WRA Comments on UConn's Water Supply Plan

Date: May 24, 2007

To: University of Connecticut Water and Wastewater Policy Advisory Committee

RE: Comments on 4/2007 Draft "University of Connecticut Water and Wastewater Master Plan"

Thank you for the opportunity to comment on the draft "University of Connecticut Water and Wastewater Master Plan." We appreciate Milone and MacBroom's efforts to collect and analyze water supply data for the draft Plan, and we concur with and support most of the information and recommendations in their draft. We are suggesting changes to the brief Executive Summary so that it more accurately reflects the information contained in the 200+page Plan, as well as some new additions to both the Plan and the Summary. These items should be presented more clearly in the Summary document because most of the public, and most officials, will read only the Summary. The current version offers a false sense of security about some issues, as illustrated in newspaper articles about the Plan. (Hartford Courant and Willimantic Chronicle, May 22, 2007).

The Willimantic River Alliance is not opposed to growth in the Storrs area, but our members consider it important to plan for that growth with a solid knowledge of available resources and with provisions to protect these resources from future impairments. Because a reliable and secure source of water is critical to the functioning of the University, as well as other users in the entire Storrs urban area, it is important to identify, as accurately as possible, the actual amount of available water, and to establish reserve water resources as a backup in case of temporary emergencies, such as fire or drought. We support the University's water conservation measures, but we do not consider them sufficient to allow complaisance about identifying a dependable source of water.

We offer the attached pages of recommendations. If you need further information, please contact us at info@willimanticriver.org.

Yours Truly,

Vicky Wetherell and Meg Reich

for the Willimantic River Alliance

Willimantic River Alliance Comments on the April 2007 "Draft of University of Connecticut Water and Wastewater Master Plan"

I. Amend statements in the Executive Summary so it is consistent with the Plan.

Comments Regarding ADEQUATE WATER SUPPLY

1.) Page ES-3 (first paragraph) states, "The University system currently has an available margin of water for average day and peak monthly conditions. This amount is above and beyond what is needed to serve the existing and future projected...demands, while maintaining a margin of safety of 15%."

This statement contradicts information on page 2-31 of the Plan, which states, "Thus, if Fenton River Wellfield withdrawals are to be limited as suggested in the Instream Flow Study, and if Willimantic River Wellfield withdrawals are to be limited as implied by the Level A modeling, the University and the Town of Mansfield would need to identify other sources of water in order to meet on-campus and off-campus demand projections."

2.) Page ES-3 of the Summary notes these possible limitations, but recommends seeking additional water supply sources only "to meet uncommitted future demands." This statement is also contradictory to the above quotation from page 2-31.

3.) The University's current and committed water needs may or may not be adequately supplied by water from the currently available aquifers. (The Level A modeling for the Willimantic River Wellfield notes that the registered diversion amount is not sustainable. See pages 2-29 to 2-30.) Also, the water amounts available in times of low flow in the Fenton and Willimantic Rivers will not be known until the low-flow study of the Willimantic River is completed. These low flow periods coincide with peak use at the beginning of the school year in September. Without reference to actual data on limits during low-flow periods, and without confirmation of the Level A modeling for the aquifer's capacity, it is not possible to make any definitive statement about available water supply for current and committed demands.

4.) We suggest that the first paragraph on page ES-3 be amended to state that, "This amount MAY BE above and beyond what is needed to serve existing and future projected....demands..." This amendment will make it consistent with the qualifying conditions stated on page 2-31.

5.) The second paragraph on page ES-3 should be amended as follows: "If restrictions on water withdrawal at one or both wellfields are implemented as a result of environmental concerns (i.e., Fenton River Wellfield) or aquifer limitations (i.e.) Willimantic River Wellfield), an additional source of water may be needed from August through October in any given year to MEET EXISTING AND PROJECTED WATER DEMANDS BOTH ON-CAMPUS AND OFF-CAMPUS."

II. Amend list of priority recommendations in the Executive Summary (Pages ES-6 & ES-7)

1.) The list should contain an additional recommendation to complete, as soon as possible, the proposed Willimantic River instream low-flow study and confirmation of the Level A modeling results because this is critical information for future planning for growth at the University and in Mansfield. A low-flow study of the Willimantic River similar to the Fenton River study is contained in the University's 2006 Strategy document, but readers of this Executive Summary will not have received that information. It is important for officials and the public to know that this critical information will be aggressively pursued to prevent another crisis during a drought or other emergency. We recommend adding the following item to the list (quoted from page 2-30), "Investigate how a reduction in the Willimantic River wellfield could impact future ability to meet demands by completing the proposed instream low-flow study and confirming the Level A modeling of the aquifer's capacity as soon as possible."

2.) Item 8 refers to upgrading the storage system, but does not address the need for increased storage capacity to alleviate demand on aquifers during low-flow periods. We suggest that this item also state, "CONSIDER AN EXPANSION IN STORAGE CAPACITY AS PART OF THIS SYSTEM UPGRADE TO BETTER ADDRESS DEMAND DURING LOW-FLOW PERIODS."

III. General Questions & Comments regarding Plan and Executive Summary Documents

1.) It is not clear whether the projected summer campus water demand accurately reflects recent University policy; this should be addressed in both the Executive Summary and Plan documents. At the recent spring 2007 Public Hearings held by the Mansfield Planning and Zoning Commission on Downtown Storrs, questions were raised by the public about the economic viability of proposed new businesses in Storrs, when the lack of students, faculty and staff has always posed difficulty for existing businesses during the summer. A University official responded and was quoted in newspapers, saying, in effect, that the University is expanding its summer programs and activities, which will increase the campus population in the summer, and help to ensure the economic viability of businesses in Storrs. It is not clear from the tables and text in the Plan if this increased future campus summer population and the resulting additional water demand is accounted for, or if only past summer campus water use is presented. This matter should be clarified with specific projections, tables and text elaborating summer campus water demands from increased University population in appropriate sections of the Plan and Summary.

2.) The issue of the need for additional water storage capacity is not fully covered. The Plan does discuss water storage in a number of sections. It calls for a study of water needs for fire safety and suppression. It calls for the replacement of old water storage towers. It documents water storage capacity in the existing storage structures. The Plan also acknowledges the possible need for supplemental water sources in any year during the months of August, September and October, because demand could exceed supply in that quarter of the year. From the point of view of the Willimantic River Alliance, it would logically follow that additional water storage should be considered and more thoroughly discussed in the Plan. It would seem that pumping and storing water during times of abundant water, could help to offset the lack of supply during dry times.

It may not be cost effective to construct such additional storage structures. Or the amount of water required to be stored might be impractical. But lacking any discussion in the text about the need, or lack of need, for more storage, it seems as if the subject is simply overlooked. It may be that the issue is intended to be covered in the fire safety study, but that subject is also covered too briefly. It may be that replacing the old water towers with the same size storage structures is required, but there are no details on the matter. Overall, a few more explanatory sentences are needed to adequately cover the matter, and indicate whether only replacement water towers, or significant new water storage structures should be anticipated. Actual amounts and costs, of course, would need further study, which hopefully could be addressed in the fire study that is recommended in the Plan and Summary documents.

3.) The Willimantic River Low Flow Study is not fully discussed in the Plan. The University's Strategy document includes the need for such a study, as well as an outline of what such a study should contain. The Plan should include a summary of this information. The Plan should also explain how it and the University's Strategy document relate to one another. (Committee members will recall that this was a question that came up at the Plan's public presentation on May 2nd). The Executive Summary should include an item (as noted in WRA above comment # II 1.) listing an instream low flow study for the Willimantic River as a priority recommendation.