The state’s approval process offers two opportunities for the public to weigh in:

Send in your comments on the Environmental Impact report (FEIR). 
The FEIR has been submitted to MEPA and comments are due on October 23.
Click here if you need more info about how to submit your comments.

Comment on the permit
Comments are due to Ms. Anne Canaday by regular mail, email: Anne.Canady@state.ma.us or fax
(617) 626-1181 by Friday, October 23, 2009.

Copies of the Birch Road FEIR/NPC and the EEA Secretary’s August 7, 2009 Certificate for the DEIR can be accessed by clicking here, or by calling Framingham’s SEA consultant Peter Newton
(508) 743-7882.

More information
Here is a link to a website that has documents related to the project and comment letters from a variety of environmental groups. 

A Globe article on Aug. 26, 2009 described the environmental threats posed by the project.

An editorial in the Sept. 1, 2009 Globe makes the case that Framingham’s savings will result in a cost increase for the rest of the MWRA’s customers.


Regulatory Status (as of 9/1/09)
The Secretary of Massachusetts Executive Office of Energy and Environment (EOEE), Ian Bowles, issued a Certificate for the project’s DEIR on Aug. 7, 2009 which required filing of a Final Environmental Impact Report (FEIR).

The Town of Framingham has submited the FEIR and comments are due by Friday, October 23, 2009. 

The Town also filed an application for a Water Management Act permit with MA DEP in February 2009.  It is currently under review at MA DEP.

Proposed Framingham well project would reduce flows in the Sudbury and Concord Rivers and water levels in Lake Cochituate.

The Town of Framingham is proposing to revive its old Birch Road well field site and withdraw 3.17 million gallons per day from it.  The project also includes construction of a water treatment plant.  Currently, Framingham uses water from the Massachusetts Water Resources Authority (MWRA) and sends its sewage to the MWRA Deer Island treatment plant in Boston Harbor.  The proposed wells would reduce, but not eliminate, the Town’s reliance on MWRA water.  All sewage would continue to be sent to Deer Island for treatment and discharged to Massachusetts Bay. 

Sudbury River

The Sudbury River runs dry at Fruit Street in Hopkinson, in 1999

The town is proposing this project to save its ratepayers some money. 
It is not clear that this will indeed be the case (see below).  Even so, an editorial in the Sept. 1, 2009 Globe makes the case that Framingham’s savings will result in a cost increase for the rest of the MWRA’s customers. A Globe article on Aug. 26, 2009 described the environmental threats posed by the project.

Allowing this project to go forward as proposed would be poor public policy.
The town of Framingham already has water.  A withdrawal of this magnitude would damage nearby water resources of state and federal significance (Lake Cochituate, the Sudbury River, and the Concord River respectively). The state is mandated to protect rivers across the commonwealth.  The DEP recently used its authority under the Water Management Act to restore the Ipswich River – long a victim of uncontrolled municipal water use – and should use that same authority to protect the Sudbury River and Lake Cochituate.

The proposed water withdrawal of 3.17 million gallons per day (MGD) could harm summer and fall flows in the Sudbury and Concord Rivers, water levels in Lake Cochituate, and water levels in nearby wetlands.  The Sudbury and Concord Rivers are federal Wild and Scenic Rivers and Lake Cochituate is a popular state-owned recreation area. 

The proposed well withdrawal represents 22% of August median flow in the Sudbury River near the project location and 93% of the Sudbury River's calculated 7Q10 flow (the lowest stream flow for seven consecutive days that would be expected to occur once in ten years).  The Massachusetts Department of Conservation and Recreation stated in its July 31, 2009 comment letter on the project’s Draft Environmental Impact Report (DEIR) that “during the summer and fall of 2007, the Sudbury River at Saxonville fell below the proposed Birch Road wells water withdrawal rate during three weeks between August and October.  The wells would have had the capacity to completely dry up the river during these period.”  And none of the water withdrawn from the Birch Road wells, nor the remaining flows from the MWRA, would be returned the Sudbury and Concord River watersheds. Instead, this water will be discharged, as treated sewage, to the Boston Harbor.

Reduced flows in the Sudbury and Concord Rivers would also decrease the amount of drinking water available to the Town of Billerica.  The Sudbury River is a major tributary of the Concord River and the Concord River is Billerica’s only public water supply.  In addition, the remaining flow in these rivers would contain a higher proportion of wastewater effluent, as the proposed withdrawal would also reduce the dilution of discharges from the Wayland and Concord municipal wastewater treatment plants.  (The Town of Wayland discharges to the Sudbury River and the Town of Concord discharges to the Concord River, downstream of the Framingham Birch Road well field).  It is possible that US EPA and MA DEP would need to modify the NPDES discharge permits for these two facilities, in particular the dilution-based pollutant limits, to account for lower river flows.  The withdrawal will also require an interbasin transfer, a portion of which (3.17 mgd) the state asserts is grandfathered.

Will it really be cheaper for Framingham to pump and treat its own water?
Unclear.  According to the town’s DEIR., the project will cost $39 million. According to the DEIR, the town currently pays MWRA $2,514 per million gallons of water.  After the Birch Road water treatment facility is built, the cost will be $2,555 per million gallons of water, an increase of $41 per million gallons.  

The projected economic benefit is entirely based on a projected increase of 37% in MWRA rates by 2014.  In 2014, MWRA rates are projected to be $3,435 per million gallons.  No estimate was given for the cost of Birch Road well water in 2014, but a cost savings of $50,000,000 over 20 years is projected for the Birch Road well project.  No details were given on the rates used in these projections or the construction, maintenance, and/or operational costs that were included or not included.

The Town of Framingham also has water quality potential concerns about the well water, which are causing them to build the water treatment plant so that it can be upgraded to treat additional pollutants that may show up in the water in the future.  The cost of final upgrades and treatment isn't factored into the current analysis because recent water samples from the site itself came back clean enough.