ISLAND END RIVER CHAPTER 91 COMMENT LETTER
ISLAND END RIVER CHAPTER 91 COMMENT LETTER
Attached and below is a form comment letter for the Chapter 91 permit application for the Island End River Coal Tar Plant.
The EPA is trying to get the compensatory mitigation for loss of habitat to be in Rumney Marsh in Saugus. This is unacceptable. Both the cities of Everett and Chelsea want the mitigation to happen on or for the Island End River. Towards that end we have drafted a "form" comment letter (attached) that we are asking all of you to send to the DEP for the Chapter 91 Permit (The contact information is on the form letter).
The mitigation we propose is to repair/replace all of the sewer and drain lines that were installed in a substandard manner by the former Eastern Gas & Fuel Associates. These lines are corrugated steel pipes that are failing and providing a means for contaminants from the uplands to migrate to the river. Raw sewage has overflowed into the street and into the catch basins because of failing lines. These lines were never accepted by either city because of improper installation.
Please take the time to place this form comment letter on your agency/organization or personal letterhead, personalize it and send it off to the DEP via email to Ben.Lynch@... today as the comment periods ends today.
Sorry for duplicate posts.
Officer Patrick Johnston
Everett Police-Marine Unit
Program Chief WRP
One Winter St
Boston Ma, O2108
Re :KHB Ventures, LLC - Chapter 91 Permit Application - Island End River , Everett, Ma.
[name of organization] submits this letter in response to the Public Notice published by the Department of Environmental Protection Waterways Regulation Program. [name of organization] is a non-profit organization whose mission is … .
The Public Notice seeks comments on Chapter 91 permit applications submitted by the parties responsible for the cleanup of contamination caused by a former coal tar processing facility adjacent to the Island End River (the Responsible Parties). Specifically, the Public Notice seeks comments on the Responsible Parties’ proposal to dredge contaminated sediment from approximately 5.2 acres of the River and to fill 1.9 acres of the River with contaminated sediment dredged from the River and then cap this sediment. All told, approximately 6.1 acres of the River will be impacted by the proposal, all of which are within a Designated Port Area and have been designated as Essential Fish Habitat (EFH).
In return for the right to fill and impact 6.1 acres of waters, the applicable regulations and policies require that the Responsible Parties protect and promote the public use of tidelands and to provide for the prudent management of development on navigable waterways. [name of organization] feels that the Responsible Parties have not, to date, provided adequate assurances that this project will not be detrimental to public rights in tidelands or that the loss of water sheet will serve a proper public purpose without mitigation.
In addition, all licenses and permits issued under Chapter 91 must comply with the Massachusetts Wetlands Protection Act, and, in this case, almost certainly the Rivers Protection Act. These regulations encourage restoration and other forms of mitigation to put a stop to the further deterioration of water quality. Compensatory mitigation may take the form of rehabilitation and enhancement of the physical, chemical and biological characteristics of a degraded aquatic environment to improve water quality and wildlife habitat. This certainly would include the preservation and maintenance of an aquatic environment through the removal of any threats to, and through preventing the decline of, conditions within the environment.
As appropriate mitigation, the Responsible Parties should be required to alleviate an ongoing threat to the Island End River posed by deteriorated storm and sewer systems that reportedly have been improperly designed and constructed of corrugated metal that is now corroded and hole-ridden. As a result of this failing condition, they serve as a potential pathway for contaminants deposited through past industrial activities to continue to pollute the River, including the former coal tar related materials intended to be remediated by the Responsible Parties’ proposal. The corroded pipes also allow sewage to seep out and further contaminate the local environment. Obviously, these conditions, if allowed to continue, threaten to undermine much of what could be achieved by the cleanup.
Given the proximity of the River to valuable Essential Fish Habitat, the goal of any permit allowing for the River to be dredged and filled should be to stem any and all sources of pollution resulting in water quality degradation. We believe that this goal is best served by addressing the dismal environmental conditions created by the dysfunctional storm and sewer systems. Only through this action will the Island End River be restored to a valuable aquatic environment worthy of public access while removing it as a threat to contiguous aquatic environments and Essential Fish Habitat within Boston Harbor.