Board Members: John Abernethy, MD Jane Ceraso
Eric Hilfer
Pam Kelly
Lee Ketelsen
Warren Leon
Steven Lowe
Christine Macdonald
Alex Marciante
Mary Michelman
Evelyn Olschewski
Senator Pam Resor
Leonard Phillips
Chris Schaffner

ACES - Acton Citizens for Environmental Safety
c/o 39 Pope Road
Acton, MA 01720

February 15, 2003

Ms Barbara Kickham
Massachusetts DEP Central Region
627 Main Street
Worcester, MA 01608

Re: Water Management Act Application
Quail Ridge Country Club, Acton, MA

Dear Ms Kickham:

As a Board Member and Corporate Clerk of Acton Citizens for Environmental Safety (ACES), I have been charged with the task of reviewing the Water Management Act Application referenced above. It is my understanding that the Organization for the Assabet River (OAR) has made comments regarding the condition of the pertinent basin; therefore, I will limit the ACES comments to other matters. The ACES comments are as follows:

• While mathematically accurate, the volume requested figure of 60,480/day averaged over the course of an entire year does not appropriately reflect the potential impact to the aquifer of a much larger daily withdrawal during irrigation season.

• The Applicant answers question 20, part B, as 100%. ACES notes that this figure does not take into consideration the amount of water lost to evapotranspiration from the irrigated areas, nor does it take into consideration the water lost to evaporation from the irrigation holding ponds. Please see the attached letter from Acton Survey & Engineering, Inc., dated June 7, 2002, regarding Hydrologic Impacts, DEP 85-778. ACES contends that this loss has the potential to negatively impact the water resources in the area.

• The Applicant, on Form F, leaves blank the answer to the question "What pollutants will be added or removed in the discharge?" The Applicant intends to apply several pesticides, herbicides, and fertilizers as part of the golf course’s IPM plan. ACES contends that these substances should be listed on Form F as pollutants, as they have negative human and environmental health effects. Please see attached letter from ACES to the Acton Board of Selectmen dated January 28, 2002.

• In the DEP Forms section, in the attached General Special Conditions in the Acton Conservation Commission Order of Conditions, Condition 53, the Applicant is directed to "apply for Basic (Bronze) Membership in the Audubon International Signature Cooperative Sanctuary Program and shall maintain membership in perpetuity or until that program ceases to exist". The Applicant has not yet done so, and at a Planning Board meeting in June 2002 the Applicant stated an intention not to do so, citing alleged hardship. The Planning Board had also made Basic Membership a condition of their permit approval. The current proposed design of pesticide, herbicide and fertilizer storage at the Quail Ridge Country Club precludes approval for such membership. Condition 87 states "The initial application of the Integrated Pest Management system shall be limited to a list of chemicals approved by the Commission." The list of chemicals provided with the Water Management Act Application is not the list of chemicals approved by the Commission, but is in fact the original list that raised the Commission’s concerns. Condition 109 notes "the Applicant has not to the date of the issuance of this Order proposed a sufficient, adequate and effective project or program for such off-site mitigation or compensation, nor has the Commission accepted any proposal put forth by the Applicant". This situation remains to this date.

• In Appendix 3.0, section 3.9.3, Nagog Pond, it is noted that "Water levels of Nagog Pond were not monitored during the pump test". ACES believes that the water levels should have been monitored, and that the pump tests should have been scheduled for a date when the pond was not ice-covered so that any effects on water level could have been noted.

• ACES is concerned that the total water withdrawal over several months of irrigation of the golf course could have a cumulative effect on the general watershed that cannot be assessed by a one-week test period.

• ACES is concerned that chemical applications could have the potential to negatively impact both surface and groundwater resources in the area.

• ACES is concerned that, over time, continued irrigation withdrawals and pesticide and herbicide applications could negatively impact the public water supply acquired from Conant Wells.

Sincerely,

Carol Holley
Clerk
Acton Citizens for Environmental Safety

Enclosures