Board Members:
John Abernethy, MD
Jane Ceraso
Robert Eisengrein
Eric Hilfer
Pamela Kelly
Lee Ketelsen
Warren Leon
Steven Lowe
Alex Marciante
Michael Murphy, Ed.D.
Evelyn Olschewski
Senator Pamela Resor
Leonard Phillips
Chris Schaffner

January 7, 2003

Acton Planning Board
Town Hall
Acton, MA 01720

Re: Quail Ridge Country Club (QRCC)

Dear Planning Board Members,

ACES has previously expressed concerns regarding the potential adverse human and environmental health effects of the proposed Quail Ridge Country Club. The site is located between Nagog Pond, a public water supply for the Town of Concord, and the Conant Wellfield, a public water supply for the Town of Acton. The site is also proximate to relatively dense residential areas in the form of apartments and single-family homes.

The Planning Board’s original Conditions tied in, to a large degree, with this project’s assumed acquisition of a Water Management Act Permit. ACES understands that, with the withdrawal of the Water Management Act Application and the issuance of DEP ACO-CE-03-002, the Planning Board is revisiting the originally-issued conditions. ACES would like, therefore, to reiterate some previously submitted comments and to make a few new comments, as follows:

• The Planning Board should continue to require Audubon International Audubon Signature Cooperative Sanctuary Program Bronze Status for QRCC. ACES has noted that a golf course at Devens, Massachusetts has recently received Bronze status and could serve as a nearby role model. A recent check at the Audubon International web site yielded no record of any QRCC activity toward membership.
• Pending Audubon International application process, the Planning Board should ensure that the criteria for Audubon Membership as noted in the AI document, "How to Fail To Achieve Cooperative Sanctuary Certification [October 1, 2000]" or any more recent iteration of this document, are met.
• The Planning Board should assess the statements in paragraph 6 of the DEO Administrative Consent Order as compared to the original conditions of the Planning Board: "The (Acton Water Supply) District has agreed to sell water to the Company (QRCC) on a temporary and seasonal basis, consistent with the Town of Acton’s water use restrictions. However, the Board of Water Commissioners reserves the right to immediately, and without notice, revoke the right to use this temporary construction meter." The Planning Board should communicate with the District regarding any impacts this agreement may have on current or future developments that will rely on the public water supply, and should assess the impact on QRCC should "the right to use this temporary construction meter" be revoked.
• ACES has reviewed the IPM plan pesticide list as set forth in the latest iteration of the Turf Management Plan, and is very concerned that the substance list is markedly similar to that of the DEIR, and also is very concerned that the specified list is noted to be "some of the chemicals that will be used at Quail Ridge Country Club". ACES urges the Planning Board to require that ALL of the chemicals to be used be included in the IPM plan as submitted to ensure appropriate review of environmental and human health impacts.
• In its review of the IPM plan, ACES has found that many of the best management practices for handling the chemicals on the submitted list seem to be at cross-purposes: for the least environmental impact, certain substances must be applied with irrigation immediately following, and certain other substances are subject to the opposite recommendation -- irrigation should be held off as long as possible without application. ACES is concerned that substances be applied in such a way as to minimize environmental impact, and recommends a continuous oversight and review process be put into place. It may be more appropriate for the Health or Natural Resources Departments to manage this process, but its establishment could be part of the Special Permit Conditions.
• In its review of the IPM plan, ACES noted that information regarding Solubility, Half-Life, and Soil Mobility in the IPM plan was not necessarily consistent with other sources of information. The Planning Board, Board of Health and Natural Resources Department should require authoritative citations of any statements regarding chemical fate and transport in the application document. Other comments on the IPM Plan that do not directly relate to Planning Board Conditions, but should be addressed in the IPM Plan, follow:
  
• In its review of the IPM plan, ACES has found information regarding the volatilization and runoff of pesticides and herbicides, and is concerned about volatilization and runoff as potential exposure pathways. The IPM Plan addresses only leaching into groundwater. The application document should address all three potential ways pesticides and herbicides could leave the QRCC site -- runoff, leaching, and volatilization.
• In its review of the IPM plan, particularly the product labels and Material Safety Data Sheets of certain substances, ACES has noted that very specific precautions need to be undertaken should pesticides and herbicides be applied through an irrigation system. These systems should not be connected to a public water supply.
• In its review of the IPM plan, ACES has found information that high levels of one herbicide, Dithiopyr (Dimension), can be transported in clippings. The IPM Plan should address how clippings are handled to avoid off-site migration of Dithiopyr.
• In its review of the IPM plan, ACES found information stating that certain dried substances cling to the surface of plant leaves for an extended period of time. The IPM Plan should address how shoes and other items (clothing, clubs, golf balls) will be cleaned to ensure the hazardous materials do not leave the QRCC site.

Sincerely,

Carol Holley, Clerk
Acton Citizens for Environmental Safety

cc: Board of Selectmen
Board of Health
Conservation Commission