November 28, 2023 - Save the Harbor/Save the Bay

U.S. Environmental Protection Agency · from the EPA · 2 pages · 215 KB
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November 28, 2023 
Michele Barden
US Environmental Protection Agency - Region 1
5 Post Office Square, Suite 100 (06-4)
Boston, MA 02109-3912 
Submitted via email: barden.michele@epa.gov 
Claire Golden
Massachusetts Department of Environmental Protection, Surface Water Discharge Program
150 Presidential Way, Woburn, MA 01801 
Submitted via email: MassDEP.npdes@mass.gov 
Dear Ms. Barden/Ms. Golden: 
Thank you for the opportunity to provide comments to the US EPA Region 1's draft National Pollutant
Discharge Elimination System (NPDES) permit issued to the Massachusetts Water Resources Authority
(MWRA) Deer Island Treatment Plant and CSOs (MA0103284), and to the Massachusetts Department of
Environmental Protection (MassDEP). Thank you especially for previously extending the public comment
deadline to allow for thoughtful feedback from community and organizational stakeholders. 
Save the Harbor/Save the Bay has “ been there from the beginning ” advocating for the Boston Harbor
Cleanup, construction of the Deer Island Treatment Plant and the transformation of Boston Harbor from
a national disgrace into a source of recreational, educational and economic opportunity and civic pride.
We take our name from the fact that not only would this effort eliminate the over 300 million gallons of
sewage a day running into Boston Harbor, but would do so without sacrificing the health of
Massachusetts Bay. After over 20 years of operation, testing and monitoring, the MWRA ’ s operation of
Deer Island is an unqualified success, with Boston boasting the nation ’ s cleanest urban beaches as a
result. 
We write today to strenuously advocate for the continued inclusion of the Outfall Science Advisory
Monitoring Panel (OMSAP) in the current permit renewal. 
While little concern remains about the outfall ’ s impact on water quality and environmental health of
Boston Harbor and Massachusetts Bay, we strongly encourage the retention of the OMSAP as a body for
responding to emerging and future issues and questions that will continue to arise, including climate
resiliency and contaminants of emerging concern. 
OMSAP is a volunteer group of scientists and experts in their fields who have dedicated the last 23 years
to peer-reviewing the ambient monitoring plan, and using science-based methods for reviewing reports
and addressing questions and concerns. It would be short-sighted to not include this group in the
renewal and keep an established, effective system in place at little to no cost. If in-kind costs and EPA
staff support of the OMSAP is the primary barrier to continuing this system, Save the Harbor is willing to

work with the agency to identify funds or alternative base for the OMSAP, if we can rely on their
continued authority and the existing communication and reporting structure. 
As Chair of the Public Interest Advisory Committee (PIAC), Save the Harbor is of course supportive of
retaining the Committee as a part of the permit. Also volunteers, the PIAC helps ensure transparency of
OMSAP, EPA and MWRA ’ s work and reporting, alleviating concerns about and opportunity for
misinformation. 
In the end, Save the Harbor, like all of those involved with this process and the Boston Harbor Cleanup,
will continue to strenuously advocate for swimmable waters, better fisheries, and the cleanest urban
beaches in the country. In that pursuit, we need to make sure there is science-based decision making,
and that it be flexible and transparent, and we believe that local scientists are best situated to do that.
We have that in the OMSAP, which can respond quickly and provide information, and is not at risk of
becoming more or less empowered under various administrations. 
We strongly encourage EPA to retain the OMSAP in the renewal permit. Thank you for all your time and
dedication to clean water and healthy fisheries in Boston Harbor and Massachusetts Bay and for your
attention to our recommendation. 
Sincerely, 
Chris Mancini
Executive Director
Save the Harbor/Save the Bay