November 28, 2023 - Town of Wellesley

U.S. Environmental Protection Agency · from the EPA · 11 pages · 409 KB
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November 28, 2023 
Michele Barden Claire Golden 
U.S. Environmental Protection Agency
Region 1
Water Division 
Surface Discharge Program
Massachusetts Department of Environmental
Protection 
5 Post Office Square, Suite 100
Boston, Massachusetts 02109
barden.michele@epa.gov 
150 Presidential Way
Woburn, MA 01801
massdep.npdes@mass.gov 
Re: Town of Wellesley Department of Public Works’s Comments on Draft NPDES Permit
No. MA0103284 for MWRA Deer Island Treatment Plant 
Dear Ms. Barden and Ms. Golden: 
I submit this comment on behalf of the Town of Wellesley Department of Public Works
(Wellesley DPW). The Wellesley DPW appreciates the opportunity to comment on the draft
National Pollutant Discharge Elimination System (NPDES) Permit No. MA0103284 (the Draft
Permit) for the Massachusetts Water Resources Authority (MWRA) Deer Island Treatment Plant
(DITP), which the U.S. Environmental Protection Agency – Region 1 (EPA or the Region)
noticed for comment on May 31, 2023. 1 As one of the entities subject to the terms of the Draft
Permit once they are finalized, Wellesley DPW writes to express its support for the comments
submitted by the Massachusetts Water Resources Authority Advisory Board (Advisory Board),
which are incorporated by reference as if set forth herein, and also to write separately to
articulate and highlight issues of particular concern to our community. 
As an initial matter, Wellesley has substantial concerns about the Draft Permit’s
imposition of a novel requirement to develop and implement a major storm and flood event
plan for its sewer system. This requirement will impose significant financial and resource
burdens on communities like Wellesley. The extent of these burdens is unknown because
neither EPA nor MassDEP has conducted any cost-benefit analysis of this new requirement.
Wellesley also has significant concerns about the Draft Permit’s directive to complete and begin
implementing a plan within twelve months of the effective date of the final permit. 
We are also concerned that the mandate to modify the plan whenever new data are
generated or discovered threatens to cast aside local planning priorities in favor of a federally
mandated, perpetual planning cycle. 
Wellesley has other significant concerns with the Draft Permit discussed in detail below.
In particular, the Draft Permit and State Permit inappropriately regulate communities like
Wellesley as co-permittees and have failed to define their obligations with adequate clarity. As
the Advisory Board has commented, unless EPA and MassDEP clarify the communities’ and
MWRA’s responsibilities, the DITP’s permit could upset the longstanding and successful
relationship among MWRA and the communities. 
1 On May 31, 2023, the Massachusetts Department of Environmental Protection (MassDEP) also issued a draft 2023
Draft Massachusetts Permit to Discharge Pollutants to Surface Waters for DITP (the State Permit) that incorporates by
reference Parts I.A-K and Part II of the Draft Permit. This letter similarly comments on the State Permit.

I. Major Storm and Flood Events Planning Requirements 
Part I.E.2.(e)(2) of the Draft Permit (the Major Events Planning Provisions) would
impose on Wellesley and other communities novel and onerous long-term obligations to
develop and implement plans to address the climate change resiliency of their sewer systems.
These plans, which the Draft Permit requires to be updated every five years, must include (1) an
asset vulnerability evaluation; (2) a systematic vulnerability evaluation, and (3) a mitigation
measures alternatives analysis, and they must take into consideration future conditions,
“specifically the midterm (i.e., 20-30 years) and long-term (i.e., 80-100 years) and, in the case of
sea level change, the plan must consider sea level change.” Draft Permit Part I.E.2.(e)(2). 
This requirement could strain Wellesley’s resources and disrupt its broader capital
planning process. The Draft Permit also gives Wellesley insufficient time to complete its plan.
Worse yet, EPA lacks the authority to impose this new planning and project development
obligation in DITP’s NPDES permit, and both EPA and MassDEP have failed entirely to justify
this new set of obligations. 
A. EPA Failed to Evaluate the Costs that Wellesley and Other Communities Will
Bear. 
Complying with the Major Events Planning Provisions will impose substantial costs on
Wellesley. The investments to undertake this work, including the up-front vulnerability and
mitigation alternatives analysis and the significant implementation and ongoing re-evaluation
requirements, will likely require thousands of hours of personnel time and the engagement of
outside consultants. Wellesley DPW does not presently have the staff to undertake the Major
Events Planning Provisions and would be required to either hire additional staff to engage in
this planning or contract with outside consultants. These costs could pale in comparison to the
potential capital costs that Wellesley may incur in order to implement mitigation measures that
could require relocating existing facilities or building new ones. 
The associated financial burdens on communities like Wellesley are unknown but
certain to be substantial. Wellesley DPW will need to assess whether it must hire more staff or
engage consultants to comply with the Major Events Planning Provisions. Based on its planning
efforts, Wellesley DPW will then have to modify its capital plans and budget for resiliency
projects. These additional costs will ultimately impact other parts of Wellesley’s budget,
resulting in lower spending on other critical infrastructure or other community needs. 
EPA and MassDEP must evaluate these costs before finalizing the Major Events
Planning Provisions. At the very minimum, before issuing a final permit, EPA or MassDEP
should provide Wellesley and the public more generally with a formal cost-benefit assessment
that informs all interested parties of the cost burdens of implementing these novel and
significant planning and implementation requirements. 
B. The Major Events Planning Provisions Do Not Provide Sufficient Time for
Compliance. 
The Major Events Planning Provisions provide Wellesley DPW inadequate time to
develop a plan that must accomplish the following: (1) analyze sewer system-related assets and
assess vulnerabilities, (2) conduct a systemic vulnerability evaluation of each individual system
and develop an alternatives analysis, and (3) begin implementing mitigation measures. Draft
Permit Part I.E.2.(e)(2). The Draft Permit affords Wellesley and its peer communities only 12

months to accomplish these tasks, an amount of time that is obviously insufficient to (a) retain
the necessary staff or consultants and (b) complete the tasks required by the Draft Permit. 
If EPA and MassDEP insist on including the Major Events Planning Provisions, the
agencies must provide Wellesley and other communities a reasonable deadline to complete this
major undertaking. Any final permit should allow the communities at least thirty-six months to
develop and begin implementing major storm and flood events plans. 
C. The Agencies Should Explore Whether Existing Programs Achieve the
Objectives of the Major Events Planning Provisions. 
Before requiring Wellesley to expend the significant resources necessary to comply with
the onerous Major Events Planning Provisions, the agencies should assess the extent to which
existing efforts or programs address or could be adapted to address the interests EPA seeks to
protect through the Major Events Planning Provisions. For example, wastewater utilities in
Massachusetts regularly seek funding from the Commonwealth’s Clean Water State Revolving
Fund (CWSRF), and this program already requires applicants to comply with planning and
asset management requirements in order to receive funding. The agencies may find that the
CWSRF is a better tool to address long-term planning obligations than an NDPES permit that is
limited to governing specific discharges over a five-year term. 
D. EPA and MassDEP Failed to Justify These Planning Requirements. 
In addition to the foregoing issues, Wellesley DPW is concerned that it has not had an
adequate opportunity to comment on the Major Events Planning Provisions because EPA and
MassDEP have failed to show their work. Both agencies’ fact sheets must address “the
significant factual, legal, methodological and policy questions considered in preparing the draft
permit.” 40 C.F.R. § 124.8(a); 314 CMR 2.05(3). For a set of programmatic requirements as
important and sweeping as the Major Events Planning Provisions, one would expect substantial
discussions of the various “factual, legal, methodological and policy questions” each agency
considered. 
EPA, however, justified the Major Events Planning Provisions by simply declaring them
“necessary to ensure proper operation and maintenance” of wastewater treatment
infrastructure. 2 Fact Sheet at 102-03. This explanation fails short of what EPA’s regulations
require, but it at least provides some indication of EPA’s views. MassDEP, by contrast, failed
entirely to discuss the Major Events Planning Provisions in its Supplemental Fact Sheet. If
Wellesley DPW and the public are to have a meaningful opportunity to comment on the Draft
Permit, the agencies must better explain the Major Events Planning Provisions and allow for
additional public comment. 
Wellesley DPW suspects that EPA may have failed to justify the Major Events Planning
Provisions because it lacks authority to impose them under the Clean Water Act (CWA). The
statute limits EPA’s authority under the NPDES program to regulating discharges, not the
wider facility (or facilities) that discharge. See, e.g. , Natural Resources Defense Council v. EPA, 859
F.2d 156, 170 (D.C.Cir.1988) (“[T]he [Clean Water Act] does not empower the agency to regulate
point sources themselves; rather, EPA’s jurisdiction under the operative statute is limited to
regulating the discharge of pollutants.”). The Major Events Planning Provisions, however, reach
far beyond regulating discharges by potentially regulating the location of permittees’ facilities
or even requiring the construction of additional infrastructure. Because the Major Events 
2 This explanation appears inconsistent with what the Major Events Planning Provisions require. They do far more
than ensuring “proper operation and maintenance” by requiring Wellesley and other communities to consider—and
possibly pursue—relocating facilities or building entirely new ones. Draft Permit Part I.E.2.e.(2)i.(c)(ii), (iv).

Planning Provisions exceed EPA’s jurisdiction under the CWA, they should be removed from
any final permit. 
II. THE DRAFT PERMIT IMPERMISSIBLY INCLUDES SANITARY SEWER
COMMUNITIES AS CO-PERMITTEES. 
As the Advisory Board has emphasized in its comments, for the first time, EPA and
MassDEP are attempting to regulate Wellesley and thirty-eight other sanitary sewer
communities under DITP’s permit. This radical change to these communities’ regulatory
obligations exceeds both agencies’ respective authorities and threatens to disrupt the
longstanding relationships between MWRA and the communities it serves. The agencies have
also sought to impose this new regime without Wellesley’s consent by unlawfully waiving their
permit application requirements. 
Worse yet, MassDEP has provided no explanation at all for its decision to regulate the
Co-permittees under the State Permit. MassDEP has an obligation to provide a “summary of the
basis for the draft permit conditions including references to applicable statutory or regulatory
provisions” in its fact sheets but has provided none in the Supplemental Fact Sheet for
including these Co-Permittees in the State Permit. 314 CMR 2.05(3)(c). In order for Wellesley to
have an adequate opportunity to comment on the State Permit, MassDEP should explain its
reasons and open a new comment period. 
A. Neither EPA nor MassDEP Has Jurisdiction to Regulate Communities Like
Wellesley. 
1. The Federal Draft Permit 
The Draft Permit’s inclusion of Wellesley as Co-permittee exceeds the EPA’s authority
under the NPDES program. Under the CWA, EPA may only regulate “the discharge of [a]
pollutant.” 33 U.S.C. § 1311(a). A regulated discharge requires an “addition of any pollutant to
navigable waters from [a] point source ….” 33 U.S.C. § 1362(12)(A); 40 C.F.R. § 122.2. Unless its
sanitary sewer system adds a pollutant to navigable waters, Wellesley is “neither statutorily
obligated to comply with EPA regulations for point source discharges, nor are they statutorily
obligated to seek or obtain an NPDES permit.” Waterkeeper Alliance, Inc. v. EPA , 399 F.3d 486,
504 (2d Cir. 2005); Nat’l Pork Producers Council v. EPA , 635 F.2d 738, 751 (5th Cir. 2011) (“There
must be an actual discharge into navigable waters to trigger the CWA’s requirements and the
EPA’s authority.”). 
Wellesley’s sanitary sewer system adds no pollutants to navigable waters. As EPA
concedes in the Fact Sheet, it only adds pollutants to MWRA’s treatment works. Fact Sheet 20
(“The Massachusetts municipalities in Appendix A own and operate wastewater collection
systems that discharge flows to the DITP ” (emphasis added)). The only addition of pollutants to
navigable waters occurs downstream from Wellesley’s sewers, when DITP discharges treated
effluent from Outfall T01. 3 
EPA rules reinforce that the communities do not have discharges that trigger the
Region’s CWA authority. The regulatory definition of a “discharge of a pollutant” explains that
the term encompasses releases “through pipes, sewers, or other conveyances owned by a State, 
3 The Region’s assertion that a sewer system’s lack of proximity to the “the ultimate discharge point is not material to
the question of whether it ‘discharges’” is inconsistent with the Supreme Court’s interpretation of the Act. Fact Sheet,
Appendix D at 13. In County of Maui v. Hawaii Wildlife Fund , the Court explained that “[t]ime and distance traveled
are obviously important” to determining whether a regulated discharge has occurred. 140 S. Ct. 1462, 1476 (2020).

municipality, or other person which do not lead to a treatment works ….” This language would
only be necessary if the obverse is true: flows conveyed through municipally-owned sewers that 
do lead to a treatment works are not discharges. 
2. The State Permit 
For the reasons set forth above, MassDEP regulation of Wellesley and the other Co - 
permittees in the State Permit is inconsistent with the regulations governing Surface Water
Discharge Permits. The Surface Water Discharge Permit regulations, like the CWA, generally
impose the requirement to obtain a permit on persons who “discharge pollutants to surface
waters ….” 314 CMR 3.03(1). And much like the federal program, the regulations define a
“discharge” as an “addition of any pollutant to waters of the Commonwealth,” and explain that
a discharge includes “discharges through … sewers, or other conveyances owned by a …
municipality … which do not lead to a POTW.” 314 CMR 3.02. 
The sanitary systems’ conveyance of flows to DITP involves no addition of pollutants to
any waters of the Commonwealth. They add flows only to the downstream POTW, a
circumstance that the regulations make clear is not a discharge that requires a permit. 
B. Communities like Wellesley are not part of the Deer Island Publicly-Owned
Treatment Works. 
1. The Federal Draft Permit 
EPA cannot cure its lack of jurisdiction by lumping Wellesley and other sanitary sewer
communities in with the larger publicly-owned treatment works (POTW) that includes DITP
authorized under the Draft Permit. 4 EPA’s regulations define a POTW to be “a treatment works
… which is owned by a State or municipality —expressed only in the singular. 40 C.F.R. § 403.3(q)
(emphasis added); see also id. (referring to “ the municipality … which has jurisdiction over
Indirect Discharges to and discharges from such a treatment works.” (emphasis added). The
definition’s use of the singular means that a POTW can only be owned by a single municipal
entity, such that Wellesley’s sewer system cannot be part of same POTW as DITP. 
EPA’s regulatory definition of a “discharge” confirms that the Region has improperly
expanded the definition of POTW to span multiple communities’ sewer systems. That definition
covers “discharges through pipes, sewers, or other conveyances owned by … a municipality …
which do not lead to a treatment works.” 40 C.F.R. § 122.2. If a satellite collection system could
be part of a POTW, there would never be circumstance where a municipally-owned sewer
could “lead to a treatment works.” Instead, this provision would refer to municipally-owned
sewers “which are not part of a treatment works.” The Region’s attempt to make the Co-
Permittees part of the same POTW as DITP contradicts and cannot be reconciled with its own
regulations. 
2. The State Permit 
MassDEP similarly cannot deem Wellesley’s sewer system part of the same POTW as
DITP under its permitting regulations. Like their federal counterpart, the Surface Water
Discharge Permit regulations define a POTW by reference to a single public entity rather than
several. See 314 CMR 3.02 (“any device or system used in the treatment … of municipal sewage
… which is owned by a public entity .” (emphasis added)). Having chosen to define a POTW by 
4 See Fact Sheet, App’x D at 10 (EPA may regulate satellite communities because they are part of “facilities subject to
the NPDES program”); id. (“NPDES regulations similarly identify the ‘POTW’ as the entity subject to regulation.”).

reference to a single owner, MassDEP cannot include satellite systems owned by thirty-nine
communities in the same POTW as DITP. 
C. Wellesley Did Not Submit An Application To EPA or MassDEP, and Neither
Agency Has Authority To Waive The Requirement To Do So. 
Wellesley did not submit a permit application to either EPA or MassDEP. Even if the
agencies could regulate the Co-permittees in DITP’s permit, issuance of a permit to a
community that never submitted a permit application would violate their respective permitting
regulations EPA’s rules specify that “[a]ny person who discharges … must submit a complete
application ….” 40 C.F.R. § 122.21(a)(1). The Region then “shall not issue a permit before
receiving a complete application for a permit ….” Without a permit application from Wellesley,
EPA cannot issue a permit imposing conditions on Wellesley. 
EPA cannot avoid this problem by waiving application requirements. See Fact Sheet 12, 
21. EPA’s March 8, 2023 letter to Wellesley claimed that 40 C.F.R. § 121.21(j) authorized the
Region to waive permit application requirements in their entirety. See Attachment A. The
Region’s waiver authority under this provision, however, extends only “to any requirement
under this paragraph [ i.e. , the POTW-specific requirements in § 122.21(j)].” 40 C.F.R. § 122.21(j).
Thus, EPA only could have waived discrete information requirements for treatment works, not
the fundamental requirement that a regulated entity submit a permit application. Accord 64 Fed.
Reg. 42434, 42440 (Aug. 4, 1999) (“EPA proposed the introductory paragraph of § 122.21(j) to
allow the Director to waive any requirement in paragraph (j) ” (emphasis added)). The Region
violated its own regulations by attempting to waive Wellesley’s obligation to submit an
application. 
MassDEP similarly violated its regulations by seeking to regulate Wellesley in the State
Permit without having received a permit application from Wellesley. The Surface Water
Discharge Permit rules specify that “[a]ny person required to obtain a permit … shall complete
and submit the appropriate application form(s).” 314 CMR 3.10(1); see also 314 CMR 2.03(1)
(“Any person required to obtain an individual permit … shall apply to the Department.”).
MassDEP “shall not issue a permit before receiving a complete application ….” 314 CMR
3.10(4); see also 314 CMR 3.02(2) (“The Department shall not issue an individual permit … before
receiving a complete application.”). Nothing in MassDEP’s regulations offer the department any 
authority to waive permit application requirements. This framework dictates that MassDEP
cannot issue a permit that regulates Wellesley because Wellesley did not submit an application
for a Surface Water Discharge Permit. 
III. The Draft Permit Fails to Define with Sufficient Clarity the Relative Responsibilities
of MWRA, CSO-Responsible Co-Permittees and Co-Permittees. 
Even if EPA and MassDEP could lawfully structure DITP’s permit to include Wellesley
and other communities, neither the Draft Permit nor the State Permit define these parties’
obligations with clarity sufficient to ensure that they are not held liable for conduct or events
over which they have no control. 
The cover page and Part I.E.2 must be revised to provide the communities and MWRA
with absolute clarity that the communities are not responsible for MWRA’s noncompliance and
vice versa. Any final permit issued by EPA and MassDEP must make clear that the
communities cannot be held liable for violations of permit requirements applicable to DITP; the
Draft Permit and State Permit fail to do this. Language in Part C, Part D, and Part E must also be
clarified further to remove any ambiguity regarding the several liability of MWRA, the CSO-
responsible Co-permittees, and the Co-permittees.

It is particularly critical that EPA and MassDEP clearly delineate these responsibilities to
avoid disrupting the longstanding relationship between MWRA and the communities, and
among the communities themselves. Each community and MWRA have their own
responsibilities with respect to wastewater treatment, and collection system management and
compliance. 5 Under its organic statute, MWRA must be accountable to the communities, rather
than a manager or regulator of the satellite sewer systems it serves. An NPDES permit or
Surface Water Discharge Permit that could make the communities liable for MWRA’s conduct—
or vice versa—could threaten that relationship. Accordingly, Wellesley DPW supports the
Advisory Board’s proposed revisions to the Draft Permit’s language that the Board submitted
with its comments. 
IV. Conclusion 
Wellesley DPW appreciates the opportunity to comment on the Draft Permit and State
Permit. As mentioned above, there is a lack of clarity throughout the Draft Permit and State
Permit as to Wellesley’s obligations. Further, the Major Events Planning Provisions provide an
infeasible amount of time for Wellesley and its peer communities to accomplish the required
tasks, all of which will necessitate significant time, expense, and resources. Thank you for your
attention to our comments. 
Sincerely,
Maurica D. Miller 
Cc: Meghan Jop, Executive Director
David Cohen, Director of Public Works
David J. Hickey, Town Engineer 
5 See Acts of 1984 ch. 372, § 26(d), 1984 Mass. Acts 809 (each local body served by MWRA has “the charge and control
of the respective water, waterworks and sewer works owned and used by said local body and not in the ownership,
possession and control of [MWRA].”).

ATTACHMENT A 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 
Region 1
5 Post Office Square, Suite 100
Boston, MA 02109-3912 
VIA EMAIL - READ RECEIPT REQUESTED 
March 8, 2023 
Re: Waiver of Permit Application and Signatory Requirements for Municipal Satellite Sewage 
Collection System – co-permittees to the MWRA Deer Island Treatment Plant, NPDES No. 
MA0103284 
Dear MWRA Deer Island Treatment Plant Satellite Collection System Member Community: 
EPA Region 1 is currently developing a draft National Pollutant Discharge Elimination System (NPDES)
discharge permit and an accompanying fact sheet that summarizes the significant facts, legal and policy
questions considered in preparing the draft permit for the Massachusetts Water Resources Authority Deer
Island Treatment Plant (MWRA DITP) including the collection systems from all member communities.
The purpose of this letter is to inform you of our plans for incorporating communities with satellite
collection systems that discharge into the MWRA DITP as co-permittees in the permit and any permit
application requirements. Please be advised that your municipality will be included as a co-permittee in
the forthcoming Draft NPDES discharge permit issued to the MWRA for the DITP. 
The satellite collection system member communities of the MWRA DITP listed in Attachment A will all
be included as co-permittees in the draft discharge permit issued for the DITP. Under NPDES regulations,
all Publicly Owned Treatment Works (POTWs) must submit permit application information set forth in
40 CFR § 122.21(j) unless otherwise indicated. Where Region 1 of the Environmental Protection Agency
(EPA) has “access to substantially identical information,” or such information is “not of material concern
for a specific permit,” the Regional Administrator may waive permit application requirements for existing
POTWs. Id. Pursuant to my authority under this regulation, I am waiving NPDES permit application and
signatory requirements applicable to certain operators, including your system, of the municipal satellite
collection systems that contribute to the MWRA DITP. 
EPA regulations do not specifically address how NPDES permit coverage is to be obtained by satellite
collection system components of POTWs. Ordinarily the treatment plant operator applies for the POTW’s
NPDES permit, and discharges from the POTW, including those from the collection systems operated by
others, are covered by the permit issued to the treatment plant. Satellite collection system operators have
generally not submitted separate permit applications for coverage under the POTW permit, because the
treatment plant operator generally submits the information necessary for the permit writer to write limits
and conditions in the permit applicable to all components of the POTW on the basis of the treatment
plant’s application. Receiving a single application from the operator of a portion of the discharging
POTW is one reasonable way to structure the permit application process, particularly in the case of a
regionally integrated treatment works where there is a centralized administrative entity responsible for
operating the POTW Treatment Plant and coordinating wastewater flows from the multiple satellite
collection system operators that all contribute to the final effluent discharge. 
Although EPA has the authority to require operators of the municipal satellite collection systems to
submit individual permit applications, in this case I find that requiring a single permit application
executed by the regional POTW owner/operator will be sufficient, as I have been provided, or have access
to, “substantially identical information” to what would have been provided to EPA by the collection
system operator, or that the detailed information requirements of Form 2A are not otherwise material to

EPA’s drafting of co-permittee requirements. Requiring a single application will also be less duplicative
and less burdensome than requiring separate applications from each municipal satellite collection system
owner/operator. Municipal satellite collection system owners/operators should consult with the regional
POTW operators to ensure that any information provided to EPA about their respective entities is
accurate and complete. If EPA requires additional information, it may use its information collection
authority under CWA § 308. 33 U.S.C. § 1318. 
As a general matter, EPA does not foresee the need to require individual permit applications from each
municipal satellite collection system operator and anticipates that information in the POTW operator’s
permit application and other information in the administrative record will be sufficient to establish permit
limits and conditions for the entire treatment works. In the future permitting cycles, EPA will indicate
whether it will require additional material from those entities operating the outlying portions of the
treatment works to render the permit application “complete” under 40 CFR § 124.3(c) after receiving and
reviewing the re-application for the permit from the MWRA DITP. 
This notice reflects my determination based on the specific facts and circumstances in this case. It is not
intended to bind the agency in future determinations where a separate permit for municipal satellites
would not be duplicative or immaterial. 
Prior to issuing the draft permit and fact sheet for public notice, EPA Region 1 will hold a virtual
informational session for MWRA and the co-permittees on March 28, 2023 from 1:00 pm to 2:00 pm
( Click here to join the meeting ). EPA will explain the draft permit’s co-permittee requirements at this
meeting and will answer questions pertaining to EPA Region 1’s co-permitting strategy. 
The co-permittees and MWRA will each receive a copy of the draft permit and the fact sheet when EPA
publicly notices them. The public will then have at least 30 days to submit comments on the draft permit
to EPA. Consistent with 40 CFR § 124.10, EPA’s public notice will detail how the public may comment
on the draft permit. 
If you have any questions or would like to discuss this decision, do not hesitate to contact Michele Barden
of my staff at (617) 918-1539 or barden.michele@epa.gov . 
Sincerely, 
David W. Cash
Regional Administrator
Office of the Regional Administrator 
cc: Claire Golden, MassDEP
Frederick Laskey, MWRA

Attachment A
Co-permittees to NPDES Permit No. MA0103284
MWRA Deer Island Treatment Plant 
Town of Arlington
Department of Public Works
51 Grove Street
Arlington, MA 02476 
Town of Ashland
Department of Public Works
20 Ponderosa Road
Ashland, MA 01721 
Town of Bedford
Department of Public Works
314 Great Road
Bedford, MA 01730 
Town of Belmont
Department of Public Works
19 Moore Street
Belmont, MA 02478 
Town of Braintree
Department of Public Works
P.O. Box 850903
Braintree, MA 02185-0903 
Town of Brookline
Town Engineer
333 Washington Street
Brookline, MA 02445 
Town of Burlington
Town Engineer
29 Center Street
Burlington, MA 01803 
Town of Canton
Department of Public Works
801 Washington Street
Canton, MA 02021 
Town of Dedham
Department of Public Works
55 River Street
Dedham, MA 02026 
City of Everett
Department of Public Works
19 Norman Street
Everett, MA 02149 
City of Framingham
Department of Public Works
100 Western Avenue
Framingham, MA 01701 
Town of Hingham
Department of Public Works
210 Central Street
Hingham, MA 02043 
Town of Holbrook
Department of Public Works
50 N. Franklin Street
Holbrook, MA 02343 
Town of Lexington
Department of Public Works
201 Bedford Street
Lexington, MA 02420 
City of Malden
Department of Public Works
200 Pleasant Street
Malden, MA 02148 
City of Medford
Town Engineer
85 George P. Hassett Drive
Medford, MA 02155 
City of Melrose
Department of PublicWorks
72 Tremont St.
Melrose, MA 02176 
Town of Milton
Department of Public Works
629 Randolph Avenue
Milton, MA 02186 
Town of Natick
Department of Public Works
75 West Street
Natick, MA 01760 
Town of Needham
Department of Public Works
470 Dedham Avenue
Needham, MA 02492 
City of Newton
Department of Public Works
1000 Commonwealth Avenue
Newton, MA 02459 
Town of Norwood
Department of Public Works
566 Washington Street
Norwood, MA 02062 
City of Quincy
Department of Public Works
55 Sea Street
Quincy, MA 02169 
Town of Randolph
Department of PublicWorks
41 South Main Street
Randolph, MA 02368

Town of Reading
Department of Public Works
16 Lowell Street
Reading, MA 01867 
City of Revere
Department of PublicWorks
321 Rear Charger Street
Revere, MA 02151 
Town of Stoneham
Public Works Department
16 Pine Street
Stoneham, MA 02180 
Town of Stoughton
Department of PublicWorks
950 Central Street
Stoughton, MA 02072 
Town of Wakefield
Director of Public Works
1 Lafayette Street
Wakefield, MA 01880 
Town of Walpole
Department of PublicWorks
135 School Street
Walpole, MA 02081 
City of Waltham
Department of PublicWorks
165 Lexington Street
Waltham, MA 02452 
Town of Watertown
Department of PublicWorks
124 Orchard Street
Watertown, MA 02472 
Town of Wellesley
Department of PublicWorks
455 Worcester Street
Wellesley, MA 02481 
Town of Westwood
Department of PublicWorks
50 Carby Street
Westwood, MA 02090 
Town of Weymouth
Department of PublicWorks
120 Winter Street
Weymouth, MA 02188 
Town of Wilmington
Department of Public Works
121 Glen Road
Wilmington, MA 01887 
Town of Winchester
Department of PublicWorks
15 Lake Street
Winchester, MA 01890 
Town of Winthrop
Department of Public Works
100 Kennedy Drive
Winthrop, MA 02152 
City of Woburn
Public Works Sewer Division
50 North Warren Street
Woburn, MA 01801 
NOTE: The Cities of Boston, Cambridge, Chelsea and Somerville have received separate letters as current
permittees under NPDES Permit Nos. MA0101192, MA0101974, MA0101877 and MA0101982, respectively.