Water Capacity Concerns
The LCWD serves more than 2,600 customers and draws its drinking water from the limited well fields in the Saugus and Ipswich River Watershed. Consumption has exceeded capacity for a number of years. As recently as 2019, the Ipswich River Watershed Association (IRWA) asked the LCWD to find other sources, to reduce the strain on the Ipswich River and its watershed. The LCWD has imposed water restrictions almost every summer because demand outstrips LCWD water supply. Why would the LCWD seek to expand the District to new customers without sufficient existing supply? Significantly, this matter is listed on the LCWD website and includes a red border that references the significant water use restrictions throughout the District for its existing customers and the request for an emergency order due to a lack of sufficient water.
Therefore, a new development has the potential to significantly draw on Lynnfield's overly strained water supply and further deplete its wells. LCWD Commissioner Joe Maney stated that the anticipated water demand of the development would be 5,000 to 6,000 gallons a day, yet this grossly underestimates a hydrogeologist who stated that the demand of the 66 two-bedroom units would be 40,000 gallons per day (gpd) or 28 gallons per minute (gpm) and that the estimate peak hour demand would be 53,280 gpd or 37 gpm. This estimate rises even more dramatically if the developers are permitted to build 128 units. Maney states that this LCWD water will “only be used for only essential use and no outside irrigation watering,” yet this is beside the point as it begs the question of how much usage is too much usage when the LCWD is still struggling to connect to MWRA and manage its own water supply. This should also be contextualized with Sagamore Hills’ failed plan to secure water from Peabody to meet its housing project demand in 2018. This caused Sagamore Hills to return to the drawing board for a water source. According to the minutes of a 2019 Planning Board meeting, the Sagamore Hills’ engineer and developer reported that there was a verbal agreement to provide water through the City of Peabody or other infrastructure, which failed again for Sagamore Hills.
The LCWD as well as the Lynnfield Water District have insufficient on-site groundwater sources for Lynnfield residents. This is not conjecture; it is the continuing status of the insufficient water supply. This is particularly concerning given the recent Level 5 watering restriction (the highest possible level) that was put in place of July of 2022 and only brought down to Level 3 a month ago. The absence of the necessary quantity and high-quality public water supply has been exacerbated by the droughts in 2021 and 2022. In fact, LCWD has been working on the MWRA as a new source for more than two (2) years.
The forecasted increase in droughts and extreme weather spells an uncertain future for water supplies in Lynnfield. Is rapidly approving new LCWD members and new consumption of limited water resources is in the best interest of ratepayers and the community at large? This water quantity issue is compounded by the water quality issue given LCWD’s recent PFAS problem. Any new development also has the potential to introduce more PFAS and other hazardous chemicals directly into the groundwater near public water supplies, What good is having protected wetland areas when we do not do detailed environmental impact assessments on the effects of building development by them?
There is a also legitimate concern as to how water line hookups to the community could affect Boston Clear Water Company’s water supply. Their water supply was already decreased from an LCWD well rehabilitation project two years ago, so it is reasonable to suggest that the Town of Lynnfield should assess the impact the community development would have on Boston Clear Water Company’s spring as well as LCWD’s water supply. Lynnfield’s Planning and Conservation Director Emilie Cademartori has not gone to Boston Clear Water Company to discuss the possibility of how their spring would be impacted by the development, which could reasonably be expected on a project of this scale. Therefore, Boston Clear Water Company is making the effort to assess the impact of the Sagamore Development on its water supply and the surrounding water supply, but this process could take over six months, which is why the project should be suspended until this environmental impact assessment can be undertaken. In this regard, the development can still go forward if the necessary protections are put in place to safeguard the water supply. Also, I request that Conservation Director Emilie Cademartori’s environmental assessment of the project be made widely available so the specifics can be discussed in greater detail. We have to not only consider the development’s water demands on the LCWD system and the water supply drawn from by the Lynnfield Water District,, but additional factors such as the extent to which pumping of water by the Sagamore Golf Course has lowered the groundwater table in the area. The Conservation Commission should inquire into all aspects of the environmental impact before further significant approval steps are taken such as approving the zoning changes.
2. Water Quality Concerns
The second matter to be addressed is the current water quality of the LCWD public water supply, which has been impacted by PFAS. The LCWD water source is groundwater that has been subject to background and artificial contaminants introduced by commercial, industrial and residential uses and discharges since 2015. The dangers and presence of PFAS in the LCWD public water system have been widely discussed. LCWD has been developing an action plan to address the dangerous PFAS prior to 2021 upon its discovery in the public water supply. Superintendent Scenna confirmed elevated levels of PFAS in the public water supply, which, according to the LCWD’s water consultants, CDM Smith, do not “break down easily and biodegrade naturally” and have been linked to “environmental and human health effects.” Even if non-detectable levels are reported (which should be verified by a third-party). Is it responsible to put more pressure on the system when the PFAS issue has not been solved at its source? PFAS in the LCWD water system must be satisfactorily addressed before new customers are added with new demands, and the potential to introduce additional hazardous substances into their septic systems which make it back to the groundwater and public drinking supply.
3. The Benefits Offered by Sagamore Are Not Clear And Not In Place
At the presentation by Sagamore Hills at the LCWD meeting on September 28, 2022, the Sagamore project team suggested there would be multiple advantages to LCWD and its customers with the admission to the District of Sagamore. Sagamore and LCWD spoke in general terms of looped water and future development restrictions. Notably, these benefits are neither in place nor a long-term benefit to LCWD’s current customers. First, while there is a representation that Sagamore Hills will grant an easement to LCWD to create a connection and looped water system for the District, there was no condition attached to the Warrant Article vote by the LCWD Board. That is, the admission of Sagamore Hills by the District members is not tied to any existing or future requirement for a looped water line. When asked about the looped line, the LCWD Superintendent admitted that the District does not control the Vallis Street connection and there is no looped water system guaranteed with the Sagamore easement. Second, Sagamore Hills admitted that the future “development restrictions” on the Property to prevent future buildings are only for decades, meaning the Property will be open for more development. The restrictions should be permanent under M.G.L. C.184, not temporary. The decision to admit new customers into the LCWD must be carefully considered to protect LCWD’s existing customers and its infrastructure, and it must be taken only after full transparency. The increased draw down of LCWD groundwater sources from this project and future projects from the expanded District is not in the best interest of LCWD or its customers at this time, despite the vote to allow the development’s inclusion into the system. The tax revenue from the development will be significant, yet does this come at the expense of watershed damage that cannot be undone? Only by suspending the project temporarily and fully assessing the environmental impact, especially by third-party experts, can we answer that question for sure. So why the rush to approve the project so quickly? Partly because it has tried and failed before and now is the time to make it happen, but wouldn’t taking more time and ensuring more transparency make this a more honest process?
Sagamore Hills should return to request admission only when water quality protection, water quantity assurances, and benefits are securely in place, and not speculative as they are today. The only immediate beneficiary from the District expansion is Sagamore Hills. In the Lynnfield Villager editorial “Tread lightly with Sagamore project,” it was written that “It doesn’t require a mathematician to figure out 66 homes would generate less traffic than [planned] 82” for the development. Yet the traffic issue is burying the lead, as the most pivotal question is how would this development affect the public water supply on which Lynnfield residents depend.
As a final comment with respect to LCWD ratepayers, I put forth that LCWD is accountable for water quality issues AT the tap where the water comes out of the faucet. I have previously emailed LCWD superintendent John Scenna who has stated that “LCWD is responsible for the maintenance and operation of all water services to each account from the connection at the water main to the shut off (typically located in the sidewalk or front property line of customer homes.). Access to and maintenance of the shut off and the installation and maintenance of the service pipe from said shut off to homes is the responsibility of each individual homeowner. LCWD provides and installs meters at the point of entry into every home. So does responsibility for water quality end at the point of entry or at the tap? If it is at the tap, should LCWD be paying for the water purification devices that ratepayers need for potable water. The Lynnfield Water District has stated that it is responsible for its customer’s water AT the tap, so why isn’t LCWD clear about this and putting the burden on its ratepayers? Thank you for your consideration.
5,000-6,000 gallon usage: https://lcwd.us/2022/10/11/lynnfield-center-water-district-to-hold-special-district-meeting-on-oct-20-voters-will-select-new-commissioner-consider-accepting-new-parcels-into-district/