To Members of the Select Board:

I oppose the proposed 40% increase in the water rates proposed for July 2024.

Any increase for future MWRA connection – or future higher MWRA costs beyond the $1 million engineering contract for the design of the proposed connection to the MWRA – is not needed this year. Getting approval for 2.7 million gallons a day of water from the MWRA (as was suggested by former Town Manager Norman Khumalo and DPW Director Kerry Reed) in the near future is unlikely. 

As most of you know, I serve on the state Water Resources Commission (WRC), which sets water policy for the Commonwealth and approves all Interbasin Transfers (IBT), which Hopkinton’s connection to the MWRA would be. The IBT Act protects potential donor basins and makes sure that any interbasin transfer of water is a last resort.  The information required for a complete IBT submittal includes an Environmental Notification Form (ENF), Environmental Impact Report (EIR), Massachusetts Environmental Protection Agency (MEPA) approval, and WRC approval. This will likely take several years (2-4) before construction can begin. For reference, a recent proposal for a simple IBT requesting a small quantity of water, which was fully supported by DEP staff, has taken nearly two years to get to a vote of completion, and the formal WRC staff evaluation will now begin. 

>> REFERENCE: Select Board to consider 40% Water Rate Increase

Hopkinton’s interface with WRC staff to-date is so minimal that Hopkinton is not yet on the monthly list of pending IBT projects. Hopkinton is on the approved WRC staff work plan for FY25 and the WRC expects detailed discussions to begin soon. But until those discussions start, the Hopkinton DPW and the town’s consultant do not really know what information will be expected in the IBT / MEPA submittal. I have provided them a draft copy of WRC’s Interbasin Transfer Act Performance Standards Guidance, now out for comment and expected to be voted on by the WRC this July.

In contrast to the simple scenario described above, Hopkinton’s application will be much more complicated due to existing IBTs and an Unaccounted for water loss (UAW) that greatly exceeds the standard of 10%. Additionally, some of our practices do not meet WRC performance requirements, and the viability of new and existing sources of water in town will be rightly questioned. In simple terms, just because some of our wells have high iron and manganese levels or even have PFAS does not rule them out as viable water sources because they can be treated. Hopkinton’s application will need to make the case that our wells are not viable, and given that 40% of our current peak water needs are supplied by the Ashland Water Treatment Plant, that might be considered a viable source by WRC staff.

>> REFERENCE: Town Water, Part 1: Ashland Pulled Out but Hopkinton Forged Ahead

The failure to improve the 20% unaccounted for water loss will make it harder to justify the need for the extra water to WRC staff. To support the need for extra water beyond the current permitted amount will likely require an updated water needs analysis report by WRC staff. Also, if you greatly improve the water supply to support business expansion on South Street, an increase in the IBT due to wastewater treatment in Milford will be required (more inflow means more outflow). The existing IBTs that Hopkinton has will likely be reviewed for compliance to conditions and even the existing Fruit Street MEPA approval could be reviewed for compliance of conditions.

The IBT application information submittal and approval process will be long and complicated, and until we know what will be approved, and whether it is a mix of local sources with better treatment, or a blending station and the MWRA, we do not know what the costs will be.  The Select Board (acting in their role of Water Commissioners) needs to focus on getting IBT approval, not the detailed design of a potential MWRA connection when we have no idea what amount (if any) might be approved by WRC.

As we stand, future water costs are unknown, but rates are likely to increase as treatment improves, storage tanks are replaced, meters are replaced, new sources are developed (either MWRA or wells), and new operating practices are adopted. These projects need to be planned and budgeted for. Until this is done, the proposed 40% rate increase is premature.

Sincerely,

Ken Weismantel