November 22, 2023 - Chris Powicki, Cape Cod & Islands Group of the Sierra Club

U.S. Environmental Protection Agency · from the EPA · 2 pages · 135 KB
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From: Chris Powicki 
To: Barden, Michele (she/her/hers) 
Cc: Clint Richmond ; Diane LeDuc ; Mary Mary ; morgan Peck ; David ; Keith Lewison ; Vickash Mohanka 
Subject: Comments to USEPA on Draft Permit, Deer Islands Treatment Plant, from Sierra Club Cape Cod & Islands Group 
Date: Wednesday, November 22, 2023 10:14:10 AM 
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Dear Ms. Barden, 
The Cape Cod & Islands Group of the Sierra Club is opposed to eliminating the Outfall Monitoring Science
Advisory Panel (OMSAP) as part of the proposed renewal of the Massachusetts Water Resource Authority
(MWRA) discharge permit for the Deer Island Treatment Plant’s ocean outfall to Massachusetts Bay. These
comments complement and extend those being submitted by the Massachusetts Chapter of the Sierra Club
as a signatory to a coalition letter prepared by Just Zero. 
Continued long-term scientific monitoring of the outfall—guided by a direct advisory function and based on
sampling campaigns and research studies identified, designed, and implemented by a multidisciplinary team
of independent experts—is essential as a permit condition for understanding and managing interactions
among outfall constituents, other sources of nutrients and pollutants, and additional stressors, notably
climate change’s effects on storm frequency and severity and on ocean water temperature, chemistry,
circulation, primary productivity, and ecosystem function. 
Over the past 23 years, Boston Harbor’s water quality has greatly improved as a result of the operation of
the Deer Island Treatment Plant and its ocean outfall in Massachusetts Bay. To meet an equally important
challenge facing Cape Cod & the Islands, the Massachusetts Department of Environmental Protection
(DEP) has issued regulations to reduce nitrogen loading effects on coastal embayments attributable to
uncontrolled development and widespread use of Title V septic systems. In response, the town of Falmouth
is launching a study of an outfall pipe in Nantucket Sound as the possible point of discharge for growing
volumes of treated effluent collected from newly sewered neighborhoods, and other communities adjoining
Joint Base Cape Cod (JBCC) are studying whether to enlarge the JBCC wastewater treatment plant, with an
outfall pipe in Nantucket Sound. 
US Environmental Protection Agency (EPA) is still developing regulations regarding discharge limits for
contaminants of emerging concern (CEC), including microplastics and PFAS chemicals known to be
concentrated in the Deer Island effluent. All research to date related to microplastics in this effluent has
been conducted by the OMSAP. Some CECs are knowns to bioaccumulate in finish and shellfish, creating
potential for human exposure, including for those who fish to put food on the table and thus raising
environmental justice concerns. Dilution is not the answer to CEC pollution, according to Sierra Club
policy. 
Now is not the time for the elimination of OMSAP as a necessary independent scientific body. Instead, EPA
should expand OMSAP’s scope to better understand and address CEC contamination of marine
environments and food chains attributable to long-term operation of the Deer Island outfall within the
context of other stressors including cumulative impacts, nutrient loading, and rapidly changing climate,
oceanography, and ecology. 
Studies of proposed outfalls in Nantucket Sound, the implementation of DEP’s nitrogen management
regulations, and development and implementation of EPA’s CEC regulations will benefit from historical
and continued OMSAP-directed scientific monitoring of effluent from the Deer Island plant. Continued
function of OSMAP as a permit condition is essential for informing future permit actions within an
adaptive, ecosystem-based management framework.

Thanks for your consideration of these comments. 
Sincerely, 
Chris Powicki,
Chair, Executive Committee
Cape Cod & islands Group, Sierra Club 
cc:
David Dow, Diane LeDuc, Keith Lewison, Morgan Peck, Mary Waygan, Executive Committee
Members/Officers, Sierra Cape Cod & Islands Group
Clint Richmond, Conservation Chair, and Vic Mohanka, Acting Director, Sierra Massachusetts Chapter