think, by Peter Hearn are especially appropriate
In addition to the photochemical oxidants, western
Connecticut has one of the highest ozone atmospheres in the
country, second to Los Angeles, many parts of the year. I
"nave seen no analyses that would project the increase in
traffic and the production of ozone as a result of growth in
this area.
Flood water runoff seems not to have been
considered. When, for example, heavy precipitation occurs,
perhaps twenty per cent of what falls will run off into the
streams, it will run off directly into the streams and into
the water courses. Maybe eighty per cent left for recharge,
perhaps to appear as springs or to be lost by
evapotranspiration. As a result of development, a one hundred
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per cent sewered area will be approximately sixty-five per
cent impervious. As a result of precipitation, possibly
thirty or thirty-five per cent will be lost to runoff. This
may create flooding. As a matter of fact, at that point, in
another area study, it was found that the flooding increased,
the overbank flows increased six hundred per cent. I can
cite references for you if you would like, on that, on these
particular studies done in the northeast.
And so, it seems to me that although an
encyclopedia has been produced, a large number of questions
remain. It was also recognized that many of the failures,
septic failures, are not as a result of new construction.
They're the result of past construction and, perhaps,
seasonal developments. If this is the case, then what's the
rush? Are we planning on new failures because of new
construction? If these past failures we're planning to
accommodate or take care of — and then I don't understand
what the rush is. Thank you.
(Applause.)
MR. STICKNEY: Thank you, Doctor. Mr. Carl Dunham,
Economic Development Committee, New Milford Chamber of
Commerce. After Mr. Dunham, I'd like to call on Mr. John
Donet.
MR. DUNHAM: Thank you. As the Economic
Development Committee of the New Milford Chamber of Commerce,
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we hereby wish to go on record in support of a sewage
expansion project that will provide a base of quality
industrial and commercial growth. This is necessary in order
to keep a balance with the anticipated residential
development which will inevitably be forthcoming in the
Township of New Milford.
With less suitable land available to the south,
New Milford, even with its lower grade Route 7, is in line
to catch the growth overflow from upper Fairfield County.
As a community faced with these problems within the next few
years, careful assessments must be made by all Town agencies
as to the Town present position and where it wishes to be in
the future. Our group feels we cannot shut our eyes to the
growth that is just over the horizon. We must make
preparations, today, for this potential development.
Inadequate sewerage systems serving some of our present and
potential industrial and commercial sites should and must be
part of our overall master plan.
We, as a group, request that a careful measurement
be made of the economic impact of the overall project on the
Town, as well as the long-range effect of any scaling down
that might be favored at the present time. Improper scaling
down of the sewer project at this time would most likely
cost the Town and its taxpayers, excessive amounts in future
years as the increasing needs must be satisfied at inevitable
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higher cost. The essence of our interest is to provide a
good industrial, commercial tax base for the Town and thereby
ultimately relieve residential homeowners of the burdens of
higher taxes. We feel anything done at this time to
discourage the quality industrial and commercial growth will
prove damaging in the long-range economic development of our
community. We are sitting on the edge of an urban explosion
that will require additional public services and schools and
it is, therefore, essential to continue and to increase the
advantage of having large corporate taxpayers in the Town.
Thank you.
(Applause.)
MR. STICKNEY: Mr. Donet, please. (No response.)
Okay. I'd like to call on Doctor Zehrung, Director of Health,
New Milford.
DOCTOR ZEHRUNG: Ladies and Gentlemen, there have
been a number of changes in the concepts of this project
since its first inception. One of them which I think is
encouraging is the fact that the overall size of the plant
has been reduced. I think one of the other things which is
very commendable is the fact that the underlake connector
from New Fairfield to New Milford has been eliminated. And
I can see nothing to gain by talking about adding a connector
under the lake. Technology, yes. You can, probably, build
a pipeline that will be, essentially, foolproof, and it is
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spelled M-O-N-E-Y. And I think for the same cost or
considerably less cost, the New Fairfield problems can be
pumped to other areas.
We have a problem in Candlewood Lake, being a
manmade lake with basins in it and if there should be a
major raw sewage escape into the lake, it would be next to
impossible to remove it. You'll probably ask, well, they
put sewers under rivers. Yes, they do. But a river is a
flowing body of water and it will, in time, cleanse itself.
True, all of the effluent goes out to the ocean. But, this
is a lot different from a manmade lake that has little or no
flow. Now, some of the things that have worried rae about
the impact study has been the apparent completely oversight
of water conservation which has been alluded to by several
speakers in the past. We pump the water out of the ground.
We use it for our domestic and industrial purposes and, at
the present time, a great deal of it is put back into the
ground where it came from, through the sub-surface sewage
disposal systems that we have in many of the houses. And, at
present time, there's a small percentage of it that is piped
to a sewerage treatment plant and eventually finds its way
into the river and eventually out to the ocean.
Now, if we go along with our State DEP's idea of
mass sewering, we're going to be taking all of this water,
presently some four million gallons a day, and dumping it in
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the Atlantic Ocean. And it's not going to be doing us any
good, as far as re-use in our own water supplies. We have
had periods in the past when, as you well know, many of our
wells have gotten pretty low. Some wells have ceased
functioning. And the water is not an inexhaustible supply.
It must be considered and conserved. And one of the best
ways to do it is to put it back where you got it when you're
through using it.
There were some statements earlier which I would
like to correct. There was one statement that I heard that
there had been no abatement orders issued on failing systems.
In New Milford, there have been abatement orders issued and
these conditions have been corrected. Now, one of our
problems is that we do have, and I think you know as well as
I do, that there are areas in the Town that have problems as
far as the sewage disposal systems are concerned. Not every
house in each area is involved. It is scattered. And,
likewise, along Candlewood Lake, along the road, there are
houses that have good systems, that are functioning. The
people have space for one hundred per cent reserve and there
is no problem. There are other areas in which people have
modified summer houses on very small plots. They, very
obviously, have a marginal system. If it failed, the
correction of this would be difficult. And these areas,
true, should be considered for sewering.
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The quality of the water is something that we must
consider. I concur with the Impact Study that we have to do
something about it. The one thing that I do question is,
are we developing a mass network of sewers to the benefit of
developers to cane in and convert zoning to their needs where
we could come in and put in houses on half-acre or quarter-
acre land? Or, is the concept of sewering to meet the
immediate needs of the community, perhaps have the sewering
program designed so that it can expand as the Town expands
in orderly growth. I think that our impact study alluded to
this. I would have been happier had they been more specific.
I think that we do have to consider that it is time to
update our sewer system.
I think that we have to decide where we're going to
put our main trunk lines and these must be designed to carry
the load that would be anticipated in the next twenty-five
to fifty years, because it would still be cheaper to put a
large pipe in now, than to tear it all up and put in a
second pipe later on. This does not necessarily give a
mandate that all of the laterals must be extended. This
should come under the control of the Planning Commission.
This is the group in Town that decides how the Town grows,
where it grows and what type of growth we are going to have.
And, I believe that the Planning Commission should have a
very close working agreement with our sewer planning groups.
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If they do their job properly, then we will not have sewers
developed for the sake of developers. Thank you.
(Applause.)
MR. 8TICKNEY: Thank you, Doctor. Ms. Jane Garvey,
Alternate Member of the Planning Commission. After her,
Clifford Chapin, C-H-A-P-I-N.
MS. GARVEY: My name is Jean Garvey. I am a
resident and taxpayer in New Milford. I am not speaking on
behalf of the Planning Commission. I am speaking on my own
behalf.
I have been involved with this proposed sewer
project for several years. I have served on the Planning
Commission sewer study, attended hearings, workshops and read
volumes of studies done since 1967. It is evident to me
that we have spent considerable time and money and gotten
nowhere fast. No Local Official has taken a firm stand on
this issue in ten years. Our leadership has been totally
lax about taking a position on this matter. I have very
strong feelings about this proposal and I want to have them
on record at this time.
First, I have several questions that demand answers.
After reading the Environmental Impact Statement, it becomes
evident that this is not people-oriented. It covers water
quality, construction, flood plain and wildlife impacts, et
cetera, et cetera. However, there is little or no
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consideration given to the quality of the social impact
involved. There are no estimates of the impact of new
schools which will be required due to induced growth. The
impact of additional Police protection. The impact of a
larger and perhaps full-time Fire Department and additional
highway services. What impact will this project have on the
aesthetics of New Milford? How many wooded hills, green
valleys and country lanes will be left? What impact will
this have on the economics of our residents?
In addition to the already burdensome tax load,
can our residents afford the high cost of lateral and
hook-up fees estimated at four thousand dollars per heme?
Can we afford the high annual cost estimated at over three
hundred dollars per year? This annual cost could increase
the average taxpayer's burden by one-third or more of what
they are now paying. What impact will this project and the
growth it will force on the Town, have on our present form
of Government? Will we be able to manage the Town with the
volunteer work of our citizens or will we have to hire these
services in the future?
Finally, has anyone ever asked the residents of
New Milford whether they really wanted this enormous project?
Because of these and other reasons too numerous to mention,
I am totally opposed to the scope of this proposed project.
I will continue to press for adherence to the wishes and
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needs of the people of New Milford.
Although I am opposed to the magnitude of this
projected project, I do feel there is a need for expansion
of our present facilities. However, the sewer expansion
should compliment our updated plan of development rather
than dictate changes. I feel that I have conveyed the
feelings of public opinion for the residents of New Milford
and we must comply with their wishes. After all, they will
bear the burdens of this excessive program. Thank you.
(Applause.)
MR. STICKNEY: Mr. Chapin, please.
MR. CHAPIN: Good evening, Ladies and Gentlemen.
I did have a prepared statement but I don't think I better
use it. This is a highly emotional hearing. We have a big
thing to decide upon. I don't think it should follow
political lines. Probably, the people at the table here
don't know what the season is for New Milford but this is our
political season. I don't think that this problem should get
involved in politics in any way. Therefore, I'm not going to
make any statement. Thank you.
MR. STICKNEY: Mr. Chapin, any statement you wish
to submit in writing, of course, will be responded to. I'm
somewhat shocked by the brevity of that statement. We'll
press on. Ms. Barbara Obeda, O-B-E-D-A. And, next, Mr.
Howard Kemmerer.
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MS. OBEDA: How do you do? My name is Barbara
Obeda. I'm a resident of Brookfield Center and I'm on the
Inland Wetlands Commission in Brookfield but I am speaking
this evening as a private citizen.
My concern is that little analysis and even less
concern has been given to the long-term environmental effects
of this proposed sewering. Tonight, I find that the decision
to run the sewer line from Candlewood Shores via Elbow Hill
Road and north along Route 7 through the Still River Valley
to New Milford, was a political decision, i.e., to advance
industrial expansion. I feel that the secondary
environmental and ecological effects of today and into the
future, for the next ten, twenty-five or fifty years, have
not been adequately assessed. Pollution of all kinds must
be controlled and, lest we forget, this also includes human
density. It is here, during these future years, the
pressures of the grossly overstressed ecosystem and — will
be all too apparent. The dollars, tax dollars earned today
by industrial expansion will have to be spent many times
over for expanded, publicly supported, municipally operated
water systems, for they, too, will become necessary.
I cannot see sacrificing the environmental future
of Brookfield, New Milford and the Housatonic River's
presently extremely viable assets for the gold ring on the
merry-go-round called industrial expansion. Being extremely
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aware of the complex interrelationship of all environmental
parameters, I ask that the future not be sold down the river
for the dollars that sewers seem to be earning today.
(Applause.)
MR. STICKNEY: And, after Mr. Kemmerer, Mr. Leonard
Stevens, please.
MR. KEMMERER: Thank you. My name is Howard
Kemmerer. I'm from Newtown, private citizen.
Us people in Newtown are quite concerned about the
New Milford-Brookfield sewer because we're downstream from
you. So, whatever you do, we're going to get. I would like
to make a few comments about the Environmental Impact. First
of all, concerning downstream impact, we are presently, in
Newtown, under orders to sewer by the State of Connecticut
and, also, there are two other towns, Woodbury being one —
I can't think of the third one — that are involved in the
study of a three-town sewer. What impact will this sewer
project have upon the future and the advisability and the
feasibility of the sewers in those three towns.
Number two is, the Environmental Impact Statement
did not address itself at all to sludge and sludge disposal.
They indicated that the maximum would be somewhat over fifty
cubic yards of sewage sludge being produced per day, either
disposed of in landfill or seme other method. And, in the
Impact, it said the alternatives would be explored when the
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final alternatives were determined. Well, it seems to me
that New York City has quite a problem right now. They're
under orders by EPA, I believe your organization, to dump
the sludge two hundred miles out in the ocean which is out
at the continental limit. I daresay New Milford might find
a little problem in doing that.
The third thing and it always comes up and I wish
that everybody would totally ignore this threat or this pie
in the sky about industrial tax base; the economic impact is
needed. Believe me, there are no studies and you cannot find
an economic study anywhere in the country that's been done
that will prove, conclusively, one way or another, thay any
industry is good or bad for a community. There are no
formulas. Believe me, I've tried. So, all you can do is
suppose. We know, innately, that an industry that has a
high inventory, expensive inventory, a few employees,
probably a few housewives, a part-time job, so you don't have
to move anybody into town, or one of these large corporate
headquarters that do not have to be sewered and watered or
that you don't have to build a special exit off 84 for, are
good.
(Applause.)
But, I don't think you're going to find too many
of those industries. Therefore, without any substantial
data and sewers, a community is forced into accepting any
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industry that wants to come in, under the threat that this
will broaden the tax base of the community. Believe me, all
it does is give the community a net loss and I think one of
the previous speakers al/luded to services in the community,
schools, roads, fire, police, et cetera, et cetera. So,
please, and I urge the Final Impact Statement to plan for the
people, with the people utmost in mind, and not for industry
only and in the Environmental Impact Statement or study,
the cost benefit ratios must be assessed and must be looked
at. And, please, do not go under the threat of industrial
tax base.
(Applause.)
MR. STICKNEY: I'd like to call on Mr. Stevens and
then Ms. Hague and then Mr. LeFavre.
MR. STEVENS: My name is Leonard Stevens. I am a
resident of Bridgewater. I've had an office in New Milford
for twenty years. I'm the Chairman of the Sunny Valley
Preserve Project Committee which made an offer and a
proposal related to the project that we're talking about
tonight. But, I am not here representing that proposal or
that organization. I would like to speak for myself. I,
also, am a member of the Conservation Commission of
Bridgewater and Bridgewater is very related to this since we
have a great deal of shore on Lake Lillinonah.
One evening nearly four years ago in this same
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building I was Chairman of a seminar attended by nearly a
hundred and fifty municipal officials, industrial officers,
civic leaders, editors and educators who spent some six hours
learning about the new Federal Water Pollution Control Act
amendments of 1972. There, we heard Thomas E. Jorling,
former Minority Counsel of the U.S. Senate Committee on
Public Works, one of the chief drafters of the new Act and
one of the nation's leading authorities on the law. The Act
which had, only recently, been overwhelmingly passed by the
Congress, pointed to a fundamental new direction in water
pollution control, said Jorling. It firmly established that
the nation's waters, its rivers in particular, were no
longer to be considered part of our waste treatment and
disposal system. With the new direction, he continued, we
must apply our technological genius to achieve recycling or
to combine, confine and contain pollutants so our waters
will be restored to the role that nature intended. A great
deal of money would be expended in establishing this
dramatic new policy for water pollution control and the
administrator of it all was to be the Environmental
Protection Agency, the EPA.
Yes, replied Mr. Jorling, to a question, the law
had serious opponents, not so much in affected industries,
as in the Government itself. Indeed, in the implementing
agency, the EPA. There seems to be a reservoir of hostility
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said our seminar guest, to the concept of ecologically
sound pollution control represented in the 1972 amendments.
There is still preference for the old notion of using our
natural waters for waste treatment. That was the most
serious threat to the new Act, he concluded.
Tonight we are here in the same building under
the aegis of that implementing agency, the EPA, to comment
on a Draft Environmental Impact Statement concerning a
proposed wastewater collection and treatment system that
would be largely funded under the 1972 Act and, thus, a
system that should reflect some of that new direction we
heard about four years ago. Sadly, it does not. The
proposed system would go right on doing what we have always
done, partially treating our sewage and discharging it in
the river which is then expected to complete the treatment
job. This is the disastrous course we have followed for
decades, the one that the new Federal Law was supposed to
change.
As Mr. Jorling reminded us, the change was supposed
to occur by the EPA encouraging the recycling of potential
sewage pollutants and/or the confined and contained
disposal of pollutants not recycled. These key ideas are
foreign to the proposed New Milford system. Recycling was
quickly forgotten, if ever thought of in the first place and
a system that proposes to reach into other towns, collect
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sewage pollutants, consolidate them for only partial
treatment and then dump them into the Housatonic for transport
by water to the Long Island Sound, can hardly be described
as encouraging the confined and contained disposal of
pollutants. This would be forgiveable if the proposed
system abided by the 1972 Act by explaining how, in the
future, its design would become part of a larger system that
would do what the Law calls for us to do. The effort to do
this by the proponents is so feeble as to be practically no
effort at all.
Now, one might expect that the guardian of this
Federal Act, the Administrator, the EPA, might have
something to say about these rather obvious omissions,
especially in this three hundred and twenty-five page EIS
that we, as citizens, taxpayers and constituents of those
who passed the Law, are here to comment on. In my reading
of the voluminous document, I fail to see any evidence that
the EPA is hardly aware of any new direction or national
policy established by the Congress in 1972. In an
unbelievably wordy, difficult to read book,the EPA blithely
buys the same time-worn concepts that in the name of water
pollution control, has given us water pollution and little
control.
(Applause.)
Mr. Jorling's fears about the nature of the
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opposition of the new Law are well-supported by the Draft
EIS. This aversion to the Law is particularly evident with
the kind of treatment system that the Federal Act clearly
and forcefully encourages. It is called land treatment and
it satisfies the main thrust of the new Law. It depends on
carefully strained, partially treated and sterilized
wastewater on croplands. Two things happen: the soil acts
as an amazing filter to contain the pollutants as the
wastewater filters downward through the earth or trickles
across the surface. Furthermore, the roots of growing plants,
hay, silage corn, trees or nursery stock, take up and thrive
upon the so-called pollutants which are really fertilizing
nutrients like nitrogen and phosphorous. The filtered water
in a well-designed land treatment system can be of drinking
water quality that may be reclaimed and re-used in various
ways, or put into a river without fear of pollution. The
crops may even help pay for the system. It has advantages
of preserving open space and for serving a good purpose in
augmenting today's hard-pressed fertilizer supplies. The
Federal Act and subsequent regulations make it mandatory that
land treatment be considered as an alternative treatment
system. Most conventional Sanitary Engineers don't like that
requirement. They are seldom equipped to carry it out
thoroughly and well and, perhaps more to the point, their
fee system is less certain to be as profitable with land
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treatment as with conventional systems.
The result: this kind of a system gets studied
more by word than by deed. This, in my opinion, is what
happened in New Milford. The original assessment of land
treatment by Metcalf and Eddy was off the cuff and negative.
It was clearly written by someone inexperienced and
unqualified to do a valid investigation. I pressed to find
out who did the job and what were his qualifications and I
have yet to find out. I believe it was only a sop to the
requirements of the Law.
Subsequently, a group of us involved with Sunny
Valley Preserve brought a highly-qualified and experienced
expert on land treatment to New Milford, Doctor John
Schaefer of Chicago. He was co-designer of a remarkably
successful land treatment system at Muskegan, Michigan which
many people have read about or heard about. His view of the
land treatment possibilities in New Milford were very
different from Metcalf and Eddy's. Doctor Schaefer felt
that the Town might benefit from land treatment, that it
could very well provide a more cost effective, environmentally
sound system than the current proposal offered. Doctor
Schaefer and I were invited to appear before a special
meeting of the New Milford Selectmen and there, I know he
convinced many of the listeners that land treatment was,
indeed, a viable alternative for the community. I believe
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Doctor Schaefer*s organization was on the verge of being
retained by the Selectmen to back up this contention with an
engineering study for cost effectiveness when the EPA's
intention to do the IS, EIS was announced. Understandably,
the Selectmen held off with Doctor Schaefer.
Soon, the EPA selected another firm of Sanitary
Engineers to assess the work of the first such firm. The new
one was Anderson-Nichols who actually produced the Draft EIS
before us tonight. After the first workshop held last June,
their representatives met with me and two other members of
the Sunny Valley Preserve. They indicated that they would
look carefully at land treatment. We invited them to call
upon Doctor Schaefer and they agreed to do so. Now, today,
here comes their Draft EIS and the section on land treatment
is virtually a rewrite of Metcalf and Eddy's material. At
the most recent workshop on this Draft report, Anderson-
Nichols introduced a young Engineer responsible for the land
treatment assessment. How much time did he spend in New
Milford making the assessment? One day. What was his
experience and qualifications on land treatment? Rather
indefinite. Did he consult Doctor Schaefer? No. Why?
Because he had decided Doctor Schaefer represented a vested
interest.
Meanwhile, land treatment has not been
comprehensibly studied in New Milford by an experienced,
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qualified firm. It won't be if the Draft EIS is allowed to
stand and rule. It was Doctor Schaefer's belief that with a
qualified study, it might very well be seen that the
community could have a full, advanced or tertiary treatment
system through land treatment for a cost comparable to that
of the proposed secondary or partial treatment system that's
before us. This has a great deal of meaning for the Town,
taxpayers, local, State and Federal and to the environment.
I urge the EPA that the Draft EIS not be
completed until a truly valid land treatment study has been
addressed. To date, an experienced, qualified consultant
has not made a full and fair assessment of the cost
effectiveness of this alternative and this is neither in
keeping with the letter or spirit of the Federal Water
Pollution Control Act amendments of 1972. In the next couple
of weeks I intend to comment in detail on a number of the
statements in the Draft EIS. I will submit them in writing.
Thank you.
(Applause.)
MR. STICKNEY: Thank you, Mr. Stevens. Ms. Hague?
MS. HAGUE: Mr. Moderator, may I ask that Mr.
Standt speak in my place?
MR. STICKNEY: I see no reason why not if he
doesn't.
MR. STANDT: My name is Fred Standt. I've been a
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resident of the Town of Brookfield for twenty-six years. I
served on the Brookfield Planning Conmission from 1965 to
1975, much of the time as its Chairman and as such, I was
deeply involved in the early stages of the questions
examined in this Environmental Impact Statement.
After leaving the Planning Commission, I served on
the Brookfield Sewer Commission for a year and a half.
Currently, I'm an Associate Supervisor for the Fairfield
County Soil Conservation District and I'm a Department of
Environmental Protection appointee to the Executive Committee
of the Kingsmark Resource Conservation Development Project.
I've served as its Vice Chairman since its inception.
I attended both workshops that you gentlemen held
in Brookfield, the first which you ignored; the second which
we ignored. And now the media tells us, tonight, that this
is our last chance to speak out on your environmental impact
report but, wait, in tonight's paper, another message from
the media. I read the headline for the record: "Sewer
talks may be a formality". It appears that Mr. Huppner,
Chief of "Water Unit, Environmental Protection, has said
yesterday that there's little evidence that could be offered
at tonight's hearing that will change the State's orders to
sewer. I admire the man's honesty, I'm sure.
Further into the article, he was asked if he could
think of any evidence that might convince the State to change
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its sewer orders for New Milford and Brookfield. Huppner
replied, "I couldn't say. I can't think of anything offhand
but if I could, I wouldn't say." And I'm sure of that, too.
By God, the man is honest.
Mr. Huppner goes on to say that "Our mind is
already made up." And, it's true. It was made up a decade
ago and it was made up for us also. The last statement he
says, "We were never really in favor of an Environmental
Impact Statement on this question. That was the EPA's idea'.'
The Department of Environmental Protection not in favor of an
Environmental Impact Statement? I wonder why. Could it be
that an EIS done in 1976 might come into collision with
minds that were made up ten years ago? Well, Mr. Huppner had
nothing to fear. This EIS just reinforces all the previous
thinking and promotes the State's long-stated intention of
urbanizing the Still River Valley.
One thing your report does not state is that
Brookfield's original orders were issued about 1967 and were
based on a State Health Department report dated October,
1957, ten years prior to when the orders were issued and ten
of the eleven violations that were included in there, ten of
them were already resolved before the orders to sewer were
written. At present, there is not one single documented
violation in Brookfield and the report, your report doesn't
document one. Am I saying that we don't have any sewage
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problems in the Town of Brookfield? No. Anyone who owns a
septic system has a problem. It's one you learn to live with.
You learn to adjust to it, to provide for it. You learn to
live with it.
Am I saying that we don't need sewers in Brookfield?
No. I'm no more prepared to say that than those people that
stood here tonight saying we need them are prepared to say
that. Then, what am I saying here tonight? What I am saying
is that the conclusions in this Environmental Impact
Statement, to the degree that it agrees with the State's
intentions, is a manipulation and a perversion of the stated
purposes of the Clean Waters Act in that its primary intent
and eventual conclusion is not to resolve existing sewage
problems and to improve water quality in the service area,
its primary intent is to urbanize the entire undeveloped
Still River Valley.
(Applause.)
I would appreciate it, really, if you don't clap,
because it's going to make my talk seem twice as long as it
is and it really isn't. It's only one more page.
I charge that this perversion of the Clean Waters
Act was conceived in Hartford in an attempt by certain
Connecticut Officials, to obtain Federal funding for the
execution of their stated plans to urbanize the Still River
Valley and I further charge that persons and agencies within
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the State Government issued orders to sewer Brookfield and
probably other areas without substance or fact and without
adequate investigation and that local officials were coerced
and intimidated, myself included, into collusion with the
same Connecticut Officials to gain Federal funding based on
unsubstantiated needs. Again, the goal: to urbanize the
Still River Valley.
My criticism of the report is in its failure to
expose these perversions. I feel the report is inadequate in
that it fails to demonstrate a clear environmental improvement
resulting from this great expenditure of Federal,State and
local funds. I think the EIS fails in that it lacks true,
in-depth consideration for the fragile nature of this Still
River Valley. And, may I read a statement that comes from
the 1977 — February, 1977 Environment News which is, really,
the newsletter of the U.S. Environmental Protection Agency,
the fellow we're all supposed to be working for here. It's
an article that's about this long. I would like to read
just one paragraph. The article is headed "Sewage Costs to
Small Towns to be Discussed at EPA Conference" and the
third paragraph down states:
"The EPA wants towns which may receive EPA grants
to consider carefully a number of systems that could be
cheaper alternatives to building costly and complex
conventional treatment plants and sewer lines. Such systems
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include septic tanks with community maintenance programs and
other small treatment systems for houses or small clusters of
houses." And just the first statement of the next paragraph:
"The general use by communities of relatively large
centralized treatment plants instead of smaller, localized
units has, traditionally, been promoted." However, their
intention is to go the other way. That concept is not
reflected in your report, gentlemen. I suspect it was ten
years old the day you started. Thank you.
(Applause.)
MR. STICKNEY: Because the news item was brought up
several times and I know many of you have copies, I'd just
like to emphasize that anyone is welcome to state an opinion
on the Impact Statement and what we intend to do with it.
However, the Environmental Protection Agency is the only
group charged with determining whether or not it intends to
fund any proposal that's been put forward and it will remain
there, must rest with the EPA and must stay with the SPA and
we are the sole determiners as to the value of the
Environmental Impact Statement and of the comments that are
proposed.
Is Mr. LeFevre here? (No response.) Mr. LeFevre?
L-E--F-E-V--R-E. Doctor Mellett?
DOCTOR MELLETT: My name is Doctor James Mellett
and I'm a resident of New Fairfield. I'm a Geologist by
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profession. I have a few comments on the Draft Impact
Statement.
The Statement, as I see it, glossed over the
impact that a major sewage treatment plant might have on
ground water levels in the three-town area to be, quote
"served", unquote, by it. The Connecticut General Assembly
Plan of Conservation and Development clearly stated its
intent to use ground water rather than surface water for
municipal water supplies. On pages thirty-two to thirty-six
of the Impact Statement, the report refers to a study done by
the Housatonic Valey Council of Elected Officials concerning
ground water resources in the area. This was simply an
estimate of ground water demands compared to potential
surface and ground water supplies. That report concluded
actual ground water investigations need to be carried out to
accurately assess the development potential of this source of
water supplies.
In other words, we are really ignorant about the
quantity and quality of ground water levels. Yet, on page
195 of the report, we are re-assured that we have adequate
supplies. If we don't know, how can the authors of the
Impact Statement be so sure? It is stated on page 194 that
seventy per cent of septic tank effluent is lost to the
atmosphere by evapotranspiration. That statement is
inaccurate and misleading. I challenge it and I would like
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to see the data on which it was based. A seventy per cent
evapotranspiration deficit for water injected below the
ground is a figure that one might expect for Tucson, Arizona
or Saudi Arabia, but not the Kousatonic Valley.
From November to March, the ground in this area is
solidly frozen. Evapotranspiration is zero now and only
becomes a significant factor from June to September. Because
the ground is frozen now, all precipitation is subject to
runoff, and recharge from precipitation is now, also, zero.
Because they inject water into the ground below the frost line
septic tanks may be the only factor in ground water recharge
during the winter months in this area. The failure to
consider septic effluent in recharge is even more puzzling
because on page 296, the report states that irrigation of
treated effluent onto the ground surface is an alternative
method of further tertiary treatment and a method of
recharging ground water. Again, I ask, how, on the one hand,
can water applied to the surface be a means of recharging
ground water when it is argued that septic effluent is not.
This is an extremely important point and I suggest the
following might happen:
When a proposed plant is in full operation — and
the full operation, I'm assuming New Fairfield, Sherman and
God knows what else will be tied into it — ten million
gallons a day of effluent, primarily derived from ground
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water will be flowing into the Housatonic River. Because of
reduced recharge, ground water levels start falling and wells
in higher elevations begin to go dry. There will then be a
clamor for a regional, municipal water supply that would have
to come from surface sources such as Candlewood Lake, Ball
Pond or new reservoirs.
Once again, bond issues are raised, taxes go up and
streets are torn up all over again, but this time to lay
pipe for the northwest Connecticut regional aquiduct system.
(Applause.)
In summary, I argue that a major potential impact
of sewer plant construction will be on ground water reserves
in this area. This impact has not been addressed and before
any further action is taken on this plant, the complete
area-wide inventory of ground water resources must be
undertaken. The purpose of this impact report is to explore
and understand alternatives before we perform an irreversible
action. Unless a ground water investigation is carried out,
this impact proposal has failed to fulfill its primary
function. Thank you.
(Applause.)
MR. STICKNEY: Thank you, Doctor. Peter Pratt.
And after Peter Pratt, Mr. Lawrence Rose, please.
MR. PRATT: In contrast to some of the speakers
who felt that this statement was basically well done, I must
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disagree and I'd like to document my opinion with the
following comments.
On page 42, the statement notes that nitrates in
high concentrations are a cause of a blood condition known
as methemoglobinemia which causes cyanosis or blueness and
this is true. It does so, however, at concentrations
probably ten to twenty times the level of what currently
exists in ground water and only in infants under three months
of age. This problem is weakly related, actually, to ground
water nitrates. Furthermore, it is extremely rare and hasn't
been reported from ground water nitrates in a number of years.
But that isn't to say that ground water nitrate isn't
important because I strongly support the State levels of
ground water nitrate because nitrates are now, have recently
been shown to be the most significant cause of stomach cancer.
And the decline of stomach cancer over the past forty years
has been attributed to the advent of refrigeration and the
decreased use of nitrates as preservatives of meat. Also,
those primitive societies in South America that are now
going to agricultural type of living and putting large
amounts of fertilizer on their land and increasing the ground
water nitrate are also showing increased incidents of
stomach cancer. I think that's very important and I note
that the Statement uses, as its reference for this really
complex field, the Housatonic Valley Council of Elected
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Officials. I think that's a very superficial investigation
of a substantial problem;if they so so far as to mention it
or include it, they should go a little further in finding out
what it's really all about.
The Statement goes on and notes that ground water
nitrate levels are a problem throughout the northeast but
they state, and I quote, "Locally, however, an additional
source of nitrate has been identified." And that source was
shown to be the agricultural activities of Sunny Valley Farm.
Now, this statement infers that the agricultural activities
in other areas of the northeast are not significant sources
of ground water nitrate, which is incorrect. And also, it
singles out the Sunny Valley Farm from other farms which is
also totally misleading. In fact, if you take any farm
without manure storage and dig a well in one of the nearby
fields, used for storing manure during the winter, then you
will get high ground water nitrate.
I'd like to go on now to Appendices B and C which
describe, evaluate the Carrousel and land application
modalities respectively. In evaluating the Carrousel, there
appears to be limited information validating the predicted
performance and the cost and maintenance and they further
state that, quote, "It is probable, however, that to achieve
the required removal efficiency, the process must be
controlled within close limits as a slight upset will result
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in violation of the EPA secondary treatment standards."
Unquote. Now, I would like a moment of silence while we all
ponder Murphy's Law, if wrong something may goeth, so will it
for sure goeth; and it will in this case.
Unfortunately, they maintain that — unfortunately,
they fail to mention the possibility of the effluent of the
Carrousel containing live viruses such as a hepatitis virus.
They don't speak of toxic metals that may remain: in the
effluent. There's no mention of the persistent and
potentially carcinogenic hydrocarbons, while evaluation of
land application introduces a host of adverse factors whose
significance is poorly substantiated and, in contrast to the
Carrousel evaluation, the land application evaluation section
requires a complete chemical analysis of sewage. I
suggest that both require such an analysis.
The failure of Anderson-Nichols to consult or even
recognize the work by the well-known expert, Doctor Schaefer,
has been noted by Mr. Stevens whose comments I certainly
agree with.
The Statement does not bring up water conservation
as a substantial alternative and does not mention the use of
anaerobic digestion in land treatments, an example of which
is being constructed in Sterling, Colorado. They also fail
to note that in contrast to the Carrousel,land application
conserves water, conserves nitrogen for food production and,
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thus, reduces the need for costly petroleum-based chemical
fertilizer that add to the total nitrogen runoff into the
river. And, most important, they fail to note that in
contrast to the Carrousel, land application does not add
pollutants to the river which is the intention of the original
bill while the Carrousel, indeed, adds a tremendous amount.
I think that the Statement is severely biased, is
very superficial and I think that Anderson and Nichols have
not met the responsibility given them to give us an unbiased,
thorough statement that will allow us to really make a proper
choice.
(Applause.)
MR. STICKNEY: Mr. Lawrence Rose, please and after
Mr. Rose, Mr. Vincent Foley.
MR. ROSS: My name is Lawrence Rose. I'm a
resident of Candlewood Shores. I'm a member of the Board of
Directors of the Property Owners' Association. I'm also a
member of the Sewer Fact Finding Committee from that same
neighborhood. I cannot say that I come here before you with
the strength of a political office to reinforce whatever
opinions and statements I might make. I come here just as a
humble citizen who feels as though he is about to be
fleeced.
It is my gut feeling that the burden of proof for
sewers should rest with the proponents of sewering. And it
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is my feeling that this condition has not been satisfied. I
listened to statements made here tonight by people who
occupy a responsible position in the Town of Brookfield, that
by sewering, Candlewood Shores, we are going to preserve our
lake; that by sewering Candlewood Shores, we will further
industrial development. Now, I ask you to look at the facts
with reference to the particular situation governing
Candlewood Shores. The repeated testing of the water has
shown that the water condition of the waters off Candlewood
Shores, the quality is excellent. The basis, in fact, for
sewers is immediately destroyed right there as far as I'm
concerned.
We must remember that this is a community of about
four hundred and thirty-five homes. There are more than
five thousand homes that border on the confines of the lake.
To that, let us sewer this area, we are saving this lake,
this, gentlemen, is utter nonsense and gall, I might add.
(Applause.)
You think that — well, one of the people who
occupy a position on the Board in the Town of New Milford, he
made a statement that, you know, sometimes the left hand
doesn't know what the right hand is doing. You think things
are bad in New Milford, you should really know how they're
going in Brookfield. There, I attended a meeting of the
Sewer Commission on the 19th of January and a member of the
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Commission at that time, uttered the statement, in all candor,
he said, referring to the Planning Commission, the Planning
Commission hasn't done a damn thing here for fifteen years
and won't do another damn thing for the next fifteen years.
Let us take the bull by the horns. To me, I feel that by all
of this, I'm indeed being victimized. I try hard, sometimes,
to understand the basis, in fact, for reasons for those who
are proponents of sewering. I think, perhaps, I could shed
some light on this by making known to you at this time, at
least in part, the contents of an office memorandum under the
date of June 9th which refers to a meeting held in Brookfield
on the 27th of May, 1975 and I ask you to note that this
meeting was held long before any study was made and at this
meeting were present the principals of Candlewood Shores,
the two owners, Mr. William Tappan and Mr. Gaudier from the
Sewer Commission, together with Mr. Clifford Gold, Engineer,
Brookfield Sewer Commission. Now, I think there are some
revealing statements made here and I will just read in part
some of these statements.
It says, "There are easements along the property
lines for utility purposes and these will be made available
to the Commission at no cost. Easements along the private
roads will be turned over to the Commission but there may be
some cost involved where such easements front on developable
lots which they probably own, as an offset against assessment
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Pumping station sites will be sold to the Commission at the
market price for developable lots estimated at twenty thousand
dollars per lot." One of the principals for Candlewood Shores
he asked for drawings showing the pumping station locations,
building elevations and property requirements and so forth.
Ke also registered an objection that there would be a need,
he felt, for a resurfacing of the entire street width.
Another section states in this same memorandum that there are
approximately eighty undeveloped lots still owned by this
group of people. And it says, "Clearly, the developers
would like to offset future assessments for the purchase
price of real estate by the Commission". I just wonder
whether, in fact, that in some small way a memorandum like
this might shed some light on the interest of certain people
with reference to having this particular area sewered.
This is a private area and, I don't know, maybe
someone has something to gain by all of this but I want this
noted in the record. It states here that "This meeting
ended without real conclusions." I wonder who would pay for
all of this. Thank you.
(Applause.)
MR. STICKNEY: Thank you, Mr. Rose. Is Mr. Foley
here? And after Mr. Foley, a Ms. Mauger, M-A-U-G-E-R or
M-A-U-G-E-N.
MR. FOLEY: My name is Vincent Foley. I live in
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Candlewood Shores.
I couldn't agree with Doctor Kemmerer more, the
gentleman who made the remark from Newtown that the problem
is passed downstream. I have in my hand, minutes of a
Congressional record that was held on the question of sewering
In it, it continually makes reference to the problem being
passed downstream. It is the largest ongoing project in the
country today and there was a symposium that was held at the
expiration of this meeting and at that time, sane forty to
fifty alternatives to sewers were introduced. We have not
seen anything near that number as an alternative to the
problems that we have.
The final assessment in here, which is a very
classic remark, was made by Ralph Nader. "In the past fifteen
years, there has been some three and a half billion dollars
spent on sewering and to date, we do not have one clean
river or one clean lake to show for it."
(Applause.)
I think that's a rather shocking example and I
think that should be included in your record. I don't think
it's a very impressive record.
Today, I called Mr. Merlin Huppner and inquired
about this available money, this some hundred and thirty-eight
million dollars that has just appeared on the scene. Since
I live in a private area, I did want to know what effect it
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had to me in this lateral funding. I was told by his office
that, as far as private areas are concerned, the Town has to
own the road in order to be eligible. Now, this is something
that everyone living in private areas should question and
find out whether this money is so available or not.
It shocks me to think that over the years the
leadership that we've had in Brookfield has been unable to
direct and utilize its Building Inspector and its Sanitarians.
We find ourselves at an impasse right now for things that
should have been done over the years. This same condition
will only multiply in the event that we get sewers because
the same people will be running the show. Thank you.
(Applause.)
MR. STICKNEY: Mr. Foley, do you have a citation
on that Congressional record you wanted entered into the
record? Thank you.
MR. MAUGEE: My name is Miesse Mauger. I live at
Little Bear Hill. I don't come under that magic red marker
so everything I'm going to say tonight is actually based on
past experience.
Eight years ago, I lived in Ocean County, New
Jersey. They went through exactly what you're going through
right now, with all the meetings, all the workshops, all the
rhetoric and everything that was stated, didn't happen.
Everybody says the tax base will make it easier on us; in
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fact, there, ray taxes went, on a third acre with a nice
house, frail about two hundred dollars up to fourteen hundred
dollars a year. They tore my street up. They tore it up so
bad they had to redo the street in four years. They
assessed nie for that. The Police Department could not keep
up with the expanding growth of the community at all.
Crime accelerated so fast that they had a national write-up
in Newsweek magazine, how they surpassed L.A. County in the
rise in their crime rate. This all happened after the
sewers were put in.
In 1970, the year after we moved out — we couldn't
take it any longer — schools went on a half-day. They're
still on a half-day. They cannot catch up in building
schools, to catch up with the growth of the people that are
moving into that county. And that growth is predicated
directly to the sewers because they could not build on those
lots until they got sewers and they could get their eighth
acre and quarter acre and third acre zoning. If you think
Zoning Commissions and Planning Commissions are going to keep
that type of building out, you're sadly mistaken. One stroke
of the pen and it's all gone. And, with the latest Court
rulings that are out now, they're not even Constitutional.
You cannot say, I'm going to keep a two-acre zoning and so
forth because, then, that's discrimination. And, in a way,
it is.
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I don't have much more to say except that what
we're really talking about tonight is our lifestyles in New
Milford and Brookfield and if you like your lifestyle now,
you better atop this because it will change and it will
change for the worse. Thank you very much.
(Applause.)
MR. STICOEY: Is Mr. Crawford here? Mr. John E.
Crawford. And, after that, Mr. Benedict.
MB. CRAWFORD: I want to thank you gentlemen of
the EPA for giving us this opportunity to vent our fears and
anxieties about this sewer system. There is much to be
desired in the information that you didn't print in this
thing. It has a lot of facts and figures that Metcalf and
Eddy didn't have originally, but it also has just more or
less made a case for the facts and figures that they presented
I would like to dwell tonight mostly on this Order
31 issued by Mr. Robert Taylor's Department. It was signed
by a Mr. Medona. I think that Mr. Taylor has left now. Is
he still here? Oh, hi. In the tirae period between March
and June of 1967, something as yet undocumented, changed the
thinking of the public officials involved to change the
recommended sewer expansion for the Town of New Milford from
one point fifty-five million gallons a day or four and one
half times its present treatment plant's minimum flow, to
thirteen point nine million gallons a day or forty times its
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present flow rate just to meet all the demands contained in
DEP Order Number 81. Now, how, you might ask, do I arrive at
these figures?
Well, let's take, on the face of it, what the
purpose and intent of Number 31, as it was issued, which was
really what started the wheels in motion on this entire
project. It states in that Order, requires New Milford to
construct additions to its present system to serve future
flow. Sewer entire town. Provide capacity for outside areas.
And provide for present or future industrial needs. All
right. The only documentation I found in this entire three
hundred and twenty-five page volume of any pollution in New
Milford ever existed, is listed on page forty-five which is
the six industrial plants, then, at that time, existing in
the Town of New Milford. One was Nestle's which has a total
volume pollution of one million seventy-four thousand gallons.
The second was Scovill which is now Century Brass, was two
million eight hundred and seventy-nine thousand gallons.
Winchester Electronics had a hundred and twenty-nine thousand
gallons. Diventco, Incorporated, sixty thousand gallons;
Kimberly-Clark, twenty-five hundred and fifty thousand
gallons; Burndy Corporation, forty-four thousand gallons. If
you total these plants together, this is six million seven
hundred and fifty-four thousand gallons a day.
Now, the New Milford sewer plant, here they were
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taking a minimum flow which would be the midnight to morning
flow, which was three hundred and fifty thousand gallons.
Evidently, this was polluting the river also which I know it
is but which hasn't been stated at any point in here that I
can find.
Next, we take the Town of Brookfield. Everybody
has been discussing one point three million, demand for the
Town of Brookfield. I call this number eight on here and I
call it five million one hundred thousand gallons a day
demand for the simple reason that in the intermunicipal
agreement between the Town of New Milford and the Town of
Brookfield, on section three, page two, it states, and I
quote, "Several of the interceptors shall be of adequate
capability to afford conveyance of a peak, instantaneous flow
rate of five point ten million gallons a day originating
within the Town of Brookfield." So, this means, just simply,
from everyone I've asked that would know anything about this,
that this pipe is being designed big enough to carry five
point ten million gallons a day. So, Brookfield can grow
about three times as big as they are now and New Milford can
foot the bill and take care of them.
Now, it says, "Future flows." One more industry or
combination of industries the size of Nestle's, you could
figure at one million one hundred thousand gallons a day.
Then, because you'd be building this gigantic plant, you could
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also figure, according to figures in this Statement as
backup, three thousand new housing units created by induced
growth through sewer expansion at one hundred and fifty
thousand gallons per day per family which would give you —
one hundred fifty gallons per day per family to give you
four hundred and fifty thousand additional gallons of
effluent.
Now, you have to also add, as number eleven on
here, the New Milford sewer plant peak load which would be
plus two hundred thousand gallons. So, if you take the total;
— take one through eight first, it would give you twelve
million two hundred and four thousand gallons and if you
take the totals of the future flows and induced growth, nine
through eleven which would be one million seven hundred fifty
thousand gallons a day, which would give us a grand total of
thirteen million nine hundred and fifty-four thousand
gallons a day without adding anything except the anticipated
future flow on a normal growth rate induced by this sewer.
I tremble to think of the financial impact this would have on
the average taxpayer in this town. And, of course, I hope it
never ernes downstream.
Now, these are facts that you've never seen
printed in any paper in the area. You've never seen any part
of it in this EIS but it's a very simple exercise in
arithmetic to figure this out. What the intent of the
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Connecticut DEP was in the first place was, naturally, to
include all of these systems in there since they all are in a
very close proximity of each other, the sewer plant and at
least five of these industrial polluters are all within
striking distance of either the old plant or the new
proposed location.
Now, I'd like to come to some of my conclusions on
this project. Based on all back-up information to date,
although there has never been a clear plan presented for
Stage I, II or III of this proposed sewer expansion, but many
of this EIS report relating to construction and engineering
costs. I would evaluate this information as highly suspect.
It is impossible to challenge a group of figures on unit
costs if you do not know the unit sizes, numbers or the
exact location. Ana, also, I think that any SIS dealing with
a project this big should also give us some of the dangers
that we can get into. In fact, I think this is a part of
professional ethics in the engineering field, and I think
the biggest one we have to look into here is organised crime.
I'm certainly going to bring this out tonight. Organized
crime is rapidly expanding their hold and influence on all
construction projects and public works where State and
Federal funds are used for financing. Their standard M.O.D.
is to form several dummy corporations a.nd take over a
well-known engineering or architectural firm doing lots of
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business with Government agencies. These front organizations
usually consist of (1) a heavy equipment contractor; (2) a
concrete and masonry contractor; (3) a plumbing and electric
contractor; (4) an equipment leasing contractor and a
material supply contractor.
Since the mob already has strong control within
the labor organizations, all that is necessary to get the
money rolling in is to bribe or blackmail some strategically
located public officials. I would like to note one thing
here, that you've heard of all kinds of scandals in New York
City and Chicago and San Francisco and everything but
Connecticut has had some real beauts in the last few years.
We've had some of the most fantastic ripoffs in the United
States and just now they're starting to come to the press.
One was a medical-dental building in Farmington, Connecticut
where Dave Offer, a Reporter for the Hartford Courant did a
forty-series article completely documenting every kind of
graft and corruption that was possible on that job and not
one State Official took any action v^hatsoever to prosecute
these people. This is one of the main reasons I bring this
up, because it's obvious that the magnitude, both in size and
cost, has direct relation to the size and profits that can be
made and the speed at which they can be easily extracted.
Connecticut has many projects which were created
solely for the enrichment of some special interests at the net
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loss of any profit, any potential use for the taxpayers who
foot the bills. The thrust of these objectives is to create
conditions favorable to the project and Federal propaganda in
rapid succession that will con the public into believing that
there is a need for these huge expenditures. And the
necessity to expedite them immediately so as not to be
victimized by a big inflationary price rise next year. How
many times have you heard those?
With forty times our present plant's minimum
capacity set up to process the effluent, only to the primary
level, we would not be fulfilling the provisions of the
Public Act 92500 which would mean that no sooner would this
construction be completed than we would be forced to proceed
with construction of a second and third stage treatment
facilities. These boys thing big, really big. This is why I
made past reference to this project as the great southwestern
Connecticut sewage disposal system. God help us all if this
planned system should ever come downstream.
I sincerely hope that you gentlemen from the
Federal EPA will weigh the facts and figures just given you
before you decide to fund any part of a project like this.
I'd like to make one statement of opinion here, too, that
several speakers here tonight have touched on and I think
it's a most important thing as far as conserving our natural
resources and for water quality of the river. It is my
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opinion that, after analyzing all of the information over the
years and considering all future alternatives, it would be
far less expensive to meet all environmental demands if the
people who administrate the mandates of the Connecticut DEP
had the grace and the guts to issue immediate direct orders
to the six documented industrial polluters and the New
Milford Sewer Commission to remove all effluent discharge
pipes from the Housatonic River and change the respective
methods of discharging wastewater, to go through a land or a
soil filter system. When this is accomplished, Public Act
92500 will be complied with in full. Thank you.
(Applause. )
MR. STICKNEY: Thank you, Mr. Crawford. I must
observe that if anybody in organized crime thinks it's easy
to get money from EPA, you ought to try it. It's just as
hard to get money as it is to get a project approved. And we
will, definitely, need to clarify those flows, simply that
the average flow of sewage occurs or the main flow of
sewage occurs during a few short hours of the day, and they
don't occur all day long and, evidently, that has to be
further developed. Mr. Benedict. And after Mr. Benedict, I
think we'll probably need to change our tape. We're moving
on. We don't have many speakers left and I beg your
indulgence and I hope we can finish.
MR. BENEDICT: Gentlemen, I was asked to prepare a
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special paper on my objections to the Carrousel process. I
don't think it's very necessary for me to make comment on
some of the things I had intended to say because, in the
beginning, as forewards, because I believe that the manner in
which the State represented itself here tonight, obviates
that.
I will state that the EIS correctly identified the
land use plan of the State, the land use and conservation as
regards New Fairfield and it has been the arbitrary departure
from its own plan in which water compliance played so big a
part in drawing it up, that's resulted, at least as far as
I'm concerned, in eleven thousand or so hours of activity
concerning this sewer project. For two and a half years, I
have raised questions in numerous writings and Exhibits sent
to EPA to the effect that the Carrousel process, never before
used in America, has no place here. I feel that the EIS,
itself, regardless of its statement that it becomes an
engineer's choice more than confirms our position. It does
this, especially, in eleven pages of special comment and, by
our ability to refute other points about this plant that come
up in other portions of the thres hundred and twenty-five
pages.
First, it is not most cost effective. Using
Metcalf and Eddy's figures, the EIS finds it costs fifty-six
thousand dollars more. On the one hand, the EIS says that
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the project costs and cost effectiveness are variable. Yet,
it settles down on a precise figure of higher cost and uses
Metcalf and Eddy figures to do it. How do we know, since
cost effectiveness is said to be so stretchy a term, that the
difference is not a hundred and fifty-six thousand or four
hundred and fifty-six thousand more? Yet, in a May 20tia,
1974 letter to Metcalf and Eddy, EPA wrote, quote, "The
patent fee associated with the use of the Carrousel activated
sludge process is an allowable project cost provided it can
be demonstrated that the overall project offers the most
cost effective solution, conforms to applicable National
Environmental Policy Act requirements and is in compliance
with other requirements of the regulations." EPA underlined
"provided". Obviously, if it costs more, a patented process
is not most cost effective.
Obviously — and I don't refer only to the
Carrousel, but to anything. National policy cannot tolerate
that consultants anywhere can make a pet of a patented
process and make choice of process an arbitrary thing that
keeps the public from benefit of wide open bidding. Unless a
patented item is so decisively better, such as a self-starter
in a car, as compared to hand cranking, t'here is no place
for this sort of thing. Even more important, how does the
Carrousel arrive at the exalted position whereby using
Metcalf and Eddy figures, it only costs a little more? The
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EIS makes the important point that it omits primary settling
tanks. Later on, I'll refer to a DEP letter to Metcalf and
Eddy that will show that recommended engineering services are
also omitted in this effort to make the Carrousel come
somewhere near tried and true, fully equipped standard
American plants.
Up-to-date sewage plants of high quality provide
primary settling tanks. Before processing, sewage goes to
the tanks; heavy particles settle; grease and fats rise, they
can be removed before processing. I think this reduces wear
and tear on the plant. I think it reduces the cost of
chemicals needed in processing, especially, in a secondary
plant, I think it reduces the amount of nutrients, the algae
producers, that finally reach the river to further endow
Lakes Lillinonah and Zoar.
June 4th, 1974, Senior Sanitarian, now Principal
Sanitarian, Robert Smith of DEP, wrote to Mr. Jacobs of
Metcalf and Eddy about several aspects of the Carrousel. I
quote one paragraph: "In Mr. Van Hyper's memo of November S,
1973, it was indicated that Mr. Zeper of Dwars, Hedrick and
Verhey, feels that their agreement with Envirobics will not
provide the amount of engineering backup necessary for the
first several American Carrousel projects. Mr. Zeper
suggested that a separate agreement for the engagement of
Dwars, Hedrick and Verhey's services by Metcalf and Eddy
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would be desirable. However, the economic comparison seems
to leave no room for such additional cost. Please comment on
Metcalf and Eddy's position in this matter."
I think the meaning is clear. It would seem to me
that not only are primary settling tanks omitted, but also
what may be even more important, recommended engineering
services for a first in America plant in western Connecticut's!
first and foremost and most cherished system of waterways.
That seems to me a cute way to reach the position whereby
giving themselves all the generosity of their own calculations!
they are only a little more expensive. Well, that royalty
fee alone, seven cents a gallon, on a four million gallon per
day plant is two hundred and eighty thousand dollars. You
take it from there on up to six or ten million.
Equipment to treat phosphates costs less than the
royalty fee on Stage I. Primary tanks appear to cost not
much more. Is all this most cost effective? Would you, as
homeowners, put dishes into the dishwasher without first
scraping the fat and bones into the garbage can or buy a
dishwasher when you were told in advance it is a type never
before used in America and the engineering backup is
inadequate? I poured through the document, a new loop in
aeration tank design, a brochure prepared by Mr. Jacobs and,
through the pamphlet by Metcalf and Eddy, given to the public
hearing for the environmental assessment held June 19, 1975
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in New Milford. The main claim for cost effectiveness
appears to have been a table asserting lower electric
consumption by the Carrousel. I note that although Anderson-
Nichols uses, necessarily, Metcalf and Eddy figures when they
print the table of electric costs, Anderson-Nichols discards
any differences and prints the same table of estimated costs
for Carrousel or standard. Who can blame them? Does anybody
knov? anything off base more often than projections of
savings on power costs, even when asserted by CLP? I once
sat down, projected the Metcalf and Eddy electric savings.
The way I figure, I found this: Even accepting them, their
figures and comparing them with the initial cost of the
Carrousel royalty which is, of course, a capital cost, that
it would take twenty to twenty-six years to break even.
I became worried at something I read on page
twelve of Mr. Jacobs' new loop paper and wrote to EPA long;
long ago. He says the Carrousel operates at a speed
uncommon in America by use of a variable aerator or impella,
the key moving part. He also, in a footnote, mentioned it
is, quote, "manufactured by Hanson-Patton and Philadelphia
Gear." I asked EPA whether, in view of the uncommon speed
and the seemingly limited source of supply, parts would be
readily available in case of emergency. I cited my visions
of ecological and environmental disaster if they were not.
Now, I do not know whether Hanson-Patton and Philadelphia
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Gear represent two separate suppliers or whether they work
together and are a single source of supply. I do know this,
that neither is a major company because financial data is
unavailable in Standard and Poor's. I do know this, and
have brought the legal evidence with rae, in a merger of two
totally unrelated companies as to this project, a prospectus
filed December 15 under litigations, Philadelphia Gear is a
Defendant in several important lawsuits. The suits allege
failure to deliver on time, poor workmanship, poor design and
poor material. The products involved had to do with cargo
ships.
Additional concern arises on my part from what
Anderson-Nichols has to say that I think pertains directly to
this situation from a different aspect. They raise questions
whether, since they could get absolutely no response to their
inquiries about the Carrousel which they conscientiously
made to foreign users, that phosphate treatment could be
provided within the lagoons because of the slower momentum of
the process. They had doubts, This, of course, relates to
the uncommon in America speed, the aerator, impeller, et
cetera. Anderson-Nichols makes another important point.
They say that their study shows that unless the Carrousel
operates very precisely, it could produce effluents that
depart from EPA standards. Though from long ago, when I was
a World War II setup man on precision automatic machine
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projects destined for bazookas and anti-aircraft shells, I
still get the shivers at what used to happen when machines
would run on edge. Does anyone think a municipal sewer plant
is going to be able to turn ferris-wheel sized impellers with
such precision? Why would not temperature change alone, from
summer to winter, put varying strains on the limited supply
parts I mentioned?
I think Anderson-Nichols is overly generous in
promising odorless performance to the proposed plant or at
least odorless to the extent that would do credit to a
deodorized petunia. Here we have lagoons that are bigger and
deeper. They retain the sewage in the lagoons several times
longer than do standard plants that operate in smaller,
shallower lagoons and do not penetrate so deeply into the
flood plains, the wetlands, the general aquifer of the
Housatonic. Almost by definition, there's water smell,
especially in the absence of the primary tanks. I think EPA
has a special responsibility nationally to investigate the
validity of the patent itself.
For as long back as two years, I sent up material
on this very question. It is admitted that the patent
applies to the shape of ditches and the fact that baffles are
within them that act to direct the flow. Can you really
patent the shape of a ditch and have the patent survive
tests? A patent, to stand up, has to be absolutely unique.
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Yet, the Carrousel is said to be merely a variation of the
paasveer method, a far more complicated process based on shape
The basic oxygen furnace process in the steel industry was
rejected by the United States Supreme Court in the famous
McLouth Steel Company case which defeated Austrian claims.
The Philadelphia U.S. Circuit Court, likewise, rejected a
renewed effort by the Keyser Steel Company, holders of the
Austrian patent rights against LTB. I think these cases are
a direct precedent. I cannot understand how, especially
since the Carrousel contract has now, according to the press,
contracted for many new places with New Milford possibly
being the precedent, that EPA can fail to test this patent.
Millions of dollars are at stake. More than that, critical
ecological and environmental ones are also at stake besides.
The reprints of the LPV press items from the Wall
Street Journal are at EPA for years. The loop pamphlet
outlines eight different ditch shapes. Some seem quite
familiar, something like an Egyptian ancient scarab, something;
like the emblem of Continental Can, something like the
broiler element in anybody's electric oven, lots of things
that resemble the mazes, not only of formal English or Long
Island gardens, but the labyrinth by which Ariadne and
Theseus escaped the wicked Cretan Minotaur. Will a patent on
the shape of a ditch withstand test?
I have to note the appearance of what I consider
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pressure methods to bring about the first in America
Carrousel contract. Those with a memory of press articles of
1374 will remember the great urgency that was placed on
rapid signing of a contract. You will remember what I
nicknamed the pot and pan meeting of the Sewer Commission
when a Mr. Gussman representing Snvirobics, the licensee,
brought to the meeting by the consultant, engaged in dispute
with Mr. Corey as to how many times a month Envirobics could
bring prospects to see the Carrousel in action. You will
remember that Town Counsel Moots engaged a Mr. Frederick of a
prestigious firm of patent Attorneys to inquire into patent
validity. You will remember Mr. Frederick advised further
inquiry after preliminary study. You will remember that the
Sewer Commission decided against that follow-up. Some member;
have told me they did that because of the high cost but they
still recommended that SPA make the follow-up.
I think they were in error not to follow-up because
the other factors of cost effectiveness and environmental
nature make that legal cost insignificant. Personally, I
think it was lacking in taste for the Vice Chairman of that
Commission to vote as he did, while at the same time being
engaged by Metcalf and Eddy as Surveyor for the project. I
have to make special note of one factor concerning dates.
April 29, 1974, EPA sent Commissioner Douglas Costle of DEP
a letter warning of the great likelihood of this EIS. As
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those of you who read the New Milford Times know so well,
from its various articles and editorials, that letter was not
formally presented to either the consultants or the
Commission by DEP though it was certainly in the May, 1974
press in articles a yard long.
You know, they say that had they got the letter and
it's date-stamped May 8th, 1974 by DEP, that all work would
have ceased. Could that mean that since the Carrousel
contract was not signed by the Town until December 15th, 1974
that there might be no Carrousel contract at all had that
letter been distributed as intended by EPA? I feel the
public was not treated fairly at the public hearing of June
19, 1975. Why were we not told that the contract is
cancellable at will by the New Milford Sewer Autnorities up
to the point that the project goes out to bid. Why were we
not given the data, we, the public, regardless of what they
may have known in the Commission, on which to comment on Mr.
Van Hyper*s trip to the Netherlands, of November, 1973, in
which he reports that the head of the Dutch equivalent of EPA
and Doctor Paasveer who originated the process of which the
Carrousel is a variation, had very strong reservations about
it. • Why does this 1973 key material surface only in
September, 1975 in a Metcalf and Eddy rebuttal to arguments
made at the public hearing three months before?
It was certainly thoroughly available for such
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presentation and comment as we can see from Smith's letter
fifteen months earlier from which I quoted. Incidentally,
there is no written answer to that Smith letter. Mr. Robert
Taylor told me that answers by Metcalf, over the phone,
satisfied him. He's Smith's boss.
I'm going to conclude by relating, factually,
without comment on ray part, three sets of facts. Envirobics
was incorporated October 29th, 1971 in New York State under
the name Aerobics, later changed. That was six or seven
weeks after the firm of Strobel and Hongved, Engineers
representing the original patented Paasveer process had sent
a letter and brochure to the Sewer Commission which was
forwarded to Hartford. The Passveer process, itself, was
opposed by the consultants.
Two, Dun and Bradstreet listed, in reports of the
earliest period on Envirobics, among others, two persons as
principals of the firm. Each appears to be identical with
the same names in financial records of high executives of
Grolier which has had a plant in Danbury and the first
telephone listing of Envirobics had the same address as
Grolier in Manhattan.
Three, the EIS states that as of June, 1976, the
firm of Envirotech acquired the Carrousel rights from
Envirobics. Envirotech is a major manufacturer of wastewater
and other pollution equipment. It was formed as a private
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venture called W.P. Associates within the brokerage firm of
Donaldson, Lufkin and Jenrette in 1969. It made its first
public stock offering September 16, 1971. September 25tn,
1971, Governor Meskill named Mr. Lufkin to be Connecticut's
first Commissioner of Environmental Protection. The brokerag
firm owned stock in Envlrotech before, during and after the
Commissionership and after he returned to the firm. Whether
that firm still owns stock is unknown to me. Two Directors
of Envirotech were officials of the brokerage firm. A
chronology of events has been presented to EPA along with a
copy of this paper some twenty pages of exhibit and text and
chronology. I think EPA has a bound duty to assess fully all
aspects of the patent situation. I think it should enlist
the aid of the Government Accounting Office to help in their
areas of special expertise.
(Applause.)
MR. STICKNEY: Thank you, Mr. Benedict. We need a
five minute recess here.
(Whereupon, a short recess was taken.)
MR. STICKNEY: The floor is all yours.
MR. MEINHARDT: Thank you, Mr. Stickney. The hour
is late and I'm at a disadvantage, first in, apparently, last
out. But, my remarks were originally set forth to open the
meeting and here we are closing it. But, let's see what we
can come up with. I should like to express my appreciation
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for the opportunity that is given to us tonight and it v/as an
opportunity that had to fight the opposition of our DEP and
our consultants.
Just a brief comment on this article that appeared
in the newspaper the other day. I was not surprised by it
because we know that this is the position of the DEP. In
this very room in 1975, Mr. Taylor made almost the same
remark. He said, quote, "It doesn't make any difference
what you people want, you're going to get it anyway." So
that the attitude is not new. It's not novel. It's just a
repetition of what we have had in the past. Now, tonight,
many of the things that — and, in preparing a response to
this Draft, you think that you suddenly come up with some
great ideas but as I listened tonight, many of them were
held by many other people. So, there's nothing really quite
so unique. And that, I think, itself, says something. We
are, basically, just average ordinary folk. We have many
different persuasions. We have different professions. We
are not professionals in this particular sense.
But, we've been forced to do an awful lot of
homework and I'm very proud of these communities for having
finally gotten off their pollution and getting it out in the
fresh air. And I think this particular kind of a thing
demonstrates the essential validity of the law of permitting
public expression. As ordinary folk who live in a town
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that's being requested to get involved in a tailor-made
program which could very well destroy this community, we
look at this a little different than the professional.
The Engineer comes in, he makes his assessments;
he does his work and he leaves. We in the community are left
with the results of that work. We have to pay the cost. We
have to live with it and if it's wrong, we have to suffer
with it and, within the memory of the few people who are left
in the audience, not too many years ago, we were burned by
an incinerator. And now we're, apparently, going to be
taken for a merry-go-round on a Carrousel.
The community is only favored, however, and it's
fortunate when the bureaucracy responds to its needs, its
capacities and its ability to pay the costs. And it's this
process tonight which we hope the local community has an
opportunity to express its opinions and try, constructively,
to effectuate a marriage between orders and programs on the
one hand and the desire and needs of the local community on
the other hand. And, I stand here and I didn't really know
if, truly, I was speaking for a community because we are a
diverse group and two of us, Mr. Seinfeld and :nyself,
decided we'd take a quick test over a short weekend. And v/e
prepared a petition and with help of a lot of people, in a
short weekend, the petition which we will submit in due
course, presently has over one thousand fifty names. And
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these are not just names, they are heads of families; they ar
widows; they are senior citizens; they are all residents of
the Town of Milford and they are all over the age of eighteen
years.
The petition says this: "We the undersigned
residents of the Town of New Milford, State of Connecticut,
do petition the United States Environmental Protection Agency
and state, one, the proposed eight-fold extension of
wastewater treatment and collection system is excessive to
our needs and ability to pay which will be destructive to
our natural growth; two, mindful that our existing plant
requires modernization, we urge reconsideration of
a program to extend capacity to a maximum amount, not to
exceed two million gallons per day." And I think this
demonstration is loud and clear when, in a short weekend,
just a few people can get that kind of response and it's the
response not just of a thousand fifty people but these are
heads of families. These are people who live and work in
this community. I think it should make an impact.
I think that, even though it's a late hour, a
brief recount, in general terms, of the program. In 1967,
our Town Sewer Consultants reported that our present plant
should be retained, might even get paid for, and expanded to
treat a total of one point five five million gallons per day
as the maximum foreseeable needs. If this best engineering
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advice had been accepted, for the past eight years, we would
have had our efficient, modernized plant at costs that would
be considerably less than today and the alleged pollution
would not have been continuing on for eight years. I say
eight years because it is only, basically, since the Metcalf
and Eddy assessment report was thrust out to the public, when
I think the public became truly aware of what was happening.
And it was that report that galvanized many people to cane
forth and see what was going on. There are others who had
been working right from the very beginning. I confess I'm a
latecomer.
Suddenly, after this report goes in and without any
attempt to justify, without any information, backup informati
we suddenly receive an order for a regional program and this
was issued fifteen days within the enactment of the Clean
Water Act of May 1, 1967. And, I understand the Department,
the DEP, issued in rapid-fire order, some hundred seventeen
orders. They were ready. Our consultants, in response to
direct questions, have maintained that they have never seen
any data to support this action and that an examination of
the f.iles of the DEP, similarly, shows no justifiable or
backup data, just conclusions.
From that time on, from the time of the issuance
of the order — and I would say this would, perhaps, be
appropriate under the law as it is now written — in effect,
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what vi .e our consultants, really became the employees of the
State, of the DEP. And, if you read the Act, it says clearly
that consultants and engineers become responsible to the
State. And the issuance and the various programs that were
then set forth, in effect, are in response to the State
mandate and State requirements for, after all, they say they
are paying the bill and we, in the Town, are merely conduits
for that payment.
Now, a serious question, I think, comes up which
has not been touched upon and it only becomes serious because
we have to, some way, try to explain why, why a bureaucracy
tries to impose its fiat and its order on a community that,
apparently, doesn't really want what they're saying. And,
when you read the Clean Water Act of 1967, you run into a
bunch of vague terms and even the word that's been bandied
about, the word "pollution", 'potential pollution", is not
really defined. I copied the definition out of the Act this
afternoon. There are no standards set. There, really, is no
requirement for objective standards in this Act. And,
certainly, the word "potential pollution" — potential
pollution can mean anything that you want. They do qualify
it only by the word "reasonable", not probable. We, as a
community, really cannot determine whether we are really
polluters under this Act or not and, perhaps it was so
designed so that we will not be able to make this
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determination. The objective was to give the order and it's
a very strong Act and if we add to the Act, the administration
of that Act since 1967, we find a rather strong dictatorial
approach so that Administrators can come into a community and
have the guts to say it doesn't make a bit of difference what
you want, you're going to do as we say. And that was said to
us a couple of years ago. It was said to us the other day.
We hope, Mr. Stickney, and we anticipate, Mr. Stickney, that
what you said we'll follow.
Now, without the need for justification, we see
the issuance of orders, counter orders, counter counter orders;
so that even the technical consultants at our last workshop,
frankly, said that they were confused just as to the precise
place that we now stand. Welcome. We welcome you. For nine
years, this community was imposed upon and manipulated. The
machinations to avoid tonight are well-known and there are
those who have the temerity to say and argue that it's only
effect will be tc increase the costs. The past nine years of
delay indicate the essential weakness of the program and the
difficulty in tailoring the story to fit the order.
Pollution was a real threat. If pollution was a
real threat, ten years ago, how come., how corae they let it go
so long and we're in this position?
I would like to say something else here and it has
to do with a direct question that was asked and it was asked
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of Mr. Taylor. In 1975, in this very room, in response to
this direct question, Mr. Taylor replied that the order to
the Town of New Milford has nothing to do with the pollution
of Lake Candlewood because we have been told, in the Metcalf
and Eddy report, that there was a danger that this was
happening, that our lake could be lost. And I became
confused and I asked this straightforward question: Has this
order to do with Lake Candlewood? The answer was, no.
Nevertheless we hear constant reference to the preservation
of our lake, our resource, our swimming, maybe even used for
water. And I would suggest that in making the judgement that
EH'A is called upon to make, that we take Mr. Taylor at his
word and do not consider that Lake Candlewood is a part of
this program.
The arguments are made concerning Candlewood Lake
since the tradeoff of sewering Brookfield Village with the
Ironworks and Brookfield Center for Candlewood Shores. To
get Candlewood Shores in, in November, 1973, orders were
issued for New Fairfield so as, primarily, to qualify for
Federal funding. As a result of public opposition and the
resulting political pressure, this order was ultimately
revoked. These are not my words. These are Mr. Taylor's
words. This is a quote. Nothing said about pollution and
nothing said about the propriety of revoking that order, but
political pressure.
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I now, also, quote from a report of September 10th,
1975 by Mr. Taylor, Director of the Water Compliance and
Hazardous Substances. Quote, "Subsequent to revocation of
the order to New Fairfield, the Department has confirmed to
the Town of Brookfield that it would continue to support
grants for the construction of a Candlewood interceptor on
the condition that capacity be provided in reserve for the
future needs of the Town of New Fairfield." And I believe
that Mr. Taylor re-affirmed that tonight, in essence.
But, in other words, what we are saying here, that despite
the revocation of the order to the Town of New Milford,
despite the recommendation in the draft, this particular
draft, we are still going to keep and built into the design
flow capacity in the proposed sewer, according to 1973
figures, is an added cost factor of sane four hundred and
seventy thousand dollars which, to my knowledge has never
been and might never be changed, unless the EPA gives us this
relief.
We are carrying these added costs because
potentially, down the line, somewhere, maybe, without the
proof of pollution, they may call in New Fairfield.
In the same timeframe, a brief mention of the
handling by the State DEP of a letter dated April 29th, 1975,
from Mr. John McLennan of the EPA, to Mr. Douglas Costle,
where it is unequivocally stated that, quote, "It now appears
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an environmental impact statement will be required.!f You've
heard other people comment on that tonight and data will be
submitted concerning it. But, I suggest that the withholding
of this information to the Town of New Milford is damn close
to fraud.
We have not yet assessed the damage that this
caused and we have not yet had an accounting of it. We will,
though.
Nothing appears in the files of the DEP that
indicates that a response was ever made to the EPA. While no
official notice of this letter was ever given to the Town of
New Milford or to its consultants, we do know that our
consultants were aware of it. They commented upon it in the
newspaper.
Now, I'd just like to say something and,
unfortunately, they're not here, but to the Chambers of
Commerce, the self-serving declarations that they made
tonight where some of our officials felt that that was the
source of information to which they should go rather than to
the official officers of the Town, I would just like to
suggest this and I will make this part of my submission.
Recently, Joe Hurley of the Danbury News Times has written a
series of articles on the Town of Bethel and what impact
growth has had on its residents.. And it says it very well
and expresses the concern, I think, that we have, even with
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natural growth and not the induced growth that is admitted
we will have.
In Bethel, which is a town not too far from us, a
population growth of two thousand seven hundred forty-five
people now costs an additional four million dollars a year in
their budget. An additional four million dollars a year iu
their budget. I will submit tnese figures under a separate
cover but, now, according to the Draft EIS on page — the
four million gallons per day sewer program will generate,
conservatively, an additional sixty-five hundred people or
some forty-three per cent of the project growth of our
community, not just twenty per cent of the total population,
but some forty-three per cent of the growth.
Now, based on our sister town's experience, we
might anticipate a potential of two and a half times their
cost or possibly a ten million dollar increase in our budget
for this induced growth. On page two eighteen, the EIS
states clearly that growth is at a tax base deficit which may
not be balanced by its own economic growth. To put this
community in this precarious position becomes even more
shameful when we are being asked to extend beyond our
demonstrated needs with an unproved and deficient system as
Mr. Benedict, I think, so ably advised us. By the way, it's
the same Carrousel which our DEP has approved, the Metcalf
and Eddy report in forwarding it to the EPA.
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Now, as many experts as there are in this field —
I have done a lot of reading — we find so many confusing
expressions and there is a good, respectable body of opinion
that maintains that proper septic systems are the best
feasible and desirable means of disposing of septic waste.
Instead, though, what we are doing is to gather up four
million gallons a day of these wastes, concentrate them and
then dump the effluent into the river. And, it's interesting
to note that most of these wastes would probably never reach
the river were they left disbursed in septic systems to
recharge the water tables.
It is further submitted that under the vague, broad
and questionable definitions of pollution and potential
pollution under the so-called Clean Water Act of 1967, that
this very concentration and discharge of the secondary
treated effluent could be its own violation. The Act was
drawn so broad and indefinite, with such authority that it
may carry the seeds of its own destruction, and especially as
exemplified by its administration.
Others will, and have, discussed cost factors, land
treatment and the merry-go-round. I would direct your
attention, if I may, in just concluding, to three very
important pages in this report: pages 223, 4 and 5,
concerning the adverse impacts which cannot be avoided. I
urge that each one of these be considered in much greater
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depth and I'm imposing but, if I may, I've waited this long,
I'm sorry.
These adverse impacts which cannot be avoided if
we go into four million gallons a day, the increased BOD load
on the Housatonic River, is this pollution? Two, at least a
temporary increase in phosphorous discharges to the Housatonii
and Lake Lillinonah; is this pollution? Does this also
imply tertiary treatment? The loss of nutrients to the
river; is this pollution? Some absolute loss of ground
water. In addition to the strain on the admittedly weak
water supply company that we have, what will the effect of
the added growth be on our water resources? A young man was
here, a Geologist, who said it, I think, beautifully.
Secondary impacts: one, a measure, I say forty-
three per cent, a measure of induced growth in the sewered
areas; two, loss of agricultural land and open space. And,
here, again, we have the left hand not knowing what the right
hand was doing. We have the agricultural attempt to preserve
our agricultural lands and they are prepared to spend
considerable resources and we are prepared to spend
considerable resources to fight them, one and the same State.
Some absolute increase in air pollutant concentrations; an
increase in the volume of solid wastes produced in New
Milford and concommitant shortening of the effective
lifespan of the existing sanitary landfills.
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This is a new subject that has not been discussed.
We are told that four point one to,forty-one to fifty-three
point five cubic yards of sludge will be generated by this
large plant on a daily basis, and that they're going to go
over to the SCS Services, the landfill. It may surprise a
lot of people to know that they have not committed that they
will accept this vast amount of sludge. There is no
contract. There is no agreement. There is no understanding.
As a matter of fact, at the moment, there is an antagonistic
condition existing in the town between the town and these
services. What do we do with these cakes, fifty-three and a
half cubic yards a day?
The indirect cost to the residents of the study
area and associated with the secondary costs of the project,
that is, the community facilities and services — and we've
heard a young woman tonight say some of theni. I don't have
to repeat them but they are costs that the Town of Bethel has
found putting them in dire straits.
Some absolute increase in noise levels. Well, we
can live with that. Some loss of wildlife habitat. Some
ground and surface water contamination associated with the
urban runoff of the induced population. And I add another
one, that the proposed plant is to be built over a general
aquifer on wetlands in a flood plain and these ditches or
dams that they are going to make, they're going to be in that
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flood plain and, you know what, with these dams, we're going
to have to dam the damn dam. I say, what good is the damn
dam if you have to dam it?
In conclusion, it's a strange position for a
community to be in, when we are asking for less than what
somebody wants to give us. And, our only request is, give
us what we need and it is even stranger that we have to turn
to the Federal Government to protect us from the excesses of
our own State Government and this is the last Court of Appeal
and I think this is why tonight was so important. It says
to this community and I think we have the pulse of the
community, I think, basically, most of the folk in this
community say, please, please, give us only what we need,
what we can handle and what we can digest. Do not push us to
the excess of seeking legal relief. It's only counter-
productive but we will fight if we have to, to protect and
preserve our community. Thank you.
(Applause.)
MR. STIC.KNEY: I presume that while you were
waiting, you were writing, perhaps. Mr. Marquard,
M-A-R-Q-U-A--R-D.
MR. MARQUARD: First of all, I would like to
express my appreciation for your hearing, whether it's a
formality or whether you're interested or whether the truth
lies somewhere in between. I assure you that we're interestes
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and we appreciate the opportunity to express ourselves.
My name is Paul Marquara and I'm a resident of New Milford.
I live in an area which will be directly affected by the
proposed sewer expansion.
I will state at the outset that I'm against the
plan as it is presently presented and I would like to offer
a few comments. I think the cost of the project is
excessive, even if the EPA estimate is accurate. Vfoen cost
overruns and inflation are considered, the cost increases
even more. If this mammoth sewer expansion is permitted, the
resulting development and population increase will create
the need for greatly increased services adding more to the
cost, which must be borne by the property owner in the form
of added taxes. The total cost appears to be unbearable.
The need for the project is questionable. It has
been created by the State out of some unreasonable desire to
industrialize and develop this area, and the developers would
be tiie main beneficiaries. But what effect will such
development have on the environment? The trees and the grass
and the soil will be removed and will be replaced by
automobiles and trucks, by fumes, noise, asphalt and brick,
all of which will produce a seven-fold increase in sewage.
And this sewage, which is of questionable quality at the end
of its treatment, will be dumped into a river which can't
handle it. Obviously, the effect on the environment can only
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be a negative one.
Mention has been made on numerous occasions of the
State's master plan for the development of northwestern
Connecticut and the induced growth necessary for that
development. Induced growth is actually planning without
representation, as the future of the Town is programmed by
distant officials. Two hundred years ago, this nation fought
a war over the issue of taxation without representation and
now New Milford finds itself in exactly the same situation,
in which our taxes are to be increased as a result of
dictates from afar. It is the Town's responsibility and the
Town's right to determine how it will grow. It is our
environment we are talking about. We will have to live with
the changes wrought by officials and developers. Therefore,
our concerns must receive the weightiest consideration.
Our personal environment, that is, the appearance
in the temple of the Town in which we live and raise our
children is of great importance to all of us. Large scale,
rapid changes in this environment will only have negative
consequences. We will accept guidance and other assistance
in planning for the growth which we all recognize must be an
ongoing, but orderly process. But, we will not yield to those
who take it upon themselves to decide for us how we shall
live. Local planning must be done locally by those most
affected by the planning. Anything else is unreasonable and
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it's inconsistent with good order. The proposed sewer
expansion will place a large number of families in financial
distress white providing great dividends for only a very few.
It will create a need for greatly increased
services and municipal administration, totally inconsistent
with sane and orderly growth. It will forever alter the
environment of the people who live here, fouling the river
while polluting the air and assaulting the ear while offendin
the eye. It will undermine the principle of self-determinati
of people, as the State determines our future for us while
local Government is relegated to deciding whether or not to
buy a new dump truck. A military officer in Viet Nam was
asked once why it was necessary to bomb a particular village
and his reply was that it was necessary to destroy the town
in order to save it. I can't help but wonder if someone
will be saying that to my son someday about New Milford.
You are producing an Environmental Impact
Statement and you have asked for an assessment of tlie project
impact on the environment, our environment. 1 can tell you
that the impact on our environment will be a harmful one and
we are, frankly, appalled by it. Thank you very much.
(Applause.)
I®. STICKNEY: Mr. Ronald Bryant or Brant? (No
response.) Mr. James Geroy or Geray? (No response.) Mr.
E.B. Horton? (No response.) Mr. George ¥. Bossers.
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(No response.) Brenda Croteau. (No response.) Sir. James
Lynch. (No response.) Mr. Brian Heath. (No response.)
Mr. Ernest Seinfeld.
MR. SEINFELD: I was the first one at the meeting,
I think I turned in the first card. They got shuffled
around and now — I have made an analysis of the project and
I will give you the analysis but it's quite late and I will
spare you. I will just read very short excerpts from my
statement and then I will give you the rest of the
statement.
Now, my name is Ernest Seinfeld. I live in New
Milford and by training, am an Economist and Financial
Analyst. As an Economist, I am concerned with the most
efficient use of scarce resources. As a Financial Analyst,
I'm interested in the best return on our investment. Last,
but not least, as a resident of New Milford, I am very much
concerned with the pernicious influence which the proposed
four to eight million gallons a day sewer plant is bound to
have on the quality of life of the residents of this Town now
and in the future but, equally, how it will affect the
character, balance, growth and institution of New Milford.
This Draft is technically biased towards a maximum
solution and I would like to give you just one example. In
evaluating expansion of the present sewer plant in terms of
water quality, the study assigns this aspect the very lowest
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grade, number three though it admits, to quote, "Implementatio
of this alternative would serve a large part of the problem
area of New Milford. Surface and ground water quality
should improve at local scale. Also, individual community
wells within the service area would be protected." End of
quote.
I have studied and analyzed this EIS very
thoroughly for I believe that its recommendation will
influence in a very negative and irrevocably manner, the
character of our Town as a semi-world of community with
balanced and limited inclusion of commerce and industry,
balanced growth accessible to all income groups as it is now
and has been for a long time. The EIS Draft recommendations
are economically unsound. They are financially misleading
and even if it could be argued that the EIS Draft
recommendations could be supported on financial and economic
grounds, the great negative impact which these recooimendationi
will make on the very character of this Town is sufficiently
strong to reject them.
This is the more so the case since we have an
alternative which does not have all these drawbacks, namely,
the expansion of the present plant. Before going into the
details — and I'm not going to go into all the details — of
these objections, I want to point out that we, as individual
homeowners, will be burdened with large costs, costs which
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quite a number may have very great difficulties to bear and
which will be quite unnecessary for the vast majority who
have good and sufficient septic systems and will be charged
assessments regardless if they use it or not.
This project is uneconomical because it wastes
resources. The present sewer plant built in 1958 is within
its capacity, an efficient plant, located in a section of the
Town where its negative impact is minimal. The efficiency is
reduced by excessive infiltration. However, this can be
remedied. I refer to Metcalf and Eddy, Incorporated, in
their statement in their 1967 report, to quote, "Although
certain pieces of mechanical equipment will require increasing
parts replaced, the remaining useful life of the treatment
facility is considerable." And also, "The existing plant
has many years of useful life remaining and is acceptable to
reasonable economic enlargement." End of quote. It has
also been stated by the consultants in October, 1968 report
that, I quote,"If formal agreement by Brookfield and
Kimberlj'-Clark cannot be obtained, the Town should undertake
expansion of existing plant and sewer extensions as
recommended in our March, 1967 report." End of quote.
Since Kimberly-Clark, which produces the largest
actual amount of industrial wastewater, by far, in New
Milford, has built their own disposal system, this
recommendation by the consultants seemed to be the most
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logical solution and also the most desirable one when viewed
from the viewpoint of achieving a balanced growth of New
Milford. The consultants selected the one point five five
million gallon capacity increase, not because this is the
limit to which this plant can be enlarged, but because of
their population projection for the study area of the 1967
report. This report did not take into consideration the fact
that a considerable area adjacent to the present plant is
unused and, most likely, availaole. See Mr. Morris Branden's
statement, June, 1975 environmental assessment herein.
This project is also financially unsound and the
fact that the Federal and State Government share the large
part of it does not alter this point. I want to point out
here that the actual share borne by the Town will be much
larger than the ten per cent, as believed by many, including
some Elected Officials. Even a cursory glance at the EIS
Draft reveals that many costs of this project must be borne
by the Town entirely. Furthermore, it would be naive to
believe that the projected figure of seven million dollars
will not be doubled or tripled before the project is finished
Projects like these have a tendency to mushroom in cost while
they are being built. For example, the current sewer
expansion in New York City cost already nearly four times
the amount that was anticipated when the project was started
and, as of now, it is still not finished and entirely
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accounted for.
I come now to the impact which this proposed
project will have on the way of life of New Milford. This
Town is just coming out of the harmful effects due to the
lack of zoning during the decade of the nineteen sixties.
Some effects still linger on, a few large development projects
started during this period went away before the Planning
Board and the Courts. New Milford's population shot from
eight thousand three hundred in I960 to fourteen thousand
six hundred in 1970,an annual growth rate of five point seven
eight per cent while the rest of Litchfield County increased
at an annual rate of one and a half per cent and the State
of Connecticut rate was one point eight per cent.
I'll finish quite soon. I don't want to take too
much of your time. When we look at the scorching pace of
development in New Milford during the nineteen sixties at
the time when Danbury was still in economic decline, we can
well foresee what is bound to happen when the economy of
Danbury is expanding and New Milford will be the logical
place to become the bedroom community of Danbury and other
parts of Fairfield County. With such extensive sewering,
zoning will collapse and what happened during the nineteen
sixties will look rosy in retrospect.
Sewers, yes, but not the sewer system which will
not serve but destroy the Town. This is not an empty warning,
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Many other towns in Connecticut have to worry about
excessive and unbalanced growth. Look at Torrington,
Winchester, Thomas, in our own County- They practically
stand still with declining industries and new ones shunning
them. Industry is declining in Connecticut. Only communities
which can offer an attractive atmosphere will have a chance
to attract new and desirable industries and commerce.
If we want to have a chance at all to attract such
industry and commerce, we need a simple but definite growth
strategy. This strategy is balanced and sustainable growth,
doivn zoning, a euphemism for strangling zoning will not
permit such a strategy.
Since I gave you this, I'm going to just cose to a
conclusion. It's quite late.
I want now to review the financial impact which
this sewer project will have on the individual homeowner.
Ho definite figures are available but the figures on hand in
comparison with similar projects and construction projects in
general, permit us to establish a range of likely costs. It
is my estimate that the average household will be burdened
an additional seven thousand to eighteen thousand dollars
debt burden or, in other words, the average household will be
in the same position as if taking out a second mortgage in
these amounts. The seven thousand dollars — the amount of
seven thousand dollars is not only based on the unrealistic
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cost expectation of the EIS Draft but does not include the
complete loss of the present individual septic system and
also assumes a cutoff date of twenty years of user charge so
we all know that this charge will not end in twenty years
but will be much higher. The seven thousand dollar figure
does not include the increased capital investment with the
resulting tax rate increase necessary for additional schools,
firehouses, similar public requirements and other additional
services created by population growth induced by the
proposed sewer project and the resultant tax base deficit.
This figure also does not include the loss of the
present plant for which the town is still paying, nor does
this figure include the very likely additional cost of
phosphate removal and eutrophication. This figure does not
include the one point seven million needed for the southerly
interceptor necessary to connect Brookfield.
I laugh at this conservative, even unrealistically
low figure of seven thousand dollars by generally accepted
methods of establishing the value of future payments. The
amount of three hundred and thirty-two annual payment for
the average house is equivalent to an additional mortgage of
four thousand one hundred and eighty-seven dollars. In
addition, about twenty-five hundred to about thirty-five
hundred average will be necessary to connect the house to
the sewer line and make the necessary plumbing changes within
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the house. This estimate is baaed on similar sewer
connection costs in Long Island.
However, as I have stated, I believe strongly that
this figure of seven thousand is too low. Many sewer
projects turn out to cost two to five times more than
estimated, as seen, for instance in the above-mentioned
sewer expansion in New York City. The seven thousand dollars
is based on average assessment figures of the house of
twenty-one thousand dollars. Larger assessment figures will
result in higher costs. This figure also assumes the
unlikely event that the tax rates will not go up.
Thus, to the deterioration of life in Mew Milford,
the lessened prospect of attracting desirable business, each
homeowner would be saddled with additional debt burdens and
most of the investment in the present septic system. This
burden will fall upon each homeowner in an area of New
Milford scheduled for this expansion where about seventy-five
to eighty per cent of the residents live.
Thus, it seems to be reasonable that the proposed
formerly gallant plan should be rejected. This project is
harmful to the prosperity and quality of life in Inew Llilford.
It is uneconomical and financially doubtful. It will burden
the individual households with extraordinary costs. Its
effects will be final and irretrievable. It will lead to the
urbanization of Hew Milford. This road to disaster is the
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more unacceptable and should be resisted for all the residents!
of this Town since we have a good and viable alternative,
namely, the enlargement of our present plant in conjunction
with the pilot project of land treatment. We have arrived at
the crucial stage in the planning of the sewer project.
Some people have become complacent in the belief that because
this question has been hanging in the fire for so long, we
will have another decade before facing the reality of this
question. This is a fallacy. Neither time nor the sewer
experts who, like most experts, see beauty in size and scope,
are on our side. We have to study all the ramifications and
take a firm stand. I hope that the majority of the
residents choose to stand up for a sound future for New
,'vlilford. Thank you.
(Applause.)
MR. STICKltEY: Thank you, very much. Is Leonard
Lake here?
A VOICE: Don't you think it's getting kind of late°
MR. STICKNEY: Yes, I do.
A VOICE: Why don't we come back some other night?
MR. STICKNEY: With what we've got invested in this
evening and this morning, sir, I'd like to stay on.
A VOICE: There were a lot of people that wanted to
speak that have already left.
MR. STICKNEY: Well, I believe that we've given
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each and every one opportunity to speak their piece and in
the interest of making sure everything that should be said
to allow it to be said, we've allowed people to go into areas
that, occasionally, don't border on the responsibilities of
the EIS. It seems to me we've covered practically every
possible subject that could be raised so far. There's one
other name here, Mr. Manton.
The record will remain open until the 7th. A
written comment has the same weight as a comment submitted at
the hearing, both legally and in terms of our regard for the
need to answer it in the EIS. I appreciate your patience.
A VOICE: I v/ould like to ask a question. When you
say a written statement will have the same regard as a
statement here and will be answered in the EIS, exactly what
do you mean by "answered"?
MR. STICKNEY: The EIS has to be responsive by
either a change —
A VOICE: But, what does that mean?
MR. STICKNEY: It means — I'd like to tell you.
It means that either the EIS must indicate its line of
reasoning for why it should not adopt the comment or it
should indicate that the project has been changed in such a
way that the coiiment has been incorporated.
A VOICE: You make a decision in the Final Draft;
is that correct?
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ME. STICKNEY: Yes. The Final EIS will include a
decision, will include copies of all the written comments and
our responses and indications as to where the text has been
changed if it has been changed.
A VOICE: That's all I wanted to know.
MR. SEINFELD: Do you have any idea when to expect
a Final Draft?
MR. STICKNEY: Well, we would have given you one
answer at 3:00 o'clock last evening, perhaps another one at
1:00 o'clock this morning. Bob, what is the schedule?
MR. MENDOZA: Our original schedule for producing
the Final Impact Statement was going to be late spring or
early summer. It's difficult to say at this point with the
comments that we've had this evening plus whatever written
comments we'll get in the future, up until the 7th of March.
How long it's going to take, I really don't know.
MR. STICKNEY: However, it's not unusual for an
Impact Statement to be subjected to such a critical review.
It comes with the territory.
A VOICE: (Inaudible.)
MR. STICKNEY: That's a decision that's made after
the comments are reviewed and unless there were inadequacies
in the Draft or issues that weren't raised in the Draft that
need to be circulated for a public hearing, then this would
be the final hearing. The Final would be published and there
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would be a thirty-day grace period after that before any
action could be taken.
MR. BENEDICT: On the points I raised, I think a
lot of it needs determination by your Counsel. YJill these
things be determined by your Legal Department or by the
Engineers?
MR. 8TICXNEY: The legal issues will, certainly,
be reviewed by our Legal Department, not by us.
ME. MEINHARDT: What is the limit of your authority
as to the programs submitted? Can you alter the program —
I know you can reject it or accept it but can you alter it
as submitted?
MR. STICKNEY: Only in the regard that we can
determine that we will only fund it if it's presented in such
a manner, a particular manner .
MR. MEINHARDT: Could that mean that you could
reject or accept a part of it? In other words, if it were
your judgement that this community needed X amount of gallons
— let's assume just for argument that it's what we want,
two million gallons — is your authority to accept that or
not accept it?
MR. McSWEENEY: I think I can probably help you
out, Wally.
¦IfEl. STICKNEY: All right. It's about time you said
something, Mr. McSweeney.
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MR. McSWEENEY: In that regard, we can limit the
eligibility to portions that we would contribute to. In
other words, the portions of the project that we feel are
environmentally sound, we would limit the eligibility to thos
portions and to those sizes of pipes and proportions of the
projects. That's how we would limit it.
MS. MEINHARDT: Where do we sit then with the
State if the State disagrees?
MR. McSWEENEY: Well, I'm not an Attorney. I
really couldn't say in that regard. But that's the limit of
our ability. In other words, if we weren't involved in the
funding of this project, there wouldn't be an EIS here at all
In other words, the limit of our control is, essentially, in
the funding.
MR. MEINHARDT: To fund a particular program.
MR. McSWEENEY: Yes.
MR.- MEINHARDT: A particular program that you
would, ostensibly accept. You would fund that. So that
your jurisdiction is, therefore, to alter, if you decide
that it's something that you think is correct.
MR. McSWEENEY: Well, we would limit the funding
to the eligible portion. In other words, if the State or
the City chose to build a larger system that we found to be
ineligible or environmentally unsound, we would not
contribute to that portion. That's about the limit of our
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control.
A VOICE: The funding of what you consider to be
an eligible portion, would that mean that a portion that you
find environmentally not sound could be built if you would
not fund it?
MR. McSWEENEY: Yes, it could be.
A VOICE: It's the job of the Environmental
Protection Agency and I underline the word Protection, that
something could be built, you just won't fund it.
MR. McSWEENEY: Yes. That's the limit of our
control in certain areas. In other words, if the Town chose
to build an interceptor sewer without any Federal assistance,
they could do it. That's wtiat I'm saying.
A VOICE: It seems that you could not stop it.
ME. McSWEENEY: We could stop it, depending on what
they did with the sewer. If they decided to just- dump raw
sewage into the river we could do something about it.
MR. BENEDICT: That's been going on right now.
MR. McSWEENEY: Allegedly we're doing something
about that or trying to do something about that.
A VOICE: Would it depend on the degree of how
unsound, environmentally, it was?
MR. McSWEENEY: Yes. It would depend on a lot of
things. I can't say that we can — there are things that we
can do. We can take enforcement actions, theoretically.
-------
1
2
3
4
5
6
7
8
9
10
1 1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
161
Where tiiere is a violation of the law, we can attempt to stop
that violation of the law but if there is no violation of the
law — building a sewer is not a violation of the law. If
the City chooses to build a sewer, we can't stop them.
A VOICE: You seem to be saying that if it might be
possibly environmentally unsound, that it could be built.
MR. STICKNEY: I'd like to respond to that and
then we'll have to close. Somebody may build something which
we may judge to be environmentally unsound but no enforcement
action can be taken until after a violation takes place. And
an enforcement action by EPA has to directly relate to an air
pollution violation or a water pollution violation, toxic
substances or something like that. That's a different,
totally different situation from our funding, our affirmative
action in funding a project in which we think there is a fair
chance for environmental degradation. Two different actions
entirely.
A VOICE: You almost don't sound like a Protection
Agency. You sound like a Police Agency.
MR. STICKNEY: It depends on which hat we have.
Some days we're a Police Agency. Sometimes we're a
Construction Agency and we have many different responsifciliti2
This hearing is at a close.
(Whereupon, at 1:30 a.m., the hearing in the
above-entitled matter was closed.)
-------
APPENDIX C
WRITTEN COMMENTS
-------
LIST OF EIS WRITTEN COMMENTS
Comment #
Source
Date
Rl
R2
R3
R4
R5
R6
R7
R8
R9
RIO
Rll
R12
R13
FEDERAL AGENCIES
Department of Commerce/National
Marine Fisheries Service 3/8/77
Department of the Interior/Bureau
of Outdoor Recreation 3/21/77
Department of the Interior 3/18/77
Advisory Council on Historic
Preservation 2/8/77
EPA/Laboratory 2/3/77
EPA/Environmental Study
Coordinator 2/17/77
EPA/Noise Consultant 2/1/77
STATE AGENCIES
Connecticut Office of Inter-
governmental Programs/Department
of Planning and Energy Policy 2/28/77
Connecticut DEP/Air Pollution 2/2/77
Connecticut Historic Preservation
Officer 2/28/77
Connecticut State Representative
Walter J. Conn 2/21/77
TOWN AGENCIES
Town of New Milford/Planning
Commission 2/15/77
Town of Brookfield/Sewer
Commission 2/18/77
-------
Comment #
Source
Date
R14
R15
R16
R17
R18
R19
R20
R21
R22
R23
R24
R25
R26
R27
R28
R29
R30
TOWN AGENCIES (cont.)
Town of Brookfield/Industrial and
Commercial Development Commission 2/15/77
Town of New Fairfield/First
Selectman 2/3/77
Town of Bridgewater/Conservation
Commission 3/3/77
PRIVATE ORGANIZATIONS
Sunny Valley Preserve 3/4/77
Candlewood Shores Property Owners
Association/Workshop 2/6/77
Candlewood Shores Property Owners
Association/Hearing 2/28/77
CLC Owners Corporation 3/7/77
Housatonic Valley Association, Inc. 2/14/77
Candlewood Lake Defense Associates 3/1/77
Addendum #1 3/2/77
Addendum #2 3/4/77
INDIVIDUALS
Ira Meinhardt et al (petition) 3/4/77
Adam Halasi-Kun et ux 3/2/77
Russell T. Posthauer, Jr. 3/7/77
Leonard A. Stevens 3/4/77
Anna E. Schiappacasse et al 2/20/77
William J. Philipps 2/11/77
Jonathan H. Malone 2/26/77
(Mrs.) William P. Guerra 2/23/77
-------
Comment # Source Date
INDIVIDUALS (cont.)
R31 Barbara Setear 2/5/77
R32 Saul Schary et ux 2/7/77
R33 John E. Crawford 1/10/77
R34 Austin A. Knox 1/20/77
R35 R.N. Roberts et ux 2/4/77
R36 Edith L. Knox 2/9/77
R37 Doris C. O'Neil 3/1/77
R38 Antoinette Went 3/9/77
R39 Linda King 2/28/77
R40 Angela Yagid 3/2/77
R41 Clifford C. Chapin 2/22/77
R42 Paul Dousky et ux 3/1/77
R43 John E. Crawford 2/1/77
R44 Oscar G. Rogg undated
R45 Sally Spring Rinehart 3/3/77
R46 Stephen M. Golembesky et ux 1/14/77
R47 Donna Elms 3/6/77
R48 E.B. Horton et al 3/4/77
R49 George W. Bossers 2/4/77
R50 Ernest W. Critzer et ux 2/21/77
R51 Jeffrey Kass 2/27/77
R52 Joseph J. Martinkovic, Jr. 1/16/77
-------
Comment #
Source
Date
R53
R54
R55
R56
R57
R58
R59
R60
R61
INDIVIDUALS (cont.)
W. Lourdes et ux
William A. O'Leary
Veronica Mooney
Natalie Sirkin
John Lowenthal
James S. Mellett, Ph.D.
MISCELLANEOUS
Town of New Milford/First
Selectman
Metcalf & Eddy, Inc.
Paul T. Carroccio
2/4/77
2/15/77
3/4/77
3/6/77
3/5/77
2/2/77
3/23/77
2/7/77
4/21/77
-------
DOCUMENT R1
UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary for Science and Technology
Washington, D.C. 20230
March 8, 1977
Mr. John A.S. McGlennon
Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
This is in reference to your draft environmental impact
statement entitled, "Wastewater Collection and Treatment
Facilities, New Milford, Connecticut." The enclosed
comments from the National Oceanic and Atmospheric
Administration are forwarded for your consideration.
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you.
We would appreciate receiving five (5) copies of the
final statement.
Sincerely.
Sidney R. Galler
Deputy Assistant Secretary
for Environmental Affairs
Enclosure - Memo from National Marine Fisheries Service,
February 14, 1977
-------
XS"'- ™''oX
iffli
-"(i c_
UMITEIf STATES DEPABTMEITr OF COMMERCE
Nation ^ Qce^snir. anii Atmospheric Administration
NATION'"1! MARINE f ISHEHICS SLRViCE
Federa i Building, 14 Elm Street
Gloucester, Massachusetts 01930
f i
-------
2.
specific information on the soils, wetlands, and vegetation of the
property. Because this parcel might be designated under Wild and
Scenic Rivers Act provisions, the environment around the proposed
facility should be discussed in as much detail as possible.
RWSmith/djh
cc: ¥53(3)^
FNE
Milford EAB
-------
DOCUMENT R2
United States Department of the Interior
BUREAU OF OUTDOOR RECREATION
WASHINGTON, D.C. 20240
MAR 2 11977
Mr. John A. S. McGlennon
Environmental Protection Agency
Boom 2203
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
In accord with our letter to you dated February 8, 1977, we have
completed our review cf the possible effects of the proposed New
Milford, Connecticut, wastewater treatment plant on the Eousatonic
River. As you were advised in our letter, this agency is studying
the river under the National Wild and Scenic Rivers Act, P.L. 90-542
and is required under the Act to review all federally sponsored
water resource projects that could have a direct and adverse
effect on the river and its immediate environment.
Our investigation,carried on by our Northeast Regional Office
with full cooperation from your office, has led us to the
conclusion that the plant described as "selected alternative (4)" in
the Draft Environmental Impact Statement would have a direct and
adverse effect on the river values unless mitigating measures
are taken.
Our finding is based on several concerns which we want to work
out with you as expeditiously as possible to avoid delay of the
project. It appears that overall, the construction of the plant
at New Milford could provide substantial benefits to the community.
Our review indicated that it will decrease pollution on the river
being caused by failing septic tank systems and industrial pollution
Our express concerns along with recommended action are as follows:
1. Concern: That the plant will be highly visible from the
river and its immediate surroundings. This is due primarily to
the size and elevation of the proposed facility.
Recommendation: That the landscape plan be revised to soften
the visual impact of the structure on the river.
IN REPLY REFER TO
^OLU Tl0/V
?6-l9"?6
-------
2
2. Concern: The effluent from the plant, particularly at times of
low flow in the river, would increase the level of phosphates flowing
into Lake Lillinonah an estimated four fold. The present phosphate
level in the lake is already reported to be 10 times that needed
to produce an algae bloom.
Recommendation: Consideration should be given to the
amelioration of this problem through the alteration of the
plant design or other appropriate measures.
In addition, we are concerned that the plant would have the
effect of encouraging significant new developments. We are not
in a position, however, to state that these new developments will
occur and/or that they will have a direct and adverse effect on
the river. Any consideration that you could give to this
matter, however, would be desirable.
We are reviewing the Draft Environmental Impact Statement for the
New Milford plant, and will provide "inputs for" Interior's
review consistent with this letter.
Our Northeast Regional Office will be glad to meet with you or your
staff at your earliest convenience to agree on precise methods
for addressing these concerns. Mr. Robert Mendoza and other
members of your office have been very helpful to us during our
review.
Sincerely yours,
JL, Mary Lou Grier
v Acting Director
I
-------
DOCUMENT R3
KAfi 21 jgyp
United States Department of the Interior
OFFICE OF THE SECRETARY
NORTHEAST REGION
In reply refer to:
ER-77/35
JOHN F. KENNEDY FEDERAL BUILDING
ROOM 2003 M & N
BOSTON, MASSACHUSETTS 02203
March 18, 1977
Regional Administrator
Environmental Protection Agency
Region 1, JFK Federal Building
Boston, MA 02203
Dear Sir:
This responds to your recent letter requesting comments from the Department
of the Interior relative to the draft environmental impact statement for
Wastewater Collection and Treatment Facilities, Litchfield County,
New Milford, Connecticut. The following comments are provided on the
subject document.
Although the draft statement is exemplary in most respects, the evaluation
of environmental impacts related to geologic conditions would benefit from
the inclusion of more quantitative information. For example, although the
treatment plant and certain pump stations would evidently be constructed on
the flood plain of Housatonic River (p. ix, par. 6), we found no discussion
of flood levels with respect to proposed elevation of structures. Fill
would evidently be required to raise the general site area above flood
level, but we found no details on the surface area or volume of fill, or
probable source of the fill material. In addition, the impact of
construction on flood levels should be mentioned, although the impact
may not be significant.
We found no quantitative information on impacts of constructing the sewer
lines; an estimate of the total length and diameters of the lines should
be provided, as well as some indication of the total earthwork required.
In addition, the total acreage of wetlands likely to be disturbed by the
project should be estimated, as reference has been made to such disturbance
(p. ix, last par.).
Despite a recommendation of the New Milford workshop (p. 247) , the document
does not evaluate effects of infiltration on the water table — either
under the existing conditions or under any of the preferred alternatives.
The infiltration loss for New Milford (142,000 gpd) under the current
system (p. 132) should furnish a basis for at least rough estimates of this
impact for all areas involved, and specifications for any new system
^0V-UT'Qv
-------
would make it possible to anticipate the degree of amelioration of
water-table impacts. Exfiltration potential should, also, be considered
under both present and completed project situations.
In regard to recreational activities, the draft environmental statement
inadequately addresses several of our concerns.
First, there is no mention of the ongoing Wild and Scenic Rivers Study
under P.L. 90-542 on the Housatonic River. The final statement should
reference to that study which is being conducted by Interior's Bureau
of Outdoor Recreation.
Second, assuming the plant will be visible from the river, mitigating
measures, such as screening and landscaping should be discussed.
Third, the discussion of phosphate effluent indicates that no tertiary
treatment is proposed and the river will receive approximately four times
as much phosphate as it gets at present. A positive alternative such as a
change in plant design to perform tertiary treatment, or acceleration of
ongoing eutrophication studies should be considered.
In addition, we are concerned that the plant would have the effect of
encouraging significant new developments in the immediate environment
of the river. We are not in a position, however, to state that these
new developments definitely will occur and/or that they will have a
direct and adverse effect on the river. Any consideration that could
be given in regard to this matter would improve the scope of the
statement.
Because of the Wild and Scenic River Study, the Bureau of Outdoor Recreation
is carrying out a concurrent review of this project under Section 7(b) of
the National Wild and Scenic Rivers Act. That section provides in part that:
. .no Department or Agency of the United States shall
assist by loan, grant, license, or otherwise in the
construction of any water resources project that would
have a direct and adverse effect on the values for which
such river might be designated, as determined by the
Secretary responsible for its study or approval."
At this time and based upon the available information, it is our probable
position that the New Milford plant as proposed would constitute a direct
and adverse effect on the Housatonic River which could be addressed through
mitigation measures.
We are pleased to note the efforts given to the determination of the
presence of cultural resources, particularly archeological, in the project
area. A number of recommendations are recorded (pp. 109, 206 and 209)
for the need for further archeological investigations prior to
construction and careful site monitoring during construction in
particular sectors of the overall wastewater collection and treatment
project. We should like to see further commitment given in the final
statement to assure the timely accomplishment of these cultural
-------
resource protection endeavors to avoid inadvertent damage or loss. It
would seem wholly appropriate that the EPA action in this case be
conditional upon timely and adequate treatment of recommended cultural
resource protection measures.
We,also, note that one site is in the process of nomination for inclusion
on the National Register of Historic Places. The EPA should be reminded
that the Chief, Office of Archeology and Historic Preservation, National
Park Service, Washington, D.C. 20240, will, upon request, provide a
determination of eligibility for the site's inclusion on the National
Register. Should the site be eligible, the EPA is responsible for Section
106 compliance, fulfillment of which should be presented and discussed
in the final environmental statement.
The statement is adequate insofar as fish and wildlife and mineral
resources are concerned.
Sincerely,
William Patterson
Regional Environmental
Review Officer
-------
DOCUMENT R4
Advisory Council on
Historic Preservation
1522 K Street N.W.
Washington, D.C. 20005
rrr. ¦ •
February 8, 1977
Mr. Mendoza
Environmental Policy Coordination Office
United States Environmental Protection Agency
Region I
JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. Mendoza:
Thank you for your request of January 5, 1977 for comments on the environ-
mental impact statement for the wastewater collection and treatment
facilities, New Milford, Connecticut. Pursuant to our responsibilities
under 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 impact statement does not contain sufficient information
concerning compliance with the Council's procedures.
On page 206 of the Environmental Impact Statement you refer to the
Pickett District Cemetery as a property that may be impacted by construc-
tion of this project. Because this property has been previously listed
in the State Historical Preservation Plan, the Council feels that further
investigation into the eligibility of this property for the National
Register is in order, pursuant to Section 800.4(a) of the Council's
procedures.
Also on page 206, under the subheading Archeological Sites, there is
reference to an archeological site which has been nominated to the
National Register and will be destroyed by the project. We recommend
that the Environmental Protection Agency initiate the Council's procedures
as soon as possible to insure completion of the compliance process prior
to issuance of the final environmental statement. A copy of the Council's
updated archeological procedures is enclosed for your review.
To ensure adequate consideration has been given to the above points, the
Council recommends that the final environmental statement contain evidence
of contact with the appropriate State Historic Preservation Officer. A
copy of his comments concerning the effects of the undertaking upon these
resources should be included in the final statement. Also, provisions
should be made to monitor future project construction in this archeologically
sensitive area. The State Historic Preservation Officer for Connecticut
is Mr. John Shannahan, Director, Connecitcut Historical Commission,
59 South Prospect Street, Hartford, Connecticut 06106.
The Council is an independent unit of the Executive Branch of the Federal Government charged by the Act of
October 15, 1966 to advise the President and Congress in the field of Historic Preservation.
-------
Page 2.
Should you have any questions on these comments or require any additional
assistance, please contact Sharon Conway of the Advisory Council staff
at 202-254-3380.
Sincerely yours,
/ John D. McDermott
Director, Office of Review
and Compliance
Enclosure
-------
DATE:
DOCUMENT R5
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
February 03, 197 7
fCB
SUBJECT: Survey Data
FROM: William tf. Walsh
Chief, Water Section
T0: See Below Ssj-' LU-tul. *u~
Attached for your information is a listing of survey data that is
presently on file at Lexington. Specific requests for this data
can be made to the Water Section. t I j i . ,>
CLt
Walter Newman
^Wallace Stickney . i_
Wayne Wirtanen o
Stuart Peterson t *
Thomas Devine 0LcA-Z^~ v>-v .
Attachments
EPA For,,, l 3 20-6 IRo». 3-76)
-------
.SURVEY DATA
in
SURVEILLANCE BRANCH FILES
(NOT IN STORET)
River
Housatonic R.
Still R.
Hockanum K.
Reach of River
Lake Lillinonah Conn.
Lake Housatonic Conn.
Lower Housatonic Conn.
Still R. Conn.
HatLfuid LU
Date of Survey
Summer of 1973
Summer of 1973
Summer of 1973
Ashuelot R.
Keene-Hinsdale NH.
August 6-8, 1976
Winuoski R. Essexjct-Burlington VT. July 29-Aug. 7,1975
Otter Creek Clarendon-Middlebury VT. July 21-Aug 4,1976
Woonasquatucket Bryant College-Georgia- Oct 1-Oct 4, 1974
R. ville Pond RI.
Parameters Analyzed
BOD, Temp, DO., NH3, NO2-NO3,
Total P. Bacti
Purpose
Load Allocatioi
Temp., pH, Do, BOD, NH3, NO2-
NO3, TNFR, Bacti, Metal
Temp, DO, BOD, Total P., NH3,
NO2-NO3, TKN Chlor a
Temp, DO, BOD, Total P., NH3
}
N02-N03, TKN, Chlor a
Pheophytin £, TNFR
Load Allocatioi
Load Allocatiot
Load Allocatioi
Evaluate Bryan)
College Discha:
-------
-SURVEY DATA
in
SURVEILLANCE BRANCH FILES
(NOT IN STORET)
River Reach of River
Spicket R. Salem, NH - Lawrence,
Mass.
Date of Survey
July-Aug., 1974
Spicket R. Salem, NH - Lawrence, Sept 75
Mass.
Sleeper R. Headwater - Mouth Vt June, Sept.,1975,
May, 1976
Norwalk Harbor Head of Tide - Outer June 1976
Harbor Conn.
Parameters Analyzed
Purpose
BOD, Nitrogen Series, Total P., Tech Assist to
Residue, Chloraphyl a, Algae NH.
Coliforms, DO, Temp., pH, Benthos
DO, Temp, pH, BOD Tech. Assist t
VT,
DO, Temp, pH, Total P., Nitrogen Typify Non poi
Series Coliforms, Turbidity, Res- source polluti
idue
BOD, DO, Temp., pH, total P., Collect data J
Nitrogen Series, Chloraphyl £ developing ha:
models
-------
DATE:
SUBJECT:
FROM:
TO:
DOCUMENT R6
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
February 17, 1977
Proposed New Milford Wastewater Treatment Project In
relation to Housatonic Wild and Scenic River Study
Bart Hague ljrV*
Environmental Studies Coordinator
Wally Stickney, Director
Environmental Policy Coordination Office
G
-------
DOCUMENT R7
MEMORANDUM
FROM: G.A. Russell DATE: February 1, 1977
Noise Consultant
TO: Robert Mendoza
Environmental Assessment Office
SUBJECT: Review of DRAFT EIS WASTEWATER COLLECTION AND TREATMENT
FACILITIES, NEW MILFORD, CONNECTICUT
At the request of Mary Shaughnessey I have very briefly reviewed
the referenced DRAFT EIS with respect to the possible noise
impacts from the proposed action.
It appears that only a minimum amount of attention has been given
to possible noise impact. This reviewer concurs with the identi-
fication of two main noise sources (traffic and machinery operation)
and with the general assessment that neither source is likely to
produce a significant impact. Some quantitative evidence to support
this conclusion however, would make the EIS more effective.
There are approximately 40 residences at a distance of about 1000
feet from the proposed location and several other residences as
close as 500 feet (see page 222). These distances are not very
large in terms of noise attenuation, for example only 20 dB of
attenuation can be expected in going from 50 feet to 500 feet with
an additional 6 dB if the source to receiver separation is in-
creased to 1000 feet. Because of the 24 hour operation of the
proposed facility it is desirable to keep the plant generated noise
levels at the nearby residences at 45 dBA or less. This implies
that the loudest noise at 50 feet from the plant should be no
greater than 65 dBA during the nighttime hours. This level of
noise emission can be obtained if proper attention is given to noise
abatement measures during the final design of the project instal-
lation.
The somewhat off-hand dismissal of possible noise impacts (see
page 111) is disturbing to this reviewer in view of the above re-
marks. The EIS would have been a stronger presentation if the
points brought out above were addressed in the Draft document. If
possible, these points should be treated in the final version.
-------
DOCUMENT R8
STATE OF CONNECTICUT
%
OFFICE OF INTERGOVERNMENTAL PROGRAMS
340 Capitol Avenue - Hartford, Connecticut 06115
ELLA T. GRASSO
February 23, 1977
BARRY I. BUDLONG
GOVERNOR
ADMINISTRATOR
ROBERT K. KILLIAN
LT. GOVERNOR
Environmental Protection Agency-
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Attention: Environmental Policy Coordination Office
Gentlemen:
Draft Environmental Impact Statement—Wastewater
Collection and Treatment Facilities.
New Milford. Connecticut (EIS #190;
The Office of Intergovernmental Programs has received copies
of the above-referenced Draft Environmental Impact Statement and
has distributed them to interested state agencies for review and
comment.
This is to advise you that the review has been completed and
written comments were received from the Department of Planning and
Energy Policy. A copy of these comments are attached for your
information.
Sincerely
Michael AT. Sartori
State Clearinghouse Coordinator
MVS/lsb
Attachment
cc: Mr. William Cox
Department of Planning and Energy Policy
-------
SUGGESTION COMMITTEE SAYi Improve Your Own Condition; Eom Coth ond Recognition! Send In a Sugq»»tlonl
Inferdepartment Message SAVE TIME: Handwritten massages are acceptable.
STO-200 REV. 11/73 (Stock No. 6938-OXl-til) Use carbon if you really need a copy. If typewritten, ignore faint lines.
To
NAME
Michael V. Sartori
TITLE
State Claringhouse Coordinato
DATE
r January 28, 1977
agency office of Intergovernmental
Programs
AODRESS
340 Canil-nlAvermp. Hartford. CT
From
NAME
William Cox
TITLE
Planning Analyst
TELEPHONE
AGENCY
Planning & Energy Policy
ADDRESS
340 Capitol Avenue, Hartford, CT
SUBJECT
New Milford Waste-water Collection and Treatment Facilities (EIS #190)
I have reviewed the draft New Milford EIS and have no critical comments
of substance.
The draft does a first-rate job of presenting the issues and impacts associated
with the several alternative approaches. DPEP's earlier concerns about the
appropriateness of population projections appear to have been fully answered.
RECEIVED
JAN bx
OFFICE Of
MTEMOrERNMEfiTAl PROGRAMS
SAVE TIME: If.convenient, bandwrite reply to sender on this tame sheet.
-------
DOCUMENT R9
if£B 3 m
STATE OF CONNECTICUT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
State Office Building Hartford, Connecticut 06115
February 2, 1977
U.S. Environmental Protection Agency
Environmental Policy Coordination Office
Roan 2203
John F. Kennedy Federal Building
Boston, Jfessachusetts 02203
Dear Sirs:
I have reviewed the air quality section of the "Environmental Impact
Statement, Waste Water Collection and Treatment Facilities, New MLlford,
Connecticut" and have discovered seme technical errors in the presentation
of air monitoring data.
The errors appear on pages 52-54 and have been corrected on the copies
enclosed.
Very truly yours,
fl.
Michael K. Anderson
Air Pollution Control Engineer
Telephone (203) 566-3310
MKA: jr
Enc.
Iku paps\ wai. produced fam ueefded pope*. - hoik ivtie and hetUed.
-------
Designated Air Quality Maintenance Areas are those areas
in the state that have a potential for exceeding primary
or secondary air quality standards within a ten year planning
period. New Milford and Washington are not in a designated
AQMA, Brookfield and New Fairfield, however, are a part of
the Connecticut AQMA in which particulate, sulfur oxides,
carbon monoxide, and photochemical oxidants may potentially
exceed air quality standards. While this designation is
primarily a result of high pollutant concentrations in the
New York-New Haven-Hartford-Springfield corridor, the
Danbury industrial/residential concentration may be an
important source of air pollutants in the study area.
Ozone standards are regularly violated throughout New
England.
The Connecticut DEP maintains a statewide network of air
quality monitoring stations. There are no monitoring
stations in the study area, but there is one in Danbury,
directly to the south, and one in Kent, directly to the
north. A summary of pollutant concentrations at these
stations is presented as TABLE 14. Air quality in the
study area.is probably intermediate between the values
for these two towns.
The significance of air quality levels is best assessed in
relationship to national primary and secondary ambient
air quality standards. Primary standards are those es-
tablished to protect public welfare. Violation of these
standards is indicative of less than pristine air quality.
Air quality in the study area is influenced to some extent
by the New York City urban concentration. The intense
urban development of Danbury, however, may be a more im-
mediate factor 'in the determination of air quality. Be-
cause of the basically rural character of the study area,
although it is on the fringes of areas with air quality
problems, air quality is essentially good. In addition,
there has been a trend toward an improvement in air quality
in the study area.
Sulfur dioxide and oxides of nitrogen standards were not
exceeded in the study area in 1975. Carbon monoxide was
not monitored. Ozone concentration limitations were
regularly exceeded during the summer months throughout the
State of Connecticut. This condition is attributed to
sources outside of Connecticut, ^ftl-though mc-aampoAtotal
suspended particulate concentrations did not exceed annual
52
-------
TABLE 14
SUMMARY OF STUDY AREA AMBIENT AIR QUALITY
TOTAL SUSPENDED PARTICULATES
TOWN
YEAR ANNUAL GEOM. MEAN
(ng/m3)
PREDICTED NUMBER
DAYS STANDARD EXCEEDED
Primary Secondary
DANBURY
DANBURY
DANBURY
DANBURY
1972
1973
1974
1975
84.1
58.1
51.5
53.9
24
2
©
o
7?
to
4
%
KENT
KENT
KENT
1973
1974
1975
38.6
31.4
31.9
I
O
0
7
z
0
SULFUR DIOXIDE
TOWN YEAR
ANNUAL AWfV MEAN STANDARD EXCEEDED
(ug/m3) Primary Secondary
DANBURY
DANBURY
1974
1975
Insufficient Data
31 No
No
KENT
1975
Not Monitored
SOURCE:
Connecticut Air Quality Summary, Connecticut DEP, 1975
-------
Svfcp*M(i?cl ^yV»ci»W\e- ij c.o\*dvcJ"J o^\
every sixH\ oU^ tckei«/\e_ &«- "i. VolvI o{ (*{
y^evSuf^-ol v/\d\"3^»o«*> <^W©rY \ f rvt\
C*a.A Vr) S'K^df'cJU C«r- V e^A-^^s. yiovugt/fr.
standards in 1975, Qtatistical^c^culations^sugges-^^hjat the
annual secondary standard wai^cxc^eded onftwo^aays in Danbury.
The primary ^standard was not violated in 1975. .Short Lcvm
(-24 hum).—slrandardo fog-part,icuka-te eoncontrationc weye
also not viola Led in Dai*bury. At the Kent monitoring station
the annual mean particulate concentration was about half of
the allowable concentration. Short term standards for
particulate were not violated in Kent in 1975. The air
quality in New Milford is probably intermediate between that
measured in Danbury and Kent.
A.2.c. Odor
In New Milford odors from the existing wastewater treatment
facility and scattered subsurface disposal systems impact
local ambient air quality. Odors, although not hazardous
to health as are some air pollutants, may pose a consider-
able nuisance to those persons affected by them. None of
the four towns of the study area maintains an official
record of odor complaints, but occassional odor problems
throughout the study area are readily.acknowledged.
Odors are indicative of an inadequate or improperly main-
tained treatment facility or subsurface disposal system;
under proper management wastewater treatment systems are
virtually odorless. Odors from domestic sewage are a
result of the anaerobic decomposition of sulfur containing
wastes by bacteria. Hydrogen sulfide gas, with its char-
acteristic rotten egg odor, is the principal product of
this decomposition although more obnoxious compounds such
as indol, skatol, and mercaptans are also produced. In
the existing New Milford wastewater treatment plant, the
principal sources of odors are from 1) septic sewage con-
taining hydrogen sulfide on arrival at the plant, 2)
industrial wastes discharged to the collection system
3) unwashed grit, 4) scum on primary settling tanks, 5)
sludge-thickening tanks, and 6) chemical mixing operations.
In subsurface disposal systems, in which the wastewater is
anaerobic by design, most odors can be traced to leaks of
wastewater to the surface.
Odors, as stated above, are not a problem in a properly
operated treatment facility; however, upset conditions do
inevitably occur and odors may be generated. The impact
of these odors varies widely under varying conditions. In
general, odors from New Milford's treatment facility tend
to dissipate rapidly and are not usually noticeable beyond
the plant's property lines. Under unfavorable wind condi-
tions, however, the odors may be carried some distance.
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Office of the DOCUMENT RIO
STATE
HISTORIC
PRESERVATION
OFFICER
for Connecticut
59 SOUTH PROSPECT STREET • HARTFORD, CONNECTICUT 06106 • 203 566-3005
February 28,1977
Environmental Protection Agency
Region 1
John F. Kennedy Federal Building
Boston, Mass. 02203
Attn: Environmental Policy Coordination Office
Subject: Draft E.I.S.: Wastewater Treatment and Collection
Facilities, New Milford, Connecticut
Dear Sirs:
The State Historic Preservation Office has reviewed the above named Draft
Environmental Impact Statement (E.I.S.)• The archaeological special
studies - 1975 section is erroneous in that the State Historic Preservation
Officer has not initiated National Register of Historic Places nomination
procedures with respect to the archaeological site located at the proposed
treatment site on Pickett District Road. The State Historic Preservation
Officer has requested clarification from Dr. Frederic Warner, Connecticut
Archaeological Survey,Inc. project consultant archaeologist, as to several
inadequacies within his reconnaissance survey report concerning descriptions
and significance of the recovered data from the treatment plant area. None-
theless, the archaeological site located at the treatment plant site may be
eligible for the National Register of Historic Places and, as such, Advisory
Council Procedures 36 CFR 800 should be applied in this situation.
When routes are finalized, reconnaissance surveys should be undertaken for
the East Aspetuck and Southerly Interceptors in order to locate, identify,
and assess the significance of archaeological resources within the project
area. Surveys should be conditioned to include the preparation and submis-
sion of a written report for State Historic Preservation Officer cultural
resource review purposes in accordance with the legislative responsibilities
of National Environmental Policy Act (P.L.91-190), National Historic Preser-
vation Act of 1966 (80 Stat 915, 16 USC 470 as amended), and Advisory Council
Procedures 36 CFR 800.
In the opinion of the State Historic Preservation Officer, this project will
have no impact on historical and architectural properties listed on the National
Register of Historic Places or eligible for the National Register of Historic
Places. However, as noted above, this project may have an impact on archae-
^ 9
STATE HISTORIC PRESERV ATI ¦ )N OFFICER: The person responsible for implementation in Connecticut of the National
Historic Preservation Act of 1966 administered by the Department of the Interior, National Park Service, Washington, D. C.
-------
Environmental Protection Agency (Cont'd) - 2 -
Boston, Mass. 02203
February 28,1977
ological resources which may be eligible for the National Register of
Historic Places, and Advisory Council Procedures 36 CFR 800 should be
applied.
For further information, please contact David A. Poirier, Archaeologist,
Connecticut Historical Commission.
Sincerely,
DAP:aas
cc: Mr. Jordan Tannenbaum
Advisory Council on Historic
Preservation,
Wash ing ton, D.C.
John W. imannahan
State Historic Preservation
Officer
Dr. Frederic Warner
Connecticut Archaeological Survey,Inc.
Mr. David Clark
National Park Service
Mid-Atlantic Regional Office
Boston, Mass. 02114
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DOCUMENT Rll
of ffifltmwtirut
HOUSE OF REPRESENTATIVES
STATE CAPITOL
HARTFORD. CONNECTICUT 06I1B
Walter J. Conn
Sixty-Seventh District
225 DANBURY ROAD
NEW MILFORD, CONN. 06776
February 21, 1977
U.S. Environmental Protection Agency
Region I
JFK Federal Building
Boston, Massachusetts 02203
Technical Consultant
Anderson-Nicholas & Co., Inc.
Boston, Massachusetts
lie: My statement prepared for the hearing held on Tuesday,
February 15th, New Milford High School, Environmental
Impact Statement, Wastewater Collection and Treatment
Facilities, New Milford, Connecticut.
Gentlemen:
I am Walter J. Conn, State Representative from the
67th District serving Roxbury, Washington, Bridgewater and
New Milford in the General Assembly in Hartford. My address
is, 225 Danbury Road, New Milford, Connecticut 06776.
I would like to start my remarks off by saying I have
heard no one say we do not need some increase in plant size and
improvement in our area now covered and also an increase in the
area to be sewered.
We did by town meeting on April 24, 1972 and also by
referendum decide to allow the town to bond for 11.5 million dollars
which says, I believe, the sewer authority when the plans are finally
approved by the state and federal agencies must move to build.
The area, I believe, we should be sewering is that area
where it is or can by our increased use pollute the so called
aquafier of the Housatonic Valley extending along the Housatonic
Valley to Boardmans Bridge approximately and East Aspetuck River,
also Great Brook which originates on the west side of town.
FEB 2 c 1077
-------
Page IT
February 2¦, 1977
I do not believe we oar. or should concern ourselves
with trying to service New Fairfield or the New Preston area of
Washington. These and all outside areas of Kew Milford must and
can be controlled and corrected if problems exist by our Town
Sanitarian and Health Office working in conjunction with all
town and state offices, such as the planning and zoning, selectmen, etc.
'"his town has 64 plus square miles of area, a good portion
of which it is our responsibility to keep in it's rural state. It
is also the duty of our surrounding towns to protect the environment
equally as well.
The terrain in most of the outlying areas of Kew Milford
and surrounding towns is such that, installation of sewer lines would
be a major and unneeded project. It would only destroy the New England
character we are trying so hard to keep. Any building of any type
built outside the sewered area should and must be strictly controlled
and nothing larger than single family dwellings should be authorized.
Any multiple housing must be kept in areas of our ability to sewer.
Regarding the town of Brookfield, they are part of the
so called aquafier being in the Still River Valley and they have
a duty to protect it. If the Federal E.I.S. says we should take a
part of Brookfield which it appears they will. Then it is their
duty to fund the plant and size accordingly. Lines and area covered
also by their decision and judgement.
Now we have established wnat I believe are the areas, I
will try to give my beliefs on the plant and building program. I cr
any laymen is not qualified to decide the size of the plant the
experts who are hired for this purpose must decide. When it comes
to general statements regarding areas of ideas everyone should express
their views.
It is my belief any plant we build should be equiped to
handle tertiary treatment for the removel of phosphates. It is our
duty to protect our river in everyway possible. I also understand it
would be completly funded by state and federal funds, as it should be.
The federal governeant is mandating this program, they should pay
the bill.
-------
Page III
February 21, 1977
Regarding all trunk lines, piimping stations to
deliver to the plant are completely funded by the federal
and state governments. It is my belief included in trunk lines
should be a system of delivery of seme of the effluent from the
plant up to the Sunny Valley Farm for use by them on an
experimental basis, when conditions exist to prove their worth
in land treatment. This can be done with very little extra expense,
as lines vr"" 1 have to be layed in those areas. This can also and
should be funded by the federal and state government.
The proper authority of the town should at the earliest
possible time, with the proper help from federal and state officials,
make application for funding of laterals as were brought to our
attention just before the February hearing. This then puts the town
in the position of having to fund a small portion of the laterals
and the users of paying for the operation cf the plant.
It is the duty of the Federal 3.I.3. preparer to also
include in the final document the approximate cost of every aspect
of this system and to recommend some measure of equal participation
of all new additions to this system in the future to also protect
those who are now participating from being unduly burdened.
I do not normally believe in being so eager to accept
federal and state funds for projects, however, after reviewing our
position in this matter and knowing we in Connecticut send
approximately $1 .33 to Washington for 31.00 return, while our friends
in the south send 3 ,6'-} and up and receive 31.00 return, I feel we
are owed and should have this plant, especially after the statement
by E. I. S. that they would be the final decision maker.
Immediatley upon receiving the final decision from
2. I. 3. a meeting of all interested parties should be called.
The appropriate persons from the federal and state agencies must
then brief all town officials, planning commissions, sewer commissions,
selectmen, etc., in all aspects of the program.
-------
Page IV
February 21, 1977
It would be ny final observation that any future
programs in any areas of government involving federal, state
and local input be brought to a decision by the legislative
body of the town only when a complete and final statement can
be offered for their judgement.
I should also add that some statements relative to
hearings and their use made by persons in some of our state
departments do not reflect my views on how our government should
operate and. a full investigation of persons serving you and I
must be a continual process, otherwise, we become servants to
our government instead of their serving us.
Thank you for your consideration.
Sincerel:/ yours,
'¦'alter iK Conn
State Representative
District 67
-------
DOCUMENT R12
PLANNING COMMISSION
TOWN or Nl-w MILI*Or5NTAL IMPACT STATEH5HT
"WASTEWATER COLLECTION AND TREATI-SNT FACILITIES
NEW MLPORD, CONNECTICUT"
The draft E.I.S. concerning the proposed facilities in Now Milford displays, on
tho whole, a good understanding of an admittedly very involved and to somq degree
emotional issue. There are, however, in the opinion of the Planning Commission,
a number of instances where outdated and erroneous assumptions are used to sup-
port the conclusions of the draft E.I.S.
In other instances the conclusions advanced completely ignore recent changes in
laws and/or priorities.
The E.I.S. draft nakes no attempt whatsoever to substantiate or refute the neces-
sity, or lack thereof, of sewering tho entire area of New Milford covered under
what is commonly referred to as Phase I.
The justification for the unchallenged acceptance of Phase I construction rests
on such general statements as found on Fage 42. We would like to particularly
challenge the following paragraphs found on Page 42.
42-1 The early EGP orders to the towns contained both specific state-
ments and inferences to the types of problems described above. The
engineering roports prepared for the towns, in response to the
orders, generally allv.dad to tho second' t/yr>e of problem. Interviews
with town snnitarians a'irost- always expressed similar concerns,
especially snail lot development exists.
42-2 While documentation of actual ease histories in the study area of di-
sease transmission is rare, the conclusion that intensive shore devel-
opment threatens water quality remains. The coliform measurement pro-
grams of the state, towns, and lake associations reflect the continued
vigilance for water quality problems of this typo.
The New Milford Planning Commission did not receive one formal request during the
past seven years for help and/or assistance in the updating or strengthening of
the applicable sanitary code.
Yet tho authors of this $40,000o00 document justify a substantial part of a 30-
rdllion dollar project with statements and I quote Page 182, bottom paragraph...
-------
-2-
"Stage I is basically in responoo to pist and existing nood..." or Pag© '1-2...
Generally allude to the second tyng of problom. Interviews with Town Sanitarians
almost always expressed similar concerns... Surely, there must bo concrete ex-
amples to substantiate a project which will have such profound long-term implica-
tions for the Town of New Mi'lford,. a« well as the Region, The Now Mllford Planning _
Commission has supported the improvement of wastewater treatment facilities in_ tho__
pasFand does so at present..^ Wo believe yery strongly, however, that a groat num-
*Der"of conditions have changed since the original conceptional approval in 1972.
The changes since 1972 require a serious reordering of priorities and not a docu-
ment supported by allusions and generalities. The draft E.I.S. for example com-
pletely fails to consider in its conclusions that the sewer area covered in Phase
I is in substantial conflict with recent water management studies undertaken since
1970.
For example: "The State of Connecticut Plan of Conservation and Development",
Figure 3» has identified a substantial potential reservoir and a high priority
aquifer within the area proposed for sewering during Phase I,
The Water Management Study Phase II prepared for the Rousatonic Valley Council of
Elected Officials in 197^ lists the East Aspetuck River Reservoir as the single
most productive reservoir with a safe yield of ten million gallons per day or ap-
proximately 40$ of the potential reservoir sources identified in this report.
The major trunk sewer along Paper Mill Road and the East Aspetuck River through
this very same area would most certainly foreclose any future possibility of having
the water reservoir potential of this area realized. The sewering of this water-
shed is in direct conflict with the policy statement included in "St»te 'of Connecti-
cut Plan of Conservation and Development". which states in part, "It is State policy
that sevorinr: which r*av entourage extensive residential development, not be per-
mitted within these areas.'1
The same conflict exists with the major aquifer on the Westerly side of the Housa-
tonic in an area bounded approximately by Sunny Valley Road, Jerusalem Road, and
to a degree, Route 7 North and Candlewood Lake Road North. Two trunk sewer lines
are projected to serve the entire area covering this very important natural re-
source 0
The reliance of both Anderson-Nichols & Co. and Metcalf & Eddy on Planning Com-
mission acceptance of the present Phase I sewer area in the land use designation
adopted in 1971 is simply no longer justified.
The basis of the aforementioned water management studies are only one reason for
our opposition to the proposed plan. Other factors, equally important, must be
considered in the light of the conditions prevailing in 1977 rather than 1971*
The relative mix of new residential, commercial, and industrial development is a
very important factor in the future character of any community. The E.I.S draft
properly states the aim of tho New Kilford Plan of Development as well as the later
CDAP document. "....Industrial and commercial growth be encouraged to provide local
employment and a tax base in balance with anticipated residential growth..." This
stated community objective has been substantiated again and again during community
surveys.
The proposed phasing of the wastewater project in both the present MstenIf & Eddy
as well as Anderson-Nichols positions is in sharp conflict with New Milford's aim
for balanced growth.
-------
-3-
Vory little, if any, induced industrial development can bo anticipated by Phaso I
of the sewor project due to its primary orientation towards areas most suitable
for residential development. In addition, when the Plan of Development was up-
dated in 1971, the proposed "Super S^ven" was slated for completion by 1980. This
now road was assumed to bo a major inducement for commerce and industry to locate
in industrial areas located near interchanges.
The present indefinite tine table for further construction of U.S. 7 North of
Brookfield requires a substantial reordering of priorities if the Town of New Mil-
ford is to maintain its socio-economic balance. To accept .the phasing of this
project supported in the draft E.I.S. is simply not acceptable to the,New Hilford
Planning Commission, for New Milford. The thrust of Phase I must be oriented to:
1, Preserve the water resources mentioned earlier;
2« limit induced residential growth;
3, Encourage industrial development in industrial areas reasonably well access-
able through the existing transportation networko
The need for this re-orientation of all phases of the sewer project on the basis
of 1977 conditions, can be illustrated by data from Table 18, Page 96.
Daribury's population is projected to increase from 51*769 in 1980 to 57,67^. or
approximately 11$, while the places of employment both in manufacturing .and non-
manufacturing are slated to rise from 31»218 jobs to 38,058, or 22$ approximately.
The prognosis for New Kilford shows a population growth from 19,000 in 1980 to
22,000 in 2000, or an increase of about 16$, while jobs (the number of new factor-
ies, offices, and stores) are projected to rise from 6tklZ to 7,129, or again,
about I65&,
However, if we use population figures which include the induced growth due to the
availability of sewers, Table 25, Page 213» we 6ee the population of New Milford
increase from 21,500 in 1980 to 32,000 in 2000, or ^8$, while the inadequate
transportation network and the built-in bias of the presently proposed sewer pro-
ject in favor of residential growth makes corresponding influx of new manufacturing
facilities unlikely.
The New Milford Planning Commission has considered the substantial amount of data
available on this project in conjunction with the information contained in this
draft E.I.S. during several meetings and it is the unanimous opinion of the
Commission that the adoption of the 30-million dollar sewer project as it stands
now, or the slightly modified version recommended by the draft E.I.S.,is contrary
to the objectives pursued by the Commission.
The Commission is in full agreement that the proposed course of action is contrary
to the long term as well as short term interests of the Town of New Milfordo
The negative implications of this sewer project are recognized by Anderson-Nichols
as well. As an example we quote Paragraph B.3»h.2 on Page 218 Regional....
-------
Jj~
Rogional housing plans should bo developed with pirticular relation-
ship to providing low and moderate income housing in proximity to
existing or proposed economic development. By providing r; ewers to
serve' housing ar<*as, Now Mil ford my be able to serve such a rood,
but at gro-'.t distar.ee from .iobs ar=d at a tax b'ire deficit v?hich may
not be bal-'ir:rod by it.:; own nconor'ic fVQ'.itho
The Planning Commission recommends a drastic re-orientation of the entire program
including Phase I and would be happy to provide detailed recommendations to that
effect to Anderson-Nichols and/or the U, S0 Environmental Protection Agency,
Very truly yours,
Oskj
¦ary
OGR/bfc
-------
Architecture
Engineering
Planning
85 Willow Street
New Haven, Conn. 06511
(203) 562-2181
M.H. Lincoln
Lawrence Moore
Humbert V. Sacco Jr.
E. Paul Lambert
William 6. Aniskovich
Kermit 0. Thompson
Gary R. Mueller
February 15, 1977
Mr. Clarence C. Mitchell, Jr.
Chai rman
New Mil ford Planning Commission
Town Hall
New Mil ford, Connecticut 06776
Re: Environmental Impact Statement
New Mil ford's Proposed Wastewater
Collection and Treatment Facilities
Dear Mr. Mitchell:
In accord with your instructions, I wish to submit the following with regard
to the Environmental Impact Statement submitted for New Mil ford's Proposed
Wastewater Collection and Treatment Facilities.
New Mil ford is situated at the northerly edge of what is the fastest growing
sector of the State of Connecticut and one which will see dramatic change
in the next decades. Your Commission is responsible for the guidance of that
change to insure orderly growth within reasonable economic, social and phy-
sical limits. To achieve this objective, New Milford prepared an Updated Plan
of Development in 1972, which plan was carefully detailed and organized to
accorranodate a realistic balance of growth and-environmental control.
Two factors played a very important role in the preparation of the Updated
Plan: (1) The 1967 Plan for expansion of New Milford's sewer facilities and
the proposals by the Connecticut Department of Transportation for the recon-
struction of Route 7 into New Milford. While both of these factors are support-
ing facilities, they also act as catalysts for growth. The Play of Development
was carefully coordinated to balance their impact. Since the Plan of Develop-
ment was updated, the Route 7 situation has been drastically altered. New
construction was terminated well south of New Milford's boundary. Department
of Transportation officials informed us in late 1975 that the remainder of
Route 7 into New Milford would not be constructed until 1990. We were further
informed that the State is not proposing any alternate means of traffic improve-
ment.
At the same time, the sewer facilities program has been expanded beyond the
1967 Plan to now include providing sewer service to over 25% of New Milford's
-------
S©fWl€®
Mr. Clarence C. Mitchell, Jr.
February 15, 1977
page two
land area - an area larger than the total area of many of Connecticut's
communities.
One of the principal objectives of New Mil ford's Updated Plan is in danger of
being violated - the construction of a growth factor without concurrent con-
struction of the necessary supporting transportation facilities. It is our
recommendation therefore that prior to the construction of any new sewer
facilities, the provisions of the 1967 Sewer Plan, as well as all plans which
follow, be reevaluated. It may in fact be necessary to reduce the proposals
contained in the 1967 Sewer Plan.
There are several items in the Environmental Impact Statement which could
present problems to your Commission in the future.
Throughout the report, there is reference to growth in vacant land areas,
which growth is based on present zoning. Present zoning in these cases is
based on the ability of the soil to support on-site sewage disposal facilities.
When a sewer is constructed, the soil conditions are no longer critical.
It is our opinion that it is not correct to make the assumption the report does
concerning development densities. Our experience and the experience of many
communities in the State has indicated that when sewers are constructed adja-
cent to vacant land there is substantial pressure for zone changes to higher
density construction. It may be very difficult for your Commission and the
Zoning Commission to combat such pressure since soil conditions are no longer
a factor.
Pages 209 and 210 of the Environmental Impact Statement discuss induced de-
velopment and population. A comment is made recommending "that the Updated
Plan of Development be revised to mesh residential densities with proposed
sewer service areas". This is a direct contradiction to the sewer plan's
earlier references to new development occurring at present zoning densities.
There may also be a legal question. In Connecticut, the planning function in
a community is vested in the Planning Commission. The above statement implies
that the sewer plan and the Sewer Commission become the planning body for New
Milford. The situation should be reversed. The sewer service areas should
be revised to reflect the intent of the people of New Mil ford as printed in
their Plan of Development.
-------
Mr. Clarence C. Mitchell, Jr.
February 15, 1977
page three
A reference is made on page 213 of the Environmental Impact Statement regard-
ing the "possible desirability of having sewers from a developer's viewpoint".
This is a gross understatement. There is no question that sewers adjacent
to vacant land will indeed be an "inducement". One only has to look at adja-
cent communities to understand the situation which will occur.
Page 215 comments on the fact that a "downzoning suit" can be defended given
present zoning and sewer capacities. I cannot agree with such a generalized
statement. It is my opinion that a basis for upholding present zoning in
potential sewer areas is if the present character of a neighborhood is so well
established that downzoning will affect property values. With soil as the
basis for zoning, I can envision difficulties for your Commission. Page 215
of the statement does indicate that some "downzoning" may be required to pro-
vide housing for senior citizens and low and moderate income groups. This
factor should be carefully considered again by your Commission prior to the
completion of New Mil ford's sewer program. Such factors were considered in
1971 and 1972 when the Plan was updated. However, with proposals for such
substantial expansion of the proposed sewer system, the higher density de-
velopment could occur in areas difficult to service with other community
facilities.
In January of 1976, we recommended that your Commission be given the opportu-
nity to work closely with the sewer consultant in an effort to resolve some
of the above questions and to avoid having to "review" the Environmental Im-
pact Statement when completed. Since this did not occur and since a review
had to be made quickly, we have only been able to address ourselves to the
planning provisions of the Statement. We trust the above will be of assistance.
lumbert V.
TPA Services
ftecttvgDjs, t97 7
Sognrrmo r« oefi
feo is , J977
HVSjr/jp
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DOCUMENT R13
TOWN OF BROOKFIELD
SEWER BROOKFIELD CENTER. CONN. 06805
COMMISSION
February 18, 1977
Mr. Stuart C. Peterson, Chief
Municipal Facilities Branch
U, S. Environmental Protection Agency
Region 1
J. F. Kennedy Fednral Building
Boston, Massachusetts, 02203
Dfjar Mr. Peterson:
Enclosed is h copy bf the Resolution adopted by tha
Brookfield Sewer Commission at n Special Meeting on
February 9, 1977. This Resolution la in conaldaratlon
of alternative procedures far Bewaring the Nortfi and
Central Areas of Brookfield.
Sincerely yours,
Judith A. Fisher
Clark, Bewar Commiesion
1 Erie*
Jf
-------
RESOLUTION
WHEREAS, The Town of Brookfield has been considering
alternative procedures for sewering the North and Central Areas of
Brookfield since the first orders were issued by the State Water Resources
Commission in Kay, 1967, and since more specific orders were issued by the
State in December, 1972; and
WHEREAS, these orders resulted in a "Comprehensive Sewerage
Study", dated October, 1968, a "Supplementary Sewerage Study" dated
April, 1972, and a stvdy entitled"North and Central Areas, Study of
Alternative Routes" dated April, 1975, find the "Study of Sewer Needs"
dated December, 1976, with each report recommending prompt action in
sewering sections of the North and Central Areas of the Town; and
WHEREAS, public meetings have been held on several occasion?,
providing information to residents regarding concepts for sewering the
North and Central Areas; and
WHEREAS, a contract has been signed with the City of Danbury based
on a limited flow from the Southwest Area in Brookfield, and a separate
agreement has been executed with the Town of New Milford providing for
treatment facilities and intercepting sewers for service to the North and
Central Areas of the Town; and
WHEREAS, the need for sewers has been substantiated and documented
in the following publications:
A) Study af Sewer Needs, December, 1976,
B) King's Mark Environmental Review Team Report on the General!
Purpose Zone (as to industrial needs only)*
-------
2.
C) The Draft Environmental Impact Statement issued by the
United States Environmental Protection Agency, dated
November, 1976,
D) Correspondence from the former Town Sanitarian; and
WHEREAS, the Stat^ and Federal grant funding programs will
terminate this year, and may only be renewed for short periods; and
proceed with a program for final planning, grant funding,
and construction of sewers in the Areas of Immediate Concern
as outlined in the "Study of Hewer Needs" dated December,
1976.
B) The plan selected by the Corr.m.lssion shall be Alternate 3 aa
described in the April, 1975* report entitled "North and
Central Areas, Study of Alterhative Routes", which includes
a connection across Elbow Hill Road, and a trunk sewer flowing
north into New Milford along the Still River Valley.
C) The Commission's Engineer shall submit an outline of the steps
which must be undertaken by the Commission to accomplish this
purpose, and shall also submit a proposal for the Engineering
services involved, by February 23, 1977*
D) Copies of this resolution shall be forwarded to the Board of
Selectmen, Planning Commission, Zoning Commission and Board
of Finance, for their information.
NOW, THEREFORE BE IT RESOLVED THAT:
A) It is the intention of the Brookfield Sewer Commission to
ADOPTED AT THE COMMISSION MEETING ON
FEBRUARY 9, 1977
Sewer Commission
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DOCUMENT R14
TOWN OF BROOKFIELD
BROOKFIELD CENTER, CONN. 06805
February 15, 1977
Department of Environmental Protection Agency-
Re: Environmental Impact Study
Brookfield Sewers
Gentlemen:
As the future of Brookfield includes an ever-increasing population and
commercial and industrial development, it is apparent that the water re-
sources of the town become more and more important. Consequently, to
facilitate the logical and economic development that will be required in
the not too distant future, the Brookfield Industrial and Commercial
Development Commission supports the sewering of the Route 7 corridor.
The Kings Mark Environmental Report has indicated that there is a great
water resource running parallel to the Still River through the Route 7
corridor. Since this water resource is readily available, it is of the utmost
importance that the town take the necessary action to prevent its pollution.
If this sewering of the Route 7 valley is accomplished within a reasonable
length of time, this extremely important water resource will not be polluted
and will continue to be available for the entire town's benefit. We feel that
it is of the utmost importance to avoid contamination of natural resources
such as this to assure that the town has a continuous supply of water for the
forseeable future.
We find this stand consistent with the normal, logical economic development
that we forecast for this area within the next five to ten years. Consequently,
we urge the town of Brookfield to seriously consider protecting this vital water
resource by avoiding the pollution that may be generated by the normal devel-
opment that we will experience in the future.
obert
RHW/ljd
Brookfield Industrial and Commercial
Development Commission
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DOCUMENT R15
Slofon £Jffn Jfairfirld
TOWN HALL
NEW FAIRFIELD, CONN. 06810
(203) 746-2448
COMMENTS BY JOHN FAIRCHILD, FIRST SELECTMAN, TOWN OF NEW FAIRFIELD,
CT. AT 2ND WORKSHOP MEETING ON ENVIRONMENTAL IMPACT STATEMENT FOR
THE WASTEWATER TREATMENT AND COLLECTION FACILITIES FOR NEW MILFORD.CT.
WE HAVE REVIEWED THE DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR
THE WASTEWATER TREATMENT AND COLLECTION FACILITIES FOR NEW MILFORD, CT.
AND HAVE THE FOLLOWING COMMENTS TO MAKE RELATING TO NEW FAIRFIELD'S
INVOLVEMENT IN THE STATEMENT:
(1) SINCE NEW FAIRFIELD, AFTER COMPLETING A SEWERAGE STUDY ORDERED BY
¦jiC
THE DEP, BECAME A PART OF THE AREA TRIBUTARY TO THE NEW MILFORD SEWAGE
TREATMENT FACILITIES, IT IS OUR JUDGEMENT THAT ONLY THE DEP CAN REMOVE
IT FROM SUCH TRIBUTARY AREA.
THE DECISION TO INCLUDE NEW FAIRFIELD IN THE NEW MILFORD AREA WAS
NOT TAKEN CAPRICIOUSLY BUT ONLY AFTER CAREFUL STUDY BY OUR CONSULTANTS,
WHICH STUDY CONCLUDED THAT, AT 1973 COSTS, NEW FAIRFIELD WOULD SAVE
ABOUT 4 1/4 MILLION DOLLARS IN CAPITAL COSTS PLUS THE CAPITALIZED
COSTS OF OPERATION AND MAINTENANCE BY ROUTING ITS FUTURE SEWAGE TO
NEW MILFORD INSTEAD OF TO DANBURY. THIS WAS PREDICATED ON THE ASSUMP-
TION THAT, IN DUE COURSE, DANBURY WOULD BE REQUIRED TO PROVIDE COMPLETE
TERTIARY TREATMENT AND NOT JUST PHOSPHATE REMOVAL.
WE CAN AGREE TO OUR REMOVAL FROM THE NEW MILFORD TRIBUTARY AREA
IF ASSURED BY THE DEP THAT NEW FAIRFIELD WILL NOT INCUR ANY EXTRA FU-
TURE COSTS BY REASON OF THIS SEPARATION. PRESUMABLY, THIS WOULD OCCUR
IF BOTH THE NEW MILFORD AND DANBURY PLANTS ARE PROVIDING THE SAME DE-
GREE OF TREATMENT AT THE TIME NEW FAIRFIELD MAY BE REQUIRED TO INSTALL
SEWERS, WHICH WE DO NOT ANTICIPATE WITHIN THE USEFUL LIFE OF EITHER THE
NEW MILFORD OR DANBURY TREATMENT PLANTS.
(2) BECAUSE WE DO NOT ANTICIPATE ANY SEWERING OF NEW FAIRFIELD IN THIS
CENTURY, OR PERHAPS EVER, WE WOULD AGAIN STRESS OUR OPPOSITION TO SEW-
ERING OF ANY PART OF CANDLEWOOD BASIN IN ANY OF THE FIVE TOWNS BORDER-
ING THE LAKE. IT IS OUR JUDGMENT THAT THE WATER QUALITY OF THE LAKE
WILL BE BEST PROTECTED BY SUCH A POLICY. ACCORDINGLY WE WOULD REQUEST
THAT THIS EIS RECONSIDER THE INCLUSION OF PORTIONS OF NEW MILFORD AND
BROOKFIELD WHICH ARE LOCATED WITHIN CANDLEWOOD BASIN IN THE AREA TRIBUTARY
TO THE NEW MILFORD TREATMENT FACILITIES AS STAGE III OF THE PROJECT.
JOHN FAIRCHILD,
FIRST SELECTMAN
-------
DOCUMENT R16
cnsezvation
ommtsuOH
tLA/jewalet.. (..-rwtectuul Ot) ~752.
March 3, 1977
To: United States Environmental Protection Agency
From: Town of Bridgewater-Conservation Commission
Sirs:
A review of the draft E.I.S. written for the town of New Milford
prompts the following statement from our commission.
Within the township of Bridgewater there are approximately four miles
of land frontage along lake Lillinonah which forms the western boundary of
the town. The lake, as it exists today, is practically unusable due to
pollutants from towns either north along the Housatonic, or south via the
Still River. The lake borders are, for the most part, quite rugged and
practically undeveloped. The lake itself, could and should be the towns
largest natural resource. However, we cannot swim in the lake, eat fish
from the lake, or even boat with any pleasantness during the summer algae
blooms.
We feel quite frankly, that you are writing off the Housatonic River
as a wastewater stream with your proposal of a secondary treatment sewage
plant at the confluence of the Still and Housatonic Rivers in New Milford.
We must further assert that you are ignoring the Federal Water Pollution
Control Act, Amendments of 1972 - Public Law 92-500, which calls for the
confining and containing of pollutants not recycled, and the reclamation
of wastewater.
The proposal to gather sewage wastes from thousands of acres of land
by pipeline and septage truck, and bring them to a river for disposal and
ultimate dispersion is not forward thinking. In our training as Boy Scouts,
we learned early that when you must dispose of waste you do not go to a river.
The best answer, in our minds, is of course to recycle the waste and
hopefully put it to some use or at least dispose of it away from water.
In the enclosed newspaper article we notice that Richard Woodhull, Chief of
the Connecticut State Health Department's Water Supplies Division, is
recommending land-treatment for Litchfield sewage since area towns are
getting thirsty and are looking for clean water. The Shepaug River which
forms part of our towns eastern boundary is suddenly valuable. We demand
the same standards for the Housatonic. The need for clean water can only
get more severe in the future. We insist that you take the necessary steps
to insure a clean Housatonic for us and the generations to follow.
Sincerely
Dennis L. Ketchum
Secretary
-------
SOt st Newsstand
Danbury, Conn. 04810. Sunday, February 27, 1977
Phone 744-5100 !Conn.) - 179-80 38 (N.Y.)
Future water source?
Area thirst leads to Sinepanij
By Michele Derus
News-Tunes staff
Area towns' thirst for. new water
supplies have led them to the banks of
the Shepaug.
The Shepaug River, which flows
through Washington and Roxbury, is
clean, plentiful and relatively close.
Unlike aquifers, its location can be
pinpointed and its waters easily
drained.
Unlike wells, it can't dry up or move
out of reach and isn't likely to become
contaminated from nearby septic
systems.
F\imping the Shepaug from Roxbury
Falls to Danbury area towns is not a
new idea. The possibility was suggested
by state health officials and the region's
consultants a decade ago.
Towns preferred instead to designate
Candle wood Lake their emergency
supply, despite the lake's recreational
use and intense surrounding
development.
Sewage discharges into the lake make
use of Candlewood as drinking water
illegal. Sewage concentrations were
high enough in the Lattin's Cove area
last summer to close beaches.
In response to evaporating water
surplus*^ and brisk growth, the eight-
town llousatonic Valley Council uf
Elected Officials die decide last year to
invest $12,500 in a ftudy of Newtown's
Pootatuek aquifer. The aquifer, or
underground water storage area, is
hoped to yield nore water than
Newtown needs. If so. the town has
agreed to share any surplus.
Little else has been done to alleviate
an increasingly tight supply, however.
Regional water shortages, especially
in Danbury, Bethel and Ridgefteld,
were predicted in 1969. 1970 and 1974
government and private studies. The
News-Times updated the growing
problem in a special series of articles in
late 197$.
Since then. Bethel has undertaken a
$1.9-million project to meter its
customers and improve distribution and
storage of the municipal water supply
Bethel First Selectman Francis
Clarke predicted this week the project
will be completed this summer.
Our basic problem was we couldn't
trap and filter our water properly. Our
second problem was a lack of storage
capacity." he said New equipment will
alleviate both problems, according to
Clarke.
Metering all customers "will equalize
cost and encourage conservation.'' he
said "There's a dramatic effect 'W
water use when meters go in. A lot of
businesses and people who let wat«*
leak and leak and leak suddenly realize
how much water — and money — that
wastes."
Clarke anticipates the project will
remove the immediate danger of
shortages, "but we still are in trouble in
the U>r w of several potential areas
lh-*;£h "
A'-kiJ whi'tiiir he considers supply
' tight'. as state health officials say.
SchweJzer said. "No. not as Ion* as
thor«* are certain conservation
i..ei-yes we tan tak*» Metering for
; n_*.!.»n • v
Mr- nnt' eity water users Mould t.ike
' a tmplt uf years." he said, which is
"Vrrr.i? as quirk as devrloping another
snurrt
Pubic Utilities Supt. Ralph Welch
said Danbury's supply is about nine
Coeilaued oa Page A4
Thirsty area looks
to Sliepaug River
Coattaaed from Page A-l
million gallons per day. Average use
was 6.3" million gallons per day ;a 1975
and 6 S2 million gallons per day ia 1276.
Water use peaked at 8.8 million gallons
per day last August,
million pallors per dav last August.
Welch doesn't think city residents
have to worry about this situation, "at
least in wet years. We mi^ht have
pn»!>!».'ins in dry years," he added.
Ridge/icld has a few wells now. which
First Selectman I»uis Fossi said took
the edge off his town's supply problems.
He too predicted future problems if a
major new water source isn't found.
Jack Green, llousatonic Valley
Council planner, and engineer for
Bethel and Ridgefield. said a few towns
will experience outages if they don't act
soon.
"Mareerie Reservoir was the last big
r'w supply and that was in the '30's."
(>:* ;-n ' 'Ihe only real r.ew v/jree
fnn> has be»'n the Kenosia wells.
.*•?« .;nv.'hile. the town:? keep adding
P» '-pir and adding people.
"American-; ;-re used to reacting to
rm:« situations." Green said But this
is one problem you can't press a button
to make go away. Any solution will Lake
yars."
Green said he favors tapping the
Shepaug. a move Fossi also endorses.
"The cost of acquiring enough land for
new surface water supplies would be
absolutely prohibitive," he said. "We
could try for oew ground vater
supplies, but we'd have to drill zod test
a lot and I'm not convinced thf supply
would be worth it.
"Tapping the Shepaug would to
expensive, but we wouldn't have high
treatment costs .because It's already
clean ar.d it wouldn't carry the social-
political impact of other alternatives."
he said. "We wouldn't affect
recreational activities hecause we'd be
usir.g waf^r from below that."
The concept is heartily endorsed by
Richard W.xdhull. chief of the state
health dc-parLxent's water supplies
division. Stamford a,nd Norwalk already
are considering the proposition, he said.
"It's a clean stream, pd do:;bt about
that," Wi/idhull said. "The one
exception is a tertiary-treated
dis:harpe. I ili:;ik ;r..;n Lrn.i.i.c-ld. ti-al
JwouM have t'i hi' divrj'.f-d onto land
instead."
Woodhull said he's advised the
Housatonie region to explore the
Sh^paug's possibilities
"It w-'iifi have to be a repi'inal
undeitakinp and someone has to take
the lead.' he said "Frankly, I h^ped
Danbury would since they have the
grejier need."
Green and Fossi said they will
suggest this year's council budget
include an appropriation for studying a
Shepaug river tap.
"At this stage, we'd better do
something." commented Green. "Look
at the drought In California and the
western states. That happened to as
once and we can't count on luck
forever."
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DOCUMENT R17
imp. 7 B?T
Sunny Valley Preserve
4 SUNNY VALLEY LANE • NEW MILFORD • CONNECTICUT 06776
Telephone (205) 354-0321
March I4., 1977
Environmental Protection Agency
Attn: Environmental Policy Coordination Office
Room 2203
John F. Kennedy Federal Building
Boston, Mass, 02203
Re: Draft E.I.S. Wastewater Treatment and Collection
Facilities for New Milford, Conn,
Gentlemen:
On page 17i|. of the Draft Environmental Impact Study for
New Milford, there is an incorrect statement that should be
eliminated or corrected. In the second full paragraph, it states
that findings of excessive nitrate concentrations in the ground-
water in the proximity of Sunny Valley Farm is "attributed
by the Connecticut Department of Health to the farm's use of
fertilizer."
If the Department of Health did make such an attribution
officially, you will find that it undoubtedly was based on an
earlier claim about the source of the high nitrate accumulation
made by the Department of Environmental Protection. That claim,
it turned out, was not based on sound data. It was, in fact,
more opinion than truth.
The D.E.P.'s unsupportable claim was taken up by our coun-
sel with the officials responsible for the assertion, and it was
pointed out to then that their actions constituted a potential
liability to the farm that we viewed with great concern. We,
Indeed, retained a well known groundwater expert from the Univer-
sity of Massachusetts to advise us on this matter. Eventually
the D.E.P. revised its claim substantially. A copy of the letter
revealing the change of position is attached.
A review of this correspondence will, I assume, lead you
to correct the statement on page 1714- of the draft E.I.S. There
has been no proof of the farm's fertilizer contaminating the
aquifer underlying the property.
Cordially yours,
National Office: 1800 North Rod Strut, Arlington, Virginia 22209
Chairman
-------
STATE OF CONNECTICUT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
State Office Building Hartford, Connecticut 06115
July 19, 1976
Mr. Leonard Stevens
Sunny Valley Farm
Sunny Valley Road
New Mil ford, CT 06776
Dear Mr. Stevens:
As you requested during our recent meeting of July 8, 1976 at Sunny Valley
Farm this is to clarify our position with the respect to item No. k of our
letter of February 19, 1976.
In our correspondence we had made a general statement concerning the source
of nitrates to municipal and public wells in the area which has caused you c
great deal of concern. We would like to clarify this statement by saying that
from the data we have gathered there is a high priority aquifer which lies
beneath the Sunny Valley Farm and flows northward beneath Sunny Valley Estates
and eventually reachs the Housatonic River. Nitrates enter this aquifer from
farming operations at the Sunny Valley Farm and from various other sources in
the Sunny Valley Estates area including septic systems and the use of lawn
fertilizer, etc. It is impossible at this time to quantify the nitrates originating
from the various sources as they may collectively affect individual wells located
north of the Sunny Valley Farm. We consider Sunny Valley Farm to be a significant
source of nitrate rather than the major source for these wells. However, it is
our opinion.that the farm operations are the major source of nitrates to the
semi-public well serving Sunny Valley Farm and its employees dwellings.
We hope this clarifies our position with the respect to the wells north of
Sunny Valley Farm property line and are hopeful that we can work together in a
constructive fashion to alleviate these problems. If you have any questions please
feel free to call the office at 566-3282.
Very truly yours,
Robert L. Smith
Principal Sanitary Engineer
RLSsnjk
ccs Wi11iam Rhines
-------
DOCUMENT R18
Candlewood Shores Property Owners Association
Candlewood Shores. Brookfield, Connecticut 06804
Scwcr Fact Finding Cojiuiiil>t66 Lsksshors Drive
Brookfield, CT 06804
February 6, 1977
Mr. Robert E. Mendoza
E.P.A. Project Officer
United States Environmental Protection Agency
Region # 1
J.F.K. Federal Building
Boston, Massachusetts 02263
Dear Mr. Mendoza:
This letter is prompted by the outcome of the E.I.S. hearing held in Brookfield
on February 2, 1977 at the Brookfield Library.
Since you were present at this meeting it seems unnecessary to elaborate on how
outraged our taxpayers are in regard to the overall question of sewering this
community.
Those participants at that meeting were Messieurs Robert Austin, Fred Standt,
Vincent Foley and Jack Hegerty who are now or have been chairmen or members
of our zoning, planning and Sewer Commission. As taxpayers we were amazed by
their remarks, particularly the statement made by Mr. Fred Standt (Chairman of
the PlanningCommission at the time) by Mr. Robert Taylor, that "needed or not--
your'11 get sewers in Brookfield."
In the absence of answers we repeatedly sought such as alternative methods of
correcting septic failures, establishing true costs, the peril to our water
systems, what costs to homeowners in private areas not eligible for federal or
state grants—we have not received the answers we are entitled to.
The Carousel system in New Milford is in question—New Fairfield and Washington
are no longer included in this project.
Must the harried taxpayer of Brookfield say nothing and go blindly into a sewering
project that is questionable in many ways?
We are enclosing a copy of our town newspaper "The Brookfield Journal". As you can
see, it clearly spells out the problems facing this community.
We were told by Mr. Clifford Gold, of C.G. Engineers that perhaps federal funding
in private areas and lateral lines could be as high as 50% to 60%. We were
shocked to learn that lateral funding is denied by the State of Connecticut.
We feel tighter septic and building codes should be implemented in Brookfield.
Rigid regulations governing the cleaning of septic tanks should be under a
a town ordinance where proof of having this service performed has to be accompanied
by a receipted bill from a reputable and town certified tank cleaning service
company with the homeowner's local tax return every two (2) years.
Drainage is an easily correctable solution to handle ground water. Further, a
complete ban on the use of fertilizers should be instituted by the town.
-------
Mr. Robert E. Mendoza
February 6, 1977
Page Two
It is obvious to us, that if the above alternatives have not been tried and the
only solution offered to us is a costly and perhaps unnecessary sewering program,
then we are being ripped-off as American taxpayers!!
Our concern is further aggravated by reading the Congressional Record of the
second (2nd) session of the 94th Congress, Volume # 122, statement # 152, dated
Tuesday, October 26, 1976. At this hearing it was stated by Senator Jennings Randolf
that municipal sewage collection treatment facilities is now the largest single
public works program in our nation. The cost to homeowner's usually amounts to
somewhere between $5,000.00 to $10,000.00; and further studies we have available
to us makes mention of still more staggering costs to follow. This is brought
about by overall poor planning and excessive engineering fees, being a major part
of these cost overrides.
After reading this congressional report, also "The Interceptor Sewers and Suburban
Sprawl" and reports in "environmental quality"-we wonder how many unnecessary
sewage treatment plants have been built so far and where the same huge amounts
of appropriated monies could have been spent more wisely.
Attracting industry into our town by way of providing sewers can create another
area of problems. Can the impact on our water resources,complete lack of a master
plan, strain on our town services, sustain the record growth and problems sure to
follow.
We hopefully feel we can depend on your cooperation to remedy the situation,
which otherwise could very well force many of our homeowners to leave this area.
May we hear from you cr-t your earliest convenience?
Charles D. Elms,
Chairman
and Members,
Vincent Foley
Margaret Foley
Lawrence Rose
Dorothy Rose
Donna Elms
John Dunnett
Hank Kelly
Maureen Kelly
Helen Andrews
cc: Mrs. Ella Grasso, Governor, State of Connecticut
Lowell Weicker, Senator, U.S. Senate
John McGlennon, Regional Administrator, EPA, Boston, MA.
David Smith, State Rep. Brookfield, CT
Sincerely,
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DOCUMENT R19
MAR 7
Candlewood Shores Property Owners Association
Candlewood Shores, Brookfield, Connecticut 06804
Sewer Fact Finding Committee
1977
February 28, 1977
37 N. Lakeshore Drive
Brookfield, CT 06804
Mr. John McGlenhon
Regional Administrator
Environmental Protection Agency
Room 2203
J.F.K. Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
This letter is prompted by a large number of homeowners living in the
Candlewood Shores area of Brookfield, which has been designated for
sewering.
In our endeavor to become more knowledgeable in this matter, we have
attended many local sewer commission meetings plus other informational
meetings sponsored by Brookfield and surrounding towns. We asked
repeatedly if we were under State orders to sewer and until just two
weeks ago, we were told we were not under State orders to sewer.
Whenever sewers were mentioned, it was done in the following manner:
Attract industry along Route #7,
Candlewood Lake is polluted
and/or There is a health hazard in the proximity of the lake.
As far as the original sewer orders covering the Still River area along
Route #7, we homeowners in this private area have fallen into some sort
of a trade-off deal. Candlewood Shores is a highly residential area
offering no room for industrial development. We feel we are being drawn
into the sewer project through an effort to sewer the whole town.
Repeatedly the E.I.S. refers to the condition of Candlewood Lake as good
or above average. If the goal of the Clean Waters Act is to clean
polluted lakes or rivers, then the condition of the lake makes the
final answer to sewering NO, no sewering in Candlewood Shores is needed.
We do not, nor have we had an epidemic in this area and both state
and local records satisfies that point.
We attended the E.I.S. meeting of February 2, 1977 at the Brookfield
Library. Unfortunately, the business of that meeting was never conducted
because of a complete lack of knowledge of the questions asked. A 325
page E.I.S. report was given out at the door to those attending and for
many, it was the first time they saw this report. Likewise, a similiar
report prepared by the Albertson, Sharpe and Backus Engineering firm
of Norwalk, Connecticut was withheld from the public until just three
weeks prior to the E.I.S. Report. To date, only one copy of the
Albertson, Sharpe and Backus report is available at our Town Hall for
everyone in this town to see. Surely a project of this size, warrants
better study by those who are asked to pay. We are certain, the intent
of the E.I.S. questionaire was to gether the most intelligent answers
or alternatives that only fully informed people could render.
-------
Mr. John McGlennon
February 28, 1977
Page Two
At this particular meeting, it was quite surprising that no one from the
Brookfield Industrial Commission was present. This fact was noted by
Mr. Robert Mendoza.
Since we have been unable to obtain additional information on this
proposed project-perhaps you can answer the following for us:
Why is it necessary to build a larger capacity plant in New Milford?
Is this because it requires two (2) towns to get federal funding?
It is our understanding that since October 8, 1972 under the Clean
Waters Act of 1972, funding for one town is not available. If that
is so, then Brookfield should be excluded. At present, it's hard to
justify Brookfield's inclusion when New Fairfield and Washington have
been released from sewer orders in this project.
We also question the method of sewage treatment proposed by the Metcalf
and and Eddy Engineering firm. The Carousel system is foreign made, a
second stage treatment facility carrying excessively high royalty fees.
We further question the outrageous engineering costs for Metcalf and
Eddy and hope they come under your close scrutiny.
Now, in regard to our immediate area, we were forced to have a PUCA
hearing in Brookfield last year on our local water system. Complete
records are available to you upon request regarding its inability
to deliver water at various times of the year. This shortage situation
can only become more acute with further demands placed on it. Many
residents not now owning washing machines, dishwashers, etc. will
have them installed. Then what?
As taxpayers, we question why alternative methods have not been more
fully explored. Ground drainage is one area that could achieve significant
results. There is very poor ground drainage here in this area. Many
troubled septic systems could be remedied by this simple corrective approach.
The town could enforce local sanitary codes by diligent use of its
sanatarian. Questionaires could be send to every household requesting
location and size of each septic. Informational material offering
assistance to homeowners should be send. Homeowners should be required
to include receipted bill from a certified septic cleaning company with
their town tax bill every two years. This has never been done and the
Town should also place a ban on the use of all fertilizers near the lake
area. Up-zoning should be stressed!! Where empty lots are available,
the concept of community septic systems should be explored.
The thought of sewering only 5 to 6 miles of lakefront in our area,
containing only 450 homes to keep the lake from pollution is
psoposterous, when there still remains a 75 to 100 mile area of lake
frontage containing some homes.
If urbanizing Brookfield is the intent of our local officials, it is
being done in the absence of a master plan. We feel good common sense
has been completely forgotten in this entire program and only the thought
of grabbing federal and state funds prevails.
If sewering is needed for industry along Route 7, then we already have
the Southwest corner project going into Danbury to satisfy that need.
Already built!!
-------
Mr. John McGlennon
February 28, 1977
Page Three
We are lead to believe that our costs, if sewered will be approximately
$2,500 per homeowner- This figure is very unrealistic since funding
lateral lines in a private area is not grant eligible.
It is hard to accept the fact that no solution is available to Brookfield
except more costly sewering that is perhaps unnecessary.
In fairness to Anderson Nichols, we feel the questions asked on their
#2 Workshop questionaire were phrased in such a way that no matter
how answered would lend our support to a project we truly feel
is unneeded.
We respectfully request that you study the above facts further
and feel free to contact us for further information.
Charles D. Elms,
Donna Elms
Co-Chairmen,
Candlewood Shores Property Owners Assoc.
Sewer Fact Finding Committee
-------
Petition
Page
We, the undersigned residents of the Town of New Milford, State of Connecticut
do petition the United States Environmental Protection Agency and State:
1. The proposed eight-fold extension of Wastewater treatment and
collection system is excessive to our needs and ability to pay
which will be destructive to our natural growth.
2. Mindful that our existing plant requires modernization, we urge re-
consideration of a program to extend capacity to a maximum amount
not to exceed 2 M.G.D,
NAME
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-------
DOCUMENT R20
CLC OWNERS CORP.
Candlewood Lake Club
Brookfield, Connecticut
Telephone
New Milford, Conn.
ELgin 4-4004
March 7, 1977
Mr. John A. S. McGlennon
Regional Administrator
U.S. Environmental Protection Agency
Region 1 Room 2203
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
CLC Owners Corp. and its stockholders own between them the Candlewood
Lake Club community comprising almost 400 acres of land extending
about 6000 feet along Candlewood Lake Road, the southern portion in
the Town of Brookfield and the northern, larger part in the Town of
New Milford. The property extends westerly to Carmen Hill Road.
All of the property except the individual one-family residences of
our members is owned by CLC Owners Corp. About two-thirds of the
acreage is open space providing excellent and natural environmental
protection for the community and the aquifer which supplies the
community-owned and maintained water system. That system utilizes
modern wells, storage tank,mains and hydrants all within the community,
adequate for its needs and furnishing water of excellent quality, as
periodic tests show.
All recreational facilities and all roads within the community are
owned and maintained by us at our expense. There is no commercial
use, that would be wholly out of keeping with the purpose for which
the community was developed. Most of the residents spend the winter
months away from the community. The area occupied by homes repre-
sents about one-third of the total area and is within about ten
percent of complete development; only a few building sites remain.
All residential lots have a depth of at least 100 feet and most
have at least that frontage. The total acreage owned and controlled
by us amounts to over 2 acres per family.
Re: Environmental Impact Statement
Wastewater Collection and Treatment
Facilities - New Milford, Connecticut
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CLC OWNERS CORP.
Candlewood Lake Club
Brookfield, Connecticut
Mr. John A. S. McGlennon
- 2 -
Telephone
New Milford, Conn.
ELgin 4-4004
The object of the community is to preserve its open space and its
high residential character,
I mention the foregoing matters because they demonstrate that our
community is in no way a "problem area", as suggested in the subject
Impact Statement. The Statement concedes, seriatim, that supporting
documentation, at least as to us, is lacking. Our "problenf'designa-
tion is not based on the actual conditions, and rests on the supposition
that our area would be further intensively developed on an indiscriminate
small lot pattern and that then the septic systems might prove inadequate.
While our residences are served by septic tanks as is generally true
of all similar areas in the State, they have presented no "problems",
although, like any sewerage disposal system, they require normal
maintenance.
We are gravely concerned, therefore, that the community in which we
have invested so much to achieve a healthful and enjoyable place to
live, should be lumped with others where, it is stated, intensive,
and especially urban type development might sometime call for a sewer
mains system, with its heavy expense to home owners to be added to
mounting taxes and expenses of all kinds. It seems to us that any
need for a sewer mains system would arise, as far as our part of New
Milford is concerned, only if Town planning and zoning progressively
encouraged over use for commercial purposes of the Route 7 area, and
that would not call for sewer mains in our locality some miles away.
The Impact Study seems to be incomplete and erroneous, as applied to
us, for other reasons:
1. The conclusions rest on the proposition (p. 194) that the state
of knowledge as to septic systems suggests that they are only
short-term solutions at best, when long-term protection of
ground water is used as a criterion of their effectiveness. It
is recognized, however, that river pollution will be increased
substantially by a sewer mains system.
2. Surprisingly, the Statement apparently fails to mention or give
consideration to recent findings of the Environmental Protection
Agency itself to the effect that even small housing developments
and smaller towns can be adequately served by modern septic
systems and thus avoid the burden of much costlier sewer mains
systems. The research in this area is ignored.
-------
CLC OWNERS CORP.
Candlewood Lake Club
Brookfield, Connecticut
Mr. John A. S. McGlennon
2
Telephone
New Milford, Conn.
ELgin 4-4004
3. The estimated costs of a sewer mains system are based on data
which appears to date back at least two or more years and no
trending of the data by reference to construction cost indices
or the like is mentioned.
4. The Study fails to discuss the costs and problems associated
with house connections, especially in hilly areas like ours
where some homes are below the grade of the street. We under-
stand home owners would have to install and maintain at their
expense a pump and a back-up pump under such conditions. Nor is
consideration given to use of a system of house connections in
lieu of feeder street mains in hilly areas.
5. The Study seems not to consider, and give appropriate weight
to the disruption of a settled community by the installation
and maintenance of a sewer mains system and the fact that such
a system is not immune to rupture, pumping or other failure
contributing to contamination.
Our desire to protect our environment is evidenced by the kind of
community we maintain. We recognize the need for proper wastewater
facilities, but, for the reasons outlined herein, we think that any
foreseeable needs in this area can be met much more cost effectively
by establishment and enforcement of proper standards as to land use
and as to design and maintenance of septic or related type localized
facilities.
We would appreciate your comments and would like to be supplied with
any further statements or materials that may affect us.
Sincerely yours,
Arthur L. Webber
President
ALW:tk
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DOCUMENT R21
H
HOUSATONIC VALLEY ASSOCIATION, INC.
Route 7, Kent, Connecticut, 00757 Telephone (203) 027-4088
Comments on the Draft
Environmental Impact Statement
Wastewater Collection and Treatment Facilities
New Milford, Connecticut
February 14, 1977
The draft Environmental Impact Statement prepared by Anderson Nichols is a
thoughtful analysis of a complex situation. It is the purpose of a draft to
elicit criticisms, so for the sake of brevity, these comments will dwell only
on shortcomings of the EIS.
The following areas will be addressed: Plant Capacity, Protection of Water
Resources, Mode of Treatment, Secondary Effects, Need for the Plant.
Plant Capacity: During the drafting of the EIS, two significant developments
have occured regarding the projected capacity of the plant. 1) Consultants
for the town of Brookfield have recoirroended use of the Danbury Sewer Plant
rather than the New Milford Plant. 2) Elimination of Nestle's effluent from
the proposed New Milford plant has been suggested.
These reductions would reduce the projected capacity at the New Milford plant
by 2.1 million gallons per day. (.33 reserved for Nestle, 1.89 reserved for
Brookfield) The final EIS should therefore look at both of these possiblities
from the standpoint of impact on water quality and cost effectiveness for the
towns and industry involved.
Protection of Vfater Quality: It has taken mankind centuries to realize that
dumping the chamber pot into the river makes no more sense than dumping it
into the street. The proposal to convert New Milford from a town that dumps
.54 million gallons per day of secondarily treated waste into the Housatanic
to a town that dumps 4 million gallons a day into the river is a throwback
to primitive thinking that has no place in the 1970's.
At a minimum, phosphorous removal must be required at the New Milford plant.
The question of siting the plant on an aquifer needs further study. Although
the plant itself may not danage this potential source of drinfeing water, the
possibility exists that old or damaged sewer lines leading to the plant may
leak pollution into the aquifer. This possibility should,be considered in the
final EIS.
Wild S Scenic: The draft EIS nakes no mention of potential federal desig-
nation of the Housatonic as a "wild £ scenic" river. Protection of this
resource should be priority in all planning for the sewer plant.
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Page 2
rfo
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DOCUMENT R22
Protect Water Resources
Preserve Wildlife
Respect History
CANDLEWOOD LAKE DEFENSE ASSOCIATES
NEW FAIRFIELD, CT., COMMITTEE
RD No. l,Rte 39 • Now FalrftaM, Ct. 06610
(203)- 746-4665
Compatible Recreation Levels
Intelligent Growth
Welcome to Good Neighbors
MAR 1 1977
March 1, 1977
cmwi! mn www mm
It is extremely difficult to arrive at the proper point of departure to comment
upon the draft statement. The reasons are several. The statement is a conscien-
tious effort by Anderson-Nichols as consultants, and Region I in fulfillment of
duty, to piece together the disparate parts of the 10-year old situation.
The recommendations are themselves disparate, totally correct in important part,
partially correct in others, and contradictory not only in conclusion but to the
purposes and intent of Region I in ordering the study in other parts.
This is not surprising, and is not in itself a fundamental criticism of USEPA.
It arises from the fact that, beginning with original orders issued only 15 days
after enactment of the State 1967 Water Pollution Law, strange orders were issued
to New Milford and Brookfield. The orders were to participate in a regional sewer.
Construction of the regional sewerf and not abatement of pollution of pollution
were the heart or the order.
The 1967 orders to those two towns did not describe or identify specific situations
Indeed, 10 years after such orders, the Water Compliance Division of DEP is still
perfectly willing to yield priority of the Iron Works area of Brookfield, for which
the orders were originally issued--and to substitute something else. In fact, in
an inner-department memo written by the Director in 197U, the word in lieu of ap-
pears. Robert Austin, until recently Chairman and still a member of Broolcf ield fs
Planning Commission, was quoted in the press in a comment upon the EIS. He stated
that the subject of the 1967 order is still 15 years in the future—making apparent-
ly 25 years ahead of the 1967 edict.
In New Milford, without any identification of problem whatsoever, within those same
15 days, the Town got orders to plan to abandon its 8-year old sewer (hardly midway
in payment), and get going on a regional sewer—for which it had to buy a new site.
Hhat had happened is this: The Connecticut 1967 law permitted the former Water Re-
sources Commission (superseded by Division of Water Compliance & Hazardous Materials
of DEP) to issue orders to abate pollution or "potential pollution." Hie latter was
undefined. This has been the cause of the trouble, and apparently not only in
Western Connecticut. This very week, the Environment Committee of the Legislature
took testimony on Bill 651*6, introduced by two Representatives from other parts of
the State. If enacted, this bill will define "potential pollution," establish rights
of hearing and due process before issuance of any orders.
It is clear that when orders are given without reference to an identifiable situation
and are based solely on far off hypothesis, the seeds of discord are sown. The
EIS deserves credit for its frank admission that sewers do go to the very heart of
town planning and zoning, contrary to representations from other quarters. Orders
based upon guesstimates a generation ahead, which make no provision for demograph-
ic change of trend, and apply to no present condition—In effect usurp the Town
function of planning and zoning#
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-2-
It is this usurpation that underlies the complications and controversies. It
is contrary to the intent of our Legislature, which specifically delegates such
planning and attendant zoning, such study of land characteristics, to the towns.
The United States Supreme Court more strongly than ever in its latest rulings
upholds this same principle. It goes even further. It has ruled that indeed it
is the function of local planning to consider costs of services, taxation therefrom,
and the economic ability of residents to bear such costs, that arise from induced
population growth.
Herein lies also a basic criticism of the EIS« It falls into the same error,
and, without present justification, proposes to dictate such future course and
rate of local development. Others have made the point that the EIS places the
thing backwards. It proposes the sewey and then calls for local officials to ad-
just their planning and zoning accordingly.
Complications of the project increased greatly in 197U. January $, 197U, an order
dated November 19, 1973 was delivered to New Fairfield, and the other two towns.
It ordered New Fairfield to bear major cost of a shoreline interceptor between
Brookfield and New Milford ( excoriated by Connecticut Light & Power ), and to pay
full cost of a cross-lake force line to pay for it. Again, not for a present pur-
pose, but for a hypothesis 20 to 30 years hence. Even the hypothesis is suspect.
The same inner-department memo of September, 197b, written by the Director, reveals
the truth.....to obtain funding for the line to run through a private development,
otherwise ineligible for funding without the participation of New Fairfield.
It is an axiom of law that actions based upon undefined premises and hypothesis is
unenforceable. In this instance, Town Meeting voted unanimously to authorize legal
action. The first prescribed procedure, Hearing before the Commissioner, was ap-
plied for, but never held. The order was revoked May U, 197iu At this point, in
view of happenings at the February 15, 197h Public Hearing on the EIS, one might ob-
serve that there is no record to show other than that this decision of the Town
Meeting remains in effect. The legal axiom, that hypothesis is unenforceable,
again is illustrated within the month, this time in Minnesota*. Sixth District,
Jan. 28, 1977, even in instances where strong arguments are made for the hypothesis.
This latter is notably absent locally.
At this point in our comment, it is perhaps best to adopt the format of the EIS
itself, and to address things first in their positive aspects, and then in their
adverse effects.
It is impossible to overestimate the positive contribution of Region I in order-
ing the EIS. No matter what the outcome, can one conceive of a greater denial of
public right than to have failed to give opportunity to officials and citizens to
express their views, and bring to USEPA the multiple considerations involved?
The original order for EIS mentioned "virell-dooumented concerns" of citizens and
organizations. We believe that USEPA had opportunity to see for itself the diffi-
culties of getting fair hearing and evaluation in Connecticut. We believe that
the specifics of the occasion may well have convinced USEPA to give renewed atten-
tion to the situation in those towns where there is such sharply contrasting opini-
on, namely in Brookfield and in New Milford.
Candlewood Lake Associates have never desired in any way to intervene in inner
affairs of other towns, except where specific actions would be detrimental to the
life of the Lake itself. In all other matters, the supporters of CLDA act as in-
dividual citizens in respective towns, though most reside in New Fairfield.
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-3-
The vigor of our efforts to convince EPA of the need for an EIS reflected that,
for many reasons, we had been among the earliest to unravel the mysteries of the
project, and to be convinced ourselves of the tragedy if the thing went through
without review.
Now that this has been accomplished, we gladlyaccede to the primacy of citizens and
officials of New Milford and of Brookfield to decide their own fate, life express the
hope that now EPA will give full consideration to the virtual unanimity with which
New Milford officials—during and even more stronglyly since February 15, are calling
upon you to moderate your proposals. The virtual sole exception is the sewer commis-
sion.
In Brookfield, as EPA noted, there is a notable absence of crystallized approach.
Consultants say opposite things. There is division amongst officials. Whatever may
have been the atmosphere at the Brookfield workshop, it is notable that our inquiries
produced this fact: That three of the participants in discussion who questioned
the EIS conclusion are all former chairmen of the Planning Commission, one a former
sewer commission member, himself perhaps the volunteer official of longest years of
service in the whole town. Another former sewer commission member, and the only one
of these four,who resides in Candlewood Shores, also opposes the conclusions.
***
The conclusions of the EIS regarding New Fairfield are beyond dispute, and consistent
with state landuse and conservation policy. The conclusion that, if in the future
the western part of the town should require sewering, it shouldgo to Putnam County
is correct. That would follow the natural drainage flow of the land. We believe, in
fact, that EPA policy precludes going against a natural drainage basin, let alone
the monumental e«emfcne«4 economic injury, to absolutely unbearble extent, that follows
going over miles and miles of hills and water instead of downhill over onefs shoulder.
*****
ADVERSE FACTORS
From our viewpoint, the greatest overall ecologic and environmental error is to
fail, as the EIS does fail, to recognize Candlewood Lake as an inevitable potable
water resource. In 1971 and 1972, Technical Planning Associates made its water re-
sources study for the Housatonic Valley Council of Elected Officials. It reached
the conclusion that, by 1990-2000, Candlewood would have to supoly 27 million gpd.
It is true that there are debateable parts of the study, but only in degree.
Technical Planning Associates used the same population figure that Metcalf & Eddy
did in their environmental assessment, which is exaggerated, as regards New Milford
and Brookfield, but not as regards Danbury, where it is quite in line. Bringing
the TPA figures into the same proportion as did EPA for the other two towns would
merely reduce the 27 million gpd estimate, but leave it very substantial# That
27 million was not merely a small part of total demand, but over h2% of an esti-
mated 6U million gpd demand. Hence, the lake must figure in. As you know, Danbury
already used it for drinking. Other towns in the drought of the sixties hauled Lake
water to communities for non-potable purposes.
It must also be borne in mind that, to best of our knowledge, the TPA water study
did not contemplate the major depletion of ground waters that would result from
a sewer project of the proposed magnitude. To some extent, this offsets the exag-
-------
-u-
gerations of the TPA population data. It is wrong in principle to sewer the
Gandlewood Basin. This is doubly so since Brookfield residents of the Lake
area repeatedly express belief that corrective measures could take care of
whatever problems exist.
It is not our purpose to maintain that septics never fail, in Brookfield, New
Fairfield, or anywhere else. It is our purpose to say that it is good public
policy to adopt vigourous enforcement methods, even to harsh levels, to insure
an inevitable major water supply. It has to be recognized also that, though
no one can predict the future, legally or otherwise, that the Army Corps also
identified this Lake as the hub of a major metropolitan water resource in its
Northeast study, mandated by 6ongress» Sewers in other areas than the Housatonic
area also deplete ground water, water failures are so widespread and frequent,
that no federal agency should take responsibility now for sticking sewers in
the water supply of the next generation, and possibly our own.
We think that the paper of Professor James Mellett, submitted at the New Fairfield
Workshop, effectively disputes the EIS contention that 10% of septic waters
are transpired. Just a couple of days prior to that workshop, the regional weather
scientist at Tllfesconn warned of possible shortages this year, because the bitter
cold had deepened the frostline, and prevented recharging of ground water.
We have conditions, because of our geology, where wells are not predictable.
A gusher of 30 gpm often is next door to one gpm. Wells U00 feet deep are known
to yield less than one gpm. Some homes have two, sometimes more wells, to get a
minimum.
Vfe ask EPA to consider whether it is itself in compliance with public law 92-500,
or with the decision of US Supreme Court this week in regard to industrial dis-
charges, in its inclusion of Nestle in a secondary plant. It has to be noted that,
October 16, 1967, Nestle received a state order to complete its own plant by
September 30, 1970. The fact that it wns not done is not the fault of the company.
It was merely a pawn in the game of juggling the parts of a regional sewer based
on hypothesis. The deleterious effects on three lakes have occurred.
In its effort to give the State as much say as possible, back in 1970 the federal
enforcement officials of that time allowed themselves to be dissuaded from an
enforcement action. It is our sincere hope that EPA will not "justify" this pre-
vious error of a federal agency by perpetuating it, and going against the spirit,
at very least of 92-500,
The motivation of DEP to utilize Nestle as an ingredient of its hypothesis for
a regional sewer is especially evident from the excessive terms of the NPDES is-
sued to Nestle by Water Compliance. Nestle itself has declared that it utilized
only one-fourth of the limits permitted by this NPDES I Does not such a permit
practically cry out, "Pollute all you please, so long as you hang around and put
your volume into a sewer system we can*t justify any other way?"
We believe another area where an adverse mark exists against the EIS regards
land treatment methods. «ve agree heartily that the EIS is correct when it says
land treatment cannot handle New Milford's entire sewage output. In July, a
personal paper of CLDA's executive secretary made that point. At the same time,
-------
-5-
the point was made that (and not necessarily at Sunny Valley, though possibly)
there are plenty of sites for a limited plant. Many speakers at the New Mil-
ford workshop made this same p6int, none more ably than Selectman Raymond
O'Brien.
lfe hope that EPA will help this region pioneer this already-proven method as
an adjunct to a conventional sewage system. One of the great needs in Connec-
ticut, expressed over and over again on every possible occasion by environmental
people, is to stop using our rivers as the inevitable transporters of waste-
water. The call is for newer approaches, for innovation of acceptable type.
We do feel that predilection for sewers seems to be a habit of important engin-
eers, and that Anderson«Michols also has the same preference. Limnologists
on the other hand speak oppositely. Wherever it is at all possible, the liranol-
ogists 1 approach is better, A sewer transports at once the entire wastewater of
huge areas to a stream. On theother hand, with septics, a major part never reaches
a stream at all, and even a failing septic does not yield its entirety to a stream#
We'd like to end this commentary on a positive note, after having mentioned
some of its negatives. Anderson-Nichols did attempt to address many, many
issues that were totally overlooked, in the environmental assessment^-5t did not
attempt to sweep adverse things under the rug, and we highly respect the honesty
of their approach.
We think the appropriation was altogether too small for the scope of what they
were asked to do. Tnat being so, we feel that EPA sould give especial heed to
the input of the workshops, and to the feelings especially in New Milford, which
the EIS rightfully describes as the hub town of the project.
We think also that EPA will not fail to note that, in original OT^ers back in
1967, Candlewood Lake^ or anything to do with its preservation^vmSe not mentioned
in slightest degree. .Ye think EPA will realize that Candlewood Lake has been
dragged in only in latter stages by the big-sewer advocates in order to try
to create some sort of rationale.
le think also that EPA will recall that, starting with the Regional Conference
held in New Fairfield on June 22, 197b, the opposite positions were revealed,
where, on the one hand EPA strongly encouraged local input, on the other the
State, (via Water Compliance) strongly protested local input, and called for its
own omnipotence--to the exclusion of both federal and community viewpoints.
With appreciation for the indisputable positives, and hopes for EPA's willingness
to amend the negatives of the draft EIS, we submit tnis paper.
One exhibit is affixed, because we think the item itself should be a part of
the record, namely, the press article of Feb. 15th, commented on by Mr. Stickney.
Frederick Benedikt,
Executive Secretary.
-------
VAN&Vfif A/£WS-7)M£S
FeS- /$ '?7?
Sewer talks may he formality
By David O'Reilly School, and under consideration is a an environmental impact statement on
News-Times staff proposed $32 million project calling for this that was the EPA's idea."
construction of a sewage treatment Asked if he could think of any
NEW MILFORD — Tonight's public plant and the placement of sewer lines evidence that might convince the state
hearing on the proposed sewer project in northwestern and central Brookfield to change its sewer orders for New
for New Milford and Brookfield is and in central and southeastern New Milford and Brookfield, Hupfer replied,
largely a formality, according to a state Milford. "I couldn't say. I can't think of anything
official. The plans are a variation of orders off hand, but if I could, I wouldn't say."
Merwin Hunfer chief of the water issued to ^ two towns by the DEP in He ®aid tonilW'9 hearing is required
, Merwin ""Pter, cniei 01 We water November 1973 by fed(!ral reguiations as part of the
Environmental Protection (DEP) said Public opposition to the project, preparation of the final environmental
ve^erdav he th£ ttere is litt e which critics Predict cos"y imPact statement. Asked if he felt it
evidence that could be offered at flnd wiU induce devel°pment in the was simply a formality at this stage,
tonights hearine Uiat will cEe the towns' Prompted the U.S. Hupfer said, "Yes. This is tlie
state's or!e« tester Environmental Protection Agency procedure."
state s orders to sewer. (EpA) jn ,ate m5 to c()nduct itg own
Hupfer supervises most sewer environmental impact study on the . wjf • j. I -
planning for the DEP. The hearing project. ~
begins at 7:30 p.m. at New Milford High Tonight's hearing will be conducted
; by representatives of the EPA as a part
- - ¦'¦wwww n' * > ; of its impact study. The
~ representatives, the Boston engineering
firm of Anderson-Nichols, have
tentatively approved the project for
federal funds. <
"Our mind is already made up," ^
Hupfer said. "We were never in favor of
!\etv Milford calendar a
' TODAY a
* Environmental Protection Agency
public hearing on sewer project for New i:
Milford and Brookfield, 7:30 p.m., high h
school. 1
- e f ¦
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MAS 2 1977
Protect Watar Raaourcaa
Prastrva Wildlife
Raapact Hlitory
CANDLEWOOO LAKE DEFENSE ASSOCIATES
NEW FAIRFIELD, CT.. COMMITTEE
Cofnpatltria Racraatlon Lavala
Intalllgant Growth
Welcome to Good NaJghbora
RD No. 1, Rta 39 • New FalrfMd, Ct. 008X0
(203)' 746-4665
TO: REGION I, USEPA--
March 2, 1977
ADDENDA TO OUR COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT, NEW MILFORD
Please consider the following comment, and attached article concerning the
Shepaug River as a source of water supnly to be an addenda to the main body
of our comments, sent to you under date of March 1, 1977. This additional
material became available after the main text was prepared and sent, to reach
you on or about March 1,
The 1971-72 regional water resource study conducted by Technical Planning As-
sociates on behalf of the Housatonic Valley Council of ELected Officials estim-
ated the safe yield of the Shepaug River to be 9*2 million gpd. The yield was
taken into account in the total figures of estimated future regional demands
and deficit. After all figuring, the TPA, (as commented upon in our paper of
March 1 ), placed the future demand upon Candlewood Lake to be 27 million gpd.
We made tne necessary comment upon that figure in our paper.
Something new, however, has been added that never before has been publicized.
That is, Stamford and Norwalk are now mentioned also for possible future demand
upon the Shepaug. This makes clearer than ever that Candlewood Lake remains the
one big available body of water. The responsibility of all government bodies is
to take all major factors into account with this sewer project. The responsi-
bility is to protect, and not further impair Candlewood Lake. EPA has the main
responsibility as the funding body. Casual dismissals on a purely present basis,
because of present state regulations regarding water supply, cannot be taken too seriously.
The actual facts that thousands of American communities right now are utilizing
sources of far less potability than the lake as it stands must be remembered.
In our opinion, it is ecological, environmental, and economic folly of the first
magnitude to have EPA and the DEP of Connecticut adopt a purely opportunistic
approach. Likewise, any overdependence on the Shepaug is shortsighted. The
photgraph of the Shepaug, at the point where the taps are suggested, quickly dis-
pelSany notion (apparently held even by some officials) that the Shepaug is a
veritable Amazon of the North.
Page 1...please cross out repetition of words "of pollution" in last lines
Frederick Benedikt,
Executive Secretary
CORRECTIONS IN TEXT OF COMMENT OF MARCH 1, 1977
of paragraph 3
Page2.».paragraph 3•~•«line 5.••should read "full cost of a cross-lake line
to reach it."
-------
Compatible Recreation Levels
Intelligent Growth
Welcome to Good Ne^hbors
March U, 1977
A^NDAJW. 2, TO OUR COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT. NEW MILFORD
It seems important that EPA should be apprised of the action of the Brookfield
Planning Commission, as per this article which appears tonight. Since it is so
close to the deadline for comment, we take it upon ourselves to make it available.
With the addition of the present chairman, Mr. Radigan, this makes four successive
chairmen (and at least in this instance the entire commission) who oppose the sewer-
ing of the route 7 corridor. The other chairmen were! Fred Standt, Jack Hegarty,
and Robert Austin.
Other things become clear from the article. There is an illogic that harks back to
the shaky foundation of the project as a whole—-based on the desire of the DEP and
its predecessor for a regional sewer, regardless of lack of foundation in any specif-
ic pollution abatement from the start.
If the only ."reason" to be part of the New Milford Project is "to sewer Candlewood
Shore," jo frig New Milford is a strange way to commit the folly, OSEPA already has
funded the southerly route 7 interceptor I It is in operation. As Brookfield's
special study recommended, the cheapest and most logical route is to go along Candle-
wood Road, to join the interceptor. Brookfield has a sizable reserve capacity, in
the Danbury plant, right now.
Again, this harks back to the original controversy as far as Brookfield is concerned.
At the public hearing on February 15, we all heard Fred Standt proclaim that "he him-
self had been intimidated." The intimidation consisted of this: There was from the
start opposition by Brookfield planners to the route 7 development prospect.^ How-
ever, when they expressed opposition, the incumbent Director of Water Compliance,
who at that time served on a predecessor to DEP, threatened legal action against the
town. The planners did not (as is clear from the present article) have clear sail-
ing and official unity behind them. There were and are those who favor heavy devel-
opment.
Accordingly, "cakes to appease the dragon" were offered—-the famous "in lieu of"
route 7, take the Shores' All the planning chairmen of the past said, "If, and we
don't concede it, any place in town needs sewering, then it is Candlewood Shores."
Now that "in lieu of" may also be included, the contradiction and illogic is there to
roost. There is no real way to avoid involvement of route 7 as well. The game is over.
Aside from that, EPA should clarify a number of things;
It) If only the Shores is involved, why is another interceptor needed?
2.) What will EPA really fund? There are no town roads within the Shores. All
are privately owned. Are people being advised correctly when told "if you
hurry, the EPA will fund laterals, etc.,"—-within tne Shores?
3.) to view of the fact that town planning is supposed to be the dominant consid-
eration, can EPA ignore the basic attitude on development of both the New Mil-
ford and now the Brookfield Planning Commissions? Can EPA fail to note the
new controversies, or to note that industrial development in Brookfield will
take place in the southerly part, near its new interceptor—not in the north?
Frederick Benedikt, Exec. Secy.
Protect water rmouixm CANDLEWOOD LAKE DEFENSE ASSOCIATES
Preserve Wlldllf^. NEW FAIRFIELD, CT., COMMITTEE
Respect History ¦' TQyy No. I, Rte 39 - Now Fairfield, Ct. 06S10
(203)- 746*4665
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12
THE NEWS-TIMES, FRIDAY, MARCH 4, 1977
Brookfield sewer project proposal
By Sari Koshetz
News-Times staff
BROOKFIELD — The planning
commission does not like the sewer
commission's sewer project proposal.
The commercial and industrial
development commission does.
p At its meeting last night, the
I planning commission unanimously
t voted against the sewer commission's
* recommendation to embark on an $8.1
million sewer project with New
Milford. The sewer lines would run
from the Candlewood Shores, over
Elbow Hill Road and then north along
Route 7 to New Milford for treatment,
according to the proposal.
According to attorney A. Searle
Pinney of Brookfield, the planners'
vote will not hold up a town meeting on
the sewer commission's proposal. The
board of selectmen was scheduled to
meet today to set a date for a meeting
Son the sewer project.
Joseph Radigan, planning
commission chairman, said the panel
favors joining with New Milford and
sewering the shores area, but are
opposed to sewering the Route 7
corridor.
J Jeffrey Kass, a planning commission
Pmember, recommended a letter be
I sent to the sewer commission stating
1 that no data has been presented
I showing that Route 7 must be seWered
| Kass said the letter should also say g
¦ that the problems present in 1967 when
the original sewer orders were issued
have been corrected, no estimates of
tax benefits to the town have been
presented and no estimates of the
f effect of "sewer-induced development
S on the health and safety" of the town
J have been given.
#¦ Twenty-four hours earlier, the
commercial and industrial
-------
DOCUMENT R23
Ira Meinkardt
25 Ecko Drive
j9/7 New Milford, Conn. 06776
. n • 4,1'77
U.S .Environmental '-rotc-ction Agency
Regionl
Boston, >'ass. 02203
?.e: Wastewater Collection and Treatment
facilities, "ew ;r.ilford, Conn.
Gentlemen:
The enclosed comments are submitted on behalf of :
1. myself and fan'lty as residents of Few ilford for 2) yrs;
2. 62 families of t: e lakes aide comrnun ty of Birch. Grves,;
3. and :;enerally for some 1150 res'dents and family heads,
whotw'>lie they may have differing reps ->ns, a11 agree that
the proposed e.'ght-fold extens: on of t:'r e waste water treatment
and collection system is excessive to or needs and a.ility
to nay and which will •••)e destructive to our natural rowth.
They also agree that our existing plant requires modernization
and urge reconsideration of a program to extend capacity to
a maximuts amount n -t to exceed 2 M.O.D.
It is interesting to note that this netition was achieved
in ">ne short week-end without fanfare, nublicity or threats
and renresents the most significant expression of concern. A
copy of the signatures and petition is attached as an Exhibit.
Though I ara now retired,35 /ears exr-erience as a member
of the T'T.T. Bar has taught rne that "hen a community has become
informed ,concerned and aroused, authority should r.nd must listen.
From the very inc.ption of this ro ram almost 10 years
ago, this co m unity has been manipulated, been confused by
orders, counter-orders and counter counter orders; has had a
members of its Sewer Commissi on compromised; has been subjected
to the fraudulent withelding of information by the State in
trving to disregard the Federal Agency and Law; has bean
exposed to a scheme to impose a patented 'Carrousel' rocess
w ith susoect engineering and questionable patent which could
cost millions of dollars of public funds and has had a viable
urogram, which it set forth in 1967 with the best available
engineering advice, delayed for almost 10 ve.rs wherein costs
have almost tripled. The 8 years of delay attributed to the
State only gives credence to the fact that the reasons for the
original orders were less compelling than they should have
been to justify t' is tremendous expenditure. liven if the orders
were based on that even iT
-------
Ira Meinkardt
25 Ecko Drive
New Milford, Conn. 06776
aid Brook-field G-.-Titer for Candler-jood Shores. To get Candlewood
Shores in and eligible for Federal funding,in Nov. 1973, orders
were issued for '"lew Fairfield. As a result of "public opposition
and the resulting pjsjhiiEXJSrsxsiarE political pressure, this.,
order was ultimately revoked." It is im ortant to note that
the real motivation for the orders was the fact of Federal funding
and no regard to 'pollution'. It was also at ttis time that
we hear the talk of pollution on Lake Candlewood.
The handling by State D.. of the letter of April 29,1974
from John XcGlennon of E. -'.A. where it was unequivocally stated
that "it now appears an environmental impact statement will be
required" is againclear evidence of the impropriety. This
letter was fraudulently witheId from the Town of New Milford.
Were it not for the diligence of a reporter,this letter might
never have come to light. Even our Consultants,who b}? this
time had given some $30,000. worth of business to a member of
our Sewer Coramission,became a party to t is act when they stated
that they had, never received 'official' notice of this letter
although t ie Project Engineer is quoted in the press on its
contents.
These machinations and manipulation of this Community,while
a sorry snectacle,did more than destroy the confidence of the
Community . It has brought into sharp focus the serious question
of the valididty of the entire program and the very law under
which it has been oromulgated. The Clean Water Act of 1967 of
the State of Connecticut sets no objective valid standards to
define 'pollution' and even less for the words 'potential
pollution'. It leaves it to the whim of the Administrator to
make this determination. When the administration of a vague law
is motivated by considerations of funding and makes no valid
attempt to even justify 'pollution', it conclusively demonstrates
the essential weakness of that law. In part, it also explains
the arro ance of the administrators who have let us know in no
uncertain terms that it doesn't make any difference what we
want or need and that they will dictate the terras both to us
arid to the Federal government, "e do not read the Federal Law -
Public Law 92-500 that way.
In addition,ifthe statements on Page 223 of the Draft S.I.S.
under C.L. Primary Impacts are correct,then the entire program
of dumping 4 H.H.D into the river violates State and Federal Law,
for it 'increases the BOD load on the Housatonic River, it causes an
increase in phosphorus discharges to the Housatonic River and
Lake Lillinonah and pours nutrients to the river. It gathers
at least 3.5 1*. -.D. of waste water with their pollutants thalz
under present circumstances would probably never reach that river.
It does not provide for "the confined and contained disposal of
pollutants net recycled" as required in Sec. 201 of Public Law
92-500. Neither the language nor the intent of the law is
served by the proposed program.
We are fighting against as. a ilts on our environment and against
excessive,costly,ill-conceived programs,the net effect of
which will exoand the pollution so that it will enyulf us.
-2-
-------
Ira Meinkardt
25 Ecko Drive
Npw Milf ord, Conn. 06776
-3-
are not iust interested in naming points. TTe are average
citizens of oiany persuasions,backgrounds and experience
without organized financial resources and have no capacity
to suddenly discover $137 millions of uncommitted finds.
However,when threatened we ' ave t hs inherent strens-th and
intelligence to marshal our resources.
-------
Dlease consider t'-e following as an addenda in su-wary form as ad'itioal
cnf'wnts on the Draft fi.T.S.
1. Sludge/'Seotage Disposal "'3.177):- The 53 cu yds of sludge generated
dailyfrom a n«>w olant-i"\ Services is a private organization and no
arrantc^onts have ;j.?<*n ^ade wit~ the "'own for .1 i.s'-osal with then, "Jhey have
indicated that t h? v wo ild L '.he t ot out -f trhc. so otic vaste business and
are at odds '•? -th the Town.
2. Carrousel:- " thers :-ave nrwurly addre;-:s-d this subject. "v.-p. the
.v ' " . ' '' . •!, - ¦ - 'V- ^"1 o'-. 1. Ion has it that the patent
should oe quo st i or.ed before uuods ars ennith; ¦ to it.
3. Z O'ts: - ?'¦•->...£ have n ;vcr been or inertv ar.szxs a. vo dec J. a X-">ri has as
yet be^n r.;ujo as to t'^o .>1 \'.'cat">n of c\sV.s between us-:rs and non-users
and ev.rer ->r? the figures J .sec! re cv'il°tsly artificial. The cents of the
Carrousel in too ration have not: b en verified, as n« figures were cade
available to Vndersin-1'ichols Co. Inc.^he secondary costs to the
Community have only b- on alluded to and never "ro^erly assessed .'\hsse costs
include the necessary f.xtw.s ion of municioal services '. school., f ire , t own
;overnment, roads and h ' ehway, ool ice , tra £ r c , a tc .e tc . ) . These ad "ec; rosis
are not only f or he natural growth that we could reasonabl/ sx^ct , hut
the admitted 'induced growth' caused by s fewer in t ;»h i.ch is conservatively
estimated at f>5">0 people. This, induced growth, basec on the figures used,
reore.s'jnts U3"« oZ the projected growth of the Town. It is further
achno'vl.-dj/. d in the Draft Statement that "growth L r.o.act casts will be at a
s j bs1 an • i al tax :ase de ^'i.eit which cannot be balanced by ac.onom'c growth'.
¦ 'e need only look at a series ef articles w'i'ch a' -peered in the -Von bury
vews times by reporter ..Toe ^urlo.y vh'ch explorer. the oroblens 'rowth is
creating? ->r our sister ? ovn of lie thai'. (Cony submitted as an Ex h .' b it).
h. Change of Character -f the. Crnwunity: It Is admitted that an
urbanization "ill occ.ir as a re : 'It '¦>£ sewers . This is desite the clearly
express ¦ "es * re 'Z the C ¦-"'luri ity that i"s rural character be '-ia :nta 'ned.
It is f urt1 r ad Titt'.'i in th* Draft olat vmer. t that 'dvre will be a loss
of farm land to development which is contrary to the exTOt-ssd "olicy of
rhe "tate which is prepared to nour millions of dollars into the ^reservation
of agriculture.
5 .Vater Resources: -It is admitted that there will be an a.is olute loss
of ;ro :nd water. The OraCt statement while understat ir.r the e. ¦' ur,t ¦•£ t'-is
loss,overstates the water resru-ccs available and m in imuzes the canrj-n i-n
necessary in e^rowth. The. l-srgc-.it area -f growth v> ,-l bo su'-:>lied wi'-h water
by a nrivate '-'ater Corpoan-/. The reoort states that water resources would,
have to be developed. There are no er'"'c.ctive r ran -em'-nt s for this
development by the "rivate co-oiny and no guarantee that it is dis--os d to
do this. Certoinly,the re is no assessnent of the cost.
6. Location of °rooosed '"ew "lant: It is located ;n a fl --od nlain ar<:a,
over a general aquifer and i.n a wetlands area. The nronosed "lant will
have to be raised ani the deeoer trenches of th? Carrousel "ill have to be
nrotected by walls. vo wetlands applications have be-*n na 'e to tl,e best
of available knowledge.
7. Mestles: "'his ->lant is the only admitted "ollutor of the. river . It
has stated publicly that it is -'illing and able to handle the treatment
of its own effluent which has been variously estimated to have a biological
demand 20 ti^es that of ordinary sewage. They clain that they cald effect
treatment at less c.ost than b'-ing co-ioelled to join the nunicioal system.
TTe see no reason to refuse, th^m rhis rit/ht in order to build uo the volune
of sewage for the Municipal s.-stem.
8. Land Treatment: "his ^ost effectively meets the re-au •' ren<-nts of law
and when e Ciciently installed serves as t'e ;r>ost ef "ective tertiary
treatment. It has been casually judged at the k M.C.3 require-iert and
improperly compared in cost with a secondary fom of treatment. Inadequate
consideration has robbed authority of the possibility of beinr; creative
and innovative in addressing the problems of waste water management. There
must be many communities throughout 'he country that f ind .' hem?elve.s in the
Dosition of >!ew iilford and this is a perfect. situation for a pilot program
to demonstrate how the combination of imnroved existing; facilities can be
combined with the flexibility of land treatment to respond to needs as
they are required. It would appear to meet the ultimate requirements of
the recycling and utilisation of valuable wastes and the preservation of
valuable water resources.
/*).
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Petition
Page [_
we, the undersigned residents of the Town of New Milford, State of Connecticut
Jo petition the United States Environmental Protection Agency and State:
1. The proposed eight-ioid extension of Wastewater treatment and
collection system is excessive to our needs and ability to pay
which will be destructive to our natural growth.
2. Mindful that our existing plant requires modernization, we urge re-
consideration of a program to extend capacity to a maximum amount
not to exceed 2 M.G.D.
NOTE
The above petition bearing the signatures and addresses
of 1167 residents of the Town of New Milford is included
as a part of Document R23.
-------
Fiscal -tightrope
Bethel faces crucial choices
Editor's note: This is the first of
two articles dealing with Bethel's
growth and its Impact on the town's
taxes now and in the future.
Today's article explores the
problems growth is creating for
town policy makers.
By Joe Hurley
News-Times staff
BETHEL — There's a For Sale sign
on the manicured front lawn. It's been
there two years. Inside, the owner looks
through his picture window at the back
of the sign. No calls today. He wonders
what went wrong and decides to again
lower the price on a house he once
thought would yield a nice little nest
egg.
He wonders about the tax bill he just
received — $2,000 a year to keep his
dreamboat afloat.
This is the sobering reality faced by
many Long Island home owners today
and the spec tre of a pattern which could
haunt Beth( 1 in the future.
Like othei area towns, Bethel is in the
midst of unparalleled growth. Town
officials walk a tightrope, trying to
provide essential services without
overcommitting the town's resources.
Spend too little and the town may face
several staggering projects at once.
Spend too much and the town may be
committed to an unnecessarily high tax
rate.
The key to balancing on the tightrope,
some qualified observers say, is
spotting growth trends and limiting
services when growth stops. Some area
residents feel that missteps by Long
Island policy-makers sent that housing
market tumbling.
After World War II, home
developments sprouted up on eastern
and middle Long Island like wildflower
patches on a country hill.
Many of the new residents were
former city dwellers attracted to places
like Hicksville because a new highway
system eased access back to New York
City.
The former urbanites expected city
services and, in many cases, officials in
the newly swollen towns provided them
in anticipation of even more growth.
By 1960 however, the tide turned. The
anticipated growth never materialized.
Towns were stuck with costly services
they could have done without. Taxes
went up. Expensive schools went
unused. Businesses began to leave. Tax
rates increased to the point of making
some otherwise attractive homes
undesirable.
Bethel and the Danbury area opened
up to New York residents with the
completion of Interstate 684 in 1968. The
proposed upgrading of Route 7 from
Norwalk to New Milford could create
another corridor for urban traffic.
Now town officials must deal with the
same problems Long Island officials
faced. But they are determined to avoid
the same mistakes.
"The average person doesn't realize
how much we grew," says Tax Assessor
Thaddeus Carcasty, noting Bethel has
just passed through five years of the
greatest growth the town has ever
experienced.
In 1960 the population was 8,200. In
1970 it was 10,945. Carzasty estimates
the current population at 16,00Q.
Along with new residents come new
services. Part of the pressure comes
from sheer numbers. But part also
comes from a new type of resident.
Like Long Islanders of the 1950s,
many of Bethel's new residents are
former city dwellers. They are
accustomed to services and used to
paying for them.
But First Selectman Francis Clarke
points out that the cost of these services
in Bethel may be intolerable.
Continued on Page A-3
-------
Bethel faces crucial choices
Continued from Page A-l
"We don't have the tax base of cities
like Greenwich," he says, pointing out
that the average taxpayer will have to
bear the burden. Caught in the middle
could be the longtime town resident who
neither wants nor can afford the new
services.
"It's one thing if people want those
services," Clarke says, "but they have
to be willing to pay for them."
Spiraling growth and demands have
. spawned a proliferation of services and
1 facilities.
In the past ten years. Bethel has built
a hfgh school, added to it and built an
elementary school. It has constructed a
new police station, added to both fire
stations and is constructing a water
treatment plant.
The police department has jumped
from fewer than 5 men to a force of 26.
New fire equipment has been purchased
for both volunteer fire departments. A
new health department operates out of
rented quarters. A new park and
recreation director operates out of the
old police headquarters.
There is a new public works
department, a new public works
director and new assistant director. The
highway department is rapidly
outgrowing its quarters.
There is a new comptroller, new
building inspector, new social service
worker and new conservation officer.
The first selectman, who had one
assistant in 1950, now has three. Other
town officials have also taken on
additional staff.
Town boards and commissions have
grown. The past ten years have seen the
creation of a conservation commission,,
public works commission, permanent
building committee, health council and
council on the aging. The new housing
authority has a $700,000 housing
complex on the drawing board.
Nor is the end in sight. Clarke says
further expansion of the police
department will be necessary if Bethel
continues to grow. Police Chief Richard
Carlo feels expansion already is
overdue.
. Clarke, who is deeply involved in
plans for an area-wide solid waste
disposal plant, says that is coming soon.
The town, along with.Danbury, is under
state orders to build a sewage
treatment plant.
Public works director Edward
Reynolds has proposed a new public
works garage. He said the town has no
place to store sand and salt and town
vehicles are being housed outside.
"The multiplicity of problems
dictates that we do something," Clarke
says.
A new elementary school, as well as
additions to two others, may get under
way this year if the state's 50 per cent
funding can be cleared.
Funds for a full-time park and
recreation director, a drainage study
plan and automation of the tax
collector's office are all expected to be
in next year's budget proposals.
Other possible areas of expansion
include joining an area-wide health
district, library expansion, park and
recreation program expansion,
expansion of town hall and employment
of a housing officer.
These new services cost — and cost
dearly. The town's budget has more
than doubled since 1969. It was $3.5
million then. It is $7.5 million now. lt
jumped nearly $2 million since 1973.
These services in the future are
expected 'to be at least as expensive.
Some may come free at the start, such
as the sewage treatment plant the state
Department of Environmental
Protection has ordered Danbury and
Bethel to build.
The plant will be built with state and
federal funds. But operating costs will
be picked up by the town. Selectman
Kenneth Parsons says neither the
personnel rior the chemicals for the
plant will come cheap.;
Police department dispatchers are
another example. Th|y were hired
under a federal grant which paid their
salary during the firs! year of their
employment. The federal share of their
paycheck diminishes yearly.
The dilemma whicfi faces town
policy-makers is, "How much, how
soon?" -
Clarke is the first to admit it takes a
generous portion of luck, as well as
close attention to area and town growth
trends, to come up with the right
amount of services for the town's needs
and budget.
Tomorrow's article will explore how
Bethel has managed to escape the
ravages of huge tax increases, whether
its stable tax rate can continue and look
at some of the uncontrollable expenses
that could lie in the future.
-------
Bethel running out
of its tax cushions
Editor's note: This is the second
of two articles dealing with Bethel's
growth and its impact on the town's
taxes now and in the future.
Today's article explores the
problems in maintaining a stable
tax rate.
By Joe Hurley
News-Times staff
BETHEL — Bethel's phenomenal
growth has given spectacular rise to the
cost of running town government but
homeowners have not yet had to reach
too deeply into their pockets to pay for
the rising cost of services.
An increasing grand list has been the
town's salvation. As expenses have
increased so has the taxable property
list, thus lowering each owner's share
of the burden.
The growth in commercial and
industrial property forming the
"profitable" portion of the grand list
increase may be ending, officials say.
Bethel may have to increase its caution
with town services — or face hikes in its
tax rate.
No matter how frugal they are, town
policy makers could be put in a bind by
the demands of federal and state
governments. First Selectman Francis
Clarke says the tax rate will be in
jeopardy if federal and state
governments continue to mandate
programs without providing the funds
to pay for them.
Clarke says his overriding goal for the
next few years is to keep the town's tax
rate stable. He concedes the town's 58-
mill tax rate may not stay the same, but
he says he wants to keep it from taking
a large jump in any given year.
During the past five years, when the
town's growth rate was its most intense
the mill rate increased only three mills.
Since 1969 it has risen seven mills while
the budget, which was $3.5 million then,
has more than doubled to $7.5 million.
Since one mill translates to about $1 of
taxes per $1,000 of assessed value, the
tax on a $50,000 home has increased by
about $50 during the past five years.
The grand list — the total value of the
town's taxable property — rose by $28
million from 1970 hitting $100 million
last year. It had increased only $21
million from 1950 to 1960 and by $40
million from 1960 to 1970.
Tax Assessor Thaddeus Carzasty says
commercial and industrial property
accounted for 25 per cent of the grand
list increase. Commercial and
industrial growth tends to bring
revenue without demanding town
services. In terms of revenue versus
expenditures, residential property is
considered a liability, creating a
demand for services which cost more
than the town will realize in taxes.
Available land in the town is
dwindling and with it the prospects for
rapidly increasing grand lists.
Desirable commercial and industrial
space is becoming especially scarce.
As growth slows, current property
owners will shoulder a larger share of
new expenditures. If commercial
growth dips, residential owners can
expect to take up even more of the
slack.
Policy makers must balance today's
needs against tomorrow's ability to
pay. A school or town building
constructed in the 1970's will be paid for
in the 1980's. And the "extra" money
that is flowing from rising grand lists
may not be available in five or ten
years.
Clark Andrews, Bethel's treasurer,
says looking only five years into the
future can be frightening.
"A good deal depends on whether
Bethel becomes a bedroom community
for Danbury," Andrews says.
The town should be "very sure" it
Continued on Page 3
-------
Bethel running out
of its tax cushions
Continued from Page 1
needs a building before constructing
one, he said.
He would be willing to see schools go
into double sessions if he were not
convinced new buildings are not
necessary, he added. "You would be no
hero if you asked taxpayers to pay for a
building that's not being used,"
Andrews said.
Not building soon enough can leave
the town in a precarious position
according to Clarke and Robert Weiss,
a board of finance mamber.
"One way to keep the mill rate at a
minimum is to attack the basic
priorities," says Weiss who sees a
parallel in the rapid growth in other
communities and the Danbury area.
Weiss says facilities should be built as
they become necessary in order to
avoid an accumulation of problems
which will have to be attacked all at
once.
But he adds that other towns made
the mistake of building schools and
town facilities which were
"monuments" but soon became unused
white elephants.
He says the town should build only
what is absolutely necessary and keep
construction costs to a minimum. Some
expenditures such as park and
recreation programs and library
facilities are tempting, he said, but
residents should ask themselves
whether they are essential. "If you have
$5 to spend, do you go out and buy a cake
or do you buy nourishing food?" Weiss
asked.
Clarke says he intends to follow a
program of "prudent growth" in town
services, meaning that need must be
demonstrated before money is
allocated.
He adds that demonstration of need is
the cornerstone of his budgets.
"There's a lot of talk about zero based
budgeting. In effect we've already had
that here. Town departments have to
justify their needs. It's the only way we
can keep budgets from getting out of
control," Clarke says.
When it comes to anticipating the
growth trends Clarke admits that sheer
attention to detail is no guarantee of
success. Luck plays a large part in
foreseeing the future.
And, no matter how hard town fathers
squeeze the nickel; no matter how
prudently they construct their
buildings; no matter how correctly they
anticipate future trends; there is a
Catch-22 — government mandated
programs.
State-mandated but locally funded
programs are Clarke's personal peeve.
He contends they are the largest threat
to the town's stable tax rate.
"My greatest concern is that 70 per
cent of the budget goes to schools and
many of the schools' programs are
mandated. We have no control," he
says.
While not contesting the state's right
to require programs, Clarke argues that
once they are mandated the state should
fund them.
"Too many times the state has
walked away from its responsibility.
The state is going to have to do some
soul searching on the legislative level.
They enact but we pay. There should be
a cost impact attached to each piece of
legislation."
Clarke feels that if the burden
continues to fall on the local property
owner, that owner "is going to back up
and say 'no more.' "
Clarke believes the courts may step in
to curb state mandated but locally
financed programs by turning the
funding of schools over to the state. But
he adds that this would probably lead
to a state income tax.
Nor is the state the only villain in
Clarke's book. He says questionable
federal requirements kept the town
from participating in a program which
could have upgraded Benedict Road.
"We do not begin to get our fair share
of federal money," he added.
Property owners in Connecticut are
paying more and more in taxes.
According to a survey by the
Connecticut Public Expenditures
Council 130 state municipalities
increased their tax rates last year; 84 of
these increases exceeded 5.1 per cent.
Twenty-eight towns had increases of
over ten per cent.
Stonington's tax rate jumped 33.7 per
cent according to the council.
Stonington's rate went from 23 mills
for the i975-76'fiscal year to 30 mills for
fiscal 1976-77.
Meanwhile, the Connecticut
Conference of Municipalities says
Connecticut towns and cities rank fif*h
highest in the nation in local taxes r er
capita.
The conference says Connecticut's
per capita local taxes with $355 in 1974-
75, the last year for which national
figures are available. The national was
$288 per person.
Asked whether he thinks local
taxpayers are reaching the limit of
their ability to pay, Clarke replied I
do. I honestly do."
r
-------
DOCUMENT R24
Adam and Karen Halasi-Kun
West Meetinghouse Road
New Kilford, Connecticut 06776
March 2, 1977
Environmental Protection Agency
Region I
JFK Federal Office Building
Boston, Massachusetts 02203
Attention Environmental Policy Coordination Office
Gentlemen:
In re Draft EIS for the Wastewater Treatment and Collection
Facilities for New Milford, Connecticut
We are opposed to the expansion of the sewering system, as
outlined by Alternatives IV-VII, because, to a great extent, its
rationale is based not on current need, but on projected need. As
the higher population estimate projected in the 1960's for the area
has been revised (it is no longer realistic based on present-day
considerations), it appears foolhardy to develop a system, regardless
of who picks up the tab, based on population projections, which
assumes the completion of new Route 7, a continued movement of people
to the external fringes, a continued availability of fossil fuels at
a reasonable cost which allows for our present decentralized mode of
living, a continued movement of industry into the area, continued
"norms," such as the desirability of suburban and/or rural living,
and continued acceptance by the public and elected officials of the
loss of irreplaceable agricultural lands and watershed lands for
development.
While problems in recent years in the area indicate the need for
upgrading and/or expansion of present sewer capacity, we feel that
Alternative III, with modification and possibly with enlargement
potential, if and when the need arises, coupled with stricter land
use controls, would more than adequately meet immediate, short-, and
medium-term future needs. Alternative III, with modification, would
result in the concentration of the growth of multi-family housing,
industrial sites, etc., in those areas immediately bordering the
presently sewered area. It would also reduce the desirability and
cost ^effectiveness of multi-family housing and other high density
housing unto non-sewered areas. Alternative III, with modification,
however, differs from Alternatives IV and up in that it would result
-------
Environmental Protection Agency
March 2, 1977
Page 2
in minimal "induced" growth and would do much to facilitate the
maintenance of the rural character of the town. While, as the
study stated, similar limitations may be achieved through the phasing
process, defining interceptor locations, once built, it might become
too easy to disregard "town" interests, as is being done now, in
favor of special interest groups or "regional" interests. In addi-
tion, all of the alternatives, from III on, with the interceptors
indicated, potentially conflict with reservoir and watershed
considerations, such as the Aspetuck/Paper Mill Roads area on
page 33, and the desire to maintain the natural state of the
Housatonic River area. As much as possible, sewer expansion should
be limited in area to New Milford's main underground water aquafir.
The study states on page 219 that EIS does not represent a growth
strategy. While the EIS package may not be a growth strategy explicitly,
implicitly it is}as the EIS's interpretations of state and regional
guidelines of future growth and location of growth suggest, if not
determine, how these guidelines could, and should, be implemented.
We feel that the mandate from the town is clear—a desire to
maintain a rural characterization of the area with the attendant
"quality of life" that exists today. The proposals, as presented by
Alternatives IV-VII, clearly go against this mandate.
Again, we are opposed to the sewer expansion as presented by the
EIS package indicated by Alternatives IV-VII. We are in favor of a
limited expansion, possibly as outlined by Alternative III with
modification, coupled with strong land usage controls.
Thank you for your attention.
Sincerely yours
Adam Halasi-Kun
Karen Halasi-Kun
-------
DOCUMENT R25
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W nat s going on with tertiary treatment orders?
Danbury and Bethel are under orders
from the state to plan teritary treatment at
their sewage disposal plants to cut down the
phosphates and other nutrients entering the
Still River.
One reason for the order is to lessen the
effects the nutrient-rich effluent now has on
promoting algae growth in Lakes Lillinonah
and Zoar, both formed by the Housatonic
River by dams below the point where the
Still River meets the Housatonic at New
Milford.
In spite of the orders affecting two
sewage plants on the stream which feeds
into the Housatonic, the New Milford Sewer
Commission chairman apparently expects
New Milford can get away Without tertiary
treatment of sewage there.
He told the commission at its meeting
this week that tertiary treatment is hardly
worth the expense and will do little to
eliminate algae in Lillinonah.
His observation brought a challenge from
a spokesman for the Lake Lillinonah
Authority and we expect similar sentiments
can be found along Lake Zoar.
We still expect the state, if it is to be
consistent^ to follow up its orders to
Danbury and Bethel _ with one to New
Milford. Arid we still Believe ffiat T\ew'
MSITdnTought to take a new look atJhe
surface disposaPplan advanppd hv thp
SurihyValley Land Trust.
Under this plan, the nitrates and
phosphates would be recycled into the soil,
helping produce food for animals which in
turn provide food for man.
This plan would avoid the need to install,
either in the near or distant futureT energy-
intensive machinery needed to remove
-phosphates and nitrates h-om the effluent.
And it would be much less costly to oneratp-
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DOCUMENT R26
Date: March 4, 1977
To: Environmental Protection Agency
Attn: Environmental Policy Coordination Office
Room 2203
John F. Kennedy Federal Building
Boston, Mass. 02203
From: Leonard A. Stevens
Box 38
New Milford, Conn. 06776
Re: Draft Environmental Impact Statement, Wastewater Collection and
Treatment Facilities, New Milford, Conn.
The following are additional remarks for the record to be added to
my oral statement made at the New Milford hearing, Feb. 15, 1977.
SLUDGE DISPOSAL
While the Draft EIS voices great concern for the preserving of the
water quality of the aquifer underlying Sunny Valley Farm when it speaks of
land treatment, it does not reveal any similar fears of depositing from
41 cu. yd./day to 53.2 cu. yd/day of sludge in the former McNulty landfill.
Has no one recognized that the landfill is also situated over the same
valuable aquifer?
The impact of this proposed practice on the groundwater of this area
should be carefully addressed and assessed in the final EIS.
PHOSPHOROUS REMOVAL
The draft EIS devotes many words to the discussion of phosphorous
removal by the Carrousel system, as does the original proposal made by
Metcalf and Eddy. However, after all the verbiage the reader is left
with several key questions:
1. Has any successful phosphorous removal system been added to
a Carrousel anywhere in the world?
2. What would be the capital cost of a successful phosphorous
removal system added to the Carrousel proposed for New Milford?
3. What would be the added cost of operation and maintenance
for phosphorous removal?
4. What impact would the chemical additives for phosphorous removal
have on the Carrousel's sludge and how would this affect
disposal of the sludge?
5. When would the phosphorous removal system have to be added to
the Carrousel?
-------
Leonard A. Stevens
page 2
NITROGEN REMOVAL
Potential problems associated with the increased discharge of nitrogen
to the Housatonic River have practically been ignored by the draft EIS.
Several questions thus remain unanswered:
1. What will be the impact of the additional nitrogen discharge
from the Carrousel to the Housatonic River and Lake Lillinonah?
2. If in keeping with the goals, policies and objectives of the
1972 Amendments, it becomes necessary to cease the discharge
of nitrogen, as well as phosphorous, to the receiving waters,
how will this be accomplished with the Carrousel?
3. What would be the cost of a nitrogen removal system added to the
proposed Carrousel, both for capital expenditure and operation
and maintenance?
Such questions should be addressed and answered before the draft EIS
is completed.
LAND TREATMENT
As I have repeatedly charged at the February hearing on the draft
EIS and on previous occasions land treatment has not been competently
assessed in the New Milford-Brookfield area by personnel with the experience
and knowledge necessary to make a fair and competent cost-effective assessment
of the alternative. Both the Metcalf and Eddy proposal and now the draft EIS
betray a lack of knowledge and experience about land treatment. They obviously
see it as only a "disposal" method. Their comprehension of the soil's
capabilities as an advanced treatment system is clearly lacking. Their
knowledge of agricultural drainage methods is thin or nonexistent. Their
concept of how modern, earthen treatment and storage lagoons are constructed
has amused persons with experience in this field. Their discussions of how
many months spray irrigation can continue each year reveals lack of knowledge
on the subject. And their discussion of the role crops can play in the
treatment process indicates a low level of understanding.
The question of who made the land treatment assessment and how they
went about it was never made clear for the Metcalf and Eddy report. I
understand that the draft EIS land treatment material was assembled by a
sanitary engineer, George Sansoucy of Anderson and Nichols Concord, N. H.
office. He has reported to me that he was assisted by two or three other
sanitary engineers and a biologist of the same firm. According to Mr.
Sansoucy, he and the biologist spent one day, from about 8:00 a.m. to
4:00 p.m. making an on-site investigation of land treatment. The bulk of
the information, according to Mr. Sansoucy, came from "files" on the subject.
He and his colleagues, the sanitary engineer reported to me, then spent time
discussing the matter before preparing the land treatment part of the draft
EIS. I have yet to be convinced that any of these people are solidly grounded
in the subject of land treatment certainly not compared to Dr. John Sheaffer
who was brought to New Milford with private funds, spent several days here
-------
Leonard A. Stevens
page 3
and arrived at a considerably different, more favorable assessment for land
treatment.
The Metcalf and Eddy proposal and the draft EIS both address the
subject of land treatment from obviously negative viewpoints. They clearly
set out to prove it is not an acceptable, cost-effective alternative, as
opposed to someone who might address the problem from a positive point of
view, attempting to show land treatment is an acceptable, cost-effective
alternative. The initial approach to the problem, of course, can make all
the difference in the conclusions.
The negativism is revealed in several ways by the reports themselves ,
largely by omissions.
1. They avoid stating that a land treatment system, which would
include secondary treatment, is a full, advanced treatment
system that meets the goals and objectives of the 1972
Amendments.
2. In comparing costs with the recommended Carrousel system
the reports fail to draw a comparison between the Carrousel,
plus advanced treatment units, and land treatment, which is
a full tertiary system—both capital and operation and
maintenance.
3. All the potential land treatment sites were clearly not
considered for either study. Brookfield land, for example,
was not considered at all.
4. The reports fail to discuss the potential income-producing
features of possible land treatment systems in the area,
which could be a cost factor, especially in the terms of
operation and maintenance.
5. The reports belabor the possible hazards of land treatment,
but fail to raise the same questions in regard to the
discharge of secondary effluent to the Housatonic. The
possible impacts of nitrogen consume considerable space in
the land treatment parts of the reports, but is barely
alluded to as a potential pollutant that would be introduced
to the Housatonic by the Carrousel.
6. A major point is made about the hazards of aerosols from
spray irrigation in a land treatment system, but the authors
fail to report that Metcalf and Eddy's investigation of the
Carrousel in Europe revealed how there was great concern in
one country over the problems of "misting" (aerosols)
associated with the equipment. They also neglect to discuss
how the hazards of aerosols can be minimum in a properly
designed land treatment system.
-------
Leonard A. Stevens
page 4
I am led back to the conslusion stated at the beginning of this
section. Land treatment has not received a fair, competent assessment to
determine its feasibility and cost effectiveness in the New Milford study.
Such an assessment should be made with a positive approach to the
subject by experienced, competent personnel before the EIS is completed
and federal funds granted.
FUTURE CONSIDERATIONS
Section 201(g)(2)(A) of the FWPCAA '72 states "As appropriate, the
works proposed for grant assistance will take into account and allow to the
extent practicable the application of technology at a later date which will
provide for the reclaiming or recycling of water or otherwise, eliminate the
discharge of pollutants."
Other than discussion of possible phosphorous removal neither the
New Milford proposal nor the draft EIS satisfy the statutory charge that
is clearly set forth in this paragraph of the 1972 Act. The subject of
reclaiming and recycling water is hardly touched upon. Other pollutants
than phosphorous would, of course, be discharged to the Housatonic River
by the proposed system. How will they be eliminated in the future?
As Administrator of the 1972 Act, the EPA through this EIS should,
it seems, address this question which is certainly involved with any
recognition of the objectives, policies and goals of the 1972 law.
CEQ GUIDELINES
The guidelines on preparation of the EIS set forth by the Council
on Environmental Quality have not been followed in at least two ways
(cited on pages 2 and 3):
A. As other parts of my statement discuss, the draft report hardly
reflects "a process of sound scientific analysis." This is
especially true of (1) population analysis, (2) statements
regarding area septic systems, and (3) assessment of a land
treatment alternative.
B. The draft EIS definitely does not "make every effort to convey
the required information succinctly in a form easily understood."
In my Webster's "succinct" is defined as being "marked by brief
and compact expression or by extreme compression and lack of
unnecessary words and details." The draft is overly long
because of extensive, unnecessary descriptions that bring no new
information to the public and officials it addresses. It is
expanded by redundancy. The style is turgid and obscured from
lay understanding by jargon. The final version should be edited
heavily.
If the lay public is really expected to comprehend such a document,
I suggest it at least include a glossary.
-------
DOCUMENT R27
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-------
DOCUMENT R28
William J. Philipps
RFD #2, Kent Rd.
New Milford, Conn. 06776
February 11,1977
FEB 2 3 1977
Mr. John McGlennon
Regional Administrator
Environmental Protection k&ency
John ?. Kennedy Federal Bldg.
Boston, Mass., 02203
Lear Sir:
Re: New Milford Sevier
Boardman District
Lines to
Why is the Boardman section of
New Iviilford and west side particularly
being omitted from any proposed sewage
lines to 1 • te?
the large volume of the Nestle
even further growth it would
a giant step to come up
Trailer Parks which
Muck Brook.
V/ith
plant and
not be much af
to service the
straddle Bully
.I believe this area is above .plant
level and would be gravity flow. With
the relocation of the plant to the west
side of the river, the pipe woul d not
even have to cro'ss the Housatonic.
Yours truly,
-------
WfcR2 1977
DOCUMENT R29
86 Second Hill R. 3 523 Wren Hall Tufts University
New Milford, CT 06??6 (andBedford, MA 02155
February 26, 1977
Environmental Protection Agency
Environmental Coordination Office
J. F. Kennedy Federal Building
Boston, MA 02203
Dear Sirs:
This letter is to register my disapproval of your draft
Environmental Impact Statement for the proposed Wastewater Col-
lection and Treatment Facilities for the town of New Milford,
Connecticut. I base my opinion on the following points:
1. As proposed, the project is too large. There isn't
a need for a plant of this siz«.
2. Establishment of this massive sewering project
with its "Induced growth" will result in pressure for downzoning.
This ignores the intent of the Master plan of Development for
New Milford.
3. Route 7 will probably never be reconstructed into
New Milford. Therefore, there will not be a major artery south
to, handle the demands of increased population in this town.
b. Additional housing for the elderly can be constructed
without a sewer expansion of this size.
5. With the resultant increases in property values
-------
-2-
brought on by land speculation, farming will not survive In the
area.
6. Land Treatment Is the logical alternative. On a
scaled down project, there would be enough land available. Also,
there is much debate on your agency's conclusion that thi? al-
ternative is not cost effective. The area deserves more investi-
gation.
7. I take strong objection to Point 3 on page 215.
The town's plans do not call for "development anticipated and
induced". Development in the area is inevitable due to its prox-
imity to New York City. This has been recognized by the commun-
ity. Plans have therefore been drawn to provide for orderly
growth based on the zoning regulations. This sewer project will
poduce growth beyond that planned for at present and will ignore
our local intention? for growth in the area.
8. The most absurd point :lii the document come? on page
218. In reference to regional housing, "...New Milford may be
able to serve such a need, but at great distance from Job? and
at a tax base deficit which may not be balanced by it? own economis
growth." To say the least, that is hardly good planning for a
community.
A moderately sized land', treatment £lafet ;should be: the'aiafof
sewer reconstruction in New Milford.
Respectfully,
/yuonathan H. Malone
-------
DOCUMENT R30
February 23, 1977
To The Director
Environmental Protection Agency,
Region 1
JFK Federal Office Building
Boston, Mass. 02203
Re: EIS - New Milford Sewer Expansion
Project
Dear Sir:
I am adamantly opposed to the proposed sewer expansion
plant t© be built in the New Milford-Brookfield-Washiagton
area. It has been suggested that such an expansion will be
needed because of projected population growth estimates.
Granted, there will be a need f©r sewer expansion, but, to
the extent of 4,000,000 gallons a day? And where is all
this sewage to be dumped? Why, right in the Housatonic
River, already being polluted by wastes from several indus-
trial plants, the Nestle Corporation being one. Right now,
garbage is being trucked in daily from all ©ver Connecticut
and parts of New ¥©rk State. Why does New Milford have to
become the official cesspool of the state?
It seems to me that there must be some powerful outside
special interest groups who are pushing this project. Cer-
tainly, the residents of New Milford are not in favor of it.
Not at an initial cost of $4,000.00 per home, plus an addi-
tional $300.00 a year for upkeep. How can these outside
groups knowwhat this town wants or needs? They do not live
here, therefore this expansion will not affect their way of
living. Undoubtedly, there are some few who will benefit
financially, but only at the expense of many. A prime example
concerns a builder who has been granted permission to con-
struct a 460-unit apartment complex in the Pumpkin Hill area
of New Milford. This would probably mean about 800 more
children afed 6-800 mere cars to cause further pollution. And
this particular builder lives in Florida.
Our sch©ols, Police Force, Fire Department, Social Ser-
vices, hospital, etc. will all have to be drastically enlarged
at additional expense to the homeowner by means of increased
real estate tafxes. The completion of the new Route 7 will
be pushed to accommodate the influx which the expanded sewer
project will bring about.
FEB 2 8 1977
-------
2.
BIS - New Milford Sewer Expansion (cont'd)
New Milford will grew, but it should be permitted to do s©
at a normal pace s© that the town caa readily assimilate such
growth without undue hardship @n the present population.
I am thinking ®f Derby, Connecticut which, at one time was
a lovely resort area, but, which, because ©f too-quick and un-
planned growth, has become a blight and an eyesore.
Candlewood Lake, in my estimation, will become nothing but
a swamp. It is already dangerously polluted in several spots.
Toe-rapid growth can only accelerate this condition.
I would like to state, finally, that, where overcrowding
and overpopulation occur, poverty and crime inevitably follow.
Sincerely yours,
Mrs. W. P. Guerra
124 Carmen Hill #2
New Milford, Conn.
06776
-------
DOCUMENT R31
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DOCUMENT R32
FiS 9 t977
56 WEST TENTH STREET
NEW YORK II, N. Y
February 7,1977
Environmental Protection Agency,
Att'n Ehvironmental Policy Coordination Office, Room 2203
John F. Kennedy Federal Building, Boston, Mass o2203
Gentlemen:
I address you on the EIS report on the proposed New Milford(Conn) sewer
expansion. I also address you as a property owner in New Milford for over
Uo years. My husband and I bought property in a delightful, quiet, beautiful
small New England village- New Milford- shortly after we were married in
193^.
We have worked and paid taxes, improving our property as we wefe able all
these years with the end of retiring there to enjoy the fruits of our labors
to commune with the nature we so love, to garden, to cook, to live a simple
life with simple, nice people.
What do we find now? Now that the time for our move has become imminent?
A town frought with dissension, mostly caused by outside developers, over-
active "planners", a sewerage system discussed 8 times greater than any
capacity either we or our neighbors need, huge highways nobody wants
all plans bent on the destruction of the natural beauty we found and
havw sought tta preserve!
When will government..supported by our taxes...respect the wishes indic-
ated by the residents of our community for the protection of farm lands,
the quiet rural character of our towb, the plan of aeveopment we voted
for.
Please note that this family protests this gigantic, unnecessary and costly
plan. We will not be able to attend the February 1$ town meeting, much to
our regret. We take this means to tell you where we stand#
c' \ \ i SadlZ>
CfciLvJ \ O ^ C.tc,
y Saul and Hope Schary i
Long Mountain Road,
New Milford, Conn 06776
-------
DOCUMENT R33
¦i ESTABLISHED 1924 TELEPHONE Elgin- 4-4720
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Architectural Service • Building Contractor
JAN 13 lg77
NEW MILFORD, CONNECTICUT
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rh3«*r»JJJe&s 4 //e TemefMt.MM, Ccnn."
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hrde, sc^.MMxccion^ ot we nr^/s^
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Sewer expMsjcrl prcj&of' Tsbks #T+Q h'sted anpafyts /Py-lS'y
present detailed
-------
DOCUMENT R34
January 20 , 1977
Environmental Protection Agency
Environmental Policy Coordination Office
Room 2203 JFK Federal Bldg
Boston Mass 02203
Gentlemen,
Thank you for the copy of the EIS statement on the proposed
waste treatment plant in New Milford.
After a thorough perusal these are my comments:
1. The proposed facility is much too large for the present
population.
2. For the population growth as outlined and projected in the
report the facility is much too large.
3. The projected costs are just that, projected. There hasebeen
no construction cost estimates on a job this size that, in my
memory, have been met.
The actual costs a nd the hook up costs to present home owners
plus the inevitable maintenance costs would be an intolerable
burden on present property owners and residents of New Milford.
Ij.. If the projected population growth a s outlined in the study
is realistic, the town would be bankrupted;
5. If the population growth figure, assuming the treatment facility
is put in, is not realistic and indeed would be much greater,
the environmental impact of such a population growth is totally
ignored.
New Milford has a limited road and bridge capacityjand present
facilities cannot handle a larger population.
There is already*problems in New England as an area as to fuel
supply and delivery} elctrical capacity is limited and growing
more expensive.
The problem of the water table and its ability to supply more
people with potable water is not addressed.
6. If these and other Important considerations are not addressed
it brings into question the validity of other aspects of this
report•
JAN 2 4 1977
-------
Pa ge 2
7. The town of New Milford can exist and prosper and handle
the projected population growth with a fraction of the
proposed expenditure by upgrading present facilities and
upgrading present septic tank standards.
8. As a concerned citizen I am not convinced bigger is necessarily
better. I would like to see a few spots, at leasts left for my
children and grandchildren to enjoy. I dor^t think it necessary
to make every country village into an urban area.
Very truly yours,
Austin A. Knox
295 Pumpkin Hill
New Milford
Connecticut 06776
-------
DOCUMENT R35
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-------
DOCUMENT R36
February 9, 1977
Mr. John A.S. McGlennon
Regional Administrator 14 1977
EPAj Boston Mass*
Dear Mr. McGlennon,
In reference to the EPA meeting on February 2, 1977 in New
Milford regarding the proposed new sewer system, I would like
to make these commentsi
1. Of the courses proposed by the EPA team, I and apparently
most of the people at that meeting, am opposed to the EIS
proposals there presented.
Particularly, plans two and three are patently out of line
with the communities* resources, projected growth^and with
the residents hopes and desires.
2. The Arab oil embargo and the recent winter power shortage
should make it apparent to you that further Installation
a nd expansion of huge energy intensive pro jects^ such as the
proposed sewer treatment center, is Insane.
3. No longer is bigger automatically better. We must consider no
longer, only our own present comfort and convenience^ but must
start to consider our descendants? right to some share in our
dwindling natural'resources.
lj.. The proposed sewer treatment center and the accompanying net-
work of drains could very well lead to a much greater
pollution disaster than the present dispersed septic tank
systems pose.
In case of a power failure or a prolonged power reduction
or In case of prolonged malfunction of such a large treatment
plant could very well result in the release of such a flood
of effluents that the results would be terrible to contemplate.
5. It was admitted by the EPA team that:
a. That the land use alternative that has been proposed would
absorb a few hundred thousand gallons per day with no under
drains or any other upgrading of that area.
b. That the EPA team had investigated the land use alternative
in a very desultory way a nd had taken the recommendation
of an engineering firm who was obviously against such a
system. This rather than to Investigate, in an unbiased way,
land treatment use In all of its ramifications.
Obviously there are many other areas than the proposed Sunny
Valley area that could be used to cut down on the size of
an enlarged sewer treatment plant.
6. Apparently no thought was given by the EPA team to the effect on
the water /table in this area.
In 1965 there was a drastic water shortage and many wells ran
dry. It could well happen again and 36on.
The effect of gathering up huge amounts of storm water and of
watery effluents a nd dumping it into the river can only have
deleterious effects on the water table.
-------
Conversely the storm water and effluents percolating into the
ground over a wide dispersed area from small septic tanks can
only help maintain the water table.
7* My own recommendations are that the present treatment plant be
upgraded to meet reqiirements of purity of discharge. That septic
tank standards be upgraded and enforced.
That land treatment facilities be instituted to handle the
increased requirements for the present sewer drainage area.
If it becomes absolutely necessary in the future to construct
additional treatment facilities, that such facilities be
formed in small dispersed units so that a catastrophic failure
cannot occur.
Very truly yours,
- X,
Edith L. Knox
295 Pumpkin Hill
New Milford Conn 0677&
-------
DOCUMENT R37
272 Pumpkin Hill Rd.
New Milford, Conn. 0^77^
March 1, 1977
E PA
Region 1
JFK Federal Bldg.
Boston, Mass. 02203
cc: Gov. Ella Grasso
Dear Sir:
I am writing to protest the State's proposal for increased Sewerage
facilities in New Milford.
New Milford is populated mostly by hard working, blue collar people.
We do not have the financial means to do what you are telling us to do. The
burden of the debt we will have to take on will be ruinous to a great many of
the tax payers.
Our democracy is being threatened when the state can order us to do
things which are so much against our wishes, our needs, and our ability to pay.
Tours truly
Doris C. O'Neil
Attatched: Signed petition
-------
Petition
Page
We, the undersigned residents of the Town of New Milford, State of Connecticut
do petition the United States Environmental Protection Agency and State:
1. The proposed eight-fold extension of Wastewater treatment and
collection system is excessive to our needs and ability to pay
which will be destructive to our natural growth.
2. Mindful that our existing plant requires modernization, we urge re-
consideration of a program to extend capacity to a maximum amount
not to exceed 2 M.G.D.
NAME ADDRESS
iQ • *2^6 s p4.y,u (LL,
AA
3. J 7C
4 .Cj 'foa/Arvf ^ ^4
^*¦* -* —
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
-------
DOCUMENT R38
Mrs. Antoinette Went
267 Pumpkin "ill Rd.
New Kilford , Conn. 06776
Environmental Protection Agency
Region I
JFK Federal Office Building,
Eoston, Mass. 02203
Sir?:
As a citizen of New Gilford, and a former member of the Lake
Lillinonah Authority., I am opposed to the notion of "induced" growth, as
well as the additional unbelievable- phosphate load on La^e Lillinonah.
"Induced" growth is not good for afiy tov;n. Orderly growth takes into
consideration a town's needs and desires. The 20th century has seen the
demise of too many small towns whose charm will never again be revived.
Land is a commodity which cannot be i«produced. With disorderly growth 'comes
s 1 urns.
That is not what the people of New Milford want. Those peoole who
havc lived here all their lives and those who hive "aconted" New Gilford
for their permanent residence would li'-e to preserve its rur?l qualities,
while progressing in an orderly, well thought out manner. Connecticut
is such a small and beautiful state. Why not keep it that way?
I am opposed to the total disregard of the EI3 as to the increased
pbophate load on Lake Lillinonah. The EI3 makes not of the fact on page
3.1+2, B.3»c.l that high> phosphorous concentrations stimulate the growth of
Anabaena and Anhanizomenon, "yet you propose to increase the phosphate
load."
It is obvious voU have not taken a thorough look at Lake Lillinonah.
You have rightly shown concern for Lake Cancllewood which is larger and
Highly developed. -But Lillinon :h is virgin in many points along the way.
The scenic views from the lake are breathtaking and could be a recreational
asset to the six towns bordering it, if care were taken to improve it,
not destroy it! Lake Lillinonah, cleaned up, could become a source of
recreational industry, and could be an asset not .a detriment. With
water at such a premium, Lake Lillinonah should be cleaned up not destroyed!
Sincerely,
tr
Antoinette Went
-------
DOCUMENT R39
MAP -
9 Howe Road.
New Milford, Ct. 06776
Februaru 28, 1977
Gentlemen:
A federal draft environmental impact statement (EIS) recommends
that New Milford build a 4 mgd sewer plant. One mgd of this
capacity is intended, according to the EIS for "induced growth."
There is no need to induce growth in New Milford. There are
now plans in progress to build 1,006 apartment units, 119 houses
and 135 trailor lots in New Milford. These plans are not
inconsistent with the town's soil based zoning.
This type of zoning was the foundation for New Milford's Updated
Plan for Development, 1972. The development of necessary town
services such as police and fire protection, schools and trans-
portation was planned in an orderly way in accordance with the
population growth the soil could support. THat the EIS would have
the Sewer Commission usurp the responsibilities of the Planning
Commission and destroy the basis of New Milford's zoning and
planned growth, is evident in the statement on pages 209 - 210
of the EIS "that the Updated Plan of Development be revised to
mesh residential densities with proposed sewer service areas."
Orderly development Includes industrial growth. The building of
the new route 7 into New Milford was expected to attract new
industrial growth to the area. The completion of that road
is now in the indefinite future. A greatly enlarged population
in New Milford would find itself without employment in the area
or even adequate transportation to jobs further away.
It is questionable whether 25^ of New Milford, an area larger
than some Connecticut towns, needs to be sewered as planned In the
EIS. All houses built in New Milford in the past five years
have 100)8 septic reserve. This should serve them for the next
quarter century. Despite allusions in the EIS to trouble spots,
the public testimony of Dr. William Zehrung, town health
director, about eighteen months ago gave no evidence of such
trouble spots.
The seven million dollar bonding required to fund the sewer
project would put New Milfofcd heavily in debt. This is likely
to mean increased taxes to support necessary services. This
cost, in addition to the high price of hooking up to the sewers,
will not fall lightly on a town of primarily working people.
There are also in the EIS plans for a trunk sewer along Paper
Mill Road and East Aspetuck Road, in the watershed area of the
East Aspetuck River Resevolr which constitutes of the resevoir
sources cited in the EIS, Other sewer lines conflict with
a major aquifer on the western side of the Housatonic in the
general Sunny Valley area. Sewwring of these watershed areas
conflicts with the water management policies of the "State of
Connecticut Plan of Conservation and Development."
EPA
Begion I
J. F. K. Federal Building
Boston, Mass. 02203
-------
Expansion of present sewering facilities is required in
New Milford to meet present needs and to protect the waters
of our river valley. In planning the size of that expansion the
following must be kept in mind:
1. The lack of need to "induce" residential growth
in New Milford.
2. The need for industrial expansion to provide
more employment opportunities.
3. The soundness of New Milford's current Plan of
Development.
4. The cost to the people of New Milford.
5. The observance of sensible water management practices.
Yours truly
Linda King
-------
DOCUMENT R40
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DOCUMENT R41
120 Chapin Road
New Milford, Connecticut 06776
February 22, 1977
U. S. Environmental Protection Agency
Region I
JFK Federal Building
Boston, Massachusetts 02203
Dear Sirs:
As a former Selectman and candidate for the office of
First Selectman for the Town of New Milford, I wish to place
my thoughts concerning the Sewer Expansion in New Milford
before the Environmental Protection Agency.
First, it should be noted that New Milford has always
acted responsibly when the need for public improvements has
arisen and it is evident that some expansion and improvement
of the sewage facility in New Milford is needed. The single,
most important question before us is, "How much expansion is
needed and is good for the Town of New Milford?"
To properly determine the degree of expansion, certain
guide-lines must be considered:
1. The immediate cost of the project to the Town;
2. The amount of growth which will be induced by
differing degrees of expansion;
3. The future cost to the Town due to such growth,
among such items to be considered, are the in-
creased demand which will be placed upon the
Town's schools, roads, and health and public
services;
4. New Milford's commitment to protect its environ-
ment and safeguard its future water supply.
Given the Town's commitments to local industry, the apparent
inadequacy of the present sewage facility and the need to protect
the river valley, some expansion is necessary. The cost and
other consequences of any growth, which will be induced by the
project, which is much larger than our actual needs, would be
detrimental to the Town. A more reasonable proposal, one which
serves the needs of the Town of New Milford, is needed.
-------
Recommendations from New Milford's Planning, Zoning, and
Sewer Commissions, the Town's Board of Education and Board of
Selectmen should be considered along with the above mentioned
guide-lines. After these various considerations have been
weighed, the Environmental Protection Agency should present a
proposal which is in keeping with the needs of the Town of
New Milford.
To demonstrate the Town's sincerity concerning this problem,
four positive steps have been taken:
1. Purchase of the plant site.
2. Purchase of a pump station site.
3. Authorization of the bonding by Referendum.
4. Requested E.I.S. Study be made.
In view of the above stated facts, I sincerely request your
consideration to review the proposal.
Sincerely yours,
Clifford C. Chapin
CCC: a
-------
DOCUMENT R42
Paul Douskey
RFD #1 PAPER MILL RD
NEW MILFORD
CONNECTICUT 06776
EPA
Region I
JFK Federal Building
Boston Mass 02203
Gentlemen:
We wish to strongly protest the excessive
sewer program being proposed for our small
town.
We are fully capable of deciding what is
best for our town as we know the area much
better than any outsiders.
No town can absorb unlimited hordes of
parasites who immediately demand city ser-
vices without any consideration for the
citizens of the town and its financial
status.
New Milford does not NEED such a huge pro-
ject and would never have needed same if
developers(fly-by-nights) did their job
rightj
// ,v Yours truly, 7
Paul Douskey ~ Douskey Q
1.3. Towns should hold all bureacrats legally and
financially liable for irresponsible errors J
$ ^"
March 1, 1977
-------
DOCUMENT R43
Feb, 10/977
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-------
PETITION FOR REFERENDUM
TO THE TOWN CLERK OF THE TOWN OF HEW MILFORD. COBB.
Pursuant to Section 7-7 of the General Statutes of the State of Connecticut
and any amendments thereto, we the undersigned being duly qualified electors and
voters of the Town of New Milford, do hereby petition that the proposed Resolu-'
tions number (1) through (6) to authorize and appropriate $11,500,000.00 for the
acquisition and construction of sewage system improvements including Federal and
State grants-in-aid and the issuance of not exceeding $11,500,000.00 bond3 of
the Town to meet said appropriation, which will be presented to and acted upon
by a Special Town Meeting to be held April lUth, 1972, or any adjournment or
rescheduling thereof, be submitted to the persons qualified to vote in a Town
Meeting called for that purpose, not less than 7 nor more than lU days there-
after, on a day set by the Town Meeting, or, if the Town Meeting does not set a
date, by the Selectmen tor a "Yes" or "Ho" vote on the voting machines during
the hours between 12:00 noon and 8:00 P.M., on said date, or such other hours as
the Town Meeting shall set.
SIOHAHJRES (as registered) ADDRESS
"I, circulator of this petition page, do hereby state under the penalty of
perjury, that my address is in the Town of New
Milford, that I am an elector and voter in said Town, that each person whose
name appears on this page signed the same in person, in my presence and that I
either know each such signer or that such signer identified himself or herself
to me, and that all of the signatures on this page were obtained not earlier
than six months prior to the filing of this petition.
Date:
Signature of Circulator
I, Town Clerk of the Town of New Milford, do hereby certify that prior to
the time I accepted this petition page, the circulator thereof signed in my
presence the foregoing statement as to the authenticity of the signatures and
that I either know such circulator or that such circulator satisfactorily iden-
tified himself or herself to me.
Date: ¦ ¦ Town Clerk
¦Qironj -fhg
-------
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-------
DOCUMENT P.45
/iaMy- MsruAatjC t^arzd-AMd.
March 3, 1977
v<
EPA
Region I, JFT Federal Bid?.,
Government Center
Boston, -'ass. 02203
To Whom It *'ay Concern:
'.15; New 'ilford Sewers
-'y two orimary concerns are to insure
the plant be equipped to operate on a
tertiary basis and that it not be overly
1 a r ¦.•>•••? so that it would destroy the rural
atmosphere of our town.
I support the statement submitted
by Walter Conn, district representative
to the legislature.
Sincerely,
Sally Spring Rinehart
-------
DOCUMENT R46
90 Second Hill R.3
New Milford, Ct. 06776
January 14, 1977
Environmental Protection Agency
Environmental Policy Coordination Office, Rm. 2203
John F. Kennedy Office Building
Boston, Ms. 02203
Dear Sirs;
We are writing to your agency to voice our disapproval of
the proposed massive sewer expansion in New Milford, Ct. We
have "been landowners in New- Milford for 56 years and feel en-
titled to our opinion.
In the plan of development prepared several years ago, the
residents of New Milford called for the retention of a semi-rural
character to our town. This sewer system project will destroy
any such possibilty. Downzonihg will result in increased taxes
to pay for added police, fire, roadway, and education costs.
New Milford is a working community whose citizens can't afford
a steeper "tax burden.. Your agency appears to feel that New Mil-
ford is zoned with exclusionary intent. This is false. The
town's zones are based ori soil classifications. Our town is o-
pen to whomever wishes to build on an ecologically sound and ap-
proved building lot;.
The resultant downzoning from Ms project will kill off the
remaining farms in New Milford. With the increased value in
property, it will become much more profitable to sell rather than
farm.
*8
-------
2.
\Je seriously question the validity of your recommendations
and the intent behind them. Are you seeking an environmentally
sound sewerage treatment plant, or are you following some di-
rective aimed at instituting social policy? If you are genu-
inely concerned with.'.the former you would not have discounted
the land treatment proposal. If you are concerned with the
latter,as you appear to be, you will recommend a system that
ignores the wishes of the townspeople and seeks to abrogate the
zoning laws of the town of New Milford. Which is It?
C'* 1
Stephen M.. Golembesky
!•' * v-:- //'
Vera X. Golembesk
(Mrs. Stephen M.)
-------
DOCUMENT R47
KO 1611
March 6, 1977
37 N. Lake Shore Drive
Brookfield, Connecticut 06804
Mr. John McGlennon
Regional Administrator
Environmental Protection Agency
Room 2203
J.F.K. Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
This letter is in regard to the sewering of the town of Brookfield and
especially the portion of Brookfield known as Candlewood Shores.
I attended both E.I.S. meetings held in Brookfield on this issue and the
Public Hearing held in New Milford in February. At all three meetings,
the public feeling was "Nc^sewgjs". However, the Draft EIS statement
failed to express those feelings and it almost seemed that the gentlemen
conducting the meeting in New Milford thought the entire issue was laughable.
We as taxpayers, who will be bearing the brunt of this sewering, do not
find one thing funny in the entire issue!J This is a very serious matter.
The Environmental Protection Agency was originally established to clean
up water pollution. Recent studies disclose, however, that you have failed
to accomplish this with your past solutions. Perhaps, then it is time, that
the EPA realize that the path it has chosen in the past, is not the solution.
In this particular instance, Candlewood Lake is rated excellent by water
specialists and repeatedly tests so. Why then, sewer this lake area?
We feel that this sewering is being done entirely for one reason, and that
is to urbanize this area. The original sewering order for Brookfield required
that the Still River area be sewered--we are several miles west of the Still River.
Why then is this area being considered for sewering? Candlewood Lake is a very
desirable recreational lake and could possibly be the future site of large
condominiums, apartments, lakefront developments, etc., only if sewers are
installed. The influx of people the sewers will bring will cause an undue
strain on this town and indeed, will cau^e a strain on our beautiful lake,
more boats, more people swimming, camping on the islands, throwing garbage
into the lake, etc. etc. etc.
Candlewood Shores is a private development—we have a private water system
that is inadequate during peak summer season, many homes have outages. What
will the increased demand on our water supply mean if sewers are installed?
We have no storm water drainage in this community--if there are problem septics
in here, they most probably could be assisted with storm water drainage., The
roads are privately owned.
There are many facts that your Draft Statement ignored—what the impact will
be on our small rural town 5-10 years from now--the increased demand for services,
etc. etc.
I urge you Mr. McGlennon, to take a good hard look at the real issue here.
There is no proven need for sewering in this town and I would like for my
feelings to be written into the records as strongly 'opposing this issue.
Sincerely,
Donna W. Elms
-------
DOCUMENT R48
E. B. HORTON
RFD No. 4
Brookfield, Ct. 06804
March 4th, 1977
Mr. John A. S. McGlennon
Regional Administrator
U.S. Environmental Protection Agency
Region I
J.F. Kennedy Federal Building
Dear Mr. McGlennont
I am one of the residents of Brookfield who signed up to
speak at the Public Hearing on the "Draft EIS, Wastewater
Collection and Treatment Facility, New Milford", held at the
New Milford High School on February 15th. That meeting ran be-
yond 1 a.m. I could not stay that late; consequently, 1 was
not allowed to speak at that time.
1 therefore request that this letter and its enclosure in
their entirety be made a part of the public record of that meet-
ing in the EIS Final Report.
With all due respect, the chart, Costs to Typical Brookfield
Property Owners (Table 6, p. 22) is incomprehensible. No defini-
tion of the termst Shores Area I, Shores Area 11, and Central
Area, is given. How is the homeowner supposed to know which set
of figures applies to him? Please include a map with this chart
which designate^ specifically the location of the areas discussed
here.
The source for these figures was a Clifford Gold study pub-
lished in May, 197$. That means these are probably 1974 figures.
Not only are they out-of-date due to inflation, but they are not
complete. The homeowner must pay for the cost of lateral lines.
That is not shown. The homeowner must pay for his house hook-up,
which he can be forced to do if the sewer runs a mile away from
his home. That is not shown. Not showing these costs is unfair
to the Brookfield resident who is trying to judge the cost-benefit
~alue of this.
Obviously, you cannot give exact figures on heme hook-up
costs, because conditions vary. Just as obviomsly, you can pro-
vide the parameters of this cost, showing the range of costs for
this, together with complete information on the factors affecting
that range, fend let the homeowner judge for himself.
Quite a few private communities are located along Candlewood
Lake in both New Milford and Brookfield. Your cost figures do not
indicate whether costs to homeowners in private communities would
Boston, MASS 02203
-------
To Mr. McGlennon
From E.B. Horton
- 2 -
EIS Draft
New Milford
March 4, 1977
be higher than those of other residents. If higher, how much higher, and
for what reasons.
Finally, the cost figures given show no indication whatsoever of the
time factor involved. What, if anjj costs does the homeowner pay over a
period of years? If so, for how many years?
To summarize: in your charts showing costs to homeownea, particularly
for Brookfield, please l) Indicate complete costs; 2) Indicate up-to-date
costs; 3) Higher or lower costs for private community residents; and
4) Specific costs for each year over a period of time.
The EIS Draft does not mention the fact that installing sewers depletes
groundwater by removing it elsewhere* The fact that wherever sewers are
installed, wells run dry. The fact that as a result, townspeople must also
pay to install a water supply for the Town.
That is a cost to the homeowner which the EIS Draft does not mention.
It should. It is a cost which the homeowner has to pay.
That is an environmental impact which the EIS Draft minimizes.
It is also significant that this ENTIRE PROJECT could not exist without
State Orders to these Towns to install sewers.
It is significant that the State has not merely ordered these Towns to
abate pollution, but ordered these Towns to sewer.
I enclose an 11-page -excerpt from the Congressional Record, Vol. 122,
No. 132, October 26, 1976.
Quote from this CR excerpt, p. 5s
"To a visitor from another planet, it would seem incredible
that human beings who are intelligent enough for space travel solve
their problems of personal hygiene by putting their body wastes into
the public drinking water and then spending billions in futile efforts
to restore the water to its original condition....traditional disposal
methods are at a dead end—more sewers for more people, more billions
for more treatment plants, more refined methods of intensive treatment,
and still the effluent damages water quality downstream...."
I quote this CR excerpt, p. 8t
"A task force headed by Ralph Nader concluded that after
the United States had spent >3.5 billion in a 15-year water clean-up
effort, the level of filth had not been reduced in a single major
body of water."
-------
To Mr. McGlennon - 3 — EIS Draft
Proa E* B. Horton New Milford
March 4, 1977
I quote from the CR excerpt, p. 1.
"There is also a reluctance on the part of both Federal
and State agencies to adopt technological advances available to
them in the area of sewage treatment. In many cases, the preoccu-
pation with centralized sewage systems has precipitated their con-
struction where they are neither suited nor cost effective."
The wastewater treatment recommended in the EIS Draft—which would increase
New Milford's treatment capacity 8-fold——and the sewering of Brookfield to
feed that facility are neither suited nor cost—effective for these rural
towns.
The enclosed Congressional Record excerpt contains information on new
technology-—established as effective elsewhere—available to the homeowner
to solve septic problems. Similar technology is now available for condo-
miniums and communities in these town with septic problems, for waste treat-
ment on a smaller scale, as an alternative to sewering many areas in these
towns which do not need it—at enormous cost.
The EIS Draft ignores these alternatives. I would like to see a full
and complete discussion—¦and consideration—of these alternatives in the
Final EIS Report. Any layman with common sense can see that they provide
a far better solution—at far lower cost—for whatever septic problems may
now exist. Most important, they are far more sound ecologically than sewers.
Incidentally, the CR excerpt, October, 1976 (p. l) is able to give an
average cost to homeowners that is more up-to-dates "...in many rural areas
around the country, it is not uncommon to find the cost of conventional public
wastewater collection and treatment facilities running between $5«000 to
$10,000 per house.
Perhaps the most incredible aspect of the EIS Draft*s recommendation
for this wastewater treatment facility—and concomitant sewering to feed it—
is the fact that this facility will dump waste into the Housatonic River.
And the fact that this facility will dump waste into a natural waterway
because it has been built with Federal funds allocated for the specific pur-
pose of keeping natural waterways clean. The EIS Draft minimizes this effect.
That is an outrage.
The citigen cannot help but look at this fact; cannot help looking at
the multitude of contradictions in the EIS Draft; at the weak documentation
of existing septic problems in the EIS Draft; at the Draft*s irreverent dis-
missal of alternative solutions; at the Draft's discussions of planning foi
future development; at statements by State DEP officials such as Merwin Hup—
fer made to the effect that the EIS February 15th Public Hearing was a mere
"formality"....
-------
To Mr. McGlennon
From E. B. Horton
- 4 -
EIS Draft
New Mi Iford
March 4, 1977
The citizen cannot help looking at all this, without the growing sus-
picion that the ultimate motivation behind this project is not water pollu-
tion prevention, not to protect and keep our natural waterways clean; but
to develop and industrialize this region of Connecticut.
It is significant that State DEP officials have ordered these towns
NOT to abate pollution, but to SEWER.
It is significant that this recommended project, and its 8-fold increase
in New Milford's treatment capacity, would NOT be viable without those State
DEP orders to sewer*
The citizen cannot help looking at these facts without the strong sus-
picion that the State is using this project—and these Federal funds—for its
own purposes! To attract industrial development—with its jobs and fat taxes—
into the State.
The residents and townspeople in this region do not want the induced
development that this project would bring. No one could sit through your
February 15th Public Hearing on this and believe otherwise.
This project will drastically change the character of every town subjected
to it. The induced growth resulting from this project will destroy the rural
quality of life in these towns and, in effect, urbanize them.
The EIS Draft minimizes this urbanizing effect which this project will
have. I would like to see a much more solid and comprehensive consideration
of this urbanizing effect in the EIS Final Report. It affects the environment.
Insofar as this urbanizing may seem to be in accord with Town Develop-
ment Plans, I can say that the Brookfield 1976 Development Plan discussed in
the EIS Draft on p. 78 is one that no one in Brookfield knows anything about-
least of all, the residents.
No doubt it was given to those who compiled this EIS Draft, and they
accepted it in good faith. Evidently it was drawn up by a handful of Planners
in Brookfield who seem to be the only ones who know it exists.
When, as a resident of Brookfield, 1 asked to see a copy of it at the
Town Clerk*s Office last week, I was told that no such plan existed. The
First Selectman's Office, the same day, told me they had never heard of this
1976 Plan of Development. A few days later, I asked to see this 1076 Plan
at Brookfield'a Town Planning Office. The secretary there told me it did
not exist. When I showed her the reference to it in the EIS Draft, she
made several phone calls, and it developed that there was a copy of it in
some file. Then I was told that copy of the Plan—apparently the only one
extant in Brookfield——could not be taken out of the office. Only after I
asked for a copy to study at home for the fourth time, did the Planning
Secretary put in a phone call to the First Selectman to ask permission to
give me—a resident of this town—a copy to take home.
-------
To Mr. McGlennon
From E.B. Ilorton
- 5 -
EIS Draft
New Mi Iford
March 4, 1976
This is how Brookfield is run--like a closed corporation. There is
MO copy of Brookfield's 1976 Plan of Development in the Town Library; nor
is there a copy of the Albertson, Sharp and Backus Report, nor of the EIS
Draft—nor anything of this nature in the Town Library, except very old
(usually outdated) studies. This fact waa pointed out to Town officials
a month ago. Today, copies of these reports are still not in the Library.
Town officials hare claimed these reports are available to residents.
1 investigated. I found that usually one copy each of these studies—if
that—is available in the First Selectman's Office, only between the hours
of 8|30 a.m. and 4»30 p.m.
When can the resident who works see these? That is most of the tax-
payers in Brookfield.
I mention these facts to make the point that what EIS Planners are told
by Town officials—at least in Brookfield—is NOT necessarily what Brookfield
Town residents want.
In summary, I must express the strongest disagreement with the EIS Draft
Summary Sheet conclusions, p. iit
1) This pro.ject will NOT ensure water quality protection. To the
contrary; it will dump oollutants into the Housatonic River.
Candlewood Lake is now in the cleanest of clean water categories,
and has been during the long ten-year history of this effort..
EIS Draft, p. 134» "Very shortly after the State ordered the
sewering of the Route 7 area, the desirability of providing ser-
vice to the Candlewood Shores area was raised, and apparently
widely accepted."
Sewering Candlewood Shores is not widely accepted. This
area, further, could be served by a smaller alternative system.
Is it possible that bj "sewering" the Shorea, the State gains
ll.QO Jirp.Qkfieid residents to pay for sewering Routh 7? It has been
said by Town officials at Coomiission meetings that there are NOT
enough residences along Route 7 to pay for sewering that area—
which is most probably the real objective of this sewering effort.
EIS officials ought to consider this possibility, and recognize
it for what it is—an effort to develop Brookfield industrially.
2) Insofar as this project may seem to be in accord with Town Develop-
ment plans, the 1976 Development Plan is the best-kept secret in
Brookfield. This project is NOT in accord with what Brookfield
residents want—as they have said at Town meetings and at EIS Workshops.
3) This project WILL have SIGNIFICANT LONG-TERM ADVERSE environmental
impacts. Urbanizing these rural towifc will change their entire
character, with significant effect on the natural environment in
which they now exist.
-------
To Itr. McGlennon
Fran E.B. Horton
- 6 -
EIS Draft
New Milford
March 4, 1977
Lastly, please forgive my typing. It is simple fact that town
residents do not have secretarial services available, nor benefit of
salaries for their time, in pursuing this effort.
Finally, thank you for this opportunity for the public to be heard.
Despite Mr. Hupfer, we hope someone is listening.
Sincerely,
£. B. Horton
Brookfield, CT
Snc.-—Congressional Record, Oct. 26, 1976
My neighbors whose signatures appear below join in expressing these views.
-------
Hf» cejigcessMa,
PilOC2f.OlN.G3. AND DEBATES Oi? THE 0-\f" CONGRESS, SECOND SESSION
utod Sti;cl
/ Ajucrrca
vol. m
WASHINGTON, TUESDAY, OCTOBER 26, 19/6
No.
\^"s=Pccmjj~ genafg
yi>
RANDOLPH STRESSES
THE NEED TO EXPLOHH NEW
SEWAGE TREATMENT CONCEPTS
rj^
t t-'y
SENATOR
Mr
In my judgment, new technology has
developed possible alternatives which
make the treatment of waste for individ-
ual homes, a practical, cost effective way
Mr.. RANDOLiPH. Mr; President, the' . .. .. c ,
construction of numeral sewa-re coil's-" ?f mee£ng tuo Problems ° X-
¦ Won an:; treatment facilities is" now the :t:c,-? *}tao'? th° r*8.2? for
larrrpct J*;"' ~T .collection lines ana large treatment fa-
our Nation.' Despite fl 'realties..¦ Individual home treatment units
billions of dollars, the 1970* census shows1 i could Provide effective sanitation to mil-
that 2G.8 percent of the housing units iiL ^
the United States are not served by pub-! wonomicaLy by con-
lic sewers.-This means that 19.5 million! ^atonal methods, ouchrsystems wi:l re-
households consisting -of 58 5 nrllion .; Ciucs the cost oA sanitation and he;p pre-
Aniericans must provide for themselves!' : serve, our-precious water supplies. ^2g=.-
some method of home disposal for tha ^L_ar§' ^vailaole._EIuch can recycle
nearly 3 billion gallons of domestic sew-i directed ^aste-
Bge which they generate daily. In the; T-riiv^ r¦ -¦or•
vast majority of cases, this situation crc- £u!?°£5?-- tc=nnOi0=" «oula b~ 01
.ates serious health hazards. - . i^es[£ importance in areas rot-re scarce.
The efforts initiated through Federal 'JSS^^s^vate^^ou-u ^ rcs^vtt;
grant • programs to mest. the need lor igo^ig&orin'angj^ajia^igg. Sucn p. -
propei:,c^-ccicn, treatment. and dispesa ;?rams- rRXl rfC4Uce Jy ^ yercexi^ thw
of waste, vhlcn fine envixcnrnentaniealin, -amount of warer used oyanaveia^e 110^
of our Nation demands, has been ham-'; 'hold.
1/
jperwi,
sfcruraon ccsi^.
""On? Government agency. the Appa-
v- or taa *^t o*"' l&chian. Regional Commission—ARC—
rs-'O? --.lfesd the. potential of allerr.a-
sevytag more households
The Commission is pres-
"¦".i," 1 ,¦. 1 eniiy eiiguseu in a demonstration project
i
areas around tSTcoun&y itUzot i serve* f,mgiei "oaie°J «-K ~
ted th»W*hravj5?1 °P.8rated... -nd. maintained by a
public vra.3t&yS^f"c'61!scSon and' i
facilities . running between
•O^CQjaaLjjaii&s. One exam-
problem is -the Hopsibah Pub-
COCUoJlO,
! oi this pr;
: public sanitary district. This concept in-
sures responsible maintenance and opti-
mum-operation.
Members of the Fublic Works Com-
W,^lfc*»ra^.nottov.«i«u1te!£^
mission as a Federal/State partnership.
(public sanitary facilities and a new
sanitation system serving GOO families is
now under study. One segment of the
proposed system which win serve 150
hemes has an estimated construction cost
of $1.2 million, or $8,000 per family. Sven
with 75 percent frrant funds from EPa,
poor ruirJ communities cannot afford to
finance such -facilities.
Thus, it is impossible for local. State,
and Federal governments to provide this
most tunffament'il service to a large seg-
ment of the American naonla bv ccnven-
tlonal means. It Is critical that QltoiT.a-
^tivc methods wnicn nave developed )
I believe the Boyd County residential
wexstewater treatment demonstration il-
lustrates an aspect of the Commission
which has not often, been commented
upon: It is small enough tn h" able to_
resreonci to new ideas-In tills insii-.nce.
the Commission employee with the new
idea was Mr. Larry Waldorf, ARC Pro-
gram Coordinator. It was Mr. Waldorf
who first brought to the attention of the
Commission the contribution which
could be made to dispersed rural popula- .
tions by. Self-contained waste treatment.
> and it was Mr. Waldorf's
1 -J ¦'u.011 Ve" tion to the Commission that a nub
s susses-
! .. . -® • * < ¦ ¦ ji ii. (/tIJil LU biiV LilVVU *V OUbliC Snil-
ispo.^iblg >-ia. and that further develop itpry district be established to assure the
effective maintenance of the unit-
(to handle J ion
isponsibl;
rosnt of tl-.uni bo air.Tresoivelv pursued
I.
-------
Additionally, this pro'.-ra.n has had the
active support and involvement of ARC
Federal Cochalrman Don Whitehead; the
ARC Executive Director Harry Teter;
end Gary Curran,. Special Assistant' to
the Fediral Ccchairman. This vital proj-
ect vo^I-jcts th? cc.r.milr'.c-nt rf these'
public servants to assist peojplein solving'
"their problSfes^l_. ~ . |
. ~Acc'crcIih^ to engineering studies, the
estimated-cost of providing centralized
sewage facilities to the area of Boyd
County served by the ARC demonstra-
tion project is approximately $565,000 or
more tharv $9,000 per house.
The present cost of the Boyd County
demonstration is $200,000 or $4,200 per
house. It should be noted, however, that
this cost includes many items which, are
a result of the demonstracion nature of
the project. In addition, the innovative
nature of the project resulted in rather
inefficient installation procedures and
resulted in higher cost. The lessons
learned In the Boyd County project, how-
ever, will be of great benefit in the ef-
ficient and economical development of
future systems of this type. The Commis-
sion feels that, based on what they- know
from this demonstration, it is not un-
realistic to expect the cost of future sys-
tems to be in the $2,50C to $3,000 range
per house.
The effluent quality tests from the
project indicate that the management
concept developed for the project will
permit optimum operation-of the treat-
ment. This is particularly demonstrated
by the fact that equipment using surface
.dlsshargij ia meeting o • exceeding EPA
standards.
I believe that the Appalachian Re-
gional Commission has taken a signifi-
cant step In developing this system ap-
proach to individual rural sanitation and
earlier this year, in a letter to Adminis-
trator Russell Train, I urged EPA to
fund such projects under title II of Pub-
lic Lav/ 92-500. Indeed, th-a law requires
that such alternative systems be utilized
where they can be shown to be cost
elective
It is gratifying that.the Environmental
Protection Agency is responding to this
now concept. EPA has conducted a site
visit of the Boyd County project and is in
the process of scheduling a future in-
spection. I am informed also that EPA is
in the process of formulating regulations
with regard to the utilization of systems
to serve single homes. I am hopeful that
EPA pursues this effort vigorously.
Mr. President,. I submit a briefing
paper describing the ARC project, my
letter to Mr. Train—with enclosures—
and his response for printing in the
Record.
Thera being no objection, the material
was ordered to be printed in the Record,
as follows:
[Briefing puper from the Appalachian I'.e-
fclon.il Commission, Washington, D.C,}
P.c:tAL Sanitation: A Syst::m Approach To
Individual liOMZ _
This briefing paper describes the Home
Wastewater Treatment Demonstration Proj-
ect now underway la Boyd County, Kentucky,
and ttif> rationale behind the project's c!j-
velopavjnt.
w j Appalachian He3lcn?.l Csaunl&ilon hi-s
approved the .sum of $100,000 la Section £j2ii
Commission Research funds for ths purpose
of establishing and conducting this demon-
stration project. The purpose of the demon-
stration 13 to bring together the latest tech-
nology In the field of home wastewater
treatment In a way which will be potentially
most beneficial to rural Appalachla.
THE PB03LEM DETWEa
Throughout Appalachla, as well as other
rural sections of the United States, countless
f.rens • exist which pcce ol^nlicaat obstacles
to tfco.. Installation of conventional sewage
collection and trsatment facilities. Factors
such as severe tocography and low popula-
a-:e the cost
tlon dsnsjtx.ma:-
ccst. of conventional
.sanitation faclUtles"prohibitive, ranging from
35,000 to 510,000 psr connection. Although
septic tan£s are -widely used lr. rural areas
as an alternative, it is estimated that ap-
proximately 50 percent of these septic sys-
tems do not function properly. The sells In
much of Appalachla do not provide the
percolation required for septic tank use. The
choice, therefore, is either to prohibit de-
velopment, in such areas or to finance the
extremely high cost of conventional sewaga
collection and treatment facilities. This cost
Is, In Itself, a substantiardete:ent to develop-
ment in nsw p.rea3. Similarly, thsre remains
the problem of homes presently in use with
falling septic equipment. The alternative
here Is either to provide adequate sanitation
facilities or, short of moving ??.;ni!i
-------
TUB SYSTEM Ai'P:iO.VCJS
The alternative which seems to hold tho
¦nose promise 13 the "system approach" to-,
.ndlvlchul home sanitation as now In oper-
ation in U\o Boyd County project. The dem-
- Titration proji-": hus created a public sanl-
¦.ry dlwict (fxinilatton District No. 3) \iri-
v tliS 1-V.V3 or tho Commonwealth of I'cn-
"•..t:ky. All of the equipment In tho Boyd
C\ uaty project wlli be owned, operated and
maintained by Sanitation District No. 3. The
Districts.lias In Its cm; loy a licensed sewage
treatment plant operator wiiose full-time
responsibility Is the efliclent operation of
the entire system of Individual aerobic treat-
ment units. In the initial stages of the pro]-,
ert, tho operator has been Involved in the.
Installation and start-up of all project equip-'
ment. He receives Instruction from the man-
ufacturers involved In the project in repair
and maintenance of each type ci equipment.
In addition, the operator Is on-call for emer-
gencies and has at his disposal the necessary
spare parts to quickly replace any malfunc-
tioning components.
In the first year of the demonstration the
Appalachian Regional Commission will fund
100% of the cost of maintaining all equip-
ment in the system. In the second year of
operation the maintenance cost will be
shared 50% by ARC and 50 & by the home-
owners. In the third year, all maintenance
will be paid for at the local level. To ac-
complish this, starting In the second year
each home will be assessed a maintenance
fee which will be paid to the Sanitation Dis-
trict. As the Boyd County District No. 3 is a
permanent sanitation system which will op-
erate in the same manner r.s a municipal sys-
tem, it Is envisioned that the number of
homes' served by the system will be expanded
in the future. It Is presently calculated that,
a system serving one hundred hemes cr.'iUl
be operated, after the initial 3 month period,
for a per unit operating f ee of 35 to $7 par
month. This fee compare:, favorably with
charges paid for municipal sewage collection
and treatment facilities. ) ..
If it can be demonstrated that this system
approach1 to individual home sanitation is a
cost effective and efficient method for meet-
ing the growing rural sanitation problem,
the Commission feels that the major Fed-
eral grant-in-aid programs such as EPA and
the Farmers Home Administration, should
participate In such systems through regular
construction grants. The system approach as
presentad in th» Boyd County project estab-
lished for the first time, an ongoing public
body which is a legal applicant for Federal
gr&ntl-ln-ald funds- ior sanitation systems
composed of Individual home treatment
units.
'project scope
Tho project has the participation of the
sir National Sanitation Foundation (N.S.F.)
approved mahiif'acturers Juration ho.me
"wastewater treatment sys'tems. The sis- man-
'TflScCurei's participating In the demonstra-
tion are as follows:
Multi-Flo Incorporated—Dayton, Oh 16.
Nayadlc Sciences, Inc.—Uwchland, Penn-
sylvania.
Cromaglass Corporation—Wllilamsport,
Pennsylvania.
Bl-A-Robi Systems—Hamlin, Pennsylvania.
Jat Aeration Company—Cleveland, Ohio.
Flyyfc Corporation—NorwaUt, Connecticut.
Each of these manufacturers has agreed to
supply six -jingle family units for the proJ-Jct
at a price which is at cr below dealer cost.
The total of 30 units are located In u :>m.i!l
area of Boyd County known as Upper Chr.d-
Wlclt Creole approximately five miles from
the .Huntington Airport. The 30 units are
plp.ced in. lr.dlviJ'jal homes lh this area and
V.:i I'2 ,;:rvio«l i-.n-J monitored for a period
of one year. In ac'.diilor., v.va multi-family
units service a total of eleven familic.-, where
small clusters of homes provide a natural
setting for such multi-family units.
As come manufacturers offer more than
one system configuration, maximum project
range has been achieved by utilizing as many
system variations as possible. For example,
Multi-Flo offers a system which can be used
in conjunction with" jrecy cl lr_g equipment
which reuses treated waler for the toilbt. It
13 proposed, therefore, tha't ^.'uitl-Flcw sup-
ply three units with recycling equipment and
three without. Similarly, Js: Aeration manu-
factures a system with or without a second-
ary treatment tank. Both options have been
Incorporated Into this project. Further op-
tions are available with other manufacturers
vrhtoh allow wastewater treatment facilities
to be used in addition to or replacement of
existing septic tanis, as well as the modifica-
tion of such septic tanlss for use as the major
component of the wastewater -treatment sys-
tem. Tie project has been laid cut, therefore,
to assure the maximum number of possible
Individual configurations. This aspect of the
project has also been aided by the many dif-
ferent installation requirements encountered
In the proj ect area.
Since a properly maintained aerobic treat-
ment tjnh produces "an effluent of 'sxtperiot
qujvlity to that of a septic tan'.;, aeration
oSera greater fisilfcllity in the options avali-
r.hle for' e21usni "disposal. Th? mother's of
disposal being v.:. MOWTTORING
The JTVCO Area Development District in
Boyd County received the grant to carry out
this project, and contracted with the partici-
pating ilrm3 for tha purchase of all equip-
ment. For the purpose of insuring eiaclent
operation, each manufacturer supervised the
Installation of his six units through & com-
pany representative or distributor. While all
Installation costs ore paid by the project,
the power required for each system will be.
tied Into existing service ar.d the homeowner
will pay for any additional electricity. Hone-
owners have been asked to record the in-
crease In their monthly electric bill so that
the average opsratlng cost can be determined.
Prior to tho stari-up of the wastewater
-------
treatment units, K1VCO water quality
tciw performed on tho stream which drains
the proj'-ct nroA (Upper Forlc of Chadwlcls
Creek). Similar tests will by performed at
the conclusion ot the demonstration to do-
t-.-rrnlne If c.iiy Improvement la wM. r qv.rdlty
l::vs resulted '¦'ro:n tl:!a j In mtdlt!<.-n,
t* via demonstration unic w;*I 'co tested twice
wtonthly. A :;arlc;3 of teiU will be performsJ
to determine the quality or ei2uent produced
li/ each system. Tests to be performed are:
L.UD. SS; l'h, Tamp, Dissolved Oxygon and
Fsoal Collform. Test results will bo available
from ARC on a monthly basis, and a final re-
port will be Issued at the end of the demon-
stration.
THE DEMONSTRATION AREA
'.!Thfield demonstration project by
the Appalachian Regional Commission In
Boyd County, Kentucky. This endeavor Is to
test a system approach to individual small
single family and multiple family aerobic
treatment plants, utilizing a public sanitary
district manrigen^rst concept It-Is my un-
derstanding that EPA, four years after the
enactment of P.L. 02-500, has no demonstra-
tion project that has progressed as far as
the Commission's field testing project. This
apparent neglect of' Sections 101(q) and
105(c)(2) should be remedied Immediately.
The Hepstbah Publis Service District (PSD)
In West Virginia is currently completing Its
Step 1 phase for a conventional sewer system
with central treatment connected to homes
by sewer lines. Prohibitive costs have caused
approximately 150 residences In three very
Isolated areas In the PSD to be removed from
the project. It seems that these three areas
would provide an excellent location for an
expanded demonstration project similar to
the one In Eoyd County. These homes would
provide a cost comparison with; the other
areas of the PSD'cerved by the more tradi-
tional treatment and collection line system.
Enclosed is a description of the Commis-
sion's- demonstration project Our staff has
met with olUclals of the PSD, the Appala-
chian Commission, and representatives of
EPA from both Washington, and Philadel-
phia. The EPA personnel have been helpful
and cooperative in our discussions. The PSD
Is anxious to cooperate In this type of aero-
bic system project In the three areas and the
Commission has uiade a commitment to pro-
vide advice and counsel based on their cur-
rent experience in Boyd County.
I strongly ur^e you to assure the con-
tinued cooperation of EPA v;lth the PSD
stair, their consulting engineer, and the
Appalachian Commission to expand tlic pres-
ent project to Include aerobic systems In the
abovc-roeiitloncd isolated areas.
H
-------
An you knov/. there Is a limited amount of
funding nvullablo for research and demon-
strallon. Thua, I believe thin aerobic system,
which la eligible under Sutton 213(2) (a)
and (b), should be funded under the regu-
lar EPA 75 percent grant program. Tilts pro-
cedure Is In.portent because It may be possi-
ble for the Appalachian C-.iKimtjrJon ur.d^r
lt.s Section 2C2 or 21-1 .-.iUtLcrity to piovicla
a supplemental (jrant of up to five percent.
In. my judgment, a further demonstration
of aerobic systems or other single family
or multiple family systems by EPA la re-
quired to carry out the Congressional In-
tent of Section 104(q) and 105(e) of PXi.
92-500. The cost factors demand It. If the
conventional Hepzlbsh project was to be ex-
panded to the three Isolated areas presently
deleted (150 cowaae. connections). It would
add at least $1.2 million to the total project
cost. Preliminary estimates based on the
figures from the Boyd County c'ernor.otratlon-
project indicate that the aerobic systems
would cost approximately $-100,000, a two-
thirds savings.
If this projected cost savings proves out.
It will/have a major beneficial Impact on the
cost of" cleaning our Nation's wastewater
problems. It v/ould also improve substantially'
at reasonable cost the quality of life In rural-
areas...
Russell, I am very excited about this con-
cept and its potential. Tour personal.efforts?
to Insure that it receives a full and fair test'
will be genuinely appreciated.
With sincere thanks and very best wishes,
I am
Truly,
Jennings Randolph.
Enclosures.
(Extracted from the Bulletin of the Atomic
Scientists. Novemtsr 1975]
The Se'.verlesj Sccrjrv
(By Harold H. Celeb)
The flush tollat took clviii^^ilon down the
wrong road a century ago, and the problem
grows worse each year; now, i culet revolu-
tion In disposal methods promises p. more.
Jsehsfble~alternative, but it will take con-'
certed public effort to bring It about.
To a visitor from another planet It would
seemTncredlble that human beings who are:
Intelligent enough "or space travel solve thgte.
problems of personal hygiene by putting'
their body .waste Into the public '"drin&las-
water and then spend billions in futns_eifcris-
to restore the"water to Its original condition,
It is scientifically possible but'financlaHy
lnfcftslble to restore-water completely on<;e
it hn¥~Eeen Contaminated by body "wastes.1
"The flusii'toilet, long considered the jy.erg-
syrhT55l or modern sanitation and progress.
wastes about 40 percent of all water piped
Jf.Vo tne home and befouls waterways from
"the muddy Potomac_to _ the blue Med'iter-
. fanean. Despite the money and energy spent"
"on sewage treatment, traditional disposal
methods are atjt dead end—mora sewers for_
more people, more fethloiis~!gr~"nigfe"tre'at-
l njent"" plants, more refined" mefEocis. of ln-
Itensive treatment, "and stilf'tha eiiluent"
damages water quality" "downstream. Ad-
verse 'efrccts ~of present sewage disposal sys-
tems Include the following:
Risk of transmitting diseases to water
users ' dovmstrearh. Chlorlnatlcn effectively
1:111s bacterid In the drinking water but thcro
Is lew certainty about killing viruses, which
cause diseases such as'polio ahd infectious
hepatitis and are suspected as or.a cause of
cancer.2 r.ocont finding in ML-r.lssIppl
Hivvr "oa;l:» Indicate that chlorlr.atlon t.3 kill
bacteria from t>3!lets \jpstream may Itself
create carcinogenic substances In the drink-
ing water.'
Waste of large quantities of purified drink-
ing water to carry away small quantises of
body wastes. The average toilet flush uses
about five gallons of water. In one year the
typical user of a flush toilet coutamlnaies
13.CC0 >::;ulor.j oi' ire.Vn water to carry away-
165 gallons of body wastes.
Enormous expenditures for sewer lines and
treatment plants. A recent estimate states
that complete sewage treatment for'one small
river basin—the Potomac—will cost $1.4 bil-
lion in addition to the substantial sums al-
ready Invested in recent decades. But even
this huge expenditure will not make^the river
6vZIffimai}ie. (in T5~S5 President JoftHLcn, In
signing a water quality bill, pledged to re-
open the Potomac for swimming by 1975.)
Accelerated eutrophlcation of lakes and es-
tuaries. Even advanced treatment dees not
completely remove the dissolved unwanted
nutrients from the efihient.
Leakage of raw sewage. Aging sewer lines
can allow leakage into the ground water
supply or Into surface waters.1 The reverse,
ground water leaking Into' sewer lines, can
also happen.
Build-up of large amounts of sewage
.sludge. The sewage sludge produced at the
'Blue Plains Plant serving the Washington,
D.C., area, for example, is expected to reach
2,400 tons a day when fully operational.
^Ttural residents do not look with favor oh
receiving the growing waste lead.-
In an effort to overcome environmental
problems caused by the flush toilet, sanita-
tion authorities have developed excessively
centralised systems—the collection c:" hu-
man wastes from hundreds of thousand and
even millions of people Into one place for
disposal. Such centralized sr? terns
ner?b
downs
l::yf?6"ociih^ or h:::h TvaiT r—all or whim ca
send miliions of gallons of raw sewage
downstream.
The present situation is bad ehough, "out
what of the future? In 1970 the Council on
Environmental Quality estimate-:! that mu-
nicipal sewage loads would nearly quadiuole
within 50 years. The Environmental Protec-
tion Agency received estimates in 1972 from
municipalities for more than $50 billion to
build sewage treatment facilities by 1SD0. but
cautioned that the estimates might Include
Inflated costs because 75 percent o' the
amount would come from Federal funds.
V/lnfield M. Kelly, Jr.. of Prince Gerr-a's
County, Ma., staged that 1035 sewn^.-'Iow
"huc-'g proposed regional trca~t-
q county exceeded the avail-
U* iUlrV U.ili X\J 1
sposal. Such centralized systems an- vul-
srable co fcower failures, equipment b.-?ak- )
wns, employee strikes, and ~rT-~- ^
" "" J
estimates for :
meat plan x'or
abie~Tr£Ter supplies for the area by 321 mil-
lion gallons a day.
Thus it Is.Increasingly apparent that sani-
tary engineers and public health officials took
the wrong turn In the road in the nine-
teenth century when they encouraged v.-be-
spread adoption of the flush toilet. The tens
of billions now programmed in this country
for sewage disposal merely take, us further"
same read.''Sanitation authorities
should also take a hard look at the kitchen
garbage grinder, wh ich pu to a h eayy""!oad oT
organic wastes into the pub!!c water sup-
ply. Is the time to stoji^this new threat
.to^our rfyers., la};«;..tvnd ooeansr. '
'flic solution iOL_{hese water-supply Jinij
sanitation problems seema'elementary"(j) \
body wastes should not be nut Into tlio pub- 1
lie water supply, rnd (2) s;owB£e dirpjsal '
_ sv:it::ti\r, ¦ liouid'^-o decentrall-/ ;d with a:"ivT
d'..-po^;d oTi:"-Vij ;ndiv Id;fal House." p.p.irt="
-------
mu.it factory. I*i:fcr^ f>:s. tJr.j-n
ot pli!r:iTJT:: ;; iincfctu^ hr-d avaWms
for rcsxcUl'i. boOywiuitra buck to the land—
crude. perhaps, but nwrVecolosjically couud
for'TKe long run .than liUohing them . Into
tbe jvftter supply of tbe next, town down-
jstrcg.ru. ..
A ln!? plficfr In Sv--:lc!;n unci'
trie Stat;:.;. li:r.7 mjihad^pforalue to.
solve tl:o_ jsewage. projteco~6y' 'gEpasi ng of
Vnstes on "or near- tho site without the use
of large* quantities of water. Thoy ofTe'r us '
the_ch»nce to decentralize humsa sanita-
tion without going buck to the evils of the
outhouse. .If widely adopted they would dras-
tically cut clbw'n'water consumption and
could- eventually eliminate costly sanl'tary
sewers and. treatment plant3..
Waterless toilets were developed several
decr.des ago for owners of hemos where water
and sewer connections wars not available.
Because it is now forbidden, by lav to d'a-
charge bedy wastes into harbors and other
confined waters there Is a need for sewage
disposal systems aboard. Inland and ocean-
going VC33&13; and several large companies
are now Investing millions in this field. It is
only a step to adapt this new marine tech-
nology for use In year-round dwellings and
high-rise buildings ashore.
There are at least seven dieersnt types of
sewer!?;>s toilets or sewage disposal, systems
on the market or under development at this
time. (Tee author has not personally tested
"any of these systems.)
AE20BIC TANKS j
The problems of septic tanks are well'
known, recently a number of U.S. companies
hp.ve rr.p.r'.:'.;ied disposal systems that depend
on aerobic rather than anaerobic action to
digest waste materials in the tanks and drain
fields. TJv:y dlTsr in czst tnd iesigri but h?.vo
in ccr-irnon the use of small electric pumps
that p:r-ci!c.a!ly m!:: air :*ito th; tanks to
break* up solids and speed xip digestion. of the
waates. In contrast to a septic tank, th
-------
tion of methane which could be sold for •
household or industrial use.
AU other devices lu the categories above
require some use of electricity, oil, or gas and.
In addition, the vacuum toilet usos small
amounts of pumped water. It would take a
detailed study of each system in actual use
by many families for a period of months to
IfYik-3 valid aino:.;; them, and to
cumpai'c t.ic..- .total energy reiiulromsiHj in
a city of %ay, 100,000 people with the great
amount of energy needed for pumping mil-
lions of" gallons of fresh water and sewage a
day through the traditional centralized dis-
posal system of that city.
The economics of the new" equipment may
favor a sewerless society over traditional
methods. In some places it now costs a build-
er from $1,000 to 51,700 to connect a, new
house to a sewer line, in addition to the cost
of commodes and waste lines in the house.
Such costs would go a long way to pay for
tho new devices. But even if pressnt co:;ts
were doubled, the new equipment would be
worth Installing because of its great ecolog-
ical benefits.
Clearly the transition to the sewerless
society will be a task which will take decades.
As a first step the new devices could be In-
stalled where no sewer fines exist; "and they
could be_lnstalled as original equipment in
our jjrowlng suburbs and new towns. Finally
they could be used as replacement equlp7
ment ~ln existing cities and towns, block by
block, with the help of public funds in whole
or in part. '
In the meantime, what about the tens of
billions already .profgrammed for new sewer
lines and treatment plants? \Ye~Kave no
choice but to proceed with building these
facilities, even, though thev will be only an.
interim clean-up measure. .When the sewer-
less society arrives sewage tre?.tment plants
can be converted'to clean':g o**. -street storm
drainage, in itself a heavy ecological burden
for arlvjrs r-nd Ir.lxs to absorb.
While awaiting tho sewerless society we
can make better use of cenrallzed sewage
sludge than stockpiling it in old quarries,
burning it, or dumping it in the ocean off
our bathing beaches.11 For many years Mil-
waukee has dried it'and sold it In 50-pound
bags as a garden fertilizer under the same
VMilorganite." The U.S. Department of Agri-
culture has"an encouraging experiment under
way at Its Eeltsvllls, Maryland, station to
compost sludge from the Blae Plains treat-
ment plant, in Washington. The sludge is
heated for 10 days and Js then mixed with
wood chips and composted for about three
¦weeks; The temperature In the heaps rises to
150 * F, and the resultant product is said to
be odorless and nearly sterile. Nevertheless
the White House turned down an offer to
spread the finished compost on the south
lawn.
A few experiments are under way to pipe
liquid sewage to farmlands and forests, where
It Is sprayed as a fertilizer.1,1 This has a double
advantage: the waste Is recycled to the land
and the water, filtered by tho sol!, replenishes
the water table. But the long-range efTect
Is not yet clear: there may be an undesirable
buildup of heavy metals and toxic chemicals
In the soil, and air drift of pathogenic or-
ganisms is possible. Such land treatment for
all municipal sewage would require; Immense
traets of land near large cities; for example,
about 124,000 acres near Washington, DC.,
and more than one million acres hear New
York City."
• Agricultural use of sludge and compost
from hou.ehold source; like vacuum, oi«-
ilu-hcd.- and composting toilets would in-
volve Jess danger of accumulating heavy
metals and toxic chemicals In the toll than
would sludge from municipal plants since the
harmful contaminants generally come from
factories that dump their wastes Into 'munic-
ipal sewers. But regulations to discourage'
householders from dumping paiv.U. pesti-
cides, ar.;l crankca:;-! oil Into tl.olr toilers
r.r.;;ht still be needed.
Another use of sludge would be for meth-
ane production. Plans for the new headquar-
ters building of the U.N. Environment Pro-
gramme, Nairobi; Kenya, call for generating
methane gas from many waste sources such
as leaves and manure.
Sewerless systems would offer developing '
nations the chance to avoid the sanitation
errors of the industrialized ones. These sys-
tems would also be far more economical to 1
install, if the expenses of sewer lines and
treatment plants are taken Into account. As
an Environmental Protection Agency repre-
sentative 'in New Tori; City said' "If we had
to do it all over again, we might do it differ-
ently, but we're kind of stuck with the sys-
tem now." ™ With no investment in sewer
lines or treatment plants, the developing na-
tions can leapfrog the flush toilet and go
right to the new non-polluting technology.
The government of Nigeria has approved the
use o- the biological toilet.
It is encouraging that more attention is
now being paid to the major environmental
problems created by the flush toilet. Several
articles in widely read publications have re-
cently discussed this subject. At the School
of Architecture at McGill University in Moa-
Jcrnl, study"of alternatives To tha'hush toilet,
identified 60 alternative "systems.-1 .On the
other hand, "the voluminous 1973 study of
sewage problems by the National Water Com-
mission did not contain a word about sewer-
leas disposal methods."
As the r.e::t step. official U.S. nser.cies
might take a more positive view of the new
technology. Certain public bodies such as the
Maryland state government, Montgomery
County, Md., and Fairfax County, Va., should
be commended for their open-mindsd testing
of new sewerless devices. The EPA has an
experiment under way to try an incinerating
toilet system in an Eskimo village In Alaska.
But a more concerted effort, taking only a
minute fraction of the funds being devoted
to building sewers and treatment plants,
would be fruitful.
For example, EPA could coordinate a na-
tionwide testing program through state and
local sanitation agencies to insure that every
promising sewerless device is tested on a
large scale in actual use and carefully mon-
itored. Part of the evaluation would involve
relative costs of installation and operation
and energy needs. The results could then be
discussed at a national conference of sani-
tation authorities and. hopefully, measures
would be taken to encourage rapid adoption
of the successful systems.
- But if the tests show that no existing com-
mercial product can do the job, then a major
federal research project should be launched
in view of the great ecological and financial
benefits to.be achieved if a sewerless solution
l.s found. Surely the brilliant sicentlsts of the
National Aeronautics and Space Administra-
tion. and the National Bureau of Standards
have a contribution to make on waterless
waste disposal. Federal millions arc going
Into energy research. Sewerless waste disposal,
however. Is equally Important to our nation's
future as well as to modern soclctg-Whlch
must inirthnr^ for i:nn.polluting
disposal oT¦lu.-.T'.n body waste.) for the world's
-------
Rrov.-l-^; population.
rOOTrfov.::;
1A task force headed by Ralph Nr.ier. how--a
over, concluded that after the United States I
had spirit $3.5 billion In a 15-yoar water \
clcari-up eff; rt. the lov-l of filth had not )
been" ri:d!;v: :J In a eln^lo "major body of*
water.
5 W^whlnr-t.~m Pest, July 20, lfi'/j, interna-
tional Herald Tribune, Uov. 13, 1072.
1 Washington Star-News, Nov. 8, 1974.
4 At the height of the 1375 tourist season
tho National Park Sjrvlc .¦ closed Crater Lake
National Parl: In Oregon because several
hundred people became 111 when sewage
leaked Into the water supply (Washington
Post. July 12, 1975).
•"Containing the Flow of Sewage Sludge."
Environmental Science and Technology, Au-
gust 1074, p. 702.
• • » » . i
"On Slt;> Waste Water Disposal for Homes
In Ur.scvered Areas, Small Scale Waste Man-
agement Project, University of Wisconsin,
September 1973. p. 10.
"Merrill B. Glasser, "Garrett County Home
Aeration, Wastewater Treatment Project,"
Draft (Baltimore, Md., Environmental Health
Administration. May 1975).
"Anthony T. Voell and Richard A. Vance,
"Home Aerobic Wastewater Treatment Sys-
tems. Experiences in a Rural County," Ohio
Home Sewage Conference Proceedings, Ohio
State University, 1974. pp. 20-36.
"For an excellent discussion of ocean
dumping sea Tracy Kidder, "Sludge," Atlan-
tic Monthly, April 1975 pp. G2-70.
"For example, "Using the Land for Sew-'
age Disposal." World, Dec. 19, 1972, p. 43. and
Paul W. Eastman, "The Muskegon County,
Mich. Waste Water Management System."
Pctomac Basin Reporter, T^orsiate Com-
mission the Potomac Rival- Easin, Oct. 137-1,
p. 4-.,
>• Mld-Atlunic Region. Kuvironnontal Pro-
tection Agency, Draft Environmental Impact
Statement for the District of Columbia Water
Pollution Plant, April 1972.
59 Kenneth Walker, as queried In New York
Times. July 23. 1971.
"Wltold Ryboznskl and Alve.ro Ortega.
Stop tho Five Gallon Flush (4th ed. Montreal
Minimum Cost Housing Group. School of
Architecture, McGill University, March 1973).
12 National Water Commission, Water Poli-
cies for the Future. Final Report to the Pres-
ident and to the Congress. Washington, D.C.,
June 1973. Another voluminous study by
David Zwlck and Mary Em-stock, with an
Introduction by Ralph Nader, also did not
contain a word about sewerless disposal
methods (Water Wasteland (New York Gross-
man Publishers, 1971V).
[From the Washington Post, Jan. 31, 1076]
Aekosic Tanic Test in Kentucky as
Alternatives
(By Harold H. Leich)
The remote valleys of Appalachta have
long bceu the preferred iocr.le for Jokes
about hlllbllHes and outhouses. Now some-
thing new Is happening out yonder—Indoor
plumbln;*' is being tested under conditions
that promise a boost for the environment ar.
well as a plcasanter life for participants In
tho project.
Tho Appalachian regional Commission, a
federal-stuto agency charged with Improving
living conditions In 13 ca;;tcrr. stntcs. la de-
voting $100,000 to .i c'."raor.:-Uat;on project
Coii—iy. illsy« it., 4 i*
pc:iutui2 ttca-oicg7 can Improve s.i.i-
lia'.Isn.
If tho demonstration la successful, the
commission hopes that the equipment will
bo l^uitallo4 throughout rural Ao;)a'.:ichU
and thereby avoid the r.ood to spend ::-r.ua
0-") VUlor. cr more that vo-Id fc.>
for traditional sewer lines r.ncl centrdi^vi
sewage tr«.*aC-raent, plus the related environ-
mental problems.
A slid 2 show by the ARC director of the
project Illustrates the problems of rural san-
itation that the project hopes to solve, ex-
pensive homes- are shown with beautiful
lawns that have been gouged out by the
overflow of sewage from falling septic tanks.
Other slides portray sewer drains pouring
untreated waste waters Into sparkling
streams. Only the odors are missing from th2
8hOV7.
The new equipment, marie by st t!l:Ter«>ct'
manufacturers, comes under the heading of
tho aerobic tank, an improvement over tho
septic, or anaerobic, tank. It treats all waste-
water from the home In a tank ur.ds;- the
lawn Bnd releases relatively clean water to
the environment. Unlike a septic tank, an
aerobic tank has an electric pump that mixes
air Into the wastes, breaks up solids and pro-
motes the growth of alr-lovlng bacteria that
reduce cdors and spaed up digestion cf the
pastes.
After treatment, water from the aerobic
tanks will ba dissipated in several .different
ways as part of the experimental project:
To a typical tile drain field under the
lawn, as with a septic tank.
Through a sand filter and then into a
stream or drainage ditch.
Intp an evapotranspiration bed.
To a spray Geld.
Or right hack to the houie for reuse In.
the. toilet lanVvs.
(The consequent v/ater raving wili allow
to family to stop hauling vatc-r for house-
hold use.)
Those various disposal, methods v,Til be
carefully monitored to determine_re!ative ad-
vantages and disadvantages. In the case of
discharging to a stream—the e.V.uent will first
be . . . disinfected with icdme. Cholorina-
tion will not be used for disinfection be-
cause it Is suspected of creating carcinogenic
substances in the drinking water.
Each of the six manufacturers will supply.
sl:c units to the project at dealer's cost. Thus
S3 different homes along Upper. Chadwlck-
Creek In. Soyd County will receive the equip-
ment. Costs will be borne by ARC and the
units will become the property of the local
sanitary district.
The homes differ greatly In location, some
being on steeo land and others birinc mom
favorably situated. Because of wide dispari-
ties In family income and living patterns, the
units will be exposed to a broad variation in
use. To Insure proper installation, they will
be placed in service.by representatives the
manufacturers, and all units will be in-
spected by trained personnel twice a month.
In addition, two larger units will be in-
stalled—one serving five houses and one serv-
ing six. Thus, variables are being deliberately
cranked Into the project by ARC so that re-
sults can be compared and the best con-
figurations determined for future vise. Since
ail of the houses are built along Upper
Chadwlck Creek, one tcsc of the prjjeci's
success will ba "before" and "after" measure-
ments of the creek's water to see whether any
Improvement In quality has resulted.
-------
A novel feature or the Boyd County proj-
ect Is ta.it the local sanitary district, rather
than tBch homeowner, will be responsible
for Inspecting each unit periodically and
making any necessary adjustments or repairs.
A service mf.a with ft stock of sparo parts will
be on. call H hours a day. This new arrange-
ment ov;:r-.ernes obj,v:tljns from some .'.uni-
tary cr-;lir«srs that ;:o:.-.;o^n..'rn cannot b.i
« .pectod to Isaep sueli unS :s operational on a
ious-terrn i.-as':.-, and that a traditional sew-
Bgs treatment plant la the only permanent
solution.
During recent months some of the manu-
facturers participated In a trial of aerobic
untts, oh a smaller scale. In the town of Oak-
land In western Maryland. The demonstra-
tion wau considered successful by the Mary-
land Environmental Health Administration
butr each homeowner was responsible for
maintenance of his own unit. The ARC proj-
ect la a "flr'ot" in respect to centralizing re-
sponsibility in a sanitary district.
ARC will pay 100 per cent of maintenance
costs during the first year of the project and
00 per cent during the second year. There-
after, each home owner will be billed for.
maintenance expenses by the sanitary dis-
trict. The cost of electricity to service the
new units will be paid .by each homeowner,
who will keep records so that cost compari-
sons can be made among the dtSerent instal-
lations.
Harry Teter Jr., executive directorof ARC,
stated that the new project will serve as a
demonstration for all of Appalachia by test-
ing the long-term feasibility of these systems
as an alternative to expensive conventional
sanitation methods.
The real estate world, will watch the Hoyd
County demonstration with. Interest to see
If this new pattern of sewage disposal can be
used in the Washington metropolitan area
and other places where sewer moratoriums
hiive been inpesed and home bullying has
bei'n hampered. If successful. AP.C may estab-
lish a useful :;attt-m thai -..•ill prove less costly
as well as more environmentally acceptable
than the usual pattern of long and expensive
sewer lines leading to centralized treatment
plants that have been so detrimental to our
waterways
A3 to cost comparisons between aerobic
; tanks end centralized sewer treatment, r. re-
j cent news story 13 enlightening. In Prince
[ George's County two new sewer lines ere
I being Installed to service 10 hous-is with
faulty septic tanks at a total cost of $103,350,
or 310,350 a house. And this does not include
the pro-rata cost per house of building and
operating the sewage treatment plant. (True
enough, it is possible that new houses may
be built along these sewer lines at some
time In the future.) An aerobic tank can
be purchased and installed for $1,000 to
$3.000.8 house.
The • following manufacturers are partici-
pating In the Boyd County project: Bi-A-Robi
Systems. Hamlin, Pa.: Croinaglas3 Corp., V711-
liamsport. I'a., Flvgt Corp., Norwalk, Conn.;
Jet Aeration Co., Cleveland; Multo-I'lo, Inc.,
Dayton, Ohio and Nayadlc Sciences, Inc..
Uwchland. Pa.
In addition to the Kentucky project with
With reliance on aerobic systems. AP.C is look-
ing Into other types of sewerless toilets which
could be installed in new homes to be built
in tho area; fof example. Incinerating and
composting toilets md vacuum and oil-
flu.ihcd systems.
Thus, AUG is taking the leadership role in
using Appaluchla as a laboratory for testing
Innovative und non-polluting technology of
potcntlni value to our entire nation.
U.S. Environmental
Pr.oTi:crio:; Agency,
Washing ion, D.C., April 9, 1076.
Hon. Jennings Randolph,
U.S. Sonata,
Washington, D.C.
Dzah Jennings: V/e apologize for the delay
in rty.pondlTSi! to your letter of I'eliruary 20,
i.'f". concerning tin 11 :;:.:ib::h Public 3.
ice District Project. Tha concerns expressed
your letter about the need for a more con-
certed research, effort In developing low-cost
sewage treatment programs in rural areas and
l;i the attached article by Mr. Harold Leich
titled "The Sewerless Society" are quite valid.
It Is the purpose of this response to attempt
to clarify the problem and describe present
Agency research and development ei:or>s to-
ward its alleviation.
The rural and suburban wastewater dispos-
al problem Is the one which is most seriously
addressed by your remarks and Mr. Leic'a's ar-
. tide. Conventional technology and planning
approaches have historically been limited to
" sewered and non-sawered areas, the latter
usually being served by conventional septic
. tank-soil absorption fields. In many rural
areas the onsite treatment and disposal of
household wastes by septio tank systems has
been successful and economical. In several
areas these systems have not performed their
functions properly due to improper spplica-
. tion, faulty design and construction toch-
nla.ues, inadequate maintenance and un-
favorable soil conditions. Proper construction
and maintenance procedures are relatively
well document in the professional literature,
and they can be implemented through proper
guideline preparation and enforcement by
ctate and local regulatory agencies. Deter-
mination of proper application ana design
methods is a more di"ic\;lt task which re-
quires greater understanding of the func-
tioning of septic tank-soil absorption systems
than presently exists.
In suburban areas conventional technol-
ogies are not ideally suited. If sewers are
chosen, they are often in the form of urban
sewer extensions which causes additional
loads on already overloaded urbSSi triatmer.t
systems. Even if they are kept separate from
¦ sprawling urban systems, the population den-
sities are still relatively low, which results
in high per capita costs when compared to
high density urban areas. If septic tank sys-
tems are chosen, the relatively small lot si"es
which are common in suburban communities
present the opportunity for serious health
hazards and aesthetic problems in the event
of any system failure. In less-suitable soils
which do not accept wastewater resdily the
minimum lot sizes may necessarily increase,
resulting in significant increases in the cost
of homes. Even in well designed and properly
operated septic systems there is a need for the
septic tank, to be pumped periodically. The
solid materials, which are removed, then must
bo disposed of in an environmentally safe
manner. Further groundwater problems can
occur by failure of percolation systems; emi-
nent moving through coarse gravel beds, frac-
tured rocks, solution channels or lava tubes;
and percolation systems being located below
the biologically active zone.
Approximately 70 percent of the United
Ste.tcs is served by municipal sewers and
centralized treatment. The remaining SO per-
' cent is served by septic tank-soil absorption
and, to a smaller extent, other onsih) tech-
nologies. such as pit privies. Unfortunately,
less than 50 percent of the available land
area of the U.S. is amenable to soli absorp-
tion systems with reasonable hydraulic load-
ing rates. This fac: and the already noted
-------
lucl: o? «t;rtcT -,tn!: Jln-jC of otisl'.ii soil- absorp-
tion operation havu resulted 1:1 :'.g-
niftr.-.tic v. <.stcwater disposal prtsbtarns from
septic tar.:-; Installations. As a consequence
of theso problems, UPA has undertaken ac-
tlvlttej which are designed to provide the
nece.ssary data "on new alternatives to coii-
vsiitlufiat r.ysiema and sotr.o lonfi-overdua
o'». t.; :i -i.-.tloii::;; uu:l disi0ii
of existing technologies.
In order to relate thesa activities to Mir.
Leleh'y article, several facta must bo con-
sidered. Two EPA funded studies, show that
t t pear capita water usage In the home la
about ~o gallons per day which Is substan-
tially leas than the figure quoted by Mr.
I^leh, Tif which about 30 percent Is used for
toilet flushing. The 30 percent used for toilet
fiushin;; (black water) contains approxi-
mately one-half of the orjjanic and suspended
follds pollutants, about two-thirds of the.
nltrcg an," oaa-slxth of the phosphorous -and
most oZ the microbiological pollutants. Ho-.v-
ever, the remaining' seventy percent ci house-
hold wastewater, which contains pathogens,
nutrients and 'organic matter, generally Is
Ignored In Mr. Lelch's discourse. The gray
water (non-toilet wastes) Is. polluted and
must be disposed of In a safe end environ-
mentally acceptable manner. If the entire
household wastewater Is considered, one can
readily determine that the devices cited In
the subject article r.re essentially tools which
may have potential to solving several • prob-
lems 1:: the water pollution control area, hut
they raur.t be combined with other systems
p.nd devices to provide complete solutions to
both bir.wC r.nd grey water pollution from
households. Ei'A, through Its Bess-arch. and
Dsvetopme.it program Is analysing the capa-
bilities of these various conUnnatloas to de-
termine Jo:i3ible alternatives which are de-
signed to handle all of the household wastes.
One o* TJI-'A's first projects relating to
raeihoda o* ocr/aRS tUspoj;^ invcl-vec. a study
ot flov r-sdvctioii find treatment. of v/aate-
v.'.-.te;* frr.ts Aiouiehdds. 'n v.s.-j rd'ewad, to
early 1S71 with a series of contracts and
grcnts !cr re.'e'-.ich, development and dem-
onstration of sewage treatment systems that
could he installed on various wa'iercrafr, (rec-
reational to commercial size vessels). The
developed systems were required to remove
po% of the biochemical 0:173en demand, 20%
of the suspended solids and produce and
effluent having a collform density of less
¦than 240 colli'o-ms per 100 rc.I. Twelve pro-
totype systems were developed. Included In
the, systems were various meihcds-o£ clari-
fication, catalytic oxidation, stodge lnclncera-
tlon and disinfection Although those sys-
tems have nqt been developed extensively
because of the Issuance of re3Ulatlons pro-
hibiting discharges by marine sanitation de-
vices on June 23, 1972, the reports prepared
on these systems could provide an excellent
basis for development of non-sewered sys-
tems lor rural homes, camps, park sites and
other recreational facilities. In addRion, a
r.'jn-Mwswi system was developed for a
recreational site P-nd was demonstrated at
Mount Hushmore. The system used oil as a
dialling medium. The oil was clarified and
recirculate::. The project was a limited suc-
cess, but before It can be accepted several
inherent problems associated with the use of
oil must be solved.
Soms of the many areas under study cur-
rently by i,?A r.re the vacuum toilets and
aerobic treatment systems described by Mr.
Letch. An 3-.PA vacuum sewer contract en-
tails sous study or vacuum toilets. Aerobic
units for Individual home treatment are
' boln^ r-ti'dl'iU under an EVA par.t at the
t Vniversiry of V/'rscssla. As to other cx.es
'¦it. Lolch prcse.ata ir.anu^'acturers' -chilis 3 ols
nupportlni; evidence for the superiority of
' these devices. Unfortunately, the Claims cited
regarding louder soil life and less frequent
pumpout requirements are not supported by
the contrail-id studies conducted at the Uni-
versity of Wisconsin.
Also, as part o; the University of Wlscon-
r'u'i study, work lias been done o;i we-ste-
¦ water characterisation, analysis of per-
formances of several treatment systems, soil
system design improvements and alternatives,
removal of biological and chemical pollu-
tants, which i iclude virus and nutrient,
studies, and institutional control system de-
velopment for optimal use of on-site alter-
natives.
A grant to the Unlverstiy of Colorado will
define the cost, applicability and design
¦parameters for onstle systems which dispeso
ct liquid wastewaters by evaporation and
evapo transpiration to the atmosphere where
conventional approaches are not feasible.
When combined with flow reduction and re-
cycle devices, concepts of this type may
eliminate soil Impermeability as a limitation
¦on residential development of land.
Several projects have been undertaken
to develop and demonstrate improved cow-
age collection methods for small commu-
nities, low-density suburban areas, and other
clusters of homes for centralized treatment.
The improved systems for low-dens!:y areo.3
are based on pressure and vacuum methods,
which result in significant savings In capital
expenditures through reduced labor and
materials requirements In rocky or hilly areas
or where hi^h gour.dwater conditions r.re
prevalent. Early pressure sewer demonstra-
tion projects have indicated that these sys-
tems can be Installed for around $2.CCD r.er
home, as opposed to conventional £»v;erc3*
estimates of more than tvrlce thi-: r.rr.o-j-.it.
Other active projects wiil- yield info.-,-:1.".ion
on vacum systems and n-ren i;rs e^j.viive
p.«.-«ura system inodlflcr.tlons.
Another area of activity has focused on
the s'.udpes (septage) "ihlch must be pv.mped
periodically from seotic tanhs. This iepte.^e
occurs throughout the country in volumir.oi-.r.
quantities (one billion eallon^, or the same
order of magnitude as sluti;;cs from munici-
pal treatinent plants) each year and reav-lres
prooer treatment be-fore disposal. Several
EPA pilot studies have been made to charac-
terise the sentafie r.r.d develop ultcmr.tive
methods o* treatment. In addition, a con-
tractor is presently consolidating the results
of these studies and other non-EPA informa-
tion in a report for use by local officials af-
fected by the septate problem.
Although our past efTorts have been modest,
the Office of Research and Development is
planning .to-increase their activity in this
area In Fiscal Vear 1377. Our researchers are
closely following the Eoyd County. Kentuci;y,
project and they will be receiving monthly
progress report.-! from the Appalachian Re-
gional Commission. The University of Wis-
consin project is somewhat similar; it also
Is evaluating a number of dilTerent home
treatment systems. However, we feel the
Boyd County Project i=; very significant be-
cause of the recycle systems that tire also
under study there. We certainly plan to In-
corporate some of the result.'; from Boyd
County Into our overall program.
Our Regional Office In Philadelphia Is
working with the State and the Hepnlbah
Public Service District to determine If treat-
ment units for Individual homes or clusters
of homes In the Isolated areas of Hepzibali
fO
-------
•wisnlil be cc.tV-o^-srtirs retatrpe to other
nvst'tccU of v/nstswn L-r colhtcrtlt/ii and- trist-
tv.*«k.cosi-a.r.jctiv?!*.!»« c.\a I;< ?Jjir»n eii4
c£!u»r.-apoUcabln n:r]v~:.-.^r.4n'.. cs& ba nisi,
euch'wi public G'.yn^r-ihip and operation, t'.-.i
tr«sftiif-ant unita wouUl b» e'.lziola- for t* 75
cercmt: ccntruct'.on grant saa'-jiancsr under
Tlttoul Of PJj. 90-ECO.
(Jinca tho Hspatbah project zr-Xy tkiII ba
tliSK-Jrit of Its kiaiS In tfia ccuatry funded
under- Title IX, there may'also be interest
by the OVi'.ce of Research and Development
in a. grant for field evaluation of the project.
We woulS be hr.ppy to. consider any proposal
that Kopzlbah may wish to submit.
Please be assured that the Hepzlbah Pub-
lic Service Diuirict Project will bs given our
close "attention as the application moves
through the grant processing stages.
Sincerely yours,
Russell E. Traix.
H
-------
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DOCUMENT R50
The Critzers
R. D. 2, Stony Hill Rd., Brookfield Center, Conn. 06805
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UTc^ic jvriixidiA. tffU&cue'fi
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-------
MAR 2 1977
DOCUMENT R51
Silvermine Road
Brookfield Center, Ct. 06805
February 27, 1977
Mr. John McGlennon
Regional Administrator, EPA
Room 2203
John P. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
Having read the draft EIS for Wastewater Collection and Treatment
Facilities, New Milford Connecticut, I wish to offer the following
comments:
The proposed New Milford system is inadaquate in regards to the
purity of its effluent. Lake Lillinonah is now a problem lake
with severe algae blooms in the summer. The proposed system
will only serve to exacerbate this problem (see Summary, page v).
I believe that the recommendations contained in the Brookfield
Sewey Needs Study by Albertson, Sharp, & Backus are superior to
those in the EIS draft. Brookfield sewers should be connected
to Daribury, not New Milford, for the following reasons:
1. From a planning point of view, the line to Daribury makes more
sense. The problems which existed in the Still River valley in
1967 when the original sewer orders were issued have long since
been corrected. There is now no need to sewer along route 7
at its present state of development. There is most certainly
a need to sewer the Candlewood Shores area. However, by running
a sewer line down Candlewood Lake Road from the Shores to the
Southwest interceptor, we can sewer the Shores and withhold
a decision on the sewering of route 7 until developmental
pressures require it. The Anderson Nichols proposal that the
sewer line run over Elbow Hill Road to route 7 has the effect
of combining these two separate decisions into one.
2. Running sewer lines to New Milford places Brookfield at the
mercy of the actions of another town. Because of the length of
time between design of the New Milford system and its construction,
costs have escalated significantly, and a supplemental allocation
of funds will be necessary. This will require a town meeting in
New Milford, and it is by no means assured that the town's
residents will allocate the funds. Recently the New Milford
Planning Commision voted to oppose the scope of this project;
feeling that it was overly ambitious. If the supplemental funds
-------
are not approved, it is unlikely that the town would begin to
spend those funds already approved. Thus it is possible that
Brookfield could be left out in the cold if it is banking on
connecting with the New Milford System.
3. The ability of the Danbury treatment plant to handle the
volume of sewage from the Candlewood Shores area under the
existing contract is not in question. Contrary to the statement
on page 134 of the EIS, we are not constrained from running this
sewage to Danbury. The current agreement with Danbury is for a
volume which assumes further development along route 7, and is
for a far greater volume than is currently required. By trading
off the volume of sewage from proposed development along route 7
with that from Candlewood Shores, a sewer line along Candlewood
Lake Road to the Southwest interceptor could be installed without
any need to renegotiate the current agreement with Danbury. It
is only when we wish to further develop route 7 that such
renegotiation would be necessary. However, as I have already
indicated in point 1 on the previous page, this is a separate
decision and should be treated as such. Right now several
factors mitigate against rapid development of this area. -The
King's Mark study has drawn Brookfield*s attention to the
preservation of our aquifers. Thus it is doubtful that the
Zoning Commission will take any steps toward expanding the
General Purpose zone prior to the completion of a water resources
study. In addition, we will probably see new regulations from
the Zoning Commission with regards to permitted uses in the flood
plain of the Still River. These factors which could have
significant impact upon the development along route 7, only
reinforce my feelings that the decision to sewer route 7 should
be separate from that to sewer Candlewood Shores.
Finally, I wish to state that I believe that the EIS is biased.
The proposals embodied within it are primarily an effort to solve
New Milford's sewage problems with little real consideration given
to what is best for Brookfield. What is best for Brookfield is
to tie into Danbury's system, and that is the way in which
Brookfield should proceed.
Very truly yours,
.j
Jeffrey Kass
cc: Brookfield Planning Commission
-------
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DOCUMENT R52
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DOCUMENT R53
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DOCUMENT R54
U.S. Environmental Protection Agency,
Region 1,
J.F. Kennedy Federal Building,
Boston, Massachusetts 02203•
Short Woods Road, PCB 8801,
New Fairfield, Ct. 06810.
February 15, 1977
* 3
Attention: Environmental Policy Coordinating Office - Room 2203<
Re: Draft Environmental Impact Statement for the Wastewater
Treatment and Collection Facilities for New Milford, Ct.
Gentlemen:
Pursuant to your letter of January 5» 1977 with reference to the
subject EIS, I submit the following comments in connection therewith.
(1) Attached hereto as Reference 1 is a copy of the comments I made
on behalf of the Town of New Fairfield and its officials at the work-
shop meeting held in New Fairfield on June 24, 1976. ( This statement
is referenced in''Memorandum on New Fairfield Workshop(page 264) but
does not appear in the memo. It should be included.
(2) On page ii of the Summary sheet it is stated under 2. Introduc-
tion. that "The Impact Statement urges, however, that coordinated fa-
cilities and development plans be prepared in New Milford and Brook-
field for any interceptor sewer extension or treatment plant expan-
sion beyond Stage 1 of the proposed project. With or without any sew-
er construction, the need for greater local planning is necessary in
the light of the natural growth that is anticipated in the area"
This statement appears to conflict with the statement on page
viii under 7. Conclusion. that"The development of an extensive collec-
tion system in New Fairfield in the forseeable future is unwarranted".
New Fairfield, under orders from the Connecticut DEP and at its
own expense had a sewerage study made which was a planning procedure
for the future. The question appears to be - is this future forseeable
at this point in time? In the cases of New Milford and Brookfield the
forseeable future ten years ago was about the same as it is for New
Fairfield now. Furthermore New Fairfield has its own small lot devel-
opments in some lake communities and in the western part of the town.
I can see no justification for saying that New Fairfield's future plan-
ning is unwarranted. The statement flies in the face" of intelligent
planning as mandated not only by common sense but by the strictures of
the Federal Water Pollution Control Act as amended in 1972 (PI 92-500).
If the statement said "unwarranted at this time" it might be palatable.
(3) Whenthe statement says "in localized .areas of potential problems,
alternatives other than a connection with a New Milford system should
be sought" it is obvious that your consultants did not digest the con-
tents of the New Fairfield Sewerage Study. Such alternatives were con-
sidered and it was the conclusion of the ConnecticutDEP, the Town of
New Fairfield and its consulting engineers that thelffew Milford connec-
tion was the most economical alternative if complete tertiary treat-
ment was to be required at Danbury but not at New Milford. There are
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2.
many facets of the report and subsequent attempts to inveigle New Fair-
field into participating in the construction of an interceptor in New
Milford which should have been discussed with New Fairfield town offic-
ials and their consultants. It does not appear that the town's reac-
tion to the recommendations of the Hudson and Housatonic River Basin
Plans has been considered in this EIS nor was the town ever apprised of
the Federal EPA's reaction to the town's comments on the aforementioned
plans.
(4) On page iii under Purpose of the Proposed Action, it is stated
"Most of these problem areas involve either intense development , such
as multi-family units, or extensive areas of small lot development".
No mention is made of the failures of septic systems at the various
New Milford Shopping Centers starting with the first center near the
Memorial Bridge and continuing with the most recent center near the
SCA Landfill.
(5) The point I am trying to emphasize here is that if a community
elects to so manage the administration of its subsurface sewage dispos-
al program as to cause failures at an early stage, it does not seem
equitable to saddle State and Federal taxpayers with the cost of this
disregard of the Public Health Code. If we concede that sewering is the
only solution then the cost of such sewering and treatment should be
met by the town and its taxpayers, home owners, landlords, etc. who are
involved in the pollution problem. As is often the case, the developer
who caused the problem in the first place escapes the penalty of paying
for the debacle.
As I interpret the intent of the Federal Water Pollution Control
Act it was to help the older cities and towns who already had sewers,
mostly of the combined type, to upgrade their facilities and to con-
struct sewage treatment plants. This applied to New Milford when the
existing facilities were constructed. It was not intended to fund sew-
ers to new areas or to such areas which were built in callous disre-
gard of the Public Health Code with respect to the design, construction
and operation of subsurface sewage disposal systems. Nor was it intend-
ed to apply to political subdivisions who installed sewers which were
laid improperly and contrarjfco the plans and specifications such as New
Milford where much of the sewer system was laid "uphill". I have a copy
of the original sewer plans and though the grades were too flat, there
was at least a grade. This EIS seems to condone these practices and,
to all intents and purposes, recommends that the Federal EPA and the
State DEP "bail out' all who were instrumental in creating the condi-
tion including the banks who granted and hold the mortgages on the of-
fending properties.
(6) On page viii under Conclusion, the EIS states with respect to
Brookfi^eld's connection with New Milford that "In any case, Brookfield's
needs are most logically served by participation with New Milford".
Despite this observation, Brookfield's latest consultants - Albert, Sharp
& Backus, are of the opinion that the Candlewood Shores area should be
sewered to Danbury. This and the suggestion of the EIS that New Fair-
field should also be connected to Danbury despite the possible require-
ment of complete tertiary treatment raises the question of having work-
shop sessions m Danbury. Should not Danbury citizens and taxpayers
have a voice in these decisions?
(7) This writer was a consultant to Manganaro, Martin & Lincoln on the
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3-
design of the Danbury Sewage Treatment Plant modernization and expansion
and recommended that the plant be phased out along with the New Milford
and Bethel plants and that one regional plant be built in the lower
reach of the Still River to serve the entire drainage basin of the Still
River and that portion of the Housatonic tributary to the New Milford
plant. I estimated at the time that the cost of such a regional plant
with the necessary trunk lines(exclusive of Bethel) would be about
$21,000,000. The ENR Cocstruction Cost Index for 19^7 was 1070. The
present cost using an ENR Cost Index of 2500 would be about $49,000,000.
Despite the fact that the Danbury plant was expanded contrary to my
recommendation there is still merit in the proposal even if it included
scrapping the Danbury plant in due course.
The cost of tertiary treatment at Danbury and Bethel when added to the
cost of the New Milford-Brookfield proposal plus the capitalized costs
of operation and maintenance at both installations (instead o$bne) would
certainly warrant another look at the economics involved. Included as
Reference 2 is a copy of the proposal I made at that time. I suggest
that this be considered as an alternate in the EIS and that the areas
involved (Danbury and Bethel) be included in the EIS. The 1972 Amend-
ments to the Federal Water Pollution Control Act (PL 92-500) envisaged
such handling of basin planning under Section 208.
(8) On page x under 8.Mitigating Measures. sub-title Development Im-
pacts . it is stated "Local planning efforts have been evaluated and rec-
ommendations made where revisions are necessary to guide future growth".
The recommendation that New Fairfield be taken out of the New Milford
plant drainage area is in conflict with the above quoted statement. The
statement continues and says "The process of construction of a central-
ized collection and treatment system has been analyzed and future de-
cision points have been identified which should encourage more enlight-
ened public participation. Secondary impacts of development can be les-
sened by controlled expansion of the collection system. The necessity
for expansion can be postponed through the conscientious use of non-
structural methods of waste water treatment."
The meaning of this statement should be clarified. Would it not
be in order to review the policy which this EIS seems to endorse of sew-
ering the Candlewood Basin under Stage III of the project? It is my
considered opinion that Candlewood Lake is Danbury's reserve water sup-
ply, the opinions of tfte Connecticut DEP and Health Department notwith-
standing. It should be protected against massive pollution which would
occur in the event of failure of reserve generators at sewage pumping
stations..New Fairfield has urged that a study of Candlewood Lake and
its basin be undertaken by the Federal EPA similar to the study mandated
for Lake Tahoe in PL 92-500. There are alternatives for handling the
environmental protection of Candlewood Lake which have not been explored.
The Croton Reservoirs, just a few miles west in New York State, are part
of New York City s primary water supply. Treated effluent from sewage
treatment plants is allowed to enter the streams feeding the reservoirs
after slow sand filtration and chlorination. If sewering the Candlewood
Basin is to be sanctioned why should not similar protection be accorded
this valuable water resource?
Following herewith are comments on the various sections of the
report:
Section D.2 Water Quality (page 13) It is stated that "The Still River
is below standards due to oxygen depletion by treatment plant effluent.
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This problem results primarily from the low flow of the river which car-
ries the wastewater from a comparatively large plant in Banbury. This h
problem will ultimately be solved by higher required levels of treatment.
At the time that New Fairfield's former First Selectman, Mr. Wil-
liam Raacke, Mr. Horsefield and myself, representing Camp, Dresser & Mc-
Kee, conferred with Mr. Robert Taylor, then Director of Water Resources
of the former Department of Water Resources, at the start of the sewer-
age study for New Fairfield, I raised the question of the feasability of
a regional sewage treatment plant to serve Danbury, Brookfield and New
Milford as I had suggested to his predecessor, Mr. William Wise. Mr.
Taylor said that he was opposed to such an idea because he preferred to
have treated effluent in the Still River rather than no flow at all.
This decision, shared in by Danbury's consultants, Manganaro, Martin &
Lincoln, as noted previously under (?) has now "backfired" since there
is pressure to provide tertiary treatment for the effluents of both the
Danbury and Bethel sewage treatment, plants. Furthermore it makes the
recommendation of this EIS that New Fairfield's sewage be routed to Dan-
bury economically untenable. This recommendation does not make sense po-
litically, economically or from a sanitary engineering point of view.
I have always questioned whether a "B" classification is attainable for
the Still River. It will always be sistorm drain for an urban area with
all the connotations involved in this function.
Historically and for sound reasons sewage flows into streams and
rivers are intercepted and carried downstream to a sewage treatment plant
in the lower reaches of the river and discharged as treated effluent at
that point. I know of no case in the Metropolitan area or elsewhere
where sewage is pumped upstream and treated effluent carried downstream
except in the case of the Still River. The Saw Mill, Hutchinson and
Bronx Rivers are notable cases in Westchester County in New York and
the Elizabeth, Rahway and Passaic Rivers in New Jersey.
Section E.Mpages 15 & 16) Candlewood Lake as Water Supply. It is stated
that "The Connecticut Department of Environmental Protection has been
quoted as saying that the lake cannot be regarded as a future water sup-
ply because the river from which it draws water is a carrier of sewage
effluent from upstream"
"The long term importance of the lake for use as water supply is
difficult to forsee. Many who cite the potential use in relation to their
fears of sewers in the area, may not have evaluated the environmental im-
pacts of recreation restrictions that might accompany the designation of
the lake as a public water supply."
The DEP's policy with respect to prohibiting the use of streams
receiving treated sewage effluent for water supply is untenable. If
such a policy were in force nation-wide, few if any cities would have
public water supplies. It is not even followed in Connecticut since Water-
bury takes water from the Shepaug which receives treated effluent from
the Litchfield sewage treatment plant.
The use of the lake with relation to water supply is not as a pri-
mary supply but as a reserve supply to be used in time of extreme drought.
This would not affect the normal use of the lake for recreation but if it
had to be used in the recreation season for water supply it might be nec-
essary to curtail bathing and power boating. What other course would there
be?
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5-
To illustrate the inevitability of the use of recreational wat-
ers in time of extreme drought I cite the action taken by the U.S. De-
partment of the Interior during the drought of the 60s in funding the
pumping of water from Greenwood Lake in New Jersey to the Jersey City
water supply. In accordance with a suggestion I made at the time, when
the Connecticut Light & Power Company planned to lower Lake Candlewood
some 8 feet in order to replace a wooden penstock, "both the U.S. Depart-
ment of the Interior and the New York City Board of Water Supply con-
sidered pumping the upper 8 feet of the lake via Interstate Route #84
to the Croton System in New York State.
Following the abatement of this crisis, I was retained by Malcolm
Pimie Associates to report on a scheme I had evolved to construct a
regional water interchange between the Housatonic River and the New York
City water supply system by by either pumping to the Croton system or
by gravity through a 9 mile long deep rock tunnel to the Croton River
from the southern end of Lake Candlewood. A pumping station at the
lower end of this tunnel would enable the return of water from the New
York City water system to Candlewood Lake in time of excess water in
New York. This scheme was deemed feasible and was included in a report
on'Comprehensive Public Water Supply Study for the City of New York and
the County of Westchester dated August 19^7 by Metcalf & Eddy, Hazen &
Sawyer and Malcolm Pirnie Engineers.
The future use of Candlewood Lake as a potential secondary water
source should not be dismissed lightly. To allow a course of action
which would so degrade the quality of lake water as to make it useless
for use in a drought would be a major environmental blunder. One need
only consider the drought of last year in Great Britain and the current
drought in the far west to spur concern on the possibility of another
severe drought in the northeast. This EIS, by endorsing the idea of
sewering part of the Candlewood Basin as Stage III of the New Milford
project is encouraging such degradation. There are other alternatives
to sewering by pumping which is environmentally hazardous. Sewage flow
by gravity out of the basin by gravity is feasible by tunnelling but is
expensive. An engineering study of such an alternative should be con-
sidered. There is considerable opposition to pumping sewage under the
lake by lay people whose motivation may be more political than profes-
sional. These same people make no objection to the pumping of New Mil-
ford sewage under the Housatonic from the converted old treatment plant
on West Street to the interceptor on Pickett District Road. A failure
of this force main which is much more likely than a failure of a force
main under Lake Candlewood would cause massive pollution of Lake Lilli-
nonah.
It is my opinion that this EIS has not followed the requirements
of PL 92-500, Title II-Grants for Construction of Treatment Works, Sec-
tion 201.(2) which states "The Administrator shall not make grants from
funds authorized for any fiscal year beginning after June 30, 1974, to
any State, municipality or intermunucipal or interstate agency for the
erection, building, acquisition, alteration, remodeling, improvement or
extension of treatment works unless the grant applicant has satisfactor-
ily demonstrated to the Administrator that -
(A) alternative waste treatment techniques have been studied and
evaluated and the works proposed for grant assistance will provide for
the application of the best practicable waste treatment technology over
the life of the works consistent with the purposes of this title."
I also make reference to Section 314 on "Clean Lakes" which calls
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for the submission by each S-tate an identification and classification
according to eutrophic condition*of all publically-owned fresh water
lakes in each state along with procedures, processes and methods(in-
cluding land use requirements) to control sources of pollution in such
lakes.
I again make reference to the study on Lake Tahoe mandated under
Section 114 of Public Law 92-.&
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7-
On page 8? under B.3.b.l - Department of Environmental Protection,
paragraph 5 states "The DEP's stated policy is to make the original order
general in nature to allow for local decision making. In accordance with
these orders, each of the communities has prepared an engineering study
and plan to abate pollution. The acceptance by the State of the plan be-
comes in effect the order of the State. The engineering reports for all
of the towns within the study area have been accepted".
It should be noted that no engineering study was made for Sherman.
In fact, New Fairfield's consultants were directed by the DEP to provide
capacity for portions of Sherman tributary to Squantz Pond and this was
done. The failure to hold a workshop meeting in Sherman, is, in my judg-
ment, a procedural flaw in the EIS process. Also, judging from the con-
troversies and uncertainties in Brookfield it is not evident that Brook-
field's plans have been accepted. Since this EIS suggests that Danbury
should be the recipient of some of New Fairfield's sewage and Brookfield's
latest consultants are recommending s similar destination for the sewage
from Candlewood Shores, a workshop meeting should have been held in Dan-
bury to get the reaction of that City's citizens and taxpayers to the a-
bove proposals. If this is not done a protest to the U.S. Environmental
Protection'Agency's highest command might well invalidate this EIS.
Under Section B.?«a Sludge/Septic Disposal, it is stated on page
111 that "In New Milford the SCA Disposal Facility(formerly the McNulty
Landfill) on Route 7 is an approved receiving facility and accepts septage
from the Town of New Milford only. This is incorrect. The facility accepts
septage from Brookfield, Bridgewater, Sherman and other towns.
Section A.l.a 2)b) Raw Sewage Discharges to Waterways. states "Over
the life of the project, the placement of sewer lines and pump stations
near water bodies, poses the possible theoretical risk of contamination
due to some malfunctions of equipment. The real risks associated with
such equipment are, however, minimal. Although pumping is usually accom-
plished by electrical power, auxialiary power equipment is required.
Regular maintenance of this equipment is normally practiced to ensure its
reliability. As a consequence, the magnitude of this impact is minor".
This statement from professional sanitary engineers is amateurish
and shows that they have had little, if any, experience in operation of
sewage pumping stations. When the people of New York City voted by ref-
erendum in 1962 to place the responsibility for all sewerage in the five
boroughs of the City under the Bureau of Water Pollution Control of the
Department of Public Works, which I headed, some 62 sewage pumping sta-
tions came under my control. Most of these stations were in such poor
condition that a large program of rehabilitation had to be undertaken
after an engineering survey.
I do not believe that any experienced sanitary engineer, whose res-
ponsibility included operation of sewage pumping stations, would subscribe
to the statement made under Section A.l.a 2)b). The very nature of sew-
age pumping is such as to be fraught with uncertainty and subject to van-
dalism, particularly when the stations are not located at the central sew-
age treatment plant. Power failures in this general area are numerous
and on occasion, such as in the winter of 1975-76. outages can last for
days.
Under Section A.l.b.l)a) Improvement of Ground Water Quality by El-
imination pf Septic Systems some questionable observations are made. This
writer disagrees strongly with the observation on the reliability of pro-
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8.
perly designed and constructed septic systems. The statement that seepage
systems lose up to 70% of the liquid through evapo-transpiration may "be
true for the growing season but certainly does not apply in the colder
periods particularly when the ground is frozen. Therefore design has to
be based on the conditions obtaining in the winter months.
The Connecticut Public Health Code now requires a 100% reserve
area for the seepage system except where public sewers are expected with-
in 5 years. If the percolation test is the slowest allowed by the Code,
that is a 1" drop in 30 minutes, the effective seepage area for a 3 bed-
room house is 750 square feet. The seepage rate based on the percolation
test cited above is 29.9 gallons per square foot per day and is designed
for a rate of 0.9 gallon per square foot per day, a factor of safety of
about 30. The life of the seepage system should be at least 20 years and
more likely 30. When failure becomes evident the reserve area can be used
and if piped initially can be alternated every couple of years thus al-
lowing an indefinite life.
I see no reason to be so pessimistic about septic system performance.
The difficulties stem from improper design and installation. This can ap-
ply to sewers also as, witness the fact that substantial portions of New
Milford's original sewer system were laid uphill and those portions laid
to proper grade are leaky.
Evaluation of the Carrousel System under Section X - Appendices.
Metcalf & Eddy, in their earliest report on the New Milford Waste-
water Treatment Plant recommended the step-aeration mode of activated
sludge treatment (page ^9, M&E Report to New Milford Sewer Commission
dated October 25, 19&Q) with primary settling tanks and aeration tanks
with 3 hour minimum detention. The change to the Carrousel System has
never been satisfactorily explained. Your files contain letters which
I addressed to your staff from tim£ to time seeking some justification
for your apparent approval of this system. The Technology Transfer Of-
fice in Washington, D.C. was not knowledgeable about the technology of
the system. This being the situation, it seems superficial for your con-
sultants to say that decision should be left up the Metcalf & Eddy. In
an attempt to clarify this decision I had a meeting with Mr. Van Riper
and Alan Jacobs of Metcalf & Eddy who indicated that the reason for the
preference for the Carrousel System was the ammonia load from Nestle.
However, there is no State requirement that treatment at New Milford go
beyond secondary treatment and surely step-aeration would acheive this
if the sludge age was properly computed and the secondary system was sized
accordingly.
The "cost effectiveness" of the Carrousel System, including a high
royalty fee, has not been demonstrated to me and it is my opinion that
this is the wrong choice of treatment systems. Primary tanks should be
called for in any event to eliminate the scum problem.
Summarizing, the principal points raised in these comments are:
(A) Future plans requiring. New Fairfield to seek other solutions to
its sewerage and sewage disposal needs than those recommended in its approv-
ed sewerage study calling for a connection to New Milford if Danbury is
required to provide complete tertiary treatment are insupportable polit-
ically, economically and from an environmental viewpoint.
(B) This EIS blandly accepts the thesis that political subdivisions
may, with impunity, so manage their subsurface sewage disposal programs
U-L!
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9-
as to cause the economic burdens of failures to be borne by others notably
the taxpayers of Cormecticult and the United States.
(C) Sewering of any portion of Candlewood Basin will inevitably lead
to degradation of the quality of the water in Lake Candlewood and foreclose
future use of the lake as a secondary water supply for use in time of ex-
treme drought. Alternatives to sewering by pumping, other than non-struct-
ural solutions, should be explored.
(D) A Section 208(PL 92-5Q0)study of areawide wastewater management
should be ordered. A central regional sewage treatment plant should be
reconsidered even at this late date. Its advantages far outweigh any oth-
er adverse consequences. Such a plant should be located in the lower por-
tion of the Still River near its confluence with the Housatonic. It should
have capacity to enable phasing out the existing Danbury, Bethel and New
Milford plants and have sufficient plant area to provide capacity for New
Fairfield and Sherman if such need ever develops.
Respectfully submitted,
William A. O'Leary, F.Ev
Consulting Engineer
Enclosures:
(Reference l) Comments by William A. O'Leary, P.E. at workshop
meeting on EIS being prepared by Anderson-Nichols,
consulting engineers in connection with New Milford
sewage treatment plant expansion and the sewer as-
sessment report by Metcalf & Eddy.
(Reference 2) Letter to Arthur Harris, Brookfield, Ct. on pro-
sal to build a regional sewage treatment plant
for Still River Valley, dated December 18, 1967.
(Reference 3) Statement-by William H. Raacke, First Selectman,
New Fairfield on Hudson River Basin Plan made at
Public Hearing, Ridgefield, Ct. December 18, 1975.
Reference 4) Comments by William A. O'Leary, P.E. to DEP on
Housatonic River Basin Plan, dated April 6, 1976.
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REFERENCE 1.
COMMENTS BY WILLIAM A. O'LEARY AT WORK SHOP MEETING ON ENVIRONMENTAL IMPACT
STATEMENT BEING PREPARED BY ANDERSON-NICHOLS, CONSULTING ENGINEERS IN
CONNECTION WITH THE NEW MILFORD SEWAGE TREATMENT PLANT EXPANSION AND THE
SEWER ASSESSMENT REPORT BY METCALF & EDDY.
My name is William A. O'Leary. I am a consulting sanitary engineer,
resident in New Fairfield since early 1968 and prior to that in New Milford
on Candlewood Lake as a full-time resident from 1964 to 1968 and a part-time
summer and vacation time resident from 1941 to 1964.
I was the Director of Water Pollution Control for the City of New York
from 1954 to 1965 and prior to that Chief of Design of the Bureau of Water
Pollution Control from 1948 to 1954. There was a rapid expansion of New York
City's water pollution control facilities during this period.
After retirement from New York City's service I became a consultant to
Camp, Dresser & McKee of Boston, which firm made the sewerage study for
New Fairfield. I was project consultant on this study. I am now an indepen-
dent consulting sanitary engineer.
When the design and construction of the New Milford Sewage Treatment
Plant and its' tributary sewers was first ordered by the Water Resources
Commission in the early 1950's I was asked by leading citizens of New Milford
to advise on procedures. I did this and gave a talk before the Lion's Club
among other actions, including letters to the Editor of the New Milford Times,
etc.. The advice was generally ignored, which circumstance cast me in an
adversary role as the years went by. The history of the plant is a saga of
poor design, poor construction, supervision and general mismanagement from
its inception. Parts of the sewerage system were laid with negative grades
and storm water intrusion into the sewers is a problem to this day.
In 1965 the Area Chambers of Commerce formed a Clean Water Committee and
I was asked to join the group as its engineer member. In the course of our
work I concluded that the best solution to the area water pollution control
problem was to construct a regional treatment works close to the lower reaches
of the Still River near its confluence with the Housatonic and phase out the
existing Danbury and New Milford plants and ultimately the Bethel Plant also.
In due course I discussed this proposal with the then Director of Water
Resources, Mr. William Wise, who showed great interest and ordered Danbury1s
sewage treatment and sewerage consultant to confer with me and explore the
economics and merits of my proposal. After receiving and evaluating my
proposal, they -Manganaro, Martin & Lincoln- rejected it stating "An examina-
tion of this proposal indicates that the lack of development between Danbury
and New Milford does not lend economic feasibility to the proposed scheme."
As events transpired this area has become one of the fastest growing areas
in the State. Soon afterward steps were taken to expand and improve the
Danbury Plant with State and Federal funds.
- 1 -
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In 1964 the Chairman of the New Milford Sewer Commission asked me for
some advice relating to problems they were having with the sewage treatment
plant. At that time he asked me for a recommendation as to a consultant
and I recommended Metcalf & Eddy who were retained and are still their engineer-
ing consultants. Several reports were made by M & E from 1968 to the latest
report which is the subject of the work shop meeting being held here tonight.
I would like to point out that Mr. Raacke, when he was First Selectman
of New Fairfield, asked for a copy of this Sewer Assessment Report. The
request was ignored despite the fact that when New Fairfield's report on
Wastewater Disposal was completed and accepted by the D.E.P., a copy was given
to each town bordering Lake Candlewood. So we are in the anomalous position of
being here tonight to discuss the New Milford Sewer Assessment Report without
having had a copy for study.
My original recommendation for the*construction of a regional sewage
treatment plant was followed in part in that the D.E.P. required that the new
New Milford Plant be designed to treat sewage from the northerly part of
Brookfield and the Danbury Plant accept sewage from the southerly part. The
northerly part of Brookfield encompasses the Candlewood Shores area, a develop-
ment of some 500-600 homes on the shore of Candlewood Lake. This area was
formerly a part of New Fairfield. When the sewerage report for Brookfield was
submitted by Manganaro, Martin & Lincoln, consultants for Brookfield (also for
Danbury) in 1968 (revised in June 1969) they gave first priority to the sewering
of the Route #7 Corridor including the Iron Works District and second priority
to the sewering of Candlewood Shores stating that while there was a potential
problem at the Shores, there was no indication of lake pollution. This matter
of sewering Candlewood Shores has become the subject of controversy between
factions in Brookfield and the D.E.P. and as the controversy proceeded, New
Fairfield became involved.
New Fairfield was ordered to make a sewerage study by the State in August
of 1970. The D.E.P., successor to the Water Resources Commission, who issued
the original order, leaned toward treatment of New Fairfield's sewage at the
Danbury Sewage Treatment Works. Camp, Dresser and McKee, consultants for the
New Fairfield study, however, explored all possible alternates and had concluded
that this was the most economical alternate. The controversy relating to the
sewering of the Candlewood Shores area and how this was to be accomplished
erupted during the latter stages of the New Fairfield study. Suddenly the
Director of Water Compliance for the D.E.P., Mr. Robert Taylor, requested an
opinion concerning the effect on the economics of New Fairfield's sewage and
collection problem if Danbury was required to provide tertiary treatment of
sewage instead of just secondary treatment. The reevaluation indicated that
under such changed criteria it would be more economical to route New Fairfield's
sewage to New Milford via an underlake force main and a gravity sewer (after
discharge from a pumping station at Chimney Point in New Milford) along the lake
shore from the New Milford-Brookfield boundary to tfoe proposed treatment works
at the confluence of the Still and Housatonic Rivers. This was predicated on
only secondary treatment at New Milford.
- 2 -
-------
When this opinion was given to the D.E.P., the New Fairfield sewerage
study was accepted by the D.E.P. and became the master plan (so to speak)
of sewage disposal for the affected areas. New Fairfield, not contemplating
any involvement in sewage disposal for decades to come, acquiesced in the
decision until it suddenly became apparent that the decision was a key element
in solving the dilemma of sewering the Candlewood Shores at miniumum cost to
Brookfield and maximum cost to New Fairfield, the State and the Federal Govern-
ment. With New Fairfield ultimately contributing to the flow in the trunk
sewer from the Candlewood Shores area;to New Milford, the line became eligible
for 90% funding by the State and Federal Government.
The D.E.P. at this point, November 19, 1973, ordered New Milford, Brookfield
and New Fairfield to participate in the construction of an interceptor or trunk
sewer from the New Milford-Brookfield boundary on Candlewood Lake Road South to
the treatment works. The Chairman of the New Milford Sewer Commission sent to
the First. Selectman of New Fairfield a sketch of the proposed interceptor with
an estimated cost breakdown indicating that New Fairfield's share of the cost
would be $292,500, New Milford's share $82,830, Brookfield's share $95,370 for
a total local share of $470,750 and the State and Federal share $4,236,750,
based on 907. State and Federal grants.
First Selectman Raacke of New Fairfield and I took umbrage at this
development and jointly took steps to appeal the order. It did not seem
equitable or reasonable to us to saddle New Fairfield, the State and the
Federal taxpayers with the cost of sewering Candlewood Shores at a cost per
home of close to $10,000. We marshalled technical, political and economic
arguments and induced the Town to appropriate funds to finance legal action in
connection with the appeal. Before the hearing relating to the Town's appeal,
Mr. Raacke and I met with the Counsel for D.E.P., Mr. Tunderman, Deputy
Commissioner Beck and Robert Taylor, Director of Water Compliance on March 26,
1974 and presented our arguments against the order.. The order was rescinded in
May of 1974.
Environmental Considerations:
New Fairfield has a special interest in this project and its environmental
impact on the region. The Town's position with respect to the environment has
been stated officially by former First Selectman Raacke and other Town officials,
including the Zoning, Planning and Conservation Commission members on several
occasions. When an attempt was made to construct a Planned Unit Development on
the shores of Candlewood Lake in New Fairfield and Sherman, the Town appropriated
funds to finance its effort to analyze this proposal. Hearings were held before
the Zoning Commission at which I, among many others, argued that such a develop-
ment would soon double the Town's population and force sewers upon us.
We have taken the position that any sewering of Candlewood Basin would,
in addition to generating pressures for intensive development, increase the
risk of serious lake pollution because of power failures and the effect of
these upon 1007. performance of reserve power generators for pumping sewage
during primary power outages.
- 3 -
-------
We have also argued in favor of classifying the Lake Candlewood Basin as
a secondary water resource, so that in time of extreme drought such as occurred
in the 1960's, its waters could be pumped into Margerie Reservoir as was done
during that crisis. Increasing the risk of sewage pollution by sewering the
Candlewood Basin would militate against the policy of establishing the lake
as a water resource. One need only contemplate the current pollution problem
on the ocean beaches of Nassau and Suffolk Counties in New York State after
large sewage treatment plants itfith ocean outfalls were established along the
shores.
In recent comments on the Housatonic River Basin Plan proposed by the
D.E.P. I have questioned the sanitary engineering soundness of the decision
to require phosphorus removal at the Danbury, Bethel and the proposed New
Milford Sewage Treatment Plants. If this added treatment is not justified by
the results to be achieved in improved river water quality then New Fairfield
would not be directly involved in the New Milford project since its sewage
would then be routed to Danbury. it would, however, still have an interest
in the matter of lake sewering since the five towns bordering the lake have
a common interest in water quality.
Since New Fairfield's present and future economic welfare is related to
sewering and its prohibitive cost, it has charted a course which is based
upon subsurface sewage disposal into the indefinite future. We believe that
such a policy should be mandated for the entire Candlewood Basin and to that
end we have petitioned our Congressional representatives in the House and
Senate to have a study of Candlewood Basin mandated by the U.S. Environmental
Protection Agency similar to the one presently mandated for Lake Tahoe on the
California-Nevada border in the Federal Water Pollution Control Act (PL 92-500).
cc: Mr. John Fairchild, First Selectman, New Fairfield
Mr. William H. Raacke
- 4 -
-------
REFERENCE 2.
rev; MiifordT Cortii. 067-78»
feceooer 18, 1G67
l-.tr, Art-fun karris, Chairman,
iir to vac cdtiavticn
aloa;;: the hea if.ll< fatcaeaeea ra-P faoaa fiver raae:aeys in l-.ea York eealo
i.y. !-•ao'eea/tal fcy eacllaaiaa rca/ sovvaye era ivrceaaa ;.e:ve-; c eifliaent
freei the f::.ver eaairoly. fi;i& could bo cione by baildiny a joint tr; al-
ine,-.it plant e.lorg the northerly reaches of tko valley as near to tho
^uiiOlion vv.ltli tiio nducatoiiic Liver as is feasible. In the caaec of the
If a York 3 a very r.oaaionoc a.apoe, thex-e are traak cta'ors alcap lire Blreeas
va:Ich ooaasy all see rye to tea era ';a:'t plc~n,o oil the val J era.-. Store- run-
off :>.g ooe-ee - <:e to tia; ctroeas eaei ainr thio is urban inn-ojf it. is
hiyaly turbic and polluted onu dyrina t
-------
2.
The sdv&nta^es of a joint sewa-e tr^atrent rueiit are (1) rjinbaiai .unit,
operation cost* (2) higher index of reliability in operation oaeaujx:
of possibility of ebtainin.;; hx^nnr skill in operating personnel a»d (3)
lower capital cost to local Kunicipalities because of higher grants try-
State and Federal Governmc-nta 'by reason of joint operation.
If it is decaded to provide* p.evisyo sasd irdustrial waste treatment at
multiple points along the River? zi::z irxiex of reliability of vaitor pol-
lution control rill bo at a consistent?.1/
vny Ratiaib.caory ox the river ;a-->;r;• •': •• •
I ; v be ;!:• . •- ibr b.-.aVa: •* aa>< awa: a.a 1
grate eacaaaa. or oyaaea daficb.aaa ;.aa. :
of color or odor the pablae r.-a-;wvr; itl :?
cur if the river. boea'na iafeaiaa; aa. lb -b
":ov-r level f-ueh as to preclude
.V..-! Of-'-j. O'.-I OO.'".' a. -Vat". 2
for:aa of i'aaa life :a y ai-
there an a.a n ce. .u;j.c trace
'.'•.v. aaaie reaction v:oi.\Xh oe~
1 bi.:">'> a...
'without tI'.'f lav-re flc;v froa the P;ynfcury rrr-a t-bo. r-ehf.e of icirt opera-
id on T.;;y':Ia rot- be /jaa -ah':' able :Ir ay cn:;'adon« ;'f the ;,, is .* a
ly '} arr;e a e can dibrce the caller cvarfiaiee of1 iiu'ivs trial aaiEhes r:aa;
aa-.he t'aa; aaaaacie to treat ay trio aeaavaued aludee ac-a . >. V.ea.e
v.\..rvoer. v.ould. eave to * a eeabideu in ee.y evor.;t« "h>e aa-leta? a ..'. bary
Plant la ova'- ye ey-cl caaaaaiea. It should bo acre-need - nd the in*v; con-
verted to r;c;';e other m-.e-. l':f it j 3 enpanaed from it;:; present condition
only i":.ir;.;.c' .o 1 prisi* '• .aV! reeed t.
r\n-tlior:noro, tiio oroblora of nitrate ; r.-i o. ;o5'ph: to removal ivlli t;vvo to
bo yrripplcci \v:i.ub. in th^ near tuture .a,b oiily a y. .: j.iooc.:r;; p'L^iit
vrj.t ¦ ciox't reserve orya c:.:-i be iooi-roa '.vita o: x. a • il.ea:ibija ¦
ty to ea::ible thewe ai:'ditinr.?.l faoilI':,ica to be arte-Taaoc iaa^.> ,,ho J.cy-
out, v='e vziy be auly to renove i:a.if oi' a-'ia./ nitrato ia'Oao.aa-;,o load or;
tbc- :;'t: c.a-a: by a;a^at:^erit •» ti"a obei' haib oceeo biaai a."'p-icuXUiral ;..ra
urbaxi l;::;.nd run-off aad tiu.;. rcauct.J.oa of ta::.r. fraction is :bi tho lao of
tlic Goco. A recent stucor of 'Bantan I,ake in 3,itchfir;l-vtor s to cone Judo t'ftat algae -were prooont eiiea the a.u i--:-. was
• owzisci by tno Indiana anU is not nocessoar-iiy c-aused by ore sent cay ;,ho:.io
sapiens". .....
.".^y studies of flic oro'oablc. cost-o of a point ti'eateont plant as cornp/n crci
with separate plants for the Still livor valley are about c-s folloivs:
Trunk Scwero
Joint Project
Eatiirated
Cost in yd.l,-i.
Contribution by
Fed. Govt. State Uunicip&lity
Froia Danbury
14.0
7.7
4.3
2.1
Froa Ke;v Milford 1.1
0.605
0.33
0.165
Pumping Station
l;:evv Mi.lfoj'd
0.22
O.Tdl
O.0G6
0.033
Sev/a^c ?rQf?X,i
-------
3
Separate Probata
Hurdcinality
r»*»" **« ¦•••* •:* •'* r'.":
'* O . :.«v • \4•*
.4. i. Le,
Contribution by
Fed. State ;viinicp.
Govt.
«"-iXlX3.C?*
O-aOary
lit. .^0J
.iilic:;-
r: '/r.'/:: o 007
1.) • 1 «' -t - O 0 f
1.108
fa =¦¦/;! 1.300
.O.aOo <6
0,
£U.
3.
703 l015o
6:>3. 0,43-jt
7 •: O9K.;0
0 »0 :: : 0 *« ;0
-4. p c . j
OO.rO^
O'V : J. LO /. . .
5.00
»._• <> V.-
lt c
i.?- C J-.1-'
-
6.00C
0,000
ie 000
xO « V: O'J
j ' ' '•• , '
s' : - ¦'.< "T, aO,.C",' ^
' :;o.l~':: :7. ^
in th
} •!./;
v c v >':* :
• . v: .0/ if.••.OiJ 0
y_ K;;.0.00 \::\\. '
; '¦ C: -
1 :•
10 C C oo.c
cu.> -•
V.1'"0;" rr;r"
c::;iiiO ^ ate. oi OOe jc
5. n t >
¦0 •L» i..** ¦' I i c.lX
roo,^ >'C to
("¦pen'-c.tir-^' aaO
capital coirts aic given bslo^v;
1. Op&ra.tJ *•=''• costr.
r:< .• treaO'e
xc 0 or- ;f:00/:: :-y
017c
¦ ;.•'¦• 0 0/y ear
2, i:;ai!rtc:r.'-rce of «.?
'LUaCx *; C':
•err
'.tic?]
60
,000/ "
3. rixoo c^ztn
oO ytar Ferial
ii":0 ? '"*6 X!,' i - Cri 0X1
11 y\s v. i ~ > i» * 1!.. 5
bo";'ic
:r-. So.-/rear
iiv.-ir:'- o.j coupon
^verari^g 00/pv.r ovor
."0 yeur ii 1'c or Kxaic
VoUl 0.03,,/ycar ;: - !:0>140,000-
ll\-- , C ^ cau*
Total arr.ual c::rens<
'• O ^ /". CO A - .
I assumed the population would be 67,000 iro;:i j)aiibury, Id,000 Irosi
Brookfield and 18,000 from Mew I.Iilford connected to the severs and
sewa-e trcc..tycr.t plant# :V.ch of popuiati.:?i viil i-~'vwr l-» connected
to the crv-'V -c system, Ohe cost per capita per ytar unO<;i the .joiiiu
scheme would be about 33.4ft, Tiiio iar ol course, i'or treatment only.
The costs of lateral sewers is not included.
-------
4.
Senarat.o rr-o.icota
1. Operating Co«t8S
A, Danbury
oV.'.'i e? 0100/100 - :?7.l/day -
Be Brnok^i<0!.d
.?•.» Oa . ?."ii v'x ty£QU/iv&»' •* <>oi;0/Gay •**
C. Few •.'•iliford
2.34 j-SD C o2COA-V, ~ O-iOS/day -
!. "V -v-.'-.-f- ,,~f "T-ar.:; ¦ •-. ...v,-a
chargeable to Treatment
i. rL:rci c:c;-v¦•.¦:¦;:¦- Traatruev-t:
A, /,/rO«!
^0":':0 :•: >y?7 V:' :>
ii. Brcoiiielc 4^4,4**
i .'••• .... >r* *1 f\;- • ''• ~ r\
' O .) ¦¦: - ' 'iv J I ; - f . W
G,. 1-h.v,' ¦ rllf ci a f?c»
. ' O
ji'-
OO <»/-%• J .-'>/>
'" \ - ¦¦> ¦ - ~ -. •¦ -: r>
J. •- v. .... ... V
'" (¦> - :J . > li. ',jij , \J i
i.-.3 zi ;:;o?gci>ooo
Total
$319,000/year
l'va?GOO/y€-ar
171f000/year
.£6a2, OOQ/yc&r
$25,000/year
7 2,, / a 0
\1q V ' v.- / > Cf.-C6
2>-?r 4 <"5
lo?f ii'
^"2 ?*av
165,CC£/year
Total Fixed Cost:; - > :';t/7#lC0/ys:^r
Octal All Coots - 01,934, 100/year
It is roodiXy apparent that there -Ja about a 0 to 1 ratio in favor of
a joint proioct as eenTaarr.O vith separate pv-ej rcto. '¦'¦his :i.r becauoe
of the Pcdcrai ;..}..-. L\l2.Zij contribution ubicb is heavily weighted, in
rC'avor or jo lilt projects.
ii;eee cc-tierces are 0:1 the high side. Ple&ce rote that the en tinned
co;:.t o:C thr gov:gv fj-om J>^ricu:ry to t'r.« pl;.mt io i3.4,000,COO for
£.'pcu:t 9.1 1VLX03 or Gov;er v.ri.th a di;-"9t«r of i-2 inches. Con^-i'e T.iiio
v/ith the co-yo ci' the :;ar,'v.-;a:.. -irv: v;>:icr; a oic:
price oh . '..;rh (ij000. :huh etc. • /hir.;hl cost p; 00a-
bly in tbe "order of >'l.?.OO,OC0. 'O.o lc;i.,^h i:-i nir,e niJ.es oi* tbout the
ear-.e ler^th as the proposed trunk from hanbury.
Tbei-e is al&o enclosed two aerial views cf '.vne Cakwocd Beach Gev.fcge
Tr eatment Plant on Statc-rs Island in the City ox*' New York, "b.e capaci-
ty of thic -nlant in ir. the sa/.'.c i ':r_;;e a: p; ooootd foi' -c.be 001..]. 1
Valley ;v :o t;;e 'oerrain io Gi;^ilax. hote thciL a £i:ali streasa bi.d "Lc ot;
diverted . rour.c the plant,.
The biygest problem in water pollution control today is competent opei--
ation. Please note the enclosed article from the Engineering Nevs-hcc-
-------
5.
ore of Movf'-:b-::r P3? IT 67 tie rev ibiiur tlic problems of 2-ot'lon9 base. in
getting a ce'c::rs;e plant into ovh-t atim:-.. k pro J.:', foration
oi' crall olr.rrts shou'ic- bo i-voided. The 1C*S6 Ar.nuiil l-eport of the. L'ev;
Uilboro Ca:r;ci«o:»Oi;. spates ti:-at t'br- ol* treat it'v.
li.ofi palJea<-- ob mwnrin ir. 2b o 11ocol year crbirg Judo 2Cr Ibco was- +05,
410 ox ab;a ¦;... .bbO rx;r uiilii or. pallor:;, '"b\ a is fo_" operation and nain-
terunce .: :u-c 2ocr not ireluos-' b:iacb costs. If brooicf.bba decide-s
to "po it, cba-acr' coots v/iii bo cvapavabi£.
In r:» -jv £;¦¦¦'¦;:::• ?\t a beoirbon to eoatxrae discharging treated eb.TLuer.t fro;!;
tl c tyabur v p.p>2. iyp.o lie atill : ivar v. .1.'• j pcrpcr.uate the -aba-air p ur,--
Si v'.C i, O • ¦ :J C ; Ol I « I i ' ¦! «H .>. i i ;"lO C v" ? i .',C ¦¦ .' li. ti';C
traa. va txi .aaa.t X'.; ca 22^ nlanl .••:• vbe ••••••:-," ro ov ihc. flov; in-
eraaaa-; tl :¦ ¦: ':a; bl lave ••¦j, ::a -ravaaLabp c€ I ¦::• 06 ri Oub -aCPeca, Upon x,t:e riv-_
C-'» a j. i C';.1 !.• a - J. J. ap OC. ajaai "u i V'; aaauUjpy* ii.CVv C..
i;a eaaipb: ob a paebla/; :<.Ya;: 'aa point of viaa ob ciarolvcu o. \ . ci. in il.:
0 .... -o i. .' v.- ' 'v-'o. -' 1 eJ,v!; C . i i"t J t.j Oi':.-...)' "OfiB C 0' jf X O'X .li'i (j'£ IlUa
.1 rii. . ..Li ' .'. v i V- i : l.iw ; o L- t\: ¦. f i.i L-; j .J- ^ v.. iC C j »i' v. iA O XO J*.C-i:.3fc> ;b' ¦,(/ 1. ;• v.,.-:r:c. 'Oo:-:1 rad'OQt.:'. on v, n
c/;.cul2 .
o y'.¦ i -V
bbr .\0;
¦ too 2till
Kl'v'¦•:-¦¦¦
• Wi i ¦'
TrT.: c; \.r; be aroa. b;
el h ':;dcn
•* ¦ ¦
;bc;:ps vb
';?p I -:-;;::'.' -.at r:^ a pJ.r..;iL : b;;^ :^-c: - r
c-:>:Tu v.oulo
ha:.r;v
• o 0;.r
'¦-. 'u ¦- ¦ v; .1.0: ¦' ' i'llil C> j,_ J^iXX ; .
U;-;:C v;ci'
i '.i
'Vv;i: j.o:"P'-r:. .:b' .. a.a;.bav b:v; ..b.bb:;.'0 •/::
'• '0ul;.;jc
.-'V/ V •
»"i "r\ '¦ -
ob 12a:; foz cc\
: o.Vi
b.7
, vC>l.-; ¦
'¦¦'¦u r\..idy in z:::: .-xr",, Oii bav;' . .1 Iv'oi. acv:eriJ:
Cj uV.td
.ndrL
pi;obl'::
¦vs called bor treaf«es:t piavii, iri thia a^-ea.
Very truly yours,
'.Villicin A.C^J.caiy, V.}-,.
-------
REFERENCE 3.
STATEMENT BY WILLIAM H. RAACKE, FIRST SELECTMAN, NEW FAIRFIELD, CONNECTICUT
AT PUBLIC HEARING ON " HUDSON RIVER BASIN PLAN" PREPARED BY THE DEPARTMENT
OF ENVIRONMENTAL PROTECTION, RIDGEFIELD TOWN HALL, RIDGEFIELD, CT. DEC. 18,'74.
ON BEHALF OF THE TOWN OF NEW FAIRFIELD I HAVE THE FOLLOWING COMMENTS TO OFFER IN
CONNECTION WITH "THE HUDSON RIVER BASIN PLAN" OF THE STATE OF CONNECTICUT.
THE TOWN OF NEW FAIRFIELD HAS 5.8 SQUARE MILES OF ITS LAND AREA TRIBUTARY TO THE HUD-
SON RIVER, SHERMAN HAS 2.5 SQUARE MILES AND DANBURY 1.5 SQUARE MILES. UNDER I-
DESCRIPTION OF THE BASIN, IT IS STATED "THE BASIN INCLUDES LAND AREA WITHIN THE
TOWNS OF RIDGEFIELD AND NEW FAIRFIELD". NO MENTION IS MADE OF DANBURY AND SHERMAN.
BY ORDER NO. 874 BY THE STATE WATER COMMISSION, NOW THE DEPARTMENT OF ENVIRONMENTAL
PROTECTION, DATED AUGUST 17, 1970, THE TOWN OF NEW FAIRFIELD WAS REQUIRED TO MAKE A
STUDY OF WASTE WATER COLLECTION AND DISPOSAL. WE RETAINED THE FIRM OF CAMP, DRESSER,
& McKEE, INC. OF BOSTON, MASS. TO MAKE THIS STUDY. SIX ALTERNATE SCHEMES FOR HAND-
LING OUR FUTURE WASTEWATER WERE STUDIED, THREE OF WHICH INVOLVED CONVEYING FUTURE
SEWAGE FLOW FROM THAT PART OF OUR LAND AREA DRAINING TO THE HUDSON RIVER TO SOUTH-
EAST, N.Y. FOR TREATMENT IN A PLANT TO BE BUILT THERE AT SOME FUTURE DATE. AFTER
OUR CONSULTANTS HAD GONE TO THE EXPENSE OF STUDYING THESE ALTERNATE SCHEMES, WE WERE
INFORMED BY THE DEP THAT THESE ALTERNATE SCHEMES WERE CONTRARY TO CONNECTICUT STATE
POLICY WHICH, BY STATUTE (SECTION 25-26a, CHAPTER 474), ENACTED IN 1973, FORBIDS THE
DISCHARGE OF TREATED SEWAGE EFFLUENT INTO FEEDER STREAMS OF WATER SUPPLY RESERVOIRS.
THIS POLICY OF THE DEP, IF FOLLOWED THROUGHOUT THE COUNTRY, WOULD DEPRIVE VAST AREAS
TRIBUTARY TO THE NATION'S MAJOR RIVERS OF A SOURCE OF WATER SUPPLY. TREATED SEWAGE
EFFLUENT ENTERS THE STREAMS FEEDING NEW YORK CITY'S CROTON, CATSKILL AND DELAWARE
WATER SYSTEM RESERVOIRS. HOW WOULD NEW YORK CITY AND ITS NEIGHBORS TO THE NORTH
OBTAIN WATER IF THE PRESENT CONNECTICUT POLICY WAS IN EXISTENCE IN NEW YORK STATE?
WE QUESTION THE SOUNDNESS OF' THIS POLICY IN CONNECTION WITH DRAINAGE AREAS WHOLLY
WITHIN THE STATE OF CONNECTICUT BUT WHEN THE STATE PROPOSES TO APPLY THESE RESTRIC-
TIONS TO DRAINAGE AREAS DRAINING INTO ANOTHER STATE WE STRONGLY OBJECT AND DO SO NOT
-------
2.
ON ANY PEDESTRIAN BASIS, BUT ON COMPETENT SANITARY ENGINEERING ADVICE.
MR. WILLIAM A. O'LEARY, A PROFESSIONAL ENGINEER, NOW RESIDENT IN NEW FAIRFIELD, WAS,
DURING HIS ACTIVE PROFESSIONAL CAREER, CONNECTED WITH THE INTERDEPARTMENTAL BOARD FOR
THE SANITARY PROTECTION OF THE NEW YORK CITY WATER SUPPLY. THIS GROUP WAS MADE UP OF
THE CITY'S TOP ENGINEERS IN WATER SUPPLY, SEWAGE DISPOSAL AND HEALTH. BY REASON OF
THIS FORMER CONNECTION HE IS FAMILIAR WITH THE POLICIES OF NEW YORK CITY AND STATE
WITH RESPECT TO THE PROTECTION OF THE RESERVOIRS WHICH THE "HUDSON RIVER BASIN PLAN"
ADRESSES ITSELF TO. HE HAS REVIEWED "THE REPORT ON COMPREHENSIVE INTERCEPTING SYS-
TEM FOR SANITARY AND INDUSTRIAL WASTES ON THE CROTON AND KENSICO WATERSHEDS" WHICH
WAS SUBMITTED IN FEBRUARY OF 1963 BY ALEXANDER POTTER ASSOCIATES, CONSULTANTS TO
THE THEN DEPARTMENT OF WATER SUPPLY, GAS AND ELECTRICITY.
THIS REPORT EMBRACED A COMPLETE STUDY OF THE DRAINAGE BASIN OF WHICH THE RIDGEFIELD,
DANBURY, NEW FAIRFIELD AND SHERMAN AREAS REFERRED TO IN THE HUDSON RIVER BASIN PLAN
ARE A VERY SMAlL PART. THE CROTON WATERSHED, WHICH INCLUDES PARTS OF DANBURY, NEW
FAIRFIELD AND SHERMAN HAS A DRAINAGE AREA OF 375 SQUARE MILES AND THE KENSICO WATER-
SHED 13 SQUARE MILES. THUS THE PERCENTAGE OF THE AREA OF THE CROTON WATERSHED OCCU-
PIED BY DANBURY, NEW FAIRFIELD AND SHERMAN IS ABOUT 2.6%.
THE REPORT RECOMMENDED THAT ALL TREATED SEWAGE EFFLUENT ORIGINATING ON THE WATERSHED,
AFTER SLOW SAND FILTRATION AT THE VARIOUS TREATMENT PLANTS LOCATED THROUGHOUT THE
WATERSHED BE INTERCEPTED AND CONVEYED TO A TRIBUTARY OF THE HUDSON RIVER SO THAT NO
TREATED EFFLUENT WOULD ENTER THE CROTON OR KENSICO RESERVOIRS. ONE OF THE PROPOSED
TREATMENT PLANTS WOULD BE LOCATED IN THE TOWN OF SOUTHEAST IN PUTNAM COUNTY, NEW YORK
AND THE REPORT PROPOSED THAT WHEN AND IF POINT SOURCES OF POLLUTION BECAME UNAVOIDABLE
ON THE WATERSHED, INCLUDING THE CONNECTICUT PORTION THEREOF, BY REASON OF FAILING
SEPTIC SYSTEMS, THE RESULTING SEWAGE WOULD BE TREATED AT THIS PROPOSED PLANT IN NEW
YORK STATE. NO EXPENSE TO CONNECTICUT WOULD BE INVOLVED OTHER THAN THE COST OF BUILD-
ING AND MAINTAINING SEWERS IN CONNECTICUT AND THE PROPORTIONATE COST OF MAINTAINING
AND OPERATING THE PLANT IN SOUTHEAST, NEW YORK.
-------
3.
THE HUDSON RIVER BASIN PLAN WHICH IS THE SUBJECT OF THIS HEARING HAS A TOTALLY
DIFFERENT PHILOSOPHY. UNDER IT, CONNECTICUT WOULD REQUIRE THE SEWAGE ORIGINATING
IN CONNECTICUT TO BE PUMPED BACK OVER THE DIVIDE INTO ANOTHER DRAINAGE BASIN FOR
TREATMENT IN CONNECTICUT. WE DO NOT SEE ANY MERIT OR JUSTIFICATION, ENGINEERING
OR ECONOMIC, IN THIS PLAN, IN FACT, WE ASSERT THAT IT IS NOT IN THE BEST INTEREST
OF NEW FAIRFIELD, DANBURY, SHERMAN OR THE STATE AS A WHOLE. FURTHERMORE, IT APPEARS
TO CONFLICT WITH THE PROVISIONS OF SECTION 208 OF PUBLIC LAW 92-500 RELATING TO
AREAWIDE WASTE TREATMENT MANAGEMENT AND SECTION 209 OF THE SAME FEDERAL ACT ON
BASIN PLANNING.
THE PROPOSAL BECOMES EVEN MORE UNTENABLE WHEN ONE CONSIDERS THE RECENTLY PROMULGATED
PLAN OF CONSERVATION AND DEVELOPMENT OF THE STATE OF CONNECTICUT WHICH INCLUDES
PRACTICALLY THE WHOLE AREA OF NEW FAIRFIELD IN WATERSHEDS TRIBUTARY EITHER TO THE
CROTON SYSTEM IN NEW YORK STATE OR THE DANBURY RESERVOIRS IN CONNECTICUT. UNDER
THIS PLAN IT WOULD BE NECESSARY TO PUMP SEWAGE FROM ONE WATERSHED AREA TO ANTOHER
AND THEN REPUMP IT TO THE HOUSATONIC BASIN.
WE CALL ATTENTION TO THE INCONSISTENCY OF THE PROPOSED POLICY INVOLVING INTERSTATE
DRAINAGE AREAS BY CITING A DECISION OF THE DEP IN CONNECTION WITH THE NEW FAIRFIELD
WASTE WATER STUDY WHICH REQUIRES DANBURY TO ACCEPT FUTURE SEWAGE FROM THE MARGERIE
RESERVOIR AREA OF NEW FAIRFIELD INTO THE PADANARAM INTERCEPTOR RATHER THAN PUMPING
IT OVER THE DIVIDE INTO ANTOHER DRAINAGE AREA. IN OTHER WORDS, CONNECTICUT'S INTRA-
STATE POLICY IN THIS RESPECT IS DIFFERENT FROM ITS INTERSTATE POLICY.
WE NOTE SECTION IV- RECOMMENDATIONS AND INPLEMENTATION IN RELATION TO ZONING DEN-
SITIES AND SUPPORT THESE WHOLEHEARTEDLY. THE POLICY WITH RELATION TO ZONING DEN-
SITIES APPEARS TO FAVOR 2-ACRE ZONING FOR THOSE AREAS WHICH ARE TO BECOME DRAINAGE
BASINS FOR WATER SUPPLY RESERVOIRS. THIS INCLUDES ALMOST ALL OF THE LAND AREA OF
NEW FAIRFIELD AS NOTED PREVIOUSLY. WE WOULD LIKE TO INQUIRE HERE HOW THE STATE PRO-
POSES TO ENFORCE OR SUPPORT THIS POLICY.
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4.
IN THE LIGHT OF THE FOREGOING OBSERVATIONS IT IS REQUESTED THAT THE POLICY RE-
QUIRING POINT SOURCES OF POLLUTION ORIGINATING ON CONNECTICUT WATERSHEDS DRAINING
NATURALLY TO NEW YORK STATE BE RETURNED TO DRAINAGE AREAS IN CONNECTICUT BE RE-
CONSIDERED. ANY FUTURE SEWERING OF CONNECTICUT TOWNS OR CITIES WITH LAND AREAS
DRAINING TO NEW YORK STATE WILL BE EXPENSIVE ENOUGH WITHOUT THE IMPOSITION OF IN-
DEFENSIBLE AND UNREALISTIC POLICIES WHICH, IN REALITY, ARE UNILATERAL AND NOT DE-
MANDED BY THE NEIGHBORING STATE. LASTLY, WE DO NOT THINK THE FEDERAL ENVIRONMENTAL
PROTECTION AGENCY WILL LOOK WITH FAVOR ON A POLICY WHICH APPEARS TO BE UNIQUE WITH
CONNECTICUT.
RESPECTFULLY SUBMITTED,
WILLIAM H. RAACKE,
FIRST SELECTMAN, TOWN OF
NEW FAIRFIELD, CONNECTICUT
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REFERENCE 4.
Short Woods Road, RD3»
New Fairfield, Ct. 06810,
April 6, 1976.
Department of Environmental Protection,
State of Connecticut,
State Office Building,
Hartford, Connecticut 06115-
Attention: Mr. Robert B. Taylor, Director, Water Compliance
and Hazardous Substances.
Subjects Housatonic River Basin Plan.
Dear Sirs
I hereby submit comments on the subject Plan.
(1) It is noted that the Plan states on page 11 that - "Certain towns
which should not need municipal sewage systems show high growth(at
least 50?° rate and a minimum growth of 2500) to year 1990- These towns
should be particularly careful that the expected growth takes place in
a manner so that on-site sewage disposal systems will function indefi-
nitely so that central sewage and water systems will not be needed, as
noted in the Plan of Conservation and Development. These towns in the
Housatonic Basin-include all of Bethany and most of Oxford and Prospect".
It is suggested that the towns of New Fairfield and Sherman are
also in "this category and the Plan should so state.
(2) It is suggested that more attention should be paid in the Plan to
the future of Candlewood Lake and its drainage basin. A disproportion-
ate amount of space in the report is given to Lakes Lillinonah, Zoar
and Housatonic but hardly any mention is made of Candlewood Basin. In
the light of recent - attempts to force intensive development of a large
tract of shorefront on Candlewood Lake as a high density PUD, which de-
velopment, if successful, would have forced the sewering of parts of
New Fairfield and Sherman, I recommend that the policy of the State
with respect to the classification of Candlewood Lake be reconsidered.
I believe that the Lake and its drainage basin should be classified as
a future potential water supply area and receive the same protection
from a zoning point of view as lands tributary to water supply reser-
voirs.
To this end I recommend that Section 25~26a of the State Statutes
be modified to permit the taking of water fov water supply purposes from
streams or rivers receiving sewage effluents which have received at
least secondary treatment with 90% removal of biochemical oxygen demand
and effective chlorination. I do not see how the U.S. Environmental
Protection Agency can have one set of water supply standards for New
York, Chicago, Philadelphia or any of the other large cities and a more
stringent one for Connecticut. The Safe Drinking Water Act requires
the same standard for all water supplies. Most urban areas of the
country take their drinking water supplies from streamsrivers and
lakes which receive treated sewage effluent. In fact the City of New
York does not even filter its supplies which are taken from drainage
areas which are interspersed with sewage treatment plants.
-------
2.
(3) I cite the impact of this legislation(Section 25~26a of the Statutes)
which, presumably, was enacted on the recommendation of the DEP or its
predecessor agency, on the implementation of water supply policy in the
Housatonic Valley Region centered around Danbury. It seems obvious to
me that in the event of another severe drought such as occurred in the
60s Danbury would again have to depend on Candlewood Lake water to sup-
plement its supply. There would then be posed a "Hobson's Choice" of
pumping water into Margerie Reservoir or rationing water. Would the
Legislature have to be called into special session to repeal or modify
Section 25~26a. I suggest that it would make more sense to modify the
law now.
This would accomplish two things - it would guarantee Danbury*s
water life line and would stop Danbury from "looking with avaricious
eyes" on New Fairfield's and Sherman's own future water resources.
(4) Mr. William H. Raacke, the former First Selectman of New Fairfield,
had urged all of our area legislators, including Senators Ribicoff and
Weicker, Congressman Sarasin and the then Congresswoman Grasso to intro-
duce legislation in the Congress to include in upcoming revisions to the
Federal Water Pollution Control Act Amendments of 1972 a provision that
a study of Candlewood Lake and its drainage basin be mandated similar to
the study which the present act mandates for Lake Tahoe on the Nevada-
California border. I believe this matter shoud again be considered and
that the Housatonic Basin Plan should recommend such a study. Unless
some action of this kind is taken soon, one of the repeated attempts to
establish a damaging development on the Lake is likely to succeed and
destroy for all time the Lakes's potential for water supply and reason-
able recreation. Witness the latest attempt at Wildman's Landing at
the lower end of Danbury Bay to establish a large recreational complex.
Such a study would determine the validity of my contention that
the water quality of Candlewood Lake would best be protected by banning
the sewering of any portion of iti basin unless gravity flow out of the
basin can be provided. This is feasible but expensive. The sewerage
study made for New Fairfield was based on circumstances which might con-
ceivably occur if town development based on septic systems came afoul of
large scale septic system failures which could not be remedied on small
lots, thereby forcing sewers on the town. Such a situation is now appar-
ent in portions of Danbury. Such sewering in New Fairfield would require
numerous pumping stations, some of which, based on the ordinary law of
probability would malfunction during power outages and cause heavy pol-
lution of the Lake. As Camp, Dresser & McKee warned in their report on
town sewering, this necessity should be avoided at all costs. I, there-
fore urge that the Housatonic Basin Plan make some definite recommenda-
tions to guarantee that Candlewood Basin will not be sewered but rather
will be required to survive on subsurface sewage disposal.
(5) I note on page 72 the statement that - Serious consideration should
be given to requiring P(phosphorus) removal at the New Milford Plant"
In this connection I call your attention to the decision of the DEP,
based uponthe recommendation of Camp, Dresser & McKee when they complet-
ed their sewerage study of New Fairfield that if Danbury was required
to provide advanced waste treatment but not New Milford, the economic
choice for New Fairfield would be to send its sewage to New Milford but
if both Danbury and New Milford were required to give the same degree of
treatment then the economics favored treatment at the Danbury Plant. Ac-
cordingly I suggest that the future planning of sewerage and sewage treat-
-------
3-
merit for New Milford, Brookfield, Danbury and New Fairfield is affect-
ed by this decision.
(6) Lastly I raise the question as to the necessity for phosphate re-
moval at either New Milford or Danhury sewage treatment plants. There
appears to "be some uncertainty relating to the availability of phosphate
detergents in area supermarkets. The Grand Union in New Fairfield, for
instance, has no phosphate detergent for sale except dish washer deter-
gent which has no satisfactory non-phosphate substitute. A partial
check of Danbury supermarkets indicates that the customer has a choice
of phosphate or non-phosphate detergents.
Under the circumstances it seems to me that a recheck of the cal-
culations relating to possible phosphorus content of sewage effluent at
the Danbury plant is in order. 1
Permanent phosphate removal facilities have not been incorporated
in the expansion and modernization of the Pittsfield Sewage Treatment
Plant at the head waters of the Housatonic. I quote from a technical
article by Charles A. Parthum of Camp, Dresser & McKee on the design
and construction of the Pittsfield facilities in the Journal of the New
England Water Pollution Control Association, Volume 8, No. 2, on page
190 to witi "A combination of factors led CDM to recommend that perma-
nent phosphorus facilities not be constructed initially. In the first
place, the water quality of the Housatonic River, even as far upstream
as Hinsdale, presently exceeds the standard of 0.05 mg/l total phosphor-
us. Thus, even if 100^ of the phosphorus was removed from the wastewat-
ers, the standard could not be met. Secondly, both capital and oper-
ating costs for phosphorus removal facilities would be considerable.
Thirdly, the federal government does not have sufficient definitive in-
formation on the effectiveness of phosphorus removal and- is still in-
vestigating it . The Massachusetts Division of Water Pollution Con-
trol concurred with the recommendation".
Respectfully submitted,
William A. O'Leary, P.E.
Consulting Engineer. ,
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DOCUMENT R55
Veronica H. Mooney
INVESTMENTS
P. O. DRAWER A
NEW FAIRFIELD. CT. 06810
Environmental Protection Agency
J.F. Kennedy Federal Building
Boston, Massachusetts 02203.
Gentlemen:
Re: EIS New Milford Wastewater
Facilities.
I wish to question the utilization of the
Carrousel Process and the inclusion of the Nestle'
effluent in the new Milford disposal facilities.
Since there are no installations of this process in
the U.S. and only limited data has been available from
Eurppe, the specification of this process gives rise
to some impprtant questions:
1. Why was a proces^with only secondary capabilities
selected for New Milford when Danbury, whose
effluent reaches the same river was ordered to ins
stall tertiary treatment facilities?
2. Is the engineering capability to install and
operate a Carrousel system available in the U.S.?
3. Why were no primary settling tanks provided?
4. What are, and how reliable are,the sources of
mechanical equipment? Prime source? Second Source?
5. What would be the time required to obtain
replacement parts?
6. What would be the effect upon the environment
in the event of a breakdown and delay in the
repair of the facility? Would raw sewage enter
the Hoiiisatonic River system?
7. What would by the effect of the highly corrosiue and
concentrated effluent of the Nestle'plant on the
operation of the system?
8. How did Metcalf and Eddy arrive at the cost
figures that were included in the EIS? With no
U.S. experiential basisljfor them, is this merely
an exercise in punching keys on a calculator?
Before EPA agrees to spend taxpayers1*- money
to fund this installation, it seems to me that these
are significant questions that require answers.
Very /truly yours, N
)/ (< /
/ >--7. >7?.-ST ¦ ' ' I
(Mrs. Arthur J. Mooney)
March 1977
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DOCUMENT R56
BR 1, Sherman, Connect3.cut 0678^
March 6, 197?
Mr. John A. S. KcGlennon
re: Comments on Environmental Impact
Stat^ent...New Milford, Connecticut
J
Regional Administrator
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Dear Sir:
I ask that you add my comments to those which you have al-
ready received. ?!y right to comment stems from the fact that
Sherman should rightly have had an opportunity to "be included in
the discussions, as much as New Fairfield. One sewer plan in-
volving New Fairfield would have passed through thp Squanta Fond
area which is Sherman.
I agree with all those who have pointed out that the State-
ment is "biased in favor of greater capacity than necessary. One
needs even less than a kitchen course in statistics to observe
that the growth-rates depicted on p, 9^ are absurd. The rate for
the "Plan of Development" for New Milford is steady from 1970 to
1990. Yet growth started slowing down in the early'?0s. And as
any reader of newspapers knows, there is a net outmigration from
the northeast to the sunbelt df the south and southwest. The
DANBURY SKSA shows a decrease in net population in the latest
period for which data are available, 1970-7^•
Growth-rates which show the same high rate of growth from
1970-80 are similarly biased upward.
The errors are too numerous in this report for the report
to be given credence. I would point to an example which others
may not have mentioned, since it is far from the most iripcrtafit:
The authors of the EIS, in their advocacy of a^mas.siye capacity
for the projeclfynew sewer, cite statistics of/price of houses
OFFERED for sal£. What nonsense! Everybody knows that the ac-
tual selling^jprice is below the offer price generally, and is
certainly asxeTabove it. 'ihat is the purpose of overstating the
price of housing? And is it not equally relevant to point out,
if the author Relieves the^grige gf housing is relevant in this
SIS, that apartments/iaKipmcrl tfian single-family houses of equal
size? (These ars National Association of Home Builders data and
therefore cannot easily be challenged. I attach the dat^ from
the HUD report submitted to Congress.)
As a scholar concerned with competence and accuracy, I
would never again hire the writers of the EIS for an IJIS.
.End.
(Mrs. Gerald Sirkin, M.A., Econ.)
-------
from rtOD Condominium/Cooperative Study, Volume , National Evaluation,
done u..ier contract with HUD by Arthur D. Litt: A*July, 1975
~nir nousing units in tne u.a. iuv*..
Thus, condominium units in structures now being built arc slightly
smaller than the average U.S. living unit.
TABLE 111-21 PRICE RANGE BY TYPE OF HOUSING - 1974
Condominium
Townhouse
Single-family
Price Range
Less than $20,000
2%
3%
$20,000-30,000
40
12%
28
$30,000-40,000
31
25
32
$40,000-50,000
13
39
19
$50,000-60,000
9
12
12
$60,000 or More
5
12
6
Median Price
$32,100
$43,300
$34,750
Median Floor Area
1,256 sq ft
1,433 sq ft
1,754 sq ft
Median Price per Square Foc# S25.55 $30.21 /r2- $19.81 J iTl>
Median Price per Square Foot (1973) $24.07 JJj $21.35 (pf $18.32 f (T&
Source: National Association of Home Builders.
In addition to being smaller on a per-square-foot basis than single-family
homes, condominiums have a smaller number of rooms per home than
these units. Table 111-22 compares the number of bedrooms for those
projects responding to the survey of homeowners associations with the
national averages as reported in the 1970 Census of Housing. It can be
seen that condominiums have a much higher percentage of units with
two or fewer bedrooms than all owner-occupied units, and even have a
from HUD Condominium/Cooperative Study,
Vol. II, Appendix A, Area Market Studies,
Boston
TABLE A-12
NEW CORE AREA RENTERS AND CONDOMINIUM OWNERS, AND CITY RESIDENTS,
BY HOUSEHOLD INCOME - 1973
Core Area
Income
Renters
Condominium
Owners
City of Boston
(1970 Census)
S 0-7,999 9.9% 0.0% 50.6%
$ 8,000-9,999 8.f) 2.5 14.5
$10,000-14,999 19.2 15.0 21.0
$15,000-24,999 31.8 30.0 11.0
$25,000 and Over 30J) 52.5 2.9
Total 100.0% 100.0% 100.0%
Median Income $18,368 $25,438 $7,835
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DOCUMENT R57
JOHN LOWENTHAL
SECOND HILL ROAD
BRIDGEWATER. CONNECTICUT 06752
TEL (203) 354-0538
5 March 1977
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Attn: Messrs. J.A.S. McG-lennon and W. Stickney
Environmental Policy Coordination Office - Room 2203
Re: Draft Environmental Impact Statement
Wastewater Collection and Treatment
Facilities - New Mllford, Connecticut
Gentlemen:
Your draft EIS (1) seeks to justify a £32.9 million project
by presuming a population increase based in part on obsolete
projections already proven unreliable as predictors and in
part on population growth induced by the project itself;
(2) proimses that the EPA fail to perform its duties under
federal law; and (3) disregards the views of the community
solicited by the EPA.
(l) The draft EIS mentions the unreliability of recent
high population growth estimates, but then goes right ahead
to rely on them anyway. Thus, states the draft EIS:
The high estimates of population growth made
in the 195°'s and 1960's are testimony to the
hazards of growth determination. (21^)
The authors of the draft EIS list the Regional Plan Association1s
The State of the Region: A Digest of Selected Trends Through
197^i Number 97, March 1975, as a document they 11 reviewed" (227,
233)• But they do not tell us what that document reveals, such
as that all projections made in the period 1957-1972 "erred on
the high side" (^-2); that "The 1972 projections were overtaken
by events and a major report ... to explain their Implications
in detail, was never published" (^1); that the "current prospect
. . . is one of population stability rather than growth" (1); and
that "An end to population growlbh appears to be what a large share
of the Region's residents want." (2)
Yet the draft EIS would endorse the proposed treatment facility
on the basis of growth projections no more reliable than those
recently "overtaken by events". Moreover, included in those
;7
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EPA 5 March 1977
-2-
projectlons is a growth of 20% induced by the very facility
the impact of which the EIS is supposed to be evaluating (211-17).
(2) The objective of the Federal Water Pollution Control Act
Amendments of 1972 "is to restore and maintain the chemical,
physical, and biological integrity of the Nation's waters".
To achieve that objective, the Act declares that "(1) it is
the national goal that the discharge of pollutants into the
navigable waters be eliminated by 1985" (sec. 101(a)).
Yet the facility endorsed by the EPA in the draft EIS would do
the exact opposite: Its very first adverse Primary Impact would
be "Increased BOD load on the Housatonic River" (223) resulting
from the eight-fold increase in effluent (treated only to secon-
dary levels) discharged into the river (191).
The Act goes on to direct the EPA to "encourage waste treatment
management" that provides for ''recycling of potential sewage
pollutants" or "the confined and contained disposal of pollutants
not recycled" (sec. 201(d)). Again, the proposal endorsed by the
EPA in the draft EIS would do the exact opposite: It would col-
lect even more pollutants and dump them into the Housatonic River
and local landfill (223).
Even as a lawyer and professor of law, I am at a losfe to understand
how the EPA's endorsement of this proposal could be other than a
failure by the EPA to fulfill its statutory obligations to further
the objective, national gofcls, and specific directions of the Act.
(3) Just when a Governor1s task force and many legislators and
other citizens are seeking ways to protect Connecticut's dwindling
farms and open spaces from development, the proposal endorsed in
the draft EIS would "eliminate farmlands and woodlands" (203) an&
convert "land use from 6pen space to developed as a result of in-
duced growth" (225). Just when New Milford is struggling to cope
with its and others' solid wastes, the proposal would add ^0 cubic
yards of sludge per day (221). With Connecticut's air pollution
already among the worst in the nation, the proposal would cause
"Some absolute increase in air pollutant concentrations" (223).
"Leap-frogging" development and "Land speculation" (216), down-
zalng (215) &nd accelerated suburbanization (20^), increased
traffic and strain on schools (216), and accelerated "aesthetic
decline of the Route 7 corridor " (205) are among the other im-
pacts propasedfor New Milford.
Then the draft EIS tells New Milford that the "negative implica-
tions" its people have drawn from such "induced growth" are "not
correct" (215), but, instead, the EPA's own proposed balancing
of values is the right one for New Milford and is consistent with
its development goals (22^). After all that, it is mere empty
rhetoric for the EPA to intone that "An EIS is not a growth
strategy. Such a strategy is the responsibility of the community."
(219) The EPA has been to New Milford and heard its strategy in
workshops, hearings, and petitions, all of which this draft EIS
proposes to disregard.
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EPA 5 March 1977
-3-
As a taxpayer, I am appalled at the waste In this draft EIS.
As an environmentalist, I wish we still had the trees instead
of the paper it consumed.
The CTS itself proclaims that it 'should be written "succinctly"
for "easy comprehension by the general public" (3, ^). But it
is 3^8 pages - over two pounds - of turgid, repetitious bureau-
cratase. It reads as if its authors, Anderson-Nichols, were
being paid by the word - which, at the reported $47>000 payment,
comes to 3*5^ per word. For example, we are told not just once
but a dozen times about the eutrophic algal blooms in Lake Lilli-
nonah (14, 15, 30, 41, 46, 63, 141-42, 201, 284, 303), a fact
already well known to local residents who get even a glimpse of
the Lake in summertime.
Yet what really matters is that the proposed project would
Increase the phosphate load on Lake Lillinonah (v, 191-92),
while the treatment system the EPA proposes to endorse fails
to incorporate the very phosphate removal facility that con-
cededly "may (sic) be required in the future because (of)
phosphorous . . . eutrophlcation of . . . Lake Lillinonah"
Worse, a close reading of Anderson-Nichols" evaluation of the
endorsed Metcalf & Eddy "Carrousel" prodess (280-87) reveals
such serious shortcomings in the process, and such doubts about
its compatibility with phosphate removal, that its proposed en-
doresemnt unavoidably raises dark suspicions in the reader's
mind. These suspicions are reinforced when the reader also learns
that the Carrousel process has "no inherent advantages" over the
conventional activated sludge process (175)> is more'"expensive
than the latter, and is thus not even the most cost-effective
process (287-91).
In sum, this draft EIS by Anderson-Nichols reads like an over-
blown rewrite of the very Metcalf & Eddy proposal it was supposed
to be reviewing. It looks just like one sanitation engineering
company back-scratching another. Nor can the EPA duck responsibility
simply by saying (twice) "The choice of treatment process, then,
is a matter of engineering prerogative." (291; 175) The EPA com-
missioned the engineers Anderson-Nichols to write the draft EIS,
and it is published as prepared by the EPA.
Proper proteotion of the environment in this instance should not
require lawsuits by citizens or review by the General Accounting
Office. Such protection is the job of the Environmental Protec-
tion Agency.
(284; 175, 303).
¦y truly vours
hn Lowenthal
cc.: Rep. Toby Moffett
The Editor, The New Milford Times
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DOCUMENT R58
Curtis Ave. RD 4
New Fairfield, CT 06810
2 February, 1977
Dear Workshop:
Sorry I couldn't make it this evening, but I have
very late classes on Thursday. If there are any comments on
my written submission, I'll be happy to try and answer them.
I have read the EPA draft Environmental Impact Statement on
the proposed wastewater facility planned for New Milford. My
comments on it follow.
I am, first of all, wary of any agency that wants to do
something for my own good. I have difficulty reconciling how
one state agency can express deep concern over the quality
of water supplies, when another state agency allowed a builder
to construct a sump at the south end of Ball Pond for the
purpose of supplying public drinking water.
Watch out, New Fairfield--you're not out of the woods
yet. of the 5 impact alternatives involving sewer construction,
you are included in 2 of them (alternatives V and VII). If this
town is ever saddled with a weak or corrupt group of town officials
at some future date, you will see sewer construction. And if
you think the High School has cost you money, wait until you
see your sewer taxes.
The impact report is at fault in one major area-
It completely glossed over the impact that a major
sewage treatment plant might have on ground water levels in
the 3 town area to be "served" by it.
First of all, the Conn. General Assembly plan of conser-
vation and development clearly stated its intent to use
groundwater, rather than surface water for municipal water
supplies (p. 32 of Impact Statement).
On pp. 32-36, the report refers to a study done by the
HVCEO concerning ground water resources in the area. This
was simply an estimate of water demands compared to potential
(emphasis mine) surface and groundwater supplies. That
report concluded"... actual groundwater investigations need
to be carried out to accurately assess the development
potential of this source of water supplies." In other
words, we are really ignorant about the quantity and quality
of groundwater levels. Yet on p. 195> we are reassured that
we have adequate supplies. If we don't know, how can the
authors of the impact statement be so sure?
It is stated on p. 19^ that 70 percent of septic tank
effluent is lost to the atmosphere by evapotranspiration.
-------
Mellett 2
That statement is innacurate and misleading. I challenge
it, and I would like to see the data on which it was based.
A 70 percent evapotranspiration deficit for water injected
below the ground is a figure that one might expect for
Tucson Arizona, or Saudi Arabia, but not the Housatonic
Valley.
From November to March, the ground in this area is
solidly frozen. Evapotranspiration is zero now, and only
becomes a significant factor from June to September. Also,
because the ground is frozen, all precipitation is subject to
runoff and recharge from that source is also zero. Because
they inject water into the ground below the frost line,
septic tanks may be the only factor in groundwater recharge
during the winter months.
The failure to consider septic effluent in recharge
is even more puzzling, because on p. 296, the report states
that irrigation of treated effluent onto the ground surface
is an alternative means of further treatment, and a method
of recharging ground water. Again I ask, how on the one
hand can water applied to the surface be a means of recharging
ground water when it is argued that septic effluent is not?
This is an extremely important point, and I suggest
that the following might happen:
When the proposed plant is in full operation, 10 million
gallons per day of effluent, primarily derived from ground-
water flows into the Housatonic. Because of reduced recharge,
groundwater levels start falling and wells in higher elevations
begin to go dry. There will then be a clamor for a regional
municipal water supply that would have to come from surface
sources, such as Candlewood Lake, Ball Pond, or new
reservoirs. Once again, bond issues are raised, taxes go
up, and streets are torn up all over again, but this time to
lay pipe for the Northwest Connecticut Regional Aqueduct
System.
In summary, I argue that a major potential impact of
sewer plant construction will be on groundwater reserves in
this area. This impact has not been addressed and before
any further action is taken on this plant, a complete areawide
inventory of groundwater resources must be undertaken.
The purpose of this impact report is to explore and
understand alternatives before we perform an irreversible
action. Unless a groundwater investigation is carried out,
this impact proposal has failed to fulfill its primary function.
I have just a few more comments.
On p. v, an alleged direct benefit of the plant is
an improvement of water quality in the Housatonic. Yet on
-------
Mellett 3
the same page we are told that this plant will increase,
repeat increase, phosphorous pollution in Lakt. Lillinonah
by 320 percent! And that is described as a marginal increase.
Just what Lake Lilly needs- another dose of goodies for its
resident algal population.
It is alleged that septic tanks contaminate groundwater
with salt (pp. iv, 19*0 • Yet no mention is made of the tons
of road salt that are applied to our roads in the winter.
Road salt is such a serious threat to surface and groundwater
supplies that some states are considering banning its use.
We are building a sewage treatment plant to cope with a non-
existent threat from septic tanks when the real villains are
state and local agencies themselves.
Another potential impact not considered is the type
of industry that will be attracted to the Housatonic Valley
once the plant is built. Will they be clean, housebroken
industries, or will they dump lead, cadmium, zinc, mercury,
PCB's, asbestos, and other uglies into the sewers? Does the
plant as envisioned have methods of monitoring for these and
other toxic materials, and does it have provisions for removal
of toxins before the effluent is dumped into the Housatonic?
My final point concerns the Carrousel Process. The
entire discussion of this component in the plant was
confusing and evasive. If the Carrousel system will not
remove phosphorous, the major algal nutrient in fresh water
ecosystems, why was it considered at all?
If the Federal Water Pollution control Act requires the
most cost effective treatment system(cee p. 287), will the
Carrousel, plus a tacked on phosphorous removal system be
the most cost effective? If it is not, it will be illegal
to install it.
Throughout the report, then© were statements that
gave me the disturbing feeling that the Carrousel Process
has a number of serious, perhaps fatal flaws. Apparently,
attempts at phosphorous removal may interfere with nitrogen
removal (p. 176); on p. 10, denitrification capabilities
are claimed for the process. You mean it has not been
verified? Are we buying a pig in a poke?
I was always under the impression that one could not
patent a natural process. Since the Carrousel works by (a)
flowing water and (b) bacterial action, what is it about
the process that is unique enought to patent? Couldn't the
state design its own system of treatment that would include
phosphorous removal? Finally, are there royalty payments
for the Carrousel process, and were they included in the
cost figures on pp. 287-290?
~james S. Mellett, Ph.D.
Associate Professor of
Geology, New York Univ.,
Consultant in Environmental
Geology
-------
DOCUMENT R59
TOWN OF NEW MILFORD
C, \!0/ r,
PHONE 354-5516 10 MAIN STREET NEW MlLFORD, CONNECTICUT 06776
KV0- —
Office of the FIRST SELECTMAN
A{ V*
March 23, 197 RECEIVED
MAV. -S, IV/ 7
State of Connecticut ,,,
t\ # j. t-> • j- -n 4. j- • ANP5 inonHf ^ & i#Q., NC»
Department of Environmental Protection £
State Office Building
Hartford, Connecticut 06115
Attention: Robert B. Taylor, Director
Water Compliance and Hazardous Substances
Dear Mr. Taylor:
The intent of this letter is to inform the Department of
Environmental Protection of the official Town position with regard
to Project # C090202.
On March 17, 1977, a meeting was called by me, which took place
at the Town Kail. The purpose of the meeting was to review positions
and proposals and to discuss in detail the aforementioned project.
In attendance at said meeting were the Chairmen and members of the
Board of Selectmen, Sewer Commission, Zoning Commission, Planning
Commission and Conservation Commission. Also in attendance were the
Director of Health, Sanitarian and Public Works Director. In order
to assure the full co-operation of potential future Town Officials
and the continuity of our efforts, the two candidates for the Office
of First Selectman were also in attendance. As you know, one of these
two candidates will be elected at our municipal election May 2nd. All
those in attendance at the meeting have reviewed the EPA Report and
attended the meetings where the public had an opportunity to express
its opinion.
As I am sure you are aware, the Town, some years ago, did purchase
ten acres of land for the purposes of constructing a new sewer treat-
ment plant. The Town has also authorized bonding in the amount of
$11,500,000, which sum is sufficient to implement the following proposals
enumerated in this letter (items a through k).
The following items represent the conclusions and the consensus
of those present at this meeting and we hope that this will assist your
department in understanding what we believe to be a program which is
not only in the Town's best interest, but the best interest of our entire
region as well:
a. construction of a new 4 million gallon per day sewerage
treatment plant of the carrousel type to be located on land
owned by the Town of New Milford on the east side of Pickett
District Road.
-------
StatVof Connecticut
2
March 23, 1977
b. conversion of the existing treatment plant into the east
side pump station.
c. installation of an East Aspetuck interceptor beginning
at the intersection of VanCar and Papermill Roads and running
southerly to a point where the Housatonic Avenue and Youngs-
field Roads intersect.
d. construction of a pump station at the above intersection,
better described as the East Aspetuck Pump Station.
e. construction of an east shore interceptor and force main
from East Aspetuck Pump Station to existing treatment plant.
f. a north Housatonic trunk line beginning at the intersection
of Fort Hill Road §2 and U. S. Route 7 and running southerly
to a point on the west side of the Housatonic River opposite
the existing treatment plant.
g.. construction of a west shore pump station at the southerly
end of the above north Housatonic Trunk line.
h. construction of a connecting force main and west shore
interceptor running from the above west shore pump station
to the new treatment plant.
i. construction of a southerly interceptor beginning at the
intersection of U. S. Route 7 and Lanesville Road and running
northerly to the new treatment plant.
j. the east Aspetuck interceptor shall be constructed of
sufficient size to allow for the future inclusion of Washington,
and that the southerly interceptor be constructed of sufficient
size to accept the affluent from Brookfiela.
k. furthermore, that it would not be in the best interest of
New Milford or the region to accept sewerage from any region
that would, if accepted, necessitate the installation of sewerage
trunk lines across or under the Candlewood Lake.
I feel that the above is of sufficient clarity to enable you
to understand our position. However, if you have any questions, or
need further information, please feel free to call upon me at any time.
Of course, I would be more than happy to meet with you or representa-
tives of your department to clarify this matter further at a mutually
convenient time and date if, in your opinion, you feel it is necessary.
-------
State of Connecticut
3
March 23, 1977
I would like to take this opportunity to thank you for your
time and efforts in this matter so far and I am sure that I can
look forward to your continued co-operation in the future. I will
await your reply.
Yours, very truly,
C"'Louis C. White
First Selectman
LCW/'lm
-------
document R60
60 East 42nd Street New York New York 10017
212/867-3076
RECEIV "
February 7, 1977 j
Mr. B. Ketchem an D E 1 ^ i o ti.o Li & 0o.L
Anderson-Nichols & Co., Inc.
150 Causeway Street
Boston, Mass. 02114
Dear Mr. Ketchem:
It was with great interest that we read the Draft Environmental
Impact Statement upon "Wastewater Collection and. Treatment
Facilities, New Milford, Connecticut". The report was most
complete and I am certain will clarify the development of the
project and its goals which had become clouded in controversy.
During our review of the report we noted some minor items
which we would like to comment upon. We submit this letter
informally and do not intend to make our comments part of the
official record.
On page 175 it is stated that "There are no inherent advantages
or disadvantages of the Carrousel process". Our selection of
the Carrousel process was based on what we determined, after
thorough examination, to be inherent advantages. They are
primarily:
a. The lesser number of aerators required in the
Carrousel vs. complete-mix. Although essentially
the same installed horsepower is required in
either process, the mixing requirements of
complete-mix systems require more aeration units.
We believe the reduced maintenance on fewer
required units is an inherent advantage.
b. In the New Milford design it will only be
necessary to operate one of the two aerators (per
basin) to maintain adequate channel velocities.
Shutting off half of the aerators in a complete-
mix basin would result in inadequate mixing (at
least in an extended aeration design.) We feel
the ability to operate at reduced power levels
and resultant lower costs, during low loading
periods is an inherent advantage.
c. The Carrousel design may be effective in
accomplishing denitrification without additional
facility construction or methanol addition. We
feel that this is an inherent advantage.
d. Lastly, we believe that the inherent combination
of complete-mix and plug-flow zones will result in
more reliable effluent quality than would result
BOSTON PALO ALTO CHICAGO
-------
Mr. B. Ketchem
February 7, 1977
2.
with use of a conventional complete-mix
process.
On page 283 of the report it is stated that "the process must
be controlled within close limits, as a slight upset will
result in a violation of the EPA secondary effluent standards.
It is important to note that the processing train does not
incorporate primary settling, which makes careful control of
the aeration basins of paramount importance, since the
hydraulic and organic buffering provided by the primary
clarifiers, together with the possible reduction in organic
loading to the aeration basins, will be eliminated."
You note that close control of the biological process is
essential in order to consistently meet effluent limitations.
This is true, of course, of any activated sludge process,
particularly where short aeration tank detention times and
high secondary settling tank overflow rates are employed. At
the New Milford plant the design overflow rate at the peak flow
of 11.88 mgd is 756 gpd/sf. This relatively low overflow rate
along with return sludge pumping capability 1007o of average
flow should assure the stability of the process when considering
that the average aeration tank detention time is 24 hours.
The decision not to incorporate primary settling tanks in the
flow train was based on cost-effectiveness and efficiency of
these units. The wastewater from Nestle Co., Inc. has a
high, extremely soluble BOD component, as noted by a BOD of
5260 mg/L and a suspended solids concentration of 930 mg/L.
Based on this, the effectiveness of primary settling tanks
was evaluated to result in overall BOD removals of less than
207o. Therefore, it was more cost-effective to increase the
size of the aeration tanks than to incoroporate primary settling
tanks.
Although some limited organic buffering capacity may be
accomplished by installation of primary settling tanks, it is
not clear how such tanks provide hydraulic buffering. Height
over the weirs may be an inch or two at most. The storage in
two, eighty foot diameter tanks could not exceed 12,500 gallons
from a height change of two inches. Given that changes in flow
rate are not immediate, primary tanks really provide no
hydraulic buffering.
On page 283 it is also stated that "One of the major advantages
claimed in a paper presented at the New York Water Pollution
Control Association's Spring Meeting, June 1974 was that the
process required less oxygen than complete-mix processes at
the same loading (91-Exhibit 8). This was concluded, based upon
-------
Mr. B. Ketch em
February 7, 1977
3.
an erroneous assumption that a residual DO concentration of
less than 2.0 mg/L will be permitted in sections of the Carrousel
aeration basins, and that levels less than 2.0 mg/1 will not be
permitted in the complete-mix basin."
That paper illustrated that given the same average tank DO at
a particular loading, the horsepower required to maintain
that average DO was less in the Carrouselthan in the complete-mix
basin. In the complete-mix basin, in order to maintain a 2 mg/L
average DO, essentially all areas of the tank must be maintained
at 2 mg/L. In the Carousel it is possible to maintain a 2 mg/L
average DO by starting out at 5 or 6 mg/L at the aerators and
ending up at a 1/2 mg/L at the end of the flow circuit. Since
the transfer across a gradient of 1/2 to 6 mg/L is greater than
across a gradient of say 1.5 to 2.5 mg/L as in a complete-mix
system, the efficiency will be higher.
However, subsequent investigations did prove this to be
somewhat erroneous. Since oxygen transfer testing is based
upon aerating clean tap water, the deficiency in a test across
the aerator in successive passes of the aerated water in the
Carousel will approach Omg/L (since no oxygen is consumed) as
in the complete mix process. The oxygen transfer actually
results from the summation of the transfer resulting from
complete-mixing (in the aerator sections) and plug flow
(in the channel section). A subsequent paper "Loop Aeration
Tank Design Offers Practical Advantages" concluded that
the savings are more in the order of 10% not the 22% calculated
by the oxygen transfer equation for complete-mix basins in
the paper presented at the N.Y.W.P.C.A. meeting.
I have enclosed a paper entitled "Determination of the
Oxygen Capacity in Carousel Plants" for your reference. This
paper develops the equation for oxygen transfer in Carxousels
based on the combination of the oxygen transfer equations for
complete-mix and plug flow (oxidation ditch) formulae.
If a 2 mg/L or greater DO was required in all parts of the
Carrousel,the power requirements would of course be greater,
probably equivalent to those found in complete-mix basins.
On page 286 it is stated "One of the major reservations that
has been expressed in the engineering community regarding the
Carrouse]process, is the ability of the system to maintain
scouring velocities away from the aerator impeller".
This, of course, was one of our major concerns during our
investigation of the process. Only after examination of the data
on velocity measurements, inspection of operating Carrousels by
Metcalf & Eddy and discussions with Dr. Pople of Delft Technological
Institute, Netherlands, were we satisfied that adequate scouring
-------
Mr. B. Ketchem
February 7, 1977
4.
velocities could be maintained in all parts of the channel.
Lastly, we seriously question the Capital Cost Summary presented
in Table B-l. These costs appear low. The environmental
assessment prepared in January 1975 presented cost data that
we developed in June 1973. At that time, we estimated the
construction cost of the treatment plant at $6,408,000
(including the patent fee). Based on present costs it will
be considerable higher.
Very truly yours,
Allan Jacobs
Project Manager
AJ:srb
cc:J. Corey
-------
DOCUMENT R61
7 North Pleasant Rise
Brookfield, Connecticut
April 21, 1977
Brookfield Planning Commission
Grays Bridge Road
Brookfield, Connecticut
Gentlemen:
Please accept this letter in lieu of an oral statement concerning the necessity
of sewers in your Plan of Development. As a resident of Brookfield who is concerned
about the future of the Town from an economic, aesthetic and environmental viewpoint,
I feel that it is necessary to state my views concerning the need for sewers.
The question of need in the proximity of Candlewood Lake is obvious to me for
the following reasons:
(1) The area known as Candlewood Shores is presently occupied by some 500
homes of which the majority are over 20 years old. The septic systems
installed at the time of construction of these houses most probably
do not meet present health code standards, as the present code was
not in affect at the time of their installation. Soil types encountered
in this area are primarily Paxton and Woodbridge, each of which consists
of a moderately well drained upper soil layer and fragipan (hardpan)
at depths approximately 24 - 30 inches. The upper soil layers are
permeable enough to allow percolation of septic effluent whereas the
fragipan layer is not. This leads me to believe that septic effluent
which has percolated through the upper more permeable layer reaches
the fragipan layer which is relatively impermeable and follows this
layer to a lower level which in this case is Candlewood Lake. The
movement of the septic effluent through the fine grained permeable
upper layer is such that the majority of bacteria and viruses are
removed. However, this layer provides little or no removal of
nitrates or phosphates. It is my conclusion then that nitrate and
phosphate pollution of the Lake is a real possibility.
(2) Considering the soil types in the Shores and also those areas known as
Pleasant Rise and Woodview, a prediction of septic system life can be
compared to a study done in Connecticut by David E, Hill entitled,
"Longevity of Septic Tank Systems, Glastonbury, Connecticut". In this
study, a copy of an abstract is attached, it was found that the median
age for the first failure of systems in glacial till varied from 5.4
tii 6.6 years. The half life or that period of time at which at least
507 of the systems in this type of soil are expected to fail ranged
from 22 to 38 years. Assuming an average of these two figures, it
would be expected that 50% of those systems in the above mentioned
areas constructed in glacial till would fail within 30 years from
their insta1 lation. Considering the present age of the svsterns
particular!y i n the Carta i rvood Shores area it can be expected that
-------
Brookfield Planning Commission
April 21, 1977
failures would be more prevalent in the next 5-year period than in the past 5-year
period.
NEED FOR SEWERS IN STILL RIVER VALLEY:
(I) The Still River Valley consisting of an area drained by the Still River
contains what has been delineated by the United States Geological Survey
as an aquiferwith transmissivity (the ability of the aquifer to carry
water) of approximately 2700 to 10,500 feet squared per day per foot of
depth. The depth delineated on the attached map ranges from 10 to
40 feet indicating that using the lower transmissivity stated above
and the shallowest depths of the aquifer of 10 feet it can be expected
that this aquifer would flow at a rate of 27,000 cubic feet per day.
This conservative factor would yield one quarter of a million gallons
per day. Using the higher transmissivity factor and the shallowest
depths of the aquifer, the yield could be expected to approach the
one million gallons per day figure. In terms of water supply, this
portion of the Still River Valley can be considered valuable. As you
well know a good portion of the Still River Valley, particularly to
the east of Route 7 and bordered by the Still River on the east is
zoned for industrial usage. The disposal of industrial wastes into
the ground which would flow into the aquifer could have disastrous
affects on the quality of the water in this aquifer. Therefore, if
it is ever intended to allow industrial facilities in this area, it
is clear to me that municipal sewers must be provided them.
(2) There are presently two viable alternatives available to Brookfield
in terms of final disposal of sewage effluent, one being the proposed
New Milford treatment plant and the other the existing Danbury
treatment plant. The Danbury plant is presently a secondary treatment
facility which removes 85-90% of B0D-* (organic pollution loading)
and approximately the same amount of suspended solids. There are no
provisions at this plant for removal of nitrates or phosphates.
The final discharge of the plant is the Still River which then flows
north through Brookfield and New Milford and filially empties into the
Housatonic River.
The proposed New Milford plant would also be a secondary plant removing
approximately the same quantities of BOD and suspended solids as the
Danbury Plant. This plant will not be constructed with phosphate or
Nitrate removal processes and will have a final discharge into the
Housatonic River in New Milford. Considering the quantity of flows
in the Still River and the Housatonic River it is obvious that the
Housatonic River has a flow rate far in excess of that of the Still
River. Dilution of treated sewage effluent is a primary parameter
considered in the design of a plant and the location of its final discharge.
To further concentrate sewage effluent in the Still River which presently
during low flow periods consists of approximately one-half treated sewage,
by adding the effluent from the southwestern part or the flow from the
Shores, Pleasant Rise, Woodview areas would most probably create a
condition far worse than exists today. The same quantity of treated
sewage discharged into the Housatonic River would be more greatly
diluted than if it were discharged into the Still River.
Future plans include the addition of nitrate and phosphate removal
processes at the Danbury treatment plant. The operational maintenance
costs for nitrate and phosphate removal is quite high in that large
quantities of expensive chemicals are required to achieve removal of
these pollutants.
-------
Brookfield Planning Commission
-3-
April 21, 1977
Conclusions: (1) Based upon the age, soil types and size of the majority of
the present systems in the Candlewood Shores, Pleasant Rise and Woodview areas, it
seems to me that sewers will be required in these areas in order to minimize pollutional
affect on Lake Candlewood. If the projected rate of failure previously discussed
is anywhere near accurate, approximately 50% of those systems over 20 years old
can be expected to fail within a 5-year period, thereby creating a large overall
expenditure to residents of this area.
(2) In order to provide a more broad tax base, I feel that industry
in Town is required.Since the majority of the industrial zone fronts on Route 7 the ser-
vices fro© the Town concerning access would be minimal if not totally nonexistent
as that would be provided by the State. Police and fire services would be required,
however, those industries requiring extraordinary services of this type generally
incorporate them into their original design and operation. To consider the northern
portion of the Still River Valley as an aquifer with a potential for water supply
I feel that the only way to allow industry in this area is to provide them with
municipal sewers.
(3) The decision whether to discharge sewage from Brookfield
into the Danbury or New Milford plant must be looked at from at least two points
of view:
(a) The future costs of maintenance and operation of the Danbury
plant versus the future costs of the New Milford plant; included in this comparison
must be the examination of which of the two alternatives is more environmentally sound.
(b) If my feelings that industry is needed in the Town of Brookfield
andmust be placed along Route 7 is a correct assumption, and sewer services must be
provided to this area, it is obviously far more practical to provide this sewer
service by a line which'will terminate in New Milford carrying effluent from a greater
portion of-Town than just the industrial zone,as opposed to separate flows to two
different plants.
I hope that this letter will assist you in deciding on a course of action con-
cerning sewers for the Plan of Development. I thank you for the opportunity to
express my views and welcome any questions that you may have concerning this subject.
Very truly yours,
Paul T. Carroccio
-------
1
LONGEVITY OF SEPTIC TANK S'-YI'TEMT. - tJLAfl'K/NHURY, CCNTi.
David E. Hill
The Connecticut Agricultural Experiment Station, New Haven
Table 1. Longevity of systems that have failed and occurrence of premature
failure.
Soil Group
Median Age
to Failure
(Years)
Premature
Failures
(Number)
**
Percent of
Total Failures
for Group
Stratified sand and gravel
Loose glacial till
Compact glacial till (hardpan)
Poorly drained soils
Shallow to bedrock soils
13-1
9-7
6.1
6.2
11.5
6
10
9
1
_h
30
2
11
22
5
7
* The median age is a measure of the number of years in which 50$ of the failing
systems failed. Successes are not taken into account.
** A premature failure is a system that required repair within 2 years following
initial use.
Table 2. Multiple Failures.
i of
Soil Group
Number of
Systems
Total
Failing from
Group
Years
Median Age to Failure
1st 2nd 3rd
Stratified sand and
gravel
lU
5
lit. 1
5-3
3-3
Loose glacial till
l(
it"'
2.9
5.3'
Compact glacial till
6
1';
'4.2
3.2
Poorly drained soils
0
0
-
-
-
Shallow to bedrock soils
0
0
_
-
_
^ i resented t.o the Ojniic^tio-jt .'•""Ws.-'t'- . ibj • •inM r , 1-9 f'*» H«'0ky Hill, CT
-------
Table 3» Failures vs. Successes
Pre-i960 Post i960
1o "to
Failure Failure
Soil Group Successes Failures of Total Successes Failures of Total
Stratified sand and
gravel 708 2U7 25.9 613 bo 6.5
Loose glacial till 131 57 3O.3 267 36 11.9
Compact glacial till 126 25 16.6 112 15 11.8
Poorly drained soils 26 9 25.7 85 9 9«6
Shallow to bedrock
soils lk6 39 21.1 132 16 10.8
Miscellaneous soil
types U 0 0.0 2 0 0.0
Totals llkl 377 1211 116
Table 5- Longevity of septic tank systems installed in different soil groups.
% Failure in Cumulative Span Half-life
(Years)
5-Year
10-Year
15-Year
18-Year
All systems
U.9
12. k
21.0
26.7
27
Stratified sand and gravel
2.7
9-5
18.6
2k.6
25
Loose glacial till
6.3
17.0
28. u
3^.2
22
Compact glacial till
11.6
16.1
20.2
2i+.6
38
Shallow to bedrock
14.2
10:9
18.3
23.2
29
Poorly drained soils
6.7
16.3
21.5
26.8
2h
-------
Table U. Rates of failure of septic tank systems in study area
Year of Initial Use
Age
Vv.o \
(Yrs)
• - c
'55
'56
'57
'58
'59
'60
'61
'62
'63
'64
•65 '66
1
2
2
2
2
1
1^
1
1 3
3
-^2
l
2
1
l 2
L
1
1
1
i.
5
3^
1
2
3
1'
1 1
6
1
2
1
1
2 1
7
2
1
1
2
1
1
1
U
1
3 1
8
J,
4
2
3
3
1
2
1+
4
4
2
9
1
2
1
1
4
3
1
3
1
10
3
3
2
5
2
2
1
2
11
-
2
•3
2
3
3
1
12
7
1
2
4
5
1
13
2
2
6
5
1
4
3
lU
_L -
k
•3
1
2
2
15
-
2
j
5
1
16
/"
G
2
1
17
c
¦3
1c
n -
1
ilures
2-5*
24
37
25
17
29
19
10
16
16
9
8 11
^cesses
679*
94 105 113
70
79
77
75
78
90
95
85 100
Total 92k 118 1U2 138 87 108 96 85 9k 106 10U 93 111
£ Failure 26 20 26 18 20 27 20 12 17 15 9 .9 10
* Also includes systems installed before I9M+.
'67 '68 '69 '70 *71 '72 '73
1
6
1
1
3
i
1+
1
1
1
1
3
1
9 6 5 3 1+ - -
8k 129 93 66 70 66 10U
93 135 98 69 7h 66 10U.
10 k 5 k 5 0 0
CO
W
0)
Gj
3 QJ
H
•rl I
Cti CO
I—I
11
18
12
7
13
12
18
33
17
21
18
20
23
22
17
12
21
1U
0) §
¦p p<
w zo
>i
10 fn
03
¦H
+? 1
o m
EH IH
1232
122U
1266
1279
13^8
1392
1375
1357
1327
1303
1268
1218
1162
1116
1033
933
650
722
(1)
U
3
0.9
1.5
1.0
0.5
1.0
0.9
1.3
2.U
1-3
1.6
1.4
1.6
2.0
2.0
1.6
1.3
2.5
1.9
a> nJ
> ft
•H CO
•p
to
k.9
12.U
21,
26.7
------- |