HomeMy WebLinkAbout2005-05-04 Board of Selectmen HandoutGPCD Usage
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READING ITA CONDITIONS (IRWA SUGGESTED EDITS)(Gall commentary)
Based on the analyses and concerns expressed about this project, staff recommend approval of
Reading's application under the Interbasin Transfer Act for admission to the MWRA System
subject to the following conditions. Reading must commit in writing to abide by these conditions.
1. (a) Reading will manage its sources so that for the months of May through October, it
will limit use of its Ipswich River Basin sources to 1 mgd and will purchase up to 219
million gallons of water from the MWRA during that period.
(b) As noted in the MEPA letter of March 31, 2005, "in the event that the Town of
Reading should require the withdrawal of additional water supply from within the
Ipswich River Basin beyond the proposed 1 m dg during,, the May 1-October 31 low-flow
period as described in the FEIR to respond to an unforeseen, isolated or emergency
situation, the Town would not be required to notify the MEPA Office. This is
superfluous. The remaining portions implement the intent of the paragraph. As a
technical matter I would argue that the FEIR does not limit itself to the 1 mgd, although
others have made that interpretation. Perhaps a small point, but in the future few will
read beyond this document.
Should the Town require additional water supply from within the Ipswich River Basin in
amounts beyond the proposed 1 Miens during the May 1 to October 31
period to address its water supply needs to respond to more than an unforeseen, isolated
or emergency situation, then the Town would be required to submit a Notice of Project
Change (NPC) to the MEPA Office."
YeaF period, the Te:,A%,Y611 be required to submit a Notice of Pr-ejeet Change t
MEPA Offlee- H e uent occasions of de minimus um in less than 1%
over 1 m d shall not result in are u' t to file a a e wl awal from
Ipswich Basin sources does not exceed or . Ober period for that ear,
and if an days when exceeds 1 m d do not coincide with eriods w en flows
are below 0.42 cfsm the South Middleton gage. Adding the 0.42 requirement in here is
pushing; it. The intent of the deminimus provision is to cater to some imprecision in
operations that is bound to happen. This could happen at virtually any time, and is not
with respect to the level of flow in the river
(c) By "unforeseen, isolated or emergency situation" th
water if DEP has issued an emergency declaration with respect to opply. It also
appears to limit DEP's ability to issue an emergency declaration based on a drought
condition. This raises the question: can DEP issue an emergency declaration that
authorizes you to buy more water from the MWRA. In general, the answer would be yes,
but see the next section where that possibility has been effectively eliminated.
(d) If, for any reason other than ^ DEP emergeney deelar tion Reading amends its
contract with the MWRA to increase the amount of water purchased, the Town shallvAg
need to apply for additional ITA review. By deleting the terms "other than a DEP
emergency declaration", this eliminates the possibility that Reading could use the
MWRA for more water during a drought. It should be noted that DEP's issuance of an
emergency declaration is not a "get out of jail free pass". It comes with numerous
potential conditions -refer to the policy for details, and think of the Wilmington case as
precedent.
~-2.Because Reading's Ipswich River withdrawals will continue to impact the river and
reduce its flows, and i( this is editorial commentary that does not belong here. We could
elaborate on the imprecision of the comments, if appropriate) In order to comply with the
ITA requirement to implement all practical water conservation measures, ( again, this is
editorial commentary that should be deleted. Does one consider conservation measures
that do not return flow to the river, or which do not extend the utility of the 219 MG as
"practical". I, for one, would not.) ensure that the water purchased from the MWRA will
last through October, and that restrictions on Reading's water use are linked to
streamflow in the Ipswich River, the Town shall amend Section 4.9 of the Town of
Reading Water Conservation Program (mandatory restrictions on water use) to
incorporate at a minimum the requirements in sections A, B and C below. These
requirements shall apply to non-essential outdoor water use, which means those uses that
do not have health or safety impacts, are not required by regulation and are not needed to
meet the core functions of a business or other organization. Reading shall have up to 7
days to complete notification of the community about implementation of increased stages
of mandatory water use restrictions.
A: Insert Stage 2: If after May 1 of M year flows fall below 18.7 cfs at the
South Middleton gage ("gage") for 3 consecutive days, sprinkler use shall
be restricted to one d4y per week during the hours of 6 a.m.-8 a.m. and 6
p.m.-8 p.m. Hand-held hoses may be used on other days during the same
comes first. Failure to comply with these requirements is punishable by a
fine of $300 per day. [The Town may limit sprinkler use for even numbered
houses to a different day than odd numbered houses, to assist in managing
peak demand, however, no household shall use a sprinkler or sprinkler
system for more than one day per week during a Stage 2 declaration.]
Using historical records at the Middleton gage from 1961 to 1995, the
restrictions would be in effect for the months of may thu September for the
following percent of the time:
May
10%
Jun
53%
July
85%
Aug
95%
Sept
97%
Note that according to USGS studies, even with no withdrawals, the
restrictions would be in effect for most of the months at substantially the
same levels.
those months shown in the table below, Stage 3 restrictions shall be
implemented in lieu of Stage 2 requirements.
31-May 2.04 mqd
30-Jun 2.06 mad
31-Jul 2.24 mqd
31-Aug 2.15 mqd
I assume that these represent the average consumption for some time
frame, as I believe she described at the last meeting. Thus, the union of
the two events suggests that hand held watering would be the only kind
of irrigation allowed about half the time. I reach this estimate since the
flow is below 18.7 virtually all the time, and above the average about
half the time.
B. Insert Stage 3: If flows fall below 18.7 cfs at the South Middleton gage
for 3 consecutive days, non-essential outdoor water use shall be restricted to
hand-held hoses only during the hours of 6 a.m.-8 a.m. and 6 p.m.-8 p.m.
Failure to comply with these requirements is punishable by a fine of $300
per dam
C. Re-label Stage2 as Stage 4.
These conditions were proposed by IRWA to counter the perception that the restrictions as
crafted by the town and the VV-RC staff were some form of an "exemption" for Reading. We
should not lose sight of the fact that the Town/WRC restrictions were intended to serve to ensure
that the 219 would last into October. And the fact that they were triggered in only one year
reflects the fact that the 219 is usually adequate, so it should be no surprise that only in rare cases
would they get implemented.
This is no "exemption" on the part of Reading, since it reduces the Town's draw on the river to
about 0.4 of the winter demand, and comes at great
Rather, the exemption appears to be given to other communities who are not looking for other
supplies, who do not have reservoirs or sources of water outside the basin, and yet who are
allowed, under the permits, to have summer to winter ratios as high as 1.5 times the winter
demand.
th
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eading Stage I
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allons or- moFe o
s used 147 million
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used 190 million
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its Stage 2 water- r-estrietions (a ban on all et#deor-
e >
water- tise). The Tewfi will notify a]
v
rtrantsszniver+
ffi ma
y
"e Town detem3ciaes giat some other r-estgetions -All be at least as eff-eetive as these noted
in eaeh tkeshold above, the Tom% may petition the WRG for- modifieation of these
nt~.i nti r.
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IS
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;
,
n
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15 and~or- September 15, no
additional tluesholds -Axill be a
etivated or- eentiftued beyond
Stage
1. Stage I and 2 r-efer- to outd
oor- gulations as a
pproved by the Tovm of Rea
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B
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-3-:3_ A4 a ' ' andater-y r-estfietions shall limit fion essential outside water use to hand
,
mi~~, houf4y r-estrietioiis shall avoid water use duv;ng the houfs of 9 a.m. to .
Notwithstanding the foregoing, irrigation of public parks and recreational fields by means of
automatic sprinklers equipped with moisture sensors or evapotranspiration similar control
technology may also-be permitted between the outside of the hours of 6 p.m. and 8 a.m.-9
a.m. to 5 .m. The tefm non essepAial outside water- use is defimd to elude. Awse uses that
do not have heaM or safety impac4s, are not r-eqL&ed by r-eguMon and are not need
+ the eore funetions of n business other organization.
44.
proposed in the DEP Water ManagemepA Aet water vAffidFawal pemiRs issued
pemA#ees in the lpsv~ieh River- basin in May 200-3 and that these thresholds may be
p er-meth°ed in the ftAffe If the streamflow thresholds set forth in the water
withdrawal permits issued to permittees in the Ipswich River basin change, the
may request drat the WRC may amend the streamflow thresholds in this Interbasin
Transfer Act document to be consistent with the thresholds in withdrawal permits
applicable to other communities with groundwater sources in the Ipswich River basin.
Numerous changes here First, it moves the action toa discretionary one on the part of
the WRC rather than on the part of the Town Secondly, at present, all conditions are the
same ( even though most are under appeal). Even so, with the interbasin transfer,
Reading would be more like a surface water supplier than a groundwater supplier, and
should argue to be treated according to the source of the water.
&5. If, after the new water treatment plant is on line in Reading, an alternative purchase and
withdrawal scenario is proposed, including linkage to streamflows, Reading must consult with
WRC Staff to determine if this meets the requirements of this Interbasin Transfer Act approval.
[Note: In concept such a scenario would propose de minimus use of the Ipswich wells during
low-flow periods and increased use during higher flow periods resulting in an average use not
exceeding -I mgd with possible consideration of using La 5-year rolling average.] I do not think
the note is necessary And I do not believe that the Town should limit itself to the I mgd value.
All of those items would be on the table for discussion if the town goes forward on this idea.
6.6.Reading must provide annual reports to WRC Staff detailing how much water was
pumped from its own sources and how much water was purchased from the MWRA for the
first five years after the town begins to receive MWRA water. After this period, Reading
must furnish these reports to WRC Staff' if requested.
-7-.7.Reading must work with DEP to condition its registration statement to address the three
registration issues presented in the Secretary's Certificate on the MIR dated October 31,
2003. (Note that this was done via a letter from the Town to the DEP of November 28, 2004.)
9-. 8.Reading must, continue effective demand management programs that meet the Interbasin
Transfer Performance Standards for Criterion #3, Water Conservation.
-9-.9.Reading must provide the DEP Annual Statistical Reports to the WRC for the first five
years after the town begins to receive MWRA water to determine if the programs in place are
successful in keeping unaccounted-for water at or below 10% and residential gallons per
capita per day (gpcd) at 65 or less.
4-0-.1 0.1f the amount of unaccounted-for water increases to greater than 10%, Reading must
either provide an explanation of why this has occurred (e.g. water main break, large fire, etc,)
or provide a plan, for for-WRC approval, to reduce unaccounted-for water to acceptable
levels.
44l 1.If residential gpcd increases above 65, the Town must implement a comprehensive
residential conservation program that seeks to reduce residential water use through a retrofit,
rebate or other similarly effective program for encouraging installation of household water
saving devices, such as faucet aerators, showerheads and toilets and through efforts to reduce
excessive outdoor water use. If this occurs, the Town must provide a plan for this program to
the WRC for approval.
4-2-.12.Reading must notify the WRC when the High School and Barrows Elementary School
renovations have been completed, with documentation of the retrofit devices installed.
Reading must provide annual reports detailing the water conservation actions taken as part of
the four-year, $1 million program. This should include an accounting of the money spent
and the successes of the program.
*Section 4.9 Town of Reading Water Conservation Program lverbatiml
Stage 1
Stage 1 provides for mandatory water conservation, subject to penalties in accordance with law
for violation of these restrictions.
Water may be used for outdoor purposes only from 4:00 A.M. to 9:00 A.M. and 5:00 P.M. to
8:00 P.M. Monday through Sunday, and only in accordance with the following schedule:
® Even numbered addresses: Outdoor use is permitted on even-numbered days. of the
month only during the hours specified above.
® Odd-numbered'addresses: Outdoor water use is permitted on odd-numbered days of the
month only during the hours specified above.
There is no restriction on hand held devices.
In addition, the following regulation on filling swimming pools is mandatory: Swimming pools
shall be filled in accordance with the above schedule only, unless a waiver is granted by the
Town manager.
Stage 2
Stage 2 is provided for the eventuality that only enough water is available for essential public
health and safety _purposes. In this event, no outdoor water use of any type is permitted. Water
use is restricted to domestic home use only for including normal bathing, laundry, an
sanitary
Violation of these regulations is punishable by a $300.00 fine.
Adopted 4-25-89, 11/04, Revised 1-4-05
SIGN-IN SHEET FOR THE BOARD OF SELECTMEN MEETING
DATE:
NAME
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