January 29, 2013

Secretary Richard K. Sullivan, Jr.
EOEEA, Attn: MEPA Office
Richard Bourre
100 Cambridge Street, Suite 900
Boston, MA  02114
Subject: Request for Advisory Opinion

Barnhardt Dam Repair – Colrain, Massachusetts

Dear Secretary Sullivan,

I am submitting comments on the Request for MEPA Advisory Opinion on dam repairs at the Barnhardt Manufacturing Company dam on the North River in Colrain on behalf the Connecticut River Watershed Council (CRC).  CRC is the principal nonprofit environmental advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed.  The proposed project is to rebuild a dam that was breached during Tropical Storm Irene in 2011.  We have the following comments.

Dams have known negative impacts on water quality and the ecology of rivers.  When the Barnhardt Dam was breached in 2011, the Massachusetts Division of Ecological Restoration (DER) felt that the breach offered a potential to look at alternatives to rebuilding, and they found money in their limited budget to fund an alternatives analysis.  It is my understanding that Barnhardt did not pay for this study, and public funding did.  I am attaching a copy of this analysis done by Tighe & Bond if you have not already seen it.

The Tighe & Bond analysis found that a groundwater source was available, and their engineers felt that the dam repair was not a viable option, stating, “It should be noted that repairing the breached section of spillway and leaving the remaining portions of the spillway intact is not considered a viable option at this time as the remaining intact portions of the timber crib spillway likely do not have sufficient factors of safety for stability. This is confirmed by the fact that the dam has breached multiple times since it was constructed. Moreover, it is likely that the remaining portions of the spillway were further compromised during the Irene flooding and the associated breach. Therefore, if the dam will still be used as a long term water supply source, it is our recommendation that the spillway be replaced with a new concrete structure, in its entirety.”

Although a repair or replacement of an existing structure may not automatically trigger a MEPA review, CRC recommends that MEPA in this case make a discretionary decision to require an additional submittal, given the interest of another state agency (DER) in looking at alternatives to rebuilding.  We think it would be appropriate for the MEPA office to request Barnhardt to respond to the options outlined in the Tighe & Bond report, how this decision minimizes impacts to the environment when there is an economically viable alternative, and for their consulting engineers to provide a technical explanation how repairing the dam is, in their opinion, going to hold up over time.  The MEPA office should have a state engineer or consulting engineer comment on the opinion of Tighe & Bond vs. the opinion of Barnhardt’s consulting engineer.

We thank EOEEA for the opportunity to comment on this filing.  I can be reached at adonlon@ctriver.org or 413-772-2020 x. 205.

Sincerely,


Andrea F. Donlon
River Steward
Connecticut River Watershed Council

Cc:
Alex Hackman, Massachusetts Division of Ecological Restoration
Christine Duerring, Massachusetts Department of Environmental Protection
Brian Yellen, Deerfield River Watershed Association
Amy Singler, American Rivers