Friday, January 28, 2000
Chelmsford ConsCom requests more data on proposed wells
The Chelmsford Conservation Commission displayed considerable skepticism about the Barnes Terrace well proposal at a January 18 public hearing on the Chelmsford Water District's pumping application. This second of what promises to be a lengthy series of continuations was called for the express purpose of completing the district's first-pass responses to questions raised about the impact on the wetland complex of which Carlisle's Cranberry Bog is a major feature. Present, in addition to interested Chelmsford citizens, were Carlisle selectmen John Ballantine and Doug Stevenson, four members of the Carlisle Conservation Commission (ConsCom) and Carlisle Cranberries president Mark Duffy.
Opening the discussion, Chelmsford commission chair David McLachlan suggested that the district's proposal to activate six wells with a pumping capacity of 360,000 gallons per day from within the Cranberry Bog reservation was probably an important enough project to warrant bringing in both engineering and legal counsel. Community development coordinator Andrew Sheehan concurred but remarked that a watershed analysis of this sort is usually the responsibility of the applicant.
The matter of outside counsel was apparently introduced in view of decisions made by the Carlisle Board of Selectmen at their January 10 meeting to seek further professional advice, so as to protect the town's water rights. Carlisle's concerns, including a recommendation for a "peer review" of the water district's impact analyses, were conveyed to the Chelmsford commission last week in a letter signed jointly with ConsCom. Discussion of Chelmsford's reaction was temporarily set aside to allow water district representatives to answer the board's technical questions concerning data contained in their application for the Barnes Terrace well field.
Questions about tests
District spokesman George Allen pointed out that the district's Zone 2 impact analysis had already received preliminary approval from the state Department of Environmental Protection (DEP), following tests conducted according to its regulations and designed to assure protection of the aquifer, even under the most extreme conditions. He indicated that when the tests were done in 1993, hydrologists from the DEP inspected the site from Heart Pond in South Chelmsford to the Cranberry Bog.
Repeating misgivings expressed at the December 21 hearing, Chelmsford commissioner John Smeldane questioned whether the impact analysis took into account the effects of pumping on surface water levels, since no quantitative relationship appeared to have been established between pumping rates and surface water reaction. He found this troubling because the district's application states specifically that 70 to 100 percent of the water pumped will come from surface sources.
When asked by Chelmsford commissioner Mike Jasinski about the reliability of the analytical model used to determine safe yield, Allen said this model had been approved by the state Division of Water Supply because the DEP considered this to be "a simple site." He did not feel the numerical model, preferred by Jasinski, would result in appreciably different conclusions.
Plans for monitoring impact
After further delving into technical data, questioning turned to the district's plans for monitoring and regulating impacts on the wetlands, should the plan be accepted. The district's hydrobiologist indicated that DEP mandates regular monitoring of wetland health within 150 feet of a well. Jasinski said he would like to see the commission set up "thresholds" to trigger mitigation procedures, particularly for vernal pools in the area of the pump house.
McLachlan was interested in the district's proposed operating hours of 12 on and 12 off, and how that schedule was determined. Allen replied that the configuration was adopted in order to "mitigate effects and let us work with the Cranberry Bog." McLachlan posited a situation that might arise in a serious drought when turning the water off after 12 hours would mean that the same customers who ran out of water last summer might experience water problems. "What would your procedures be then?" he queried. There was no reply. Smeldane insisted that the commission would need to know precisely what the district's management procedures would be. District commissioner Ron Wetmore offered, "You give us a management requirement and we'll follow it." To which McLachlan responded that if the nonexpert commission were foolish enough to establish these procedures, the onus would be on them if trouble arose.
To related questions of whether mitigation plans have been developed in case of adverse impacts, Allen again responded in the negative. Smeldane observed that he would like to see options laid out for a variety of scenarios, something he said is a legal requirement under the state Water Protection Act.
Allen offered "water budget" charts of annual and summer water flow through the site, which indicated regular flow out of Heart Pond. This triggered commissioner Mark Grant's curiosity to know what happens to water flowing out of the Cranberry Bog. McLachlan volunteered the information that it eventually flows back into Chelmsford from Great Brook Farm, through another water district's well field and into wetlands in that part of town. That suggested that limiting flow to the Cranberry Bog might impact wetlands outside the Heart Pond aquifer.
Concerns about Heart Pond
The first Chelmsford citizen to speak up was a homeowner whose property abuts Heart Pond. "In all this, I haven't heard anything about impacts on Heart Pond," he complained. McLachlan noted, "Duffy has the right to lower the water." Duffy, in turn, commented that people from Heart Pond do not let water flow out through the control dam during the summer because they want the water level high enough for boating and swimming. He described Heart Pond, along with the two holding ponds or impoundments above the bog, as "reservoirs" created by former bog owners. "They are not flowing streams," he continued. "What I take from the holding ponds is a lot of water, and it sometimes comes close to emptying them. Recognizing the interests of the residents in maintaining a high level at Heart Pond, I draw from it only as a last resort."
This account caused Smeldane to observe, "It looks as if it's not a good idea to expect to take water from Heart Pond on a regular basis." Following up, McLachlan warned, "This is a very complex system, important to a great many people. My concern is that this [location] should be a last resort for drawing water for Chelmsford." He then summarized the information the commission will be looking for from the applicant as the fact-finding process continues, i.e. availability of reasonable alternatives, analysis of surface water impact, clear watershed basin delineation, specific management procedures, careful review of district infrastructure and distribution status, a mitigation program and a statement of how the district plans to work with Duffy.
Obviously annoyed, Wetmore jumped on the final requirement to accuse Duffy of "stonewalling" and refusing to consider any withdrawal at all. To which McLachlan replied in an even tone, "Reasonable dialogue is always possible."
Sheehan reminded the commission that two pertinent processes are already under way. The first is a town-wide review of the infrastructure and distribution factors in all three of the town's privately-owned water districts. The second is a permit application from the South Chelmsford district pending before the DEP under the Water Management Act. The commission therefore decided to wait for the results of the latter before proceeding with further technical or legal consultation.
Speaking for Carlisle
Near the close of the hearing Ballantine commented for the record that the whole problem of water rights and withdrawal is the concern of both the selectmen and conservation commission of the Town of Carlisle, since the town, not its lessee Duffy, is the legal owner of the bog and its water rights. Agreeing that "this is a step-by-step process" and that more information is clearly needed, he let it be known, "We are not comfortable with what we see as of now."
The hearing was continued to February 15.
© 2000 The Carlisle Mosquito