May 13, 2015 Matthew Beaton, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 Attn: Purvi Patel, MEPA Office Re: Environmental Notification Form, Well3A New Source Replacement Well, Norfolk, MA, EOEEA No. 5360 Dear Secretary Beaton: The Charles River Watershed Association (CRWA) submits the following comments on the Environmental Notification Form for the above project. Well #3A, while not increasing the total authorized withdrawal for MCI Norfolk (0.49 mgd), requires new source approval and a new or amended Water Management Act permit.1 Accordingly, it will, contrary to the statement on p. 1 of the ENF, require a DEP permit. It is subject to the recently promulgated revisions to the Water Management Act regulations. It would have been helpful if the ENF had included a map with the location of the existing MCI wells in relation to well 3A. Well 3A is located in subbasin 21134, classified as Groundwater Withdrawal Category 4 (25-55% August percent alteration in flow) and Biological Category 5 (greater than 65% fluvial fish alteration) under the streamflow criteria in the new regulations. The net groundwater depletion for this subbasin is 25%, which under the new regulations requires minimization of the impacts of the withdrawal “to the greatest extent feasible.” See 310 CMR 36.22(5). The proponent should analyze potential minimization measures. We do not know based on the information in the ENF whether the “baseline” withdrawal for MCI Norfolk is exceeded or indeed, whether the mitigation requirement in the regulations would be triggered. The draft Zone II delineation provided by the proponent includes the Stony Brook drainage and extends to the Stop River, a tributary to the Charles which suffers from low flow in the summer. We have concerns about the validity of the pump test given the extensive alteration of the area by the Mosquito Control Program shortly before the pump test. As the proponent acknowledges, this “affected the hydrology of the area considerably.” Appendix C at 2-1. Please feel free to call me if you have any questions at 781-788-0007 ext. 234. 1 According to the proponent’s consultant, the project is not being permitted as a “replacement well.” Charles River Watershed Association 190 Park Road Weston, MA 02493 t 781 788 0007 f 781 788 0057 e charles@crwa.org www.charlesriver.org Sincerely, Margaret Van Deusen Deputy Director and General Counsel cc: Kevin MacKinnon Duane Levangie Charles River Watershed Association 190 Park Road Weston, MA 02493 t 781 788 0007 f 781 788 0057 e charles@crwa.org www.charlesriver.org