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Your Right to be Heard

Please join us next Sunday, May 31st, from 3:45 PM – 5:15 PM (RSVP here) at the Barn to ask questions, share opinions, and voice concerns. We are gathering to prepare for the Town’s upcoming Environmental Justice (EJ) meeting regard to the proposed wastewater increase into Camelot Park, scheduled for Thursday, June 4th at Town Hall.

The state’s MEPA regulations legally mandate that this Environmental Justice meeting be held to guarantee “meaningful involvement” for populations that may bear a disproportionate environmental or public health burden. Because the Camelot Park facility sits directly within a designated Environmental Justice neighborhood, state regulators at the MEPA office will be closely monitoring this process.

To make the greatest impact, our community should focus its comments and questions on five core objectives to challenge the town’s Draft Environmental Impact Report (DEIR) before it is formally submitted.

The 5 Core Objectives & Key Questions

1. Demand an Updated, Present-Day Environmental Baseline

The town has previously leaned on environmental studies dating back to 1997 to justify using the Camelot Park infiltration beds. Citizens should strongly object to the use of outdated data that ignores three decades of local development and watershed degradation.

• “How can the town accurately predict the impact of pumping 3.0 million gallons of wastewater per day when our baseline models completely ignore 30 years of development, land clearing, and watershed changes?”

2. Challenge the Insufficiency of the 2018 Testing Window

The town’s Expanded Environmental Notification Form (EENF) relied heavily on a single, limited field test conducted nearly a decade ago. This test took place during August and September of 2018—historically dry months when the water table is at its lowest seasonal level.

• “With climate change driving heavier annual rainfall and higher seasonal water tables, why hasn’t the town conducted hydrogeological testing during the wettest months of the year to model worst-case scenarios?”

3. Expose the “Pollution Shifting” Burden on Public Health

The stated goal of the project is to reduce saltwater algae blooms and virus threats to oyster beds in Plymouth Harbor. However, a state EJ analysis strictly prohibits resolving one neighborhood’s problem by transferring the environmental and public health burden onto another.

• “Are we protecting the harbor by shifting wastewater into a Sole Source Drinking Water Aquifer? What specific safeguards are in place to ensure contaminants such as pharmaceuticals, PFAS, endocrine-disrupting chemicals, heavy metals, etc., do not contaminate local drinking wells or the headwaters of the Eel River?”

4. Demand Accountability on Unanswered Technical Questions, Grants, and Data Gaps

The town’s own Wastewater Discharge Citizens Advisory Committee (CAC)—including its Clerk, a licensed Professional Environmental Engineer—voted 3-2 against proceeding because the town failed to answer critical technical questions. While certain Select Board members voted to proceed under the assumption that more data will be collected, the town has no clear plan on the what, when, or where of those studies. Furthermore, some votes were cast purely out of a fear of losing a $3M grant—a financial constraint never vetted by the CAC.

• “The Town plans to install new monitoring wells between the WWTP and Warren Wells Brook (near the wind turbine), but has not done so yet. What additional data will be collected, what additional studies will be done, and exactly when will they occur to respond to the critical technical gaps identified by the CAC?
• “The Select Board has indicated that moving forward with the headwater discharge plan is necessary to protect $3 million in grant funding. Why is the town allowing short-term fiscal deadlines to dictate potential long-term, irreversible hydraulic and chemical risks to the Plymouth-Carver Sole Source Aquifer and Warren Wells Brook?
• “Why was this critical financial piece never brought before the Citizens Advisory Committee for evaluation?”

5. Force a Rigorous Evaluation of Alternatives and Siting Realities

A thorough MEPA review legally requires the town to explore alternatives that minimize environmental harm. Several alternative locations evaluated in the EENF and DEIR were ruled out by the town due to their proximity to wetlands. Yet, the current Camelot Park location sits directly at the headwaters of the Eel River watershed.

• “If the Town were going through a modern wastewater treatment plant siting process today, wouldn’t the current Camelot Park location be completely ruled out for the exact same reasons other sites were rejected—specifically, its proximity to critical wetlands?”
• “If the town continues ocean discharge, why aren’t we focusing on advanced effluent treatment to eliminate harbor impacts instead of moving the problem inland?
• If the town moves full discharge to Camelot Park, what is the plan to manage the severe hydraulic impacts—including
  • biological fouling of the infiltration beds (which have never been tested at 3 MGD)
  • managing water levels from Warren Wells Brook down to Russell Mills Pond
  • the potential structural impacts on the wind turbine and new construction on Mary B Lane?”

Our Strategy for the June 4th Meeting

When you speak at Town Hall, state clearly that you want your comments formally recorded in the Public Involvement Report that the town is legally required to submit with its DEIR to the state.

Our concerns are two-part: Chemical and Hydraulic. When town officials give vague answers or promise to “look into it through future monitoring wells,” it indicates to the state’s MEPA Secretary that the current DEIR lacks the critical data needed to evaluate soil fouling, water level fluctuations, and aquifer safety, and requires strict, legally binding conditions before an expanded discharge license can ever be granted.

See you at the Barn this Sunday, May 31st at 3:45 PM!