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Origin of the "Needs Area"

In 2002, the Town hired sewer company Woodard & Curran to do a study identifying wastewater solutions for Acton. Unfortunately, this arrangement was a conflict of interest, as Woodard & Curran is in the business of selling sewers. (Woodard & Curran designed and now operates the South Acton sewer.) The study is called the CWRMP for "Comprehensive Water Resource Management Plan."

In their analysis, Acton parcels were identified as "needs lots" based on factors like size, soil type, groundwater level and proximity to wetlands. Regions with several needs lots were grouped into "needs areas." West Acton is referred to as Needs Area #12.

However, data for attributes such as percolation rate and groundwater level were not readily available across Acton. Therefore the authors of the study turned to a national soil survey conducted by the Natural Resources Conservation Service (NRCS). Based on this soil survey, physical characteristics were assigned to every lot in Acton. However, according to the NRCS, this is not a valid use of the soil survey. The NRCS states, "The soil survey is not intended for, nor should it be applied to, the site specific level. It should not be applied where on-site investigation is warranted such as siting a septic system. To do so can result in misleading information and misinterpretation. Applying NRCS soil units to individual lots is a misuse of the soil survey.” Note that Middlesex County was mapped at a scale of 1:24000, making the resolution, or smallest unit, 4-6 acres.

A second major problem with the CWRMP is that it is based on septic system technology from twenty years ago. Since then, many low-cost, innovate systems, such as the Presby system, have been developed that can be installed within just 2 feet of groundwater. These systems can also be installed on very small lots, of which there are few in West Acton. Note that Presby systems are similar in cost to traditional septic systems.

The third major problem with the CWRMP is that it's authored by Woodard & Curran, the sewer company that designed, built and now runs the South Acton sewer. In the CWRMP, Woodard & Curran identified West Acton as a "sewer needs area" via a proprietary algorithm they would not disclose to the public. Now Woodard & Curran is on the cusp of being awarded a $15 million contract to sewer that very neighborhood.

Today, we can use the advantage of time to see if any of the CWRMP's predictions have borne out. The map below shows the specific West Acton lots which were identified as "needs lots" in red and yellow:

Above, the color red denotes "alternative solution required," which is meant to convey that no replacement septic system can be installed on these lots. What has happened with these lots since this map was created? A survey of Acton Health Department records shows that, of the single- and two-family lots show in red and yellow, four have needed septic upgrades or replacements. Replacements and system upgrades were in fact successfully installed on these lots. These are:

  • 6 West Road (replacement in 2016 after 46 years)

  • 8 West Road (replacement in 2002 after 32 years)

  • 7 Church Street (design flow upgrade in 2003)

  • 11 Church Street (replacement in 2004; age of original system unknown)

All of these lots were fitted with traditional septic systems. And while some did require mounds, advances in septic system technology make the need for mounds less likely in future.

In writing the CWRMP, Woodard & Curran was paid $500,000 by the Town to identify needs areas for its product, sewers. The methodology of the study was wrong and its assumptions about septic system technology are out of date. What do we know today? We know that septic systems in West Acton fail inspection less frequently than average in Acton, and don't have above average maintenance and replacement costs. We also know that there is no indication of septic discharge in the environment of West Acton. Based on these facts, it is clear that West Acton is not a needs area for sewers.


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