February 13, 2010
Secretary Ian Bowles
Executive Office of Environmental Affairs
Attn: MEPA Office
Attention: Anne Canaday
RE: MEPA Project EEA
14537 – Foundry Pond Dredging and Restoration Project,
Dear Secretary Bowles,
The
Weir River Watershed Association is a nonprofit organization concerned with the
health of the
The
project seeks to dredge significant wetland resource areas for improvement of
water quality, to increase open water and benthic habitat, increase storage
volume, reduce aquatic plant habitat and biomass and internal nutrient cycling.
Foundry Pond is a manmade impoundment formed by a dam at the head of the tide
on the
In the late 1990s the dam was repaired under an emergency condition and the stream channel below the dam was widened, bank vegetation removed and riprap placed in the stream. This habitat alteration resulted in spawning smelt habitat diminishing significantly (pers. comm. Brad Chase, MassDMF). MassDMF has provided assistance to the town to restore stream channel and smelt habitat. That stream restoration work has not been completed as yet though has been in the planning stages for several years.
Clearly, the anadromous fish population at this site has been diminished significantly to the point where herring are almost nonexistent from this river system and are in danger of becoming locally extinct from this river.
In many other river systems that were dammed during the industrial revolution, communities and private dam owners are reviewing dam removal and river restoration as an alternative to keeping and maintaining a dam. In many cases, dam removal can make sense from a cost and ecological perspective. Removing a dam restores river habitat, improves water quality, decreases thermal pollution, increases oxygen levels in the water, restores anadromous fish habitat and passage, restores river fish species, like brook trout, while at the same time alleviates the owner of liability associated with the dam, the maintenance of the dam or dredging of the upstream impoundment.
If river restoration is feasible, little or no dredging behind the dam may be needed. In many other river restoration projects, the impoundment is drained and the natural stream channel is allowed to form behind the dam, some targeted dredging to form the channel and grading to shape the river banks might be needed but not the large amount proposed.
We would like to request that the Secretary require an Expanded ENF or Environmental Impact Review that examines the alternative of removing the dam and restoring the natural river system at this site. The alternatives examined in the current ENF were No Action and the two alternative methods of dredging. A full comparison of costs, ecological benefits and environmental impacts should be done for both dredging and river restoration before a final decision is made as to which option provides the most environmental benefit with the least environmental damage. The option for dredging should provide information on how the dam, the pond, and the fish ladders are proposed to be maintained in the future to restore anadromous fish populations in the Weir River and how the stream channel and streamflow will be managed downstream of the dam, particularly during summer low flow periods, to maintain downstream habitats.
Lastly, according to the Hingham Conservation Commission, it is our understanding that the proposed dredging is a precursor to dam removal and if the dredging is needed to meet the ultimate goal to restore the river then the project should outline how that goal is to be met in the filing.
Sincerely,
Darrell Baker
President